Power Plants

Ireland in turn is then required to ‘provide an opportunity to the public in areas likely to be affected to participate in the Environmental Impact Assessment [EIA] procedures regarding proposed activities and shall ensure that the opportunity provided to the public of the affected Party is equivalent to that provided to the public of the Party of origin’.



The UK EIA states that the nuclear plant will not have any impact beyond the Severn Estuary on which it is located, in spite of the fact that simple modelling – and the Austrian Environmental Agency has done this [url below] show that any severe accident may cause transboundary impacts (e.g. radioactive contamination) if necessary measures are not implemented.



The issue here is anti or pro nuclear – simply the right to be consulted.



We are a small non–governmental environmental organisation that have established a complaint under this convention with the United Nations Compliance Committee which will be considered at a meeting in Geneva on 5 September, 2013, along with a similar complaint from a Member of the German Parliament on behalf of Germany.



We would urge you to place a motion before your council asking them to complain to the Espoo Convention Compliance Committee so that all of us may exercise our rights to public participation in a matter than could affect us all.



It is not possible for us to send to you by these mailing copies of all the documents, but they are freely available on our website by following the urls below.



The complaint form is very straightforward.



Respectfully yours,



Friends of the Irish Environment

Contact: Tony Lowes 027 74771 /087 2176316



URLS

FIE submission to Espoo Compliance Committee

http://www.friendsoftheirishenvironment.org/cmsfiles/Library/Espoo-complaint-and-supplementary-25.03.13.pdf



Austrian Environmental Agency Maps of possible contamination

http://flexrisk.boku.ac.at/en/results.html





Friends of the Irish Environment



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All Ireland



Right to be consulted over new UK Nuclear Plant

FIE is calling for Bord na Mona to use the present shutdown of its peat fired plants as an opportunity of switching to biofuels. Bord na Mona has ordered the new 'state of the art' power plant at Lanesboro closed after evidence of corrosion was found on turbine pipes. The new companion plant at Shannonbridge is expected to follow.

Peat is the dirtiest fuel of all in CO2 emissions and Ireland's use of it as a fuel is environmentally indefensible. Even before the pollution from burning the fuel, the harvesting releases greenhouse gases. It is contrary to sustainable development and will contribute to global warming. These plants were opposed by the Organisation for Economic Cooperation and Development and by our own Economic and Social Research Institute, as well as by this organisation in the High Court, all unsuccessfully.

The corrosion that has arisen from the burning of peat is due to the nature of the fuel. The ionised bed system in use at both Lanesborough and Shannonbridge is the same technology that could be used for the incineration of any material, including locally grown biomass.

Every user of electricity in Ireland is paying surcharge on his bill for these peat fired plants through a PSO [public service obligation] charge on their ESB bill. These subsidies should be used to generate clean green energy.

SEARCH OUR SITE FOR MORE...
FIE is calling for Bord na Mona to use the present shutdown of its peat fired plants as an opportunity of switching to biofuels. Bord na Mona has ordered the new 'state of the art' power plant at Lanesboro closed after evidence of corrosion was found on turbine pipes. The new companion plant at Shannonbridge is expected to follow.

Peat is the dirtiest fuel of all in CO2 emissions and Ireland's use of it as a fuel is environmentally indefensible. Even before the pollution from burning the fuel, the harvesting releases greenhouse gases. It is contrary to sustainable development and will contribute to global warming. These plants were opposed by the Organisation for Economic Cooperation and Development and by our own Economic and Social Research Institute, as well as by this organisation in the High Court, all unsuccessfully.

The corrosion that has arisen from the burning of peat is due to the nature of the fuel. The ionised bed system in use at both Lanesborough and Shannonbridge is the same technology that could be used for the incineration of any material, including locally grown biomass.

Every user of electricity in Ireland is paying surcharge on his bill for these peat fired plants through a PSO [public service obligation] charge on their ESB bill. These subsidies should be used to generate clean green energy.

SEARCH OUR SITE FOR MORE...
The project promoters did not consider any location other than the site that they are now proposing. They informed us of this fact at a meeting in June. They believed that they could use the existence of a 2MW Combined Heat and Power plant which was auxiliary plant to the dairy operations of Waterford Foods as justification for the construction of the proposed 105MW power station. This attitude ignored the fact that the auxiliary CHP was redundant the moment that Waterford Foods/Glanbia ceased it's dairying manufacturing operations and this 2MW Combined Heat and Power plant did not have an existence in it's own right.
DUNGARVIN POWER PLANT

LOCATION.


The project promoters did not consider any location other than the site that they are now proposing. They informed us of this fact at a meeting in June. They believed that they could use the existence of a 2MW Combined Heat and Power plant which was auxiliary plant to the dairy operations of Waterford Foods as justification for the construction of the proposed 105MW power station. This attitude ignored the fact that the auxiliary CHP was redundant the moment that Waterford Foods/Glanbia ceased it's dairying manufacturing operations and this 2MW Combined Heat and Power plant did not have an existence in it's own right.


An alternative location widely spoken of in the town would be one in close proximity to the existing

110kV substation at Killadangan, approximately three miles outside the town, beside which is located Radley Engineering giving this location an existing industrial character.


This alternative location would avoid the necessity of the construction of a 3km overhead 110kV power line which is currently a cause of dispute with the affected landowners.


It should also be noted with regard to the former Glanbia site, that the IDA have expressed absolutely no interest in developing any part of it. The IDA has recently acquired 26 acres outside the town to add to it's landbank.





The eastern part of the Waterford Foods site, including the CHP site, adjacent to Davitt's Quay, Grattan Square, and O'Connell Street, had blocked the natural expansion of the town centre for over 60 years. In 1998,with the cessation of manufacturing activity, the possibility of fulfilling it's natural function in accommodating the expansion of the town centre arose.


Looking at Davitt's Quay, TF Meagher Street, Grattan Square and O'Connell Street; the development on those streets took place in the 18th and 19th centuries. There has been no expansion of the town centre in the 20th century due mainly to dairy manufacturing activities to the west of Grattan Square and to the north of O'Connell Street over the greater part of the century. Indeed one street, Davis Street, built in the 19th century, was cleared of it's inhabitants and it's residential nature obliterated in the mid-sixties to accommodate the building of a grain silo and a provender mill adjacent to the street.


The recent renewal of residential activity in Davis Street, based on government infill housing policy in the mid 1990's, is in stark contrast to the proposal to build a power station less than 80 metres away. The residential nature of lands im- Mediately to the west of the proposed power station as advocated in the Dungarvan Draft Development Plan, 2,000, is also in stark contrast to the proposed power station. See attached map.






VISUAL BLIGHT.


The visual blight which accompanied the dairy manufacturing business of Waterford Foods was tolerated by the residents of the town in the interest of many hundreds of jobs at a time when jobs were hard to come by and peoples' expectations of the built environment were less than they are now. In the year 2,000, the number of jobs on offer in this venture is negligible in a town of this size; expectations of the built environment have changed since the 1960's. The visual blight in such a prominent position on the bypass will detract from the town's picturesque estuarine setting; running counter to Dungarvan's role as a tourist gateway to the Southeast and to the mountain ranges of the Comeraghs and the Knockmealdowns. See enclosed submission from An Taisce and enclosed submission from Councillor Damien Dillon who is also a local architect.



EFFECTS ON RESIDENTS

The increased nitrous oxide levels resulting from this plant, (250 tonnes per annum), in particular those associated with the existence of a chimney in the vicinity of neighbouring high buildings will lead to added pressure on the respiratory systems of those, particularly children and the elderly, living in the vicinity of the power station. The 2MW CHP operated on oil. The developers of the current proposed plant intend to use 7,000 tons of oil EACH YEAR ! (Dr. John O'Shea, who was upto recently Chairperson of Dungarvan Energy Holdings Ltd., commissioned the former 2MW CHP plant of Waterford Foods in 1984 !)



Waterford Foods/Glanbia ceased all manufacturing activities on the site in 1998. All the industrial buildings are due to be demolished and a new town centre to be created. A planning application for a shopping centre has been lodged, (21st July, 2,000), adjoining the southern boundary of the proposed power station site. Up to 500 parking spaces plus through traffic from a new roundabout on the by-pass will avail of this proposed shopping centre. The additional nitrous oxides and particulate matter resulting from this increased traffic in a residential area should be taken together with the output from the proposed power station. In the applicant's submission to the Environmental Protection Agency, they make repeated assertions that the plant on it's own will not breach guidelines or limits for nitrous oxides. However, the plant would not exist in isolation and it's contribution to an increasing nitrous oxides load in existing residential areas of the town cannot be taken in isolation. See enclosed letter from Professor Henshaw.


Dungarvan is built on the banks of the estuary of the Colligan river. It is situated between two rivers, with Dungavan Bay on the eastern edge of the town. The Drum hills bound the valley to the south with the Comeragh foothills bounding the valley to the north. The climate is cold and damp for much of the year and on cold winter nights a blanket of smog hangs over the town. A river fog suspended over the town is a regular feature of the town of Dungarvan. What chemical compounds will result when the plume of hot nitrous oxides exiting the stack of the proposed power station is mixed with the moisture laden air of these fogs ? Nitrous oxides are composed of NO and NO2; can anybody predict that we will not be subject to NO3 suspended in this fog ?


The pollutants from the proposed power-station would be additional to those of other industries in the town, Waterford Glass, Smithklime Beecham, as well as the pollutants from traffic and domestic heating. See letter from Professor Henshaw.


I have serious concerns about the noise of the proposed power station. My home is approximately 100 metres from the proposed site. The previous 2MW CHP was a constant source of noise caused by steam release and daily operational activities. My young family's sleep was continuously interrupted by the aforementioned almost nightly, as well as the nuisance of same during the day. I enclose letter from Councillor Damien Dillon and two letters from

Laurence O'Connor, Senior Environmental Health

Officer with the South Eastern Health Board which also express similar concerns.


The conditions attached to the 1982 planning permission for the erection of the C.H.P. plant included amongst others, conditions intended to avoid nuisance to residents from noise and emissions. Both the operators of the plant and the supposed enforcers of the conditions, (local authority), honoured these two conditions more in the breach than in the observance.


Also see quote from High Court, Maher v An Bord Pleanala, Justice Kelly applied a purposive approach in interpreting of one of the thresholds laid down in the First Schedule to the EIA Regulations. In so doing, he observed that the EIA regulations fell to be interpreted in accordance with the underlying purpose of Council Directive 85/337:

" Directive 85/337 proceeds on the basis that the best environmental policy consists in preventing the creation of pollution or nuisance at source, rather than trying to counteract their effects. It affirms the need to take effects on the environment into account at the earliest possible stage in all the technical planning and decision making processes. It recites that it necessary to achieve one of the Community's objectives in the sphere of the protection of the environment and the quality of life. It goes on to point out in the recital that the general principles for the assessment of environmental effects should be introduced with a view to supplementing and co-ordinating development consent procedures governing public and private projects likely to have a major effect on the environment. The recitals to the directive also provide that the development consent

for public and private projects which are likely to have a significant effect on the environment should be granted only after prior assessment of the likely significant environmental effects of these projects has been carried out. It also provides that the effects of a project on the environment must be assessed in order to take account of concerns to protect human health, to contribute by means of a better environment to the quality of life, to ensure maintenance of the diversity of species and to maintain the reproductive capacity of the ecosystem as a basic resource for life. "


HEALTH RISKS, EMF AND AIR POLLUTION

There are increasing international concerns amongst scientists and the public regarding the effects on public health of electric magnetic FIElds. The ESB in it's policy statement state that they follow the advice of the WHO and the ICNIRP, (World Health Organisation, and the International Commission on Non-Ionising Radiation Protection). It should be noted that numerous countries, Russia, Hungary, China, Italy and most recently Switzerland have rejected the advice of the WHO and the ICNIRP in setting limits for their populations for exposure to electric magnetic radiation. The FOEFL, the Swiss government department with responsibility for protecting public health, stated in a letter that the ICNIRP guidelines, (which are the same as the WHO recommendations), are not sufficient to protect public health during chronic exposure. The precautionary approach would suggest that this proposed power station be sited in a remote location away from built up areas. I note that the Porvoo facility held up as an example by the project promoters is located in a forest outside Helsinki and not in the centre of the city !


See enclosed letter from Professor Henshaw as printed in the IRISH TIMES.



ENVIRONMENTAL IMPACT STUDY.


No environmental impact study/assessment was

provided by the promoters of this project. Indeed when one looks at the information required by an EIS one can understand their unwillingness do so.


BOILER CAPACITY

The promoters of the project have made much of the existence of the C.H.P. plant on the site of the proposed power-station. The C.H.P. plant's primary purpose was to provide large volumes of steam for the dairy manufacturing process of Waterford Foods. The 2MW electricity generation was a minor consideration in the operation. What is the thermal input capacity of the boiler in the existing C.H.P. plant? Has the E.P.A. ascertained this capacity ? I ask this in specific relation to Annex 2 to the E.E.C. Council Directive, 85/337/EEC of 27th June 1985. There are also four oil-fired boilers in the Niro buildings on site which were used to provide steam in conjunction with the output from the C.H.P. plant. What is the heat input capacity of these boilers? What is the combined thermal input capacity of the C.H.P. Boiler AND the four Niro boilers? Has the E.P.A. ascertained these values? I ask this in specific relation to Annex 2 of the Directive.



WATER ABSTRACTION/DISCHARGES.

In a submission to An Bord Pleanala, Mr. Brian Meehan, on behalf of the project promoters, claims on page 3 that the operation will abstract water at the rate of 130 tonnes per hour from the local acquifer; some 3,120 m3/day or in excess of 1,100,000 m3/year.

This volume of water is greater than 50% of the amount abstracted by the local authority to supply the town of Dungarvan.

In the details submitted to the E.P.A. with regard to discharges from the power station, the combined daily discharges do not amount to the figure of 3,120 m3/day. How are these two sets of figures to be reconciled?


PROXIMITY TO S.P.A.

The aerial photograph supplied shows the proximity of the proposed power station to the existing S.P.A. and proposed N.H.A.



1. Existing thermal input capacity of CHP boiler and four Niro boilers? Unknown. If 300MW or above then it is covered by Annex 2 of the European Council Directive. ( Annex 2 of European Council Directive, 83/337/EEC of 27th June, 1985.)

2. Thermal input capacity of proposed power station? - 230 MW. In answering the question posed by the E.PA. regarding the thermal input capacity of the proposed power station, the promoters of the project proceeded thus. Working from the stated maximum output capacity, ( 120MW ), they worked backwards using

an efficiency figure of 53-55% to arrive at a thermal input capacity of approximately 230 MW. The promoters have answered a question but not necessarily the question that they were asked, which was "what is the thermal input capacity of the plant" and not "what is the thermal input requirement to operate the generators which they intend to install in this phase of the project". The question "what is the thermal input capacity of the plant" would be accurately answered by specifying the capacity of the boiler to be installed.

To illustrate this point, I forward you a copy of a letter written in support of the proposed power station, printed in today's local paper, 11/10/2,000. See below.














3. Extraction of water from the aquifer. The promoters' figure > 1,100,000 m3/ year. Extraction of water from an aquifer falls under Annex 2. The threshold is 2,000,000 m3/year.

4. Approximately 3 miles of overhead 110kV line. Annex 2, it falls below voltage and distance thresholds.

5. Approximately 40 kilometres of gas pipeline. Annex 2, depending on pipeline pressure may or may not fall below relevant threshold.

6. Adjacent/adjoining SPA but not located in SPA. See aerial photograph.


This is a substantial project comprising of several component parts; thresholds may not be reached for each individual component of the project but the European Court in it's September 1999 Judgement, (Commission V Ireland, 392-96), has ruled against splitting a project into component parts or phases, which are individually below relevant thresholds, so as to avoid an E.I.S. of the project taken as a whole.



It should be noted that under a recent European Court judgement given in September 1999, (Commission V Ireland, 392 - 96,) states that "… by setting thresholds for the classes of projects covered by points 1(d) and 2(a) of Annexe 2 to the Directive without also ensuring that the objective of the legislation will not be circumvented by the splitting of projects, Ireland has exceeded the limits of it's discretion under Article 2(1) and 4(2) of the Directive."

Though this development is of a class belonging to Annex 1 of the Directive, the application of the logic and spirit of the European Court's ruling to this project would indicate the necessity for an Environmental Impact Study/Assessment.


During a meeting with the project developers it was indicated that further developments would take place on the power station site though the specific nature of the developments was not revealed. The construction of a gas pipe-line from Clonmel to power this plant plus the large scale of competing power stations under development ranging from 300MW to 600MW output power would suggest to me that this proposed development of 120MW output cannot remain at such a low capacity and be commercially competitive with the larger power stations.




The application of the 1999 Statutory Instrument, No. 93, First Schedule, Section 13, (copy enclosed), should the operators of the plant wish to increase the capacity of the plant by an additional 50 MW output, they could do so without being subjected to an EIS. With an output of 150 MW the plant would have a thermal input power of approximately 300 MW. The plant could be developed in instalments and because of the 1999 SI's and the setting of thresholds, a 300 MW power station, or greater would never be subjected to an EIS. The setting of thresholds and the use of regulations such as this to circumvent the need for an EIS is contrary to both Council Directive 85/337/EEC of 27th June, 1985 and European Court Judgement 392 - 96, delivered on the 21st September, 1999, copy enclosed.


This current development has been spilt into five component elements and there are more than five planning applications for this project;

1. Power station,

2. 110kV overhead power line, (Waterford County Council and Dungarvan U.D.C.,)

3. switching bay at Killadangan,

4. 110kV switchyard within the power station

5. the gas pipe line, (not yet applied, Tipperary County Council, Waterford County Council and Dungarvan U.D.C.).

European Court judgement 392 - 96 also states that project splitting is not allowed.


The proposed power station is likely to have a significant effect on the environment. The proposed

power station would be located in a densely populated area. Furthermore, Duchas in a submission to the EPA, is concerned about the serious ecological consequences for Dungarvan estuary resulting from the large volumes of warmed cooling water, over 3,000 tons per day, that would be discharged to the estuary.

Duchas also point out the following,

The promoters of the power station also state that "there are no areas in the vicinity of the site that have been designated Special Areas for Conservation under the Habitats Directive 79/409 EU."

Dungarvan Bay is itself a SPA. See aerial photograph.


In the enclosed letter, Duchas also points out that the power station promoters state that "there are no areas in the vicinity of the site that have been designated as a Special Area for Conservation under the Habitats Directive 79/409 EU."

Duchas warns of the effect of the power station on the Comeraghs, a designated Special Areas of Conservation, and the acid soil ecosystem of same.


I ask that the Environmental Protection Association seek an Environmental Impact Study/Assessment on the basis that now is the appropriate time to consider all the aspects of this development and not at a later date when the operators would use existing investment and employment as leverage to increase the capacity of the plant, arguing commercial viability as their justification. Council Directive 85/337/EEC of 27th June 1985, page 1 and 2 states "that the best environmental policy consists in

preventing the creation of pollution or nuisances at source, rather than subsequently trying to counteract their effects; whereas they affirm the need to take effects on the environment into account at the earliest possible stage in all the technical planning and decision-making processes; whereas to that end, they provide for the implementation of procedures to evaluate such effects;" Also see quote from High Court, Maher v An Bord Pleanala, Justice Kelly applied a purposive approach in interpreting of one of the thresholds laid down in the First Schedule to the EIA Regulations. In so doing, he observed that the EIA regulations fell to be interpreted in accordance with the underlying purpose of Council Directive 85/337:

" Directive 85/337 proceeds on the basis that the best environmental policy consists in preventing the creation of pollution or nuisance at source, rather than trying to counteract their effects. It affirms the need to take effects on the environment into account at the earliest possible stage in all the technical planning and decision making processes. It recites that it necessary to achieve one of the Community's objectives in the sphere of the protection of the environment and the quality of life. It goes on to point out in the recital that the general principles for the assessment of environmental effects should be introduced with a view to supplementing and co-ordinating development consent procedures governing public and private projects likely to have a major effect on the environment. The recitals to the directive also provide that the development consent

for public and private projects which are likely to have a significant effect on the environment should be granted only after prior assessment of the likely significant environmental effects of these projects has been carried out. It also provides that the effects of a project on the environment must be assessed in order to take account of concerns to protect human health, to contribute by means of a better environment to the quality of life, to ensure maintenance of the diversity of species and to maintain the reproductive capacity of the ecosystem as a basic resource for life."

The case Commission v Ireland, judgement of 21st September, 1999, (paragraphs 66 and 67), reaffirms the duty on member states to ensure that projects that have significant effects upon human beings, fauna and flora and soil, water, air, climate and landscape are made the subject of an Environmental Impact Assessment, even where they fall below the thresholds laid down in Annex 2 of Council Directive 85/337.




It is understandable that Dungarvan Urban District Council, for financial motives would encourage the presence of a large and long-term source of rates' funding in the urban area. The Urban District Council suffered a serious financial set-back to it's finances when Glanbia ceased it's manufacturing facility. It lost rates payments of approximately £300,000 per annum. The existing IDA estate lies outside the Urban District Council boundary and the rates payment from this IDA estate goes to Waterford County Council.



FIRE RISK / EXPLOSION


The site of the proposed power station lies in a dip; there is a proposed shopping centre adjoining the proposed power station with numerous homes adjacent to it. Further residential development is proposed even closer to the proposed power station. See enclosed copy of map from Dungarvan Draft Development Plan, 2,000.

Should anything go wrong with the proposed power station, the danger and the disruption will be greatly magnified because of it's location adjacent to residential areas. If the power station were alternatively located at Killadangan, the risk would be much smaller.

On Wednesday, 26th January, 2,000, part of the former Waterford Foods site was set alight accidentally. The fire raged for half an hour until it ran out of fuel; because of the size of the buildings and their location and layout, the local fire brigade tenders were unable to get close enough to dampen the fire. The fire ran it's course and as you can see from the photograph, covered the town in a pall of black smoke of unknown constituents. See article and photograph over.

The location of a potential hazard such as the proposed power station in a residential area does not allow for worst case analysis.

Fires are not unknown in this type of plant and have shown to be extremely difficult for emergency fire services to contend with.


EXISITING POLLUTION ON SITE.


I would also like to point out that the site survey carried out on behalf of the developers show the existence of large amounts of chromium in soil samples taken from the site. I also have contact with one individual who contracted anthrax while working in a water filled trench on this particular site. It should be noted that the current site was previously used as a dumping ground for tannery waste from the local tannery industry and as a general dump for the town over a fifty year period.



Colette OConnell,

COMMUNITIES AGAINST MICROWAVE RADIATION

4, Davis Street,

Dungarvan,

Co. Waterford.

Tel 058 41910 after 9 p.m.

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