ABPsubm,Air Quality,I.Shanahan,CSRPlanners.pdf

AIR QUALITY IMPACT ASSESSMENT OF

PROPOSED NATIONAL CHILDREN’S HOSPITAL

AT ST JAMES’S HOSPITAL CAMPUS, JAMES’S STREET, DUBLIN 8

AIR QUALITY SUBMISSION

PREPARED FOR

THE JACK & JILL FOUNDATION

Report Ref 22577 01 October 2015 Dr Imelda Shanahan

Phone: +353-1-4626710

Fax: +353-1-4626714

Web: www.tmsenv.ie

TMS Environment Ltd

53 Broomhill Drive

Tallaght

Dublin 24

t m s environment ltd

http://www.tmsenv.ie/

Air Quality Impact Assessment for the proposed National Children’s Hospital

TMS Environment Ltd

Report Ref 22577 Page 2 of 69

Table of Contents

Executive Summary

1.0 Introduction and scope 8

2.0 The development proposal 9

3.0 Impact assessment approach 10

4.0 The receiving environment 12

4.1 Meteorological data for the air quality impact assessment 12

4.2 Baseline air quality in the receiving environment 19

5.0 Air quality impact assessment 34

5.1 Potential air quality impacts 34

5.2 Air Quality Standards and impact assessment criteria 41

5.3 Prediction and evaluation of Construction Phase impacts on air quality 45

5.3.1 Potential Construction Phase air quality impacts

5.3.2 Dust from general construction

5.3.3 Aspergillus emissions

5.3.4 Construction vehicle emissions

5.3.5 Drimnagh Sewer relocation

5.3.6 Emissions associated with demolition works

5.3.7 Emissions of hazardous substances from excavation in contaminated ground

5.3.8 Observations on the impact assessment approach adopted in the EIS

5.4 Prediction and evaluation of Operation Phase air quality impacts 55

5.4.1 Potential Operation Phase air quality impacts

5.4.2 Traffic emissions

5.4.3 Energy Centre emissions


6.0 Conclusions 69


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Executive summary

This air quality impact assessment report was prepared on behalf of the Jack & Jill

Foundation for the proposed development of a national children’s hospital at the site of the

existing hospital at St James’s Hospital Campus, James’s Street, Dublin 8. The Charity’s

position is that they do not object to the principle of a children’s hospital but they are very

firmly of the view that this is an entirely inappropriate location for a national children’s

hospital for a number of reasons including air quality. Our brief is to evaluate the air quality

aspects of the proposal and to advise on the suitability of the proposed location for the

children’s hospital in terms of existing and future air quality impacts. The concerns of the

Jack & Jill Foundation relate solely to proposals for the St James’s Hospital Campus and our

report therefore focuses only on this element of the application.

In our assessment, our objective is to challenge the air quality impact assessment of the

development proposal as presented in the EIS in Chapter 12 Air Quality and Climate. The

approach that we have adopted for the assessment is to carry out a complete assessment of

the air quality impact of the proposal and to then compare our independent assessment

findings with those presented in the EIS. We seek to provide a rigorous assessment of the

methodologies adopted in the EIS, the findings of the impact assessment and the

conclusions drawn and therefore aim to provide An Bord Pleanala with a robust assessment

of air quality aspects of the proposed development from the perspective of the most

important stakeholders, Ireland’s sick children.

The approach to the assessment is described in detail in this report and is summarised as

follows:

Characterise the receiving environment in terms of baseline air quality and

meteorological conditions which have the potential to influence the dispersion of

pollutants and therefore the air quality impact of, and on, the proposed

development;

Identify the likely and possible air quality impacts of Construction and Operation

Phases of the proposal;


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Carry out a quantitative assessment of the potential air quality impacts of the

proposal, benchmarking the assessment against Air Quality Standards and Guidelines

formulated for the protection of human health, amenity and the environment;

Evaluate the overall air quality impact of the proposal and advise on the suitability

of the site for the proposed development proposal.

A comprehensive assessment was carried out and the main findings are presented in this

report. It is clear from this report that there are differences in the methodologies adopted

by the EIS Team and ourselves in some aspects of the air quality impact assessment. As a

result of the work undertaken, we are concerned that the air quality impact assessment

presented in the EIS understates the potential air quality impacts of the proposal. The

principal concerns are summarised as follows.

(i) Baseline air quality in the receiving environment is representative of the city centre

location of the proposed development and is strongly influenced by traffic and by

emissions from commercial and industrial activities in the area. The baseline air quality

against which future impacts are predicted does not consider this and is understated in

the EIS, having selected data that is representative of the wider Dublin area rather than

the specific location where the development is proposed. Baseline air quality is poorer in

the proposed location than almost anywhere outside the city centre, which is not

surprising given the influence of emissions from traffic on air quality in the area. There is

therefore limited assimilative capacity available in the receiving environment to

accommodate any significant developments and especially developments as significant,

and as uniquely sensitive, as the proposed children’s hospital and future maternity

hospital.

The approach followed in Chapter 12 of the EIS is to select a single set of baseline air

quality data to represent air quality at St James’s, Tallaght and Blanchardstown. This is

inappropriate in my opinion and leads to an underestimate of the existing level of

pollutants in ambient air at St James’s. The most seriously ill children will spend time in

the proposed children’s hospital at St James’s and sick children will spend longer in this

location than either of the satellite centres. It is therefore very important that a reliable

statement of baseline air quality specifically for the St James’s campus is formulated. It is


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an over-simplification to consider the three sites together and the assumption that the

same data set reliably describes baseline air quality at each site is an understatement of

baseline conditions at St James’s.

(ii) Construction Phase air quality impacts will be significant and will endure for four years.

The impacts have the potential to significantly impact on the existing St James’s hospital

as outlined in this report and will require a reliable and extensive Air Quality

Management Plan to accompany any such construction programme. Even with extensive

and effective management and control measures, there are significant risks associated

with the emissions of hazardous substances during construction. The assessment of

Construction Phase traffic impacts appears not to have considered Heavy and Light

Goods Vehicle (HGV and LGV) movements associated with construction, at least not on

the site, and therefore these impacts are understated.

(iii) Operation Phase air quality impacts of the proposal are extremely significant and this

report has shown that the EIS very significantly understates the potential impacts. The

most significant Operation Phase impacts on air quality are associated with emissions

from the Energy Centre that is planned to meet the significant energy requirements of

the combined existing and proposed development. The energy requirements of the site

will more than double for the proposed children’s hospital, and future expansion of the

children’s hospital and the maternity hospital would more than treble the energy

requirements of the campus. This means that the emissions to atmosphere associated

with the Energy Centre would at least double for the proposed children’s hospital and

increase by at least 300% for the future expansion phase and inclusion of the maternity

hospital; and this does not take account of the required future expansion and

development of the adult hospital at the site. Emissions to atmosphere from the Energy

Centre could be even higher if the use of diesel oil as the primary fuel rather than

natural gas is required as highlighted, but not evaluated, in the EIS.

(iv) Air Quality Standards are referenced throughout the EIS but the World Health

Organisation Guidelines are not specifically referenced in the EIS. While the WHO

Guidelines are not mandatory, they represent current informed opinion on the levels to

which we should be aspiring in order to minimise adverse health impacts of air pollution.


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Since the proposed development of a National Children’s hospital will cater for sick

children with compromised immune systems and limited ability to cope with additional

stresses such as air pollution, it is prudent to consider the WHO Guidelines as well as the

mandatory Air Quality Standards for the purpose of this assessment. These guidelines

have not been formally considered in the EIS but this assessment report does consider

the Guidelines.

(v) The release of hazardous substances including toxic and hazardous pollutants and

Aspergillus spores during construction activity are specific potential impacts which were

not quantitatively assessed in the EIS. This assessment does consider these factors and

determines that significant risks are associated with such releases.

(vi) Emissions from the most significant Operational Phase emissions source, the Energy

Centre, have been understated in the EIS thus leading to an understatement of potential

air quality impacts. Some of the most significant concerns relate to the following:

Only 10 emissions sources were modelled for the Energy Centre although the EIS

states that more than this is required.;

not all emission parameters were included in the modelling eg PM10, PM2.5, CO

and SO2 were not included in the assessment;

the significant variation in emissions with the different fuel types was not

evaluated;

the magnitude of the emissions that were considered is underestimated;

the impact of nitrogen oxides (NOx) from the Energy Centre on the Grand Canal

proposed Natural Heritage Area (pNHA) has not been assessed.

(vii) The air quality impact predictions carried out for this report show that much higher

impacts are predicted than those given in the EIS. For nitrogen dioxide, the predicted

ambient concentration will be 80% of the Air Quality Standard for just the children’s

hospital and the existing facility which means that there is little or no assimilative

capacity remaining for further expansion or other developments in the area.

(viii) The use of the National Roads Authority “Guidelines for the Treatment of Air Quality

During the Planning and Construction of Major Road Schemes” for the impact


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assessment is inappropriate. While this is an excellent methodology for assessing the air

quality impact of major road schemes, there are very significant differences between the

construction of a road scheme and a fixed construction site such as the site of the

proposed Children’s hospital at St James’s Street. The methodology does not allow a

reliable assessment of all of the potential construction phase impacts.

One of the most significant differences between the construction of a road scheme and

the proposed Children’s hospital is that for a road scheme, the construction site moves

regularly and therefore the areas where air quality impacts are observed also vary with

time. For the proposed Children’s hospital, the construction site stays the same, in a

relatively confined space (relative to a road scheme) and therefore the air quality

impacts are more localised than they would be for a road scheme. For the proposed 4-

year construction programme, air quality impacts will be experienced over a relatively

small localised area and these impacts will be more intense and concentrated than for

shorter duration programmes on sites where the construction activity is moving

regularly. I believe the methodology adopted has underestimated the potential impacts

of the construction phase of the proposed development due to the significant

differences between a road scheme and a fixed construction site in a confined area.

The comprehensive dispersion modelling impact assessment carried out for this assessment

report has led to significantly higher predicted impacts than those presented in the EIS. The

modelling results suggest that there is insufficient assimilative capacity in the proposed city

centre location to ensure that air quality standards are not exceeded as a result of the very

significant emissions that will be released from the Energy Centre for the combined

activities on the site. The results further suggest that when the significantly higher emissions

associated with the expansion of the proposed children’s hospital and the future maternity

hospital are considered, Air Quality Standards could be exceed as a result of the emissions.

This leads to the conclusion that the proposed city centre location is not a suitable location

for the proposed development. Areas removed from the city centre with lower baseline air

pollutant concentrations would have greater assimilative capacity and would be more

suitable from air quality impact considerations than the proposed city centre location.


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1.0 Introduction and scope

We have been instructed by the Jack & Jill Foundation to prepare an assessment of

the air quality impact of the proposed development of a national children’s hospital

at the site of the existing hospital at St James’s Hospital Campus, James’s Street,

Dublin 8.

The Charity’s position is that they do not object to the principle of a children’s

hospital but they are very firmly of the view that this is an entirely inappropriate

location for a national children’s hospital for a number of reasons including air

quality. They believe that the new hospital will fail to meet the needs of Ireland’s

sickest children due to the unsuitability of the proposed location and they are

concerned that this once-in-a-lifetime opportunity to provide for the current and

future needs of our country’s sickest children will not achieve the best possible

outcome. The Foundation are uniquely positioned to make this assessment, and we

support the Charity in their effort to secure the best possible future care for sick

children in Ireland.

Our brief is to evaluate the air quality aspects of the proposal and to advise on the

suitability of the proposed location for the children’s hospital in terms of existing and

future air quality impacts. In our assessment, our objective is to challenge the air

quality impact assessment of the development proposal as presented in the EIS in

Chapter 12 Air Quality and Climate. We seek to provide a rigorous assessment of the

methodologies adopted in the EIS, the findings of the impact assessment and the

conclusions drawn and therefore aim to provide An Bord Pleanala with a robust

assessment of air quality aspects of the proposed development from the perspective

of the most important stakeholders, Ireland’s sick children.

The concerns of the Jack & Jill Foundation relate solely to proposals for the St

James’s Hospital Campus and our report therefore focuses only on this element of

the application. We have no comments to make on the other two elements of the

proposal unless such comments are required to support the assessments made in

respect of the St James’s hospital campus site.


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2.0 The development proposal

The project is described in detail in Chapter 2 of the EIS, and includes a number of

development features. The main project site is located on the campus of St James’s

Hospital Dublin 8 and includes the new children’s hospital and Family

Accommodation Unit which are located in the west of the campus, the proposed

Children’s Research and Innovation Centre sited along James’s Street and a

construction compound at Davitt Road which is directly associated with the

developments at the St James’s Hospital Campus. There are also ancillary works

associated with the above main development features.

The key elements of the proposed development which require assessment in respect

of potential air quality impacts during both construction and operating phases are as

follows:

Demolition of all buildings on the site of the new children’s hospital, Family

Accommodation Unit and proposed Children’s Research and Innovation

Centre;

Construction of a new children’s hospital building and associated helipad;

Construction of two level underground car park with a further level of shared

facilities management hub and energy centre below;

Construction of the Children’s Research and Innovation Centre;

Construction of a Family Accommodation Unit;

Public realm improvements including existing campus spine road, demolition

of 2 no. buildings and relocation of parking to accommodate same;

Improvements to the road junction at the existing campus entrance on St

James’s Street and a new campus entrance piazza from Brookfield

Road/South Circular Road, with minor improvements to these roads;

A new vehicular entrance from Mount Brown;

A realigned internal campus road;

A new shared flue stack for the campus;

a range of infrastructure works, including the diversion of the existing

Drimnagh Sewer and revised boundary treatments.


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In line with standard practice and best practice guidelines, there is a requirement to

evaluate the impact on air quality of all aspects of the Construction and Operation

Phases of the development proposal and this report presents such an assessment. In

this report we set out our assessment methodology and the findings of our own

independent assessment of the air quality impacts of the proposed development.

Where differences between our findings and those of the EIS Team are identified

these are highlighted in the report.

3.0 Impact Assessment Approach

The general approach to air quality impact assessment follows the scheme outlined

in Figure 1.

Figure 1 Air quality impact assessment approach

The assessment follows a well-established path through the identification and

characterisation of the air quality impacts that must be addressed, characterisation

of the receiving environment to benchmark the existing situation, quantitative

prediction of air quality impacts and assessment of the impacts against recognised

Air Quality Standards and Guidelines. From this assessment comes a definition of the

Management Plans and environmental solutions that are required to ensure that all

Scoping

• Identify & rank emission sources & issues• Map Construction Impacts• Map Operation Impacts

BaselineCharacterise the receiving environment

Assessment• Characterise emissions & potential impacts • Map topography, Site layout, Receptors • Select Meteorological data • Choose Background Air Quality data • Air Quality Standards, Impact assessment criteria • Predict and evaluate impact • Formulate Management Plans and solutions


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aspects of the impacts of the development proposal through Construction and

Operation Phases are managed and controlled to protect human health, the

environment and amenity. It is clear that if this sequence is not thoroughly and

robustly executed, then the Management Plans and environmental solutions for any

problems identified during the assessment cannot be formulated to guarantee the

effective management of air quality impacts.

Chapter 12 of the EIS for the National Paediatric Hospital Project describes an

assessment of the likely air quality & climate impact of the proposed development.

Section 12.1.2 of the EIS sets out the methodology that was adopted for the air

quality and climate impact assessment as follows:

1. “Characterise the receiving environment through detailed analysis of EPA

data;

2. Determine appropriate criteria for evaluating the significance of air

quality and climate impacts through reference to local guidance

documents where applicable and international best practice;

3. Calculate the potential air quality & climate impacts using industry

standardised calculation methods;

4. Assess the impact by comparing the calculated levels against the adopted

criteria;

5. Where necessary specify ameliorative, remedial or reductive measures to

control the impacts to be within the adopted criteria, and;

6. Present the predicted impact of the proposed development including the

ameliorative, remedial or reductive measures. “

I concur with the choice of general approach and methodology adopted in the EIS for

the air quality impact assessment, but I am concerned that some aspects of the

specific methodologies adopted do not provide a robust assessment of the actual

and potential air quality impacts of this significant development proposal. I will

follow the same general assessment approach in this assessment report, carrying out

my own assessments and quantitative prediction of impacts, and I will highlight the


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differences in opinion and / or findings in each section of this report. I am not

concerned with the Climate impact assessment and do not refer to it in this report.

4.0 The receiving environment

4.1 Meteorological data for the air quality impact assessment

The magnitude of potential impacts of any proposed development on air quality will

be influenced by the local meteorological conditions, in particular by wind speed and

direction and by precipitation rates. An evaluation of the meteorological conditions

at the site is therefore required to assist in the assessment of air quality impacts.

Furthermore, modelling or quantitative predictive studies that are employed in the

air quality impact assessment require that representative meteorological data is

selected and used for the assessment. It is therefore very important that

representative meteorological data is selected for the assessment.

The general guidance on selection of meteorological data for air quality impact

assessments is to choose representative data, recently acquired, which best

represents conditions at the site. At least three years of recently acquired data is

preferred. Met Éireann operate a Synoptic Network of weather stations at Belmullet,

Malin Head, Rosslare, Birr, Clones, Kilkenny and Mullingar while the Aviation Division

of Met Éireann maintains observing stations at Shannon Airport, Knock Airport,

Casement Aerodrome, Dublin Airport and Cork Airport. Data from one of these

stations is likely to be representative of conditions at the site for modelling and

impact assessment purposes.

There is no continuous meteorological monitoring station located uniquely close to

the site of the proposed development, but comprehensive monitoring data is

available for Dublin Airport (approximately 10 km north-east of the site) and

Casement Aerodrome (approximately 10km southwest of the site) which would be

indicative of the meteorological conditions that are experienced at James’s Street.

Casement Aerodrome may experience different conditions due to the complexity of

nearby terrain so Dublin Airport data is preferred. It is therefore recommended that

recent data from Dublin Airport is selected for the assessment.


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Wind speed and direction in particular is important in determining how emissions,

especially those from tall stacks such as the flues from the proposed Energy Centre,

are dispersed. The prevailing wind direction determines which areas are most

significantly affected by the emissions from the activity and wind speed determines

in part the effectiveness of the dispersion of the emissions. It is instructive to

examine a selection of the meteorological data from the two stations to illustrate

how the data may vary. Figure 2 shows a windrose for Casement Aerodrome for

2010 and one for Dublin Airport for 2010.

Figure 2 Windroses for Casement Aerodrome and Dublin Airport for 2010

It is clear from the windroses that there are some differences in the pattern of wind

speed and wind direction for the two locations. The dominant wind direction for

Casement Aerodrome is from the southwest, whereas the dominant wind direction

for Dublin Airport is from the west. For Casement Aerodrome, the wind speed is

below 5.14m/s for 71% of the time whereas for Dublin Airport this percentage

reduces to 64%. The average long-term wind speed for Casement Aerodrome over

the period 1985 – 2010 is approximately 5.5 m/sec and the average wind speed for

Dublin Airport for the same timeframe is 5.3m/sec. This limited analysis of the data

suggests that (a) the location of maximum predicted impact is likely to vary for the

two data sets, especially for averaging intervals other than annual, and (b) more

effective dispersion and therefore lower ground level concentrations of pollutants

Casement Aerodrome (2010) Dublin Airport (2010)


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may be predicted using Dublin Airport data compared to that for Casement

Aerodrome data.

In view of the likely sensitivity of the air quality impact predictions to the choice of

meteorological data, it is prudent to consider the sensitivity of any impact

predictions to the selection of input data such as meteorological data and therefore

it is appropriate to select three years of recent data from each of the two available

representative datasets and to evaluate the effect of any variations in the data on

the impact predictions. The worst-case data set would then generally be chosen for

the assessment unless some other consideration dictates a specific choice.

Variations of 10 – 30% in the magnitude of impact predictions for different

meteorological data sets are expected. The ‘sensitivity analysis’ whereby different

data sets are considered in the assessments is especially important when the

predictions indicate a potentially significant impact, when any air quality standard is

predicted to be approached or when significant uncertainties exist in the other data

sets used for the assessment.

The choice of meteorological data is supported by previous studies for large-scale

developments in this area. The adjacent Diageo complex at St James’s Gate operates

under the terms of an Industrial Emissions (IE) Licence from the Environmental

Protection Agency (Licence Reg No. 301-041) and this licence was reviewed in 2015

with the current revised licence issued on 12th August 2015. This significant industrial

facility is licenced for the following categories of activity:

Combustion of fuels in installations with a total rated thermal input of 50

MW or more,

The treatment and processing, other than exclusively packaging, of the

following raw materials, whether previously processed or unprocessed,

intended for the production of food or feed from: (ii) only vegetable raw

materials with a finished product production capacity greater than 300

tonnes per day.

1 Accessible for download at http://www.epa.ie/licences/lic_eDMS/090151b28054ed9e.pdf (accessed 26

September 2015)

http://www.epa.ie/licences/lic_eDMS/090151b28054ed9e.pdf


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In April 2015, Diageo applied to the Environmental Protection Agency (EPA) for a

review of their IE Licence to address a number of changes which included installing a

new fourth roasting plant to augment the existing three roasting plants at the site; a

new (fourth) afterburner will also be installed to treat the emissions to atmosphere

from the roasting plant. The roast-house is located on the upper level of the site (to

the south of James's Street) adjacent to St James’s Hospital and the four significant

roast-house afterburner emissions flues are located less than a kilometre away from

the proposed flues for the St James’s Energy Centre as shown in Figure 3. The Diageo

Energy Centre, with 5 large CHP Boilers catering for the facility is located on the main

Diageo Campus and those flues are approx. 2km from the proposed flues at the St

James’s Energy Centre.

Figure 3 Proximity of Diageo Roast House and Energy Centre to St James’s

Hospital Energy Centre

The Application to the EPA for a review of the IE Licence for the significant Diageo

industrial facility was accompanied by a significant number of reports including a

dispersion modelling assessment of air quality impacts of the existing and proposed

Distance from the Energy Centre flues to the Guinness Roast House approx. 915m

Approximate distance from St James’s Energy Centre to Diageo Energy Centre 2km


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emission points2. This report also selected meteorological data from Dublin Airport

for the assessment of air quality impacts at the St James’s Gate Diageo complex. The

report was reviewed and accepted by the EPA which indicates that the choice of

meteorological data was appropriate for this site and assessment.

Section 12.1.2.4 of the EIS, prepared by AWN Consulting, describes the Receiving

Environment in terms of meteorological data and the existing ambient air quality.

The report notes that the nearest representative weather station collating detailed

weather records is Casement Aerodrome which is located approximately 10km

southwest of the main St James’s site. The report also notes that five years of recent

representative data from 2007 – 2011 is used in the main impact assessment. The

EIS Chapter took the approach that one data set would be chosen to represent

conditions at each of the three sites in St James’s Street, Tallaght and

Blanchardstown, and chose Casement Aerodrome meteorological data to represent

the meteorological conditions at each of the three sites. For the reasons noted

above, we recommend that both Casement Aerodrome and Dublin Airport

meteorological data should be used for the assessment, with Dublin Airport being

the preferred primary data set and Casement Aerodrome data used for sensitivity

analysis.

It is especially important that cumulative impacts of emissions from the most

significant emissions sources associated with the proposed Children’s Hospital, the

Energy Centre flues, and the very significant emissions from the adjacent Diageo

Energy Centre and Roast-house afterburners are carefully evaluated. The same

meteorological dataset should therefore be used to ensure that the dispersion of

emissions from all these sources is affected in the same way by the meteorological

data and that therefore cumulative impacts are assessed.

Appendix 12 of the EIS contains a report by Arup Engineers on ‘An Air Dispersion

Modelling Assessment’ to support the New Flue Design for the Energy Centre at the

St James’s site. This report surprisingly uses meteorological data for a different

meteorological station for the dispersion modelling assessment from the main

2 Accessible for download at http://www.epa.ie/licences/lic_eDMS/090151b28052e22c.pdf (accessed 26

September 2015)

http://www.epa.ie/licences/lic_eDMS/090151b28052e22c.pdf


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report, Dublin Airport rather than Casement Aerodrome, and furthermore uses older

and unrepresentative data from 2000 to 2004. There is no discussion presented in

the EIS Chapter or in the Arup report as to why this significant discrepancy arose and

why out of date meteorological data was used for the assessment.

The best practice Guidance on dispersion modelling in Ireland is the publication by

the Environmental Protection Agency “Air Dispersion Modelling from Industrial

Installations Guidance Note (AG4)” which is widely used in Ireland in Air Quality

Impact Assessment studies of the type under consideration here. This Guidance Note

(hereafter referred to as AG4, available at web address below3) stipulates at Section

6.1 (Page 23) that:

“It is recommended that a minimum of three years of meteorological data

from an appropriate meteorological station should be used in the assessment.

Furthermore, the most recent year of the data set used should have been

compiled within the last ten years.”

The selection of meteorological data for the Energy Centre dispersion modelling

assessment that supported one of the most significant aspects of the proposal in

terms of air quality impact assessment therefore does not conform with best

practice guidance since the most recent year of meteorological data is 11 years old

and falls outside the recommended time period.

The significance of this can be considered by examining the difference in distribution

of wind speeds for different years for Dublin Airport. The most recent year of

meteorological data used in the EIS was 2004 and the windrose for Dublin Airport for

2004 is compared in Figure 4 with that for Dublin Airport for 2010. The most

significant difference between the two data sets is the distribution of wind speeds

with high wind speeds greater than 5.14m/sec observed for 49.2% of the time in

2004 and only 35.8% of the time in 2010. Very high windspeeds greater than 10.8

m/sec occurred for 18% of the time in 2004 and only 7.2% in 2010. The same pattern

is observed for the other years of data used in the EIS compared to the more recent

data. This significant difference in the distribution of windspeeds in the older

3http://www.epa.ie/pubs/advice/air/emissions/airdispersionmodellingfromindustrialinstallationsguidancenote

ag4.html#.VgLqm42FPIU (accessed 24 September 2015)

http://www.epa.ie/pubs/advice/air/emissions/airdispersionmodellingfromindustrialinstallationsguidancenoteag4.html#.VgLqm42FPIU

http://www.epa.ie/pubs/advice/air/emissions/airdispersionmodellingfromindustrialinstallationsguidancenoteag4.html#.VgLqm42FPIU


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meteorological data could lead to a significant understatement of ground level air

quality impacts. In our dispersion modelling assessment we have used the more

recent years of meteorological data as a more reliable indicator of meteorological

conditions to provide a robust assessment of potential air quality impacts.

Figure 4 Windroses for Dublin Airport for 2004 and 2010

The failure to conform to best practice guidance is disappointing and has

underestimated the impact of the emissions from the Energy Centre on ambient air

quality in the vicinity of the site and/or at locations removed from the site. The

significant height of all flues (53m above ground level according to the EIS) indicates

that the emissions are significant and that very tall stacks were required to ensure

effective dispersion of emissions. Considering the significance of the emissions it is

therefore even more important that reliable and representative meteorological data

is used for the assessment.

Dublin Airport (2004) Dublin Airport (2010)


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4.2 Baseline air quality in the receiving environment

The St James’s Hospital campus is located in the city centre in an urban area. The

dominant influences on air quality in the area are emissions from commercial energy

and heating sources, domestic heating, traffic and emissions from any industrial

activities in the area. Emissions from the existing Energy Centre, the emissions from

other combustion sources in the area such as the Diageo facility, and traffic are

expected to be the principal contributors to ambient air quality in the vicinity of the

site. These sources are also expected to be the dominant contributors to air quality

in the areas where the greatest potential off-site impact of emissions from the

facility, including the proposed Energy Centre, are predicted.

The main substances which are of interest in terms of existing air quality are sulphur

dioxide, nitrogen oxides (nitric oxide, NO and nitrogen dioxide NO2, collectively

referred to as NOx), particulate matter including PM10 and PM2.5 which could

originate from combustion sources, traffic and the existing commercial and industrial

activities in the area. Carbon monoxide is also potentially of interest due to the

expected significant emissions from the St James’s and Diageo Energy Centres and

traffic, and benzene may also be of interest from traffic sources. There are no

significant new or additional substances expected to be present in emissions

released from the proposed development relative to the existing facility but a

significant increase in emissions is predicted.

A description of existing levels of the various substances in ambient air is required to

allow completion of the evaluation of air quality impacts associated with the

development. The available data from the National Ambient Air Quality Network is a

reliable data set for consideration in this study.

The Environmental Protection Agency (EPA) and local authorities maintain and

operate a number of ambient air quality monitoring stations throughout Ireland in

order to implement EU Directives and to assess the country’s compliance with

national air quality standards. Ireland’s small population and generally good air

quality means that a relatively small number of monitoring stations are sufficient

across the country for the purposes of implementing the EU Air Directives. For

ambient air quality management and monitoring in Ireland, four zones, A, B, C and D


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are defined in the Air Quality Standards (AQS) Regulations (S.I. No. 180 of 2011) and

are defined as follows:

Zone A: Dublin Conurbation.

Zone B: Cork Conurbation.

Zone C: 24 cities and large towns. Includes Galway, Limerick, Waterford,

Clonmel, Kilkenny, Sligo, Drogheda, Wexford, Athlone, Ennis, Bray,

Naas, Carlow, Tralee, Dundalk, Navan, Newbridge, Mullingar,

Letterkenny, Celbridge and Balbriggan, Portlaoise, Greystones and

Leixlip.

Zone D: Rural Ireland, i.e. the remainder of the State excluding Zones A, B &C.

The St James’s Street site is considered to be located in Zone A and is Urban. Air

Quality Data from representative air monitoring stations in Zone A that are

designated Urban Stations is therefore considered representative of air quality at the

St James’s Hospital site. The EPA publishes Ambient Air Quality Reports every year

which details the air quality in each of the four zones. The most recent report,

published by the EPA in 2014, is the Air Quality Monitoring Annual Report 2013,

which contains monitoring data collected during 2013. Best practice requires that an

average of at least three years of recent monitoring data is used for assessments of

this type so data for 2011 – 2013 has been reviewed4.

The EPA maintains monitoring stations in a number of areas to monitor urban and

suburban background air quality as well as some traffic-oriented monitoring stations.

The urban background monitoring station is in Rathmines and suburban monitoring

stations are located in Dun Laoghaoire, Blanchardstown, Swords and, after

refurbishment, Ballyfermot; the Blanchardstown Station is a traffic-oriented

monitoring station. The Urban Traffic oriented monitoring stations are at Winetavern

Street and Coleraine Street. Other monitoring stations have operated at various

times and some new stations have been added to the network, but long term data is

available for the above stations.

4 EPA, "EPA Ireland Archive of Nitrogen Oxides Monitoring Data". Datasets Available At: Secure Archive For

Environmental Research Data managed by Environmental Protection Agency Ireland http://erc.epa.ie/safer/resource?id=216a8992-76e5-102b-aa08-55a7497570d3 (Last Accessed: 2015-09-25)

http://erc.epa.ie/safer/resource?id=216a8992-76e5-102b-aa08-55a7497570d3


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Data from the Air Quality Monitoring Annual reports for 2011, 2012 and 2013 was

reviewed and a summary of the data for representative stations for the three most

recent years is presented for each parameter of interest in Tables 1a – 1g of this

report. The most representative data set is chosen for each parameter as noted in

the Tables.

In particular it is noted that wherever available, data from the designated Urban

monitoring stations is chosen as this would best describe the existing ambient air

quality in the urban St James’s Street location. There are urban monitoring stations

located at Rathmines, Winetavern Street and Coleraine Street as shown in Figure 5.

The Rathmines station is oriented towards monitoring background urban

concentrations whereas the Winetavern Street and Coleraine Street stations are

traffic oriented stations.

Figure 5 Air Quality monitoring locations relative to St James’s Hospital

It is necessary to consider the influence of traffic-derived pollutants on air quality for

the city centre and therefore we recommend that the urban Traffic data should be

chosen because air quality in the St James’s Street location is significantly influenced

Winetavern Street Air Quality Monitoring Station

Rathmines Air Quality Monitoring Station

Coleraine Street Air Quality Monitoring Station

St James’s Hospital Campus


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by traffic. Traffic is one of the significant potential impacts identified in the EIS and

most of the impact assessment is directed at the impact of emissions from traffic

associated with the development on air quality.

The approach followed in Chapter 12 of the EIS is to select a single set of baseline air

quality data to represent air quality at St James’s, Tallaght and Blanchardstown. This

is inappropriate in my opinion and leads to an underestimate of the existing level of

pollutants in ambient air at St James’s. The most seriously ill children will spend time

in the proposed children’s hospital at St James’s and sick children will spend longer

in this location than either of the satellite centres. It is therefore very important that

a reliable statement of baseline air quality specifically for the St James’s campus is

formulated. It is an over-simplification to consider the three sites together and the

assumption that the same data set reliably describes baseline air quality at each site

is an understatement of baseline conditions at St James’s.

As noted above in section 4.1, an application in April 2015 by Diageo to the EPA for a

review of the IE Licence for the significant Diageo industrial facility was accompanied

by a significant number of reports including a dispersion modelling assessment of air

quality impacts of the existing and proposed emission points5. That report also

selected the monitoring data from Coleraine Street and Winetavern Street

monitoring stations to describe the existing baseline air quality in the vicinity of this

application site. The report was reviewed and accepted by the EPA which indicates

that the choice of baseline air quality data was appropriate for this site and

assessment. There is therefore an established precedent for the description of

baseline air quality in this area and the monitoring data from Winetavern Street and

Coleraine Street is recommended as a reliable statement of baseline air quality for

the area.

A summary of the baseline air quality data is presented in Tables 1a to 1g below

together with the data selected in the EIS. All of the data chosen in the EIS for the

assessment is annual mean data despite the fact that there are other Air Quality

Standards that require consideration, and this is of concern and is discussed below.

5 Accessible for download at http://www.epa.ie/licences/lic_eDMS/090151b28052e22c.pdf (accessed 26

September 2015)

http://www.epa.ie/licences/lic_eDMS/090151b28052e22c.pdf


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The actual data selected in the EIS for the annual mean concentration of each

parameter of interest as shown in Tables 1a to 1g below is based on an average of a

number of stations for 3 to 5 years, rounded up and then projected forward from

2013 to 2015 as the baseline data year. This is a conservative and prudent approach,

which we agree with in principle. However, we do not agree with the selection of

stations for averaging which are a mixture of urban and suburban stations and we

do not agree with the approach of choosing a single data set to represent air quality

in the very different locations of Tallaght, Blanchardstown and St James’s.

The approach we have taken is to take the average of the three most recent years

(2011 – 2013) for each of the designated Urban stations in Winetavern Street and

Coleraine Street and the average of the values for the two stations are reported in

Tables 1a to 1g. This is the data set which we use in our assessment of the potential

impact of the proposed development on air quality.

We have also taken the average of the data for each of the years 2011 – 2013 for

Rathmines and summarised this data in Tables 1a to 1g. These values agree well

with the values selected in the EIS. In our opinion, the EIS data set underestimates

the baseline air quality in the St James’s street area and consequently use of the data

leads to an understatement of the potential impacts of the proposed development

on air quality.

It is noted that the EIS gives a baseline concentration of nitrogen oxides (NOx) of

34.6µg/m3 without explaining where this data was derived from. Table 1b shows the

EPA monitoring data for nitrogen oxides and the annual mean for the urban

background station agrees well with the value quoted in the EIS.

Tables 1a to 1g also show the average data for the traffic orientated monitoring

stations in Dublin City. In my opinion this data accurately and representatively

describe the baseline air quality at the St James’s Hospital campus. When the

contributions from traffic to the ambient air quality are considered, the baseline

concentrations increase relative to the background urban values. The baseline data

is then 43% higher for NO2, 67% higher for NOx and 12.5% higher for PM10. These are

the significant pollutants for this impact assessment. The significance of this finding

is discussed further below. A graphical presentation comparing the data selected in


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the EIS with that chosen in this assessment report is presented in Figure 6 below. For

the most significant pollutants, Nitrogen dioxide and Nitrogen Oxides (NO2 and NOx)

the EIS data is significantly lower than the data recommended in this assessment

report.

Figure 6 Comparison of baseline air quality data from EIS and TMS

A concise summary of the data presented in Tables 1a to 1g is presented in Table 2

below to allow ready comparison with Table 12.10 in the EIS; a graphical

presentation is given in Figure 6 to show the existing air quality relative to Air Quality

Standards and WHO Guidelines. In summary, there is a very significant difference

between the baseline data used in the EIS and that quoted here which includes the

contributions from traffic. Given the city centre location of the St James’s campus

and the strong traffic influences on air quality, we are concerned that the EIS has

understated the baseline concentrations and may therefore have significantly

understated the potential impact of the proposed development.

It is noted that the existing air quality in respect of both NO2 and PM10 is

approaching the WHO Guideline value and the existing air quality for PM2.5 exceeds

the WHO Guideline. As noted earlier, the WHO Guideline is not a mandatory value.

However the unique sensitivity of the proposed development suggests that

0

10

20

30

40

50

60

NO2 NOx PM10 PM2.5 SO2 Benzene

EIS TMS EU Air Quality Standard WHO Guideline


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particular attention is focused on ensuring that the proposed children’s hospital is

located in an area where the best possible air quality is experienced.


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Table 1a Background air quality data for St James’s Street Hospital Site (Nitrogen Dioxide, NO2)

Station Averaging Interval 2011 2012 2013 Average EIS

Rathmines Urban Background

Annual Mean, µg/m3 Max 1-hour, µg/m3 1-hour > 200 µg/m3 (Days)

20 118 0

21 138 0

19 107 0

20 121 0

Dun Laoghaoire Suburban Background


18 127 0

18 135 0

26 123 0

21 129 0

Blanchardstown Suburban traffic


31 209 1

30 194 0

29 154 0

30 186 0

Winetavern Street Urban including traffic


34 181 0

29 136 0

31 158 0

31 158 0

Coleraine Street Urban including traffic


26 167 0

26 142 0

26 118 0

26 142 0

Selected data set

Urban Background[1] Annual Mean, µg/m3

Max 1-hour, µg/m3

1-hour > 200 µg/m3 (Days)

20 121

22.7

Urban including Traffic[2] Annual Mean, µg/m3

Max 1-hour, µg/m3

1-hour > 200 µg/m3 (Days)

28.5 150

NOTE [1] Rathmines data unless otherwise stated [2] Average of the urban traffic oriented sites


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Table 1b Background air quality data for St James’s Street Hospital Site (Nitric Oxide and Nitrogen Dioxide, NOx)



Annual Mean, µg/m3 Max 1-hour, µg/m3

32 776

31 811

28 668

30 752

Dun Laoghaoire Suburban Background


29 613

30 560

27 424

29 532



71 1227

63 909

62 1006

65 1047



61 1241

51 888

50 1209

54 1113

Coleraine Street Urban including traffic


49 1376

43 857

46 1000

46 1078

Selected data set


Max 1-hour, µg/m3 30 752

34.6


Max 1-hour, µg/m3 50 1096



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Table 1c Background air quality data for St James’s Street Hospital Site (Particulate Matter, PM10)



Annual Mean, µg/m3 24-hour mean > 50 µg/m3 (days)

16 10

14 8

17 8

16 9

Dun Laoghaoire Sub-urban Background


15 11

12 1

17 5

16 9

Phoenix Park Suburban background


12 3

11 0

14 3

12 2



16 11

No data No data

20 11

18 11



14 7

13 0

14 3

14 3

Selected data set Urban Background [1] Annual Mean, µg/m3 16 17.7

Urban including Traffic [2] Annual Mean, µg/m3 14



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Table 1d Background air quality data for St James’s Street Hospital Site (Particulate Matter, PM2.5)



Annual Mean, µg/m3 Max 24-hour µg/m3

12 60

11 57

11 76

11 64

Coleraine Street Urban Background (traffic)


11 87

10 31

11 62

11 60

Marino Suburban background


9 68

8 35

9 55

9 46

Selected data set


Max 24-hour µg/m3 11 64

12.3


Max 24-hour µg/m3 11 60



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Table 1e Background air quality data for St James’s Street Hospital Site (Sulphur Dioxide, SO2)



Annual Mean, µg/m3 3 2 2 2

Winetavern Street Urban background (traffic)


Coleraine Street Urban background (traffic)


Tallaght Suburban background


Selected data set Urban Background[1] Annual Mean, µg/m3 2 None

Urban including Traffic[2] Annual Mean, µg/m3 1



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Table 1f Background air quality data for St James’s Street Hospital Site (Carbon Monoxide, CO)


Winetavern Street Urban Background (traffic)

Annual Mean 8-hour, µg/m3 Max 8-hour, µg/m3

100 900

100 1400

0 2400

67 1567

Coleraine Street Urban Background (traffic)

Annual Mean 8-hour, µg/m3 Max 8-hour, µg/m3

400 2700

400 3500

400 2700

400 2967

Selected data set


Max 8-hour, µg/m3 234 2267

390 None


Max 8-hour, µg/m3Annual Mean, µg/m3 234 2267

NOTE [1] No data for Rathmines [2] Average of the urban traffic oriented sites


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Table 1g Background air quality data for St James’s Street Hospital Site (Benzene)



Annual Mean, µg/m3 1.6 1.2 0.94 1.3

Selected data set Urban Background[1] Annual Mean, µg/m3 1.3 1.5

Urban including Traffic[2] Annual Mean, µg/m3 1.3

NOTE [1] Rathmines data unless otherwise stated [2] No data for urban traffic oriented sites


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Table 2 Summary baseline air quality data for St James’s Hospital Campus (2013)

Data set Parameter and averaging interval Concentration µg/m3

TMS EIS

Urban background Nitrogen dioxide NO2 Annual Mean, µg/m3 Max 1-hour, µg/m3

20 121

22.7 Not stated

Urban including traffic Annual Mean, µg/m3 Max 1-hour, µg/m3

28.5 150

Not stated Not stated

Urban background Nitrogen oxides, NOx Annual Mean, µg/m3 Max 1-hour, µg/m3

30 752

38 Not stated


50 1096


Urban background Particulate Matter PM10 Annual Mean, µg/m3 Max 24-hour, µg/m3

16 74

17.7 Not stated


14 68


Urban background Particulate Matter PM2.5 Annual Mean, µg/m3 Max 24-hour, µg/m3

11 64

12.3 Not stated


11 60


Urban background Sulphur dioxide, SO2 Annual Mean, µg/m3 2 Not stated

Urban including traffic Annual Mean, µg/m3 1 Not stated

Urban background Carbon Monoxide CO Annual Mean 8-hour, µg/m3 Not stated 390

Urban including traffic Annual Mean 8-hour, µg/m3 234 Not stated

Urban background Benzene Annual Mean, µg/m3 1.3 1.5

Urban including traffic Annual Mean, µg/m3 Not stated Not stated


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5.0 Air Quality impact assessment

5.1 Potential air quality impacts

The potential air quality impacts associated with the development are evaluated by

considering the existing and proposed activities at the site, and air quality impacts

associated with each activity. These are considered in turn below.

Existing activities

The existing activities at and in the vicinity of the site have the potential to exert an

influence on ambient air quality by release of emissions as follows:

emissions of particulate matter (PM10 and PM2.5), SO2, NOx, CO from domestic,

commercial and industrial heating;

emissions of particulate matter (PM10 and PM2.5), SO2, NOx, CO and benzene

from traffic

emissions of particulate matter (PM10 and PM2.5), SO2, NOx, CO from the

Energy Centre at St James’s Hospital and the adjacent Diageo facility;

Overall, the contribution of traffic to air quality in the area is considered to be a

dominating influence on air quality in the immediate vicinity of the St James’s

hospital campus. The impact of emissions to atmosphere from the St James’s and

Diageo Energy Centres will be experienced further away from the site because the

emissions are released at significant heights through very tall stacks. There is some

potential for impact at closer receptors depending on the height of the receptor

above ground, and this is discussed further below.

The EIS provides some information about the existing emissions from the St James’s

Energy Centre. Chapter 2 (Description of the Development) describes at Section

2.4.1 the existing arrangement which is an array of 8 flues of which 4 are redundant

and 4 are operational. Chapter 14 Landscape and Visual Impact Assessment at

Section 14.1.3.3 provides the following information:

“At almost 53m over datum (OD) in height, the existing flue stack, which is

located alongside the west side of the Energy Centre is the tallest feature on

the campus (Plate 14.19) and also one of the most visually prominent –


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especially from nearby residential areas at Cameron Square (Plate 14.7) and

Ceannt Fort as well as from east along Emmet the north and northwest of the

hospital.”

A view of the existing Energy Centre discharge arrangement is shown in Figure 7

which clearly shows the very substantial flue structure that releases emissions at a

height of 53m above ground level. While the existing emissions are significant, the

increase in emissions for the proposed development is extremely significant.

Figure 7 Existing Energy Centre flue structure

Construction Phase Impacts

The proposed development involves the construction of a new national children’s

hospital with associated facilities. A significant amount of demolition work is

required to clear the site and demolish old buildings as well as very significant

excavations in a brownfield site which will uncover contaminated materials with

substantial quantities of material being transported off site for disposal. The main

emissions to atmosphere are summarised as follows:

emissions of particulate matter (PM10 and PM2.5), SO2, NOx, CO and benzene

from construction traffic including plant and machinery on the site;

emissions of particulate matter and dust from demolition and excavation

activities;

Extract from EIS Chapter 14 (Plate 14.19 View North towards Energy Centre and Plate 14.9 View west along Mount Brown with St James’s Hospital Energy centre to left (south)


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emissions of Aspergillus from earth-moving and excavation activities;

emissions of asbestos, dust and moulds from demolition activities;

emissions of toxic substances associated with the excavation of contaminated

soil, storage and transport off site;

emissions of odour and hydrogen sulphide associated with realignment of the

Drimnagh sewer;

There is the potential for a number of greenhouse gas emissions to atmosphere

during the construction of the development. Construction vehicles, generators etc.,

may give rise to CO2 and N2O emissions. However the level of emissions will be

insignificant compared to national greenhouse gas emissions.

Operation Phase impacts

The most significant potential impacts remain the same as those that currently exist

- emissions of particulate matter (PM10 and PM2.5) and combustion gases such as CO,

SO2 and NOx and NO2. These are the same substances that exert an influence on the

existing ambient air quality. They will be released from the Energy Centre with some

contributions from traffic associated with the activity.

Sulphur dioxide emissions originate from the sulphur in the fuel used in the

combustion process. The EIS (Chapter 17 and Chapter 7) notes that natural gas is the

preferred fuel but that the existing Energy Centre boilers are dual-fuel fired and that

for resilience, the new children’s hospital boilers will also be dual-fueled and that

storage for 400,000litres of diesel fuel is being provided. If the fuel is natural gas,

then Sulphur emissions will be negligible. For other fuels, for which the Sulphur

content is limited by legislation, the sulphur emissions will be relatively low.

However, if the diesel fuel is used all of the time should natural gas be unavailable,

the SO2 emissions will be much more significant given the significant energy

requirements of the campus.

Nitrogen oxides are present in the emission stream as a result of the combustion

process. Much of the emissions are in the form of nitric oxide (NO) which is

expected to be substantially oxidised to nitrogen dioxide (NO2) in the atmosphere.


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NO2 is the more significant pollutant for the protection of human health whereas the

combined NO plus NO2, referred to as NOx, is more significant for protection of

ecosystems.

Particulate matter and carbon monoxide may also arise from the combustion

process in the emission stream. Particulate matter (as PM10 and PM2.5) is likely to be

negligible if natural gas is used as the principal fuel whereas these will be more

significant for other fuel types.

There is the potential for a number of greenhouse gas emissions to atmosphere from

the Energy Centre principally as CO2 emissions. However the level of emissions will

be relatively low compared to national greenhouse gas emissions.

The proposed Energy Centre is the most significant source of emissions to

atmosphere associated with the proposed development. Chapter 2 of the EIS

(Description of the Development) contains the following information at Section 2.4.1

Page 2-22.

“Proposed New Flues

The existing St. James’s Hospital campus energy centre flues are the tallest

feature on the current campus. These rise from the southern face of the

energy centre building in a cluster of 8 no. pipes, 4 no. abreast either side of a

central steel structure, of which 4 no. are now redundant. The new children’s

hospital includes its own energy centre located on Level B02. This requires 12

no. new flues, which need to be in close proximity to the boilers and standby

generators within the proposed energy centre. The proposed solution is a

combined children’s and St. James’s Hospital flue stack with 16 no. pipes (12

no. for the new children’s hospital and 4 no. for St. James’s Hospital campus)

in a square plan form. The pipes are angled at the top, reflecting the different

height requirements of the different flues. The heights have been determined

by the mechanical and electrical engineers in accordance with best-practice

guidelines and statutory regulations. The highest point of the proposed flues

has a height of Ordnance Datum 58.7m.”


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In summary, the existing Energy Centre has 4 redundant and 4 operating flues from

which emissions are released at 53m above ground level. The new arrangement will

involve 16 flues (4 existing and 12 new) for the discharge of emissions to cater for

the existing and proposed energy requirements of the campus. This is a very

significant increase in capacity and a very significant increase in emissions. There is

some doubt about the actual height of the emissions flues. From the above extract

from the EIS, the proposed flues will discharge at 58.70m OD. However other

sections of the EIS suggest that the maximum discharge height is at 59.700mOD. For

example, Figure 8 (extracted from EIS Drawing NPH-A-BDP-PL-ZZ-ST-2101-

ELEVATIONS-CONTEXT) shows a maximum discharge height of 59.700m OD for the

proposed flues.

Figure 8 Proposed new Energy Centre emissions discharge arrangement

Section 14.1.4.1 of the EIS (Landscape and Visual Impact Assessment) indicates as

follows that the height of the flues will be c. 59mOD at the highest point and that

this is c. 6m above the height of the existing flues.

As new flues are required as part of the proposed development, a new

combined flue stack structure is proposed south of the existing location. The

top of the flues are angled at different levels and the highest is c.6m higher

than the top of the existing flues giving a total height of c.59m OD.

Extracted from EIS Drawing NPH-A-BDP-PL-ZZ-ST-2101-ELEVATIONS-CONTEXT

Flues at varying heights with highest shown at 59.700 OD


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The difference in height as well as the complexity of the proposed flue structure

relative to the existing arrangement is clear from Figure 9 which is an extract from

Chapter 14 of the EIS.

Figure 9 Existing and proposed Energy Centre flues

Figures 8 and 9 also show an array of flues five deep and other views from other

directions suggest that the arrangement will be 5 x 5 which is 25 flues. Elsewhere in

the EIS there is reference to a square flue structure which might suggest a 5x5

arrangement meaning 25 flues. It is not clear whether it is 16 flues or 20 flues or 25

flues for the combined emissions from the existing and proposed Energy Centre. For

any of the above scenarios, it is a very significant increase in emissions relative to the

existing activity and the potential impact of the emissions from the Energy Centre is

the most significant potential impact associated with the Operational Phase of the

proposed development.

Chapter 17 (Material Assets – Site Services) gives a summary of the energy

requirements of the site as follows.

Section 17.1.4.5 Gas

The existing gas network will need to be extended and modified in order to

facilitate the development of the new children’s hospital. It is anticipated that

the new children’s hospital will require approximately 9MW peak heating

output and that this will increase to 11MW peak to cater for future 20%

Extract from Appendix 14.1 Landscape and Visual Impact (Figures 24.1 and 24.3)


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expansion and then to 15MW to cater for the future Maternity Hospital. The

existing St. James’s Hospital peak gas load is approximately 9.2MW.

Therefore the estimated peak heat output demand for the new children’s

hospital plus future expansion plus future Maternity Hospital plus existing St.

James’s Hospital campus is 24.2MW. Taking combustion efficiencies into

account, this equates to peak gas input of 33MW.

This Chapter of the EIS also notes that the existing boilers are dual fuel (section

17.1.6.2) and can be switched over to run on oil to provide an alternative source of

heating should natural gas be unavailable for any reason during the construction

works. It is also noted that to provide resilience, the new children’s hospital boilers

will be provided with dual fuel oil/gas burners and a diesel oil store will provide an

alternative source of heating should natural gas be unavailable for any reason.

Separately (Chapter 7) it is noted that “A new 400,000l oil store is to be constructed

to serve the St. James’s Hospital Campus via the Energy Centre. A smaller 3,000l oil

storage facility will be constructed to serve the Children’s Research and Innovation

Centre site.”

The Energy requirements of the site will more than double for the proposed

children’s hospital which will lead to at least double the emissions from the

combined Energy Centre. In addition, for tri-location of the future Maternity

Hospital, the Energy requirement will almost treble and the emissions will increase

by at least 300%. As noted below, I am concerned that there is insufficient

assimilative capacity to ensure that such an enormous increase in emissions does not

lead to a breach in air quality standards. This is such a significant issue that it could

limit the potential for future expansion of the facility and render impossible the tri-

location of the maternity hospital which Government Policy requires. It is therefore

the aspect of the development proposal on which this report will focus most

attention.


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Traffic impacts

There will be no change in the type of emissions that will be released as a result of

traffic. The emissions include particulate matter (PM10 and PM2.5), SO2, NOx, CO and

benzene. There is a difference between the traffic impact projections presented in

the EIS and those predicted by Traffic Insights who are also evaluating this

development on behalf of the Jack and Jill Foundation. On the basis of the

assessment prepared by Traffic Insights, the emissions from traffic associated with

the proposed development will increase. This is discussed further below.

5.2 Air Quality Standards and impact assessment criteria

Air Quality Standards in Ireland have been defined to ensure compliance with EC

Directives; they are developed at different levels for different purposes. European

legislation on air quality has been framed in terms of two categories, limit values and

guide values. Limit values are concentrations that cannot be exceeded and are

based on WHO guidelines for the protection of human health. Guide values are set

as a long-term precautionary measure for the protection of human health and the

environment. The WHO guidelines differ from EU air quality standards in that they

are primarily set to protect public health from the effects of air pollution, whereas

Air quality standards are recommended by governments, and other factors such as

socio-economic factors, may be considered in setting the standards.

The Clean Air for Europe (CAFE) Directive (Council Directive 2008/50/EC) was

transposed into Irish legislation by the Air Quality Standards Regulations 2011 (S.I.

No. 180 of 2011). This Directive and the Irish Regulations set out the main standards

against which the potential impact of the development on air quality are assessed.

The assessment is based on ensuring compliance with the air quality standards.

In addition to the Air Quality Standards Regulations and the Directive Standards, it is

also appropriate to consider the World Health Organisation (WHO) Guidelines. These

guidelines were developed by the WHO to provide appropriate air quality targets

worldwide, based on the latest health information available. The air quality

guidelines for particulate matter (PM10), nitrogen dioxide and sulphur dioxide, and


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PM2.5 are considered in this report (WHO, 2005; updated in 2008). While the WHO

Guidelines are not mandatory, they represent current informed opinion on the levels

to which we should be aspiring in order to minimise adverse health impacts of air

pollution. Since the proposed development of a National Children’s hospital will

cater for sick children with compromised immune systems and limited ability to cope

with additional stresses such as air pollution, it is prudent to consider the WHO

Guidelines as well as the mandatory Air Quality Standards for the purpose of this

assessment. The air quality standards and guidelines referenced in this report are

summarised in Table 3 and Table 4.

Section 12.1.2.1 of the EIS sets out the Air Quality Standards which are relied on in

the impact assessment and states that the air quality impact assessment is based on

ensuring compliance with the appropriate standards or limit values. Appendix 12.1

of the EIS includes a statement about the WHO Guidelines but the Guideline values

are not quoted and the assessment does not consider these Guideline values. The

development proposal relates to the provision of future medical care for Ireland’s

sickest children, all of whom are in a vulnerable and sensitive state given their

medical status. For such a sensitive proposal, I believe that the assessment should

also consider the WHO Guidelines, only some of which are lower than the relevant

Air Quality Standards or Limit Values. The most significant difference is in the

Guideline values for particulate matter as PM10 and PM2.5 which are 50% of the EU

Air Quality Standards.

In carrying out the air quality impact assessment, the predicted impact of the

proposed development is evaluated by comparing the predicted levels of various

pollutants with the Air Quality Standards and ensuring compliance with the

Standards. This is the approach adopted in the EIS and it is also the approach

adopted in this report.


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Table 3 Air Quality Standards Regulations 2011 (based on EU Clean Air For Europe [CAFE] Directive 2008/50/EC)

NOTE

1. The Air Quality Standards Regulations 2011 (SI 180 of 2011) transposed EU Directive 2008/50/EC (CAFE) into Irish law.

Pollutant EU Regulation Limit Type Margin of Tolerance Value

Nitrogen Dioxide

2008/50/EC Hourly limit for protection of human health - not to be exceeded more than 18 times/year

None 200 μg/m3 NO2

Annual limit for protection of human health

None 40 μg/m3 NO2

Annual limit for protection of vegetation

None

30 μg/m3

NO +NO2

Sulphur

dioxide

2008/50/EC Hourly limit for protection of human health - not to be exceeded more than 24 times/year

150 µg/m3 350 μg/m3

Daily limit for protection of human health - not to be exceeded more than 3 times/year

None 125 μg/m3

Annual & Winter limit for the protection of human health and ecosystems

None 20 μg/m3

Particulate Matter

(as PM10)

2008/50/EC 24-hour limit for protection of human health - not to be exceeded more than 35 times/year

50% 50 μg/m3


20% 40 μg/m3

Particulate Matter

(as PM 2.5)

2008/50/EC


(Stage 1)

20% from June 2008. Decreasing linearly to 0% by 2015

25 μg/m3

Annual limit for protection of human health (Stage 2)

None

To be achieved by 2020

20 μg/m3

Carbon Monoxide

2008/50/EC 8-hour limit (on a rolling basis) for protection of human health

60% 10 mg/m3

(8.6 ppm)

Benzene 2008/50/EC Annual limit for protection of human health

0% by 2010 5 μg/m3


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Table4 WHO Air Quality Guidelines

Pollutant Limit Type Value

Nitrogen Dioxide Hourly limit for protection of human health 200 μg/m3 NO2

Annual limit for protection of human health 40 μg/m3 NO2

Sulphur dioxide Daily limit for protection of human health 20 μg/m3

10-minute limit for protection of human health 500 μg/m3

Particulate Matter

(as PM10)

24-hour limit for protection of human health 50 μg/m3

Annual limit for protection of human health 20 μg/m3

Particulate Matter

(as PM 2.5)

24-hour mean for protection of human health

25 μg/m3

Annual mean for protection of human health 10 μg/m3


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5.3 Prediction and evaluation of Construction Phase impacts on air quality

5.3.1 Potential Construction Phase air quality impacts

Section 12.1.4 of the EIS identifies the potential air quality impacts associated with

the construction phase of the proposed development for assessment in the EIS.

These potential air quality impacts studied in the EIS are summarised as follows:

a) Construction Phase – dust nuisance from construction activity;

b) Construction Phase - Aspergillus emissions from excavation and earthmoving

activity;

c) Construction Phase – construction transport emissions;

I agree with these choices but would also add the following which have not been

considered in the EIS:

d) Construction Phase – emissions associated with relocation of the Drimnagh

sewer;

e) Construction Phase – emissions associated with significant excavations in a

suspected workhouse cemetery and brownfield contaminated site;

f) Construction Phase – emissions of asbestos and/or moulds associated with

building demolition works.

The assessment of these potential impacts is addressed in the following sections of

this report.

5.3.2 Dust from general construction activities

The construction of the proposed national children’s hospital will take place on a

large city centre site (ca 5 hectares) adjacent to a functioning hospital and in close

proximity to residences. One of the most significant of the potential air quality

impacts associated with such a large-scale construction site is dust.

There are three potential impacts on air quality of the dust / particulate matter

emissions. Dust deposition on surfaces is the main potential impact associated with

the larger particles, nuisance effects such as reduced visibility could be associated


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with excessively high levels of suspended particulate matter and respiratory effects

could occur as a result of excessive levels of fine particles such as PM10 and PM2.5.

Dust emissions associated with the Construction Phase of the proposed

development are expected to be predominantly in the 10 – 75μm particle size range

so these particles, because of their size, will generally be deposited within 100m of

the emission source. Only under exceptional meteorological conditions would the

dusts be carried further downwind.

Suspended particulate matter (SPM) may also be released and this matter may

remain suspended in the air. The main effect would be on visibility but this type of

material could also be a respiratory nuisance if present at excessive levels.

Emissions of dust in the form of PM10 and PM2.5 may also occur, primarily as a result

of materials handling and storage since the dominant particle size of the main

construction materials is in the lower size ranges. There may also be some emissions

of particles in these size ranges from the general site activities.

An approach towards the quantitative estimation of emissions from the Construction

Phase is to use Emission Factors. An emissions factor is a representative value that

relates the quantity of a pollutant released to the atmosphere with the activity that

leads to the release of that pollutant. These factors are usually expressed as the

weight of pollutant divided by a unit weight, volume, distance, or duration of the

activity emitting the pollutant (e.g., kilograms of particulate emitted per hectare of

excavation). AP-42, Compilation of Air Pollutant Emission Factors, is a US EPA

publication that contains emission factors for many different categories of activity

including Construction activities6. This Reference Publication cites an emission factor

for large-scale construction activity of 2.69 Megagrams / hectare / month. For the St

James’s Hospital construction site this would equate to an uncontrolled emission

rate of more than 13tonnes of dust per month. When the more refined approach

recommended in AP-42 is considered (Section 13), this estimate reduces to more

than 10 tonnes of potential construction dust emissions per month across the site at

peak. This is a very significant potential emission rate and clearly a comprehensive

Dust Management and Control Plan is required. When the sensitivity of the existing

6 Available for download at http://www3.epa.gov/ttnchie1/ap42/; accessed 25 September 2015

http://www3.epa.gov/ttnchie1/ap42/


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hospital in the receiving environment is considered, the importance of the Control

Plan is further emphasised.

5.3.3 Aspergillus emissions

There is concern about a fungal disease, "invasive Aspergillosis” which may be

contracted as result of disturbance of materials that release fungal spores into the

atmosphere. This is a disease which is detrimental to persons with suppressed

immune systems, such as hospital patients, and is therefore of concern in relation to

the proposed children’s hospital at the St James’s hospital site. A report entitled

"National Guidelines for the prevention of Nosocomial Invasive Aspergillosis during

construction/renovation activities" deals specifically with construction works

occurring within or adjacent to hospitals. The report states that the fungal spores

responsible for invasive Aspergillosis can originate from a number of sources such as

construction, demolition, renovation, disturbance of soil, removal of fibrous

insulation material, removal of suspended ceiling tiles and from poorly maintained

air ventilation systems. The potential sources of the fungal spores associated with

invasive Aspergillosis, as detailed above, are related to the occurrence of these

operations either within or in very close proximity to the hospital buildings.

Fungal spores (the Aspergillus moulds) are found everywhere but are of particular

concern when large scale demolition, excavation and earth-moving activity takes

place and especially in close proximity to areas where vulnerable individuals are

located. The dispersion of spores (or indeed dust or any other substance) which are

released at a particular location depends on a significant number of factors which

include the rate and temperature of the release, the release height, the wind speed,

rainfall, wind direction, topography, local meteorological conditions, the nature of

the substances released, the potential for physical or chemical interactions and the

concentrations of the substances released and other factors. The dispersion of

fungal spores will depend on all of the above factors and this dispersion is evaluated

by considering the factors noted above and the distances from the source at which

the predicted impacts are to be assessed. In the first instance, the key factors are the

concentration of the spores released and the distance to sensitive receptors.


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The concentration at which fungal spores may be released from a specific source is

the first factor to be considered in assessing dispersion pathways. There is Literature

data indicating that levels of spores released as a result of construction projects

could be up to 200 / m3.

In order to reliably predict the possible impact of fungal spores released as a result

of a construction work, I have completed a dispersion modelling study to

demonstrate that dispersion of fungal spores released as a result of any activity is a

function of time and distance. I used conventional methods to complete the study

and the results are described briefly here. An initial release of 200 /m3 at a height of

ca 2m above ground over a large area of 1000m2 was chosen for modelling. This is a

hypothetically large release area but it is representative of the large construction site

on the hospital campus. The modelling study showed that the concentration of

spores as a result of such a release would be predicted to reduce to below 10 /m3

within about 70m of the release source, and be completely dispersed ie no

measurable concentration at c. 150m from the source of the release.

This exercise demonstrates the potential significance of the large scale construction

works at the St James’s campus where the functioning hospital is located very close

to the construction site, and the construction programme will extend for c. 4 years.

The National Guidelines report referred to above notes that the fundamental

requirement in respect of eliminating Aspergillus infection from construction works

is first to minimise the dust generated during construction and second to prevent

dust infiltration into patient care areas. The preventive measures could include

enclosure of the construction site where necessary and ventilation with Hepa filters

to ensure that dust ingress is prevented.

Chapter 12 of the EIS at section 12.1.6.1 states that the windows to the facades of

some wards in the hospital will be sealed prior to commencement of construction to

prevent the spread of aspergillus spores. This does not constitute a Management

Plan that conforms to the National Guidance. An effective management plan must

consider the rate of generation and release of the spores, sealing of windows of all

patient care areas as well as hepa-filtration in vulnerable areas which are classified in

the National Guidelines report above. In addition, the potential impact on non-


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hospital vulnerable receptors must also be considered which may not have been

done as it has not been reported in the EIS.

5.3.4 Construction vehicle emissions

Emissions of dust raised by vehicle movement on the roads near the site and also on

site are considered under the general construction phase emissions in section 5.3.2

above. Emissions from the construction vehicles as a result of fuel combustion are

considered here. The emissions include PM10 and PM2.5, NO2 and NOx and CO and

benzene. The EIS predicts extremely low levels of emissions from this activity which I

find surprising. The actual vehicle movement numbers are not specifically given in

Chapter 12 of the EIS and I was unable to find a specific reference to the precise

vehicle movement numbers that were used for the predictions. It appears that the

HGV and LGV movements associated with Construction may not have been included

in the assessment, and this leads to a significant understatement.

One simple calculation will illustrate why I am concerned that the emissions from

construction traffic may be understated in the EIS. There will be approximately 920

Goods Vehicle Movements per day during Phase I Construction Works, primarily

associated with removal of demolition materials and excavated materials from the

site. During Phase II (excavations) this will rise to 1380 Goods Vehicle movements

per day and 1140 Goods Vehicle movements per day for the main Construction

Phase III (Chapter 6 EIS). This is a huge increase in Goods Vehicle movements relative

to the existing situation so it is predicted that the change in emissions of pollutants

attributable to traffic will be significant. I cannot reconcile this data with the

predictions of ‘negligible increase’ in emissions presented in Chapter 12 of the EIS for

PM10 and PM2.5. One of the most significant transport-related pollutants is NO2 and

there are no impact predictions for this substance presented in the EIS. My

calculations indicate pollutant levels orders of magnitude higher than those

presented in the EIS. I am concerned therefore that the potential Construction Phase

impact of transport-related emissions is understated in the EIS.

Section 6.1.7.1 of the EIS states in respect of Construction Phase impacts that “There

will be little impact on prevailing traffic conditions on the surrounding street


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network, however there will be a temporary increase in the number of Heavy Goods

Vehicles on the surrounding street network during the construction phase of the

project.” The temporary increase in HGVs will last for four years and will amount to

an average of 115 HGV movements per hour during the normal work day – that is a

HGV passing every 30 seconds or so. The amount of Construction Phase traffic is

extremely significant and it is impossible to reconcile the statement in the EIS that

there be little impact on traffic conditions with the magnitude of the vehicle

movements required for this development to proceed.

5.3.5 Drimnagh Sewer relocation

The relocation of the Drimnagh sewer is a significant element of work which will

inevitably lead to emissions of dust, odour and perhaps other pollutants. The EIS fails

to consider this in any meaningful way. The impact of this activity can be managed

but the key to effective management is to ensure that the nature and magnitude of

the potential impact is reliably characterised.

5.3.6 Emissions associated with demolition works

Demolition of buildings which may contain or previously contained asbestos has not

been considered in the EIS, and asbestos has also been identified in some of the

waste materials to be excavated at the site. This is a highly significant potential

impact given the age of the buildings on the site. The demolition of asbestos

containing buildings is a specialised task and specialised management techniques

and experienced contractors are required. While such activity can be effectively

managed to control potential impacts, it can only be competently and effectively

managed if the potential impact is identified and evaluated, and meaningful

management plans are put in place.

The potential emissions of moulds from buildings which are to be demolished has

not been considered in the EIS. Again such activity can be managed so that impacts

are controlled but effective management cannot take place if the assessment is

incomplete. Considering the uniquely sensitive location of the site on a functioning


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hospital campus, careful consideration of these and all potential air quality impacts is

required.

5.3.7 Emissions of hazardous substances from excavation in contaminated

ground

The St James’s campus is a brownfield site and it is expected that in such a location

contaminated soils and groundwater will be encountered. The EIS (Chapter 7 Soils

and Geology) confirmed that contaminated areas and ‘Hotspots’ were found during

the extensive investigations that were carried out. The pollutants included heavy

metals, heavy-fraction hydrocarbons, polycyclic aromatic hydrocarbons, inorganic

substances, asbestos and elevated pH levels in one area which were unexplained

pending further investigation. Chapter 7 notes in Table 7.5 that 413,000m3

(approximately equivalent to 826,000 tonnes based on density of 2 tonnes per cubic

metre) of overburden will be removed to facilitate construction of the sub-surface

structures such as basements. Materials such as concrete and infill material will be

imported to support the construction programme.

The excavated materials have been characterised in Appendix 7.1 and in Chapter 10

(Waste Management) with estimates of ca 81,000 tonnes of non-hazardous waste

and about 1,000 tonnes of hazardous waste to be disposed of off-site as waste. One

area of the site has been identified in Chapter 7 as an area where a former burial

ground was located. In times past, lime was spread over burial grounds to facilitate

disease control so it is possible that this is the reason for the elevated pH readings. It

is also possible that the soils and wastes recovered from this area will be re-classified

as hazardous waste when the additional investigations are completed. A further

possibility following investigation is that a risk assessment could identify concerns

about the potential for these materials to lead to transmission of disease. The

investigations have not been completed and reported in the EIS so a full assessment

is not possible with the currently available information.

Excavation, storage and transport of these very significant volumes of waste and fill

materials will generate considerable amounts of dust and has the potential to

release contaminants such as heavy metals and organic substances into the air. Dust


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that is generated is likely to be contaminated to some extent with the pollutants

identified in the materials. As noted above, the investigations have not been fully

completed and it is possible that further contaminants will be identified for which

management plans must be formulated.

In our experience, the management of works at contaminated sites is a highly

specialised and complex undertaking, the success of which is dependent on the

accurate and reliable definition of the issues to be addressed. Since the

investigations are not complete, there is an incomplete statement of potential

impacts to be addressed and therefore the Management Plans cannot be

formulated. On construction sites in contaminated ground, depending on the level of

contaminants generated as a result of the works, there is a requirement to monitor

the impact of the emissions of hazardous substances on air quality to which the

construction workers and surrounding receptors are exposed. This proposed

construction site will be located on the site of a functioning hospital, in very close

proximity to surrounding residences. For hospital patients in particular, the potential

air quality impact associated with excavation of hazardous wastes and materials is

one of the most significant potential impacts of the Construction Phase of the

proposed development.

Chapter 12 of the EIS dealing with air quality impacts does not comprehensively

evaluate the potential air quality impacts associated with the excavation, storage

and transport of contaminated wastes. As noted elsewhere in this report,

Management Plans cannot be effectively formulated with insufficient information

and we respectfully submit that this important element of the site investigations is

incomplete and that there is incomplete information available to finalise an

assessment of potential impacts.


The impact assessment methodology described in Section 12.1.2.3 of the EIS for the

prediction of air quality impacts focuses on the impact of emissions from transport

during the construction and operation phases of the proposed development. The

methodology is based on the National Roads Authority “Guidelines for the Treatment


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of Air Quality During the Planning and Construction of Major Road Schemes”. While

this is an excellent methodology for assessing the air quality impact of major road

schemes, there are very significant differences between the construction of a road

scheme and a fixed construction site such as the site of the proposed Children’s

hospital at St James’s Street. In my opinion, this means that the methodology does

not allow a reliable assessment of all of the potential construction phase impacts.

One of the most significant differences between the construction of a road scheme

and the proposed Children’s hospital is that for a road scheme, the construction site

moves regularly and therefore the areas where air quality impacts are observed also

vary with time. For the proposed Children’s hospital, the construction site stays the

same, in a relatively confined space (relative to a road scheme) and therefore the air

quality impacts are more localised than they would be for a road scheme. For the

proposed 4-year construction programme, air quality impacts will be experienced

over a relatively small localised area and these impacts will be more intense and

concentrated than for shorter duration programmes on sites where the construction

activity is moving regularly. I am therefore concerned that the methodology adopted

has underestimated the potential impacts of the construction phase of the proposed

development due to the significant differences between a road scheme and a fixed

construction site in a confined area.

Section 12.1.7.1 of the EIS describes the predicted impact of construction transport

vehicle movement in terms of nuisance dust and the emissions from the vehicles of

PM10 and PM2.5. Construction transport vehicle movement will be significant during

such a large-scale construction programme but assessing only this impact of the

many construction phase impacts results in an inadequate statement and

assessment of potential impacts. As noted above, calculations executed for this

assessment suggests that the most significant construction traffic impacts have not

been evaluated and reported in the EIS.

The actual on-site construction activity will also give rise to emissions of dust and

fine particulate matter PM10 and PM2.5 which has not been assessed in the EIS. In my

opinion, the dust from the fixed site activities will be very significantly greater than


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that from the transport vehicles and the EIS therefore doesn’t consider the most

significant dust impacts associated with the construction phase.

All vehicle movements will also lead to emissions of NO, NO2 and CO and again the

EIS does not consider these pollutants. When the cumulative impact of the existing

baseline air quality and emissions of all these substances from all sources is

considered, the predicted impact is likely to be far greater than that stated in the EIS.

For the Construction Phase, the impact of emissions such as Nitrogen oxides and CO

have not even been considered in the assessment.

The impact predictions given in Tables 12.13 and 12.14 of the EIS are extremely low

and are described as ‘Imperceptible’ in terms of predicted impact. This is a significant

understatement of potential impact because all potential emission sources have not

been considered in the assessment – all that was considered is some of the relatively

minor Construction Transport Vehicle contributions to Construction Phase emissions.

Some of the significant Construction Phase impacts which were not considered

include on-site construction activity, earthmoving and excavation, site construction

vehicles, wind-blow across exposed surfaces, materials unloading, stockpiled

materials, and removal of excavated materials. This proposed development is

substantial and the predicted impacts are significant – the EIS does not reach this

conclusion because the most significant Construction Phase emission sources appear

not to have been evaluated.

The section of the EIS dealing with potential Construction Phase impacts on the

patients of St James’s hospital (Page 9-17) does not consider all of the potential

sources of emissions associated with the Construction Phase and the potential

impact of the programme is therefore understated. I am also concerned that the

assessment methodology for those impacts that were considered is not appropriate

for the assessment and does not reliably predict the magnitude of air quality impacts

associated with the construction phase.


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5.4 Prediction and evaluation of Operation Phase impacts on air quality

5.4.1 Potential Operation Phase air quality impacts

Section 12.1.4 of the EIS identifies the potential air quality impacts associated with

the operation phases for assessment in the EIS. These are summarised as follows:

a) Operation Phase – Building Services emissions

b) Operation Phase – emissions of traffic-related pollutants from increased

traffic on public roads

I agree with these choices. Emissions from the Energy Centre are by far the most

significant of the emissions associated with the Operation Phase, so greater

attention is focused on these emissions in this impact assessment report.

5.4.2 Traffic emissions

The impact of traffic related emissions on air quality during the Operation Phase is

assessed and the findings are presented in section 12.1.7.2 of the EIS. The report

does not give the traffic figures used in the assessment so a direct comparison of the

emission projections is not possible. It is assumed that the traffic data provided in

Chapter 6 of the EIS was used but Chapter 12 states at section 12.1.7.2 that ‘The

traffic data used in this assessment was provided by Arup Consulting Engineers’. The

EIS assessment is based on the traffic projections from the authors of the traffic

impact assessment section of the EIS and Traffic Insights, who are reviewing this

proposal on behalf of the Jack and Jill Foundation have determined that the EIS

understates traffic impacts and traffic projections. It is therefore likely that traffic

impacts on air quality have been understated in the EIS.

There is a far greater concern about the reliability of the air quality impact

assessment which centres on the fact that no cumulative impact assessment was

carried out. A report on the assessment of emissions to atmosphere from the Energy

Centre was presented separate from the main impact assessment report in Chapter

12 of the EIS and no attempt was made to consider the cumulative impact of

emission from the traffic and energy sources on and associated with the site. This


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means that there is likely to be a significantly understated impact assessment as

noted in the following section of this report.

5.4.3 Energy Centre emissions

5.4.3.1 Assessment methodology

The approach adopted in this report to the assessment of the impact of the

emissions is to carry out a dispersion modelling assessment. This type of assessment

involves use of a computer Model to predict the impact of the emissions on air

quality by predicting the concentrations of pollutants that will arise as a result of the

emissions. For reasons already identified in this report, I am concerned that the

assessment reported in the EIS has significantly underestimated the impact of the

emissions. As a consequence, I have prepared a separate assessment to ensure that

a robust and reliable statement of air quality impacts is available to support the

decision making process.

Guidance Document AG4 (the Environmental Protection Agency Guidance Note on

Dispersion Modelling) gives guidance on the use of Dispersion Models which was

followed in the execution of this study. A detailed modelling assessment was

undertaken using the US EPA Model AERMOD with the current regulatory version of

this Model. The model computes average ground-level concentrations of pollutants

emitted from either elevated or ground-level emission sources. Separate utilities

associated with the dispersion modelling software allow computation of ground-

level concentrations of pollutants over defined statistical averaging periods, and

additional features permit suitable consideration to be given to building downwash

effects and the effects of elevated terrain in the vicinity of the plant.

Evaluation of the impact of the proposed development on air quality using

dispersion modelling requires information on the following:

Emissions characteristics

Site layout and topography

Climatological data

Averaging intervals


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Receptor locations

This data is summarised in the following sections of this report.

5.4.3.2 Emissions Characteristics

Information on dimensions and physical characteristics of the main emission sources

was obtained from the EIS. As noted in Section 5.2 it was difficult to find all of the

information required to allow this study to be completed. Relevant information was

found in Chapters 2, 6, 7, 10, 11, 12, 14 and 17 of the EIS and in Appendix 7.1 and

Appendix 12.3; however, some information is contradictory and there are also some

gaps in the information which was presented in the EIS. A summary of the emissions

characteristic data is presented in the following sections together with the rationale

used for for each selection.

Pollutants

Emissions to atmosphere from the Energy Centre are discussed in Section 5.2 of this

report. The most significant potential emissions arise from fuel combustion and are

particulate matter (PM10 and PM2.5) and combustion gases such as CO, SO2 and NO2

from the boilers and CHP engines. As noted in Section 5.2, Sulphur dioxide emissions

are significant when fuel oil is used and negligible when natural gas is in use as the

primary fuel. The EIS notes that the existing and proposed energy sources are all

dual-fuelled and can be run on either natural gas or diesel fuel for which significant

storage facilities are provided. Air Quality Standards are in force for all of these

substances so it is necessary to include all of them in the dispersion modelling

assessment.

NOx chemistry

A significant issue in respect of Model Input data for emissions from combustion

sources is the selection of NOx input data. In most combustion processes, NOx is

emitted almost totally in the form of nitric oxide (NO). Nitrogen oxides are very

reactive and also contribute, due to the formation of nitrogen dioxide from nitric

oxide, to the phenomenon of photochemical ozone formation. These

transformations are generally of greatest concern in the areas where the highest


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ozone concentrations occur – for example, in rural areas in late afternoon in summer

time.

In the EPA Modelling Guideline AG4, the recommendation for screening assessments

is that a default annual NO2 / NOx ratio of 1.00 is used and a default hourly ratio of

0.5 is used; this is also the guidance given in the UK for dispersion modelling

assessments. AG4 notes that the AERMOD Modelling suite treats NOx emissions in

one of two ways:

All of the NOx emissions are treated as NO2 and an assumption is made

that a pre-determined ratio of NO2/NOx applies to the predictions; this is

where the default conversion rates noted above would apply;

The Plume Volume Molar Ratio Method (PVMRM) is used whereby an

assumption is made that the in-stack NO2/NOx ratio is 0.1 and the

equilibrium ratio is 0.90.

In our assessment, both methods are employed. The assumption made is that the

local NO2 / NOx ratio is 1 ie that 100% of the NOX is present in the form of NO2. This is

a conservative approach but given the significance of the emission sources it is

considered prudent; separate scenarios are modelled using 90% and 75% conversion

factors. THE PVMRM method is also used as a sensitivity check for the projections.

Pollutant concentrations

Appendix 12.3 provides information on the emission characteristics which were

modelled for the assessment carried out in the EIS. This data relates only to nitrogen

oxides. In my experience the levels given in the EIS are very low and may not be

accurate for the significant energy outputs from the various sources at the Energy

Centre. 33MW of gas input or c. 24 MW energy output is a significant energy output

which will consume a significant volume of fuel, either natural gas or diesel.

Emissions of nitrogen oxides and carbon monoxide will be essentially the same

regardless of fuel type, but SO2 emissions will be significant for diesel fuel and

negligible when natural gas is used. Scenarios will therefore be modelled for both

fuel types. Scenarios will be run for the NOx concentrations quoted in Appendix 12.3


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of the EIS and also for other emission scenarios.

The calculation of emissions to atmosphere from combustion plants is described in

several publications including the Corinair Combustion In Energy & Transformation

Industries (Emission Inventory Guidebook 15 February, 1996)7. This is a guidance

publication on calculating emissions from combustion plants which is recommended

by the EPA as useful guidance in preparing reports to the EPA on emissions to air.

The EPA have also published a spreadsheet tool which is used to calculate emissions

to atmosphere from combustion plant8. These references have been used to

estimate the emissions to atmosphere from the combustion plant at the proposed

children’s hospital.

The guidance requires the use of emissions factors for the various pollutants which

are sourced from the Corinair Publication. SO2 emissions are dependent on the

sulphur content of the fuel which is negligible for natural gas and limited for diesel

oil. For NOx and CO and particulate matter, the emission factors from the Corinair

Guidance are used. Using this methodology, and the information contained in the EIS

that 33MW of gas energy input is required to meet the combined requirements of

the St James’s Hospital and the proposed Children’s Hospital and a future Maternity

Hospital, an estimate of the emissions of each major pollutant for each fuel type is

determined as shown in Table 5.

Since the emission rate projections are derived directly from the energy input and

fuel usage, the emissions projections are based on the energy requirements as

stated in the EIS. The only emission rate data provided in the EIS appears to be for

natural gas and is only given for NOx at 1.94 grams per second (Table 2, Appendix

12.3). This is significantly lower than the value given above and it is unclear from the

information presented in the EIS how such a significant discrepancy arises. The

estimates above for NOx emissions are up to 6 times higher than the EIS estimates

for the St James’s Hospital & Children’s Hospital and the St James’s & Children’s &

Maternity Hospital scenarios. Since the energy sources are all stated to be dual- 7 Accessible at http://www.epa.ie/pubs/reports/air/airemissions/epacorinaircombustionfactorspdf.html#.VgrHFI2FO71

8 Accessible at

http://www.epa.ie/pubs/reports/air/airemissions/epatemplatespreadsheetforcalculatingemissionsfromcombustionplantsxls.html#.Vgr4O42FPIU

http://www.epa.ie/pubs/reports/air/airemissions/epacorinaircombustionfactorspdf.html#.VgrHFI2FO71




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fuelled, and significant storage capacity for diesel oil is provided, an assessment of

the emissions to atmosphere from the use of this fuel is essential and does not

appear to have been completed in the EIS.

Table 5 Estimated emissions from the Energy Centre for different fuels

Pollutant Emission rate, grams/second by Fuel Type

Natural Gas Diesel Oil

Combined St James’s Hospital and proposed Children’s Hospital

SO2 Negligible 0.183

NOx 8.72 9.17

CO 1.49 1.15

Particulate matter 0.025 1.05

Combined St James’s, expanded Children’s Hospital and Maternity Hospital

SO2 Negligible 0.244

NOx 11.6 12.2

CO 1.98 1.53

Particulate matter 0.033 1.39

The emission rate projections given in Table 5 show the very significant emissions

that are associated with the Energy centre and also highlight the significant

difference between the data presented in the EIS and in this report.

Source characteristics

As noted in Section 5.2, there is conflicting information presented in the EIS about

the number of emission sources and the height above ground of these emission

sources. The number of flues ranges from 12 through 16, 20 and 25 depending on

which section of the EIS is considered. Most of the available information indicates

that there will be at least 16 flues from 16 emission sources. The flues will be

configured in a square arrangement near the Energy Centre and will discharge at a

height of 53 to 59m above ground level. Considering the uncertainty, scenarios will

be run with varying stack heights in this range. It is however noted that the


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dispersion modelling assessment presented in Appendix 12.3 of the EIS models

emissions from just 10 emission sources. It appears therefore that a further

understatement of emissions has been presented in the EIS.

Site Layout and Topography

The layout and area of the site and the dimensions of the various plant buildings

were obtained from the drawings submitted with the Planning Application.

Topographical information was obtained from a site survey and from maps,

orthographic photographs and digital Ordnance Survey data. Building downwash

effects are possible as a result of the buildings on site so possible downwash effects

were modeled using the modeling suite facilities.

The presence of terrain can lead to significantly higher ambient concentrations than

would occur in the absence of terrain features, especially if there is a significant

relative difference in elevation between the source and off-site receptors.

International Guidance, and the Agency Guidance Note AG4, suggests that when

modeling in a region of flat terrain, no digital mapping of terrain will be necessary. In

relation to AERMOD, the guidance in AG4 is that digital mapping of terrain should be

conducted where terrain features are greater than 10% of the effective stack height

within 5km of the stack (for effective stack heights of 100m or less). From a review it

is concluded that digital terrain data may be required and was used for the model.

The EIS does not specifically state that terrain data was used but the dispersion

modelling report does state that terrain elevations were obtained from Ordnance

Survey of Ireland and it is assumed therefore that terrain data was used in the

assessment.

Climatological Data

The meteorological data used as input to a dispersion model should be selected on

the basis of spatial and climatological (temporal) representativeness as well as the

ability of the selected parameters to characterise the transport and dispersion

conditions in the area under investigation. The selection of meteorological data for

the Model was discussed in Section 4.1. Meteorological data from Dublin Airport


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(2011 – 2013) was the primary data set used for the assessment and data for

Casement Aerodrome (2011 – 2013) was used for the sensitivity analysis.

Averaging intervals

The dispersion model was used to predict the incremental additions to ground level

concentrations of all substances emitted from the facility over defined averaging

periods. These averaging intervals were chosen to allow direct comparison of

predicted ground level concentrations with the relevant assessment criteria as

outlined in Section 5.2. In particular, 1-hour, 8-hour, 24-hour and annual average

ground level concentrations (GLCs) of various substances were calculated at various

distances from the site; percentiles of these average GLCs were also computed for

comparison with the relevant Air Quality Standards.

Receptor locations

Since the impact of the emissions can be observed at considerable distances from

the emission sources, a fine grid, 3km x 3km centred on the main emission sources

was constructed with receptors located at 50m intervals. A coarse grid, 6km x 6km,

was also constructed with receptors placed at 100m intervals to assess the extent of

dispersion of emissions from the proposed facility. In accordance with best practice

guidance, sensitive receptors in the vicinity of the emission sources are also

specifically identified and included in the Model. On-site receptors are selected to

represent particularly vulnerable locations such as the central garden courtyard, all

upper level terraces and balconies and each Ward Floor Level, and off-site residential

receptors are also included in the model.

Background ambient air quality

The predictions from the dispersion model are evaluated by comparison with Air

Quality Standards. The existing background concentrations of the various substances

must also be added to the predicted impact of the emissions. The existing ambient

air quality in the vicinity of the site has been characterised and a detailed discussion

of the data selection was presented in Section 4.2.


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Assessment criteria

The model predicts maximum ground level concentrations of substances over

specified averaging intervals; these values are then compared with the relevant Air

Quality Standards to verify that the Standards are not exceeded. In this report, the

predicted ground level concentrations are assessed against the Air Quality Standards

– as set in Directive (2008/50/EC). Council Directive 2008/50/EC, known as the Clean

Air for Europe (CAFE) Directive was transposed into Irish law in June 2010. The limit

values imposed by Directive (2008/50/EC) are presented in Table 3. As noted earlier,

it is also appropriate to consider the WHO Guidelines in Table 4 in view of the

particular sensitivity of the development proposal and site.

5.4.3.3 Impact assessment predictions

The impact assessment involves execution of modelling runs to represent different

potential scenarios associated with the emissions. The following Scenarios were

considered in the runs.

(i) Fuel type – Model Runs were executed for all Main emission sources running

on natural gas and separately on diesel fuel;

(ii) Stack height – Model Runs were executed to consider the effect of varying

stack height on the impact predictions;

(iii) Meteorological data – Model Runs were executed to consider the effect of

meteorological data set selection on the impact predictions;

(iv) NOx chemistry – Model Runs were executed using the different approaches

for treating the conversion of NO to NO2;

(v) Pollutant concentrations – Model Runs were executed to evaluate the effect

of varying pollutant emission rates on the impact predictions.

(vi) Expansion of the children’s hospital and future maternity hospital – Model

Runs were executed to evaluate the effect of the proposed increase in

capacity and the location of a maternity hospital at the site.

The dispersion Modelling assessment completed for this impact assessment report

predicts a significantly greater impact of the emissions on air quality than that


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presented in the EIS. The predicted air quality impacts for NO2 for just the existing

facility plus the Children’s hospital without expansion, and without the maternity

hospital, is up to 10 times greater than the impact predictions presented for NOx in

the EIS. The annual mean predicted ground level concentration for NO2 when the

background concentration selected in section 4.2 is considered, is 32.1 µg/m3 which

is 80% of the Air Quality Standard. This does not take into account the future

expansion of the children’s hospital and the future location of the maternity hospital

at the campus. The predicted impact for continuous use of diesel oil as the fuel

results in even higher impact predictions.

The dispersion modelling impact assessment carried out for this assessment report

has led to significantly higher predicted impacts than those presented in the EIS. The

modelling results suggest that there is insufficient assimilative capacity in the

proposed city centre location to ensure that air quality standards are not exceeded

as a result of the very significant emissions that will be released from the Energy

Centre for the combined activities on the site. The results further suggest that when

the significantly higher emissions associated with the expansion of the proposed

children’s hospital and the future maternity hospital are considered, Air Quality

Standards could be exceeded as a result of the emissions. This leads to the

conclusion that the proposed city centre location is not a suitable location for the

proposed development. Areas removed from the city centre with lower baseline air

pollutant concentrations would have greater assimilative capacity and would be

more suitable from air quality impact considerations than the proposed city centre

location.


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The impact assessment methodology described in Section 12.1.2.3 of the EIS for the

prediction of air quality impacts focuses on the impact of emissions from transport

during the operation phase of the proposed development. The methodology is based

on the National Roads Authority “Guidelines for the Treatment of Air Quality During

the Planning and Construction of Major Road Schemes”. While this is an excellent

methodology for assessing the air quality impact of major road schemes, there are

very significant differences between a road scheme and a fixed site such as the site

of the proposed Children’s hospital at St James’s Street. I am therefore concerned

that the methodology may not be the most appropriate for this assessment.

Operational Phase air quality impacts are discussed in Section 12.1.7.2 of the EIS.

The receptors chosen for the impact assessment are residential receptors along the

link roads to the Hospital site. The methodology adopted involves a prediction of the

effect on air quality of the traffic-derived pollutants and assesses significance in

terms of the magnitude of the increase in concentration of the pollutant in ambient

air. However, this is not a major road scheme development and for many reasons

the methodology may be inappropriate.

The use of the NRA Major Road Scheme methodology in the EIS only considers the

off-site impact of road transport on air quality. No on-site receptors appear to have

been chosen for this aspect of the assessment, and the methodology appears not to

have been applied to the evaluation of the air quality impact of increased traffic

movements on the St James’s Street campus site. Therefore the predictions given in

Table 12.16 to 12.20 are likely to underestimate the potential impact of the traffic-

derived emissions on these receptors. This is of particular concern when the

sensitivity and vulnerability of the hospital patients is considered.

As noted in Section 4.2 of this report, the existing baseline concentrations of various

pollutants and especially the traffic-derived pollutants are understated in the EIS. I

have shown in Tables 1a to 1g and summarised in Table 2 the basis for my opinion

that the EIS understates the existing baseline levels of Nitrogen oxides, nitrogen

dioxide and PM10 by as much as 67%. Taking the baseline as data that includes the

traffic contributions for this urban site is critical for evaluating the potential impact


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of the emissions from this proposed activity on air quality and the EIS has failed to

consider this correctly. Although the relatively small traffic volumes mean that this is

not the most significant Operational Phase air quality impact, it is essential that the

assessment is carried out using the correct methodology, the correct baseline data

and that it leads to a reliable statement of potential impact.

The assessment of Operational Phase impacts on sensitive ecosystems is described

at Page 9-23 in Section 12.1.7.2 of the EIS. This section describes only the air quality

impact of Operational Phase traffic movements on the Grand Canal pNHA. It is

acknowledged in the EIS that the Air Quality Standard for NOx for the protection of

vegetation is exceeded for the ‘Do Nothing’ scenario and also for the ‘Do something’

scenario, but the EIS concludes that there is no need for the ecologist to assess the

significance of the impact because the predicted impact is less than 2 µg/m3. This is

an incomplete assessment because not all sources of nitrogen oxides associated with

the development have been considered. Of far greater significance is the potential

impact of NOx emissions from the Energy Centre on ambient air quality but this has

not been mentioned or considered in the assessment – in fact, the dispersion

modelling report (Appendix 12.3 ) specifically states that this is not considered in any

way. This is a very significant omission from the air quality impact assessment and I

am concerned that the potential impact is significantly understated.

The potential impact of emissions due to the energy requirements of the site is

considered in section 12.1.7.4 of the EIS. The single paragraph in the Air Quality

Impact Assessment Chapter of the EIS on this important subject states that

emissions of nitrogen oxides from the Boilers, generators and CHP engines will occur

and that Arup Engineers carried out a dispersion modelling study in relation to the

design of the new discharge flues. That dispersion model report is presented in

Appendix 12.3 of the EIS, and the EIS notes that it concluded that the predicted

ground level concentrations at the most sensitive receptors are in compliance with

the applicable air quality standards.

The emissions from the Energy Centre are the dominant emissions to atmosphere

from the existing and proposed campus. I am concerned that the assessment is

incomplete and that the impact of the most significant emissions from the proposed


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development is understated. I have reviewed the information presented in the EIS

very carefully and there are a considerable number of omissions and methodology

questions which lead me to conclude that the Appendix in the EIS which describes

the dispersion modelling assessment for the Energy Centre does not give a reliable

statement of the impact of emissions from this most significant source of emissions

associated with the Operational Phase of the development. The main concerns with

the assessment are summarised as follows:

The EIS only considers emissions of nitrogen oxides from the Energy Centre

and ignores the other potentially significant pollutants which include CO, SO2,

PM10 and PM2.5. There is no explanation given in the EIS for the omission.

The EIS does not consider the air quality impact of using diesel or gas oil

instead of natural gas;

The meteorological data selected in the dispersion modelling report is

different from the data used in the main Chapter of the EIS and is out of date

which means that best practice has not been utilised in the assessment.

The dispersion modelling assessment ignores the assessment of potential

emissions on sensitive ecosystems such as the Grand Canal pNHA. This is

especially surprising since the main section of the EIS does consider one

Operational Phase impact on the pNHA but ignores the most significant

potential impact on this sensitive receptor.

The baseline air quality data used in the dispersion modelling assessment is

inappropriate for the areas of potential maximum impact based on the data

presented in the modelling report. This means that the impact predictions

are understated.

It appears from the data presented in the dispersion modelling report that

only nitrogen dioxide has been modelled and not nitrogen oxides. This is

inappropriate and therefore the potential air quality impact may have been

understated.

The emission rate projections from the Energy Centre presented in Appendix

12.3 of the EIS and assessed in the modelling study are approximately 16% of

the levels estimated in this report; this extremely large difference in


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estimates requires detailed consideration to ensure that air quality impacts

are not understated.

The incremental contribution to emissions from the proposed Children’s

Hospital has not been specifically identified in the EIS which is inconsistent

with best practice. It is therefore not possible to determine the reliability of

the emissions projections since insufficient data was provided.

Appendix 12.3 notes that four Hot Water Boilers, two CHP engines and four

Steam Boilers will be required to serve the requirements of the site. However

elsewhere in the EIS it is stated that there will be a greater number of

emission sources (Section 5.2).

Emission rate data for NOx for each emission source considered are provided

but there is no rationale provided for how the data was derived. The

projections given in this report show that the figures that are given in the EIS

understate the magnitude of the emissions. The St James’s Hospital Campus

is already a large complex and has very considerable energy requirements

resulting in significant emissions from the Energy Centre. Adding in the

proposed Children’s Hospital will more than double the energy requirement

for the site and a very significant level of emissions is expected.

The impact of emissions from traffic and the Energy Centre on on-site

receptors has not been fully assessed.


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6.0 Conclusions

The main conclusion drawn from this assessment of air quality impacts of the

proposed new children’s hospital is that the assessment presented in the EIS

understates the potential impact of the emissions. This conclusion is drawn because

the impacts of the most significant emissions from the facility have not been reliably

assessed and no cumulative impact assessment has been undertaken. There are also

significant concerns about the methodology adopted in the EIS for aspects of the air

quality impact assessment.

The assessment indicates that there is insufficient assimilative capacity in the

receiving environment to ensure that emissions to atmosphere from the proposed

development do not lead to an exceedance of Air Quality Standards (or Guidelines).

The assessment also suggests that the city centre location proposed for the national

children’s hospital is unsuitable due to the poorer air quality in the area, and that

there is insufficient capacity to allow for future expansion of the children’s hospital

or the or the new maternity hospital in the same area.

Documents

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