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1.0 Introduction INTRODUCTION AWN Consulting Limited _____________________________________________________________________________________________________ 1.0 INTRODUCTION This Environmental Impact Assessment Report has been prepared on behalf of Ipsen Manufacturing Ireland Ltd (IMIL) to accompany an application to the Environmental Protection Agency (EPA) for the proposed new process vent abatement system at the existing IMIL facility at Blanchardstown Industrial Park, Snugborough Road, Blanchardstown, Dublin 15. The site location is shown on Figure 1.1. A planning application was submitted to Fingal County Council for the proposed development (Planning Reference FW17A/0064) on the 21st April 2017 and was accompanied by an Environmental Impact Statement (EIS). The EIS was subsequently updated in accordance with the requirements of the 2014 EIA Directive (2014/52/EU) which was enacted on the 16th May 2017 and the Draft EPA Revised Guidelines and Advise Notes (September 2015). This document is now referred to as an Environmental Impact Assessment Report (EIAR) and is the updated version of the EIS submitted with the planning application. 1.1 CONTEXT During late 2015, licence compliance monitoring required by Schedule 1(ii) of IMIL’s Industrial Emissions Licence (IE Licence Register No. P0117-01) identified a number of exceedances of emission limit values (ELVs) at the IMIL main air emission point referenced “A3” (carbon adsorption system). On foot of these exceedances, IMIL undertook a comprehensive investigation including a root cause analysis and determined that a new process vent abatement system would be required to restore compliance. On an interim basis, a number of practical measures were implemented to ensure day to day compliance however a more sustainable longer term solution is now required for the operation of the facility into the future. The licence review application is primarily to enable that solution. For inspection purposes only. Another key goal for theConsent application of copyright owner is requiredto ensure for any other, as use. well as addressing the new process vent abatement system, that the revised IE licence obtained for the facility will be fit for purpose for at least the next 5 years i.e. in line with expected growth and future development at IMIL during that timeframe. The existing facility licence was granted in 1996 and several aspects require updating. The primary amendments being sought as part of the licence review application are: • Adding a new main emission point for the proposed new process vent abatement system (and addressing the future use of the existing abatement system as a back-up unit); • Increasing the licensed site boundary to incorporate the additional 1.7ha of land recently acquired from the IDA as part of the Building 4 project; • Addressing the recent upgrade in relation to balancing/attenuation tank for effluent discharges at existing emission point SE2 and • Addressing the proposed additional Purification process at Building 4. A description of the existing facility is presented in Chapter 2 in conjunction with descriptions of the existing environment (i.e. baseline conditions) in each respective EIAR “aspect” chapter. A detailed description of the nature of the proposed development is presented in Chapter 3 of this EIAR “Description of the Proposed Development”. _____________________________________________________________________________________________________ IMIL Process Vent Abatement Project EIAR Chapter 1, Page 1 EPA Export 21-06-2017:03:24:53 INTRODUCTION AWN Consulting Limited _____________________________________________________________________________________________________ The proposed amendments will generate no significant additional air, water, noise or other nuisance emissions when constructed and will work to reduce such emissions from the existing facility. This is detailed in the relevant chapters of the EIAR. 1.2 REQUIREMENT FOR EIAR The requirement for EIA, for certain types and scales of development, is set out in the Planning and Development Regulations as amended as well as the relevant sections of the Industrial Emissions Regulations (SI 282 of 2012). During November 2016, IMIL liaised with FCC regarding planning and EIA requirements for the proposed development and it was concluded that an EIAR (formerly EIS) was not required by the planning authority (subject to an application for a Declaration of Exempted Development). It was concluded on the basis of FCC’s determination that an EIS/EIAR is not mandatorily required for the proposed development however it was identified that the development was likely to be considered “sub threshold” development for the purposes of EIA by the Agency i.e. the addition of a new main emission point meant the project was likely to have significant effects on the environment. An EIAR has been prepared, conservatively, with the intention of expediting the licence review process, on that basis. This EIAR has been prepared in accordance with the requirements of the 2014 EIA Directive (2014/52/EU). It is prepared in the Grouped Format Structure as set down in the “Revised Guidelines on Information to be Contained in Environmental Impact Statements Draft” produced by the EPA (Draft September 2015). In general the EIAR follows the framework presented in the EPA “Advice Notes on Current Practice in the Preparation of Environmental Impact Statements Draft” (Draft September 2015). The Department of Housing, Planning, Community and Local Government’s “Transposition of 2014 EIA Directive (2014/52/EU) in the Land Use Planning and EPA Licencing Systems Key Issues Consultation Paper” (May 2017) has also been For inspection purposes only. consulted and consideredConsent in theof copyright preparation owner required of for this any other EIAR use. 1.3 COMPANY BACKGROUND IMIL is part of the Ipsen Group. Ipsen Group is a global speciality driven pharmaceutical company created in 1920 in Dreux, France. It currently employs over 4,500 people worldwide and currently has over 20 products on the market. Sales for 2016 amounted to c.1.6Bn. IMIL have been manufacturing a variety of bulk active pharmaceutical ingredients, namely peptides, at their site in Blanchardstown for over 25 years. IMIL produces 2 of the group’s main strategic products, Decapeptyl and Somatuline, which are used in the treatment of a range of life threatening diseases. Further details on the products made by IMIL are presented in Chapter 2 Description of the Existing Environment. 1.4 CONSULTATION AWN, IMIL and the project team have liaised with the EPA and the relevant departments of Fingal County Council in advance of lodgment of this application. _____________________________________________________________________________________________________ IMIL Process Vent Abatement Project EIAR Chapter 1, Page 2 EPA Export 21-06-2017:03:24:53 INTRODUCTION AWN Consulting Limited _____________________________________________________________________________________________________ During the course of the preparation of the IE Licence Review application, the Agency kindly facilitated a number of preparatory meetings between September 2016 and April 2017. A pre-planning meeting was held with FCC in November 2016 and representatives of a number of departments were in attendance including Planning, Environment and Roads. In addition the relevant EIAR specialists have liaised with other statutory bodies (including NPWS and Inland Fisheries) by correspondence during the course of EIAR preparation. AWN and the other respective EIAR contributors have incorporated advice and comments received from consultees into the relevant chapters of the EIAR. 1.5 CONTRIBUTORS TO THE EIAR Table 1 below presents the EIAR project team. The majority of the team is comprised of specialists at AWN Consulting supported with input from Brady Shipman Martin, Roughan & O’Donovan, CRDS and Moore Group. Chapter Title Environmental Specialists Company Responsible Non Tech Summary Bridgette Priestly BSc. (Hons) AWN Consulting 1. 1. Introduction David McDermott BSc Pgeo AWN Consulting EurGeol MCIWM 2. Description of Existing David McDermott BSc Pgeo AWN Consulting Development EurGeol MCIWM 3. Description of the David McDermott BSc Pgeo AWN Consulting Proposed EurGeol MCIWM Development 4. Alternatives, Planning David McDermott BSc Pgeo AWN Consulting and Development EurGeo MCIWM For inspection purposes only. Context ConsentBridgette of copyright owner Priestly required forBSc. any other (Hons) use. 5. Population and David McDermott BSc Pgeo AWN Consulting Human Health EurGeol lMCIWM Bridgette Priestly BSc. (Hons) 6. Landscape and Visual Thomas Burns: BAgSc (Land Brady Shipman Hort) Dip EIA Mgmt MILI Martin 7. Traffic & John Bell BEng CEng MIEI Roughan & Transportation O’Donovan Consulting Engineers 8. Material Assets David McDermott BSc Pgeo AWN Consulting (including IW approval) EurGeol MCIWM 9. Archaeology - Cultural Dr Stephen Mandal MIAI PGeo CRDS Ltd Heritage EurGeol 10. Noise & Vibration Dermot Blunnie BEng (Hons) AWN Consulting MSc MIOA 11. Air Quality & Climate Dr. Edward Porter BSc PhD C AWN Consulting Chem 12. Biodiversity Ger O Donoghue BSc Moore Group 13. Land, Soils & Bridgette Priestly BSc. (Hons) AWN Consulting Geology 14. Water and Hydrology Bridgette Priestly BSc. (Hons) AWN Consulting 15. Waste Management Bridgette Priestly BSc. (Hons) AWN Consulting _____________________________________________________________________________________________________ IMIL Process Vent Abatement Project EIAR Chapter 1,
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