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Shell E&P Ltd Bellanaboy Bridge Gas Terminal EIS Supplementary Update Report

TABLE OF CONTENTS

Non Technical Summary

Preamble Introduction 1 Scope and Content of this Supplementary Update Report 2 Contributors and Experts 3 Project Outline, Statutory Consents and associated 3 Environmental Impact Statement Documentation History of consents for the Corrib Project 4 Environmental Impact Statement 5 Sources of Information 10 Consultation 10 Technical Difficulties 10

1 Introduction 1.1 Purpose of this report 1 1.2 Report Structure 2 1.3 Updates 2

2 Description of the Proposed Development 2.1 Site Context 1 2.2 Proposed Development 3 2.3 Plant Design and Facilities Description 3 2.4 Commissioning and Start Up 7 2.5 Site Status in Relation to the EU Control of Major-Accident 7 Hazards Involving Dangerous Substances For inspection Directive purposes only. Consent of copyright owner required for any other use. 2.6 Hazard Protection 9 2.7 Planning Amendment Applications 11

3 Construction 3.1 Introduction 1 3.2 Construction Management 1 3.3 Construction Activities 2 3.4 Construction Activities Remaining 2 3.5 Mitigation Measures 4

4 Alternatives 4.1 Need for the Project and Alternative Concepts 1 4.2 Onshore Pipeline Routing 1 4.3 Terminal Technology Options 1

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5 Human Beings 5.1 Introduction 1 5.2 Study Methodology 1 5.3 Receiving Environment 1 5.4 Characteristics of the Proposed Development 11 5.5 Impact of the Proposed Development 12 5.6 Mitigation Measures 12 5.7 Monitoring 14 5.8 Do Nothing Scenario 15 5.9 Reinstatement and Residual Impacts 15

6 Terrestrial Flora and Fauna 6.1 Introduction 1 6.2 Study Methodology 1 6.3 Receiving Environment 2 6.4 Characteristics of the Proposed Development 17 6.5 Potential Impact of the Proposed Development 18 6.6 Do Nothing Scenario 22 6.7 Mitigation Measures 22 6.8 Predicted Impact of the Proposed Development 25 6.9 Monitoring 25 6.10 Reinstatement and Residual Effects 25 6.11 References 26

7 Aquatic Ecology 7.1 Introduction 1 7.2 Study Methodology 1 7.3 Receiving Environment For inspection purposes only. 2 Consent of copyright owner required for any other use. 7.4 Characteristics of the Proposed Development 10 7.5 Potential Impact of the Proposed Development 11 7.6 Do Nothing Scenario 12 7.7 Mitigation Measures 12 7.8 Predicted Impact of the Proposed Development 13 7.9 Monitoring 13 7.10 Reinstatement and Residual Effects 14 7.11 References 14

8 Soils, Geology and Hydrology 8.1 Introduction 1 8.2 Study Methodology 1 8.3 Receiving Environment 1 8.4 Characteristics of the Proposed Development 3 8.5 Potential Impact of the Proposed Development 3 8.6 Predicted Impact of the Proposed Development 4 8.7 Do Nothing Scenario 4

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8.9 Mitigation Measures 4 8.10 Monitoring 4 8.11 Reinstatement and Residual Effects 4

9 Hydrology and Drainage 9.1 Introduction 1 9.2 Receiving Environment 1 9.3 Characteristics of the Proposed Development 2 9.4 Potential Impact of the Proposed Development 3 9.5 Mitigation Measures 3 9.6 Predicted Impact of the Proposed Development 4 9.7 Monitoring 5 9.8 Reinstatement and Residual Effects 5

10 Effluent 10.1 Introduction 1 10.2 Study Methodology 1 10.3 Receiving Environment 2 10.4 Characteristics of the Proposed Development 7 10.5 Potential Impact of the Proposed Development 9 10.6 Do Nothing 10 10.7 Mitigation Measures 10 10.8 Predicted Impact of the Proposed Development 10 10.9 Monitoring 11 10.10 Reinstatement and Residual Effects 12

11 Air Emissions

11.1 Introduction For inspection purposes only. 1 Consent of copyright owner required for any other use. 11.2 Study Methodology 1 11.3 Characteristics of the Proposed Development 1 11.4 Potential Impact of the Proposed Development 3 11.5 Do Nothing Scenario 4 11.6 Mitigation Measures 4 11.7 Predicted Impact of the Proposed Development 4 11.8 Monitoring 6 11.9 Reinstatement and Residual Effects 7

12 Noise 12.1 Introduction 1 12.2 Study Methodology 1 12.3 Receiving Environment 2 12.4 Characteristics of the Proposed Development 2 12.5 Potential Impact of the Proposed Development 4 12.6 Do Nothing Scenario 4 12.7 Mitigation Measures 4

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12.8 Predicted Impact of the Proposed Development 5 12.9 Monitoring 5 12.10 Reinstatement and Residual Effects 5

13 Landscape and Visual Impact 13.1 Introduction 1 13.2 Study Methodology 1 13.3 Receiving Environment 1 13.4 Characteristics of the Proposed Development 1 13.5 Potential Impact of the Proposed Development 2 13.6 Do Nothing Scenario 4 13.7 Mitigation Measures 4 13.8 Predicted Impact of the Proposed Development 6 13.9 Monitoring 7 13.10 Reinstatement and Residual Effects 7

14 Climate 14.1 Introduction 1 14.2 Study Methodology 1 14.3 Characteristics of the Proposed Development 1 14.4 Potential Impact of the Proposed Development 2 14.5 Do Nothing Scenario 2 14.6 Mitigation Measures 2 14.7 Predicted Impact of the Proposed Development 3 14.8 Monitoring 4 14.9 Reinstatement and Residual Effects 4

15 Cultural Heritage For inspection purposes only. Consent of copyright owner required for any other use. 15.1 Introduction 1 15.2 Study Methodology 1 15.3 Receiving Environment 1 15.4 Characteristics of the Proposed Development 3 15.5 Potential Impact of the Proposed Development 3 15.6 Do Nothing Scenario 3 15.7 Mitigation Measures 3 15.8 Predicted Impact of the Proposed Development 3 15.9 Monitoring 3 15.10 Reinstatement and Residual Effects 3

16 Material Assets 16.1 Introduction 1 16.2 Solid Waste 1 16.3 Traffic Impact Assessment 6 16.4 Consumption of Chemicals 8 16.5 Consumption of Rock Fill 10

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17 Mitigation and Impacts Summary and Impact Interactions

17.1 Introduction 1 17.2 Assessment of Impact Interactions 9 17.3 Non Routine Events 9

18 Cumulative Impacts 18.1 Introduction 1

18.2 Identification of Other Developments in the Vicinity 1

18.3 Study Methodology 5 18.4 Potential for Interactions of the Proposed Developments 5 18.5 Predicted Cumulative Impacts and Interactions 6 18.6 Consequential Development 10 18.7 Do Nothing Scenario 11 18.8 Mitigation Measures 11 18.9 Monitoring 11 18.10 Reinstatement and Residual Impacts 11

19 Sustainable Development 19.1 Introduction 1 19.2 Shell Sustainable Development Policy 1

19.3 Contribution to National Sustainable Development Priorities 1 19.4 Appraisal 1

20 Environmental Management 20.1 Introduction 1 20.2 Shell HSE Policy and Commitments For inspection purposes only. 1 Consent of copyright owner required for any other use. 20.3 Construction of Terminal 2 20.4 Terminal Operation 2

List of Appendices

Appendix 2.1 Fire Fighting Strategy Appendix 2.2 Summary of Amendments to 2004 Planning Permission Appendix 6.1 Plant Species Tables Appendix 6.2 European and Other Designated Conservation Sites in the Wider Locality – Site Synopses Appendix 6.3 Status of Non-avian Faunal Species on Site Appendix 6.4. Bird Species Recorded Appendix 7.1 Baseline Assessment of the Salmonid Habitat in the Owenmore Catchment 2004 Appendix 7.2 Results of a Survey of the Freshwater Salmonid Habitat of Sub-reaches within the Owenmore River System 2005 Appendix 7.3 Results of a Survey of the Freshwater Salmonid Habitat of Sub-reaches within the Owenmore River System 2007 Appendix 7.4 Water Framework Directive (WFD) Fish Stock Survey of , June 2011 Appendix 7.5 Biological monitoring of three freshwater watercourses traversed by the onshore pipeline (March and

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September 2012) Appendix 7.6 Water Framework Directive (WFD) Fish Stock Survey of Rivers in the Western River Basin District, 2012 Appendix 7.7 Summarised monthly water quality monitoring for winter and summer 2010-2013 at locations on the Bellanaboy River and Carrowmore Lake. Undertaken by Mayo County Council and presented at the Project Monitoring Committee meetings Appendix 7.8 Water Framework Directive (WFD) Waterbody Status Report, produced as part of the River Basin Management Plan (RBMP) for the Carrowmore catchment for 2010. Appendix 10.1 Corrib Produced Water Discharge Water Dispersion Assessment, January 2009 Appendix 10.2 SW-3 Manifold and SW-1 Outfall Seawater Quality Survey, January 2014 Appendix 10.3 2010 Biocide Selection Assessment Report Appendix 11.1 Air Dispersion Modelling Study Appendix 12.1 Background Noise Review, November 2013 Appendix 12.2 Operational Noise Emissions Models Appendix 14.1 Carbon Calculation Appendix A Natura Impact Statement (NIS) An Ecological Impact Assessment to Support the Appropriate Assessment Process, January 2014 Appendix B Baseline Report on Geology and Hydrogeology for the Terminal Site

For inspection purposes only. Consent of copyright owner required for any other use.

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PREAMBLE

Introduction On 12 th November 2007 the Environmental Protection Agency (EPA) granted a licence (Licence No. P0738-01) to Shell E&P Ireland Limited (SEPIL) under Section 83(1) of the Environmental Protection Agency Acts 1992 and 2003 to carry on the following activities:

• the operation of a gas refinery; and • the operation of combustion installations with a rated thermal input equal to or greater than 50MW at Bellanaboy Bridge Gas Terminal, Bellanaboy Bridge, Bellagelly South, , subject to conditions. On 6 January 2014, the EPA pursuant to Section 82A (11) of the EPA Acts 1992 to 2013 amended this licence to bring it into conformity with the Industrial Emissions Directive and in its decision stated that from 6 January 2014, Licence Reg No. P0738-01 shall be deemed to be an Industrial Emissions Licence granted under Part IV of the EPA Act 1992 as amended.

This Supplementary Update Report to the 2003 Bellanaboy Bridge Terminal and Srahmore Peat Deposition Site Environmental Impact Statement (the 2003 Terminal EIS) has been prepared by RSK Environment Limited on behalf of SEPIL, and relates to an application to the EPA for a review of above mentioned Industrial Emissions Licence. The licence review application principally relates to a proposed change of discharge point for treated produced water from the previously permitted outfall point just outside , to the subsea manifold located on the seabed in the Corrib Gas Field in some 350m water depth. This change followed discussions with the Inshore Fishermen’s Association, now known as Iascairí Chois Chósta Iorrais Teoranta (ICCI), in 2008, when SEPIL agreed to change the discharge point for treated produced water. Produced water, a natural by-product of gas For inspection purposes only. production, can contain traces ofConsent organic of copyright compounds owner required forand any othersome use. metals. During the operation of the Terminal, the produced water will be treated by the produced water treatment system to limits set out in the Industrial Emissions Licence before being discharged. Under the current Industrial Emissions Licence the discharge point for the treated produced water is an outfall point off Erris Head just outside Broadhaven Bay some 12.5km offshore from the landfall location. The agreement entered into between SEPIL and ICCI involved the change in the location of the discharge point to the subsea manifold located on the seabed in the Corrib Gas Field in some 350m water depth some 65km offshore, subject to statutory approval.

The Industrial Emissions licence review application also proposes to amend the emission limit value for suspended solids in storm water (rainwater) run-off. SEPIL had applied for an ELV of 30mg/l in the original 2004 application and the environmental assessments associated with this and supporting the original IPPC licence application were carried out on that basis.

The new application document to the EPA reconciles minor changes, compared to the original application in 2004. These have occurred during or as a result of the original IPPC licence determination process, including the inclusion of Waste Heat Recovery to provide

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EPA Export 04-03-2014:23:27:49 Bellanaboy Bridge Gas Terminal EIS Shell E&P Ireland Ltd Supplementary Update Report process heat to the Terminal, as well as the installation of Selective Catalytic Reduction on the power generation engine exhausts to meet the emission limit values for Oxides of Nitrogen (NOx) specified in the Licence. It also includes minor modifications to the control and monitoring of emissions.

Scope and Content of this Supplementary Update Report The scope and content of this Supplementary Update Report are aligned with the scope and content of the 2003 Terminal EIS and the information presented has regard to the information requirements specified as follows:

• Council Directive 2011/92/EU on the assessment of the effects of certain public and private projects on the environment;

• Part IV of the EPA Acts 1992 to 2013

• Part X of the Planning and Development Act, 2000 to 2013 and Part X, and Schedules 5, 6, and 7 of the Planning and Development Regulations 2001 to 2013);

• Guidelines on the information to be contained in Environmental Impact Statements, published by the Environmental Protection Agency (EPA) in 2002;

• Advice Notes on Current Practice in preparation of EIS (2003);

• The requirements of Mayo County Council, as set out in the Mayo County Development Plan 2008-2014; and

• Requirements under Article 6(3) of the EU Habitats Directive (Directive 92/43/EEC) as transposed into Irish law by SI 477 of 2011, the European Communities (Birds and Natural Habitats) Regulations 2011.

The development of the Bellanaboy Bridge Terminal facilities and the associated peat nd deposition site were subject of a Planning For inspection Permissi purposeson only. granted by An Bord Pleanála 22 Consent of copyright owner required for any other use. October 2004. An Bord Pleanála’s determination was based on a planning application supported by the 2003 Terminal EIS. The application to the EPA in 2004 for an IPPC licence, leading to the 2007 licence grant, was also supported by the 2003 Terminal EIS. An EIS addendum was issued in September 2006 on the request of the EPA to include items 1 which had been subject to further information requests from the EPA during their determination of the IPPC application.

An Environmental Impact Statement (EIS) is a statement arising from an assessment of the direct and indirect effects of a proposed development. This Report considers proposed changes, as set out above and detailed further in Section 1, to the permitted scheme as well as any relevant changes in the receiving environment since 2003, and it assesses and reassesses where necessary the environmental impacts associated with these changes, taking into account the original assessment as set out in the original 2003 EIS documents as well as the those issued in 2006, and should be read in conjunction with same.

1 Details on pigging operation, energy efficiency, on fuel and water usage, further detail on cold venting and air quality modelling, and further assessment of the impact of the aqueous discharge at the Erris Head outfall.

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A detailed list of the changes is set out in Section 1, Introduction, of the Report.

Contributors and Experts The preparation of this Supplementary Update Report has been co-ordinated by RSK Environment Limited. RSK have facilitated the briefing and scoping of input from SEPIL and from independent specialist consultants within planning, ecology, hydrology, noise and archaeology. They have also authored a number of the Supplementary Update Report sections. The original 2003 Terminal EIS contributors including the independent consultants, but with the exception of traffic and air quality, have provided the material and assessment which are contained in the 2014 Supplementary Update Report. Many of these have been and continue to be engaged in supporting SEPIL in managing and supervising the implementation of environmental mitigation and the ongoing monitoring of environmental aspects of the development.

Project Outline, Statutory Consents and associated Environmental Impact Statement Documentation

The Corrib Gas Field development is divided into four main elements as follows:-

i. Offshore sea bed installation (sub-sea wellheads and manifold at the gas field, which lies off the north-west coast of County Mayo); ii. Offshore gas pipeline (between the wellheads and manifold and the landfall at ); iii. Onshore gas pipeline (between the landfall and the gas terminal); and iv. Bellanaboy Bridge gas terminal.

Of these, the constructions of the offshore elements and the Terminal have been substantially completed. The installation of the offshore pipeline between the landfall and the offshore gas field was completed in October 2009, and the installation of the offshore

umbilical alongside the offshore pipeline For inspection was compl purposes etedonly. during the summer of 2013. Consent of copyright owner required for any other use. Significant works have been completed in relation to the subsea wells and infrastructure. Work on the construction of the Terminal at Bellanaboy Bridge, County Mayo has been largely completed with the finalisation of some minor changes outstanding, with landscaping and reinstatement of temporary construction areas to be completed once the onshore pipeline is in place.

In addition, Bord Gáis Éireann extended its transmission network from Galway up to the Terminal in 2006 to facilitate the distribution of Corrib gas into the national grid (and indeed actually connected into the Terminal in 2009).

The Terminal’s main gas infrastructure, including gas turbines, compressors and power generation engines, will be ready for commissioning, by importing natural gas through the terminal’s connection with the national grid, during the second quarter of 2014. This gas commissioning activity will trigger the commencement of operations under the Industrial Emissions Licence.

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History of consents for the Corrib Project The development of the Corrib Gas Field is being carried out under a Petroleum Lease held by SEPIL, Statoil Exploration (Ireland) Ltd and Vermilion Energy Ireland Limited (the Corrib Gas Partners).

There has been a long history of the procurement of consents, approvals, permissions and licences from the various statutory authorities in connection with the construction and operational elements of the Corrib Field Development Project.

To date, SEPIL (on behalf of the Corrib Gas Partners) has procured the following consents:

(i) Consent under Section 40 of the Gas Act 1976 (as amended) for the pipeline from wellheads to terminal was granted by the Minister for the Marine and Natural Resources on 15 April 2002.

(ii) A Foreshore Licence for the pipeline was granted by the Minister for the Marine and Natural Resources on 17 May 2002 pursuant to Section 3 of the Foreshore Act 1933 (as amended).

(iii) Consent pursuant to Section 5 of the Continental Shelf Act 1968 (as amended) for development of the Corrib Field was granted by the Minister for the Marine and Natural Resources on 15 April 2002.

(iv) A Petroleum Lease was granted pursuant to Section 13 of the Petroleum and Other Minerals Development Act 1960 (as amended) by the Minister for the Marine and Natural Resources and the Minister for Finance on 15 November 2001.

(v) Approval of the Minister for the Marine and Natural Resources on 15 April 2002 to a Plan of Development pursuant to the Petroleum Lease granted under Section 13 of the Petroleum and Other Minerals Act 1960 and in accordance with Section 13A of the Petroleum and Other Minerals Act 1960 (as amended). For inspection purposes only. Consent of copyright owner required for any other use. (vi) Planning permission for the Terminal and the associated Srahmore Peat Deposition Site was granted by An Bord Pleanála on 22 October 2004 (the life of which was extended by Mayo County Council on 20 October 2009 and 17 April 2012).

(vii) An IPPC Licence for the Terminal was granted by the EPA on 12 November 2007.

(viii) Approval from An Bord Pleanála dated 19 January 2011 for the development of the Corrib Onshore Upstream Pipeline comprising strategic upstream gas pipeline infrastructure (the proposed Onshore Pipeline is approximately 8.3 kilometres in length from the high watermark where the pipeline first makes landfall to the gas terminal), comprising part of a longer strategic upstream pipeline system for the carrying of natural gas, associated by- products from the existing Corrib Gas Field to the Terminal at Bellanaboy Bridge, County Mayo pursuant to Section 182D of the Planning and Development Acts 2000, (as amended).

(ix) Consent by the Minister for Communications, Energy and Natural Resources dated 25 February 2011 for the construction of a natural gas pipeline from the Corrib sub-sea facilities to the Terminal at Bellanaboy Bridge, County Mayo pursuant to Section 40 of the Gas Act 1976 (as amended).

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(x) Approval by the Minister for Communications, Energy and Natural Resources, dated 25 February 2011 of an addendum to the Plan of Development in accordance with the provisions of a Petroleum Lease granted pursuant to the provisions of Section 13 of the Petroleum and Other Minerals Development Act, 1960 (as amended) (arising from modifications to the onshore pipeline element as well as the change of discharge location for treated produced water from the outfall off Erris Head to the Corrib offshore subsea manifold location).

(xi) A Foreshore Licence in respect of development on the foreshore related to the Corrib Project executed and dated 22 July 2011 was issued by the Minister for the Environment, Community and Local Government.

In addition, a Waste Licence for the Srahmore Peat Disposition Site (where peat was deposited during the construction of the gas terminal) was granted by the EPA to Bord na Mona Energy Limited on 29 October 2004 with a revised Waste Licence granted on 27 July 2010 to facilitate the deposit of peat arising from the construction of the Onshore Pipeline.

Environmental Impact Statements A planning application for the (then) proposed Terminal was lodged in December 2003 (after an unsuccessful application in 2001). This application was supported by the 2003 Terminal EIS, and in October 2004 An Bord Pleanála granted planning permission for the Terminal. Planning and construction of the Gas Terminal commenced in 2005.

An application to the EPA for an IPPC licence for the terminal was lodged in December 2004, and this application was accompanied by the 2003 Terminal EIS. As set out above, in response to a request from the EPA during their determination process, an Addendum to the 2003 Terminal EIS was prepared in September 2006 and submitted to the EPA.

An EIS (the Corrib Onshore Pipeline EIS, RPS 2010) in respect of the gas pipeline, associated umbilical and water outfall pipe, was prepared and submitted in 2010 to An Bord Pleanála reflecting changes in the permitted For inspection (2002) purposes only.design and routing of the pipeline. Consent of copyright owner required for any other use.

At the same time SEPIL also applied to the Minister for Communications, Energy and Natural Resources for a Section 40 Consent under Section 40 of the Gas Act 1976 (as amended) and for a Plan of Development Addendum Approval for the Corrib Gas Field Development arising from the proposed modifications to the onshore pipeline. The relocation of the treated produced water discharge point which is the primary reason for the Industrial Emissions Licence review application formed part of the Plan of Development Addendum application and the Section 40 application. These applications were accompanied by an EIS which included the Corrib Onshore Pipeline EIS, RPS, 2010, as well as an updated Offshore EIS, comprising –

(a) Corrib Field Development Offshore (Field to Terminal) EIS and Appendices, 2001 (reprinted 2008); and

(b) Offshore Supplementary Update Report and appendices (Rev. 03), 2010.

The details of the development of the offshore section of the pipeline had not been materially altered since the publication of the 2001 Offshore EIS, however the 2010 Supplementary Update Report for the 2001 Offshore EIS was prepared to reflect the (then) current status of

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EPA Export 04-03-2014:23:27:49 Bellanaboy Bridge Gas Terminal EIS Shell E&P Ireland Ltd Supplementary Update Report the offshore development, as well as up-to-date baseline survey data that have been acquired and the findings of monitoring carried out since 2001. The 2010 Offshore EIS Supplementary Update Report together with the original 2001 Offshore EIS (reprinted 2008) considered and assessed the offshore elements of the development.

The considerations, assessments and reassessments which are arising out of the changes sought in the 2014 Industrial Emissions licence review application and presented in this Supplementary Update Report, are primarily based on the baseline information presented in the 2003 Terminal EIS as verified and updated, as well as the offshore seabed and seawater quality baseline data relevant to the two offshore discharge points contained in the updated Offshore EIS.

The major statutory approvals / licences / consents that are associated with the Corrib Gas Field Development are summarised in Table 1 below along with the EIS documents associated with each consent for ease of reference.

For inspection purposes only. Consent of copyright owner required for any other use.

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Table 1: Consents, Approvals and associated EIS documentation for the Corrib Gas Field Development.

Licence/Consent Status Environmental Im pact Statement

Petroleum Lease, the Minister for the Marine and Granted 2001 Natural Resources.

Plan of Development for the Corrib Field, the Approved 2002 Corrib Field Development Offshore (Field to Terminal) EIS 2001 Minister for the Marine and Natural Resources. Bellanaboy Bridge Gas Terminal EIS 2001

Consent under Continental Shelf Act 1968, the Granted 2002 Minister for the Marine and Natural Resources.

Foreshore Licence for pipeline, umbilical and Granted 2002 Corrib Field Development Offshore (Field to Terminal) EIS 2001 outfall, the Minister for the Marine and Natural Resources.

Consent to Construct a Pipeline (Section 40 of the Granted 2002 Corrib Field Development Offshore (Field to Terminal) EIS 2001 Gas Act), the Minister for the Marine and Natural Resources.

Planning Permission 2 – Bellanaboy Bridge Gas Granted 2004 Bellanaboy Bridge Gas Terminal and Srahmore Peat Deposition Site EIS, 2003 Terminal and associated peat deposition site, An For inspection purposes only. Bord Pleanála. Consent of copyright owner required for any other use.

Waste Licence for peat deposition at An Srath Granted 2004 Bellanaboy Bridge Gas Terminal and Srahmore Peat Deposition Site EIS, 2003 Mór (Srahmore) (Bord na Móna), EPA.

Integrated Pollution Prevention and Control Granted 2007 Bellanaboy Bridge Gas Terminal and Srahmore Peat Deposition Site EIS, 2003, Licence for Bellanaboy Bridge Gas Terminal,

2 A number of minor amendments to the terminal design have been permitted by the Planning Authority through amendment applications. None of these amendment applications, details of which are set out Section 2 of the Supplementary Update Report, have required the submission of Environmental Impact Statements.

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Licence/Consent Status Environmental Im pact Statement

EPA 3 Bellanaboy Bridge Terminal EIS Addendum, September 2006

Green House Gas Emission Permit, Bellanaboy Granted 2009 Bridge Gas Terminal, EPA

Revised Waste Licence for peat deposition at An Granted 2010 Corrib Onshore Pipeline EIS 2009 Srath Mór (Srahmore) (Bord na Móna), EPA.

Planning Approval, Corrib Onshore Pipeline Granted 2011 Corrib Onshore Pipeline EIS, 2010 development, An Bord Pleanála 4.

Plan of Development Addendum (new onshore Approved 2011 Corrib Onshore Pipeline EIS, 2010 pipeline route and change to discharge point for treated produced water), the Minister for Corrib Field Development Offshore (Field to Terminal) EIS 2001, reprinted 2008 Communications, Energy and Natural Resources. Corrib Offshore EIS Supplementary Update Report, 2010

New Foreshore Licence for revised pipeline, Granted 2011 Corrib Onshore Pipeline EIS, 2010 umbilical and outfall from the Minister for Environment, Heritage and Local Government. Corrib Field Development Offshore (Field to Terminal) EIS 2001, reprinted 2008

Corrib Offshore EIS Supplementary Update Report, 2010 For inspection purposes only. New Consent to Construct a Pipeline (Section 40 Granted 2011 Consent of copyrightCorrib owner Onshore required Pipelinefor any other EIS, use. 2010 of the Gas Act), the Minister for Communications, Corrib Field Development Offshore (Field to Terminal) EIS 2001, reprinted 2008

3 On 6 January 2014, the EPA pursuant to Section 82A (11) of the EPA Acts 1992 to 2013 amended this licence to bring it into conformity with the Industrial Emissions Directive and in its decision stated that from 6 January 2014, Licence Reg No. P0738-01 shall be deemed to be an Industrial Emissions Licence granted under Part IV of the EPA Act 1992 as amended.

4 Minor amendments to the pipeline design have been permitted by An Bord Pleanála through three amendment applications lodged in 2011 and 2012. None of these amendment applications have required the submission of Environmental Impact Statements.

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Licence/Consent Status Environmental Im pact Statement

Energy and Natural Resources. Corrib Offshore EIS Supplementary Update Report, 2010

Industrial Emissions Licence, EPA This application – Bellanaboy Bridge Gas Terminal and Srahmore Peat Deposition Site EIS, 2003, Determination pending Bellanaboy Bridge Gas Terminal and Srahmore Peat Deposition Site EIS Addendum, 2006

Bellanaboy Bridge Gas Terminal EIS Supplementary Update Report, 2014.

Corrib Field Development Offshore (Field to Terminal) EIS 2001, reprinted 2008

Corrib Offshore EIS Supplementary Update Report, 2010

For inspection purposes only. Consent of copyright owner required for any other use.

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Sources of Information The assessment of the proposed development has been based on detailed data provided by SEPIL and their contractors.

Consultation Pre-application consultation has been carried out. The main organisations contacted were:

• Department of Communications, Energy and Natural Resources; • Mayo County Council; • National Parks and Wildlife Service of the Department of Art, Heritage and the Gaeltacht; • Inland Fisheries Ireland; and • The Environmental Protection Agency (EPA).

SEPIL has also advertised in local newspapers, and written to local residents advising them of the upcoming Industrial Emissions Licence Review application process, and of the updating of the EIS. In this way, people and organisations have been invited to make submissions in advance of the EIS being completed.

Any concerns raised have been addressed in the Supplementary Update Report.

Technical Difficulties In the preparation of this EIS there were no technical difficulties or lack of know-how encountered which would result in the EIS being incomplete or lacking in the assessment of impacts due to inadequate type or volume of data.

For inspection purposes only. Consent of copyright owner required for any other use.

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1 INTRODUCTION

1.1 Purpose of this Report

In 2003, an Environmental Impact Statement (EIS) was prepared for the (as it then was) proposed Bellanaboy Bridge Gas Terminal and associated Srahmore Peat Deposition Site. This EIS (“the Terminal EIS”) accompanied a Planning Application to Mayo County Council which resulted in a grant of Planning Permission for the development (An Bord Pleanála) in 2004. The 2003 Terminal EIS was also used to support an application by Shell E & P Ireland Limited (SEPIL) for an Integrated Pollution Prevention and Control (IPPC) Licence to the Environmental Protection Agency (EPA) in December 2004. The application resulted in a grant in 2007 of an IPPC licence (EPA reference number 0738-01) ‘to carry on the following activities: • The operation of a gas refinery; and • The operation of combustion installations with a rated thermal input equal to or greater than 50 MW at Bellanaboy Bridge Gas Terminal, Bellanaboy Bridge, Bellagelly South, County Mayo, subject to conditions’ During the IPPC determination process, and in response to a request from the EPA under Article 14 of the EPA Act to incorporate additional information provided by SEPIL, an addendum was submitted to the EPA and thus forms part of the 2003 Terminal EIS. In accordance with the requirements of the Industrial Emissions Directive as implemented in Ireland, the EPA recently examined the terms of the 2007 IPPC licence and determined on the 6 th January 2014 that, subject to an amendment, Licence Reg no P0738-01 shall be deemed to be an Industrial Emissions Licence. This Supplementary Update Report for the Bellanaboy Bridge Gas Terminal Environmental Impact Statement has been prepared to support an application for a review of the Industrial Emissions Licence. It should be read in conjunction with the 2003 Terminal EIS and associated 2006 Addendum. In addition information on the For inspection purposes only. offshore components ofConsent the ofdevelopment copyright owner required including for any other th euse. offshore pipeline, umbilical and outfall pipeline are described in the 2001 Offshore Field to Terminal EIS, updated by the 2010 Offshore Supplementary Update Report and this Supplementary Update Report should also be read in conjunction with those documents. This Supplementary Update Report considers specific changes currently being sought as part of an application for a review of the Industrial Emissions Licence (0738-01), as well as the potential and predicted environmental impacts associated with these changes It provides updated information where relevant, taking into account new baseline (receiving environment) information that has become available since 2003, as well as environmental monitoring data that has been acquired or otherwise been collected to date. It also summarises the modifications to design that have been approved and/or implemented in accordance with amendment planning permissions. The assessment of environmental impacts of the proposed changes is presented taking into account development works that are still outstanding, i.e. facilities commissioning and the final landscaping works to be implemented during and following removal of the existing temporary construction phase facilities, as well as the changes to the overall project development schedule. It is noted that the Terminal facilities have been constructed and are largely unchanged from those considered in the 2003 Terminal EIS.

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1.2 Report Structure

This Supplementary Update Report generally follows the same section structure as that presented in the 2003 Terminal EIS.

1.2.1 Other EIS Documents

The section of pipeline between the landfall (including a new landfall valve installation (LVI)) and the Terminal are described in the Onshore Pipeline EIS, RPS 2010. Further details of the regulatory context of the various elements of the Corrib gas field development project, as well as the environmental impact statement documents associated with these, are provided in the Preamble to this supplementary Update Report,

1.3 Updates

The Supplementary Update Report and its Appendices have been compiled by the following retained technical specialists: Specialist Consultants Supplementary Update Report Contribution RSK Environment Ltd EIA Project Management and Collation Aquatic Ecology Soils, Geology and Hydrogeology Hydrology and Drainage Effluent Air Quality Landscape and Visual Climate Cumulative Clarke Saunders Associates Noise For inspection purposes only. Tom Phillips and AssociatesConsent of copyright owner required for anyHuman other use. Beings

Courtney Deery Heritage Consultancy Cultural Heritage Ecological Advisory and Consultancy Services Terrestrial Flora and Fauna Natura Impact Statement

1.3.1 Remaining Project Elements

The main activities currently being undertaken at the Terminal site are: • process improvements; • maintenance and/or substitution of items of plant and equipment (authorised where required by grants of planning permission); and • non-hydrocarbon pre-commissioning of plant and equipment. The main outstanding construction / start-up activities are: • commissioning, including hydrocarbon commissioning of the plant and process; • removal of temporary construction facilities (construction related equipment, portacabins, car parks, hard standings etc.); and

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• landscaping of the site including tree planting, compensation habitat development and environmental conservation of the surrounding areas. These activities are discussed further in Sections 2 and 3 of this report. The scope of this report is associated with the updates listed in Table 1.1 below. Table 1.1: Summary of Updates Updated Information Presented Section Project Description 2 • Description of the main activities currently being undertaken and construction activities remaining. • Changes associated with the operation of the plant: • The discharge of treated produced water via the control umbilical to the subsea manifold at the Corrib Field and associated enabling infrastructure and operations. • The discharge of treated surface water from process areas only through the water outfall pipe. • Use of waste heat recovery on turbine exhausts and the associated elimination of the need for the direct fired Heating Medium Heaters. • Use of Selective Catalytic Reduction technology to reduce NOx emissions from power generation engines. • Use of additional mitigation to reduce tank breathing losses. • Rationalisation of the drainage design and associated used firewater retention capacity to accommodate all firewater and the simultaneous failure of the 3 largest methanol tanks. • Rationalisation of storm water management and the automatic diversion of storm water in the event of a fire or chemical spillage. • Disposal offsite by tankers of excess treated produced water that cannot be discharged through the umbilical cores due to their hydraulic capacity. • An overview of all minor amendments to Terminal plant and equipment (planning amendments) • A description of transitional arrangements required for commissioning certain items of plant with natural gas from the grid (Back Feed Gas - BFG) prior to gas from the Corrib field For becoming inspection purposes available only. through the incoming pipeline. Consent of copyright owner required for any other use. • Update to the SEVESO status of the site and to the regulatory regime for safety in upstream petroleum exploration and exploitation activities. Construction Activities 3 • Overall development schedule update. • A review of the main activities currently being undertaken at the Terminal i.e. process improvements, maintenance and/or substitution of items of plant and equipment; and pre-commissioning of plant and equipment, (authorised where required by grants of planning permission); • A review of the main construction related activities remaining including removal of temporary construction facilities landscaping. • Additional mitigation measures where required.

Alternatives 4 • Consideration of new ‘alternatives’: • Location of discharge point for treated produced water offshore. • Selection of Selective Catalytic Reduction to reduce NOx emissions. • Selection of abatement technology i.e. internal floating roofs (IFRs) and additional measures to minimise VOC emissions from tanks.

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Updated Information Presented Section Human Beings 5 • Status updates on the receiving environment. • Description of the social investment programme and community liaison activities. • Reassessment of impacts on human beings. Terrestrial Flora & Fauna 6 • Updated and additional survey data from ongoing monitoring programmes. • Reassessment of impacts on flora and fauna. • Reassessment of requirements for ongoing mitigation and monitoring. Aquatic Ecology 7 • Updated description of baseline conditions based on additional survey data. • Reassessment in the context of proposed change to suspended solids emission limit value for storm water discharge. • Reassessment of impacts on aquatic ecology. • Reassessment of requirements for ongoing mitigation and monitoring. Soils, Geology & Hydrogeology 8 • Updated description of baseline conditions, based on additional site investigation data acquired during construction. • Reassessment of impacts on soils, geology and hydrogeology. Hydrology and Drainage 9 • Updated description of baseline conditions, based on monitoring data acquired. • Update to description of the drainage design, including updates to mitigation measures. • Reassessment of impacts on hydrology and drainage. • Reassessment of requirements for ongoing mitigation and monitoring. For inspection purposes only. Effluent Consent of copyright owner required for any other use. 10

• Updated description of baseline conditions based on survey data and cross reference to Offshore Supplementary Update Report 2010 where appropriate. • Reassessment of potential impacts on water quality associated with new treated produced water discharge location at the offshore manifold location. • Assessment of the implications of the Water Framework Directive. • Reassessment of requirements for ongoing mitigation and monitoring if required. Air Quality 11 • Updated description of baseline conditions. • Reassessment of impacts of air emissions associated with: • Use of waste heat recovery on gas turbine exhausts and the consequential removal of the direct fired Heating Medium Heater. • Use of Selective Catalytic Reduction technology to reduce NOx emissions from power regeneration engines. • Change in quantity of cold vented gas associated with the purging of the compressors during restarts and changeovers. • Decrease in fugitive emissions including those associated with tank breathing losses.

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Updated Information Presented Section • Updated dispersion modelling to predict how air emissions from the Terminal disperse in the atmosphere and to determine the potential levels of pollutant exposure at sensitive locations including nearby dwellings. • Reassessment of impacts associated with additional emission abatement and up-to-date meteorological data. • Reassessment of impacts of emissions to the atmosphere. • Reassessment of requirements for ongoing mitigation and monitoring. Noise 12 • Updated description of baseline conditions. • Noise impacts associated with: • Modified plant including changes in duty to existing plant and processes (e.g. ventilation rate increases in the sales gas compressor building). • Updated noise data for existing plant, using vendor information and/or updated noise emissions estimates. • Specific flaring and cold venting scenarios. • Reassessment of noise impacts. • Reassessment of requirements for ongoing mitigation and monitoring. Landscape & Visual Impact 13 • Review of landscape and visual impacts. • Review of requirements for ongoing mitigation and monitoring. Climate 14 • Review and update on overall GHG emissions for the development. Cultural Heritage 15 • Update of assessment based on the results of archaeological monitoring undertaken to date (nothing of an archaeological significance was revealed). Material Assets 16 For inspection purposes only. • Reassessment ofConsent traffic of copyrightimpacts owner during required operations for any other phase use. as a result of the transport of produced water containing MEG at well start up, the transport of excess treated produced water, transport of condensate offsite and delivery of biocide, including simultaneous landscaping works (incorporating transport of excess hardcore off-site). • Updated information on chemicals to be stored. • Updated waste inventory. • Reassessment of requirements for ongoing mitigation and monitoring if required. Mitigation and Impact Summary and Impact Interactions 17 • Update to summary of the proposed mitigation measures and residual impacts, and consideration of impact interactions. Cumulative Impacts 18 • Updated assessment of the cumulative impacts that may arise during the construction (remaining activities) and operation of the Terminal. Sustainable Development 19 • Updated appraisal against SEPIL’s current sustainable development principles.

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Updated Information Presented Section Environmental Management 20 • Summarises the monitoring requirements envisaged for the Terminal under licensed operations. Appendices • Natura Impact Statement (NIS) (Appendix A) • Baseline Report on Geology and Hydrogeology for the Terminal Site (Appendix B)

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2 DESCRIPTION OF THE PROPOSED DEVELOPMENT

2.1 Site Context

The Bellanaboy Bridge Gas Terminal forms an integral part of the Corrib natural gas field development. The development’s offshore elements are a series of gas wells and seabed infrastructure in the Corrib field, a manifold that gathers the flow of gas from each of the wells, and a gas pipeline leading from the manifold to shore at Glengad. The pipeline continues from where it first comes onshore at Glengad to the Gas Terminal located at Bellanaboy Bridge. There will also be a multipurpose umbilical that runs from the Terminal to the Corrib field. An updated schematic of the Corrib Development is shown in Figure 2.1. Details of the section of pipeline and umbilical between the landfall and the Terminal itself is discussed in the 2010 Onshore Pipeline EIS (RPS, 2010), and information on the offshore components of the development including the offshore pipeline, umbilical and water outfall pipe are described in the Offshore Field to Terminal Environmental Impact Statement (RSK, 2001), updated by the Offshore Supplementary Update Report (RSK, 2010). The Terminal and a 26 inch natural gas pipeline connecting the Terminal to the national grid have been constructed, and the Terminal site is currently the subject of temporary construction and installation works associated with the incoming gas pipeline. In addition, there is ongoing maintenance and refurbishment work on the process plant within the Terminal footprint, and landscaping works are progressing on a phased basis. The offshore pipeline and umbilical between the Corrib field and the landfall have been installed, and the onshore pipeline including the umbilical between the landfall at Glengad and the Terminal at Bellanaboy are currently being constructed. Once the construction and associated testing of the onshore pipeline and umbilical are completed, production of gas from the Corrib Field will commence. For a period prior to this, it is intended to commission sections of the Terminal facilities with natural gas from the national grid. For inspection purposes only. Consent of copyright owner required for any other use.

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Figure 2.1: Schematic of the Corrib development

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2.2 Proposed Development

2.2.1 Construction Activities

The main activities associated with construction of the Terminal, namely enabling works, peat excavation works and Terminal civil and mechanical construction works, have been completed. Due to the changes to the routing and associated phasing of the construction of the onshore pipeline, installation works are still ongoing. In addition, temporary construction facilities at the Terminal site are being utilised to provide support for the pipeline construction works.

2.2.2 Remaining Project Elements

The main activities currently being undertaken at the Terminal can be divided into the following categories: • process improvements; • maintenance and/or substitution of items of plant and equipment; and • non-hydrocarbon pre-commissioning of plant and equipment. The main outstanding construction/start-up activities remaining are: • commissioning, including hydrocarbon commissioning of the plant and process; • removal of temporary construction facilities (construction related equipment, portacabins, car parks, hard standings etc.); and • landscaping of the site including tree planting, habitat enhancement and creation, and environmental protection of the surrounding areas.

2.3 Plant Design and Facilities Description

There have been minor changes to operational aspects of the Terminal design. These are described below. For inspection purposes only. Consent of copyright owner required for any other use. 2.3.1 Hydrocarbon Condensate Export and Waste Heat Recovery

As set out in the 2006 EIS Addendum, Waste Heat Recovery (WHR) on the gas turbine exhaust stacks has replaced the direct fired heating medium heaters which were previously proposed for generating process heat in the Terminal. The WHR units are estimated to provide approximately 5.5 MW of heat energy to the Terminal’s processes. This is sufficient to satisfy the heat demand under normal operating conditions. The heating medium fired heaters, which were to be partly fuelled by hydrocarbon condensate from the Corrib field, have been removed. All hydrocarbon condensate will be stabilised by a series of pressure reductions and heating processes. It will then be cooled and transferred to atmospheric fixed roof storage tanks which contain internal floating covers to minimise emissions. Stabilised condensate will be transported offsite by road tanker to a suitably licensed third party, probably for use as fuel. Small quantities of gas released from the condensate during stabilisation will be recovered and added to the low pressure (LP) fuel gas system supplying the gas engines used for electrical power generation. A block diagram is provided in Figure 2.2.

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Figure 2.2 Condensate Recovery and Stabilisation

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2.3.2 NO X Abatement for Power Generation Engines Using Selective Catalytic Reduction Technology

Selective Catalytic Reduction (SCR) systems have been installed on each of the three main electrical power generation engines in order to reduce the concentration of oxides of nitrogen in the exhaust emissions from these engines. These units which are located in a new annex to the main power generation building use ammonia/urea in the presence of a catalyst to selectively convert the oxides of nitrogen present in the exhaust gases to nitrogen and water.

2.3.3 Site Drainage

The firewater containment requirements for the site have been re-evaluated and the drainage system has been rationalised so that in the event of the worst case scenario considered (simultaneous failure of the 3 largest methanol storage tanks) the drainage systems on site will assist in providing sufficient containment capacity on-site. The approach to storm water management has also been revised so that in the event of a fire or chemical spillage into the uncontaminated surface water drainage system being detected, the isolation valve on the outlet of the Emergency Holding Tank (EHT) can be

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automatically closed to prevent discharge into the settlement ponds which discharge offsite towards Carrowmore Lake. In this event the storm water retained within the storm water ditches within the Terminal footprint and the perimeter surface water drainage system and can then be sampled and routed into the treated surface water system for treatment prior to discharge via the water outfall pipe. Figure 2.3 Surface Water Treatment System

For inspection purposes only. Consent of copyright owner required for any other use.

Discharge of Treated Produced Water The proposed discharge of treated produced water at a permitted outfall point approx 12.7 km from the landfall was subject to discussion with local fishermen. As a result of this, SEPIL is proposing to discharge this water at the Corrib offshore manifold, which is located at 350 m water depth in excess of 80 km from the landfall. There are no changes to the treatment system for produced water arriving at the Terminal with the gas from the field. However, the discharge of the treated produced

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water will no longer be connected to the discharge system for treated surface water system; the two systems are segregated. A block diagram for the surface water treatment system is provided in Figure 2.3. The treated produced water from the produced water treatment plant (ESMIL) will initially be routed into a collection sump from where it can be recirculated for further treatment if necessary to meet the required parameters or routed into the discharge sump, from where it will be pumped offshore via cores in the umbilical. Should there be water in excess of the capacity of the available core(s), the treated produced water will be tankered offsite to a licensed waste water disposal facility. A biocide will be injected into the treated produced water stream to prevent fouling within the umbilical cores. The Produced Water Treatment System will produce a number of waste streams (see Figure 2.4). Figure 2.4 Flow Diagram- Produced Water Treatment System

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2.4 Commissioning and Start Up

2.4.1 Introduction

The hydrocarbon commissioning of the Terminal facilities will take place in two phases, Back Feed Gas (BFG) and Forward Feed Gas (FFG). Once non-hydrocarbon pre-commissioning of the Terminal facilities has been completed, gas from the Bord Gáis Network transmission system will be introduced to enable operational qualification of items of plant and equipment. This phase of commissioning is termed Back Feed Gas (BFG). As the gas for this phase will be sourced from the transmission system, there will be no liquids (i.e. produced water, hydrocarbon condensate, methanol or other production chemicals) arising in the gas process during this period. Once the onshore pipeline, umbilical and water outfall pipe construction and associated pre-commissioning works have been completed, gas will start flowing into the Terminal from the Corrib field. This phase is known as Forward Feed Gas (FFG) and represents the final phase of commissioning and start of full production. At this stage all of the Terminal infrastructure will be operational. Further details are provided in Section 3.

2.4.2 Transitional Arrangements - Discharge of Treated Drainage Water from Areas at Risk of Contamination

The onshore section of the pipeline and associated water outfall pipe and umbilical will not be available at the time BFG commissioning is scheduled to commence. Therefore, during this phase and until the water outfall pipe is fully connected, it is proposed that the treated surface water from the process areas and tanker access roads is routed to the settlement ponds and local ditch instead of the outfall off Erris Head. As soon as the water outfall pipe is available, the discharge will be routed back to the permitted water outfall pipe discharge point (SW1).

2.5 Site Status in Relation to the Control of Major-Accident Hazards and Safety

2.5.1 The ‘Seveso’ Directive For inspection purposes only. Consent of copyright owner required for any other use. In light of industrial accidents (Toulouse, Baia Mare and Enschede) and studies on carcinogens and substances dangerous to the environment, the EU Seveso II Directive was extended by Directive 2003/105/EC of the European Parliament and of the Council of 16 th December 2003 amending Council Directive 96/82/EC. The most important extensions were to cover risks arising from storage and processing activities in mining; from pyrotechnic and explosive substances; and from the storage of ammonium nitrate and ammonium nitrate based fertilizers. This amendment was implemented in Ireland under S.I. 74 of 2006. Further adaptation of the provisions on major accidents occurred on 4th July 2012 with the publication of a replacement Directive - 2012/18/EU. The main changes in this, so- called, Seveso III Directive were: • Technical updates to take account of changes in EU chemicals classification. In 2008, the Council and the European Parliament adopted a Regulation on the Classification, Labelling and Packaging (CLP) of substances and mixtures, adapting the EU system to the new UN international chemicals classification (Globally Harmonised System - GHS). In turn, this triggered the need to adapt the Seveso Directive, since its scope is based on the former chemicals classification which will be repealed by the CLP Regulation by June 2015. • Better access for citizens to information about risks resulting from activities of nearby companies, and about how to behave in the event of an accident.

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• More effective rules on participation, by the public concerned, in land-use planning projects related to Seveso plants. • Access to justice for citizens who have not been granted appropriate access to information or participation. • Stricter standards for inspections of establishments to ensure more effective enforcement of safety rules. The Seveso III Directive 2012/18/EU was promulgated in July 2012. Member States of the European Union (EU) have to transpose and implement the Directive by 1st June 2015, which is also the date when the new chemicals classification legislation becomes fully applicable in the EU. Status of the Corrib Terminal In 2012 and 2013, reviews were carried out by SEPIL on the dangerous substances to be handled and stored at the Terminal and listed in the Control of Major Accident Hazards (COMAH) notification for the site. In consultation with the Competent Authority (the Health and Safety Authority), it was agreed that it would be appropriate to re-classify raw methanol and unstabilised hydrocarbon condensate. As a result, SEPIL concluded that Articles 9 (Safety Report), 11 (Emergency Plans) and 13 (Information on Safety Measures) of the “Seveso II” Directive (upper tier requirements) will be applicable, together with the general duties (to ‘take all necessary measures…’ etc). Thus the provisions of S.I. 74 of 2006 (and of any subsequent regulations which arise from the implementation of the Seveso III Directive in Ireland) will apply to the facility.

2.5.2 Petroleum (Exploration and Extraction) Safety Act 2010

The Electricity Regulation Act 1999, as amended inter alia by the Petroleum (Exploration and Extraction) Safety (PEES) Act 2010 gives the Commission for Energy Regulation (CER) responsibility for the safety regulation of petroleum exploration and extraction activities in Ireland. The PEES Act requires the CER to establish and implement a risk- based Petroleum Safety Framework. The Petroleum Safety Framework is the overall system established by the CER to regulate the safety of petroleum activities and, in particular, designated petroleum activities, carried out by petroleum undertakings. The Petroleum Safety Framework established under the PEES Act is a permitting regime, is For inspection purposes only. goal-setting and risk-based,Consent of wherebycopyright owner petroleum required for any other unde use.rtakings are required to reduce risks to a level that is as low as is reasonably practicable (ALARP). In December 2013 the PEES Act was commenced in full bringing into operation the Petroleum Safety Framework, and the CER is now the safety regulator for upstream petroleum activities in Ireland as set out in the PEES Act. The PEES Act requires all petroleum undertakings that carry out designated petroleum activities to submit a Safety Case (or Safety Cases) to the CER with respect to that designated petroleum activity. The PEES Act prescribes certain things that have to be included in a Safety Case and the minimum conditions that must be satisfied in order for the CER to approve it. All safety cases submitted to the CER under the PEES Act are required to be prepared in accordance with CER’s Safety Case Guidelines (CER/13/283). In respect of a designated petroleum activity or activities, each Safety Case must address the particulars specified in the Safety Case Guidelines that relate to that activity. The CER shall only approve a Safety Case for the purposes of issuing a Safety Permit where the information contained in the Safety Case complies with the relevant requirements of the PEES Act. Status of the Terminal The PEES Act is applicable to all the upstream elements of the Corrib field development, i.e. the offshore wells and subsea facilities, the pipeline(s) and umbilical, and the Terminal itself. Therefore, SEPIL is required to submit Safety Case(s) to the CER in relation to designated petroleum activities. Designated petroleum activities are defined in

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S.I. 89 of 2013 and include Well Work, Production and Decommissioning. The operation of the Terminal, both in terms of system commissioning with hydrocarbon gas from the network (back feed gas), and when handling gas from the Corrib field will be designated petroleum activities and, as a result, SEPIL is required to submit a Production Safety Case to the CER. The Terminal cannot be operated with hydrocarbon gas unless a safety permit is in force in respect of its operation.

2.6 Hazard Protection

The fire fighting strategy for the Terminal facilities has been enhanced through detailed design since that described in the 2003 Terminal EIS. This is reflected in an updated Appendix 2.1.

2.6.1 Hazard Detection and Monitoring

Hazard identification and prevention has been a key component of the Terminal design and will minimise the risk of accident/ hazardous and emergency situations arising during the operation of the Terminal. The Emergency Plan which is in preparation for the Terminal will be regularly tested and reviewed and will detail the emergency response including the organisation and facilities in place and the measures to be taken to minimise the consequences of any accident/emergency situations on human health and the environment. Specific measures incorporated into the Terminal design to detect and respond to hazardous situations are described in the following sections. The purpose of the hazard detection and monitoring is to detect any hazard at the earliest possible moment. The principal detection and monitoring measures at the Terminal include the following: • controls and instrumentation to ensure that the plant operates normally, i.e. within its intended operating range in terms of flow, temperature, pressure and liquid level. If any of these parameters stray from the intended limit of the normal operating range, then an alarm will attract the operator’s attention; and • further independent instrumentation to detect deviations outside normal operation and to initiate For inspectionadditional purposes alarms only. and shutdown. Consent of copyright owner required for any other use.

2.6.2 Hazard Mitigation and Protection

In the event of a hazard being detected, the aim is to isolate the affected section of plant and depressurize it safely to flare as rapidly as possible. All control and shutdown systems have been designed to default to a safe condition in the event of failure. The principal detection and monitoring measures effective after a loss of containment include the following: • gas detectors have been installed at strategic locations in the process areas and at air intakes to buildings and to any equipment with ignition sources, i.e. gas turbines and engines. These detectors will give early warning of potentially explosive atmospheres. An explosion could only occur if a gas cloud, first were to have a concentration above the lower explosive limit and, secondly, were to be ignited by a flame or spark. Detection of flammable gas near an ignition source would immediately shut down that piece of equipment so as to eliminate the potential source of ignition; • smoke detection in all buildings. High Sensitivity Smoke Detectors (HSSDs) will be used for the very early detection of electrical fires. These enable incipient electrical fires to be extinguished before they develop;

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• fire detectors have been installed at strategic locations in the plant and in all buildings. Fire, gas and smoke detectors are all integrated into the fire and gas monitoring system, which provides executive shutdown action and warnings in the control room as appropriate. Fire detection in the storage tank area will automatically initiate the tank deluge systems; and • CCTV will be used to monitor critical areas. The principal mitigation and protection measures include: a) Emergency shutdown (ESD) and isolation initiated by fire and/or gas detection or by process deviations (outlined above). The ESD system at the Terminal will ensure the safe isolation and shutdown of equipment under fault or fire conditions and will provide a basis for the safe and efficient shutdown of process operations and the isolation of flammable / toxic materials within the facilities. The principal aims and objectives of the system are: • the protection of personnel; • the prevention and/or minimisation of pollution to the environment; • the protection of plant and equipment; and • continuity of production by minimising spurious shutdowns. The objectives will be achieved as the system: • warns of an abnormal operational or equipment condition; • provides manual and automatic initiation for shutting down and/or isolating sections of the plant, with the objective of mitigating any consequential effects of abnormal operation; • provides remote manual or automatic isolation; and • provides facility for remote manual depressurising of each plant section once isolated. The ESD system is a fully fail-safe design providing fully automatic isolation of the relevant sections of plant by ESD valve closure. The Terminal ESD system will operate on four levels depending on Forthe inspection situations, purposes only. which are outlined in Table 2.3 below (the Consent of copyright owner required for any other use. offshore subsea system follows the same philosophy).

Table 2.3: Terminal ESD Operating Levels

ESD Operation Level Level 0 Total field shutdown Level 1 Terminal shutdown, excluding the emergency generator Level 2 Shutdown of a Terminal system (e.g. gas, condensate or methanol) Level 3 Shutdown of a section of equipment within a system (e.g. gas compression, condensate tankage, or methanol injection)

b) Depressurisation of an isolated section or sections of plant or, if appropriate, the entire plant, during an emergency, by venting to flare (blowdown). c) Pressure relief valves to provide safe and automatic venting of pressure to the high level flare before equipment becomes over-pressured.

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d) A self-sufficient and comprehensive fire protection / fire-fighting system. e) Design and construction of the control building to withstand potential overpressures from the Terminal’s processes and hazard inventories to protect the operators and equipment to enable the safe shutdown of the plant in the event of an external explosion. f) Secondary means of egress from the plant to the North via 3 emergency exit gates in addition to the main exit to the south east via the Administration building. g) Emergency Response Facilities. In the event of an emergency the Control Room Building (manned on a 24-hour basis) will act as the Emergency Response Centre for the Corrib Facilities. Upon activation of the Internal Emergency Response Plan the Corrib Location Response Team (LRT) will be mobilised to two locations. The Main Site Controller, Control Room Operator and Operations Technicians will muster to the Control Room, while the rescue team will mobilise to the LRT Building immediately to the west of the Administration Block and put on emergency response equipment as directed by the Site Main Controller. The Control Room will monitor the process and the Site Main Controller (Shift Supervisor) will take command of the situation, calling on external support if necessary. The Process is monitored by the Control Room Operator with visual monitoring of the Terminal via CCTV. External support may be obtained from any of the Principal Response Agencies (An Garda Síochana, HSE Ambulance Service or the Local Authority Fire Services) or from within SEPIL by requesting support from the SEPIL Emergency Response Team. The SEPIL Emergency Response Team (ERT) mobilises to the Emergency Response Centre located in the SEPIL office in . The SEPIL ERT provides support in areas such as technical support, next of kin support, community liaison, etc. In summary, hazard identification and prevention is a key component of Terminal design and will minimise the risk of accident and emergency situations arising during operation. In the unlikely event of accident or emergency situations arising the detection and control/response systems to be employed at the Terminal will minimise the consequences on human health and the environment.

2.7 Planning Amendment Applications For inspection purposes only. Consent of copyright owner required for any other use. Appendix 2.2 provides a summary of planning (amendment) permissions relating to the Terminal. The amendments are listed by application number and the elements within each are also categorised by general type. One such category identifies those amendments specifically relating to the requirements under the site’s Industrial Emissions (previously IPPC) Licence.

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3 CONSTRUCTION

3.1 Introduction

The main construction of the Terminal took place during the period 2005 – 2010, and the Terminal facilities are essentially complete. The Corrib onshore pipeline is being constructed and the pipeline construction activities are being carried out from temporary facilities within the Terminal site. The main activities associated with removal of the temporary construction facilities and landscaping of the wider Terminal site will be carried out as the construction and start up activities are completed. The potential and predicted impacts on the environment, arising from construction activities, were assessed in the 2003 Terminal EIS and where appropriate are reconsidered as part of this Supplementary Update Report.

3.2 Construction Management

3.2.1 Project Management and Control

As the earthworks and mechanical construction activities of the Terminal are completed, there is no longer a main construction management contractor associated with the site. The Terminal site is managed by SEPIL.

3.2.2 Project Monitoring Committee

Throughout the development of the facilities at the Terminal site a Project Monitoring Committee (PMC) has been monitoring the development as well as compliance with the relevant conditions of the planning permission during all stages of construction. This has included the monitoring of SEPIL’s compliance with the Environmental Management System (EMS) for the site. The PMC is chaired by the County Manager and includes representatives of Bord na Mona, the Environmental Protection Agency (EPA), the Department of Communications, Energy and Natural Resources (DCENR), Mayo County Council, the National Parks and Wildlife Service (NPWS) of the Department of Arts, Heritage and For inspection purposes only. the Gaeltacht, Inland FisheriesConsent of copyright Ireland owner (IFI), required SEPI for anyL, other and use. representatives from the local community. The PMC was established in 2005, when the initial construction activities at the Terminal commenced. The Committee has been a forum at which environmental concerns relating to the construction project could be and have been raised, discussed and resolved. The Committee meets on a regular basis throughout the period, and meeting records and associated documentation are available on Mayo County Council’s website.

3.2.3 Environmental Management

An EMS and associated monitoring plan have been in operation on the site since commencement of construction. The monitoring plan has been subject to annual updates, each of which has been subject to consultation with the PMC and Mayo County Council’s approval. The key elements of the EMS are the management and monitoring of: • water quality (groundwater and surface water quality); • traffic movements; • noise and vibration; • dust; and

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• waste. The various mitigation measures detailed in the 2003 Terminal EIS and the approved EMS will continue to apply where relevant in respect of the remaining construction phase activities.

3.3 Construction Activities

The three main phases of construction activity undertaken at the Terminal site were the enabling works, the peat excavation works and the main civil and mechanical construction works. Activities currently being undertaken at the Terminal site can be divided into the following categories: • Minor process improvements; • Maintenance and/or substitution of items of plant and equipment; and • Non-hydrocarbon pre-commissioning of plant and equipment. The main outstanding construction / start-up activities are:: • Further pre-commissioning and hydrocarbon commissioning of the plant and process; • Removal of temporary construction facilities (construction related equipment, portacabins, car parks, hard standing etc.); and • Landscaping of the Terminal site including tree planting, habitat enhancement and creation and environmental protection of the surrounding areas.

3.4 Construction Activities Remaining

3.4.1 Working Hours

Typical working hours during the construction phase are 0700 - 1900 Monday – Friday and 0700 - 1600 Saturday. Certain work activities are undertaken at night and/or at weekends through considerations of safety, weather or where specific construction activities such as testing require greater than 12 hour duration, and in accordance with arrangements agreed with Mayo ForCounty inspection Council. purposes only. Consent of copyright owner required for any other use. Once the plant becomes operational the site will be operating on a 24 hour basis.

3.4.2 Pre-Commissioning and Commissioning

The commissioning of the Terminal will be carried out in a systematic and controlled manner to ensure that the plant is brought safely into operation. Due to the changes to the development timeframe for the Corrib Project and the associated late completion of the construction of the onshore pipeline, it is intended to commence the commissioning of the Terminal facilities in a phased manner in order to enable commercial gas production as early as possible after completion of the onshore pipeline. Following pre-commissioning and commissioning without hydrocarbons, the Terminal will be declared fit to receive hydrocarbons and operational qualification of equipment using gas from the BGE network (Back Feed Gas) will be performed. Once these are completed, monthly integrity runs will be carried out at the Terminal until such time that the onshore pipeline is in place and the facilities are ready for start up with FFG from the Corrib Field. All necessary utility and safety systems to allow normal operation of the Terminal will be completed and commissioned before hydrocarbons are introduced to the plant. This includes non-hydrocarbon systems such as: • utility systems such as drains, water, instrument air etc.; and

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• safety systems such as emergency power, fire and gas detection, firewater, deluge etc. Nitrogen/helium leak testing of terminal systems and associated pipework, as well as emergency depressurisation of the emergency shut-down and blow down system sing nitrogen will also be carried out. The duration of the commissioning activities with Back Feed Gas will be 65 days approximately and is scheduled to commence in the third Quarter 2014. During this period, the following key operational qualification activities will take place: • test running of power generators, emission abatement equipment and power management system; • test running of sales gas compressors including waste heat recovery; and • testing the operability and design functionality of the methanol regeneration system. During the BFG programme, the ability of the equipment to operate in compliance with the relevant Emission Limit Values (ELV’s) set out in the Industrial Emissions Licence will be verified. The monthly integrity runs, which will be carried out subsequent to the operational qualification period, will comprise of the running up of power generation, gas compression, methanol regeneration and associated systems on gas from the grid. Commissioning of the condensate recovery and storage system will not be carried out during BFG. This system will be isolated until start up on gas from the Corrib Field (Forward Feed Gas -FFG) when condensate will be produced with the gas from the field. . Further, systems which will not be fully commissioning until FFG include: • the product methanol storage and methanol injection systems will be isolated. They will be pre-commissioned and filled prior to FFG; • the methanol still acid wash storage tank will be isolated. It will be pre- commissioned prior to FFG; and • the corrosion inhibitor, methanol scale inhibitor, biocide dosing and sale gas odourisation chemical For inspection injection purposes skids only. will be isolated. They will be pre- Consent of copyright owner required for any other use. commissioned and filled prior to FFG. These systems will be maintained in a state of preservation and empty (or filled with inert fluids) during the BFG period. Pipework and vessel systems will generally be held under a low pressure nitrogen inert atmosphere blanket. Rotating machinery will be filled with preservation fluids. The systems will be pre-commissioned in accordance with the Integrated Terminal Commissioning Schedule and later made ready for Terminal start up at FFG. This is expected to occur approx one year after the introduction of BFG.

3.4.3 Transitional Arrangements – Commissioning and Start-UP

During operation of the Terminal, surface water run-off from paved areas and tanker delivery road routes, i.e. drainage water from areas at risk of contamination, will be collected and treated before disposal to sea at discharge point SW1 1 via the outfall pipe. During the BFG phase, it is proposed that the discharge stream for the treated drainage water from areas at risk of contamination is rerouted through the storm water settlement ponds (SW2 1) to a drainage ditch to the southwest of the Terminal. As soon

1 Ref EPA Industrial Emissions Licence no 0738-01

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as the onshore connection to the outfall pipe is available, the discharge will be routed back to the permitted outfall discharge point (SW1). Once the onshore pipeline has been completed and connected with the offshore pipeline and the Terminal, the subsea production wells will be brought into operation, and gas and liquids from the wells will be arriving at the Terminal. During the initial production phase,, the produced water arriving at the Terminal will be collected and brought to a licensed waste water plant. This is to ensure that any mono ethylene glycol, which has been injected into the production wells during well completion activities offshore is removed from the production stream, before the final commissioning of the produced water treatment facilities on the Terminal can take place.

3.4.4 Demobilisation

Pipeline construction activities within the Terminal site and between the Terminal and the landfall are currently ongoing. These activities are managed from temporary facilities within the Terminal site. The main demobilisation (removal of site temporary construction facilities, i.e construction related equipment, portacabins, car parks, hard standing etc.), the final landscaping of the Terminal site will therefore be phased to allow all necessary construction related activities to be completed.

3.4.5 Site Landscaping

Following removal of temporary facilities, the site will be landscaped according to the agreed landscape strategy including tree planting, habitat enhancement and creation, development and protection of the surrounding areas. The post-construction reinstatement landscaping will be phased as areas become available.

3.5 Mitigation Measures

Throughout the construction phase of the Terminal, SEPIL have been consulting extensively with the local community and the PMC to clearly understand and where possible address local concerns For and inspection mitigate purposes only. as far as possible the impacts during Consent of copyright owner required for any other use. construction.

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4 ALTERNATIVES

4.1 Need for the Project and Alternative Concepts

Section 4 of the 2003 Terminal EIS discussed the need for the project with regard to energy sources in Ireland and discussed alternative design concepts considered during the pre-feasibility, feasibility, front-end engineering and detailed engineering phases. Alternative siting of the Terminal and alternative construction techniques were also considered. New/further alternatives associated with changes to the future operation of the Terminal have been considered below.

4.2 Onshore Pipeline Routing

The onshore pipeline development was subject to a review which commenced in 2007 and included the consideration of: • alternative landfall points, pipeline routes, construction methods; and • alternative options for the design and configuration of the Landfall Valve Installation (LVI). The review resulted in the selection of a new pipeline route between the permitted landfall point and the Terminal, as well as an update to the design of the landfall valve. The alternatives considered were reported in the Onshore Pipeline EIS (RPS, 2010), and are not considered further in this Supplementary Update Report.

4.3 Terminal Technology Options

SEPIL is seeking to move the discharge point for treated produced water away from the permitted outfall point off Erris Head. This is in response to concerns raised by local fishermen in relation to the location of the previously permitted outfall point. Alternatives considered prior to making a decision to propose moving the discharge to the Corrib subsea manifold location are outlined below. For inspection purposes only. A limited number of modificationsConsent of copyright toowner the required process for any other an use.d associated technology at the

Terminal have been implemented during the previous IPPC licensing process which resulted in an IPPC licence granted (with conditions) in 2007. The alternatives considered in relation to these, which are listed below, are also contained in this section: • selection of Selective Catalytic Reduction to reduce NOx emissions; and • methods of minimising vapour losses from storage tanks.

4.3.1 Treated Produced Water Disposal

A number of disposal options were considered for the treatment and discharge of produced water in the 2003 Terminal EIS. The option selected was to treat the water to a high standard, and to discharge all treated produced water and site run-off water from process areas via an outfall pipe attached to the gas pipeline and connecting to an outlet with a diffuser at a point off Erris Head. Modelling showed that this would have a negligible effect on seawater quality and on marine life. SEPIL now propose to move the discharge of treated produced water to the Corrib offshore manifold location.

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Alternative disposal options for produced water were identified and reviewed. The options, screened for practicability, cost, environmental impact and viability, are summarised in Table 4.1 below. Table 4.1: Disposal Options Identified Disposal Options Description Considered 1. Seabed Seabed separation of produced water and re-inject or discharge at seabed. separation 2. Disposal by truck Dispose of the produced water onshore by road/rail tanker, with or without treatment. 3. Market Sell as a marketable product (treated process water) to a third party by road tanker. 4. Further purify the Extend the Terminal’s water treatment facilities to produce even cleaner produced water water that the fisherman could accept for disposal by the “existing” sea outfall line. Export the treatment sludge by road tanker to licensed waste contractors. 5. Boiler-feed Extend the Terminal water treatment facilities to produce a boiler-feed quality water that could be provided to power plants. Export the treatment sludge by road tanker to licensed waste contractors. 6. Re-use Re-use the treated produced water on site. 7. Evaporate Evaporate the water, and disperse the steam via the Gas Turbine exhaust. 8. Inject Inject the produced water into an onshore disposal well. 9. Re-inject Re-inject the water back into the reservoir offshore. 10. Extend the Extend the water outfall along the offshore pipeline route so that it would outfall terminate outside the 12 mile territorial limit. 11. Reroute the Reroute the water outfall to terminate outside the 12 mile territorial limit, but outfall not along the pipeline route. 12. Umbilical Reroute the treated produced water to release it outside the 12 m territorial limit by using available spare core(s) in the control umbilical.

For inspection purposes only. Preferred Option for ProducedConsent Water of copyright Disposal owner required for any other use.

Of those alternatives considered as potentially feasible, deepwater disposal of treated produced water via the available spare umbilical core(s) in combination with onshore trucking was identified as the preferred option. This option would ensure a high level of treatment, combined with disposal at a deep water outfall, where significant dispersion would be available, or through suitably licensed waste water treatment plants, hence ensuring that there would be no significant impact arising from the disposal.

4.3.2 Selection of Selective Catalytic Reduction to reduce NOx emissions

The conditions attached to the 2007 IPPC licence requires that power generation 3 engine exhausts meet a NO X Emission Limit Value (ELV) of 250mg/ Nm . Abatement as required in order to meet this limit, and several alternative options to reduce the NOx level in the exhaust gas were considered. The five alternative options (set out in Table 4.2 below) identified were screened for practicability, cost, environmental impact and viability.

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Table 4.2: Alternatives Considered Disposal Options Description Considered 1. Selective Catalytic Retain the purchased gas engines and install an SCR exhaust treatment Reduction (SCR) package to reduce emitted NOx below the ELV. 2. Convert Gas Convert the purchased gas engines to run at fixed speed to achieve NOx Engines with emission level of 250 mg/Nm3 NOx with connection to the electricity grid to connection to handle plant load variations and procure an emergency diesel generator-set Electricity Grid and to meet lower onsite power requirement during grid outages. use of an emergency diesel generator 3. Convert existing gas Convert the purchased gas engines to run at fixed speed to achieve NOx engines with emission level of 250 mg/Nm3 NOx with connection to the grid to handle connection to the plant load variations. Existing gas engines would be run during grid Electricity Grid, during outages. outages only using generators 4. Connection to Replace purchased gas engine generator sets with a dual-redundant grid electricity grid connection. 5. Procure other Use alternative power generation arrangements, such as gas turbines, available power Combined Heat and Power (CHP) or renewable energy. generation technology

Preferred Option - Selective Catalytic Reduction (SCR) Of those alternatives considered as technically feasible and economically viable, Selective Catalytic Reduction (SCR) was identified as the preferred option, as it is a proven method of reducing NO x emissions and has been implemented on numerous gas engine applications elsewhere. A design study confirmed the feasibility of retro-fitting SCR systems to the gas engine power generation units to achieve the required NO x emission reduction levels with minimum changes to the Terminal plant.

4.3.3 Methods of Minimising Vapour For Losses inspection frompurposes Storage only. Tanks Consent of copyright owner required for any other use.

Hydrocarbon condensate and methanol fixed roof storage tanks in the bulk storage area of the Terminal have all been fitted with internal floating covers. This now also includes the offspec condensate tank which did not include an internal floating roof in the original AMEC design. The installation of internal floating covers with high integrity seals are estimated to achieve reductions in VOC emissions by more than 97% which represents BAT. The application of additional vapour recovery or vapour treatment is not deemed to be practical or economical, particularly considering the uncertainty and variability in relation to the composition of the vapours from the different tanks throughout the production life of the Corrib field. The offspec condensate tank was originally intended to be used as a contingency during planned maintenance or process upsets as a temporary buffer tank to allow rerouting of offspec condensate back to the condensate stabilization process. This was the design basis at a time when all condensate was going to be consumed on site as fuel for the Heating Medium Heater. Now, all condensate will be exported from site by road tanker. The expected frequency of “offspec condensate” has been reduced further since an additional small electric heater has been installed for condensate stabilisation, which will be available even when the heating medium system is shut down. This will allow

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continuous operation of the condensate stabilisation system even at low condensate production rates, eliminating the need for “batch operation”. Given that the tank will be primarily be out of use, an internal floating roof will require a minimum operating level of an inert liquid in the tank to allow smooth operation of the floating roof to be maintained (to be advised by the vendor during commissioning). The offspec tank will always be kept under a nitrogen blanket for safety reasons. Principles of Best Available Techniques have been incorporated into all other aspects of the design and planned operation and maintenance of the bulk storage tanks to ensure fugitive emissions are kept to a minimum

For inspection purposes only. Consent of copyright owner required for any other use.

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5 HUMAN BEINGS

5.1 Introduction

The 2003 Terminal EIS discussed the key issues affecting human beings, and the potential impacts of the Terminal on them. In addition to providing an update to the baseline population, employment and economic figures, and an updated discussion on the remaining construction and operational phase impacts of the development, details are also provided in this section on the Community Social Investment Programme that has been put in place by SEPIL. This latter item includes details of the Community Gain Investment Fund which has been set up in accordance with Condition 58 of the Approval relating to the Corrib onshore pipeline. This section has been prepared by Tom Phillips and Associates in association with Shell E & P Ireland Ltd (SEPIL) and relevant disciplines as set out in Section 1 Introduction of the Bellanaboy Bridge Gas Terminal EIS Supplementary Update Report.

5.2 Study Methodology

The update to the population profile for the local area surrounding the Gas Terminal at Bellanaboy Bridge has been determined from Small Area Population Statistics (SAPS) records provided by the Central Statistics Office (CSO). This analysis is carried out using the 1996, 2002, 2006 and 2011 SAPS. The site is mainly located within the Electoral Division (ED) of , but given that it is adjacent to the boundary of the Knocknalower ED, the figures presented below in relation to the local community include the two EDs. The Qualitative research was informed through public consultation undertaken during the preparation of the applications for the previous consents granted for the project to date. Qualitative information has also been provided by members of SEPILs Community Liaison Officer team based in a Corrib Natural Gas public information office in Belmullet.

5.3 Receiving Environment For inspection purposes only. Consent of copyright owner required for any other use. 5.3.1 Population

As recorded in the 2003 Terminal EIS, the 1991-1996 period was the first period of growth in County Mayo since the beginning of Census records. In more recent times, the population of County Mayo has increased by 5.3% between 1996 and 2002, by 5.4% between 2002 and 2006 and by 5.5% between 2006 and 2011. However, urban centres have accounted for the majority of recent population growth. As shown in Table 5.1 and Figure 5.1, the populations at State and County levels have consistently increased between 1996 and 2011. Over the same period, the populations of the Belmullet Rural District and, at a more local level, the EDs of Knocknalower and Glenamoy, have declined overall between 1996 and 2011, albeit that the population in the Belmullet Rural District has stayed relatively static since 2002. The reasons stated in the Cill Chomain Development Plan 2006-2010 (which includes, among others, the EDs of Knocknalower and Glenamoy) for this recorded decline in population in the area are “a decline in the birth rate, emigration, lack of local employment opportunities, out-migration of young adults to attend third level institutions, many of whom do not return because of a shortage of job opportunities to match their qualifications”. This

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is also very clearly demonstrated in Figure 5.2 when the age cohorts for the various Census periods are overlain. The number of residences close to the Terminal is, as previously recorded, limited. Within 2 km of the centre of the site there are only 21 no. households, which is reflective of the population density of one person per 9.3 hectares in the Knocknalower and Glenamoy EDs. This population density is typical for rural areas in the Erris region outside of the main settlements. In comparison, the respective figure for County Mayo is one person per 4 hectares, which is itself low compared to the State level (one person per 1.5 hectares) and reflects the primarily scattered rural population that occurs within the county. As a consequence of existing and proposed planning policies restricting rural housing (in the operational and Draft County Mayo Development Plans, respectively), it is not expected that the number of residences in proximity to the Terminal site will increase significantly in the medium to long term.

5.3.2 Age Profile

Table 5.2 shows the age profile of the State, County Mayo, Belmullet Rural District and the EDs of Glenamoy and Knocknalower in 2011. As shown in Table 5.2, the local area surrounding the Terminal has a lower proportion of young people aged >15 years (18.9%) than the State (21.3%) and County (20.9%), but marginally higher than the wider Rural District (18.6%). It also has a significantly lower proportion of 25-44 year olds (20.3%) than the State (31.6%) and County (26.9%) and somewhat higher than the Rural District (23.9%), recorded in the 2011 Census. The proportion of 45-64 year olds in the local area is significantly higher (31.3%) than the State (22.7%), County (25.8%) and somewhat higher than the Rural District (28.2%). Similarly, the proportion of over 65 year olds in the local area (16.9%) is notably higher than the State (11.7%), is slightly higher than the County (14.9%) and slightly less than the Rural District (17.4%). The proportion of the population classified as “Dependent” relates to the age groups of 0- 14 year olds and over 65 year olds. The dependency rate in Knocknalower and Glenamoy in 2011 was 35.8%, the same as for County Mayo and very similar to the Rural District, but higher than the average for the State (33%). For inspection purposes only. Table 5.1: Population ChangeConsent of1996 copyright – 2011 owner (Source:required for any CSO) other use.

Year ► Population % Population Change

1996 - 2002 - 2006 - Area ▼ 1996 2002 2006 2011 2002 2006 2011 Ireland 3,626,087 3,917,203 4,239,848 4,588,252 8.0 8.2 8.2 County Mayo 111,524 117,446 123,839 130,638 5.3 5.4 5.5 Belmullet 8,339 7,927 7,923 8,005 -5.1 0 1 Rural District Knocknalower 1,137 1,095 1,108 1,074 -3.7 1.2 -3.1 & Glenamoy

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Table 5.2: Age Profile of the State, County Mayo, Belmullet Rural District & Glenamoy & Knocknalower EDs, 2011 (%). (Source: CSO)

Area ► State County Mayo Belmullet Rur al Glenamoy & Age Groups District Knocknalower ▼ Less than 21.3% 20.9% 18.6% 18.9% 15 15 -24 12.6% 11.5% 11.9% 12.6% 25 -44 31.6% 26.9% 23.9% 20.3% 45 -64 22.7% 25.8% 28.2% 31.3% 65+ 11.7% 14.9% 17.4% 16.9% Total 100% 100% 100% 100% Dependency 33% 35.8% 35.8% 36% Ratio

Figure 5.1 shows the age profile of the local community in Knocknalower and Glenamoy, analysed over the last four Censuses. This graph shows three general trends in terms of age distribution. Firstly, the proportion of young people in the local area has reduced significantly over the Census periods, albeit that all four Censuses record a peak around these age cohorts. The second trend is that this peak is consistently followed by a sharp drop in population in the 20-24 and 25-29 year age cohorts, suggesting a high migration rate as young people leave to attend third level education or to take up employment in urban areas. A combination of in-migration and people returning to the area was recorded in the 2003 Terminal EIS as resulting in a noticeable peak in the 35-39 age cohort in the 1996 Census, with a subsequent peak in the 40-44 age cohort recorded in the 2002 Census. This third general trend has continued over subsequent 2006 and 2011 Census periods. One notable feature of this in-migration is that the migrants appear to be returning at an older age for each progressive Census. Figure 5.2 shows the age profile of the wider community in the Belmullet Rural District, over the last four Censuses. The overall graph is similar in some respects to Figure 5.1, with a high proportion of young people in the area, although this has become much less pronounced in each subsequent Census from the peak of 983 no. 10-14 year olds recorded in the 1996 Census. The 2011 ForCensus inspection results purposes only. are notable in this respect in that for the first Consent of copyright owner required for any other use. time the peak in population is in the 50-54 year age cohort, rather than for people under 20 years of age. The progression of the population between the 15-19 and 20-24 year age cohorts has consistently recorded a decline, indicating a “braindrain” in the wider Rural District. The most recent Census shows an increase in the population of 25-29 year olds, which contrasts from the three previous Censuses. This contributes to a generally ‘flatter’ age profile in the 2011 Census than has previously been the case.

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Figure 5:1: Age Profile of Knocknalower & Glenamoy 1996-2011 (Source CSO)

Figure 5:2: Age Profile of Belmullet Rural District, 199602011 (Source CS0)

For inspection purposes only. Consent of copyright owner required for any other use.

5.3.3 Household Numbers & Size

Census trends indicate that the average household size in Ireland has gradually declined over time. Between 1986 and 2002, the national average household size fell from 3.53 to 2.94 persons per household. This reduction has continued in more recent years, down to 2.81 persons in 2006 and 2.73 in 2011. As indicated in Table 5.3, the average household size is consistently slightly higher in the EDs of Glenamoy and Knocknalower as compared to the State in the corresponding years recorded

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above. The average household size in the Belmullet Rural District is slightly lower than the local area, but in both cases the national trend of declining average household size has been followed. Table 5.3 also shows that the number of households in the EDs of Glenamoy and Knocknalower has shown modest but consistent increases during each inter-Census period, to sit at 393 in 2011, up from the 364 no. households recorded in the 2003 Terminal EIS. The number of households in the Belmullet Rural District has similarly consistently increased over the same time period. In both instances, this is despite the population in these areas staying relatively static or slightly declining, resulting in the reduction in average occupancy noted above.

Table 5.3: Household Numbers & Size, 1996 – 2011 (Source: CSO)

1996 2002 2006 2011 Households No. Avg. Size No. Avg. Size No. Avg. Size No. Avg. Size (persons) (persons) (persons) (persons) Glenamoy & 340 3.45 364 3.12 379 2.88 393 2.79 Knocknalower Belmullet 2476 3.33 2557 2.99 2740 2.81 2937 2.70 Rural District

5.3.4 Economic Performance

Relative Deprivation The Pobal Haase-Pratschke Deprivation Index provides a measurement of the overall deprivation of the area. Based on the 2006 and 2011 Census, the index takes into consideration Demographic Profile, Social Class Composition and Labour Market Situation. The index gives both a relative and an absolute measurement of deprivation, where the relative measurement compares a particular ED relative to all others, while the absolute measurement allows for comparison between Census periods. The 2006 and 2011 Deprivation Indices differ from that used in respect of previous deprivation indices (including that recorded in the 2003 Terminal EIS), which doesn’t allow for a direct comparison. The previous indices ranked each ED on a scale of 1 (most affluent) to 10 (most disadvantaged), whereas the current For indicesinspection purposes rank only.each ED on a scale ranging from +40 (most Consent of copyright owner required for any other use. advantaged) to -40 (most disadvantaged). Notwithstanding these differences, a qualitative comparison can be made in terms of the changes observed between 1996 and 2011. The 1991 and 1996 deprivation score for both Knocknalower and Glenamoy was 10, while in the Belmullet Rural District; all 14 EDs had a score of 10 in 1996. This meant the entire Rural District was in the top 10% most deprived areas in the country, well above the national mean of 4.6. The 2006 Indices record an absolute deprivation score of -15 for Glenamoy and -22.1 for Knocknalower, as compared to -20.9 and -25.7, respectively, in 2011. This compares with -14.7 in 2006 and -20 in 2011 for the Belmullet Rural District, with a range in score from of -6.2 (Barroosky) to -22.1 (Knocknalower) in 2006 and -13.4 (Belmullet) to -25.7 (Knocknalower) in 2011. This worsening of deprivation is consistent with a general trend witnessed across the State as a whole (-1.3 in 2006 and -8.5 in 2011) resulting from the economic recession. However, what is notable is that the quantum of decline between 2006 – 2011 for the Belmullet Rural District, at - 5.4, is less than the -7.2 recorded at State level over the same period. When the relative deprivation scores are examined in this context, it also shows that relative (i.e. compared) to all other EDs, those in the Belmullet Rural District have fared well, with an increase of 1.7 between 2006 – 2011. As noted above, while a direct comparison cannot be made over the period of 1996 and 2011, what can be seen is that the relative deprivation of the area is generally improving. In particular it is notable that between 2006 and 2011 (where direct comparison is possible), all but three EDs in the Belmullet Rural District showed a relative improvement in their deprivation index score, with

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the two local EDs of Glenamoy and Knocknalower recording improvements of 1.1 and 3.5, respectively. Notwithstanding this improvement, the local EDs in particular remain classed as ‘disadvantaged’, in keeping with the majority of EDs that make up the Belmullet Rural District.

5.3.5 Employment

Poor employment growth is a feature of lagging economic development and there is a correlation between this measure and the state of the region’s infrastructure, low labour force participation rates and higher rates of outward migration. The level and growth in employment in the Western Counties (i.e. those west of the Shannon) is shown in Table 5.4 and gives a context within which to view the employment performance of County Mayo. Between 2002 and 2006, the region experienced significant employment growth of 19%, but subsequently recorded a 5.9% reduction between 2006 and 2011. Employment growth followed a similar pattern in County Mayo, with a 16.8% increase being followed by a 6.1% decrease. To gauge the employment trends in the local area, an examination has been carried out of the recent Live Register figures for the Belmullet area (see Table 5.5), which is representative of the population in the vicinity of the Gas Terminal. These figures show considerable fluctuation over the 12 year period from 2002 to October 2013, ranging from a low of 474 No. people in 2007, to a high of 1109 No. people in 2011.

Table 5.4: Employment Growth in the West, 2002 – 2011 (Source: CSO)

% Change % Change County/Region 2002 2006 2011 2002-2006 2006 - 2011 Mayo 44,764 52,277 49,076 16.8 -6.1 Galway 85,210 104,495 100,764 22.6 -3.6 Donegal 48,379 56,670 53,277 17.1 -6.0 Sligo 23,927 27,328 25,434 14.2 -6.9 Leitrim 9,990 12,669 11,972 26.8 -5.5

Roscommon 21,270 For inspection 25,829 purposes only. 24,390 21.4 -5.6 Consent of copyright owner required for any other use. Clare 43,679 50,607 45,606 15.9 -9.9 Total "West" 277,219 329875 310519 19.0 -5.9 Ireland 1,641,587 1,930,042 1,807,360 17.6 -6.4 Leinster 916,027 1,077,710 1,009,942 17.7 -6.3

Table 5.1: Average Number of Persons on the Live Register in Belmullet, 2002-2013 (Source: CSO)

Year 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Average No. of 770 692 599 554 515 474 563 851 1041 1109 997 923 Persons

Employment Status The principal economic status of persons aged 15 years and over, recorded at State, County, Rural District and local ED levels in 2011, are given in Table 5.6. The local EDs have a population of people “at work” (31.6%) of significantly less than the State level (50.1%), and notably lower than the populations “at work” in County Mayo (47.5%) and in the Belmullet Rural District (38.1%). The proportion of unemployed people is notably higher at the local level (19.5%), than the comparable proportions at State (10.8%), County (10.6%) or Rural District level (16%).

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The labour force in the area adjacent to the Terminal can be gauged from the employment status of persons aged 15 and over in the local EDs of Knocknalower and Glenamoy. Table 5.7 presents these figures for the 1996, 2002, 2006 and 2011 Censuses. As can be seen from the Table 5.7, in 1996, 2002 and 2006, the two most common categories were people ‘at work’ and people engaged in ‘home duties’. However, over the period shown the percentage of people engaged in home duties steadily fell, such that in 2011 it was supplanted as the second most common category by the percentage of people classed as ‘unemployed’ (19.5%, which recorded a 9.9% increase from 2006) and ‘retired (15.6%). Of those classed as ‘at work’, this has varied significantly over time, with a 48% increase between 2002 and 2006, followed by a 10.7% reduction between 2006 and 2011. In the most recent Census, only 0.8% of the population were first time job seekers, while 10% were students. As shown in Table 5.6, in the wider Belmullet Rural District for 2011, the employment status of persons aged 15 years and over has a different profile to that of the local EDs. Whilst the most frequent category, of people ‘at work’ is the same, people who are ‘retired’ is the next most common followed by ‘unemployed’ – which is a reversal of the order of these latter two categories at the local level. Table 5.6: Persons aged 15 years and over in the State, County Mayo, Belmullet Rural District, Glenamoy and Knocknalower EDs, classified by principal economic status, 2011 (Source: CSO)

Area ► State County Mayo Belmullet Rural Glenamoy & Principal Economic District Knocknalower Status ▼ At work 50.1% 47.5 % 38.1 % 31.6 % 1st Job Seeker 0.9% 0.9% 0.8% 0.8% Unemployed 10.8 % 10.6 % 16.0 % 19.5 % Student 11.3% 10.2% 9.4% 10.0% Home Duties 9.4% 9.7% 11.7% 15.2% Retired 12.7% 15.7 % 16.9 % 15.6 % Unable to Work 4.4% 5.1% 6.5% 6.6% Other 0.4 % 0.4 % 0.5 % 0.7 % Total 100% 100% 100% 100%

Table 5.7: Employment Status of Those For inspection Aged 15purposes Year only.s and Over, Knocknalower & Glenamoy, 1996 - 2011 (Source: CSO) Consent of copyright owner required for any other use.

1996 2002 2006 2011 Employment No. of No. of No. of No. of % % % % Status Persons Persons Persons Persons At work 237 28.7 208 24.7 308 35.3 275 31.6 1st Job 38 4.6 26 3.1 21 2.4 7 0.8 Seeker Unemployed 108 13.1 101 12.0 84 9.6 170 19.5 Stu dent 83 10.0 111 13.2 87 10.0 87 10.0 Home Duties 231 28.0 201 23.9 171 19.6 132 15.2 Retired 93 11.3 101 12.0 101 11.6 136 15.6 Unable to 36 4.4 83 9.9 91 10.4 57 6.6 Work Other 0 0.0 10 1.2 9 1.0 6 0.7 Total 826 100.0 841 100 872 100 870 100

Employment by Industry The number of persons aged 15 and over, categorised by the industry in which they work in the local EDs of Knocknalower and Glenamoy, in 1996, 2002, 2006 and 2011 is outlined in Table 5.8. From this data, it is obvious that there has been a significant shift in category of employment over time. For example, the number of persons engaged in agriculture dramatically declined from

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50.2% in 1996 to 18.3% in 2002, reaching a low of 9.4% in 2006 before rebounding to near the 2002 level in 2011 (18.2%). This represents an overall decrease of 32% in the proportion working in the agricultural sector, albeit that in 2011 it was still the second most common category after ‘professional services’. This latter category is notable in its own right for the significant increases which have occurred from 1996 (6.8%) to 2011 (23.3%). This is in contrast to the ‘manufacturing industry’ which has consistently declined, such that in 2011 it occupied the same proportion of people (8.4%) as ‘building and construction’, which itself was the category that recorded the biggest decline from 2006 – 2011, dropping 16.9% over this period. Table 5.9 below shows the number of persons aged 15 and over, categorised by industry, in the wider Belmullet Rural District. This data also shows an obvious decrease in the proportion of people employed in the agricultural sector, falling from 32.5% in 1996 to 15.2% in 2011. As at the local level, the ‘professional services’ sector is now the largest employer, with 24.7% of the population engaged in the activity in 2011. Also similar to the situation at the local level, the reliance on the manufacturing industry has dropped from 18.7% in 1996 to only 8.9% in 2011, while the ‘building and construction’ sector has also followed the same pattern of increases from 1996 (5.7%) to 2006 (18.9%) and a significant decline in 2011 (7.4%).

Table 5.8: Persons Aged 15 and Over, Categorised by Industry in Which they Work, Knocknalower & Glenamoy, 1996 – 2011 (Source: CSO)

1996 2002 2006 2011 At Work by No. of % No. of % No. of % No. of % Industry Persons Persons Persons Persons Agriculture 119 50.2 38 18.3 29 9.4 50 18.2 Building and 12 5.1 44 21.2 76 24.7 23 8.4 Construction Manufacturing 54 22.7 29 14.0 39 12.7 23 8.4 Industry Commerce 22 9.3 37 17.8 60 19.5 47 17.1 Transport 4 1.7 11 5.3 14 4.5 8 2.9 Public 4 1.7 8 3.8 9 2.9 12 4.4 Administration Professional 16 6.8 21 10.1 50 16.2 64 23.3 Services For inspection purposes only. Consent of copyright owner required for any other use. Other 6 2.5 20 9.5 31 10.1 48 17.5 Total 237 100 208 100 308 100 275 100

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Table 5.9: Persons Aged 15 and Over, Categorised by Industry in Which they Work, Belmullet Rural District, 1996 – 2011 (Source: CSO)

1996 2002 2006 2011 At Work by No. of No. of No. of No. of % % % % Industry Persons Persons Persons Persons Agriculture 594 32.5 409 19.9 424 15.6 378 15.2 Building and 5.7 297 14.4 515 18.9 184 7.4 Construction 104 Manufacturing 18.7 247 12.0 277 10.2 220 8.9 Industry 343 Commerce 252 13.8 341 16.6 497 18.3 377 15.2 Transport 70 3.8 90 4.4 98 3.6 77 3.1 Public 4.2 103 5.0 121 4.4 159 6.4 Ad ministration 77 Professional 14.8 338 16.4 456 16.8 612 24.7 Services 271 Other 119 6.5 232 11.3 334 12.3 474 19.1 Total 1830 100.0 2057 100 2722 100 2481 100

Social Class Structure Social class, as defined by the CSO, is based on an ordinal scale, with ‘1’ being the highest social class. In general, Social Classes 1 to 3 includes professional workers, farmers on larger landholdings, as well as other non-manual occupations. Social Classes 4 to 7 includes skilled, semi-skilled and unskilled manual labour, service employment sectors, and farmers on smaller landholdings. As shown in Table 5.10, proportionally, social classes 4 to 7 are a significant majority at the local ED level, although this proportion has reduced over the Census periods from a high of 80% in 2002, to 72% in 2011. This remains some 7% higher than at the Belmullet Rural District level in 2011 (64%), which has also recorded a similar trend of decreases in these social classes over time (from a high of 71% in 2002). Both the ED and Rural District levels have a significantly greater proportion of the population aged 15 and over classified in these social groups than the County (52%) and State (49%) as recorded in the 2011 Census, which is again a consistent

pattern over the three Census periods For inspectionexamined. purposes only. Consent of copyright owner required for any other use. Unlike at the local ED and Rural District levels, it is notable that for the County and State, the overall distribution across these social class groupings has remained remarkably consistent across the Census periods, recording only a 6% change for the County and 3% change for the State. Allied to this, although there remains a significant difference in social classes between the State and County compared to the Rural District and local ED levels, this difference has been diminishing over time, which is indicative of an improving socio-economic status in the Rural District and local area.

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Table 5.10: Percentage Distribution by Social Class, Persons Aged 15 and Over, 2002 – 2011 (Source: CSO)

Categories ► 1 2 3 4 5 6 7 1 to 3 4 to 7 Area ▼ State 2011 7 27 17 15 11 4 18 51 49 State 2006 7 26 17 17 11 4 18 50 50 State 2002 6 26 16 17 11 6 18 48 52 Co. Mayo 48 52 5 25 18 17 13 4 18 2011 Co. Mayo 5 25 16 20 13 5 16 46 54 2006 Co. Mayo 4 22 16 20 13 7 18 42 58 2002 Belmullet Rural District 3 19 14 17 15 6 27 36 64 2011 Belmullet Rural District 2 20 15 21 17 8 17 37 63 2006 Belmullet Rural District 2 15 12 19 19 13 20 29 71 2002 Knocknalower & Glenamoy 2 13 12 12 17 8 35 28 72 2011 Knocknalower & Glenamoy 1 13 12 21 22 13 19 26 74 2006 Knocknalower & Glenamoy 1 10 9 17 19 18 26 20 80 2002

Social Class Categories: Social Class 1: Professional Workers Social Class 2: Managerial & Technical Social Class 3: Non-Manual Social Class 4: Skilled Manual Social Class 5: Semi-Skilled Social Class 6: Unskilled Social Class 7: Others gainfully employed For inspection purposes only. Consent of copyright owner required for any other use. 5.3.6 Tourism

County Mayo County Mayo remains a largely rural area with rich scenic resources and a distinctive culture. Tourism was recorded in the 2003 Terminal EIS as being, and has continued to be since that time, an engine for growth in the County. The Draft County Mayo Development Plan 2014 – 2020 identifies it as an emerging key employment sector and an ‘economic opportunity’ for the County and accordingly proposes policies that seek to support sustainable tourism development. Tourism in the Area Local to the Terminal Tourist attractions in the immediate vicinity of the site remain as stated in the 2003 Terminal EIS; fly-fishing and spinning remain the main attractions of the Bellanaboy local area. As was previously the case, tourist activity in the wider area remains mainly focused on hill walking, golfing, fishing, horse riding and other specific and scenic tourism resources including the North West Sculpture Trail (Tir Saile) and the scenic coastline and local beaches. The main centres for tourism nearest the site remain Glenamoy, Bangor, Pollatomish, , Belderg, Belmullet, Glencad and Inbher. Since 2003 there has been a significant increase in tourist accommodation in the wider area along with the development of additional, and provision of improved, recreational and sporting facilities.

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5.3.7 Language and Culture

The Terminal site and surrounding area, as previously recorded, is located in a Gaeltacht area.

5.3.8 Land Use

The predominant land use surrounding the Terminal site remains as stated in the 2003 Terminal EIS and consists of low intensity sheep and livestock faming, forestry and rural housing. Forestry in the Bellanaboy area remains primarily controlled by Coillte, however there are pockets of private plantations. The majority of the plantations remain coniferous.

5.4 Characteristics of the Proposed Development

The Terminal at Bellanaboy Bridge is, as previously recorded, a gas reception and treatment facility, further details of which are included in Section 2 of this report. The recruitment and manning philosophies remain as stated in the 2003 Terminal EIS.

5.4.1 Health and Safety

The 2003 Terminal EIS recorded that under the Seveso II Directive, the site was designated as ‘lower tier’ on the basis of the levels of inventory of hazardous substances in the plant. The status of the site has been reclassified to an ‘Upper Tier’ Establishment following consultation with the Health and Safety Authority (HSA). This change to an ‘Upper Tier’ Establishment has essentially resulted from a reclassification of unstabilised condensate stored on the site, such that the combination of all qualifying substances on the site exceeds the ‘Upper Tier’ threshold. The status of the establishment (Upper or Lower Tier) has no bearing on the calculation of consequences and risks; in other words, the change in tier status does not change the risk to the local population. Furthermore, the change from ‘Lower Tier’ to ‘Upper Tier’ does not in itself involve any physical changes to the plant or equipment on the site, nor does it involve any increase in overall volumes of hazardous materials or changes to the permitted capacity or throughput of the Terminal. Therefore, there are no new impacts arising from the change to ‘Upper Tier’ status. The main consequences of the change to ‘Upper Tier’ status will be the need for a Safety Report to be submitted to and assessed by the HSA in advance of the introduction of , For inspection purposes only. gas to the Terminal and the localConsent competent of copyright owner authority required for will any otherneed use. to prepare an external emergency response plan for the site. The Petroleum (Exploration and Extraction) Safety (PEES) Act 2010 gives the Commission for Energy Regulation (CER) responsibility for the safety regulation of petroleum exploration and extraction activities in Ireland. The PEES Act requires all petroleum undertakings that carry out designated petroleum activities to submit a Safety Case to the CER. The PEES Act is applicable to all the upstream element of the entire Corrib field development, i.e. the offshore wells and subsea facilities, the pipeline(s) and umbilical, and the Terminal itself. The operation of the Terminal, both in terms of system commissioning with hydrocarbon gas from the network (back feed gas), and when handling gas from the Corrib field will be designated petroleum activities and, as a result, SEPIL is required to submit a Production Safety Case to the CER. The Terminal cannot be operated with hydrocarbon gas unless a safety permit is in force in respect of its operation has been issued by the CER on foot of its acceptance of this Safety Case. . Further detail in relation to the health and safety aspects of the operation of the Terminal is provided in Section 2 of the Supplementary Update Report.

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5.4.2 Environmental Emissions

The predicted environmental emissions from the development which have the potential to negatively impact on human beings; these include air, noise, water, visual impact, and light emissions remain as stated in the 2003 Terminal EIS.

5.5 Impact of the Proposed Development

5.5.1 During Construction Impacts

While it is acknowledged that the construction period has been longer than originally envisaged, the construction of the Terminal is almost complete. Therefore, the potential for construction impacts (both positive and negative) on Population, Language and Culture; Architectural Heritage; Employment and Economic Impacts; Agriculture, Forestry and Fishing; Tourism; Recreation and Sport; Health and Safety; and Environmental Emissions will remain the same in scope and less in quantum than previously predicted in the 2003 Terminal EIS.

5.5.2 Impact of the Proposed Development during Operation

There is no proposed change to the operation of the Terminal facility. Consequently, the predicted operational impacts in respect of Population, Language and Culture; Architectural Heritage; Employment and Economic Impacts; Agriculture, Forestry and Fishing; Tourism; Recreation and Sport; and Environmental Emissions as they relate to the human receiving environment remain as stated in the 2003 Terminal EIS. As noted in Section 5.4.1, the status of the Terminal under the Seveso II Directive has changed from Lower Tier to Upper Tier. This will not result in any additional impacts on the health and safety of local residents. As noted in section 5.6.4 of the 2003 Terminal EIS, impacts on health and safety during operation will be mitigated with the adoption of the Major Accident Prevention Policy document and a training strategy document to train employees in the safe and efficient operation of the plant.

5.6 Mitigation Measures For inspection purposes only. Consent of copyright owner required for any other use. All mitigation measures relating to human beings as described in the 2003 Terminal EIS have been or will be implemented as required. Additional measures relating to mitigating impacts on human beings over and above those described in the 2003 Terminal EIS have been implemented as part of the overall Corrib Natural Gas Field Development. These include: • provision for active community engagement through the use of a team of Community Liaison Officers (CLO’s); and • implementation of a Community Social Investment Programme.

5.6.1 Community Liaison

At present, there is a team of five full-time CLOs working in the area of the development, and through which messages related to the project and its progress – both positive and negative – are communicated. In excess of 150 households are covered by the CLO team. The CLO team also deals with any specific complaints in respect of the project that are made through the Corrib Natural Gas public information office in Belmullet. The CLOs role is that of dissemination of accurate information, combined with ongoing community consultation, which is crucial during both the construction and operational phases of the development, and which has and will continue to assist in minimising potential conflict and/or

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misunderstanding of the overall scope and extent of the Corrib Gas Field Development over the long-term. There will be a CLO function continuing into the operations phase of the Terminal.

5.6.2 Community Social Investment Programme

The Corrib Gas Partners (Shell, Statoil and Vermillion) have developed a Social Investment Strategy in Erris, which forms an important part of the Corrib Project’s commitment to sustainable development and of the Partners’ stated commitment to being a good neighbour in the area in which it operates. The key principle underlying the establishment of the Social Investment Programme was the provision of appropriate support to contribute to the long-term development of the Erris region whilst enabling the community itself to identify and address its’ own needs and priorities, and ensuring that funding and benefits provided under the Social Investment Programme would be in addition to, rather than replacement of, existing statutory funding from Government sources. The main objectives of the social investment programme are: • to contribute to the long-term economic, social, environmental and cultural development of Kilcommon and the wider Erris region; and • to contribute to capacity building in Kilcommon and the wider Erris area by providing both financial and non-financial assistance which will benefit the local community. Key criteria were established for all the social investment activities from 2008 onwards, and those criteria remain the cornerstone of assessment of all applications under the Social Investment Programmes. The three key criteria are: ; Inclusive (of benefit to a general community); and Local to the Erris area. In this latter regard, the Social Investment Programme is open to all five parishes within the Erris region, but the parish of Kilcommon is prioritised over other areas of Erris. The social investment activities commenced in 2007 with the launch of a Third Level Scholarship Programme. This programme was supplemented in 2008 and 2009 with the addition of a Local Grants Programme and Erris Development Fund. Local Grants Programme The Local Grants Programme is designed to provide small scale financial support (including seed-corn development funding) to local voluntary and community organisations which are For inspection purposes only. working to contribute to the Consent economic, of copyright social, owner required cultura for anyl andother use. environmental development of the communities in which they exist. A total of 140 local groups from across the five parishes of Erris have benefited under this Programme, with €1.6m disbursed in funding from 2008-2013 (with a further estimated total spend of €350k to commencement of operation of the Terminal). This Programme is also supported by contractors working on both the Bellanaboy Terminal site and the temporary onshore pipeline construction sites at Aughoose and Glengad. The Corrib Gas Partners are committed to this Programme in its’ current format throughout the remaining construction activities. This programme will be reviewed at the time of commencement of operation of the Terminal. Third Level Scholarship Programme A Third Level Scholarship Programme was launched in 2007 for an initial three year period, offering scholarships to ten Leaving Certificate students each year from the four secondary schools serving the Erris region. Following reviews of the Programme in 2009 and 2012, it has been continued due to its’ widely accepted success as a sustainable investment programme. The Programme currently offers Scholarships for 16 students per year. This Programme has resulted in a total investment (to 2015) of €1.1m. To-date 76 scholarships have been awarded, with a number of those scholars also benefiting from internship opportunities in various disciplines within Shell. This Programme is due to be reviewed again in 2015.

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Erris Development Fund The Erris Development Fund (EDF) was launched in 2009 with initial front-loading of the fund (in line with the recommendations contained within the 2005 Peter Cassells mediation report). In advance of the commencement of this long-term fund, a number of one-off financial grants were made, totalling €280,000. In the initial three year period of the Erris Development Fund (2009- 2011) applications were accepted in three categories, namely Enterprise and Knowledge (including education); Marine and Environment (including tourism); and Sports and Culture, with 27 no. projects receiving funding of €4.2m out of the original €5m fund. This enabled recipient organisations to leverage €16m in additional funding from other sources. The structure of the Erris Development Fund was reviewed in 2011 following the grant of Planning Approval for the Corrib Onshore Pipeline and in particular the imposition of Condition 58. This Condition mandated the formation of a Community Gain Investment Fund (CGIF), to be managed and administered by Mayo County Council. The CGIF is to be used to finance community facilities and services to benefit the community in the area of the development. The Corrib Gas Partners must contribute €8.5m over a five year period, commencing in 2011. Mayo County Council (MCC) was mandated within Condition 58 to draft a Community Development Plan for the affected area to provide a basis upon which the CGIF would be disbursed and against which applications for funding would be considered. MCC completed a community consultation exercise and adopted a Development Plan in February 2012. The first disbursement of funds was in summer 2012. In addition to the CGIF, the Corrib Gas Partners decided to continue with the EDF. However, in order to avoid unsustainable development (through potential duplication of applications for funding under both the EDF and CGIF) it was decided that a more strategic approach to social investment through the EDF was required. This led to a change whereby the EDF is no longer based on a competitive application process; it instead delivers a proactive yearly programme of community initiatives under the themes of Enterprise; Safety (in particular road safety); and Community Development (this category includes support for cultural initiatives particularly including supports for the ), which were identified as key areas of need within the community. From January 2012 onwards the Corrib Gas Partners, alongside the EDF Advisory Board, have built a yearly programme of community For inspection initiatives purposes only. under these three themes, such as Erris Consent of copyright owner required for any other use. Enterprise Week, Irish Language Scholarship Scheme, Advice Workshops for voluntary and community sector organisations, Safe Driving Programme for secondary school students, the distribution of Road Safety Kits, Water Safety Awareness courses for national schools in the Erris region. It is the intention of the Corrib Gas Partners that from 2015 onwards the Erris Development Fund will be the primary source of social investment funding.

5.7 Monitoring

In addition to the monitoring outlined in the 2003 Terminal EIS, SEPILs Community Liaison Officer team will continue to act as a point of contact between the local community and the project.

5.7.1 Environmental Monitoring

In accordance with the various consents granted to date relating to the Corrib Natural Gas Field Development, four separate monitoring committees have been established, as follows: 1.Consents Condition Monitoring Committee (established under Condition No. 4 of the 2011 Section 40 Consent) (this has taken over from the Environmental Monitoring Group 2002 Foreshore Licence and Section 40);

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2.Environmental Monitoring Group (established under Condition No. 9.6 of the 2011 Foreshore Licence); 3.Project Monitoring Committee (Terminal) (established under Condition No. 34 of the Terminal Planning Permission); and 4.Project Monitoring Committee (Pipeline) (established under Condition No. 14 of the Onshore Pipeline Planning Approval). The purpose of the Monitoring Committees is to monitor the environmental impacts of the construction of the various aspects of the overall Corrib development and provide for the inclusion of additional mitigation where necessary and appropriate. All Committees have representatives of the local community who can raise environmental concerns relating to the construction of the project on the community’s behalf. These Committees are required to meet on a regular basis for the duration of the construction period. Allied to the above, environmental management plans have been established and implemented for all aspects of the Corrib Natural Gas Field Development, as described in Section 20 of this Supplementary Update Report.

5.8 Do Nothing Scenario

The do nothing scenario is no longer relevant as the Terminal has been constructed.

5.9 Reinstatement and Residual Impacts

5.9.1 Reinstatement

No reinstatement is required in respect of human beings as a result of the Terminal development.

5.9.2 Residual Impacts

Construction Phase It is predicted that there will be a slight and temporary adverse impact on the residential communities in the local area, primarily arising from traffic impacts on the haulage routes during the remaining construction works. However, the implementation of appropriate mitigation measures and adherence to the Traffic For inspection Management purposes only. Plan (as outlined in Section 16), including Consent of copyright owner required for any other use. the provision of adequate public information, and ongoing community liaison, will ensure that this inconvenience is minimised. The Community Social Investment Programme operating as part of the overall Corrib Gas Project will provide planned and targeted community gain, directed specifically at the needs of the local and wider residential community within the Erris region; this is a significant and positive community impact of the development. Operational Phase The implementation of the Community Social Investment Programme developed in respect of the overall Corrib Gas Field Development represents a significant and positive community impact, and a significant community gain for an area identified as suffering from high levels of material deprivation. Aspects of the Community Social Investment Programme will continue to operate for the operational phase of the development.

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6 Terrestrial Flora and Fauna

6.1 Introduction

The purpose of this Section of the Supplementary Update Report is to describe the changes that have taken place in the receiving environment since 2003 in terms of the flora and fauna present and to assess any likely impacts that might arise as a result of the remaining construction activities, commissioning and operation of the Bellanaboy Bridge Gas Terminal in the light of recent updated baseline information.

The study has been undertaken by EACS - Ecological Advisory and Consultancy Services and associates who have also carried out ecological monitoring at the site since 2003.

The approach and methodology to the Ecological Impact Assessment (EcIA) is the same as that followed for the 2003 Terminal EIS, with due regard to the EPA Advice Notes on Current Practice (2003); EPA ‘Guidelines on the Information to be contained in Environmental Impact Statements’ (2002); but also in accordance with new and/or revised guidance as contained in: the Institute of Ecology and Environmental Management’s Guidelines for Ecological Impact Assessment (IEEM, 2006); and with reference to the National Roads Authority Guidelines (NRA) for ecological impact assessment (Revision 2, 2009).

The habitats and species are described along with their current status and an updated evaluation of their conservation value where appropriate. During construction vegetation and faunal monitoring surveys have been undertaken by EACS and associates in accordance with the current Terminal Environmental Monitoring Programme (EMP), which during construction is subject to annual review and approval by Mayo County Council.

Potential impacts on adjoining areas and nearby designated conservation sites are also evaluated.

The location of the Terminal site is not subject to whole or part of any conservation designation under current legislation, National, European or International. Neither is any designated conservation area immediately adjacent to the site. For inspection purposes only. Consent of copyright owner required for any other use. As described in Section 6 of the 2003 Terminal EIS, the Terminal site is located on part of the former Glenamoy Peatland Experimental Station, the activities of which had resulted in significant habitat modification. The main changes that have taken place since 2003 have resulted from loss of habitat on the Terminal footprint and in the temporary construction areas. Landscape planting in Phases 1a and 1b have also slightly changed the character of the site in terms of habitat.

6.2 Study Methodology

Where survey methodologies for habitats and species have differed from those described in the 2003 Terminal EIS, this is explained in the relevant section below.

Ecological surveys and inspections have been undertaken in the course of monitoring at the Terminal site over the past decade since 2003, including those conducted in accordance with the EMP. Many of the surveys were specifically conducted in relation / in response to specific construction activities taking place at any particular time. For this reason, only the most recent site surveys which provide the current baseline information required to enable an updated ecological impact assessment (EcIA) of the operation of the Terminal are included here.

• Vegetation and habitats: October 2013

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• Non-avian fauna: General faunal surveys (including Frog surveys) 2012 and 2013; bat detector surveys in 2012 and 2013; and inspections of Pine Marten den boxes and bat boxes in 2013 • Avian fauna (birds): Breeding bird surveys 2011 and 2012.

6.3 Receiving Environment

6.3.1 Introduction and Past Management of the Site

The influences from past management practices on the site, as described in Sectionr 6 of the 2003 Terminal EIS, continue to influence the biodiversity potential of the site in terms of its habitats and species.

Apart from some clear-felling of conifer plantations there has been no significant change in landuse in the hinterland of the site.

6.3.2 Flora and Habitats

Changes in the Receiving Environment since 2003

These are:

• Loss of habitat on the Terminal footprint, including areas of species - rich wet rushy grassland • Loss of habitat in temporary construction areas • Landscape Phases Ia and Ib: planting of deciduous trees and replacement coniferous species

Survey Methodology

The site was surveyed in October 2013. The primary aim of which was to compare the habitats and vegetation occurring with those present in 2003, prior to the construction of the Terminal and associated temporary construction facilities, offices, welfare areas etc.

The methodology used for vegetation survey and habitat assessment in 2013 was the same as that described in the 2003 Terminal EIS. The For inspection plant purposes specie only.s present were noted for each of the main Consent of copyright owner required for any other use. vegetation types/habitats within the site.

Vegetation of the Site

The main habitats occurring within the site in 2013 are:

• Conifer plantation • Built ground (including roads) • Species-poor wet grassland dominated by Soft Rush (Juncus effusus ); • Recently planted Juncus effusus wet grassland; • Low deciduous scrub along track and plantation margins; • Stony forest tracks; • Wet drains supporting marsh vegetation; • Remnant blanket bog;

Of these, the dominant habitat types are conifer plantation, built ground and wet rushy grassland. The difference between 2003 and 2013 in terms of habitats is the loss of species-rich wet rushy grassland (dominated by Soft Rush) which occurred in parts of the area now occupied by the Terminal footprint. In addition to the dominant habitats, there are narrow stretches of scrub which mainly occur along the margins of woodlands, tracks and boundaries. These primarily comprise Willow ( Salix spp.), Rhododendron ( Rhododendron ponticum ) and, in places, New Zealand Flax ( Phormium tenax).

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A schematic representation of habitats present on site in 2013 is shown in Figure 6.1. Because many of the vegetation types, for example the areas of scrub, are quite fragmented, it is not possible to show the detail of mosaics and pockets of vegetation at this scale of mapping.

Plant species recorded within the study area between 2001 and 2003 were listed in Appendix 6.1 of the 2003 Terminal EIS, the majority of which species were also recorded in 2013. Updated species lists are presented in Appendix 6.1 of this Supplementary Update Report. Changes in species composition between 2003 and 2013 are indicated in the tables.

Stony Forest Tracks

As a result of road construction within the site since 2003 there has been a reduction in the length of stony forest track habitat. The majority of plant species associated with the habitat still grow along the margins of roads and on existing mineral ground within the site.

Remnant Blanket Bog

In places a few narrow strips of blanket bog, usually less than 5m in width, are to be found between the roads/tracks and margins of forestry/wet grassland. At present most of these areas of bog are in a desiccated condition due to drainage effects, however occasional waterlogged areas do occur where drainage has been impeded. The vegetation composition of these areas is largely unchanged since 2003. One of the more unusual bog species recorded is the insectivorous Pale Butterwort, Pinguicula lusitancia , which is generally less common in Ireland than the larger Pinguicula vulgaris .

Note : Habitat and vegetation classifications and associations refer to intact blanket bog but there is no intact blanket bog on the site itself, only small modified remnants of blanket bog. However the remnant bog can be broadly aligned with these vegetation types: Fossitt: (PB3) Lowland Blanket Bog;Equivalent Phase 1 survey habitat classification for intact areas: Blanket bog (E1.6.1); Equivalent Phase 1 survey habitat classification for cutaway or overgrazed areas: Wet modified bog (E1.7); Phytosociological synonymy: Pleurzio purpureae – Ericetum tetralicis Braun-Blanquet et Tüxen1952; Equivalent N.V.C. community: Scirpus cespitosus – Eriophorum vaginatum blanket mire (M17).

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Plate 1: Remnant blanket bog and conifers in 2013

Wet Grassland Dominated by Soft Rush

Since 2003 there has been a reduction in the area of wet rushy grassland within the site as a direct result of construction activities. The remaining areas of rushy grassland tend to be species-poor. It must be noted however that the majority of the plant species recorded from wet rushy grassland habitat in 2003 were recorded in 2013, albeit with a reduced distribution and abundance.

Habitat/vegetation classification and associations for wet rushy grassland are: Fossitt: Wet grassland (GS4); Equivalent Phase 1 survey habitat For inspection classificat purposesion: only. Neutral grassland (B2) and Marsh/marshy grassland (B5); Phytosociological Consent synonymy: of copyright Holco-Jun owner requiredcetum for any other effusi use. Page 1980; Equivalent N.V.C. community: Holcus lanatus-Juncus effusus rush pasture (MG10).

Wet Drains Supporting Marsh Vegetation

Most of the active drains within the site flow towards the settlement ponds which are located in the south-western corner of the site. Although some sections of wet drain have been lost as a result of recent construction activity the habitat remains relatively frequent within the site.

Habitat types/vegetation classifications for the wet drains found on the site are: Fossitt: Drainage ditches (FW4); Equivalent Phase 1 survey habitat classification: Swamp, marginal and inundation (F2).

Scrub and Hedgerow

There is still relatively little extensive scrub development within the study area. Scrub species, such as bramble, Rhododendron ponticum and eared Willow ( Salix aurita ) are frequent along the ride verges and often spread into adjoining grassland areas. Many of the larger drains and tracks have an associated narrow verge of scrub composed mainly of willow and young Rhododendron . Gorse ( Ulex europaeu s) is also present but not common.

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Low Deciduous Scrub Along Track and Plantation Margins

Whist there has undoubtedly been some loss of scrub along track margins as a result of recent construction activity there has been some localized spread of willow shrubs in areas of wet grassland in recent years. Habitat types/vegetation classifications for the scrub found on the site are: Fossitt: Scrub (WS1): Equivalent Phase 1 survey habitat classification: Dense/continuous scrub (A2.1) and Scattered scrub (A2.2).

Plate 2: Roadside willow scrub at Bellanaboy October 2013

For inspection purposes only. Conifer Plantations Consent of copyright owner required for any other use.

Since 2003 there has been a reduction in the area of conifer plantation within the site as a direct result of construction activities with a loss of conifers from plantations of all age classes and remnant plantations.

In recent years some conifers have been planted in parts of the fields of wet grassland to the west of the Terminal footprint (Landscape Phases Ia and Ib and there is ongoing natural colonisation by Lodgepole Pine ( Pinus contorta ) by means of self-seeding, particularly in areas of rushy grassland adjacent to existing plantations and shelter belts.

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Plate 3: Conifers planted in areas of wet rushy grassland as part of the landscape programme

Plate 4: Self-seeded Lodgepole Pine colonising areas of wet rushy grassland (2013)

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Exotics and Aliens

Rhododendron and Olearia spp (Daisy Bush) are still present on site as before. However, Gunnera tinctoria (Giant Rhubarb), an invasive alien plant species, has been recorded as being present since 2012. See also mitigation below.

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Built Land

As a result of construction activities since 2003 the area of built land has increased, as shown in Figure 6.1 resulting in commensurate habitat loss in these areas - mainly wet grassland and conifer plantation.

6.3.3 Flora – Evaluation

Method of Evaluation

There has been no significant change in either the evaluation or status of habitats from the 2003 Terminal EIS, albeit one of methodological source references Regini (2000 and 2002) had been updated and published as IEEM (2006); and one habitat - species rich wet grassland habitat is no longer present. Assessment is based on the same criteria used in 2003 as summarised in Tables 6.2 and 6.3 of the 2003 Terminal EIS.

The evaluation of habitats present on site in 2013 is summarised in Table 6.1 which included minor change in the light of accumulated knowledge since 2003 and the value of habitats for species of fauna have been taken into consideration, for example while wet rushy grassland is of negligible value in terms of flora and habitat per se, it is also of Low Local value in faunal terms because of its habitat value to the Common Frog, similarly mature conifer plantation in respect of the Pine Marten.

Rare and Protected Plant Species

No rare and protected species have been found, or are known to occur on the site. Of the plant species recorded during the botanical surveys up to and including 2013, none are listed under the current Flora (Protection) Order 1999 (SI No. 94 of 1999) under the Wildlife and Amendment Acts, 1976 and 2000.

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Table 6.1 Summary of Habitat Types in Terms of Their Ecological Value

Habitat Type Frequency of occurrence in the wider area Ecological Evaluation – after IEEM (2006 ) Stoney forest A common habitat throughout much of the country and Negligible tracks typical of gravel forestry tracks. The vegetation is dominated by common plant species typical of disturbed grassland. Remnant blanket Although blanket bog itself is of high ecological Low Local bog interest, these fragmented remnants occurring along edges of forestry are small and of little conservation interest. Species-poor wet This habitat is common throughout County Mayo and Negligible to grassland indeed is frequent throughout the west of the country. Low Local (for fauna) dominated by Soft Typically the vegetation type dominates wet Rush ( Juncus abandoned pasture effusus ) Provides faunal habitat - Co mm on Frog Wet drains These species-rich wetland drains add much to the Low Local supporting marsh botanical diversity of the site. Most of the species vegetation; recorded are relatively frequent in wetland habitats elsewhere in the general area. Low deciduous Willow scrub is generally common throughout Ireland, (Willow scrub) Low Local scrub (native) there is however little on the site. This habitat is to Moderate Local along track and important for birds which utilise the site. plantation margins Immature conifer A habitat with low plant species diversity and frequent Negligible plantation throughout the west of Ireland. Mature conifer A habitat with very low plant species diversity due to Negligible to plantation the shading of mature conifers. Low Local (for fauna) Provides faunal habitat - Pine Marten and birds Roadside habitats A mix of roadside verge drain; and clear – felled Negligible to Low Local south of the R314 forestry. Common habitats and vegetation types throughout the locality and country as a whole. Exotic and alien These species were either planted for shelter and (Exotics) Negligible species commercial use, or are recent invasive aliens For inspection purposes only. Consent of copyright owner required for any other use.

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Introduced Exotic Species / Invasive aliens

As described above, Gunnera tinctoria (Giant Rhubarb) is a recent addition to the flora of the site. It is of no ecological value and regarded as a pest species.

Plate 5: Giant Rhubarb ( Gunnera tinctoria ) at Bellanaboy 2013

6.3.4 Fauna (non avian)

Introduction

Faunal surveys have been conducted in the course of monitoring at the Terminal site over the past decade since 2003, many of which were conducted in relation to specific construction activities taking place at a particular time.

The area has a limited range of habitats Forin inspectionterms ofpurposes fauna, only. but nevertheless the site supports a good Consent of copyright owner required for any other use. representation of Ireland’s faunal species. The species that are present are generally common and widespread faunal species. Mammalian, amphibian and reptilian species found at the Terminal site are listed in Appendix 6.3 along with their current adjudged status in the area.

This section summarises the findings of the various fauna studies carried out in 2012 and 2013. The vertebrate fauna (mammals, amphibians and reptiles) occurring on the site are described and the likely impacts of the remaining construction and operational phases of the Terminal on fauna discussed. Faunal representation on site has remained similar to that reported in 2003, but with some additions

Survey Methodology

The fauna studies which form the basis for the current assessment were conducted in February 2012 and March 2013. In addition, a number of inspections and surveys have been conducted over portions of the site from 2012 through to September 2013. Trail cameras have been employed at several locations to assist in monitoring of faunal populations on site. Bat surveys were conducted in September 2012 and 2013. Inspections of bat boxes and pine marten boxes that had been installed in 2011 were conducted in September 2013. All surveys were conducted in favourable weather conditions. Personnel on site have also reported sightings and other observations in Wildlife Logs which have been referred to where appropriate in this Supplementary Update Report. The nature and type of habitats present are also indicative of the species likely to be present.

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Survey Constraints

Where vegetation cover is dense, badger setts and otter holts, also fox dens, may be obscured and not found. Considerable portions of the site were and remain extremely difficult to search, in particular some of the conifer plantations. Nevertheless, mammal signs would usually indicate the presence of main (badger) setts or otter holts nearby, and there was no indication that main setts or otter holts had been missed in surveys on site in 2012 or 2013. Signs at prominent boundaries or features or paths entering woodland along the boundaries did give a good indication of activity by mammals within the afforested areas.

Given the constraints of heavy cover, it was considered that no substantial improvement in survey results could be achieved without prior scrub clearance and improved access to impenetrable areas.

Cold weather during the bat survey in September 2012 may have resulted in no observations of bats being made during night time survey using heterodyne bat detectors. However, bats were detected on site in better weather conditions during surveys in 2013.

Mammals

• Badgers (Meles meles ) continue to forage on site, but known badger setts have not been in active use for some years. • Otters (Lutra lutra ) have also continued to forage on site, with frogs a principal prey during spring. • Pine Martens ( Martes martes ) have been sighted regularly and appear to be more common now than in 2003. • Irish hares (Lepus timidus hibernicus ) remain common on site. • Bat numbers continue to be very low on site, but two additional species have been recorded there since 2003; Common pipistrelle (Pipistrellus pipistrellus ) had been recorded in 2003), Soprano pipistrelle (Pipistrellus pygmaeus ), and Leisler’s bat (Nyctalus leisleri). • In 2013 Irish stoat (Mustela erminea hibernica ) has been added to the list of faunal species known to occur on site, whilst its presence had been considered potential in 2003. • Other common or widespread species on site, as in 2003, include the Fox (Vulpes vulpes ), Wood mouse (Apodemus sylvaticus For), inspection and Pygmy purposes only.shrew (Sorex minutus ). • Consent of copyright owner required for any other use. There have been one tentative and one confirmed sighting of American mink (Neovison vison) on site in 2013.

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Plate 6: Pine Marten at Bellanaboy

Plate 7: Badger tracks

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Plate 8: Irish Hare

Plate 9: Soprano pipistrelle bat at Bellanaboy September 2013 (in the hand of a bat licensed bat handler)

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Amphibians

• Frogs (Rana temporaria ), continue to be very common on site. Loss of some frog breeding habitat occurred during construction but frog breeding habitats on site have been improved by the provision of dams and weirs along former and new drainage channels on site. These measures are considered to have been successful in maintaining a high population of this species on site. • The Smooth newt (Lissotriton vulgaris ) has been found on site in recent years, a species not recorded in 2003, but there have only been two records to date.

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Plate 10: Common Frog

Plate 11: Smooth newt at Bellanaboy April 2011

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Reptiles

• The Common or Viviparous lizard ( Zootoca vivipara - formerly Lacerta vivipara) is known to occur in the locality and has been observed nearby at Aughoose on a number of occasions, but has not been found at Bellanaboy to date. It is likely to occur on the site however, albeit infrequently.

Faunal signs and observations are mapped in Figures 6.2 and 6.3 for 2012 and 2013 respectively.

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6.3.5 Birds

Introduction

Bird surveys have been conducted at the Terminal since 2000 with detailed bird surveys being undertaken in 2004, 2005, 2008, 2009, 2011 & 2012. These included general surveys and breeding bird surveys. The following sections and assessment are based on the breeding bird surveys undertaken in 2012 and supplemented by additional information from general observations to and including 2013. Bird species lists are presented in Appendix 6.4.

Methodology

The bird surveys are conducted within the site boundary using a series of walked transects in accordance with the methodology and protocols described by Bibby et al . (2000). As a result of the changing nature of the site over the years there has been some variation in the transect layout since the commencement of surveys in 2000. However, transects have always been selected to survey a representative sample of the habitats present at and in the vicinity of the Terminal footprint where the same transects have been used since 2008. Transects used in 2012 are shown in Figure 6.4. Surveys were generally carried out in the early morning when birds were at their most active and are undertaken only in suitable weather conditions, with periods of heavy rain and /or winds over F4 (Beaufort Scale) and poor visibility being avoided.

Constraints

The recent surveys were not subject to any constraints climate or otherwise.

Results

The most common bird species at the site have been consistently recorded across all of the surveys from 2000-2012. Of the 53 species found on site in this time – 13 of these have been recorded in each of the surveys (treating the early 2000-2003 survey data as one block). Many further species have been recorded on all but one of the survey periods. There are also species which have been recorded For inspection purposes only. on a single occasion or survey periodConsent and of copyright have owner not required been for observedany other use. on site during any other survey work. Hen Harrier, Water Rail, Woodcock and Sparrowhawk were only recorded during the early (pre- 2003) surveys.

Conversely several bird species were not recorded in any of the early years of surveys at the site (up to and including 2005) but have been regularly recorded since 2008 e.g. Blackcap, Chiffchaff, Goldfinch, and to a lesser extent Spotted Flycatcher and Long-tailed Tit. Some seed-eating species like Linnet and Reed Bunting have been absent since the early years of the bird survey work (2005 and earlier).

The decline in the regularity at which some species of open farmland have been recorded, and increase in the occurrence of birds typical of woodland edge is probably reflective of the changing and maturing habitats present on site.

Some of the observed changes are likely to due to chance e.g. Jackdaw and Black-headed Gull were recorded in early pre-construction surveys but not since that time. The habitats on site have not become any more unattractive for these species in this time – these species may occasionally occur at, or overfly, the Terminal site, but are infrequently recorded in the surveys.

Overall, species diversity has increased somewhat in recent breeding seasons. Breeding birds recorded in the 2012 survey are listed in Appendix 6.4.

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As with non-avian species, in addition to surveys, a detailed log of sightings of species of note at the Terminal site has been kept by site staff for several years. This log draws together the observations made by personnel of fauna, including birds, at and in the vicinity of the Terminal.

6.3.6 Fauna – Evaluation

Non-avian Fauna

Species of Conservation Interest

There has been no change in the level of protection afforded to faunal species under Irish wildlife legislation since 2003, though the conservation status of certain species has changed. Non-avian faunal species present on site are listed in Appendix 6.3 together with their level of protection (legal status) and their current conservation status, as listed in the Irish Red Lists and the EU Habitats Directive Article 17 status report (NPWS, 2013) where relevant.

Birds

There has been no change in the level of protection afforded to bird species under Irish wildlife legislation since 2003, however the conservation status of some species has changed. Bird species recorded on site between 2000 and 2012 are listed, along with their current conservation status, in Appendix 6.4

6.3.7 European Sites and Other Designated Conservation Areas

Legislation

The key legislative change in relation to flora and fauna since 2003 has been the implementation of new statutory instruments, the most relevant of which is SI 477 of 2011 European Communities (Birds and Natural Habitats) Regulations 2011, also the introduction of guidelines for planning and regulatory bodies in relation to appropriate assessment under Article 6(3) of the EU Habitats Directive, NPWS (2009, Rev Feb. 2010). For inspection purposes only. Consent of copyright owner required for any other use. European Sites and Other Designated Conservation Areas in the Locality

As described in the 2003 Terminal EIS, there are a number of designated conservation sites at varying distances from the Terminal. Potential direct and indirect effects of the Terminal development were considered in the 2003 Terminal EIS in relation to construction and operation. The Special Areas of Conservation (SACs) and Natural Heritage Areas (NHAs) that were listed in the 2003 Terminal EIS remain the same. No new sites have been added to the Natura 2000 network in the immediate vicinity of the Bellanaboy Bridge Terminal since 2003, however conservation objectives have now been developed for all European sites and these are set out below for sites in the vicinity of the Terminal.

The main changes from 2003 are: • Blacksod/Broadhaven Bay Special Protection Area (Site Code No 004037) the boundaries and qualifying interests for which have been since amended. • In the wider area, the intention to designate the West Coast SAC (Site Code 0002998), for Bottlenose Dolphin, was announced in 2012.

European and other designated conservation sites in the locality are included in Tables 6.2 and 6.3 respectively, together with their distances from the Terminal. Updated site synopses are provided in Appendix 6.2 for those sites for which a more recent version is available.

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Conservation Objectives for European Sites in the vicinity of the Terminal

Conservation objectives for the following European sites in the Natura 2000 network have been downloaded, as published, from the website of the National Parks and Wildlife Service of the Department of Arts, Heritage and the Gaeltacht. (http://www.npws.ie/ ).

Special Areas of Conservation (SACs) Glenamoy Bog Complex SAC (Site Code 0000500)

The site specific conservation objective for the Glenamoy Bog Complex SAC is to maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected:

• [1106] Salmo salar (only in fresh water) • [1230] Vegetated sea cliffs of the Atlantic and Baltic coasts • [1393] Drepanocladus (Hamatocaulis) vernicosus • [1395] Petalophyllum ralfsii • [1528] Saxifraga hirculus • [21A0] Machairs (* in Ireland) • [3160] Natural dystrophic lakes and ponds • [4010] Northern Atlantic wet heaths with Erica tetralix • [5130] Juniperus communis formations on heaths or calcareous grasslands • [7130] Blanket bogs (* if active only) • [7140] Transition mires and quaking bogs • [7150] Depressions on peat substrates of the Rhynchosporion

Carrowmore Lake Complex SAC (Site Code IE 0000476) The site specific conservation objective for the Carrowmore Lake Complex SAC is: to maintain or restore the favourable conservation condition of the Annex I habitat(s) and / or the Annex II species for which the SAC has been selected: • [1393] Drepanocladus (Hamatocaulis) vernicosus • [1528] Saxifraga hirculus For inspection purposes only. Consent of copyright owner required for any other use. • [7130] Blanket bogs (* if active only) • [7150] Depressions on peat substrates of the Rhynchosporion

Broadhaven Bay SAC (Site Code IE 0000472) The site specific conservation objective for the Broadhaven Bay SAC is: to maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected:

• [1140] Mudflats and sandflats not covered by seawater at low tide • [1160] Large shallow inlets and bays • [1170] Reefs • [1330] Atlantic salt meadows (Glauco ‐Puccinellietalia maritimae) • [8330] Submerged or partly submerged sea caves.

Slieve Fyagh Bog SAC (Site Code IE 0000542) The site specific conservation objective for Slieve Fyagh Bog SAC is to maintain or restore the favourable conservation condition of the Annex I habitat(s) and/or the Annex II species for which the SAC has been selected:

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• [7130] Blanket bogs (* if active only)

Special Protection Areas (SPAs) Carrowmore Lake SPA (Site Code IE 004052) The site specific conservation objective for the Carrowmore Lake SPA is: to maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for this SPA: • Larus canus [breeding ] • Sterna sandvicensis [breeding ]

Blacksod Bay / Broadhaven SPA (site code IE 004037) The site specific conservation objectives for the /Broadhaven SPA are: Objective: To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for this SPA:

• Gavia immer [wintering] • Branta bernicla hrota [wintering] • Melanitta nigra [wintering] • Mergus serrator [wintering] • Charadrius hiaticula [wintering] • Calidris alba [wintering] • Calidris alpina [wintering] • Limosa lapponica [wintering] • Numenius arquata [wintering] • Sterna sandvicensis [breeding ] • Wetlands

6.4 Characteristics of the Proposed Development

For inspection purposes only. The characteristics of the constructedConsent Terminalof copyright owner were required set for out any other in use. the 2003 Terminal EIS. Changes covered by this Supplementary Update Report in aspects of the operation and design of the Terminal and the overall site that are relevant in ecological terms, in the context of terrestrial flora and fauna, are in relation to:

• Discharges to water (storm water: increase to Suspended Solids Emission Limit Value) • Emissions to air (NOx Reduction - using Selective Catalytic Reduction SCR) • Noise emissions • Updated strategy for habitat and biodiversity enhancement measures in the western part of the site • Updated landscape design strategy, including in the context of ecological mitigation requirements.

During operation of the Terminal noise, waste water and air emissions would marginally increase. Clean run-off from the Terminal site will also be directed into local watercourses. Measures have been taken to minimise these effects. Details of changes are given in relevant sections of this Supplementary Update Report.

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6.5 Potential Impact of the Proposed Development

6.5.1 Method of Impact Assessment

There has been no change in the assessment criteria, or method of impact magnitude and significance assessment since 2003, albeit that reference texts have been superseded /updated as described above.

6.5.2 Consideration of Likely effects on Terrestrial Flora and Fauna

There is potential for the following activities to impact on terrestrial flora and fauna:

• Works associated with further construction activities on the Terminal • Works associated with the landscape planting of the site • The operation of the Terminal

Construction Activities on the Terminal

Potential impacts arising from the construction of the Terminal in terms of terrestrial flora and fauna were assessed in the 2003 Terminal EIS and whilst it is acknowledged that the duration of the overall disturbance period associated with construction has been greater than initially anticipated, there is no change to the level of overall predicted impact associated with construction to the level predicted in the 2003 Terminal EIS.

The level of site lighting in use during construction has created an upwards glow at night-time and it should be noted that several individual migratory seabirds of two species (Manx Shearwater, Puffinus puffinus and Storm Petrel, Hydrobates pelagicus ) have been found on site during migration periods. Most “strikes/landings” occurred during autumn 2008 when two Manx Shearwaters and six Storm Petrels were recovered. All but one of these birds was found to be healthy and they were released successfully at the coast in accordance with site protocols and best practice and as agreed with NPWS. In recent years the frequency at which these migrants are occurring at the Terminal has declined, and it is anticipated that when lighting associated with construction activities is switched off and the permanent lighting regime is in use the likelihood For inspection and purposes freq only.uency of migratory seabirds occurring on site Consent of copyright owner required for any other use. will diminish. During construction the impact level has been slight to moderate negative and this is predicted to reduce to negligible during the operational phase.

To put this in a wider context, any bright light in an otherwise dark night-time landscape, such as floodlights and security lights on dwellings and farm buildings, has the potential to attract migratory birds of this kind.

Some construction activities are ongoing, including pipeline works as well as those in connection with the permitted changes to the plant largely confined to the Terminal footprint.

Commissioning / Transitional Activities

For the early phase of hydrocarbon commissioning, when parts of the Terminal plant is run on natural gas from the national gas network, and before the production of gas from the Corrib field commences, it is proposed that treated surface water runoff from process areas and tanker delivery routes is discharged through the settlement ponds to a local ditch (discharged from the site via SW2). These transitional arrangements will remain in place until construction of the onshore section of the gas pipeline and associated water outfall pipeline has been completed, at which time discharges will be made as planned via the SW1 outfall off Erris Head.

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Site Landscaping Activities

These were included in the 2003 assessment, being the final stage of construction. Changes have been made to the original plans for landscape planting proposals in order to encompass more fully ecological mitigation commitments in terms of habitats and further biodiversity enhancement measures particularly in relation to the western section of the site. Measures will include the creation of areas of wetland habitat as well as additional planting of native species of deciduous trees and shrubs. The plans for the western fields were the subject of a planning amendment for which permission has been granted by Mayo County Council (MCC Reg. Ref 12/603).

Whilst there is no change in terms of temporary and short term impacts on flora and fauna during the works, the permitted habitat creation and enhancement measures will lead to an increase in biodiversity within the site in due course and are predicted to result in a slight positive impact in the long term.

Operation of the Terminal

Changes in relation to the operation of the Terminal are set out in other sections of this Supplementary Update Report. Potential sources of impact in ecological terms include: noise and light disturbance and storm water discharge effects on watercourses and the faunal species which utilise them - Otter, Common Frog and Smooth Newt. Aquatic ecology is dealt with separately, in Section 7 of this report.

Impacts associated with the operation of the Terminal on flora and fauna were assessed in the 2003 Terminal EIS, and it was concluded that the procedures and mitigation methods proposed at that time would result in the operation of the Terminal having negligible impact.

The proposed changes relevant to terrestrial flora and fauna are:

• Discharges to water (storm water: increase to Suspended Solids Emission Limit Value The proposed change will not give rise to an additional impact on terrestrial flora and fauna over and above that assessed in the 2003 Terminal EIS. Thus the impact assessment undertaken at that time remains valid.

• Emissions to air (NOx Reduction - using Selective Catalytic Reduction SCR). For inspection purposes only. The 2003 Terminal EIS predatedConsent of the copyright NRA owner guidance required for anydocu othermentation use. (Revision 1 2011, and the superseded first version) on air quality including sensitive ecosystems and so no detailed assessment on the effects of NOx emissions on vegetation was undertaken at that time. However, as the guidelines do not provide for an assessment of impacts on low value habitats such as those which are present on site and with a reduction in NOx emissions from that originally proposed, no change in impact on habitats and species present on the Terminal site is predicted.

• Lighting design – the consented minor changes (eg. MCC Reg. Refs. 11/56, 13/68) in lighting design since 2003 do not alter impact predictions made at that time.

Impacts on habitats in European sites and other designated areas in relation to storm water discharge and NOx emissions are considered below.

Potential Impacts on Surrounding Areas

The assessment of the proposed changes since the 2003 assessment upholds the conclusions reached at that time, in that the development will not affect the functioning of ecosystems, the habitats, flora and faunal diversity of adjoining afforested and blanket bog areas. There is therefore no change to the level of predicted impact set out in the 2003 Terminal EIS.

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Indirect Impacts – European and Other Designated Conservation Sites

The potential for impact on European sites as a result of the completion of construction, operation and maintenance of the Terminal arise only from indirect impacts in relation to water discharges, emissions to air, noise and light spillage.

The 2003 Terminal EIS concluded that the construction and operation of the Terminal was not anticipated to impact on the terrestrial habitats and constituent species of the nearby European sites and NHA, namely Glenamoy Bog Complex SAC, Carrowmore Lake Complex SAC and Slieve Fyagh Bog SAC and Pollatomish Bog NHA, These sites and others in the wider locality are listed, together with distances from the Terminal, in Tables 6.2 and 6.3.

The following is an assessment of the changes proposed and their potential to affect these and other sites.

• For a limited time during hydrocarbon commissioning using back feed gas from the BGE network, it is proposed that treated surface water runoff from process areas and tanker delivery routes is discharged through the settlement ponds to a local ditch (discharged from the site via SW2). These transitional arrangements will remain in place until construction of the onshore section of the gas pipeline and associated water outfall pipeline has been completed, at which time discharges will be made as planned via the SW1 outfall off Erris Head.

• Discharges to water (storm water: increase to Suspended Solids Emission Limit Value An increase of the suspended solids concentration to 30mg/l, associated with periods of heavy rainfall, will not give rise to any additional impact over that which has been experienced during the construction phase of the Terminal and which has been determined to not have a significant impact on the Bellanaboy River or Carrowmore Lake. The limit imposed by the Planning Authority for the construction phase of the project is 35mg/l of suspended solids.

• Discharges to water during the commissioning (transitional) phase are as stated above. As the proposed limit is less than that already imposed by Mayo County Council, and owing to the measures in place to control the quality of surface water leaving the site, no changes to water

quality in Carrowmore Lake are For anticipated, inspection purposes both only. during remainder of construction, during commissioning and during operation.Consent of copyright owner required for any other use.

Owing to the stringent controls in place and the quality of surface water leaving the site, no changes to water quality in Carrowmore Lake are anticipated during the remainder of construction, commissioning and operation of the Terminal. It should be noted that the habitats and species for which the Carrowmore Lake Complex SAC has been selected are terrestrial and would therefore not be subject to impact in the unlikely event that a sediment run-off incident should occur.

The Carrowmore Lake SPA (004052) and the Carrowmore Lake Complex SAC (0000476) will not be subject to direct or indirect impact as a result of the discharge of storm water. At all times compliance with the emission limit values for surface water enforced by the Planning Authority will be met, therefore no impact to any European site is anticipated.

In addition, no impact is anticipated, direct or indirect, on any European site as a result of the discharge of storm water from the Bellanaboy Bridge Gas Terminal.

• Emissions to air (NOx Reduction - using Selective Catalytic Reduction SCR).

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The 2003 Terminal EIS predated the NRA guidance documentation (Revision 1 2011, first version was undated) on air quality including sensitive ecosystems and so no detailed assessment on the effects of NOx emissions on vegetation was undertaken at that time.

Taking into consideration the distance from the Terminal and the NOx levels, no impact on any European or other designated conservation site resulting from emissions to air is anticipated.

As a result of the assessment, which takes account of the best scientific knowledge and the conservation objectives of each European site, it can be determined that the commissioning and operation of the Terminal either individually or when taken in combination with other plans or projects, is not likely to have a significant effect on a European Site.

Pursuant to the requirements of SI 477 of 2011 in relation to Article 6(3) of the EU Habitats Directive a Natura Impact Statement (NIS) has been prepared in relation to the operation of the Bellanaboy Bridge Gas Terminal to inform the appropriate assessment process. The NIS is appended to this Supplementary Update Report in Appendix A.

Table 6.2: European sites within 15km of the Bellanaboy Bridge Gas Terminal Designation Site Name Site Code Approximate Distance Glenamoy Bog Complex 0000500 1.6 km Broadhaven Bay 0000472 5.2 km Carrowmore Lake Complex 0000476 1.5 km Special Area of Slieve Fyagh Bog 0000542 1.6 km Conservation (SAC) Owenduff/Nephin Complex 0000534 6.4 km Bog Complex 0001922 7.2 km Mullet/Blacksod Bay Complex 0000470 7.6 km

For inspection purposes only. BlacksodConsent Bay/Broadhaven of copyright owner required for any 004037other use. 1.6 km

Special Protection Areas Carrowmore Lake 004052 2.4 km (SPA) Owenduff/Nephin Complex 004098 7.0 km Stags of Broadhaven 004072 10.0 km 004074 8.4 km

Table 6.3: Other designated conservation sites within 15km Designation Site Name Site Code Approximate Distance Pollatomish Bog 1548 1.4 km Glenturk More Bog 2419 3.0 km

Natural Heritage Area Ederglen Bog 2446 4.0 km (NHA) Tristia Bog 1566 6.0km Tullaghan Bay and Bog 1567 8.5 km Inagh Bog 2391 12.5 km

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Designation Site Name Site Code Approximate Distance Ramsar Site Blacksod Bay / Broadhaven 844 1.6 km

6.5 Do Nothing Scenario

The do nothing scenario is no longer relevant as the Terminal has been constructed.

6.6 Mitigation Measures

In Section 6 of the 2003 Terminal EIS recommendations were made for mitigation measures to protect habitats and species during construction, to enhance the remaining and reinstated habitats so that they would not only continue to support existing species but would increase the site’s biodiversity.

6.6.1 Mitigation Implementation to Date

Measures to Protect Faunal Species

During construction, measures required to protect faunal species (Badger, Otter, and Common Frog) have been implemented as recommended in 2003. Licences have been applied for and received from National Parks and Wildlife Service (NPWS) permitting Common Frog translocations so that they could be removed from danger / threat from construction and general activities and - in recent years - from the footprint itself.

Additional measures have been required as a result of permitted changes to the original design of the Terminal. For example, the construction of a double fence around the footprint where mammal proofing has been necessary to prevent entrapment of animals. Similarly at the settlement ponds where permanent mammal proofing has been installed, together with escape ramps and one way egress gates.

For inspection purposes only. In addition to the need for physicalConsent mitigation, of copyright other owner requiredmeasures for any otherhave use. been put in place to ensure best practice and the protection of species on and adjacent to the site (roads), including:

• Wildlife logs: these have been set up for reporting frog translocations, general faunal sightings and incidents such as road kills in close proximity to the site; • Best practice protocols have been put in place for dealing with frog translocations, injured / trapped protected species, for example the migratory seabird strikes referred to previously.

Enhancement Measures to Date

A number of enhancement measures have been put in place, including: • Frog breeding habitat enhancement: dams to enable ponding at intervals have been placed in some of the drains on site where not in the proximity of construction activities (Plate.12) • Bird nest box scheme • Bat box scheme • Pine Marten den box scheme

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Plate 12: Frog breeding habitat mitigation – dams in drain at Bellanaboy

Plate 13: Bird nest box inspection at Bellanaboy

For inspection purposes only. Consent of copyright owner required for any other use.

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Plate 14: Erecting Pine Marten den box at Bellanaboy in 2011

6.6.2 Mitigation Requirements During Landscaping and the Operation of the Terminal

General Mitigation Measures

Measures for the protection of habitats and species as set out in 2003 and in place for construction will need to continue and be maintained as at present. Consultation with National Parks and Wildlife Service (NPWS) will continue in relation to protected species. For inspection purposes only. Consent of copyright owner required for any other use. Habitat Reinstatement and Landscaping

The reinstatement strategy that has been developed and refined in tandem with the landscape strategy for the site will be implemented following removal of temporary construction facilities.

This includes those measures set out in Section 6 of the 2003 Terminal EIS under “Habitat Retention, Replacement and Landscaping” and further biodiversity enhancement measures such as wetland creation, planting of deciduous trees and scrub, and planting of suitable species - rich grassland have been incorporated into the reinstatement strategy in particular in the western part of the site, described above and in Section 13 of this report and which is the subject of a planning permission granted by Mayo County Council (MCC Reg. Ref 12/603). The inclusion of boardwalks in the permitted plans for the western part of the site will provide biodiversity educational potential going forwards as the wetland and deciduous scrub woodland habitats mature.

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6.7 Predicted Impact of the Proposed Development

6.7.1 The Terminal Site During Operation

The best available technology to reduce emissions to air and noise levels, appropriate lighting design to reduce spillage and the continuing application of robust mitigation measures to control surface water runoff sediment levels will ensure that impacts on terrestrial flora and fauna will be minimised. Further details are provided in Sections 2, Project Description and Sections 11 and 12.

Flora and Fauna

If the Terminal continues to be constructed and operated following the principles of mitigation described in this document, the overall impact of the development will be Negligible or Minor in terms of effects on fauna and habitats, with likely slight positive impacts in the long term as a result of biodiversity enhancement..

6.8 Monitoring

Ecological monitoring has taken place throughout the construction period at the Terminal site and will continue during the remaining construction, reinstatement and landscaping works, and during operation of the Terminal. Monitoring will be in accordance with the environmental monitoring programme, as revised, amended and updated. Monitoring will include: species mitigation, habitat reinstatement and creation (during and post reinstatement) and will be carried out by ecological specialists to ensure the successful and correct implementation of all measures. Consultation with NPWS will continue in relation to protected species. The frequency and duration of monitoring will be in accordance with the monitoring programme.

6.9 Reinstatement and Residual Effects

Habitat reinstatement and creation strategies, as planned and described above, will provide for the continued use of the site by resident species and an increase in biodiversity, in terms of habitats and species of flora and fauna both on site and in the immediate locality. It will also ameliorate those losses of pre-existing habitat on site. For inspection purposes only. Consent of copyright owner required for any other use.

However it should be noted that, despite the loss of habitat as a result of construction, the majority of plant species recorded within the study area between 2001 and 2003 were also recorded in 2013, with several additional species being recorded in 2013 resulting in a slight net increase in species diversity since 2003. Also to date has there been no significant impact on, or reduction in, faunal species occurring at the site. Indeed there has been an increase in the species diversity of non-avian vertebrates. Similarly bird species diversity has increased in recent breeding seasons.

No negative residual effects are anticipated therefore as a result of the reinstatement, following removal of temporary construction facilities, or landscaping of the site and the commissioning and operation of the Bellanaboy Bridge Gas Terminal.

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6.10 References

The following source references post date the 2003 Terminal EIS:

• European Communities (Birds and Natural Habitats) Regulations 2011 (S.I. No. 477 of 2011)

• IEEM 2006 Guidelines For Ecological Impact Assessment The Institute of Ecology and Environmental Management

• King, J.L., Marnell, F., Kingston, N., Rosell, R., Boylan, P., Caffrey, J.M., FitzPatrick, Ú., Gargan, P.G., Kelly, F.L., O’Grady, M.F., Poole, R., Roche, W.K. & Cassidy, D. (2011) Ireland Red List No. 5: Amphibians, Reptiles & Freshwater Fish . National Parks and Wildlife Service, Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.

• Lynas P., Newton S.F. & Robinson J.A. 2007. The Status of Birds in Ireland: An Analysis of Conservation Concern 2008-2013 . Irish Birds, 8: 149-167.

• Marnell, F., Kingston, N. & Looney, D. (2009) Ireland Red List No. 3: Terrestrial Mammals, National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin, Ireland.

• National Parks and Wildlife Service 2009 Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities Revised February 2010 Department of Environment, Heritage and Local Government

• National Parks and Wildlife Service. 2008. The Status of EU Protected Habitats and Species in Ireland. Conservation status in Ireland of habitats and species listed in the European Council directive on the conservation of habitats, flora and fauna 92/43/EEC . National Parks and Wildlife Service, Department of Environment, Heritage and Local Government.

• NPWS (2013) The Status of EU Protected Habitats and Species in Ireland. Species Assessments Volume 3, Version For 1.0. inspection Unpublished purposes only. Report, National Parks & Wildlife Service. Consent of copyright owner required for any other use. Department of Arts, Heritage and the Gaeltacht, Dublin, Ireland.

• National Roads Authority. 2004 Guidelines for assessment of ecological impacts of National road schemes. NRA, Dublin.

• National Roads Authority. 2009 Guidelines for assessment of ecological impacts of National road schemes. Revision 2. NRA, Dublin.

• National Roads Authority 2011. Guidelines for the Treatment of Air Quality During the Planning and Construction of National Road Schemes Revision 1 . NRA, Dublin.

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7 AQUATIC ECOLOGY

7.1 Introduction

This section of the Supplementary Update Report has been written by RSK Environment Ltd and deals with updates since 2003 in relation to the likely impacts of the development on the aquatic ecology of the Terminal site and its surroundings. This includes any updates to the baseline information around the two marine discharge points, i.e. the permitted outfall location off Erris Head (SW1) and the new proposed treated produced water discharge location (SW3) at the Corrib offshore manifold location. This section overlaps with other sections of the Supplementary Update Report as well as the Offshore EIS Supplementary Update Report 2010. Please refer to other sections of this report in respect of the following: • information on terrestrial flora and fauna (Section 6); • information on the mammals and other non-fish vertebrates of the area which use the watercourses (such as otter and amphibians), as well as descriptions of the aquatic vegetation associated with drains on site (Section 6); • results of the aquatic flora surveys (Appendix 6.1); • update on information on the effluent discharge at the outfall (treated surface water) and Corrib manifold (treated produced water) (Section 10); and • hydrology and drainage from the site to the surrounding waterbodies, and potential impacts associated with same, Section 9 of this report. This section has been prepared by RSK Environment Ltd.

7.2 Study Methodology

This section contains the following: • An update of the baseline information presented in the 2003 Terminal EIS; and For inspection purposes only. • A review and re-assessmentConsent of copyright owner of therequired potentia for any otherl impacts use. likely to arise as a result of the future activities associated with the Terminal development. The review has drawn on the data and assessment presented in the 2003 Terminal EIS, and the various baseline marine studies, surveys and modelling activities that have been undertaken since 2003. Results of the studies carried out in the vicinity of the Terminal are summarised in Section 7.3. The main findings of those studies which relate to the marine aquatic ecology in the vicinity of the outfall location and the Corrib manifold are also summarised in Section 7.3, however, more detailed information is also available in the 2010 Offshore EIS Supplementary Update Report.

7.2.1 Baseline Studies and Surveys

Freshwater Studies incorporating biological and chemical analyses of the watercourses in the locality of the Terminal site, electrofishing operations in the northern region of the Ballina fishery area and kick sampling for macro invertebrates have been carried out. Specifically these studies include: • surface water samples for the determination of river water quality;

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• standard kick sampling for macro invertebrate analysis (also undertaken on watercourses to the north of the Terminal (Leenamore River) as part of the monitoring for the onshore pipeline); • electrofishing sampling during Terminal earthworks construction (2004, 2005 and 2007) also undertaken on watercourses to the north (Leenamore River) and north east () of the Terminal in 2012 as part of the construction monitoring programme for the onshore pipeline, and as monitoring for the Water Framework Directive (WFD); • seine netting surveys during Terminal earthworks construction (annually until 2007), and; • gill netting surveys undertaken at locations on Carrowmore Lake in 2011 as part of monitoring for the Water Framework Directive (WFD) All surveys were carried out in consultation with Inland Fisheries Ireland (IFI) (then the North Western Regional Fisheries Board (NWRFB)), who are the fisheries protection authority for the area. Additional consultation took place with the Marine Institute, Salmon Management Services Division, and data from surveys were provided to the Institute. The kick sampling for macro invertebrates and electrofishing was conducted under licence from IFI. Gill netting surveys as part of ongoing WFD monitoring has been undertaken directly by IFI. Marine The marine surveys undertaken since the 2003 Terminal EIS are detailed in the 2010 Offshore EIS Supplementary Update Report, but in the case of the most recent survey (2013) of seawater quality, are included within Section 10 of this report. A brief summary of the status of the aquatic ecology at the SW3 and SW1 locations is provided in Section 7.3.

7.3 Receiving Environment

7.3.1 Aquatic Habitats on the Terminal Site

As described in the 2003 Terminal EIS the aquatic habitats on site have been reduced

due to the construction of t he Terminal. For inspection purposesHowever, only. some habitats have been created including: Consent of copyright owner required for any other use.

• settlement ponds; • dams to enable ponding at intervals have been placed in some of the drains on site to provide frog breeding habitat - where not in the proximity of construction activities; and • Terminal perimeter drainage ditches. The final landscaping of the site will also include some additional wetland habitat creation in the western fields area of the Terminal site, as shown in Figure 13.1. These wetland areas will be interconnected by a series of vegetated swales, as well as being connected to the overall site drainage network, which will discharge to a channel downstream of the settlement ponds. These wetland areas will include a boardwalk and stone track for access to allow monitoring to take place. The drainage from the Terminal area in general continues to be to the south west, to the Bellanaboy River and Carrowmore Lake (see Figure 7.1).

7.3.2 Aquatic Habitats in the Wider Area

Freshwater habitats The freshwater aquatic habitats remain as described in the 2003 Terminal EIS.

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Marine habitats There are no changes to the offshore habitats, however as described above studies have been undertaken since 2003 to further characterise the marine habitats in the areas of the Corrib Field and Erris Head outfall. These studies are described in detail in the 2010 Offshore EIS Supplementary Update Report. Benthic communities in the vicinity of the Corrib manifold are typical of those expected for the area and the substrate type. The macrofaunal community is characterised by relatively high species diversity. No species or habitats were of particular conservation interest. The benthic macrofaunal communities present in the vicinity of the Erris Head SW1 outfall are of moderate to high diversity, generally with moderate abundance and a high degree of evenness, with low dominance by single species, indicating a stable seabed ecosystem. Similarly to the SW3 location, no species of particular conservation value were recorded. Amphibians Breeding sites of the common frog (Rana temporaria) are located within the area and the common frogs remain abundant. Since 2003, there have been two sightings of the smooth newt (Triturus vulgaris). Amphibians are discussed in more detail in Section 6.3.4. Otter Otters (Lutra lutra) continue to be present throughout the area including drains on the Terminal site itself, particularly in the spring when frogs form a significant part of their diet. The presence of otters is discussed further in Section 6.3.4. Fish Bellanaboy River System (Carrowmore Catchment) A number of surveys were carried out between 2004 and 2007 to ascertain the status of the fish population (species, locations, size, age and numbers (density)) and life cycles in the aquatic environment surrounding the Terminal site. The survey reports for the electrofishing and seine netting surveys carried out in 2004, 2005 and 2007 are included in Appendices 7-1 -3. The fishing survey site locations are shown in Figure For inspection purposes only. 7.1. Key trends in the surveyConsent of results copyright ownerare requiredsummarised for any other in use. the subsections below.

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Figure 7.1: Electrofishing site locations including identification of the production area and models used in estimates. (Source: de Eyto et al., 2007)

Electrofishing In the locations surveyed in 2004 (Poole et al., 2004) (Appendix 7-1), 2005 (Poole et

al., 2005) (Appendix 7-2) and 2007 For inspection(de Eyto purposes et al only.., 2007) (Appendix 7-3) salmon Salmo salar, and brown trout, SalmoConsent oftrutta copyright, 3-spineowner required stickleback for any other use. (Gasterosteus aculeatus),

minnow (Phoxinus phoxinus), eel (Anguilla anguilla), and brook lamprey (Lampetra planeri), were recorded. However in all sites sampled minnow, eel, and brook lamprey were scarce. Catches of 0+ and 1+ salmon in the Bellanaboy catchment indicate a reduction in smolt production after 2005 and predicted a slight recovery by 2009. The recommendation of the 2007 report was that every effort be made to ensure the continued successful spawning and recruitment of salmon in the upper Bellanaboy catchment. Seine netting Seine netting carried out in Carrowmore Lake in 2004, 2005 and 2007 (Appendices 7- 1-3) indicated that numbers of salmon and trout were generally low compared to reported studies in the littoral zones of other lakes. Carrowmore Lake has a very large littoral area by comparison with other lakes (in relation to the overall size of the lake), which could account for the relatively low densities recorded. The density of salmon, trout and 3-spined stickleback remained generally unchanged over the years of the survey period. Fish surveys provide one biotic index for assessing the ecological quality of river systems, and the results indicated that the quality in the Bellanaboy catchment remained high enough to support populations of salmon and trout at the time of the surveys.

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Gill netting Gill net surveys were carried out at 18 locations throughout Carrowmore Lake in summer 2011 (Appendix 7-4). A total of five fish species were recorded from a total of 501 fish captured over the two night survey period. Brown trout, 3-spined stickleback, salmon, minnow (Phoxinus phoxinus) and eel were all recorded with brown trout (dominant in terms of biomass) and 3-spined stickleback (dominant in terms of species abundance) making up the majority of the species captured. Based on the fish populations present during this survey, Carrowmore Lake was assigned a High ecological status. Leenamore River System Monitoring of the local watercourses for fish was undertaken by the Aquatic Services Unit of University College Cork (UCC) in 2012 and 2013 -detailed results for 2013, however, were not available at the time of writing this EIS Supplementary Update Report). This work targeted those watercourses that could potentially be impacted by the construction of the onshore pipeline. Five sites were studied (three on the Leenamore River including up and downstream of the confluence with the Terminal Stream), and at locations on the Terminal Stream itself and the Forest Stream (see Figure 7.2)

For inspection purposes only. Consent of copyright owner required for any other use.

Figure 7.2: Locations of electrofishing and macro invertebrate monitoring sites in watercourses immediately north of Bellanaboy Bridge Terminal (Source: UCC Leenamore Study).

The data from the 2012 electrofishing surveys and macro invertebrate sampling on the Leenamore River are presented in Appendix 7.5, and summarised in the following

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section. This study, and the WFD monitoring on the Glenamoy River (below) has been included to help provide additional information regarding fish populations in rivers and streams in the wider area around the terminal site, however there are no proposed discharges to these rivers from the terminal, and as such no environmental impacts are envisaged as a consequence of the future terminal operations. Electrofishing Electrofishing was carried out at two locations on the Leenamore (Site 1 and 2) upstream and downstream of the confluence with the Terminal stream. Three species were recorded at Site 1 (salmon, trout and 3-spined stickleback, while at Site 2 only trout were recorded. At the time it was considered likely that eels would also be present on the Leenamore, however they were not recorded. Subsequently, electrofishing on the Leenamore River during construction of the inlet crossing in 2013 confirmed the presence of eels. Salmon was not recorded in 2013. The 2012 survey was the first occasion on which salmon have been recorded on the Leenamore River (previous surveys have been undertaken, reported in the 2010 Onshore Pipeline EIS). This could be due to the fact that previous surveys concentrated effort further upstream, but it is also possible that the 2007 ban on drift netting at sea and draft netting at the mouth of the Sruwaddacon has resulted in an increase in salmon numbers returning to the system, including the lower reaches of the Leenamore. Glenamoy River System Electrofishing A single site was surveyed by electrofishing on the Glenamoy River as part of the wider WFD monitoring of rivers in 2012. The full report of the WFD survey programme of rivers in the Western Basin District (which includes the Glenamoy) is included as Appendix 7-6. The survey site was approximately 4km upstream of the point where the Glenamoy River enters the Sruwaddacon Estuary. A total of 4 species of fish were recorded, in order of abundance as follows: Salmon, eel, brown trout and 3-spined stickleback. Based on the fish populations present in 2012, the ecological status of the Glenamoy River at the location sampled is considered Good with a confidence of 60%. For inspection purposes only. Macro invertebrate AssemblagesConsent of copyright owner required for any other use.

The 2003 Terminal EIS included data on macro invertebrates, comparing the number of faunal groups identified at a particular location against a biological index, in this case the Q-index to estimate pollution and assess water quality. The Quality Rating System (Q-Index) developed by the EPA rates the overall water body quality status based on the macro-invertebrate assemblage as predictable assemblage responses to changes in water quality enables their use as biological indicators of water quality. The Q-value index is calculated and the quality of the stream classified as indicated in Table 7.1. Table 7.1: Classification of Water Quality in relation to Q-Value Index Biotic Index Quality Status Quality Water WFD Class Quality Status Q5, Q4-5, Q4 Unpolluted Class A Good-Fair High-Good Q3-4 Slightly polluted Class B Fair- Moderate Doubtful Q3, Q2-3 Moderately Class C Doubtful- Poor polluted Poor Q2, Q1-2, Q1 Seriously polluted Class D Poor-Bad Bad

During 2005, a single specimen of Ephemera dancia was recorded from the Muinginguan River approximately 500 m upstream from the confluence with the

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Bellanaboy. This species is considered an indicator of relatively good water quality and may indicate a change in trophic or pH status of the river. However, no firm conclusions were given due to the fact that it was an isolated specimen (Poole et al, 2005). The report summarising the data collected in 2005 (Poole et al., 2005) concluded that no impact was detectable on the invertebrate community in the Muingingaun River from the Terminal development. Since 2005 further studies on macro invertebrates in the local water courses have been undertaken. . The results of these surveys are described below. Further kick-sampling surveys were conducted during the spring and autumn seasons during 2012 at locations on the Leenamore River and Terminal and Forest Stream (Appendix 7.5). The locations for these sampling activities are shown in Figure 7.2. The findings of this study have been included in order to provide some additional information regarding the macrofaunal assemblages of watercourses in the wider area around the terminal site, however there are no proposed discharges to these rivers from the terminal, and as such no environmental impacts are envisaged as a consequence of the future terminal operations. The majority of sites sampled for macro invertebrates in both seasons fell into Q-value categories 4-5, indicating fair-good water quality. No sites were recorded as being less than good on the WFD water quality status scale, which would tend to indicate that these watercourses were in a healthy overall status, using macro-invertebrate assemblages as an indicator of water quality. Water Quality In 2009, a new statutory instrument European Communities Environmental Objectives (Surface Waters) Regulations 2009 (SI No. 272 of 2009) (later amended by (S.I. No. 327/2012)) was published which brought the requirements of Directives into Irish law:

• 2008/105/EC on environmental quality standards in the field of water policy;

• to give further effect to Directive 2000/60/EC establishing a framework for Community action in the field of water policy; and For inspection purposes only. Consent of copyright owner required for any other use. • 2006/11/EC on pollution caused by certain dangerous substances discharged into the aquatic environment of the Community.

Of relevance to the Terminal development, the Regulations require:

• the establishment of legally binding quality objectives for all surface waters and environmental quality standards for pollutants;

• the examination and review where necessary of existing discharge authorisations by Public Authorities to ensure that the emission limits laid down in authorisations support compliance with the new water quality objectives/standards;

• the classification of surface water bodies by the EPA for the purposes of the Water Framework Directive; and

• the establishment of inventories of priority substances by the EPA.

As a result of the introduction of these regulations, new water environmental quality standards (EQS’s) for the surface waters around the Terminal development were

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established. Relevant standards can be found in Appendix 7--7, along with the results of the monthly water monitoring carried out by Mayo County Council at two locations on the Bellanaboy River and a location on Carrowmore Lake since 2005. This data has been presented and discussed at the Terminal Project Monitoring Committee (PMC) meetings which have been held on a regular basis since Terminal construction activity commenced. Water quality monitoring data from locations on Carrowmore Lake and Bellanaboy River has been collected for a number of years, and the latest data (2010-2013) has been summarised to form a baseline for the purposes of this Supplementary Update Report. This recent period is considered most relevant as it does not include the peak periods of earthworks and construction on the Terminal site, as was the case in some of the preceding years. As such this period is considered to be representative of baseline conditions. Data is summarised for winter and summer months to correspond with maximum and minimum flow rates. The data is summarised below. The results of the surface water monitoring (summarised 2010-13 Mayo County Council water quality data (Appendix 7.7) shows that the surface waters surrounding the Terminal (Bellanaboy and Carrowmore Lake) meet most of the new EQS’s with the exception of total phosphorus and ammonia which exceed the EQS during some of this period. During the earthworks phase of the Terminal construction specific ground conditions (mineral soils) were encountered, which when, coinciding with heavy rainfall, resulted in surface runoff containing elevated levels of suspended solids including total aluminium. An electro-flocculation treatment plant (Axonics) was installed along with temporary retention ponds to deal with this particular issue. For the remainder of the final landscaping period of the Terminal it is proposed to install temporary water treatment technology to aid in the control suspended solids, and following the completion of construction on site the temporary water treatment facilities will be demobilised. During construction works the discharge limits for suspended solids in surface water from the Terminal site (discharged via the storm water settlement ponds) was set by Mayo County Council at 35 mg/l. While there have been occasional exceedances, for the majority of the time the monthly monitoring has recorded levels well within these For inspection purposes only. limits. During operation ofConsent the Terminalof copyright owner an required emission for any otherlimit use. value of 30 mg/l has been proposed for total suspended solids, which is an increase from the IED Licence ELV of 5 mg/l. A study of the water quality of Carrowmore Lake and its tributaries was undertaken during 2004 and 2005 by the NWRFB (NWRFB, 2005). At this time the lake was found to be strongly eutrophic. The Bellanaboy River catchment was found to have the highest catchment phosphorous export rate, while ammonia levels were also elevated at a number of stations sampled. Water quality in both the Bellanaboy and Carrowmore Lake at this time appeared to be deteriorating with ortho-phosphate levels in the streams and chlorophyll and ortho-phosphate concentrations in the lake both giving rise to concern. Appendix 7-8 shows the Water Framework Directive (WFD) waterbody status report, produced as part of the River Basin Management Plan (RBMP) for the Carrowmore catchment for 2010. This provides a range of information about the overall health of the waterbody. In 2010 the ecology of the waterbody was described as being of moderate status, with good physico-chemical status. Eutrophication (presented in the 2010 RBMP) was considered to be at “at risk” status in 2008. Results at the time indicated that the Bellanaboy River was tending towards a moderately polluted status. The high phosphorus measured in the Bellanaboy provided evidence for a deterioration in water quality and trophic status. Annual maximum chlorophyll concentrations of 46 µg/l during 2004 categorized the lake as

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being strongly eutrophic. This was thought to be due in most cases to excess input of phosphorous to the catchment from landuse practices. It was determined that excessive siltation and phosphorous run-off in the upper areas of the catchment was a critical factor in the decline of the habitat value of this tributary at this time. The levels of suspended solids in the watercourses in the Bellanaboy catchment are generally relatively high naturally, however monitoring of fish, macro invertebrates and water quality parameters (as mentioned the most recent measured parameters on the Bellanaboy and Carrowmore Lake) indicate that the aquatic environment remains healthy and that the environmental quality status is improving. Offshore Fauna Offshore fauna are described in the 2010 Offshore EIS Supplementary Update Report and confirmed by studies undertaken since publication of the 2001 Offshore EIS and 2003 Terminal EIS. These surveys highlight the overall stability of the benthic communities and moderate to high species diversity of the seabed habitats in the areas of the Corrib Manifold (SW3) and Erris Head (SW1) outfall locations, as well as reflecting the lack of anthropogenic inputs with levels of contaminants consistent with published oceanic background concentrations.

7.3.3 Evaluation – Receiving Environment

Species of Conservation Interest Mammals Protected mammal and amphibian species recorded as present, and which utilise the freshwater ecosystem are described in Section 6. Fish Noting the gradual improvement in the overall health of the system as a whole, the streams and rivers in the vicinity of the Terminal site should continue to be classed as highly sensitive receptors, including the flora and fauna found within them. The nursery areas for trout and salmon, as with the whole river ecosystem, are sensitive to disturbance or excessive suspended solids. Therefore, it is necessary to ensure For inspection purposes only. protection of the systemConsent as aof copyrightwhole. owner It shouldrequired for beany othernoted use. that high levels of suspended solids naturally occur in these streams. Trout were found in all sampled locations and salmon at sampling locations on the Carrowmore, Leenamore and Glenamoy catchments between 2004-7, 2011, and 2012 giving a further indication of the importance and improving health of the whole freshwater ecosystem. Three lamprey species are found in Ireland, all of which are protected under the European Union Habitats Directive. The Bellanaboy River hosts a population of Brook Lamprey an Annex II species under the EU Habitats Directive. The Atlantic Salmon and the lamprey species are listed on Annexes II and V of the EU Habitats Directive. Annex II lists animal and plant species of community interest whose conservation requires the designation of special areas of conservation; Annex V lists animal and plant species whose taking in the wild and exploitation may be subject to management measures. Freshwater macro invertebrates In general, the freshwater macro invertebrate species identified in 2005 were typical of running water and the assemblages recorded would tend to indicate a standard of good quality status based on the Q value on the WFD scale.

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Marine species Protected marine species are described in the 2010 Offshore EIS Supplementary Update Report, which describes the impacts on marine flora and fauna as negligible (and may not even be observable at any significant distance from the point of discharge). The relocating of the discharge point from the SW1 treated surface water outfall off Erris Head, to the SW3 location at the Corrib subsea manifold in significantly deeper water would increase the levels of dispersion, such that any impacts will be further reduced.

7.3.4 European and Other Designated Sites in the Wider Locality

Designated conservation sites in the vicinity of the Terminal, and the potential direct and indirect effects of the Terminal development on these sites were considered in the 2003 Terminal EIS. An update on this and associated further detail is set out in Section 6 of this Supplementary Update Report and Natura Impact Statement (Appendix A). In the wider area, the intention to designate the West Connacht Coast SAC (Site Code 0002998), for bottlenose dolphin, was announced in 2012. At its closest boundary the West Connacht Coast SAC is 1 km from the outfall discharge (SW1) location and 43.1 km from the manifold discharge (SW3) location. As a result of the assessment, which takes account of the best scientific knowledge and the conservation objectives of each European site, it can be determined that the commissioning and operation of the Terminal either individually or when taken in combination with other plans or projects, is not likely to have a significant effect on a European Site.

7.4 Characteristics of the Proposed Development

7.4.1 During Construction

The characteristics remain as stated in the 2003 Terminal EIS.

7.4.2 During Commissioning

Storm water will continue to be discharged through the settlement ponds at the south- western corner of the Terminal site. For the early phase of hydrocarbon For inspection purposes only. commissioning, when partsConsent of the of copyrightTerminal owner plant required is for run any other on use.natural gas from the national gas network, and before the production of gas from the Corrib field commences, it is proposed that treated surface water runoff from process areas and tanker delivery routes, after treatment, is routed and in this way continue to be discharged through the settlement ponds to a local ditch (discharged from the site via SW2). These transitional arrangements will remain in place until construction of the onshore section of the gas pipeline and associated water outfall pipeline has been completed, at which time discharges will be made as planned via the SW1 outfall off Erris Head.

7.4.3 During Operation

The discharge of treated produced water will take place at the Corrib offshore manifold location. A biocide will be added to the treated produced water stream. Only treated surface water runoff from process areas and tanker delivery routes will now be discharged off Erris Head. The storm water management system has been enhanced. In the event of a fire or a spill etc, analysers in the Emergency Holding Tank can automatically divert the discharge prior to it entering the settlement ponds. The retained water can then be pumped back to the Open Drain Sump for subsequent onsite treatment. It is proposed to increase the suspended solids limit from 5mg/l to 30mg/l in the storm water discharge stream (storm water discharge at 30 mg/l was assessed in the 2003

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Terminal EIS and no significant impact identified). This proposed increase will set the suspended sediments ELV more at a level that can be achieved in the context of the naturally occurring levels while not resulting in exceedences of European environmental quality standards in the receiving water bodies (as evidenced in the monitoring undertaken by Mayo County Council (Appendix 7-7). Maximum levels of suspended solids in the storm water leaving the terminal site (averaged over a number of years (including those during major earthworks) have been well within the proposed ELV of 30mg/l. Surface Run-Off Collected in Open Drains and Perimeter Drains The characteristics remain as stated in the 2003 Terminal EIS. Surface Run-off Collected in Enclosed Drains The characteristics remain as stated in the 2003 Terminal EIS. Discharge of Treated Produced Water Apart from the additional pumps and biocide injection there are no changes to the produced water treatment system at the Terminal, however, it should be noted that the discharge of the treated produced water will no longer be connected to the discharge system for treated surface water system, and the two systems are segregated. The changes in discharge location for produced water are discussed in Section 2. The treated produced water from the produced water treatment plant will initially be routed into a collection sump from where it can be recirculated for further treatment if necessary or routed into the discharge sump, from where it will be pumped offshore via available spare cores in the umbilical. Should water production exceed the capacity of the available spare core(s), excess treated produced water will be tankered offsite to a licensed waste water disposal facility. A biocide is now proposed to be injected into the treated produced water stream as it enters the umbilical core to to prevent biofouling on the inner walls of the core. The details of this process are discussed further in Sections 2 and 10.

7.5 Potential Impact of the Proposed Development

7.5.1 During the Remainder of Construction For inspection (Landscaping), purposes only. Commissioning, and Operations Consent of copyright owner required for any other use.

The Terminal Site The only potential source of impacts on local watercourses during remaining construction works and operation is the surface water and storm water run off from areas of the Terminal site. As set out in Section 7.4.2 above, a transitional arrangement is proposed for the discharge of treated surface water during the early phases of hydrocarbon commissioning, whereby the treated drainage water from process areas and tanker delivery roads will be routed via the storm water settlement ponds to be discharged to the south west Terminal drain (SW2). It is proposed that this arrangement will remain in place until the outfall pipeline is completed (the onshore section of the outfall pipeline is currently being constructed alongside the Corrib onshore pipeline to link with the already constructed offshore gas pipeline and outfall pipeline at Glengad). Storm water collection and discharge from non-contaminated areas via SW2 will be unaffected. Therefore, during this early part of the commissioning phase there is potential under exceptional circumstances for contaminants to be released into local watercourses. However, provided successful treatment in the drainage water treatment plant and appropriate management of the drainage stream prior to discharge, no changes to water quality in Carrowmore Lake are anticipated, either during remainder of construction, commissioning, or during operation.

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It is considered that an increase of the suspended solids concentration to 30mg/l, associated with periods of heavy rainfall, will not give rise to any additional impact over that which has been experienced during the construction phase of the Terminal and which has been shown through monitoring carried out by and on behalf of Mayo County Council not to have had a significant impact on the Bellanaboy River or Carrowmore Lake. This will bring the suspended solids limit more in line with that imposed by Mayo County Council for the construction phase of the project (35mg/l), which level was assessed in the Terminal EIS (2003 ).Monitoring of all surface water discharge streams leaving the Terminal site will continue during the commissioning phase. The procedures and methods applied will result in the development having a negligible impact on surrounding areas. Impacts on Offshore Areas The predicted impacts on the offshore areas or marine aquatic environment are discussed in Section 10.7 of this report. Worst Case Scenario Due to the design of the drainage system and the capability of retaining contaminated fire water / drainage water within the Terminal, the operation of the Terminal should not lead to significant impact on freshwater ecology. Under a “worst case scenario” such as a major pollution incident or fire there is potential for impact on the freshwater ecology through the escape of contaminated water to local water courses. However, the detection and control arrangements (rerouting to used firewater retention system in the event of Total Carbon/Total Organic Carbon detection in the incoming stream) provided around the emergency holding tank (EHT) in compliance with the conditions of the site’s Industrial Emissions Licence and as described in Section 9 of this report significantly reduces the likelihood of damages to nearby watercourses resulting from an emergency scenario at the Terminal that involves the drainage system.

7.6 Do Nothing Scenario

The do nothing scenario is no longer relevant as the Terminal has been constructed.

7.7 Mitigation Measures

For inspection purposes only. 7.7.1 General Consent of copyright owner required for any other use.

Measures for the protection of aquatic habitats and species, as set out in the 2003 Terminal EIS and in place for construction will continue and be maintained as at present. As such there are no changes from the 2003 Terminal EIS.

7.7.2 Protection of Natural Flows and Hydrology

The mitigation measures relating the protection of natural flows and hydrology are described in Section 9.4 of this report.

7.7.3 Habitat Retention, Replacement and Landscaping

The strategy referred to in the 2003 Terminal EIS is being developed for the final landscaping of the site, and will be implemented in tandem with the removal of temporary construction facilities. This includes those measures set out in Section 6 of the 2003 Terminal EIS and further biodiversity enhancement measures including wetland creation, in particular in the western part of the site as can be seen in the updated landscape drawing (Figure 13.1).

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7.7.4 Construction Phase

The mitigation measures relating to surface water drainage during the construction phase is described in Section 9.4.1 of this report.

7.7.5 Commissioning Phase

The mitigation measures relating to surface water runoff from process areas during commissioning is described in detail in Sections 2 and 10. The surface water treatment plant will be fully commissioned before general facilities commissioning, and will treat the water to limits set by the Industrial Emissions Licence, ensuring no significant impact on the receiving environment. The drainage systems also allow for containment and retention of potentially contaminated water in the event of an incident, this is achieved by continuous monitoring of wastewater streams using detectors for total carbon and total organic carbon, which, if detected in sufficient quantities, will reroute storm water to the used firewater ponds. This will also allow for early identification in the event of a failure in any of the treatment / separation processes.

7.7.6 Operational Phase

With the exception of the strengthening of the ability to contain contaminated water at the EHT in the event of an incident, the mitigation measures will remain as stated in the 2003 Terminal EIS.

7.7.7 Treatment of process/produced water

The treatment of the produced water that will be discharged offshore at the Corrib subsea manifold location is described in Section 10.6 of this report.

7.8 Predicted Impact of the Proposed Development

The continuing application of robust mitigation measures to control surface water runoff from the Terminal site during the remaining construction activities and throughout its operations, in particular with regards to the discharge of suspended sediment concentrations, will ensure that impacts on aquatic flora and fauna will be avoided or For inspection purposes only. minimised. Consent of copyright owner required for any other use.

The impacts of the treated produced water in the offshore field are discussed in Section 10.6 of this report and in the 2010 Offshore EIS Supplementary Update Report. The impacts related to the discharge of treated surface run off via the water outfall pipe to the permitted outfall off Erris Head are similarly described in Section 10 and in the 2010 Offshore EIS Update Report. If the current and planned mitigation and approach to surface water management are applied, the overall impact of the development will be Negligible or Minor in terms of effects on aquatic ecology, with likely slight positive impacts in the long term as a result of biodiversity enhancement, in particular the creation of wetland habitat.

7.9 Monitoring

Monitoring of the aquatic environment in the vicinity of the Terminal site is taking place, and will continue. Ambient monitoring of the local receiving surface waters will be carried out using the Small Stream Risk Scoring (SSRS) method. SSRS is a biological risk assessment system developed by the EPA and Western River Basin District (WRBD) for detecting potential sources of pollution in rivers. This monitoring will support the objective of the Water Framework Directive that all water bodies will achieve ‘Good’ status by 2015.

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The monitoring uses aquatic insects and other macro invertebrates as continuous monitors of water quality. It is proposed that 3 locations be monitored biannually (two within a drainage channel within the Terminal, and one downstream of the SW2 discharge location). This monitoring will be in addition to regular ambient water quality monitoring of the watercourses and surface water within the terminal drainage channel prior to discharge, which would be undertaken as conditions of the Industrial Emissions Directive consent. All monitoring will be carried out by suitably trained individuals including aquatic ecology specialists where necessary, to ensure the integrity of the sampling, analytical and reporting techniques. Ongoing offshore monitoring is described in Section 10 and in the 2010 Offshore EIS Supplementary Update Report.

7.10 Reinstatement and Residual Effects

7.10.1 Terminal Site

As set out in the 2003 Terminal EIS, suitable habitat replacement and creation should allow for an increase in the representation of flora and faunal species in the area and ameliorate losses of existing habitat on site.

7.10.2 Wider Area

Residual effects will remain as stated in the 2003 Terminal EIS.

7.10.3 Offshore Area

Residual effects will remain as stated in the 2003 Terminal EIS.

7.11 References

The following references are added to those already provided in the 2003 Terminal For inspection purposes only. EIS: Consent of copyright owner required for any other use.

de Eyto, E., Poole, R., Cooney, J., Sweeny, D., and M. Hughes (2007). Results of a survey of the freshwater salmonid habitat of sub-reaches within the Owenmore River System. North Western Regional Fisheries Board, Ballina. Commissioned Report by Shell E&P Ireland Ltd. Kelly, F.L., Connor, L., Morrissey, E., Wogerbauer, C., Matson, R., Feeney, R. And Rocks, K. (2012) Water Framework Directive Fish Stock Survey of Carrowmore Lake, June 2011. Inland Fisheries Ireland, Swords Business Campus, Swords, Co. Dublin, Ireland. Kelly, F.L., Matson, R., Connor, L., Feeny, R., Morrissey, E., Wogerbauer, C., and Rocks, K. (2013) Water Framework Directive Fish Stock Survey of Rivers in the Western River Basin District. Inland Fisheries Ireland, Swords Business Campus, Swords, Co. Dublin, Ireland. NWRFB (2005). An examination of the causes and factors related to the recent eutrohication of Carrowmore Lake. Internal Report, Ballina referenced in Poole, R., de Eyto, E., Kennedy, B., & Dillane, M (2005) Results of survey of the freshwater salmonid habitat of sub-reaches within the Owenmore River System. North Western Regional Fisheries Board, Ballina. Commissioned Repoty by Shell E&P Ireland Ltd. Poole R., Kennedy, B., O ‘Hea, B. & Dillane, M. (2004). A baseline survey of the freshwater salmonid habitat of sub-reaches within the Owenmore River System. North

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Western Regional Fisheries Board, Ballina. Commissioned Report by Shell E&P Ireland Ltd. Poole, R., de Eyto, E., Kennedy, B., & Dillane, M (2005) Results of survey of the freshwater salmonid habitat of sub-reaches within the Owenmore River System. North Western Regional Fisheries Board, Ballina. Commissioned Report by Shell E&P Ireland Ltd.

For inspection purposes only. Consent of copyright owner required for any other use.

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8 SOILS, GEOLOGY AND HYDROLOGY

8.1 Introduction

This section deals with the solid geology, superficial geology and soils underlying the Bellanaboy Bridge Terminal Site and the influence of these on the hydrogeology of the site. The bulk of construction of the Terminal took place during the period 2005 – 2010, and the facilities are substantially complete. The landscaping of the wider Terminal site will be carried out as the pipeline construction and Terminal start up activities are completed. The potential and predicted impacts of the development on the geological and hydrogeological environment, were assessed in the 2003 Terminal EIS and where appropriate are reconsidered as part of this Supplementary Update Report. This section has been prepared by RSK Environment Ltd.

8.2 Study Methodology

In addition to the site investigations carried out prior to construction, further data has been acquired at the site during the construction of the Terminal. The results of these investigations have been assessed to supplement the published geology on the site and the initial data obtained for the 2003 Terminal EIS and they have provided further detail about the site geology.

8.3 Receiving Environment

A synthetic geological cross-section of the Terminal site was presented in the 2003 Terminal EIS and the information acquired since then has broadly confirmed the succession, adding more detail but not materially changing the basic structure with one exception, which is the presence over part of the site of a soft clay horizon known locally as daub. For inspection purposes only. Consent of copyright owner required for any other use. 8.3.1 Drift Deposits Including Soil

The geological data remains as stated in the 2003 Terminal EIS.

8.3.2 Solid Geology and Hydrogeology

The geology of the site, and the groundwater levels and flows within/through both the superficial deposits and bedrock are interrelated. As part of the various investigations post the preparation of the 2003 Terminal EIS, the presence over part of the site of a soft clay horizon known locally as daub was noted. Daub is considered to be a glacially derived material with similar mineralogy to the weathered underlying mica schist bedrock and one of the predominant minerals found in this weathered deposit is aluminium. Daub in its virgin condition is of very low strength and softens rapidly when exposed to the elements, creating a silt laden fluidised material (see Section 9). On testing the solid constituents of the softened daub, it was noted that aluminium, in both dissolved and suspended particulate form, was present and the aluminium content is considered to have been derived from the weathering of the schists underlying the superficial deposits in the region. Prior to major construction works between 2005 and 2009 a series of piezometers were installed to provide relevant data on groundwater conditions beneath the site. The

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piezometers were installed prior to any bulk excavation within the footprint of the Terminal and around the footprint’s perimeter. The monitoring has confirmed that the hydrogeological model as presented in the 2003 Terminal EIS is still as predicted. There was no significant variation in groundwater levels across the site during or after the main construction / excavation phase, and groundwater water level remained stable with minor seasonal variations recorded in response to rainfall and recharge.

8.3.3 Baseline Report, Industrial Emissions Directive 2010

The Industrial Emissions Directive, Article 22 requires: “Where the activity involves the use, production or release of relevant hazardous substances and having regard to the possibility of soil and groundwater contamination at the site of the installation, the operator shall prepare and submit to the competent authority a baseline report before starting operation of an installation or before a permit for an installation is updated for the first time after 7 January 2013”. The baseline report shall contain the information necessary to determine the state of soil and groundwater contamination so as to make a quantified comparison with the state upon definitive cessation of activities provided for under paragraph 3. The baseline report shall contain at least the following information: (a)information on the present use and, where available, on past uses of the site (b)where available, existing information on soil and groundwater measurements that reflect the state at the time the report is drawn up. Table 8.1 below provides a road map to explain where the detailed information required by Article 22 can be found together with a summary of that information. A Baseline Report on Geology and Hydrology for the Terminal Site is provided as Appendix B of this Supplementary Update Report.

Table 8.1: Location of Information relating to Article 22 Uses Location of detailed information in Summary information 2003 Terminal EIS Historical uses Section 6 Terrestrial Flora and Fauna The Terminal site is located on part of the Section 7 Aquatic For inspectionEcology purposes only. former An Foras Taluntais Peatland Section Consent8 Soils, of copyrightGeology owner and required for any otherExperimental use. Station, Glenamoy. It is a flat

Hydrogeology platform site prepared using a cut and fill Section 9 Hydrology and Drainage process where material excavated to Volume 1: Technical Appendix 1 create a flat site is used as fill to raise Section 9 Hydrochemistry lower levels of the site up to grade. In the Figure 17 local environment the site lies at an altitude of between 20m and 45m O.D. and the surrounding terrain is for the most part gently sloping. Throughout the wider site the main soil type is a damp peat, which generally exceeds 1m in thickness. The two main habitat types present immediately adjacent site are immature conifer plantation and wet, rushy grassland.

Occasional high levels of phosphorus were detected in peat samples; this is assumed to be as a result of artificial fertiliser application during the historical use of the site as a grassland research station and later for commercial forestry. There are no known public records of contaminated land or recorded pollution incidents in the vicinity of the Terminal site location.

Groundwater samples taken from the

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Uses Location of detailed information in Summary information 2003 Terminal EIS bedrock formation during the original site baseline study in 2002 were tested for the following determinands: iron, manganese; calcium, magnesium, chloride and alkalinity. It was concluded that these determinands were derived from the soil and rock formations through which the groundwater passes. The presence of chloride was considered to be due to the sites’ proximity to the coast and the downward leaching of that ion into the ground. It was found that only iron and manganese occurred at concentrations above the drinking water standards in force at the time.

Present Uses Section 2 Description of the Proposed The Terminal facilities on site include gas Development. conditioning and power generation equipment, utilities including water treatment, firewater ponds, pipe-racks, flare, control room, administration block, maintenance building, equipment plant buildings, chemical storage areas, paved areas, walkways, plant roads and open areas including areas of peat, grassland, and woodland.

Existing Section 8 Soils, Geology and The soils beneath the Terminal facilities information on Hydrogeology comprise clean granular fill. The soil and Section 9 Hydrology and Drainage groundwater quality is monitored on a groundwater Volume 1: Technical Appendix 1 monthly basis in a series of wells, and the measurements Sections 1-8 results of the laboratory testing confirm that These Sections describe the the water is uncontaminated by hazardous methodology used to gather baseline substances. Phosphate is present as a soil and groundwater data and the result of leaching from the overlying peat. results are presented in the The results are currently being submitted accompanying appendices A-E. The on a regular basis to Mayo County Council factual reports that were prepared by who also undertake its own verification contractors who For gathered inspection purposes the only. monitoring of the same wells. baselineConsent data ofare copyright referenced. owner required They for any other use.

are reference 6 (AGEC Ltd) references 11 and 14 (Minerex Environmental Ltd.).

8.4 Characteristics of the Proposed Development

The main activities associated with construction of the Terminal, namely enabling works, peat excavation works and Terminal civil and mechanical construction works, have been completed. Changes in aspects of the operation and design of the Terminal are discussed in Section 2 and are not considered to result in any change to the assessment of impacts on solid geology, superficial geology and soils.

8.5 Potential Impact of the Proposed Development

The major construction works on the site have been completed. In the event that further excavation works are required in areas underlain by daub, there is the potential for the release of aluminium in solution or as suspended solids.

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8.5.1 Re-use of Excavated Materials for Engineering Fill

Rock and some surplus peat that has been stockpiled on site during construction will be used in the final landscaping activities that are currently underway and which will continue as the use of the temporary construction facilities on the site draws to an end.

8.5.2 Phosphate Mobility

As reported in the 2003 Terminal EIS, occasional high levels of phosphorus were detected in the peat samples related to residual deposits of fertiliser as a result of the previous land use (see Section 6 of this Supplementary Update Report). Phosphate also has been found in surface and groundwater samples.

8.6 Predicted Impact of the Proposed Development

8.6.1 During Construction

The predicted impacts during construction remain as presented in the 2003 Terminal EIS with the exception of the occurrence of daub under certain areas of the Terminal platform. It is not anticipated that the remaining construction and landscaping works at the Terminal will require any further disturbance of daub and therefore no impacts related to aluminium in solution or as suspended solids are anticipated. The handling of this material (should it be encountered as part of the remaining landscape works) and the mitigation applied to manage surface water associated this is dealt with in Section 9 of this report. The potential for phosphate release associated with landscaping works which involves the movement of peat remains as described in the 2003 Terminal EIS.

8.6.2 During Operation

The impacts remain as stated in the 2003 Terminal EIS.

For inspection purposes only. 8.7 Do Nothing Scenario Consent of copyright owner required for any other use.

The do nothing scenario is no longer relevant as the Terminal has been constructed.

8.8 Mitigation Measures

The mitigation methods as proposed in the 2003 Terminal EIS will continue to apply, as appropriate to the operations phase and the outstanding landscaping works, as well as any future land maintenance works.

8.9 Monitoring

Periodic monitoring of the groundwater levels and quality will continue as part of the Terminal operations.

8.10 Reinstatement and Residual Impacts

As presented in 2003 Terminal EIS, some of the excavated rock and peat is being used in the landscaping and screening around the Terminal site. The residual impacts therefore remain as stated in the 2003 Terminal EIS.

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9 HYDROLOGY AND DRAINAGE

9.1 Introduction

The construction of the Terminal took place during the period 2005 – 2010, and the facilities are substantially complete. The landscaping of the wider Terminal site will be carried out as the pipeline construction and Terminal start up activities are completed. The potential and predicted impacts of the development on the hydrology and drainage were assessed in the 2003 Terminal EIS and where appropriate are reconsidered as part of this Supplementary Update Report. This section should be read in conjunction with Section 8 of this report and Appendix B which presents a Baseline Report on Geology and Hydrogeology for the Terminal Site, as required by the Industrial Emissions Directive. This section sets out the existing information on surface water monitoring reflecting the state of the Terminal site as of January 2014. In addition, the likely impacts of the remaining aspects of the development on hydrology and drainage have been reassessed taking into account the proposed changes in-combination with the remaining landscaping works. This re-assessment includes consideration of the potential and predicted impacts from the drainage of the site including mitigation measures to reduce impacts of the development. This section has been prepared by RSK Environment Ltd.

9.2 Receiving Environment

9.2.1 Rainfall

A review of recent rainfall data from Met Eireann’s weather station in Bellmullet has been carried out. This has confirmed the extreme rainfall return rates set out in Table 9.1 below. Table 9.1: Extreme Rainfall Return Periods For inspection purposes only. Consent of copyright owner required for any other use. Event/basis Rainfall 1 in 100 year event, Belmullet 31mm/hr Highest recorded level (Sept 2003, Approx 40 mm/hr Pollatomish) Design basis 45mm/hr

A weather monitoring station has been operating on the Terminal site since 2004. The data collected includes rainfall, temperature (max and min), humidity, and wind speed and direction. Comparison of the local rainfall data with the data reported from Belmullet which is located approximately 20 km away has indicated that the site experiences approximately 20 per cent more rainfall on an annual basis than Belmullet.

9.2.2 European Sites and other Designated Conservation Sites in the Wider Locality

Designated sites that could be impacted by any changes to the hydrological regime were considered in the 2003 Terminal EIS and are re-assessed where appropriate in Sections 6 and 7 of this report.

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9.2.3 Surface Water

Catchment Area The area remains as described in the 2003 Terminal EIS. Terminal Site Ongoing monitoring since 2003 has confirmed that the hydrological regime as described in the 2003 Terminal EIS and the base flows, flow directions and hydraulic gradients continue to operate as predicted.

9.2.4 Water Quality – Rivers and Drains

Since 2003 there has been a change in the legislation regarding drinking water (EC Drinking Water Regulation 2000 (S.I. No. 439 of 2000) replaced by EC (Drinking Water) (No. 2) Regulations SI 278 of 2007) and hence the impact of the development on water quality in the context of drinking water quality has been re-assessed. In 2009, a new statutory instrument European Communities Environmental Objectives (Surface Waters) Regulations 2009 (SI No. 272 of 2009) (later amended by (S.I. No. 327/2012)) was published which brought the requirements of Directives into Irish law. The other key pieces of legislation related to hydrology and drainage (EC Quality of Salmonid Waters Regulations of 1988 (S.I. No. 293, 1988); and Water Quality Standards for Phosphorus Regulations, 1998 (S.I. No. 258 of 1998)) have not changed. As a result of the introduction of these regulations, new water environmental quality standards (EQS’s) for the surface waters around the Terminal development were established. Details of the relevant standards can be found in Section 7, Appendix 7.1 along with the results of the monthly water monitoring carried out by Mayo County Council at two locations on the Bellanaboy River and a location on Carrowmore Lake since 2005. All sites sampled for macro invertebrates in both the spring and autumn surveys of 2012 indicated Q values that ranged between 3 and 5, with the majority of sites being 4-5. The results of the surface water For inspection monitoring purposes only. show that the surface waters surrounding Consent of copyright owner required for any other use. the Terminal (Bellanaboy and Carrowmore Lake) meet most of the new EQS’s with the exception of total phosphorus and ammonia which exceeded the EQS. A study of the water quality of Carrowmore Lake and its tributaries was undertaken during 2004 and 2005 by the NWRFB (NWRFB, 2005). At this time the lake was found to be strongly eutrophic. Elevated total phosphorous concentrations were also found in all catchment tributaries of Carrowmore Lake. At present the status of Carrowmore Lake remains eutrophic.

9.2.5 Protection of Natural Flows and Hydrology

Natural run-off from the Terminal site eventually feeds into designated conservation areas (see Section 6 of this report). There has been no substantial alteration to the flow regime in local watercourses as a result of the Terminal construction. Water quality monitoring data within the Bellanaboy River system (see Section 7) show that the hydrology of these areas has not been affected by the development.

9.3 Characteristics of the Proposed Development

The main activities associated with construction of the Terminal, namely enabling works, peat excavation works and Terminal civil and mechanical construction works,

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have been completed. Construction related activities remaining include landscaping of the Terminal site. The characteristics of the Terminal operation remains as stated in the 2003 Terminal EIS, with the exception of drainage through the emergency holding tank (EHT). This has been reconfigured to allow the separate management and control of the groundwater drains and the uncontaminated surface water drains (see Section 2 of this report). As described in the 2003 Terminal EIS, a drainage blanket has been installed beneath the Terminal. This is a 300mm thick layer of graded stone laid under the fill section of the Terminal. It is constructed with falls towards the perimeter groundwater drains. The perimeter groundwater drain design now consists of 2 branches (north / west branch, and the south / east branch) that drain towards the south west corner of the Terminal, where they converge in manhole 26 (MH26). Manhole 26 incorporates continuous online monitoring of total organic carbon (TOC) and total carbon (TC) and a manually operated penstock valve. Downstream of MH26 the groundwater flow commingles with the uncontaminated surface water drains discharge from the EHT in manhole 27 (MH27), and then flows via the main carrier drain to the settlement ponds. The groundwater drains are at extremely low risk of contamination, and it has therefore been decided more appropriate to operate them as a separate system from the uncontaminated surface water system.

9.4 Potential Impact of the Proposed Development

9.4.1 During Construction

The final landscaping of the Terminal site is underway along with some maintenance and replacement of items of plant within the Terminal footprint. The removal of the stone berm and creation of wetlands in the western field, which includes partial diversion of existing drainage ditches, construction in peat and the movement of relatively large quantities of both peat and stone, which have the potential to have impacts.

9.4.2 During Operation For inspection purposes only. The potential impactsConsent from of copyrightTerminal owner operationrequired for any otheron use.the hydrological environment and

site drainage remains as stated in the 2003 Terminal EIS, with the exception of drainage through the emergency holding tank (EHT). This has been reconfigured to allow the separate management and control of the groundwater drains and the uncontaminated surface water drains (see Section 2 of this report). In addition the outfall arrangement from the ponds was also modified under one of the Terminal planning amendment regulations but the potential impact associated with this does not change the assessment stated in the 2003 EIS.

9.5 Do Nothing Scenario

The do nothing scenario is no longer relevant as the Terminal has been constructed.

9.6 Mitigation Measures

The hydrology and hydrogeology of the Terminal site has been considered in detail. The measures in place to minimise the impact of the Terminal on the hydrology and drainage have been designed in sympathy with the local aqueous environment - rainfall, surface water runoff and hydrology and hydrogeology. The runoff from the Terminal site is being managed in order to minimise the impact of the development and not significantly alter the flow.

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9.6.1 Construction Phase

During the construction of the Terminal facilities, added temporary surface water mitigation was implemented to minimise impact of the construction works. These included measures to accommodate specific ground conditions encountered as the construction progressed, specifically the addition of the temporary mitigation which comprise a water treatment plant (ESMIL) and associated retention ponds to reduce the total aluminium concentrations in the drainage water from areas affected by earthworks construction. These mitigation measures will continue to be in force throughout the remaining construction activities. In addition, there will be temporary surface water mitigation measures applied to surface water runoff on a localised basis during the remaining landscaping works.

9.6.2 Operational Phase

The mitigation measures that will be put in place to minimise the risks to surface water and ground water during the operation of the Terminal are described in the 2003 Terminal EIS. The drainage systems have been designed to ensure that rainwater, which could become contaminated with hydrocarbons, is segregated, treated and discharged to the water outfall. Only clean rainwater (stormwater) and groundwater are discharged via the settlement ponds to the local watercourses. Process fluids will be in totally contained systems (also see Section 10 Effluent). All areas, where oil or chemicals could spill or leak will be bunded and sealed from the underlying ground and will not have the potential to contaminate surface or ground water. Enclosed drains will collect the contaminated water from these areas and feed it to the treatment system. In the event of contamination detected in the groundwater system at MH26 or in the surface water drains at the EHT, either system can be independently isolated from discharging into the settlement ponds. Retained water from either system can be pumped back to the Open Drain Sump for subsequent onsite treatment. Maintaining the systems segregation of groundwater and surface water in this way has the benefit of minimizing the quantity of water that would be required to be managed and treated in the event of confirmed contamination. For inspection purposes only. Consent of copyright owner required for any other use. The onshore section of the pipeline and associated water outfall pipe and umbilical will not be available at the time Back Feed Gas (BFG) commissioning is scheduled to commence. Therefore, during this phase and until the water outfall pipe is fully connected, it is proposed that the treated surface water from the process areas and tanker access roads is routed to the settlement ponds and local ditch instead of the outfall off Erris Head. As soon as the water outfall pipe is available, the discharge will be routed back to the permitted outfall discharge point (SW1).

9.7 Predicted Impact of the Proposed Development

The impacts on the hydrology and drainage of the development as a result of the changes described above remain as stated in the 2003 Terminal EIS.

9.7.1 During Construction

There have not been any changes to the predicted impacts during construction with the exception of the need to manage the presence of aluminium in the drainage water using the water treatment system described in Section 9.4.

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9.7.2 During Operation

Predicted impacts on the hydrology and drainage of the development remain as stated in the 2003 Terminal EIS.

9.8 Monitoring

Monitoring requirements remain as stated in the 2003 Terminal EIS.

9.8.1 Local Water Courses

Post-construction monitoring has been carried out and the results show no significant impact on water quality, baseflow or hydraulic gradient as a result of the construction. Monitoring of the discharge from the stormwater settlement ponds at SW2 will be undertaken both visually and sampled for a suite of parameters in accordance with relevant consent conditions. This monitoring will also be undertaken during the commissioning phase when transitional arrangements are in place for the management of surface water from process areas and tanker haul roads.

9.9 Reinstatement and Residual Impacts

Following the minor changes made to the drainage system at the Terminal as described in this section, the residual impacts have been re-assessed. Residual impacts remain as stated in the 2003 Terminal EIS.

For inspection purposes only. Consent of copyright owner required for any other use.

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10 EFFLUENT

10.1 Introduction

This section of the Supplementary Update Report describes changes in relation to the future operational aqueous discharges from the Terminal development, and reviews, and reassesses where relevant, the likely impacts arising from the activities in light of updated baseline information. Information on the receiving environment has been reviewed on the basis of the original baseline information as well as data collected and studies carried out since the 2003 Terminal EIS was issued. The Bellanaboy Bridge Gas Terminal was granted an IPPC licence by the Environmental Protection Agency (EPA) in November 2007. This licence includes limits on the aqueous discharge from the plant, both in terms of volumetric flow and quality. Two changes to the original effluent discharges are discussed in this section as follows: • Change in location of the discharge of treated produced water (originally off Erris Head, and now in the Corrib Field), and • During commissioning of the facilities treated surface water runoff will be discharged into the Muingingaun River (originally off Erris Head). This Section has been prepared by RSK Environment Ltd.

10.2 Study Methodology

In addition to the information provided in the 2003 Terminal EIS (which presented baseline data collected off Erris Head in 2000), this review has drawn on the data and assessment presented in the Offshore EIS Supplementary Update Report (2010), and the various baseline marine studies, surveys and modelling activities that have been undertaken since 2003. The updated baseline information pertinent to this review includes the following:

For inspection purposes only. • 2005 – baselineConsent survey of copyright around owner permitted required for any outfall other use. location off Erris Head;

• 2007 – additional baseline survey around permitted outfall location off Erris Head; • 2008 – post-drilling survey in and around the Corrib Field (including verification of baseline data in some areas); • 2008 – additional baseline survey off Erris Head to comply with requirements of IPPC licence; and • 2013 – additional baseline water quality survey in and around the Corrib Field, and verification survey off Erris Head. The survey reports and associated analyses are included in the 2010 Offshore EIS Supplementary Update Report with the exception of the results of the 2013 survey, which are summarised in Section 10.3.2 of this report, and provided in more detail in Appendix 10.2. These studies provide a suitable baseline against which to assess the impacts of the revised discharge streams at SW3 and SW1. The impact of relocating the treated produced water discharge (from the previously permitted outfall point off Erris Head (also termed SW1) to the Corrib subsea manifold location (also termed SW3)) has been assessed using a hydrodynamic modelling study.

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The study models the produced water effluent discharge under the proposed normal discharge scenario at a flow rate of 65m3/day (maximum discharge using a combination of the umbilical and road tanker transport could be up to 80m3/day) and with the concentration of the discharge constituents close to (or at) their Environmental Quality Standards (EQS). The assessment of likely dilution of the produced water discharge plume uses the CORMIX system, which is internationally accepted modelling software for such predictions for aqueous discharges. The modelling results are summarised in Section 10.7.1 and a full description of the modelling methods and scenarios is provided in the modelling report (Appendix 10-1). This study was also included in the 2010 Offshore EIS Supplementary Update Report as Appendix 9.1.

10.2.1 The Offshore EIS

The 2001 Offshore EIS and the associated 2010 Offshore EIS Supplementary Update Report dealt with impacts from construction activities relating to the outfall pipeline and umbilical, as well as the proposed change to the discharge point for treated produced water.

10.3 Receiving Environment

The receiving environment remains as described in the 2003 Terminal EIS with the exception of the Corrib Field which has now become a receptor given the relocation of the treated produced water discharge (from SW1 to SW3). The local streams, rivers and associated catchment which would be the receptors for the treated surface water runoff from process areas in addition to storm water during the BFG commissioning phase are described in Sections 7 and 9.

10.3.1 European and other designated areas in the wider locality

Designated conservation sites in the vicinity of the Terminal, and the potential direct and indirect effects of the Terminal development on these sites were considered in the 2003 Terminal EIS. An update of this and associated further detail is set out in Section 6 of this report, and within the Natura Impact Statement (Appendix A). For inspection purposes only. Consent of copyright owner required for any other use. In the wider area, the intention to designate the West Connacht Coast SAC (Site Code 0002998), for bottlenose dolphin, was announced in 2012. At its closest boundary the West Connacht Coast SAC is 1 km from the outfall discharge (SW1) location and 43.1 km from the offshore subsea manifold discharge (SW3) location. As a result of the assessment, which takes account of the best scientific knowledge and the conservation objectives of each European site, it can be determined that the commissioning and operation of the Terminal either individually or when taken in combination with other plans or projects, is not likely to have a significant effect on a European Site.

10.3.2 Seawater Chemistry

Marine chemistry data sets have been reviewed. The west coast of Ireland in general, and more specifically, the areas affected by the Corrib development, are not well documented, as few surveys have been carried out in these areas. Corrib Manifold (SW3) In November 2013, a total of six stations were sampled for near surface and near seabed water quality in the vicinity of the Corrib manifold. The stations corresponded with those that had previously been used for the sampling of seabed sediments, and were generally orientated with the discharge location and prevailing currents, and are shown in Figure 10.1.

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Figure 10.1: Sampling stations for seawater quality at the Corrib Subsea Manifold location

The samples were analysed for heavy and trace metals, suspended solids, nutrients, and trace organics, and in-situ measurements of temperature and salinity were also taken. The results of the analyses indicate a relatively well-mixed water column, down to a depth of around 80 m, at which point a distinct thermocline was present. Surface water temperatures were around 11.6–12°C but beyond 80 m the temperature dropped off rapidly to around 10.8°C over For inspection a depth purposes of only.around 20-30 m. Between 100-120 m and Consent of copyright owner required for any other use. down to the seabed the temperature gradually reduced by about 0.4-0.5°C, with coolest temperatures recorded closest to the seabed. Overall salinity was recorded as being relatively constant throughout the water column, with the exception of a minor increase at a similar depth to the recorded thermocline. Despite this, salinity remained at around 35 Practical Salinity Units (PSU) throughout the water column, as would be expected in an offshore location with negligible freshwater inputs. A representative example (Station 0) of the temperature and salinity depth profile at the Corrib Manifold (SW3) location for November 2013 is shown in Figure 10.2.

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For inspection purposes only. Consent of copyright owner required for any other use.

Figure 10.2: Temperature and Salinity Depth Profile in the vicinity of the Corrib Manifold

Outfall location off Erris Head (SW1) Six stations were sampled for near surface and near seabed water quality in the vicinity of the treated surface water discharge off Erris Head (SW1). Temperature and salinity depth profile data were also collected at each station. Stations corresponded with those that had previously been sampled for water quality during 2005, 2007 and 2008 and were generally orientated with the set of the prevailing currents. Figure 10.3 shows the sampled locations in the vicinity of the Erris Head treated surface water outfall.

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Figure 10.3 Sampling stations for seawater quality at the Erris Head treated surface water outfall location (SW1 location)

The results from the survey indicate sea surface temperatures of around 12°C. At all stations the water was well-mixed and temperatures remained relatively constant throughout the water column to the seabed with water depths ranging between 58 and 74 m. Previous surveys at this location For inspection (during purposes summer only. 2007 and 2008) recorded a seasonal Consent of copyright owner required for any other use. thermocline at around 40 m water depth, which did not appear to be present during this survey. It is likely that the seasonal thermocline breaks down quickly during the autumn months resulting in a well mixed water column. As would be expected in a coastal area with little freshwater input, only minor differences in the salinities of the surface waters were observed, with very little variation through the water column to the seabed. Salinity remained relatively constant at around 35 PSU. Depth profiles for temperature and salinity at stations visited off Erris Head are similar to upper 70 m or so of water column shown in Figure 10.2. Profiles are presented in Appendix 10.2.

10.3.3 Sources of Inputs to Seawater

These sources are unchanged from 2003 Terminal EIS with the exception of the location of the treated produced water discharge being moved to SW3 instead its original location at SW1, off Erris Head.

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10.3.4 Marine Contaminants

Corrib Manifold location Metals Analytical results from samples collected in November 2013 (see Appendix 10.2) show that the waters in the vicinity of the Corrib Manifold have very low concentrations of metals – which is to be anticipated, given the open nature of the marine environment – and low levels of anthropogenic input in the area. For all metals the ranges recorded during the 2013 survey are either below or in a similar range to background oceanic concentrations and levels recorded by the Marine Institutes monitoring for the Water Framework Directive and Shellfish Waters Directive in 2004-05 and 2012 (see Appendix 10.2). Suspended Particulate Matter Results from the 2013 survey show that the waters in the vicinity of the Corrib Field exhibit low suspended particulate matter concentrations both in the surface and near seabed waters, indicating the high clarity of these waters (see Appendix 10.2). Ammoniacal Nitrogen Ammoniacal nitrogen concentrations in the 2013 Corrib Field samples are very low as would be expected given that land runoff sources are 65 km or more from the Field. Ammoniacal nitrogen levels can show seasonal variation; however the 2013 results were comparable with those of the 2008 survey, and to a lesser extent with results from 2007 collected at the same sampling stations. Trace Organics Whilst some persistent organic compounds were detected in the 2013 results; these compounds were at very low concentrations, reflecting the pristine nature of the environment. Erris Head Metals Results from the 2013 samples compare well with those from previous surveys at the same locations in 2007 and 2008 (as reported in the 2010 Offshore EIS Supplementary For inspection purposes only. Update Report) and with MarineConsent of Institutecopyright owner data required collected for any other during use. monitoring surveys for the European Shellfish Waters Directive (SWD) and Water Framework Directive (WFD) in 2004-05 and 2012. Results from samples collected in 2013 are compared with those from other sources in Appendix 10.2. The results continue to show that the waters off Erris Head have low concentrations of metals – which is to be anticipated given the open nature of the outfall location – and low levels of anthropogenic input in the area. Suspended Particulate Matter Results from 2013 are indicative of the high clarity in these coastal waters. The results also correspond well with the findings from the 2007 and 2008 surveys (see Appendix 10.2). Levels of suspended particulate matter were often too low for the analytical method used to record. Ammoniacal Nitrogen Ammoniacal nitrogen concentrations in 2013 samples were below the detection limits of the method used with the exception of one sample (0.011mg/l). These results correspond well with the surveys of 2008 and are in general somewhat lower than had been the case in the 2007 survey. These concentrations are very low and despite the coastal location it seems unlikely that ammoniacal nitrogen is influenced by land run– off. It is expected that there would be a degree of seasonal variation in the ammoniacal nitrogen levels which may account for some of the minor differences

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between the results of the various surveys. Results from samples collected in 2013 are compared in Appendix 10.2 with those from other studies. Trace Organics The situation off Erris Head is very similar to that in the Corrib Field in respect of trace organics – any compounds detected were at very low concentrations, reflecting the pristine nature of the environment.

10.4 Characteristics of the Proposed Development

10.4.1 Introduction

The sources of effluent and the treatment process remain as described in the 2003 Terminal EIS and the Offshore EIS Supplementary Update Report 2010. The primary change with regard to aqueous discharges is the revised location for the discharge of treated produced water. As reported in the Offshore EIS Supplementary Update Report 2010, SEPIL now propose that during operation of the Terminal, any treated produced water will be transported via the umbilical from the Terminal to the offshore manifold in the Corrib Field, where it will be released at a water depth of approximately 350 m (this discharge point is termed SW3). Only the treated surface run-off water from the Terminal footprint will then be discharged at the permitted Erris Head outfall location, SW1. This discharge stream will essentially comprise clean (treated), rain water, within the Emission Limit Values (ELV’s) set by the EPA for discharge at this location.

10.4.2 Surface Water

During normal operations the surface water runoff from paved process areas and the tanker delivery road routes (areas with potential for hydrocarbon contamination) will be collected below ground in the Open Drains Sump, and routed through a water treatment plant prior to discharge via the SW1 outfall. Storm water in non-process areas and from building roofs (also termed uncontaminated surface water) is collected via the perimeter drain system and an Emergency Holding Tank (EHT) before being routed to the settlement ponds located at the south-western corner of the site and For inspection purposes only. discharged at the SW2 Consentlocation of copyright to local owner watercourses. required for any other use.

In the event of a fire or chemical spillage into the uncontaminated surface water drainage system being detected, an isolation valve on the outlet of the EHT can be automatically closed, and the storm water retained within the stormwater ditches and the perimeter surface water drainage system and can then be sampled and routed into the treated surface water system for treatment prior to discharge via the sea outfall. During the early phases of hydrocarbon commissioning of the Terminal (BFG), a transitional arrangement for surface water is proposed, whereby the treated drainage water from process areas and tanker delivery roads will be routed via the storm water settlement ponds (which during operation will take only clean surface water from non- process areas) to be discharged via the south west Terminal drain SW2. It is proposed that this arrangement will remain in place until the outfall pipeline is completed (the onshore section of the outfall pipeline is currently being constructed alongside the Corrib onshore pipeline to link with the already constructed offshore gas pipeline and outfall pipeline at Glengad). Storm water / surface water collection and discharge from non-contaminated areas via SW2 will not be adversely affected (the maximum contribution to the discharge during BFG from areas at potential risk of contamination will be approximately an additional 5% by flow). This scenario will not differ significantly from the present situation, with the exception that the discharge will be routed through the treatment plant and pumped to the settlement ponds, rather than flowing by gravity.

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10.4.3 Firewater

The firewater containment requirements for the site have been re-evaluated, and the drainage system has been rationalised so that in the event of the worst case scenario considered (simultaneous failure of the 3 largest methanol storage tanks) the drainage systems on site will assist in providing sufficient containment capacity on-site.

10.4.4 Oily Water Characteristics

The characteristics of oily water drainage system remain as stated in the 2003 Terminal EIS.

10.4.5 Produced Water Characteristics

The discharge system for treated produced water will no longer be discharged with the treated surface water as the two systems are now completely segregated. The treated produced water from the produced water treatment plant will be routed into a collection sump from where it can be re-circulated for further treatment if necessary or transferred to the discharge sump, from where it will be pumped offshore via the umbilical. A biocide will be injected into the treated produced water stream to prevent fouling within the umbilical core. DOW Antimicrobial 7287 (DBNPA) is the biocide currently proposed for this use. This biocide is considered to have the optimal combination of functional performance and rapid degradation characteristics in respect of its environmental impacts. The biocide will be dosed on a batch basis prior to the treated produced water being injected into the umbilical core.

10.4.6 Additional Processing Chemicals

The details remain as stated in the 2003 Terminal EIS.

10.4.7 Chemical Drains

The details remain as stated in the 2003 Terminal EIS. For inspection purposes only. Consent of copyright owner required for any other use. 10.4.8 Sanitary Waste

The details remain as stated in the 2003 Terminal EIS.

10.4.9 Waste Water Flow Rates

Produced water As per the 2010 Offshore EIS Supplementary Update Report the projected discharge rate for treated produced water is summarised below. The hydraulic capacity of the umbilical cores has been calculated at 65m3/ day (approximately 2.7m3/hour), and this has been used as the basis of the dispersion modelling and assessment (Section 10.8.1). The maximum discharge rate is predicted to be 3.3 m3/hour or a daily maximum of 80 m3. Should treated produced water volumes arising at the Terminal in the early years of production exceed the capacity of the available umbilical cores, the excess will be tankered offsite to a licensed waste water disposal facility. Additionally, the discharge will now be continuous via an available spare core of the offshore umbilical (discharging at SW3) rather than batched discharge into the treated surface water discharge at Erris Head (SW2).

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Open Drain Catchment It is now proposed that water collected from the open drain continues to be discharged to SW2 (as it currently is) until the Terminal commissioning phase is completed. The original proposal was that during commissioning of the Terminal, the treated surface water would be discharged at SW1. Clean Surface Water Drainage There is no change proposed to the clean surface water drainage system function from that described in the 2003 Terminal EIS.

10.5 Potential Impact of the Proposed Development

10.5.1 During Construction

The potential impact in terms of aqueous emissions of the construction of the Terminal remains as stated in the 2003 Terminal EIS.

10.5.2 During Commissioning

The arrangements that will be in place for surface water management during commissioning will not differ from those currently in place, and which have been used during construction. However, it is now proposed that when the water treatment plant for the surface water runoff from process areas (areas with the potential for hydrocarbon contamination) become operational during BFG commissioning, and until the onshore pipeline connection to the outfall becomes available, this treated surface water will be discharged off site through the settlement ponds. Therefore, associated with this proposal there is now the potential for impacts downstream of SW2 from this surface water stream. However it should be noted that the ratio of treated surface water to storm water will be very small due to the limited catchment (in the region of 2ha) and the treatment plant will treat the surface water runoff to a very high standard and in accordance with the ELVs set by the EPA for SW2 (see Section 10.4.2) before discharge here. This arrangement will remain in place until the onshore section of the outfall pipeline (constructed alongside the gas pipeline) is constructed.

10.5.3 During Operation For inspection purposes only. Consent of copyright owner required for any other use. Potential impacts of the treated produced water discharge on aquatic biota are discussed in Section 7 of this report, and in the 2010 Offshore EIS Supplementary Update. To prevent biofouling of the umbilical cores that will transport the produced water to the offshore manifold, a biocide will be injected into the treated water stream. Bacteria and nutrients present in the treated produced water within the umbilical core would create the potential for the build-up of a biofilm on the inner walls, which could result in a reduced discharge capacity and in a worst case cause a blockage. Overall the potential impacts are considered to be negligible as the discharge of produced water at the Corrib manifold will result in rapid dilution / dispersal. The relocation of the discharge point from SW1 to SW3 at the Corrib manifold increases the levels of dispersion further such that any impacts to aquatic ecology, and water quality are further reduced. The biocide that will be added to the discharge stream will breakdown rapidly through hydrolysis and biodegradation. The emission limit values set in the current Industrial Emissions Licence for contaminant levels in the produced water discharge are at levels such that there will be no damage to marine organisms, nor allow for an accumulation of contaminants in the area at the point of discharge. Therefore potential impacts during operation are materially unchanged from the 2003 Terminal EIS. Treated produced water discharged at the SW3, rather than SW1 location will result in no significant difference in effects.

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10.6 Do Nothing Scenario

The do nothing scenario is no longer relevant as the Terminal has been constructed.

10.7 Mitigation Measures

10.7.1 Regulations and Environmental Quality Standards

While the outfall location for the produced water is now at the Corrib Manifold in a water depth of around 350 m, it is still proposed that the water will be treated to stringent levels. This degree of treatment prior to discharge is unusual, and the dilution and dispersal afforded by the offshore location and water depth of the discharge point will serve to further rapidly reduce the concentrations of any contaminants in the discharge.

10.7.2 Water Management – Routine Operations

Updated reservoir modelling predicts that the overall volumes of produced water will be somewhat less than envisaged at the time of the 2003 Terminal EIS. Produced water will be discharged at a reduced flow rate on a continuous basis, rather than in batched discharges, and it will be discharged at SW3, at the Corrib Offshore Subsea Manifold, close to the continental shelf break, rather than in coastal waters. During operation, the management of surface water from process areas and clean areas of the Terminal will be managed as described in the 2003 Terminal EIS. During steady state operations, all surface water with the potential for contamination (drainage from process areas and tanker roads) will undergo separation of oils, settlement and treatment prior to discharge at the SW1 outfall). Clean surface water (also termed storm water) from non-process areas will pass through settlement ponds to limit in particular, the levels of suspended solids, prior to discharge at SW2.

10.7.3 Water Management – Transitional arrangements during commissioning

No specific additional mitigation measures have been proposed for the management of surface water from the open drain system in process areas during the transitional For inspection purposes only. arrangements for BFG. TheConsent treatment of copyright ownerproce requiredss that for any would other use. normally treat the surface water prior to discharge at the Erris Head outfall will treat the surface water prior to discharge to the local catchment (SW2), and the emissions limits set in the Industrial Emissions Licence for either of the discharge points will be met.

10.8 Predicted Impact of the Proposed Development

10.8.1 Impacts in the Marine Environment

Water Quality Modelling The following describes the main findings of the dispersion modelling study for the produced water discharge stream undertaken by HR Wallingford (Appendix 10.1) for SW3. The treated produced water will have a lower salinity than the surrounding seawater under normal circumstances, and is thus less dense than the receiving water. The dispersion calculations demonstrate that, once it is discharged it will rise through the water column, mixing as it ascends and becoming diluted to background levels within a short distance from the point of discharge. Concentrations of contaminants are estimated to be diluted by approximately 100 times within 5 m of the point of discharge at the Corrib Manifold. Thereafter, the extremely low discharged concentrations are further diluted to within 10% of background level up to 300 m downstream of the discharge location.

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The levels of treatment that the produced water will receive prior to discharge via the umbilical meet the contaminant concentration levels set by the Industrial Emissions Directive licence for the Erris Head discharge location. As noted earlier, biocide is now proposed for discharge within the produced water. A careful selection process was carried out to determine the most appropriate material to use for this purpose (see 2010 biocide selection assessment appended to this document as Appendix 10.3)), both in terms of effectiveness, and impact on the environment upon release with the produced water. The material chosen (DBNPA) will begin to degrade by hydrolysis once it is injected into the treated produced water discharge stream. Hydrolysis of DBNPA produces carbon dioxide, bromide and ammonia. It is estimated that the complete breakdown of DBNPA through metabolism by microorganisms proceeds at a rate of 78% after 28 days, this compares well with OSPAR guidance of 20% over this period and OECD guidelines of >70%. By the time the produced water is discharged at the subsea location at the Corrib Field, the active concentration of the biocide will have reduced to approximately 100 to 200 ppm, and rapid dilution will reduce the concentration down to around 1-2 ppm within 5 m of the discharge location. Based on the combination of the processes of hydrolysis, biodegradation and dilution, overall breakdown and dispersal will be relatively rapid and complete, and as such the overall environmental impacts associated with the addition of biocide to the produced water discharge stream are considered negligible. It is therefore concluded that there will be no impacts to water quality in the area of the Corrib Field resulting from the discharge.

10.8.2 Impacts in the Freshwater Environment

Impacts to the freshwater environment are described in Section 7 (Aquatic Ecology) and Section 9 (Hydrology and Drainage).

10.9 Monitoring

The current Industrial Emissions Licence for the Terminal includes the requirement for baseline surveys of environmental quality to be carried out prior to Terminal operations commencing. Baseline benthic surveys have previously been carried out in the vicinity of both SW1 and SW3, and Forwater inspection quality purposes surveys only. had been carried out around SW1. Consent of copyright owner required for any other use. The water quality sampling carried out in November 2013 provided the first set of baseline data for SW3 and further baseline data for SW1. The similarity in results from the two locations indicates that the two sites are located within the same water body, and the results themselves could therefore be considered as verification of existing regional data. Data collected previously from around SW1 is therefore also considered representative of the water quality around SW3. It is proposed that further baseline benthic survey work is carried out to verify the earlier collected data around SW1 and SW3 (see section 10.2). It is currently planned that this survey work will be carried out in the second or third quarter of 2014 prior to any operational discharges taking place at either of the discharge locations. In addition to sampling in the environment, the Industrial Emissions Licence requires that a programme of ecotoxicological testing using appropriate aquatic species as sensitive indicators will also be undertaken to determine the acute toxicity of the undiluted effluent proposed to be discharged at the Corrib Manifold (SW3). This testing can only be fully scoped and undertaken once production from the Corrib Field commences. The produced water discharge stream will also be analysed twice per year for the following chemicals in accordance with the requirements of the DCENR/Marine Institute; organic acids, polyaromatic hydrocarbons, naphthalene, phenanthrene and dibenzothiophene (NPD) (and derivatives), benzene, toluene, ethylbenzene, and xylenes (BTEX), aliphatic and aromatic hydrocarbons, alkyl phenols and heavy metals. The results from these analyses will be used to determine those

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components of the discharge which may be most harmful. Toxicity, persistence and potential for bioaccumulation will be assessed from the analyses. OSPAR recommendation 2012/15 presents a Risk Based Approach to the reduction of the most harmful components in Produced Water. This approach recommends the calculation of a “predicted effect concentration” (PEC) and “predicted no-effect concentration” (PNEC) for the discharge, and the use of these concentrations together with environmental measurements to assess the risks from the discharge. The Risk Based Approach has not been agreed in Ireland as yet, though the use of PEC/PNEC is likely to be included once the approach is agreed. The ecotoxicological testing discussed above will provide information for use in the calculation of PEC and PNEC, and the future analysis of the water discharge stream will provide other information required for the risk based assessment to be made. The quality of the treated produced water will be tested before it enters the umbilical, and if the consented discharge concentrations of various contaminants are not met, it will be routed to storage tanks for further treatment. Monitoring of the discharge from the storm water settlement ponds at SW2 will be undertaken both visually and sampled for a suite of parameters in accordance with relevant consent conditions. This monitoring will also be undertaken during the commissioning phase when transitional arrangements are in place for the management of surface water from process areas and tanker haul roads. This monitoring will have an expanded scope that will include monitoring of flow, pH and conductivity along with regular sampling with a suite of chemical analyses will be made of water in the treated water stream.

10.10 Reinstatement and Residual Impacts

Reinstatement and residual impacts are considered negligible as stated in the 2003 Terminal EIS.

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11 AIR EMISSIONS

11.1 Introduction

The 2003 EIS considered the emissions to atmosphere arising from the development and operation of the Bellanaboy Bridge Gas Terminal and their likely impact on local air quality. Emissions that have primarily transboundary, climatic impacts are covered in Section 14. As detailed in Section 1, some amendments were subsequently incorporated into the design of the Terminal facilities. The 2006 EIS addendum was submitted to provide additional information requested by the EPA and thus forms part of the 2003 Terminal EIS. Of relevance to impacts on air quality, the most significant design change made since the 2003 EIS and the 2006 addendum is the inclusion of selective catalytic reduction on the power generation engines to substantially reduce emissions of oxides of nitrogen. The predicted air pollutant emissions from a number of other sources have also changed, either through minor design changes or reassessment based on new information or techniques. The Terminal has now been constructed, but is yet to be commissioned. This section has been prepared by RSK Environment Ltd.

11.2 Study Methodology

The assessment of air quality impacts relies principally on a detailed dispersion modelling study using the advanced and EPA-accepted dispersion model ‘AERMOD’, provided as Appendix 11.1. This study is used to support both the EIS and the Industrial Emissions Licence application and has evolved alongside these processes. The updated air quality assessment presented in this Section is based on a new version of the dispersion study, in line with EPA guidance on dispersion modelling (EPA, 2011). For inspection purposes only. This section of the SupplementaryConsent of copyright Update owner required Report for any includes other use. the following:

• An update of the air quality baseline information presented in the 2003 EIS; • An update of the predicted emissions of air pollutants and their impacts to reflect the latest characteristics of the Terminal operation;

11.3 Characteristics of the Proposed Development

11.3.1 Construction

The Terminal has now been constructed. Air quality impacts related to construction activity are localised to the activity taking place and short-lived, not persisting more than a few hours beyond the period of the activity. They are therefore not discussed further in this Supplementary Update Report.

11.3.2 Operation

The basic characteristics of the Terminal and its emissions to air are largely unchanged since the 2003 EIS and its 2006 addendum. The most significant change is the addition of selective catalytic reduction as oxides of nitrogen abatement on the power generation engines. This has significantly reduced the engines’ NOx discharge

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concentrations. The following table summarises the sources and quantities of emissions and details changes since the 2006 addendum.

Table 11.1: Annual Emissions (Combustion Sources) Annual emission (kg) Comments on changes Source NOx as CO SO2 Particulates since 2006 EIS addendum NO2 Figures in parentheses are as per 2006 EIS addendum Heating Nil Nil Nil Nil Source removed – process medium (454) (214) (TBC) (TBC) heat to be provided solely heater by waste heat recovery system Sales gas 23,913 33,478 Negligible Negligible Refinements to expected compressor (36,792) (45,552) (Negligible) (Negliglble) performance parameters turbines Power 13,172 16,816 Negligible Negligible Addition of selective generation (50,808) (29,784) (Negligible) (Negliglble) catalytic reduction engines abatement reduces NOx emissions by half. Other performance parameters better defined Firewater 1,488 140 88 24 Operational regime used as pumps (6,448) (603) (374) (104) basis of emissions calculations changed for consistency with Industrial Emissions Licence application Emergency 868 244 77 21 No change generator (868) (244) (TBC) (21) Maintenance 26 145 Negligible Negligible Operational regime used as ground flare (504) (TBC) (Negligible) (Negligible) basis of emissions calculations changed for consistency with Industrial Emissions Licence application Where emission source types comprise multiple individual units, the emissions are calculated for all the units, i.e. the entire source category. For inspection purposes only. Consent of copyright owner required for any other use.

One of the downsides of selective catalytic reduction is that it entails the use of an additional chemical: urea, with ammonia being an intermediate product of the catalysis reaction. Systems are included (described in Section 11.6) to minimise the emission of unreacted ammonia, known as ‘ammonia slip’ but it is not possible to eliminate completely. SEPIL will use best available techniques to reduce the ammonia slip, and expects to be able to limit the emission to 75 kg/year for each engine. With the normal operational regime of 2 of the 3 engines running continuously, the total predicted emission of ammonia is therefore 150 kg/year.

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Table 11.2: Annual Emissions (Venting, Fugitive, Storage Tank and Product Loading Vapour)

Quantity Comments on changes since Source Emitted substance (tonne/year) 2006 EIS addendum

Figures in parentheses are as per 2006 EIS addendum Venting Natural gas 30 Understanding of compressor start (95) up venting process has been improved Fugitive Natural gas 19 Substantial reduction based on (119) leak testing results as opposed to generic emission factors – see below and Table 11.3 Storage Volatile organic 2.8 Not separately quantified in EIS tank compounds addendum vapour losses Product Volatile organic 2.1 Not separately quantified in EIS loading compounds (7.1) addendum – figure of 7.1 te/yr is vapour maximum from 2003 EIS losses

Table 11.5 of the 2006 EIS addendum provided a breakdown of the fugitive emissions. The expected quantity of these emissions has been reviewed and revised, based principally on a programme of leak testing undertaken in 2010. This has enabled the calculation to be based on actual measurements rather than generic emission factors and results in a significant reduction in the predicted gas losses. In 2014, SEPIL intends to repeat leak testing to accommodate the various modification works that have taken place in that period. This will provide further data and validation of the emission factors.

Table 11.3: Fugitive Emissions Breakdown Component Emission factor Total annual release Number in Terminal type For inspection purposes(kg/component/year) only. (kg/yr) Consent of copyright owner required for any other use. Figures in parentheses are as per 2006 EIS addendum. Absence indicates no change 0.102 489 Connections 4,800 (2.4) (11,520) 2,386 0.509 1,215 Valves (2,384) (33.9) (80,818) 0.509 22 Rotating Shafts 43 (101) (4,343) 9 15,079 Analysers - (12) (20,102) Other 50 42.7 2,135 18,940 Total (118,918)

11.4 Potential Impact of the Proposed Development

The potential impact of the Terminal development is a marginal reduction of air quality as a result of emissions arising from Terminal construction and operational activities. The potential impact of emissions to air on flora and fauna are addressed in Section 6.5.

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11.5 Do Nothing Scenario

There is no change from the 2003 EIS’s findings in terms of the do nothing scenario, characterised by background air quality levels. New data sources have become available since 2003 for the results of the monitoring of relevant air pollutants in rural parts of Ireland, adding to the picture that was previously presented through the monitoring programme undertaken at the Terminal site prior to construction activities starting and the consideration of UK rural monitoring data. The new data is discussed in the accompanying dispersion modelling report. It shows that the monitoring done at the terminal site yielded results that were in line with comparable monitoring done by the EPA and UK authorities. The new data did not present a case for changing the background levels used in the impact assessment study, instead they merely gave a higher degree of confidence that the values previously used (derived from the 2003 EIS baseline survey programme) can be relied on to provide a robust characterisation of the baseline conditions around the Terminal.

11.6 Mitigation Measures

The overarching mitigation approach for air emissions impacts, along with other types of impact discussed in this EIS Update, is the use of best available techniques (BAT) to minimise or prevent pollution. As the Terminal will include a prescribed process under the European Union (Industrial Emissions) Regulations 2013, SEPIL must apply for a licence and operate the installation in accordance with it. A licence will only be granted if the EPA, as the competent authority, determines that the Terminal has been designed and will be operated in accordance with BAT. Conditions of the licence will reinforce this. Particular features of the Terminal’s design that show compliance with the principles of BAT include: • Use of selective catalytic reduction to reduce NOx emissions from the power generation engines; • A comprehensive monitoring and control system on the SCR urea dosing system to ensure that the correct amount of urea is injected and the reaction takes place optimally, reducing NOx emissions while avoiding ammonia slip; For inspection purposes only. • Use of low NOx burnersConsent ofon copyright the sales owner required gas compressorfor any other use. turbines;

• Waste heat recovery on the sales gas compressor turbine exhausts; • A flare pilot that is ignited on demand, rather than constantly lit; and • Liquid storage tanks feature comprehensive measures to prevent losses of vapours, resulting in very low predicted emissions of volatile organic compounds These and other aspects of the Terminal’s BAT design and operation are presented in more detail in the 2014 Industrial Emissions Licence review application.

11.7 Predicted Impact of the Proposed Development

The predicted impact of the Terminal’s operation is assessed on the basis of the results of the updated detailed dispersion modelling study, a report of which accompanies this Supplementary Update Report. The major changes in the dispersion modelling study relative to the version that accompanied the 2006 EIS addendum referenced above are: • Normal operational scenarios include the selective catalytic reduction abatement system operating on the power generation engines, reducing NOx emissions significantly;

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• Deletion of the heating medium heater; • Updated meteorological data are used (2007-2011, updated from 1997-2001); • Addition of ammonia as a modelled pollutant (from the power generation engines only), as a result of its introduction as a new pollutant because of the addition of the SCR system; • Addition of the high pressure flare, the maintenance ground flare and the emergency generator as modelled sources with appropriate operational scenarios to consider their contribution (including both flaring and cold venting from the HP flare stack); • Addition of benzene and methane as pollutants from scenarios modelling venting and flaring events; • A more comprehensive analysis of the sensitivity of the model results to various input variables; and • As discussed in Section 11.5, more data to enable a stronger characterisation of the background air quality became readily available and warranted consideration in that part of the modelling study, though they did not result in a change to the background levels used in the assessment The results of the dispersion modelling are summarised in the following tables. Firstly Table 11.4 presents the results for scenarios where the products of combustion or flaring are the relevant pollutants. Long-term averages are relevant for scenarios 1-4, as these scenarios could be representative of the Terminal’s status for extended periods. Long-term averages are not relevant for scenario 5 (emergency flaring) as this will be a short-lived operational state. The results presented are the highest predicted off-site concentrations. They include background levels of nitrogen dioxide. Background levels of other pollutants are treated as negligible.

Table 11.4: Predicted Highest Off-site Ground Level Pollutant Concentrations – Combustion and Emergency Flaring Highest predicted pollutant ground level concentrations, μgm-3 Operational Annual mean 99.79th %ile 8-hour mean For inspection purposes only. Annual mean 1 hour mean Scenario NO2 Consent of copyrightof hourly owner required forCO any concen- other use. NH3 NH3 mean NO2 trations Scenario 1 – 6.7 74.9 113.5 0.2 2.1 worst case 1 Scenario 2 – 7.4 73.8 110.7 0.2 2.5 worst case 2 Scenario 3 – 9.8 106.0 135.4 0 0 worst case 3 Scenario 4 – 6.7 60.9 85.3 0.2 2.0 typical Scenario 5 – emergency n/a 31.3 29.5 n/a 1.0 flaring Air quality 40 200 10,000 180 2,500 standard † Environmental Assessment Levels used in the absence of air quality standards for ammonia

Results for the cold venting scenario show highest offsite 1-hour average methane concentration of 50,077 µgm-3 against a guideline value for the protection of health of 196,800 µgm-3. All the presented results are the highest derived from the range of meteorological datasets used.

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The key outcomes of the dispersion modelling study are: • The modelling predicts no relevant ambient air quality standard or guideline will be exceeded at any location beyond the site boundary when all installed plant is operating at full output (a worst case scenario) or under any of the rarer operational scenarios assessed. The highest predicted concentrations occur at or in close proximity to the site boundary. Whilst it is unlikely that members of the public will be exposed at such a location for a relevant period of time, predicted concentrations for all scenarios are within air quality standards for the protection of health and ecosystems taking into account background concentrations. The standards and guidelines have been set by environmental and health professionals across Europe following extensive worldwide research and are set to protect even very vulnerable receptors. • Following the introduction of the improvements aimed at increasing the environmental performance of the gas Terminal since the original IPPC licence application, mass emissions of NOx (the principal emission component with the potential to impact air quality) have reduced significantly. • Numerous assumptions have been incorporated into the dispersion modelling study that are designed to over predict ground level concentrations and therefore provide a conservative assessment of air quality impacts. • Existing air quality is very good and is predicted to remain so with the gas Terminal in operation. Please refer to the accompanying dispersion modelling report for full details of: • The scenarios assessed – which items of plant are operational in each and in which modes of operation; • The complete set of input parameters used; • Results at a range of discrete receptor points (houses and ecological sites) – the results presented in the above tables are the highest offsite concentrations predicted. Predicted concentrations at locations where exposure to pollutants over the relevant time scales might be reasonably expected are significantly lower and often show negligible contributions from the plant; For inspection purposes only. • Isopleth (‘contour’)Consent plots of copyrightshowing owner requiredthe shape for any other of use. the pollutant plumes and

enabling interpretation of the results for any given point of interest within the model domain; and • The results of sensitivity analyses, which all show that varying a number of input parameters within an appropriate range does not affect the results significantly.

11.8 Monitoring

SEPIL will undertake a comprehensive programme of monitoring for air quality impacts. It will include: • Direct testing of stack emission concentrations • Ambient air quality monitoring at selected locations around the Terminal • Quantification of flared and vented emissions through logging of events and their associated quantities and the use of standard emission factors (and known gas properties) to convert these to pollutant emission quantities. Most of these aspects will entail the reporting of monitoring results to the EPA and the information will be publicly available.

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The conditions of the Industrial Emissions Licence will dictate the exact details of the programme.

11.9 Reinstatement and Residual Impacts

Emissions similar to those that arose during construction will occur during decommissioning. No combustion or other emissions to atmosphere will occur after gas production from the Corrib field has stopped and there will be no vehicle activity associated with the Terminal once decommissioning and abandonment is complete, therefore there will be no residual air quality impacts or reinstatement as a result of the Terminal development abandonment.

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12 NOISE

12.1 Introduction

The 2003 Terminal EIS considered the likely impacts of the development and operation of the Bellanaboy Bridge Gas Terminal on the noise climate of both the immediate and wider environs of the site. As detailed in Section 1, some minor amendments have subsequently been incorporated into the layout and technical design of the Terminal facilities and the potential influence of these changes on noise emissions from site has been considered in detail. The engineering changes requiring updates in the schedule of significant noise sources on which the noise emissions models are based comprise the following: • Noise source updates following engineering reviews, updated vendor data and early site testing; • Minor engineering changes – addition of a methanol injection system lube oil pump and ventilation louvres to the Power Generation Building; and • Review of flare and cold vent flow rates following onshore pipeline pressure reduction and process modifications. The Terminal facilities have now been constructed, however the plant is yet to be commissioned. Some plant items have been tested individually, however, and in a number of instances more detailed vendor data has been obtained in relation to noise emissions. Noise source data has been updated accordingly. References are made in this section to related documents which form part of the Industrial Emissions Licence Application to the EPA, specifically the noise emissions modelling report and the noise source table of associated model inputs. The results from the modelling study are presented in this Section of the Supplementary Update Report This section has been prepared by Clarke Saunders Associates. For inspection purposes only. Consent of copyright owner required for any other use. 12.2 Study Methodology This section includes the following: • A review and update of the baseline noise survey data; and • A re-assessment of the potential impacts likely to arise as a result of the future operation of the Terminal. The updated assessment will account for the following updated guidance: • EIA Directive (85/337/EEC) as amended, codified by Directive 2011/92/EU of 13 December 2011; • BS 5228-1:2009 Code of practice for noise and vibration control on construction and open sites. Noise; • ISO 1996-2:2007 Acoustics - Description, assessment and measurement of environmental noise. Part 2: Determination of environmental noise levels; and • EPA Guidance Note for Noise: Licence Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4).

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12.3 Receiving Environment

12.3.1 Characteristics and Noise Features of the Receiving Environment

The environs of the Terminal site are essentially the same as those considered in the 2003 Terminal EIS. In the intervening period some increase in daytime noise levels in the immediate vicinity has occurred at times due to construction and haulage associated with this, in addition to general activity on the road network. Other general changes include increases in tree heights surrounding the Terminal footprint. This provides an element of additional noise screening, particularly in areas where replanting and subsequent growth have occurred. The historical background noise survey data indicated that the site may qualify as an ‘Area of Low Background Noise’. The screening process described in EPA NG4 has been followed, therefore, to consider whether the Noise Sensitive Receptors (NSRs) should be deemed to be in areas of low background noise. The qualifying requirements for this definition are if, at a given NSL, all three of the following criteria are satisfied: • Average Daytime Background Noise Level ≤40dB LAF90; • Average Evening Background Noise Level ≤35dB LAF90; and • Average Night-time Background Noise Level ≤30dB LAF90. The Terminal has been designed and built to comply with standards equal to the more onerous standards required for an ‘Area of Low Background Noise’. Short term manual survey measurements were carried out at the closest NSLs to the Terminal site during November 2013, and compared with data collected in 2000, 2001, 2003 and 2008. Each of these surveys represents a snapshot in time, of a continuously and highly variable soundscape which is highly dependent on meteorological conditions. Considerable experience of environmental noise survey measurements in the area from the wider Corrib project has been gained during this period, including long term statistical data from semi-permanent and permanent noise logging stations at the For inspection purposes only. Terminal site and along theConsent onshore of copyright pipeline owner required route. for any A other detailed use. review and analysis of both manual and automated noise survey measurement data is presented in the background or ‘baseline’ noise survey report at Appendix 12.1, the findings of which are summarised as follows: • No long term trends have been identified in the soundscape; • Although some NSR dwellings could be defined as in an ‘Area of Low Background Noise’ many are not in the category due to proximity to road traffic noise sources. However, the more onerous standards are applied for all receptors in any event; • Weather strongly influences the soundscape of the area. Accurate measurement of low noise emission levels presents significant challenges for much of the time; and • Entirely calm conditions in which low noise levels can be measured reliably have been confirmed from monitoring at the Terminal site to occur for less than 2% of the time.

12.4 Characteristics of the Proposed Development

Changes which could have a bearing on the noise emissions characteristics are:

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• Noise source updates - following engineering reviews, updated vendor data and early site testing; • Minor engineering changes (see below); and • Review of flare and cold vent flow rates (see below).

12.4.1 Noise Source Updates

A schedule of plant items with the potential to generate significant noise levels was used as the basis for the Terminal noise emissions modelling presented in the 2003 Terminal EIS. This schedule has been maintained, and updated with engineering developments over the intervening period and reviewed, (Appendix 12.2). The updated noise modelling also takes into account site measurement data for the fire water pump house and associated systems, and some of the more significant cooling fan systems which could be run prior to full plant commissioning with hydrocarbons (BFG). In some cases vendor data has been augmented or updated with refined vendor submissions, and/or derived empirical data on review with the engineering contractor. The most robust options were selected for all assumptions. Individual pipeline sources were included for the more significant sections of plant pipework in the 2003 schedule, but subsequently replaced with an overall sound power budget for all process valve and associated pipework noise sources, with responsibility given to the engineering contractor to demonstrate compliance more holistically, and comprehensively. Although this dramatically increased the complexity of the assessment process for the engineering contractor, introducing many lower level noise sources which made very minor contributions to the overall noise emissions level, it provided an increased level of contractual confidence in the final noise control outcome. A very detailed study of noise emissions from process valves and pipework was undertaken by the engineering contractor, which resulted in a programme of additional noise control lagging works to achieve demonstrable compliance with this requirement.

12.4.2 Minor Engineering Changes For inspection purposes only. Consent of copyright owner required for any other use.

A single additional plant item, namely a pump required to transfer oil in the lubricating system of the methanol injection pumps, has been added to the list of significant noise sources. Other additional plant items, for example the pumps required for transfer of the treated produced water for discharge at the Corrib subsea manifold, were excluded as they will not constitute a significant new noise source. The requirement for ventilation openings to be added to the Power Generation Building prompted a review of the noise levels anticipated within this building. The noise source schedule has been amended accordingly.

12.4.3 Review of Flare and Cold Vent Flow Rates

A review was undertaken of noise emissions arising from all conceivable maintenance and upset scenarios in which hydrocarbon inventory would need to be discharged from the Terminal either by cold venting or flaring. The Terminal gas pressures and resultant flow rates associated with these scenarios have changed due to the reduction in the onshore pipeline operating pressure associated with the permitted changes to the Corrib onshore pipeline design, as well as process rationalisation and updates. The noise schedule has been updated accordingly.

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12.5 Potential Impact of the Proposed Development

12.5.1 Construction Noise

Construction of the Terminal facilities is almost complete, with ongoing minor revisions and amendments prior to commissioning. Activities continue to be carried out within comfortable compliance with the noise limits set by Mayo County Council for the construction phase. All current and future activity which could be described as part of the Terminal construction process is very modest in scale, such as further demobilisation of temporary construction facilities as well as landscaping works, and can effectively be considered to have no further potential for noise impact, over and above that assessed in the 2003 Terminal EIS.

12.5.2 Operational Noise

The Terminal is a significant industrial plant, comprising hundreds of individual noise sources, many of which could give rise to significant noise impacts on nearby receptors unless appropriate noise control measures are in place. The facility has been constructed, with the control measures in place, following extensive noise control input into the engineering design. In adopting robust and pessimistic approaches wherever applicable the potential for impact has been minimised by the mitigation already in place. Plant noise sources may also have the potential to generate tonal noise, which if detected at the noise sensitive locations would represent an impact. Wherever applicable, additional noise control treatments have been applied to the more likely tonal emissions candidate plant items. The potential impact of noise disturbance on faunal species during construction and operation of the Terminal is addressed in Section 6.5.

12.6 Do Nothing Scenario

The do nothing scenario is no longer relevant as the Terminal has been constructed. For inspection purposes only. Consent of copyright owner required for any other use. 12.7 Mitigation Measures

Noise control has been a fundamental design element of the Terminal site and a key constraint in equipment selection and specification. Acoustic enclosures, packages and lagging treatments are evident throughout the facilities, with many buildings equipped with enhanced sound insulation and internal acoustic absorption as required. The plant has been designed so that during normal operation the noise contribution from the Terminal does not exceed the following noise levels as assessed at the nearest noise sensitive location (i.e. residential dwelling) under free field conditions:

• Daytime (07:00-23:00) 45 dB LAeq,1hr

• Night-time (23:00-07:00) 35 dB LAeq,15min During commissioning, noise verification measurements will be made to verify compliance with these limits and to identify both the levels and tonal content of key plant items. Receptor location tonality tests will be conducted during this process.

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12.8 Predicted Impact of the Proposed Development

The predicted noise levels at all NSR dwellings are anticipated to fall within the emission limit values for both day and night operational cases (see noise emissions contours in Figures 12.1 and 12 2). The daytime compliance margins are greater, because the vast majority of noise sources are designed for 24/7 operation, making night-time the critical design case. The noise modelling has been based on the assumption that all normal process plant runs continuously and concurrently. It is anticipated, therefore, that the actual operating conditions will result in a general situation in which noise levels are lower than the predicted and emission limit values by a greater margin the vast majority of the time. The more detailed understanding of the micro-climate in the immediate vicinity of the Terminal site from a number of years on site weather monitoring has enabled a more accurate prediction of the influence on noise propagation. Worst case weather conditions are considered in all directions in the noise modelling report, with reduced levels of impact during prevailing conditions. Noise levels generated during planned maintenance activities, including compressor change-overs and other cases in which hydrocarbons are discharged without a lit flare are modest. Relatively high noise levels can be expected in many of the lit flare scenarios, however, and could be described as potentially startling at the NSR dwellings nearer to the Terminal site. As in the 2003 Terminal EIS, the predicted operational noise impacts are moderate at NSR dwellings less than 1 km from the Terminal and negligible further afield.

12.9 Monitoring

A noise monitoring programme has been established on the basis of the site’s Industrial Emissions licence and includes continuous noise monitoring at the location indicated in Figure 12.3. Further technological developments, and lessons learned from noise compliance monitoring during the construction of the Corrib onshore pipeline have enabled the For inspection purposes only. monitoring regime to beConsent enhanced of copyright further. owner required for any other use.

A second continuous noise monitoring station will be established on the Terminal site (at the administration building, see Figure 12.3), and both monitors will provide for direct correlation with local meteorological conditions and proxy-monitoring of noise levels to enable a more accurate demonstration of compliance with the noise limits set in the Industrial Emissions licence. In addition, other monitoring locations previously defined as traditional site boundary positions for periodic manual survey measurements have been moved closer to the Terminal footprint, to locations which are more accessible. These will provide for more accurate and reliable measurements of site noise rather than ambient and weather related measurements.

12.10 Residual Impacts and reinstatement

During the operational life of the facility the mitigated, residual noise impact is expected to be moderate in the close vicinity of the Terminal, and less significant further afield. This assessment of noise impact remains as reported in the 2003 Terminal EIS, with noise emissions levels which comply with EPA’s more onerous guideline values for an ‘Area of Low Background Noise’.

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Decommissioning activities will be carried out under the same controls and mitigation activities as construction of the Terminal. The impact can be expected to be similar or lower than the noise levels experienced during construction. No residual noise impact is predicted following decommissioning and reinstatement.

For inspection purposes only. Consent of copyright owner required for any other use.

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13 LANDSCAPE AND VISUAL IMPACT

13.1 Introduction

A review of the landscape and visual impact of the Terminal development has been carried out taking into account changes to the receiving environment and amendments that have occurred since the 2003 Terminal EIS. This section has been prepared by RSK Environment Ltd.

13.2 Study Methodology

This section includes the following: • An update of the baseline information presented in the 2003 Terminal EIS; and • A review of the potential impacts likely to arise as a result of the remaining construction activities and future operation of the Terminal. The review has been undertaken in accordance the following latest guidance: • Environmental Protection Agency (2003) Advice Note on Current Practice (in the preparation of Environmental Impact Statements); and • Landscape Institute & Institute of Environmental Management & Assessment (2013) Guidelines for Landscape and Visual Impact Assessment (3rd Ed.). The landscape and visual impact assessment methodology and significance criteria remain as stated in the 2003 Terminal EIS.

13.3 Receiving Environment

13.3.1 Character of the Surrounding Wider Landscape

The landscape character of the surrounding wider area remains as described in the 2003 Terminal EIS. Though it is noted that there have been changes in the landscape in relation to coniferous plantations, where there has been substantial growth in what were young plantations at Forthe inspection time purposesof the only. 2003 Terminal EIS, and areas where Consent of copyright owner required for any other use. coniferous plantations have been clear felled. Several new properties have also been built to the south of the Terminal site.

13.3.2 Character of the Gas Terminal Development Area

Whilst the Terminal has been constructed, the landscape character of the immediate area remains as described in the 2003 Terminal EIS. However, it is noted that the existing coniferous plantations and deciduous scrub vegetation have achieved substantial growth since the time of the 2003 Terminal EIS, and areas of rush dominated grasslands have become colonised, in part, by self seeded coniferous species and deciduous species such as willow. In addition, as part of the landscape and ecological mitigation strategy committed to in the 2003 Terminal EIS, areas of open rush dominated grasslands, located in between existing coniferous plantation belts, were planted in 2009 (Landscape Mitigation Planting Phase Ia) with a substantial number of coniferous trees and a deciduous species mix planted to the edges. This mitigation planting has achieved strong growth to date.

13.4 Characteristics of the Proposed Development

The minor modifications to the detailed design and layout of the Terminal that are relevant to landscape and visual impacts can be summarised as:

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• Changes to landscape planting, including revisions to the planting in the vicinity of the settlement ponds, additional tree planting in areas to the west of the Terminal footprint including along the alignment of the main carrier drain, additional planting and creation of wetlands in the ‘western fields’ part of the site, and the addition of a planter alongside the western side of the main North- South Access Road within the site; • Minor changes such as removal of a previously permitted stack (the Heating Medium Fired Heater), relocation of the Power Generation Building exhaust stacks, new roof top enclosures, additional equipment on top of piperacks, additional stairs, addition of further emergency escape lighting within the Terminal footprint and low-level lighting at the settlement ponds water sampling station, and addition of windsocks; and • Equipment and structure additions and layout modifications at the main site entrance onto the R314 as detailed in two subsequent amendment applications (PA-001 and PA-005) affecting this area.

13.5 Potential Impact of the Proposed Development

13.5.1 National Landscape Designations or Listings

As described in the 2003 Terminal EIS, there are no designated landscapes affected by the presence of the Terminal. There has been no change to the Inventory of Outstanding Landscapes in Ireland since 2003.

13.5.2 Development Plan

The 2003 Terminal EIS considered relevant plans from the Mayo County Development Plan 2003-2009. This has been superseded by the Mayo County Development Plan 2008-2014. Relevant policies from the 2008-2014 plan and the emerging Mayo County Development Plan 2014 -2020 are detailed below in Table 13.1. Table 13.1: Relevant Development Plan Policies Policy Summary of Policy Key changes compared to Ref For inspection purposes only. 2003-2009 Consent of copyright owner required for any other use. Adopted Mayo County Development Plan 2008-2014 P/ EH-LC Recognizes and facilitates appropriate No change 1 development with regard to the character and sensitivity of the landscape. Proposals for development that have the potential to impinge on the integrity of significant landscape resources will be assessed having regard to the guidelines set out in Section 4.18 of the Development Management Guidelines. P/ EH-LC States that all proposed development shall No change 2 be considered in the context of the Landscape Appraisal of County Mayo reference to the four Principal Policy Areas shown on ‘Map 9’. P/EH-VP Ensure development does not adversely No change 1 interfere with views and prospects and the amenities of places and features of natural beauty or interest when viewed from the public realm. These are identified on ‘Map 10’.

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Policy Summary of Policy Key changes compared to Ref 2003-2009 P/EH-VP Ensures all proposals have regard to the New Policy 2 potential visual effects of development. Emerging Mayo County Development Plan 2014 -2020 PY-03 Recognises the inter-relationship between New Policy the environment; the economy; and well being of citizens. Ensures development in the County does not compromise the value of, or cause deterioration to, natural and cultural resources. LP-01 Recognise and facilitates appropriate New Policy development in a manner that has regard to the character and sensitivity of the landscape. Ensures that development will not have a disproportionate effect on the existing or future character of a landscape in terms of location, design and visual prominence. VP-01 Ensures that development does not New Policy adversely interfere with views and prospects worthy of preservation and protection, which are indentified on ‘Map 3’.

Map 10 accompanying the 2008-2014 Development Plan and Map 3 accompanying the 2014-2020 Development Plan identify scenic views and viewing points. The views and viewpoints remain as shown in the 2003 Terminal EIS.

13.5.3 Landscape Appraisal of County Mayo

The landscape descriptions set out in the current Landscape Appraisal of County Mayo 2008, remain as described in the Landscape Appraisal of County Mayo 2003-2009 and as set out in the 2003 Terminal EIS namely: • The Terminal lies within For inspection Landscape purposes only. Character Unit, Area C – North West Consent of copyright owner required for any other use. Coastal Bog; • Areas designated as Scenic Routes remain as per the County Development Plan and have not changed since the 2003 Terminal EIS; and • The Terminal lies within Principal Policy Area 1 – Montaine Coastal Zone. Following the classification of the landscape the council continue to use a Landscape Sensitivity Matrix to assess the potential impact a proposed development may have on the landscape.

13.5.4 Siuloidi lorrais (Erris Walks)

Details of walks known as the "Siuloidi Iorrais" (Erris Walks) remain as stated in the 2003 Terminal EIS.

13.5.5 Impact on Visual Amenity

Visual Impact from Properties, Roads and Surrounds As part of the 2003 Terminal EIS, a visual impact survey was undertaken involving the identification of key viewpoints from sensitive receptors (properties, roads and surrounding areas), the taking of photographs and the production of computer

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generated photomontages. A careful review of present day views is provided in Section 13.8.2. Night Time Visual Impact Consideration of potential night time visual impacts was provided in the 2003 Terminal EIS. A review of the actual lighting implications during construction and operation is provided in Section 13.8.2. The potential impact associated with the implementation of the landscape strategy on flora and fauna species is addressed in Section 6.5.

13.6 Do Nothing Scenario

The do nothing scenario is no longer relevant as the Terminal has been constructed.

13.7 Mitigation Measures

13.7.1 Terminal Design

The design of the Terminal incorporated a number of mitigation measures to minimise the visual impact of the facility, including colour treatment; locating the Terminal within an area of mixed age coniferous plantation; retention of existing screening as much as possible; and setting a reduced level for the Terminal platform. The Terminal facilities have been constructed and these mitigation measures continue to be incorporated.

13.7.2 Landscape & Ecological Mitigation Strategy

The mitigation measures outlined in the 2003 Terminal EIS continue to apply for any remaining construction activities.

13.7.3 Retention and Protection of Existing Trees

The principal strategy described in the 2003 Terminal EIS has been honoured. The protection to trees has been maintained, despite the fact that the overall construction period has been extended. For inspection purposes only. Consent of copyright owner required for any other use.

13.7.4 Forestry Management

The wider site is owned by and under the control of SEPIL to ensure no loss of visual screening through clear felling occurs and that a continuous effective screen around the whole of the Terminal site will be maintained throughout the lifespan of the development.

13.7.5 Proposed Planting

Phase I landscape mitigation planting undertaken and completed during the construction phase of the Terminal has comprised: • The planting of the new coniferous plantation to the west of the Terminal site; • Planting of deciduous trees and low deciduous scrub along the margins of the new plantation together with the additional marginal planting in association with the existing plantation to the north of the Terminal; • Tree and shrub planting along the boundary with the R314; • Coniferous and deciduous tree and shrub planting to the west of the Terminal site along the export pipeline road, carrier drain road; and

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• Native and ornamental planting around the administration building and car park areas, and to the embankments surrounding the Terminal facility.

13.7.6 Ecological Mitigation Proposals

The ecological mitigation strategy set out in the 2003 Terminal EIS included measures that would provide both landscape and ecological mitigation, including supplementing the low deciduous scrub habitat lost to construction works (refer to Phase Ia and Ib below). New planting of low deciduous scrub habitat was undertaken in 2009 and 2013.

The reinstatement strategy that has been developed and refined in tandem with the landscape strategy for the site is being implemented. This includes those measures set out in Section 6 of the 2003 Terminal EIS under “Habitat Retention, Replacement and Landscaping” and further biodiversity enhancement measures such as wetland creation, planting of deciduous trees and scrub, and planting of suitable species - rich grassland which have been incorporated into the reinstatement strategy in particular in the western part of the site. This is further described in Section 6 of this report and is the subject of a planning amendment for which permission has been granted by Mayo County Council (MCC Reg. Ref 12/603).

The inclusion of boardwalks in the permitted plans for the western part of the site will provide biodiversity educational potential going forwards as the wetland and deciduous scrub woodland habitats mature.

13.7.7 Site Reinstatement Proposals

The landscape and ecological mitigation strategy set out above forms the basis for the detailed plans for the removal of the temporary construction facilities and final landscaping and habitat reinstatement which will be undertaken during the early years of operation of the plant. The final site reinstatement proposals following the decommissioning of the Terminal remain as stated in the 2003 Terminal EIS.

For inspection purposes only. 13.7.8 Mitigation Programme Consent of copyright owner required for any other use.

Landscape mitigation works to be completed in 2014 comprise further deciduous tree and shrub planting to the west of the Terminal site along the carrier drain road, and around the settlement ponds area where there will also be planting of wetland habitat species. In addition, habitat reinstatement and creation along with biodiversity enhancement measures are also planned as set out in Section 6. Mitigation works are to be implemented in a phased approach following the anticipated Temporary Construction Facilities reinstatement programme between 2014 and 2017, which includes the removal of temporary site compounds and offices. It will comprise: • Further planting of coniferous and native deciduous trees and scrub along the margins of the existing plantations to the north east of the Terminal; and • New planting in association with the main entrance features, including the stone wall and ESB facility.

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13.8 Predicted Impact of the Proposed Development

13.8.1 During construction

The duration of the overall disturbance associated with construction has been greater than initially anticipated, however the level of overall predicted impact associated with the construction of the Terminal remains as stated in the 2003 Terminal EIS.

13.8.2 During Operation

Impact on Landscape Character The site of the proposed Terminal was chosen to take maximum advantage of extensive coniferous plantations, which have provided immediate, significant and effective screening. The inherent screening provided, combined with careful attention to the design, layout and colour treatments applied to component parts of the facility, have ensured that the vast majority of the development is not discernible in the landscape. The assessment of operational impacts presented in the 2003 Terminal EIS remains valid. The choice of site has ensured that overall the impact of the proposed development is one of slight negative significance. Impact on Visual Amenity Visual Impact from Properties A careful review has been undertaken of the actual present day views from sensitive residential receptors to those predicted through the creation of photomontages at the time of the 2003 Terminal EIS. Overall it is clear that the Terminal is being screened to a greater extent than was depicted in the photomontages, as a result of the tree growth and enhanced screening of existing vegetation which has occurred since the time of their preparation. The impact remains minor or negligible from housing at short distances from the site, moderate impact from the property represented by viewpoint 17, and a moderate/substantial impact to the property represented by viewpoint 1 and to the property represented by viewpoint 11 in the 2003 Terminal EIS. For inspection purposes only. Visual Impact from Roads andConsent Surrounds of copyright owner required for any other use.

A careful review has also been undertaken of the actual present day views from sensitive roadside receptors. Again, overall it is clear that the Terminal is being screened to a greater extent than was depicted in the photomontages, as a result of the tree growth and enhanced screening of existing vegetation which has occurred since the time of their preparation although it is acknowledged that the views looking north east from R314 have more open views of the Terminal than originally anticipated. However, overall the impact remains minor or negligible from roads at short distances from the site and moderate impact from sections of roads in the middle distance. Night Time Visual Impact Concerns have been raised that lighting needs to be carefully controlled to minimise light pollution. Construction works have been continuing in the area, incorporating temporary construction facilities associated with the onshore pipeline. The requirement for lighting during the remaining construction and operation of the Terminal remains as stated in the 2003 Terminal EIS. Mitigation measures including the production of a Light Emissions Management Plan remain as stated in the 2003 Terminal EIS and will be implemented once the plant reaches steady state operations.

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Lighting in relation to wildlife is discussed in Section 6 of this report, and taking into consideration the permitted amendment (eg. MCC Reg.Ref 13/68) in lighting since 2003, impact predictions made in the 2003 Terminal EIS remain valid. Summary The assessment of operational impacts presented in the 2003 Terminal EIS remains valid. Overall the impact of the development over the lifetime of the Terminal, including the minor modifications to the detailed design and layout that have been permitted since the time of the assessment in the 2003 Terminal EIS, is considered to be of slight negative significance, as was previously the case.

13.9 Monitoring

The 2003 Terminal EIS proposed a five-year post planting monitoring period of each landscape phase, to be followed by a monitoring programme in accordance with a Landscape Management Plan. The five year monitoring plan remains as stated in the 2003 Terminal EIS, however due to the extended construction period the Phase I and Phase II mitigation has been split over a number of years, and therefore each separate sub-phase is subject to its own 5 year monitoring period as follows: • Phase Ia 2009-2014; • Phase Ib 2013-2018; • Phase Ic 2014-2019; and • Phase II (Western Fields and temporary construction areas including the remaining site offices and site canteen) 2015 – 2022. It should be noted that as set out in Section 6.8 of this Supplementary Update Report, any ecological monitoring in relation to habitats (reinstated, enhanced and created) will be carried out in accordance with the sites Environmental Monitoring Programme - as revised, amended and updated during the life of the Project.

13.10 Reinstatement and Residual Impacts

The long term will see the substantial removal of the Terminal, including all above- For inspection purposes only. ground features, in accordanceConsent of copyright with owner legislativ required efor requirementsany other use. in force at that time. This remains as stated in the 2003 Terminal EIS.

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14 CLIMATE

14.1 Introduction

The 2003 Terminal EIS considered the emissions of greenhouse gases (GHGs) arising from the construction and operation of the Terminal. The emissions that were assessed were those that had the potential to affect or contribute to global warming and ozone depletion. As detailed in Section 1 and 2, minor amendments have been incorporated into the design of the Terminal. Of relevance to emissions with global warming potential, the major design change made since the 2003 Terminal EIS (included in the 2006 EIS Addendum) is the inclusion of a waste heat recovery system on the gas compressor turbines instead of the use of a direct fired heating medium heater. The predicted GHG emissions from a number of other sources have also changed, either through minor design changes or reassessment based on new information or techniques. An additional aspect comprising the quantification of CO2 releases resulting from peat disturbance associated with Terminal construction, has also been provided. The Terminal has been constructed, but is yet to be commissioned. This section has been prepared by RSK Environment Ltd.

14.2 Study Methodology

This section includes the following:

• CO2 emissions estimates for the peat disturbance associated with Terminal construction; and • An update of the predicted operational greenhouse gas emissions as a result of improvements to the design of the Terminal. The basic methodology of this study remains as stated in the 2003 Terminal EIS. It quantifies the GHG releases associated with the development and operation of the Terminal and places them into context by comparing them with Ireland’s national For inspection purposes only. emissions. Consent of copyright owner required for any other use.

The quantification of the peat-related carbon emissions has used the Scottish Government’s research report with accompanying guidance and calculator describing a methodology for “Calculating Carbon Savings from Windfarms on Scottish Peatlands – A New Approach”. This methodology was first published in 2008 and was used in the Onshore Pipeline EIS (RPS 2010), though there have been minor refinements since.

14.3 Characteristics of the Proposed Development

14.3.1 Construction

The remaining construction related activities i.e. final landscaping have not significantly changed since 2003 Terminal EIS.

14.3.2 Operation

The basic characteristics of the Terminal operations affecting GHG emissions during the operational phase are largely unchanged from those described in the 2003 Terminal EIS and the 2006 EIS Addendum. The major sources of GHG emissions are still combustion in the compressor turbines and power generation engines. Less significant sources are the maintenance flare, the high pressure flare (through which natural gas will also be vented, uncombusted, under certain scenarios), minor

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combustion sources (emergency generator, firewater pumps) and fugitive emissions (leaks from joints, valves and components). The quantities of the emissions from each source category have been updated, resulting from either changes in the design or operational philosophy of the Terminal, or new information or quantification techniques.

14.4 Potential Impact of the Proposed Development

14.4.1 Construction

Emissions with a potential to impact climate from any remaining construction activities on the Terminal site have not changed from those presented in the 2003 Terminal EIS apart from the ability to quantify CO2 emissions associated with peat disturbance. An assessment of the carbon losses arising from the felling of trees and removal of peat during construction is provided below. The following relevant aspects of peat disturbance are included in the Scottish Government methodology: • Loss of Carbon Fixing Potential of Peat Lands; • Changes in Carbon Stored in Peat Lands – Removed Peat; • Changes in Carbon Stored in Peat Lands – Drained Peat; • Loss of Carbon Dioxide due to Leaching of Dissolved and Particulate Organic Carbon; and • Loss of Carbon due to Forestry Felling.

14.4.2 Operation

During operation, Terminal GHG emissions will comprise: • Releases from combustion processes to provide energy to the Terminal; • Emissions from flaring and venting; and • Fugitive emissions.

As set out in the 2003 Terminal ForEIS, inspection the purposesprincipal only. combustion processes are the gas Consent of copyright owner required for any other use. turbines which drive the sales gas compressors to pressurise the natural gas which is transferred into the national distribution network and the power generation engines which produce the electrical power used on the site. Where gas must be disposed of, under abnormal operating conditions or for maintenance events, it is flared or vented. Flaring is the normal method for removing hydrocarbon inventory in an emergency or upset process conditions, whereas gas is (cold) vented in some operational circumstances, e.g. during planned and unplanned change-over from the duty to the standby compressor. Fugitive emissions may occur from connections such as valves and flanges.

14.5 Do Nothing Scenario

The do nothing scenario is no longer relevant as the Terminal has been constructed.

14.6 Mitigation Measures

All peat removed from the Terminal site was transported to the nearby Srahmore peat deposition site where it was placed in a former commercial peat cur-over. This has limited the amount of carbon released, and resulted in the retention of stored carbon rather than the overall carbon losses to the atmosphere as may occur for example when extracted peat, is used as a fuel or as a garden product.

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14.7 Predicted Impact of the Proposed Development

14.7.1 Construction

Total carbon loss calculations have been undertaken in accordance with the Scottish Government methodology and associated spreadsheet tool as presented in Appendix 14.1. Table 14.1 below presents a summary of the estimated carbon losses associated with the removal of peat and felling of trees during construction of the Terminal. The calculations assume that all stored carbon is oxidised and released to the atmosphere as CO2 – for example through combustion as a fuel, and therefore take no account of mitigation measures that were applied (see Section 14.9). Table 14.1: Carbon Emissions During Construction (Before Mitigation) Source Carbon Emissions (tCO2e) Loss of carbon fixing potential of peat 156.4 Changes in carbon stored in peat – removed peat 90,758.3 Changes in carbon stored in peat – drained peat 2,819.8 Loss of carbon from leaching of dissolved organic carbon and 29,198.3 particulate organic carbon Loss of carbon due to forestry felling 773.9 Total carbon emissions 122,706.7

14.7.2 Operation

The updated predicted inventory of greenhouse gas emissions, broken down into source categories, is presented in Table 14.3. Table 14.3: Operational GHG Emissions from the Terminal

Emissions Total GHGs (t/yr) Source (tCO2e/yr) For inspection purposes only. Consent of copyrightCO2 owner required for any CHother4 use. Energy Use/Power Generation Sales Gas Compressor 32,165 11 32,403 Turbines Electricity Generator 9,046 68 10,483 Engines Venting and Flaring Venting 0 26 551 Flaring 1,073 8 1,232 Fugitive Releases General Process Gas 0 17 352 Leaks Total 42,287 384 50,355

The inventory presented is for 2016, which is currently the year of the highest predicted emissions of those forecasted (all years to 2023). Emissions in the later years of this period are predicted to reduce by up to 20%.

Combustion and flaring CO2 emissions are calculated from predicted fuel use and gas flared; and a CO2 emission factor derived from the gas composition. Combustion methane emissions are calculated from Oil & Gas UK / DECC EEMS

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emission factors (see: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/1364 61/atmos-calcs.pdf). Venting and fugitive emissions are calculated from the predicted release quantities and the gas composition. The predicted leaks are based on a combination of the Environmental Emissions Monitoring System (EEMS) emission factors for certain components and a programme of leak testing undertaken by Shell in 2010. The combustion of diesel in minor combustion sources is predicted to contribute a further approximately 80 tCO2 and negligible methane. Over the last ten years (2003-2012), Ireland’s total yearly national greenhouse gas emissions have ranged from 58 to 70 million tCO2e (see: http://www.epa.ie/climate/emissionsinventoriesandprojections/nationalemissionsinvent ories/). The Terminal’s direct emissions would therefore contribute a small fraction (less than one thousandth) to this total.

14.8 Monitoring

As an installation which will be operating within the EU Emissions Trading Scheme, the Terminal will be subject to statutory monitoring and reporting of carbon dioxide emissions from combustion and flaring sources according to a monitoring and reporting plan under the Terminal’s greenhouse gas emissions (GHG) permit. Combustion and flaring emissions make up the majority of the Terminal’s GHG emissions.

14.9 Reinstatement and Residual Impacts

14.9.1 Peat Translocation

All 450,000m3 of peat excavated from the Terminal site was transported to the nearby Srahmore site operated by Bord na Móna and used to rehabilitate this former commercial peat extraction site. The peat was deposited at Srahmore between 2005 and 2007, with 100% vegetation cover quickly achieved. In addition For inspectionto the purposesnatural only. colonising process, in 2010 Bord na Consent of copyright owner required for any other use. Móna began creating pools by digging holes approx. 2m x 1m x 1m deep in the peat deposition areas and inoculated them with sphagnum moss. By mid-2012 there was between 20 and 100% Sphagnum cover in the pools and many more new pools have been created. The Sphagnum communities have begun to join up between pools which will lead in time to the formation of new peat. This mitigation has ensured the peat removed from the Terminal site has retained its integrity, and therefore that the carbon it contains has not been lost to the atmosphere as was assumed in Section 14.7 above.

14.9.2 Forestry Planting

Following construction of the Terminal, a total site area of 18.4 ha has been planted to date, of which approximately 95% (17.5 ha) comprised tree species (approximately 80% coniferous and 20% deciduous).

14.9.3 Residual Impacts

Table 14.4 presents construction phase carbon emissions (denoted “+” to indicate an increase in atmospheric carbon), together with carbon savings resulting from peat and forestry mitigation measures (denoted “-” to indicate a reduction in atmospheric carbon).

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Table 14.4: Residual Carbon Emissions during Construction

Source Carbon Emissions (tCO2e) Construction Total carbon emissions from peat +121,932.8 Total carbon emissions from forestry felling + 773.9 Reinstatement Carbon savings from peat translocation - 90,758.3 Carbon savings from new planting - 984.5 Residual construction carbon emissions + 30,964.0

It can be seen that the translocation of the excavated peat mitigates the large majority of potential carbon emissions. It can also be seen that the planting of trees over a larger area (17.5 ha) than was cleared for construction (12.7 ha) is calculated to result in net carbon savings. Following the implementation of these mitigation measures, residual carbon emissions are estimated at 30,964.0 tCO2e. The conservatively predicted total GHG emission from the operation of the Terminal in 2016 (the year of maximum predicted emissions) is approximately 0.05 million tCO2e. It is not possible to quantify the actual impact of specific GHG sources or sinks on the climate or environment as a whole.

For inspection purposes only. Consent of copyright owner required for any other use.

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15 CULTURAL HERITAGE (ARCHAEOLOGICAL AND ARCHITECTURAL HERITAGE)

15.1 Introduction

This section includes the following elements: • A review and update of the baseline information presented in the 2003 Terminal EIS; • An overview of the construction impacts predicted in the 2003 Terminal EIS in the context of main construction being completed; • A re-assessment of the potential impacts likely to arise as a result of the remaining construction related activities and the future operation of the Terminal; and • The results of archaeological monitoring that have taken place at the Terminal site in response to Planning Condition No 35 (Planning Reference No: P03/3343 and An Bord Pleanála Reference No: PL16.207212) and in the wider environment. The peat excavation programme of all ground works at the Terminal site resulted in no finds, features or material of an archaeological significance. This section has been prepared by Courtney Deery Heritage Consultancy in association Shell E & P Ireland Ltd (SEPIL).

15.2 Study Methodology

Monitoring and test excavation reports from the development of the Terminal were examined. The Mayo County Development Plan (2008-2014) and the draft Mayo County Development Plan (2014-2020) have been reviewed in the context of the development and consultation has taken place with the archaeologists responsible for the original assessment and the archaeological monitoring at the Terminal site during construction.

15.3 Receiving Environment For inspection purposes only. Consent of copyright owner required for any other use.

15.3.1 Cultural Heritage Landscape

As a result of the desk based analysis and field inspection of the proposed development area, the archaeological potential on the Terminal site was deemed in the 2003 Terminal EIS to be limited given the level of disturbance from the forestry activity and the early initiation date for the development of blanket bog in the region. On the basis of monitoring the site investigation test pits (Licence No 03E1487) and the information gathered during the impact assessment process, it was proposed that the overall impact on cultural heritage features would be negligible. However in compliance with the requirements of Condition 35 of the planning permission for the Terminal granted in 2004, all earthmoving and excavation works carried out on site were archaeologically monitored. Monitoring of peat and earth excavation for all site development works in relation to the Terminal site was undertaken from December 2004 until July 2005 (Licence No 04E1675) and from October 2006 to July 2007 (Licence No 04E1675ext). Under this licence additional and final monitoring works were also carried out in February and April 2009. During the excavation of peat, a permanent archaeological presence was maintained on site and all ground works across the footprint of the development were monitored. A specialist consultant from the Céide Field Interpretative Centre was

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retained in order to advise the monitoring archaeologists on the best practice in a peatland context. No archaeological or features of a cultural heritage interest were encountered. All archaeological work was completed under licence to the Heritage Service and a report was submitted to the National Museum of Ireland and the Department of Environment, Heritage and Local Government (DoEHLG) now the Department of Arts, Heritage and the Gaeltacht (DoAHG) in fulfilment of the licensing requirements. The following table (Table 15.1) summarises the results of various archaeological monitoring programmes across the Terminal site. Table 15.1: Archaeological Monitoring Results Licence No Archaeological Results 03E1487 Monitoring of geo-technical test pits. No archaeological material was discovered during the course of monitoring. 04E1675 Monitoring of peat excavation took place throughout the footprint of the development including, car park area, water treatment facility, emergency holding tank, the flare stack area, buildings, settlement ponds and pipeline wayleave as well as all roads, fencing and drainage for the site. No archaeological material or deposits were uncovered as a result of the monitoring programme. 05E0179 Monitoring of a 600m linear trench to provide a water supply to the Terminal site did not impact directly on any known archaeological remains and no archaeological material was uncovered in any of the excavated trenches.

In addition to this work, archaeological monitoring and test excavation have taken place in the wider environs of the site, and no archaeological finds or features have been revealed. The extent of this is summarised in Table 15.2 below. Table 15.2: Archaeological Investigation – wider area Licence No Archaeological Investigation 02E0568 Monitoring of topsoil removal at Glengad (offshore pipeline landfall site). 02E0846 Monitoring of inshore dredging operations in Broadhaven Bay. 02E1148 Monitoring of geotechnical test trenches in the intertidal area at Glengad. For inspection purposes only. 04E1660 Monitoring ofConsent site preparationof copyright owner work required an ford anygroundworks other use. associated with the peat

deposition site at Srahmore and Attavally. 05D086 & Maritime archaeological monitoring of pipeline trench excavations, Broadhaven Bay. 05R088 05E0411 Monitoring of geotechnical test pits and works at Glengad. 07D038, Foreshore areas were archaeologically investigated by dive and metal detecting 07D040 & surveys. 07R169, 07R170 08D14, Archaeological monitoring of construction works at Glengad Landfall. 08R49, 08E0204 & 08E0280 09E0176, Archaeological monitoring of construction works associated with the offshore Corrib 09E177, Gas Pipeline in Broadhaven Bay. 09R082 & 09D027 10E0120 Archaeological test excavation of a mound at Aughoose. 10D018 & The foreshore and intertidal areas at Aughoose and Glengad underwent further 10R034 archaeological inspection to assess any possible changes to exposure levels that may have taken place since the original on site assessment.

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Licence No Archaeological Investigation 11E0082 Archaeological monitoring of sites investigations at Aughoose. On-going archaeological monitoring (Licence No 11E0214 and 11R0090) associated with the Corrib onshore pipeline works is currently taking place in Glengad and Aughoose townland, and to date nothing of a cultural heritage significance has been discovered.

15.4 Characteristics of the Proposed Development

In addition to the anticipated landtake associated with the original Terminal footprint, as described in the 2003 Terminal EIS, further land take associated with a proposed landscaping scheme in the western fields has been permitted under Planning Amendment (MCC Reg. Ref. 12/603).

15.5 Potential Impact of the Proposed Development

Pre-development assessment determined that as there was a limited possibility that archaeological material, stray finds could be revealed during the ground preparation works on the Terminal site, archaeological monitoring was to be undertaken in order to mitigate any potential impact. This work is now completed and no further monitoring is required.

15.6 Do Nothing Scenario

The do nothing scenario is no longer relevant as the Terminal has been constructed.

15.7 Mitigation Measures

No further mitigation measures are required in relation to cultural heritage at the Terminal site; all mitigation measures as described in the 2003 Terminal EIS have been implemented.

15.8 Predicted Impact of the Proposed Development

15.8.1 During construction For inspection purposes only. Consent of copyright owner required for any other use.

The predicted impact of the proposed development was described as negligible in the 2003 Terminal EIS and this has been confirmed through archaeological monitoring as nothing of an archaeological significance was revealed.

15.8.2 During Operation

There are no operational effects anticipated in relation to cultural heritage.

15.9 Monitoring

There is no further requirement for archaeological monitoring.

15.10 Reinstatement and Residual Effects

There will be no residual effects in relation to cultural heritage.

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16 MATERIAL ASSETS

16.1 Introduction

The 2003 Terminal EIS assessed the potential impact of the project on resources that are available to the local community, including waste, the local road network and the consumption of chemicals, potable water and rock. This Supplementary Update Report presents a reassessment on these previously covered topics, as they relate to the remaining elements of the Terminal’s construction and operation. It is noted that whilst Terminal construction activity commenced during 2005 and is essentially complete, as detailed in Section 2 there are some remaining project elements to be completed. In the context of this Section, the most notable of these elements are the removal of temporary construction facilities and remaining landscaping works. it is still ongoing and it will require works over a further season to complete the remaining construction activities and the landscaping.

16.2 Solid Waste

16.2.1 Introduction

This section considers and reassesses the various solid waste materials and substances that will be generated during the final construction, commissioning, operation and decommissioning phases of the Terminal.

16.2.2 Study Methodology

Since the production of the 2003 Terminal EIS, changes to the Waste Management Act have resulted in changes to the categorisation of hazardous waste and a more rigorous system for the control and management of waste through licensing by the EPA or via Local Authority permits.

16.2.3 Receiving Environment

The physical environment within which the Terminal project sits remains as stated in the 2003 Terminal EIS. However, there have been some relevant legislative changes For inspection purposes only. which are detailed in theConsent following of copyright sections. owner required for any other use.

16.2.4 Characteristics of the Proposed Development

Some of the hazardous wastes that will be generated have changed since 2003 as a result of modifications to the process brought about by IPPC/Industrial Emissions Licensing requirements and design reviews. Table 16.1 presents an update of the generation of hazardous waste during the operational phase. The generation of non-hazardous and hazardous construction wastes remains largely unchanged from the 2003 Terminal EIS, albeit that the duration is longer than originally envisaged.

16.2.5 Potential Impact of the Proposed Development

The potential construction-related waste impacts remain largely unchanged from the 2003 Terminal EIS, but they have had a greater duration than that originally envisaged. The annual generation of Hazardous Waste during the Terminal’s operation has been reassessed in the light of the modification to the Terminal operations as described in Section 2 of this Supplementary Update Report. The updated types and quantities are presented in Table 16.1. Some of the Hazardous Waste will be generated during the Terminal’s operation on an intermittent or semi-continuous basis. Generally, wastes produced on this basis will

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relate to the treatment of the produced fluids, i.e. gas, condensate and produced water. Other Hazardous Waste will be generated during the Terminal’s operation on an occasional basis. This material will be predominately salts and scale deposits which will be removed from equipment during maintenance activities. Table 16.1 Hazardous Operational Waste Waste Description Volume Mass Frequency (m3) (tonnes) Aqueous Oil contaminated sand 0.40 0.05 1 per annum filter and inorganic salts cartridge type Condensat Oil contaminated sand 0.27 0.05 Annual e filter and inorganic salts cartridge type Odourisatio Oil contaminated 1.00 2.50 1 every 4 years n package anthracite activated carbon Mercury Oil contaminated 12.2 12.2 Every 8 years removal absorbent bed (gas stream) Mercury 14.5 14.5 Every 3 years removal bed (condensat e stream) Export Oil contaminated sand 0.02 0.1 each Annual methanol and inorganic salts filter cartridges. Product Oil contaminated sand 0.05 Annual methanol and inorganic salts filter cartridge type Produced Metals and inorganic 504 624.00 Annual For inspection purposes only. water salts Consent of copyright owner required for any other use. treatment sludge* Used 36 36 Annual chemical containers Contaminat Contaminated tri- 30.00 29 Every 10 years ed heating ethylene glycol medium Methanol Inorganic salts and 4.80 12.00 Every 3 years still reboiler sand with slight oil scale contamination Tankage Oil contaminated sand 50.00 100.00 Every 3 years and/or and inorganic salts vessel sludge Methanol Carbon steel with oil 7.00 Every 6 years reboiler contaminated sand and tubes inorganic salts Methanol Carbon steel with oil 1.00 Every 3 years still valve contaminated sand and trays inorganic salts

Chemical Spent chemicals used 5 4.5 Annual waste in laboratory Clinical 0.03 0.03 Annual

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Waste Description Volume Mass Frequency (m3) (tonnes) waste Oil 6 6 Annual contaminat ed clothing (PPE) rags etc Flourescent 0.024 0.024 Annual light tubes Condensat 840 672 Month e *The inlet filter separator will be periodically washed out and the waste water sent to the TPS.

16.2.6 Mitigation Measures

Waste Management The waste management plan to be implemented for the Terminal operations will reflect the requirements of all relevant Irish and European legislation ensuring that waste is generated, stored, transported and disposed of with the minimum risk to the environment. All other mitigation measures presented in the 2003 Terminal EIS remain unchanged.

16.2.7 Predicted Impact of the Proposed Development

Notwithstanding the changes to waste generation identified in the table above, the predicted impacts associated with its generation, handling and disposal remain as stated in the 2003 Terminal EIS.

16.2.8 Monitoring

The lists of current active landfill sites and hazardous waste transfer stations have been updated since the 2003 Terminal EIS. The monitoring requirements are aligned with the updated content in Tables 16.2 and 16.3. Table 16.2: Active Landfill Sites in County Mayo For inspection purposes only. Consent of copyright owner required for any other use. Waste Applicant/ Facility Status of Type of Annual Life License Holder Location Application waste Capacity span* Register Name permitted (tonnes) No. 67-2 Mayo Rathroeen, Licensed Non- 45,000 >10 County Ballina (Grid. Hazardous years Council Ref. G 123 323)

Table 16.3: Hazardous Waste Transfer Stations in

Waste Applicant/ Facility Status of Type of Annual License Holder Name Location Application waste Capacity Register No. permitted (tonnes) 36-2 Indaver Ireland Tolka Quay Licensed Hazardous 50,000 Ltd Road, Dublin 1 41-1 Enva Ireland Smithstown Licensed Hazardous & 37,400 Ltd Industrial Non Estate, Hazardous Shannon, Co. Clare 50-2 Veolia Corrin Fermoy, Licensed Hazardous 72,000 Environmental Co. Cork Services

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Waste Applicant/ Facility Status of Type of Annual License Holder Name Location Application waste Capacity Register No. permitted (tonnes) 54-2 Eco-safe Unit 1A, Allied Licensed Hazardous 9,525 Systems Ltd Industrial Estate, Kylemore Road 55-2 SRCL Ltd 420-430 Beech Licensed Hazardous & 15,000 Road, Western Non (Hazard Industrial Hazardous ous) Estate, Naas Road, Dublin 113-4 KMK MMetals Cappincur Ind Licensed Hazardous & 35,000 Recycling Ltd Estate Non Paingean Hazardous Road, Tullamore, Co. Offaly 115-1 Soltec (Ireland) Zone A Licensed Hazardous 5,000 Ltd Mullingar Business Park Mullingar, Co. Westmeath 145-2 Enva Ireland Unit 9a, Licensed Hazardous 5,000 Ltd Raffeen Industrial Estate, Raffeen, Monkstown, Cork 184-01 Enva Ireland Clonminam Licensed Hazardous & 101,000 Ltd Industrial Non (Hazard Estate, Hazardous ous) Portlaoise, Co. Laois 267-1 Hi Volt Ireland Ballyduff Licensed Hazardous 30,240 Ltd Thurles, Co. Tipperary 196-1 MacAnulty National Licensed Hazardous & 35,400 Specialis Recycling For inspectionand purposes only. Non Underground EnvironmentalConsent of copyright owner required for any otherHazardous use. Services Ltd Protection Ltd., John F. Kennedy Drive, JFK Industrial Estate, Naas Rd, Dublin 12

16.2.9 Reinstatement and Residual Impacts

The 2003 Terminal EIS predicted that there would be no impact on the local environment from the production of solid waste associated with the Terminal operation. New legislation concerning the management of waste will further serve to ensure that there are no impacts. The reinstatement and residual impacts following cessation of the gas processing activities on the site remain similarly unchanged from the 2003 Terminal EIS.

16.2.10 Relevant Legislation

Legislation update

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Since the 2003 Terminal EIS there have been changes to both Irish and European legislation relating to waste management. For completeness these changes are described here. European Union Legislation An updated table showing the most recent legislation is provided in Table 16.4 below. Table 16.4: European Waste Legislation Directive Name Summary 2006/12/EC Council Directive on Requires that any establishment that carries out disposal Waste operations or possible recovery operations will require a permit from the competent authority. Permits must cover types and quantities of waste, technical requirements, security precautions, disposal site and treatment method. Directive 2006/12/EC consolidates and replaces Directive 75/442/EEC as subsequently amended. 94/62/EC European Regulation introduces the concept of “producer As amended Parliament and responsibility” for packaging waste. Member states are by 2004/12/EC Council Directive on required to take measures to achieve 60% recovery by 2005/20/EC packaging and 2011 and material specific targets that range from 15% packaging waste (wood) to 60% (paper & glass). 75/439/EC Council Directive on Requires that any establishment undertaking “disposing” As amended the disposal of of waste oils (such as lubricating oils and used oils but by 87/101/EEC waste oils not oil refinery wastes) must obtain a permit from the 91/692/EEC competent authority. Member states shall take the 2000/76/EC necessary measures to ensure that waste oils are collected and disposed of without causing any avoidable damage to man and the environment. EC 1013/2006 Council regulation Establishes a system of supervision and control of all on the supervision movements of waste. It provides for a common, and control of compulsory notification system and for a standard shipments of waste consignment note for shipments of waste. Requires that within, into and out any holder of any toxic and dangerous waste who intends of the European to move it across a frontier is required to notify the Community competent authority of the member states concerned and where applicable, any third state, by means of a consignment note. Conditions are laid down covering packaging, labelling and instructions in the event of danger and an accident. For inspection purposes only. 2000/76/EC Waste IncinerationConsent of copyright Directive owner required introduces for any other use.controls when incinerating both Directive hazardous and harmless wastes may cause emissions of substances that pollute the air, water and soil, and have harmful effects on human health. 1999/31/EC Council Directive on It defines the different categories of waste (municipal the landfill of waste waste, hazardous waste, non-hazardous waste and inert waste) and applies to all landfills, defined as waste disposal sites for the deposit of waste onto or into land. Landfills are divided into three classes: - landfills for hazardous waste; - landfills for non-hazardous waste; and - landfills for inert waste.

Irish Legislation The most relevant piece of legislation currently in force is the Waste Management Act 1996 to 2012. However, as some of the related legislation listed in the 2003 Terminal EIS has been revised since the submission of the EIS, an updated list is presented below: • Waste Management (Licensing) Regulations, 2000 and 2004; • Protection of the Environment Act 2003; and

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• Waste Management (Shipment of Waste) Regulations 2007.

16.3 Traffic Impact Assessment

16.3.1 Introduction

The traffic flows and volumes during the project have been reassessed, and the changes identified to the operational phase from those reported in the 2003 Terminal EIS are presented below. No changes have been identified to the construction related traffic flows and volumes set out in the 2003 Terminal EIS other than the duration over which construction has taken place. The current activities on the Terminal site are landscaping and some on-going servicing and maintenance as well as providing some support to the onshore pipeline construction works.

16.3.2 Receiving Environment

Existing Road Network The road network used to facilitate the construction of the Terminal has been significantly upgraded since the 2003 Terminal EIS. In particular, the L1204 and R314 have been widened and re-surfaced. Significant additional road maintenance has also occurred on the wider road network. It is this road network that will be utilised for the remaining construction related activities and, as required by the parent planning permission for the Terminal, the condition of the road network will continue to be monitored and repaired as necessary during the remainder of the construction phase.

16.3.3 Characteristics of the Proposed Development

As a result of some changes to Terminal operations there will be the need to tanker offsite some materials which were not included in the 2003 Terminal EIS. These are detailed in Table 16.5. The revised heavy commercial vehicle (HCV) numbers do not differ materially from the HCV numbers anticipated in the 2003 Terminal EIS. Table 16.5 Additional Operational HCV traffic Change Traffic aspect New volume Duration Change from heating Additional road 1 per day Through the life of the For inspection purposes only. medium heater to waste Consenttanker of traffic copyright owner required for any other use. Terminal operation heat recovery Removal of produced Additional road 1 per day 4-6 weeks at the water containing MEG at tanker traffic commencement of well start up production from the Corrib field Removal of Urea as a Additional road 1 per month Throughout the life of the result of the use of tanker traffic Terminal operation Selective Catalytic Reduction Removal of treated Additional road Up to 3 per Throughout the life of the produced water in the tanker traffic day Terminal operation event of the volume exceeding the available umbilical capacity

16.3.4 Potential Impact of the Proposed Development

The potential impact from the remaining construction activities remains as stated in the 2003 Terminal EIS. The predicted traffic movements will be well within the maximum impacts predicted in the 2003 Terminal EIS.

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In terms of operational traffic movements, some additional traffic movements are expected (maximum 6 additional HCV movements per day (one way)). The traffic impact analysis undertaken for the 2003 Terminal EIS was based on a ‘worst case scenario’ involving 20 no. vehicles entering and 20 no. vehicles leaving the site during the peak hour, to account for overlap in traffic due to shift changes1. It is also worth noting that it was assumed that 100% of traffic will arrive from Bangor via the L1204 and from Glenamoy simultaneously in order to model the onerous case of right turning vehicles. Under this scenario, junction analysis showed a negligible increase in traffic flows and no significant impact on the road network, as evidenced by the data presented in Table 16.6 below (where ‘Junction 4’ is the intersection of the L1204 and the R314 (at Bellanaboy Bridge) and ‘Junction 7’ is the intersection of the L1204 and the R313 located northwest of Bangor. Table 16.6: Traffic Analysis Results for Operational Phase Junction 4 Junction 7 Maximum RFC 0.047 0.21 Queue (Vehicles) 0.0 0.3 (Source: Table 16.7 of Bellanaboy Bridge Terminal EIS) By way of explanation, the RFC is a measure of the ‘Ratio of Flow to Capacity’. A RFC value of greater than 0.85 is considered over-capacity. Thus a junction with an RFC less than 0.85 is deemed to be operating within capacity and any queues or delays which may be experienced are minimal. The very low ratios from the 2003 assessment demonstrate that there is sufficient capacity to easily accommodate the increase in traffic associated with the predicted 6 additional movements.

16.3.5 Mitigation Measures

Existing Road Network Inventory The 2003 Terminal EIS Traffic Management Plan (TMP) has been implemented and updated throughout the construction phase of the Terminal as appropriate and in agreement with Mayo County Council. In addition, a TMP has been prepared and is For inspection purposes only. currently implemented Consentfor the of copyright construction owner required of for the any otherCorrib use. Gas Onshore Pipeline. This plan takes account of the cumulative traffic movements associated with the activities at the Terminal and the Onshore Pipeline works. The TMP will continue to be used for all works associated with the remaining landscaping works on the Terminal site. Due to the low traffic numbers during normal operations there is no requirement for any further mitigation over and above that provided for in the TMP.

16.3.6 Predicted Impact of the Proposed Development

The predicted impacts remain as stated in the 2003 Terminal EIS.

16.3.7 Monitoring

SEPIL will continue to require that its contractors involved in the project adhere to the Traffic Management Plan.

1 It accounted for vehicle movements associated with approximately 50 personnel arriving / leaving the site (spread over four shifts) and three heavy goods or light goods vehicles (on average) servicing the site per day.

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16.3.8 Reinstatement and Residual Impacts

It is anticipated that the local road upgrades and the repair and maintenance works carried out to the main transport routes by Mayo County Council, will result in a better road surface following the construction period than before. SEPIL is committed to making sure that the pavement is reinstated as required after the construction works are completed.

16.4 Consumption of Chemicals

16.4.1 Introduction

This section considers the use of chemicals during operation and provides an update in relation to the chemicals that will be used and stored on the Terminal. The updates are listed in Table 16.7.

16.4.2 Study Methodology

This assessment of chemical use has been conducted as a desk top study and has drawn on information provided by SEPIL.

16.4.3 Characteristics of the Proposed Development

The characteristics of the chemical consumption remain as stated in the 2003 Terminal EIS. Table 16.7: Chemical Inventories and Estimated Use (subject to regular review and update) Material/ Substance Maximum Estimated Maximum Nature of Use Amount Annual Usage stored (tonnes) (tonnes) Natural Gas 48 Hydrocarbon Condensate 759 Diesel (aliphatic petroleum 66 32 Fuel distillates) Methanol 3350 For inspection purposes1825 only. Hydrate Inhibitor (i.e. Consent of copyright owner required for any other use. antifreeze agent) Corroless, Cortron CK352, Kl 4 70 Pipeline Corrosion Inhibitor 302C 0.5 0.6 Methanol Still Scale Inhibitor Tri-Ethylene Glycol 81 0 (single fill, Heating Medium corrosion replenished as inhibitor required, minimal losses expected) Nitrogen 2.5 (backup only). Blanketing of Storage Tanks, Purging of Process Equipment Hydrochloric Acid (5%) 10 20 Acid Wash of Methanol Still (descalant) Natural Gas Odorant (80% 9 22 Natural Gas Odorant Tertiary Butyl Mercaptan, 20% Di-Methyl Sulphide) Hydrated Lime 15 110 Produced/Surface Water Treatment 2-4-6 Trimercapto-s-triazine 1 2 Produced/Surface Water Trisodium Salt (TMT 15) Treatment Sulphuric Acid (30%) 2.5 62.4 Produced Water Treatment Milifloc EA900 Polyelectrolyte 1 5.8 Produced/Surface Water (anionic water soluble polymer Treatment in emulsion) or equivalent

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Material/ Substance Maximum Estimated Maximum Nature of Use Amount Annual Usage stored (tonnes) (tonnes) Sodium Hydroxide (30%) 3 7.7 Produced Water Treatment Ferric Chloride Solution 1 2.7 Produced/Surface Water Treatment Hydrochloric Acid (30%) 3 6.2 Produced Water Treatment Scale Inhibitor product to be 0.09 1 Nanofiltration membrane selected scale inhibitor (Produced Water Treatment) - Sodium Hypochlorite 0.5 To be determined. Potable Water Storage Generated on site Tank – Bacterial Growth from Sodium Chloride Inhibitor. Sodium Chloride 0.4 1 Potable Water Chlorination Package Propane 0.47 0 (backup only) Backup fuel for Flare Ignition Systems Roclean L211 (Avista product) 1 To be determined UF Membrane cleaning chemical Roclean L811 (Avista product) 1 To be determined UF Membrane cleaning chemical Roclean L403 (Avista Product) 1 To be determined UF Membrane cleaning chemical Carbon Dioxide 1 0 (emergency use Fire fighting only) NIAGARA 3-3 fire fighting 16 0 (emergency use Fire fighting foam concentrate only) Mobil Aero HFA 1 To be determined Lubricant for corrosion inhibitor package Sintofluid 1 To be determined Lubricant for Corrosion Inhibitor Package and Methanol Still Scale Inhibitor Package Ingersoll Rand Ultra Coolant 0.31 To be determined Lubricant for air compressors Rocol Food Lube Grease 1 To be determined General Lubricant grease (Highly refined technical white oil) Castrol Transaqua HT2 For2 inspection purposes only.1.4 Hydraulic oil in umbilical (Ethylene GlycolConsent of copyright owner required for any other use. cable for offshore subsea Triethanolamine) facilities Biocide DBNPA (antimicrobial 2 <1 Biocide for produced water 7287) discharge. Oxygen Scavenger (DEHA) 2 12 Oxygen scavenger Oxygen Scavenger (Sodium 2 4 Oxygen scavenger bisulphate) Diesel Biocide 0.05 0.025 Fuel additive Sodium sulphate 0.5 8 Produced water treatment Sodium metabisulphite 2 To be determined Suspension/preservation fluid Roclean L403 (Avista product) 3 To be determined NF Membrane cleaning chemical Urea 10 56 Exhaust gas treatment Lube Oil Shell Turbo GT 32 9.19 0.1 Lubricant: compressor turbines Shell Rimula RT4 15w/40 1.02 0.6 Lubricant: for pumps and generators Nynas Nytro 10gbxt 4 0.005 Lubricant: transformers Shell Corena P100 0.09 0.08 Lubricant: (LP Compressors) Shell TurboT46 0.06 0.05 Lubricant: (Flowserve Pumps) Shell Tellus 68 1.85 0.05 Lubricant: (Flowserve Pumps)

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Material/ Substance Maximum Estimated Maximum Nature of Use Amount Annual Usage stored (tonnes) (tonnes) CLP 220 – Shell Omala 100 0.09 0.1 Lubricant: Progressive cavity pumps Shell Omala Oil 220 0.09 0.1 Lubricant: Odourisation Metering Pump MEG 0 To be determined Suspension preservation fluid Nitric acid 0.050 To be determined Online analyser reagent Carbonate scale dissolver 0 To be determined Remediation of scale (product to be selected) deposits Sulphate scale dissolver 0 To be determined Remediation of scale (product to be selected) deposits Antifoam (Product to be 0.01 To be determined Produced fluid treatment selected) Granulated activated carbon 4.0 To be determined Produced water treatment Demulsifier (product to be 0.050 To be determined Produced water treatment selected) Proppant 1 To be determined To assist with extraction of fluids from wells Catalysys 92-1 A-H/J 1 To be determined Used in SCR systems Puraspec 5158 15 To be determined Used for mercury removal from hydrocarbon streams Puraspec 1156 8 To be determined Used for mercury removal from hydrocarbon streams Acetylene 0.39 To be determined Welding/Cutting Gas Aeroshell Fluid 1,41 0.03 0.006 Hydraulic oil Argon 0.1 To be determined Welding Gas Hydrogen 0.72 To be determined Test Gas Shell Morlina 10 0.001 To be determined Lubrication Oil Shell Morlina 220 0.02 To be determined Lubrication Oil Shell Mysella 1.14 To be determined Lubrication Oil Tectyl 502C 0.02 To be determined Preservation Fluid

16.4.4 Potential Impact of the Proposed Development

The potential impact of chemical use remains as stated in the 2003 Terminal EIS. For inspection purposes only. Consent of copyright owner required for any other use. 16.4.5 Mitigation Measures

Mitigation measures remain as stated in the 2003 Terminal EIS.

16.4.6 Predicted Impact of the Proposed Development

Predicted impacts remain as stated in the 2003 Terminal EIS.

16.5 Consumption of Rock Fill

16.5.1 Introduction

No further import of rock fill is predicted.

16.5.2 Characteristics of the Proposed Development

There are currently no requirements for any remaining imported rock fill to complete the landscaping works at the Terminal. Disposal of soils as necessary to complete the final landscaping works are as proposed in 2003 Terminal EIS.

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16.5.3 Potential Impact of the Proposed Development

The potential impact of the use of crushed rock fill remains as stated in the 2003 Terminal EIS.

16.5.4 Mitigation Measures

Mitigation measures remain as stated in the 2003 Terminal EIS.

16.5.5 Predicted Impact of the Proposed Development

Predicted impacts remain as stated in the 2003 Terminal EIS.

16.5.6 Monitoring

Monitoring requirements remain as stated in the 2003 Terminal EIS.

16.5.7 Reinstatement and Residual Impacts

Reinstatement and residual impacts remain as stated in the 2003 Terminal EIS.

For inspection purposes only. Consent of copyright owner required for any other use.

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17 MITIGATION AND IMPACT SUMMARY AND IMPACT INTERACTION

17.1 Introduction

Section 17 of the 2003 Terminal EIS summarised the potential environmental effects, proposed control and mitigation measures and residual impacts (impacts remaining after mitigation) associated with the (then) proposed Bellanaboy Bridge Gas Terminal. A reassessment of the potential impacts associated with the remaining construction and pre-commissioning activities at the Terminal site has been completed as part of this Supplementary Update Report. These remaining activities include: • process improvements; • maintenance and/or substitution of items of plant and equipment; • pre-commissioning of plant and equipment; • hydrocarbon commissioning of the plant and process; • removal of temporary construction facilities (portacabins, car parks, hard standing etc.); • reinstatement and landscaping of the site, including tree planting and habitat creation; and • environmental protection of the surrounding areas. The reassessment has focussed on proposed changes to the Terminal design as described in Section 2 and where further environmental data has been available. It is noted that whilst the main construction of the Terminal took place during the period 2005 – 2010, and the Terminal facilities are essentially complete; the Terminal is not yet in operation due to delays in the construction of the Corrib onshore pipeline. The removal of temporary construction facilities and landscaping of the wider Terminal site will be carried out as the construction and start For upinspection activities purposes are only. completed. Consent of copyright owner required for any other use. The findings of the reassessment contained in this report has resulted in some changes to the summary presented in Section 17 of the 2003 Terminal EIS. Potential environmental effects, proposed mitigation measures and residual impacts for those activities which have yet to be completed (including removal of temporary construction facilities, remaining landscaping, commissioning and start-up), and operational activities are presented in Table 17.1. Note that for ease of reference, all Operational Phase and Decommissioning and After- Use Phase potential environmental effects, proposed mitigation measures and residual impacts are included, even if there is no change from that recorded in Table 17.2 of the 2003 Terminal EIS. The same standard criteria for assessing the significance of effects or hazards as was used in the 2003 Terminal EIS have again been utilised.

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Table 17.1: Assessment of Site Specific Potential Effects and Proposed Mitigation Measures

Source / Scale of Effect Control and Mitigation Environmental Consequence / Significance Level

CONSTRUCTION PHASE (Includes removal of temporary construction facilities and remaining Landscaping)

Generation of Wastes

Primary waste sources remaining are: • Minimise construction and domestic waste through MINOR • Construction waste. implementation of Waste Management Plan. • Re-use of construction compound material • Sewage • Sewage to be collected in portable facilities and removed and at the Terminal will minimise the • Domestic waste disposed of by licensed contractor. requirement for landfill and associated • So far as is practicable, excavated material to be re-used transport effects and use of finite landfill within landscape works at the terminal. . space.

Noise and Vibration

Principal sources of noise and vibration are: • Noise controls specified to the construction contractors. NEGLIGIBLE • Construction activities associated with. • Compliance with noise requirements specified in Condition No. • Temporarily increased noise levels to local removal of temporary facilities and 25 of the Terminal ‘parent’ planning permission residents during construction activities. landscaping. • Terminal site positioned as far as possible from local sensitive • Temporarily increased noise levels to local • Testing and commissioning receptors. residents during testing and • Noise attenuation in design including the selection of modern commissioning. low noise equipment shielded by acoustic screens where appropriate. For inspection purposes only. Consent of copyright owner required for any other use. Air Emissions

• Emissions from construction vehicles and • Vehicles and equipment will be serviced regularly to minimize NEGLIGIBLE equipment. emissions. • Very localised decrease in air quality in • Dust from traffic • Compliance with dust limits specified in Condition 26 of the vicinity of vehicle movements and • Testing and commissioning – similar, but Terminal ‘parent’ planning permission equipment but well within air quality lesser, impacts to those from operation. • Use of best available techniques (BAT) such as SCRs sand standards. waste heat recovery.

Use of Local Services

Increase in use of: BENEFICIAL • Bed and Breakfast accommodation. • Contractor to use local suppliers wherever possible. Beneficial increase in trade for local suppliers

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Source / Scale of Effect Control and Mitigation Environmental Consequence / Significance Level • Self catering accommodation. and services over the construction period, of greater duration than originally anticipated.

Flora and Fauna

• Disturbance to fauna from site reinstatement • Habitat reinstatement and creation, including created wetland NEGLIGIBLE activities habitat and associated willow shrub, species-rich grassland • Very localised in the vicinity of lit areas. • Lights at night – disturbance to wildlife (e.g. and areas of deciduous shrub woodland comprising native Nesting/roosting (migrating birds). species. • Provision of further frog mitigation (dams) in drainage channels. • Use of switchable lighting and ‘downlighter’ type light standards where appropriate.

Employment

• Employment during construction. • Contractors to employ local people wherever possible with the BENEFICIAL appropriate skills. • Positive effect on local employment, of greater number and duration that originally anticipated. Archaeology

• Site clearance • Archaeological watching brief during all construction activities. NEGLIGIBLE For inspection purposes only. Consent of copyright owner required for any other use. • Confirmed through archaeological monitoring as nothing of an archaeological significance was revealed Visual Impact

• Removal of temporary construction facilities • In accordance with landscape and ecological mitigation MINOR and site landscaping. strategy. • Visual disturbance due to construction activities, of greater duration that originally anticipated. Climate Change

• Translocation of excavated peat. • All 450,000m3 peat excavated from Terminal site used to BENEFICIAL rehabilitate former commercial peat extraction at nearby • Ecological & landscape benefits. Srahmore site.

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Source / Scale of Effect Control and Mitigation Environmental Consequence / Significance Level • Forestry planting. • Approximately 12.7 ha of forestry was cleared for BENEFICIAL development, however 17.5 ha of forestry has been replanted. • Ecological & landscape benefits.

Outfall and Discharges • During commissioning, treated surface water • The treated surface water from process area will be treated in NEGLIGIBLE runoff from process areas and tanker access the water treatment plant prior to discharge to ensure • Total Carbon/Total Organic Carbon roads will be discharged through the compliance with Industrial Emission licence conditions detection associated with the flow into the settlement ponds. • The discharge from the treated surface water treatment plant Emergency holding tank (EHT) will result in will be monitored in accordance with relevant consent rerouting of storm water to the used conditions. firewater pond and hence retention of potentially contaminated water. This significantly reduces the likelihood of damages to nearby watercourses resulting from an emergency release scenario.

OPERATIONAL PHASE

Noise and Vibration

Principal sources of noise and vibration are: • Operational noise controlled in accordance with the Industrial MODERATE • Testing and commissioning. Emissions licence conditions. • Temporarily increased noise levels to local • Plant operation. • Terminal site positioned as far as possible from local sensitive residents during testing and receptors. commissioning. • Noise attenuation in design including the selection of modern • Temporary significant noise levels during low noise equipment shielded by acoustic screens where specified operations... appropriate. For inspection purposes only. Consent of copyright owner required for any other use. • Monitoring

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Source / Scale of Effect Control and Mitigation Environmental Consequence / Significance Level Visual Impact

Principal visual features of the Terminal are: Design MODERATE/MINOR • Tall features e.g. stack for HP and LP flares, • Apparent mass minimised as a result of architectural detailing, • Minor or negligible impact from adjoining methanol still and turbine exhausts. construction materials and colour treatment. roads and housing at short distance from • Associated equipment including bulk storage • Retaining existing mature vegetation as far as possible for the site. tanks and ancillary buildings. screening. • Moderate impacts from sections of roads in • Lights at night. • Planting. middle distance. • Visible emissions. • Development of a light emissions management plan which will • Moderate impacts on one house in the keep the use of unnecessary lighting to a minimum with middle distance. override for emergency situations.

• Use of ‘downlighter’ type light standards where appropriate. • Regular post-planting monitoring, with stock replacement as necessary. Air Emissions

• Testing and commissioning – similar, but • Use of best available techniques (BAT) such as SCRs sand NEGLIGIBLE lesser, impacts to those from operation. waste heat recovery. • Modelling predicts no relevant ambient air • Releases to the atmosphere of typical • Operation in accordance with Industrial Emissions Licence quality standard or guideline will be combustion-related products; and tank vapour emission limits, including the use of low NOx burners where exceeded or approached at any location losses which may have an impact on local air possible. beyond the site boundary when all installed quality. • Internal floating roofs and nitrogen blankets on liquid storage plant is operating, in any operational state. tanks For inspection purposes only. Consent of copyright owner required for any other use.

• Releases of greenhouse gases, from • Use of best available techniques (BAT), e.g. waste heat NEGLIGIBLE combustion, flaring, venting and fugitive recovery on gas turbines • Direct annual greenhouse gas emissions emissions which may have long-term impact • Operation in accordance with Industrial Emissions Licence. less than one thousandth of Ireland’s on the global environment and climate. • The number of potential fugitive sources is minimised through national emissions design (welded joints, high integrity valves, etc). • Indirect beneficial impact of fuel substitution • Flaring, in the event of an emergency depressurisation, of gas for more carbon intensive fuels. prevents methane release into the atmosphere.

Bulk Liquids Storage

• Condensate storage tanks • Methanol and condensate tanks stored in tanks containing NEGLIGIBLE • Methanol storage tanks internal floating covers and minimum emissions fittings to • Minimises VOC emissions • Odorant storage tank. minimise VOC emissions.

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Source / Scale of Effect Control and Mitigation Environmental Consequence / Significance Level

• Stored in tanks with bunding to accommodate 110% of a NO DIRECT EFFECT single tank content or 25% of the combined total of all tanks in • Bulk liquids effectively contained, therefore a bund. No valves or pipework will penetrate the bund. effects associated with use only.

Chemicals Management

• Storage. • Chemical Selection Criteria NO DIRECT EFFECT • Transfer. • Chemicals stored in accordance with manufacturer’s • Chemicals effectively contained, therefore instructions. effects associated with chemicals use only. • Chemical containers stored in suitably bunded areas to contain spills and leaks during storage and transfer operations. Spills and leaks directed to the drain system. • Volume of stored chemicals minimised.

Employment and Use of Local Goods and Services

• 50 full time jobs • Local people and services will be employed where possible. BENEFICIAL • Provision for active community engagement through the use of a team of Community Liaison Officers (CLO’s); and • Implementation of a Community Social Investment Programme.

Outfall and Discharges NEGLIGIBLE For inspection purposes only. • Storm water run-off from non process areas. • Clean surfaceConsent water of copyrightwill pass owner through required settlement for any other use.ponds to limit in particular, the levels of suspended solids, prior to discharge • Total Carbon/Total Organic Carbon at SW2. detection associated with the flow into the • Monitoring of the discharge from the storm water settlement Emergency holding tank (EHT) will result in ponds both visually and sampled for a suite of parameters in rerouting of storm water to the used accordance with relevant consent conditions. firewater pond and hence retention of • Ambient monitoring of the local receiving surface waters will potentially contaminated water. This be carried out using the Small Stream Risk Scoring (SSRS) significantly reduces the likelihood of method. damages to nearby watercourses resulting • Temporary surface water mitigation measures will be applied from an emergency release scenario. to surface water runoff on a localised basis during the remaining landscaping works. • During commissioning, treated surface water • The treated surface water from process area will be treated in • Total Carbon/Total Organic Carbon runoff from process areas and tanker access the water treatment plant prior to discharge to ensure detection associated with the flow into the

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Source / Scale of Effect Control and Mitigation Environmental Consequence / Significance Level roads will be discharged through the compliance with Industrial Emission licence conditions Emergency holding tank (EHT) will result in settlement ponds. • The discharge from the treated surface water treatment plant rerouting of storm water to the used will be monitored in accordance with relevant consent firewater pond and hence retention of conditions. potentially contaminated water. This significantly reduces the likelihood of damages to nearby watercourses resulting from an emergency release scenario. • Produced water will be treated in a water treatment plant prior • During operation, treated produced water will to discharge, NEGLIGIBLE be transported via the umbilical from the • A biocide will be added to the produced water discharge • The discharge of produced water at the Terminal to the offshore manifold in the Corrib stream that will breakdown rapidly through hydrolysis and Corrib manifold will result in rapid dilution / Field (SW3). biodegradation. dispersal • Treated surface run-off water from process • Monitoring of the effluent concentrations prior to discharge to • The emission limit values for contaminant areas (areas with potential for hydrocarbon sea will be carried out routinely in accordance with the levels in the produced water discharge contamination) will be discharged at the emission limit values set in the Industrial Emission licence. have been set at levels such that there will permitted Erris Head outfall location (SW1). • All surface water with the potential for contamination (drainage be no damage to marine organisms., from process areas and tanker roads) will undergo separation of oils, settlement and treatment prior to discharge in accordance with the emission limit values set in the Industrial Emissions licence.

Generation of Wastes

• Generation of small quantities of waste • Waste will be stored securely, transported and ultimately NEGLIGIBLE including office waste, paper, foul and grey disposed of in strict For acco inspectionrdance purposes with only.EU Regulations. • Small quantities of waste will use finite water, canteen wastes, silty water and Consent of copyright owner required for any other use. landfill space. • A Waste Management Plan will be developed and will record NORM. waste sources, methods for recording quantities, on-site • Short term, temporary increase of • Transportation of wastes will generate storage and disposal method for all wastes. Consideration to greenhouse gas emissions from landfill. emissions comprising greenhouse gases and be given to the segregation of waste, re use and recycling. • Small quantities of exhaust gases from VOCs. Audits to be carried to ensure compliance with plan. vehicles taking waste for disposal. • Use of finite landfill space and generation of • Waste disposal contractors to be audited to ensure they have CH4 as waste breaks down in landfill. the correct licences to carry and dispose of waste. • Hazardous waste will be analysed before leaving site. • All site personnel to receive training on the waste management plan. Flora and Fauna

• Habitat replacement and creation. • Reinstated and created habitats will be monitored to ensure BENEFICIAL • Recolonisation of the deposited peat. their successful establishment and plant species composition. • Development of new plant communities and

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Source / Scale of Effect Control and Mitigation Environmental Consequence / Significance Level • Alien and ruderal species may colonise • Adjacent habitats will be monitored where deemed niche habitats leading to enhanced disturbed areas in the short term. necessary... biodiversity. • Vegetation management to control alien invasive species in • Likely slight positive impacts in the long reinstated/created habitats. term on aquatic ecology as a result of • Monitoring of faunal species will be undertaken, including to biodiversity enhancement, and in particular assess the success of biodiversity enhancement measures. the creation of wetland habitat. • Use of switchable lighting and ‘downlighter’ type light • Increase the representation of flora and standards where appropriate... fauna species as a result of the above. NEGLIABLE Very localized in the vicinity of lit areas.

DECOMMISSIONING AND AFTER-USE

Noise and Vibration MINOR Principal sources of noise will be: • Adherence to set noise limits. • Temporary elevated noise levels but for a • Decommissioning activities including the • Monitoring. shorter duration than during construction demolition and removal of all facilities to phase. grade level.

Waste NEGLIGIBLE • Waste materials from disassembly of the • Options for reuse and recycling will be considered before the • Some waste will be sent to landfill and use terminal. facility is dismantled. finite landfill space. • The site will be checked for contamination; if contamination is • Small quantities of exhaust gases from found, the foundations and other non-soil type material will be For inspection purposes only. vehicle use for waste disposal. removed to Consenta depth of ofcopyright 1 metre owner below required grade. for any other use. Land Use NEGLIGIBLE • Final land use to be determined after • EIA may be required, subject to compliance with current • Reversion of land to semi- natural habitat is cessation of operational activities. legislation at time of decommissioning and subject to approval likely unless an alternative beneficial use is of relevant authorities. identified. • Environmental Management Plan will be prepared and implemented.

Hydrology NEGLIGIBLE • Slight increase in groundwater vulnerability • Issue to be considered in decommissioning plan. due to peat removal. • Any contaminated ground to be removed.

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17.2 Assessment of Impact Interactions

The EIA Directive requires that the ‘inter-relationships’ and ‘interactions’ between specified environmental effects be considered. While almost all environmental aspects are inter-related to some degree only the significant interactions were taken into consideration. For example, noise can interact with a number of environmental aspects. Most of the standards and guidelines on noise relate exclusively to human beings. However, noise can also impact on terrestrial fauna such as birds and so it must be taken into account as part of the ecological assessment. The 2003 Terminal EIS presented flow diagrams (Figure 17.1 to 17.3 which illustrated the type of interactions presented by a project such as the Bellanaboy Bridge Gas Terminal. The figures demonstrated the consequential nature of impacts and the inherent inter-relationship between the physical, natural and human environment. The potential for interactions remains as stated in the 2003 Terminal EIS, and are addressed in Sections 5 – 16 of this Supplementary Update Report where applicable.

17.3 Non -routine Events

Section 17.2 of the 2003 Terminal EIS summarised the findings of a risk assessment for non-routine events including those associated with upset conditions and emergency/accidental events. A review of the information provided has been undertaken as part of this report and indicates that there is no change to the information presented in the 2003 Terminal EIS for non-routine events.

For inspection purposes only. Consent of copyright owner required for any other use.

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18 CUMULATIVE IMPACTS

18.1 Introduction

The 2003 Terminal EIS considered the cumulative impacts that the proposed Terminal development could cause through interaction with the other elements of the Corrib Natural Gas Field Development and with other developments in the area. The offshore elements of the Corrib development are essentially completed. These elements will require future maintenance work involving seasonal inspection from marine vessels.

18.2 Identification of Other Developments in the Vicinity

18.2.1 Corrib Project

The cumulative impacts of the following elements of the Corrib project were considered in the 2003 Terminal EIS: • The seabed installations, offshore pipeline and pipeline from the landfall to the Terminal site; • The Terminal development including the deposition of peat at Srahmore; and • The Mayo to Galway Pipeline that will export gas from the Terminal to the national gas grid. This consideration and assessment of cumulative impacts include those that could arise during the construction and operation of the Project. Since the 2003 Terminal EIS the construction of all aspects of the Corrib development have been completed with the exception of: • The Corrib pipeline from the landfall to the Terminal site,(at an advanced stage of construction); • Pre-commissioning and commissioning of the Terminal plant and equipment; Removal of all temporary For inspection construction purposes only. facilities (portacabins, car parks, hard • Consent of copyright owner required for any other use. standing etc); and • Final landscaping of the Terminal site and surrounding areas.

18.2.2 Other Developments

In addition the 2003 Terminal EIS identified the following proposed/permitted developments in the vicinity that may interact with the Terminal: • The construction of a small (approximately 68 MW) gas-fired at Bellacorick. The power plant would burn natural gas from the Mayo to Galway pipeline. The construction schedule was therefore tied to the availability of this pipeline, which links to the Corrib development; • The demolition of the ESB peat-fired power station at Bellacorick; and • The development of Oweninny wind farm at Bellacorick. Bellacorick Gas Fired Power Station The planning permission granted for the Bellacorick gas fired power station has expired. No further application has been granted for the gas fired power station. Therefore, this development is no longer considered as a cumulative project.

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Bellacorick Peat Fired Power Station The ESB peat-fired power station at Bellacorick has been decommissioned and demolished. Therefore, this proposal is no longer considered as a cumulative project. Oweninny Wind Farm Planning permission has been sought (June 2013) by Bord na Móna and ESB for a new wind farm, to be known as Oweninny Wind Farm, at Bellacorick County Mayo through a joint venture company, The country’s first commercial wind farm was established at this site at Bellacorick in Co. Mayo in 1992 and in 2003 planning permission was granted for 180 wind turbines on the site. However, the construction of this 180 turbine wind farm was evidently not progressed due primarily to grid connection issues. There have been significant advances in wind energy technology design and efficiency since the grant of the permission for 180 turbines. A new design with a new layout configuration has now been developed reflecting latest wind turbine technology. This new proposed development is equivalent in terms of installed capacity of the development granted permission by An Bord Pleanála in 2003 and differs primarily only in terms of the number of turbines (decreased from 180 to 112) and turbine size (overall dimension from foundation to blade tip increased from 100 metres (m) to 176 m). This optimised layout will have a total installed capacity of approximately 370 Megawatts (MW). If planning permission is granted, the wind farm will be developed in 3 phases, beginning in 2015, with completion of Phase 1 expected by 2016, Phase 2 expected by 2018 and Phase 3 expected around 2022. The development would include 112 no. wind turbines, 8 no. meteorological masts, 4 no. substations, overground and underground cables, visitor centre and associated works including 85km of access tracks etc. A review of the Environmental Impact Statement (2012) for the proposed windfarm has formed the basis for the cumulative impact assessment discussed below.

18.2.3 Other New Developments

For inspection purposes only. Since 2003 the followingConsent new of devecopyrightlopments owner required have for any been other use. identified:

Bellmullet Wave Energy Test Site The Sustainable Energy Authority of Ireland plans to develop a National Wave Energy Test Site, which is proposed to be located off Annagh Head, on the western shore of the in County Mayo. The purpose of the wave energy test site off Annagh Head is to provide a location for the temporary mooring and deployment of wave energy machines so that their performance in generating electricity and their survivability can be tested and demonstrated in open ocean conditions. The project will comprise 5 offshore test sites located between 1km and 12km southwest to west of Annagh Head, in varying water depths, and four submarine cables from the test sites to shore at Belderra Beach. There will be a substation to which the cables will be connected and onshore power lines from the substation to the power grid. It is proposed that the site will operate for up to 20 years with devices on site intermittently throughout the year. The wave energy devices will float at the surface of the ocean and will be moored to the seabed. The cables to shore will be installed 1m below the ocean floor and the onshore cables will be underground. An application has been submitted for the foreshore elements of the Bellmullet Wave Energy Test Site on the 23rd December 2011 and is currently going through the consultation process. As yet, no planning application has been submitted for the land based substation. Therefore, as the offshore elements are too far from the proposed

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Terminal development and no onshore details are known at this time, this project is not considered further. The Grid West Project – Stage 1 and Stage 2 (out for consultation) EIRGrid are developing a new high capacity power line, known as the Grid West project, which will link the North Mayo area to the existing Flagford substation near Carrick-on- Shannon. The preferred route corridor starts north west of , runs west of Ballina, east of and , south of Charlestown and Ballaghaderreen before linking into the existing Flagford substation, near Carrick-on-Shannon. The preferred route corridor is over 25km away from the proposed Terminal development and therefore no cumulative impacts between the two projects are anticipated and this project is not considered further. Coillte Wind Farm - Cluddaun Coillte Enterprise are proposing to build a 48 turbine wind farm in Cluddaun, North Western County Mayo with a capacity to generate up to 150 MW. The site comprises 2,434 ha and is located north of the proposed Oweninny Wind Farm. The proposed wind farm is not intended to be developed in phases and while construction activity may be sequenced it is envisaged that the windfarm will be constructed in one phase. The development is currently undergoing pre-application consultation and given that no planning application has been lodged on this site yet and the uncertainties surrounding it, this project is not considered further. MAREX Initiative Organic Power Ltd are seeking planning permission for a proposed 2000MW windfarm (450 wind turbines) across north Mayo which would be connected to a water storage energy hub at Glinsk, which will then transfer the energy back to Bellacorick before being cabled across the country and to the UK where it could provide more than 1% of the UKs total energy demand per pear. Known as the MAREX initiative (Method for Atlantic Renewable Energy Export), the

project is at Pre-Applicati on Consultation For inspection purposes with only. An Bord Pleanála. Given that no planning application has been lodgedConsent of copyrightand theowner uncertaintirequired for any otheres use.surrounding it, this project is not

considered further

18.3 Study Methodology

This Section includes a review and updated assessment of the cumulative impacts and impact interactions that may arise during the remaining construction activities and future operation of the Terminal. The methodology remains as stated in the 2003 Terminal EIS.

18.4 Potential for Interactions of the Proposed Developments

Table 18.1 provides an indicative programme of all of the identified cumulative developments. Whilst most of the elements of the Corrib Project have been constructed, including the Terminal, the focus of this section is to consider cumulative impacts associated with the operation of the Terminal.

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Table 18.1: Summary of Cumulative Developments 2014 2015 2016 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Corrib Pipeline Terminal Mayo to Galway Completed Pipeline Peat Removal Completed and Deposition Site Gas Fired Power Planning Permission Expired Station at Bellacorick Demolition of Demolition Completed Peat Fired Power Station at Bellacorick Oweninny Wind Farm (Phase 1) Oweninny Wind Farm (Phase 2) Oweninny Wind Farm (Phase 3) Bellmullet Wave ? Energy Test Site The Grid West project – stage 1 ? and stage 2 Coillte Wind Farm ? - Cluddaun MAREX Initiative ?

Key to Table 18.1 For inspection purposes only. Consent of copyright owner required for any other use.

Construction Commissioning Operation ? Timing Uncertain

18.5 Predicted Cumulative Impacts and Interactions

The 2003 Terminal EIS assumed that once the Terminal is operational, the only impacts from the proposed gas-fired power station and the Oweninny Wind Farm would be likely to have the potential to interact with impacts from the Terminal. Given that the proposed Bellacorick Gas Fired Power Station planning permission has expired, only the cumulative impacts arising from the Oweninny Wind Farm are considered below.

18.5.1 Human Beings

Oweninny Wind Farm The benefits to the local community in the area of Oweninny Wind Farm during the construction of the wind farm will be positive. This will occur through increasing economic activity, with capital investment of approximately €600M and providing an estimated 100 people employed directly on the wind farm site during the peak

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construction periods, with additional external employment arising from materials production and transport to the site. In the longer term there will an ongoing requirement for maintenance support, services and equipment. The proposed Visitor Centre will also give rise to local employment opportunities Corrib Project It is predicted that there will be a slight and temporary adverse impact on the residential communities in the local area, primarily arising from traffic impacts on the haulage routes during the remaining construction works associated with the onshore pipeline construction and the ongoing Terminal landscaping works which will continue beyond commencement of production from Corrib field. However, the implementation of appropriate mitigation measures and adherence to the Traffic Management Plan (including the provision of adequate public information, and ongoing community liaison, will ensure that this inconvenience is minimised. The Community Social Investment Programme will provide planned and targeted community gain, directed specifically at the needs of the local and wider residential community within the Erris region. Once the Terminal is operational, there will be a small, but sustained demand for local employees and will continue to contribute to the local economy. Cumulative The promoters of the Corrib project and the Oweninny wind farm have all made commitments to support the local community. Taken collectively, this support is likely to have substantially more impact than the sum of the individual contributions.

8.5.2 Flora and Fauna

Oweninny Wind Farm The Oweninny site supports an important diversity of bird species that is characteristic of western blanket bog, wetland habitats and forest/scrub habitats. The development of the wind farm will result in some changes to the habitats within the site but these changes can be considered as being consistent with the rehabilitation of the site since commercial peat extraction ceased in the early 2000s. Therefore, no significant impacts will occur on the Bellacorick Iron Flush cSAC or Lough Dahybaun cSAC or any other protected areas such as the Bellacorick Bog complex, around the site. For inspection purposes only. Most bird species, includingConsent of copyrightthe wintering owner required Hen for any otherHarriers, use. will not be affected by the project. Some bird collisions may occur but species particularly prone to collision, especially swans and geese, occur within the site area only on an occasional basis and even then only in small numbers. Other important fauna species, such as otters, bats and the common frog, are unlikely to be affected by the project. In terms of potential impact on the aquatic environment the proposed wind farm development has the potential to cause sediment material loss from construction areas and pollution due to oil spills and waste material management which could reduce water quality. Corrib Project The remaining construction activities and operational activities are described in Section 3 of this Supplementary Update Report. The remaining impacts on Flora and Fauna are described in Section 6 and are deemed to be negligible or minor in terms of effects on fauna and habitats, with likely slight positive impacts in the long term as a result of biodiversity enhancement. Cumulative The cumulative impacts on flora and fauna will be negligible. There will be a small additive impact in terms of temporary loss of natural habitat, associated with the

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development of the Oweninny Wind Farm, but this will be offset by the extensive peat restoration plans associated with the wind farm development and the habitat creation plans associated with the Terminal. Cumulative impact on European and other designated sites in the wider locality. The nature of the predicted impacts, together with the spatial and temporal separation of the projects discussed above, and the operation of the Bellanaboy Bridge Gas Terminal are such that there is no potential for a cumulative impact from all of the projects on the European sites under consideration, or indeed on any other sites.

8.5.3 Hydrology

Oweninny Wind Farm Hydrology was not assessed as part of the Oweninny Wind Farm. The proposed wind farm development has the potential to cause sediment material loss from construction areas and pollution due to oil spills and waste material management which could reduce water quality. Corrib Project There have not been any changes to the predicted impacts during construction.. There are no changes to the predicted impact on the hydrology and drainage of the development from those presented in the 2003 Terminal EIS. Cumulative No cumulative impacts are anticipated during operation, as the Terminal site is sufficiently remote from the wind farm and lie in a different river catchment.

18.5.4 Archaeology and Cultural Heritage

Oweninny Wind Farm It is not envisaged that any impacts will occur with respect to Archaeology and Cultural Heritage as a result of the wind farm project proceeding, Corrib Project For inspection purposes only. The predicted impact ofConsent the of proposed copyright owner development required for any other was use. described as negligible in the 2003 Terminal EIS and this has been confirmed through archaeological monitoring as nothing of an archaeological significance was revealed There are no operational effects anticipated in relation to cultural heritage. Cumulative The pooled knowledge gained from investigation of each of the development sites will enhance the understanding of the local area.

18.5.5 Air

Oweninny Wind Farm The wind farm development overall will have a significant positive impact on air quality and will help meet the Irish Government’s international obligations regarding reduction of carbon dioxide (CO2) emissions. Corrib Project During construction, all the projects have the potential to generate dust during dry conditions and all will create vehicle emissions. This impact will be temporary, mainly local and relatively short term, it is considered unlikely to be significant.

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The basic characteristics of the Terminal and its emissions to air are largely unchanged since the 2003 Terminal EIS and its 2006 addendum. The most significant change is the addition of selective catalytic reduction as oxides of nitrogen abatement on the power generation engines. This has significantly reduced the engines’ NOx discharge concentrations. Operation of the Terminal will be subject to monitoring programmes, which will provide the basis for ensuring that emissions are within approved limits Cumulative Once operational the Terminal is sufficiently remote from the wind farm to preclude cumulative impacts on air quality.

18.5.6 Climate

Oweninny Wind Farm The wind farm development overall will contribute to reducing green house gas emissions. It is estimated that Oweninny Wind Farm will produce enough electricity per annum to displace about 558,000 tons of carbon dioxide and without leading to additional emissions of sulphur dioxide (SO2) or nitrogen oxides (NOx). It is also acknowledged that wind power, along with energy efficiency and fuel switching will play the major role in reducing emissions in the power sector in the next 10- 20 years, Corrib Project The conservatively predicted total greenhouse gas emission from the Terminal’s operation in 2016 (the year of maximum predicted emissions) is approximately 0.05 million tCO2e. Cumulative

Whilst the emissions of CO2 and CH4 from the Terminal will contribute to global warming, it is not possible to quantify the actual impact of specific greenhouse gas sources or sinks on the climate or environment as a whole.

18.5.7 Noise

Oweninny Wind Farm For inspection purposes only. Consent of copyright owner required for any other use. Construction noise is unlikely to give rise to significant impact. Distances from the turbines to the nearest dwellings outside the site ensure that noise impacts of significance will not arise from the construction or operation of the wind farm. Corrib Project Construction of the Terminal facilities is almost complete, with ongoing minor revisions and amendments prior to commissioning. All current activity which could be described as part of the Terminal construction process is very modest in scale, and will continue to be carried out in compliance with the noise limits set. As stated in the 2003 Terminal EIS, the predicted operational noise impacts are moderate at noise sensitive receptors (NSR) dwellings less than 1km from the Terminal and negligible further afield. Cumulative The Terminal activities, including the remaining construction activities and the operation, is sufficiently remote from the wind farm to preclude cumulative noise impacts.

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18.5.8 Landscape and Visual

Oweninny Wind Farm The presence of Oweninny Wind Farm will have an impact on the overall landscape and visual character within the landscape basin due to its extent and height. However, considering the large scale of the surrounding generally homogeneous landscape, and the presence of the existing wind farm, the introduction of the new wind farm will not be perceived as being out of context with the overall underlying landscape character. Corrib Project There is no change to the level of overall predicted landscape and visual impact associated with the Terminal. The site of the proposed Terminal was chosen to take maximum advantage of extensive coniferous plantations, which have provided immediate, significant and effective screening. The inherent screening provided, combined with careful attention to the design, layout and colour treatments applied to component parts of the facility, have ensured that the vast majority of the development is not discernible in the landscape. It is acknowledged that there will be some overlap in the next two years between the onshore pipeline construction and pipeline compounds reinstatement with ongoing Terminal landscaping works which will continue beyond commencement of production from Corrib field Cumulative Once operational, the Terminal, and wind farm will remain visible but cannot be seen together from any viewpoint.

18.5.9 Material Assets

Oweninny Wind Farm The construction of the wind farm at Oweninny will generate construction traffic with heavy goods vehicles transporting stone fill material from quarries, reinforcing iron bar and concrete for foundations. Normal building construction materials, such as blocks, bricks, timber steel and glass will also be delivered to site during construction. There will also be a number of abnormal For inspectionloads purposesof traffic only. for wind turbine component delivery and Consent of copyright owner required for any other use. transformer deliveries for the substation Corrib Project The potential traffic impact associated with the remaining construction activities remain well within the maximum impacts predicted in the 2003 Terminal EIS In terms of future operational traffic movements some additional traffic movements (compared to those anticipated in 2003) are expected (maximum 4 additional HGV movements per day (one way)). It is acknowledged that there will be some overlap in the next two years between traffic associated with the onshore pipeline construction and the ongoing Terminal landscaping works which will continue beyond commencement of production from Corrib field. Cumulative Construction and operational traffic associated with more than one development has the potential to increase traffic volumes on local roads. This may cause delays to other road users as well as localised increased noise and vibration. However given the moderate amount of traffic associated with the remaining landscaping and operation of the Terminal and as the Terminal is sufficiently remote from the wind farm, cumulative traffic impacts are unlikely.

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18.6 Consequential Development

The potential for consequential development remains the same as stated in the 2003 Terminal EIS.

18.7 Do Nothing Scenario

The do nothing scenario is no longer relevant as the Terminal has been constructed.

18.8 Mitigation Measures

All mitigation measures remain as described in the 2003 Terminal EIS.

18.9 Monitoring

There is no requirement for monitoring specifically for cumulative impacts.

18.10 Reinstatement and Residual Impacts

There will be no reinstatement specifically for cumulative impacts.

For inspection purposes only. Consent of copyright owner required for any other use.

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19 Sustainable Development

19.1 Introduction

The 2003 Terminal EIS considered sustainable development, and provided a high level appraisal of the proposed Terminal development against SEPIL’s sustainable development principles. The purpose of this section is to provide an updated appraisal of the project against Shell’s current sustainable development principles. This section does not seek to repeat text that has not changed since the 2003 Terminal EIS. This section has been prepared by RSK Environment Ltd in association Shell E & P Ireland Ltd (SEPIL).

19.2 Shell Sustainable Development Policy

As well as complying with national goals through the planning process, Shell aims to contribute to sustainable development in their activities in Ireland in full compliance with Shell’s Business Strategy, which incorporates sustainable development as a core component. Sustainable development at Shell is defined as helping to meet the world’s growing energy needs in economically, environmentally and socially responsible ways. This includes the choices Shell makes about its portfolio and products, and the way Shell runs its operations. Shell contributes to sustainable development by helping to secure a responsible energy future. For Shell, contributing to sustainable development is: • About meeting future energy needs in economically, environmentally and socially responsible ways; • A mindset everyone at Shell needs to have when doing their day-to-day business; • About designing projects and products responsibly from the start; For inspection purposes only. Consent of copyright owner required for any other use. • Critical to delivering Shell’s business strategy; • About people, planet and profits; and • Embedded in Shell’s General Business Principles.

19.3 Contribution to National Sustainable Development Priorities

The general philosophy of Ireland’s National Sustainable Development Objectives and the project’s contribution to those objectives remains as reported in the 2003 Terminal EIS.

19.4 Appraisal

The high level appraisal presented in Table 19.1 below provides an overview of how the project impacts on sustainable development. Table 19.1 shows that the project complies favourably with Shell’s current sustainable development principles.

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Table 19.1: Comparison of the Project against Shell’s Current Sustainable Development (SD) Principles SD priorities Project - Gas produced locally; local Terminal.

Shell SD Principles Environment Energy from gas conforms with Ireland’s long-term energy switch from solid fuel to gas to renewables. The provision of • Water resources gas infrastructure will discourage future investment in • Pollution control alternative coal or oil infrastructure. • Resource use • Conserve biodiversity Overall, the local production of gas has a lower • Collaborating with others environmental impact compared to importation, due to lower transmission energy losses. Climate Change If Bord Gas decides to supply local towns with gas, this could result in a shift from peat/coal/oil/LPG to natural gas in • Reducing CO2 emissions • Energy efficiency order to meet energy needs in NW Ireland. Since gas is a cleaner fuel, this will result in lower environmental impacts.

Although the project involves the exploitation of local finite gas resource, it will discourage the use of more carbon intensive fuels and is in line with the National energy switch from solid fuel to gas to renewables.

Use of gas close to its source rather than gas transported thousands of km will be more energy-efficient.

In terms of greenhouse gas emissions, the Terminal’s direct emissions would contribute a small fraction of Ireland’s total yearly national greenhouse gas emissions. The Terminal’s emissions would, all other things being equal, be outweighed many times by emissions avoided through the substitution of natural gas in place of more carbon intensive fuels (see Section 14 Climate).

Mitigation measures including habitat reinstatement and creation; planting of deciduous scrub using native For inspectionspecies; purposes only. along with biodiversity enhancement measures Consent of copyright owner required for any other use. will lead to an increase in local biodiversity in the future (see Section 6 Terrestrial Ecology).

Air emissions arising from the operation of the Terminal are within air quality standards for the protection of health and ecosystems (see Section 11 Air Emissions).

Safety A risk-based approach will be applied to Health & Safety. In order to manage safety risks, a Major Accident Prevention • Preventing incidents and managing risks Policy (MAPP) will be prepared for operation of the Terminal (See Section 5 Human Beings).

A Safety Report will be submitted to and assessed by the Health & Safety Authority (HSA) in advance of the introduction of gas to the Terminal, and the local competent authority will prepare an external emergency response plan for the site (See Section 5 Human Beings). A Safety Case will be submitted to the Commission for Energy Regulation (CER), and the site can only operate subject to a Safety Permit issued by the CER on approval of the Safety Case.

A training strategy document will be prepared to train employees in the safe and efficient operation of the plant

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SD priorities Project - Gas produced locally; local Terminal.

Shell SD Principles (see Section 5 Human Beings).

HSE in the supply chain - purchasing policy addresses HSE issues by issuing HSE questionnaires to potential contractors.

Economic The project will help ensure security of gas supply for Ireland throughout the life of the field, as the project will • Deliver value to customers provide an independent supply of gas that will not be affected if the interconnector supply from the UK is interrupted.

The project will also increase competitiveness in the domestic energy market which may keep costs lower than they would be in the absence of such competition.

Economic The project must be economically viable in order to go ahead. Costs and scheduling are therefore tightly managed. • Maximise profitability • Profitability (supply chain)

Communities Direct Benefits The supply of gas from the Terminal would effectively • Maximise benefits to the community. enhance security of supply should there be any interruptions • Employment (supply chain) to Ireland’s gas supply via the interconnector from the UK. • Integration with local area • Education/training The local community will realise both temporary and • Sharing benefits sustained benefits of increased employment during its operation. The employment created during the operation of the Terminal will provide the opportunity for some local people to remain in the area rather than have to move to other parts of Ireland or overseas for employment. It is possible that local people will fill not all of the jobs created. These jobs will be filled by people who will move into the area, augmenting the local communities and increasing the For inspection purposes only. Consent of copyright ownersupport required for for local any other schools, use. shops, other local businesses, sports clubs and other community activities.

Use of local contractors - The project has availed of local goods and services, and the use of local contractors.

Indirect Benefits The gas pipeline from the Terminal has allowed Bord Gáis to build a distribution system to supply gas to towns and industries along the route of the pipeline. The availability of natural gas will serve to make these towns more attractive for inward investment and boost the economy of the region by providing a supply of clean, relatively cheap fuel.

Communities Community consultation – since the beginning of the project, the project team has carried out ongoing consultations with • Engage and work with stakeholders the local community in the form of public exhibitions, group • Consultation meetings and individual consultations where local people were invited to express their views and key concerns relating to the project.

Active community engagement continues through the use of a team of Community Liaison Officers (CLO’s) to provide dissemination of accurate and up to date information on the

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SD priorities Project - Gas produced locally; local Terminal.

Shell SD Principles project (See Section 5 Human Beings).

Implementation of a Community Social Investment Programme to provide for the provision of appropriate support to contribute to the long-term development of the Erris region (See Section 5 Human Beings).

Engaging the supply chain - the project team has made efforts to integrate Health, Safety and Environment (HSE) awareness into the supply chain by issuing HSE questionnaires as part of the supplier selection process.

For inspection purposes only. Consent of copyright owner required for any other use.

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20 ENVIRONMENTAL MANAGEMENT

20.1 Introduction

Section 20 of the 2003 Terminal EIS outlined the principles of environmental management that SEPIL would adopt during the construction and operation of the Bellanaboy Bridge Gas Terminal. The construction of the Terminal is substantially complete and during this phase an Environmental Management System (EMS) has been developed and implemented and will continue to apply in respect of the remaining construction related activities up until the time of commissioning with hydrocarbons (BFG). During the Terminal commissioning and operational phase, an EMS will continue to be implemented in accordance with the environmental aspect and impacts of the Terminal site as outlined in the 2003 Terminal EIS. The current monitoring requirements envisaged for the Terminal under licensed operations are summarised below.

20.2 Shell HSE Policy and Commitments

Shell’s environmental standards are set by the Shell Group’s Health, Safety and Environmental (HSE) Policy. The Shell E&P Ireland Managing Director has signed off against this policy and further commits each member of staff to the duty of living this policy and to halting activities believed to threaten safety, health or the environment. The Policy commits Shell to: • pursue the goal of no harm to people; • protect the environment; • use material and energy efficiently to provide our products and services; For inspection purposes only. • develop energy resources,Consent of copyright products owner required and for services any other use. consistent with these aims;

• publicly report our performance; • play a leading role in promoting best practice in our industries; • manage HSE matters as any other critical business activity; and • promote and culture in which all Shell employees share this commitment. To support these commitments, Shell will: • have a systematic approach to HSE management designed to ensure compliance with the law and to achieve continuous performance improvement; • set targets for improvement and measures, appraise and report performance; • require contractors to manage HSE in line with this policy; • require joint ventures under its operational control to apply this policy and to use its influence to promote it in other ventures; and • include HSE performance in the appraisal of all staff and reward accordingly. These environmental commitments encompass the environmental philosophy that will be applied by Shell to all aspects of the proposed Terminal development.

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20.3 Construction of Terminal

The main construction of the Terminal took place during the period 2005 – 2010, and the Terminal facilities are essentially complete. An EMS and associated monitoring plan have been in operation on the site since commencement of construction. The monitoring plan has been subject to annual updates, each of which are subject to consultation with the Project Monitoring Committee (PMC) and Mayo County Council’s approval. The key elements of the management system have been the management and monitoring of: • water quality (groundwater and surface water quality); • traffic movements; • noise and vibration; • dust; and • waste. The various mitigation measures and monitoring requirements detailed in the 2003 Terminal EIS will continue to apply where relevant in respect of the remaining construction phase activities.

20.4 Terminal Operation

Environmental monitoring requirements for the operational phase of the Terminal have been further developed and refined since the 2003 Terminal EIS. Table 20.1 below outlines the current monitoring requirements envisaged for the Terminal under licensed operations. The monitoring and sampling details set out in Table 20.1 will ensure that the plant will function as intended and operate in compliance with licensed activities. The environmental monitoring will be implemented on a gradual basis from the start of hydrocarbon commissioning, when the plant starts to operate within the terms of the site’s For inspection purposes only. Industrial Emissions licence.Consent of copyrightDuring owner BFG required commissioning for any other use. there will be no produced water stream at the plant and hence, monitoring of treated produced water will not be required during this period.

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Table 20.1 Environmental Monitoring Requirements for Operational Phase Issue Emission/Ambient Description Process • Monitoring of the use of biocide. Control / • Monitoring of exhaust volumes and flow rate from gas Health & turbines and power generators. Safety • Monitoring of discharge volumes and flow rate for treated produced water and oily water. • Monitoring of the urea dosing system for the power generators. • Monitoring of certain parameters such as pressure differential and flow within the water treatment package (ESMIL) to confirm functionality of key equipment. • Periodic testing of the integrity and water tightness of underground pipework, tanks and bunds and resistance to penetration by water or other materials stored within the structure. • Monitoring of water tightness of the umbilical by continuously monitoring the treated produced water discharge pressure and flowrate against a flow resistance curve • Energy usage (including electricity, fuels and water) Aquatic Ambient • Regular monitoring of quality of treated produced water prior Ecology to the discharge. Additional detailed analysis of the treated produced water in accordance with OSPAR – risk based approach. • Baseline verification survey including sediment chemistry and benthic community biodiversity assessment of the seabed areas of the emission discharge locations at sea. • Small Stream Risk Scoring at a number of proposed locations in the vicinity of the plant. Water Emission • Sampling of produced water (untreated) during the initial period after plant start up to determine presence of MEG. MEG concentration will be based on COD levels. • Continuous monitoring of treated produced water and oily water streams for; For inspection purposes only. Consent of copyright owner required• for anyFlow other use. • pH • Conductivity • Flow proportional sampling of treated produced water and oily water streams for parameters including; • COD • Suspended Solids • Hydrocarbons • Continuous monitoring of surface water for TOC/TC. • Flow proportional sampling of surface water for parameters including; • COD • Suspended Solids • Conductivity • Visual inspection of the surface water system will be conducted regularly. • Groundwater sampling for parameters including; • pH • Conductivity • COD

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Issue Emission/Ambient Description • Hydrocarbons • Heavy Metals Air Emission • Continuous monitoring of exhaust emissions from Gas Turbines. • Stack testing of power generators on a quarterly basis.

• CO2 monitoring from activities relating to; • Gas Turbines • Gas Engines (Power Generation) • Diesel Engines (Firewater pumps and emergency generator) • Flaring Ambient • Ambient air monitoring at a number of locations in the vicinity of the plant for; • NO2 • CO • Particulate • VOC • A weather station will operate on-site. Noise Ambient • Ambient noise monitoring at a number of locations in the vicinity of the plant. • Continuous noise monitoring at two locations on site. Waste Emission • Waste quantities of hazardous, non-hazardous and recyclable materials will be monitored. • Sampling of specific waste streams for certain parameters (to be agreed with the EPA). These waste streams include; • Sludge filter cake • Mercury absorption bed • Sampling of the sanitary waste system (puraflo unit) for parameters including; • pH • BOD • Suspended solids • Total coliforms For inspection purposes only. Consent of copyright owner required• for anyFaecal other use. coliforms

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