kmk metals facility, moate road, kilbeggan, co. westmeath · 2019. 7. 6. · moate road, kilbeggan,...

NATURA IMPACT STATEMENT

KMK Metals Facility, Moate Road, Kilbeggan, Co.

Westmeath

Prepared for: KMK Metals Recycling Ltd.

SLR Ref: 501.00323.00001

Version No: 1

July 2019

KMK Metals Recycling Ltd.

Moate Road, Kilbeggan, Co. Westmeath

Natura Impact Statement

SLR Ref No: 501.00323.00006

July 2019

.

BASIS OF REPORT

This document has been prepared by SLR Environmental Consulting (Ireland) Limited with reasonable skill, care and diligence, and taking

account of the manpower, timescales and resources devoted to it by agreement with KMK Metals Recycling Ltd. (the Client) as part or

all of the services it has been appointed by the Client to carry out. It is subject to the terms and conditions of that appointment.

SLR shall not be liable for the use of or reliance on any information, advice, recommendations and opinions in this document for any

purpose by any person other than the Client. Reliance may be granted to a third party only in the event that SLR and the third party

have executed a reliance agreement or collateral warranty.

Information reported herein may be based on the interpretation of public domain data collected by SLR, and/or information supplied

by the Client and/or its other advisors and associates. These data have been accepted in good faith as being accurate and valid.

The copyright and intellectual property in all drawings, reports, specifications, bills of quantities, calculations and other information set

out in this report remain vested in SLR unless the terms of appointment state otherwise.

This document may contain information of a specialised and/or highly technical nature and the Client is advised to seek clarification on

any elements which may be unclear to it.

Information, advice, recommendations and opinions in this document should only be relied upon in the context of the whole document

and any documents referenced explicitly herein and should then only be used within the context of the appointment.




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CONTENTS

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

Background ............................................................................................................................................. 1

General Description of the Site .............................................................................................................. 1

Brief Project Description ........................................................................................................................ 2

Aim of the Report ................................................................................................................................... 2

Objectives of Appropriate Assessment (AA) .......................................................................................... 2

Evidence of Technical Competence and Experience ............................................................................. 2

2 RELEVANT LEGISLATION .................................................................................................... 3

European Nature Directives (Habitats and Birds) .................................................................................. 3

EC (Birds and Natural Habitats) Regulations 2011 ................................................................................. 3

3 METHODS ......................................................................................................................... 5

Desk Study .............................................................................................................................................. 5

Site Visit .................................................................................................................................................. 5

Natura Impact Statement ....................................................................................................................... 5

4 DETAILED DESCRIPTION OF THE DEVELOPMENT ................................................................ 6

5 NATURA IMPACT STATEMENT ......................................................................................... 11

Screening for appropriate assessment ............................................................................................... 11

Site Visit ............................................................................................................................................... 11

Natura 2000 Sites ................................................................................................................................ 12

Assessment of the effects of the project or plan on the integrity of Natura 2000 (European) Sites 17

Consideration of Findings .................................................................................................................... 25

6 REFERENCES .................................................................................................................... 26

TABLES

Table 1: Features of Interest and Conservation Objectives for Natura 2000 sites .......................... 15

Table 2: Effects of the Project on Key Habitats and Species ............................................................ 20




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1 INTRODUCTION

1.1 SLR Consulting Ireland (SLR) was commissioned on 11June 2019 by the KMK Metals Recycling Ltd.

(KMK) to prepare a Natura Impact Statement (NIS) in response to a request from the Environmental

Protection Agency (EPA) with respect to Industrial Emissions Directive (IED) Licence for the

intensification of operations at the KMK facility, Moate Road, Kilbeggan, Co. Westmeath.

Background

1.2 KMK Metals Recycling Ltd. currently has planning permission (Westmeath County Council (WCC)

Planning Reference 16/6002) and a Waste Facility Permit to process 10,000 tonnes of Waste Electrical

and Electronic Equipment (WEEE) and metals recycling per annum. KMK submitted an application on

22 December 2017 (WCC Planning Reference 17/6372) for the intensification of operations at the

facility to process 50,000 tonnes of WEEE and metals recycling per annum. Permission was

subsequently granted, subject to 12 conditions, on 22February 2018. KMK applied to the EPA for an

Industrial Emissions Directive (IED) Licence (IED Register No. P1076-01) on 27April 2018.

1.3 The EPA issued a letter to KMK on 4 June 2019 detailing additional documentation that they required

by 5 July 2019 to allow the Agency to process and determine the IED application. Item 10 of the relates

to the request for provision of an NIS and is as follows:

“10) A screening for Appropriate Assessment was undertaken on 16th May 2019 and the

Agency determined that an Appropriate Assessment of the proposed activity is required. You are

thereby required to submit a Natura Impact Statement, as defined in Regulation 2(1) of the

European Communities (Birds and Natural Habitats) Regulations 2011 as amended. You are

furthermore advised to refer to the document ‘Appropriate Assessment of Plans and Projects in

Ireland – Guidance for Planning Authorities’, issued in 2009 by the Department of the

Environment, Heritage and Local Government, and revised in 2010. This document is available

on the National Parks & Wildlife Survive website at:

http://www.npws.ie/sites/default/files/publications/pdf/NPWS_2009_AA_Guidance.pdf”

General Description of the Site

1.4 Section 3: Site Process and Description of the EIAR (December 2017) describes the KMK Kilbeggan

facility (“the Site”) is as follows:

“The site is located on the R446 Moate Road, on the outskirts of Kilbeggan on an existing

industrial site. Irish Waterjet Profiles Ltd. (supplying cut rubber profiles) is located in the building

to the east of the site and another building, currently unoccupied adjoins them. Currently the

entrance to both businesses from the R446 is shared and KMK are applying to have their own

dedicated site entrance. A green palisade fence separates KMK and the adjoining businesses.

Agricultural land lies to the north and west of the site. The nearest house to the west of the site

boundary is 165m distant and the nearest house to the east is 95m distant approx., both located

along the R446.”

1.5 The biodiversity chapter of the December 2017 EIAR (December 2017) describes the Site as follows:

“The site is covered in hardstanding (concrete) and buildings surrounded by a 2m fence for

security purposes. Therefore, it offers little by way of biodiversity value. A small area of scrub

exists on the western boundary, an area of approximately 1,250m2, stretching from the front of

the site near the road to greater than half way back. The remaining part of the western boundary

is mature hedgerow.




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Brief Project Description

1.6 The non-technical summary of the EIAR (2017) describes the project as follows:

” KMK Metals Recycling Ltd operate a Waste Electrical and Electronic Equipment (WEEE) and

metals recycling operation in Kilbeggan, Co. Westmeath. The facility operates under planning

16/6002 and Waste Facility Permit (WFP-WM-2016-07) for WEEE and metal recovery for up to

10,000 tonnes per annum. KMK began setting up the site in 2017 for their production process

and the site is currently in its infancy, processing small amounts of WEEE and metal waste.”

1.7 Detailed information on the proposed increase in operations at KMK Kilbeggan facility, including

classes of activity and recycling processes, can be found at Section 3: Site Process and Description

pages 31 – 39 of the EIAR (December 2017).

Aim of the Report

1.8 The aim of this report is to provide supporting information to assist the competent authority, in this

case the Environmental Protection Agency (EPA), to carry out appropriate assessment to determine

if there will be an adverse effect on the integrity of Natura 2000 sites arising from granting the IED

Licence for the intensification of operations at the KMK facility, Moate Road, Kilbeggan, Co.

Westmeath.

Objectives of Appropriate Assessment (AA)

1.9 The Habitats Directive promotes a hierarchy of avoidance, mitigation and compensatory measures to

be addressed in the AA process1 as follows:

• Firstly, a plan / project should aim to avoid any negative impacts on Natura 2000 sites by

identifying possible impacts early and designing the project / plan to avoid such impacts.

• Secondly, mitigation measures should be applied during the AA process (after stage 1 screening)

to the point where no adverse impacts on the site(s) remain.

• Thirdly a plan / project may have to undergo an assessment of alternative solutions. Under this

stage of the assessment, compensatory measures are required for any remaining adverse effects,

but they are permitted only if (a) there are no alternative solutions and (b) the plan / project is

required for imperative reasons of overriding public interest (the ‘IROPI test’). European case law

highlights that consideration must be given to alternatives outside the plan / project boundary

area in carrying out the IROPI test.

Evidence of Technical Competence and Experience

1.10 The Natura Impact Statement was prepared by SLR ecologist Elaine Dromey BSc MSc MCIEEM.

1.11 Elaine Dromey holds a BSc in Earth Science from University College Cork and an MSc in Vegetation

Survey and Assessment from the University of Reading, UK. She is a full member of the Chartered

Institute of Ecology and Environmental Management. Elaine has prepared AA screening reports and

Natura Impact Statements (NIS) for a range of different projects and plans.

______________________

1 The objectives as outlined are based on those set out in Scott Wilson and Levett-Therivel, (2006).




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2 RELEVANT LEGISLATION

European Nature Directives (Habitats and Birds)

2.1 The Habitats Directive (Council Directive 92/43/EEC on the Conservation of Natural Habitats and of

Wild Fauna and Flora) forms the basis for the designation of Special Areas of Conservation. Similarly,

Special Protection Areas are classified under the Birds Directive (Council Directive 2009/147/EEC on

the Conservation of Wild Birds). Collectively, Special Areas of Conservation (SAC) and Special

Protection Areas (SPA) are referred to as the Natura 2000 network. In general terms, they are

considered to be of exceptional importance for rare, endangered or vulnerable habitats and species

within the European Community.

2.2 Under Article 6(3) of the Habitats Directive an Appropriate Assessment must be undertaken for any

plan or project that is likely to have a significant effect on the conservation objectives of a Natura

2000 site. An Appropriate Assessment is an evaluation of the potential impacts of a plan or project

on the conservation objectives of a Natura 2000 site, and the development, where necessary, of

mitigation or avoidance measures to preclude negative effects.

2.3 Article 6, paragraph 3 of the EC Habitats Directive 92/43/EEC (“the Habitats Directive”) states that:

“Any plan or project not directly connected with or necessary to the management of the site but likely

to have a significant effect thereon, either individually or in combination with other plans or projects,

shall be subject to appropriate assessment of its implications for the site in view of the site's

conservation objectives. In the 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”.

EC (Birds and Natural Habitats) Regulations 2011

2.4 Part 5 of the EC (Birds and Natural Habitats) Regulations 2011 sets out the circumstances under which

an ‘appropriate assessment’ is required. Section 42(1) requires that ‘a screening for Appropriate

Assessment of a plan or project for which an application for consent is received, or which a public

authority wishes to undertake or adopt, and which is not directly connected with or necessary to the

management of the site as a European Site, shall be carried out by the public authority to assess, in

view of best scientific knowledge and in view of the conservation objectives of the site, if that plan or

project, individually or in combination with other plans or projects is likely to have a significant effect

on the European site.’

2.5 Section 42(2) expands on this, stipulating that a public authority must carry out a screening for

Appropriate Assessment before consent for a plan or project is given, or a decision to undertake or

adopt a plan or project is taken. To assist a public authority to discharge its duty in this respect,

Section 42(3)(a) gives them the authority to direct a third party to provide a Natura Impact Statement

and Section 42(3)(b) allows them request any additional information that is considered necessary for

the purposes of undertaking a screening. A Natura Impact Statement has to include such information

or data as the public authority considers necessary to enable it to ascertain if the plan or project will

affect the integrity of a Natura 2000 site. Where appropriate, a Natura Impact Statement also needs

to include:

I. the alternative solutions that have been considered and the reasons why they have not been

adopted,




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II. the imperative reasons of overriding public interest that are being relied upon to indicate that

the plan or project should proceed notwithstanding that it may adversely affect the integrity of

a European site,

III. the compensatory measures that are being proposed.

2.6 Section 42(6) requires that ‘the public authority shall determine that an Appropriate Assessment of a

plan or project is required where the plan or project is not directly connected with or necessary to the

management of the site as a European Site and if it cannot be excluded, on the basis of objective

scientific information following screening under this Regulation, that the plan or project, individually

or in combination with other plans or projects, will have a significant effect on a European site’.




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3 METHODS

Desk Study

3.1 A desk study was carried out to collate information available on Natura 2000 sites within the

potential zone of influence of the proposed works. The Site and the surrounding area were viewed

using satellite imagery2. Westmeath County Council planning portal3 was accessed for

information on other planning applications. The National Parks and Wildlife Service (NPWS)

website4 was accessed for information on Natura 2000 sites. Environmental Protection Agency

(EPA) Maps5 was accessed for other environmental information relevant to preparation of this

report.

Site Visit

3.2 The Site was visited by SLR ecologist Owen Twomey on 28 June 2019 during a period of dry,

overcast weather (8 oktas), light breeze and a temperature of 17°C. The Site was walked and the

existing water drainage system within the KMK Metal Recycling Ltd. facility at Kilbeggan was

examined. The focus of the visit was the discharge point from the facility (which includes discharge

from other buildings within the complex) to the field drain to the north at Surface Water point

two


3.3 The approach to preparing the Natura Impact Statement (NIS) is summarised as follows:

• Describe the elements of the project that are likely to give rise to significant effects on the

Natura 2000 Sites.

• Set out the conservation objectives of the Natura 2000 sites.

• Describe how the project will affect the key species and key habitats of the Natura 2000 sites.

• Describe how the integrity of Natura 2000 sites is likely to be affected by the project.

• Describe what measures are to be introduced to avoid, reduce or remedy the adverse effects

on the integrity of the Natura 2000 site.

• Consider findings and determine if potential for adverse effects on Natura 2000 sites remains

after such measures have been implemented.

3.4 The approach taken in preparing the NIS is based on standard methods and best practice

guidance, as listed in the references section of this report.

______________________

2 https://www.google.ie/maps & http://www.bing.com/maps/ (last accessed 4 July 2019) 3 http://www.eplanning.ie/WestmeathCC/searchtypes (last accessed 4 July 2019) 4 https://www.npws.ie/protected-sites (last accessed 4 July 2019) 5 http://gis.epa.ie/(last accessed 4 July 2019)




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4 DETAILED DESCRIPTION OF THE DEVELOPMENT

4.1 The detailed description of the development has been extracted from the Non-technical Summary

and Section 3: Site Process and Description of the EIAR (December 2017) submitted to Westmeath

County Council and the EPA.

4.2 The proposed development entails intensification from the current permitted volume of 10,000

tonnes of WEEE and Metals recycling per annum to 50,000 tonnes of WEEE and Metals recycling

per annum. It also entails construction of a roofed yard area for WEEE storage and processing and

construction of a site entrance to the R446, along with other minor additions. The site currently

operates under a Waste Facility Permit (WFP-WM-2016-07) and due to the proposal to process

up to 50,000 tonnes of WEEE and metals waste per annum, the site will apply to the EPA for an

Industrial Emissions Licence to operate this activity at this capacity. The IED Licence will supersede

the Waste Facility Permit.

4.3 The principal recovery activities carried out by KMK as per the fourth Schedule of the Waste

Management Act 1996 as amended is:

R4: Recycling/reclamation of metals and metal compounds

R5: Recycling/reclamation of inorganic materials, which includes soil cleaning resulting in recovery

of the soil and recycling of inorganic construction materials.

R13: Storage of waste pending any of the operations numbered R1 to R12 (excluding temporary

storage (being preliminary storage according to the definition of collection in section 5(1)),

pending collection, on the site where the waste is produced.

4.4 The hours of waste acceptance and operation of the facility for this application will be 06:00 to

22:00 Monday to Friday inclusive and 06:00 to 14:00 on Saturdays, with no operational works on

Sundays or Bank Holidays. Production will operate over two shifts; 6am-2pm & 2pm-10pm, with

office based staff working 08:00 to 17:00 primarily.

4.5 The main activities of KMK Kilbeggan operations will be the sustainable treatment of metallic and

WEEE waste for the purpose of efficient recovery and reuse of valuable secondary raw materials.

Specific metallic waste accepted from industry and other off-site waste treatment facilities will be

recycled and recovered in appropriate production processes incorporating all necessary and

statutory environmental controls.

4.6 WEEE will be treated in accordance to European Union (Waste Electrical and Electronic

Equipment) Regulations 2014, Statutory Instruments S.I. No. 149 of 2014. Treatment Standards

and recovery targets will be as per S.I. 149 Part 3, Section 22 ii (b) and Schedule 10. Preparation

of WEEE for re-use will be in accordance with Schedule 11.

4.7 The KMK site in Tullamore has ISO 14001:2015 Environmental Management System, ISO

9001:2015 Quality Management System and OHSAS 18001:2007 Health and Safety Management

Standard. Customers are assured of compliant treatment of their materials as KMK are

WEEELABEX approved. All standards on the Tullamore site will apply to the Kilbeggan site

operations also, to ensure that the process is managed to the highest standards. Recycling

certificates are issued upon completion of the collection order and treatment process. KMK has

100% traceability of all materials received.

4.8 The KMK Kilbeggan site is to consist of two large existing buildings and a proposed covered yard

area. A number of dedicated treatment processes will take place in buildings with storage of WEEE

proposed for a yard.

4.9 The main elements of the KMK Kilbeggan facility will comprise of the following:

• Flat Panel Display (FPD) Unit Treatment




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• Fines Treatment

• Large Household Appliances (LHA) Treatment

• Storage of Fridges, Freezers and WEEE Fractions

• Preparation for Re-use activity

Flat Panel Display (FPD) Unit Treatment

4.10 The treatment of FPD units will be carried out in accordance with the technical requirements and

specifications of the CENELEC EN/TS 50625 standards on the treatment of WEEE containing flat

panel displays. Part III of the S.I. No. 149/2014 - European Union (Waste Electrical and Electronic

Equipment) Regulations, 2014 on the management of waste electrical and electronic equipment

will be adhered to at all times.

4.11 FPD units (comprising of televisions and monitors) will be delivered to building A where they will

first undergo a manual dismantling activity. This entails putting the FPD unit onto a dismantling

table, removing any external plugs and cables and the plastic stand. The plastic stand is sent to

KMK Tullamore for recycling. LED units and FPD monitors will be appropriately packaged, weighed

and labelled in accordance with all relevant transport regulations and loaded for outward

transport to an authorised treatment facility by an approved haulier.

4.12 LCD TV units are placed onto the infeed conveyer of the Votechnik Trumaster-ALR machine. This

is a new technology for WEEE recycling in Ireland. The machine is a fully automated, high through-

put technology that can process sixty LCD TV units per hour. All processing is carried out at one

central location at a rate of one LCD TV unit every sixty seconds. An extraction and carbon

filtration system extracts air from within the machine via stack A-3, which is located at the back

of the site. Air extracted passes through a particulate filter and 24 carbon filters to remove

potential particulates and mercury vapour prior to discharge.

4.13 All fractions resulting from the process will be sent to covered Yard C for suitable storage prior to

transport.

4.14 All waste streams arising from the FPD process sent for recycling include:

• LCD panel and diffusers sheets

• CCFL tubes

• LCD carcass

• Circuit boards

• Transformers

• Speakers

• Plastic

• Cable

• Steel (light iron) and

• Plastic/metal mixes from the shredding process of the carcasses will be directed to area

building B for Fines Treatment.

Fines Treatment

4.15 A fines treatment process is located in building B, which comprises of feed hoppers, air table and

a screen. This screen accepts waste fractions and separate them into smaller, uniform fractions,

suitable for recycling on the air table. The air table uses a technology that will separate heavy

(concentrated metal) and light (concentrated plastic) materials. The output materials generated




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from the process will be metals, plastics, sand/grit and filter dust. Extracted air from this process

is directed to a dust extractor located externally at the back of the site, with emission point A-1.

This dust extraction has a bag filter system and minimal emissions to atmosphere. A differential

pressure gauge indicates when bags are torn or loose and the system will receive ongoing

maintenance.

Large Household Appliances (LHA) Treatment

4.16 Large Household Appliances will be delivered to area building B and manually dismantled to

remove the plug, cable, plastic, pump, motor and transformer, capacitors, plastic / wood top

panels and rubber hosing, which are sent for storage to Yard C.

4.17 After removal of these fractions, the LHA carcass is to be sent to the VRS Shredder and sorting

cabin, which manually and mechanically sorts the shredded material into separate fractions of

carcass, mineral waste (concrete, sand and glass mix), glass, steel (light iron), motor, cable and

electronic components. These final fractions will be directed by conveyors to dedicated storage

bays in Yard C.

4.18 The site proposes to install a second shredding system in building B suitable for shredding the

steel fraction from the above process. This will create an end-of-waste steel output. It can also be

used for shredding other large WEEE assemblies, creating a size reduction and value-added metal

extraction.

4.19 It reduces high-volume input materials and items with a large unit weight. This unit will be linked

to a dust extraction system proposed to be located at the north facing back wall of the site, which

will have emission point A-2. This proposed dust extraction will have a shaker filter system and

minimal emissions to atmosphere. A fault detection unit will be installed to shut down the system

when there is a fault and will receive ongoing maintenance.

Storage of Fridges, Freezers and WEEE Fractions

4.20 The storage of fridges, freezers and WEEE fractions will be carried out in accordance with Schedule

8 of the S.I. No. 149/2014 - European Union (Waste Electrical and Electronic Equipment)

Regulations, 2014 and the technical requirements of the CENELEC EN/TS 50625 standards on the

collection, logistics and treatment of WEEE.

4.21 These requirements include, but are not limited to:

• Weatherproof covering;

• Provision of spillage collection facilities;

• Impermeable surfaces;

• Appropriate storage containers;

• H&S considerations (i.e. safe stacking);

• Weigh scales for weight measurement and recording.

4.22 As fridges and freezers require the application of advanced processes for effective treatment (i.e.

refrigerant gas containment/extraction and specialist technology), the proposed processing of

these appliances within the proposed KMK Kilbeggan facility will be limited to their intake at Yard

C, inspection, decontamination (if necessary) and sending off-site to a dedicated and fully

authorised treatment facility. Fridges and freezers will be appropriately packaged, weighed and

labelled in accordance with all relevant transport regulations and loaded for outward transport

to an authorised treatment facility by an approved haulier.




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Preparation for Re-use

4.23 “Preparation for re-use” means checking, cleaning or repairing recovery operations, by which

products or components of products that have become waste are prepared so that they can be

re-used without any other pre-processing.

4.24 Preparation for re-use will be carried out in accordance with the technical requirements of the

current PAS 141:2011 Re-use standard. KMK Kilbeggan also intend to prepare IT and FPD units for

re-use in accordance with the requirements of the CENELEC EN 50614 standard on re-use once

published by the European Standardisation Organisations.

4.25 For this activity, it is proposed that IT equipment and FPD units will be delivered initially to building

A.

4.26 They will then undergo a selection criterion to determine if they are suitable for the preparation

for re-use activity. If they are not suitable, flat screens (televisions and monitors) will remain in

building A and go through the FPD unit processing operation. IT equipment will be transferred to

KMK Tullamore for recycling.

• If the selection criterion deems that the IT equipment and FPD units are suitable for the

preparation for re-use activity, they will be sent to Workshop 2 in building A for testing.

• If they pass all tests, they are deemed as products ready for sale.

• If they fail tests, spare parts will be harvested from other IT equipment / FPD units to repair

the units and if they pass this time around, they are deemed as products ready for sale.

• If they fail all tests, they will be sent for appropriate recycling.

4.27 In compliance with data protection regulations, a secure data security workshop (Workshop 1)

has been created to meet forthcoming management security standards.

4.28 Noise (NSL1 and NSL2 Noise sensitive locations west and east of the site). Both these locations

were monitored and are reported. Noise from the site is not problematic at these locations and

traffic noise is the predominant noise in the area. The site will comply with the NG4 daytime noise

limit of 55dBA, the evening time limit of 50dBA and the night time limit of 45dBA.

4.29 Dust Four boundary locations were monitored for ambient dust in 2017 and results are provided

in the IE application. All dust results are within the limit of 350mg/m2/day.

4.30 Surface Water (SW1) – There is one surface water discharge point at the (north) back of the site.

This was assessed and is reported in the Land, Soil and Water Section report provided and

undertaken as part of the EIAR for the site. Surface water discharge from the site is clean. A recent

surface water monitoring report dated March 2019 showed samples taken are in compliance with

the current facility permit emission limits. Surface water will pass through a silt trap and oil

interceptor prior to discharge. These will be adequately maintained.

4.31 Air: There are three emission points to air on the site; A-1 and A-3 are in place and A-2 is proposed.

Monitoring of A-1 and A-3 have been undertaken and sample results are in compliance with the

current facility permit emission limits. Air Dispersion Modelling of all three emission points was

undertaken assuming maximum emissions and results show that at maximum emissions, ambient

ground level concentrations will be low and not problematic. The discharges will have minimal

emissions and therefore operate well below maximum.

4.32 Soil and Groundwater

4.33 A baseline report was undertaken and reported in the Land, Soil and Water report. Three

boreholes were installed, and groundwater quality was good in all. Four window soil samples were

also taken, and one showed the presence of a small quantity of oil, while all others were

satisfactory. Further investigation into this area is ongoing under supervision of a hydrogeologist,

with a view to removing any small concentration of oil present in this area.




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4.34 All emissions from the site have been addressed and outlined in the application along with

supporting monitoring data and baseline reports.

4.35 The site has permission to conduct WEEE and Metal waste recovery operations, up to 10,000

tonnes per year, so these processes are currently ongoing at the site in the existing buildings. The

site will construct a new 2,715m2 roofed yard area to the west of the site adjoining the existing

buildings. This will be constructed in a similar manner to the existing buildings using steel supports

and metal roof cladding. The site entrance will be constructed in the area proposed in the planning

application drawings using an excavator. Works will take place from within KMK’s yard, so they

will not impinge significantly on traffic movement on the R446. All site activities will operate as

normal when construction works are ongoing.

4.36 Construction works will take place during normal working hours only and will be of short duration,

thereby causing minimal environmental impact. Any wastes generated from construction

activities (mainly soil, stones and rubble) will be disposed to a licensed waste facility.




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5 NATURA IMPACT STATEMENT

5.1 The Competent Authority will be required to carry out an appropriate assessment to determine

whether the proposed IED licence would adversely affect the integrity Natura 2000 sites. The

‘integrity of the site’ can be defined as ‘the coherence of the site’s ecological structure and function,

across its whole area, or the habitats, complex of habitats and / or populations of species for which

the site is or will be classified’6.

5.2 The headings within the appropriate assessment report template provided in the European

Commission guidance document ‘Assessment of plans and projects significantly affecting Natura 2000

sites’7 have been used to provide a basis to examine the potential effects of the proposed

Screening for appropriate assessment

5.3 The EPA carried out screening for appropriate assessment as required under Regulation 42(1) of the

European Communities (Birds and Natural Habitats) Regulations 2011 as amended.

5.4 The European sites considered by the EPA are as follows:

• Split Hills and Long Hill Esker SAC (001831)

• Clara Bog SAC (000572)

• Lough Ennell SAC (000685)

• Lough Ennell SPA (004044)

5.5 The EPA carried out screening for appropriate assessment for the IED licence and concluded that “it

cannot be excluded, on the basis of objective information, that the activities, individually or in

combination with other plans or projects, will have a significant effect on any European site and

accordingly determined that an Appropriate Assessment of the activities is required, and for this

reason determined to require the applicant to submit a Natura Impact Statement. The reason for this

decision is based on the potential significant effects of the proposed activities on the European sites.”

Site Visit

5.1 The Site is composed of artificial surfaces and built lands with occasional ruderal type vegetation. The

open field drain at the final discharge location is approximately 1.5 m wide and 0.5 m deep and travels

through agricultural fields. It was dry at the time of surveys with the silty nature of the bed of the

watercourse exposed. The existing storm water drainage system at KMK’s metal recycling facility

consists of a series of gully’s and drainage channels throughout the site which pass through a

hydrobrake, silt traps and class 1 petrol interceptor before connecting to the industrial yard water

network at the northeast corner (SW1). From here the network travels in a generally east direction

before discharging to the open field drain (SW2).

5.2 The drainage ditch is bordered by vegetation such as willowherb, bramble Rubus fruticosus agg., ivy

Hedera helix, ground elder Aegopodium podagraria, nettle Urtica dioica, dock Rumex sp, cleavers

Gallium aparine and herb Robert Geranium robertianum. A hawthorn Crataegus monogyna hedgerow

borders the drain to the north.

______________________

6 http://ec.europa.eu/environment/nature/natura2000/management/docs/art6/Provisions_Art_6_nov_2018_en.pdf 7 http://ec.europa.eu/environment/nature/natura2000/management/docs/art6/natura_2000_assess_en.pdf




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Natura 2000 Sites

5.3 The Natura 2000 sites identified as being within the potential zone of influence of the proposed

development are described below. The description of the sites has been prepared and summarised

using the supporting information available on the NPWS website8.

Split Hills and Long Hill Esker SAC (001831)

“Split Hills and Long Hill Esker is a 5 km long site which crosses the main Galway Dublin road mid-

way between Kilbeggan and Tyrrellspass in Co. Westmeath. It is a prominent feature on the local

landscape.

Split Hill and Long Hill Esker is one of the finest and longest wooded eskers in the country. It is

also one of the few woodlands in the area and a fine geomorphological feature of great scenic

value. The trees are particularly well-grown and impressive, and much of the woodland has

developed naturally on its steep slopes. The presence of a species-rich ground flora, which

includes a rare and legally protected plant species, Cardamine impatiens, at its only known Irish

location, makes this site of great botanical and ecological importance. The site also supports

some excellent examples of calcareous grassland which is rich in orchids. The increasing rarity of

this habitat (due to agricultural intensification) is recognised in that it is awarded priority status

on Annex I of the E.U. Habitats Directive.

The main threat to the esker is quarrying for sand and gravel. This activity already occurs on the

site at several locations. Grazing is a critical factor affecting esker habitats, and getting a balance

right is important. The presence of too many grazers causes damage to the ground vegetation in

both woodlands and grasslands and prevents regeneration of woody species. However, if the

grazing level is too low, grasslands are vulnerable to the encroachment of scrub at the expense

of species which require open conditions. Fertiliser application, associated with agricultural

improvement, also leads to a reduction in species-richness of grasslands.”

Clara Bog SAC (000572)

“Clara Bog is situated some 2 km south of Clara village in Co. Offaly. Much of it is State-owned

and designated a statutory Nature Reserve.

Clara Bog has long been regarded as one of the most important raised bogs in the country, being

the largest remaining example of the true midland sub-type. It has well-developed hummock and

hollow complexes, and one of the few remaining soak systems. The bog vegetation at this site

has been much-studied. Variations in the proportions of bog mosses (Sphagnum spp.), Heather

(Calluna vulgaris) and cotton grasses (Eriophorum spp.) have been related to ecological features

such as pools, soaks and ridges.

Rhynchosporion vegetation is widespread at this site but is best developed in the wettest areas

of active raised bog. This vegetation occurs along pool edges and on flats underlain by deep, wet

and quaking peat.

The largest part of the uncut high bog surface is comprised of degraded raised bog. Although the

areas of degraded raised bog have a relatively well-developed raised bog flora, they are affected

by water loss, to varying degrees, and thus they tend to be associated with the more marginal,

sloping areas of the high bog.

Bog woodland on Clara Bog occurs in several small stands associated with flushes on the western

side of the bog, the largest of which lies to the west of Shanley’s Lough. There is a good example

______________________

8 https://www.npws.ie/protected-sites (last access 4 July 2019)




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of a wet birch (Betula sp.) woodland which has a diverse vegetation, and the most easterly flush

has open water associated with it.

The transitions into calcareous woodland, to the east, and to the esker ridge, to the north, are

contained within the site, and some excellent examples of esker grassland also occur. Some

peripheral reclaimed farmland is also included in the site, because management undertaken in

these areas can affect the hydrology of the bog.

Several rare invertebrate species are associated with the soak on this bog, including the midge,

Lasiodiamesa sphagnicola (Order Diptera), for which Clara Bog is its only known Irish site, a click

beetle, Ampedus pomorum (Order Coleoptera), and another midge, Parhelophilus consimilis

(Order Diptera). Marsh Fritillary (Euphydryas aurinia, Order Lepidoptera), a butterfly listed on

Annex II of the E.U. Habitats Directive, has been recorded from the site, but in its present

condition the habitat is only marginally suitable for the species and any populations present are

likely to be intermittent, small and short-lived. Natural and human-induced changes are likely to

make the habitat less suitable in the future. The bog is also important at the only known Irish

station for the rare moss Tetraplodon angustatus.

Clara Bog supports breeding Merlin (1-2 pairs), a scarce species in Ireland and one that is listed

on Annex I of the E.U. Birds Directive. Red Grouse also breeds, along with other common bogland

species such as Meadow Pipit and Skylark.

The site has been divided into a western and an eastern section by a road. The eastern part of

the site has been damaged by previous drainage works, although restoration work is in progress.

Continuing peat extraction from the southern margins is also damaging and has a potential effect

upon much of the internal bog, including the soak system. Ideally the whole bog should be

managed as a hydrological unit.”

Lough Ennell SAC 000685

“Lough Ennell is a large, open, steep-sided lake, located 3 km south of Mullingar in Co.

Westmeath. The lake bottom is of limestone with a marl deposit. The water is markedly alkaline

and mesotrophic, possibly owing to effluents received from Mullingar town and to fertilizer inputs

from farmland surrounding the lake. The River Brosna flows into the lake from the north at

Butler's Bridge, and out from the south.

Lough Ennell supports a diverse aquatic flora. Seven stonewort species have been identified,

including two Red Data Book species, Chara denudata and C. tomentosa. Much of the lakeshore

consists of dry, stony ground colonised by calcareous grassland. These areas were formerly part

of the lake bed but are now exposed as a consequence of drainage. Alkaline fen is also found on

the lake shore, with species such as Grass-of-parnassus (Parnassia palustris), Marsh Pennywort

(Hydrocotyle vulgaris) and Bottle Sedge (Carex rostrata). Reedbeds and species-poor swamp

vegetation fringe the lake in places, particularly around the points of inflow and outflow, and on

the eastern shore around Tudenham Park.

Mixed woodland of Beech (Fagus sylvatica), Ash (Fraxinus excelsior) and Downy Birch (Betula

pubescens) fringes the lakeshore to the north-west. Yellow Archangel (Lamiastrum galeobdolon),

a rare plant listed in the Red Data Book, has been recorded in the woods along the eastern shores

of Lough Ennell. This is the only record for this species outside the south-east of Ireland. This site

shares an internationally important Greenland White-fronted Goose flock with Loughs Iron, Glen

and Owel. The numbers of geese which visit Lough Ennell are lower than for the other lakes: 9l

birds (3 year average peak).

Lough Ennell is an important amenity area, much used for fishing, boating and camping. Sections

of the shoreline are managed for visitor access and amenity. The chemical composition of effluent




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from the Mullingar sewage treatment plant has a significant impact on the water quality of

Lough Ennell. The mid-1970s saw the introduction of treatment of the sewage to reduce

phosphates, with a resulting improvement in water quality (according to data compiled during

1987-90). However, levels of planktonic algal growth in the lake water continue to fluctuate, in

response to the variable efficiency of the phosphate removal facility at the sewage treatment

plant and the re-mobilization of phosphate from the lake sediments.

Lough Ennell is of significance as a highly productive lake which supports a rich variety of lower

plant and invertebrate species. Its lakeshore habitats, which include alkaline fen, a habitat listed

on Annex I of the E.U. Habitats Directive, support a diverse flora. These habitats also provide

important refuges for wildfowl.

This lake is one of the most important midland limestone lakes but the quality of the water has

been poor owing to severe eutrophication in the 1970s. There has been improvement, however,

and in 1990 it was classified as mesotrophic. A good diversity of charophytes have been recorded,

including some of the rare species of calcareous water. Some good alkaline fen fringes the lake

in parts. Lutra lutra and Lampetra planeri occur at the site, as well as some important

invertebrate species. The site is an important bird area, and has wintering Anser albifrons

flavirostris. Further improvement in water quality would increase the value of this site.”

Lough Ennell SPA 004044

“Lough Ennell is a large, limestone lake located south of Mullingar in Co. Westmeath. It has a

length of approximately 6.5 km along its long axis and is mostly about 2 km wide. The River

Brosna is the principal inflowing and outflowing river. It is a relatively shallow lake, with a

maximum depth of c. 30 m. The water is hard, with low colour and markedly alkaline pH. The

lake is classified as a mesotrophic system though it has been eutrophic in the past. The lake

bottom is of limestone with a marl deposit.

The site is a Special Protection Area (SPA) under the E.U. Birds Directive, of special conservation

interest for the following species: Pochard, Tufted Duck and Coot. The E.U. Birds Directive pays

particular attention to wetlands and, as these form part of this SPA, the site and its associated

waterbirds are of special conservation interest for Wetland & Waterbirds.

Lough Ennell is of ornithological significance for wintering waterfowl, with three migratory

species having populations of national importance. The occurrence of Golden Plover in the vicinity

of the lake is of note as this species is listed on Annex I of the E.U. Birds Directive. Lough Ennell is

a Ramsar Convention Site.”

Features of Interest and Conservation Objectives

5.4 The features of interest and conservation objectives for the Natura 2000 sites identified by the EPA

are listed within Table 1 below. This information was obtained from the resources available on the

NPWS website (last accessed 4 July 2019).




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Table 1: Features of Interest and Conservation Objectives for Natura 2000 sites

Natura 2000 Site Location of Natura

2000 site boundary

relative to KMK

Kilbeggan

Features of Interest9 Conservation Objectives10

Split Hills and Long

Hill Esker SAC

001831

ca. 2.5 km north • Semi-natural dry grasslands

and scrubland facies on

calcareous substrates

(Festuco-Brometalia) (*

important orchid sites) [6210]

To restore the favourable conservation condition of Semi-natural dry grasslands and scrubland

facies on calcareous substrates (Festuco-Brometalia) (* important orchid sites) in Split Hills and

Long Hill Esker SAC, which is defined by the list of attributes and targets set out in the

conservation objectives available at: https://www.npws.ie/sites/default/files/protected-

sites/conservation_objectives/CO001831.pdf

Clara Bog SAC

000572

ca. 7.0 km south-west • Semi-natural dry grasslands




important orchid sites) [6210]

• Active raised bogs [7110]

• Degraded raised bogs still

capable of natural

regeneration [7120]

• Depressions on peat

substrates of the

Rhynchosporion [7150]

• Bog woodland [91D0]

To restore the favourable conservation condition of Semi-natural dry grasslands and scrubland

facies on calcareous substrates (Festuco-Brometalia) in Clara Bog SAC.

To restore the favourable conservation condition of Active raised bogs in Clara Bog SAC, which

is defined by the list of attributes and targets set out in the conservation objectives.

The long-term aim for Degraded raised bogs still capable of natural regeneration is that its peat-

forming capability is re-established; therefore, the conservation objective for this habitat is

inherently linked to that of Active raised bogs (7110) and a separate conservation objective has

not been set in Clara Bog SAC.

Depressions on peat substrates of the Rhynchosporion is an integral part of good quality Active

raised bogs (7110) and thus a separate conservation objective has not been set for the habitat

in Clara Bog SAC.

To maintain the favourable conservation condition of Bog woodland in Clara Bog SAC, which is

defined by the list of attributes and targets set out in the conservation objectives available at:

https://www.npws.ie/sites/default/files/protected-


______________________

9 Available for each Natura 2000 site at https://www.npws.ie/protected-sites (last accessed 4 July 2019) 10Conservation Objectives for all Natura 2000 sites available at https://www.npws.ie/protected-sites/conservation-management-planning/conservation-objectives (last

accessed 4 July 2019)




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Natura 2000 Site Location of Natura

2000 site boundary

relative to KMK

Kilbeggan

Features of Interest9 Conservation Objectives10

Lough Ennell SAC

000685

ca. 8.6 km north • Alkaline fens [7230] To maintain the favourable conservation condition of Alkaline fens in Lough Ennell SAC which is




Lough Ennell SPA

004044

ca. 9.0 km north • Pochard (Aythya ferina)

[A059]

• Tufted Duck (Aythya fuligula)

[A061]

• Coot (Fulica atra) [A125]

• Wetland and Waterbirds

[A999]

To maintain or restore the favourable conservation condition of the bird species listed as Special

Conservation Interests for this SPA.

To maintain or restore the favourable conservation condition of the wetland habitat at Lough

Ennell SPA as a resource for the regularly-occurring migratory waterbirds that utilise it. The

conservation objectives for the SPA can be accessed at






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Assessment of the effects of the project or plan on the integrity of Natura 2000

(European) Sites

5.5 This section of the report sets out the potential effects of the proposed IED licence to allow

intensification of operations at the KMK Kilbeggan facility (either alone or in combination with other

projects or plans) on the integrity of Natura 2000 sites with respect to the conservation objectives of

the sites and to their structure and function. The focus is on demonstrating, with supporting evidence,

that there will be no adverse effects on the integrity of any European site.

Describe the elements of the project or plan (alone or in combination with other projects or plans)

that are likely to give rise to significant effects on the environment.

5.6 The elements of the proposed intensification of operation at KMK Kilbeggan facility likely to give rise

to significant effects on the environment were not identified in the EPA screening determination.

However; based on the nature of the construction works and proposed activities associated with the

intensification of the operations at the Kilbeggan facility the elements likely to give rise to significant

effects are as follows:

• Construction of the new buildings within the existing facility.

• Disposal or recovery of hazardous waste.

• Temporary storage of hazardous waste.

5.7 While it is considered that the risk of effects to Natura 2000 sites is relatively low; given the distance

between the Kilbeggan facility and the Natura 2000 sites in addition to the low sensitivity of the

features of interest of the closest Natura 2000 sites to the potential sources of pollutants; such effects

cannot be entirely excluded and the significance of the effects is uncertain.

Set out the conservation objectives of the site

5.8 The conservation objectives and the list of specific attributes and targets defining the conservation

objectives for each feature of interest, is listed within the supporting information accessed through

NPWS website. The conservation objectives for the Natura 2000 sites and features of interest with

potential to be affected by the proposed development can be broadly summarised as follows:

Split Hills and Long Hill Esker SAC (001831)

• To restore the favourable conservation condition of Semi-natural dry grasslands and scrubland

facies on calcareous substrates (Festuco-Brometalia) (* important orchid sites) in Split Hills and

Long Hill Esker SAC, which is defined by the list of attributes and targets set out in the

conservation objectives available at: https://www.npws.ie/sites/default/files/protected-


Clara Bog SAC (000572)

• To restore the favourable conservation condition of Semi-natural dry grasslands and scrubland

facies on calcareous substrates (Festuco-Brometalia) in Clara Bog SAC.

• To restore the favourable conservation condition of Active raised bogs in Clara Bog SAC, which is

defined by the list of attributes and targets set out in the conservation objectives.

• The long-term aim for Degraded raised bogs still capable of natural regeneration is that its peat-

forming capability is re-established; therefore, the conservation objective for this habitat is




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inherently linked to that of Active raised bogs (7110) and a separate conservation objective has

not been set in Clara Bog SAC.

• Depressions on peat substrates of the Rhynchosporion is an integral part of good quality Active

raised bogs (7110) and thus a separate conservation objective has not been set for the habitat in

Clara Bog SAC.

• To maintain the favourable conservation condition of Bog woodland in Clara Bog SAC, which is




Lough Ennell SAC (000685)

• To maintain the favourable conservation condition of Alkaline fens in Lough Ennell SAC which is




Lough Ennell SPA (004044)

• To maintain or restore the favourable conservation condition of the bird species listed as Special

Conservation Interests for this SPA.

• To maintain or restore the favourable conservation condition of the wetland habitat at Lough

Ennell SPA as a resource for the regularly-occurring migratory waterbirds that utilise it. The

conservation objectives for the SPA can be accessed at



Describe how the project or plan will affect key species and key habitats. Acknowledge uncertainties

and gaps in information

5.9 The proposed project (intensification of operations at KMK Kilbeggan) does not have the potential to

directly affect habitats and species as it the facility is located outwith any Natura 2000 sites. There is

potential for the project to indirectly affect Natura 2000 sites via emissions to air, fugitive dust and

emissions to water during construction and operation of the facility. The key species and habitats that

could be affected by the project are listed in Table 2.

5.10 However; Air Dispersion Modelling of all three emission points at the facility was undertaken

assuming maximum emissions. The results show that at maximum emissions, ambient ground level

concentrations will be low and not problematic. Therefore, heavy metals in dust and contaminated

air will not reach the Natura 2000 sites as they are all outside the dispersion zone and emissions are

lower than the acceptable levels.

5.11 The main potential sources of contamination for groundwater at the site are heavy metals from the

recycled material and hydrocarbons from oil tanks stored on site. As the entire site is covered by

concrete hardstanding, the pathways from the surface to groundwater are limited.

5.12 The potential air and dust emissions of increased operations at the facility were modelled for the EIAR

and comparison with the existing KMK facility at Tullamore were carried out. The EIAR concluded that

activities at KMK Kilbeggan are not predicted to result in nuisance dust levels due to the fact that all

processing activities will take place indoors or in a covered yard and sensitive locations (houses) are

located a distance 95 – 165m from the site boundary.




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5.13 At the proposed new site entrance there will be a drainage channel which will connect to two

soakaways located in the proposed grassed areas adjacent to the proposed entrance. Surface water

drains to an attenuation tank at the northwest corner of the yard at KMK Kilbeggan, the tank has a

capacity of 233.7m3 to attenuate excess stormwater during extreme rainfall events. Overflow from

the attenuation tank discharges along drainage lines at the back of the site to a silt trap and

interceptor at the north eastern corner, before discharge off-site to the adjoining premises, which

discharges to a land drain. The land drain flows from the facility in a southerly direction to the River

Brosna and flows downstream of three of the four identified Natura 2000 sites. There will be no effect

on these sites as a result of emissions to surface water. The River Brosna flows around Clara Bog SAC

but does not connect to it via surface water pathways and there will be no effect on this SAC as a

result of emissions to surface water.

5.14 The baseline surveys carried out in support of the EIAR (December 2017) show that any effects from

the project are likely to be localised to the facility and immediate surrounds. The project will not affect

key habitats and key species of any Natura 2000 sites.




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Table 2: Effects of the Project on Key Habitats and Species

Natura 2000 Site Location of

Natura 2000

site boundary

relative to KMK

Kilbeggan

Key Habitats Key Species

Potential

Adverse

Effects

Rationale

Split Hills and Long

Hill Esker SAC

001831

ca. 2.5 km north Semi-natural dry grasslands




important orchid sites)

[6210] n/a No

This SAC is ca. 2.5 km north of KMK Kilbeggan and

is upstream of the facility. The land drain flows

from the facility in a southerly direction to the

River Brosna (downstream of the SAC). There will

be no effect on this SAC as a result of emissions to

surface water.

The baseline studies carried out in support of the

EIAR show that there is no potential source of

effects associated with intensification of the

facility that could affect the SAC grassland ca. 2.5

km north.

Clara Bog SAC

000572

ca. 7.0 km

south-west

Semi-natural dry grasslands




important orchid sites)

[6210]

n/a No

There is no landscape connectivity11 or surface

water pathway linking this SAC and the facility.

The land drain flows from the facility in a southerly

direction to the River Brosna which, although it

flows around the SAC, does not connect to it.

There will be no effect on this SAC as a result of

emissions to surface water. Active raised bogs [7110] n/a No

______________________

11 Landscape connectivity is a combined product of structural and functional connectivity, i.e. the effect of physical landscape structure and the actual

species use of the landscape (Kettunen et al. 2007)




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Natura 2000

site boundary

relative to KMK

Kilbeggan


Potential

Adverse

Effects

Rationale

Degraded raised bogs still

capable of natural

regeneration [7120]

n/a

No



effects associated with intensification of the

facility that could affect the SAC grassland ca. 2.5

km north. Depressions on peat

substrates of the

Rhynchosporion [7150]

n/a

No

Bog woodland [91D0] n/a No

Lough Ennell SAC

000685

ca. 8.6 km north Alkaline fens [7230] n/a No There is no landscape connectivity between this

SAC and the facility. The land drain flows from the

facility in a southerly direction to the River Brosna

which is downstream of the SAC. There will be no

effect on this SAC as a result of emissions to

surface water.



effects, such a groundwater drawdown,

associated with intensification of the facility that

could affect the alkaline fen ca. 8.6 km north

Lough Ennell SPA

004044

ca. 9.0 km north n/a Pochard (Aythya ferina)

[A059]

No There is no landscape connectivity between this

SPA and the facility. The land drain flows from the

facility in a southerly direction to the River Brosna

which is downstream of the SPA. There will be no

effect on this SPA as a result of emissions to

surface water.

n/a Tufted Duck (Aythya

fuligula) [A061]

No

n/a Coot (Fulica atra) [A125] No




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Natura 2000

site boundary

relative to KMK

Kilbeggan


Potential

Adverse

Effects

Rationale

n/a Wetland and Waterbirds

[A999]

No The baseline studies carried out in support of the


effects, such as noise or loss of feeding habitat,

associated with intensification of the facility that

could affect the SPA ca. 9.0 km north




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Describe how the integrity of the Natura 2000 site is likely to be affected by the project or plan.

Acknowledge also uncertainties and any gaps in information.

5.15 The integrity of Natura 2000 (European) sites is likely to be affected if the proposed development

undermines the conservation objectives for these species by reduction in their conservation status as

set out in NPWS supporting documents12 for each Natura 2000 site.

5.16 The proposed intensification of operation at KMK Kilbeggan (as described in detail in the EIAR,

December 2017) will not result in effects that are likely to extend beyond the facility and the

immediate surrounds. Therefore; the conservation status of the key habitats and species that the

Natura 2000 sites are selected for will not be affected. The integrity of Natura 2000 sites is not likely

to be affected by the development.

Describe what mitigation measures are to be introduced to avoid, reduce or remedy the adverse

effects on the integrity of the site. Acknowledge uncertainties and any gaps in information.

5.17 The conservation status of the key habitats and species that the Natura 2000 sites are selected for

will not be affected. The integrity of Natura 2000 sites is not likely to be affected by the development.

However; mitigation measures to avoid any risk of adverse effects on the integrity of Natura 2000

sites are set out below.

5.18 The KMK compliance manager and KMK Kilbeggan facility EHS officer will be responsible for

implementation of the mitigation measures as set out in this document during all phases of the

development. The monitoring and maintenance associated with the mitigation measures during

construction and operation will be documented in an auditable format and will be included in the

Annual Environmental Report (AER) for the facility.

Construction Phase

5.19 The appointed contractor for the construction phase of the proposed development will be

responsible for providing a briefing on environmental protection measures and ecological sensitivities

of the Site to all site personnel in advance of commencement of enabling works. The appointed

contractor and KMK compliance manager and EHS officer will be responsible for ensuring all

mitigation measures set out in this document and any site specific method statements are fully and

correctly implemented. It is recommended that the responsibility for environmental protection and

compliance with the required protective measures during the construction stage is assigned to an

experienced site worker or that an environmental manager is appointed by the contractor.

5.20 Good work practices such as those set out in, but not limited to, Guidelines on Protection of Fisheries

During Construction Works in and Adjacent to Waters (IFI, 2016), Environmental Good Practice on Site

Guide (CIRIA, 2015) will be employed at all times on site during the construction of the proposed

development.

5.21 The following environmental protection measures will be implemented at the facility during the

construction phase:

• There will be no direct discharge to the watercourse at any time during the construction phase.

Surface water run-off within the Site will be directed to the existing surface water system and

will pass through silt traps and hydrocarbon interceptors prior to discharge.

• Should short-term stockpiles be required during construction these will be located at least 15 m

away from the land drain north of the facility. Slopes of these stockpiles will be made stable and

______________________

12 https://www.npws.ie/protected-sites




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regularly checked by the contractor or appointed staff member. Stockpiles shall be stored on

impermeable surfaces and covered using tarpaulin

• All equipment and machinery will be checked for leaks and other potential sources of

contaminants before arriving on Site and on a daily basis. Any equipment or machinery likely to

introduce to contaminants to the facility will not be brought on Site or will be removed from Site

immediately any leak is discovered. Spill kits will be available to machine operators and they will

be trained in their use.

• There will be no refuelling of machines within 15 m of the land drain.

• A silt trap and petrol interceptor will be installed at the northeast of the site, just prior to the

stormwater drain moving off-site. This will prevent any sediment or fuel that may make its way

to the stormwater drain from entering surface water.

5.22 The environmental measures set out above will ensure that ensure protection of the environment

during construction and that there will be no effect on Natura 2000 sites as a result.

Operational Phase

• The surface water management system for the operational facility includes features such as silt

traps to capture sediments from the surface water before its discharge to the stream. Surface

water will pass through a silt trap and oil interceptor prior to discharge. This system will be

maintained throughout the lifetime of the project to ensure its functionality.

• All processing on site and all traffic movement areas will be carried out on impermeable surfaces.

• To ensure that the site does not cause contamination of land and soil beneath and surrounding

its site, it will undertake routine visual checks of hardstanding, stormwater drains, and foul water

drains at the site to ensure their integrity.

• To protect the quality of the groundwater beneath the facility the concrete hardstanding will be

regularly inspected for cracks while stormwater and foul water drains will be inspected for

leakage.

• To protect air quality the dust extractors will be visually inspected on a daily basis and maintained

as required.

• The FPD processing machine filters will be visually inspected on a regular basis and maintained

as required.

• Stack monitoring will be carried out at intervals as required by IED licence.

• There will be no storage of materials in uncovered yard areas and the site will dampen down

yard areas in dry weather if necessary to reduce dust from traffic movements.

• All internal WEEE and metal processing machines will be well maintained so that excess dust

emissions are not generated and doors of processing areas will be closed when not required for

vehicle movements.

• Existing hedgerows to the west of the site will be left in place as screening.

5.23 The maintenance and monitoring required for machinery and stacks will be clearly displayed in a

prominent place close to where they are operated and / or monitored. The KMK staff members

responsible for operation will be trained to carry out the visual inspections and will have clear

processes to follow to allow them to flag non-conformance or other concerns. Such processes should

be incorporated into the operations documents for the facility and all inspections should be

documented in an auditable manner.




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July 2019

Page | 25

5.24 The environmental measures set out above will ensure that ensure protection of the environment

during operation of the facility and that there will be no effect on Natura 2000 sites as result.

Consideration of Findings

5.25 The mitigation measures outlined in this report, if fully implemented as described, are considered to

be sufficient to prevent any effect on features of interest of any Natura 2000 sites. It is therefore

considered that, there will be no adverse effects on the integrity of any Natura 2000 sites as a result

of the proposed intensification of operations at KMK Kilbeggan.

5.26 Based on the information set out in this report as well as the December 2017 EIAR, we submit that

the competent authority has sufficient information to allow them to determine that the proposed

development, individually or in combination with other plans or projects, will not have an adverse

effect on any European sites.




SLR Ref No: 501.00323.00006

July 2019

Page | 26

6 REFERENCES

CIEEM (2018) Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial,

Freshwater, Coastal and Marine. Chartered Institute of Ecology and Environmental Management,

Winchester.

DoEHLG (2009). Appropriate Assessment of Plans and Projects in Ireland: Guidance for Planning

Authorities. National Parks and Wildlife Service, Department of the Environment, Heritage and Local

Government. Dublin.

European Commission (2001). 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.

European Commission (2018). Managing Natura 2000 Sites: The Provisions of Article 6 of the ‘Habitats

Directive’ 92/43/EEC. European Commission, Brussels, Belgium

European Union Habitats Directive, (1992). Council Directives 92/43/EEC of 21 May 1992 on the

conservation of natural habitats and of wild fauna and flora.

Kettunen, M, Terry, A., Tucker, G. & Jones A. (2007) Guidance on the maintenance of landscape features

of major importance for wild flora and fauna - Guidance on the implementation of Article 3 of the Birds

Directive (79/409/EEC) and Article 10 of the Habitats Directive (92/43/EEC). Institute for European

Environmental Policy (IEEP), Brussels, 114 pp. & Annexes.

Inland Fisheries Ireland (2016) Guidelines on Protection of Fisheries during Construction Works in and

Adjacent to Waters. Inland Fisheries Ireland

NPWS (2018) Conservation Objectives: Split Hills and Long Hill Esker SAC 001831. Version 1. National

Parks and Wildlife Service, Department of Culture, Heritage and the Gaeltacht.

NPWS (2017) Natura 2000 Standard Data Form for Split Hills and Long Hill Esker SAC (001831).

Department of Culture, Heritage and the Gaeltacht

NPWS (2013) Site Synopsis for Split Hills and Long Hill Esker SAC 001831. Department of Culture,

Heritage and the Gaeltacht.

NPWS (2016) Conservation Objectives: Clara Bog SAC 000572. Version 1. National Parks and Wildlife

Service, Department of Arts, Heritage, Regional, Rural and Gaeltacht Affairs.

NPWS (2017) Natura 2000 Standard Data Form for Clara Bog SAC 000572. Department of Culture,


NPWS (2015) Site Synopsis for Clara Bog SAC 000572. Department of Culture, Heritage and the

Gaeltacht.

NPWS (2018) Conservation Objectives: Lough Ennell SAC 000685. Version 1. National Parks and Wildlife

Service, Department of Culture, Heritage and the Gaeltacht.

NPWS (2017) Natura 2000 Standard Data Form for Lough Ennell SAC (00068). Department of Culture,


NPWS (2013) Site Synopsis for Lough Ennell SAC 000685. Department of Culture, Heritage and the

Gaeltacht.

NPWS (2018) Conservation objectives for Lough Ennell SPA [004044]. Generic Version 6.0. Department

of Culture, Heritage and the Gaeltacht.




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NPWS (2017) Natura 2000 Standard Data Form for Lough Ennell SPA 004044. National Parks and

Wildlife Service, Department of Arts, Heritage and the Gaeltacht.

NPWS (2013) Site synopsis for Lough Ennell SPA 004044 National Parks and Wildlife Service,

Department of Arts, Heritage and the Gaeltacht.

Q.E.D Engineering (2017) KMK Metals Recycling Ltd, Moate Road, Kilbeggan, Co. Westmeath

Environmental Impact Assessment Report (EIAR)

Scott Wilson and Levett-Therivel, (2006). Appropriate Assessment of Plans. Scott Wilson, Levett-

Therivel Sustainability Consultants, Treweek Environmental Consultants and Land Use Consultants.

Tyldesley. D., and Chapman, C., (2013) The Habitat Regulations Assessment Handbook, February 2019

Edition UK: DTA Publications Ltd.

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kmk metals facility, moate road, kilbeggan, co. westmeath · 2019. 7. 6. · moate road, kilbeggan,...

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