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 required to 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”.
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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.
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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
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16. Interactions David McDermott BSc Pgeo AWN Consulting EurGeo MCIWM
1.6 DIFFICULTIES IN COMPILING THE SPECIFIED INFORMATION
There were no significant difficulties in compiling the specified information.
For inspection purposes only. Consent of copyright owner required for any other use.
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Sources: Esri, HERE, DeLorme, USGS, Intermap, increment P Corp., NRCAN, Esri Japan,
BALLYCOOLEN
Ballycoolin Road R121
Legend Existing licence boundary Extent of site applicable to planning application SNUGBOROUGH Extent of land under ownership of the applicant (proposed licence boundary) For inspection purposes only. Consent of copyright owner required for any other use.
Approximate scale only 0m 100m
Esri, HERE, DeLorme, TomTom, MapmyIndia, © OpenStreetMap contributors, and the GIS user community
Note: Drawing is for illustrative purposes only; Do not scale
CLIENT: PROJECT: DRAWN: CHECKED: APPROVED: APP'D DATE: Environmental Impact E.N Copyright AWN CONSULTING LIMITED Ipsen Manufacturing Assesment Report 2017 J.Mg E.N 18/04/17 All rights reserved. No part of this work Ireland may be modified or reproduced or copied No. of SIZE: SCALE: in any form or by means - graphic, electronic AWN Consulting Ltd Ipsen Manufacturing Sheets DRAWING TITLE: Figure 1.1 or mechanical, including photcopying, The Tecpro Building, Ireland, Blanchardstown, 1 A4 1:5,000 recording, taping or information retrieval Clonshaugh Business & Technology Park Dublin15 system, or used for any purpose other than Dublin 17, Site Location REVISION DESCRIPTION SHEET REV its designated purpose, without the written ~consulting Tel: + 353 1 847 4220 (Local setting) PROJECT Ref: 16_9048 1 permission of AWN Consulting Limited Fax: + 353 1 847 4257 EPA Export 21-06-2017:03:24:53 DESCRIPTION OF THE EXISTING DEVELOPMENT AWN Consulting Limited ______
2.0 DESCRIPTION OF THE EXISTING DEVELOPMENT
2.1 INTRODUCTION
The following chapter describes the existing IMIL facility (as at November 2016) and the process/operation as carried out at the facility since it commenced operations in 1989. Chapter 3 presents a detailed description of the Proposed Development (i.e. the changes proposed at the facility as part of this application including the new process vent abatement system).
2.2 LAYOUT OF THE EXISTING FACILITY
2.2.1 Site Location
The site is located at Snugborough Road, Blanchardstown close to the N3 National Primary Road (see Figure 1.1). The site is bounded to the north by the Ballycoolin Road, to the west by other industrial units and to the south by undeveloped fields. There are 4 cottages directly to the east of the facility.
The site is located c.9km from Dublin City Centre. Though the immediate surroundings of the site are primarily taken up with industrial land-uses, there are a number of other residences in close proximity to the facility. A number of residences are also located to the north of the Ballycoolin Road at St Philomenas Court and St Bernadettes Park.
Notable neighbouring land-uses within 1km include Bristol-Myers Squibb Cruiserath, IBM Ireland, The Jellybean Factory, ADSIL Data Centres as well as Blanchardstown Institute of Technology.
2.2.2 Description of Site Layout
The layout of the facility buildings For inspection is purposes shown only. in Figure 2.1 below. The existing site Consent of copyright owner required for any other use. currently occupies an area of approximately 3.9ha. (IMIL have recently acquired an 1.7ha of additional adjacent lands). There are currently 122 employees at the facility.
The layout of the site currently comprised of 4 main process buildings:
• Building 1 – This building comprises the main reception area, administration offices and the canteen. Adjoining the offices is the principal manufacturing facility which includes: o Synthesis I and II laboratories; o Purification I and II laboratories; o IBC corridor and pilot synthesis and pilot purification laboratory; o Packaging rooms; and o Various QC labs, utility facilities and maintenance facilities. • Building 2 – This building provides additional laboratory, office and production space. • Building 3 – This building incorporates a goods receiving area, a sampling room and a warehouse. • Building 4 – Construction of the building has recently been completed and will comprise lyophilisation (drying process) and, in future, purification facilities. This facility is expected to be operational in 2017.
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Buildings 1 to 4 are supported by a tank farm to the east of Building B1 with associated yards, parking and firewater retention pond. Building B1 was completed in 1989 with the tank farm added in 1999. Buildings B2 and B3 were added in 2009 and 2011 respectively. Building 4 was added in 2016.
A number of minor amendments have also been made to each building over recent years. These amendments include extensions and modifications of office space, canteen, drum store, tank farm and other areas in addition to the more significant additions of the process buildings and warehouses described above. A full list of the amendments to the development (from 1994 to recent) is provided in Chapter 4 Alternatives and Planning and Development Context.
Figure 2.1 Overview of Activities completed at each Process Building (including recently completed Building 4) For inspection purposes only. Consent of copyright owner required for any other use.
2.3 GENERAL OPERATION
In general terms there are 3 primary activities carried out at the IMIL site.
They are; • Manufacture of Peptide Active Pharmaceutical Ingredients (APIs) • Chemistry Manufacturing and Controls (CMC) – API Development group on site • Ipsen Pharmaceuticals Ltd – Operations Group on site since August 2012
IMIL are the sole producers of peptide API for commercial products within the Ipsen Group. IMIL produce peptides in batches using laboratory scale process equipment. The process is completed in a number of relatively simple successive steps on an 8 hour day shift.
The CMC group supports existing commercial products and works on the development of new peptides and other small molecules. Ipsen Pharmaceuticals staff are primarily office based marketing and road based sales staff.
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2.4 DESCRIPTION OF EXISTING PRIMARY PROCESSES
Peptides are naturally occurring biological molecules. They are defined as any compound with two or more amino acids linked in a chain, joined by adding the carboxyl groups of one peptide to the amino group of the next. Multiple amino acids join together are known as polypeptides. Longer chain polypeptides (50+ amino acids) are referred to as proteins (though the point at which a peptide becomes a protein is somewhat subjective).
The IMIL facility produces two main synthetic peptides, Decapeptyl and Somatuline. A number of variants of these 2 products are also produced at IMIL in smaller quantities.
Decapeptyl is the product name for Triptorelin Acetate/Pamoate; a 10 amino acid peptide. Decapepetyl otherwise (Triptorelin Acetate/Pamoate) is a synthetic analogue of Luteinizing Hormone Releasing Hormone used in the treatment of prostate cancer and endometriosis.
Somatuline is the name used for Lanreotide Acetate; an 8 amino acid peptide. Somatuline is a synthetic analogue of Somatostatin – it is used to treat acromegaly and other hormone dependant cancers. IMIL produce Somatuline in different grades.
2.4.1 Peptide API Manufacture
There are 3 main steps in the production of peptide API’s.
1. Chemical Synthesis of Crude Peptide. 2. Purification of Crude (including evaporation) 3. Lyophilisation
Process equipment used includes primarily reaction vessels with supporting equipment including evaporators, purification columns, lyophilisers and packaging steps. For inspection purposes only. Consent of copyright owner required for any other use.
Synthesis of Crude Peptides
Peptides are produced by solid phase peptide synthesis (SPPS). In simple terms this involves multiple phase elongation of a single amino acid peptide by adding amino acids one at a time to the parent peptide compound (typically a single amino acid compound) attached to a polystyrene resin. This is achieved by “de-protecting” the compound with a strong acid or base and then using a solvent wash to couple additional amino acids sequentially to the peptide.
Once the desired number of amino acids have been added the peptide is separated/cleaved from the resin using an acid (such as tri-fluoroacetic acid).
Purification of Crude Peptides
Following the synthesis stage, the peptide will have a purity of between 60-75%. In order to make it suitable for supply and use the peptide must therefore be purified to the required standards set by the various regulatory authorities (including the FDA/EMA/HPRA) and IMIL customers.
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solution – the substance is then passed through the chromatographic extraction process, removing impurities on each pass. The substance is analysed for purity and passed through the chromatography system several times until the desired level of purity is achieved. The final step is to remove the acetonitrile solution by evaporation and send the product for desalt. As present, the existing abatement system for the vacuum exhaust from the evaporation equipment is a carbon adsorber unit. (Note that the proposed new process vent abatement system is described in Chapter 3).
Lyophilisation Process
Freeze drying or Lyophilisation is a complex process in which the liquid part of a substance is removed by freezing and then sublimation (turning of a solid directly into a gas). Products which have been freeze-dried in a Lyophiliser can be transported without need for refrigeration; they can be stored at ambient temperature. They can also be re-constituted quickly and remain stable for relatively long periods of time.
2.4.2 Material Storage and Handling
All raw materials at the facility are stored at the tank farm to the rear of building B1 or at the adjoining drum store.
The tank farm comprises 4 No. 30m3 stainless steel tanks, 2 No. 50m3 stainless steel tanks and 1 No. 30m3 Halar lined GRP (PFA lined) tank (4 No. tanks for solvents, 2 tanks for wastes and 1 currently not in use). Tanks are surrounded by impervious concrete bunds with an access platform and designated tanker loading/unloading bay. Wastes and solvents are pumped directly via pipe rack to and from each of process rooms where the waste or solvents are used or generated respectively.
The main drum store is located directly beside the tank farm. It is a 115m2 cladded structure with 9 chemstore bunded modules. A drum store extension next to the original store comprises 8 No. 2 high bunded modules with bunded shelving. A cut off drain is in place around the drum stores to collect any spills and divert them to the retention pond for testing prior For to inspection release purposes (in only.the unlikely event of a spill). Consent of copyright owner required for any other use.
2.5 DESCRIPTION OF PRIMARY PROCESS INPUT AND OUTPUT REQUIREMENTS
2.5.1 Inputs
The IMIL process uses three main components; o Chemical Raw Materials including Solvents o Energy o Water
Raw Materials and Solvents
In terms of chemical raw materials IMIL use four bulk solvents. Other chemicals are used in much smaller quantities as shown on Table 2.1 below. This is the inventory of raw materials used based on 2015/2016 data. The 2022 estimate has also been provided based on current projections.
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2015-2016 Usage 2022 Estimate Maximum Volume Annual Stored on Volume Maximum Usage (m³) – Site (m³) – Stored Annual Chemical Name Tonnes only Tonnes only on Site Usage where where (Tonnes) (Tonnes) indicated as indicated as T T Dichloromethane (DCM) 20 246 10 - 33 332 Acetonitrile (ACN) 34 90 17 - 35 128 Dimethylformamide (DMF) 17 51 4 - 20 83 Isopropyl Alcohol (IPA) 19 51 3 - 19 67 Trifluoroacetic Acid (TFA) 2 6 1.83 7.72 Methanol 3 13 2.00 19.30 Triethylamine (TEA) 1 1 0.30 1.30 Piperidine 3 4 2.06 8.43 Ethyl Acetate 0.3 0.2 0.19 0.20 Tetrabutylammonium Hydrate (TBAOH) 0.2 0.5 0.19 0.49 Ammonium Acetate 0.6T 1.8T 0.74 2.55 Acetic Acid 2.4 5.9 1.98 13.27 Dimethylacetamide (DMAC) 1.2 2.2 0.76 2.01 Anisole 0.1 0.2 0.15 0.32 Diisopropylcarbodiimide (DIC) 0.2 0.3 0.22 0.54 Diisopropylethylamine (DIEA) 0.04 0.1 0.05 0.10 Hydroxybenzotrialle (HOBT) 0.07T 0.16T 0.06 1.50 Toluene 0.3 0.6 0.28 0.83 Ethanol Absolute 0.4 0.5 0.23 0.54 Citric Acid Monohydrate 0.019T 0.024T 0.01 0.03 Sodium Pamoate 0.09T 0.04T 0.06 0.01 Phosphoric Acid 0.06 0.24 0.11 0.25 Sodium Sulphate Anhydrous 0.025T 0.035T 0.02 0.03 Sodium Thiosulphate - - 0.001 0.002 Iodine 0.007 0.017T 0.020 0.040 Ammonium Hydroxide 0.003 0.0036 0.00 0.00 Ammonia Anhydrous (gas) 0.4 0.87 0.36 1.26 Table 2.1 Raw Materials Storage and Annual Usage
For inspection purposes only. All solvents (apart from Consentbulk ofsolvents) copyright owner are required received for any other on use. site in 200l drums. Table 2.2
below presents the quantities of solvent used and collected for disposal from the facility during 2016.
Solvent Amount sent off site for Disposal in 2016 (tonnes) DCM 199.25 ACN 124.64 DMF 107.98 Table 2.2 Solvent Usage and Disposal 2016
Mass balances are carried out at the end of each year to assess the amount of solvent lost in production processes and ensure this is minimised.
Energy Usage
Electricity and gas provide the bulk of the heat and power requirements. Diesel is only used for generators and is stored in two 1000L double skinned bowers.
See Table 2.2 below for the 2016 figures. There was a 35% increase in production during this period and therefore represents an increased energy efficiency.
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Energy/Fuel Type Amount Consumed in 2016 % increase vs 2015 Electricity (MW-Hrs) 4,298.8 +13% Natural Gas (m3) 401,650 +25% Diesel (L) 2,000 0% Table 2.3 Energy Usage 2016
Water
Water usage at the facility during 2016 was 10,939 m3. All water is sourced from mains water and is treated and purified to the required standard on site. Annual consumption was down by 3977m3 in comparison to 2015 (-26.7%).
2.5.2. Outputs
Products manufactured by IMIL are supplied directly to the specialty and primary care sectors here and around the world. A significant portion of IMIL’s products are supplied to international consumers most notably in France.
Other than finished product, the outputs from the facility are a variety of wastes including process effluent, surface water run-off and general solid and liquid wastes from the manufacturing activity and secondary activities.
Table 3.3 below presents a summary of the waste streams and quantities of waste generated by Ipsen and sent off site for management (recovery or disposal) during 2016. (The nature and type of waste generated by the facility varies from year to year but the main waste streams are now well characterised and quantity predictable based on projected production for the year).
Waste Type EWC Code Quantity Managed during 2016 (tonnes) Organic Halogenated solvents, 07 05 03 1,745.67 Washing Liquids and Mother Liquors For inspection purposes only. Other organic solvents,Consent of07 copyright 05 04 owner required for any other use. 7.36 Washing Liquids and Mother Liquors Solid Wastes containing 07 05 13 9.763 dangerous substances Mineral based non chlorinated 13 01 10 1.318 hydraulic oils Other fuels (including mixtures) 13 07 03 15.57 Wooden packaging 15 01 03 2.5 Mixed Packaging 15 01 06 1.458 Packaging containing residues 15 01 10 8.511 or contaminated by dangerous substances Absorbents filter materials 15 02 02 87.15 wiping cloths, protective clothing contaminated by dangerous substances Discarded equipment 16 02 13 1.522 containing hazardous components other than those mentioned in 16 02 09 to 16 02 12 Inorganic wastes containing 16 03 03 0.1 dangerous substances Laboratory chemicals, 16 05 06 0.23 consisting of or containing dangerous substances
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including mixtures of laboratory chemicals Ni-Cd batteries 16 06 02 0.073 Alkaline batteries (except 16 06 16 06 04 0.177 030 Mixed Construction and 17 09 04 7.9 demolition wastes other than those mentioned in 17 09 01, 17 09 02 and 17 09 03 Wastes whose collection is 18 01 03 1.8614 subject to special requirements in order to prevent infection Paper and Cardboard 20 01 01 3.456 Mixed Municipal Waste 20 03 01 31.603 Fluorescent tubes and other 20 01 21 0.082 mercury containing waste Biodegradable kitchen and 20 01 08 4.277 canteen waste Table 2.3 Summary of Wastes produced by IMIL in 2016
2.6 DESCRIPTION OF SECONDARY PROCESSES
2.6.1 Drainage
The facility generates three main types of run off or effluent.
Clean Storm Water - Run off from clean areas such as roofs and other non- production paved areas (typically areas 1.5m away from the building perimeter) are collected in the onsite drainage network and drained to the local authority storm sewer. Drainage from newer buildings notably Building B3 and B4 were designed with SUDS paving and this effectively reduces the quantum of run off from these areas.
Storm Water from Process Areas and Yards - Run off from process areas and yards is discharged to the For firewater inspection purposes retention only. pond. The pond is sampled in Consent of copyright owner required for any other use. accordance with licence requirements and discharged to public storm sewer a number of times per year subject to limit values.
Industrial Effluent - Waste water generated from washing floors, sinks and latter stage CIP rinses from equipment and carboy (containers) cleaned in the washroom are drained to the foul sewer via emission point SE2. Boiler blowdown and reject water from the purified waste system are also directed to SE2. (See Chapter 3 for details of the new attenuation and neutralisation system that has recently been installed). The foul sewer drains to the Ringsend Waste Water Treatment plant.
IMIL monitors the quality of effluent discharged to sewer via SE2 in line with its EPA licence requirements. The facility is currently licensed to dispose of up to 40m3 of effluent per day.
IMIL monitors the performance of its effluent for pH, flow and temperature with a continuous monitoring system. BOD, COD, suspended solids, detergents and sulphates are monitored weekly.
Aqueous Process Effluent – Hazardous process wastes are collected in process drainage within buildings for off-site disposal. Effluent collected is pumped to a bunded waste storage tank and collected by bulk tanker.
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Some smaller volume hazardous wastes arising from activities are stored in drums in the bunded drum storage area pending off-site disposal by approved licensed contractors.
2.6.2 Air Emissions and Abatement
Process vessels, vacuum pumps and other fume extract points related to the process are connected via a central manifold to a carbon adsorber system to the rear of Building B1. This adsorber contains activated carbon which treats the exhaust stream from the process prior to release to atmosphere (EPA Emission Point Reference A3). The activated carbon within the unit is inspected and changed as and when required to maintain treatment efficiency.
IMIL monitors the performance of the carbon adsorbtion system in line with its EPA licence requirements. The facility is permitted to discharge up to 5,000m3/hour or 50,000m3/day via emission point A3. Emission limit values are in place for TA Luft Organics Class I, II and III substances.
During 2015 and the early part of 2016, there were a number of exceedances of ELVs at emission point A3. See Chapter 3 regarding the proposed new process vent abatement system.
2.6.3 Fire Water
Firewater is stored in two sprinkler tanks located in the north east of the site. The combined capacity of the tanks is 675m3.
A firewater retention pond (1,100m3) is present on site and has been sized in accordance with an agreed methodology between IMIL and the EPA. The agreed methodology allows for all surface water falling on building aprons and external paved areas local to each building and tank farm areas only to be disposed to firewater retention pond. For inspection purposes only. Consent of copyright owner required for any other use.
2.7 OCCUPANTS/STAFFING
IMIL currently employs approximately 110 staff at the facility. The majority of staff are employed by Ipsen Manufacturing Ireland in engineering (10), manufacturing (29), quality (29) and CMC (22). Other staff (20) are employed in support services including admin, finance, HR and supply chain functions.
Ipsen Pharmaceutical Ireland Ltd employ 12 staff – 6 are based on site and 6 are road based involved in sales activities.
Traffic Management
The facility is accessed from the west via the main route through Blanchardstown Industrial park. Staff parking is currently also provided along the western side of the facility. There is a dedicated entrance route for deliveries. All visitors to site are directed to reception and access control is in place to prevent members of the public from entering the processing/bulk storage areas of the site.
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Site Security
Access to the facility (other than reception areas) is controlled via secured access gates. A CCTV system is in place and covers all views of the yard. A security company is also engaged to carry out regular security patrols on an ongoing basis.
2.8 DESCRIPTION OF NATURAL RESOURCES USED
Other than the inputs of chemicals, water and energy, the IMIL process uses limited natural resources.
Operationally the most significant natural resources used are water and power and their use is carefully managed and where possible reduced on an annual basis in accordance with IMIL’s environmental policy and objective and targets set by the environmental management system.
2.9 DESCRIPTION OF EFFECTS, RESIDUES AND EMISSIONS
Emissions from the existing facility include air emissions via emission point A3 and sewer emissions via SE2. Both emission points are subject to emission limit values set by the EPA.
Wastes generated by the process including hazardous/flammable process wastes (containing solvents) are collected and diverted to two holding tanks, 1 for flammable waste and 1 for chlorinated waste, for off-site recovery/disposal. Please refer to Chapter 15 for further details in relation to Waste Management at the facility
Non-hazardous wastes (municipal solid wastes from process, waste from maintenance of buildings, plant and equipment, staff activities and other at the facility) are collected by suitably licensed contractors for recovery where possible or disposal at licensed facilities. For inspection purposes only. Consent of copyright owner required for any other use.
2.10 REGULATORY CONTROL
2.10.1 EPA Licence
IMIL (formerly Kinerton Ltd) has been licensed by the EPA since 1996. The licence (P0117-01) was amended in 2013 for the purposes of Section 82A(11) of the EPA Act 1992 as amended i.e. the facility now holds an Industrial Emissions (IE) licence. (Up until 2013 the facility held an IPPC licence. The IPPC directive has now been replaced by the Industrial Emissions Directive).
The licensed activity completed at the facility is;
Class 5.16 – The production of pharmaceutical products including intermediates (production means the production on an industrial scale by chemical or biological processing)
The licence for the facility sets out a wide variety of requirements including controls and mitigation measures to ensure the operation of the facility does not result in significant impacts on the environment. The Agency requires ongoing monitoring of all facility activities and reporting of results of that monitoring on a regular basis. Any ______
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failure to comply with the licence conditions or limit values, requires investigation, remedial action and can result in enforcement action against licensees.
2.10.2 COMAH/Seveso Status of the Site
The existing facility is not a COMAH/Seveso facility. IMIL have recently re-assessed the status of the facility in light of changes brought about under the Seveso III Directive (2012/18/EU). It is concluded that these did not result in any change in COMAH/Seveso status.
2.11 DESCRIPTION OF THE RISK OF ACCIDENTS
2.11.1 Design and Construction Health and Safety
The facility and each of its component parts has been designed by skilled personnel in accordance with internationally recognised standards, design codes, legislation, good practice and experience based on the existing facility and a number of similar existing facilities in Ireland and abroad.
The facility has been designed and constructed in accordance with the provisions of the Building Regulations as amended, Safety Health and Welfare at Act 2005 and the Health and Safety and Welfare at Work (General Application) Regulations SI 299 of 2007 and associated regulations (as amended).
2.11.2 General Operational Health and Safety
IMIL operates an Integrated Health and Safety Management System known as Enviromanager. This system enables IMIL manage legislative compliance, risk assessments, incident response, near misses and good catches as well as recording audit outcomes etc.
For inspection purposes only. Consent of copyright owner required for any other use. 2.12 DESCRIPTION OF DECOMMISSIONING
In accordance with the requirements of EPA guidance on Environmental Liability Risk Assessment and Closure Planning including EPA guidance “Assessing and Costing Environmental Liabilities” 2014, a Closure Plan has been prepared for the facility and submitted to the Agency. The closure plan sets out the procedure for decommissioning of the facility upon closure. A copy of the plan is available upon request.
Upon closure all buildings, plant, equipment, drainage networks etc. at the site will be fully decontaminated and decommissioned. The buildings once rendered environmentally safe will more than likely be retained and sold on as part of the site following closure. (The lifespan of the facility is not defined nor is the potential future use of the site known).
Financial Provision has been agreed with the Agency in the form of an environmental impairment liability insurance policy. This provision will be maintained going forward in accordance with EPA licensing requirements. This will ensure the safe decommissioning of the facility and all related infrastructure.
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3.0 DESCRIPTION OF THE PROPOSED DEVELOPMENT
3.1 CHARACTERISTICS OF THE APPLICATION
IMIL intend to apply to FCC for permission for the installation of a new process vent abatement system at their existing facility in Blanchardstown Industrial Park, Snugborough Road, Blanchardstown, Dublin 15.
The following chapter presents a description of the proposed upgrades as applied for in April 2017.
3.1.1 Description of the Site
The proposed development site is as described in Section 2.1 of Chapter 2 other than the addition of recently acquired lands to the west and east of the facility as shown in Figure 1.1. These lands, acquired by IMIL in 2015 are not currently in use but will be included in the EPA licensing boundary under the licence review application.
3.2 NEED FOR THE PROPOSED DEVELOPMENT
During 2015, licence compliance monitoring at main air emission point A3 (carbon adsorption system) identified exceedances for TA Luft Organics Class 1 compounds. On foot of these exceedances, IMIL undertook an investigation including a root cause analysis and determined that a programme of reduction at source (primarily focussing on DCM, flammable and chlorinated waste transfer/filling activities) and modification of the existing abatement systems were required to restore compliance. This process was completed during 2015 and early 2016 and compliance has now been restored. However IMIL identified during the investigation of the issue that a more sustainable longer term solution would ultimately be required.
In terms of the longer term solution, IMIL appointed DPS Engineering to design an For inspection purposes only. abatement system to replaceConsent of the copyright existing owner required abatement for any other systemuse. (and emission point A3) in accordance with BAT (Best Available Techniques) requirements. A description of the proposed system is outlined below.
As part of the licence review, IMIL also sought to address a number of other amendments including another recently completed project to upgrade site infrastructure associated with waste water discharges via emission point SE2 (which have also recorded some exceedances in the past 12 months). IMIL’s overall intention is to revise the licence and position it so that the facility licence is fit for purpose for the projected level of activity/output at the IMIL site for the next 5 years.
3.2.1 Description of the Proposed Development
The facility in Blanchardstown was established in 1989 and manufactures specialised bulk peptide products including two of the global company’s strategic products, Decapeptyl and Somatuline, which are used in the treatment of a range of life threatening diseases. The primary activity on site is the manufacture of peptide API’s and this facility is the sole source for peptide API for commercial products within the Ipsen Group. Chapter 2 provides an overview of the site’s existing infrastructure and processes.
The proposed development is primarily for a new process vent abatement system to be located to the south of Building 4. This will require construction of an extended ______
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hardstanding area to the south of building 4 for the process vent abatement infrastructure. Figure 1.1 shows the proposed location of the development (denoted by the red line boundary). Figure 3.1 below shows sections of the plant which will have a main emission stack of 10m.
3.2.1.1 New Process Vent Abatement System
Based on the assessments carried out by DPS Engineering during 2016/2017, the preferred technology for controlling the VOC emissions from the process vent is Cryogenic Condensation. It has a proven record of effective VOC treatment by achieving removal efficiency of VOCs greater than 99%. This methodology is most effective when the VOC stream is highly concentrated but with relatively low volumetric loads making it suitable to the IMIL vent stream. Cryogenic condensation involves a coolant (liquid nitrogen) being used to chill the gas stream and condense gases into liquid or solid form for subsequent collection and removal.
In order to comply with BAT the new abatement system will also include an acid scrubber for ammonia removal at the start of the system and a zeolite polishing filter on the outlet. The existing carbon filter abatement system will be retained in place as a back-up for the new system (in the event of breakdown, short term stoppages etc.).
For inspection purposes only. Consent of copyright owner required for any other use.
Figure 3.1 Schematic of Proposed New Process Vent Abatement System.
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3.2.1.2 Ancillary Development
Wastewater generated from washing floors, sinks and later stage CIP rinses from equipment and carboy (containers) cleaned in the washroom are drained to foul sewer via emission point SE2. Boiler blowdown and reject water from the purified wastewater system are also directed to SE2.
During 2015 and 2016 IMIL noted occasional exceedances in pH levels at SE2. As there was currently no volume or pH control system in place for industrial wastewaters from Buildings 1 and 2, IMIL has recently completed installation of a new attenuation and neutralisation system which will provide assurance that all discharges are within the licenced limits.
The changes involved re-directing industrial wastewaters from building 1 to a collection sump at building 2. From here, the wastewaters are pumped to a new 40m3 equalisation tank via a neutralisation dosing system. Industrial wastewater from the new Building 4 will also be diverted to the new system. Figure 3.2 shows a photo of new industrial wastewater tank.
For inspection purposes only. Consent of copyright owner required for any other use.
Figure 3.2 New Industrial Wastewater Tank
3.3 EXISTENCE OF THE PROJECT
Under the EPA Guidelines on the Content of Environmental Impact Statements, the description of the existence of the project is required to define all aspects of the proposed lifecycle of the facility under the following headings:
• Construction • Commissioning • Operation • Decommissioning; and • Description of Other Developments
The following sections present a description of each of these aspects.
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3.3.1 Description of Construction
The construction of the facility will comprise four main stages, namely; • Site preparation works • External Structure Construction • Equipment Installation • Mechanical and Electrical Completion
The location of the proposed area to house the new process vent abatement system to the south of Building 4. The area was levelled prior to Building 4 construction works. As such no further site levelling work is required.
Foundations will still require some excavation but minimal spoil is anticipated. Chapter 15 Waste Management sets out the proposals for management of all wastes including spoil and other construction/demolition wastes likely to be generated by the project.
3.3.1.1 Working Hours
It is anticipated that the majority of construction works will be completed during normal construction hours i.e. 7am to 7pm Monday to Friday with a half day working on Saturday (8am -1pm).
However, it is possible that the contractor may wish to carry out certain operations outside these hours i.e. evening hours during long summer days etc. Such occurrences will be kept to a minimum. Where they do occur, contractors will ensure they take place over as short a timeframe as possible and as such are unlikely to cause excessive disturbance.
3.3.1.2 Site Preparation
As stated above, levelling of the site to provide the necessary base level for a concrete pad for the new abatement system has already been completed. Additional For inspection purposes only. site preparation includingConsent breaking of copyright of owner concrete required for hard any other standing use. will also be required for the wastewater connections and drainage.
Access roads and contractors’ compound are already in place from the recent Building 4 construction and it is anticipated that these will remain in place for the development.
The compound currently provides infrastructure for portable offices, portable sanitary facilities, equipment storage, parking etc. for contractors and will be used for the duration of the works. The construction compound is fenced off for health and safety reasons so that access is restricted to authorised personnel only.
Other works required will include surveying and setting out for structures, any rerouting of services/connections to services and setting up of the construction site with fencing etc.
A combination of excavators, trucks and other soil shifting plant will then commence the main site clearance and levelling aspects. (Much of this has already been completed in preparation for the project)
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3.3.1.3 Noise, Vibration and Dust Nuisance Prevention
With regard to construction activities, reference will be made to BS5228: Noise control on construction and open sites, which offers detailed guidance on the control of noise and vibration from demolition and construction activities. Various mitigation measures can be considered and applied during the construction of the proposed development, such as:
• limiting the hours during which site activities are likely to create high levels of noise are permitted, e.g. soil levelling/excavations; • establishing channels of communication between the contractor/developer, Local Authority and residents; • appointing a site representative responsible for matters relating to noise, and; • monitoring typical levels of noise during critical periods and at sensitive locations.
Furthermore, it is envisaged that a variety of practicable noise control measures will be employed. These may include:
• selection of plant with low inherent potential for generation of noise; • erection of barriers as necessary around items such as generators or high duty compressors, and; • siting of noisy plant as far away from sensitive properties as permitted by site constraints.
The potential for dust to be emitted depends on the type of construction activity being carried out in conjunction with environmental factors including levels of rainfall, wind speeds and wind direction. The potential for impact from dust depends on the distance to potentially sensitive locations and whether the wind can carry the dust to these locations. The majority of dust produced will be deposited close to the generated source.
In order to ensure that no dustFor inspection nuisance purposes only. occurs, a series of measures will be implemented. Consent of copyright owner required for any other use.
• Hard surface roads will be swept to remove mud and aggregate materials from their surface while any unsurfaced roads will be restricted to essential site traffic only.
• If required, any area/road that has the potential to give rise to fugitive dust will be regularly watered, as appropriate, during dry and/or windy conditions.
• Vehicles using site roads will have their speed restricted, and this speed restriction must be enforced rigidly. Indeed, on any un-surfaced site road, this will be 15-20 kph, and on hard surfaced roads as site management dictates.
• In dry conditions vehicles delivering material with dust potential (soil, aggregates) will be enclosed or covered with tarpaulin at all times to restrict the escape of dust.
• Wheel washing facilities will be provided for vehicles exiting the site in order to ensure that mud and other wastes are not tracked onto public roads.
• Public roads outside the site will be regularly inspected for cleanliness, and cleaned as necessary. ______
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• At all times, these procedures will be strictly monitored and assessed. In the event of dust emissions occurring outside the site boundary, movements of materials likely to raise dust would be curtailed and satisfactory procedures implemented to rectify the problem before the resumption of construction operations.
3.3.1.4 Water Discharges
Welfare facilities will be provided for the contractors on site during the construction works. Portable sanitary facilities will be provided.
Any surface water run-off collecting in excavations will be pumped from the excavation and treated by use of suitably sized grit chambers and a 3 chamber Class I hydrocarbon interceptor prior to discharge to the Local Authority surface water drainage network in compliance with the requirements outlined in the Water Chapter of this EIAR. See Chapter 14 for a full description of mitigation measures proposed.
3.3.1.5 Material Sourcing, Transportation and Storage
Materials Key materials will include steel, concrete, composite cladding, piping, electrical cabling, process equipment and architectural finishes. Specialist equipment for the new process vent abatement system will be delivered in parts and assembled onsite. A ‘Just In Time’ delivery system will operate to minimise storage of materials on site.
Sourcing Where possible it is proposed to source general construction materials from the Dublin area to minimize transportation distances.
Storage Aggregate materials such as sands and gravels will be stored in clearly marked receptacles within a secure compound area to prevent contamination. Liquid materials will be stored within temporary bunded areas, doubled skinned tanks or For inspection purposes only. bunded containers (all Consent bunds of copyright will owner conform required for to any standardother use. bunding specifications - BS8007-1987) to prevent spillage.
Transportation Construction materials will be brought to site by road. Construction materials will be transported in clean vehicles. Lorries/trucks will be properly enclosed or covered during transportation of friable construction materials and spoil to prevent the escape material along the public roadway.
3.3.1.6 Construction Works
Once site preparation is completed, installation will take approximately 6 months. The total peak construction population on site will be less than 20 staff. Site staff will include management, engineers, construction crews, supervisors and indirect staff.
Excavations It is envisaged that spoil generated during site preparation will be re-used in landscaping and levelling of the site where possible. Any concrete wastes produced during site preparation works will also require off-site removal.
Contractors will be required to submit and adhere to a method statement (including the necessary risk assessments) and indicating the extent of the areas likely to be
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affected and demonstrating that this is the minimum disturbance necessary to achieve the required works.
Temporary storage of spoil will be managed to prevent accidental release of dust and uncontrolled surface water run-off which may contain sediment etc.
Foundations and Structure The new process vent abatement structure will require concrete pad foundations.
Waste Management Chapter 15 contains a detailed description of waste management relating to construction of the proposed development. A detailed Construction and Demolition Waste management plan will be prepared in advance of the works to ensure best practice is followed in the management of waste from the proposed development.
Building Envelopes and Finishes The construction of the walls and roof of buildings will closely follow the completion of structures. Early completion of building envelopes allows the next stage of construction to be completed without delay i.e. building finishes, equipment installation including mechanical and electrical instrumentation, controls etc. The outer finishing of the building envelope will be primarily painted metal cladding, similar in quality and sympathetic in colour to the existing facility buildings
Roads, Services and Landscaping The internal road system will be extended and will be tarmac concrete finish.
3.3.1.7 Construction Schedule
A summary of the proposed target dates (earliest possible dates) for Phase 1 are set out below.
• Application for Planning Permission – April 2017 • Commence Site Construction works (subject to grant of planning permission) For inspection purposes only. – Q3 2017 Consent of copyright owner required for any other use. • Complete Construction Works – Q1 2018 • Complete Commissioning Works – Q1 2018 • Commence Activities (subject to EPA approval) – Q2 2018
3.3.1.8 Construction Impacts
Each of the following EIAR chapters (Chapters 5-15) include an assessment of the potential impact of construction works on their individual environmental aspect and set out the relevant mitigation measures relating to that aspects.
It is proposed that a Construction Environmental Management Plan be put in place by contractors to minimise the impact of all aspects of the construction works on the local environment. The CEMP will include emergency response procedures in the event of a spill, leak, fire or other environmental incident related to construction.
The primary impacts from construction are anticipated to include;
• Impacts on population and human health in terms of nuisances relating to the air quality of the environs due to dust and other particulate matter generated from excavation works and impacts on the noise environment due to plant
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and equipment involved in construction. There is the potential for vibration impacts associated with concrete and bedrock breaking etc. • Temporary impacts on the land, soils and geology of the site during construction i.e. some loss of protection of the underlying aquifer to contaminants during construction of foundations, exaction for wastewater infrastructure, etc. • Effects on the road network of the industrial estate and its environs due to construction workers and other staff attending site during preparation, construction and commissioning phases. • Impacts on the biodiversity of the site (minimal – all existing treelines/hedgerows and boundary vegetation will be retained).
Mitigation measures to address each of these potential impacts are presented in each individual EIAR chapter.
At the time of production of this EIAR, it is noted that a number of other construction projects are occurring on neighboring sites in the Blanchardstown/Mulhuddart/Cruiserath areas. While these works may continue during a similar timeframe as the proposed development, it is anticipated that the mitigation measures proposed above and for each of these projects will ensure no significant cumulative impact from the projects occurring within the estate at similar times.
3.3.2 Description of Commissioning
Following construction, the proposed development will be commissioned within the proposed 6 month construction and commissioning period. The commissioning work will involve contractors installing and then validating i.e. testing and certifying the new abatement equipment following its installation.
As process vent abatement must be maintained at all times (during operation of the production process) it is anticipated that the existing abatement system will continue to be used up to completion and putting into operation of the new cryogenic system. For inspection purposes only. Consent of copyright owner required for any other use. 3.3.3 Operation of the Project
As outlined above, the new air abatement system will include a combination of an acid scrubber for ammonia removal followed by a Cryogenic Condensation unit and a zeolite polishing filter on the outlet. Section 3.4 below outlines the main input and outputs of the new system whilst Figure 3.3 is a process diagram showing the main processes involved.
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Note 19 EPA test point provided on stack Figure 3.3 Process Diagram for Proposed Process Vent Abatement System
3.3.4 Decommissioning of the Project
Subject to the grant of this application, the existing Closure Plan (described in Chapter 2) will be updated to account for the new process vent abatement system. In
summary it is not anticipated thatFor inspection the developmentpurposes only. will require any special additional Consent of copyright owner required for any other use. closure measures.
Upon closure all buildings, plant, equipment, drainage networks etc. at the site will be fully decontaminated and decommissioned in accordance with the requirements of the facility EPA licence. The buildings once rendered environmentally safe will more than likely be retained and sold on for future use as part of the site following closure.
3.4 DESCRIPTION OF PROPOSED INPUT AND OUTPUT REQUIREMENTS
3.4.1. Inputs
Raw Materials It is expected that there will be an increase in raw material deliveries to the facility. These will include coolant (liquid nitrogen) and scrubber reactants for the new process vent abatement system. With exception of Liquid Nitrogen, the existing tank farm has adequate storage capacity. A new liquid nitrogen tank will be installed as part of the project, to minimise the delivery frequency required. The increase in vehicle movements is considered minor/ neutral as there will be a reduction in vehicle movements for required to service the existing carbon adsorber which will only be used for backup purposes .
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A Nitrogen Recovery System will also be used to allow for re-use of liquid nitrogen and reduce the requirement for new product.
Energy Usage Energy (electricity) usage is expected to increase by a maximum of 3.5% to power the new process vent abatement system.
Water An small increase in water usage is expected as a result of the operation of the new process vent abatement system (c. 1m³ of water per day of operation).
3.4.2. Outputs
In in anticipated that wastes associated with the new process vent abatement system including solvents will be generated in relatively small amounts as a result of the system. These will be managed as hazardous wastes and will be disposed of off-site by suitably qualified contractors. Further details are outlined in Chapter 15.
3.5 CHANGES TO SECONDARY PROCESSES/ACTIVITIES
3.5.1 Drainage
The additional hardstanding area created by the process vent abatement project will be drained to the fire water retention pond.
In terms of firewater, the existing retention pond has sufficient capacity to hold firewater arising from the facility following the addition of the new process vent abatement building as outlined below (It is anticipated that firewater retention capacity will be reviewed and agreed with the Agency under the terms of the facility licence in due course).
Please refer to Chapter 14 for a more detailed description of the surface water For inspection purposes only. management system andConsent the ofbasis/rationale copyright owner required for for anyits other design. use.
As part of the preparation of this planning application and EIAR, IMIL and AWN Consulting have engaged with Irish Water (IW) regarding a proposed increase in discharges to the foul sewer network via emission point SE2. It is proposed to increase the limit value of daily volume discharged from 40m3/day to 80m3/day. Irish Water (IW) have confirmed that subject to application there will be no difficulty accepting the minor increases in proposed discharges from the facility.
3.5.2 Firewater
No additional firewater storage capacity is required on site as a result of the proposed process vent abatement system.
The additional hardstanding area to be drained to the fire water retention pond from proposed development is approximately 1300m2 which could generate an additional loading of 88.4m3 in an extreme rainfall event (based on a 1 in 20 year storm over a 24hour period). This volume can be accommodated within the existing firewater retention pond. It should be noted that the likelihood of coincident occurrence extreme rainfall event and a fire on site are considered to be extremely low.
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3.5.3 Utilities
The process vent abatement system will be connected into the site utility networks comprising electricity and gas. Electrical power and gas to the existing facility is provided from the external (off-site) connection to the grid via a ducted network connecting each building and other on-site infrastructure. Please refer to Chapter 8 Material Assets for further details regarding utilities connections.
Rainfall and any spillages on the hardstanding from the floor and ancillary areas of the building will be diverted to the firewater retention pond as required.
Hazardous liquid wastes and by-products from the abatement system will be stored in designated storage next to the abatement system prior to off-site disposal.
3.6 OCCUPANTS/STAFFING
It is anticipated that there will be no additional staff required as part of the operation of the new process vent abatement system.
3.7 DESCRIPTION OF NATURAL RESOURCES USED
Other than the slightly increased inputs in terms of chemicals, water and energy the proposed abatement processes will use limited additional natural resources.
Construction of the system will require standard construction materials. The majority will be steel for the equipment and cladding for the equipment frame. Construction materials will be locally sourced where possible to minimise impact of transport etc.
3.8 DESCRIPTION OF EFFECTS, RESIDUES AND EMISSIONS
For inspection purposes only. As the proposed developmentConsent of copyrightis for anowner improved required for any process other use. vent abatement system it is anticipated that there will be a positive impact on overall air emissions from the site as a result of the development. Sewer emissions are also anticipated to improve as a result of the industrial wastewater upgrades.
Wastes generated by the new process vent abatement system will be of a similar nature to those already produced in the existing buildings (Buildings B1-B4). Hazardous/flammable process wastes (containing solvents) will be collected and diverted to a 50m3 stainless steel holding tank for off-site recovery/disposal.
General wastes (municipal solid wastes from staff and other waste from maintenance of buildings, plant and equipment at the facility) are collected by suitably permitted contractors for recovery where possible or disposal at suitably registered/permitted/licensed facilities. Please refer to Chapter 15 for further details regarding Waste Management at the facility.
3.9 RELATED DEVELOPMENTS AND INDIRECT IMPACTS
As described in each of the respective chapters of the EIAR, a number of nearby pharmaceutical and industrial companies have recently been granted permission by FCC for additional development of their existing sites or new developments in Blanchardstown/Mulhuddart. A list of these developments, notably including Alexion, ______
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Bristol-Myers Squibb, Montjeu Ltd amongst others, is provided in Chapter 4 of this EIAR.
The proposed development is a relatively small additional structure at an existing manufacturing site with the purpose of improving overall air and water emissions from the site. As such it is anticipated that the potential cumulative impact of its operation in conjunction with the other planned developments will be minimal.
During construction there is the potential for short term nuisance impacts from traffic, construction waste, dust and noise if not carefully managed. IMIL will require contractors to implement a Construction and Environmental Management Plan to ensure these impacts are minimised.
Each chapter of the EIAR assesses the potential cumulative impact of the construction and operation of these developments on the local environment. Please refer to each specialist EIAR chapter respectively.
For inspection purposes only. Consent of copyright owner required for any other use.
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4.0 ALTERNATIVES, PLANNING AND DEVELOPMENT CONTEXT
4.1 INTRODUCTION
This chapter describes the main alternatives considered by IMIL in the development of this project and the Regional and Local planning context as set out in the relevant Fingal County Council planning policy.
The site for the proposed development is situated within the administrative area of Fingal County Council, and therefore the Planning and Development Framework with which the development complies is defined by the:
• Fingal Development Plan 2011-2017
The following sections describe how the proposed development is in compliance with the stated and statutory requirements of Fingal County Council with respect to planning and sustainable development.
4.2 FINGAL COUNTY DEVELOPMENT PLAN 2011-2017
The plan covers the administrative area of Fingal, which is 450 sq. km in extent. The district covers the area from the River Liffey and the Dublin City boundary in the south to the Meath and Kildare boundaries in the West. The plan outlines Fingal County Council’s policies and objectives for the development and improvement in a sustainable manner of the economic, environmental, cultural and social assets of the County over the period 2011 to 2017.
Zoning
The proposed development is to be located within an area zoned HT (High Technology) with the aim to; For inspection purposes only. Consent of copyright owner required for any other use. ‘facilitate opportunities for science and technology, major office and research and development based employment within high quality, highly accessible, campus style settings.’
Objective EE30 of the Plan in relation to this land use zoning states the objective to;
“Encourage the development of corporate offices and knowledge based enterprise in the County on HT zoned lands and work with Government agencies, and other sectors to achieve such development.”
Employment
It is the policy of the local authority to facilitate economic development and the growth of employment in the county through support for objectives which promote economic, social, and cultural development and in assisting the provision of employment opportunities for all.
The plan identifies Blanchardstown and Swords as Metropolitan Consolidation Town’s which will be the main growth areas within the Fingal Metropolitan area. This was outlined in the Regional Planning Guidelines 2010-2022 and makes the provision of employment in these types of locations a priority for the local authority.
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Specifically, the development plan sets out Fingal County Council’s policies and objectives to;
‘promote the growth of research and development in Fingal by facilitating the conditions conducive to such development including a high quality built and natural environment, public transport infrastructure and community and cultural infrastructure’.
Industry and Commerce
Economic Clusters and Corridors are geographic concentrations of competing, complementary or interdependent firms and industries that may do business with each other and or have common needs for talent, technology and infrastructure and rely on the services of other cluster firms in the operation of their business.
Objective EE09 states the Fingal County Council’s aim to;
‘Promote innovative economic sectors and encourage clustering which exploits links between interconnected companies and/or with third level educational institutions’.
Dublin airport and the various industrial and business parks including Blanchardstown Industrial Park are cited as particularly important areas for the creation of a cluster of high end economic development based around Foreign Direct Investment manufacturing and support industries. The positive characteristics of these areas include the availability of large plot sizes, infrastructures and heavily landscaped corporate park models.
The plan also outlines the principle development concepts for the Dublin-Belfast Corridor along which the proposed site is situated. These concepts include ensuring the protections of the Corridor’s economic potential and integrity through the facilitation of a critical mass in a physical and economic sense within exiting settlements.
For inspection purposes only. Consent of copyright owner required for any other use. 4.3 SUSTAINABLE DEVELOPMENT
‘Sustainable Development – A Strategy for Ireland’ was published by the Department of the Environment in 1997. It provides analysis and a framework to ensure that development is undertaken in a sustainable manner. The strategy recognises that a considerable proportion of the industrial base in Ireland is made up of multi-nationals and these companies operate to high environmental standards.
The strategy aims to ensure that development is carried out sustainably and in an environmentally sound manner which includes; optimisation of natural resources, minimisation of waste, safe and sparing use of chemicals and the application of clean technology.
These aspects are integral considerations in the operation of the facility on a day to day basis as well as being mandatory requirements of the facility EPA licence.
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4.4 PLANNING PERMISSIONS
The proposed development is located in a designated industrial park which in conjunction with neighbouring industrial parks including Rosemount Business Park, College Business and Technology Park and Blanchardstown Industrial Estate, has recently experienced a marked increase in applications for large scale industrial development.
IMIL is aware that several planning applications have been made by other pharmaceutical companies in the surrounding areas of Blanchardstown Industrial Park in recent times. These projects are now under construction including Montjeu Limited, Swords Laboratories t/a Bristol-Myers Squibb and Alexion Pharma International Trading Ltd. As part of the assessment of the proposed development, account has been taken of planned developments in the area, as well as existing local land uses.
The Fingal County Council Planning Department website was consulted in order to generate a list of granted planning permissions in the area of the site for the proposed development within the previous 3 years. Table 4.1 below presents a list of the notable applications within that period. A list of all planning applications made by IMIL since commencement of the activity is provided in Table 4.2.
Fingal County Council Planning Summary Description of Application Location of Development Decision Date Development Reference No. & Applicant Permission for external and internal alterations to FW16A/0104 an existing light industrial/warehouse Unit 3, Rosemount Business Permission Granted 10th Allinall Ingredients building to facilitate a new Park, Ballycoolin, Dublin 15 October 2016 Ltd light industrial use (food processing warehouse and distribution). Retention permissionFor inspection for purposes only. Consent of copyright owner required for any other use. alterations to building currently under FW16A/0085 construction (39.3m²) College Business & comprising of an ESB sub- Technology Park, Cruiserath Permission Granted 29th Montjeu Ltd station, mv/lv switch room Road, Blanchardstown, August 2016 and remote switch room Dublin 15 previously granted planning permission Reg Ref FW15A/0143. Permission for the construction of a 3 - storey extension with roof top plant-room to a 3 - storey College Business & FW16A/0080 administration building Technology Park, Cruiserath Permission Granted 15th
currently under Road, Blanchardstown, August 2016 Montjeu Ltd construction (refer Dublin 15 planning reg. ref FW15A/0038) and associated site works Permission for the construction of a four- Plaza 211, formerly Site E,
storey office building with Blanchardstown Corporate FW15A/0151 Permission Granted 15th July rooftop plant and Park (Phase 2), 2016 associated car and Blanchardstown Road Channor Ltd parking, bin-store and site North, Dublin 15 works.
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Permission for the demolition and removal of a number of FW16A/0002 buildings/structures, and Cruiserath & Goddamendy Permission Granted 7th June their associated Townlands, Cruiserath Swords Laboratories 2016 underground services, in Road, Mulhuddart, Dublin 15 t/a BMS Cruiserath six distinct areas on the existing BMS API Facility in Cruiserath. Provision of new 260 sq.m. single storey extension to existing X-Ray Department including a 102 sq.m. FW15A/0165 single storey louvered Connolly Hospital, Permission Granted 22nd plant room on roof; to Health Service Blanchardstown, Dublin 15 March 2016 accommodate staff Executive change, rest, on-call and administration facilities together with all associated works. Permission for development at this site. Full planning permission on a 4.12 hectare site comprising an existing building formerly occupied by Creative Labs Ireland. The proposed development comprises of FW15A/0117 the change of use of floor- Site formerly Creative Labs space part single part two Ireland, Ballycoolin Industrial Permission Granted 26th St Stephens Green storey building from light Estate, Ballycoolin, January 2016 Funds plc industrial warehouse use Blanchardstown, Dublin 15 with ancillary office use as a data centre with ancillary office. The proposed use will comprise of a 9,215 sq.m gross Data Centre use at ground floor level with 2,270 sq. m gross ancillary office use over ground and first floor level. Permission for the construction of a single storey building For inspection (39.3 sq.m. purposes only. maxConsent height of 4.3m)copyright owner required for any other use. comprising of an ESB sub- FW15A/0143 station, mv/lv switch room College Business and and remote switch room Technology Park, Cruiserath Permission Granted 19th and for local alterations to Road, Blanchardstown, January 2016 Montjeu Ltd boundary fence layout Dublin 15 previously approved under permitted development granted under Plan Ref. No. FW15A/0038 off Cruiserath Road. Permission for a new 2- storey building for use as electrical rooms for electronic operations, Hexagon Building, IDA together with mechanical Blanchardstown Business & FW15A/0135 plant rooms, a double Technology Park, Permission Granted 12th vehicle loading bay and Snugborough Road, January 2016 ADSIL ancillary workshops. Blanchardstown, Dublin 15 Included within the
building are associated offices, staff facilities at ground floor level and at mezzanine level.
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Phase 2 of biopharmaceutical FW15A/0067 manufacturing campus. College Business &
Technology Park, Cruiserath Permission Granted 02 July (Phase 1 under Fingal Alexion Pharma Road, Blanchardstown, 2015 County Council planning International Trading Dublin 15 register reference Ltd. FW14A/0020 and FW14A/0138). Permission for the construction of College Business & FW15A/0038 Pharmaceutical Technology Park, Cruiserath Permission Granted 15th
Manufacturing building Road, Blanchardstown, June 2015 Montjeu Ltd and associated Dublin 15 development. FW15A/0031 Extension to front (south Unit 46 Rosemount facing) elevation of the Permission Granted 02nd Business Park, Ballycoolin, Century Electrical existing wholesale display June 2015 Dublin 11 Distributors Ltd area Permission for the construction of a new Biopharmaceutical Manufacturing Facility to the north of the existing FW15A/0043 BMS Pharmaceutical Campus including Cruiserath & Goddamendy Permission Granted 29th Swords Laboratories manufacturing facility. The Townlands, Cruiserath May 2015 t/a Bristol Myers works include Road, Mulhuddart, Dublin 15 Squibb (BMS) modifications to the existing Waste Water Treatment Facilities, the local demolition of items of plant, equipment and storage facilities. Amendments to previous development granted FW14A/0138 under FW14A-0020- College Business & Permission Granted and Phase 1 of Technology Park, Cruiserath Alexion Pharma Grant Retention on 17th biopharmaceutical Road, Blanchardstown, International Trading December 2014 manufacturing campus Dublin 15 Ltd. and associated development Permission for the se paration For of Buildinginspection 1purposes only. andConsent Building of copyright 2 by removal owner required for any other use. of 3 No. single storey links building between Building 1 and 2, part removal of curved wall at entrance to Building 2 on the south FW14A/0069 facade, reinstatement of Ballycoolin Business Park, Permission Granted on 2nd side walls to west facade Blanchardstown, Dublin 15 September 2014 IBM Ireland PDL of Building 1 and east facade of Building 2, erection of boundary fence between buildings together with associated site works and the replacement of doors to the HV room to the east facade of Building 1. Construction of a 5-storey office building and roof top FW14A/0020 plant room, QC College Business & laboratories, packaging / Technology Park, Cruiserath Permission Granted on 28th Alexion Pharma warehouse, utility building Road, Blanchardstown, March 2014 International Trading and spine corridor on a Dublin 15 Ltd 16.8 hectare site. New entrance and ancillary development.
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Permission for the change of use, increase in internal area and modifications to Block B and Link Building at FW13A/0139 the existing Block B and the, Aurora Site, Ballycoolin Permission Granted 24th
Link Building at the Aurora Business Park, Ballycoolin March 2014 Symantec Ltd site, Ballycoolin Business Road, Dublin 15 Park, Ballycoolin Road, Dublin 15. Permission for the construction of a 208m2 single storey extension to FW13A/0121 the existing X-Ray Connolly Hospital, Permission Granted 20th Department including a Blanchardstown, Dublin 15 January 2014 Health Service timber fenced plant Executive enclosure and associated roof mounted plant and all ancillary works. Table 4.1 Recent Planning Applications to FCC (search conducted 25/11/2016)
Fingal County Council Planning Development Description Location of Development Application Reference No. 1. The construction of a new two storey Pharmaceutical manufacturing building (Gross Floor Area 2187m²), with 2 no. external steel stairs and associated pipe bridge extension to existing pipe bridge, external ground level equipment including Standby generator, 2 no. chiller units, recessed waste holding tank and provision of new underground stormwater attenuation. 2. The construction of a new single storey external steel stairs to the northern elevation of existing building 1. 3. The construction of Blanchardstown Industrial Park, a new single storey enclosed electrical plant room FW15A/0115 Snugborough Road, Blanchardstown, (Gross Floor Area 25.4m²), between existing buildings Dublin 15 1 and 2. 4. Erection of a new sign and logo (5.28m²) over existing office entrance. 5. And all ancillary and associated site development works. And 6. Retention of an existing single storey temporary office building (Gross floor area 85.2m²), For inspection to the purposes south only. of existing building 3, Consentfor a period of copyright of 5 years.owner required 7. Retention for any otherof an use. existing single storey contractors compound (site area 1616m²), for a period of 5 years. (Planning Permission Ref FW09a/0090 refers). 8. And all ancillary and associated site development works. FW14A/0063 Permission for development consisting of 1. Material Blanchardstown Industrial Park, change of use from warehousing to production, 2. A Snugborough Road, Blanchardstown, new internal 1st floor area. 3. Installation of new Roller Dublin 15 Shutter Doors, 2 no. emergency doors, new windows and cladding, steel frame over air handling unit. DAC/073/14 New synthesis plant area. Material alterations & Blanchardstown Industrial Park, mezzanine extension of an existing industrial unit Snugborough Road, Blnchardstown, (builing 1) to provide a new synthesis area. Dublin 15 FW13A/0019 Single storey ground floor extension to existing Blanchardstown Industrial Estate, Dublin canteen, Removal & replacement of exiting curtain 15. walling, Reorganisation of carpark including landscaping FW11A/0081 Construction of a Drum Store extension to existing Blanchardstown Industrial Estate, Dublin facility and to provide a New Storage Building 15. extension to existing Waste Store facility. FW09A/0129 Two storey extension to exiting building for provision of Blanchardstown Industrial Estate, Dublin a new Laboratory and office area, an additional 56 No. 15. car parking spaces, new boundary fence, gates, & signage
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FW09A/0118 Extension to existing tank farm approx. 7m high, Blanchardstown Industrial Estate, Dublin installation of a dump tank approx. 4m high, 15. installation of 2 No. external air handling units approx. 5m high FW09A/0094 Construction of a two-storey office and warehouse Blanchardstown Industrial Estate, Dublin building with a single storey link corridor joining the 15. existing buildings, a new site access road to the east of the new building and the construction of a waste handling area. FW09A/0090 Temporary permission granted for a temporary vehicular entrance with a pedestrian crossing, a Blanchardstown Industrial Estate, Dublin temporary contractor’s compound enclosed with a 15. palisade fence, vehicular gates and hedgerow and 74 No. car parking spaces F08A/0740 Retention permission granted for extended electrical Blanchardstown Industrial Estate, Dublin switch room and related site works on the north 15. elevation F07A/0731 New two storey Laboratory & Office Building linked at Blanchardstown Industrial Estate, Dublin ground floor level with existing production facility 15. F06A/1909 Retention permission granted for development works Blanchardstown Industrial Estate, Dublin granted under planning app Reg Ref, F06A/0637, 15. constructed works included the installation of a new window and car park extension for 20 no. car park spaces. F06A/0637 Two storey extension to existing utility building in the Blanchardstown Industrial Estate, Dublin rear service yard and a new window to the front 15. elevation at ground level, car park extension for 21 additional spaces. F05A/0928 Permission granted for a 14m high x 4m high fire water Blanchardstown Industrial Estate, Dublin retention tank 15. F04A/1109 Retention permission granted for a free standing Blanchardstown Industrial Estate, Dublin external signage to main entrance 15. F03A/0109 Permission granted for provision of a two storey office Blanchardstown Industrial Estate, Dublin extension to the west of existing building. 15. Reconfiguration of car parking. Retention of 62 sq.m of mezzanine storage space with the existing facility and associated façade alterations F01A/1258 Works on existing facility including retention of Blanchardstown Industrial Estate, Dublin temporary portacabin for 5 years, permission for new 15. chiller plant enclosure to rear of existing facility. F98A/1121 Construction of a drum storage facility, a bunded tank Blanchardstown Industrial Estate, Dublin farm comprising 4 no tanks of 30 m3 capacity each an 15. associated pipe rack and site works. F98A/0007 Permission granted For inspection to retain purposes alterations only. to existing Blanchardstown Industrial Estate, Dublin elevations,Consent the provisionof copyright ofowner a newrequired office for any area other use. and 15. extension of existing plant and utilities facility at premises. F95A/0458 Erection of 2 no. signs, a sprinkler/fire water tank, Blanchardstown Industrial Estate, Dublin Chiller Compound and Oil Storage Tank with an 15. associated Utilities Building at site F94A/0532 Extension to premises to accommodate Storage and Blanchardstown Industrial Estate, Dublin Plant facilities and permission granted for change of 15. use of Open Warehouse Area to Pharmaceutical Production. Construction of additional Car Parking and Ancillary Roads and construction of an External Oil Storage and Chiller Compund with associated Pipe Rack Gantry. Table 4.2 Record of Planning Applications made by IMIL to FCC
4.5 ALTERNATIVES
EIA legislation and the prevailing guidelines and best practice require that Environmental Impact Statements consider “alternatives” for EIA projects with regard to their environmental effects including;
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This chapter describes the alternatives that were considered for the proposed development under each of these headings and the reasons for the selection of the preferred options.
4.5.1 Alternative Project Locations
This EIAR has been primarily prepared to accompany an application for the licensing of a new process vent abatement system at an existing pharmaceutical manufacturing facility in Blanchardstown.
The existing site, and portion of site upon which the process vent abatement system will be sited, is a designated industrial area with a limited number of sensitive receptors in its immediate environs. As such, it is considered that the existing IMIL site is the only logical site for this development.
4.5.2 Alternative Design/Layouts
In order to locate the proposed new process vent abatement system, IMIL and its design team undertook an assessment of several possible locations within the existing IMIL site. The merits of each location were evaluated from an environmental, engineering, financial and spatial perspective.
One of the key considerations in the location of the new abatement system was to ensure security of supply of product for the Ipsen Group. In the event of a significant fire/other major incident at the facility, Ipsen Group (and their insurers FM Global) had identified that production activities could be affected for a significant period of time. In the worst case, this could have a direct impact on supply to Ipsen customers i.e. healthcare providers and patients dependent on IMIL products, given that IMIL is the sole source of peptide API for the Ipsen Group.
As such it was agreed that it would be preferable to locate the proposed process vent abatement system away from the existing carbon adsorber unit and retain the carbon adsorber unit as a back - up For unit inspection (as purposes described only. in Chapter 3 Proposed Development). Consent of copyright owner required for any other use. This effectively provides a platform for 2 independent production zones at the site into the future, should that be required.
Two general locations were assessed for the new process vent abatement system and these are presented in Figure 4.1 below. The 2 options were (i) the recently acquired IDA lands to the east of the IMIL facility or (ii) the general area south of the recently completed Building 4.
It was quickly concluded that locating the proposed abatement system on the recently acquired IDA lands would be undesirable given the proximity to the nearest neighbouring residential dwellings and potential for additional inconvenience/nuisances to their occupants.
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Figure 4.1 Locations considered for new process vent abatement system
As a section of the site next to Building B4 had recently been levelled prior to the construction of Building 4, considerable advantages were identified in locating the new process vent abatement system next to Building 4 (either to the south or west of the facility). Proximity to Building B4 also allows for greater efficiency of resources as the new abatement system can be connected to existing power and water utilities.
For inspection purposes only. As part of the recentConsent Building of copyright 4 project,owner required IMIL for any undertook other use. preliminary master-planning for the development of the remainder of the IMIL site over the next 5-10 years. (It is expected to review this masterplan during 2017). The current masterplan identifies a likely requirement to extend Building 4 in future and that expansion is most likely to occur along the eastern edge of the building (thereby ruling out that area as a proposed location).
The preferred location of the new abatement system is therefore to the south of Building 4 as shown in the drawings presented in Chapter 3 Proposed Development.
4.5.3 Alternative Processes
During 2016, IMIL commissioned DPS engineering to undertake a thorough assessment of possible technology options for improved process vent abatement at the IMIL site. In accordance with the requirements of the relevant BAT guidance including principally “Best Available Techniques (Reference Document) for the Manufacture of Organic Fine Chemicals, 2008”, an extensive technology selection exercise has been completed.
IMIL’s emission are characterised by a relatively low volume (intermittent) emissions containing a fairly wide variety of chemical compounds, some of which are not ideally
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suited to a number of the available process vent abatement technologies. As such only two abatement techniques were identified by DPS as suitable for detailed evaluation. They were thermal oxidation and cryogenic condensation.
Thermal oxidation systems are suitable for almost all VOC sources and are proven to destroy VOCs and hazardous air pollutants with high levels of efficiency. (Specific consideration was given to the thermal oxidation options that incorporated flue gas treatment (including scrubbers) to achieve maximum efficiency).
It was identified however, that thermal oxidation systems are more suited to high and constant volume flows with relatively low, consistent concentrations of pollutants. The operating costs of maintaining combustion temperatures during periods of low or no VOC streams can be prohibitive.
Cryogenic condensation offers a high efficiency, compact technology more suited to the very specific nature of the IMIL emission. The abatement system allows for greater control on final concentrations which can be controlled by carefully selecting the condenser temperature. Cryogenic condensers allow for recovery of organic solvents, provided they can be separated from the condensed mixture. In terms of negatives, additional liquid nitrogen is required for operation of cryogenic systems. IMIL already have an existing onsite liquid nitrogen tank in place on the site. However, it will be necessary to install an additional liquid nitrogen storage tank.
In conclusion, based on a detailed technology assessment completed by DPS during 2016, the best available option in terms of VOC reduction performance (with ≥99.9% efficiency), capital and operational costs, and space requirements has been identified as a combination of an acid scrubber system (for ammonia removal) followed by a Cryogenic Condensation unit and a zeolite polishing filter on the outlet.
Further detail is provided in the relevant Sections of the IE licence application.
For inspection purposes only. Consent of copyright owner required for any other use.
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5.0 POPULATION AND HUMAN HEALTH
5.1 INTRODUCTION
This chapter evaluates the impacts if any, of the proposed development on population and human health as defined in the EPA Draft Advice Notes on Current Practice (in the preparation of Environmental Impact Statements), 2015. In accordance with the above Draft Advice Notes, this chapter has considered the 'existence, activities and health of people’ with respect to ‘topics which are manifested in the environment such as employment and housing areas, amenities, extended infrastructure or resource utilisation and associated emissions’. Issues examined in this section include:
• Demography • Population • Employment • Natural Resources • Landscape Amenity and Tourism • Social Infrastructure • Land Use
Further discussion of these issues follows below.
The impacts of other environmental aspects associated with the project which may be human related such as noise and vibration, traffic, visual impact and air quality are discussed in the relevant chapters of this EIAR.
5.2 METHODOLOGY
The effects of the proposed development on the population and human health are analysed in compliance with the requirement of Draft “Revised Guidelines on the Information to be contained in Environmental Impact Statements” EPA, 2015 and Draft “Advice Notes on Current Practice (in preparation of Environmental Impact For inspection purposes only. Statements)” EPA, 2015Consent. of copyright owner required for any other use.
Public bodies including the Central Statistics Office (CSO) and Fingal County Council (FCC) have been consulted to gather relevant information in relation to, employment statistics, demographic statistics and community aspects.
5.3 RECEIVING ENVIRONMENT
The proposed alterations including the new process vent abatement system and other related developments described in Chapter 3, will be completed within the IMIL site at Blanchardstown Industrial Park, Snugborough Road, Blanchardstown, Dublin 15.
The site is located on a local road off the R121 which links Ballycoolin to the N3 (Navan Rd) and Blanchardstown town centre. The immediate surrounding area is predominantly industrial and office buildings with agricultural landuses further to the east and west.
There are four cottages located directly east of the IMIL facility along Ballycoolin Road. A number of residences are also located a short distance north of the facility at St Philomenas Court. (See Figure 5.1). The nearest densely populated residential areas are located in the Westway Close area of Corduff Park approximately 460m to
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the south. Corduff Park is a large residential estate which extends to the N3 duel carriageway.
The facility is well screened from the surrounding residences due to its location with the business park (mainly screened by a number of other industrial buildings). The Institute of Technology Blanchardstown campus is located to the west with the Corduff residential area to the southwest.
The topography is generally consistent throughout the site (approximately +84 mAOD). Arterial drainage is in a southerly direction towards the Tolka River, and on a more regional scale, southwards toward the River Liffey. The closest water feature to the IMIL site is the Ballycoolen stream located approximately 250m south of the site.
5.4 CENSUS AND DEMOGRAPHICS
The most recent census of population was carried out by the CSO on the 24th April 2016 with preliminary results now available. The previous census was completed on the 10th of April 2011 and before that on 23rd April 2006. The census compiles data for the whole state as well as smaller individual areas including counties, cities, towns and electoral divisions. Taking into consideration the location of the proposed development the census information on population, age profile, employment and social class, has been analysed in relation to the Fingal Region.
POPULATION
The latest census showed that Fingal Region was the largest growing county in Ireland between the census years of 2011 and 2016 with an 8.1% population increase while the population of the State increased by only 3.7%. Blanchardstown-Mulhuddart saw moderate growth with an increase of 6.7% (see Table 5.1). Nationwide and Fingal population projections indicate this trend of high population growth is to continue into the short-term future, regardless of population patterns elsewhere in the state. For inspection purposes only. Consent of copyright owner required for any other use.
Area 2011 2016 % Change 2011-2016
State 4,588,252 4,757,976 + 3.7%
Fingal 273,991 296,214 +8.1%
Blanchardstown- 3,866 4126 +6.7% Mulhuddart Table 5.1 Population Change at State, Primary and Secondary Hinterland Level 2011-2016 (Preliminary 2016 Figures Only)
As a comparison, Table 5.2 shows that significant population growth also occurred between the census years of 2011 and 2006. Over the five-year period from 2006 to 2011 the population of the state grew by approximately 8.2%, while the population of the Fingal Region and Blanchardstown-Mulhuddart increased by approximately 14.2% and 10.4% respectively.
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Area 2006 2011 % Change 2006-2011
State 4,239,848 4,588,252 +8.2%
Fingal 239,992 273,991 +14.2%
Blanchardstown- 3,502 3,866 +10.4% Mulhuddart Table 5.2 Population Change at State, Primary and Secondary Hinterland Level 2006-2011
AGE PROFILE
The age profile of the population in the affected area is an important parameter as it provides a good insight into the potential labour force, the demand for schools, amenities and other facilities and the future housing demand.
As the results for the 2016 Census are preliminary only, details about the age profiles are not currently available. As such, Tables 5.3 and 5.4 below show the age profiles for the state and Fingal region for 2006 and 2011 respectively. This allows comparison of the changes in the population profile between the years.
Total 0-14 15-24 25-44 45-64 65+ Persons
State 21% 13% 31% 23% 12% 4,588,252
Fingal 24% 12% 37% 20% 7% 273,991 Table 5.3 Age Profile at State and Hinterland Level, 2011
Total 0-14 For15 inspection-24 purposes25 only.-44 45-64 65+ Consent of copyright owner required for any other use. Persons
State 21% 16% 33% 18% 11% 4,239,484
Fingal 22% 15% 38% 19% 6% 239,992 Table 5.4 Age Profile at State and Hinterland Level, 2006
Table 5.3 shows that the age profile of the population of the State and Fingal Region in 2011 was largely unchanged from 2006 other than in the 45-64 age group which saw a marked increase from 18% to 23% at state level during the intervening period. The cohort in that age group increased only slightly in the Fingal region during the same period. In general, these population statistics indicate a very youthful working age population in the area.
From Table 5.2 it can be seen that the percentage of people in the Fingal area within working age groups (14-64) amounted to 69% in 2011 compared to the national average of 67% at that time. In 2006 this cohort measured 72%, which indicates a slight contraction in the pool of labour force available in the area.
Whilst the significant population increased outlined above make it difficult to estimate the current population situation or future population trends, these statistics indicate
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that population in the primary and secondary hinterlands of the site will continue to rise.
EMPLOYMENT
Table 5.5 describes the employment statistics for the Fingal Region. Again, the 2016 census statistics are not currently available and therefore a comparison from the most recent complete surveys are presented. It can be seen that unemployment increased significantly in the Fingal Region and in the State, between 2006 and 2011.
2011 – Labour Force Unemployed Looking for Total in having lost or At Work first regular Labour % Unemployment given up job Force previous job
State 1,807,360 34,166 390,677 3,608,662 11.8%
Fingal 119,276 2,224 20,416 207,584 10.9%
2006 - Labour Force Unemployed Looking for Total in having lost or At Work first regular Labour % Unemployment given up job Force previous job
State 1,930,042 29,372 150,084 3,375,399 5.3%
Fingal 5.6% 120,794 2,095 7,927 187,018
Table 5.5 Employment Statistics for Vicinity of Proposed Development
Table 5.6 below shows the division of the population of Fingal into different socio- economic classes in 2006 and 2011. This categorisation indicates the type of employment that the work force in that area is employed in or is capable of being employed in. The data suggests that in terms of labour force, the Fingal area has a significant requirement for For and inspection is capablepurposes only. of supporting industries with a need for Consent of copyright owner required for any other use. professional, managerial and skilled employees.
Socio-economic group of reference 2011 2006 person Employers and managers 54,886 47,513 Higher professional 20,505 17,089 Lower professional 36,027 28,337 Non-manual 61,082 52,583 Manual skilled 19,422 20,015 Semi-skilled 18,061 15,632 Unskilled 6,752 5,956 Own account workers 11,461 9,742 Farmers 1,491 1,410 Agricultural workers 798 728 All others gainfully occupied and 43,506 40,987 unknown Total 273,991 239,992 Table 5.6 Population of Fingal by Socio-Economic Group
5.4.1 Quarterly National Household Survey
The Quarterly National household’s survey is a large-scale, nationwide survey of households in Ireland in which households are surveyed each quarter.
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It generates quarterly labour force estimates that include the official measure of employment and unemployment for the state. The results of the most recent Quarterly survey which was published on 24th May 2016 for the first quarter of 2016 are quoted below.
5.4.1.1 Main Results
In the state as a whole there were 1,976,500 people in employment and 179,500 people unemployed in Q1, 2016 totalling to a labour force of 2,156,000. This represents an increase in employment of 2.4% or 46,900 in the year to the first quarter of 2016. The annual increase at the previous quarter was 2.3% and the increase in the year to the first quarter of 2015 was 2.2%, indicating continual and exponential growth.
These figures are compared to the latest available figures for all EU-28 countries which date to Q4 2015. Over the year to Q4 2015, the employment rate in Ireland grew by 1.3% to 63.9%. The employment rate in the EU-28 in Q4 2015 was 66%.
5.4.2 Summary
From comparing the census figures for 2006 and 2011 unemployment in Ireland appeared to have grown significantly during that period. However, more recent data indicates that employment in Ireland is beginning to grow at a slow but steady rate with employment figures for the State increasing from 1,807,360 in the 2011 National census to 1,976,500 in the first Quarterly household survey of 2016. The latest figures available at the time of finalising the QNHS indicate that the seasonally adjusted unemployment rate for the EU-28 for March 2016 was 8.8% compared to the seasonally adjusted unemployment rate of 8.1% for Ireland for Q1 2016.
5.5 NATURAL RESOURCES
Natural resources and land uses in the hinterland of the proposed site have also been For inspection purposes only. considered as they mayConsent have of copyright implications owner required for for anythe other development use. of the lands.
Most land-uses to the north and west of IMIL are industrial and commercial units located in the Blanchardstown Corporate Park and the IDA Ballycoolin Business Park. Areas to the south and southwest are residential (Corduff Park and Ladyswell). The Institute of Technology Blanchardstown campus is located to the west with undeveloped agricultural land located further west.
In terms of extractive industries, there are a number of rock and gravel quarries within the Fingal area. The closest active quarry to the site is Roadstone Huntstown Quarry which is located approximately 1.6km east of the site. There is unlikely to be any negative impact in terms of natural resources as a result of the proposed development.
5.6 LANDSCAPE AMENITY &TOURISM
As mentioned above the proposed facility is located in a largely business/industrial area with high density residential housing located to the south. There are four cottages located directly east of the IMIL facility along Ballycoolin Road. A number of residences are also located a short distance north of the facility at St Philomenas Court. There is an extensive road network in the area connecting the industrial
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estates/business parks to the residential areas to the south and the N3 national road which provides connection to the wider regional area.
Tourism is not a major industry in the immediate environs of the site. Blanchardstown village and shopping centre is located c. 1.8km southwest of the site. There are also a number of nearby hotels and other accommodation (B&B’s etc.) primarily serving Dublin City tourists.
In terms of landscape amenity, the wider landscape setting is generally flat with no prominent mountain features located near the site. The primary areas of landscape amenity in the wider Dublin region are the River Liffey Valley and Phoenix Park areas.
As the existing development is located in a low-lying area designed for light industry and employment, it is considered that the impact on landscape amenity is minimal. Further discussion of impact on Landscape amenity is presented in Chapter 6 Landscape and Visual.
5.7 SOCIAL INFRASTRUCTURE
Residential Dwellings There are four cottages located directly east of the IMIL facility along Ballycoolin Road. A number of residences are also located a short distance north of the facility at St Philomenas Court. The immediate surrounding area is primarily occupied by commercial /industrial business parks most notably to the north and northeast with high density residential housing further to the south, located c.460m to the south west.
Education The third level Institute of Technology Blanchardstown campus is located c.350m to the west of the site. St Patricks Primary and Secondary school is located c.950m to the south and the Riverside Community College is located c.850m to the southwest For inspection purposes only. (ref. Figure 5.1). Consent of copyright owner required for any other use.
Health The nearest hospital to the facility is Connolly Hospital in Blanchardstown
Security There is a Garda station located on the Main Street, Blanchardstown and a fire station on St Mochtas Drive, Coolmine.
5.8 LAND USE
The proposed development is located within the IMIL site boundary which is located in an established industrial park. It will not materially alter the character and/or use of the land. Nor will it result in a severance, loss of rights of way or amenities, conflicts, or other changes likely to ultimately to alter the character and use of the surroundings. Therefore, the use of the land for the proposed development will have a negligible impact on the land use.
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5.9 IMPACT ASSESSMENT
The main potential impacts on local residences and businesses associated with the proposed development will be in relation to air quality, and noise and vibration. Potential construction impacts are noted to be particularly important. The potential impacts and mitigation measures to address them are dealt with in the corresponding chapters of this EIAR as follows:
• Chapter 10 – Noise and Vibration • Chapter 11 – Air Quality and Climate
Any potential construction impacts will be short term and IMIL are committed to ensuring the appointed contractors minimise all construction nuisances.
Operationally it is not anticipated that there will be any direct increase in the workforce and therefore it is not likely to have any notable impact on the population, housing availability of the hinterlands etc. In overall terms, output from the facility is expected to increase on an ongoing basis so this would result in some positive impacts in terms of direct and indirect employment.
5.10 MITIGATION MEASURES
The previous section has outlined the potential impacts of the proposed development on humans and related aspects such as noise and air quality. The potential impact of these aspects (both construction and operationally) and their associated mitigation measures are dealt with in the corresponding chapters of this EIAR.
Of the remaining potential impacts relating to the human environment only those aspects concerning Health and Safety require mitigation measures. These are outlined in the following sections.
5.10.1 Operational Phase Health and Safety For inspection purposes only. Consent of copyright owner required for any other use. The operation of the existing facility is carried out in strict accordance with all Irish and European regulations governing safety in the work place with specific regard to the regulations implemented under the Safety, Health & Welfare at Work Act, 2005. This remain as existing following the upgrades.
Full relevant training in the operating procedures for equipment and processes are provided to each employee. In the case of a fire the emergency response procedure will be activated and necessary personnel have been fully trained to deal with such emergencies.
5.11 RESIDUAL IMPACTS
It is expected that the proposed development will have a neutral long term impact on the immediate hinterland. The facility will have a positive long term impact through continued employment and the associated economic and social benefits.
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5.12 CONCLUSIONS
There will be no significant adverse impact on the human environment from the proposed upgrades at the IMIL Facility. It will have a positive impact in terms of continuing to provide direct and indirect employment opportunities for both people already living in the area and people living in a wider geographical area.
There will be no significant adverse impacts with respect to socio-economic factors, land-use, or the amenity value and tourism potential of the area. All necessary mitigation measures will be put in place to ensure the health and safety of all site personnel.
All other environmental aspects relating to the human environment which could have an adverse impact on the local population such as noise, air & water and visual impacts both operationally and perhaps more importantly construction impacts are addressed in the relevant chapters of this EIA.
For inspection purposes only. Consent of copyright owner required for any other use.
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EPA Export 21-06-2017:03:24:53 Legend Existing licence boundary ± Extent of site applicable to planning application Extent of land under ownership of the applicant (proposed licence boundary) School Residential Development
BALLYCOOLEN
Ballycoolin Road
SNUGBOROUGH
For inspection purposes only. Consent of copyright owner required for any other use.
Approximate scale only 0km 0.5km Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community Note: Drawing is for illustrative purposes only; Do not scale
CLIENT: PROJECT: DRAWN: CHECKED: APPROVED: APP'D DATE: Environmental Impact E.N Copyright AWN CONSULTING LIMITED Ipsen Manufacturing Assessment Report 2017 J.Mg E.N 18/04/17 All rights reserved. No part of this work Ireland may be modified or reproduced or copied No. of SIZE: SCALE: in any form or by means - graphic, electronic AWN Consulting Ltd Ipsen Manufacturing Sheets DRAWING TITLE: Figure 5.1 or mechanical, including photcopying, The Tecpro Building, Ireland, Blanchardstown, 1 A4 1:20,000 recording, taping or information retrieval Clonshaugh Business & Technology Park Dublin15 system, or used for any purpose other than Dublin 17, Sensitive Receptors SHEET its designated purpose, without the written Tel: + 353 1 847 4220 REVISION DESCRIPTION REV ~consulting PROJECT Ref: 16_9048 1 permission of AWN Consulting Limited Fax: + 353 1 847 4257 EPA Export 21-06-2017:03:24:53 LANDSCAPE AND VISUAL ASSESSMENT AWN Consulting Limited ______
6.0 LANDSCAPE AND VISUAL ASSESSMENT
6.1 INTRODUCTION
This chapter comprises an assessment of the likely landscape and visual impacts of the proposed new process vent abatement system to be located to the rear of the existing IMIL facility which is located at Blanchardstown Industrial Park, Snugborough Road, Blanchardstown, Dublin 15.
The assessment was carried out on behalf of AWN Consulting by Brady Shipman Martin landscape, planning and environmental consultants.
6.2 METHODOLOGY
The following guidelines have been considered and consulted for the purposes of the assessment: • The Planning and Development Act, as amended. • 2014 EIA Directive (2014/52/EU) • Environmental Protection Agency (EPA) (2015), Draft Guidelines on the information to be contained in Environmental Impact Statements. • Environmental Protection Agency (EPA) (2015), Draft Advice Notes on Current Practice (in preparation of Environmental Impact Statements) • Environmental Protection Agency (EPA) (2002), Guidelines on the information to be contained in Environmental Impact Statements • Environmental Protection Agency (EPA) (2003), Advice Notes on Current Practice (in preparation of Environmental Impact Statements) • Fingal County Development Plan, 2017-2023
Photomontages showing the ‘as existing’ and the ‘as proposed’ view have also been prepared and these are included with this chapter.
For inspection purposes only. Consent of copyright owner required for any other use. 6.3 EXISTING ENVIRONMENT
The existing environment describes the baseline conditions including current onsite operations. Describes the context into which the Proposed Development will fit.
6.3.1 Site Context
The IMIL facility (refer Plates 6.1 & 6.2) is located within the northwest quadrant of Blanchardstown Industrial Park, Snugborough Road, Blanchardstown, Dublin 15. While the facility is located close to the roundabout junction between Blanchardstown Road North and Ballycoolin Road, access to the site is via the central tree-lined access road and the main business and technology park entrance off Snugborough Road c.800m to the east.
IMIL operates from an existing established facility located at Blanchardstown Industrial Park, Snugborough Road, Blanchardstown, Dublin 15. The existing campus comprises 4 main buildings.
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Figure 6.1 Site Context – Lands in the ownership of IMIL outlined in blue. Site for Proposed Development outlined in red. (Aerial Source www.google.ie)
The established IMIL facility is surrounded by other similarly established industrial developments, including Designer Group; Luzern Solutions; Safety Solutions etc. In addition, the business and technology park is set within the context of a wide variety of other business and industrial parks, including Blanchardstown Corporate Park to the northwest; the IDA Dublin (Ballycoolin) Business and Technology Park to the northeast and IDA College Business and Technology Park, which also includes the
Institute of Technology Blanchardstown, For inspection purposes to the only. west. Consent of copyright owner required for any other use.
Residential estates at Sheephill and Westway lie south of IDA Blanchardstown (Snugborough) Business and Technology Park – c.500m south of the IMIL Facility. Five residential cottages are located along Ballycoolin Road c.40 to 90m east of the IMIL Facility (refer Plate 6.3). The cottages are screened from the facility by a broad belt of mature trees on the eastern boundary of the IMIL Facility. A further residential development – St. Philomena’s Court, is located immediately north of Ballycoolin Road and north of the IMIL Facility. The estate is screened from the site by mature planting along the south side of Ballycoolin Road.
An ESB sub-station is located east of the cottages – c.140m east of IMIL – and a 110kV overhead transmission line runs east-west through the business and technology park c.100m south of the IMIL site (refer to Plate 6.4).
The site itself is a relatively level area located to the east of a mature tree-line comprising tall poplar trees and evergreen conifers (refer to Plate 6.2). Further mature tree-lines defined the eastern boundary of the IMIL Facility.
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Plate 6.1: View north towards Existing IMIL Facility
For inspection purposes only. Consent of copyright owner required for any other use.
Plate 6.2: View east towards rear of existing IMIL Facility (Site for proposed development is behind line of mature trees on right-hand side of image.)
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Plate 6.3: View north (from lands south of the IMIL Facility. The IMIL Facility is visible in background of the image. Proposed development to be sited behind evergreen tree-line in centre-right of image
For inspection purposes only. Consent of copyright owner required for any other use.
Plate 6.4: View southwest from Ballycoolin Road showing westernmost cottage with tree-lined boundary of the IMIL Facility to the rear.
6.3.2 Landscape Planning
The site, together with much of its wider surrounds are Zoned HT: High Technology in the Fingal County Development Plan, with the objective to… Provide for office, research and development and high technology/high technology manufacturing type employment in a high quality built and landscaped environment. Refer Figure 6.2.
Much of the surrounding lands are also Zoned HT: High Technology. Other zonings in the area include GE – General Employment; RS: Residential; CI: Community Infrastructure; and OS: Open Space.
There are no specific amenity objectives on the site. Likewise there are no protected trees, woodlands or hedgerows, or protected views pertaining to the site.
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Figure 6.2: Landscape Planning Context – Annotated Extract from Sheet 12 Blanchardstown North: Fingal County Development Plan 2017-2023. IMIL lands outlined in blue.
6.3.3 Landscape and Visual Significance and Sensitivity For inspection purposes only. Consent of copyright owner required for any other use. The site is not considered to be significant or sensitive from a landscape and visual aspect. The IMIL lands comprise part of an existing business park facility that is located within an established business and technology park. The lands are appropriately zoned and residential and other amenity is either located at distance from the site or the site is well-screened from such areas.
6.4 CHARACTERISTICS OF THE PROPOSED DEVELOPMENT & POTENTIAL IMPACTS
IMIL proposes the construction of a new process vent abatement system. The plant will be provided to the rear (east) of the existing buildings on site. Construction work is anticipated to commence in Q3 of 2017 with a c.6 month construction phase.
6.5 POTENTIAL IMPACTS
6.5.1 Construction
The construction stage has the potential for impacts associated with typical construction activity, including site disturbance, excavation working, emergence of new structures building activity, etc.
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However, the construction site is accessible via the business park and well-screened both by the existing facility and by mature tree-lines/plantings on the southern, eastern and northern boundaries. Coupled with the short-term nature of the construction period (c.6 month) and relatively small scale of construction proposed the potential for significant landscape or visual impact is considered to be minimal.
6.5.2 Operational
The operational stage has the potential for impacts arising from the visual presence of a new structures.
However, the proposed development is located to the rear of the existing facility, and is well screened from surrounding tree-lines. As such, the potential for significant landscape or visual impact is considered to be negligible.
6.6 REMEDIAL / MITIGATION MEASURES & PROPOSED MONITORING
The potential for construction and operation impact is minimal and therefore, specific mitigation measures are not required to reduce or remediate landscape or visual impact. However, mitigation measures are proposed so as to ensure that such impact does not arise indirectly as follows:
• Retention of existing tree-lined / planted boundaries. Such plantings shall be protected (in accordance with the provisions of BS 5837) during construction stage. • Finish and treatment of proposed structures to match / reflect that of the existing character of surrounding buildings and structures.
6.7 PREDICTED IMPACT OF THE DEVELOPMENT
The proposed development will not be visible. It will be screened from the north and For inspection purposes only. west by the existing facilityConsent byof copyright existing owner required topography for any other and use. mature tree-lines/plantings. The development will also be screened from the east, south and west by existing topography and mature tree-lines/plantings located on the site boundaries. In addition, the context of the surrounds is of established industrial lands and uses where similar development is already well-established.
Once constructed the proposed development will tie-in with the existing development and will not give rise to visual attention. The well-screened, integrated effect of the site and the proposed development is illustrated in the 2 Photomontages (see Figure 6.1 for locations) – one taken from within the business park itself and a second from Ballycoolin Road in the vicinity of the residential cottages. In both instances the development has no visible presence or impact on the view.
See Figures 6.3a and 6.3b for before and after view from within industrial estate. The proposed development is not visible behind the existing buildings and mature tree-line. The location of the proposed development has been outlined in red line for ease visual referencing.
See Figures 6.4a and 6.4b for before and after view from Ballycoolin Road. The proposed development is not visible and its location has been outlined in red line for ease visual referencing.
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Likewise, the proposed development has no impacts on related amenities or on trees or woodlands, views or scenic views.
Given this context, and the appropriate zoning pertaining to the lands, it is assessed that the proposed development will have a neutral effect and will not give rise to any adverse landscape or visual impacts either during construction or operation or in the short, medium or longer-term.
6.7.1 Assessment of Cumulative Impact with Neighbouring Facilities
The proposed development is fully in-keeping both with the existing established character of the site and also with the established prevailing character of its wider context.
6.8 INTERACTIONS WITH OTHER CHAPTERS
Landscape and visual aspects have particular interactions most notably with Population & Human Health, Biodiversity, Soils and Water. However, given that little or no landscape or visual impact will arise it is likewise considered that there is little potential for any appreciable interaction between these aspects.
6.9 CONCLUSIONS
The proposed development will not be visible from outside of the site. It will be well- screened from the west and north by the existing facility and from the east, south and west by existing topography and mature tree-lines/plantings.
The proposed development is fully in-keeping both with the existing established character of the site and also with the established prevailing character of its wider context
For inspection purposes only. Specific mitigation measuresConsent of are copyright not owner required required for toany otherreduce use. or remediate landscape or visual impact. However, good practice measures are proposed to protect existing trees and to tie-in the finish of the new structures with that of the existing.
The proposed development will have a neutral effect and will not give rise to any adverse landscape or visual impacts either during construction or operation or in the short, medium or longer-term.
6.10 REFERENCES
Environmental Protection Agency (2002) Guidelines on the Information to be contained in Environmental Impact Statements.
Environmental Protection Agency (2003) Advice Notes on Current Practice (on the preparation of Environmental Impact Statements.
Environmental Protection Agency (2015) Draft Guidelines on the Information to be contained in Environmental Impact Statements.
Environmental Protection Agency (2015) Draft Advice Notes on Current Practice (on the preparation of Environmental Impact Statements.
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LI/IEMA: Guidelines for Landscape and Visual Impact Assessment, Third Edition 2013.
Fingal County Council (2017) Fingal County Development Plan 2017-2023.
For inspection purposes only. Consent of copyright owner required for any other use.
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For inspection purposes only. Consent of copyright owner required for any other use.
Figure 6.3a Photomontage No. 1: As Existing View
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For inspection purposes only. Consent of copyright owner required for any other use.
Figure 6.3b Photomontage No. 1: As Proposed View. Proposed development (outlined in red) is not visible behind tree-line.
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For inspection purposes only. Consent of copyright owner required for any other use.
Figure 6.4a: Photomontage No. 2: As Existing View
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For inspection purposes only. Consent of copyright owner required for any other use.
Figure 6.4b: Photomontage No. 2: As Proposed View. . Proposed development (outlined in red) is not visible behind tree-line on boundary of IMIL Facility.
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7.0 TRAFFIC AND TRANSPORTATION
7.1 INTRODUCTION
In 2015, AWN Consulting Limited appointed Roughan & O’Donovan Consulting Engineers to prepare a Traffic and Transportation assessment for the EIS that accompanied an application for Building B4 at the existing IMIL facility located at the Blanchardstown Industrial Park, Blanchardstown, Dublin 15. This development was submitted for planning in August and received planning permission in November 2015 (REF: FW15A/0115). Construction is now complete.
As the proposed development currently under consideration will generate no additional work force it is considered that the proposal will result in no additional impact above and beyond the Building 4 development. Construction of Building 4 is now complete. As such the information and conclusions from the Building B4 Traffic and Transportation assessment have been used to prepare this revised traffic study.
This section of the EIAR addresses the existing transportation environment in the vicinity of the proposed development, the traffic generation, parking and public transportation requirements of the developments and the transportation impact on the surrounding road network.
The current workforce at the facility is c.122 personnel. No additional staffing is likely to be required post approval. A peak construction workforce of less than 20 personnel is anticipated.
7.2 METHODOLOGY
This chapter has been prepared in cognisance of the following: • Fingal County Council Development Plan 2011 -2017; • The Chartered Institution of Highways and Transportation (CIHT) Guidelines for Traffic Impact Assessment; and For inspection purposes only. • The National Roads ConsentAuthority of copyright (NRA) owner Trafficrequired for andany other Transport use. Assessment Guidelines 2007.
7.3 EXISTING ENVIRONMENT
7.3.1 Site Description and Location
The IMIL facility is located in the north west of the Blanchardstown Industrial Park. Blanchardstown Industrial Park is border by Blanchardstown Road North (R121) to the west, Ballycoolin Road to the north, Snugborough Road (R843) to the east and residential properties to the south. The Industrial Park is accessed via Snugborough Road which is the only entrance/exit point to the industrial park. A single internal access road services all of the properties within the industrial park. Footpaths are provided along the access roads within the Industrial Estate.
The IMIL facility is located on a 5.6ha site (3.9ha existing licenced site plus 1.7ha of additional acquired lands) and consists of four production and office buildings, internal access roads, numerous storage and plant buildings and 148 car park spaces. The site is bordered by the Ballycoolin Road to the north.
The company makes highly specialised pharmaceuticals with production levels currently at around 70-80kg per year. Deliveries to and from the site occur once to
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twice a month and are connected to raw materials and solvents (and associated waste streams) rather than outgoing products. The facility has gone through expansion in the recent past with three additional buildings constructed in 2009, 2011 and 2016.
A number of industrial and business parks are located to the north of the site, with agricultural fields to the west and east between Snugborough Road and M50. Densely populate areas of Corduff, Mulhddart, Blanchardstown, Clonsilla and Castleknock are located to the south.
7.3.2 Existing Road Network
Blanchardstown Industrial Park is, from a transportation point of view, strategically located on the North West fringe of the Greater Dublin Area, approximately 12km North West of Dublin City Centre and 3km from Blanchardstown Village. The Industrial Park is accessed via Snugborough Road (R843), which is connected to Ballycoolin Road (R121) to the north east and N3 to the south west. Snugborough Road is a continuation of the Ongar Distributor Road to the south west.
The proposed site is located approximately 2km north east of the N3 and approximately 4km to the north west of the M50. These routes provide access to the major road network routes throughout Dublin and in the wider context Ireland.
Snugborough Road is 13.5m wide two-way single carriageway with dedicated bus lanes, cycle and pedestrian facilities in both directions. Snugborough Road links Ballycoolin Road to the north and the N3 and Blanchardstown area to the south.
7.3.3 Existing Public Transport Network
Dublin Bus stops are located adjacent to the entrance to Blanchardstown Industrial Park on Snugborough Road. These stops are serviced by four routes, the 17A, 38, 38B and 236 with dedicated bus lanes in both directions along Snugborough Road. The routes of these bus services are as follows: For inspection purposes only. Consent of copyright owner required for any other use. • 17A: Kilbarrack to Blanchardstown; • 38/38A: Damastown to Burlington Road; and • 236: Blanchardstown to Damastown.
The 38 and 38A routes utilises the QBC for much of the route into the city centre.
In addition, Dublin Bus routes, 40D and 220, service Ballycoolin Road to the north of Blanchardstown Industrial Park and have the following routes:
• 40D: Tyrrelstown to Parnell Street; and • 220: Ballymun to Lady’s Well Road.
An Irish Rail station, the Navan Road Parkway, is located on Navan Road approximately 6km to the south east of the proposed site. The station is serviced by the Dublin Pearse to Maynooth/Longford route and Dublin Docklands to M3 Parkway. This station is also serviced by the number 38/38A Dublin Bus route which travels along Snugborough Road.
7.3.4 Existing Traffic Conditions
A detailed survey of existing traffic data information was undertaken in 2008 as part of a planning application to Fingal County Council for the proposed National Sports
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Campus Development (Planning Reference No. FW91/0061). This survey was undertaken by RPS Consulting Engineers and information from this survey will form the basis of the traffic assessment in this report.
Due to the relatively modest increase in traffic volumes generated by the proposed development during the operational phase no supplementary or updated traffic survey was considered necessary to inform this EIAR. The 2008 traffic data available will be utilised for the traffic assessment of the proposed development.
Traffic surveys were undertaken on Snugborough Road for a ten day period between the 5th and 15th September 2008. The AM and PM peak hours on Snugborough Road were identified as 8:00 – 9:00 and 17:00 – 18:00 respectively, and are presented below.
Figure 7.1 AM Peak hour turing movement at Blanchardstown Industrial Park (2008)
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Figure 7.2 PM Peak hour turing movement at Blanchardstown Industrial Park (2008)
To estimate traffic flows for the present day (2015) it was considered appropriate to apply the National Roads Authority (NRA) Traffic Growth Factors to the available traffic data. Growth factors provided in the NRA Project Appraisal Guidelines (NRA PAG) for the period 2006-2025 in Fingal for light vehicles and heavy good vehicles
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are 1.005% and 1.004% per annum respectively. These growth factors were applied to the available traffic data and are present below.
Figure 7.3 AM Peak hour turing movement at Blanchardstown Industrial Park (2015)
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Figure 7.4 PM Peak hour turing movement at Blanchardstown Industrial Park (2015)
As shown above, there is an relatively even split of light vehicle traffic travelling into the Blanchardstown Industrial Park in the AM peak hour, with a higher number of HGV traffic coming from the direction of the N3. In the PM peak hour, 39% of light vehicles travel south and the remaining 61% travelling north. The volume of HGV traffic travelling north and south in the PM peak hour is relatively evenly distributed.
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7.4 CHARACTERISTICS OF THE PROPOSED DEVELOPMENT & POTENTIAL IMPACTS
The proposed development primarily entails the construction and installation of a new process vent abatement system and associated infrastructure.
Limited construction is proposed as the majority of the component parts of the abatement system will be pre-fabricated off site. Limited construction of supporting infrastructure (pipework connections etc.). will be required. A small construction workforce of less than 20 is anticipated during the c.6 month construction and commissioning period.
No additions/amendments to roads or access arrangements are anticipated.
7.4.1 Construction
As previously stated, a peak construction workforce of approximately 20 personnel is envisaged. The duration of the construction phase is predicted to be in the region of 6 months.
The primary access point during the construction phase is likely to be via Snugborough Road and Blanchardstown Industrial Park internal distributor road. A Construction Management Plan will be prepared by the contractor when appointed which will require construction traffic to be managed to minimise impact on peak traffic conditions on the surrounding road network.
The majority of the development will be prefabricated off-site and assembled onsite by personnel. As such, the number deliveries will be minimal.
The most significant traffic impact during the construction phase is likely to be as a result of earthworks operations and the arrival and departure of construction personnel. Transportation of earthworks material will be ongoing during working hours and restricted to outside peak traffic periods. It is envisaged that the arrival and For inspection purposes only. departure of constructionConsent personnel of copyright will owner peak required between for any other use. 7:00 – 8:00 and 17:00 – 18:00.
7.4.2 Operational
The operational phase of the development will generate no additional personnel travelling to and from the development. Additional raw materials required for the process vent abatement system will be incorporated into existing deliveries and associated waste output will increase pro rata.
7.5 REMEDIAL / MITIGATION MEASURES & PROPOSED MONITORING
When possible the delivery of construction materials will be scheduled to arrive to the proposed site outside of peak traffic flow periods. It is not considered that any specific monitoring of the traffic conditions is required.
7.6 PREDICTED IMPACT OF THE DEVELOPMENT
7.6.1 Construction Phase Impact
A short term increase in traffic volumes will be experienced along roads and junctions in the vicinity of the proposed development during the construction phase. The
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increase in traffic volumes at peak hours will primarily be due to construction personnel arriving and departing from the development. Delivery of construction materials will be managed and scheduled to coincide with off-peak traffic periods and be restricted to utilising the N3 and Snugborough Road.
In general, construction activities commence at 08:00 and it is likely that construction personnel will arrive to the development between 07:00 and 08:00, outside of AM peak traffic conditions on the surrounding road network. It is envisaged that the departure of construction personnel will coincide with PM peak traffic volumes on the surrounding road network. Assuming construction personnel traffic will follow the existing traffic patterns, and taking average vehicle occupancy to be 1.5 people per vehicle, the junction will experience a c.0.5% increase in traffic volumes in the PM peak hour.
7.6.2 Operational Phase Impact
The proposed development of the facility will generate no additional permanent employees or deliveries.
There will be no impact on traffic volumes.
7.6.3 Assessment of Cumulative Impact with Neighbouring Development
The Fingal County Council planning register (online version) was consulted in November 2016 to determine if any significant developments are planned in the vicinity of the site. A number of pharmaceutical companies including Alexion Pharmaceuticals Inc., Montjeu Ltd, and Bristol-Myers Squibb are currently developing expanding their pharmaceutical facilities in Mulhuddart and Cruiserath. It is not envisaged that there will be any significant interaction in traffic volumes between these developments.
The proposed development is located in the vicinity of the National Aquatic Centre and National Sports Campus Development to the east. At the time of writing it would For inspection purposes only. appear that the NationalConsent Sports of copyright Campus owner requiredDevelopment for any other use. is now nearing completion and it is not envisaged that there will be any construction programme crossover between the developments.
There is likely to be a minimal short term increase in traffic volumes during the construction phase of the development. However, due to the adequacy of the local road network it is not envisaged that this will cause any major congestion in the area.
Due to the modest increase in traffic volumes during the operational phase there is not envisaged to be any noticeable change to existing traffic volumes on the surrounding road network.
7.7 INTERACTIONS WITH OTHER CHAPTERS
Interactions of the various Chapters are described in Chapter 16 of this EIAR.
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7.8 CONCLUSIONS
7.8.1 Construction Phase
The impact of construction traffic on the surrounding road network will be minor and short term.
7.8.2 Operational Phase
Traffic volumes generated during the operational phase are expected to be negligible. The impact on the surrounding road network will be neutral and imperceptible in the long term.
7.9 REFERENCES
NRA Project Appraisal Guidelines (January 2011) – Unit 5.5 Link-based Traffic Growth Forecasting.
For inspection purposes only. Consent of copyright owner required for any other use.
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8.0 MATERIAL ASSETS
8.1 INTRODUCTION
This chapter evaluates the impacts, if any, which the development has had or will have on Material Assets as defined in the EPA ‘Advice Notes on Current Practice (in the preparation of Environmental Impact Statements’ (Draft September 2015).
Material Assets are defined in the EPA Draft Advise Notes (September 2015) as ‘Resources that are valued and that are intrinsic to specific places. They may be either human or natural in origin’.
The assessment of cultural heritage is discussed under Chapter 9 Archaeology and Cultural Heritage therefore this Chapter evaluates the economic assets only. Economic assets have been addressed to some extent as part of Chapter 5 Population and Human Health however additional detail will be discussed as part of this chapter under the following headings;
• Ownership and Access • Local Settlement • Electricity Supply • Transport • Water Supply and Usage • Waste Management • Agriculture • Tourism • Natural Resources
8.2 OWNERSHIP AND ACCESS
The subject site and area of application is owned by Ipsen Manufacturing Ireland
(IMIL) who have operated For at inspection the purposes site for only. over 25 years. IMIL is part of the Ipsen Consent of copyright owner required for any other use. Group which is a global speciality driven pharmaceutical company. The current proposal is the installation of a new process vent abatement system and associated ancillary development.
As part of the recently completed Building 4 project, an additional 1.7 ha parcel of IDA lands to the south east and north west of the existing IMIL site was acquired during 2015. The total landholding is now 5.6ha.
The site is located just off the Ballycoolin Road which links Ballycoolin to the N3 (Navan Rd) and Blanchardstown town centre. Access to the site is from the Snugborough Road (R843 which connects IMIL to the N3 and Blanchardstown. The N3 is the main regional access road which provides access from Dublin city and Co. Meath. There is good visibility on approach to both access points as detailed in Chapter 7 Traffic & Transportation.
8.3 LOCAL SETTLEMENT
There are four cottages located directly beside the IMIL facility with a small number of residences also located within a short distance north of the facility at St Philomenas Court. The immediate surrounding area is predominantly industrial and
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office buildings with agricultural land-uses further to the east and west. The Institute of Technology campus is located directly to the west with the more densely populated Corduff residential area to the southwest. Further details on the nature of the local settlements and their inhabitants are provided in Chapter 5 Population and Human Health.
8.4 ELECTRICITY SUPPLY
The facility is currently supplied with mains power via a 10kV supply from ESB fed through a 1600 KVA stepdown transformer. Current usage is of the order of 358 MWH per month (2016 data).
The new process vent abatement system will require connection to the existing supply but no significant increase in overall power requirements (c. 3.5% increase required). (A new local electrical and instrument installation will be required including a new distribution board and fixed power supply).
8.5 TRANSPORT
Further details regarding the road network around the subject site are presented in Chapter 7 Traffic & Transportation.
8.6 WATER SUPPLY AND USAGE
The facility is supplied with public mains water. Monthly usage during 2016 was approximately 912m3 on average. The proposed new process vent abatement system will result in a small increase in water use at the site (c. 1m³ of water per day of operation).
8.7 WASTE MANAGEMENT For inspection purposes only. Consent of copyright owner required for any other use.
Chapter 15 of the EIAR describes the procedures for the management of wastes at the facility, including the management of hazardous wastes, during both the construction and operational phases. The process carried out at the facility ensures that wastes generated are disposed safely and recovered and recycled where possible.
In terms of waste water, IMIL have liaised with Irish Water (IW) in advance of this application with a view to seeking approval for an increase in the permitted volume of waste water discharged daily. It is proposed to increase the licenced discharge limit from 40m3/day to 80m3/day. This will ensure the site has adequate headroom for expected increases in discharges as production at the facility increases over the coming years.
IW have confirmed that they are agreeable in principle to the increase (subject to conditions and due consideration of the content of the IE application).
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8.8 AGRICULTURE
The facility is located within a primarily industrial and commercial area. The site is located within an IDA business park which neighbours a number of other industrial estates to the north and northeast. Lands to the south are predominantly residential.
Agricultural undeveloped lands (crops) are located c.650m to the northwest. These lands are currently zoned for office and high technology manufacturing, while c.700m southeast further lands are currently zoned for open space and recreational amenities.
8.9 TOURISM
The site is located in an urban/industrial area and as such tourism is not a major industry in the immediate environs of the site. Tourism is discussed under Chapter 5 Population and Human Health.
8.10 NATURAL RESOURCES
The process carried out at the IMIL facility has been refined over the past 25+ years and this ensures maximum efficiency of raw materials used. Any wastes generated are disposed safely and recovered and recycled where possible.
Limited construction is required to complete the process vent abatement system. Most of the system will come on pre-fabricated skids. Ancillary construction works will be required to connect the system to the existing IMIL facility infrastructure.
The process vent abatement facility itself will not have a significant impact on natural resources. The primary additional raw material required is liquid nitrogen (estimated usage of 36kg/hr when operational). Liquid Nitrogen is already in use at the site however an additional tank will be required to cater for the increased usage. This will For inspection purposes only. be located beside theConsent process of copyright vent owner abatement required for any otherplant. use.
Once operational, no significant increase in power or water usage is anticipated.
8.11 REMEDIAL AND MITIGATION MEASURES
IMIL have undertaken the manufacture of pharmaceutical products on site for 25+ years and it is considered that it has had and will continue to have a positive impact on the economic assets in the area particularly in relation to employment.
Potential mitigation measures relating to each of the material assets described above are presented within the individual specialist chapters of this EIAR.
There is no requirement for remedial measures to be carried out in relation to material assets described above.
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8.12 CUMULATIVE IMPACTS
The surrounding Blanchardstown and Cruiserath Road area is currently experiencing relatively high levels of industrial development and some local utility infrastructure is likely to be under pressure in the short to medium term.
The development and operation of the proposed process vent abatement system requires minimal additional power, water and other utility supplies.
In summary, the proposed development is considered to pose limited potential for significant cumulative impacts.
For inspection purposes only. Consent of copyright owner required for any other use.
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