attachment c - epa · 2015. 11. 6. · a2-15 . line 1 press extraction scrubber . ep10 a2-16 line 1...

Attachment CEmissions to Atmosphere Table

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Reg No: P0027-04 AIR EMISSION POINTS – NUMBERING

Page | 1

MAIN EMISSION POINTS

Old Emission Point Reference New Emission Point Reference Description New emission point A1-1 Line 1 Press Thermal Fluid

Heater New emission point A2-1 Chip Cleaning HPS Cyclo Filter New emission point A2-2 Chip Cleaning STS Cyclo Filter New emission point A2-3 Chip Cleaning SAS Cyclo Filter New emission point A2-4 Fines Silo Cyclo Filter EP34 A2-5 Line 1 Core Dryer Stage 1 EP35 A2-6 Line 1 Face Dryer Stage 1 EP27 A2-7 Line 1 Clean-Up Bag Filter EP27A A2-8 Line 1 Clean-Up Bag filter Cyclo

Filter EP28 A2-9 Line 1 Glue Blender Bag Filter EP29 A2-10 Line 1 Reject Bag Filter EP29A A2-11 Line 1 Reject Bag Filter Cyclo

Filter EP37 A2-12 Line 1 Press Vent 1 EP38 A2-13 Line 1 Press Vent 2 EP25 A2-15 Line 1 Press Extraction Scrubber EP10 A2-16 Line 1 Saw Dust Bag Filter EP11 A2-17 Line 1 Sander Bag Filter EP30 A2-18 Line 1 Sander Dust Silo Cyclo

Filter EP31 A2-19 Line 1 Sander Dust Silo Cyclo

Filter EP32 A2-20 Line 1 Hog Trim Silo Filter EP9 A2-21 Line 2 Stage 1 Dryer EP6 A2-23 Line 2 Press Vent 1 EP5 A2-22 Line 2 Press Vent 2 EP1 A2-24 Line 2 Sander Bag Filter EP4 A2-25 Line 2 Saw Bag Filter EP33 A2-26 Line 2 Sander Dust Silo Filter EP36 A2-27 Line 2 FR Dust Silo Filter

MINOR EMISSION POINTS

Old Emission Point Reference New Emission Point Reference Description None (minor) A3-1 Line 1 Cooler Vent 1 None (minor) A3-2 Line 1 Cooler Vent 2 None (minor) A3-3 Line 2 Cooler Vent 1 None (minor) A3-4 Line 2 Cooler Vent 2

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Reg No: P0027-04 AIR EMISSION POINTS – NUMBERING

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POTENTIAL EMISSION POINTS

Old Emission Point Reference New Emission Point Reference Description EP23 A4-1 Boiler Exhaust 1

EP24 A4-2 Boiler Exhaust 2

PEP7 A4-3 Diesel Engine – Line 1

Emergency Generator EP8 A4-4 Energy Plant Line 2 Start Up

Exhaust PEP5 A4-5 Energy Plant Emergency Stack

PEP8 A4-6 Diesel Engine – Line 2

Emergency Hydraulic Pump PEP9 A4-7 Diesel Engine – Line 2 Thermal

Oil Emergency Cooling Pump PEP6 A4-8 Diesel Engine – Emergency Back

Up Fire Pump

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Attachment DFuel Types

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P0027-02 Fuel Types – Boilers and Energy Plant

Wood Biomass Fuel Types:

Generated on-site

• Bark and bark screening • Wood chip • Wood chip fines • MDF Sander dust and saw trimmings • Reject MDF product • Reject Fibre • Dewatered Sludge • Settled sludge from surface water holding ponds • Untreated chipped wooden pallets and wooden packaging

Generated off-site

• Wood chip • Recovered Wood – untreated wooden pallets, untreated wooden packaging • Returned untreated MDF off-cuts • Untreated sawmill residues • Forestry brash bundles • Forestry residue

Fossil Fuel Types:

• Natural Gas – pilot flame in boilers production line 1 • LPG Propane –back up to boilers pilot flame production line 1

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Attachment EConfirmation of Monitoring Data

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Attachment FUpdated Table G(i)

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Reg No: P0027-02 Hazard Statement Codes

Material/Substance Risk Phrases Safety Phrases Hazard Statement Codes Hydrochloric Acid 28/36%

R34, R37 S2, S26 H314 Causes severe skin burns and eye damage. H335 May cause respiratory irritation. H290 May be corrosive to metals.

Sodium Hydroxide R34, R35 S26-28, S36/37/39-45 H314 Causes severe skin burns and eye damage.

Corrshield MD4100 R25-36/38 S26,27,28,36,37,39-45, S60

H301 Toxic if swallowed. H315 causes skin irritation. H319 causes serious eye irritation. Irritating to eyes and skin.

Balanced Polymer 6473E

R36/37 S26-28-36/37/39 H314 Causes severe skin burns and eye damage. H319 causes serious eye irritation.

Steamate NA0840 R21/22.R34, R43.

S24, S26, S28, S36/37/39, S45

Information on ingredients H302 Harmful if swallowed. H312 Harmful in contact with skin. H314 Causes severe burns and eye damage. H332 Harmful if inhaled - H226 Flammable liquid and vapour. H317 May cause an allergic skin reaction.

Steamate FM1000 R36/38-43 S24-26-28-36/37/39 Information on ingredients – R52 harmful to aquatic organisms. R53 may cause long term effects in the aquatic environment. H412 Harmful to aquatic life with long lasting effects.

Cortrol IS3000 R49-22-31 S23-26-28-36/37/39-45- 53

Hazard statements – mixture does not meet the criteria for classification. But info on ingredients includes sodium bisulphite H302 Harmful if swallowed.

Depositrol PY5203 No R phrases No S phrases Not considered hazardous to health. The product is not classified as dangerous for the environment.

Potassium Permanganate

R8,22,50/53 S60, S61 There are no Hazard statements.

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Reg No: P0027-02 Hazard Statement Codes

Material/Substance Risk Phrases Safety Phrases Hazard Statement Codes Napgel C2230 R22 S2,S20,S27,S46 There are no Hazard statements listed. Optisperse P05090 R36/38 S26, S28, S36/37/39 Not classified for physical hazards. Irritating

to eyes and skin. Not classified for hazards to the environment but ingredient referenced H314 causes severe skin burns and eye damage. Stated product is not classified as dangerous for the environment.

Hydrated Lime R37,38, 41 S2,25,26,37,39 H315 Causes skin irritation. H318 Causes serious eye damage. H335 May cause respiratory irritation.

Aluminium Chloride R35, R41 S24,25,36 No hazard statements. Biofeed R35,41 S1,2,26,27/28,36/

37/39,45 H315 contact with skin will cause irritation. H314 contact with eyes may cause severe damage.

Formic Acid R35 S26,37/39,45 H314 causes severe skin burns and eye damage.

Toluene R11, 38, 48, 20, 63, 65, 67-20

S36/37, 62, 46 No H numbers given but following listed under hazard identification: Highly flammable. Irritating to the skin. Possible risk of harm to the unborn child. Harmful: may cause lung damage if swallowed. Vapours may cause drowsiness and dizziness. Harmful: danger of serious damage to health by prolonged exposure through inhalation.

COD Reagent R49-23/24/ 25- 33-35-52/53

S26,28a, 45,60 Toxic and Corrosive

Sulphuric Acid R35 S1,2,26,30,45 Corrosive Strong acid Hydrochloric Acid R34-37 S1,2,26,45 H314 Causes severe skin burns and eye

damage. H335 May cause respiratory irritation. H290 May be corrosive

Glacial Acetic Acid R10,35 S23,26,45 No hazard statements Formaldehyde Solution

R23,24, 25,34, 43,50

S26,36,37,44,51 No hazard statements

Urea Formaldehyde Resin

R23,24,25,34, 40, 43

S26, 36 37, 39,51 No hazard statement.

MDI Resin Xn;R20 Xi;R36/37/38 R42/43

S23, 36/37/38,45 No Hazard statement but stated the following: Harmful by inhalation. Irritating to eyes, respiratory system and skin. May cause sensitisation by inhalation and skin contact.

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Material/Substance Risk Phrases Safety Phrases Hazard Statement Codes Green Process dye R22,37,

38,41, 50,53

S24,26,37,39,61 H301 Toxic if swallowed. H314 Causes severe skin burns and eye damage. Red Process dye R34,51,

53 S36,37,39,45,57,61 Hazard statements are provided for

components: H226 flammable liquid and vapour. H314 Causes severe skin burns and eye damage. H301 Toxic if swallowed. H411 Toxic to aquatic life with long lasting effects.

LPG Propane R12 S9,16,33 No H classes stated R and S phrases given. Stated Liquefied gas. Extremely flammable.

Natural Gas R12 S9,16,33 No H classes but stated. Extremely flammable. In high concentrations may cause asphyxiation. Compressed gas.

Mobiltherm 605 ** ** No Hazard statements but stated excessive exposure may result in eye, skin, or respiratory irritation.

Gas oil marked R40,52, 53 S2,24,36, 37,43,61,62 H226 flammable liquid and vapour H304 Fatal if swallowed H315 Causes skin irritation H372 Harm to organs through prolonged or repeated exposure H411 Toxic to aquatic life with long lasting effects.

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Environmental ReportAttachment G

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Environmental Report

For Medite Europe Limited

Final

04th November 2015

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Document Control

Status Draft Final

Date 03/11/2015 04/11/15

Version # 1 2

Written

Approved

This report has been prepared by Environet Consulting Ireland Ltd, with all appropriate care and diligence withinthe terms of the Contract with the client. This Contract incorporates our Terms and Conditions and takes accountof the resources devoted to it by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of works.

This report is confidential to the client and we accept no responsibility to third parties to whom this report, or anypart thereof, is made known. Such parties rely on the report at their own risk.

This report is confidential to the client and we accept no responsibility to third parties to whom thisreport, or any part thereof, is made known. Such parties rely on the reportat their own risk.

This report is confidential to the client and we accept no responsibility to

Dungarvan Business CentreFairlaneShandonDungarvanCo. WaterfordIrelandTel: 058-51155Fax: 058-51231Email: [email protected]

www.environet.ie

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Table of Contents:

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

Site Description..........................................................................................................................1

Commencement of Operations ..................................................................................................1

Classes of Activity Licensed ........................................................................................................1

2 HUMAN BEINGS ...................................................................................................... 2

The Existing Environment...........................................................................................................2

The Impacts of the Activity ........................................................................................................3

The Measures to Mitigate Adverse Impacts ...............................................................................4

A Non-Technical Summary .........................................................................................................6

3 FLORA AND FAUNA ................................................................................................. 8

The Existing Environment...........................................................................................................8

The Impacts of the Activity ........................................................................................................9

The Measures to Mitigate Adverse Impacts .............................................................................10

A Non-Technical Summary .......................................................................................................10

4 SOIL/GROUNDWATER ........................................................................................... 11

The Existing Environment.........................................................................................................11

The Impacts of the Activity ......................................................................................................15



5 SURFACE WATER................................................................................................... 19





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6 AIR......................................................................................................................... 25





7 NOISE .................................................................................................................... 29





8 CLIMATE................................................................................................................ 32





9 LANDSCAPE, MATERIAL ASSETS AND CULTURAL HERITAGE .................................. 36





10 INTERACTION EFFECTS .......................................................................................... 40

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1 Introduction

Site DescriptionThe site is situated approximately 4 km east of the centre of Clonmel, Co.Tipperary, a town with a population of approximately 20,000. The site has anarea of 62 hectares. The facility employs 160 full time staff and the mainprocesses operate 24 h per day, 7 days per week.

Commencement of OperationsPlanning permission for the site was granted in 1982 on a green field site andproduction commenced in September 1983. The facility was expanded toinclude a second production line in 1994.

Medite was purchased by Willamette Industries in 1996, which wassubsequently purchased by Weyerhaeuser in February 2002. The namechange to Weyerhaeuser was officially completed in May 2002.

In 2006, the Weyerhaeuser site in Clonmel was purchased by Irish forestrycompany Coillte. The name of the site was changed to Medite Europe Ltd.

Classes of Activity LicensedMedite Europe Limited (Medite) has an IPPC Licence (P0027-02) issued bythe EPA on 30th November 2001 for the following activity;

The manufacture of paper pulp, paper or board (including fibre-board,particle board and plywood) in installations with a production capacityequal to or exceeding 25,000 tonnes of product per year.

The Licensee requested a technical amendment to Register No. P0027-02 onthe 13th March 2009 in order to facilitate the installation of a new enclosedcleaning and pneumatic transport system for woodchip. The new system isreferred to as a ‘ClassiCleaner’. The Agency advised the Licensee that theproposals could not be accommodated by way of a technical amendment andthat Medite had to undergo an Industrial Emissions Licence review.

The assessment of the potential impact of the activity on site was carried outaccording to the methodology specified in the following guidance documents:

Environmental Protection Agency (EPA) Guidelines on the Information toContained in Environmental Impact Statements (2002);

EPA Advice Notes on Current Practice (in the Preparation of EIS) (2003).

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2 Human beings

The Existing EnvironmentThe site is situated approximately 4 km east of the centre of Clonmel, Co.Tipperary, a town with a population of approximately 20,000. Land use in thevicinity of the facility is a mixture of commercial sites and agricultural land. TheClonmel zoning map classifies the area as “General Industrial” (see Fig 1).The Medite site has an area of 62 hectares. The facility employs 160 people inits Clonmel plant and the main processes operate 24 hours per day, 7 daysper week. A further 500 people are employed indirectly, both locally andnationally, in providing support services to the manufacturing operation. Thesesupport services include; timber harvesting, log haulage, product distributiontransport, contract maintenance services, security and canteen services.Planning permission for the Medite site was granted in 1982 on a green fieldsite in Redmondstown and production commenced in September 1983.

Land Use Zoning Map Clonmel, 2013

2.1.1 Demographic TrendsIn accordance with the Planning and Development Acts 2000–2013, theSouth-Eastern Regional Authority has drafted Regional Planning Guidelines(RPG’s) for the region. Population projections have been calculated as part ofthe RPG’s and transposed into the South Tipperary County Core StrategyDocument. The strategic policies and objectives set out in the RPG also formthe basis for socio-economic planning in the Clonmel & Environs DevelopmentPlan. It has been projected that by 2016 Clonmel will attain a 24% share of

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South Tipperary’s population. By 2022, the RPG’s predict that the populationin the Clonmel region will reach 25,000. The Clonmel & Environs DevelopmentPlan, which sets out the framework for the development of Clonmel town andits hinterland for the period 2013-2019, states that manufacturing activitieswere the top area of employment in the region, accounting for 22% of those inemployment (2011 census).

The Regional Planning Guidelines for the South East Region have devisedeconomic development opportunities for Clonmel that take full advantage of itslocation on strategic road and rail corridors, it’s improving transportinfrastructure, the availability of zoned and services lands and the existence ofa third level educational institute offering potential for enterprise, R & D andeducational linkages.

The Impacts of the ActivityThe impacts of the activity on Human Beings will be assessed in accordancewith “Advice Notes on Current Practice in the Preparation of EnvironmentalImpact Statements” (EPA, 2003). This guidance note recommendsassessment of impact under the following headings: Economic Activity, SocialConsideration, Land-use, and Health & Safety.

2.2.1 Economic ActivityOne of the key tenets of the Clonmel & Environs Development Plan is thedevelopment of clean industries in the region. The plan aims to encourage theexpansion of existing employment and the creation of new employment atappropriate locations. Enterprise growth includes a broad range of economicand employment generating developments that rely on process-orientatedactivities to produce goods and services. The current activities at the Meditefacility are in line with the development plan’s target to promote clean industrywhile creating sustainable employment. In addition, operations at the facilityare considered to have had a positive impact on the local economy insofar asit supports continued employment in the region.

2.2.2 Social ConsiderationsTraffic flow to and from the factory which includes employees, incomingmaterials or outgoing panel products, has not significantly increased in recentyears. There has been a positive long term impact on the immediate hinterlandand the wider Tipperary Region through continued employment and theassociated economic and social benefits.

There has been no issue with noise from the Medite facility in recent years.Noise surveys are a requirement of the current IPPC licence and areconducted annually at Noise Sensitive Locations (NSLs) adjacent to the site.

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2.2.3 Land UseThe production activities at the Medite facility are enclosed and are generallynot visible from the site boundaries. The operations at the facility are notimpacting on the character and use of surrounding land.

2.2.4 Health & SafetyThe operation of the facility is carried out in strict accordance with all Irish andEuropean regulations governing safety in the work place with specific regardto the regulations implemented under the Safety, Health & Welfare at WorkAct, 2005. Full relevant training in the operating procedures for equipment andprocesses are provided to each employee. In the case of a fire the emergencyresponse procedure will be activated and necessary personnel have been fullytrained to deal with such emergencies.

Guidance in relation to the prevention of major accidents is set out in Directive96/82/EC, superseded by the European Communities (Control of MajorAccident Hazards Involving Dangerous Substances) Regulations (SI No. 74 of2006) and by the Planning and Development Regulations, 2001-2013. TheDirective defines major-accident hazard sites (COMAH sites) as those thatstore or could generate quantities of dangerous substances in excess ofspecified thresholds. As per the assessment completed for the licenceapplication EC (Control of Major Accidents Hazards involving DangerousSubstances) Regulations (SI No. 74 of 2006) and the EU (Control of MajorAccident Hazards involving Dangerous Substances)(Amendment) Regulations2013 do not apply to the Medite facility as storage of flammable gases andliquids fall below the qualifying quantities for gas oils and extremely flammablegases.

Accidents and incidents at the facility are possible sources of impacts onhuman beings. The following have been considered as plausible incidents thatmay impact on human health:

a) Releases to atmosphere;

b) Fire/explosion;

c) Spillages to ground.

The Measures to Mitigate Adverse ImpactsAll necessary measures are taken by Medite to limit the emission of pollutantsthat could adversely affect human health. Under normal operating conditions,including start up, shutdown and momentary stoppages, all necessarymeasures are taken to prevent pollution. Should an abnormal operation occuras a result of an unplanned activity, including leaks, malfunctions,breakdowns, then the site Emergency Preparedness & Response Procedure

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and the Environmental Accident Prevention & Emergency ResponseProcedure are implemented. At present there is routine 24 hour maintenanceprogramme for plant equipment, so any leakage etc. would be identifiedquickly and Corrective Action is undertaken in accordance with theaforementioned procedures.

2.3.1 Releases to atmosphereThe following emissions to atmosphere are relevant to the Medite facility:

1 x boiler emission; 26 x main emission points (including 18 bag/cyclo filters, 3 dryers, 4

press vents and 1 scrubber); 4 x minor emission points; 8 x fugitive/potential emission sources.

Potential exposure pathways for atmospheric emissions to human beings arethrough inhalation and ingestion. Ingestion may occur due to the depositionand accumulation of particulates on/in productive agricultural land used forfood production. The significant emissions to air from the facility are that offormaldehyde, Condensable Volatile Organic Compounds, Methylene diphenyldiisocyanate (MDI) and particulate matter (dust).

The emission of the aforementioned parameters is regulated through theEmission Limit Values (ELVs) prescribed by the EPA in the current IPPCLicence. Annual Environmental Reports from Medite show that there havebeen no exceedances of ELVs for these parameters in recent years. Allappropriate preventive measures are taken against pollution by Medite, inparticular through application of the Best Available Techniques (BAT) in theoperation, maintenance and monitoring of the facility. The following abatementand treatment technology is employed at the site to reduce emissions to air:

Filter bags on process vents and wood dust handling to reduceparticulate emissions;

Dryer emission cyclones.

Air Dispersion Modelling conducted by consultants ERM in October 2015concluded that there is no significant impact on ambient air quality as a resultof emissions from the Medite facility.

2.3.2 Fire/explosionAn occurrence of a fire or explosion at the facility could potentially impact onlocal residents through smoke/fume inhalation and the contamination ofgroundwater/surface water. Medite provides and maintains appropriate fireprotection & prevention equipment, and methods to protect the safety of itsemployees and facility operations. It is Medite’s policy that in the event of a

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fire, the safe-guarding of life takes precedence over all other matters. Mediteprovides Emergency Response Teams (ERT) training to all core ERT teammembers. In the event of a fire, the Environmental Accident Prevention andEmergency Response procedure is implemented. As Medite is operational 24hours, it is site policy that there is always an Emergency Response Team andLeader available to respond to an accident.

In the event of a fire, the primary objectives are extinguishment andcontainment. Emergency Response Teams are trained to deal with flammableliquid incidents by the following means:

Containment using fog/foam systems; Avoidance of ignition sources; Diverting spillage to Emergency Holding Lagoon; Use of spill kits, pig tails; Cleaning up using sand or earth.

The EPA are notified of all incidents relating to the environment. Approval andguidance from the EPA is sought prior to the disposal of materials andretained fire water.

2.3.3 Spillages to groundAccidental spillages to ground and groundwater have potential exposurepathways to human beings mainly through down-gradient drinking watersupplies. Groundwater flow is typically south-east across the site towards theRiver Anner and River Suir. There are no Drinking Water (Public Supply)Source Protection Areas in the area indicated on the GSI groundwaterdatabase.

The main site bulk liquids bund and drum storage area drain to a settlingsystem comprising three lagoons. Mitigation measures for the prevention ofemissions to ground are discussed in more detail in the Soil/Groundwaterchapter.

A Non-Technical SummaryThere will be no significant adverse impact on the human environment fromthe continued operations at the Medite facility. It will have a significant positiveimpact in terms of continuing to provide direct and indirect employmentopportunities for both people already living in the area and people living in awider geographical area.

There will be no significant adverse impacts with respect to socio-economicfactors, land-use, or the amenity value and tourism potential of the area.Health and Safety issues which may cause risks and hazards during theoperational phase of the development have been given due consideration. All

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necessary mitigation measures are in place to ensure the health and safety ofall site personnel. All other environmental aspects relating to the humanenvironment which could have an adverse impact on the local population suchas noise, air, water and visual impacts have been addressed in the relevantchapters of this environmental report.

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3 Flora and Fauna

The Existing Environment

3.1.1 Terrestrial EcologyThe Medite site is located to the west the Anner River valley. Land use in thevicinity of the facility is a mixture of commercial sites and agricultural land. Theagricultural land primarily consists of pasture. Field boundaries are generally inthe form of hedgerows and, in some cases, old estate stone walls. A notablefeature of the area is the abundance of hedgerows with well-established trees.There are two rivers in the locality of the site. The River Anner, which hasachieved a WFD River Waterbody Status of ‘good’, and the River Suir, whichhas achieved a WFD River Waterbody Status of ‘moderate’. This is discussedin more detail in the Surface Water chapter. The River Anner flows south fromLisronagh and Slievenamon, and is a tributary of the River Suir which it joinsapproximately 1km south of the facility. The floodplain of the River Anner is amixture of grassland fields on the eastern side and mature parkland andtreebelts of the former Newtownanner Demesne to the west.

During the construction of the main production facility in 1982 the topographyof the site was transformed to form a level working area. This has resulted inthe formation of steep embankments along the northwest boundary of the site.Piles of logs are stored to the northwest of the production area while awaitingprocessing.

The 62 hectares site is surrounded on all sides by woodland, mostly youngbirch and conifers. The boundary to the east of the site is planted with gardenvariety plant and tree species along the roadside. There is no naturalvegetation or habitats present in the main production area. An AppropriateAssessment on discharge of Waste Water from Medite conducted by RogerGoodwillie & Associates in January 2015 stated that the site has nothing ofsignificant ecological value though it is surrounded by trees which would havesome feeding value for bats.

3.1.2 Aquatic EcologyThe National Parks & Wildlife (NPWS) database indicates that there are noSpecial Protection Areas (SPA) or Nature Reserves in the vicinity of the site.The Service NPWS has designated the Lower River Suir as a Special Area ofConservation (SAC) (site code 002137), which includes the River Anner.There is potential for the discharge of contaminants from the site to the SACvia the WWTP and contaminated surface or ground water.

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Special Areas of Conservation in the vicinity of the Medite facility

In relation to the European Communities Environmental Objectives(Freshwater Pearl Mussel) Regulations 2009. The regulations setenvironmental quality objectives for the habitats of freshwater pearl musselpopulations named in the First Schedule. The River Anner is not listed as oneof the specified rivers under the First Schedule of the regulations.

The Impacts of the ActivityThere is potential for the emission of contaminants from the site to the nearbySAC from discharges to water (surface water runoff & treated processwastewater) and as a result of accidental spillages of chemicals/fuels to thesurface water collection system. However, the Natura Impact Statementcompleted by Aquafact International Services Ltd. in October 2015 concludedthat that the changes in physical-chemical parameters of the surface water arenegligible and will cause no significant deterioration in the composition of theriver water.

The main emissions to air from the facility are from the three dryer stackswhich predominantly emit water vapour. Medite has emission limits for;

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Particulates, Condensable Volatile Organic Compounds, Methylene DiphenylDiisocyanate (MDI), Formaldehyde, Carbon Monoxide, Oxides of Nitrogen,Heavy Metals and Dioxins. These are monitored as per the licencerequirements and Medite has demonstrated compliance with all emission limitsin recent years. The Air Dispersion Modelling completed by consultants ERMconcluded that here is no evidence that air emissions from the facility arehaving any effect on habitats outside the site.

The Measures to Mitigate Adverse ImpactsIn order to maintain the integrity of the natural habitats and biodiversity of thesurrounding area, water quality monitoring of groundwater and surface wateris performed in accordance with licence requirements. Medite also implementa Groundwater Protection Programme as part of their EnvironmentalManagement Programme. Surface water runoff, process effluent and domesticwastewater is treated in the WWTP and tested prior to discharge to the RiverAnner. The treatment of aqueous emissions in order to mitigate the effects onthe ambient environment is discussed further in the Surface Water chapter.Measures are in place for the containment of spills and contaminated waterwhich are discussed further in the Soil/Groundwater chapter.

All appropriate preventive measures are taken against the emission of airpollution by Medite, in particular through application of the Best AvailableTechniques (BAT) in the operation, maintenance and monitoring of the facility.These measures are discussed in further detail in the Air chapter. Climatechange has the potential to affect flora and fauna. Medite continually seeks tolimit, and reduce where possible, the emission of Greenhouse Gases from itssite operations. Biomass is the main fuel type used at Medite andgenerates69% of the sites energy requirements with zero net CO2 equivalentemissions. The use of carbon neutral fuels and energy-efficient processequipment has secondary environmental benefits in the form of reducedcarbon output which mitigates against climate change.

A Non-Technical SummaryThe National Parks & Wildlife Service (NPWS) has designated the LowerRiver Suir as a Special Area of Conservation (SAC). This area includes theRiver Anner which runs adjacent to the Medite site. There is potential for thedischarge of contaminants from the site to the SAC via air emissions andaqueous emissions from the WWTP or contaminated surface or ground water.Air emissions are managed through the use of BAT and carbon neutral fuels.The Natura Impact Statement conducted by Aquafact concluded that there areno negative effects felt on the river environment due to the Medite facility’seffluents. Furthermore the air dispersion modelling completed by consultantsERM predicted no impact on the SAC.

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4 Soil/groundwater

The Existing EnvironmentThe land in the area of the site slopes in a south-easterly direction towards theRiver Anner which is a tributary of the River Suir. The 1:50,000 scaleOrdnance Survey of Ireland map (OSI) indicates that the site is located atelevation of 20m to 35mOD. Prior to construction of the Medite facility, theoriginal land surface sloped from 45mOD in the northwest of the site to22mOD in the southeast. During the construction in 1982 the topography ofthe site was transformed to form a level working area. This has resulted in theformation of steep embankments along the northwest boundary of the site.

The site is composed of the main production plant buildings and materialsstorage areas and sealed the surfaces are typically of concrete and asphaltconstruction. All areas associated with the facility’s operations arehardstanding. A number of landscaped areas are located along the perimeterof the site. A former landfill site is located on the elevated ground north west ofthe plant, to the north of the Log Yard and Chip Store.

The hydrogeological assessment undertaken for the preparation of theBaseline Report required as part of the Industrial Emissions Licence reviewindicated that there are no pollutant linkages to ground or groundwaterassociated with the current activities and proposed emissions from theoperation of the facility. The only emissions to groundwater from the operationof the site are the discharges from the percolation areas associated with thethree septic tanks located on site. The septic tanks serve small localised toiletsat the weighbridge, adjacent to the diesel store and from the Warehousebuilding.

4.1.1 Underlying GeologyThe Geological Survey of Ireland (GSI) database indicates that the underlyinggeology of the area is characterised by Waulsortian Limestone Formations(WA), with a Silverspring Formation (SS) directly north of the site. ThisWaulsortian Formation forms underlying bedrock in the area betweenRedmondstown and the River Suir. Waulsortian formations generally comprisemainly massive, calcareous mudstones and limestones, containing originalcavities filled with calcareous cement. The top 2-3 metres of the formation istypically weathered and non-intact. The bedrock in this area is old andindurated and as such most of the original depositional features, such asprimary permeability and porosity, are no longer present. In this type of strata,secondary permeability is dominant. While the Waulsortian Limestone ischaracterised by zones of intense fracture cleavage and known to be prone tokarst features, a search of the GSI National Karst Database indicates no suchfeatures within a 5km radius of the site.

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Bedrock formations in the local vicinity of the Medite site, (GSI2015)

4.1.2 Subsoil GeologyThe Teagasc Subsoils map classifies the subsoils as Namurian Sandstone &Shale Till (TNSSs). Site-specific information from the 1981 site investigationsindicate that the bedrock is overlain by 2-3 metres of dense, fine to medium,gravel (which in places this was observed to be completely weathered rock),which is in turn overlain by silty clay and topsoil. Bedrock outcropping wasobserved approximately 800m west of the site at Rathloose. The site itself isclassified as made-ground by the Teagasc Subsoils map.

Teagasc subsoil map in the local vicinity of the Medite site, (GSI2015)

MEDITE

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4.1.3 Aquafer VulnerabilityThe Waulsortian Limestone in this region is categorised as a Karstified(diffuse) Regionally Important Aquifer (Rkd), where the groundwater flowsthrough karstified conduits. The importance of the aquifer results from thedevelopment of secondary permeability brought about by solution widening ofcalcite filled cleavage planes, original cavities, fissures and fractures. Thisoccurs more so in fault zones. The Geological Survey of Ireland (GSI)database shows a bedrock aquifer fault, running north–south, approximately 1km east of the site.

Aquifer Categorisation in the local vicinity of the Medite site &borehole location (Glenpatrick), (GSI 2015)

The groundwater vulnerability has been classified as moderate and thenearest listed groundwater borehole is the Glenpatrick spring water source,which is located approximately 3 km west in Clonmel. To the south and northof the site the bedrock is classed as a Locally Important Aquifer (Ll) i.e.bedrock which is moderately productive only in local zones. There are nolocally or regionally important sand and gravel aquifers within 20km of theMedite site. There are no reported source protection zones within a 15kmradius of the site.

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Groundwater Vulnerability in the local vicinity of the Medite site,(GSI 2015)

4.1.4 Groundwater QualityThe Medite Facility is located within the South Eastern River Basin District ofIreland. The Water Framework Directive (WFD) status for 2007 to 2009 and2010 to 2012 classified the groundwater as ‘good’ in this area. The WFD RiskScore for the region is classified as 1a – at risk of not achieving good status.

The groundwater flow direction is south east towards the River Anner andRiver Suir. There are no potential downgradient groundwater abstractionsindicated on the GSI database. The main pathways for the movement ofcontaminants off site is via the discharge to groundwater and/or the dischargeto surface water. The identified potential receptors are the:

(i) Regionally Important Karst Aquifer; and(ii) River Anner & River Suir.

There is a historic landfill located on-site, directly north of the main productionarea. The landfill was used from 1986 –1996 exclusively for the on-sitedisposal of wood dust, culled MDF, resin residue, soil and settled solids fromthe surface water lagoons. From 1996 onwards, the landfill was used todispose of only small quantities of inert material (top soil) and by 2010 thelandfill had closed completely. Monitoring of groundwater boreholes in thisarea indicates this former landfill is impacting on the groundwater quality in theimmediate vicinity of the landfill area. There is currently no evidence ofcontamination extending off-site as demonstrated by the groundwatercomposition in the downgradient monitoring boreholes. Historical monitoringhad previously shown elevated concentrations of ammonia downgradient ofthe Medite site. Subsequent studies have concluded that there is adequate

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attenuation and dilution down gradient of the landfill so as to ensure nosignificant off-site movement of contaminants. A review of the groundwatermonitoring data from 2000 to 2014 confirms that the operation of the facility isnot having an impact on the downgradient groundwater quality.

The Impacts of the ActivityVertical migration of contamination at ground level has the potential to migratethrough soils and bedrock. However, the presence of concrete and asphaltsealed surfaces throughout the production area will impede the verticalmigration to soils and the underlying bedrock. There are 3 septic tank systemswithin the site boundaries discharging to the ground. These systems servicesmall localised site toilets and each serves between 2 and 6 people. Theseseptic tank systems are constructed and maintained as per the requirementsof the EPA’s guidance document – Code of Practice: Wastewater Treatmentand Disposal Systems Serving Single Houses.

Groundwater and soil quality have been assessed via a baseline report as partof the Industrial Emissions Licence review process, and sources of potentialcontamination have been identified. The assessment indicated that there areno pollutant linkages to ground or groundwater associated with the currentactivities at the facility.

The existing facility stores and uses miscellaneous materials, such as resins,gas oil, dyes and miscellaneous maintenance oils, which are classified ashazardous substances due to the properties of their various components. Thestorage and use of these substances poses a risk to soil and groundwaterthrough leaks and spillages. Table 1 lists the bulk liquid chemicals stored onsite.

Substance Storage Capacity Location

Aluminium Chloride 20,000 kg WWTP chemical storeBiofeed 6,000 L WWTP chemical storeCorrshield MD4100 200 L Boiler chemicalFormic Acid 400 L WWTP chemical storeGas Oil 30,000 L FuelGreen Process Dye 2,000 L Raw MaterialHydrated Lime 15,000 kg WWTP chemical storeMoblitherm Fuel 1,000 L Fuel

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Optisperse P05090 440 kg Boiler ChemicalPotassium Permanganate 50 L Boiler ChemicalRed Process Dye 1,000 L Raw MaterialSteamate FM1000 400 L Boiler ChemicalSteamate NA0840 400 L Boiler chemicalToluene 100 L Chemical StoreUrea Formaldehyde Resin 700,000 L Raw Material

Total bulk storage capacities of “relevant hazardous substances”

Previous groundwater assessments state that there is no indication of springsin the area to suggest the presence of groundwater dependant ecosystems inproximity to the Medite site. There is potential for the discharge ofcontaminants from the site to the SAC via the discharge of contaminatedgroundwater to the river. A Natura Impact Statement has been completed byAquafact International Services Ltd. in October 2015 with respect to thedischarge of groundwater from the facility which concluded that it is unlikelythat there will be any negative effects felt on the river environment due to theMedite facility’s effluents.

The Measures to Mitigate Adverse ImpactsA number of mitigation measures are in place to ensure that no pathway to soilor groundwater is present at the Medite facility. The measures that have beenimplemented are as follows:

Medite Europe Ltd implements a Groundwater Protection Programmeto ensure the protection of groundwater at the site. This programmeensures that site operations are managed and controlled to ensure thatno potentially polluting substances or matter shall be permitted todischarge to groundwater;

Groundwater is currently periodically monitored at 6 monitoringlocations at the site in accordance with the licence requirements.Medite has been granted permission by EPA to install two additionalboreholes to augment the scope of the Groundwater ProtectionProgramme;

Bunds have been constructed to ensure capacity is greater than 110%of the largest tank within;

Integrity testing of bund structures in accordance with the licencerequirements every 3 years;

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All tanks and bunds are regularly inspected and bund testing is carriedout in accordance with the licence requirements with maintenancecarried out as required;

Integrity testing of storm water discharge system every 3 years. Regular visual inspection of hardstanding areas is undertaken to

monitor the condition of hardstanding areas with maintenance andrepairs being undertaken as necessary;

The procedure on site for the containment of spillages has two phases;(i) containment of liquid in the tank bund and where this fails; and(ii) manual placement of sliding baffles to block off the route to normal

discharge and to divert the runoff to the emergency lagoon. Procedures in place for the use, handling and storage of all chemicals

on site to ensure that the risk of spills is minimised. Training is providedto staff in relation to the handling and storage of all chemicals on site toensure the risk of spills is minimised;

Regular routine maintenance programmes are in place for the processequipment, environmental process equipment, continuous monitors,laboratory equipment and sampling equipment;

The emergency response teams are also trained in containmentmeasures with respect to spillages including procedures forcontainment including diverting spillages to the emergency holdinglagoon; use of spill kits and pig tails; cleaning up using sand or earthand safe disposal of clean up materials;

In the event of a fire, the procedure on site is for firewater to be divertedto the emergency holding lagoon.

A Non-Technical SummaryThere are currently no groundwater abstractions located down gradient of theMedite Facility. The area is served by the public water mains and there are noprivate wells indicated on the GSI well database down gradient of the site.

The site is located on a Regionally Important Karst aquifer. The siteinvestigation data indicates the vulnerability ranges from low to high due to thevariation in the depth of overburden. The presence of hardstanding over themajority of the facility protects the groundwater beneath the site from the siteprocesses. The groundwater quality confirms that the current site processesare not impacting on the groundwater quality at the site. The groundwater inthe immediate vicinity of the former landfill site is being impacted upon by theformer landfill. The landfill is not impacting on the groundwater quality downgradient of the facility. The Groundwater baseline assessment indicated thatthere are no pollutant linkages to ground or groundwater associated with thecurrent operations of the facility. The only emissions to groundwater from the

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site are discharges to the percolation areas associated with the three septictanks located on site.

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5 Surface water

The Existing EnvironmentThe River Anner flows in a north to south direction and is locatedapproximately 100m to the east of the site. The WFD River Waterbody Statusfor 2007-2009 and 2010-2012 classified the River Anner as having achieved‘good’ status. The River Anner discharges to the River Suir, approximately1km down gradient of the site, at Anner Bridge to the south. The River Suirflows in a west to east direction. The WFD River Waterbody Status for 2007-2009 and 2010-2012 classified the section of the River Suir which intersectsthe River Anner as having achieved ‘moderate’ status.

WFD River Waterbody Status for 2007-2009 and 2010-2012, (EPA2015)

The WFD Risk Score for both the River Anner and River Suir is Category 1a –‘at risk of not achieving good status’. There is an EPA hydrometric gauge flowrecorder (Station 16010) located on the River Anner approximately 2kmupstream of the Medite site. Information on the mean annual flow for the RiverAnner has been obtained from the Office of Public Works’ Hydro-data website.

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The mean annual flow recorded for the 1954-2005 period was 6.3337 m3/s,while the 95%ile flow was 1.29m3/s.

WFD Risk Scores & EPA Hydrometric Station 16010, (EPA 2015)

5.1.1 Aquatic EcologyThe NPWS database indicates that there are no Special Protection Areas(SPA) or Nature Reserves in the vicinity of the site. The NPWS hasdesignated the Lower River Suir as a Special Area of Conservation (SAC) (sitecode 002137), which includes the River Anner. There is potential for thedischarge of contaminants from the site to the SAC via the discharge ofcontaminated surface water or discharge from the WWTP to the River Anner.A Natura Impact Statement has been completed with respect to the dischargeof waste water and surface water from the facility by Aquafact InternationalServices Ltd. in October 2015 which concluded that it is unlikely that there willbe any negative effects felt on the river environment due to the Medite facility’seffluents.

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WFD River Basin Categorisation, (WFDIreland 2015)

WFD River Basin Risk Score, (WFDIreland 2015)

The Impacts of the ActivityThere are two discharges to the River Anner from the site, the NorthernDischarge (SW1) surface water and the Southern Discharge (SW2) which is acombination of surface water and treated process wastewater. Surface water

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from the north end of the site, which includes; the log yard, the area aroundthe debarker / chipper building and most of the warehouse building roof,passes through a settling lagoon (pond) before discharge, via SW1, to a drainleading to the river Anner. This flow is dependent on rainfall and is thereforeintermittent.

Surface water from the main external process yard areas is drained into thesite surface water system and comprises runoff from the internal roads in thesouthern part of the site, the car park, the fuel storage area, the chip storagearea, paved areas to the west of the production building and the roofs of theboiler/refiner house, production building, the blender building and part of thewarehouse building. This surface water is subjected to screening beforedischarge into two large interceptor settling lagoons.

Process effluent consists predominantly of effluent from three refiner plugfeeder screws and wash water from the de-barker rock drop. This effluentpasses through a screening unit, a dissolved air flotation system, an MBBR(moving bio-bed reactor) tank, an activated sludge tank and a clarificationsystem. The treated process and sanitary effluent then combines with thesurface water from the interceptor settling lagoons before discharge to theRiver Anner. Sanitary effluent from the site is also discharged to the WWTPbut typically constitutes less than 2% of total effluent treated.

The Measures to Mitigate Adverse ImpactsMeasures are in place to ensure that discharges do not impact the RiverAnner. Bar and run down screens are used to remove fine and course solidsfrom surface water prior to the interceptor settling lagoons, which are thenemployed to remove suspended solids and BOD from surface water.

Bulk liquids and drums are stored in bunded areas and there is also achemical store on site to provide secondary containment of drummedchemicals. Bund water is discharged into a settling system comprised of threelagoons each with a volume of 425m3. One of the lagoons is kept empty at alltimes and is used as a holding area in the event of an emergency, such as arupture of a road tanker, process line or individual drums/IBCs. There is asystem in place for the diversion of flow to the emergency holding lagoonwhich involves the manual placement of sliding baffles to block off the route tonormal discharge. The two operational lagoons are used alternately so in theevent of a sudden, undetected spillage the lagoon in use will intercept thespillage. The emergency lagoon is approximately 4 times the volume of thelargest storage tank. Oil booms are employed where necessary to prevent themigration of oil related product to the River Anner.

The WWTP is employed to remove BOD, suspended solids, phenols andnitrogen compounds from process and sanitary effluent. Medite consistently

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monitors the performance of the effluent treatment process in an effort tooptimise the process and further minimise the impact on the receivingenvironment. In 2011 the WWTP was upgraded to ensure continuedcompliance with licensed ELVs. These improvements included the installationof a new dissolved air flotation unit and MBBR (moving biological bed reactor)tank prior to existing aeration basin.

To maintain the integrity of the River Anner, the combined effluent and surfacewater discharge from SW2 flow is continuously measured and licenceparameters are monitored to ensure compliance with Emission Limit Values(ELVs) prior to discharge. Monitor results in recent years shows Medite is fullycompliant with its surface water emission requirements (see Table 2)

Parameter ELV Annual AverageSW2

MeasurementUnits

pH 6-9 7.7 pH unitsTemperature 25 max. 19 ºCBOD 50 11 mg/LCOD 400 104 mg/LPhenols (as total C) 0.3 0 mg/LNitrate 15 9 mg/LAmmonia 10 1.1 mg/LSuspended Solids 200 53 mg/LOrthophosphate 1.5 0.83 mg/LOils, Fats & Greases 10 0.95 mg/LToxicity 2.3 - TUZinc 0.5 0.06 mg/LCopper 0.5 0.004 mg/LChromium 0.5 0 mg/L

IPPC Licence Parameter Emission Limit Values & MonitoringResults, Annual Environmental Report 2014 (SW2)

A Non-Technical SummaryThere are two discharges from the site into the River Anner. The River Annerdischarges to the River Suir approximately 1km down gradient of the site andhas been designated a SAC. There is potential for the discharge ofcontaminants from the site to the SAC via the discharge of contaminated

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surface water or discharge from the WWTP to the River Anner. Howeversurface water from the main external process yard areas is drained into thesite surface water system, which is combined and treated with process effluentin the site WWTP. Process and sanitary effluent is monitored for compliancewith licence parameter ELVs prior to release to the receiving environment.Regular monitoring will ensure no environmental impacts on surface waterquality will occur.

Bulk liquid storage and drummed chemicals have secondary containmentmeasures in place to prevent accidental releases to surface water. There is asystem in place for the diversion of surface water to the emergency holdinglagoon in the event of a spill or fire on site.

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6 Air


6.1.1 Air QualityThe Medite facility is located outside of Clonmel town which is considered tobe a “Zone D” air quality area as required under the Clean Air for EuropeDirective. Zone D represents rural areas in Ireland.

Ambient air monitoring is conducted at various locations across Ireland andthe data made available through the EPA. A summary of the Zone D data forthe 2012-2014 period was used for the Air Dispersion Modelling of emissionsfrom the Medite facility undertaken by ERM in 2015. Table 3 summarises theambient air quality of the parameters relevant to the Medite facility along withthe Air Quality Standard (AQS) appropriate to each.

Pollutant Averaging Period BackgroundConcentration

(µg/m3)

Air QualityStandard(µg/m3)

Particulate matter(PM10)

Annual mean 12.2 40


24-hour mean(90.4th percentile)

21.8 50

Particulate matter(PM2.5)

Annual mean 6.1 25

(stage 1)

Carbon monoxide (CO) Maximum 8-hourrolling mean

2567.0 10,000

Oxides of Nitrogen(NOx)

Annual mean 10.1 -

Nitrogen Dioxide (NO2) Annual mean 7.0 40

Nitrogen Dioxide (NO2) 1-hour mean(99.79th percentile)

14.0 200

Formaldehyde (CH2O); - No dataavailable

-

Methylene diphenyldiisocyanate (MDI);

- No dataavailable

-

Summary of the Zone D data for the 2012-2014 period, (ERM 2015)

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The Impacts of the Activity

6.2.1 Air EmissionsAir emissions monitoring form the Medite facility are monitored for thefollowing parameters as per the IPPC licence (P0027-02) requirements:

Total particulate matter (PM); Formaldehyde (CH2O); Methylene diphenyl diisocyanate (MDI); Carbon monoxide (CO); Oxides of nitrogen (NOx as NO2).

Monitoring of these parameters is undertaken as prescribed by Schedule 1(iii)Monitoring of Emissions to Atmosphere of the IPPC licence. Monitoring datafrom recent years has reported that emissions of the scheduled parametersare below Emission Limit Values, with the exception of Volumetric Flow Ratesfrom the dryer stacks. Medite has investigated this matter in recent times andhas demonstrated that it is in fact compliant with its air emission flow ratelimits. The previously reported flow rate exceedances are believed to be theresult of erroneous measurements which arose due to the variability in the flowat the present stack monitoring location.

Air Dispersion Modelling conducted by ERM concluded that the air qualitystandards will not be exceeded at off-site locations due to the contribution oflicenced parameters from the facility. Table 4 summarises the findings of theERM report which includes, the Process Contribution (PC) for each parameterand the Predicted Environmental Concentration (PEC). These results aresummarised with the Air Quality Standards for comparison where relevant.The results of the assessment indicate that there is no significant impact onambient air quality at off-site locations as a result of emissions from the Meditefacility from any of the licenced emission points.

Pollutant Averaging Period PC(µg/m3)

PEC(µg/m3)

AQS(µg/m3)


Annual mean 8.55 20.7 40


24-hour mean(90.4th percentile)

28.00 49.8 50

Particulate matter(PM2.5)

Annual mean 8.55 14.6 25

(stage 1)

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Pollutant Averaging Period PC(µg/m3)

PEC(µg/m3)

AQS(µg/m3)

Carbon monoxide (CO) Maximum 8-hourrolling mean

549 3116 10,000

Nitrogen Dioxide (NO2) Annual mean 12.1 19.1 40

Nitrogen Dioxide (NO2) 1-hour mean(99.79th percentile)

14 73.7 200

Formaldehyde (CH2O); Annual mean 3.14 3.14 -

Methylene diphenyldiisocyanate (MDI);

Annual mean 0.0201 0.0201 -

Summary of Maximum Process Contribution and the PredictedEnvironmental Concentration at Off-site Locations, (ERM 2015)

Emissions to atmosphere have the potential to impact on overall air quality inthe region. The significant emission to air from the Medite facility are those offormaldehyde and Volatile Organic Compounds. The largest mass emission ofthese parameters occur from the three line dryers. Table 5 summarises thetotal mass emissions of scheduled parameters from the Medite facility in 2014.

PARAMETER KG/ANNUM

PARTICULATES 57,832

CONDENSABLE VOLATILE ORGANICCOMPOUNDS (AS C) 282,310

MDI <1

FORMALDEHYDE 31,549

CO 86,786

NOX (AS NO2) 308,809

HEAVY METALS 669

PCDD & PCDF 0

Summary of Annual Total Mass Emissions of ScheduledParameters from the Annual Environmental Report 2014

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The Measures to Mitigate Adverse ImpactsAll appropriate preventive measures are taken against the emission of airpollution by Medite, in particular through application of the Best AvailableTechniques (BAT) in the operation, maintenance and monitoring of the facility.The following technology is employed at the site to reduce emissions to air:

All dryers are two-stage systems with only one emission point for eachdryer.

Energy recovery from the Energy Plants (production line 1 and 2) isdiverted to the dryers to minimise emissions to atmosphere;

Filter bags on process vents and wood dust handling to reduceparticulate emissions; and

Dryer emission cyclone technology is utilised.

In recent years Medite has also reduced the formaldehyde emissions from itsraw MDF panel and so as to be compliant with the regulations set by theCalifornian Air Resources Board which are recognised worldwide. Medite hasinstalled new resin glue addition technology system (EVOjetTM) to furtherimprove efficiencies in the resin addition process.

A Non-Technical SummaryEmissions to air from the Medite facility are licenced by the EPA. Monitoringresults in recent years have demonstrated that all parameters are below theEmission Limit Values stated in the IPPC Licence with the exception ofVolumetric Flow Rate. Medite have demonstrated that previous flow ratemonitoring results were in error and were likely the product of incorrectmeasurements arising from variability in the flow at the present stackmonitoring location. All appropriate preventive measures are taken against theemission of air pollution by Medite, in particular through application of the BestAvailable Techniques (BAT) in the operation, maintenance and monitoring ofthe facility. Air Dispersion Modelling was conducted by ERM in October 2015to assess the likely environmental impacts due to air emissions from therelevant emission sources. The model concluded that there is no significantenvironmental impacts from the activities at the Medite facility predicted at off-site locations.

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7 Noise

The Existing EnvironmentThe site is situated approximately 4 km east of the centre of Clonmel, Co.Tipperary, a town with a population of approximately 20,000. There area inwhich the site is located is however predominately rural and as such is quitesparsely populated. There are no hospitals, hotels, holiday accommodation, orschools in the immediate locality adjacent to the Medite site. There arehowever a number of private domestic dwellings in the vicinity which havebeen identified and agreed with the EPA as being potential noise SensitiveLocations (NSLs). These are summarised in Table 6.

Reference Location

Residential receptor 1 A detached two storey dwelling locatedapproximately 250m north east of the siteboundary.

Residential receptor 2 A semi-detached single storey dwelling locatedapproximately 90m south of the site boundary.

Residential receptor 3 A detached single-storey dwelling locatedapproximately 210m west of the site boundary.

Residential receptor 4 A farmhouse building located approximately 600mnorth west of the Site boundary.

NSLs identified in the locality of the Medite facility.

The Impacts of the ActivityThe majority of on-site fixed plant (sorting and processing equipment etc.) arehoused internally within the on-site buildings and as such do not contributesignificantly to the noise level to the surrounding environment. The mainsources of noise from the Medite site are as follows:

Boilers; Process area; Debarker Equipment; Wastewater Treatment Plant; Site vehicles.

Traffic on the major and local roads also influences the ambient noiseenvironment as evidenced by previous annual noise surveys. The ambient

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noise environment at receptors is good and within a range typical of a ruralenvironment. Ongoing noise monitoring at the existing facility indicatescompliance with the current licence limits.

The Measures to Mitigate Adverse ImpactsMedite is required under its licence to carry out a noise survey of the siteoperations annually and within the requirements of the EPA Guidance Note forNoise (NG4) (EPA, 2012). Monitoring takes place at 4 noise measurementpositions agreed with by the EPA. The IPPC Licence requires that activities onsite do not exceed the following sound pressure limits:

Daytime: 55 dB(A) Leq, 30 minutes

Night-time: 45 dB(A) Leq, 15 minutes

Additionally the licence states that there is to be no clearly audible tonal orimpulsive component in the noise emission from the activity at any noisesensitive location.

The most recent noise monitoring survey carried out by Resource andEnvironmental Consultants (REC) Limited concluded that the noise generatedby activities within the site was within the licence requirements. Table 7summarises the locations and characteristics of the noise measurementpositions used for the 2014 survey:

Ref Location Location Characteristics

AN1 Located in the field approximately8m south of the residentialreceptor.

The noise climate at this locationconsisted of distant industrial noisefrom Medite and occasional traffic fromthe adjacent main road.

AN2 Located on the grassed area infront of the residential receptor.

The noise climate at this locationconsisted of distant industrial noisefrom Medite and occasional road trafficfrom the main road.Occasional vehicles were observed touse the road known as RedmondstownCottages close tothe location of the sound level meter.

AN3 Located on the grassed area onthe opposite side of the road totheresidential receptors.

The noiseclimate at this location consisted ofdistant noise from Medite andoccasional road traffic.

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Ref Location Location Characteristics

AN4 Located in the field on theopposite side of the main road tothe farmhousebuilding, approximately 4m fromthe edge of the main road.

The noise climate at this locationconsisted of occasional road traffic.

Summary of the locations and characteristics of the noisemeasurement positions, 2014

The site is surrounded on all sides by woodland which Medite maintains. Thiswoodland helps to attenuate noise and pollution from the site while having theadditional benefit of helping both to mitigate against climate change andcontribute to floodplain management. To mitigate against the impact of trafficnoise, Medite limits, where possible, vehicle movements to and from the siteoutside of normal working hours.

A Non-Technical SummaryAnnual noise monitoring is conducted at four noise sensitive receptors, agreedby the EPA, in close proximity to the facility. The general area in which theMedite facility is located can be described as rural in nature however land usein the area is a mixture of agricultural and commercial. Traffic on the majorand local roads also influences the ambient noise environment as evidencedby previous noise surveys. In summary, the ambient noise environment atreceptors is good and within a range typical of a rural environment. Annualnoise monitoring surveys have concluded that the facility is in compliance withthe conditions of the IPPC Licence during the daytime, evening and night-timeperiods and within the requirements of the EPA Guidance Note for Noise(NG4) (EPA, 2012).

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8 Climate

The Existing EnvironmentThe Intergovernmental Panel on Climate Change (IPCC) has concluded in itsfifth assessment report (AR5) that warming of the climate system isunequivocal and that atmospheric concentrations of carbon dioxide, methane,and nitrous oxide have increased to levels unprecedented in at least the last800,000 years. The IPCC has stated that the human influence on the climatesystem is clear and it is extremely likely (a 95-100% probability) that humaninfluence was the dominant cause of global warming between 1951-2010.

In terms of human influence, it is the emission of Greenhouse Gases (GHG)which has the greatest impact on the climate system. CO2 is the mostanthropogenically influenced of these Greenhouse Gas and ambient levelshave risen exponentially since the beginning of the Industrial Revolution. Thedramatic increase in the combustion of hydrocarbons during this period,coupled with large scale deforestation, have led to significant increases inatmospheric concentrations of CO2. According to reports published by theIPCC, global concentrations have risen from pre-industrialisation levels ofaround 280 ppm to present levels of 400 ppm.

Ireland is committed to tackling climate change and to date has signed up tothe United Nations Framework Convention on Climate Change (UNFCCC) inand ratified the Kyoto Protocol, in principle in 1997 and formally in May 2002.For the purposes of the EU burden sharing agreement under Article 4 of theKyoto Protocol, in June 1998, Ireland agreed to limit the net growth of the sixGHGs under the Kyoto Protocol to 13% above the 1990 level over the period2008 to 2012. The UNFCCC is continuing detailed negotiations in relation toGHGs reductions and in relation to technical issues such as EmissionsTrading and burden sharing.

On a commercial level, climate change is tackled via the EU EmissionsTrading Scheme. This scheme came into operation on 1 January 2005 andoperates on a "cap and trade" basis. EU Member State governments arerequired to set an emissions cap for each installation in the scheme. Meditefulfils the requirements under the European Communities (Greenhouse GasEmissions Trading) Regulations 2004 to operate with a Greenhouse GasEmissions Permit. As a consequence the emission of GHGs from the facilityare capped annually and it is therefore economically beneficial for Medite toreduce GHG emissions where possible.

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The Impacts of the ActivityThe Medite facility emits greenhouse gases from the combustion of naturalgas, diesel, liquefied petroleum gas (propane) and through the use ofelectricity. Annual usage of fuels and the equivalent tonnes of CO2 emitted aredetailed in Table 8.

2014 2013

MW tCO2/MW tCO2 MW tCO2/MW tCO2

Electricity 104,478.00 0.469 48,989.73 101,447.00 0.469 47,568.50

TJ tCO2/TJ tCO2 TJ tCO2/TJ tCO2

Natural Gas 101.709 56.87 5,783.86 97.736 57.03 5,573.57

Biomass 1051.781 0 0 1,017.847 0 0

Propane 0.315 63.70 20.04 0.691 63.70 44.04

Diesel 0.081 73.30 5.90 0.081 73.30 5.90

Total 54,799.54 53,192.02

Energy Usage and Equivalent CO2 Emissions

8.2.1 ElectricityElectricity is supplier from the national grid and arrives as a 110 kV alternatingcurrent (AC) supply. It is stepped down for the plant distribution network to 10kV. AC in two 20 MW transformers. Electricity provides approximately 24% ofthe sites overall energy requirements but contributes 90% of CO2 emissions.

The main uses of the electricity are as follows:

Motor control centre distribution; Plant lighting and utilities; Process drives (the largest being the refiners and the log chipper).

8.2.2 Natural GasNatural Gas is used to heat the thermal oil which in turn is used to heat thecontinuous steel belt in production line 1. Natural gas is also used as a back-up in the 2 boilers in production line 1. Natural gas accounts for approximately7% of the overall energy consumption and contributes 11% of total CO2

emissions.

8.2.3 LPGLiquefied petroleum gas (LPG) is used to power smaller forklifts and fuels thepilot flame for the Line 1 Energy Plant (boiler system). The LPG is stored intwo storage tanks on site. The total storage capacity of LPG on the site is 35tonnes. CO2 emissions from the use of LPG on site are considered minor.

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8.2.4 Diesel FuelDiesel fuel is stored in two above ground mild steel storage tanks. The tankcapacities are 22,000 litres and 2,750 litres. The diesel is used primarily topower the large site vehicles. CO2 emissions from the use of diesel on site areconsidered minor.

8.2.5 BiomassBiomass is used to generate 69% of the sites energy requirements with zeronet CO2 equivalent emissions. Biomass is considered a renewable energysource based on the concept that the plant material used can be replacedthrough re-growth and the carbon dioxide that is emitted from burning theharvested biomass can be absorbed by new plant growth.

The biomass fuel used at Medite is obtained from the following sources:

bark from the log debarker; hogged board trim from the saws; sander dust from the sanding operation; other wood-based materials generated on-site; wood biomass purchased in the form of recovered / recycled clean

wood; wood biomass in the form of wood residues purchased from sawmills; forest recovered residue e.g. brash bundles.

Percentage of Total Energy Consumption by Fuel Type Summary,2014

Electricity24%

Natural Gas7%

Biomass69%

ENERGY CONSUMPTION

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Percentage of Total Associated CO2 Equivalent Emissions by FuelType, 2014

The Measures to Mitigate Adverse ImpactsMedite has established a cross-functional Energy Team at the facility toimplement energy projects that will reduce energy consumption, which willconsequently reduce Greenhouse Gas emissions and operating costs. Theteam continuously monitors and records the energy profile of the facilitythrough weekly meetings and uses these datasets to identify inefficienciesthroughout the various energy systems. The Energy Team also sets outlonger-term goals for energy efficiency which are implemented as part ofMedite’s Environmental Management Plan (EMP).

All appropriate preventive measures are taken against the emission ofGreenhouse Gases by Medite, in particular through application of the BestAvailable Techniques (BAT) in the operation, maintenance and monitoring ofthe facility.

A Non-Technical SummaryMedite operates under a Greenhouse Gas Emissions Permit and thereforehas an economical incentive to reduce GHG emissions where possible.

The Medite facility’s energy requirements are primarily met through therecovery of wood biomass, bark, process dust and culled product. Thisbiomass is used as fuel for the energy plant and as boiler feed. Biomass iscarbon neutral and as such has virtually no impact on climate forcingmechanisms.

Electricity89%

Natural Gas11%

Biomass0%

CO2 (Tonnes CO2 Eq.)

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9 Landscape, Material Assets and Cultural Heritage


9.1.1 LandscapeThe site is located north of the River Suir and is accessed via a local accessroad off the N24. The existing buildings in the Medite facility are situatedapproximately 50m back from this local access road. The population density ofthe surrounding countryside would be considered low. The site is largelyobscured from view from the site boundaries by a variety of shrubs and trees.The predominant feature of the site is the steam plumes from the boiler stacks,which are visible for several kilometres. Land use in the area is a mix ofagricultural pastures and commercial sites. The area owned by Medite isapproximately 62 hectares in total. The main production site is surrounded byan embankment and occupies an area of approximately 12 hectares. There isa historical landfill on the site located to the north of the main production area.The Medite site does not intrude upon any designated views.

The predominant feature of the site is the steam plumes from thedryer stacks

9.1.2 Cultural HeritageWithin the site boundary lies an ancient ringfort (TS083-010), which has laidundisturbed since the acquisition of the site by Medite. The ringfort is locatedat the edge of landscaped grounds to the east of the main production area(see Fig. 14 & 15). The area around the ringfort is overgrown and the interioris inaccessible. The ringfort was described in 1983 by the Office of Publicworks as "a large circular, flattish area surrounded by a large earthen bank onvery high embankment with a silted up fosse outside. Interior slopes from westto east and a very large depression running west to east along southern half isvisible"

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Ancient ringfort located to the east of the main production area atthe Medite facility, (Archaeological Survey of Ireland 2015)

Ancient ringfort located to the east of the main production area atthe Medite facility, (Archaeological Survey of Ireland 2015)

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The Impacts of the Activity

9.2.1 Internal Character of the siteThe site is dominated by the main production building and the three main dryerstacks. The site perimeter is bounded by dense woodland and hedgerow. Thiswoodland restrict views from the site to the surrounding landscape. Thereforethe surrounding boundary forms the skyline internally on the site.

9.2.2 External Character of the siteThe dominant and most visible feature of the site are the steam plumes fromthe dryer stacks. These plumes are visible from most of the immediatesurrounding locations (see Fig. 13 & 16). It is the three distinct plumes whichdraws attention to the stacks at locations further afield rather than the stackitself. Visibility of the site is limited by the surrounding landscape. Apart fromthe dryer stacks, the site is only visible from the main entrance. The site is notvery visible from any public roadways adjacent to the site as it is largelyscreened by the natural contours of the land and existingwoodland/hedgerows.

The Medite facility viewed from the main access road, (GoogleMaps 2015)

The Measures to Mitigate Adverse ImpactsThe careful selection of colours and finishes on the building has helped tominimise the visual impact of the facility when it is visible from outside the siteboundary. By maintaining woodlands and planting trees around the perimeterof the site has helped to integrate the building into the surroundingenvironment. Medite will continue to maintain the existing treelines and field

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boundaries around the facility and for the most part this will be sufficient toscreen the facility from the surrounding area.

A Non-Technical SummaryThe use and activity at the site is long established and an acknowledgedaspect of the landscape context. It is well screened from neighbouringproperties and residences. It is considered that the existing facility (andproposed development) will not impact on any important views, prospects orvistas and the screening around the facility ensures local residents views arenot obscured by the development in any significant way.

Overall the Medite facility is considered to have a long term slight negativeimpact due to the steam plumes which are visible from several locationsbeyond the site parameter. The overall impact on the landscape and visualcharacteristics of the area is considered to be neutral as its appearance isgenerally in keeping with other land uses in the locality.

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10 Interaction EffectsAll environmental factors are inter-related to some extent. Not only should theindividual significant impacts required to be considered when assessing theimpact of a development on the environment, but so too must theinterrelationships between these factors be identified and assessed. The inter-relationships between the factors are further developed in this section as partof the impact assessment. An interaction effects matrix is presented in Table9. The matrix examines the potential for the factor in the left hand column tohave an effect on the environmental media listed in the top row of the table.

Hum

an B

eing

s

Flor

a &

Fau

na

Soil

& G

roun

dwat

er

Surf

ace

Wat

er

Air

Noi

se

Clim

ate

Land

scap

e, M

ater

ial A

sset

san

d C

ultu

ral H

erita

ge

Human Beings - - - - - - -

Flora & Fauna - - - - - - -

Soil & Groundwater o o - - - - -

Surface Water o o o - - - -

Air o o - - - o -

Noise o - - - - - -

Climate o o - - - - -

Landscape, Material Assetsand Cultural Heritage - - - - - - -

Interaction effects matrix for the operation of the Medite facility

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The following table provides an assessment of the interaction effects between the factors and environmental media:

IndividualImpact

PotentialInteraction

Assessment of interaction effects

Soil &Groundwater

Human Beings Emissions to soils and groundwater could potentially contaminate groundwater in the localaquifer. Consumption could lead to illness in humans through drinking water abstracted from agroundwater borehole or contamination of local food supplies.

The emission to groundwater from the percolation areas associated with the 3 septic tanks on siteare not considered to have any significant impact on the quality of groundwater beyond theboundary of the site. The storage, use and handling of all substances that pose a risk to soil andgroundwater are well managed. The potential pathway from soil and groundwater to humanbeings has been minimised through containment and control measures.

Flora & Fauna Contaminated soil and groundwater could negatively impact on the flora in the surrounding area.This could indirectly impact fauna in the region that depend on this vegetation as a source of food.

Medite implements a Groundwater Protection Programme to ensure the protection of groundwaterat the site. This programme ensures that site operations are managed and controlled to ensurethat no potentially polluting substances or matter shall be permitted to discharge to groundwater.The Natura Impact Statement from Aquafact concluded that there were no negative effects felt onthe river environment due to the Medite facility’s effluents.

Surface Water Contaminated soil and groundwater could impact locally on the surface water quality throughgaining streams and natural springs.

An assessment of surface water quality in the area by the South Eastern River Basin Districtclassifies the status of the River Anner as ‘good’.

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IndividualImpact



Surface Water Human Beings Discharge to surface water could potentially affect water quality further downstream of the site.Consumption could lead to illness in humans through drinking water abstracted from a surfacewater supplies. Discharges to surface water from the site could also potentially contaminate anamenity and shellfish stocks further downstream of the River Suir.

The emission to surface water from the site are not considered to have any significant impact onthe quality of surface water beyond the boundary of the site. Surface water from the main externalprocess yard areas is drained into the site surface water system, which is combined and treatedwith process effluent in the site WWTP. Process and sanitary effluent is monitored for compliancewith licence parameter ELVs prior to release to the receiving environment. Regular monitoringensures that no environmental impacts on surface water quality will occur.

Flora & Fauna Constituents and properties of discharges to surface water could negatively impact on the flora inthe surrounding area. This could indirectly impact fauna in the region that depend on thisvegetation as a source of food.

All surface water emissions undergo treatment and monitoring prior to and during release.Treated effluent is tested on an ongoing basis to ensure compliance with IPPC Licenceschedules. Procedures are in place for the containment of spills which could potentially impact onthe quality of surface water in the region. The Natura Impact Statement from Aquafact concludedthat there were no negative effects felt on the river environment due to the Medite facility’seffluents.

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IndividualImpact



Soil &Groundwater

Surface water is a potential pathway for contaminants to soil and groundwater. The structure andproductivity of soils could possibly be negatively impacted for prolonged periods.

The potential pathway from soil and groundwater to human beings has been minimised throughtreatment and monitoring of effluent prior to release and the containment and control measuresapplied to chemicals and bulk liquids.

Air Human Beings Air emissions have the potential to impact on human beings through accident releases, like thoseresulting from fire/explosion, or from process emissions to atmosphere.Adequate safely control measures are in place to minimise the likelihood of fires/explosionsoccurring on the site. Fire response procedures are designed to minimise the impact of smoke onhuman beings in the event a fire does occur. Abatement equipment is in place to treat each airemission and this equipment is well maintained through the maintenance scheduling system. Airemissions are monitored on an ongoing basis to ensure compliance with IPPC Licence schedules.

Air Dispersion Modelling was conducted by ERM in October 2015 to assess the likelyenvironmental impacts due to air emissions from the relevant emission sources. The modelconcluded that there is no significant environmental impacts from the activities at the Meditefacility.

Flora & Fauna Emissions from the site have the potential to affect the health of fauna in the region. Troposphericozone can be created through the interaction of solar radiation with oxides of Nitrogen (NOx),Volatile Organic Compounds (VOCs) and Carbon Monoxide (CO). Vegetation exposure to ozoneimpedes photosynthesis, growth, and other plant functions

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IndividualImpact



Abatement equipment is in place to treat each air emission and this equipment is well maintainedthrough the maintenance scheduling system. Air emissions are monitored on an ongoing basis toensure compliance with IPPC Licence schedules.

Climate Air emissions can have a direct effect on the climate through the combustion of fossil fuels.Burning fossil fuels releases carbon to the atmosphere which previously had been sequesteredfor millions of years. Combustion of fossil fuels produces Greenhouse Gases both directly, in theform of Carbon dioxide, and indirectly, in the form of Tropospheric Ozone. A net increase inatmospheric Greenhouse Gases results in positive radiative forcing.

Biomass is used to generate 69% of the sites energy requirements with zero net CO2 equivalentemissions. Biomass is considered a renewable energy source based on the concept that the plantmaterial used can be replaced through re-growth and the carbon dioxide that is emitted fromburning the harvested biomass can be absorbed by new plant growth.

Noise Human Beings Noise from the site has the potential to impact on human beings particularly through the presenceof tonal or impulsive noise emissions.

The ambient noise environment at receptors is good and within a range typical of a ruralenvironment. Annual noise monitoring surveys have concluded that the facility is in compliancewith the conditions of the IPPC Licence

Climate Human Beings Positive climate forcing mechanisms can affect human beings though climate change.Anthropogenic drivers of climate change can significantly affect the climate that a regionexperiences.

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Medite Europe Ltd.

45

IndividualImpact



Medite have established a cross-functional Energy Team at the facility to implement energyprojects that will reduce energy consumption, which will consequently reduce Greenhouse Gasemissions. Biomass is used to generate 69% of the sites energy requirements with zero net CO2

equivalent emissions.

Flora & Fauna Climate variability and change affects birdlife and animals in a number of ways; birds lay eggsearlier in the year than usual, plants bloom earlier and mammals may come out of hibernationsooner. The distribution of animals is also affected; with many species moving closer to the polesas a response to the rise in global temperatures. The migration patterns and nesting locations ofbirds is also affected by the variations in temperature.

In an effort to reduce the impact on the climate, the Medite Energy Team sets out both short andlonger-term goals for energy efficiency which are implemented as part of Medite’s EnvironmentalManagement Plan (EMP).

Assessment of the interaction effects between the factors and environmental media.

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Updated Appropriate Assessment

Attachment H

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Appropriate Assessment Screening Document

for

Medite Europe Ltd.’s

Manufacturing Facility in Clonmel, Co. Tipperary

Produced by

AQUAFACT International Services Ltd.

On behalf of

Medite Europe Ltd.

November 2015

AQUAFACT INTERNATIONAL SERVICES ltd.

12 KILKERRIN PARK,

GALWAY

www.aquafact.ie

[email protected]

Tel +353 (0) 91 756812

fax +353 (0) 91 756888

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http://www.aquafact.ie/

Table of Contents

1. Introduction 1

1.1. Requirement for an Article 6 Assessment ..................................................................... 1

1.2. The Aim of this Report ................................................................................................... 2

1.3. Appropriate Assessment Process ................................................................................... 2

1.4. Monte Carlo simulations ................................................................................................ 3 2. Background – An overview of Medite 3

3. Description of the Receiving Environment 5

4. Natura 2000 Sites 9

4.1. Identification of Relevant Natura 2000 Sites ................................................................. 9

4.2. Designated Sites of Relevance ..................................................................................... 13

4.3. Characteristics of the Designated Sites ........................................................................ 13 4.3.1. Lower River Suir cSAC (IE002137) .......................................................................................... 13 5. Potential Impacts of the Proposal 14

6. Screening Assessment 14

6.1. Impact on Habitats ....................................................................................................... 14 6.1.1. Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation ........................................................................................................................ 14 6.1.2. Hydrophilous tall herb fringe communities of plains and of the montane to alpine levels. .. 15

6.2. Impact on Species ........................................................................................................ 15 6.2.1. Otter (Lutra lutra) .................................................................................................................. 15 6.2.2. Salmon (Salmo salar) ............................................................................................................. 15 6.2.3. Twaite Shad (Alosa fallax fallax) ............................................................................................ 16 6.2.4. River Lamprey (Lampetra fluviatilis) ...................................................................................... 16 6.2.5. Brook Lamprey (Lampetra planeri) ........................................................................................ 17 6.2.6. Sea Lamprey (Petromyzon marinus) ...................................................................................... 17 6.2.7. White-clawed Crayfish (Austropotamobius pallipes) ............................................................. 18 6.2.8. Freshwater Pearl Mussel (Margaritifera margaritifera) ........................................................ 18

6.3. Cumulative and In Combination Effects ....................................................................... 18 7. Screening Conclusion 19

8. References 19

List of Figures

Figure 2.1: Location map of the Medite facilities north and south outflows. ................................................... 4

Figure 3.1: View looking upstream towards southern outflow. ....................................................................... 8

Figure 3.2: View looking from the east bank upstream of the northern outflow. ............................................. 9

Figure 4.1: Location of Medite facility – waste water discharge in relation to Natura 2000 sites within 15km.10

List of Tables

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Table 3.1: Water quality results (15th October 2015) ........................................................................................ 6

Table 3.2: Environmental Quality Standards from the 2009 Regulations ......................................................... 6

Table 3.3: Summary of effluent concentrations for 2014/2015. ....................................................................... 7

Table 3.4: Kick sample results from Upstream of North Outflow. .................................................................... 7

Table 3.5: Kick sample results from Downstream of South Outflow. ............................................................... 7

Table 4.1: Natura 2000 sites, Qualifying Interests, Potential Impacts and Screening Assessment. * denotes

priority habitats. ................................................................................................................................... 11

Appendix 1 Lower River Suir (2137): site synopsis

Appendix 2 Monte Carlo results

Appendix 3 Hydrological data

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Appropriate Assessment Screening,

Medite Facility, Co Tipperary

Medite Europe Ltd

November 2015

1. Introduction

1.1. Requirement for an Article 6 Assessment

This report assesses whether the discharges from Medite Europe Ltd.’s manufacturing facility in

Clonmel, alone or in combination with other plans and projects, are likely to have significant effects

on a Natura 2000 Site(s) in view of best scientific knowledge and the conservation objectives of the

site(s). Natura 2000 Sites are those identified as sites of European Community importance

designated as Special Areas of Conservation under the Habitats Directive or as Special Protection

Areas under the Birds Directive.

Articles 6(3) and 6(4), of the Habitats Directive, set out the decision-making tests for plans and

projects likely to affect Natura 2000 sites (Annex 1.1). Article 6(3) establishes the requirement for

Appropriate Assessment (AA):

Any plan or project not directly connected with or necessary to the management of the [Natura

2000] site but likely to have a significant effect thereon, either individually or in combination

with other plans or projects, shall be subjected to appropriate assessment of its implications for

the site in view of the site’s conservation objectives. In light of the conclusions of the

assessment of the implications for the site and subject to the provisions of paragraph 4, the

competent national authorities shall agree to the plan or project only after having ascertained

that it will not adversely affect the integrity of the site concerned and, if appropriate, after

having obtained the opinion of the general public.

Article 6(4) states:

If, in spite of a negative assessment of the implications for the [Natura 2000] site and in the

absence of alternative solutions, a plan or project must nevertheless be carried out for

imperative reasons of overriding public interest, including those of a social or economic nature,

Member States shall take all compensatory measures necessary to ensure that the overall

coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory

measures adopted.

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1.2. The Aim of this Report

This screening document has been prepared in accordance with current guidance (Appropriate

Assessment of Plans and Projects in Ireland – Guidance for Planning Authorities [DEHLG, 2009,

Revised February 2010]; EU Guidance document on Article 6(4) of the ‘Habitats Directive’ 92/43/EEC

[EC, 2007]; Assessment of plans and projects significantly affecting Natura 2000 sites.

Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive

92/43/EEC [EC, 2002] and Managing Natura 2000 Sites: The provisions of Article 6 of the ‘Habitats’

Directive 92/43/EEC [EC, 2000]) and provides an assessment of the ecological impacts of the

discharge of waste water from Medite Europe Ltd.’s manufacturing facility in Clonmel.

This document provides the information required in order to establish whether or not the

discharges are likely to have a significant impact on surrounding Natura 2000 sites in the context of

their conservation objectives and specifically on the habitats and species for which the site has been

designated.

By taking the ecological impact assessment in a step by step manner in relation to the habitats and

species of the Natura 2000 sites, together with their conservation objectives, this report seeks to

inform the screening process required as the first stage of the process pursuant to Article 6.3 of the

EU Habitats Directive.

The report is laid out as follows:

Section 1 provides an introduction, Section 2 provides a description of the proposed works and

Section 3 provides a description of the receiving environment. Section 4 details the Natura 2000

sites of relevance and their ecological characteristics, Section 5 details potential impacts of the

proposal and Section 6 provides the Screening Assessment followed by the Screening Conclusion in

Section 7.

1.3. Appropriate Assessment Process

There are four separate stages to undertaking an AA as outlined in current EU and DEHLG guidance:

1. Appropriate Assessment Screening

2. Appropriate Assessment – Natura Impact Statement

3. Assessment of Alternatives in cases where significant impact cannot be prevented

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4. Where no alternatives exist, an assessment of compensatory issues in the case of projects or

plans which can be considered to be necessary for imperative reasons of overriding public

interest (IROPI)

This document serves as Stage 1 Appropriate Assessment Screening.

1.4. Monte Carlo simulations

The Monte Carlo method is a set of computational statistics that rely on repeated random

sampling to compute their results. Monte Carlo methods are often used in simulating physical

and mathematical systems. These methods are most suited to calculation by a computer and

tend to be used when it is infeasible to compute an exact result with a deterministic algorithm.

This method is also used to complement the theoretical derivations. Monte Carlo methods are

especially useful for simulating systems with many coupled degrees of freedom, such as fluids,

disordered materials, strongly coupled solids, and cellular structures. They are used to model

phenomena with significant uncertainty in inputs. They are widely used in mathematics, for

example to evaluate multidimensional definite integrals with complicated boundary conditions.

2. Background – An overview of Medite

Medite Europe Ltd. produces Medite which constitutes a range of different Medium Density

Fibreboards (MDF) in Clonmel, Co. Tipperary. During the production process, waste water is

produced which may have elevated levels of different chemicals and other substances in it. This

waste water is released into the adjacent Anner River. In order to stay within the parameters of

their licence agreement, as well as within the parameters of the regulations set down by the

European Union’s Water Framework Directive and to avoid having any negative effects on the

conservation objectives of the Lower River Suir cSAC, Medite monitors effluents introduced to

the receiving aquatic environment from its facility to ensure that it is not significantly affected

by the chemicals present in the facilities effluents.

There are 2 aqueous emissions from the site to the River Anner: surface water run-off from part

of the log yard discharges via a lagoon and is known as the Northern Discharge. This is a non-

process surface water discharge.

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Surface water run-off from the rest of the log yard, joined by other minor emissions from the

process plant (such as refiner packing water) is passed through screening equipment and

settling ponds prior to discharge to the River Anner. This is known as the Southern Discharge

and is included in the SW2 discharge license which includes the combined process effluent and

southern run off effluents.

Figure 2.1: Location map of the Medite facilities north and south outflows.

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3. Description of the Receiving Environment

The discharge from the Medite Facility enters the River Anner one kilometer upstream of where it

joins the River Suir. The catchment for the Anner is predominantly agricultural land with some small

sections of mixed woodland along the east bank. The Medite plant to the west of the river is

surrounded predominately by young birch and conifer trees.

A site visit was carried out which included a walkover of both discharge pipes. Water samples were

taken upstream and downstream of the discharges along with kick samples. The results from the

water samples (see Table 3.1) showed that both total ammonia and phosphorous were below

mandatory levels. Total ammonia levels were classified as high status, with phosphorous classified

as good status but only marginally above high status concentrations (see Table 3.2 for EQS). The

Monte Carlo simulations agreed with these results in showing that discharge rates from the facility

would not cause a significant impact on the river (Monte Carlo results can be found in Appendix 3).

It predicted that the ammonia concentration of effluent could go as high as 27.5 mg/l N without

breaching the EQS of 0.09 mg/l limit (the maximum concentration for 2014/2015 was 8.7mg/l

N).Therefore, the current ELV of 10mg/l is adequate. The Monte Carlo simulation also found that the

discharge would not significantly impact the BOD level of the river. It found that the facilities

discharge could have BOD levels of up to 385 mg/l without causing any downstream impact. As the

facilities mean discharge for 2014/2015 of BOD was 11.63 mg/l (Table 3.3) the license limit of 50

mg/l will not be exceeded. As the levels of orthophosphate are at or above high status levels

upstream of the discharge “Good” status limits were used. The Monte Carlo simulation predicted

that the levels of orthophosphate in the discharge would cause a slight exceedance of the good

status EQS of 0.075 mg/l at 0.08 mg/l. This is as a result of the high background levels in the river

originating up stream of the Medite facility. It should be noted that the EPA monitoring station

downstream of the discharge has regularly shown a drop in orthophosphate from upstream stations.

The levels measure at the downstream station (no. 16A02-1100) have actually been below good

status and just exceeding high status. The pH levels were within the EQS standards (Table 3.2). The

levels of chromium, zinc and copper in the discharge are in quantities that will not have a significant

impact on the river (See Monte Carlo results Appendix 2).

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Table 3.1: Water quality results (15th October 2015)

Station pH Ammonia mg/l N

Nitrate mg/l N

Nitrite mg/l N

Phosphate mg/l P

Conductivity µS/cm

Temperature ˚C

North outflow

Upstream 8.48 <0.010 2.06 0.005 0.007 596 8.8

Downstream 8.38 <0.010 2.13 0.004 0.004 606 8.4

South outflow

Downstream 8.23 0.033 2.22 0.009 0.026 636 9.2

Table 3.2: Environmental Quality Standards from the 2009 Regulations

Parameter River Water Body

Thermal Conditions Temperature

≤1.5°C rise in ambient temperature outside mixing zone

Oxygenation Conditions Biochemical Oxygen Demand (BOD) (mg O2/l) Dissolved Oxygen (lower limit) Dissolved Oxygen (upper limit)

High status ≤1.3 (mean) or ≤2.2 (95%ile) Good status ≤1.5 (mean) or ≤2.6 (95%ile) 95%ile >80% saturation 95%ile >120% saturation

Acidification Status pH (individual values)

(1)Soft Water 4.5<pH<9.0 (2)Hard Water 6.0<pH<9.0

Nutrient Conditions Total Ammonia (mg N/l) Molybdate Reactive Phosphorus (MRP) mg P/l)

High status ≤0.040 (mean) or ≤0.090 (95%ile) Good status ≤0.065 (mean) or ≤0.140 (95%ile) High status ≤0.025 (mean) or ≤0.045 (95%ile) Good status ≤0.035 (mean) or ≤0.075 (95%ile)

Specific pollutants (annual average(3)(9)) Zinc(6) Copper(7) Chromium III Chromium VI

EQS µg/l(4)(5)(8) 8 or 50 or 100 5 or 30 4.7 3.4

(1) Water Hardness ≤100mg/l CaCO3 (2)Water Hardness >100mg/l CaCO3 (3)The calculation of the arithmetic mean and the analytical method used must be in accordance with technical specifications to be adopted for chemical monitoring and quality of analytical results in accordance with Directive 2000/60/EC of the European Parliament and of the Council, including how to apply an EQS where there is no appropriate analytical method meeting the minimum performance criteria. (4)The values for all metals are for dissolved metals i.e. after filtration through a 0.45 micron filter, in designing monitoring programmes, it was recommended that total chromium be determined. Where the result for total chromium is less than the EQS for Cr VI, no further investigation is deemed necessary. Where the total Chromium level is above the EQS, an assessment should be made of the potential discharges of Cr VI into the water body. Where there is a risk of Cr VI contamination, speciation studies should be included in the monitoring programme. (5)The values for all metals, except Chromium VI, are as added values to background concentrations. (6)In the case of Zinc, the standard shall be 8 μg/l for water hardness with annual average values less than or equal to 10 mg/l CaCO3, 50 μg/l for water hardness greater than 10 mg/l CaCO3 and less than or equal to 100 mg/l CaCO3 and 100 μg/l elsewhere.

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(7)In the case of Copper the value 5 applies where the water hardness measured in mg/l CaCO3 is less than or equal to 100; the value 30 applies where the water hardness exceeds 100 mg/l CaCO3. (8)Standards for compounds other than metals refer to total concentrations in the whole water sample. (9)AA-EQS means that for each representative monitoring point within the water body, the arithmetic mean of the concentrations measured over a twelve month monitoring period does not exceed the standard.

Table 3.3: Summary of effluent concentrations for 2014/2015.

BOD

(mg O2/l)

Ammonia

(mg/l N)

Orthophosphate

(mg/l P)

Mean 11.63 1.0 0.90

SD 9.21 1.44 0.38

The species returned from the kick samples collected up and downstream of the discharges can be

seen in Table 3.4 and 3.5 respectively.

Table 3.4: Kick sample results from Upstream of North Outflow.

Species Number Group Q value

Hydrobiidae 3160 C

Q3

Coleoptera (larvae) 104 C

Coleoptera (adult) 2 C

Hydropsychidae 13 C

Glossosomatidae 9 B

Limnephilidae 1 B

Gammarus 3 C

Table 3.5: Kick sample results from Downstream of South Outflow.

Species Number Group Q value

Ephemerellidae (Serratella ignita) 1 C

Q3-4

Heptagenia 2 A

Coleoptera (larvae) 35 C

Caenis 1 C

Leuctridae 1 B

Baetidae 33 B

Gammarus 74 C

Asellus 9 D

Coleoptera (adult) 1 C

Leptoceridae 1 B

Hydropsychidae 38 C

Polycentropodidae 2 C

Simuliidae papae 2 C

Valvatidae 5 C

Hydrobiidae 31 C

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Dirronota 2 C

Austropotamobius pallipes 1 C

Perla bipunctata 1 A

Q-values obtained for both upstream and downstream kick samples suggest a drop in water quality

when compared to EPA results from 2011 (Q4). However, the downstream result (Q3-4) was slightly

better than upstream (Q3). As Q3-4 is considered a transitional condition this may suggest a source

of pollution upstream. White-clawed crayfish were recorded downstream of the discharges.

Figure 3.1: View looking upstream towards southern outflow.

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Figure 3.2: View looking from the east bank upstream of the northern outflow.

4. Natura 2000 Sites

4.1. Identification of Relevant Natura 2000 Sites

In accordance with the European Commission Methodological Guidance (EC, 2002), a list of Natura

2000 sites that can be potentially affected by the proposed network extension has been compiled.

Adopting the precautionary principle in identifying these sites, it has been decided to apply a buffer

zone of 15km around the scheme infrastructure (Scott Wilson et al., 2006). Figure 4.1 shows the

proposed network extension in relation to the Natura 2000 sites within 15km of the project.

Table 4.1 details the qualifying interests (QIs)/special conservation interests (SCIs) of each of the

Natura 2000 sites, the potential impact (if any) upon them and whether the QI/SCI is screened in or

out for assessment.

Those sites or individual qualifying interests that are screened out at this stage (primarily as a result

of being too great a distance away from the works and having different habitat requirements) are

not assessed further. Sites/qualifying interests that are screened in for further Appropriate

Assessment are highlighted in Table 4.1.

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Figure 4.1: Location of Medite facility – waste water discharge in relation to Natura 2000 sites within 15km.

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Table 4.1: Natura 2000 sites, Qualifying Interests, Potential Impacts and Screening Assessment. * denotes priority habitats.

Natura 2000 Site Site Code Qualifying Interest Potential Impacts Screened In/Out

Lower River Suir cSAC

IE002137

1330 Atlantic salt meadows (Glauco-Puccinellietalia maritimae)

None-no pathway for interaction due to distance. (c. 80km southeast of discharge)

Screened out

1410 Mediterranean salt meadows (Juncetalia ollusk )

3260 Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation Potential interaction due to reduced

water quality

Further assessment

required 6430 Hydrophilous tall herb fringe communities of plains and of the montane to alpine levels

91A0 Old sessile oak woods with Ilex and Blechnum in the British Isles

None- no pathway for interaction due to terrestrial habitat

Screened out 91E0 Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae)

91J0 Taxus baccata woods of the British Isles

1029 Margaritifera margaritifera (Freshwater Pearl Mussel)

Potential interaction due to reduced water quality

Further assessment

required

1092 Austropotamobius pallipes (White-clawed Crayfish)

1095 Petromyzon marinus (Sea Lamprey)

1096 Lampetra planeri (Brook Lamprey)

1099 Lampetra fluviatilis (River Lamprey)

1103 Alosa fallax fallax (Twaite Shad)

1106 Salmo salar (Salmon)

1355 Lutra lutra (Otter)

Comeragh Mountains SAC

IE001952 3130 Oligotrophic to mesotrophic standing waters with vegetation of the Littorelletea uniflorae and/or Isoeto-Nanojuncetea

None – no pathway for interaction due to distance (c. 9.8 km south of discharge)

Screened out 3260 Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation

4010 Northern Atlantic wet heaths with Erica tetralix

4030 European dry heaths

4060 Alpine and Boreal heaths

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Natura 2000 Site Site Code Qualifying Interest Potential Impacts Screened In/Out

Comeragh Mountains cSAC (cont’d)

IE001952 8210 Calcareous rocky slopes with chasmophytic vegetation None – no pathway for interaction due to distance (ca 9.8 km south of discharge)

Screened out 8220 Siliceous rocky slopes with chasmophytic vegetation

1393 Drepanocladus vernicosus (Slender Green Feather-moss)

Nier Valley Woodlands cSAC

IE00668 91A0 Old sessile oak woods with Ilex and Blechnum in the British Isles

None – no pathway for interaction due to distance (ca. 9.2km south of discharge)

Screened out

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4.2. Designated Sites of Relevance

One cSAC from Table 4.1 above was screened in. This Natura 2000 site and its QIs are listed below:

Lower River Suir SAC (IE002137): 1355 Otter (Lutra lutra), 1106 Salmon (Salmo salar), 1103

Twaite Shad (Alosa fallax fallax), 1099 River Lamprey (Lampetra fluviatilis), 1096 Brook

Lamprey (Lampetra planeri), 1095 Sea Lamprey (Petromyzon marinus), 1092 White-clawed

Crayfish (Austropotamobius pallipes), 1029 Freshwater Pearl Mussel (Margaritifera

margaritifera), 6430 Hydrophilous tall herb fringe communities of plains and of the montane

to alpine levels and 3260 Water courses of plain to montane levels with the Ranunculion

fluitantis and Callitricho-Batrachion vegetation.

After an initial review of Natura 2000 sites, it was considered that “no pathway” exists by which the

proposed works could impact upon any other designated site and therefore only the Lower River

Suir cSAC and its QIs listed above were brought forward for further assessment.

4.3. Characteristics of the Designated Sites

The characteristics of each of the designated sites are described below. The Conservation Objectives

of each of these sites are discussed in Section 7 Screening Assessment in the context of the potential

impacts on them.

4.3.1. Lower River Suir cSAC (IE002137)

Lower River Suir cSAC consists of the freshwater stretches of the River Suir immediately south of

Thurles, the tidal stretches as far as the confluence with the Barrow/Nore immediately east of

Cheekpoint in Co. Waterford. The Suir has many tributaries including the Clodiagh in Co. Waterford,

the Lingaun, Anner, Nier, Tar, Aherlow, Multeen and Clodiagh in Co. Tipperary. The Suir and its

tributaries flow through the counties of Tipperary, Kilkenny and Waterford. The site crosses many

different types of geology including Devonian Sandstone, Carboniferous Limestone, Upper Palaezoic

Rocks, Lower Carboniferous Visean and Tournaisian, Silurian Rocks, Old Red Sandstone and Lower

Avonian Shales.

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This site is of ecological importance due to the presence of seven habitats listed in Annex I of the

E.U. Habitats Directive along with eight Annex II species listed on the same directive. This site is a

cSAC selected for Atlantic salt meadows, Mediterranean salt meadows, Hydrophilous tall herb fringe

communities of plains and of the montane to alpine levels, Water courses of plain to montane levels

with the Ranunculion fluitantis and Callitricho-Batrachion vegetation, Old sessile oak woods with Ilex

and Blechnum of the British Isles, Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-

Padion, Alnion incanae, Salicion albae), Taxus baccata woods of the British Isles which are priority

habitats in Annex I of the E.U. Habitats directive. This cSAC has also been selected for otters (Lutra

lutra), Salmon (Salmo salar), Twaite Shad (Alosa fallax fallax), River Lamprey (Lampetra fluviatilis),

Brook Lamprey (Lampetra planeri), Sea Lamprey (Petromyzon marinus), White-clawed Crayfish

(Austropotamobius pallipes), Freshwater Pearl Mussel (Margaritifera margaritifera) which appear in

Annex II of the same directive (the site synopsis can be found in Appendix 3).

5. Potential Impacts of the Proposal

The potential impact on Natura 2000 sites or their QIs from the waste water discharge is as follows:

Impacts on water quality due to increased nutrient levels.

6. Screening Assessment

6.1. Impact on Habitats

6.1.1. Water courses of plain to montane levels with the Ranunculion fluitantis and

Callitricho-Batrachion vegetation

Floating river vegetation is sensitive to nutrient enrichment as this can cause excessive plant growth.

The excessive growth of plants such as filamentous green algae can smother other aquatic plants by

out competing them for resources.

However, the waste water from the Medite facility will not cause such conditions due to the low

level of nutrient input. This conclusion is supported by the results from the site visit which show

both total ammonia and phosphate downstream of the discharge are below safe levels (Surface

Water Regulations, 1989). The conservation objective for this habitat is to maintain/ restore

favourable conservation status (NPWS, 2015). The operation of this facility will not impact on this QI,

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its conservation objectives nor the integrity of the SAC and therefore can be screened out.

6.1.2. Hydrophilous tall herb fringe communities of plains and of the montane to alpine

levels.

This habitat occurs at the edges of slow moving rivers in lowland areas and is sensitive to pollution of

watercourses arising from nutrient enrichment. The waste water from the Medite facility will not

cause such conditions due to the low level of nutrient input. This conclusion is supported by the

results from the site visit which show both total ammonia and phosphate downstream of the

discharge are below safe levels (Surface Water Regulations, 1989). The conservation objective for

this habitat is to maintain/ restore favourable conservation status (NPWS, 2015). The operation of

this facility will not impact on this QI, its conservation objectives nor the integrity of the cSAC and

therefore can be screened out.

6.2. Impact on Species

6.2.1. Otter (Lutra lutra)

One of the main threats to otter populations is organic pollution which can cause a reduction in their

prey i.e. fish kills, reduction of crustaceans such as white-clawed crayfish and molluscs. However, the

discharge will not cause such effects due to the low levels of nutrients released. Samples taken down

stream of the outflow showed that the discharge did not elevate nutrient levels above

recommended levels (Surface Water Regulations 1989, Freshwater Fish Directive 78/659/EEC,

Salmonid Waters Regulations 1988). The conservation objective for this species is to maintain/

restore favourable conservation status (NPWS, 2015). The operation of this facility will not impact on

this QI, its conservation objectives nor the integrity of the cSAC and therefore can be screened out.

6.2.2. Salmon (Salmo salar)

Salmon require rivers with good water quality and clean unsilted gravel beds for successful breeding

and recruitment. The excessive plant growth caused by nutrient enrichment causes night time lags in

oxygen levels which can cause fish kills. A secondary impact of excessive growth is the retention of

silt and fine particles due to obstruction by the plants making the sediment unsuitable for eggs to

survive.

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The discharge will not cause such effects due to the low levels of nutrients released. Samples taken

down stream of the outflow showed that the discharge did not elevate nutrient levels above





6.2.3. Twaite Shad (Alosa fallax fallax)

Twaite shad spends most of its life in estuaries and coastal waters, but migrates upstream in late

spring to breed. Reduction in water quality due to nutrient enrichment could have a negative effect

on spawning success.







6.2.4. River Lamprey (Lampetra fluviatilis)

River lamprey breed in freshwater rivers and streams. The adults spawn in spring in gravel beds,

after hatching larvae drift downstream to river beds with silty sediments where they live as filter

feeders until developing into adults and switch to feeding parasitically on large fish in

estuarine/waters. Nutrient enrichment could cause impacts on oxygen level and spawning bed

suitability. However, there is considered to be no significant pressures impacting these species

(NPWS, 2013).







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6.2.5. Brook Lamprey (Lampetra planeri)

Brook lamprey breed in freshwater rivers and streams. The adults spawn in spring in gravel beds,

after hatching larvae drift downstream to river beds with silty sediments where they live as filter

feeders until developing into young adults. The young adults then overwinter before migrating short

distances upstream to spawn. Nutrient enrichment could cause impacts on oxygen level and

spawning bed suitability. However, there is considered to be no significant pressures impacting

these species (NPWS, 2013).







6.2.6. Sea Lamprey (Petromyzon marinus)

Sea lamprey breed in freshwater rivers. The adults spawn in spring in gravel beds. After hatching,

larvae drift downstream to river beds with silty sediments where they live as filter feeders until

developing into adults. Young adults migrate downstream to estuarine water and open sea in late

autumn – winter. Nutrient enrichment could cause impacts on oxygen level and spawning bed

suitability. However, the main impediment to good conservation status are barriers to upstream

migration (NPWS, 2013).




Salmonid Waters Regulations 1988). The conservation objectives for this species is to maintain/



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6.2.7. White-clawed Crayfish (Austropotamobius pallipes)

White-clawed crayfish is the largest non-marine invertebrate found in Ireland, growing to 11cm in

length and living for maximum of 10 years. They are considered to be tolerant of organic pollution

according the Q-value metric. However, high levels could still impact on the population. The major

threat to white-clawed crayfish is the possible introduction of crayfish plague and non-native

crayfish.




Salmonid Waters Regulations 1988). The conservation objectives for this species is to maintain/



6.2.8. Freshwater Pearl Mussel (Margaritifera margaritifera)

The freshwater pearl mussel is the largest bivalve mollusc in Ireland and is a very slow growing, long

lived animal. It requires clean, well oxygenated water to survive. Siltation of river beds along with

algae and plant growth smother the young which burrow into the sediment and in more severe

cases can smother adults.







6.3. Cumulative and In Combination Effects

The results from samples taken during the site visit showed that inputs from the Medite facility had

little to no impact on the River Anner water quality: none of the results of nutrients analysed

exceeded environmental quality standards. This is supported by records from EPA monitoring

stations (Station No. 0900 upstream & station No. 1100 downstream) indicating a reduction in

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orthophosphate downstream of the discharge.

The area upstream of the Medite facility is used for intensive agriculture. This requires the spread of

significant levels of fertilizer which contains high levels of nitrogen and phosphorous with rainfall

washing the excess fertilizer into the river. This is reflected by the high background levels of

orthophosphates recorded from the EPA’s monitoring station at Thorny Bridge indicating that

nutrient levels are almost at breach point before passing the Medite Facility’s discharge site.

The Medite facility has historically been discharging its effluent into the River Anner in combination

with nutrients from agriculture upstream. Levels of orthophosphate have consistently been lower

downstream of the discharge (EPA station No. 1100) compared to upstream (EPA station No. 0900)

(EPA, 2013). Therefore, no significant cumulative or in combination effects are expected as a result

of the Medite waste water discharge.

7. Screening Conclusion

It is unlikely that there will be any negative effects felt on the aquatic environment due to the

Medite facility’s effluents. This is supported by the data collected from the EPA’s river monitoring

stations that indicate that orthophosphate levels, the parameter of most concern, decrease

downstream of the manufacturing plant. The Monte Carlo predictions along with sampling carried

out by AQUAFACT also indicates no negative impact.

Therefore, based on the above there is no requirement to proceed to Stage 2 Appropriate

Assessment.

8. References

DEHLG. 2009. Appropriate Assessment of Plans and Projects in Ireland – Guidance for Planning

Authorities (Revised February 2010).

European Commission. 2000. Managing Natura 2000 Sites: The provisions of Article 6 of the

‘Habitats’ Directive 92/43/EEC. Office for Official Publications of the European Communities,

Luxembourg.

European Commission. 2002. Assessment of plans and projects significantly affecting Natura 2000

sites. Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive

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92/43/EEC. Office for Official Publications of the European Communities, Luxembourg.

European Commission. 2007. EU Guidance document on Article 6(4) of the ‘Habitats Directive’

92/43/EEC. Clarification of the concepts of: alternative solutions, imperative reasons of overriding

public interest, compensatory measures, overall coherence, opinion of the Commission.

Hayden, T. & R. Harrington. (2000). Exploring Irish Mammals. Duchas, Dublin.

NPWS (2015) Conservation objectives for Lower River Suir SAC [002137]. Generic Version

4.0. Department of Arts, Heritage and the Gaeltacht.

NPWS (2013). The Status of Protected EU Habitats and Species in Ireland. Overview Volume 1.

Unpublished Report, National Parks & Wildlife Services. Department of Arts, Heritage and the

Gaeltacht, Dublin, Ireland. Editor: Deirdre Lynn

Scott Wilson, Levett – Therivell Sustainability Consultants, Treweek Environment Consultants and

Land Use Consultants. 2006. Appropriate Assessment of Plan

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Appendix 1

Lower River Suir (2137): Site Synopsis

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Site Name: Lower River Suir SAC

Site Code: 002137

Lower River Suir SAC consists of the freshwater stretches of the River Suir immediately south of

Thurles, the tidal stretches as far as the confluence with the Barrow/Nore immediately east of

Cheekpoint in Co. Waterford, and many tributaries including the Clodiagh in Co. Waterford, the

Lingaun, Anner, Nier, Tar, Aherlow, Multeen and Clodiagh in Co. Tipperary. The Suir and its

tributaries flow through the counties of Tipperary, Kilkenny and Waterford.

Upstream of Waterford city, the swinging meanders of the Suir criss-cross the Devonian sandstone

rim of hard rocks no less than three times as they leave the limestone-floored downfold below

Carrick-on-Suir. In the vicinity of Carrick-on-Suir the river follows the limestone floor of the Carrick

Syncline. Upstream of Clonmel the river and its tributaries traverse Upper Palaeozoic Rocks, mainly

the Lower Carboniferous Visean and Tournaisian. The freshwater stretches of the Clodiagh River in

Co. Waterford traverse Silurian rocks, through narrow bands of Old Red Sandstone and Lower

Avonian Shales, before reaching the carboniferous limestone close to its confluence with the Suir.

The Aherlow River flows through a Carboniferous limestone valley, with outcrops of Old Red

Sandstone forming the Galtee Mountains to the south and the Slievenamuck range to the north.

Glacial deposits of sands and gravels are common along the valley bottom, flanking the present-day

river course.

The site is a Special Area of Conservation (SAC) selected for the following habitats and/or species

listed on Annex I / II of the E.U. Habitats Directive (* = priority; numbers in brackets are Natura 2000

codes):

[1330] Atlantic Salt Meadows

[1410] Mediterranean Salt Meadows

[3260] Floating River Vegetation

[6430] Hydrophilous Tall Herb Communities

[91A0] Old Oak Woodlands

[91E0] Alluvial Forests*

[91J0] Yew Woodlands*

[1029] Freshwater Pearl Mussel (Margaritifera margaritifera)

[1092] White-clawed Crayfish (Austropotamobius pallipes)

[1095] Sea Lamprey (Petromyzon marinus)

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[1096] Brook Lamprey (Lampetra planeri)

[1099] River Lamprey (Lampetra fluviatilis)

[1103] Twaite Shad (Alosa fallax)

[1106] Atlantic Salmon (Salmo salar)

[1355] Otter (Lutra lutra)

Alluvial wet woodland is a declining habitat type in Europe as a result of drainage and reclamation.

The best examples of this type of woodland in the site are found on the islands just below Carrick-

on-Suir and at Fiddown Island. Species occurring here include Almond Willow (Salix triandra), White

Willow (S. alba), Rusty Willow (S. cinerea subsp. oleifolia), Osier (S. viminalis), with Yellow Iris (Iris

pseudacorus), Hemlock Water-dropwort (Oenanthe crocata), Wild Angelica (Angelica sylvestris),

Pendulous Sedge (Carex pendula), Meadowsweet (Filipendula ulmaria) and Common Valerian

(Valeriana officinalis). The terrain is littered with dead trunks and branches and intersected with

small channels which carry small streams to the river. The bryophyte and lichen floras appear to be

rich. A small plot is currently being coppiced and managed by the National Parks and Wildlife

Service. In the drier areas species such as Ash (Fraxinus excelsior), Hazel (Corylus avellana),

Hawthorn (Crataegus monogyna) and Blackthorn (Prunus spinosa) occur.

Eutrophic tall herb vegetation occurs in association with the various areas of alluvial forest and

elsewhere where the floodplain of the river is intact. Characteristic species of the habitat include

Meadowsweet, Purple Loosestrife (Lythrum salicaria), Marsh Ragwort (Senecio aquaticus), Ground

Ivy (Glechoma hederacea) and Hedge Bindweed (Calystegia sepium).

Old oak woodlands are also of importance at the site. The best examples are seen in Portlaw Wood

which lies on both sides of the Clodiagh River. On the south-facing side the stand is more open and

the oaks (mainly Pedunculate Oak, Quercus robur) are well grown and spreading. Ivy (Hedera helix)

and Bramble (Rubus fruticosus agg.) are common on the ground, indicating relatively high light

conditions. Oak regeneration is dense, varying in age from 0-40 years and Holly (Ilex aquifolium) is

fairly common but mostly quite young. Across the valley, by contrast, the trees are much more

closely spaced and though taller, are poorly grown on average. There are no clearings; large oaks

extend to the boundary wall. In the darker conditions, Ivy is much rarer and Holly much more

frequent, forming a closed canopy in places. Oak regeneration is uncommon since there are as yet

few natural clearings. The shallowness of the soil on the north-facing slope probably contributes to

the poor tree growth there. The acid nature of the substrate has induced a ‘mountain’ type oak

wood community to develop. The site is quite species-rich throughout, including an abundance of

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mosses, liverworts and lichens. The rare lichen Lobaria pulmonaria, an indicator of ancient

woodlands, is found here.

Inchinsquillib Wood consists of three small separate sloping blocks of woodland in a valley cut by the

young Multeen River and its tributaries through acidic Old Red Sandstone and Silurian rocks. Two

blocks, both with an eastern aspect, located to the north of the road, are predominantly of Sessile

Oak (Quercus petraea) and Hazel, with Downy Birch (Betula pubescens), Ash and Holly. The ground

flora is quite mixed with, for example, Wood-sedge (Carex sylvatica), Bluebell (Hyacinthoides non-

scripta), Primrose (Primula vulgaris), Wood-sorrel (Oxalis acetosella), Pignut (Conopodium majus)

and Hard Fern (Blechnum spicant). The base poor nature of the underlying rock is to some extent

masked by the overlying drift. The third block, to the south of the road, and with a northern aspect,

is a similar although less mature mixture of Sessile Oak, Birch and Holly. Here the influence of the

drift is more marked, with the occurrence of Wood Anemone (Anemone nemorosa) amongst the

ground flora.

Two stands of Yew (Taxus baccata) woods, a rare habitat in Ireland and the E.U., occur within the

site. These are on limestone ridges at Shanbally and Cahir Park. Both are in woods planted with non-

native species, including conifers. However, the area at Cahir Park is fairly substantial in size and

includes some relatively undisturbed patches of wood and some very old trees. Regeneration of the

Yew trees is mostly poor, due to competition from species such as Sycamore (Acer pseudoplatanus)

and, at Shanbally, due to heavy grazing by goats. Other native species which occur with the Yew

trees include Ash, Pedunculate Oak, Hazel and Spindle (Euonymus europaeus). Future prospects for

these Yew woods are good as the sites are proposed for restoration under a Coillte E.U. LIFE

programme.

Floating river vegetation is evident in the freshwater stretches of the River Suir and along many of its

tributaries. Typical species found include Canadian Pondweed (Elodea canadensis), water-milfoils

(Myriophyllum spp.), Fennel Pondweed (Potamogeton pectinatus), Curled Pondweed (P. crispus),

Perfoliate Pondweed (P. perfoliatus), Pond Water-crowfoot (Ranunculus peltatus), other crowfoots

(Ranunculus spp.) and the moss Fontinalis antipyretica. At a couple of locations along the river

Opposite-leaved Pondweed (Groenlandia densa) occurs. This species is protected under the Flora

(Protection) Order, 1999.

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The Aherlow River is fast flowing and mostly follows a natural unmodified river channel. Submerged

vegetation includes the aquatic moss Fontinalis antipyretica and Stream Water-crowfoot (R.

pencillatus), while shallow areas support species such as Reed Canary-grass (Phalaris arundinacea),

Brooklime (Veronica beccabunga) and Water Mint (Mentha aquatica). The river bank is fringed in

places with Alder (Alnus glutinosa) and willows (Salix spp.).

The Multeen River is fast flowing, mostly gravel-bottomed and appears to follow a natural

unmodified river channel. Water-crowfoots occur in abundance and the aquatic moss Fontinalis

antipyretica is also common. In sheltered shallows, species such as Water-cress (Nasturtium

officinale) and water-starworts (Callitriche spp.) occur. The river channel is fringed for most of its

length with Alder, Willow and a narrow strip of marshy vegetation.

Salt meadows occur below Waterford City in old meadows where the embankment is absent, or has

been breached, and along the tidal stretches of some of the inflowing rivers below Little Island.

There are very narrow, non-continuous bands of this habitat along both banks. More extensive areas

are also seen along the south bank at Ballynakill, the east side of Little Island, and in three large salt

meadows Version date: 13.12.2013 4 of 6 002137_Rev13.Doc between Ballynakill and Cheekpoint.

The Atlantic and Mediterranean sub-types are generally intermixed. The species list is extensive and

includes Red Fescue (Festuca rubra), oraches (Atriplex spp.), Sea Aster (Aster tripolium), Sea Couch

(Elymus pycnanthus), frequent Sea Milkwort (Glaux maritima), occasional Wild Celery (Apium

graveolens), Parsley Water-dropwort (Oenanthe lachenalii), English Scurvygrass (Cochlearia anglica)

and Sea Arrowgrass (Triglochin maritima). These species are more representative of the Atlantic sub-

type of the habitat. Common Cord-grass (Spartina anglica), is rather frequent along the main

channel edge and up the internal channels. The legally protected (Flora (Protection) Order, 1999)

Meadow Barley (Hordeum secalinum) grows at the landward transition of the saltmarsh. Sea Rush

(Juncus maritimus), an indicator of the Mediterranean salt meadows, also occurs.

Other habitats at the site include wet and dry grassland, marsh, reedswamp, improved grassland,

coniferous plantations, deciduous woodland, scrub, tidal river, stony shore and mudflats. The most

dominant habitat adjoining the river is improved grassland, although there are wet fields with

species such as Yellow Iris, Meadowsweet, rushes (Juncus spp.), Meadow Buttercup (Ranunculus

acris) and Cuckooflower (Cardamine pratensis).

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Cabragh marshes, just below Thurles, lie in a low-lying tributary valley into which the main river

floods in winter. Here there is an extensive area of Common Reed (Phragmites australis) with

associated marshland and peaty fen. The transition between vegetation types is often well

displayed. A number of wetland plants of interest occur, in particular the Narrow-leaved Bulrush

(Typha angustifolia), Bottle Sedge (Carex rostrata) and Blunt-flowered Rush (Juncus subnodulosus).

The marsh is naturally eutrophic but it has also the nutritional legacy of the former sugar factory

which discharged into it through a number of holding lagoons, now removed. Production is high,

which is seen in the size of such species as Celery-leaved Buttercup (Ranunculus sceleratus), as well

as in the reeds themselves.

Throughout the Lower River Suir site are small areas of woodland other than those described above.

These tend to be a mixture of native and non-native species, although there are some areas of semi-

natural wet woodland with species such as Ash and willow. Cahir Park Woodlands is a narrow tract

of mixed deciduous woodland lying on the flat-lying floodplain of the River Suir. This estate

woodland was planted over one hundred years ago and it contains a large component of exotic tree

species. However, due to original planting and natural regeneration there is now a good mix of

native and exotic species. About 5 km north-west of Cashel, Ardmayle pond is a long, possibly

artificial water body running parallel to the River Suir. It is partly shaded by planted Lime (Tilia

hybrids), Sycamore and the native Alder. Growing beneath the trees are shade tolerant species such

as Remote sedge (Carex remota).

The site is of particular conservation interest for the presence of a number of Annex II animal

species, including Freshwater Pearl Mussel (both Margaritifera margaritifera and M. margaritifera

subsp. durrovensis occur), White-clawed Crayfish, Salmon, Twaite Shad (Alosa fallax fallax), three

species of Lampreys - Sea Lamprey, Brook Lamprey and River Lamprey, and Otter. This is one of only

three known spawning grounds in the country for Twaite Shad.

The site also supports populations of several other animal species. Those which are listed in the Irish

Red Data Book include Daubenton’s Bat, Nattererer’s Bat, Pipistrelle Bat, Pine Marten, Badger, Irish

Hare, Smelt and Common Frog. Breeding stocks of Carp are found in Kilsheelan Lake. This is one of

only two lakes in the country which is known to have supported breeding Carp. Carp require

unusually high summer water temperatures to breed in Ireland. As the site is therefore unusual in

this regard, it may also support interesting invertebrate populations.

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Parts of the site have also been identified as of ornithological importance for a number of Annex I

(E.U. Birds Directive) bird species, including Greenland Whitefronted Goose (10), Golden Plover

(1,490), Whooper Swan (7) and Kingfisher. Figures given in brackets are the average maximum

counts from four count areas within the site for the three winters 1994-1997. Wintering populations

of migratory birds use the site. Flocks are seen in Coolfinn Marsh and also along the reedbeds and

saltmarsh areas of the Suir. Coolfinn supports nationally important numbers of Greylag Goose on a

regular basis, with numbers between 600 and 700 recorded. Other species occurring include Mallard

(21), Teal (159), Wigeon (26), Tufted Duck (60), Pintail (4), Pochard (2), Little Grebe (2), Black-tailed

Godwit (20), Oystercatcher (16), Lapwing (993), Dunlin (101), Curlew (195), Redshank (28),

Greenshank (4) and Green Sandpiper (1). Nationally important numbers of Lapwing (2,750) were

recorded at Faithlegg in the winter of 1996/97. In Cabragh marshes there is abundant food for

surface feeding wildfowl which total approximately 1,000 in winter. Widgeon, Teal and Mallard are

numerous, and the latter has a large breeding population, with up to 400 in summer. In addition,

less frequent species like Shoveler and Pintail occur and there are records for both Whooper and

Bewick's Swans. Kingfisher, a species that is listed on Annex I of the E.U. Birds Directive, occurs along

some of the many tributaries throughout the site.

Land use at the site consists mainly of agricultural activities including grazing, silage production,

fertilising and land reclamation. The grassland is intensively managed and the rivers are therefore

vulnerable to pollution from run-off of fertilisers and slurry. Arable crops are also grown. Fishing is a

main tourist attraction on stretches of the Suir and some of its tributaries, and there are a number of

Angler Associations, some with a number of beats. Fishing stands and styles have been erected in

places. Both commercial and leisure fishing takes place on the rivers. The Aherlow River is a

designated Salmonid Water under the E.U. Freshwater Fish Directive. Other recreational activities

such as boating, golfing and walking are also popular. Several industrial developments, which

discharge into the river, border the site including three dairy related operations and a tannery.

The Lower River Suir contains excellent examples of a number of Annex I habitats, including the

priority habitats alluvial forest and Yew woodland. The site also supports populations of several

important animal species, some listed on Annex II of the Habitats Directive or listed in the Irish Red

Data Book. The presence of two legally protected plants (Flora (Protection) Order, 1999) and the

ornithological importance of the site adds further to the ecological interest and importance.

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Appendix 2

Monte Carlo Results

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Appendix 3

Hydrological Data

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