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Fishmeal Plant Reconfiguration Environmental Impact Statement Co ns en to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . Non Technical Summary Delivering Sustainable Solutions for our clients rpsgroup.com/ireland EPA Export 23-12-2014:23:06:04 UFI FISHMEAL PLANT RECONFIGURATION ENVIRONMENTAL IMPACT STATEMENT NON TECHNICAL SUMMARY DOCUMENT CONTROL REPORT United Fish Industries, Killybegs Project Title UFI Fishmeal Plant Reconfiguration Document Title Environmental Impact Statement – Non Technical Summary Document No. IBE0 721 This Document Comprises DCS TOC Text List of Tables List of Figures No. of Appendices 1 - - - - - Co ns en to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . Client Rev . Status Author(s) Reviewed By Approved By Office of Origin Issue Date 1 Final Ruth Barr Diarmuid O’Loan Dr Alan Barr Belfast March 2013 IBE0721.00/EIS EPA Export 23-12-2014:23:06:04 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary 1 INTRODUCTION 1.1 PROJECT SUMMARY United Fish Industries (UFI) is proposing to renovate and reconfigure their existing Fishmeal Plant located on Donegal Road at the entrance to Killybegs Town, Co Donegal. UFI is owned by Welcon AS, Europe’s largest manufacturer of marine proteins and oils servicing the aquaculture, pig and poultry feed sectors. The company operates six manufacturing facilities - Killybegs (UFI) in Ireland, Grimsby and Aberdeen in the UK and Bodø, Måløy and Karmsund in Norway. Origin Enterprises PLC, a subsidiary company of the Aryzta PLC, is a 50% shareholder of Welcon AS. ru se . The plant, which was built in 1957, produces low temperature and steam dried fishmeal for the agriculture and aquaculture industries as a feed material. High quality crude fish-oil is also produced which is used for the manufacture of products primarily for aquaculture consumption. to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he The fishmeal plant produces fishmeal and fish-oil primarily from trimmings (a waste product from the fish processing industry) and responsibly sourced whole fish unsuitable for human consumption in Ireland (boarfish). The use of fish trimmings represents a beneficial use of a by-product material. The current annual production of raw material is in the region of 70,000 tonnes. The maximum daily production is circa 800 tonnes/day. ns en It is proposed to renovate and reconfigure the existing plant in order: To make environmental improvements in order to meet the future requirements of the plant’s Integrated Pollution Prevention Control (IPPC) License conditions set by the EPA; • To invest in new technology in order to increase energy efficiency and thereby reduce energy costs; and • To increase the throughput of the raw material in order to achieve a higher quality product by increasing the maximum daily production capacity to circa 1,200 tonnes/day. It is not envisaged that there will be any significant increase in the annual production of fishmeal at the plant. The production will remain seasonal with peak production occurring during the winter and early spring. Co • The renovation and reconfiguration of the plant will take place largely within the ‘footprint’ of the existing plant. The plant will be encapsulated within a new outer cladding and roof. Minor changes will be made to the profile and height of the roof to accommodate the new equipment. Overall, an improvement to the aesthetics of the reconfigured plant is expected as a result of the proposed works. IBE0721.00/EIS NTS i EPA Export 23-12-2014:23:06:04 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary The proposed works will lead to water quality improvements within Killybegs Harbour. The existing method of direct scrubbing will be replaced by indirect scrubbing. This means that the cooling water discharged from with the plant will no longer be contaminated, other than giving rise to a small increase in temperature. The cooling water discharge will also be relocated, to ensure there is no significant environmental impact with respect to the raised temperature. The condensate produced by the indirect scrubbing process will be discharged via Donegal County Council’s new long sea outfall located in the outer Harbour. This Environmental Impact Statement (EIS) (and Non Technical Summary) is required by the Planning and Development Regulations 2001 has been prepared in support of the Planning Application for the proposed development submitted to Donegal County Council. The emissions from the plant are subject to the phased implementation of a separate IPPC Licence granted by the EPA. The proposed works will enable the long-term environmental conditions set by the EPA to be achieved. ot PROJECT JUSTIFICATION to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny 1.2 he ru se . It is proposed to commence the construction works in the Autumn 2013, subject to all statutory permissions being in place. The existing UFI Fishmeal and Fish-oil plant at Killybegs is now over 50 years old. Investment is needed in new technology to maintain the viability of the plant: Replace old equipment and inefficient processes need replaced; • Environmental improvements are required in order to meet the future requirements of the plant’s IPPC Licence conditions set by the EPA; • Energy improvements are required in order to reduce costs which will also benefit the environment from a lower carbon footprint. The proposed use of waste heat recovery and indirect steam drying is expected to reduce the plant’s energy usage by 15%; and • Increase the throughput capacity to process raw material in a more timely fashion to improve the quality of the fishmeal and fish-oil product. Co ns en • The proposed renovation and reconfiguration of the plant associated with this Planning Application and supporting EIS will enable UFI to achieve these goals and thereby maintain the viability of the plant. UFI are keen to put in place the investment required and to remain in Killybegs to maintain the cohesion of the workforce and also show their commitment to the town itself and the local region. UFI attach considerable importance to the retention and expansion of its expert and highly motivated staff in Killybegs. Currently the company employ circa 25 people with IBE0721.00/EIS NTS ii EPA Export 23-12-2014:23:06:04 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary another 10 seasonal staff at peak production times. Staff turnover is practically non-existent which speaks volumes about the loyalty of the workforce and commitment of management. 1.3 CONSIDERATION OF ALTERNATIVES The consideration of alternatives is an important requirement of the Environmental Impact Assessment (EIA) process. For the purposes of the EIA Regulations, alternatives may be described at three levels: • Alternative Locations • Alternative Designs • Alternative Processes 1.4 PLANNING PROCESS to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . Various alternatives were considered. Following an evaluation of alternative locations, designs and processes, it was determined that the preferred option, in terms of economic, social and environmental sustainability is to renovate and reconfigure the existing fishmeal and fish-oil plant at Killybegs. UFI’s proposal to renovate and reconfigure their existing fishmeal and fish-oil plant at Killybegs requires planning permission from Donegal County Council. Co ns en The application for planning permission will be made under the provisions of the Local Government (Planning and Development) Regulations 2001. The fifth schedule of the Planning and Development Regulations 2001 (SI No 600 of 2001) sets out a comprehensive list of project types, and development thresholds where relevant, subject to Environmental Impact Assessment for the purposes of the Regulations. The proposed reconfiguration and refurbishment of the UFI fishmeal plant fits under 7(h) Food Industry Projects of Part II of the Fifth Schedule: “All fish-meal and fish-oil factories” An Environmental Impact Assessment (EIA) is therefore required to be carried out for this project and an Environmental Impact Statement (EIS) submitted in support of the planning application to Donegal County Council. IBE0721.00/EIS NTS iii EPA Export 23-12-2014:23:06:04 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary 2.0 CONSULTATION PROCESS 2.1 INTRODUCTION The consultation phase of the Environmental Impact Assessment (EIA) is of utmost importance as it enables all concerned and interested parties to have their opinions on the project heard during the initial design stages of the project. This can allow changes to be made during the design stage taking on-board comments and ideas from the consultation process. A comprehensive consultation phase was conducted as part of the EIA for the proposed renovation reconfiguration of the existing UFI fishmeal and fish-oil plant at Killybegs. This chapter of the Environmental Impact Statement (EIS) reports on the various stages and findings of the consultation process. 2.2 STATUTORY AND RELEVANT BODIES CONSULTATION to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . Consultation meetings were held with the principal statutory consultees at the outset of the project. This consultation with statutory bodies continued throughout the EIA and particularly when potential issues were arising during the impact assessment phase. Key meetings which were held with the statutory bodies included the following: 6th June 2012 Meeting with technical staff of Donegal County Council (Meeting held in Public Services Building, Donegal Town) 15th October 2012 Meeting with official of Department of Agriculture, Food and the Marine (Meeting held at Landing Pier in Killybegs) Co ns en In addition to the above meetings, a letter and information on the proposed development was sent to all relevant statutory and non-statutory consultees. The statutory and non-statutory consultees consulted about the proposed development by letter are listed in Table 2.1 Table 2.1 Organisations/Agencies Consulted as Part of the EIA Process Organisation Department of Communication, Energy and Natural Resources Border Regional Authority Environmental Protection Agency Coillte Inland Fisheries Ireland (Ballyshannon) Department of Agriculture, Food and the Marine HQ An Taisce Health and Safety Authority Bord Gais Eireann Office of Public Works Bord na Mona Department of Education and Science Inland Fisheries Ireland HQ IBE0721.00/EIS NTS Department of Environment, Community and Local Government iv EPA Export 23-12-2014:23:06:04 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary Organisation Commissioners of Irish Lights Eircom Department of Transport, Tourism and Sport Geological Survey of Ireland Department of Arts, Heritage and the Gaeltacht Marine Institute An Comhairle Ealaion (The Arts Council) Killybegs Fishermen’s Organisation Birdwatch Ireland National Roads Authority Bord Iascaigh Mhara Department of Enterprise, Trade and Innovation Department of Health Department of Agriculture, Food and the Marine (Ballyshannon) Donegal County Council Electricity Supply Board 2.3 PUBLIC CONSULTATION to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . A public consultation event was held between 3rd - 7th December 2012 to inform the public about UF’Is plans to renovate and reconfigure the existing fishmeal and fish-oil plant. The event was advertised in the local press. Co ns en The consultations consisted of open sessions from Monday 3rd December to Friday 7th December between 11am and 4pm in the meeting room/reception area of the UFI fishmeal plant in Killybegs. Staff were on hand to give information about the proposed reconfiguration which was on display with layout drawings presented and written information about the EIA which was underway at the time. Members of the public were invited to come along and view the information and find out the plans at first hand. 2.4 CONCLUSIONS The various submissions and comments made in relation to the proposed fishmeal plant reconfiguration have been fully considered by the consultants in the preparation of the Environmental Impact Statement. Every effort has been made to address all of the concerns raised, and where possible, mitigation measures have been proposed to reduce the environmental impact of the development. IBE0721.00/EIS NTS v EPA Export 23-12-2014:23:06:04 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary 3 SITE DESCRIPTION 3.1 SITE LOCATION Co ns en to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . Killybegs is located in south west Donegal, approximately 26km from Donegal Town. Road access from Donegal Town is via the N56 (National Primary Road) and then the R263 to Killybegs (Regional Road). The location of Killybegs is shown in Figure 3.1. Figure 3.1 Killybegs Location Map The UFI fishmeal and fish-oil plant is located on the outskirts of Killybegs. The plant is located on the left hand side when approaching Killybegs from the Donegal Town direction and is situated approximately 1km from Killybegs town centre. The location of the UFI fishmeal and fish-oil plant is shown on Figure 3.2. 3.2 SITE CONTEXT AND EXISTING LAND USE The UFI fishmeal and fish-oil plant site occupies a site of 1.69 hectares (Plate 3.1). It is bounded to the East by Killybegs Harbour and to the West by the R263 Regional Road. There is a petrol station and commercial units in close proximity to the plant. There is also a housing development on elevated ground to the West of the site. IBE0721.00/EIS NTS vi EPA Export 23-12-2014:23:06:04 EIS – Non Technical Summary Figure 3.2 to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . UFI Fishmeal Plant Reconfiguration Location of UFI Fishmeal Plant in Killybegs Town Co ns en A rock armour revetment forms the barrier between the UFI Site and the sea along it’s coastal boundary. A palisade fence forms the barrier along the site’s land boundary. Plate 3.1 Existing Layout of UFI Fishmeal Plant, Killybegs The fishmeal and fish-oil plant comprise the following main elements: • Main Production Building – all the fishmeal and fish-oil production processes take place within this building. The fishmeal product is also stored in this building. • Office and administration buildings IBE0721.00/EIS NTS vii EPA Export 23-12-2014:23:06:04 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary • Raw material storage silos • Tank Farm (fish oil, diesel, heavy fuel, tallow, water) • DAF (effluent treatment) building – two DAF (dissolved air floatation) units are used to treat the process effluent prior to discharge to the Donegal County Council sewerage network. • Commercial Laboratory – the plant operates a laboratory (fully accredited with INAB Registration Number 075T) to monitor the quality of the process and effluent streams. It also provides a testing facility for local industry. • Maintenance building The existing site has the visual appearance of an industrial plant associated with the fishing industry. It has been a fixture in this present location in Killybegs for over fifty years.project Co ns en to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . description IBE0721.00/EIS NTS viii EPA Export 23-12-2014:23:06:05 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary 4 PROJECT DESCRIPTION 4.1 INTRODUCTION The fishmeal and fish oil processing plant in Killybegs has been amended and reconfigured internally in stages over the past 50 years and currently runs 2 parallel streams of processing equipment in different parts of the factory, having been installed at different times. Many items of plant are nearing the end of their effective life and a significant upgrade is now required. Such an upgrade will facilitate a more energy efficient process with less environmental impact – all in accordance with more stringent IPPC licence conditions (Integrated Pollution Prevention and Control Licence). The opportunity of reconfiguring and upgrading the plant and fabric of the enclosing buildings also provides environmental gain in terms of noise and odour emissions which UFI are keen to minimise. to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . In line with the more efficient process plant being proposed for the upgraded factory, the opportunity is being taken to increase the available daily throughput from 800 tonnes per day of raw material to 1200 tonnes per day. This increase will provide for the most efficient processing of the available material during times of low throughput but more crucially, will also allow faster throughput of raw material during peak processing between January and March to provide for the freshest production available. There are currently times when the existing plant struggles to cope with the daily throughput of raw material and fish must be held in silos as buffer storage awaiting processing. The proposed upgraded plant will reduce any possible negative impact on process quality during times of peak demand by allowing faster time of entry into the processing phase. Co ns en This proposal to increase production at the site by 50% on a daily throughput basis, will not necessarily increase annual production by the same amount. In fact, annual production will remain subject to quota restrictions and the available supply of whole fish and fish trimmings from the filleting industry. The 50% increase in daily throughput is required to enhance the freshness of the resulting meal and avoid backlogs of raw material being stored for several hours in holding silos. 4.2 SITE LAYOUT AND INFRASTRUCTURE 4.2.1 Proposed Upgrade Works It is proposed to redevelop and reconfigure the existing UFI Fishmeal Plant at Killybegs. Part of the existing process building will be re-clad and the roof raised to accommodate larger and more efficient process equipment in a single location. A single span, portal framed roof will be adopted in lieu of the several pitched roofs currently found in the building. The disparate layout of the existing process plant internally will be removed and a more concentrated and centralised layout will be adopted to maintain efficiency – less pumping and transporting distances required and better insulation of the building to avoid heat losses and dissipate internal noise. A significant part of the existing factory building will be demolished and rebuilt on a similar footprint to modern environmental standards with fully insulated panels to IBE0721.00/EIS NTS ix EPA Export 23-12-2014:23:06:05 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary minimise noise and odour leakages and provide a fully sealed roof. The new building development has a footprint of approximately 109m by 32m and a height of up to 15m from internal floor level - though the internal floor level is typically 2-3m below the roadside levels at the building – so the roadside building elevations appear lesser in height. The building will be constructed mainly from concrete base and ground beam, partial height blockwork or poured concrete walls with a steelwork frame sheeted with plastic coated double skin galvanized steel sheets. The steel sheets will be double skinned as this is a mitigation measure recommended by the noise impact assessment and will also provide best sealing from fugitive odours. Roller shutter doors or single pedestrian doors will be used to gain access to the main production area. The colour of the main cladding for the buildings will be silver or two shades of grey (for roof and walls) in keeping with other existing buildings around Killybegs Harbour and other fish processing plants in Killybegs. The cladding will be high quality, particularly on the nearest visible facades to the roadside to present a high quality façade. Co ns en to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . The fishmeal storage area located on the seaward side of the current buildings will be maintained and continue to operate as normal. However, a new meal outloading bay with roller shutter doors at each end to facilitate easy truck access is proposed on the seaward side of the current meal silos. This building will complement the existing buildings in height and roof pitch and will allow straightforward access when loading, compared with the current arrangement where trucks must reverse into a confined width bay. As the floor space of the existing process areas will be concentrated into a more efficient footprint, the remaining plant footprint (primarily at the north-eastern end of the plant) will be converted into meal storage bays with reinforced concrete walls and internal access from the current bulk silos. All meal is out-loaded via an enclosed building into enclosed bulk trailers or bagged and palleted for dispatch by flatbed lorry. The three existing chimneys at various locations over the building will be combined into a single multi-flue chimney at one location only, to minimise visual impact and allow efficient installation at one position. The height of the proposed chimneys will be maintained at 34m as per the existing chimneys and in line with the determination of air and odour quality modelling as outlined in the EIS The chosen location is at the rear of the building when viewed from the Donegal Road to minimise visual intrusion as far as possible. Similarly, the two separate waste heat extraction units which project through various parts of the current roofs will be combined into a single unit located on the seaward pitch of the new portal frame. It is intended that the new arrangement will provide cleaner lines and a less intrusive appearance to the skyline over the factory. The air treatment plant currently located at various locations surrounding the buildings will be rationalised into a single location between the main building and the liquid storage tanks (tank farm). This location is not readily visible from the Donegal Road and allows for the positioning of such air treatment equipment (which must be located outside) to be shielded from typical roadside views and maintain clean building lines and least visual interference from the main roadside views. Some existing external tanks and air scrubbing equipment will IBE0721.00/EIS NTS x EPA Export 23-12-2014:23:06:05 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary be removed – particularly those along the north east elevation which is a dominant view when approaching Killybegs. The proposed plant upgrade will also include a relocation of the existing seawater return outfall into Killybegs Harbour. The seawater is used as a source of cooling water to condense vapours at the evaporator stage. The current outfall runs only approx 80m from the coastline of the existing plant into the shallow inner part of the harbour, close to the alignment of the low tide mark. Returned seawater thus achieves low initial mixing at the present outfall. To upgrade this situation and in compliance with improvements required by the EPA under the plant’s proposed IPPC licence, a new location for the outfall has been proposed near the Landing Pier where deep water will allow for significant mixing of the returned seawater at all stages of the tide. se . It should be noted that direct condensing of vapours is presently employed in the current fishmeal plant whilst the proposed upgraded plant will use indirect condensing and have no cross-contamination of the seawater. The proposed plant will thus use seawater to absorb excess heat and is returned to the Harbour as warmed water only. Co ns en to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru The location of the returned seawater outfall is shown on the drawings and is located approx 80m to the east of the Landing Pier. The diffuser works and pipeline beyond the High Water Mark will require a Foreshore Licence from the Department of Agriculture, Food and the Marine. However, the pipeline and land based works to reach the coastline will require planning permission as part of this EIS. The proposed pipe route is aligned along the Donegal Road between the Fishmeal plant and the Harbour. The precise alignment of the pipe route will require detailed consideration and consultation with Donegal County Council Roads Section and service providers to avoid existing services. Such discussions would be scheduled pending successful outcome of this planning application. The existing operations in peripheral buildings and equipment will be maintained as per the existing plant operations. Thus no changes are planned for the garage, office building, tank farm, perimeter security fencing, external lighting, lorry wash or parking/storage areas. The proposed works are confined to the footprint of the main process plant only. External fire fighting provision will also be maintained as existing. There will also be no proposed works to the recently upgraded industrial pipework installed as part of the Killybegs Sewerage Scheme which now carries the separated effluent from the plant rather than returning it to the inner Bay. 4.3 CONSTRUCTION ACTIVITIES Construction and commissioning of the proposed upgraded fishmeal plant development is expected to take approximately 30 months to complete to allow partial ongoing processing whilst preliminary works are underway. The contractor is expected to move onto site in early summer 2013, so that completion of the plant is achieved by the end of 2015. This will enable IBE0721.00/EIS NTS xi EPA Export 23-12-2014:23:06:05 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary the plant to remain operational in phases so that the provision of services to the fish filleting industry is not withdrawn. The construction works will involve Civil Engineering works and Mechanical and Electrical works. The Contractor’s working hours on site will be related to the time of year and the need to sequence works to keep the existing plant partially operational. There will be certain periods of limited duration throughout the works when large items of plant will require to be lifted into place and large reach cranes will be employed. These will typically be located on the seaward side of the existing building footprint so minimise reach and keep the plant furthest from roadside views. In common with most construction works, certain operations which employ expensive plant may be undertaken around the clock for short durations. Co ns en to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . The buildings and the infrastructure required to service the development sites will be constructed using traditional building materials and techniques. Removal of existing cladding and demolition of the existing building will also be undertaken in phases to suit the phased construction programme – to allow for ongoing though restricted processing to be maintained during construction. IBE0721.00/EIS NTS xii EPA Export 23-12-2014:23:06:05 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary 5 SUMMARY OF IMPACTS AND MITIGATION MEASURES 5.1 INTRODUCTION This section summarises the impacts identified and measures required to mitigate against them, where necessary. The key impacts and mitigation measures identified in the EIS are summarised in Table 5.1. Table 5.1 Summary of Impacts and Mitigation Measures Topic Impact/Comment Mitigation Air and Climate - Potential for dust emissions - A dust minimisation plan will be prepared as part of the Construction Environmental Management Plan (CEMP). Mitigation measures will include measures such as: 1. any site roads with potential to give rise to dust will be regularly watered; ns en to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . Construction Phase Co - Potential for greenhouse gas emissions with the potential to cause climate change will arise from a number of sources. IBE0721.00/EIS NTS 2. wheel washes will be used to wash wheels before construction vehicles exit onto public roads; 3. site roads will be regularly cleaned and maintained as appropriate. - The design of the construction phase can be proactive in mitigating potential greenhouse gas emissions e.g. materials with a reduced environmental impact may be incorporated into the construction design through re-use of materials or incorporation of recycled material in place of conventional building materials. xiii EPA Export 23-12-2014:23:06:05 UFI Fishmeal Plant Reconfiguration Operation Phase EIS – Non Technical Summary - the predicted impact to air quality as a result of the proposed development is considered to be negligible. Once emission limits are maintained below the levels specified in the IPPC license, the impact will remain low. - No mitigation measures required. - In order to mitigate against future fugitives odour emissions, the existing odour management plan should continue to be implemented at the site as required by the IPPC license. - the impact to air quality in terms of odour will not have an adverse impact and will remain within the relevant guidelines for the protection of human health at the nearest sensitive receptors. Noise - short-term impact of noise during construction phase, but noise levels from works will be kept to within acceptable levels at noise sensitive locations for the duration of the contract. Mitigation measures to control noise levels will be specified as recommended in BS 5228 and shall include: - Use of good well maintained plant and where possible new plant manufactured under recent EC guidelines; - Substitution of unsuitable plant; - Maintenance of silencers and moving components. to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . Construction Phase Co ns en - Providing a response to queries raised by the local public. Operational Phase - Impact of night time working - if there are items of plant in use during night-time hours they will be chosen, sited and enclosed such that levels at the nearest residential properties do not exceed background levels. - There will be noise from the industrial workings of the plant both inside and outside the fishmeal plant. - Modifications will be made to the seawater tank to reduce its potential for noise production. - Noise modelling software has been used to predict the noise levels at locations outside the plant and at nearest residential properties. - Noise levels for the reconfigured plant will be within the levels specified in the EPA IPPC license for the fishmeal plant. IBE0721.00/EIS NTS - A responsible person, who will be present on site, will be made available to answer and act upon queries from the local public. - The façade of the newly reconfigured plant will act as a noise barrier due to the noise attenuation properties of the material its composed of. - the cumulative result of covering of the fish intake area and associated elements will make a positive impact on noise reduction at the plant also. xiv EPA Export 23-12-2014:23:06:05 UFI Fishmeal Plant Reconfiguration EIS – Non Technical Summary Roads and Traffic Construction Phase - there will be no significant impact on surrounding highway network. - No mitigation measures required. Operational Phase - The maximum percentage impact upon the adjoining highway network (R263) during both the AM and PM peak hour periods is expected to be less than 1%. The traffic assessment concluded that the operational traffic will have no significant impact on the surrounding road network. - No mitigation measures required. Construction Phase - The impact of construction plant and machinery will be short-term in duration. - Good site design, use of an environmental management plan during the construction phase and general site housekeeping will help to minimise visual impact during the construction phase. Operational Phase - The reconfiguration of the fishmeal plant will improve the present appearance of the fishmeal plant and will significantly enhance the external appearance of the UFI plant. It is recommended that the following is used as a mitigation measure to ensure the reconfigured plant integrates into the landscape: to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ot he ru se . Landscape and Visual - careful integration of constructed elements with existing elements such as roads and building sites. Co Water - appropriate materials and colours of buildings; ns en - A total of eight viewpoints were assessed and no significant visual impacts will occur at any of the viewpoints as a result of the reconfigured plant. - sensitive use of construction materials; Cooling Water Discharge - the reconfigured plant will use a system called “indirect scrubbing” which means that the cooling water is not in direct contact with the contaminants. The discharge to Killybegs Harbour will satisfy the requirements of the Freshwater Fish Life Directive. The proposed cooling water discharge will have no significant detrimental impact on the receiving waters of Killybegs Harbour and environ. - No mitigation measures required. Treated Effluent Discharge - The quantity and quality of effluent to be discharged to Outer Killybegs Harbour via the Council’s long-sea outfall has been agreed with Donegal County Council and is in full compliance with the conditions specified by the Foreshore License and national legislation which are set to safeguard the local marine environment. - No mitigation measures required. IBE0721.00/EIS NTS xv EPA Export 23-12-2014:23:06:05 UFI Fishmeal Plant Reconfiguration Flood Risk EIS – Non Technical Summary - The assessment of flood risk shows that the proposed floor levels are significantly high not to be at risk from coastal flooding. - No mitigation measures required. Flora and Fauna - There is no significant impact on flora and fauna expected. The plant is not located within a Natura 2000 Site. There will be no impact from the proposed works on any Natura 2000 sites. - No mitigation measures required. Fisheries - The proposed cooling water discharge satisfies the requirements of the EU Freshwater Fish Life Directive. The proposed cooling water discharge will have no detrimental impact on the receiving waters of Killybegs Harbour and environs or on migratory fish passing to and from Bungosteen (Stragar) River. - No mitigation measures required. - The reconfigured plant will be more efficient in terms of water usage that the current plant. - The reconfigured plant will be more energy efficient and therefore will require 15% less energy. - No mitigation measures required. Flora and Fauna he ot to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny Electricity Supply ru se Water Supply . Material Assets - No mitigation measures required. - There will be a negligible impact on surrounding road network. - No mitigation measures required. Navigation and Moored vessels - There will be minimal impact during the construction of the outfall close to Landing Pier. - The Harbour Master will be kept informed at all times during construction period so as appropriate warnings can be put in place for pier users. Co ns en Road Infrastructure - The cooling water discharge will have no impact on moored vessels, pier infrastructure and vessels navigating through Killybegs Harbour. 5.2 - No mitigation measures required. INTERACTIONS This section describes the interactions between the various aspects of the environmental impact assessment of the proposed construction and operation of the harbour development at Bantry. This is a requirement of the European Community (Environmental Impact Assessment) (Amendment) Regulations, 1999. Table 5.2 identifies each chapter of the Environmental Impact Statement where the impacts or environmental effects of specific topics within the environmental statement interact between each other. Mitigating measures where necessary have been provided for in the appropriate chapter of the EIS. Please refer to the text below the table for a brief description of the interactions. IBE0721.00/EIS NTS xvi EPA Export 23-12-2014:23:06:05 UFI Fishmeal Plant Reconfiguration Table 5.2 EIS – Non Technical Summary Interactions between different EIA Topics (See text below for description of the interactions) Air and Climate Noise Roads and Traffic Landscape and Visual Water Material Assets Flora and Fauna Roads and Traffic A B Landscape and Visual None None None Water None None None None Material Assets None None None None Flora and Fauna None C None None se None None None ns en to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny None Interaction between Roads and Traffic and Air and Climate Co A ot he ru Noise . Air and Climate There is potential for a increase in traffic on the road network to have a negative impact on the air quality and also the local climate. B Interaction between Roads and Traffic and Noise The additional traffic generated during the construction phase and well as increased traffic during the operational phase has the potential to result in increased noise in the local area. C Interaction between Flora and Fauna and Noise There is interaction between flora and fauna and noise particularly in respect to risk of disturbance to birds. IBE0721.00/EIS NTS xvii EPA Export 23-12-2014:23:06:05