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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 1 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
ABCO MARINE Marine Civil Engineering Specialist
ABCO Marine
ABCO Marine Ltd
282 Moira Road
Lisburn
Co Antrim
BT28 2TU
T 028 9262 2731
www.abcomarine.co.uk
Document Number: C20196-MP-002-CEMP
Killybegs Smooth Point Pier Extension Construction Environmental Management Plan (CEMP)
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 2 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
CONTENTS
Document Control .......................................................................................................................................... 5
1.0 Environmental Management Plan...................................................................................................... 6
1.1 Project Introduction ....................................................................................................................... 6
1.2 Purpose of the CEMP ..................................................................................................................... 6
1.3 Environmental Control ................................................................................................................... 8
2.0 Pre-Construction Information ............................................................................................................ 9
3.0 Project Team ....................................................................................................................................10
3.1 Identification of Roles ..................................................................................................................10
3.1.1 Contact details .............................................................................................................................12
3.2 Induction, Training and Briefing Procedures for Staff ..................................................................13
3.2.1 Environmental Site Induction ......................................................................................................13
3.2.2 Toolbox Talks and Daily Briefings.................................................................................................13
3.2.3 Environmental Actions and Commitments Register ....................................................................14
3.3 Key Environmental Legislation .....................................................................................................14
3.4 Understanding of EPA Dumping at Sea Requirements ................................................................15
3.5 Understanding of Planning Condition 17/51385 .........................................................................17
3.6 Protection of Sensitive Areas .......................................................................................................18
4. Ecology ......................................................................................................................................................19
4.1 Large Megafauna .........................................................................................................................19
4.2 Otters ...........................................................................................................................................20
4.3 Fisheries .......................................................................................................................................20
5. Monitoring of Construction Activities .......................................................................................................21
6. Control of Environmental RIsk ..................................................................................................................22
6.1 Dredging Unsuitable Material ......................................................................................................22
6.1.1 Spillage of Dredged Material into water ......................................................................................23
6.1.2 Spill and the Dredging Operation.................................................................................................23
6.2 Disposal at Sea .............................................................................................................................24
6.3 Offloading from Barge ..................................................................................................................25
6.4 Ecological Clerk of Works .............................................................................................................25
6.5 Marine Mammals .........................................................................................................................25
6.5.1 Operational Mitigation ................................................................................................................26
6.5.2 Marine Mammal Observer ...........................................................................................................26
6.5.3 Pre-Start Monitoring ....................................................................................................................26
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 3 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
6.5.4 Mitigation Zone ............................................................................................................................26
6.5.5 Soft Start ......................................................................................................................................27
6.5.6 Breaks in Operations ....................................................................................................................27
6.5.7 Reporting .....................................................................................................................................27
6.6 Archaeology & Cultural Heritage .................................................................................................27
6.6.1 Excavation Strategy – Marine Dredge..........................................................................................28
6.6.2 Excavation Strategy - Shore .........................................................................................................28
6.7 Air Quality ....................................................................................................................................29
6.7.1 Dusts, Fibres and Particulates ......................................................................................................29
6.7.2 Emissions (CO²) ............................................................................................................................30
6.7.3 Gases, Vapours and Aerosols (including pathogens) ...................................................................30
6.7.4 Fires on Site ..................................................................................................................................31
6.8 Waste Management and Materials .............................................................................................31
6.9 Ground Conditions .......................................................................................................................31
6.10 Water ...........................................................................................................................................32
6.11 Visual Impacts ..............................................................................................................................33
7 Population and Human Health ..................................................................................................................34
7.1 Economic Activity .........................................................................................................................34
7.2 Social Considerations ...................................................................................................................34
7.3 Health and Safety .........................................................................................................................34
8. Environmental Monitoring Requirements ................................................................................................35
8.1 Marine Monitoring Sites ..............................................................................................................35
8.2 Phytoplankton & Zooplankton Monitoring ..................................................................................36
8.3 Benthic Monitoring ......................................................................................................................36
8.3.1 Benthic Sediment Survey .............................................................................................................37
8.3.2 Benthic Fauna ..............................................................................................................................37
8.3.3 Sediment Profile Imagery ............................................................................................................38
8.4 Water Quality Monitoring ............................................................................................................38
8.4.1 In-Situ Monitoring ........................................................................................................................38
8.4.1.1 Turbidity ....................................................................................................................................38
8.4.1.2 Dissolved Oxygen ......................................................................................................................38
8.4.2 Mobile Monitoring .......................................................................................................................39
8.4.3 Mitigation Measures ....................................................................................................................39
8.5 Noise & Vibration .........................................................................................................................39
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 4 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
8.5.1 Noise ............................................................................................................................................39
8.5.2 Vibration ......................................................................................................................................41
8.6 General Prevention of Spillage .....................................................................................................42
8.6.1 Environmental Control within Laydown Areas ............................................................................43
9. Incident Prevention and Emergency Response ........................................................................................44
9.1 Summary of Procedures to be followed in the Event of an Environmental Emergency ..............44
9.2 Environmental Complaints, Spills & Incidents .............................................................................45
Appendix 1 – Accident Prevention Procedure ..............................................................................................46
Appendix 2 – Register of Environmental Actions & COmmitments (REAC) ..................................................47
Appendix 3 – Dredge Layout Plan .................................................................................................................48
Appendix 4 - Complaint/ Spills/ Incident Report ..........................................................................................49
Appendix 5 – Complaint/ Spills/ Incident Log ...............................................................................................50
Appendix 6 - Marine Mammal Recording Form ...........................................................................................51
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 5 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
DOCUMENT CONTROL
PREPARED BY ABCO MARINE LIMITED IN THE ROLE OF PRINCIPAL CONTRACTOR
Issue / Date Status Prepared by Reviewed by Approved by
Rev001
24/09/2019 First Issue
Name:
Fionnuala Kerr Name: Ryan McDermott Name: John McGill
Signature:
Fionnuala Kerr
Signature:
Signature:
Rev002
27/09/2019 Revised after Client Review
Name:
Fionnuala Kerr Name: Ryan McDermott Name: John McGill
Signature:
Fionnuala Kerr
Signature:
Signature:
Issue details: Rev 002
Distribution:
Controlled copies: Rev 002 Uncontrolled copies: Rev001
Contract File: Site / Server Contractor: ABCO Marine
Originated by: Fionnuala Kerr Reviewed by: Ryan McDermott
Authorised for issue by:
This document will be routinely reviewed by the ABCO Project Manager and QHSE Director, with the report re-
issued after any revision or refinement as the project progresses.
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 6 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
1.0 ENVIRONMENTAL MANAGEMENT PLAN
1.1 Project Introduction
Killybegs Harbour is regarded as one of the largest fishing ports in Ireland, with approximately 45% of Ireland’s
total fish landings taking place at Killybegs Harbour Fisheries Centre. The Department of Agriculture Food and
the Marine (DAFM) seek to provide improved berthing facilities at Smooth Point to meet the demands of the
fishing industry in Ireland and allow the port to take on new opportunities in the oil and gas industry.
Due to the success of the harbour development in 2004, marine traffic associated with both commercial and
the fishing industry have increased significantly and consequently the demand for berthing now exceeds
available quay space at peak periods. The objective of the contract is to create an additional 120m of deep-
water quay to -9m CD allowing for sheltered, deep water, stern on berthage for fishing vessels in the location
of Smooth Point. Smooth Point is a naturally occurring gravel spit located to the western end of the north quay
at Killybegs FHC.
The works will involve:
▪ Capital Dredging of approximately 108,00m³ of silts gravels and rock to create the required berthing pocket
▪ Disposal of approximately 92,000m³ of dredged silts and gravels at sea under EPA Dumping at Sea Permit
▪ Stockpiling of approximately 18,000m³ of dredged rock on a site within the FHC
▪ Construction of new Combi Type Quay Wall and return wall
▪ Construction of piled relieving platform slab behind the quay wall
▪ Excavation of existing hinterland to achieve the payline stipulated on the drawings. This material will be stockpiled within the FHC and processed for re-use as site won 6A and 6N material in the permanent work
▪ Provisions for future retro fit of Ship to Shore Power including a future Isolating Transformer Building
▪ Installation of piles to support future construction of Isolating Transformer Building
The proposal to upgrade the existing Killybegs Harbour and associated Vessel Berths provides opportunities to
maximise the use of the existing infrastructure at the Harbour. It is considered that the proposed development
is consistent with objectives set out in the national and regional documents for sustainable developments.
1.2 Purpose of the CEMP
This document defines the Environmental procedures, work practices and management responsibilities
relating the marine operation during the delivery of the Killybegs Smooth Point Pier Extension project. This
plan fulfils the requirements of ABCO Marine’s (ABCO) environmental policy statement and has been
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DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
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prepared to include any environmental considerations brought to our attention by the Client. It should be
read in association with business unit policies and procedures, and Pre-construction Information where
applicable.
The development of a project specific environmental plan will flow from the ABCO Pre-Start Meeting Agenda
with sections amended, deleted or added as required.
The Project Manager is responsible for reviewing the proposed work processes and monitoring site activities.
The environmental implications of the project’s activities will be considered during design reviews, planning
meetings, method statement reviews and on site as part of the health, safety and environment inspections.
ABCO’s QHSE Director and Environmental Manager will provide environmental management guidance to the
project. Where necessary further advice may be sought from specialist external consultants.
The Objectives of the CEMP are to:
▪ Identify the key staff structures and responsibilities, and the environmental control and communication and training requirements
▪ Provide all the necessary guides in achieving the Project’s stated environmental objectives and targets;
▪ Ensure legal and contractual compliance by outlining procedures set for the management of all environmental issues envisaged with negative impacts at the project delivery phase
▪ Demonstrate how all operations required during the project delivery phase will be properly integrated to the requirements of environmental legislation, policy, good practice, and those of the environmental regulatory authorities and third parties;
▪ Record the objectives, commitments and mitigation measures to be implemented together with programme and date of achievement
▪ Provide a review, monitoring and audit mechanism to determine effectiveness of, and compliance with, environmental control measures and how any necessary corrective action will take place.
The CEMP is a live document for managing potential environmental risks and opportunities and provides the
framework for identifying environmental aspects and impacts associated with the Project and, therefore, will
be regularly reviewed and updated to take account of new information, changing external factors and
feedback from the review. ABCO are committed to constructing the Smooth Point Pier Extension without
compromising or depletion of natural resources, which is evident throughout the project. The CEMP has
been developed taken into account the importance of Killybegs Harbour to the local community, fishing
industry and economy.
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ABCO No: C20196-MP-002- CEMP
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DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
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1.3 Environmental Control
ABCO operate an integrated management system incorporating ISO:14001 Environmental, ISO:9001 Quality
and OHSAS:18001 Health and Safety management systems, that we use in conjunction with any additional
Client requirement / marine license and planning permit, for effective environmental management of the
project.
The performance of the site will be regularly checked via site inspections carried out by the QHSE Director
and senior personnel. All sites will:
▪ Comply with all relevant environmental legislation avoiding prosecutions for the contravention of environmental law and regulations
▪ Raise environmental awareness throughout the site management team and subcontractors by means of regular environmental tool box talks and awareness sessions
▪ Implement suitable and robust controls to achieve zero pollution incidents (emergency spills, noise /nuisance, water contamination, waste management issues, fire prevention) whilst maintaining an operational work site
▪ Implement the waste hierarchy: prevent waste where we can; reuse materials until we can’t use them again; recycle waste where reasonably practicable; recover waste (e.g. energy recovery); and only dispose of waste if no other options within the hierarchy are possible
▪ Identify and recognise all designated sites, preventing damage to existing buildings, fences, gates, walls, roads, paved areas and other site features, which are to remain in position during execution of the works. The site will instigate appropriate mitigation measures to ensure adequate protection and that minimum disturbance is caused.
BS EN ISO 14001:2015 Registration
ABCO Marine hold registration to BS EN ISO 14001:2015. The certificates can be made available on request.
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
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DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
2.0 PRE-CONSTRUCTION INFORMATION
The following information was provided to ABCO Marine help inform the development of the CEMP:
▪ Smooth Point Pier Extension, Killybegs Fishery Harbour Centre (FHC), Co. Donegal Natura Impact Statement: Screening Report (NIS)
▪ Smooth Point Pier Extension, Killybegs Fishery Harbour Centre (FHC), Co. Donegal Assessment of Impact on the Receiving Environment (AIRE) Volume 1
▪ Smooth Point Pier Extension, Killybegs Fishery Harbour Centre (FHC), Co. Donegal Assessment of Impact on the Receiving Environment (AIRE) Volume 2 Drawings and Figures
▪ Smooth Point Pier Extension, Killybegs Fishery Harbour Centre (FHC), Co. Donegal Assessment of Impact on the Receiving Environment (AIRE) Volume 3 Technical Appendices
▪ Smooth Point Pier Extension, Killybegs Fishery Harbour Centre (FHC), Co. Donegal Assessment of Impact on the Receiving Environment (AIRE) Non-Technical Statement
▪ Department for Agriculture, Food and the Marine - Dumping at Sea Permit – Permit Reg No. S0028-01
▪ Monitoring Plan for Dredging & Disposal Operations for Killybeg Harbour – Aquafact International Services Ltd - September 2016
▪ Planning Conditions 17/51385
▪ Article 11 Declaration No.2167
▪ Specification Requirements
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DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
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3.0 PROJECT TEAM
3.1 Identification of Roles
The environmental manager that has been appointed for this project is:
Name: Fionnuala Kerr
Email: [email protected]
The environmental manager may delegate duties to appropriate members of the site team however all project
staff have a responsibility to work in accordance with the CEMP, from the senior management down to all
operatives. Sustainability and environmental protection are core values; therefore, all staff will lead by
example, setting the highest standards for environmental management practice and performance.
All personnel will be inducted prior to the commencement of every operation, in which they are to act
immediately to correct any non-conforming practice or behaviours and promote environmental awareness,
good environmental behaviours and continuous improvement at every opportunity. Works supervisors and
frontline workers will confirm during their induction that they understand these requirements. The roles of
individual team members are highlighted below:
Project Director – John McGill:
The Project Director will provide leadership sufficient to inspire and influence all project staff to achieve the
predetermined environmental project objectives. For this project, he is the principal source of functional and
technical expertise available to the entire Project team and must ensure sufficient resources are available to
achieve the Project’s set objectives and targets and that those resources have sufficient skills to conduct the
roles competently.
▪ Responsible for ensuring all significant environmental issues are reflected in all related environmental aspects identified for the Project.
▪ The Project Director is responsible for ensuring that resources are available to implement site management procedures and plans.
▪ Environmental plans, procedures and work instructions as applicable are prepared, reviewed and approved prior to the commencement of works.
Project Manager – Emmet Scanlan:
For this project, he is the principal source of functional and technical expertise available to the entire Project
team and must ensure sufficient resources are available to achieve the Project’s set objectives and targets and
that those resources have sufficient skills to conduct the roles competently.
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DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
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▪ Ensure that all relevant environmental permits are obtained for the Project and finally strategies
monitoring programmes, which assess the performance of this CEMP thereby relating it to other project delivery plans, as scheduled to be implemented.
▪ Arranges for full details of all arising, movement and treatment of waste to be recorded during the project.
▪ Ensuring that site personnel, contractors, subcontractors and visitors are aware of environmental procedures relevant to their activities on-site.
▪ Ensuring that site environmental procedures are implemented and adhered to.
Environmental Manager – Fionnuala Kerr:
Assist Project Director and Project Manager in delivering highest environmental standards.
▪ Implementation of this CEMP and monitoring progress internally.
▪ Responsible for ensuring that relevant environmental legislation and obligations are communicated to the site team.
▪ Responsible for implementing monitoring, inspection and auditing regimes.
▪ Dealing and recording all Environmental Complaints.
▪ Cross examination of relevant environmental documents and ensuring all significant environmental issues are reflected in the environmental aspects identified.
▪ Provide ongoing support to work supervisors and site personnel in implementing this CEMP.
Marine Operations Manager – Martin Patten:
Marine Operations Manager ensures that dredge operations are planned in line with license and monitoring
requirements, and all environmental aspects are reviewed during daily activities.
▪ Implementation of this CEMP for the marine operations.
▪ Liaise daily with the Harbour Master to ensure the Works are progressing as planned and concerns such as dust, spillage within the Harbour are adequately addressed.
Shore Works Supervisor – John Keaney:
Shore Works Supervisor ensures that materials are ordered so that the quantity delivered, the timing of the
delivery and the storage is not conductive to the creation of unnecessary waste.
▪ Implementation of this CEMP for the shore based operations.
▪ Liaise daily with the Harbour Master to ensure the Works are progressing as planned and concerns such as dust, spillage within the Harbour are adequately addressed.
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Environmental Clerk of Works – Michael Deery:
An Ecological Clerk of Works shall be engaged on site during the works to ensure implementation of all
environmental mitigation and protection measures in accordance with Planning Register 17/51385.
Archaeologist – Mizen Archaeology:
As the works area is located within an area of high archaeological importance, an Archaeologist will be
employed to monitor the loading activity at Smooth Point.
▪ Compliance with Archaeological License and constraints.
Marine Mammal Observer – Mizen Archaeology:
Employed to provide mitigation measures for marine mammals and meet the monitoring and reporting
requirements of the National Parks and Wildlife Service.
▪ Compliance with Marine License and Dumping at Sea (DaS) Permit.
Site Operatives:
Site Operatives have a responsibility to adhere to site environmental management procedures to ensure that
their activities do not have a detrimental effect on the environment.
Subcontractors:
It is the responsibility of all subcontractors to adhere to the environmental procedures whilst on site.
3.1.1 Contact details
All queries relating to the CEMP should be directed to Fionnuala Kerr. These contact details will be made
available to the all site staff. The site environmental team contact details are:
Responsibility Name Contact Details
Project Manager Emmett Scanlan +44 (0) 7764 958509
Environmental Advisor Fionnuala Kerr +44 (0) 7713 973133
Marine Operations Manager Martin Patten +44 (0) 7738 758665
H&S Manager Gareth McKee +44 (0) 7719 478307
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3.2 Induction, Training and Briefing Procedures for Staff
3.2.1 Environmental Site Induction
The Environment team will prepare and deliver an environmental site induction. All staff, regardless of their
position or level of responsibility, will receive the induction which will cover the following:
▪ The statutory consents associated with the Planning Conditions and Dumping at Sea Permit Conditions
▪ The environmental sensitivities at the project site and constraints associated with Killybegs Fishery Harbour Centre and outlying area towards the dump site location; This is to ensure from the outset that all the environmentally sensitive areas and the appropriate management techniques are communicated to all staff during the initial site induction
▪ The environmental requirements and restrictions as set out in this CEMP including Method Statements for environmental mitigation
▪ The procedure for stopping works if activities on site do not comply with legal environmental requirements
▪ Monitoring and reporting environmental risks
▪ Actions to take in the event of an environmental incident, including emergency contact details.
The environmental site induction will be delivered to staff prior to commencing works on site. Inductions will
be held regularly as new staff join the project or as environmental requirements are refined.
3.2.2 Toolbox Talks and Daily Briefings
To reinforce and supplement the information provided as part of the induction process, Toolbox Talks will be
delivered to ensure that all staff are briefed on the environmental risks associated with each phase of work,
and their responsibilities for environmental protection. At all other times, all staff will attend a daily briefing,
which will include details relating to environmental issues and control measures.
The details of proposed Toolbox Talks will include;
▪ Spill Response Plan
▪ Killybegs Harbour Specific Requirements
▪ Oil and Diesel Spill Prevention and Remediation
▪ Dump at Sea Permit Compliance
▪ Dredge to Barge Transfer – Material Transfer
▪ Archaeology
▪ Noise & Marine Mammals
▪ Environmental Policies, permits and licensing
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These will be displayed in works areas/ works vessels along with a copy of the dumping at sea permit, as a
constant visual reminder to all personnel and site visitors of the conditions necessary to ensure compliance.
Environmental Pocket Books will also be provided to personnel on site to raise potential environmental issues
and provide the appropriate mitigation in case of an incident.
3.2.3 Environmental Actions and Commitments Register
The identification of Environmental Actions and population of a Register of Environmental Actions and
Commitments (REAC) is an important aspect of the environmental performance of a project. The draft of the
REAC is provided in Appendix 2.
The register is developed to allow compliance with the measures outlined therein, by considering the option
of impact avoidance, minimisation and application of all reasonable and practicable measures to prevent or
minimise impacts associated with the dredging operation and disposal process to wholly comply with
applicable environmental legislation.
3.3 Key Environmental Legislation
The proposed development is subject to European and National legislation. Principal legislation as follows:
▪ European Directive 2011/92/EU
▪ The Planning Development Act, 2000 (As Amended)
▪ The Planning and Development (Amendment) Act 2010
Further subsidiary legislation is as follows:
▪ The Water Framework Directive (Council Directive 2000/60/EC)
▪ The Groundwater Directive 2006/118/EC
▪ European Communities (Water Policy) Regulations (2003)
▪ The Wildlife Act, 1976 aa amended by the Wildlife Act 1976 Regulations, 1980, 2000 and 2010
▪ European Communities (Conservation of Wild Birds) Regulations 1985
▪ European Communities (Natural Habitats) Regulations
▪ European Communities (Conservation of Birds & Natural Habitats) Regulations 2011
▪ The Flora (Protection) Order, 1999
▪ The Planning & Development Acts, 2000-2010
▪ National Biodiversity Plan, 2002
▪ Biodiversity Species List for County Donegal, 2009
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▪ Threat Response Plan: Otter 2009-2011 (DEHLG, 2009)
▪ Environmental Noise Regulations 2006 (SI 140/2006)
All works shall be undertaken in strict accordance with the EPA Dumping at Sea Permit and Planning Permission
17/51385.
3.4 Understanding of EPA Dumping at Sea Requirements
The Dumping at Sea Permit S0028-01 for loading in Killybegs and Dumping in Donegal Bay refers to a series of
Conditions in Part III. A copy of this permit will be issued to all relevant personnel whose duties relate to any
condition of this permit and information, instruction and supervision necessary to ensure compliance will be
provided.
A summary of the conditions is provided below to demonstrate ABCO’s understanding of these conditions:
Condition
Number Details Summary of Key Elements for DAFM and AFJV relating to loading and unloading
Condition 1 Scope ▪ The dredging works in Smoothpoint will be carried out using GPS Dredging
system and relate specifically to the defined dredge area. The exclusion zone
will be applied to ensure potentially contaminated material is not brought to
sea (see section 7.1);
▪ The maximum dredged material per day is limited to 6,075 tonnes. Our
proposed dredge volume is less than this. (see section 7.2)
Condition 2 Management
of loading and
dumping at
sea activities
▪ Notification of the Agency (EPA) at least fourteen calendar days prior to
commencement of loading and dumping;
▪ Experience, qualifications of personnel during works (see section 3.1);
▪ Toolbox Talks on the DaS Permit for compliance of the associated conditions
(see section 3.2.2);
▪ Corrective Action: Procedures for non-conformity. ABCO will have in place an
escalation process in the event of a breach to the conditions with an
associated improvement plan (see section 6);
▪ Public Awareness and Communication programme. ABCO will assist or lead
as required:
- Reduction in manmade materials dumped at sea;
- No significant noise emissions;
▪ Dissolved oxygen at Swynes Bay, Donegal Bay (Dump Site) and Harbour
limited to between 5 percentiles > 80% (Lower) to 95 percentiles < 120%
(Upper) (see section 8.4.1.2).
Condition 3 Loading and
dumping at
sea activities
▪ Programme constraints. Dredge is planned first in the programme to de-risk
from winter dredge;
▪ Turbidity monitoring carried out with responsive plan such as silt curtain if
thresholds were exceeded (see section 8.4.1.1);
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▪ Overflow of material on transit to the dump site or during loading. Barges
have agreed limit to fill to avoid overflow (see section 8.4.3);
▪ Recording of the dumping voyage which we propose to use IDS Datalink and
SPOT GEN3 GPS Tracker;
▪ Location co-ordinates off set inwards of DaS site to de-risk material being
dumped outside of the DaS location (see section 8.3.2);
▪ Marine Survey Office approval of the proposed vessels involved in the
dredging (see section 7.1);
▪ Access by others. We will permit access as required for
inspection/enforcement compliance.
Condition 4 Control and
Monitoring ▪ C1.2 Bathymetry surveys of the harbour and of the DaS location;
▪ Archaeology C1.5 at loading locations with individuals with relevant
qualifications and a license from Department of Culture, Heritage and the
Gaeltacht (see section 7.5.1);
▪ Turbidity/suspended solids including an alarmed sensor (see section 8.4);
▪ Suspended solids, dissolved oxygen, Phytoplankton and Zooplankton testing
(see section 8.2 & 8.4);
▪ Marine Mammal Observers (MMO) C1.4 at loading location (see section 7.4);
▪ Vessel speed limited to 5 Knots (see section 7.4.1);
▪ Vessels fitted with guarded propellers (see section 7.4.1);
▪ Dissolved oxygen limits (see section 8.4.1.2);
▪ Limiting dredging of area within the exclusion zone locations as identified in
C1.1.1 (see section 7.1);
▪ Benthic monitoring surveys as C1.1 including grab samples for fauna and
sediments (see section 8.3);
▪ Water quality monitoring C1.3 (see section 8.4);
▪ Sediment monitoring C2.3 (see section 8.3).
Condition 5 Incident
Prevention
and
Emergency
Response
▪ Development of emergency response procedures;
▪ Agreed recording of incidents and notification according to the permit
requirements.
(see section 10)
Condition 6 Notification,
Records and
Reports
▪ Notification of incidents to the agency and their bodies as listed;
▪ Record of incident;
▪ Complaint Register;
▪ Availability of documentation;
▪ Environmental Report including;
- Register of loading and dumping activities
- Incidents, complaints, monitoring, MMO reporting, Accident prevention,
emergency response procedure, investigation of alternative re-use
summary.
(see section 10)
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Condition 7 Financial
Charges ▪ As required by the license
3.5 Understanding of Planning Condition 17/51385
Planning Condition 17/51385 details a number of conditions on which planning permission has been granted.
A summary of the conditions is provided below to demonstrate ABCO’s understanding of these conditions:
Condition Number
Details Summary of Key Elements
Condition 1 Logged Plans In order to define the permission, the development will be carried out in strict accordance with the logged plans detailed within the planning register.
Condition 2 CEMP In the interest of orderly development, the Construction Environmental Management Plan (CEMP) will be submitted to the Planning Authority detailing the intended construction practice; traffic management, waste management, material storage, hours of construction and dust/dirt control. See:
- C20196-MP-005-TMP – Traffic Management Plan
- C20196-MP-006-MTMP – Marine Traffic Management Plan
- C20196-MP-010-SWMP – Site Waste Management Plan
Condition 3 AIRE Mitigation To protect the integrity of the environment and ecology of the area and that of Natura 2000 sites, development will be carried out in strict accordance with the mitigation measures set out in the AIRE.
A) Sediment and water control
B) Marine Mammal Observer
Condition 4 Archaeological Monitoring
To protect the archaeological heritage of the area, archaeological monitoring will be carried out during all ground works.
If archaeological monitoring reveals deposits of archaeological potential then , excavation and construction works will cease until permission is obtained from the Planning Authority for recommencement of the works.
Condition 5 Ecological Clerk of Works
To define the terms of the permission and ensure the integrity and perseveration of Natura2000 sites and their qualifying interests, and ECoW will be engaged on site for the duration of the works.
ECoW will supervise, monitor and ensure strict implementation of all mitigation, observation and monitoring works set out in the AIRE dated November 2016.
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3.6 Protection of Sensitive Areas
A screening for Appropriate Assessment was undertaken to assess whether the planned works pose an adverse
effect on the integrity of any of these European sites. The works location is not located within a Natura 2000
site, however there are four Special Area of Conservation (SACs) and further four Special Protection Areas
(SPAs) within 15km of the proposed development:
Figure 1 - SPAs and SACs within 15km of Killybegs Harbour. Source: Natura Impact Statement: Screening Report
▪ St John’s Point SAC (1)
▪ Inishduff SPA (2)
▪ West Donegal Coast SPA (3)
▪ Slieve League SAC (4)
▪ Donegal Bay (5)
▪ Slieve Tooey/ Tormore Isalnd/ Loughros Beg Bay SAC (6)
▪ Lough Nillan Bog (Carrickatlieve) SAC (7)
▪ Lough Nillan Bog SPA (7)
The AIRE report demonstrates that the proposed works are unlikely to cause any significant effects on the
protected sites. Modelled outputs of the dredging and disposal plumes show that no impact is expected on
reef habitats within the SACs due to the distance and the insignificant levels of suspended sediments. In
addition, any impact on bird populations due to dredging and disposal operations was considered negligible.
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4. ECOLOGY
The main ecological sensitivities and relevant mitigation approaches to be implemented during the project
delivery, guided by the AIRE, are detailed below.
In the event of disturbance to and/or the unforeseen discovery of protected species, further measures will be
implemented which will be agreed with the relevant statutory agencies including the National Parks and
Wildlife Service (NPWS) and Donegal County Council as and when required.
4.1 Large Megafauna
Baleen whales (minke whale, fin whale), toothed whales (killer whale, sperm whale, cuvier’s beaked whale,
harbour porpoise, common dolphin, bottle nose dolphin, risso’s dolphin, striped dolphin, white sided dolphin,
white beaked dolphin), seals (common seal, grey seal), basking sharks and turtles (leatherback) have all been
recorded in inshore Irish waters.
Potential impacts on the megafauna of Donegal bay are likely to be from an increase in underwater noise levels
generated through dredging and underwater construction, dredging and disposal operations and an increase
in collision risk with vessels.
In order to reduce the risk to large megafauna within Donegal Bay, the following mitigation shall be
implemented:
▪ A suitably qualified MMO shall be employed for the full duration of dredge and disposal activities, operating in accordance with DAHG document ‘Guidance to manage risk to marine mammals from man-made sound sources in Irish waters January 2014’ (see section 6.5).
▪ Vessels carrying out loading and dumping activities from 1st April – 31st August inclusive, shall be limited to a speed no greater than 5 knots so as to reduce the likelihood of collision with megafauna.
▪ Vessels with unguarded duct propellers will be prohibited to prevent any large megafauna from being pulled through the duct.
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4.2 Otters
The Eurasian Otter, the only native UK species of Otter, is fully protected as a European protected species and
also under sections 9 & 11 of the Wildlife Act 1976 and EU Directive 92/43 and the Bern Convention (1979) for
international standard. Phase 1 Habitat & Otter Survey conducted as part of the AIRE found suitable resting
places however anecdotal evidence of otter presence in the works area.
In order to reduce disturbance to otter populations potentially present in the works area, the following
mitigation is recommended:
▪ Site works shall be avoided between sunset and sunrise to minimise disturbance to otters which are primarily nocturnal or crepuscular.
▪ In the event that an otter is discovered on site, work in that area must stop immediately and a suitably qualified ecologist consulted.
4.3 Fisheries
Donegal Bay is home to a number of important fishing grounds including McSwynes Shellfish farm, Richie’s Bay
finfish farm and there is a known salmon/trout migratory-run directly through Killybegs Harbour.
McSwynes Bay is a designated shellfish area under the EC Quality of Shellfish Waters Regulations 2006, located
5km southeast of Killybegs Harbour. There a further 16 finfish farms within 5km of these shellfish waters and
an Atlantic Salmon and Sea Trout migratory pass through the bay into the Bungosteen River, used for migration
upstream between September and August.
Killybegs is an operational fisheries harbour whereby the bed is continually disturbed through propeller wash
as vessels access/ egress the berthing facilities. Through this activity, the harbour already demonstrates
insignificant levels of ecological impact and so no specific mitigation for the protection of fisheries is required.
The relevant mitigation is already built into the project design and will also be covered by following standard
best practice guidance during the construction period.
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5. MONITORING OF CONSTRUCTION ACTIVITIES
The following activities shall be completed by the environmental team on an ongoing basis to ensure strict
monitoring and compliance with the CEMP.
1. Completion of Site Weekly HSE Inspection Sheet
2. Fortnightly review of site waste management plan (see document C2016-MP-010-SWMP – Site Waste
Management Plan)
3. Monthly audits carried out by Senior Management, QHSE Director and ABCO Environmental Manager.
4. Ongoing noise, dust & vibration monitoring (see document C2016-MP-009 NVMP – Noise & Vibration
Monitoring Plan)
5. Ongoing water quality monitoring – turbidity/ suspended solids, dissolved oxygen content,
phytoplankton & zooplankton
6. Ongoing observation for marine mammals
7. Ongoing archaeological monitoring
In the event of non-compliance, a Non-Conformance Report (NCR) will be immediately reported to the
Employer, the Employer’s Representative and Employer’s Site Representative. ABCO site management team
will raise the NCR documentation and the team will review the procedure to establish the cause of the failing.
The NCR will be raised to the Environmental Manager, Project Director and Project Manager.
▪ If staff behaviour is found to be the cause, the member(s) of staff involved will receive additional environmental awareness training, which will focus on ensuring that the staff understand the importance of conforming with the environmental policy, procedures and to the requirements of this CEMP.
▪ If a failure of equipment is found to be the cause, the equipment will be serviced and if necessary, replaced.
▪ If a failure of procedure is found to be the cause, the CEMP will be reviewed and revised as necessary.
The Environmental Manager will report the findings to the management team and the course of action to close
the NCR and to avoid reoccurrence.
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6. CONTROL OF ENVIRONMENTAL RISK
This section details the environmental risks associated with all project activities and, describes the mitigation
measures that are set in place to eliminate or reduce the risks. As the project proceeds, changes in the
environmental risks will be monitored and evaluated.
6.1 Dredging Unsuitable Material
One of the key environmental risks of the project is the accidental dredging of material deemed to be
unsuitable for dumping at sea due to the presence of elevated levels of chemical contaminants. There is
potential for contaminants to be present in the surface silts and gravels in the area of Smooth Point adjacent
to the previous dredging campaign.
The risk of dredging material in this area will be mitigated by the use of a 3D Machine Guidance System
displaying Exclusion Zones.
▪ The top 1.1m of sediments from the area outlined in green of drawing “E2538-AML-00-XX-DR-X-1001 – Phase A Layout Plan” was previously dredged and disposed through a previous project.
Figure 2 - E2538-AML-00-XX-DR-X-1001- Phase A Layout Plan
▪ The excavator will be fitted with several positional sensors on the bucket, stick and boom together with GPS receivers for positional correction, giving a live feed of the barge, excavator and bucket positions at all times.
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▪ An RTK base station was set up at a fixed position on the shore providing positional correction to the
excavator GPS via a radio communication link
▪ The pre- works bathymetry survey, design dredge level, tolerances and the exclusion zone will be uploaded to the software enabling the operator to view in real time proximity to the exclusion zone.
▪ Should the bucket encroach on the exclusion zone an alarm will be raised within the cab and in the wheelhouse of the dredge barge, which is monitored by the Vessel Master.
▪ A quayside benchmark will be established with a known position and elevation to enable regular bucket checks to be carried out to confirm the accuracy of the bucket positioning. Checks will be carried out regularly, at least on a weekly basis and where there was a change to the sensors or excavator set up.
▪ A line of buoys will be deployed along the edge of the area to provide a constant visual reminder, as identified by Black Hatched Line in Fig. 2 – Drawing: E2538-AML-00-XX-DR-X-1001- Phase A Layout Plan.
▪ All vessels involved with dredge activities will receive approval from the Marine Survey Office prior to the commencement of works.
In addition, all reasonable efforts shall be made to remove any solid/floating waste during the loading and
dumping activities:
▪ Dredged material will be passed through ≤ 30cm grid screen to minimise the amount of man-made materials dumped at sea.
6.1.1 Spillage of Dredged Material into water
Another key environmental risk for this project is the dispersion of dredged material during the dredging
operation and transportation. The release of dredge material can result in significant adverse effects on marine
species. A site-specific Spill Response plan has been developed to counteract, minimise and eliminate those
risks.
6.1.2 Spill and the Dredging Operation
Marine Dredge operations will be undertaken with a specially adapted sealed ‘environmental bucket’. The
environmental bucket is designed to minimise loss or spillage of dredged sediment. The dredger is controlled
using Global Positioning System (GPS) technology which ensures a high degree of accuracy.
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Figure 3 - Environmental Bucket
Dredged material will be deposited directly into hopper barge. The bucket will not be lifted from the bed before
the bucket has been properly sealed shut. The bucket will then be lifted to the surface and slewed over the
hopper barge, with the material deposited into the Hopper Barge.
6.2 Disposal at Sea
In order to accurately control and record the nature of each disposal event, a bespoke automatic vessel logging
system will be installed onto all vessels used for sea disposal activities. This system has been developed in
conjunction with IDS Monitoring (IDS), a marine technology specialist, and the Environmental Protection
Agency (EPA) for use on split hopper barges and is programmed to record the following information for each
voyage:
▪ Name of Vessel;
▪ Source of Material;
▪ Date, time, location and position at which loading began and ended;
▪ Date, time, location and position at which dumping voyage for purposes of dumping began;
▪ Date, time, location and position at which dumping began;
▪ Date, time, location and position at which dumping ended;
▪ Quantity of material dumped (m3);
▪ Date, time, location and position at which the vessel completed the voyage for the purpose of dumping, and;
▪ Logged vessel track record data.
In addition, the release of suspended solids into the water column during loading and on voyages to and from the dumpsite will be minimised.
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The maximum daily rate of disposal will be limited to 6,075 tonnes per day. Disposal will be limited to a total
maximum quantity of 170,000 tones (wet weight) dredge material and be completed by 30th April 2019.
6.3 Offloading from Barge
The hopper barge will be moored alongside the quay. Dredged material not to be dumped at sea will be
offloaded into articulated dumpers for transportation to the temporary storage area. An environmental bucket
will be used, which will be sealed shut. The bucket will remain above the barge until all water has ceased
draining from it.
Articulated Dumpers will be loaded not exceeding their capacity to reduce the risk of spillage during
transportation. The jetty, hardstanding and haul road will be cleaned immediately if dredged material is spilt
onto surfaces.
For effective monitoring, site personnel will be assigned to ensure all haulage vehicles upon leaving the
contractor’s working area. All vehicles will be inspected for wheel and undercarriage cleanliness prior to leaving
the working area. All road gullies will be screened using geotextile to prevent contaminated water from being
washed into the storm sewer network.
A general note for the works supervisors prior to the commencement of all operation/dredging activities, they
should ask and ensure that spill kits are readily accessible and there is sufficient material to clean up a range
of spills
6.4 Ecological Clerk of Works
An Ecological Clerk of Works shall be engaged on site during the works to ensure implementation of all
mitigation and protection measures. Their role will include observation and monitoring of the works in
accordance with Planning Register 17/51385.
6.5 Marine Mammals
To date 25 species of cetaceans have been recorded in Irish waters and two regularly occurring seal species,
the Grey Seal and Harbour/Common Seal. This high number reflects the diversity of habitats which are used
for foraging, transit between terrestrial resting places and other behaviours linked to their annual life cycles
(e.g., social behaviour, territoriality).
In Ireland, cetaceans (whale, dolphins and porpoises), pinnipeds and the Eurasian otter (Lutra lutra) are
protected under a suite of national and international legislation. European and national legislative frameworks
include the EC Habitats Directive and conventions such as the Convention on Biological Diversity and OSPAR
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Convention. All cetaceans, as well as grey (Halichoerus grypus) and harbour seals (Phoca vitulina) and otters
are also protected under the Wildlife Act (1976) whereby it is an offence to hunt, injure or willfully interfere
with, disturb or destroy the resting or breeding place of a protected species. In order to maintain legislative
compliance and prevent harm or disturbance to any marine mammals encountered during the works, the
following mitigation measures shall be implemented.
6.5.1 Operational Mitigation
Vessels employed for dredging and dumping at sea between April and August will be instructed to limit speed
of passage to <5knots to minimise risk of collision. In addition, unguarded ducted propellers will be prohibited.
6.5.2 Marine Mammal Observer
ABCO will provide a suitably qualified Marine Mammal Observer (MMO) with awareness of Irish Regulatory
Procedures. The dedicated MMO will supervise the works in accordance with National Parks and Wildlife
Service “Guidance to manage risk to marine mammals from man-made sound sources in Irish Waters, January
2014” and be responsible for advising ABCO personnel if a delay in the commencement of operations is
required.
The MMO will be JNCC qualified and will operate to the Joint Nature Conservation Committee’s (JNCC)
‘Statutory nature conservation agency protocol for minimising the risks of injury to marine Mammals from
piling noise’ (August 2010) will be followed.
6.5.3 Pre-Start Monitoring
Prior to the commencement of any noise producing activities, MMO will be positioned onboard the source
vessel to conduct a pre-start search of the mitigation zone. In waters up to 200m deep, pre-start monitoring
will be completed at least 30 minutes before noise producing activities are due to commence. Activities shall
not commence until 30 minutes have elapsed with no marine mammals detected within the Mitigation Zone
(see section 6.5.4). Construction activities shall only commence in daylight hours where effective visual
monitoring has been achieved. Where effective visual monitoring is not possible, activities shall be postponed
until effective visual monitoring is possible.
6.5.4 Mitigation Zone
A mitigation zone will be established around the source of the noise producing activity. The MMO will keep
watch within this area and delay the start of activity should any marine mammal be detected.
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▪ During dredging operations, the mitigation zone is a 500m radial distance from the dredging
sound source.
▪ During piling operations this zone is extended to 1000m radial distance from the pile driving sound source.
▪ For all multibeam, single beam, side-scan sonar and sub-bottom surveys conducted within bays, inlets and estuaries, or 1,500m from the entrance of enclosed bays/inlets/estuaries, the mitigation zone will be 1,000m radial distance from the sound source.
6.5.5 Soft Start
Soft-start procedure shall be adopted for marine operations on the project. During this ramp up period if a
mammal is observed within the mitigation zone, the ramp up should either be stopped or maintained at the
same noise level until the mitigation zone is observed as clear for 30 minutes after the last visual detection.
The MMO will track any marine Mammals detected and ensure they are satisfied the animals have left the
mitigation zone before they advise the crew to commence dredging activities.
6.5.6 Breaks in Operations
Once normal dredging operations commence, there is no requirement to halt or discontinue the activity at
night-time, if weather or visibility conditions deteriorate nor if marine mammals are observed within the
mitigation zone. If there is a break in dredging sound output for a period greater than 30 minutes (e.g., due to
equipment failure, shut down or location change) then all pre-start monitoring must be undertaken in
accordance with the above conditions prior to the recommencement of dredging activity.
6.5.7 Reporting
MMO will log all marine mammal detections and relevant sound-producing events using the standardised
reporting form included in Appendix 5.
6.6 Archaeology & Cultural Heritage
Smooth Point is in located an area of high archaeological significance, where there is a potential for the
development works to impact previously unrecorded archaeological material.
ABCO will engage a specialist and suitably qualified archaeologist to monitor the works in compliance with the
requirements of the EPA Dumping at Sea Permit, Planning Permission 17/51385 and the Underwater
Archaeology Unit of Department of Culture Heritage and the Gaeltacht.
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3 weeks prior to the commencement of loading and dumping activities, ABCO will notify the Underwater
Archaeology Unit of the Department of Culture Heritage and the Gaeltacht to obtain an Archaeological
Excavation License.
Archaeological monitoring will be carried out during all onshore and marine works. If deposits of archaeological
potential are uncovered during excavations, excavation and construction works will cease until permission is
obtained from the Planning Authority for recommencement of the works.
6.6.1 Excavation Strategy – Marine Dredge
The site archaeologist will be notified when works are due to commence and be positioned in a safe
observation area to review and confirm dredge materials do not contain items of interest in accordance with
the archaeological license.
Constant visual inspection of the excavator bucket shall be maintained as it emerges from the water and as
material is deposited into the hopper barges. Should any material of archaeological interest arise from the
dredging operation, the Underwater Archaeology Unit will be notified immediately, and dredging works will
cease whist the material is inspected and logged by the Archaeologist.
The steps to be taken in the event of a discovery are listed below:
1. STOP work immediately.
2. IMMEDIATELY PROTECT the find by marking/blocking off.
3. NOTIFY the discovery to the project team including Client’s Representative who should notify
the Underwater Archaeology Unit of the Department of Culture, Heritage and the Gaeltacht
and other relevant Stakeholders.
4. Access to the area by vessels, machinery and personnel is to be prevented.
5. Time is to be allowed for the archaeologist to undertake the appropriate level of recording.
6. Archaeological objects and treasure discovered must be reported to the regulator.
Note: A suitable water tank will be available on site so that findings may be stored appropriately to
prevent degradation.
6.6.2 Excavation Strategy - Shore
The site archaeologist will be notified when works are due to commence and be positioned in a safe
observation area to review and confirm shore excavations do not contain items of interest in accordance
with the archaeological license.
For
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Constant visual inspection of the excavated area shall be maintained. Should any material of archaeological
interest arise from the operation, the Department of Arts, Heritage and the Gaeltacht will be notified
immediately, and works in the area will cease whist the material is inspected and logged by the Archaeologist.
The steps to be taken in the event of a discovery are listed below:
1. STOP work immediately.
2. IMMEDIATELY PROTECT the find by fencing/blocking off.
3. NOTIFY the discovery to the project team including Client’s Representative who should notify the
Department of Culture, Heritage and the Gaeltacht and other relevant Stakeholders.
4. Access to the area by machinery and personnel is to be prevented.
5. Time is to be allowed for the archaeologist to undertake the appropriate level of recording.
6. Archaeological objects and treasure discovered must be reported to the regulator.
Note: A suitable water tank will be available on site so that findings may be stored appropriately to
prevent degradation.
6.7 Air Quality
The key environmental risks associated with air quality are the generation of dust, particulates, gases, vapours
and aerosols, which can affect human health. The following measures will be implemented to reduce these
risks.
6.7.1 Dusts, Fibres and Particulates
The main source of dust will be from excavations, vehicle movements, windblown dusts from the site and the
dredged material from the rock brought to shore. Dust will only be created in dry conditions; during such times
dust monitoring, will be carried out to ensure that the works do not cause a nuisance. If the entrance/exit to
the contractor’s working area generates dust from vehicle movements, a road sweeper will be used. Haulers
will take all appropriate measures including covering their loads if necessary. If necessary, water bowsers will
be used to dampen windblown dusts on-site.
The trigger level for implementing dust control measures will initially be by visual evidence of dust whip,
followed by monitoring of suspended dust (PM10) to ensure compliance with emission limits (50 micrograms
per cubic - 24 hr. average).
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6.7.2 Emissions (CO²)
The main source of emissions will be from running construction plant and delivery to and from the site. The
following mitigation measures shall be adopted to minimise emissions during the construction operations:
▪ Site Office facility shall be energy efficient, incorporating sensors and push water taps to minimise energy use. Energy and water usage will be monitored and recorded for the duration of the project.
▪ All plant shall be regularly serviced to have engines working efficiently, to minimise fumes/ smoke from engine exhaust.
▪ Construction vehicle movements will be minimised, and all plant engines shall be turned off when not in use.
▪ Enhancing employee and subcontractor understanding, with a site specific environmental induction for all personnel.
▪ Source environmentally sustainable materials, reducing our consumption of energy and raw materials and maximising the opportunities to re-use and recycle, where feasible.
▪ Encourage shared transport to and from site for all personnel, including subcontractors.
▪ Audio and visual conference facilities provided to support site meetings and communications, mitigating against prolonged travel to site.
▪ Local supply chain shall be engaged were suitable to support site operations, supply materials or supporting personnel.
▪ Energy efficient lighting shall be used to support winter working.
▪ No burning of waste will be permitted on site.
6.7.3 Gases, Vapours and Aerosols (including pathogens)
Monitoring for vapours will be carried out daily to determine if odours are deemed to be a nuisance. Olfactory
assessment will be carried out within agreed designated areas on the site. If necessary, a photoionization (PID)
meter will be used to measure volatile organic compounds (VOCs) at the boundary and if a detection reading
of above 10ppm for VOCs is measured then all materials will be covered during operations with polythene to
reduce the vapours. To minimise odour emission during excavation, excavated material placed in stockpile that
is emitting odours will be covered with an impermeable membrane until levels are acceptable. If odours do
become a problem even after being covered then a secondary system can be implemented, i.e. an odour
masking/misting system; however, this is not likely to be required.
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6.7.4 Fires on Site
To limit the risk of any flash point fires, smoking is not permitted on-site. All works will be carried out in open
aired conditions, which will reduce the risk of vapour build up, and flash point fires. In the event of a fire, the
Fire Brigade will be called. All plant will be equipped with fire extinguishers in the event of any fires.
Killybegs Fire Brigade, Shore Road, Killybegs. Tel: 999/112
Tel: 074 97 31272
In the event of fire outbreak, the following procedures will be followed
▪ Activate the nearest fire alarm to warn others - this may be a horn on construction sites.
▪ Notify the local fire service and other relevant emergency services
▪ Disconnect utilities and equipment unless doing so jeopardises safety
▪ Remove fuel (mobile fuel bowser) if it is safe to do so
▪ Assemble in the designated ‘Fire Assembly Point’ which will be clearly marked using relevant signage
6.8 Waste Management and Materials
Refer to C20196-MP-010-SWMP Site Waste Management Plan. As an overview, the following mitigation
measures will be implemented:
▪ Waste skips will be on site to segregate timber, plastic and rubber for transport off site for suitable recycling;
▪ Waste Skips will be provided for site offices and removed by a licenced waste contractor;
▪ Waste Transfer documentation for all material removed from site will be submitted to the Engineer on a weekly basis;
▪ Disposal or recovery of solid waste shall only take place in accordance with the conditions of permit S0028-01 and in accordance with the appropriate National and European legislation and protocols;
▪ Solid waste sent for disposal or recovery shall be transported only by an authorised waste contractor. The solid waste shall be transported from the site of the activity to the site of the recovery/disposal only in a manner that will not adversely affect the environment and in accordance with the appropriate National and European legislation and protocols.
6.9 Ground Conditions
The following mitigation measures will be implemented:
▪ Ensure that all areas where liquids (including fuel) are stored or cleaning is carried out are in a designated area
▪ Careful consideration will be given to the location of any fuel storage facilities. These will be designed in accordance with guidelines produced by CIRIA, and will be fully bunded
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▪ All works will be carried out in accordance with the following Pollution Prevention Guidelines (PPGs)
relating to water quality. Special consideration given to
• PPG1 General Guide to the Prevention of Pollution
• PPG2 Above Ground Oil Storage Tanks [new GPP issued January 2017]
• PPG5 Works in, Near or Liable to Affect Watercourses [new GPP issued January 2017]
• PPG6 Working at Construction and Demolition Sites
• PPG21 Pollution Incident Response Planning [new GPP issued July 2017] ▪ Damaged, leaking or empty drums will be removed from site immediately and disposed of by
registered a waste disposal contractor
▪ Mobile plant will be refuelled in a designated area, away from drains or watercourses
▪ All vehicles and plant will be regularly inspected for fuel, oil and hydraulic fluid leaks. Suitable equipment to deal with spills will be maintained on site
▪ Soils requiring off site removal will be undertaken in accordance with the specific waste acceptance criteria of the receiving facilities and in accordance with relevant waste legislation
▪ Minimise the use of cleaning chemicals
▪ A spill kit with sand, earth or commercial products that are approved for the stored materials will be kept close to the storage area. Staff will be trained on how to use spill kits correctly
▪ Dredged (Rock) material will be placed in dump trucks at the designated quay for transport to storage areas
▪ Stockpiles will be compacted, sealed and battered with the back of the excavator bucket to prevent any storm water infiltration
▪ All road gullies will be screened using geotextile to prevent surface run-off construction water from being washed into the storm sewer network
6.10 Water
The following mitigation measures will be implemented:
▪ Ensure that all areas where liquids (including fuel) are stored or cleaning is carried out are in a designated impermeable area that is isolated from the surrounding area and within a secondary containment system, e.g. by a roll-over bund, raised kerb, ramps or stepped access
▪ Careful consideration will be given to the location of any fuel storage facilities. These will be designed in accordance with guidelines produced by CIRIA, and will be fully bunded
▪ Damaged, leaking or empty drums will be removed from site immediately and disposed of by registered a waste disposal contractor
▪ Mobile plant will be refuelled in a designated area, on an impermeable base away from drains or watercourses
▪ All vehicles and plant will be regularly inspected for fuel, oil and hydraulic fluid leaks. Suitable equipment to deal with spills will be maintained on site
▪ Ensure that all staff are trained and follow vehicle cleaning procedures. Post details of the procedures in the work area for easy reference
▪ Soils requiring off site removal will be undertaken in accordance with the specific waste acceptance criteria of the receiving facilities and in accordance with relevant waste legislation
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▪ Minimise the use of cleaning chemicals
▪ Dredged material will be placed in sealed dump trucks at the quay side via a sealed environmental bucket
▪ Stockpiles will be compacted, sealed and battered with the back of the excavator bucket to prevent any storm water infiltration
▪ All road gullies will be screened using geotextile to prevent contaminated water from being washed into the storm sewer network
6.11 Visual Impacts
Visual impact was scoped out of the Assessment of Impact on the Receiving Environment (AIRE) (November
2016). As the site is located within the Killybegs Harbour estate, the project is not expected to be sensitive in
terms of visual impact as works will be at the level of the existing quay. The risk of adverse effects on the
landscape are minimal and no specific mitigation measures are proposed.
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7 POPULATION AND HUMAN HEALTH
As the works are to be carried out within the existing harbour area, the risks of disturbance to people and
communities are low. All roads will be kept free of mud and debris and any other material which might cause
a nuisance. Vehicle movements will be kept to a minimum and restricted to defined haul routes within the site.
If for any reason the site traffic leaving the site causes a fouling of the roadway, then the debris will be cleared
using hand shovels or a mobile road sweeper. All such incidents will be fully recorded in a daily log.
A commercial Scarab type road sweeper will be on site at all times during the dredging, treatment and disposal
operations. All dust will be controlled in accordance with the material COSHH sheet and the recommendations
of the manufacturer of the material.
ABCO will implement and maintain a Public Awareness and Communications Program to ensure members of
the public can obtain information at reasonable times concerning the environmental performance of the
works. ABCO will provide an environmental storyboard and a copy of the monthly progress report, available
within the harbor office, for inspection by the public during office hours.
7.1 Economic Activity
With the appropriate mitigation measures outlined in this CEMP in place, the construction and operational
process will have an imperceptible impact on adjacent businesses, and it is considered that there will no further
mitigation measures required.
7.2 Social Considerations
The mitigation measures included in this CEMP will reduce or eliminate any negative impacts on local amenity
and social facilities. No further measures are required.
7.3 Health and Safety
Mitigation measures will be proposed to minimise any health and safety risk to the public and residents, as
well as ensuring the site layout and surrounding roads have the capacity to deal with the additional traffic.
▪ In accordance with current legislation and in order to prevent and minimise construction activities accidents, a QSHE manager has been appointed to co- ordinate the design and to address and minimise construction risks during the design period
▪ A Health and Safety Plan will be implemented and reviewed by the project team
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▪ During construction all areas will be delineated and will be under the control of the QSHE
manager who will coordinate and supervise all safety aspects of the project
▪ A Safety File will be compiled and maintained on site for the duration of the project and the implementation of the Plan will be subject to regular audits
▪ Strict security procedures will be implemented on site. These procedures will require all vehicles and personnel visiting the site to be logged in and out.
8. ENVIRONMENTAL MONITORING REQUIREMENTS
The key monitoring requirements for this project relate to water quality and construction noise output. There
is potential for changes in water quality and benthic structure resulting from dredging and offshore disposal
activities as well as an increase in noise and vibration within the harbour area from construction activities.
▪ All analysis and measurements will be undertaken by competent staff and in accordance with the
relevant documented operating procedure;
▪ Operating procedures will be assessed for suitability for the test matrix and performance characteristic
determined;
▪ All procedures will be subject to Analytical Quality Control using control standard with evaluation of
test response;
▪ Analysis for compliance purposes including sub-contracted analysis, shall be done by a competent
laboratory.
8.1 Marine Monitoring Sites
Marine monitoring sites have been selected based on environmental sensitivities within the area.
The sensitive areas that require monitoring are the aquaculture sites at Inver Bay and McSwynes Bay as well
as the SAC at St Johns Point. In addition to these, it is best practice to monitor the area surrounding the
dredging operation and to monitor an offshore control for the disposal site outside the influence of the disposal
operation.
On the basis of this, 4 static monitoring locations have been selected in addition to the dump site itself:
Monitoring Location Longitude Latitude
Static Monitoring Locations
1 Killybegs Harbour -8°26.40’ 54°37.03’
2 McSwynes Bay -8°25.19’ 54°34.75’
3 Inver Bay -8°23.84’ 54°36.41’
4 Offshore Control Site -8°32.40’ 54°33.65’
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Disposal Monitoring Locations
5 Offshore Disposal Site
(i) -8°37.85 54°33.62
(ii) -8°37.29 54°33.63
(iii) -8°37.84 54°33.30
(iv) -8°37.28 54°33.30
(v) -8°37.57’ 54°33.46’
8.2 Phytoplankton & Zooplankton Monitoring
As fundamental components of the water food web, plankton are among the first to react to water quality
changes and by this initiate a chain reaction which is successively reflected within other groups of organisms
such as benthic fauna, fish and birds etc.
As plankton communities are sensitive to changes in their environment and respond rapidly, levels of
Phytoplankton and Zooplankton will be periodically monitored as measure of water quality. Monthly samples
shall be collected at the 4No static monitoring locations, beginning a minimum of 1 month prior to loading and
dumping activities and will continue monthly for the duration of the works until all loading and dumping
activities are complete.
Survey Method Storage Solution
Phytoplankton 10-minute surface tow Lugol’s Iodine
Zooplankton U-tow (from the surface down to the seabed and back up to the surface)
5% Buffered Formalin
8.3 Benthic Monitoring
Benthic surveys within Donegal Bay shall be completed at the 5 monitoring locations identified in section 8.1,
to assess the condition of fauna and sediment. Grab sampling techniques will be used to establish the
distribution patterns of benthic animals as well as their relationship with the biochemical properties of the
sediment.
The benthic monitoring program has been designed to statistically measure the direction and severity of any
change in the benthic environment. The frequency and extent of each monitoring survey to be completed is
detailed below:
Monitoring Frequency
10 Days Post Disposal 6 Months Post Disposal 12 Months Post Disposal
Monitoring Survey Requirements
4No Static Monitoring Locations
Grab samples for benthic fauna and sediment
Grab samples for benthic fauna and sediment
Grab samples for benthic fauna and sediment
Grab samples for benthic fauna and sediment
Grab samples for benthic fauna and sediment
Grab samples for benthic fauna and sediment
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Disposal Monitoring Location
SPI Survey SPI Survey SPI Survey
Grab samples will be processed for sediment and fauna in accordance with the analytical and quality
requirements set out in ‘M. Cronin et al, 2006. Guidelines for the Assessment of Dredge Material for Disposal
in Irish Waters. Marine Environment & Health Series, No24. Marine Institute’ and ‘’Marine Sediment and
Benthic Studies for Killybegs Harbour Dredging and Disposal Operations’’ provided as part of the AIRE.
8.3.1 Benthic Sediment Survey
The proposed works could potentially lead to chemical contamination of the environment as a result of
suspension and dispersal of poor-quality sediments during dredging and disposal activities. The potential for
introduction of tributyl tin (TBT), formally used as ship anti-fouling paint, through the release of dredge
sediments is the main concern. The TBT compound is by far the most toxic to marine life, responsible for the
disruption of the endocrine system of marine shellfish, impairing immune system and causing malformations
after exposure to even extremely low concentrations.
In order to prevent the disposal of poor-quality sediments, the following mitigation shall be employed:
▪ The risk of dredging contaminated material will be mitigated by the use of a 3D GPS Machine Guidance System, displaying exclusion zones to ensure no material is dumped at sea which is classified as unsuitable. (See section 7.1 Dredging Unsuitable Material for further mitigation).
▪ Identified contaminated sediment found unsuitable for disposal at sea will be removed by an excavator fitted with an environmental bucket for processing and disposal on land.
▪ No material will be dumped at sea that has been classed as unsuitable.
8.3.2 Benthic Fauna
Dumping sediments on the seabed may smother and crush organisms living on the seafloor and may cause
changes in benthic habitats and biological communities. In order to mitigate against any potential changes to
the benthic environment, the following mitigation shall be employed:
▪ Dumping will be via release of material through hull of the vessel while the vessel is in motion to aid the dispersion of sediments over the full dump site area and lessen the effects of smothering.
▪ Dumping activities will be conducted to ensure a uniform spread of material thoughout the dumping site.
▪ Dumpsite location coordinates will be offset inwards of the permitted DaS site in order to de-risk the potential for material being dumped outside the permitted area.
▪ Dredge material will be passed thought a ≤ 30 cm grid to minimise the amount of large sediments and rock disposed offshore.
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8.3.3 Sediment Profile Imagery
A Sediment Profile Imagery (SPI) survey will be conducted at the dumpsite pre works in order to set a baseline
for measuring change, and a further 10 days, 6 months and 12 months post disposal.
SPI is an underwater technique for photographing the sediment-water interface at the seafloor and can be
used to measure the biological, chemical and physical processes occurring at the benthic boundary layer. SPI
takes images of the upper 25cm of the sea floor and records physical parameters such as sediment grain size
and dredge material thickens.
With the growing requirements for environmental impact assessment and monitoring, SPI a very rapid means
of assessing the status of underwater sediment habitats.
8.4 Water Quality Monitoring
8.4.1 In-Situ Monitoring
Water quality will be continuously monitored at the 4 static monitoring stations detailed in section 8.1
throughout the works using an in-situ sensor providing real time data on turbidity, suspended solids and
dissolved oxygen. A moored buoy will be deployed at each of 4No locations 1 month prior to dredging
commencing and will remain in place for the duration of dredge operation.
8.4.1.1 Turbidity
During the pre-dredging phase, water samples for suspended sediments will be collected to calibrate against
turbidity and obtain a background range. These will be collected every hour for 12 hours for 1 week during the
baseline data collection phase and continue weekly thereafter.
At the sensitive aquaculture sites of St Johns Point/ Inver Bay and McSwynes Bay, a turbidity trigger level of
50mg/l above background has been agreed. If turbidity levels exceed this agreed limit, a silt curtain shall be
utilised.
8.4.1.2 Dissolved Oxygen
The limits for dissolved oxygen are set in accordance with permit condition 4.8 and are detailed below:
Dissolved Oxygen Lower Limit Dissolved Oxygen Upper Limit
5 percentile >80% 95 percentile <120%
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8.4.2 Mobile Monitoring
In addition to in-situ monitoring, a mobile monitoring campaign will be carried out within Killbegs Harbour
during active dredging.
Mobile monitoring will be carried out downstream from the dredger on the ebb and upstream on the flood
tide during the dredging activity i.e. twice a day. Sampling will involve 5No point samples at the following
distances from the dredger: +20m, +50m, +100, +250m, +500m.
A further transect through the dredge plume every 50-100m will be monitored hourly during dredging
operations. Once compliance with the trigger levels is demonstrated, the time between dredge plume sampling
sessions may be extended to 12 hourly intervals. Mobile monitoring will commence 2 days prior to dredging,
continue every day during of active dredging and cease 24 hours after dredging ceases.
8.4.3 Mitigation Measures
ABCO will employ tried and tested techniques to mitigate against a reduction in water quality due to the
elevation of suspended solids:
▪ The direction of dredging works will be orientated with the current, instead of across the current to minimise the potential for negative effects on water quality.
▪ A sealed environmental bucket will be fitted to all excavators employed for the removal of soft sediments to minimise suspension of bed material through washout. Once the bucket is full, a shutter is closed and only then is the bucket hauled out of the water and sediments discharged into the barge. Sealing the bucket prior to raising from the seabed limits the potential for dispersion of material and generation of suspended solids.
▪ Fill levels on the Hopper Barges employed the transfer of dredge material to sea will be closely monitored and recorded to prevent overloading or overflow of the barge, limiting the release of suspended solids into the water during loading and on voyage to the dump site.
▪ Overflow of dredge material from hopper barge during loading activities and on voyage to/from the disposal site is prohibited.
8.5 Noise & Vibration
8.5.1 Noise
There is potential for the noise environment of residents located in close proximity to Killybegs Harbour to be
impacted by construction activities. The most sensitive receptors considered to have a view of the harbour
development site are as follows:
▪ Residential properties on Fintra Road
▪ Killybegs Community Hospital
▪ Binroe Hamlet (North)
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▪ Binroe Hamlet (South)
The closest sensitive-receptor is a residential property on St Catherine’s Road, approximately 300m distance
from the harbour development. With reference to the AIRE, the noise limits at this property should not exceed
the following levels:
Day Time Period Noise Target (LAeq)
Monday to Friday
7am – 8am 70 dBA
8am – 6pm 75 dBA
6pm – 7pm 70 dBA
7pm – 10pm 65 dBA
10pm – 7am Not audible
Saturday 8am – 1pm 75 dBA
1pm – 2pm Not audible
Sunday N/A Not audible Note: A maximum noise limit of 75dB applies to all construction works on site and within the harbour.
Mitigation Measures
The only construction activity predicted to have any noise impact is piling in the evening period. This will be a
short-term activity and site operates will control this through restricted working hours.
▪ Good neighbour/tenant relations are recognised as an important factor in reducing nuisance.
▪ Selection of optimum technology for piling activities.
▪ ABCO will establish a project email address and phone line for engagement with local community during the project.
The works will be carried out in accordance with the general recommendations set out in BS 5228:1 2009 Code
of Practice for Noise Control on Construction and Demolition Sites.
Some of the best practice activities that will be adopted to minimise noise include:
▪ Ensuring where possible, that static items such as generators, are sited away from sensitive receptors and where necessary noise control means such as barrier, enclosures or silencers are utilised to further reduce noise;
▪ Limiting the hours of operation for specific pieces of equipment or operations, especially mobile sources operating through community areas;
▪ Reducing project traffic routing through community areas wherever possible;
▪ During the works, noise levels will be monitored when a new work item is stared;
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▪ All restrictions on noise imposed by Donegal County Council will be strictly complied with.
The main ongoing noise source will be the plant in operation. The following measures will be implemented to
reduce the effects of noise on site:
▪ Drop heights of materials will be minimised. In accordance with Best Practicable Means, plant and activities to be employed on site will be reviewed to ensure that they are the quietest available for the required use.
▪ Plant and equipment will be regularly maintained by trained personnel.
Electricity supply via ESB is available on site. It is unlikely that compressors will be required. In the unlikely
event compressors are required, the following will be implemented:
▪ Compressors will be silenced either by using fully silenced models fitted with effective exhaust silencers and properly lined and sealed acoustic covers or using effective acoustic screens to enclose the noise source.
▪ Compressors, silencers or other equipment will be maintained in good and efficient working order and will not be altered in such a way that the noise caused in operation is made greater by the alterations.
▪ Ancillary pneumatic percussive tools used on the site will be fitted with silencers of a type recommended by the manufacturers of the tools.
NOTE: ABCO will comply with any project specific restrictions. All noise levels relating to new works
activities will be recorded and reported to the Employers Representative on a weekly basis, or as required.
8.5.2 Vibration
A key risk of the works, particularly the rock breaking and piling activities, is the risk imposed on existing
structures within the vicinity of work such as the existing quay wall and Syncrolift located adjacent to the north
east corner of the site. Further, piling activities at the eastern section of site have been identified as having
potential to disrupt residential properties as well as buildings on site and within the immediate vicinity of the
harbour. Cosmetic damage may be possible to structures located 20m from piling activities, however at greater
distances damage is less likely to occur.
To mitigate against any potential damage caused by vibration, vibration monitors will be positioned on the end
of the Syncrolift and on the existing quay wall adjacent to the works, for the full duration of the piling and rock
breaking activities.
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 42 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
Figure 4 – Vibration Monitoring Locations
Monitors will provide real time data and have alerts set for the agreed limits of 5mm/s (intermittent) and
1.5mm/s (continuous), in accordance to BS5228. If these vibration limits are exceeded, activities will be ceased
immediately or altered so as to prevent damage to adjacent structures.
8.6 General Prevention of Spillage
As part of additional control measures, the dredging operation is planned to ensure that all reasonable care
will be taken that no materials or equipment will fall into the water. In the event that something unavoidably
falls into water, it will be recovered as soon as it is safe to do so.
Any leaks from mobile plant and equipment that comprise oil products will be cleaned away using absorbents.
An appropriate stock of absorbents should be maintained on-site and, in a location, accessible to all personnel.
However, after the use of the absorbent it will be stored in a temporary container until disposal to a licensed
landfill site.
All fuel storage tanks on-site will comply with Control of Pollution Oil Storage Regulations 2010. All fuel will be
stored in double bunded locked tanks, sited at least 25m from water.
All fuel transfer and plant refuelling operations shall be supervised, with Spill Kits, Drip Trays, Plant Nappies
and Secondary containment kit utilised were applicable. Onshore a designated refuelling area will be
established within the treatment works, in a controlled environment with spillage kits as required to prevent
entering the water body.
Vibration Monitoring
Control Point 1
Vibration Monitoring
Control Point 2
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 43 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
Routine maintenance and checks for all plant and machinery which form part of our Quality Management
Procedures will be carried out prior to deployment. All mobile plant will also be inspected daily by the plant
operator, with all records maintained within the site files.
All works will be carried out in accordance with the following Pollution Prevention Guidelines (PPGs) relating
to water quality. A review plan for the PPGs is currently underway, which will result in a replacement guidance
series, Guidance for Pollution Prevention (GPPs). The CEMP will be regularly reviewed and updated with any
changes in legislation and guidance. Referenced should be made to the following;
▪ PPG1 General Guide to the Prevention of Pollution
▪ PPG2 Above Ground Oil Storage Tanks [new GPP issued January 2017]
▪ PPG3 Use & design of oil separators in surface water drainage systems
▪ PPG5 Works in, Near or Liable to Affect Watercourses [new GPP issued January 2017]
▪ PPG6 Working at Construction and Demolition Sites
▪ PPG18 Managing Firewater and Major Spillage
▪ PPG21 Pollution Incident Response Planning [new GPP issued July 2017]
▪ PPG26 Storage and Handling of Drums and Intermediate Bulk Containers
8.6.1 Environmental Control within Laydown Areas
At all times, contractor’s laydown areas should be tidy up and clean, free from all hazardous substances which
has the potential of causing environmental. Storm water run-off containing fuel and lubricants will be
minimised, by following best practice and ensuring robust mitigation measures are in place, including a Spill
Response Plan and ensuring sufficient bunded areas for storage of hazardous substances are in place. This is
particularly important in the vicinity of the contractor’s laydown area; specifically the storage facilities, plant
and equipment parking area etc.
The laydown areas should be secured, fenced off to prevent unauthorised access. Additionally, storage areas
for hazardous substances shall be clearly marked. Work supervisors should always ensure and inquire that all
hazardous substances within the laydown and storage areas for fuel and other hazardous substances are
bunded correctly.
In addition, the vehicle refuelling location shall be strategically located, taking into consideration the
topographical nature of the area, preventing Storm water from returning spills to the water course
No leaks or spill will be considered as minor, due to the environmental sensitivity of the project site, therefore,
works supervisors should ensure full implementation of our spill response plan.
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ABCO No: C20196-MP-002- CEMP
Page : 44 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
9. INCIDENT PREVENTION AND EMERGENCY RESPONSE
In the event of an environmental incident resulting in harm/ potential harm to an any of the environmental
sensititives identified within this CEMP, ABCO will:
1. Identify the date, time and place of the incident;
2. As soon as practicable, notify the EPA and all other relevant bodies;
3. Carry out an investigation to identify the nature, course and cause of the incident and any impact
arising therefrom;
4. Isolate the source of any such impact;
5. Evaluate the pollution, if any, cause by the incident;
6. Identify and execute measures to minimise the effects thereof.
Please refer to Appendix 1 for the Accident Prevention Procedure.
9.1 Summary of Procedures to be followed in the Event of an Environmental Emergency
The methodology and mitigation measures set out in this CEMP will minimise the risk of an environmental
emergency or incident. If an environmental emergency occurs, the member(s) of staff involved in must
maintained active communication by contacting their supervisor immediately.
In the event of an incident the permit holder shall immediately: -
1. Identify the date, time and place of the incident
2. As soon as practicable notify the Agency, in a format prescribed, and other relevant authorities;
3. Carry out an investigation to identify the nature, source and cause of the incident and any impact arising therefrom;
4. Isolate the source of any such impact;
5. Evaluate the pollution, if any, caused by the incident; and
6. Identify and execute measures to minimise the effect thereof.
Prior to works commencement, an Emergency Plan will be prepared which will set out the procedures to be
followed in the event of an environmental emergency. Possible emergencies will be identified, taking into
consideration the causes, risks, locations or point sources related to the type of emergency referred to in the
Plan.
The following aspects will be considered:
▪ The activities to be performed and the construction methods used
▪ Raw materials, including their characteristics, storage conditions, and the quantities stored
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ABCO No: C20196-MP-002- CEMP
Page : 45 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
▪ Equipment and facilities, including consideration of the risk of leaks and spills, systems for the
transfer and handling of products, and the potential for the malfunction of detection systems
▪ Waste generated
The Emergency Plan will be circulated to all staff and will form part of the environmental site induction. As a
minimum, all personnel are required to satisfactorily complete the Project Induction.
All staff will be encouraged to report any incidents of non-compliance with the CEMP to their supervisor. The
Environment Team will investigate the incident and report on the findings, including any changes required to
working practices and/or staff training.
9.2 Environmental Complaints, Spills & Incidents
▪ Complaints received by the public or other interested parties as a result of the works must be
recorded on the Environmental Complaints/Spills/Incident Report. Refer to Appendix 3.
▪ Every effort should be made to establish the cause of the issue leading to a complaint/spill/incident.
Assuming the issue arose from the failure of a control system, the issue shall be put right at the
earliest opportunity. This should be logged within the project Environmental Complaints Log
(Appendix 4).
▪ The response action shall be recorded on the Environmental Complaints/Spills/Incident Report by
the Project Manager / H&S Manager / Environmental Manager.
▪ A log of all complaints/spills/incidents and follow-up actions should be kept and made available for
inspection.
▪ Environmental Complaints/Spills/Incident forms should be forwarded to the Project Manager,
Environmental Manager & QHSE Director who are responsible for investigating environmental
complaints.
▪ The Project Manager shall retain all records with relation to an environmental complaint/spill or
incident.
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 46 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
APPENDIX 1 – ACCIDENT PREVENTION PROCEDURE
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Title: ACCIDENT PREVENTION PROCEDURE
___________________________________________________________________________________
Section Ref: AB-QHSE-08 Date: 30/01/19 Revision: 1.0 Page: 1 Approved by: ABCO QHSE
___________________________________________________________________________________
1.0 PURPOSE
This procedure details the operational & organisational measures employed by ABCO so as to control and prevent accidents.
2.0 APPLICATION
This Procedure will be operated by ABCO Marine Ltd / ABCO Divers Ltd / ABCO Marine Ireland Ltd marine personnel and specialist subcontractors.
3.0 REFERENCES
ABCO Marine – H&S Policy AB-IMS08 Pre Contract Planning AB-IMS10 Mobilisation AB-IMS14 Inspection and Practical Completion AB-IMS16 Training, Awareness and Competence AB-IMS18 Identification of Health and Safety Risks and Environmental Aspects & Risks AB-IMS21 Legal and Other Requirements AB-IMS22 Incident Investigation AB-IMS23 Monitoring and Measuring AB-IMS24 Emergency Plans AB-IMS25 Waste Management P1-Quality Policy P2-HSW Policy P3-Environmnental Policy P4-First Aid Policy P5-PPE Policy AB-IMS12 Procurement of Subcontractor or Designers AB-QHSE-02 Risk Assessment Guidance AB-QHSE-04 Incident Investigation Procedure Environmental, Quality and Health and Safety Management System, ISO 14001, ISO 9001 and OHSAS 18001
4.0 CONTROL OF DOCUMENTS
All procedures and risk assessments are controlled in line with ISO:9001, ISO:14001 and OHSAS 18001.
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Title: ACCIDENT PREVENTION PROCEDURE
___________________________________________________________________________________
Section Ref: AB-QHSE-08 Date: 30/01/19 Revision: 1.0 Page: 2 Approved by: ABCO QHSE
___________________________________________________________________________________
5.0 SCOPE
This procedure applies to all employees, suppliers, contractors and visitors. It outlines ABCO’s overall aims and
principles of action with respect to the control and prevention of accidents on all metal recovery sites and any
environmental impact of accidents.
6.0 DEFINITIONS
Accident:
An unplanned event which results in death, ill health, personal injury or damage to health.
Incident:
An unplanned event which does not result in personal injury but does result in damage to equipment, environment,
plant or product.
An unplanned event which results in an impact or potential impact to the environment.
7.0 PROCEDURE
Accident:
An unplanned event which results in death, ill health, personal injury or damage to health.
7.1 ABCO operates an Integrated Management System (IMS) (ISO 9001, ISO 14001 & OHSAS 18001) in order to
manage quality, environmental and health & safety issues. The H&S policy statement and risk assessments form
an integral part of both the Integrated Management System and the Accident Prevention Procedure.
7.2 Control measures are implemented for all potential hazards identified via risk assessments and development of
safe systems of work. Procedures to support planning and management include, AB-IMS08 Pre Contract
Planning, AB-IMS10 Mobilisation and AB-QHSE-02 Risk Assessment Guidance.
7.3 All ABCO employees are appropriately trained in accordance with AB-IMS16 Training, Awareness and
Competence. AB-IMS16 stipulates that employee training will be reviewed and evaluated on an on-going basis
Training records are maintained electronically on the IMS database.
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Title: ACCIDENT PREVENTION PROCEDURE
___________________________________________________________________________________
Section Ref: AB-QHSE-08 Date: 30/01/19 Revision: 1.0 Page: 3 Approved by: ABCO QHSE
___________________________________________________________________________________
7.4 AB-IMS24 Emergency Plans and AB-IMS18 Identification of Health and Safety Risks and Environmental Aspects &
Risks Procedure sets out the actions to be taken in situations where there is an immediate risk to employee
health & safety or the environment.
7.5 In accordance with AB-IMS21 Legal and Other Requirements and P5-PPE Policy. PPE is supplied by ABCO to
employees at no cost to the employee. Minimum PPE to be worn on all ABCO sites includes Hard Hat, Hi-
Visibility Vest/Jacket, Gloves. Light Eye Protection and Safety Footwear. Additional items of PPE are required for
specific tasks. Failure to comply with company PPE requirements may lead to disciplinary action.
7.6 All accidents, incidents and near misses are reported to the QHSE Department and where necessary to external
bodies such as the HSE/HAS, MIAB or Local Authority. Reporting of incidents & accidents is detailed in AB-IMS22
Incident Investigation and AB-QHSE-04 Incident Investigation Procedure.
7.7 All accidents, incidents and near misses that occur within the ABCO group are recorded, each incident / accident
/ near miss is investigated, and appropriate control measures are implemented to prevent reoccurrence.
7.8 ABCO Safety Committee Meetings are conducted on a quarterly basis so that IMS issues can be identified and
discussed.
8.0 AMENDMENT HISTORY
Date Amendment
Number Page
Number New Issue
Comment Approved
By
30.01.19 1 ALL 1.0 Draft and Issue RMD
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 47 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
APPENDIX 2 – REGISTER OF ENVIRONMENTAL ACTIONS & COMMITMENTS (REAC)
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F8.10 Register of Environmental Actions Commitments (REAC)
Sub No. ReferenceDescription of Environmental Commitment/
Mitigation Action
Achievement Creiteria / Reporting
Requirement
Reference Document
(for futher information)Responsibility Status
Date
Completed Action By
1 EC 001 Provide CEMP, SWMPProduction of key environmental documentation to ensure ongoing environmetmal
protection in strict accordance with EPA DaS Permit and Planning Regsiter Document issue to Client (DAFM)
C20196-MP-002-CEMP
C20196-MP-010-SWMPABCO Ongoing
2 EC 002 Environmental SIte Induction
Environmental induction communicated to all personnel on site:
- The statutory consents associated with the Planning Conditions and Dumping at Sea
Permit & environmental sensitivities at the project site;
- Procedure for stopping works if activities do not comply with environmental legisaltion;
- Monitoring and reporting.
F3.11 Site Safety Induction signed and
stored within site filing system. Site register
updated daily following all project
inductions.
Site Register ABCO Ongoing
3 EC 003 Environmental Toolbox TalksDelivered on a regualr basis to reinforce and supplement information provided during
induction. Site Regsiter updated with all TBT's Site Register ABCO Not Started
4 EC 004 Compliance Document Review Fortnightly Review of SWMP
Monthly Environmental Audit C2016-MP-010-SWMP
ABCO/ Third Party
Environmental AuditerNot Started
5 EC 005
Ecological Management
Marine Mammals - Prevent risk to marine mammals as a
result of underwater noise/ construction activities
Marine Mammal Obserer employed for the project duration, to meet the monitoring and
reporting requirements of the National Parks and Wildlife Service;
Vessels not to travel greater than 5 knots;
All ducted propellers will be guarded.
Daily monitoring. Daily reporting forms
recorded.
Full reporting on MMO operations and
mitigation undertaken to be made to EPA
and [email protected] within 1 month of
campaign completion.
C20196-MP-002-CEMP
Permit Number S0028-01 (4.7)Marine Mammal Observer Not Started
6 EC 006
Ecological Management
Ecological Clerk of Works - To enusure integrity and
preservation of Natura 2000 sites and their qualifiying
interests
ECoW employed for the duration of the works to implament mitigation identified in CEMP. Daily inspection on site C20196-MP-002-CEMP ECoW Not Started
7 EC 007Archaeology & Cultural Heritage- Protect the
archaeological heritage of the area
Appoint a suitably qualified Archaeologist to monitor all works in compliance with the
requirements of the EPA Dumping at Sea Permit, Planning Permission 17/51385 and the
Underwater Archaeology Unit of Department of Culture Heritage and the Gaeltacht.
Daily inspection on site C20196-MP-002-CEMP
Permit Number S0028-01 Archaeologist Not Started
8 EC 008Air Quality - Reduce impacts from dust and emissions of
heavy construction machinery
Road sweeper to be utilised during dry conditions;
Hauliers to take approproate care and cover loads if necessary;
If dust whip is observed, suspended dust monitoring will be undertaken.
Emission limits of 50 micrograms per cubic -
24h average C20196-MP-002-CEMP ABCO Not Started
9 EC 009Landscape - Reduce visual impacts from construction
compound
Screening to be provided around the works compound to reduce impacts on surrounding
residents;
Construction lighting will be directed away from residental and busniess properties to
reduce the effect of light pollution;
Night time working will be minimisued to minimise light pollution from the works.
Daily inspection on site C20196-MP-002-CEMP ABCO Not Started
10 EC 010 Loading Activites
All efforts made to remove soild waste collected during loading. Soild waste brought
ashore.
Material passed though a 30x30cm grid to removed solid waste.
Archaeologist to monitor each bucket as it is lifted from the water and discharged into
Hopper Bage.
Daily dredge log C20196-MP-002-CEMP ABCO Not Started
11 EC 011Dumping at Sea - ensure compliance with dump at sea
permit S0028-01
No material will be dumped at sea that is considered unsuitable for disposal..
Automatic logging of each diposal activity,
Daily disposal log.
Logged vessel track record data collected
for each disposal event using IDS vessel
monitoring equipment
C20196-MP-002-CEMP
Permit Number S0028-01 ABCO Not Started
12 EC 012
Water Quality - Reduce the negative impact of dreding
activites on turbidity, suspended solids, dissolved oxygen
and plankton communities
Environemntal bucket used for all soft-sediment dredging.
Overflow during loading activites is prohibited.
Tubidity levels shall not exceed the prediected SS values detailed in the document
'Mathematical modelling of proposed dredge and spoil disposal operations for Killybegs
harbour development works '.
Monitoing results made available on site.
Monitroing report to be made available to
the Agency as part of ARE
C20196-MP-002-CEMP
Permit Number S0028-01 ABCO/ Client Not Started
Client
Project Name
Project Number
Register of Environmental Actions & Commitments (REAC)
Department of Agriculture, Food and the Marine (DAFM)
C20196
DAFM Killybegs Smoothpoint Pier Extension
Document: F8.10
Rev: 1.0
Date: 30/08/2019
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 48 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
APPENDIX 3 – DREDGE LAYOUT PLAN
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A B C D E F G H I J K L M N O P Q R S T U V X X
Dredge Pocketto -9m CD
Dredge Pocketto -7m CD
Exclusion zone
MLWS Contour = +0.60mCD
Line of buoys toshow exclusion zone
Alarm to be raised in wheel house of dredgershould bucket cross into exclusion zone
Indicative location of rock abovedesign level. Rock location to beconfirmed on site
Capall Mara excavating soft material into850m3 split hopper barge
850m3 split hopper barge
850m3 split hopper bargebeing towed to dump site
Ocean bank tug
Possible risk mitigation measurematerial to be dredged and broughtashore for testing and remediation
-2.20mCD contour.Dredging can only take place
at high water in this area toallow for draught of vessels
150.751m 63.593m
Rock armour to be removedby land marine
A A
Foyle barge for dredging
Syncrolift
Benchmark for daily bucketchecks to confirm accuracy ofGPS machine guidance system
Quay
Exte
nsion
Exist
ing Q
uay W
all to
be R
etaine
dLiv
e Ber
th to
be M
aintai
ned
Drawing Status
Scale at A1
Drawing No Issue
Drawing Title
Job Title
A1
1
2
3
4
5
6
7
8
9
10
11
A B C D E F G H I J K L M N
Do not scale
T1
1:500
Preliminary
E2538-AML-00-XX-DR-X-1001
Phase 2A Layout Plan
Contractor
Issue Date By Chkd Appd
/ /T1 15 05 19 PM JMcG JMcG
Tender Issue
ABCO Marine Ltd
ABCO House, 282 Moira Road, Lisburn, BT28 2TU
t +44 (0) 2892 622731
www.abcomarine.co.uk
Principal Contractor
Client
Killybegs Smooth Point Pier
Extension
Key:
Extent of soft material to be dredged to -9mCD
Extent of dredge pocket to be dredged to -7mCD
Extent of Dredge pocket to be graded to existingsurface level at a minimum 1:5 slope
Extent of dredge envelope to be graded to a level of-7mCD at a minimum 1:5 slope
Extent of Dredge pocket to be graded to existingsurface level at a minimum 1:4 slope
Extent of rock material in dredge envelope to begraded to existing rock surface level at 1:1 slope
Extent of dredge pocket to be removed and takenashore for testing
Extent of rock to be removed (data taken from March 2000 boreholes)
Barge Exclusion zone
MLWS Area at low tide access by land
-2.2mCD This area is subject to reduced accessdue to shallow draft
Proposed Line of buoys
Material to be removed to licensed facility
Tide Levels
MHWS = +4.10m CD MHWS = +1.76m ODMHWN = +3.00m CD MHWS = +0.66m ODMLWN = +1.50m CD MLWN = -0.84m ODMLWS = +0.060m CD MLWS = -1.74m OD
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 49 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
APPENDIX 4 - COMPLAINT/ SPILLS/ INCIDENT REPORT
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F8.7 Environmental Complaints / Spills / Incident Report
Document: F8.7 UNCONTROLLED WHEN PRINTED Page 1 of 1
Rev: 1.0
Date: 30/01/18
Project
(Title/Number)
Date/Time of Incident
What happened, nature of incident?
Did others witness the incident? If so who?
What caused it?
What measures have been taken to ensure it does not happen again?
Was there any significant pollution or environmental damage to land, water or protected areas – for example: dust,
odour or noise pollution outside the site or spillage of polluting liquids onto the ground, or into a drain or a watercourse?
If so what?
Is there a continuing threat? YES / NO
Circulate this form to ABCO Management & QHSE
Manager
Date Form was circulated?
Date Form was returned?
Please PRINT your
name & sign:
ABCO QHSE Review:-
Does the incident need to be the authorities? YES / NO
How (if required) was the incident reported?
Please PRINT your
name & sign:
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Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 50 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
APPENDIX 5 – COMPLAINT/ SPILLS/ INCIDENT LOG
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F8.8 Environmental Complaints / Spills / Incident Log
Document: F8.8 UNCONTROLLED WHEN PRINTED Page 1 of 1
Rev: 1.0
Date: 30/01/18
Reference Date Details of Incident
Named ABCO
person dealing
with issue
Action Taken Was the incident
reportable?
Follow up actions
if any?
Date issue
was closed
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EPA Export 26-05-2020:04:08:28
Construction Environmental Management Plan (CEMP)
ABCO No: C20196-MP-002- CEMP
Page : 51 of 51
DAFM Killybegs Smooth Point Pier Extension Issue: REV 002
Date: 27/09/2019
APPENDIX 6 - MARINE MAMMAL RECORDING FORM
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EPA Export 26-05-2020:04:08:28
F7.31 MMO Recording Form
Document: F7.31 UNCONTROLLED WHEN PRINTED Page 1 of 4
Rev: 1.0
Date: 30/01/18
MARINE MAMMAL RECORDING FORM - COVER PAGE Regulatory reference number (e.g. DECC no., BOEM permit no., OCS lease no., etc.)
Country Location Ship/ platform name Contract No:
Client
Contractor Survey type site VSP 2D WAZ 3D piling 4D explosives OBC other 4C
Start date End date
Number of source vessels Type of source (e.g. airguns)
Number of airguns (only if airguns used)
Source volume (cu. in.)
Source depth (metres)
Frequency (range in which peak
energy is emitted, in Hz)
Intensity (primary peak-to-peak
amplitude in dB re. 1µPa or bar metres)
Shot point interval (metres)
Method of soft start
increase number increase frequency increase pressure increase number increase number other of guns (where permitted) (where permitted) and frequency and pressure
Visual monitoring equipment used (e.g. binoculars, big eyes, etc.)
Magnification of optical equipment (e.g. binoculars)
Height of eye above water surface (metres)
How was distance of animals estimated?
by eye
with laser rangefinder
with rangefinder stick/ callipers
with reticle binoculars
by relating to object at known distance
other
Number of dedicated MMOs
Training of MMOs
JNCC approved MMO training course for UK waters
PSO training course for the Gulf of Mexico
MMO training course for Irish waters
MMO training course for New Zealand waters
other
none
Was PAM used?
yes no
Number of PAM operators
Description of PAM equipment
Range of PAM hydrophones from airguns (metres)
Bearing of PAM hydrophones from airguns (relative to direction of travel)
Depth of PAM hydrophones (metres)
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F7.31 MMO Recording Form
Document: F7.31 UNCONTROLLED WHEN PRINTED Page 2 of 4
Rev: 1.0
Date: 30/01/18
MARINE MAMMAL RECORDING FORM – OPERATIONS
Regulatory Reference Number ...............………………………………... Ship / Project Name ........................................................................... (e.g. DECC no., BOEM permit no., OCS lease no., etc.) Complete this form every time the airguns are used, including overnight, whether for shooting a line or for testing or for any purpose. Times should be in UTC, using the 24 hour clock.
Date
Reason for firing l = line t = test x = test
followed immediately by
line
Time soft start /
ramp-up began
Time of full power
Time of start of line
Time of end of line
Time of reduced
output (if relevant)
Time airguns/ source
stopped
Time pre-shooting
search began
Time search ended
Time PAM began
Time PAM ended
Dept range (during pre-
shoohting search)
s = <200m d = >200m b = both
Was it day or night in
period prior to firing?
d = day n = night w = dawn k = dusk
Was any mitigating
action required?
(yes/ no)
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EPA Export 26-05-2020:04:08:28
F7.31 MMO Recording Form
Document: F7.31 UNCONTROLLED WHEN PRINTED Page 3 of 4
Rev: 1.0
Date: 30/01/18
MARINE MAMMAL RECORDING FORM - EFFORT
Regulatory reference number ................………………………………... Ship/ platform name ........................................................................... (e.g. DECC no., BOEM permit no., OCS lease no., etc.)
Record the following for all watches, even if no marine mammals are seen. START A NEW LINE IF SOURCE ACTIVITY OR WEATHER CHANGES. ENTER DATA AT LEAST EVERY HOUR.
Date
Visual watch
or PAM (v/ p)
Observer's Name / Operator's Name
Time of start of section
of watch (UTC, 24hr
clock)
Time of end of section
of watch (UTC, 24hr
clock)
Source activity
(f/ s/ r/ n/ v)
Start position (latitude and longitude)
Depth at start (m)
End position (latitude and longitude)
Depth at end
(m)
Speed of
vessel (knots)
Wind dir’n
Wind force (B’fort scale)
Sea state
(g/s/c/r)
Swell (o/m/l)
Vis. (visual watch only)
(p/m/g)
Sun glare (visual watch only)
(n/wf/sf/vf/wb/sb/
vb)
Precip. (n/l/m/h/
s)
Visual watch or PAM: v = visual watch; p = PAM Source activity: f = full power; s = soft start; r = reduced power (not soft start); n = not active; v = variable (e.g. tests) Sea state: g = glassy (like mirror); s = slight (no/ few white caps); c = choppy (many white caps); r = rough (big waves, foam, spray) Swell: o = low (< 2 m); m = medium (2-4 m); l = large (> 4 m) Visibility: p = poor (< 1 km); m = moderate (1-5 km); g = good (> 5 km) Sun glare: n = none; wf = weak forward; sf = strong forward; vf = variable forward; wb = weak behind; sb = strong behind; vb = variable behind Precipitation: n = none; l = light rain; m = moderate rain; h = heavy rain; s = snow
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F7.31 MMO Recording form
Document: F7.31 UNCONTROLLED WHEN PRINTED Page 4 of 4
Rev: 1.0
Date: 30/01/18
MARINE MAMMAL RECORDING FORM – SIGHTINGS Regulatory reference number (e.g. DECC no., BOEM permit no., OCS lease no., etc.)
Ship/ Project Name Sighting number (start at 1 for first sighting of survey)
Acoustic detection number (start at 500 for first detection of survey)
Date
Time at start of encounter (24hr clock)
Time at end of encounter (24hr clock)
Were animals detected visually and/ or acoustically?
visual acoustic both
How were the animals first detected?
visually detected by observer keeping a continuous watch visually spotted incidentally by observer or someone else acoustically detected by PAM both visually and acoustically before operators/ observers informed each
other
Observer's/ operator's name
Position (latitude and longitude) Water depth (metres)
Species/ species group
Description (include features such as overall size; shape of head; colour and pattern; size, shape and position of dorsal fin; height, direction and shape of blow; characteristics of whistles/ clicks)
Bearing to animal (when first
seen or heard) (bearing from true north)
Range to animal (when first seen or heard) (metres)
Total number
Number of adults (visual sightings only)
Number of juveniles (visual sightings only)
Number of calves (visual sightings only)
Photograph taken yes no
Behaviour (visual sightings only)
Direction of travel (relative to ship)
towards ship variable away from ship milling parallel to ship in same direction as ship stationary parallel to opposite direction to ship other crossing perpendicular ahead of ship unknown
Direction of travel (compass points)
N W NE NW E variable SE stationary S unknown SW
Airgun (or other source) activity when animals first detected
full power not firing soft start reduced power
(other than soft start)
Airgun (or other source) activity when animals last detected
full power not firing soft start reduced power
(other than soft start)
Time animals entered mitigation/ exclusion zone (UTC, 24hr clock)
Time animals left mitigation/ exclusion zone (UTC, 24hr clock)
Closest distance of animals from airguns (or other source) (metres)
Time of closest approach (UTC, 24hr clock)
If seen during soft start give: First distance Closest distance Last distance during soft start (metres)
What action was taken?(according to requirements of guidelines/ regulations in country concerned) none required delay start of firing shut-down of active source power-down of active source power-down then shut-down
of active source
Length of power-down and/ or shut-down (if relevant) (length of time until subsequent soft start, in minutes)
Estimated loss of production (if relevant) due to mitigating actions (km)
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