alexandra basin redevelopment project · document title: environmental liabilities risk assessment...
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Alexandra Basin Redevelopment Project
Environmental Liabilities Risk Assessment (ELRA)
September 2017
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
Ref: IBR0668 i Status: Final Rev A Date: September 2017
DOCUMENT CONTROL SHEET
Client: Dublin Port Company
Project Title: Industrial Emissions Licence P1022-01
Document Title: Environmental Liabilities Risk Assessment (ELRA)
Document No: IBR0668/Reports
This Document Comprises:
DCS TOC Text List of Tables List of Figures No. of Appendices
1 2 21 1 1 1
Rev. Status Author(s) Reviewed By Approved By Office of Origin Issue Date
F01 Final A McGinley D Doyle D Doyle Letterkenny 15/06/17
F02 Final Rev A A McGinley D Doyle D Doyle Letterkenny 28/09/17
Dublin Port Company
P1022-01
Environmental Liabilities Risk Assessment (ELRA)
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
Ref: IBR0668 ii Status: Final Rev A Date: September 2017
TABLE OF CONTENTS
1 INTRODUCTION ........................................................................................................................ 1
2 SCOPING ................................................................................................................................... 2
3 RISK IDENTIFICATION ............................................................................................................. 3
3.1 METHODOLOGY ................................................................................................................ 3
3.2 SITE OPERATION ............................................................................................................. 3
3.3 ENVIRONMENTAL SENSITIVITY ........................................................................................... 5
3.3.1 Groundwater ..................................................................................................... 5
3.3.2 Surface Water ................................................................................................... 6
3.3.3 Air Quality ......................................................................................................... 7
3.3.4 Natural Habitats and Protected Species .......................................................... 7
3.3.5 Human Beings .................................................................................................. 8
3.4 RISKS IDENTIFIED AT THE FACILITY .................................................................................... 8
4 RISK ANALYSIS ...................................................................................................................... 10
5 RISK EVALUATION ................................................................................................................. 17
6 COSTING ................................................................................................................................. 19
6.1 IDENTIFICATION OF THE WORST CASE SCENARIO .............................................................. 19
6.2 QUANTIFICATION AND COSTING ....................................................................................... 19
7 CONCLUSIONS ....................................................................................................................... 21
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
Ref: IBR0668 iii Status: Final Rev A Date: September 2017
LIST OF TABLES
Table 3.1 List of Risks Identified at the facility ........................................................................................ 8
Table 4.1 Risk Classification Table – Likelihood ................................................................................... 10
Table 4.2 Risk Classification Table – Consequence ............................................................................. 10
Table 4.3 Risk Analysis at the Facility ................................................................................................... 11
Table 5.1 Risk Evaluation ...................................................................................................................... 17
Table 5.2: Risk Matrix ............................................................................................................................ 18
Table 6.1: Quantification and Costing of Worst Case Scenario ............................................................ 20
LIST OF FIGURES
Figure 3.1 Process Flow Diagram for Treatment Activity ........................................................................ 4
APPENDICES
APPENDIX A Drawing
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
Ref: IBR0668 1 Status: Final Rev A Date: September 2017
1 INTRODUCTION
This report provides an Environmental Liabilities Risk Assessment (ELRA) for the Dublin Port Authority (DPC). This report has been completed in accordance with Condition 12.2.2 of Industrial Emission Licence P1022-01 for the treatment of contaminated dredge material for recovery in Berth 52/53 and Graving Dock #2
The ELRA and was conducted in accordance with the Environmental Protection Agency (EPA) Guidance on Assessing and Costing Environmental Liabilities (Draft), published in July 2013.
This ELRA will not deal with the underwriting of costs for remedial actions following closure as these costs are covered in the Closure, Restoration and Aftercare Management Plan (CRAMP) which has also been prepared in accordance with Condition 2.2.2.8 of Industrial Emission Licence P1022-01.
The report has been updated to take account queries from EPA following meeting on the 30/08/17 and request for information received (Reference RI008113)
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2 SCOPING
As per EPA guidance the ELRA should cover environmental risks leading to a potential or anticipated liability. Environmental risks will be deemed to cover all risks to: surface water, groundwater, atmosphere, land and human health.
Liabilities associated with closure are not considered in this ELRA as they have been covered in the Closure, Restoration and Aftercare Management Plan (CRAMP) which has also been prepared in accordance with Conditions of Industrial Emission Licence P1022-01.
Condition 12.2.2 of the licence P1022 states that the ELRA shall be reviewed as necessary to reflect any significant change on site and in any case every three years following initial agreement. Review results are to be notified as part of the AER.
DPC will be engaging a contractor to undertake the treatment of contaminated dredge material for recovery in Berth 52/53 and Graving Dock #2. Specific details of the proposed process will not be known until a contractor was appointed by DPC. The ELRA will be reviewed if required following the appointment of a contractor.
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
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3 RISK IDENTIFICATION
3.1 METHODOLOGY
The risk identification process involved;
The identification of site operations/processes that pose potential hazards to the environment,
The risks will focus on unplanned, but possible and plausible events occurring during the operational phase that could result in unknown liabilities.
The quantification and plausibility of the risks , and
The identification of potential environmental receptors at the facility.
A list of plausible risks was subsequently developed for the facility and is displayed in Table 4.
3.2 SITE OPERATION
An Environmental Impact Statement (EIS) for the Alexandra Basin Redevelopment (ABR) project has been completed. Best practice industry techniques will be used to treat the contaminated material yielded from the dredging of the Alexandra Basin West. Stabilisation/Solidification (S/S) is a remediation technology that reduces the mobility of contaminants. Immobilisation is achieved by reaction of contaminants with reagents to promote sorption, precipitation or incorporation into crystal lattices, and/or by physically encapsulating the contaminants1. The method produces a high strength monolith-like product that physically reduces the mobility and chemically binds contaminants to the produced matrix. The treated mass can then be recovered to serve as infill material. Following treatment the material will be placed in Graving Dock #2 and Berth 52/53 as a recovery activity, replacing the need to use virgin materials that would otherwise be required for the development.
1 Bone B.,et al (2004); Guidance on the use of Stabilisation/Solidification for the Treatment of Contaminated Soil Pollution .Environment Agency
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
Ref: IBR0668 4 Status: Final Rev A Date: September 2017
Figure 3.1 Process Flow Diagram for Treatment Activity
Discharge to Surface water
Note on Emissions Noise Dust Fugitive dust emission Gaseous Emissions Wastes
Raw material delivery
Dredged Contaminated Sediments
Boundary of treatment activity
Raw material delivery e.g. For ex situ S/S Additives Ordinary Portland cement (OPC), quicklime and pozzolanic materials, which include pulverised fuel ash (PFA) and granulated ground blast furnace slag (GGBS).
Ex situ stabilisation using process stabilisation. e.g Batching plant. Consisting of silos, premixing chamber, mixing chamber, belt feeding/ conveyors control room and unloading area or as proposed by appointed contractor .
Treated sediment will be off loaded by trucks or pumped
Waste Water Treatment Plant
Storage and preparation
Sediment Unloading, Screening and Dewatering if required
Sediments returned to process
Treated contaminated dredged material recovered for use as infill for Graving Dock #2, Berths’ 52/53 and adjacent area.
Monitoring Short Term Long Term
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3.3 ENVIRONMENTAL SENSITIVITY
This section identifies environmental receptors that have the potential to be affected by site operations at the facility. The sensitivity of potential environmental receptors will also be discussed and this will inform the impact severity or consequence of any identified risks. Environmental receptors at facility include;
Groundwater
Surface Water
Air Quality
Natural Habitats and Protected Species
Human Beings
3.3.1 Groundwater
Geological Society of Ireland published mapping indicates the site is underlain by Estuarine deposits which generally comprise sandy gravelly silt overlying low permeability Glacial Till deposits which generally comprise variable lithology, usually sandy, silty clay with pebbles, but can contain gravel-rich, or laminated sand layers. These are further underlain by bedrock of Limestone from the Calp Formation.
The Lower Carboniferous rocks that underlie the region have been classified by the Geological Survey of Ireland as “Locally Important Aquifer, bedrock which is moderately productive only in local zones”. These locally productive zones are due to the presence of more permeable strata that are encountered in different parts of the outcrop area due to substantial faults, fractures or fissures. The limited groundwater movement within the rock tends to be restricted to the weathered horizons or to non-extensive fractured zones. These zones tend to have a limited hydraulic continuity, low storage capacity and low potential yield. Groundwater levels beneath the site remain close to sea level and are affected by tidal variation.
Shallow groundwater at the site does not represent a sensitive receptor in its own right (due to the salinity and likely contamination); and the Aquifer associated with the Bedrock represents a sensitive receptor, however is protected by the low permeability Glacial Till. There are no ground water abstractions down gradient of the facility so there are no sensitive groundwater receptors.
A number of site investigations have been undertaken within Dublin Port's current estate. As part of the IE application process a site investigation was undertaken in January – February 2015 which comprised the advancement of nine boreholes to a maximum depth 18.45m.bgl. Boreholes were advanced around the two areas proposed for infilling (Appendix B). Four boreholes (BH1, BH2, BH4, and BH5) were advanced adjacent to Graving Dock No.2 and five boreholes (BH6, BH7, BH8, BH10 and BH12) were advanced adjacent to Berth 52/53. Boreholes were positioned to provide an insight into the geology, hydrogeology, geotechnical properties and groundwater quality.
Groundwater monitoring of the boreholes installed during the 2015 site investigation and of surface water upstream and downstream of Alexandra Basin has provided information on the background groundwater/surface water concentrations of contaminants. A complete set of ground and surface water monitoring data showing contaminant levels metals, PAHs and PCBs is presented in Appendix D of the site-specific detailed quantitative risk assessment.
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Arsenic exceeded the EU Surface Water Objective of 20µg/l in all groundwater samples during both monitoring rounds except BH1 – shallow, BH2 and BH4 (Round 2 only). Cadmium exceeded the EU Surface Water Objective of 0.2µg/l in three groundwater samples collected from adjacent to Graving Dock #.2 and one sample collected from adjacent to Berth 52/53 during monitoring round. Zinc exceeded the EU Surface Water Objective of 40µg/l in groundwater samples taken from BH4 and BH6 – deep both adjacent to Graving Dock #.2 in monitoring round one.
EU Surface Water Objective values do not exist for Petroleum Hydrocarbons or PAHs. A screening value for Petroleum Hydrocarbons of 10ug/l is generally accepted as an acceptable concentration protective of controlled waters. PAH screening values protective of controlled waters in the UK vary but are all generally no higher than 0.1ug/l. Using these as a baseline, elevated concentrations of hydrocarbons are present in boreholes adjacent to Graving Dock #.2 and Berth 52/53 during both monitoring rounds. Elevated levels of PAHs are present in three boreholes all adjacent to Berth 52/53 in monitoring round one and elevated PAHs are present in one borehole adjacent to Graving Dock #.2 and four boreholes adjacent to Berth 52/53 in monitoring round two.
The EU Surface Water Objective for Tributyl Tin of 0.0002ug/l was exceeded in three samples collected from adjacent to Graving Dock #.2 and six samples from boreholes adjacent to Berth 52/53.
3.3.2 Surface Water
The existing surface water drainage system at Dublin Port utilises silt traps/oil interceptors prior to discharge. This existing surface water drainage system will be decommissioned during the treatment and infilling works and reinstalled following the completion of the infilling works.
Surface water will be collected through a series of storm water drain networks from the infilled areas installed in the surfacing layer. The storm water drains will flow via an underground pipe network as shown in Drawings IBR0668/112 and 113.
Chapter 10 of the EIS provides details of the existing water quality in the vicinity of the proposed development. The available monitoring information for the water bodies in the immediate vicinity of the ABR Project (i.e. the Liffey Estuary Lower and Dublin Bay water bodies) indicates that:
the overall WFD status of the water bodies is ‘moderate’ due to general components and morphology;
tropic status is ‘unpolluted’;
dissolved oxygen levels are satisfactory and capable of supporting nearly all forms of aquatic life;
the level of oxygen demand in the water bodies is acceptable; and
the designated bathing areas in the vicinity of the ABR Project are compliant with bathing water quality standards.
There shall be no emissions to water of environmental significance. A detailed quantitative risk assessment (DQRA) has been undertaken to assess the potential impact of available contamination within the dredgings to the quality of controlled waters receptors. Remedial Target Concentrations (RTC’s) have been set based on EU Surface water and EU Groundwater Objectives for certain parameters.
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3.3.3 Air Quality
There will be no point source emission points to air during Construction from the S/S treatment process and in the aftercare phase from the infilled areas.
3.3.4 Natural Habitats and Protected Species
Natural Habitats
The Alexandra Basin Redevelopment (ABR) Project including its capital dredging scheme will take place within the Liffey Estuary and Dublin Bay.
There are two designated Special Protection Areas (SPA) for birds in the vicinity of the proposed development and a further six SPAs on the wider Dublin coastline, that could have connectivity with the proposed development area. These SPAs are:
South Dublin Bay and River Tolka Estuary (site code 004024)
North Bull Island (site code 4006)
Skerries Islands (site code 4122)
Rockabill (site code 4014)
Lambay Island (site code 4069)
Ireland’s Eye (site code 4117)
Howth Head (site code 4113)
Dalkey Island (site code 4172)
The proposed Alexander Basin redevelopment does not lie within any statutory sites designated for nature conservation. Six Natura 2000 sites and two Ramsar sites lie within km of the development:
North Dublin Bay cSAC (Site Code: 000206);
South Dublin Bay cSAC (Site Code: 000210);
North Bull Island SPA (Site Code: 004006);
South Dublin Bay and River Tolka Estuary SPA (Site Code: 004024);
Sandymount Strand/Tolka Estuary: Ramsar Site (Site Code:832);
North Bull Island: Ramsar Site (Site Code: 406).
No Natural Heritage Areas or proposed NHAs are considered to be potentially affected by the proposed development.
The emissions to surface water and groundwater from the facility will discharge directly into Liffey Estuary and Dublin Bay.
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Protected species
Chapter 5 of the EIS assesses the impact of the proposed development on the natural environment in terms of birds, marine mammals, terrestrial ecology and marine ecology (including fisheries).
Alexandra Basin West was found to be;
Artificial surfaces and sea walls, piers and jetties - The terrestrial component of this habitat (buildings and artificial surfaces) is of low importance and rarity at a local scale and is therefore of ‘negligible’ ecological value.
Exposed sand, gravel or till, spoil and bare ground - The terrestrial component of this habitat is of low to medium importance and rarity at a local scale and is therefore of ‘low’ ecological value.
Berth 52/53 was found to be;
Exposed sand, gravel or till , spoil and bare ground - This habitat has low to medium importance at a local scale due to the continued arrival of broadleaved herbs, providing foraging habitat for invertebrates, particularly bees. The terrestrial component of this habitat is of low to medium importance and rarity at a local scale and is therefore of ‘low’ ecological value.
3.3.5 Human Beings
Human beings will not be exposed to the treated contaminated sediment as the material will be covered with concrete hard-standing thereby negating any direct contact, ingestion or inhalation pathways.
Noise levels will be monitored as part of the IE licence as required and comply with the required noise emission limits for day and night time hours.
3.4 RISKS IDENTIFIED AT THE FACILITY
Proposed S/S operations on site where reviewed in relation to site operation, operator performance and environmental sensitivity to determine the potential for environmental liabilities to arise. The risks presented in Table 3.1 have been identified at the facility. The list includes all plausible risks that are considered possible at the facility.
Table 3.1 List of Risks Identified at the facility
Risk ID Process Potential Hazards/Risks
1 Unloading of Dredged Material
Uncontrolled or poorly controlled release of dredge spoil during unloading
2 Material intake Contaminated dredgings delivered to site generating contaminating effluent
3 Material intake Contaminated dredgings delivered to site generating dust
4 Raw Material Storage Wind borne dust dispersion
5 Raw Material Storage Discharge to soil/groundwater/surface water
6 S/S Process Plant Wind borne dust dispersion
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Risk ID Process Potential Hazards/Risks
7 S/S Process Plant Fire in treatment area
8 Process oil storage Oil leak to ground
9 Process oil storage Oil spill during filling of equipment or drums
10 Fuel (diesel) storage Fuel leak to ground
11 Fuel (diesel) storage Fuel spill during vehicle refuelling/tank refilling
12 Material output Fuel/oil leak from collection truck
13 Material output Overfill of trucks
14 Infilling Treated material unsuitable for recovery infilled. Discharge to surface water/groundwater
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4 RISK ANALYSIS
Potential hazards identified in Table 3.1 are assessed against the Risk Classification Tables (RCT) in Tables 4.1 and 4.2. The RCT’s were designed to reflect the levels of risk appropriate to the facility. Ratings, taken from the risk classification table, were applied to the severity and likelihood of occurrence of each risk. A risk score was calculated for each risk using the ratings.
The Risk Classification Tables (RCT) were designed to reflect the levels of risk appropriate to the facility. The RCT provides likelihood and consequence for the ranking of risks on a qualitative basis.
Table 4.1 Risk Classification Table – Likelihood
Rating Likelihood
Category Description
1 Very Low Very low chance of hazard occurring
2 Low Low chance of hazard occurring
3 Medium Medium chance of hazard occurring
4 High High chance of hazard occurring
5 Very High Very high chance of hazard occurring
Table 4.2 Risk Classification Table – Consequence
Rating Consequence
Category Description
1 Trivial No damage or negligible change to the environment.
2 Minor Minor impact/localised or nuisance
3 Moderate Moderate damage to environment
4 Major Severe damage to local environment
5 Massive Massive damage to a large area, irreversible in medium term
Table 4.3 sets out the risk analysis register for those risks identified in Table 3.1 against the criteria in Tables 4.1 and 4.2. This risk analysis is carried out based on the current mitigation controls in place at the time of the assessment.
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Table 4.3 Risk Analysis at the Facility
Risk ID
Process Potential Risks Environmental
effect Consequence
Rating Basis of Consequence
Likelihood Rating
Basis of Likelihood Risk Score
(Consequence x Likelihood)
1 Un loading of Dredged Material
Uncontrolled or poorly controlled release of dredge spoil during unloading
Discharges to air, ground and surface water.
3 Air release with human health impacts. Contaminated water release to locally important aquifer not supplying drinking water in the locality. Contaminated water release to Liffey Estuary and Dublin Bay. The WFD status of both the Liffey Estuary Lower and Dublin Bay water bodies was reported as ‘moderate’ in the final status classifications reported in 2011.
2 A suite of Construction Phase Management Plans will be prepared in association with the preferred Contractor(s) in accordance with the Construction environmental Management Plan (CEMP). These Management Plans will reflect any conditions imposed by ABP and EPA and will be agreed with DPC and the relevant competent authorities. For the S/S project these will include • Traffic Management Plan • Site Waste Management Plan • Noise Management Plan • Dust & Odour Management Plan • Water Quality Management Plan • Waste Acceptance Management Plan
6
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Risk ID
Process Potential Risks Environmental
effect Consequence
Rating Basis of Consequence
Likelihood Rating
Basis of Likelihood Risk Score
(Consequence x Likelihood)
2 Material intake
Contaminated dredgings delivered to site generating contaminating effluent
Discharges to ground and surface water.
3 Air release with human health impacts. Low volume contaminated water release to locally important aquifer not supplying drinking water in the locality. Low volume contaminated water release to Liffey Estuary and Dublin Bay.
2 As above 6
3 Material intake
Contaminated dredgings delivered to site generating dust
Discharges to air, ground and surface water.
3 Air release with human health impacts. Low volume contaminated water release to locally important aquifer not supplying drinking water in the locality. Low volume contaminated water release to Liffey Estuary and Dublin Bay.
1 As above 3
4 Raw Material Storage
Wind borne dust dispersion
Discharges to air, ground and surface water.
2 Air release with human health impacts. Low volume contaminated water release to locally important aquifer not supplying drinking water in the locality. Low volume contaminated water release to Liffey Estuary and Dublin Bay.
1 As above 2
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Risk ID
Process Potential Risks Environmental
effect Consequence
Rating Basis of Consequence
Likelihood Rating
Basis of Likelihood Risk Score
(Consequence x Likelihood)
5 Raw Material Storage
Discharge to soil/groundwater/surface water
Potentially contaminating effluent discharged to surface water.
3 Air release with human health impacts. Contaminated water release to locally important aquifer not supplying drinking water in the locality. Contaminated water release to Liffey Estuary and Dublin Bay.
2 As above 6
6 S/S Process Plant
Wind borne dust dispersion
Discharges to air, ground and surface water.
2 Air release with human health impacts. Low volume contaminated water release to locally important aquifer not supplying drinking water in the locality. Low volume contaminated water release to Liffey Estuary and Dublin Bay.
2 As above 4
7 S/S Process Plant
Fire in treatment area
Discharges to air, ground and surface water.
3 Air release with human health impacts. Contaminated water release to locally important aquifer not supplying drinking water in the locality. Contaminated water release to Liffey Estuary and Dublin Bay.
2 As above 6
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Risk ID
Process Potential Risks Environmental
effect Consequence
Rating Basis of Consequence
Likelihood Rating
Basis of Likelihood Risk Score
(Consequence x Likelihood)
8 Process oil storage
Oil leak to ground
Hydrocarbon discharge to ground and surface water
3 Low volume contaminated water release to locally important aquifer not supplying drinking water in the locality. Low volume contaminated water release to Liffey Estuary and Dublin Bay.
1 Oil will be stored in bunded area or self bunded double-skinned storage tank. Spill kits will be available. Oil interceptor installed in surface water drainage system.
3
9 Process oil storage
Oil spill during filling of equipment or drums
Hydrocarbon discharge to ground and surface water
2 Low volume contaminated water release to locally important aquifer not supplying drinking water in the locality. Low volume contaminated water release to Liffey Estuary and Dublin Bay.
2 Oil will be stored in bunded area or self bunded double-skinned storage tank. Spill kits will be available. Oil interceptor installed in surface water drainage system. If refilling/refuelling occurs outside of bund. SOP will be in place. Spill trays will be provided.
4
10 Fuel (diesel) storage
Fuel leak to ground
Hydrocarbon discharge to ground and surface water
3 Low volume contaminated water release to locally important aquifer not supplying drinking water in the locality. Low volume contaminated water release to Liffey Estuary and Dublin Bay.
1 Oil will be stored in bunded area or self bunded double-skinned storage tank. Spill kits will be available. Oil interceptor installed in surface water drainage system.
3
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Risk ID
Process Potential Risks Environmental
effect Consequence
Rating Basis of Consequence
Likelihood Rating
Basis of Likelihood Risk Score
(Consequence x Likelihood)
11 Fuel (diesel) storage
Fuel spill during vehicle refuelling/tank refilling
Hydrocarbon discharge to ground and surface water
2 Low volume contaminated water release to locally important aquifer not supplying drinking water in the locality. Low volume contaminated water release to Liffey Estuary and Dublin Bay.
2 Oil will be stored in bunded area or self bunded double-skinned storage tank. Spill kits will be available. Oil interceptor installed in surface water drainage system. If refilling/refuelling occurs outside of bund. SOP will be in place. Spill trays will be provided.
4
12 Material output
Fuel/oil leak from collection truck
Hydrocarbon discharge to ground and surface water
2 Low volume contaminated water release to locally important aquifer not supplying drinking water in the locality. Low volume contaminated water release to Liffey Estuary and Dublin Bay.
3 Spill kits provided on site. Hard standing cover at site. Oil interceptor installed in surface water drainage system. Vehicle service
6
13 Material output
Overfill of trucks Discharges to air, ground and surface water.
2 Low volume contaminated water release to locally important aquifer not supplying drinking water in the locality. Low volume contaminated water release to Liffey Estuary and Dublin Bay.
3 SOP will be in place. Spill kits provided on site. Hard standing cover at site. Oil interceptor installed in surface water drainage system.
6
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
Ref: IBR0668 16 Status: Final Date: September 2017
Risk ID
Process Potential Risks Environmental
effect Consequence
Rating Basis of Consequence
Likelihood Rating
Basis of Likelihood Risk Score
(Consequence x Likelihood)
14 Infilling Treated material unsuitable for recovery infilled. Discharge to groundwater
Potentially contaminated water discharge to ground water
4 Contaminated water release to locally important aquifer not supplying drinking water in the locality.
2 Specification based contract. Q&C Testing procedures in place.
8
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
Ref: IBR0668 17 Status: Final Rev A Date: September 2017
5 RISK EVALUATION
Based on the risk analysis carried out in Table 4.3, the risks have been prioritised to identify the risks with the highest profile and allow for prioritisation of risk treatment. The prioritised risks are presented in Table 5.1. The risk evaluation table highlights that the highest priority risk treated material unsuitable for recovery infilled.
Table 5.1 Risk Evaluation
Risk ID Process Potential Risk Consequence
Rating Likelihood
Rating Risk Score
14 Infilling Discharge to groundwater 4 2 8
1 Unloading of Dredged Material
Uncontrolled or poorly controlled release of dredge spoil during unloading
3 2 6
2 Material intake Contaminated dredgings delivered to site generating contaminating effluent
3 2 6
5 Raw Material Storage
Discharge to soil/groundwater/surface water
3 2 6
7 S/S Process Plant
Fire in treatment area 3 2 6
12 Material output Fuel/oil leak from collection truck 2 3 6
13 Material output Overfill of trucks 2 3 6
6 S/S Process Plant
Wind borne dust dispersion 2 2 4
9 Process oil storage
Oil spill during filling of equipment or drums
2 2 4
11 Fuel (diesel) storage
Fuel spill during vehicle refuelling/tank refilling
2 2 4
3 Material intake Contaminated dredgings delivered to site generating dust
3 1 3
8 Process oil storage
Oil leak to ground 3 1 3
10 Fuel (diesel) storage
Fuel leak to ground 3 1 3
4 Raw Material Storage
Wind borne dust dispersion 2 1 2
14 Infilling Treated material unsuitable for recovery infilled. Discharge to groundwater
4 2 8
In addition to the risk evaluation table in Table 5.1, a risk matrix has been developed to allow the risks to be easily displayed. The consequence and likelihood ratings are used in the matrix with the level of consequence forming the x-axis and the likelihood forming the y-axis. This matrix provides a visual tool for regular risk reviews since the success of mitigation can be easily identified. The risk matrix is displayed in Table 5.2.
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
Ref: IBR0668 18 Status: Final Rev A Date: September 2017
The risks have been colour coded in the matrix to provide a broad indication of the critical nature of each risk. The colour code is as follows;
Red – These are considered to be high-level risks requiring priority attention.
Amber – These are medium-level risks requiring treatment, but are not as critical as a red coded risk.
Green – These are the lowest-level risks and indicate a need for continuing awareness and monitoring on a regular basis. Whilst they are currently low or minor risks, some have the potential to increase to medium or even high-level risks and must therefore be regularly monitored and if cost-effective mitigation can be carried out to reduce the risk even further this should be pursued.
The Risk Matrix indicates that there are no risks in the red zone requiring priority treatment. There is 1 risk in the amber zone requiring treatment through mitigation or management action. The risk in the amber zone is related to the treated dredge material.
A site-specific DQRA of the likely source – pathway – receptor pollutant linkages has been undertaken in line with guidance and best practice in order to quantify the significance of leachable contamination identified in the treated dredged material upon the quality of controlled waters, specifically the River Liffey as agreed with the EPA. Remedial Target Concentrations (RTC’s) have been derived for the treated dredged material. Therefore the risk of activities causing pollution to ground, groundwater and surface water is very low.
The remaining 13 risks are located in the green zone indicating the need for continuing awareness and monitoring on a regular basis. However, assessment of the green zone risks has indicated that a number of these risks can be reduced through the implementation of mitigation measures. These risk treatment measures should be adopted where considered cost-effective to further reduce the risks.
Table 5.2: Risk Matrix
V. High 5
Likelihood High 4
Medium 3 12,13,11
Low 2 6,9 1,2,3,5,7 14
V. Low 1 4 8,10
Trivial Minor Moderate Major Massive
1 2 3 4 5
Consequence
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
Ref: IBR0668 19 Status: Final Rev A Date: September 2017
6 COSTING
6.1 IDENTIFICATION OF THE WORST CASE SCENARIO
Section 5 of this report represents the risk analysis for the proposed treatment of dredge material for recovery in Berth 52/53 and Graving Dock #2 and ranks all risks in descending order of risk score (refer Table 5.1).
The risk with the highest risk score relates to Risk Id 14, treated material unsuitable for recovery infilled resulting in discharge to groundwater. In this case the likelihood of the event is considered “low” given the proposed controls but the consequence of such an event is deemed “major”.
The IE Licence and planning permission will have number of conditions which must be adhered to which will reduce the potential for the failure in this case.
6.2 QUANTIFICATION AND COSTING
The worst case scenario as described above has been developed to allow for a meaningful quantification of the potential costs that would be incurred following an extreme event at the facility. The assumptions that have been employed in this scenario are outlined in the paragraphs below.
The following assumptions are included in this costing:
A field test of proposed S/S method will be undertaken. The objectives of the field test are to demonstrate and verify the applicability of the S/S method with respect to:
o environmental properties of the treated dredge material. o geotechnical properties of the treated dredge material o effects on the surrounding environment and: o the process stabilisation technology to be used
The field test will be performed by the appointed contractor and will form a base to the design and execution of the main S/S process to be undertaken. Approximately 3-5000 m3 of dredged material will be treated in the field test. This will allow the method to be refined before the main works are undertaken. It is assumed that treated material unsuitable for recovery infilled resulting in discharge to groundwater occurs during the undertaking of the field test (worst case scenario).
A ground investigation consisting of soil and groundwater sampling will be undertaken to verify that no contamination from the infilling has been discharged to ground. It is assumed existing boreholes installed as part of the IE application process will be sufficient to investigate potential ground contamination.
It is assumed treated dredge material is hazardous and will not be able to go to a non hazardous landfill. Is it assumed that all clean-up works will be undertaken by third party operators and not by DPC.
Cost for Remediation of ground/groundwater contamination is included in the 15 % contingency figure
Table 6.1 presents an estimation of the costs associated with controlling, cleaning, remediating and monitoring the pollution caused by this scenario. A significant contingency has been added to the costing to ensure that any uncertainty in the assessment is adequately covered.
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
Ref: IBR0668 20 Status: Final Rev A Date: September 2017
Table 6.1: Quantification and Costing of Worst Case Scenario
Task Description Quantity (No.) Measurement
Unit
Unit Rate
(€)
Cost
(€)
Risk ID 14 Infilling
Excavation of treated dredge material 31252 m3 128 400,000
Disposal gate fee for of treated dredge material (includes transport) 3125 m3 216
675,000.00
Consultancy costs 20 days 600 12,000
Waste sampling and analysis (WAC suite ) 6 samples 400 2,400
Groundwater sampling and analysis 12 samples 300 3,600
Environmental report 1 event 5000 5,000
Remediation of ground/groundwater contamination 1
Included in Contingency
Total (€) 1,098,000.00
Contingency (%) 15%
Total including contingency(€) 1,262,700.00
2 Estimated volume for excavation 3,125m3 (5,000 tonnes).
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
Ref: IBR0668 21 Status: Final Rev A Date: September 2017
7 CONCLUSIONS
An Environmental Liabilities Risk Assessment (ELRA) has been completed by Dublin Port Company in accordance with Condition 12.2 of the Licence. The ELRA was carried in accordance with the Environmental Protection Agency (EPA) Guidance on Assessing and Costing Environmental Liabilities (Draft), published in July 2013.
Risk identification for the site identified 14 risks that could potentially impact the surrounding environment and risk analysis and evaluation ascertained that treated material unsuitable for recovery infilled was the risk with the highest risk score.
The worst case scenario underwent quantification and costing and a financial provision of €1,262,700 (including contingency) was calculated based on this event.
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Dublin Port Company Environmental Liability Risk Assessment P1022-01
Ref: IBR0668 Status: Final Rev A Date: September 2017
APPENDIX A
DRAWING
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Ro Ro No.4
Bulk Jetty
Alexandra Quay West
TOLKA QUAY ROAD
ES
Warehouse
Port
Centre
J
e
t
t
y
Jetty
ALEXANDRA
BASIN
HW
M
H
ES
ES
LS
Platform
Coal Yard
Freight Terminal
W
B
Tank
WB
Area under construction
Car Park
Area under construction
WM
Transit Shed
Grain Store
Tank
WB
Tanks
Tanks
Overhead C
onveyor
WB
Overhead
Passage
Chy
Overhead
Conveyor
Overhead
Conveyor
C
ra
n
e
R
a
il
Tanks
Tanks
Oil Installations
Tanks
Tks
Dock Gates
ALEXANDRA BASIN
North Wall
Graving
Dock
Dock Gates
ALEXANDRA QUAY
QU
AY
2
RO
AD
RO
AD
BR
AN
CH
TOLKA
1
NO
RT
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op-up B
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op-up B
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225Ø
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150Ø
225Ø
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6
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AREA REQUIRES WALK-AROUND CHECK.
AREA REQUIRES WALK-AROUND CHECK.
Pump House
150Ø
300Ø
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.V.
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150Ø
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300Ø
300Ø
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125124
106
123
112
122
163
120
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1
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OBSOLETE
600mmØ
180mmØ
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0
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180mmØ
450mmØ
ALEXANDRA
ROAD D.M.A
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DU
ND
AN
T
RE
DU
ND
AN
T
RE
DU
ND
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3
0
0
m
m
Ø
6
0
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m
m
Ø
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8
0
m
m
Ø
300mmØ
ENLARGED VIEW
150Ø
150Ø
150Ø
WM
225Ø
150Ø
WM
100Ø
150Ø
SV Dom.
75Ø
Fire Service
EXISTING OUTFALLUNPLUGGED AND EXTENDEDTO FACE OF PROPOSEDQUAY WALL
EXISTINGINTERCEPTOR
EXISTING DRAINAGE DIVERTED THROUGH NEWFULL RETENTION INTERCEPTORS TO DISCHARGETHROUGH FLAP VALVE VIA QUAY WALL
EXISTING OUTFALLEXTENDED TO FACE OFPROPOSED QUAY WALL
EXISTING OUTFALL SYSTEMRELOCATED TO SUIT AIDPOSITION OF LINKSPAN.POSITION TO BEDETERMINED AT DETAILEDDESIGN STAGE
PROPOSED FULLRETENTIONINTERCEPTOR
NEW DRAINAGE DISCHARGESOUT THROUGH FULLRETENTION INTERCEPTOR
DRAINAGE FROMCONSERVATIONZONE A
NEW DRAINAGE THROUGHGRAVING DOCK Nr 2DISCHARGES THROUGH FULLRETENTION INTERCEPTORAND PASSES THROUGH FLAPVALVE THROUGH QUAY WALL
FULL RETENTION INTERCEPTORS TO DISCHARGE
Drawing Number
Drawing Status Sheet Size
Client
Rev
Drawing Scale
drawnamendmentsrev
Project
Title
date
/
Dublin Port Authority
Initial ReviewProject Leader Drawn By Date
Alexandra Basin Redevelopment
Proposed Drainage - Graving Dock Nr 2
Preliminary
Mar '15
1:10,000
IBR0668
A3
112 0
DD AMB AMcG
1. Verifying Dimensions.The contractor shall verify dimensions against such otherdrawings or site conditions as pertain to this part of the work.
2. Existing Services.Any information concerning the location of existing servicesindicated on this drawing is intended for general guidance only. Itshall be the responsibility of the contractor to determine and verifythe exact horizontal and vertical alignment of all cables, pipes, etc.(both underground and overhead) before work commences.
3. Issue of Drawings.Hard copies, dwf and pdf will form a controlled issue of thedrawing. All other formats (dwg, dxf etc.) are deemed to be anuncontrolled issue and any work carried out based on these files isat the recipients own risk. RPS will not accept any responsibilityfor any errors arising from the use of these files, either by humanerror by the recipient, listing of un-dimensioned measurements,compatibility issues with the recipient's software, and any errorsarising when these files are used to aid the recipients drawingproduction, or setting out on site.
NOTES
4. Datum: All Coordinates in metres and relative to ITM
5. Keys
RPS Consulting Engneers
Enterprise Fund Business Centre
Ballyraine
Letterkenny
Co. Donegal
+353 (0) 74 91 61927
+353 (0) 74 91 61928
W www.rpsgroup.com/ireland
Proposed IED Site Boundary
100m SCALE 1:10 000
Proposed Drainage Line - Graving Dock Nr 2
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EPA Export 21-12-2017:03:49:50
Ro`Ro No.5
5
Berth No.52
Berth No.53
Ro Ro No.1
7
Ro Ro No.7
Ro Ro No.8
Mh
R
a
m
p
WB
Ramp
Elevated R
am
p
WB
Tank
WB
Ferry
Terminal
WB
Freight Terminal
Car Park
Ram
p
Freight Terminal
LS
TE
RM
IN
AL R
OA
D N
OR
TH
Jetty
MP
Mooring P
osts
Sluice
Jetty
Pier
MP
Sluice
HWM
H
W
M
HWM
HWM
HW
M
HW
M
HW
M
Mh
Car Park
Car Park
Ramp
Tank
Pla
tform
Elevated Ramp
Beacon
Beacon
DUBLIN PORT PASSENGER TERMINAL
Pier
LW
M
Dolphin
Concrete
HWM
TE
RM
IN
AL R
OA
D S
OU
TH
ALEXANDRA ROAD EXTENSION
ALEXANDRA ROAD
225Ø
300Ø
3
0
0
Ø
150Ø
900Ø
300Ø
300Ø
300Ø
350Ø
TANK
300Ø
225Ø
300Ø
300Ø
450Ø
300Ø
225Ø
225Ø
525Ø
300Ø
450Ø
375Ø
300Ø
300Ø
300Ø
450Ø
300Ø
525Ø
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300Ø
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600Ø
5
2
5
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300Ø
525Ø
6
0
0
Ø
INT.
675Ø
450Ø
750Ø
750Ø
450Ø
750Ø
INT.
900Ø
900Ø
9
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IN
T.
150Ø
150Ø
150Ø
150Ø
225Ø
225Ø
225Ø
INT.
2
0
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900Ø
4
5
0
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SLUICE VALVE
FISH TAIL
PUMP STATION
225Ø
300Ø
3
0
0
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150Ø
300Ø
300Ø
300Ø
350Ø
TA
NK
300Ø
2
2
5
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INT.
150Ø 150Ø 100Ø
150Ø
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2x50Ø
150Ø
150Ø
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ENLARGED VIEW
200Ø
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1
5
0
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300Ø
300Ø
200Ø DPC/225ØAS BUILT
300Ø
300Ø
300Ø
300Ø
300Ø
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100Ø
100Ø
100Ø
100Ø
1
0
0
Ø
?
DOES A MAIN
EXIST THRO' SITE
45
46
47
44
4342
49
50
51
39
40
41
48
52
53
56
58
57
54
55
59
60
61
62
63
35
36
37
38
IRISH
FERRIES
D.M.A
STENA
LINE
D.M.A
200Ø
200Ø
200Ø
100Ø
150Ø
150Ø
150Ø
59
61
64
150Ø
150Ø
71
150Ø
80Ø
200Ø DPC/225ØAS BUILT
200Ø DPC/225ØAS BUILT
200Ø DPC/225ØAS BUILT
200Ø DPC/225ØAS BUILT
EXISTING DRAINAGENETWORK EXTENDED TOFACE OF NEW QUAY WALL.ALL EXISTING RETENTIONSYSTEMS RETAINED
EXISTING RETENTIONSYSTEM RETAINED
EXISTING RETENTIONSYSTEM RETAINED
EXISTING RETENTIONSYSTEM RETAINED
EXISTING DRAINAGENETWORK EXTENSION TIESINTO NEW LINE OFDRAINAGE AFTER THEPROPOSED FULL RETENTIONINTERCEPTOR
PROPOSED FULLRETENTIONINTERCEPTOR
PROPOSED OUTFALLDISCHARGES THROUGH NEWQUAY FACE VIA A FLAPVALVE OR SIMILAR
EXISTING OUTFALLS ANDRETENTION SYSTEMRETAINED
Drawing Number
Drawing Status Sheet Size
Client
Rev
Drawing Scale
drawnamendmentsrev
Project
Title
date
/
Dublin Port Authority
Initial ReviewProject Leader Drawn By Date
Alexandra Basin Redevelopment
Proposed Drainage - Berth 52/53
Preliminary
Mar '15
1:10,000
IBR0668
A3
113 0
DD AMB AMcG
1. Verifying Dimensions.The contractor shall verify dimensions against such otherdrawings or site conditions as pertain to this part of the work.
2. Existing Services.Any information concerning the location of existing servicesindicated on this drawing is intended for general guidance only. Itshall be the responsibility of the contractor to determine and verifythe exact horizontal and vertical alignment of all cables, pipes, etc.(both underground and overhead) before work commences.
3. Issue of Drawings.Hard copies, dwf and pdf will form a controlled issue of thedrawing. All other formats (dwg, dxf etc.) are deemed to be anuncontrolled issue and any work carried out based on these files isat the recipients own risk. RPS will not accept any responsibilityfor any errors arising from the use of these files, either by humanerror by the recipient, listing of un-dimensioned measurements,compatibility issues with the recipient's software, and any errorsarising when these files are used to aid the recipients drawingproduction, or setting out on site.
NOTES
4. Datum: All Coordinates in metres and relative to ITM
5. Keys
RPS Consulting Engneers
Enterprise Fund Business Centre
Ballyraine
Letterkenny
Co. Donegal
+353 (0) 74 91 61927
+353 (0) 74 91 61928
W www.rpsgroup.com/ireland
Proposed IED Site Boundary
Proposed Drainage Line - Berth 52/53
50m SCALE 1:2500
Existing Drainage Line
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EPA Export 21-12-2017:03:49:50