ENVIRONMENTAL PERMIT APPLICATION
NTT Global Data Centers UK EMEA Limited Datacentre
Environmental Risk Assessment
Prepared for: NTT Global Data Centers EMEA Limited Client Ref:410.10114.00001
SLR Ref: 410.10114.00001 Version No: Final December 2020
NTT Global Data Centers EMEA Limited NTT Global Data Centers UK EMEA Limited Datacentre SLR Ref No: 410.10114.00001 Filename: 410.10114.00001 ERA December 2020
BASIS OF REPORT
This document has been prepared by SLR with reasonable skill, care and diligence, and taking account of the manpower, timescales and resources devoted to it by agreement with NTT Global Data Centers EMEA Limited (the Client) as part or all of the services it has been appointed by the Client to carry out. It is subject to the terms and conditions of that appointment.
SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any purpose by any person other than the Client. Reliance may be granted to a third party only in the event that SLR and the third party have executed a reliance agreement or collateral warranty.
Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied by the Client and/or its other advisors and associates. These data have been accepted in good faith as being accurate and valid.
The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other information set out in this report remain vested in SLR unless the terms of appointment state otherwise.
This document may contain information of a specialised and/or highly technical nature and the Client is advised to seek clarification on any elements which may be unclear to it.
Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole document and any documents referenced explicitly herein and should then only be used within the context of the appointment.
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CONTENTS
INTRODUCTION ...... 1
ENVIRONMENTAL RISK ASSESSMENT ...... 1 2.1 Climate Change Risk Assessment ...... 2
IDENTIFYING THE RISKS ...... 2
THE SITE ...... 3 4.1.1 Industrial and Commercial ...... 3 4.1.2 Local Transport Network ...... 3 4.1.3 Woodland and Open Land ...... 3 4.1.4 Residential ...... 4 4.1.5 Recreational ...... 4 4.1.6 Educational ...... 4 4.2 Geology, Hydrogeology and Hydrology ...... 4 4.2.1 Geology ...... 4 4.2.2 Hydrogeology ...... 4 4.2.3 Hydrology ...... 4 4.3 Ecology and Cultural Heritage ...... 5 4.3.1 Ecology ...... 5 4.3.2 Cultural Heritage ...... 6 4.4 Receptors ...... 6 4.4.1 Wind Rose ...... 8
ENVIRONMENTAL RISK ASSESSMENT ...... 9
ADAPTATION TO CLIMATE CHANGE RISK ASSESSMENT ...... 20 6.1 Screening ...... 20 6.2 Climate Change Risk Assessment ...... 20
DOCUMENT REFERENCES
TABLES Table 4-1 Surrounding Land Uses ...... 3 Table 4-2 Identified Receptors ...... 6 Table 5-1 Air Risk Assessment and Management Plan ...... 10
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Table 5-2 Noise Risk Assessment and Management Plan ...... 11 Table 5-3 Fugitive Emissions Risk Assessment and Management Plan ...... 13 Table 5-4 Accident Risk Assessment and Management Plan ...... 15 Table 5-5 Global Warming Potential (GWP) ...... 18 Table 6-1 Climate Change Screening Assessment ...... 20
FIGURES Figure 4-1 Windrose (London City Airport 2014-2018) ...... 9
APPENDICES Appendix 01: EA Nature and Heritage Conservation Screening Report 30th January 2020 Appendix 02: Adaption to Climate Change Risk Assessment: Thames River Basin District Worksheet
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INTRODUCTION
SLR Consulting Limited (SLR) has been instructed by NTT Global Data Centers EMEA Limited to prepare an Environmental Risk Assessment (ERA) in support of an application for a new bespoke Environmental Permit (EP) for a datacentre, which will be owned by NTT Global Data Centers EMEA Limited and operated by NTT Global Data Centers UK EMEA Limited (NTT), located on Londoneast-UK Business and Technical Park, Yewtree Avenue, Dagenham, RM10 7FZ. This ERA has been undertaken in accordance with the Environment Agency (EA) guidance Risk Assessments for your Environmental Permit1 (2019). The aim of the ERA is to identify any potential significant risks and demonstrate that the risk of pollution or harm will be acceptable by taking the appropriate measures to manage these risks.
ENVIRONMENTAL RISK ASSESSMENT
This Environmental Risk Assessment (ERA) is an assessment of the risks to the environment and to human health that may be associated with the proposed operations at the datacentre. The assessment has been completed in accordance with the Environment Agency (EA) Technical Guidance ‘Risk Assessments for your Environment Permit’ dated February 2020. The aim of the assessment is to identify any significant risks and demonstrate that the risk of pollution or harm will be acceptable by taking the appropriate measures to manage these risks. This ERA uses the following approach for identifying and assessing the risks from the proposed operation: Step 1 Identify risks and sources of risk from your activity. Step 2 Where risks are identified from Step 1 then identify the receptors that could be affected. Step 3 Identify potential pathways between the sources of risk and receptors. Step 4 Assess the risks and check that they are acceptable. Justify appropriate measures to control your risks, if necessary. Step 5 Submit your assessment. Section 3.0 of this document is a screening step to identify the risks requiring consideration as part of this assessment. Section 4.0 identifies people or parts of the environment that could be harmed (at potentially significant risk) by the activity. The ERA for an EP application requires all receptors that are near a site and could reasonably be affected by the activities to be identified and considered as part of the assessment. For the purposes of this ERA the following distances have been used to identify potentially sensitive receptors for the datacentre site: • A 10km radius has been adopted in reviewing potentially sensitive receptors of international ecological importance; • A 2km radius has been adopted in reviewing potentially sensitive receptors of national cultural and ecological importance; and
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1 https://www.gov.uk/guidance/risk-assessments-for-your-environmental-permit
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• A radius of 500m has been adopted for all other potentially sensitive receptors (for example residential, commercial, industrial, agricultural and surface water receptors). Section 5.0 of this document presents the environmental risk assessment and demonstrates that any risks of pollution or harm will be mitigated to manage the risk.
2.1 Climate Change Risk Assessment An adapting to climate change risk assessment is also required for a new bespoke waste and Installation EP application if the activity is expected to operate for more than 5 years. As the datacentre is expected to operate for more than 5 years a climate change risk assessment has been completed, the results of which are presented in Section 6.0. Identifying the Risks
Step 2 of the ERA is a screening step to identify the potential risks to the environment from the Installation. The EA’s guidance requires the following to be considered as ‘Risks from your site’: • Any discharge, for example sewage or trade effluent to surface or groundwater; • Accidents; • Odour; • Noise and vibration; • Uncontrolled or unintended (‘fugitive’) emissions, including dust, litter, pests and pollutants that should not be in the discharge; • Visible emissions, for example smoke or visible plumes; • Release of bioaerosols. Further, for Installation and waste EP applications the EA guidance states that assessment of the following additional aspects is required, where applicable: • Risks from air emissions; • Risks to groundwater; • Global Warming Impact; • Risk to groundwater from landfill leachate; • Risks to surface water from hazardous pollutants; • Risks to surface water from sanitary and other pollutants; and • Installations and waste operations must also decide how to treat, recycle or dispose of waste. The Installation will not produce any process effluent or release bioaerosols, and there will be no point source emissions to groundwater, surface water or land from the application activities. There will be several point source emissions to air associated with each diesel-fired generator stack and the potential for visible emissions from these stacks. Therefore, only the following potential impacts are considered further in this risk assessment: • Point source emissions to air; • Accidents;
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• Noise & vibration; • Visible emissions, for example smoke or visible plumes; • Fugitive emissions; and • Global warming potential.
The Site
The datacentre site, centred at NGR TQ 50944 85355, is located off Yewtree Avenue, Dagenham, RM10 7FZ. The immediate surrounding area is predominantly open land to the north, east and south, and mixed industrial and commercial to the west. A summary of the immediate environmental site setting is provided in Table 1. The site location, local receptors and environmental site setting are shown on drawings 001, 002, 003A and 003B as submitted with the EP application.
Table 4-1 Surrounding Land Uses Boundary Description
North Sports fields, open land and Eastbrookend Country Park and lakes.
East A lake, The Chase Nature Reserve and Beam River.
South Land currently under redevelopment, railway line, Beam Valley Country Park, lake and residential properties.
West Mixed industrial and commercial properties and residential properties.
The immediate surrounding land use is described in further detail below.
4.1.1 Industrial and Commercial The site is located adjacent to an industrial estate, on its western edge.
4.1.2 Local Transport Network Various roads are located beyond the Site to the north, east, south and west. A railway is located circa 130m to the south of the Site.
4.1.3 Woodland and Open Land The closest area of woodland is adjacent to the north of the Site, with further areas of woodland located to the north east of the Site associated with The Chase Local Nature Reserve and to the south, beyond the railway line, associated with Beam Valley Country Park. Open areas of land are also associated with the aforementioned country parks and nature reserve.
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4.1.4 Residential Residential properties associated with Dagenham are located to the south and west of the site, and further afield to the east beyond The Chase Nature Reserve. The nearest residential properties are located approximately 400m to the south and west.
4.1.5 Recreational There are numerous recreational areas within 500m of the Site, the nearest being playing fields adjacent to the north and Eastbrookend Country Park circa 10m to the north of the Site and The Chase Nature Reserve 200m east. To the south is Beam Valley Country Park, which lies beyond the railway, approximately 200m south.
4.1.6 Educational The closest educational facilities are Arcus Academy training centre approximately 40m west and John Perry Primary School approximately 600m to the south.
4.2 Geology, Hydrogeology and Hydrology
4.2.1 Geology British Geological Survey (BGS) data indicates that the Site is underlain by a bedrock of London Clay Formation Clay, Silt and Sand, formed in the Palaeogene period approximately 48-59 million years ago in a marine environment. Underlying this is the Lambeth Group (sand, silt and clay) and then the Thanet Formation (sand). The BGS also records superficial deposits overlying the bedrock comprising Hackney Gravel Member Sand and Gravel, formed in the quaternary period up to 2 million years ago a fluvial environment.
4.2.2 Hydrogeology A search on the Multi-Agency Geographical Information for the Countryside (MAGIC) map revealed that the bedrock (London Clay) beneath the Site is classified as unproductive strata, defined as having low permeability and negligible significance for water supply or river base flow. The superficial deposits are classified as a Secondary A aquifer, which is defined as ‘permeable layers capable of supporting water supplies at a local rather than a strategic scale’2.
4.2.3 Hydrology The MAGIC map revealed that drains are adjacent to the Site’s northern border. The nearest surface water feature is a pond 15m east, Tom Thumb Lake 210m north and Beam Valley Country Park Lake 200m south. The Flood Map for Planning3 identifies the site as lying within a Flood Zone 1, defined by the website as having a less than 1 in 1,000 annual probability of river or sea flooding.
______2 http://apps.environment-agency.gov.uk/wiyby/117020.aspx. 3 https://flood-map-for-planning.service.gov.uk/
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4.3 Ecology and Cultural Heritage
4.3.1 Ecology European/International Sites A review of MAGIC map confirmed that there are none of the following within a 10km radius of the Site: • Ramsar Sites; • Special Areas of Conservation; and • Special Protection Areas. National Ecological Sites There are numerous national sites of ecological importance located within 2km of the Site’s boundary. The sites are shown on drawings 003A and 003B Environmental Site Setting and the Environment Agency Nature and Heritage Conservation Screening Report presented in Appendix 01 and include: Local Nature Reserves (LNR): • Beam Valley LNR, c. 200m south; • The Chase LNR, 200m east; • Eastbrookend Country Park LNR, 150m north; • Dagenham Village Churchyard LNR, 1,150m southwest; and • Ingrebourne Valley LNR, 2km southeast.
Local Wildlife Sites (LWS): • Mid Beam Valley in Dagenham and Dagenham East LWS, 550m south east; • The Chase and Eastbrookend Country Park LWS, 100m north; • Mid Beam in Havering LWS, 450m south east; • Wantz Lake and Crowlands Golf Course LWS, 2km north west; • Pondfield Park and adjacent railside LWS, 1km west; • Beam Valley South in Dagenham and the Wantz Stream LWS, 1,600m south west; • St Peter’s and St Paul’s Churchyard, Dagenham 1.2km south west; • Beam Valley South in Havering, 1.2km south; • District line in Havering, 800m east; • Harrow Lodge Park, 1.3km north east; and • Hornchurch Country Park, 2km south east.
Searches on the MAGIC map confirmed none of the following are present with a 2km radius of the Site: • National Nature Reserves; • Areas of Outstanding Natural Beauty;
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• Sites of Special Scientific Interest; • Biosphere Reserves; and • Ancient Woodland.
Priority Habitats (England only)
Priority habitats are ‘habitats of principle importance for the conservation of wildlife in England’ and include:
• protected or priority species; • nationally and internationally protected species; and • species of principle importance for conservation of wildlife in England. The EA Nature and Heritage Conservation Screening Report, included as Appendix 01, has not identified any priority habitats or priority/protected species on the datacentre site or within a 2km radius.
4.3.2 Cultural Heritage There are several listed buildings within a 2km radius of the Site, to the north, east, south and west, with the nearest located 230m west. These are illustrated on Drawing 003A Environmental Site Setting. Searches on the MAGIC map confirmed that none of the following are present within a 2km radius of the Site: • Registered Parks and Gardens; • Registered Battlefields; • World Heritage Sites; and • Scheduled Monuments.
4.4 Receptors Table 2 details receptors that could potentially be affected by operations at the datacentre.
Table 4-2 Identified Receptors Receptor Name Receptor Type Direction Approximate Distance at Closest Point (m)
Local Receptors within 500m, as illustrated on Drawing 003A Environmental Site Setting
Drains Surface water North Adjacent
Woodland Open Land and Woodland North Adjacent
Industrial Estate Industrial and Commercial West Adjacent
Sensor Coating Systems Industrial West Adjacent
Playing Fields Recreational North 10
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Receptor Name Receptor Type Direction Approximate Distance at Closest Point (m)
Eastbrookend Country Recreational North 10 Park
Ponds Surface Water East 15
Arcus Academy Educational West 40
Open Land Open Land and Woodland North, East 50
J. GO Consultants Limited Commercial West 80
Railway Local Transport Network South 130
The Chase Recreational East 200
Beam Valley Country Recreational and Surface South 200 Park Lake Water
Tom Thumb Lake Surface Water North 210
Bardag Lake Surface Water North West 220
Wheelers Lake Surface Water North 350
Residential Properties Residential South, West 400
Scrap Yard Commercial and Industrial South 500
Beam River Surface Water South East 500
Ecological and Cultural Heritage Receptors are shown on Drawings 003A & 003B Environmental Site Setting
The Chase and Local Wildlife Site North 100 Eastbrookend Country Park LWS
Eastbrookend Country Local Nature Reserve North 150 Park LNR
Mid Beam Valley in Local Wildlife Site South East 550 Dagenham and Dagenham East LWS
Beam Valley LNR Local Nature Reserve South 200
The Chase LNR Local Nature Reserve East 200
Listed Buildings Listed Buildings North, East, South and 230 West
Mid Beam in Havering Local Wildlife Site South East 450 LWS
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Receptor Name Receptor Type Direction Approximate Distance at Closest Point (m)
District line in Havering Local Wildlife Site East 800
Pondfield Park and Local Wildlife Site West 1,000 adjacent railside LWS
St Peter’s and St Paul’s Local Wildlife Site South West 1,200 Churchyard, Dagenham LWS
Harrow Lodge Park Local Wildlife Site North East 1,200
Beam Valley South in Local Wildlife Site South 1,200 Havering
Beam Valley South in Local Wildlife Site South West 1,600 Dagenham and the Wantz Stream LWS
Dagenham Village Local Nature Reserve South West 1,150 Churchyard LNR
Ingrebourne Valley LNR Local Nature Reserve South East 2,000
Hornchurch Country Park Local Wildlife Site South East 2,000 LWS
Wantz Lake and Local Wildlife Site North West 2,000 Crowlands Golf Course LWS
4.4.1 Wind Rose A windrose for London City Airport observing station for the 5-year period (2014 to 2018), providing the frequency of wind speed and direction, is presented in Error! Reference source not found.1. The windrose shows winds from the south-west are most frequent with winds from the north and south-east least frequent.
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Figure 4-1 Windrose (London City Airport 2014-2018)
ENVIRONMENTAL RISK ASSESSMENT
The following tables in this section assess the potential risk to receptors from the following hazards, taking into account the measures proposed to reduce those risks: • Point source emissions to air; • Accidents; • Noise & vibration; • Fugitive emissions; and • Global warming potential. The probability of exposure is the likelihood of the receptors being exposed to the hazard, and is defined as low, medium or high. These terms are qualified as follows: • Low: exposure is unlikely, barriers in place to mitigate against exposure; • Medium: exposure is fairly probable, barriers to exposure less controllable; and • High: exposure is probable, direct exposure likely with few barriers. The methodology outline in Section 1.0 of this report is the basis on which it is determined whether the proposed operations will lead to significant impacts on the surrounding environment. Where a conclusion of ‘not significant’ has been reached, it is proposed that the mitigation and management measures that will be in place at the Installation will be sufficient to ensure that there will be no impact at the surrounding environment.
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Table 5-1 Air Risk Assessment and Management Plan What do you do that can harm and what could be Managing the Risk Assessing the Risk harmed? Hazard Receptor Pathway Risk Management Probability of Consequence What is the Exposure overall risk What has the What is at risk How can What measures will you take to reduce the risk? Who is How likely is What is the What is the risk potential to cause what do I wish the responsible for what? this contact? harm that that still remains? harm? to protect? hazard can be The balance of get to the caused? probability and receptor? consequence Emissions from All receptors Air A detailed risk assessment of the impact on air quality of Low due to Pollution, Low generator stacks: identified in in emissions of combustion products from the datacentre is management Harm to drawings 003A presented in Section 6 of this EP application measures environment - planned and 003B (410.10114.00001 AQA_WD6). The findings of the and human maintenance and limited assessment for routine testing and maintenance health and testing operational operations are that for planned maintenance and testing - emergency hours significant impacts are considered unlikely. outage In the highly unlikely event of a 500 hour ‘electrical grid outage’ there is potential for impacts on human and ecological receptors. NTT will develop an Air Quality Emergency Action Plan (AQEAP) which will detail the management actions to be taken in the event of an emergency outage that could result in the prolonged usage of the generators which could potentially result in adverse impacts on local air quality. NTT will liaise with the Local Authority and the Environment Agency to agree actions to be taken in the event of a prolonged outage situation. Planned preventative maintenance (PPM) will be in place for the maintenance and testing of the generators; maintenance will be conducted in accordance with the manufacturer requirements.
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The Site Manager will be responsible for implementing risk management measures in conjunction with the operating techniques document (Ref: 410.10114.00001/BATOT). Visible emissions from All receptors Air Planned preventative maintenance (PPM) will be in place Low due to Pollution, Low the diesel fired identified in in for the maintenance and testing of the generators; maintenance Harm to generator stacks, drawings 003A maintenance will be conducted in accordance with measures environment typically on start-up of and 003B manufacturer requirements. and limited and human the generators. operational health NTT will implement visual checks for visible emissions hours from the generators during start up.
Table 5-2 Noise Risk Assessment and Management Plan What do you do that can harm and what Managing the Risk Assessing the Risk could be harmed? Hazard Receptor Pathway Risk Management Probability of Consequence What is the overall Exposure risk What has What is at How can What measures will you take to reduce the risk? Who is How likely is What is the What is the risk that the potential risk what do I the hazard responsible for what? this contact? harm that can still remains? The to cause wish to get to the be caused? balance of probability harm? protect? receptor? and consequence Noise from Industrial, Air A Noise Assessment has been undertaken for the datacentre Low Nuisance Low vehicular commercial, (propagati (410.10114.00001/Noise Assessment). The assessment movements residential on) concluded that operation of the generators is unlikely to (fuel and cause an adverse impact on the nearby noise-sensitive deliveries) ecological receptors. receptors The site will be operational on a 24 hour a day, seven days a identified in week basis. On-site vehicles will be required to adhere to a drawings considerate speed limit. 003A and 003B
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Fuel oil deliveries will only be carried out during daytime hours except in the case of emergency outage situations where more frequent deliveries may be required. Due to the distance of residential receptors, it is not expected that noise from vehicles will impact the local vicinity in a detrimental way. Any noise complaint received will be logged. An appropriately designated person will investigate the complaint and will take action to identify the source of the noise and remedial measures implemented where appropriate. Site access and operational areas will be maintained and repaired to minimise emissions of noise due to uneven and poor surfacing. The Site Manager will be responsible for implementing risk management measures in conjunction with the operating techniques document (Ref: 410.10114.00001/BATOT). Noise from Industrial, Air The generators will be housed within bespoke container Low due to Nuisance Low operation of commercial, (propagati units fitted with noise attenuation. mitigation the residential on) measures in All equipment will be maintained and operated in generators and place accordance with the manufacturer’s guidance and ecological maintained in good working order. receptors identified in The planned maintenance and testing of the generators is drawings not predicted to result in excessive levels of noise that could 003A and adversely impact identified sensitive receptors. 003B Any noise complaint received will be logged. An appropriately designated person will investigate the complaint and will take action to identify the source of the noise and remedial measures will be implemented where appropriate
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The Site Manager will be responsible for implementing risk management measures in conjunction with the operating techniques document (Ref: 410.10114.00001/BATOT).
Table 5-3 Fugitive Emissions Risk Assessment and Management Plan What do you do that can harm and what could Managing the Risk Assessing the Risk be harmed? Hazard Receptor Pathway Risk Management Probability of Consequence What is the overall Exposure risk What has the What is at risk How can the What measures will you take to reduce the risk? Who is How likely is What is the What is the risk that potential to what do I wish hazard get to responsible for what? this contact? harm that can still remains? The cause harm? to protect? the be caused? balance of receptor? probability and consequence To Air Emissions Industrial, Air Best practices will be adhered to for all fuel Low Pollution, Low during the commercial, loading/unloading activities. Such measures will not Harm to transfer of and residential remove potential for emissions but will limit the Environment substances in receptors duration of such releases. and Human and out of identified in Health Deliveries of diesel will be from operator approved storage (filling drawings 003A suppliers and will be undertaken in accordance with and and 003B delivery procedures which will be developed as part of emptying). the Environmental Management System. Emissions Spill kits will be available for use in the event of an during tank unplanned fuel release during delivery. breathing A spill procedure will be developed for the site as part of the Environmental Management System. Areas where fuel is to be stored will be subject to daily visual inspections as part of daily operational activities.
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The Site Manager will be responsible for implementing risk management measures in conjunction with the operating techniques document (Ref: 410.10114.00001 BATOT). To Water
Runoff from Land, Overland Generators and associated diesel belly tanks will be Low Pollution, Low potentially groundwater percolation housed external to the datacentre building; this area Harm to will benefit from concrete surfacing. Environment contaminated See drawings through the areas (i.e. 003A and ground The generators have the benefit of being containerised. external areas 003B where the There is no bulk storage of fuel on site, rather each generators generator will be located within a dedicated propriety and steel contained unit. Beneath the floor of the container associated units for each SBG will be a belly tank, which is integral diesel belly to the SBG container unit, which will automatically tanks are supply diesel to the SBG. The belly tanks will be located). provided with secondary containment (110% capacity). Leak/spill protection measures include fill points located in lockable cabinets provided with a drip trays, tank level gauges, level alarms, pressure delivery over- fill prevention valves and leak detection alarms connected to the building management system (BMS). The integrity of diesel tanks and secondary containment will be subject to daily visual inspection by site personnel as part of daily operations. Any defects or weaknesses spotted in a tank or containment measures will be repaired as soon as practicable. Surface water runoff from the area where the SBGs are to be located will be directed to the on-site surface water drainage system via a suitably sized oil interceptor which will ultimately discharge to the municipal combined sewer (this final point of discharge being located off site, specifically on the southern
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boundary of the adjacent site to the south of the datacentre). The interceptor will be subject to regular emptying and maintenance by an appointed specialist contractor. All interceptor oil/sludge will be removed by suitably licensed contractors. No oily water will be permitted to leave the site under normal operating conditions.
Table 5-4 Accident Risk Assessment and Management Plan What do you do that can harm and what Managing the Risk Assessing the Risk could be harmed? Hazard Receptor Pathway Risk Management Probability of Consequence What is the overall Exposure risk What has What is at How can What measures will you take to reduce the risk? Who is How likely is What is the What is the risk that the potential risk what do I the hazard responsible for what? this contact? harm that can still remains? The to cause wish to get to the be caused? balance of harm? protect? receptor? probability and consequence Leak from Land, Over land, Generators will be housed external to the datacentre Low Pollution, Low on-site fuel groundwater Water building; this area will benefit from concrete surfacing. The Harm to oil storage generators have the benefit of being containerised. Environment See and Human drawings The generator belly tanks will be located within the Health 003A and generator container units and provided with suitable 003B secondary containment. Leak/spill protection measures will include fill points located in lockable cabinets provided with a drip trays, tank level gauges, level alarms, pressure delivery over-fill prevention valves, leak detection alarms connected to the BMS.
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The integrity of diesel tanks and secondary containment will be subject to daily visual inspection by site personnel as part of standard daily operations. Any defects or weaknesses spotted in a tank or containment measures will be repaired as soon as practicable. The Site Manager will be responsible for implementing risk management measures in conjunction with the operating techniques document (Ref: 410.10114.00001 BATOT). Discharge of Industrial, Over Land, Best practices will be adhered to for fuel unloading and Low Pollution, Low fuel oil commercial, Water loading activities which will limit the duration of potential Harm to outside residential, emission releases. Environment bunded or surface and Human Deliveries of diesel will be from operator approved suppliers kerbed area water, Health and will be undertaken in accordance with delivery recreational procedures which will be developed as part of the and Environmental Management System (EMS). ecological receptors Diesel fuel suppliers will be required to adhere to the current identified in Carriage of Dangerous Goods (ADR) Regulations. drawings Storage areas will be kept sealed and secured at all times. 003A and 003B Operational areas, roads and external surfacing will benefit from impermeable surfacing to prevent percolation of any spilt/leaked fuel or potentially contaminated runoff to soil and groundwater. Any spillage that does occur will be cleaned up/contained immediately using absorbent material in the spill kits which will be provided on-site. All spills will be removed from site by a suitably licensed waste contractor. A spill procedure will be developed for the site as part of the Environmental Management System. The Site Manager will be responsible for implementing risk management measures in conjunction with the Operating Techniques (Ref: 410.10114.00001/BATOT).
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NTT Global Data Centers EMEA Limited NTT Global Data Centers UK EMEA Limited Datacentre SLR Ref No: 410.10114.00001 Filename: 410.10114.00001 ERA Dcember 2020
Fire Industrial, Air The site will benefit from a fire alarm system and associated Low Pollution, Low commercial, (smoke) fire suppression systems inside the datacentre building. The Harm to residential, generator containment units themselves will not have fire Environment surface suppression systems. and Human water, Health Emergency Procedures will be developed as part of the EMS; recreational these will detail the actions to be taken in the event of a fire. and ecological The Site Manager will be responsible for implementing risk receptors management measures in conjunction with the operating identified in techniques document (Ref: 410.10114.00001/BATOT). drawings 003A and 003B
Security and Industrial, Air/Land The following security measures will be implemented at the Low Pollution, Low Vandalism commercial, site: Harm to residential, • 24/7 security; Environment surface and Human water, • Site access control system; Health recreational • Site perimeter security fencing; and and ecological • CCTV monitored by a security firm. receptors A minimum of 12 site personnel (comprising security and identified in facilities management personnel) will be present on site drawings 24/7. 003A and 003B All visitors to the site will be required to sign in and out of the site to prevent unauthorised access. The Site Manager will be responsible for implementing risk management measures in conjunction with the Operating Techniques (Ref: 410.10114.00001/BATOT). Flooding Industrial, Land, The datacentre lies within a Flood Zone 1, defined as an area Low Pollution, Low commercial, Water with a low probability of flooding. Harm to residential, Environment surface water,
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NTT Global Data Centers EMEA Limited NTT Global Data Centers UK EMEA Limited Datacentre SLR Ref No: 410.10114.00001 Filename: 410.10114.00001 ERA Dcember 2020
recreational Operational areas, roads and external surfacing will benefit and Human and from impermeable surfacing to prevent the percolation of Health ecological any potentially contaminated water to soil and groundwater. receptors The site will benefit from a sealed drainage system which identified in discharges to the municipal combined sewer system via an drawings on on-site interceptor. 003A and 003B Evacuation procedures will be implemented in the event of flooding. The Site Manager will be responsible for implementing risk management measures in conjunction with the operating techniques document (Ref: 410.10114.00001/BATOT).
Table 5-5 Global Warming Potential (GWP) What do you do that can harm and what Managing the Risk Assessing the Risk could be harmed? Hazard Receptor Pathway Risk Management Probability of Consequence What is the overall Exposure risk What has What is at How can What measures will you take to reduce the risk? Who is How likely is What is the What is the risk that the potential risk what do I the hazard responsible for what? this contact? harm that can still remains? The to cause wish to get to the be caused? balance of harm? protect? receptor? probability and consequence Generation National and Air Operation of the generators will involve the combustion of Medium Harm to Medium of CO2e global air diesel fuel to generate electricity for use at the datacentre in environment, emissions quality and the event of an emergency outage of the National Grid Harm to climate supply of electricity. The generators will be subject to human health change planned maintenance and testing. The combustion of diesel will result in the generation of CO2e emissions. NTT will be a participant to a Climate Change Agreement, (CAA) for the datacentre sector. Energy management
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NTT Global Data Centers EMEA Limited NTT Global Data Centers UK EMEA Limited Datacentre SLR Ref No: 410.10114.00001 Filename: 410.10114.00001 ERA Dcember 2020
techniques will be implemented to monitor, record and track energy consumption at the datacentres. To achieve the reductions that will be required under the CCA energy reduction targets will be established in the Environmental Management System. Energy consumption has been considered in the BATOT document (ref. 410.10114.00001/BATOT).
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NTT Global Data Centers EMEA Limited NTT Global Data Centers UK EMEA Limited Datacentre SLR Ref No: 410.10114.00001 Filename: 410.10114.00001 ERA December 2020
ADAPTATION TO CLIMATE CHANGE RISK ASSESSMENT
An adapting to climate change risk assessment (CCRA) is required for new bespoke Installation environmental permit applications if the Installation is expected to operate for more than 5 years. A CCRA must be completed even if it is possible that the Installation will not be operational in 2050 as predicted climate changes, which can potentially be extreme, may be experienced before this time. The NTT datacentre will be operational for more than 5 years from the date of this permit application and therefore CCRA screening has been completed.
6.1 CCRA Screening CCRA screening involved completion of Part 6b of application form B2 for a bespoke environmental permit. The results of the screening assessment are included in application form B2; these are presented in Table 6-1. As the screening score for the datacentre was >5 a CCRA is required.
Table 6-1 Climate Change Screening Assessment
Screening Screening Answers Screening Score Category Timescales The environmental permit will be 5 required until 2060 or beyond (more than 40 years from now) Flood Risk Very low 1 for Rivers and Sea* Water Use Mains water 1 Screening Score Total 7 * - https://flood-warning-information.service.gov.uk/long-term-flood-risk
6.2 Climate Change Risk Assessment In order to complete the CCRA the appropriate risk assessment worksheet must be selected, this is based on the river basin district the site is located in. The NTT datacentre will be located in the Thames River Basin District; the completed risk assessment worksheet is presented in Appendix 02. Based on the ‘potential changing climate variables’ presented in the worksheet and the potential impact on operations at the datacentre, specifically related to the diesel-fired generators and diesel storage, the overall risks are low, with risk scores ranging from 1 – 3; these scores are below the threshold whereby mitigation measures are required to ensure operational resilience against potential climate change impacts. The risk assessment worksheet will be included in the NTT Environmental Management System and will be subject to regular updates. Where there are changes in the level of risk, for example as a result of new climate change predications or changes in site infrastructure, the CCRA worksheet will be updated and if necessary, mitigation measures implemented to reduce risk.
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NTT Global Data Centers EMEA Limited NTT Global Data Centers UK EMEA Limited Datacentre SLR Ref No: 410.10114.00001 Filename: 410.10114.00001 ERA December 2020
APPENDIX 01
EA Nature and Heritage Conservation Screening Report 30th January 2020
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Nature and Heritage Conservation
Screening Report: Bespoke installations
Reference EPR/WP3602BD/A001
NGR TQ5092185369
Buffer (m) 180
Date report produced 30/01/2020
Number of maps enclosed 2
The nature conservation sites identified in the table below must be considered in your application.
Nature and heritage Screening Further information conservation sites distance (km) Local Nature Reserve (LNR) 2 Natural England
Beam Valley (LNR)
East Brookend Country Park (LNR)
Dagenham Village Churchyard (LNR)
The Chase (LNR)
Ingrebourne Valley (LNR)
Local Wildlife Sites (LWS) 2 Appropriate Local Record Centre (LRC) Mid Beam Valley in Dagenham and Dagenham East Lake
The Chase and Eastbrookend Country Park
Mid Beam Valley in Havering
Wantz Lake and Crowlands Golf Course Pondsfield Park and adjacent railside
Beam Valley South in Dagenham and the Wantz Stream
St Peter's and St Paul's Churchyard, Dagenham
Beam Valley South in Havering
District line in Havering
Harrow Lodge Park
Hornchurch Country Park
The relevant Local Records Centre must be contacted for information on the features within local wildlife sites. A small administration charge may also be incurred for this service.
Please note we have screened this application for protected and priority sites, habitats and species for which we have information. It is however your responsibility to comply with all environmental and planning legislation, this information does not imply that no other checks or permissions will be required.
Please note, the enclosed pre-application map(s) is valid for a period of 6 months. If you plan to submit your application more than 6 months after the map(s) was generated, you must request that the screen is re-run. This will ensure that you have used the most current information on heritage and nature conservation interests in your application.
Local Nature Reserves
Legend
LNR (England)
1: 25,000 0 625
Metres © Crown Copyright and database rights 2020 . Ordnance Survey 100024198. Local Wildlife Sites
Legend
Local Wildlife Sites
1: 25,000 0 625
Metres © Crown Copyright and database rights 2020 . Ordnance Survey 100024198. NTT Global Data Centers EMEA Limited NTT Global Data Centers UK EMEA Limited Datacentre SLR Ref No: 410.10114.00001 Filename: 410.10114.00001 ERA December 2020
APPENDIX 02
Adaption to Climate Change Risk Assessment: Thames River Basin District Worksheet
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Thames river basin district: climate change risk assessment worksheet
Name (as on your part A application form): NTT Global Data Centers EMEA UK Limited
Our permit reference number (if you have one): TBC Your document reference number: 410.10114.00001ERA
Risk assessment worksheet for the 2050s Thames river basin district You must carry out a climate change risk assessment for any new bespoke waste and installations permit applications if you expect to operate for more than 5 years. Use the user guide to complete the table. You can add in extra pages if necessary. Consider how your operations will be affected by the changes in weather and climate described in the table. Consider any changes to average climate conditions that may impact on your operations, for example extreme rainfall. Also consider: • critical thresholds - where a ‘tipping point’ is reached, for example a specific temperature where site processes cannot operate safely • changes to averages - for example an entire summer of higher than expected rainfall causing waterlogging • where hazards may combine to cause more impacts You can add in other climate variables if you wish. If you have stated on your application form that you do not expect to be operational in 2050, you must still consider climate change risks for the time you do intend to operate. Whilst the variables are for the 2050s, this is an estimated date and you may experience these conditions before then. This worksheet will sit in your management system. It must appear on the management system summary you submit with your application, even if you do not need to submit the whole risk assessment with your application. If your pre-mitigation risk score (column D) is 5 or higher, you must complete columns E to H. A B C D E F G H Potential changing climate variable Impact Likelihood Severity Risk Mitigation Likelihood Severity Residual (B x C) (what will you do to mitigate this (after (after risk risk) mitigation) mitigation) (F x G) 1. Summer daily maximum temperature Interruptions in National 1 3 3 N/A N/A N/A N/A may be around 7°C higher compared to Grid electricity supply to average summer temperatures now. the datacentres resulting in the need to operate the generators as emergency back-up resulting in emissions to air due to the combustion of diesel.
National Grid Climate Change Adaptation Reporting, Second Round Response, July 2016 states that increased temperatures are unlikely to have a significant impact on electricity supply (https://assets.publishin g.service.gov.uk/govern ment/uploads/system/u ploads/attachment_dat a/file/566151/climate- adrep-national-grid.pdf)
It is considered unlikely that each generator will be operated for >500 hours per year for emergency back-up purposes.
The air emissions risk assessment has con- cluded that operation of the generators for 500 hours per year will have a high probability of ex- ceedances for short- term emissions of air quality standards/envi- ronmental assessment levels. It is however rec- ognised that such a pro- longed emergency sce- nario is highly unlikely and that the reliability of electricity supply from the local network could, A B C D E F G H Potential changing climate variable Impact Likelihood Severity Risk Mitigation Likelihood Severity Residual (B x C) (what will you do to mitigate this (after (after risk risk) mitigation) mitigation) (F x G) conservatively, be ex- pected to be unavailable for <1 hour per year. This is recognised in ‘Data Centre FAQ Headline Approach, Draft Version 10.0 H. Tee 01/06/18 – Release To Industry. .
2. Winter daily maximum temperature No negative impact N/A N/A N/A N/A N/A N/A N/A could be 4°C more than the current expected average.
3. The biggest rainfall events are up to (a) Surface water a. 1 a. 1 a. 1 N/A N/A N/A N/A 20% more intense than current drainage system is b. 1 b. 2 b. 2 extremes (peak rainfall intensity)*. overloaded. The site will have a rainwater harvesting tanks and an on-site water retention system.
(b) flooding of generator container units. The container units will be raised on concrete plinth which will act to minimise the risk of flooding.
A B C D E F G H Potential changing climate variable Impact Likelihood Severity Risk Mitigation Likelihood Severity Residual (B x C) (what will you do to mitigate this (after (after risk risk) mitigation) mitigation) (F x G) 4. Average winter rainfall may increase (a) Surface water a.1 a. 1 a. 1 N/A N/A N/A N/A by 36% on today’s averages. drainage system is b. 1 b. 2 b. 2 overloaded. The site will have a rainwater harvesting tanks and an on-site water retention system.
(b) flooding of generator container units. The container units will be raised on concrete plinths which will act to minimise the risk of flooding.
5. Sea level could be as much as 0.6m No negative impact 1 1 1 N/A N/A N/A N/A higher compared to today’s level *. expected.
The MAGIC map indicates that the datacentres are not located in an area designated as a Flood Risk Management Priorities (England) (i.e. priority areas for measures to address flood risk management issues).
Climate Change Risk Assessment screening stage confirmed that there is a very low risk of flood from rivers and sea.
A B C D E F G H Potential changing climate variable Impact Likelihood Severity Risk Mitigation Likelihood Severity Residual (B x C) (what will you do to mitigate this (after (after risk risk) mitigation) mitigation) (F x G) 6. Drier summers, potentially up to 42% No negative impact 1 1 1 N/A N/A N/A N/A less rain than now. expected.
Water use is not integral to operation and maintenance of the generators or the associated diesel storage arrangements. 7. At its peak, the flow in watercourses No negative impact 1 1 1 N/A N/A N/A N/A could be 35% more than now, and at its expected. lowest it could be 75% less than now. The datacentre has no process wastewater discharges to and does not abstract water from surface watercourses.
*Indicates data has come from climate change allowances as part of the spatial planning process. Evidence from your planning submission is acceptable evidence for this worksheet.
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