responses to request for further information - drehid mbt facility€¦ · 2012, in relation to the...

Responses to Request for Further Information from An Bord Pleanála

ABP Reference: PL09.PA0027

TOBIN CONSULTING ENGINEERS

Template rep 003 DCO 0084

REPORT

PROJECT: Drehid MBT Facility

CLIENT: Bord na Móna Plc.

COMPANY: TOBIN Consulting Engineers Block 10-4 Blanchardstown Corporate Park Dublin 15

www.tobin.ie

6301 - Responses to Request for Further Information from An Bord Pleanála - ABP Reference: PL09.PA0027

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DOCUMENT AMENDMENT RECORD

Client: Bord na Móna Plc. Project: Drehid MBT Facility Title: Responses to Request for Further Information from An Bord Pleanála (ABP Reference:

PL09.PA0027)

PROJECT NUMBER: 6301 DOCUMENT REF: 6301-04-01

Rev A Response to RFI Tobin 04/10/12 ST 04/10/12 DG 04/10/12

Revision Description & Rationale

Originated Date Checked Date Authorised Date

TOBIN Consulting Engineers


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TABLE OF CONTENTS

1 INTRODUCTION ....................................................................................... 1

2 RESPONSES TO REQUEST FOR FURTHER INFORMATION ............... 1

2.1 ITEM 1 ....................................................................................................................... 1 2.1.1 An Bord Pleanála text - Item 1 ..................................................................................... 1

2.1.2 Response to An Bord Pleanála - Item 1 ....................................................................... 1





2.4 ITEM 4 ..................................................................................................................... 10 2.4.1 An Bord Pleanála text - Item 4 ................................................................................... 10

2.4.2 Response to An Bord Pleanála - Item 4 ..................................................................... 10








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1 INTRODUCTION Further to a request for Further Information received from An Bord Pleanála, dated September 13th 2012, in relation to the proposed development of a Mechanical Biological Treatment (MBT) Facility at Coolcarrigan, Drummond and Kilkeaskin, Carbury, Co. Kildare, this submission has been prepared for the Board’s consideration. This document provides responses to each of the requested Further Information items. For the reader’s convenience, the An Bord Pleanála text for each of the Further Information items has been reproduced and included ahead of each response within this document. While this opportunity to provide Further Information in respect of the proposed MBT Facility is welcomed, the applicant would expect to be afforded an opportunity to comment on aspects of the third party submissions and the Kildare County Council Manager’s Report, received by An Bord Pleanála, prior to the decision of An Bord Pleanála on the Planning Application for the proposed development. 2 RESPONSES TO REQUEST FOR FURTHER INFORMATION 2.1 ITEM 1 2.1.1 An Bord Pleanála text - Item 1 The applicant is requested to provide a more detailed overview of abstraction of water proposed for the proposed development. It is indicated that annually 1,463 cubic metres of water will be abstracted for potable water. It is necessary to give greater clarity in relation to process water requirements where it is indicated that in Tables 2-4 and 2-5 of Chapter 2 of the Environmental Impact Statement (EIS) that an annual water usage of between 11,462 cubic metres and 14,097 cubic metres will be required depending on whether configuration A or B as the operating process. The source of this water should be clearly indicated and, in particular, if abstracted water is or will be used to meet the process water requirements. 2.1.2 Response to An Bord Pleanála - Item 1 As detailed in Section 2.2.1.18 of the EIS (Volume II), potable water supply for the site will be from an on site borehole. As detailed in Section 2.2.1.18, it is proposed to pump water from this borehole to the site infrastructure, via a water treatment plant, which will treat the water to remove iron, manganese and ammonia to acceptable limits. It is estimated that there will be an annual requirement for some 1,463m3 of water to be abstracted from this borehole for use as potable water (See Table 2-4 and Table 2-5 of the EIS (Volume II)). In relation to MBT process water requirements, Section 5.3 of the Engineering Services Report (Appendix 2.2 of the EIS (Volume IV)) states: “The proposed MBT Facility will have a requirement for fresh water. Fresh water requirements will be met by means of surface water within the attenuation ponds (No. 1 & 2) and the on site borehole”. “Fresh water will be required in the proposed MBT Facility for the following process activities:

• wash down and cleaning activities within the MBT facility buildings • irrigation of the biofilter media in order to maintain appropriate humidity levels and thereby

optimum odour removal efficacy • replenishing and refreshing of water levels in the acid scrubbers • replenishing and refreshing of water levels in the air humidifiers • maintaining of minimum percolate levels in the fermentation tanks (in the case of Configuration

B (MBT with Dry Anaerobic Digestion and Composting))”


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In accordance with Table 5.1 of the aforementioned Engineering Services Report:

• Configuration A (MBT with Composting) will have a fresh water requirement of 31.4m3 per day (which equates to approximately 11,462 cubic metres per annum)

• Configuration B (MBT with Dry Anaerobic Digestion and Composting) will have a fresh water requirement of 38.7m3 per day (which equates to approximately 14,097 cubic metres per annum)

As noted in Appendix 1 of the Engineering Services Report (Indicative Water Flow Diagrams), the on-site borehole is only proposed to act as a potential top-up source for fresh water to meet MBT process requirements. An overview of process water availability from the attenuation ponds is provided below to give greater clarity in relation to process water requirements and to demonstrate the potential of the borehole to provide for MBT process water requirements, but also to highlight the unlikely requirement for the use of the borehole for MBT process water supply. The minimum volume (volume retained below the outlet) of the relevant attenuation ponds (No.1 and No.2 – please refer to Figure 2.2 of Volume II of the EIS) is 5,668m3. A minimum of 1,800m3 shall be retained for fire fighting requirements leaving 3,868m3 available for the supply of water to the MBT process assuming no rainfall. Based on the process water requirement for Configuration B which has a higher water requirement, a volume of 38.7m3 is required each day to serve the MBT process. On this basis, it would take approximately 91 days (when an allowance is made for evaporation at the attenuation ponds) or approximately 3 months of no rainfall before the available water in the attenuation ponds would be fully exhausted. The longest period of dry weather (<0.2 mm/day) on record in Ireland is 56 days between 16th July and 9th September 1976 (Brogan and Cunnane, 20051). It is therefore highly unlikely that the available water in the attenuation ponds will ever be fully exhausted.

However, in the highly unlikely event that the attenuation ponds were fully drawn down, the on site borehole has the capacity to provide adequate water to the MBT process. As reported in Section 5.3.5 of the EIS (Volume II), a 72 hour pump test of borehole GW6 was carried out in 2003 as part of previous hydrogeological investigations at the Bord na Móna landholding to determine the characteristics of the underlying aquifer. The peak pump rate measured during the test was 56 m3/day with an average of 48.5 m3/day (over the 72 hour period). While the borehole pump test conducted at the Bord na Móna landholding indicated a relatively low permeability of the underlying aquifer, this aquifer is capable of supplying a minimum yield of 48.5 m3/day based on GW6. Previous borehole pump testing, aquifer category and aquifer characteristics confirm that the combined volumetric requirement for potable water supply (4.69 m3/day) and MBT process water top-up (38.7 m3/day – in the case of Configuration B) could be satisfied by a borehole abstraction within this aquifer. Again, it should be noted that on the basis of historical weather data and the prevailing climatic conditions, the use of the borehole to supply fresh water to the MBT process is highly unlikely.

1 Low Flows and Low Flow Distributions for Ireland by L. Brogan and C. Cunnane 2005


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2.2 ITEM 2 2.2.1 An Bord Pleanála text - Item 2 Reference is made to the submission to the Board received by the Department of the Arts, Heritage and the Gaeltacht, in particular in relation to water abstraction raised in Chapters 2 and 6 of the EIS and the observation which refers to these abstractions which are not considered to be assessed in the Appropriate Assessment Screening Report submitted. The submission also makes reference to the impact of the proposed water abstraction in combination with other water abstractions on any wetland Natura 2000 or other sites of nature conservation, which may be dependent on the same aquifer for their nature conservation interest. The applicant is requested to clarify this matter fully by reference to detailed analysis, survey data and other relevant information and to establish whether any potential impact on any qualifying conservation interest arises and the nature of those impacts. Note 2 2.2.2 Response to An Bord Pleanála - Item 2 One of the main aims of an Appropriate Assessment Screening Statement is to identify likely significant impacts on Natura 2000 sites. Abstraction impacts (alone and in-combination) on Natura 2000 sites and specifically Ballynafagh Lake SAC were considered by the project team at an early stage of the Appropriate Assessment Screening process. Potential impacts of the proposed borehole abstraction on Ballynafagh Lake (alone and in-combination) were assessed as part of the Appropriate Assessment screening exercise, however potential impacts were not considered to be likely. By way of explanation, the following facts informed this initial assessment that potential impacts of the proposed borehole supply on Ballynafagh Lake (alone and in-combination) were not considered to be likely:

• The key consideration is that groundwater flow, to Ballynafagh Lake or to any other Natura 2000 sites, is not connected to groundwater abstraction from the proposed borehole. There are no Natura 2000 sites or other sites of nature conservation interest with any groundwater flow connection to the proposed groundwater abstraction. The Drehid MBT facility borehole will be fed by groundwater in the immediate vicinity of the proposed MBT Facility.

• Ballynafagh Lake is influenced by the local geology and hydrogeology in the immediate vicinity of the lake. A review of surface water drainage patterns; topography; soils and bedrock, indicates that Ballynafagh Lake is fed from surface water and a number of small springs which rise to the northeast of the lake (See Appendix 1 of this Submission, Figure 1). This was confirmed during a walkover at Ballynafagh Lake in June 2007 and November 2011 where groundwater was seen to discharge to deep drainage ditches to the northeast of the lake. The source area of the springs to Ballynafagh Lake is upgradient lands to the north, northeast and east of the lake. It is unlikely that land to the west contributes groundwater to Ballynafagh Lake as this land appears to be downgradient based on surface water patterns, soils and topography.

• Moreover, given the distance of 5.8 km between the proposed water abstraction borehole and Ballynafagh Lake, the change in geology between the location of Ballynafagh Lake and the location of the proposed water abstraction borehole, and the change in the aquifer

2 Text from Submission from the Department of Arts, Heritage and the Gaeltacht to An Bord Pleanála

It is noted by the Department that the Applicant refers to water abstraction in Chapters 2 and 6 of the EIS. However, water abstraction has not been assessed in the appropriate assessment screening report submitted. It is recommended that when making a decision An Bord Pleanála should consider the impact of the proposed water abstraction, in combination with other water abstractions, on any wetland Natura 2000 sites, or other sites of nature conservation importance, which may be dependent on the same aquifer for their conservation interest.


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characteristics, it is not possible for the proposed water abstraction borehole to impact on Ballynafagh Lake SAC. In terms of geology change, the Allenwood and Boston Hill Formations lie between Ballynafagh Lake and the proposed water abstraction borehole. While both locations lie within the Waulsortian Formation, the bedrock around Ballynafagh Lake is likely to have increased fracturing and fissuring close to a major NE-SW fault at the Kildare Inlier (See Appendix 1 of this Submission, Figure 3). The groundwater flow characteristics within the Waulsortian Formation limestones are dominated by secondary permeability, i.e. fissure flow. Where folding/faulting occurs, increased dissolution and secondary permeability occurs. The proposed MBT Facility is located further away from this major SE-NW fault and therefore likely to have a lower permeability. Borehole site investigation data and pumping test data for the Bord na Móna landholding confirms the relatively low permeability of the underlying bedrock aquifer. Details of the pumping test and hydrogeological maps are included in Appendix 1 of this Submission.

• The aquifer characteristics of a Locally Important (LI) aquifer indicate that the aquifer has low transmissivity values and a relatively poorly connected network of fractures, fissures and joints, giving a low fissure permeability which tends to decrease further with depth. Some recharge will occur in the upper, more fractured/weathered zone which is likely to flow along the relatively short flow paths and rapidly discharge to streams, small springs and seeps. As illustrated below in Figure 2.1, an Ll aquifer is characterised by groundwater path lengths typically less than 1km. Transmissivity values (T) of between 2 m2/day and 16 m2/day which were calculated for GW6 and nearby observation wells confirm the aquifer category (as included in the EIS which supported the Planning Application for the extension and intensification of the Drehid Waste Management Facility - An Bord Pleanála Ref. PL.09.PA0004). As noted above, details of the pumping test and hydrogeological maps are included in Appendix 1 of this Submission.

• A borehole pumping test, conducted at the Bord na Móna landholding (Refer to Section 5.3.5 of the EIS (Volume II)) as part of a previous EIS (referenced in previous bullet point), confirms the relatively low permeability of the underlying bedrock aquifer and Locally Important aquifer classification of the underlying geology at the Bord na Móna landholding (See Appendix 1 of this Submission, Figure 3). The localised nature of the cone of depression, generated by the pumping test, demonstrates the poor and localised nature of the permeability in the bedrock underlying the Bord na Móna landholding.

• In addition, a groundwater discharge zone, the Blackwood Feeder and associated tributaries, acts as a groundwater divide and is situated between Ballynafagh Lake and the proposed borehole abstraction. Hence, there is no link/ groundwater pathway and therefore no potential effect of the proposed abstraction borehole (alone or in combination) on Ballynafagh Lake.

Figure 2.1 Transmissivity, Aquifer category and typical distance to discharge zones

The above information confirms that potential impacts/effects of the proposed groundwater abstraction, in combination with other water abstractions, on Natura 2000 sites are not likely. Precautionary mitigation procedures to minimise impacts to ground and surface waters (detailed in the EIS) are comprehensive and prevent significant localised impacts and indeed impacts to distant SAC sites. The key conclusion of the Water Chapter of the EIS (Section 6.5, page 234 in EIS (Volume II)) is that the


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measures employed will ensure that there is no adverse impact on the surface water or groundwater environment. Potential effects on Ballynafagh Lake were not considered likely based on consideration of the available information including distance from proposed borehole abstraction, limited abstraction, pump testing, aquifer classification, and understanding of the aquifer properties. It is confirmed that no potential impacts on any qualifying conservation interests are likely to arise as a result of the proposed development.


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2.3 ITEM 3 2.3.1 An Bord Pleanála text - Item 3 In relation to the Appropriate Assessment Screening Report (Appendix 4.1), it is indicated that none of the sites listed in Table 1 will be impacted by the proposed MBT facility. The Board considers that the screening report should provide the data, information and detailed considerations leading to the conclusion outlined and having regard to the conservation objectives of the European sites identified in Table 1. 2.3.2 Response to An Bord Pleanála - Item 3 In reaching the conclusion outlined in the Appropriate Assessment Screening Statement, consideration was given to the conservation objectives of the European sites identified in Table 1 of the Screening Statement. Section 3.3 of the Appropriate Assessment Screening Statement (Appendix 4.1 of the EIS (Volume IV)) identifies relevant Natura 2000 sites that might be affected by the proposed development. Table 1 therein identifies the relevant Natura 2000 sites within 15km of the proposed development. Table 1 is reproduced below for reference. Table 1: Natura 2000 Sites within 15km of the proposed MBT development site boundary

Name Site Code Designation Approximate distance from site/activity boundary

Ballynafagh Bog 000391 cSAC 6.4 km

Ballynafagh Lake 001387 cSAC 5.8 km Long Derries, Edenderry 000925 cSAC 7.2 km Mouds Bog 000395 cSAC 11 km

Pollardstown Fen 000396 cSAC 13.2km

In accordance with An Bord Pleanála’s request for further information, the conservation objectives of the European sites identified in Table 1 are provided below. The subsequent section of this response provides the considerations leading to the conclusion that none of the sites listed in Table 1 will be impacted by the proposed MBT facility. Conservation Objectives Ballynafagh Bog cSAC Location As noted in Table 1 of the Appropriate Assessment Screening Statement, Ballynafagh Bog cSAC is located approximately 6.4km from the proposed development. Conservation Objectives Data with regard to the conservation objectives3 for Ballynafagh Bog cSAC [Site Code 000391] designated by the NPWS was considered as part of the screening process and is given below: “To maintain or restore the favourable conservation condition of the Annex I habitat(s) and / or the Annex II species for which the SAC has been selected:

• [7110] * Active raised bogs • [7120] Degraded raised bogs still capable of natural regeneration

3 ’NPWS (2011) Conservation objectives for Ballynafagh Bog SAC [000391]. Generic Version 3.0. Department of the Arts, Heritage & the Gaeltacht’


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• [7150] Depressions on peat substrates of the Rhynchosporion” Ballynafagh Lake cSAC Location As noted in Table 1 of the Appropriate Assessment Screening Statement, Ballynafagh Lake cSAC is located approximately 5.8km from the proposed development. Conservation Objectives Data with regard to the conservation objectives4 for Ballynafagh Lake cSAC [Site Code 001387] designated by the NPWS was considered as part of the screening process and is given below: “To maintain or restore the favourable conservation condition of the Annex I habitat(s) and / or the Annex II species for which the SAC has been selected:

• [1016] Vertigo moulinsiana • [1065] Euphydryas (Eurodryas, Hypodryas) aurina • [7230] Alkaline fens”

The Long Derries cSAC Location As noted in Table 1 of the Appropriate Assessment Screening Statement, The Long Derries cSAC is located approximately 7.2km from the proposed development. Conservation Objectives Data with regard to the conservation objectives5 for The Long Derries cSAC [Site Code 000925] designated by the NPWS was considered as part of the screening process and is given below: “To maintain or restore the favourable conservation condition of the Annex I habitat(s) and / or the Annex II species for which the SAC has been selected:

• [6210] Semi-natural dry grasslands and scrubbed facies on calcareous substrates (Festuco Brometalia) (* important orchid sites)”

Mouds Bog cSAC Location As noted in Table 1 of the Appropriate Assessment Screening Statement, Mouds Bog cSAC is located approximately 11km from the proposed development. Conservation Objectives Data with regard to the conservation objectives6 for Mouds Bog pNHA / cSAC [Site Codes 00395 / 002331] designated by the NPWS was considered as part of the screening process and is given below:

4 ’NPWS (2011) Conservation objectives for Ballynafagh Lake SAC [001387]. Generic Version 3.0. Department of the Arts, Heritage & the Gaeltacht’ 5 ’NPWS (2011) Conservation objectives for The Long Derries SAC [000925]. Generic Version 3.0. Department of the Arts, Heritage & the Gaeltacht’ 6 ’NPWS (2011) Conservation objectives for Mouds Bog SAC [002331]. Generic Version 3.0. Department of the Arts, Heritage & the Gaeltacht’


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“To maintain or restore the favourable conservation condition of the Annex I habitat(s) and / or the Annex II species for which the SAC has been selected:

• [7110] * Active raised bogs • [7120] Degraded raised bogs still capable of natural regeneration • [7150] Depressions on peat substrates of the Rhynchosporion”

Pollardstown Fen cSAC Location As noted in Table 1 of the Appropriate Assessment Screening Statement, Pollardstown Fen cSAC is located approximately 13.2km from the proposed development. Conservation Objectives Data with regard to the conservation objective7 for Pollardstown Fen cSAC [Site Code 000396] designated by the NPWS was considered as part of the screening process and is given below: “To maintain or restore the favourable conservation condition of the Annex I habitat(s) and / or the Annex II species for which the SAC has been selected:

• [1013] Vertigo geyeri • [1014] Vertigo angustior • [1016] Vertigo moulinsiana • [7210] * Calcareous fens with Cladium mariscus and species of the Caricion davallianae • [7220] * Petrifying springs with tufa formation (Cratoneurion) • [7230] Alkaline fens”

Guidance on Stage 1 – Screening The guidance document from the Department of the Environment, (Department of the Environment, Heritage and Local Government (2009), “Appropriate Assessment of Plans and Projects in Ireland, Guidance for Planning Authorities”), details the stages required in undertaking an Appropriate Assessment and the methodology for Stage 1, ‘Appropriate Assessment Screening’. For Appropriate Assessment Screening, the guidance notes that an assessment is required to establish whether the proposed activity is likely to have an effect on a Natura 2000 site, and if so, to follow with a determination of whether there is a risk that the effects identified could be significant, “All likely sources of effects arising from the plan or project under consideration should be considered together with other sources of effects in the existing environment and any other effects likely to arise from proposed or permitted plans or projects.” “As a guide, any element of a plan or project that has the potential to affect the conservation objectives of a Natura 2000 site, including its structure and function, should be considered significant”. Consideration on whether development is likely to have effect on relevant Natura 2000 sites The considerations that informed the overall conclusion that the proposed activity is not likely to have an effect on the Natura 2000 sites (listed in Table 1 of the Appropriate Assessment Screening Statement), are detailed below.

7 ’NPWS (2011) Conservation objectives for Pollardstwon Fen [000396]. Generic Version 3.0. Department of the Arts, Heritage & the Gaeltacht’


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Each of the Natura 2000 sites listed in Table 1 of the Appropriate Assessment Screening Statement was considered to identify if the proposed development has the potential to impact on the Natura 2000 site in question. As the assessment and responses below are the same for each of the Natura 2000 sites listed in Table 1, the considerations are presented altogether in relation to: Ballynafagh Bog cSAC, Ballynafagh Lake cSAC, The Long Derries cSAC, Mouds Bog cSAC and Pollardstown Fen cSAC. There are no likely effects on any of the Natura 2000 sites identified in Table 1 of the Screening Statement due to the lack of any potential or definite source-pathway-receptor links between the proposed development and the Natura 2000 sites. There are no source-pathway-receptor links, potential or definite, between the proposed development and any of the Natura 2000 sites listed in Table 1: Ballynafagh Bog cSAC, Ballynafagh Lake cSAC, The Long Derries cSAC, Mouds Bog cSAC and Pollardstown Fen cSAC. No hydrogeological pathway or source-pathway-receptor link exists between the cSACs listed and the potential activities at the proposed Drehid MBT Facility site based on site investigation data, pump testing, aquifer classification, aquifer characteristics and the distance between the Natura 2000 sites and the proposed MBT Facility. Details of the pumping test and hydrogeological maps are included in Appendix 1 of this Submission. The aquifer underlying the cSAC’s listed and the proposed development is classified by the Geological Survey of Ireland (GSI) as a Locally lmportant aquifer / poorly productive aquifer. For clarity, it should be noted that poorly productive aquifers include the generally unproductive aquifer categories and Locally lmportant aquifers as per the Water Framework Directive working group 20038. As defined by the GSI, a Locally lmportant aquifer is characterised by groundwater path lengths typically less than 1km [See Figure 2.1 above]. All Natura 2000 sites are at least or in excess of 5.8km removed from the proposed development. (See Appendix 1 of this Submission, Figure 2 for Aquifer categories and Natura sites) In relation to any potential groundwater abstractions at the proposed development, alone and in combination with other existing groundwater abstractions in the existing environment, the effect of the abstractions will be restricted to a local influence, due to the characteristics of the aquifer being poorly productive and having short flow paths. No hydrological pathway or surface water link exists between the cSACs listed in Table 1 and the potential activities at the proposed Drehid MBT Facility site. All Natura 2000 sites within 15kms of the Drehid MBT Facility site (listed in Table 1) are situated in a separate sub-catchment within the surface water catchment in the area. The conservation qualifying interests of the Natura 2000 sites detailed (see Table 1) are groundwater dependent. As detailed above there is no linkage between the proposed development and these conservation qualifying interests. There are no other effects likely to conversation qualifying interests of the Natura 2000 sites (listed in Table 1) from the Drehid MBT Facility. Other effects considered included possible noise, dust, odour, flight risk (to birds) etc. This is fundamentally due to the fact that these Natura 2000 sites are situated at a significant distance (at least 5.8km) from the proposed Drehid MBT Facility. In conclusion, there will be no likely effects from the proposed development on the sites listed in Table 1 of the Screening Statement or on the habitats or species for which the sites have been selected as a protected site (i.e. the conservation objectives of the Natura 2000 sites). As there are no likely effects, there is no following determination required as to whether there is a risk that the effects could be significant.

8 Groundwater Working Group (2003) Guidance Document GW3. Water Framework Directive (WFD) River Basin District Management Systems: Approach to delineation of Groundwater Bodies. Paper by Working Group on Groundwater, 16 pp.


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2.4 ITEM 4 2.4.1 An Bord Pleanála text - Item 4 It is noted that the proposed MBT Facility in its operational phase will extend beyond 2028 and the existing Drehid Waste Management Facility’s current planning permission to accept waste is due to expire in 2028. The Board seeks clarification in relation to whether the applicant has examined future waste stream intake post 2028 in the context that the Drehid Waste Management Facility ceases activity in 2028, and whether any alteration in waste stream intake would have any predicted and residual impacts other than those presented in the EIS. 2.4.2 Response to An Bord Pleanála - Item 4 It is the applicant’s intention to operate the proposed Drehid MBT facility beyond the current permitted life of the landfill at the Drehid Waste Management Facility. We confirm that the applicant has examined future waste stream intake to the Drehid MBT Facility post 2028 in the context that the Drehid MBT Facility ceases activity in 2028 and can confirm that the quantity, source and nature of the waste stream intake to the MBT Facility will not be affected by the closure of the landfill at the Drehid Waste Management Facility post 2028. As a result of there being no alteration to the waste stream intake to the MBT Facility, there are no resulting predicted and residual impacts other than those presented in the EIS. The rationale for same is expanded on hereunder. Waste Stream Intake Quantity As noted in Section 1.2 of the EIS (Volume II), “The proposed Drehid MBT Facility will primarily accept and process municipal solid waste and will provide for an overall capacity of 250,000 tonnes per annum (TPA)”. Section 1.2.1 of the EIS (Volume II), notes, “The overall annual waste tonnage accepted at the existing Drehid Waste Management Facility and the proposed MBT facility will be the sum of the following:

• Municipal Solid Waste per annum accepted at the proposed 250,000 TPA MBT facility; • Residual Municipal Solid Waste per annum accepted directly at the previously permitted

120,000 TPA landfill9; and • Municipal Biowaste per annum accepted at the previously permitted 25,000 TPA composting

facility. Upon commencement of MBT operations, and during the life of the landfill’s current planning permission (120,000 TPA from December 2013 onwards), approximately 69,617 TPA of MBT residues will be accepted at the existing permitted landfill from the MBT Facility, with the remaining 50,383 TPA (120,000 TPA – 69,617 TPA) of other residual municipal solid waste accepted directly at the landfill (unrelated to the proposed MBT Facility activities). For the avoidance of doubt, the cessation of landfill activity will not result in any alteration in waste stream intake at the MBT Facility. The EIS (Chapter 11 – Traffic – Volume II) considers the traffic implications of the MBT Facility being constructed and operating at the same time as the permitted landfill at the Drehid Waste Management

9 The residual municipal solid waste per annum accepted directly at the previously permitted landfill will be 120,000 tonnes less the MBT residues (which will also be deposited in the landfill during the lifetime of the Drehid Waste Management Facility).


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Facility located within the Bord na Móna landholding. The EIS also considers the traffic implications of the planned ongoing independent operation of the MBT Facility beyond the current permitted life of the landfill (post 2028) at the Drehid Waste Management Facility. Specific details in relation to the waste intake quantities are provided in Section 11 of the EIS (Volume II), in Table 11-1, “Estimated Deliveries to the existing landfill and the proposed MBT Facility from 2015”. As shown therein, the delivery of 250,000 TPA to the MBT Facility will be the same both in Scenario 1 (with the landfill operational (pre 2028)) and in Scenario 2 (when the landfill’s current planning permission expires (post 2028)). In other words, the fact that the landfill at the Drehid Waste Management Facility is currently due to cease activity in 2028 does not result in either an increase or a decrease to the planned tonnage of waste stream intake to the Drehid MBT Facility. Waste Stream Intake Source Chapter 1 of the EIS (Volume II) and the Need Assessment Report (Appendix 1.2 of the EIS (Volume IV)) provide details in relation to the source of the waste stream intake. Section 1.3.3 of the EIS (Volume II) notes that the Need Assessment has been undertaken to assess the source of the waste stream intake from four waste management regions; the Kildare, Wicklow, Midlands and South East Waste Management Regions, “The purpose of this ‘Need Assessment Report’ is to provide a clear and concise scrutiny of available data and trends to assist in the forming of a definitive opinion of the potential to develop the Drehid MBT Facility.” “This Report examined a number of scenarios to demonstrate the need for the development of an MBT Facility to service the four subject waste management regions….”. Section1.3.3 of the EIS (Volume II) also notes, “In addition, a significant volume of waste is also available outside of the boundaries of the four waste management regions and this waste will also need to be diverted from landfill. The waste arising outside of the subject regions may be diverted to other facilities in the future, such as the Poolbeg Energy from Waste (EfW) Facility, but the proposed Drehid MBT Facility will be well positioned to accept this municipal waste for pre-treatment, if required.” The fact that the landfill at Drehid Waste Management Facility is due to cease activity in 2028 does not in any way change the potential source of the waste stream intake to the MBT Facility from that outlined above. In particular the closure of the landfill, which up until 2028 will accept some 50,383 TPA direct to the landfill (unrelated to the proposed MBT Facility activities), would not result in a change to the potential source of the municipal solid waste to the MBT Facility i.e. the source of the waste stream intake will remain the same, both pre 2028 and post 2028. Waste Stream Intake Nature As noted above and in Section 1.2 of the EIS (Volume II), “The proposed Drehid MBT Facility will primarily accept and process municipal solid waste and will provide for an overall capacity of 250,000 tonnes per annum (TPA)”. The nature of the waste stream intake to the MBT facility is municipal solid waste and the nature of the waste stream intake will remain the same, both pre 2028 and post 2028. The fact that the Drehid Waste Management Facility is due to cease activity in 2028 does not have any impact on the nature of the waste stream intake to the MBT facility. Other Predicted and Residual Impacts


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In the context that the Drehid Waste Management Facility is due to cease activity in 2028, it is confirmed that this will not result in any alteration in waste stream intake to the MBT facility. It is also confirmed, as a result, that as there will be no consequent alteration to the waste stream intake to the MBT facility, there will be no resultant predicted and residual impacts post 2028 other than those already presented in the EIS.


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2.5 ITEM 5 2.5.1 An Bord Pleanála text - Item 5 It is noted that as part of the EIS an odour management plan will be developed prior to the detailed design and construction of the proposed facility. It is considered that the EIS and accompanying documentation should include the details of the odour management plan in the application as odour is identified as a potential significant effect from the facility. The applicant is therefore requested to provide full details of the odour management plan. 2.5.2 Response to An Bord Pleanála - Item 5

FULL DETAILS OF THE ODOUR MANAGEMENT PLAN In response to the request from An Bord Pleanála, we now provide full details of the Odour Management Plan (OMP) which will be implemented at the proposed Mechanical and Biological Treatment (MBT) facility in the townlands of Coolcarrigan, Drummond and Kilkeaskin, Carbury, County Kildare. The MBT Facility is designed to process municipal solid waste with an overall capacity of 250,000 tonnes per annum. The EIS for the proposed development includes, in Chapters 2 and 8 (Volume II), the detailed odour mitigation measures which will be implemented as part of the OMP to reduce the risk of any adverse odour nuisance beyond the site boundary. The full details of the OMP have been delineated into a number of sections below. These sections, which are representative of the sections within the OMP that will be implemented, include the details of the specific measures which will be employed to minimise and control odour generated from the acceptance and treatment of waste at the proposed MBT Facility.

1.0 Introduction The introductory section of the OMP will include the following information. The OMP is a documented operational management system detailing the measures employed to anticipate the formation of odours and to control their release from the site. The OMP is based on general requirements of the UK Environment Agency’s “Additional Guidance For H4 Odour Management – How To Comply With Your Environmental Permit”(1) and the “Good Practice & Regulatory Guidance on Composting and Odour Control for Local Authorities” (DEFRA, 2009)(2). The OMP will address the following topics:

• All activities which produce odour and release points for odour under both normal and abnormal operation.

• All odour control measures which will be in place and justification that the control measures are in line with Best Available Techniques (BAT).

• Consideration of process or control failures which could lead to an increased level of

exposure.

• All management procedures in place including the repair and maintenance schedule of plant and machinery.


14

• Monitoring of processes, controls, source sampling and site inspections and

surveys.

• Emergency & incident response procedures.

• Record keeping including records of maintenance of plant, monitoring results, communication, incidents, training etc.

In addition to the OMP, standard operating procedures (SOPs) and safe systems of work will be implemented to ensure safe and controlled operating conditions. The level of complexity of the OMP will be commensurate with the complexity of the processes and on the potential impact of a release of odour on neighbouring premises.

2.0 Ambient Environment & Local Receptors

The OMP will provide details of the ambient environment and local receptors. This section of the plan will be based on the information provided in the EIS (particularly Section 2.1 and Chapter 8 – Volume II). The following information will be provided in this section of the OMP. The Bord na Móna proposed Mechanical and Biological Treatment (MBT) facility is located in the townlands of Coolcarrigan, Drummond and Kilkeaskin, Carbury, County Kildare. “The site boundary or the activity boundary, outlined by the red line in Figure 1.1, which is defined as the area in which all activities associated with the Drehid MBT Facility will occur, is confined to the townlands of Coolcarrigan, Drummond and Kilkeaskin. It should be noted that the activities associated with the Drehid MBT Facility will be confined to a landbank of approximately 29ha.” (Page 67 of the EIS (Volume II) – Section 2.1.1) “Access has been provided into the previously permitted Drehid Waste Management Facility from the R403 regional road via a dedicated site entrance and a 4.8km access road. This entrance and road will also provide access from the R403 regional road to the MBT Facility”. (Page 67 of the EIS (Volume II) – Section 2.1.1) “The village of Derrinturn is located approximately 3km north west of the closest edge of the site activity boundary and Timahoe crossroads is located approximately 2.5km east of the closest edge of the site activity boundary.” (Page 67 of the EIS (Volume II) – Section 2.1.1) “Housing in the immediate area of the proposed site comprises predominantly single dwellings with adjacent farmyards and new bungalows.” (Page 68 of the EIS (Volume II) – Section 2.1.2) The site is located in an area of reasonably sparse population density with the nearest residential properties located approximately 1000m to the west of the facility as shown in Figure 8.1 of the EIS (Volume II). “The largest concentration of houses close to the proposed facility is to the north west of the site in the village of Derrinturn.” (Page 68 of the EIS (Volume II) – Section 2.1.2) “Land use on and adjacent to the MBT Facility site is primarily disused cutaway bogland used up to approximately twenty two years ago for production of sod peat for energy generation. Immediately adjacent to the MBT Facility site there are areas of land where turbary, commercial forestry and agricultural usage are evident.” (Page 68 of the EIS (Volume II) – Section 2.1.3)


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3.0 Sources With Odour Potential From The Facility

This section of the OMP will describe the characteristics of odour. The information outlined below is provided in Section 8.1.1.1 of the EIS (Volume II). Odour “Odours are sensations resulting from the reception of a stimulus by the olfactory sensory system, which consists of two separate subsystems: the olfactory epithelium and the trigeminal nerve. The olfactory system is extremely complex and peoples’ responses to odours can be variable. This variability is the result of differences in the ability to detect odour; subjective acceptance or rejection of an odour due to past experience; circumstances under which the odour is detected; and the age, health and attitudes of the human receptor.” (Page 245 of the EIS (Volume II) – Section 8.1.1.1) Odour Intensity and Threshold “Odour intensity is a measure of the strength of the odour sensation and is related to the odour concentration. The odour threshold refers to the minimum concentration of an odorant that produces an olfactory response or sensation. This threshold is normally determined by an odour panel consisting of a specified number of people, and the numerical result is typically expressed as occurring when 50% of the panel correctly detect the odour. This odour threshold is given a value of one odour unit and is expressed as 1 OUE/m3. The odour threshold is not a precisely determined value, but depends on the sensitivity of the odour panellists and the method of presenting the odour stimulus to the panellists. An odour detection threshold relates to the minimum odorant concentration required to perceive the existence of the stimulus, whereas an odour recognition threshold relates to the minimum odorant concentration required to recognise the character of the stimulus. Typically, the recognition threshold exceeds the detection threshold by a factor of 2 to 10(3).” (Page 245 of the EIS (Volume II) – Section 8.1.1.1) Odour Character “The character of an odour distinguishes it from another odour of equal intensity. Odours are characterised on the basis of odour descriptor terms (e.g. putrid, fishy, fruity etc.). Odour character is evaluated by comparison with other odours, either directly or through the use of descriptor words.” (Page 245 of the EIS (Volume II) – Section 8.1.1.1)

Hedonic Tone “The hedonic tone of an odour relates to its pleasantness or unpleasantness. When an odour is evaluated in the laboratory for its hedonic tone in the neutral context of an olfactometric presentation, the panellist is exposed to a stimulus of controlled intensity and duration. The degree of pleasantness or unpleasantness is determined by each panellist’s experience and emotional associations. The responses among panellists may vary depending on odour character; an odour pleasant to many may be declared highly unpleasant by some.” (Page 245 of the EIS (Volume II) – Section 8.1.1.1)

Adaptation “Adaptation, or Olfactory Fatigue, is a phenomenon that occurs when people with a normal sense of smell experience a decrease in perceived intensity of an odour if the stimulus is received continually. Adaptation to a specific odorant typically does not interfere with the ability of a person to detect other odours. Another phenomenon known as habituation or occupational anosmia occurs when a worker in an industrial situation experiences a long-term exposure and develops a higher threshold tolerance to the odour”. (Page 246 of the EIS (Volume II) – Section 8.1.1.1)


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Processes With Odour Potential from Drehid MBT Facility – Configuration A (MBT with Composting) Details of the processes with odour potential and the abatement / mitigation measures employed to reduce the risk of odour nuisance, as outlined in Section 8.1.1.1 of the EIS (Volume II) (page 250 and page 251), will be provided in the OMP. Process With Odour Potential from Bord na Móna Drehid MBT Facility – Configuration B (MBT with Dry Anaerobic Digestion and Composting) Details of the processes with odour potential and the abatement / mitigation measures employed to reduce the risk of odour nuisance, as outlined in Section 8.1.1.1 of the EIS (Volume II) (page 251, page 252 and page 253), will be provided in the OMP.

4.0 Operational And Process Controls

The odour management strategy for the facility will be primarily based on the principle of preventing the release of odour and containment of the release in a proactive manner rather than reacting to odour generation. The operational and process controls have been designed with the minimisation of odour as one of the key factors. The techniques for odour control have been designed in accordance with the EPA document “BAT Guidance Notes for the Waste Sector: Waste Transfer and Material Recovery (EPA, 2011)”(4). The management techniques which are outlined in the BAT guidance, and which have been adopted for the proposed MBT Facility are as follows:

• The location of the facility with regard to off-site receptors was taken into account during the design stage. The facility is located at a distance of 1000m from the nearest receptor in an area of relatively low population density.

• At the design stage a great deal of consideration was given to the requirement for the capture, containment and treatment of odour. The MBT Facility will be completely enclosed within a negative pressure environment with all waste air being directed to an odour abatement system prior to release from a tall stack.

• The operational procedures will take into account the nature of the waste which will be

accepted (municipal solid waste) and the waste processing activities (mechanical and biological treatment – composting/anaerobic digestion). The MBT Facility has been designed to minimise the risk of odour occurring from these operations (negative pressure facility, extracted air released via biofilter).

• Appropriate procedures have been developed to deal with malodorous waste with all

waste being unloaded into the waste reception bunker which will have rapid closing doors and will be maintained under negative pressure. In addition, the doors for the acceptance of waste will be fitted with air curtains to minimise the escape of odorous emissions when a door is open.

• Vehicles delivering and removing waste will be enclosed or covered.

• The facility will use appropriate odour abatement techniques which are in line with BAT.


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Specific Odour Operational Controls Details of the specific operational controls to minimise and control the odour which is generated by the acceptance and treatment of waste are outlined in Section 8.1.4.2 of the EIS (Volume II) (Pages 278, 279 and 280). These include:

• “Air from the Mechanical Treatment Building and the Refining Building will pass through a dust filter prior to passing through a the odour abatement system;”

• “The biofilters will be maintained to ensure optimum performance;”

• “All processes will be internal within buildings under negative pressure so air will not

escape buildings;”

• “Doors at the waste reception area will be rapid closing doors, with an opening or closing time of approximately 20 seconds. Doors for the acceptance of waste will be fitted with air curtains to minimise the escape of odorous emissions or dust when a door is opened;”

• “All waste delivered to the MBT facility will be in covered/enclosed vehicles. Similarly, all waste residues being removed from the MBT facility will be in covered/enclosed vehicles;”

• “The first stage of the biological treatment process is the most critical with respect to

odour emissions, since easily biodegradable components (e.g. sugars, proteins and fats) are degraded at a high rate, thus causing gaseous by-products. This intensive phase of the biological treatment process will be undertaken in fully enclosed concrete composting/dry AD tunnels located within an enclosed building - thereby providing double containment features;”

• “The maturation process will be undertaken by means of negative aeration. Negative

aeration draws air from within the building through the trapezoidal windrows and into the aeration ductwork. This arrangement will greatly reduce emissions from the trapezoidal windrows within the building, thereby minimising the potential for nuisance odour emissions;”

• “Air streams with a potential for high ammonia levels will be treated in an acid scrubber

prior to biofiltration;”

• “Critical and key odour abatement system performance parameters will be continually monitored on the SCADA control system. Should any parameter deviate outside of its accepted range, an alarm will be immediately generated. Critical alarms will be texted to selected mobile phones numbers thereby ensuring the communication of critical alarms to responsible individuals on a 24 hour basis;;”

• “Good housekeeping practices (internally and externally) and a closed-door

management strategy will be maintained at all times;”

• “Biofilters will be compartmentalised to facilitate maintenance and replacement of media. Each biofilter will comprise of two sections such that treatment is provided by one of the sections while the other section is being maintained;”

• “Biofilters will be covered and hence isolated from extreme weather conditions (e.g.

intensive rainfall or intensive heat) thereby providing optimum control of biofilter efficacy;”


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• “Normal operational practices will be such that the organic fines fraction (putrescible fraction with the highest potential for odour) generated in any day by the mechanical treatment process will be loaded into the composting/dry AD tunnels on the same day;”

• “Treated air from the biofilters will be emitted through 20m high stacks to facilitate

appropriate residual odour dispersion;”

• “The organic fines fraction will be conveyed from the Mechanical Treatment Building to the biological treatment buildings in fully covered and enclosed galleys;”

• “If composting temperatures exceed approximately 65°C, odour emissions increase

significantly, due to the changes in process biochemistry. Excessive increases in composting temperatures are especially relevant in the first stage of composting when, due to the fast degradation, a lot of energy will be released. Temperature sensors will be used to measure the temperature in the composting tunnels and subsequently in the maturation area. The SCADA control system will ensure that the composting temperature does not exceed 65°C by adding more fresh process air to the composting mass. This will reduce the odour load in the process air being transported to the odour abatement systems;”

• “In the case of Configuration B (MBT with Dry Anaerobic Digestion and Composting), a

standby gas flare will be provided to facilitate the thermal destruction of the biogas in the event of unavailability of the CHP plants and that there is insufficient volume in the biogas storage bladders.”

5.0 Monitoring And Auditing

Monitoring of odorous releases will be undertaken, as part of the OMP, in order to determine the effectiveness of the odour control measures. Odour Monitoring Plan The OMP will serve as a useful check of the impact of the proposed MBT Facility in the ambient environment. The following options are available in order to undertake an OMP:

• Assessing impact (using complaints, community questionnaires, interviews and field sniff tests);

• Assessing exposure (using field surveys, field dilution olfactometry, surrogate monitoring);

• Investigate sources and pathways (using fence line monitoring, meteorological

monitoring);

• Measure releases (using dynamic dilution olfactometry, assessment against emission limit values);

• Control processes (using temperature, oxygen level, pH, moisture).

The purpose of the monitoring plan will be both proactive (i.e. routine monitoring of performance in order to improve environmental performance) and, where necessary, reactive (i.e. in response to complaints).


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Boundary Sniff Test The monitoring protocol will in the first instance be proactive with the following procedure in place:

• On a daily basis (preferably prior to arrival onsite) a member of staff will undertake a sniff test at the boundary of the facility. The staff member will not be regularly exposed to the facility odour in order to avoid odour fatigue. A member of the office staff or similar personnel will undertake the assessment.

• The person undertaking the assessment will avoid strong food or drinks (including coffee) at least 30 minutes prior to the survey and strongly scented toiletries / vehicle deodorisers will also be avoided.

• The location of the sniff test will be dictated by the current wind direction and recorded

using standard sniff test forms.

• A daily record of the odours observed by on-site personnel will be maintained on-site as part of the site record keeping.

• In the event that the sniff test indicates that corrective action is required, the facility

management team will attempt to isolate and identify the equipment which requires corrective action and will implement measures immediately to correct the problem.

• A record of the daily sniff test and any necessary corrective action will be maintained on-

site as part of the site record keeping Site Odour Assessment On a daily basis, on-site operators will undertake sniff tests at source. The information obtained from the sniff tests will be used to confirm that all equipment is operating correctly. In the event that the sniff test indicates that corrective action is required, the operator will identify the item of equipment which requires corrective action and will implement measures immediately to correct the problem. A record of the daily sniff test and any necessary corrective action will be maintained on-site as part of the site record keeping. Monitoring At Source Monitoring of the biofilters for odour and other relevant parameters will be undertaken to ensure that the biofilters are operating efficiently. This frequency will be in line with the proposed MBT Facility’s waste licence (to be granted by the EPA). The monitoring records will include details on the following:

• Date, time and details of emission points sampled; • How the samples were preserved (condensation, holding time, conditions);

• Method of sampling (e.g. stack sampling via stainless steel tube etc);

• The laboratory where the results were analysed and details of the laboratory certification

to undertake the analysis;

• Any laboratory observations that might affect how the results were interpreted;


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• Process parameters at the time of sampling and whether these differ from the average conditions;

• Meteorological considerations at the time of sampling.

A record of monitoring results and associated information and any necessary corrective action arising from the results will be maintained on-site as part of the site record keeping. Complaint Procedure Any complaint received either directly or via Kildare County Council or the EPA will be investigated promptly and appropriate remedial action undertaken where necessary. As a first step, the odour complaint will be recorded using a standard Odour Complaint Record. All complaints will be reviewed and assessed using the site’s standard procedure which is outlined below.

• Staff members will organise and direct a sniff test to be undertaken by a member of staff provided the odour complaint has been received immediately following an odour incident;

• The complaint will be reviewed to assess the quality of the complaint and whether there

is a number of similar complaints;

• The complaint will also be assessed in terms of the frequency of occurrence (is it a one-off complaint or a regular occurrence).

• The meteorological conditions during the period of detected odour complaint will be

assessed to determine whether the site is likely to be the source of the odour complaint or if there is an alternative nearby source;

• In the event that elevated odour levels are detected, an assessment of any possible

abnormal operating site activities will be undertaken and any necessary corrective or preventative action will be taken to ensure that a reoccurrence of the problem does not arise;

• The complainant will be contacted as soon as reasonably possible after the complaint

and given an update on the investigation and any corrective action which has been implemented;

• All complaints will be raised with site management and discussed at the site’s

management meetings. Equipment Maintenance Maintenance of plant and equipment will form a critical dimension of the OMP. The regular maintenance of all plant and equipment utilised on-site will be undertaken in accordance with the manufacturer’s guidelines. A strict preventative maintenance and management programme will be implemented to ensure that all odour mitigation techniques remain operational at optimal capacity throughout all operational scenarios. This preventative maintenance programme will help to minimise occurrences of breakdowns on-site. In the event of any breakdown, the item of plant or equipment will be promptly repaired or replaced. A maintenance building will be provided on site to facilitate this maintenance programme. All plant and equipment will be checked on a daily basis.


21

The facility will conduct regular inspections, monitoring and maintenance of waste handling areas and abatement equipment. Annual Audit The effectiveness of the OMP will be reviewed, by means of audit, on an annual basis. The frequency of the odour review will be increased if there are complaints or relevant changes to the operation of the facility. Audits in line with the facility’s Environmental Management System (EMS) will also be undertaken and will include spot checks on the record keeping in line with the requirements outlined in Section 7.0 below, visual inspection of waste acceptance to ensure the waste acceptance policy is being adhered to and random checks to odour control equipment throughout the year.

6.0 Emergency Plans And Corrective Action

Corrective Action As part of the OMP, a range of corrective actions will be implemented in the event that the operational odour control measures require corrective action. In line with BAT, all critical and key odour abatement system performance parameters will be continually monitored on the SCADA control system. Should any parameter deviate outside of its accepted range, an alarm will be immediately generated. Critical alarms will be texted to selected mobile phones numbers thereby ensuring the communication of critical alarms to responsible individuals on a 24 hour basis. The waste reception bunker is designed to accommodate the storage of approximately three days of incoming waste, thereby providing contingency in the event of unavailability of the mechanical processing equipment. In the event that odour complaints arise due to mechanical failure, a range of mitigation measures will be considered including a partial shutdown of the plant where the mechanical failure can be isolated and the rest of the facility, which can operator correctly, will continue to process waste. In the event of a serious incident requiring the complete shutdown of the facility for an extended period of time, the facility will divert the waste that would have been delivered to another facility. Once correct action has been implemented, a review will be undertaken to identify any failings in the skills / training of the staff. Appropriate training will be implemented in the event that gaps in skills are identified.

7.0 Record Keeping

The OMP will keep a range of records in accordance with the procedures of the site’s environmental management system (EMS). The main types of information which will be filed onsite include:

• Location of all sensitive receptors including the distance from the source;

• Details of all stack monitoring undertaken including date, time of sampling, sampling methodology, laboratory results and any comments by the stack team or laboratory in reference to the results;

• Details of the daily off-site (boundary) sniff tests including details of the prevailing

meteorological conditions, intensity of odour (if any) and corrective action recommended;


22

• Details of the daily on-site (source) sniff tests including details of which sources were

tested and corrective action recommended (if any);

• Details of any complaints including details of the prevailing meteorological conditions, intensity of odour (if any) and corrective action recommended;

• Details of the regular inspections of equipment including dates, source equipment and

corrective action required;

• Details of the preventative maintenance schedule for the waste handling areas and odour abatement equipment including details of any replacement of parts, changes to equipment technology etc.

8.0 Summary

The OMP will be a documented operational management system detailing the measures employed to anticipate the formation of odours and to control their release from the site. The odour management strategy for the facility will be primarily based on the principle of preventing the release of odour and containment of the release in a proactive manner rather than reacting to odour generation. This proactive approach includes using BAT to capture, contain and treat the odour and operational procedures which will be designed to minimise the risk of odour occurring. In addition to the OMP, standard operating procedures (SOPs) and safe systems of work will be implemented to ensure safe and controlled operating conditions.

9.0 References

(1) UK Environment Agency (2012) Additional Guidance For H4 Odour Management – How To Comply With Your Environmental Permit

(2) UK DEFRA (2009) Good Practice & Regulatory Guidance on Composting and Odour Control for Local Authorities

(3) Water Environment Federation (1995) Odour Control in Wastewater Treatment Plants (4) EPA (2011) BAT Guidance Notes for the Waste Sector: Waste Transfer and Material

Recovery


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2.6 ITEM 6 2.6.1 An Bord Pleanála text - Item 6 It is noted that the EIS and other documentation submitted has not addressed the site’s proximity to the Leinster Orbital Route. This matter was raised by the National Roads Authority in an EIS scoping submission to the applicant. The applicant is requested to submit its comments in relation to this matter. 2.6.2 Response to An Bord Pleanála - Item 6 In a National Roads Authority scoping submission, the applicant was advised to have consultations with the relevant Local Authority - Kildare County Council. A consultation meeting between representatives of Kildare County Council (Roads and Transportation Department), TOBIN Consulting Engineers and Bord na Móna took place on Friday 2nd March 2012 relating to the proposed MBT Facility. At this meeting, future road schemes that may be impacted by the proposed MBT Facility were discussed. Kildare County Council raised only one project that needed to be considered in the assessment - the ongoing road improvement works on the R402. In response to this, the impact of the proposed MBT Facility on the existing R402 was addressed in Sections 11.2.2, 11.3.5 and 11.3.7 of the EIS (Volume II). The road improvement works on the R402 were discussed in Section 11.2.3 of the EIS (Volume II). The conclusion of the traffic impact assessment (Section 11.5 of the EIS (Volume II)) notes that, “The R402 Road Improvement Scheme will further improve the haul route for vehicles accessing the proposed MBT Facility from the north”. The Leinster Orbital Route (LOR) has been progressed to the end of the Feasibility Stage and a Feasibility Report was published in 2007. Since then, the project has been suspended and no further road alignments/designs have been published in relation to the scheme. The Feasibility Report for the LOR outlines high level benefits of undertaking the road scheme, but provides limited detail as to the exact location of the road. Wide route corridors (approximately 2,000m) are provided along with several potential route variations. The nearest potential corridor is located some 3km to the east of the proposed MBT Facility site, with all other variants being even further removed from the site. Also unavailable at this time is information relating to the location of junctions and there are only limited estimates of traffic volumes for the various links. Due to (i) the limited information available in respect of the LOR Scheme and (ii) the number of different indicative alignments of the proposed LOR, it is not possible to conduct a more detailed assessment of the impact of the Drehid MBT Facility on the LOR at this time. On the basis of the expected high traffic volumes on the LOR, the volume of MBT Facility generated traffic using the LOR would likely be a minor percentage of the overall traffic using the LOR. As a result, it is expected that the MBT Facility generated traffic would have a corresponding minor impact on the LOR with an estimated order of magnitude similar to that caused by the MBT Facility traffic on the M4 and M7 (projected traffic increases on the M4 and M7 are reported in the Section 11.3.5 of the EIS (Volume II)). In its submission to An Bord Pleanála, the National Roads Authority has noted that from a national roads perspective it is satisfied with the scope of the traffic analysis undertaken in the EIS and has no objection to the findings presented. Given the lack of detail with respect to the exact alignment of the proposed LOR it is not possible to consider further the potential impact of the MBT Facility on the route in relation to noise, air quality and visual impacts. However, it is reasonable to suggest that these potential impacts will likely be less than those experienced by the nearest sensitive receptors to the proposed Drehid MBT Facility, which although located quite a distance away, are closer than the nearest corridor currently delineated for the LOR. Potential impacts on the nearest sensitive receptors are described in the EIS (Volume II) in Chapters 8 (Air Quality), 9 (Noise and Vibration) and 10 (Landscape and Visual).


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2.7 ITEM 7 2.7.1 An Bord Pleanála text - Item 7 Three settlement lagoons are indicated in the proposed development to provide surface water attenuation prior to discharge to a watercourse. It is noted that the calculations of the sizing of these lagoons provides for a climate change increase of 10%. The applicant is requested to submit revised settlement lagoons with an adjustment factor of 20%. 2.7.2 Response to An Bord Pleanála - Item 7 The calculations, supporting the sizing of the surface water attenuation lagoons, submitted with the Planning Application were based on the requirements of the Greater Dublin Strategic Drainage Study and in particular, Volume 5, Climate Change. This document recommends that present day design rainfall depths are to be increased and factored by 10% (1.1). The attenuation calculations prepared in support of the Planning Application recommended a minimum value of storage of 7,882m3. The actual value of storage provided in the 3 No. attenuation lagoons is, however, far in excess of this minimum value, amounting to 11,232m3. [5,278m3 in each of lagoon No. 1 and 2 and 676m3 in lagoon No. 3]. In order to comply with the An Bord Pleanála request for further information, the application of a climate change factor of 20% to the design is required thereby resulting in a minimum storage volume requirement of 10,066m3 . The storage capacity of the existing lagoons is 11,232m3 and is clearly in excess of the storage volume required when a climate change factor of 20% is applied. The design of the lagoons submitted in support of the Planning Application therefore has adequate capacity to cater for the increased climate change factor of 20%. No change is required to the layout/design of the lagoons to facilitate a climate change factor of 20%. Hence, there is no requirement to “submit revised settlement lagoons”.

APPENDIX 1

Hydrogeology and Geology Figures

Details of the 72 Hour Pumping Test

Appendix 1 of this Submission to An Bord Pleanála includes (i) Hydrogeology and Geology Figures and (ii) Details of the 72 Hour Pumping Test In relation to (ii) above – A summary is provided of the pumping test information included in the EIS supporting the Planning Application for the Extension and Intensification of the Drehid Waste Management Facility ‐ An Bord Pleanála Ref. PL.09.PA0004. Copies of two Appendices (2.4.7 and 2.4.8) submitted as part of the aforementioned EIS are also provided at the end of this Appendix One. The summary of the pumping test information references these Appendices.

Site Location

Ballynafagh Lake

Ballynafagh Bog

0 220 440 660 880110Metres

DREHID MECHANICAL BIOLOGICAL

TREATMENT (MBT) FACILITY

DESIGNATED SITES- Special Areas of Conservation -

M. Nolan J.Dillon October 2012D.Grehan

Figure 1 A

1. FIGURED DIMENSIONS ONLY TO BE TAKEN FROM THIS DRAWING2. ALL DRAWINGS TO BE CHECKED BY THE CONTRACTOR ON SITE3. ENGINEER TO BE INFORMED OF ANY DISCREPANCIES BEFORE ANY WORK COMMENCES4. ALL LEVELS RELATE TO ORDNANCE SURVEY DATUM AT MALIN HEAD

NOTES

D01 03-10-12 Issued M.N. J.D.

Ordnance Survey Ireland Licence No EN 0016012 ©Ordnance Survey Ireland and Government of Ireland

Scale @ A3:

Issue Date Description By Chkd.

Client:

Project:

Title:

Prepared by: Checked: Date:

Project Director:

Consulting, Civil and Structural Engineers,Block 10-4, Blanchardstown Corporate Park, Dublin 15, Ireland.tel: +353-(0)1-8030406fax:+353-(0)1-8030409e-mail: [email protected]

6301No part of this document may be reproduced or transmitted in any form or stored in any retrieval system of any nature without the written permission of Patrick J. Tobin & Co. Ltd. as copyright holder except as agreed for use on the project for which the document was originally issued.

1:30,000

Legend

Special Area of Conservation - SAC

Springs in Drainage Ditches

UPGRADIENT SOURCE AREA FOR BALLYNAFAGH LAKE

Site BoundaryOwnership Boundary

Site Location

Mouds Bog

Pollardstown Fen

Ballynafagh Bog

Ballynafagh Lake

The Long Derries, Edenderry

Ll

Lm

Rkd

Lk

Pl

0 610 1,220 1,830 2,440305Metres



AQUIFERCLASSIFICATION MAP WITH

DESIGNATED SPECIAL AREASOF CONSERVATION


Figure 2 A


NOTES

D01 03-10-12 Issued M.N. J.D.


Scale @ A3:


Client:

Project:

Title:


Project Director:



1:80,000

LegendSite Boundary

Locally Important Aquifer - KarstifiedLocally Important Aquifer - Bedrockwhich is Moderately Productive only in Local ZonesLocally Important Aquifer - Bedrock which is Generally Moderately ProductiveRegionally Important Aquifer - Karstified (diffuse)

15Km Buffer


RiversLakes

Poor Aquifer - Generally Unproductive except for Local Zones

Ownership Boundary

Site Location

Fault

Boston Hill Formation

Kildare InlierKildare Inlier

Ballynafagh Bog

Ballynafagh Lake

Waulsortian Limestones

Boston Hill Formation

Lucan Formation

Allenwood Formation

Feighcullen FormationOld Red Sandstone (undifferentiated)

Cloghan Sandstone FormationFerbane Mudstone Formation

0 300 600 900 1,200150Metres



BEDROCK GEOLOGY MAP WITHDESIGNATED SPECIAL AREAS

OF CONSERVATION


Figure 3 A


NOTES

D01 03-10-12 Issued M.N. J.D.


Scale @ A3:


Client:

Project:

Title:


Project Director:



1:40,000

LegendSite Boundary


Feighcullen Formation

Lucan Formation

Waulsortian LimestonesAllenwood FormationBoston Hill Formation

Cloghan Sandstone Formation

Old Red Sandstone (Undifferentiated)Ownership Boundary

Summary of Section 2.4.5, page 84-87 of the Drehid Waste Management Facility Intensification and Extension EIS – (ABP Reference PL09.PA0004) Aquifer Potential The groundwater flow characteristics within the limestones underlying the site are dominated by secondary permeability, i.e. fissure flow. There is effectively no primarily permeability (inter-granular permeability) in these rocks. As part of this hydrogeological investigation of the aquifer potential a 72 hour pump test was carried out to determine the characteristics of the aquifer. The pump test was undertaken on borehole GW6. Before the pump test began the static water level (SWL) in all monitoring boreholes was recorded to act as a datum for measurement during the test. The water levels in all boreholes were measured periodically to determine if the pumping was resulting in a radial cone of depression as a result of drawdown from the pumped borehole. The pump test was undertaken by pumping from GW6, which was drilled to a finished 150mm diameter borehole. The other boreholes installed at the site were monitored during the course of the pump test to observe any water level fluctuations. The discharge drawdown data from the pump test are included in Appendix 2.4.7. The only water level fluctuation in the observation wells was recorded in monitoring wells BH1D and BH1S, which are approximately 35m from the pumping well. A drawdown of 1.53 m was achieved in BH1D with a drawdown of 0.6 m being achieved in borehole BH1S indicating the pumping and drawdown only had a very localized effect. The peak pump rate measured during the test was 56m3/day. The pump rate of 43m3/day was used for calculations as an average pump rate maintained during the log cycle in which the data was interpreted (i.e. 10 to 100 minutes), due to slight fluctuation in discharge during the test. These fluctuations in pumping rate are discussed below. Due to slight variation in the pumping rates observed during the test, the pumping rate used in the Jacob Calculation was correlated with the pumping rate observed during a full log cycle. A value of 43m3/day was used for the calculation of the aquifer transmissivity in the 10 to 100 minutes log. The drawdown per log cycle during the 10 to 100 minutes log cycle was 37.2m (with actual observed drawdown between 25 and 27 m, however as per the Jacob Method the drawdown per log cycle is used). Therefore, the figures used for calculating the Transmissivity are a drawdown per log cycle of 37.2m and the pumping rate of 43m3/day, giving a calculated transmissivity of 0.215 m2/day (See Calculation Appendix 2.4.8). Following 100 minutes of pumping the drawdown in the well began to vary, making the determination

of a straight line slope for calculation difficult. A similar slope (and hence Transmissivity value) is noted from 1709 minutes to 2909 minutes. Notwithstanding the slight variation, the drawdown in the pumped well was at a relatively steady-state (though oscillating) at a level between 23m and 27m (with an approximate average value of 25m). A Logan Approximation calculation which relates transmissivity to the pumping rate and steady-state drawdown in a well was applied to this data for pumping after 100 minutes. The Logan Approximation was deemed an appropriate method to approximate the aquifer transmissivity due to the slight variation in drawdown in the pumped well. The values used were a pumping rate 48.5 m3/day (an average pumping rate over the 100 to 4349 minute period) and a drawdown of 25 m. This Logan calculation gave a transmissivity result of 2.37 m2/day, presented as a rounded value of 2 m2/day. The calculated specific capacity of the pumping well is 1.94 m3/day/m, using the above values of the average mid to late pumping rate of 48.5 m3/day and an average drawdown of 25 m. This means the well would be classified as Well Productivity Class V (the lowest classification), as per the Geological Survey of Ireland well classification system. An additional analysis of the pump test data was undertaken using a simplified Thiem Equation formula. This simplified Thiem equation was derived by Aslibekian (1998) and is normally applied to steady radial flow in a confined aquifer in typical Irish Aquifers. The simplified Thiem Equation gave a transmissivity result of 2.31 m2/day, confirming the values obtained through other methods of data interpretation. (See calculation, Appendix 2.4.8). The values for Transmissivity calculated from drawdown data from GW6 are presented below in Table 1. Table 1: Transmissivity Values from Drawdown Data from GW6PW

Analytical Method used

Jacob Straight Line (10 to 100 minutes)

Logan Approximation (100-4349 minutes)

Aslibekian (simplified Thiem Equation)

Arithmetic Mean

T (m2/day) 0.215 2.37 2.31 1.7 The recovery period of the aquifer pump test was monitored and the data interpreted using the Jacob Straight Line Method using a semi-log plot of residual drawdown (s’) vs. t’/t (time since cessation of pumping divided by time since commencement of pumping). The recovery period was 210 minutes long with water levels recovering from a drawdown of 25.93 m to within 1.37 m of zero drawdown (the SWL prior to the test). Monitoring of the data ceased after continuous monitoring of the data curve showed there was sufficient data to allow an analysis to be carried out and due to the incrementally slower recovery

which always occurs in the final metre of any recovery test, but which is more due to well effects than aquifer response. Analysis of the graphs showed three subtly different slopes for late, mid and early points in the recovery (highest values of t’/t are early time, lowest values are late time). Values of transmissivity were calculated using the highest pumping rate observed of 56m3/day and also the average pumping rate over the 72 hours of 49m3/day. The calculated values of transmissivity for the recovery data are presented below in Table 2. The transmissivity data from the recovery data is in agreement with the values determined from the pump test drawdown data, with transmissivity values of approximately 2m2/day (See Graph and Calculations in Appendix 2.4.8). Table 2: Transmissivity Values from Recovery Data from GW6PW Pumping Rate Late Mid Early Average m3/day T (m2/day) T (m2/day) T (m2/day) T (m2/day) 56.68 3.84 1.7 0.72 2.09 49.14 3.3 1.47 0.62 1.81 Analysis of drawdown data from observation well GW1D gave calculated transmissivity of 16 m2/day. Analysis of recovery data using the two pumping rates resulted in transmissivity values in general agreement with the values calculated using drawdown data, with values of 16.06 and 18.5 m2/day being calculated, as presented in Table 3. Table 3: Transmissivity values from recovery data at observation well GW1D

Pumping Rate Average m3/day T (m2/day) 56.68 18.5 49.14 16.06

A distance drawdown analysis was carried out by plotting the two data points on a semi-log plot (using 25 m as the steady drawdown for the pumping well and 1.53m as the maximum drawdown for GW1) the straight line intercepts the zero drawdown line at 19.6 m from the pumping well. This indicates that the zone of depression induced by pumping extends approximately 20m. While this is a correctly calculated value, it is most likely not a valid number given the very low drawdowns achieved. It does however demonstrate that the cone of depression is quite restricted in area due to the low Transmissivity of the bedrock aquifer. When a Jacob Straight Line analysis is applied, using the distance drawdown method using the maximum and averaged pumping rates over the test, the calculated transmissivity values of 0.76 and 0.88 m2/day (as presented in Table 4) are in general agreement with values calculated with the Jacob Drawdown and Recovery and Aslibekain Calculations above.

Table 4: Transmissivity Values from Distance Drawdown Analysis

Pumping Rate Average m3/day T (m2/day) 56.68 0.88 49.14 0.76

No appreciable drawdowns were detected in the other monitoring boreholes. While minor water level fluctuations occurred these cannot logically be related to the pumping well, with SWLs actually increasing (GW5D) and one well (GW4S) showing a decrease in water levels of 0.19 m and then an increase in water levels after 2000 minutes, halfway through the pumping period (see graphs in Appendix 2.4.8). Discussion of Results Although on-paper there is an order of magnitude difference between the calculated transmissivity values for Mid and Late pumping time values the numbers are only important in that they express that the transmissivity is low. The calculated transmissivity values for the pumping well of 0.2 m2/day (for drawdown) to 2 m2/day (for recovery) at GW6 and 16 m2/day (for drawdown) and 18.5m2/day (for recovery) at observation well GW1D are typical of the Waulsortian Limestone in the northern half of Ireland. These values concur with transmissivity values ranging from 0.3 to 115m2/day with a 50th Percentile value of 10m2/day (Aslibekian 1998) for the Waulsortian elsewhere in the Midlands. The consistency of the results allows for a high degree of confidence in the Transmissivity value presented as being in the region of 2 to 16 m2/day, with the transmissivity value of 2m2/day from the pumping well being the most representative of the aquifer.

APPENDIX 2.4.7 Pump Test Data

Pumping

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APPENDIX 2.4.8 Pump Test Calculation Sheets and Graphs

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