ABPsubm, Air Quality, I.Shanahan, CSRPlanners PDF

tms
environment ltd
TMS Environment Ltd
53 Broomhill Drive
Tallaght
Dublin 24
Phone: +353-1-4626710
Fax: +353-1-4626714
Web: www.tmsenv.ie
AIR QUALITY IMPACT ASSESSMENT OF

PROPOSED NATIONAL CHILDRENS HOSPITAL
AT ST JAMESS HOSPITAL CAMPUS, JAMESS STREET, DUBLIN 8
AIR QUALITY SUBMISSION
PREPARED FOR
THE JACK & JILL FOUNDATION
Report Ref 22577

01 October 2015
Dr Imelda Shanahan
Air Quality Impact Assessment for the proposed National Childrens Hospital
TMS Environment Ltd
Table of Contents
Executive Summary
1.0
Introduction and scope
2.0
The development proposal
3.0
Impact assessment approach
10
4.0
The receiving environment
12
4.1
Meteorological data for the air quality impact assessment
12
4.2
Baseline air quality in the receiving environment
19
5.0
Air quality impact assessment
34
5.1
Potential air quality impacts
34
5.2
Air Quality Standards and impact assessment criteria
41
5.3
Prediction and evaluation of Construction Phase impacts on air quality
45
5.3.1 Potential Construction Phase air quality impacts

5.3.2 Dust from general construction
5.3.3 Aspergillus emissions
5.3.4 Construction vehicle emissions
5.3.5 Drimnagh Sewer relocation
5.3.6 Emissions associated with demolition works
5.3.7 Emissions of hazardous substances from excavation in contaminated ground
5.3.8 Observations on the impact assessment approach adopted in the EIS
5.4
Prediction and evaluation of Operation Phase air quality impacts
55
5.4.1 Potential Operation Phase air quality impacts

5.4.2 Traffic emissions
5.4.3 Energy Centre emissions
6.0
Conclusions
69
Report Ref 22577 Page 2 of 69
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Executive summary
This air quality impact assessment report was prepared on behalf of the Jack & Jill
Foundation for the proposed development of a national childrens hospital at the site of the
existing hospital at St Jamess Hospital Campus, Jamess Street, Dublin 8. The Charitys
position is that they do not object to the principle of a childrens hospital but they are very
firmly of the view that this is an entirely inappropriate location for a national childrens
hospital for a number of reasons including air quality. Our brief is to evaluate the air quality
aspects of the proposal and to advise on the suitability of the proposed location for the
childrens hospital in terms of existing and future air quality impacts. The concerns of the
Jack & Jill Foundation relate solely to proposals for the St Jamess Hospital Campus and our
report therefore focuses only on this element of the application.
In our assessment, our objective is to challenge the air quality impact assessment of the
development proposal as presented in the EIS in Chapter 12 Air Quality and Climate. The
approach that we have adopted for the assessment is to carry out a complete assessment of
the air quality impact of the proposal and to then compare our independent assessment
findings with those presented in the EIS. We seek to provide a rigorous assessment of the
methodologies adopted in the EIS, the findings of the impact assessment and the
conclusions drawn and therefore aim to provide An Bord Pleanala with a robust assessment
of air quality aspects of the proposed development from the perspective of the most
important stakeholders, Irelands sick children.
The approach to the assessment is described in detail in this report and is summarised as
follows:
Characterise the receiving environment in terms of baseline air quality and

meteorological conditions which have the potential to influence the dispersion of
pollutants and therefore the air quality impact of, and on, the proposed
development;
Identify the likely and possible air quality impacts of Construction and Operation
Phases of the proposal;
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Carry out a quantitative assessment of the potential air quality impacts of the
proposal, benchmarking the assessment against Air Quality Standards and Guidelines
formulated for the protection of human health, amenity and the environment;
Evaluate the overall air quality impact of the proposal and advise on the suitability
of the site for the proposed development proposal.
A comprehensive assessment was carried out and the main findings are presented in this
report. It is clear from this report that there are differences in the methodologies adopted
by the EIS Team and ourselves in some aspects of the air quality impact assessment. As a
result of the work undertaken, we are concerned that the air quality impact assessment
presented in the EIS understates the potential air quality impacts of the proposal. The
principal concerns are summarised as follows.
(i) Baseline air quality in the receiving environment is representative of the city centre
location of the proposed development and is strongly influenced by traffic and by
emissions from commercial and industrial activities in the area. The baseline air quality
against which future impacts are predicted does not consider this and is understated in
the EIS, having selected data that is representative of the wider Dublin area rather than
the specific location where the development is proposed. Baseline air quality is poorer in
the proposed location than almost anywhere outside the city centre, which is not
surprising given the influence of emissions from traffic on air quality in the area. There is
therefore limited assimilative capacity available in the receiving environment to
accommodate any significant developments and especially developments as significant,
and as uniquely sensitive, as the proposed childrens hospital and future maternity
hospital.
The approach followed in Chapter 12 of the EIS is to select a single set of baseline air
quality data to represent air quality at St Jamess, Tallaght and Blanchardstown. This is
inappropriate in my opinion and leads to an underestimate of the existing level of
pollutants in ambient air at St Jamess. The most seriously ill children will spend time in
the proposed childrens hospital at St Jamess and sick children will spend longer in this
location than either of the satellite centres. It is therefore very important that a reliable
statement of baseline air quality specifically for the St Jamess campus is formulated. It is
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an over-simplification to consider the three sites together and the assumption that the
same data set reliably describes baseline air quality at each site is an understatement of
baseline conditions at St Jamess.
(ii) Construction Phase air quality impacts will be significant and will endure for four years.
The impacts have the potential to significantly impact on the existing St Jamess hospital
as outlined in this report and will require a reliable and extensive Air Quality
Management Plan to accompany any such construction programme. Even with extensive
and effective management and control measures, there are significant risks associated
with the emissions of hazardous substances during construction. The assessment of
Construction Phase traffic impacts appears not to have considered Heavy and Light
Goods Vehicle (HGV and LGV) movements associated with construction, at least not on
the site, and therefore these impacts are understated.
(iii) Operation Phase air quality impacts of the proposal are extremely significant and this
report has shown that the EIS very significantly understates the potential impacts. The
most significant Operation Phase impacts on air quality are associated with emissions
from the Energy Centre that is planned to meet the significant energy requirements of
the combined existing and proposed development. The energy requirements of the site
will more than double for the proposed childrens hospital, and future expansion of the
childrens hospital and the maternity hospital would more than treble the energy
requirements of the campus. This means that the emissions to atmosphere associated
with the Energy Centre would at least double for the proposed childrens hospital and
increase by at least 300% for the future expansion phase and inclusion of the maternity
hospital; and this does not take account of the required future expansion and
development of the adult hospital at the site. Emissions to atmosphere from the Energy
Centre could be even higher if the use of diesel oil as the primary fuel rather than
natural gas is required as highlighted, but not evaluated, in the EIS.
(iv) Air Quality Standards are referenced throughout the EIS but the World Health
Organisation Guidelines are not specifically referenced in the EIS. While the WHO
Guidelines are not mandatory, they represent current informed opinion on the levels to
which we should be aspiring in order to minimise adverse health impacts of air pollution.
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Since the proposed development of a National Childrens hospital will cater for sick
children with compromised immune systems and limited ability to cope with additional
stresses such as air pollution, it is prudent to consider the WHO Guidelines as well as the
mandatory Air Quality Standards for the purpose of this assessment. These guidelines
have not been formally considered in the EIS but this assessment report does consider
the Guidelines.
(v) The release of hazardous substances including toxic and hazardous pollutants and
Aspergillus spores during construction activity are specific potential impacts which were
not quantitatively assessed in the EIS. This assessment does consider these factors and
determines that significant risks are associated with such releases.
(vi) Emissions from the most significant Operational Phase emissions source, the Energy
Centre, have been understated in the EIS thus leading to an understatement of potential
air quality impacts. Some of the most significant concerns relate to the following:
Only 10 emissions sources were modelled for the Energy Centre although the EIS
states that more than this is required.;
not all emission parameters were included in the modelling eg PM10, PM2.5, CO
and SO2 were not included in the assessment;
the significant variation in emissions with the different fuel types was not
evaluated;
the magnitude of the emissions that were considered is underestimated;
the impact of nitrogen oxides (NOx) from the Energy Centre on the Grand Canal
proposed Natural Heritage Area (pNHA) has not been assessed.
(vii)
The air quality impact predictions carried out for this report show that much higher
impacts are predicted than those given in the EIS. For nitrogen dioxide, the predicted
ambient concentration will be 80% of the Air Quality Standard for just the childrens
hospital and the existing facility which means that there is little or no assimilative
capacity remaining for further expansion or other developments in the area.
(viii)
The use of the National Roads Authority Guidelines for the Treatment of Air Quality
During the Planning and Construction of Major Road Schemes for the impact
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assessment is inappropriate. While this is an excellent methodology for assessing the air
quality impact of major road schemes, there are very significant differences between the
construction of a road scheme and a fixed construction site such as the site of the
proposed Childrens hospital at St Jamess Street. The methodology does not allow a
reliable assessment of all of the potential construction phase impacts.
One of the most significant differences between the construction of a road scheme and
the proposed Childrens hospital is that for a road scheme, the construction site moves
regularly and therefore the areas where air quality impacts are observed also vary with
time. For the proposed Childrens hospital, the construction site stays the same, in a
relatively confined space (relative to a road scheme) and therefore the air quality
impacts are more localised than they would be for a road scheme. For the proposed 4year construction programme, air quality impacts will be experienced over a relatively
small localised area and these impacts will be more intense and concentrated than for
shorter duration programmes on sites where the construction activity is moving
regularly. I believe the methodology adopted has underestimated the potential impacts
of the construction phase of the proposed development due to the significant
differences between a road scheme and a fixed construction site in a confined area.
The comprehensive dispersion modelling impact assessment carried out for this assessment
report has led to significantly higher predicted impacts than those presented in the EIS. The
modelling results suggest that there is insufficient assimilative capacity in the proposed city
centre location to ensure that air quality standards are not exceeded as a result of the very
significant emissions that will be released from the Energy Centre for the combined
activities on the site. The results further suggest that when the significantly higher emissions
associated with the expansion of the proposed childrens hospital and the future maternity
hospital are considered, Air Quality Standards could be exceed as a result of the emissions.
This leads to the conclusion that the proposed city centre location is not a suitable location
for the proposed development. Areas removed from the city centre with lower baseline air
pollutant concentrations would have greater assimilative capacity and would be more
suitable from air quality impact considerations than the proposed city centre location.
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1.0
Introduction and scope

We have been instructed by the Jack & Jill Foundation to prepare an assessment of
the air quality impact of the proposed development of a national childrens hospital
at the site of the existing hospital at St Jamess Hospital Campus, Jamess Street,
Dublin 8.
The Charitys position is that they do not object to the principle of a childrens
hospital but they are very firmly of the view that this is an entirely inappropriate
location for a national childrens hospital for a number of reasons including air
quality. They believe that the new hospital will fail to meet the needs of Irelands
sickest children due to the unsuitability of the proposed location and they are
concerned that this once-in-a-lifetime opportunity to provide for the current and
future needs of our countrys sickest children will not achieve the best possible
outcome. The Foundation are uniquely positioned to make this assessment, and we
support the Charity in their effort to secure the best possible future care for sick
children in Ireland.
Our brief is to evaluate the air quality aspects of the proposal and to advise on the
suitability of the proposed location for the childrens hospital in terms of existing and
future air quality impacts. In our assessment, our objective is to challenge the air
quality impact assessment of the development proposal as presented in the EIS in
Chapter 12 Air Quality and Climate. We seek to provide a rigorous assessment of the
methodologies adopted in the EIS, the findings of the impact assessment and the
conclusions drawn and therefore aim to provide An Bord Pleanala with a robust
assessment of air quality aspects of the proposed development from the perspective
of the most important stakeholders, Irelands sick children.
The concerns of the Jack & Jill Foundation relate solely to proposals for the St
Jamess Hospital Campus and our report therefore focuses only on this element of
the application. We have no comments to make on the other two elements of the
proposal unless such comments are required to support the assessments made in
respect of the St Jamess hospital campus site.
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2.0
The development proposal

The project is described in detail in Chapter 2 of the EIS, and includes a number of
development features. The main project site is located on the campus of St Jamess
Hospital Dublin 8 and includes the new childrens hospital and Family
Accommodation Unit which are located in the west of the campus, the proposed
Childrens Research and Innovation Centre sited along Jamess Street and a
construction compound at Davitt Road which is directly associated with the
developments at the St Jamess Hospital Campus. There are also ancillary works
associated with the above main development features.
The key elements of the proposed development which require assessment in respect
of potential air quality impacts during both construction and operating phases are as
follows:
Demolition of all buildings on the site of the new childrens hospital, Family
Accommodation Unit and proposed Childrens Research and Innovation
Centre;
Construction of a new childrens hospital building and associated helipad;
Construction of two level underground car park with a further level of shared
facilities management hub and energy centre below;
Construction of the Childrens Research and Innovation Centre;
Construction of a Family Accommodation Unit;
Public realm improvements including existing campus spine road, demolition

of 2 no. buildings and relocation of parking to accommodate same;
Improvements to the road junction at the existing campus entrance on St

Jamess Street and a new campus entrance piazza from Brookfield
Road/South Circular Road, with minor improvements to these roads;
A new vehicular entrance from Mount Brown;
A realigned internal campus road;
A new shared flue stack for the campus;
a range of infrastructure works, including the diversion of the existing

Drimnagh Sewer and revised boundary treatments.
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In line with standard practice and best practice guidelines, there is a requirement to
evaluate the impact on air quality of all aspects of the Construction and Operation
Phases of the development proposal and this report presents such an assessment. In
this report we set out our assessment methodology and the findings of our own
independent assessment of the air quality impacts of the proposed development.
Where differences between our findings and those of the EIS Team are identified
these are highlighted in the report.
3.0
Impact Assessment Approach

The general approach to air quality impact assessment follows the scheme outlined
in Figure 1.
Figure 1
Air quality impact assessment approach
Assessment
Baseline
Characterise emissions & potential impacts

Map topography, Site layout, Receptors
Characterise the receiving Select Meteorological data
environment
Choose Background Air Quality data
Air Quality Standards, Impact assessment criteria
Scoping
Predict and evaluate impact
Identify & rank emission sources & issues Formulate Management Plans and solutions
Map Construction Impacts
Map Operation Impacts
The assessment follows a well-established path through the identification and

characterisation of the air quality impacts that must be addressed, characterisation
of the receiving environment to benchmark the existing situation, quantitative
prediction of air quality impacts and assessment of the impacts against recognised
Air Quality Standards and Guidelines. From this assessment comes a definition of the
Management Plans and environmental solutions that are required to ensure that all
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aspects of the impacts of the development proposal through Construction and
Operation Phases are managed and controlled to protect human health, the
environment and amenity. It is clear that if this sequence is not thoroughly and
robustly executed, then the Management Plans and environmental solutions for any
problems identified during the assessment cannot be formulated to guarantee the
effective management of air quality impacts.
Chapter 12 of the EIS for the National Paediatric Hospital Project describes an
assessment of the likely air quality & climate impact of the proposed development.
Section 12.1.2 of the EIS sets out the methodology that was adopted for the air
quality and climate impact assessment as follows:
1. Characterise the receiving environment through detailed analysis of EPA
data;
2. Determine appropriate criteria for evaluating the significance of air
quality and climate impacts through reference to local guidance
documents where applicable and international best practice;
3. Calculate the potential air quality & climate impacts using industry
standardised calculation methods;
4. Assess the impact by comparing the calculated levels against the adopted
criteria;
5. Where necessary specify ameliorative, remedial or reductive measures to
control the impacts to be within the adopted criteria, and;
6. Present the predicted impact of the proposed development including the
ameliorative, remedial or reductive measures.
I concur with the choice of general approach and methodology adopted in the EIS for
the air quality impact assessment, but I am concerned that some aspects of the
specific methodologies adopted do not provide a robust assessment of the actual
and potential air quality impacts of this significant development proposal. I will
follow the same general assessment approach in this assessment report, carrying out
my own assessments and quantitative prediction of impacts, and I will highlight the
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differences in opinion and / or findings in each section of this report. I am not
concerned with the Climate impact assessment and do not refer to it in this report.
4.0
The receiving environment
4.1
Meteorological data for the air quality impact assessment

The magnitude of potential impacts of any proposed development on air quality will
be influenced by the local meteorological conditions, in particular by wind speed and
direction and by precipitation rates. An evaluation of the meteorological conditions
at the site is therefore required to assist in the assessment of air quality impacts.
Furthermore, modelling or quantitative predictive studies that are employed in the
air quality impact assessment require that representative meteorological data is
selected and used for the assessment. It is therefore very important that
representative meteorological data is selected for the assessment.
The general guidance on selection of meteorological data for air quality impact
assessments is to choose representative data, recently acquired, which best
represents conditions at the site. At least three years of recently acquired data is
preferred. Met ireann operate a Synoptic Network of weather stations at Belmullet,
Malin Head, Rosslare, Birr, Clones, Kilkenny and Mullingar while the Aviation Division
of Met ireann maintains observing stations at Shannon Airport, Knock Airport,
Casement Aerodrome, Dublin Airport and Cork Airport. Data from one of these
stations is likely to be representative of conditions at the site for modelling and
impact assessment purposes.
There is no continuous meteorological monitoring station located uniquely close to
the site of the proposed development, but comprehensive monitoring data is
available for Dublin Airport (approximately 10 km north-east of the site) and
Casement Aerodrome (approximately 10km southwest of the site) which would be
indicative of the meteorological conditions that are experienced at Jamess Street.
Casement Aerodrome may experience different conditions due to the complexity of
nearby terrain so Dublin Airport data is preferred. It is therefore recommended that
recent data from Dublin Airport is selected for the assessment.
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Wind speed and direction in particular is important in determining how emissions,
especially those from tall stacks such as the flues from the proposed Energy Centre,
are dispersed. The prevailing wind direction determines which areas are most
significantly affected by the emissions from the activity and wind speed determines
in part the effectiveness of the dispersion of the emissions. It is instructive to
examine a selection of the meteorological data from the two stations to illustrate
how the data may vary. Figure 2 shows a windrose for Casement Aerodrome for
2010 and one for Dublin Airport for 2010.
Figure 2
Windroses for Casement Aerodrome and Dublin Airport for 2010
Casement Aerodrome (2010)
Dublin Airport (2010)
It is clear from the windroses that there are some differences in the pattern of wind
speed and wind direction for the two locations. The dominant wind direction for
Casement Aerodrome is from the southwest, whereas the dominant wind direction
for Dublin Airport is from the west. For Casement Aerodrome, the wind speed is
below 5.14m/s for 71% of the time whereas for Dublin Airport this percentage
reduces to 64%. The average long-term wind speed for Casement Aerodrome over
the period 1985 2010 is approximately 5.5 m/sec and the average wind speed for
Dublin Airport for the same timeframe is 5.3m/sec. This limited analysis of the data
suggests that (a) the location of maximum predicted impact is likely to vary for the
two data sets, especially for averaging intervals other than annual, and (b) more
effective dispersion and therefore lower ground level concentrations of pollutants
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may be predicted using Dublin Airport data compared to that for Casement
Aerodrome data.
In view of the likely sensitivity of the air quality impact predictions to the choice of
meteorological data, it is prudent to consider the sensitivity of any impact
predictions to the selection of input data such as meteorological data and therefore
it is appropriate to select three years of recent data from each of the two available
representative datasets and to evaluate the effect of any variations in the data on
the impact predictions. The worst-case data set would then generally be chosen for
the assessment unless some other consideration dictates a specific choice.
Variations of 10 30% in the magnitude of impact predictions for different
meteorological data sets are expected. The sensitivity analysis whereby different
data sets are considered in the assessments is especially important when the
predictions indicate a potentially significant impact, when any air quality standard is
predicted to be approached or when significant uncertainties exist in the other data
sets used for the assessment.
The choice of meteorological data is supported by previous studies for large-scale
developments in this area. The adjacent Diageo complex at St Jamess Gate operates
under the terms of an Industrial Emissions (IE) Licence from the Environmental
Protection Agency (Licence Reg No. 301-041) and this licence was reviewed in 2015
with the current revised licence issued on 12th August 2015. This significant industrial
facility is licenced for the following categories of activity:
Combustion of fuels in installations with a total rated thermal input of 50

MW or more,
The treatment and processing, other than exclusively packaging, of the

following raw materials, whether previously processed or unprocessed,
intended for the production of food or feed from: (ii) only vegetable raw
materials with a finished product production capacity greater than 300
tonnes per day.
Accessible for download at http://www.epa.ie/licences/lic_eDMS/090151b28054ed9e.pdf (accessed 26

September 2015)
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In April 2015, Diageo applied to the Environmental Protection Agency (EPA) for a
review of their IE Licence to address a number of changes which included installing a
new fourth roasting plant to augment the existing three roasting plants at the site; a
new (fourth) afterburner will also be installed to treat the emissions to atmosphere
from the roasting plant. The roast-house is located on the upper level of the site (to
the south of James's Street) adjacent to St Jamess Hospital and the four significant
roast-house afterburner emissions flues are located less than a kilometre away from
the proposed flues for the St Jamess Energy Centre as shown in Figure 3. The Diageo
Energy Centre, with 5 large CHP Boilers catering for the facility is located on the main
Diageo Campus and those flues are approx. 2km from the proposed flues at the St
Jamess Energy Centre.
Figure 3
Proximity of Diageo Roast House and Energy Centre to St Jamess
Hospital Energy Centre
Approximate distance from St Jamess

Energy Centre to Diageo Energy Centre 2km
Distance from the Energy Centre

flues to the Guinness Roast
House approx. 915m
The Application to the EPA for a review of the IE Licence for the significant Diageo
industrial facility was accompanied by a significant number of reports including a
dispersion modelling assessment of air quality impacts of the existing and proposed
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emission points2. This report also selected meteorological data from Dublin Airport
for the assessment of air quality impacts at the St Jamess Gate Diageo complex. The
report was reviewed and accepted by the EPA which indicates that the choice of
meteorological data was appropriate for this site and assessment.
Section 12.1.2.4 of the EIS, prepared by AWN Consulting, describes the Receiving
Environment in terms of meteorological data and the existing ambient air quality.
The report notes that the nearest representative weather station collating detailed
weather records is Casement Aerodrome which is located approximately 10km
southwest of the main St Jamess site. The report also notes that five years of recent
representative data from 2007 2011 is used in the main impact assessment. The
EIS Chapter took the approach that one data set would be chosen to represent
conditions at each of the three sites in St Jamess Street, Tallaght and
Blanchardstown, and chose Casement Aerodrome meteorological data to represent
the meteorological conditions at each of the three sites. For the reasons noted
above, we recommend that both Casement Aerodrome and Dublin Airport
meteorological data should be used for the assessment, with Dublin Airport being
the preferred primary data set and Casement Aerodrome data used for sensitivity
analysis.
It is especially important that cumulative impacts of emissions from the most
significant emissions sources associated with the proposed Childrens Hospital, the
Energy Centre flues, and the very significant emissions from the adjacent Diageo
Energy Centre and Roast-house afterburners are carefully evaluated. The same
meteorological dataset should therefore be used to ensure that the dispersion of
emissions from all these sources is affected in the same way by the meteorological
data and that therefore cumulative impacts are assessed.
Appendix 12 of the EIS contains a report by Arup Engineers on An Air Dispersion
Modelling Assessment to support the New Flue Design for the Energy Centre at the
St Jamess site. This report surprisingly uses meteorological data for a different
meteorological station for the dispersion modelling assessment from the main
2
Accessible for download at http://www.epa.ie/licences/lic_eDMS/090151b28052e22c.pdf (accessed 26

September 2015)
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report, Dublin Airport rather than Casement Aerodrome, and furthermore uses older
and unrepresentative data from 2000 to 2004. There is no discussion presented in
the EIS Chapter or in the Arup report as to why this significant discrepancy arose and
why out of date meteorological data was used for the assessment.
The best practice Guidance on dispersion modelling in Ireland is the publication by
the Environmental Protection Agency Air Dispersion Modelling from Industrial
Installations Guidance Note (AG4) which is widely used in Ireland in Air Quality
Impact Assessment studies of the type under consideration here. This Guidance Note
(hereafter referred to as AG4, available at web address below3) stipulates at Section
6.1 (Page 23) that:
It is recommended that a minimum of three years of meteorological data
from an appropriate meteorological station should be used in the assessment.
Furthermore, the most recent year of the data set used should have been
compiled within the last ten years.
The selection of meteorological data for the Energy Centre dispersion modelling
assessment that supported one of the most significant aspects of the proposal in
terms of air quality impact assessment therefore does not conform with best
practice guidance since the most recent year of meteorological data is 11 years old
and falls outside the recommended time period.
The significance of this can be considered by examining the difference in distribution
of wind speeds for different years for Dublin Airport. The most recent year of
meteorological data used in the EIS was 2004 and the windrose for Dublin Airport for
2004 is compared in Figure 4 with that for Dublin Airport for 2010. The most
significant difference between the two data sets is the distribution of wind speeds
with high wind speeds greater than 5.14m/sec observed for 49.2% of the time in
2004 and only 35.8% of the time in 2010. Very high windspeeds greater than 10.8
m/sec occurred for 18% of the time in 2004 and only 7.2% in 2010. The same pattern
is observed for the other years of data used in the EIS compared to the more recent
data. This significant difference in the distribution of windspeeds in the older
3
http://www.epa.ie/pubs/advice/air/emissions/airdispersionmodellingfromindustrialinstallationsguidancenote
ag4.html#.VgLqm42FPIU (accessed 24 September 2015)
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meteorological data could lead to a significant understatement of ground level air
quality impacts. In our dispersion modelling assessment we have used the more
recent years of meteorological data as a more reliable indicator of meteorological
conditions to provide a robust assessment of potential air quality impacts.
Figure 4
Windroses for Dublin Airport for 2004 and 2010
The failure to conform to best practice guidance is disappointing and has

underestimated the impact of the emissions from the Energy Centre on ambient air
quality in the vicinity of the site and/or at locations removed from the site. The
significant height of all flues (53m above ground level according to the EIS) indicates
that the emissions are significant and that very tall stacks were required to ensure
effective dispersion of emissions. Considering the significance of the emissions it is
therefore even more important that reliable and representative meteorological data
is used for the assessment.
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4.2
Baseline air quality in the receiving environment

The St Jamess Hospital campus is located in the city centre in an urban area. The
dominant influences on air quality in the area are emissions from commercial energy
and heating sources, domestic heating, traffic and emissions from any industrial
activities in the area. Emissions from the existing Energy Centre, the emissions from
other combustion sources in the area such as the Diageo facility, and traffic are
expected to be the principal contributors to ambient air quality in the vicinity of the
site. These sources are also expected to be the dominant contributors to air quality
in the areas where the greatest potential off-site impact of emissions from the
facility, including the proposed Energy Centre, are predicted.
The main substances which are of interest in terms of existing air quality are sulphur
dioxide, nitrogen oxides (nitric oxide, NO and nitrogen dioxide NO 2, collectively
referred to as NOx), particulate matter including PM10 and PM2.5 which could
originate from combustion sources, traffic and the existing commercial and industrial
activities in the area. Carbon monoxide is also potentially of interest due to the
expected significant emissions from the St Jamess and Diageo Energy Centres and
traffic, and benzene may also be of interest from traffic sources. There are no
significant new or additional substances expected to be present in emissions
released from the proposed development relative to the existing facility but a
significant increase in emissions is predicted.
A description of existing levels of the various substances in ambient air is required to
allow completion of the evaluation of air quality impacts associated with the
development. The available data from the National Ambient Air Quality Network is a
reliable data set for consideration in this study.
The Environmental Protection Agency (EPA) and local authorities maintain and
operate a number of ambient air quality monitoring stations throughout Ireland in
order to implement EU Directives and to assess the countrys compliance with
national air quality standards. Irelands small population and generally good air
quality means that a relatively small number of monitoring stations are sufficient
across the country for the purposes of implementing the EU Air Directives. For
ambient air quality management and monitoring in Ireland, four zones, A, B, C and D
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are defined in the Air Quality Standards (AQS) Regulations (S.I. No. 180 of 2011) and
are defined as follows:
Zone A:
Dublin Conurbation.
Zone B:
Cork Conurbation.
Zone C:
24 cities and large towns. Includes Galway, Limerick, Waterford,

Clonmel, Kilkenny, Sligo, Drogheda, Wexford, Athlone, Ennis, Bray,
Naas, Carlow, Tralee, Dundalk, Navan, Newbridge, Mullingar,
Letterkenny, Celbridge and Balbriggan, Portlaoise, Greystones and
Leixlip.
Zone D:
Rural Ireland, i.e. the remainder of the State excluding Zones A, B &C.
The St Jamess Street site is considered to be located in Zone A and is Urban. Air
Quality Data from representative air monitoring stations in Zone A that are
designated Urban Stations is therefore considered representative of air quality at the
St Jamess Hospital site. The EPA publishes Ambient Air Quality Reports every year
which details the air quality in each of the four zones. The most recent report,
published by the EPA in 2014, is the Air Quality Monitoring Annual Report 2013,
which contains monitoring data collected during 2013. Best practice requires that an
average of at least three years of recent monitoring data is used for assessments of
this type so data for 2011 2013 has been reviewed4.
The EPA maintains monitoring stations in a number of areas to monitor urban and
suburban background air quality as well as some traffic-oriented monitoring stations.
The urban background monitoring station is in Rathmines and suburban monitoring
stations are located in Dun Laoghaoire, Blanchardstown, Swords and, after
refurbishment, Ballyfermot; the Blanchardstown Station is a traffic-oriented
monitoring station. The Urban Traffic oriented monitoring stations are at Winetavern
Street and Coleraine Street. Other monitoring stations have operated at various
times and some new stations have been added to the network, but long term data is
available for the above stations.
4
EPA, "EPA Ireland Archive of Nitrogen Oxides Monitoring Data". Datasets Available At: Secure Archive For
Environmental Research Data managed by Environmental Protection Agency Ireland
http://erc.epa.ie/safer/resource?id=216a8992-76e5-102b-aa08-55a7497570d3 (Last Accessed: 2015-0925)
TMS Environment Ltd
Data from the Air Quality Monitoring Annual reports for 2011, 2012 and 2013 was
reviewed and a summary of the data for representative stations for the three most
recent years is presented for each parameter of interest in Tables 1a 1g of this
report. The most representative data set is chosen for each parameter as noted in
the Tables.
In particular it is noted that wherever available, data from the designated Urban
monitoring stations is chosen as this would best describe the existing ambient air
quality in the urban St Jamess Street location. There are urban monitoring stations
located at Rathmines, Winetavern Street and Coleraine Street as shown in Figure 5.
The Rathmines station is oriented towards monitoring background urban
concentrations whereas the Winetavern Street and Coleraine Street stations are
traffic oriented stations.
Figure 5
Air Quality monitoring locations relative to St Jamess Hospital

Coleraine Street Air Quality
Monitoring Station
Winetavern Street Air Quality

Monitoring Station
St Jamess Hospital Campus
Rathmines Air Quality

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

the city centre and therefore we recommend that the urban Traffic data should be
chosen because air quality in the St Jamess Street location is significantly influenced
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by traffic. Traffic is one of the significant potential impacts identified in the EIS and
most of the impact assessment is directed at the impact of emissions from traffic
associated with the development on air quality.
The approach followed in Chapter 12 of the EIS is to select a single set of baseline air
quality data to represent air quality at St Jamess, Tallaght and Blanchardstown. This
is inappropriate in my opinion and leads to an underestimate of the existing level of
pollutants in ambient air at St Jamess. The most seriously ill children will spend time
in the proposed childrens hospital at St Jamess and sick children will spend longer
in this location than either of the satellite centres. It is therefore very important that
a reliable statement of baseline air quality specifically for the St Jamess campus is
formulated. It is an over-simplification to consider the three sites together and the
assumption that the same data set reliably describes baseline air quality at each site
is an understatement of baseline conditions at St Jamess.
As noted above in section 4.1, an application in April 2015 by Diageo to the EPA for a
review of the IE Licence for the significant Diageo industrial facility was accompanied
by a significant number of reports including a dispersion modelling assessment of air
quality impacts of the existing and proposed emission points5. That report also
selected the monitoring data from Coleraine Street and Winetavern Street
monitoring stations to describe the existing baseline air quality in the vicinity of this
application site. The report was reviewed and accepted by the EPA which indicates
that the choice of baseline air quality data was appropriate for this site and
assessment. There is therefore an established precedent for the description of
baseline air quality in this area and the monitoring data from Winetavern Street and
Coleraine Street is recommended as a reliable statement of baseline air quality for
the area.
A summary of the baseline air quality data is presented in Tables 1a to 1g below
together with the data selected in the EIS. All of the data chosen in the EIS for the
assessment is annual mean data despite the fact that there are other Air Quality
Standards that require consideration, and this is of concern and is discussed below.
5
Accessible for download at http://www.epa.ie/licences/lic_eDMS/090151b28052e22c.pdf (accessed 26

September 2015)
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The actual data selected in the EIS for the annual mean concentration of each
parameter of interest as shown in Tables 1a to 1g below is based on an average of a
number of stations for 3 to 5 years, rounded up and then projected forward from
2013 to 2015 as the baseline data year. This is a conservative and prudent approach,
which we agree with in principle. However, we do not agree with the selection of
stations for averaging which are a mixture of urban and suburban stations and we
do not agree with the approach of choosing a single data set to represent air quality
in the very different locations of Tallaght, Blanchardstown and St Jamess.
The approach we have taken is to take the average of the three most recent years
(2011 2013) for each of the designated Urban stations in Winetavern Street and
Coleraine Street and the average of the values for the two stations are reported in
Tables 1a to 1g. This is the data set which we use in our assessment of the potential
impact of the proposed development on air quality.
We have also taken the average of the data for each of the years 2011 2013 for
Rathmines and summarised this data in Tables 1a to 1g. These values agree well
with the values selected in the EIS. In our opinion, the EIS data set underestimates
the baseline air quality in the St Jamess street area and consequently use of the data
leads to an understatement of the potential impacts of the proposed development
on air quality.
It is noted that the EIS gives a baseline concentration of nitrogen oxides (NO x) of
34.6g/m3 without explaining where this data was derived from. Table 1b shows the
EPA monitoring data for nitrogen oxides and the annual mean for the urban
background station agrees well with the value quoted in the EIS.
Tables 1a to 1g also show the average data for the traffic orientated monitoring
stations in Dublin City. In my opinion this data accurately and representatively
describe the baseline air quality at the St Jamess Hospital campus. When the
contributions from traffic to the ambient air quality are considered, the baseline
concentrations increase relative to the background urban values. The baseline data
is then 43% higher for NO2, 67% higher for NOx and 12.5% higher for PM10. These are
the significant pollutants for this impact assessment. The significance of this finding
is discussed further below. A graphical presentation comparing the data selected in
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the EIS with that chosen in this assessment report is presented in Figure 6 below. For
the most significant pollutants, Nitrogen dioxide and Nitrogen Oxides (NO 2 and NOx)
the EIS data is significantly lower than the data recommended in this assessment
report.
Figure 6
Comparison of baseline air quality data from EIS and TMS

EIS
TMS
EU Air Quality Standard
WHO Guideline
60
50
40
30
20
10
0
NO2
NOx
PM10
PM2.5
SO2
Benzene
A concise summary of the data presented in Tables 1a to 1g is presented in Table 2

below to allow ready comparison with Table 12.10 in the EIS; a graphical
presentation is given in Figure 6 to show the existing air quality relative to Air Quality
Standards and WHO Guidelines. In summary, there is a very significant difference
between the baseline data used in the EIS and that quoted here which includes the
contributions from traffic. Given the city centre location of the St Jamess campus
and the strong traffic influences on air quality, we are concerned that the EIS has
understated the baseline concentrations and may therefore have significantly
understated the potential impact of the proposed development.
It is noted that the existing air quality in respect of both NO 2 and PM10 is
approaching the WHO Guideline value and the existing air quality for PM 2.5 exceeds
the WHO Guideline. As noted earlier, the WHO Guideline is not a mandatory value.
However the unique sensitivity of the proposed development suggests that
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particular attention is focused on ensuring that the proposed childrens hospital is
located in an area where the best possible air quality is experienced.
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Table 1a
Background air quality data for St Jamess Street Hospital Site (Nitrogen Dioxide, NO2)
Station
Rathmines
Urban Background
Dun Laoghaoire
Suburban Background
Blanchardstown
Suburban traffic
Winetavern Street
Urban including traffic
Coleraine Street
Averaging Interval
2011
2012
Annual Mean, g/m3

Max 1-hour, g/m3
1-hour > 200 g/m3 (Days)
Annual Mean, g/m3
Max 1-hour, g/m3
Annual Mean, g/m3
Max 1-hour, g/m3
Annual Mean, g/m3
Max 1-hour, g/m3
Annual Mean, g/m3
Max 1-hour, g/m3
20
118
0
18
127
0
31
209
1
34
181
0
26
167
0
21
138
0
18
135
0
30
194
0
29
136
0
26
142
0
Urban Background[1]
Selected data set
Urban including Traffic
NOTE
[2]
2013
19
107
0
26
123
0
29
154
0
31
158
0
26
118
0
Annual Mean, g/m3
Max 1-hour, g/m3
Average
20
121
0
21
129
0
30
186
0
31
158
0
26
142
0
20
121
EIS
22.7
Annual Mean, g/m3 28.5

Max 1-hour, g/m3 150
[1] Rathmines data unless otherwise stated

[2] Average of the urban traffic oriented sites
TMS Environment Ltd
Table 1b
Background air quality data for St Jamess Street Hospital Site (Nitric Oxide and Nitrogen Dioxide, NOx)
Station
Averaging Interval
2011
2012
2013
Average
Rathmines
Urban Background
Annual Mean, g/m3

Max 1-hour, g/m3
32
776
31
811
28
668
30
752
Dun Laoghaoire
Suburban Background
Annual Mean, g/m3

Max 1-hour, g/m3
29
613
30
560
27
424
29
532
Blanchardstown
Suburban traffic
Annual Mean, g/m3

Max 1-hour, g/m3
71
1227
63
909
62
1006
65
1047
Winetavern Street
Annual Mean, g/m3

Max 1-hour, g/m3
61
1241
51
888
50
1209
54
1113
Coleraine Street
Annual Mean, g/m3

Max 1-hour, g/m3
49
1376
43
857
46
1000
46
1078
Urban Background[1]
Annual Mean, g/m3 30

Urban including Traffic[2]

Selected data set
NOTE
EIS
34.6

TMS Environment Ltd
Table 1c
Background air quality data for St Jamess Street Hospital Site (Particulate Matter, PM10)
Station
Averaging Interval
2011
2012
2013
Average
Rathmines
Urban Background
Annual Mean, g/m3

24-hour mean > 50 g/m3 (days)
16
10
14
8
17
8
16
9
Dun Laoghaoire
Sub-urban Background
Annual Mean, g/m3

15
11
12
1
17
5
16
9
Phoenix Park
Suburban background
Annual Mean, g/m3

12
3
11
0
14
3
12
2
Blanchardstown
Suburban traffic
Annual Mean, g/m3

16
11
No data
No data
20
11
18
11
Winetavern Street
Annual Mean, g/m3

14
7
13
0
14
3
14
3
Selected data set

NOTE
Urban Background [1]
Urban including Traffic [2]
EIS
17.7

TMS Environment Ltd
Table 1d
Background air quality data for St Jamess Street Hospital Site (Particulate Matter, PM2.5)
Station
Averaging Interval
2011
2012
2013
Average
Rathmines
Urban Background
Annual Mean, g/m3

Max 24-hour g/m3
12
60
11
57
11
76
11
64
Coleraine Street
Urban Background
(traffic)
Annual Mean, g/m3

Max 24-hour g/m3
11
87
10
31
11
62
11
60
Marino
Suburban background
Annual Mean, g/m3

Max 24-hour g/m3
9
68
8
35
9
55
9
46
Urban Background[1]

Max 24-hour g/m3 64

Max 24-hour g/m3 60
Selected data set

NOTE
EIS
12.3

TMS Environment Ltd
Table 1e
Background air quality data for St Jamess Street Hospital Site (Sulphur Dioxide, SO2)
Station
Averaging Interval
2011
2012
2013
Average
Rathmines
Urban Background
Annual Mean, g/m3
Annual Mean, g/m3
Annual Mean, g/m3
Annual Mean, g/m3
Winetavern Street
Urban background
(traffic)
Coleraine Street
Urban background
(traffic)
Tallaght
Suburban
background
Selected data set
NOTE
Urban Background[1]
Annual Mean, g/m3 2
Annual Mean, g/m3 1
EIS
None

TMS Environment Ltd
Table 1f
Background air quality data for St Jamess Street Hospital Site (Carbon Monoxide, CO)
Station
Averaging Interval
2011
2012
2013
Average
Winetavern Street
Urban Background
(traffic)
Annual Mean 8-hour, g/m3

Max 8-hour, g/m3
100
900
100
1400
0
2400
67
1567
Coleraine Street
Urban Background
(traffic)

Max 8-hour, g/m3
400
2700
400
3500
400
2700
400
2967
Urban Background

[1]
Selected data set

Urban including Traffic
NOTE
[2]
EIS
390
None

Max 8-hour, g/m3Annual Mean, g/m3 2267
[1] No data for Rathmines

TMS Environment Ltd
Table 1g
Background air quality data for St Jamess Street Hospital Site (Benzene)
Station
Averaging Interval
2011
2012
2013
Average
Rathmines
Urban Background
Annual Mean, g/m3
1.6
1.2
0.94
1.3
Selected data set

NOTE
Urban Background[1]
EIS
1.5

[2] No data for urban traffic oriented sites
TMS Environment Ltd
Table 2
Summary baseline air quality data for St Jamess Hospital Campus (2013)
Data set
Urban background
Parameter and averaging interval

Nitrogen dioxide NO2

Urban background
Nitrogen oxides, NOx

Urban background
Particulate Matter PM10

Urban background
Particulate Matter PM2.5

Urban background
Urban background
Urban background
Sulphur dioxide, SO2

Carbon Monoxide CO
Benzene
Annual Mean, g/m3

Max 1-hour, g/m3
Annual Mean, g/m3
Max 1-hour, g/m3
Annual Mean, g/m3
Max 1-hour, g/m3
Annual Mean, g/m3
Max 1-hour, g/m3
Annual Mean, g/m3
Max 24-hour, g/m3
Annual Mean, g/m3
Max 24-hour, g/m3
Annual Mean, g/m3
Max 24-hour, g/m3
Annual Mean, g/m3
Max 24-hour, g/m3
Annual Mean, g/m3
Annual Mean, g/m3
Annual Mean, g/m3
Annual Mean, g/m3
Concentration g/m3
TMS
EIS
20
22.7
121
Not stated
28.5
Not stated
150
Not stated
30
38
752
Not stated
50
Not stated
1096
Not stated
16
17.7
74
Not stated
14
Not stated
68
Not stated
11
12.3
64
Not stated
11
Not stated
60
Not stated
2
Not stated
1
Not stated
Not stated
390
234
Not stated
1.3
1.5
Not stated
Not stated
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5.0
Air Quality impact assessment
5.1
Potential air quality impacts

The potential air quality impacts associated with the development are evaluated by
considering the existing and proposed activities at the site, and air quality impacts
associated with each activity. These are considered in turn below.
Existing activities
The existing activities at and in the vicinity of the site have the potential to exert an
influence on ambient air quality by release of emissions as follows:
emissions of particulate matter (PM10 and PM2.5), SO2, NOx, CO from domestic,
commercial and industrial heating;
emissions of particulate matter (PM10 and PM2.5), SO2, NOx, CO and benzene
from traffic
emissions of particulate matter (PM10 and PM2.5), SO2, NOx, CO from the
Energy Centre at St Jamess Hospital and the adjacent Diageo facility;
Overall, the contribution of traffic to air quality in the area is considered to be a

dominating influence on air quality in the immediate vicinity of the St Jamess
hospital campus. The impact of emissions to atmosphere from the St Jamess and
Diageo Energy Centres will be experienced further away from the site because the
emissions are released at significant heights through very tall stacks. There is some
potential for impact at closer receptors depending on the height of the receptor
above ground, and this is discussed further below.
The EIS provides some information about the existing emissions from the St Jamess
Energy Centre. Chapter 2 (Description of the Development) describes at Section
2.4.1 the existing arrangement which is an array of 8 flues of which 4 are redundant
and 4 are operational. Chapter 14 Landscape and Visual Impact Assessment at
Section 14.1.3.3 provides the following information:
At almost 53m over datum (OD) in height, the existing flue stack, which is
located alongside the west side of the Energy Centre is the tallest feature on
the campus (Plate 14.19) and also one of the most visually prominent
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especially from nearby residential areas at Cameron Square (Plate 14.7) and
Ceannt Fort as well as from east along Emmet the north and northwest of the
hospital.
A view of the existing Energy Centre discharge arrangement is shown in Figure 7
which clearly shows the very substantial flue structure that releases emissions at a
height of 53m above ground level. While the existing emissions are significant, the
increase in emissions for the proposed development is extremely significant.
Figure 7
Existing Energy Centre flue structure
Extract from EIS Chapter 14 (Plate 14.19 View North towards Energy Centre and Plate 14.9
View west along Mount Brown with St Jamess Hospital Energy centre to left (south)
Construction Phase Impacts

The proposed development involves the construction of a new national childrens
hospital with associated facilities. A significant amount of demolition work is
required to clear the site and demolish old buildings as well as very significant
excavations in a brownfield site which will uncover contaminated materials with
substantial quantities of material being transported off site for disposal. The main
emissions to atmosphere are summarised as follows:
emissions of particulate matter (PM10 and PM2.5), SO2, NOx, CO and benzene
from construction traffic including plant and machinery on the site;
emissions of particulate matter and dust from demolition and excavation

activities;
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emissions of Aspergillus from earth-moving and excavation activities;
emissions of asbestos, dust and moulds from demolition activities;
emissions of toxic substances associated with the excavation of contaminated

soil, storage and transport off site;
emissions of odour and hydrogen sulphide associated with realignment of the

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

during the construction of the development. Construction vehicles, generators etc.,
may give rise to CO2 and N2O emissions. However the level of emissions will be
insignificant compared to national greenhouse gas emissions.
Operation Phase impacts

The most significant potential impacts remain the same as those that currently exist
- emissions of particulate matter (PM10 and PM2.5) and combustion gases such as CO,
SO2 and NOx and NO2. These are the same substances that exert an influence on the
existing ambient air quality. They will be released from the Energy Centre with some
contributions from traffic associated with the activity.
Sulphur dioxide emissions originate from the sulphur in the fuel used in the
combustion process. The EIS (Chapter 17 and Chapter 7) notes that natural gas is the
preferred fuel but that the existing Energy Centre boilers are dual-fuel fired and that
for resilience, the new childrens hospital boilers will also be dual-fueled and that
storage for 400,000litres of diesel fuel is being provided. If the fuel is natural gas,
then Sulphur emissions will be negligible. For other fuels, for which the Sulphur
content is limited by legislation, the sulphur emissions will be relatively low.
However, if the diesel fuel is used all of the time should natural gas be unavailable,
the SO2 emissions will be much more significant given the significant energy
requirements of the campus.
Nitrogen oxides are present in the emission stream as a result of the combustion
process. Much of the emissions are in the form of nitric oxide (NO) which is
expected to be substantially oxidised to nitrogen dioxide (NO2) in the atmosphere.
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NO2 is the more significant pollutant for the protection of human health whereas the
combined NO plus NO2, referred to as NOx, is more significant for protection of
ecosystems.
Particulate matter and carbon monoxide may also arise from the combustion
process in the emission stream. Particulate matter (as PM 10 and PM2.5) is likely to be
negligible if natural gas is used as the principal fuel whereas these will be more
significant for other fuel types.
There is the potential for a number of greenhouse gas emissions to atmosphere from
the Energy Centre principally as CO2 emissions. However the level of emissions will
be relatively low compared to national greenhouse gas emissions.
The proposed Energy Centre is the most significant source of emissions to

atmosphere associated with the proposed development. Chapter 2 of the EIS
(Description of the Development) contains the following information at Section 2.4.1
Page 2-22.
Proposed New Flues
The existing St. Jamess Hospital campus energy centre flues are the tallest
feature on the current campus. These rise from the southern face of the
energy centre building in a cluster of 8 no. pipes, 4 no. abreast either side of a
central steel structure, of which 4 no. are now redundant. The new childrens
hospital includes its own energy centre located on Level B02. This requires 12
no. new flues, which need to be in close proximity to the boilers and standby
generators within the proposed energy centre. The proposed solution is a
combined childrens and St. Jamess Hospital flue stack with 16 no. pipes (12
no. for the new childrens hospital and 4 no. for St. Jamess Hospital campus)
in a square plan form. The pipes are angled at the top, reflecting the different
height requirements of the different flues. The heights have been determined
by the mechanical and electrical engineers in accordance with best-practice
guidelines and statutory regulations. The highest point of the proposed flues
has a height of Ordnance Datum 58.7m.
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In summary, the existing Energy Centre has 4 redundant and 4 operating flues from
which emissions are released at 53m above ground level. The new arrangement will
involve 16 flues (4 existing and 12 new) for the discharge of emissions to cater for
the existing and proposed energy requirements of the campus. This is a very
significant increase in capacity and a very significant increase in emissions. There is
some doubt about the actual height of the emissions flues. From the above extract
from the EIS, the proposed flues will discharge at 58.70m OD. However other
sections of the EIS suggest that the maximum discharge height is at 59.700mOD. For
example, Figure 8 (extracted from EIS Drawing NPH-A-BDP-PL-ZZ-ST-2101ELEVATIONS-CONTEXT) shows a maximum discharge height of 59.700m OD for the
proposed flues.
Figure 8
Proposed new Energy Centre emissions discharge arrangement

Flues at varying heights with highest shown at 59.700 OD
Extracted from EIS Drawing NPH-A-BDP-PL-ZZ-ST-2101-ELEVATIONS-CONTEXT
Section 14.1.4.1 of the EIS (Landscape and Visual Impact Assessment) indicates as
follows that the height of the flues will be c. 59mOD at the highest point and that
this is c. 6m above the height of the existing flues.
As new flues are required as part of the proposed development, a new
combined flue stack structure is proposed south of the existing location. The
top of the flues are angled at different levels and the highest is c.6m higher
than the top of the existing flues giving a total height of c.59m OD.
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The difference in height as well as the complexity of the proposed flue structure
relative to the existing arrangement is clear from Figure 9 which is an extract from
Chapter 14 of the EIS.
Figure 9
Existing and proposed Energy Centre flues
Extract from Appendix 14.1 Landscape and Visual Impact (Figures 24.1 and 24.3)
Figures 8 and 9 also show an array of flues five deep and other views from other
directions suggest that the arrangement will be 5 x 5 which is 25 flues. Elsewhere in
the EIS there is reference to a square flue structure which might suggest a 5x5
arrangement meaning 25 flues. It is not clear whether it is 16 flues or 20 flues or 25
flues for the combined emissions from the existing and proposed Energy Centre. For
any of the above scenarios, it is a very significant increase in emissions relative to the
existing activity and the potential impact of the emissions from the Energy Centre is
the most significant potential impact associated with the Operational Phase of the
proposed development.
Chapter 17 (Material Assets Site Services) gives a summary of the energy
requirements of the site as follows.
Section 17.1.4.5 Gas

The existing gas network will need to be extended and modified in order to
facilitate the development of the new childrens hospital. It is anticipated that
the new childrens hospital will require approximately 9MW peak heating
output and that this will increase to 11MW peak to cater for future 20%
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expansion and then to 15MW to cater for the future Maternity Hospital. The
existing St. Jamess Hospital peak gas load is approximately 9.2MW.
Therefore the estimated peak heat output demand for the new childrens
hospital plus future expansion plus future Maternity Hospital plus existing St.
Jamess Hospital campus is 24.2MW. Taking combustion efficiencies into
account, this equates to peak gas input of 33MW.
This Chapter of the EIS also notes that the existing boilers are dual fuel (section
17.1.6.2) and can be switched over to run on oil to provide an alternative source of
heating should natural gas be unavailable for any reason during the construction
works. It is also noted that to provide resilience, the new childrens hospital boilers
will be provided with dual fuel oil/gas burners and a diesel oil store will provide an
alternative source of heating should natural gas be unavailable for any reason.
Separately (Chapter 7) it is noted that A new 400,000l oil store is to be constructed
to serve the St. Jamess Hospital Campus via the Energy Centre. A smaller 3,000l oil
storage facility will be constructed to serve the Childrens Research and Innovation
Centre site.
The Energy requirements of the site will more than double for the proposed
childrens hospital which will lead to at least double the emissions from the
combined Energy Centre. In addition, for tri-location of the future Maternity
Hospital, the Energy requirement will almost treble and the emissions will increase
by at least 300%. As noted below, I am concerned that there is insufficient
assimilative capacity to ensure that such an enormous increase in emissions does not
lead to a breach in air quality standards. This is such a significant issue that it could
limit the potential for future expansion of the facility and render impossible the trilocation of the maternity hospital which Government Policy requires. It is therefore
the aspect of the development proposal on which this report will focus most
attention.
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Traffic impacts
There will be no change in the type of emissions that will be released as a result of
traffic. The emissions include particulate matter (PM10 and PM2.5), SO2, NOx, CO and
benzene. There is a difference between the traffic impact projections presented in
the EIS and those predicted by Traffic Insights who are also evaluating this
development on behalf of the Jack and Jill Foundation. On the basis of the
assessment prepared by Traffic Insights, the emissions from traffic associated with
the proposed development will increase. This is discussed further below.
5.2
Air Quality Standards and impact assessment criteria

Air Quality Standards in Ireland have been defined to ensure compliance with EC
Directives; they are developed at different levels for different purposes. European
legislation on air quality has been framed in terms of two categories, limit values and
guide values. Limit values are concentrations that cannot be exceeded and are
based on WHO guidelines for the protection of human health. Guide values are set
as a long-term precautionary measure for the protection of human health and the
environment. The WHO guidelines differ from EU air quality standards in that they
are primarily set to protect public health from the effects of air pollution, whereas
Air quality standards are recommended by governments, and other factors such as
socio-economic factors, may be considered in setting the standards.
The Clean Air for Europe (CAFE) Directive (Council Directive 2008/50/EC) was
transposed into Irish legislation by the Air Quality Standards Regulations 2011 (S.I.
No. 180 of 2011). This Directive and the Irish Regulations set out the main standards
against which the potential impact of the development on air quality are assessed.
The assessment is based on ensuring compliance with the air quality standards.
In addition to the Air Quality Standards Regulations and the Directive Standards, it is
also appropriate to consider the World Health Organisation (WHO) Guidelines. These
guidelines were developed by the WHO to provide appropriate air quality targets
worldwide, based on the latest health information available. The air quality
guidelines for particulate matter (PM10), nitrogen dioxide and sulphur dioxide, and
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PM2.5 are considered in this report (WHO, 2005; updated in 2008). While the WHO
Guidelines are not mandatory, they represent current informed opinion on the levels
to which we should be aspiring in order to minimise adverse health impacts of air
pollution. Since the proposed development of a National Childrens hospital will
cater for sick children with compromised immune systems and limited ability to cope
with additional stresses such as air pollution, it is prudent to consider the WHO
Guidelines as well as the mandatory Air Quality Standards for the purpose of this
assessment. The air quality standards and guidelines referenced in this report are
summarised in Table 3 and Table 4.
Section 12.1.2.1 of the EIS sets out the Air Quality Standards which are relied on in
the impact assessment and states that the air quality impact assessment is based on
ensuring compliance with the appropriate standards or limit values. Appendix 12.1
of the EIS includes a statement about the WHO Guidelines but the Guideline values
are not quoted and the assessment does not consider these Guideline values. The
development proposal relates to the provision of future medical care for Irelands
sickest children, all of whom are in a vulnerable and sensitive state given their
medical status. For such a sensitive proposal, I believe that the assessment should
also consider the WHO Guidelines, only some of which are lower than the relevant
Air Quality Standards or Limit Values. The most significant difference is in the
Guideline values for particulate matter as PM10 and PM2.5 which are 50% of the EU
Air Quality Standards.
In carrying out the air quality impact assessment, the predicted impact of the
proposed development is evaluated by comparing the predicted levels of various
pollutants with the Air Quality Standards and ensuring compliance with the
Standards. This is the approach adopted in the EIS and it is also the approach
adopted in this report.
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Table 3
Air Quality Standards Regulations 2011 (based on EU Clean Air For Europe
[CAFE] Directive 2008/50/EC)
Pollutant
EU Regulation
Limit Type
Nitrogen
Dioxide
2008/50/EC
Hourly limit for protection None

of human health - not to be
exceeded more than 18
times/year
Annual limit for protection None
of human health
of vegetation
200
NO2
Hourly limit for protection 150 g/m3

times/year
Daily limit for protection of None
human health - not to be
times/year
Annual & Winter limit for None
the protection of human
health and ecosystems
350 g/m3
24-hour limit for protection 50%

times/year
50 g/m3
Annual limit for protection 20%

of human health
40 g/m3
Sulphur
dioxide
Particulate
Matter
(as PM10)
Particulate
Matter
(as PM 2.5)
2008/50/EC
2008/50/EC
2008/50/EC
Margin of Tolerance
Value
g/m3
40
g/m3
NO2
30 g/m3
NO +NO2
125 g/m3
20 g/m3
Annual limit for protection 20% from June 2008. 25 g/m3

of human health
Decreasing linearly to
0% by 2015
(Stage 1)
of human health (Stage 2)
To be achieved by 2020
20 g/m3
Carbon
Monoxide
2008/50/EC
8-hour limit (on a rolling 60%

basis) for protection of
human health
10 mg/m3
(8.6 ppm)
Benzene
2008/50/EC
Annual limit for protection 0% by 2010

of human health
5 g/m3
NOTE
1. The Air Quality Standards Regulations 2011 (SI 180 of 2011) transposed EU Directive 2008/50/EC (CAFE)
into Irish law.
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Table4
WHO Air Quality Guidelines
Pollutant
Limit Type
Value
Nitrogen Dioxide
Hourly limit for protection of human health
200 g/m3 NO2
Annual limit for protection of human health
40 g/m3 NO2
Daily limit for protection of human health
20 g/m3
Sulphur dioxide
10-minute limit for protection of human health 500 g/m3

Particulate Matter
(as PM10)
Particulate Matter
(as PM 2.5)
24-hour limit for protection of human health
50 g/m3
Annual limit for protection of human health
20 g/m3
24-hour mean for protection of human health
25 g/m3
Annual mean for protection of human health
10 g/m3
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5.3
Prediction and evaluation of Construction Phase impacts on air quality

5.3.1 Potential Construction Phase air quality impacts
Section 12.1.4 of the EIS identifies the potential air quality impacts associated with
the construction phase of the proposed development for assessment in the EIS.
These potential air quality impacts studied in the EIS are summarised as follows:
a) Construction Phase dust nuisance from construction activity;
b) Construction Phase - Aspergillus emissions from excavation and earthmoving
activity;
c) Construction Phase construction transport emissions;
I agree with these choices but would also add the following which have not been
considered in the EIS:
d) Construction Phase emissions associated with relocation of the Drimnagh
sewer;
e) Construction Phase emissions associated with significant excavations in a
suspected workhouse cemetery and brownfield contaminated site;
f) Construction Phase emissions of asbestos and/or moulds associated with
building demolition works.
The assessment of these potential impacts is addressed in the following sections of
this report.
5.3.2 Dust from general construction activities

The construction of the proposed national childrens hospital will take place on a
large city centre site (ca 5 hectares) adjacent to a functioning hospital and in close
proximity to residences. One of the most significant of the potential air quality
impacts associated with such a large-scale construction site is dust.
There are three potential impacts on air quality of the dust / particulate matter
emissions. Dust deposition on surfaces is the main potential impact associated with
the larger particles, nuisance effects such as reduced visibility could be associated
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with excessively high levels of suspended particulate matter and respiratory effects
could occur as a result of excessive levels of fine particles such as PM 10 and PM2.5.
Dust emissions associated with the Construction Phase of the proposed
development are expected to be predominantly in the 10 75m particle size range
so these particles, because of their size, will generally be deposited within 100m of
the emission source. Only under exceptional meteorological conditions would the
dusts be carried further downwind.
Suspended particulate matter (SPM) may also be released and this matter may
remain suspended in the air. The main effect would be on visibility but this type of
material could also be a respiratory nuisance if present at excessive levels.
Emissions of dust in the form of PM 10 and PM2.5 may also occur, primarily as a result
of materials handling and storage since the dominant particle size of the main
construction materials is in the lower size ranges. There may also be some emissions
of particles in these size ranges from the general site activities.
An approach towards the quantitative estimation of emissions from the Construction
Phase is to use Emission Factors. An emissions factor is a representative value that
relates the quantity of a pollutant released to the atmosphere with the activity that
leads to the release of that pollutant. These factors are usually expressed as the
weight of pollutant divided by a unit weight, volume, distance, or duration of the
activity emitting the pollutant (e.g., kilograms of particulate emitted per hectare of
excavation). AP-42, Compilation of Air Pollutant Emission Factors, is a US EPA
publication that contains emission factors for many different categories of activity
including Construction activities6. This Reference Publication cites an emission factor
for large-scale construction activity of 2.69 Megagrams / hectare / month. For the St
Jamess Hospital construction site this would equate to an uncontrolled emission
rate of more than 13tonnes of dust per month. When the more refined approach
recommended in AP-42 is considered (Section 13), this estimate reduces to more
than 10 tonnes of potential construction dust emissions per month across the site at
peak. This is a very significant potential emission rate and clearly a comprehensive
Dust Management and Control Plan is required. When the sensitivity of the existing
6
Available for download at http://www3.epa.gov/ttnchie1/ap42/; accessed 25 September 2015
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hospital in the receiving environment is considered, the importance of the Control
Plan is further emphasised.
5.3.3 Aspergillus emissions

There is concern about a fungal disease, "invasive Aspergillosis which may be
contracted as result of disturbance of materials that release fungal spores into the
atmosphere. This is a disease which is detrimental to persons with suppressed
immune systems, such as hospital patients, and is therefore of concern in relation to
the proposed childrens hospital at the St Jamess hospital site. A report entitled
"National Guidelines for the prevention of Nosocomial Invasive Aspergillosis during
construction/renovation activities" deals specifically with construction works
occurring within or adjacent to hospitals. The report states that the fungal spores
responsible for invasive Aspergillosis can originate from a number of sources such as
construction, demolition, renovation, disturbance of soil, removal of fibrous
insulation material, removal of suspended ceiling tiles and from poorly maintained
air ventilation systems. The potential sources of the fungal spores associated with
invasive Aspergillosis, as detailed above, are related to the occurrence of these
operations either within or in very close proximity to the hospital buildings.
Fungal spores (the Aspergillus moulds) are found everywhere but are of particular
concern when large scale demolition, excavation and earth-moving activity takes
place and especially in close proximity to areas where vulnerable individuals are
located. The dispersion of spores (or indeed dust or any other substance) which are
released at a particular location depends on a significant number of factors which
include the rate and temperature of the release, the release height, the wind speed,
rainfall, wind direction, topography, local meteorological conditions, the nature of
the substances released, the potential for physical or chemical interactions and the
concentrations of the substances released and other factors. The dispersion of
fungal spores will depend on all of the above factors and this dispersion is evaluated
by considering the factors noted above and the distances from the source at which
the predicted impacts are to be assessed. In the first instance, the key factors are the
concentration of the spores released and the distance to sensitive receptors.
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The concentration at which fungal spores may be released from a specific source is
the first factor to be considered in assessing dispersion pathways. There is Literature
data indicating that levels of spores released as a result of construction projects
could be up to 200 / m3.
In order to reliably predict the possible impact of fungal spores released as a result
of a construction work, I have completed a dispersion modelling study to
demonstrate that dispersion of fungal spores released as a result of any activity is a
function of time and distance. I used conventional methods to complete the study
and the results are described briefly here. An initial release of 200 /m 3 at a height of
ca 2m above ground over a large area of 1000m2 was chosen for modelling. This is a
hypothetically large release area but it is representative of the large construction site
on the hospital campus. The modelling study showed that the concentration of
spores as a result of such a release would be predicted to reduce to below 10 /m3
within about 70m of the release source, and be completely dispersed ie no
measurable concentration at c. 150m from the source of the release.
This exercise demonstrates the potential significance of the large scale construction
works at the St Jamess campus where the functioning hospital is located very close
to the construction site, and the construction programme will extend for c. 4 years.
The National Guidelines report referred to above notes that the fundamental
requirement in respect of eliminating Aspergillus infection from construction works
is first to minimise the dust generated during construction and second to prevent
dust infiltration into patient care areas. The preventive measures could include
enclosure of the construction site where necessary and ventilation with Hepa filters
to ensure that dust ingress is prevented.
Chapter 12 of the EIS at section 12.1.6.1 states that the windows to the facades of
some wards in the hospital will be sealed prior to commencement of construction to
prevent the spread of aspergillus spores. This does not constitute a Management
Plan that conforms to the National Guidance. An effective management plan must
consider the rate of generation and release of the spores, sealing of windows of all
patient care areas as well as hepa-filtration in vulnerable areas which are classified in
the National Guidelines report above. In addition, the potential impact on non-
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hospital vulnerable receptors must also be considered which may not have been
done as it has not been reported in the EIS.
5.3.4 Construction vehicle emissions

Emissions of dust raised by vehicle movement on the roads near the site and also on
site are considered under the general construction phase emissions in section 5.3.2
above. Emissions from the construction vehicles as a result of fuel combustion are
considered here. The emissions include PM10 and PM2.5, NO2 and NOx and CO and
benzene. The EIS predicts extremely low levels of emissions from this activity which I
find surprising. The actual vehicle movement numbers are not specifically given in
Chapter 12 of the EIS and I was unable to find a specific reference to the precise
vehicle movement numbers that were used for the predictions. It appears that the
HGV and LGV movements associated with Construction may not have been included
in the assessment, and this leads to a significant understatement.
One simple calculation will illustrate why I am concerned that the emissions from
construction traffic may be understated in the EIS. There will be approximately 920
Goods Vehicle Movements per day during Phase I Construction Works, primarily
associated with removal of demolition materials and excavated materials from the
site. During Phase II (excavations) this will rise to 1380 Goods Vehicle movements
per day and 1140 Goods Vehicle movements per day for the main Construction
Phase III (Chapter 6 EIS). This is a huge increase in Goods Vehicle movements relative
to the existing situation so it is predicted that the change in emissions of pollutants
attributable to traffic will be significant. I cannot reconcile this data with the
predictions of negligible increase in emissions presented in Chapter 12 of the EIS for
PM10 and PM2.5. One of the most significant transport-related pollutants is NO2 and
there are no impact predictions for this substance presented in the EIS. My
calculations indicate pollutant levels orders of magnitude higher than those
presented in the EIS. I am concerned therefore that the potential Construction Phase
impact of transport-related emissions is understated in the EIS.
Section 6.1.7.1 of the EIS states in respect of Construction Phase impacts that There
will be little impact on prevailing traffic conditions on the surrounding street
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network, however there will be a temporary increase in the number of Heavy Goods
Vehicles on the surrounding street network during the construction phase of the
project. The temporary increase in HGVs will last for four years and will amount to
an average of 115 HGV movements per hour during the normal work day that is a
HGV passing every 30 seconds or so. The amount of Construction Phase traffic is
extremely significant and it is impossible to reconcile the statement in the EIS that
there be little impact on traffic conditions with the magnitude of the vehicle
movements required for this development to proceed.
5.3.5 Drimnagh Sewer relocation

The relocation of the Drimnagh sewer is a significant element of work which will
inevitably lead to emissions of dust, odour and perhaps other pollutants. The EIS fails
to consider this in any meaningful way. The impact of this activity can be managed
but the key to effective management is to ensure that the nature and magnitude of
the potential impact is reliably characterised.
5.3.6 Emissions associated with demolition works

Demolition of buildings which may contain or previously contained asbestos has not
been considered in the EIS, and asbestos has also been identified in some of the
waste materials to be excavated at the site. This is a highly significant potential
impact given the age of the buildings on the site. The demolition of asbestos
containing buildings is a specialised task and specialised management techniques
and experienced contractors are required. While such activity can be effectively
managed to control potential impacts, it can only be competently and effectively
managed if the potential impact is identified and evaluated, and meaningful
management plans are put in place.
The potential emissions of moulds from buildings which are to be demolished has
not been considered in the EIS. Again such activity can be managed so that impacts
are controlled but effective management cannot take place if the assessment is
incomplete. Considering the uniquely sensitive location of the site on a functioning
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hospital campus, careful consideration of these and all potential air quality impacts is
required.
5.3.7 Emissions of hazardous substances from excavation in contaminated

ground
The St Jamess campus is a brownfield site and it is expected that in such a location
contaminated soils and groundwater will be encountered. The EIS (Chapter 7 Soils
and Geology) confirmed that contaminated areas and Hotspots were found during
the extensive investigations that were carried out. The pollutants included heavy
metals, heavy-fraction hydrocarbons, polycyclic aromatic hydrocarbons, inorganic
substances, asbestos and elevated pH levels in one area which were unexplained
pending further investigation. Chapter 7 notes in Table 7.5 that 413,000m3
(approximately equivalent to 826,000 tonnes based on density of 2 tonnes per cubic
metre) of overburden will be removed to facilitate construction of the sub-surface
structures such as basements. Materials such as concrete and infill material will be
imported to support the construction programme.
The excavated materials have been characterised in Appendix 7.1 and in Chapter 10
(Waste Management) with estimates of ca 81,000 tonnes of non-hazardous waste
and about 1,000 tonnes of hazardous waste to be disposed of off-site as waste. One
area of the site has been identified in Chapter 7 as an area where a former burial
ground was located. In times past, lime was spread over burial grounds to facilitate
disease control so it is possible that this is the reason for the elevated pH readings. It
is also possible that the soils and wastes recovered from this area will be re-classified
as hazardous waste when the additional investigations are completed. A further
possibility following investigation is that a risk assessment could identify concerns
about the potential for these materials to lead to transmission of disease. The
investigations have not been completed and reported in the EIS so a full assessment
is not possible with the currently available information.
Excavation, storage and transport of these very significant volumes of waste and fill
materials will generate considerable amounts of dust and has the potential to
release contaminants such as heavy metals and organic substances into the air. Dust
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that is generated is likely to be contaminated to some extent with the pollutants
identified in the materials. As noted above, the investigations have not been fully
completed and it is possible that further contaminants will be identified for which
management plans must be formulated.
In our experience, the management of works at contaminated sites is a highly
specialised and complex undertaking, the success of which is dependent on the
accurate and reliable definition of the issues to be addressed. Since the
investigations are not complete, there is an incomplete statement of potential
impacts to be addressed and therefore the Management Plans cannot be
formulated. On construction sites in contaminated ground, depending on the level of
contaminants generated as a result of the works, there is a requirement to monitor
the impact of the emissions of hazardous substances on air quality to which the
construction workers and surrounding receptors are exposed. This proposed
construction site will be located on the site of a functioning hospital, in very close
proximity to surrounding residences. For hospital patients in particular, the potential
air quality impact associated with excavation of hazardous wastes and materials is
one of the most significant potential impacts of the Construction Phase of the
proposed development.
Chapter 12 of the EIS dealing with air quality impacts does not comprehensively
evaluate the potential air quality impacts associated with the excavation, storage
and transport of contaminated wastes. As noted elsewhere in this report,
Management Plans cannot be effectively formulated with insufficient information
and we respectfully submit that this important element of the site investigations is
incomplete and that there is incomplete information available to finalise an
assessment of potential impacts.

The impact assessment methodology described in Section 12.1.2.3 of the EIS for the
prediction of air quality impacts focuses on the impact of emissions from transport
during the construction and operation phases of the proposed development. The
methodology is based on the National Roads Authority Guidelines for the Treatment
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of Air Quality During the Planning and Construction of Major Road Schemes. While
this is an excellent methodology for assessing the air quality impact of major road
schemes, there are very significant differences between the construction of a road
scheme and a fixed construction site such as the site of the proposed Childrens
hospital at St Jamess Street. In my opinion, this means that the methodology does
not allow a reliable assessment of all of the potential construction phase impacts.
One of the most significant differences between the construction of a road scheme
and the proposed Childrens hospital is that for a road scheme, the construction site
moves regularly and therefore the areas where air quality impacts are observed also
vary with time. For the proposed Childrens hospital, the construction site stays the
same, in a relatively confined space (relative to a road scheme) and therefore the air
quality impacts are more localised than they would be for a road scheme. For the
proposed 4-year construction programme, air quality impacts will be experienced
over a relatively small localised area and these impacts will be more intense and
concentrated than for shorter duration programmes on sites where the construction
activity is moving regularly. I am therefore concerned that the methodology adopted
has underestimated the potential impacts of the construction phase of the proposed
development due to the significant differences between a road scheme and a fixed
construction site in a confined area.
Section 12.1.7.1 of the EIS describes the predicted impact of construction transport
vehicle movement in terms of nuisance dust and the emissions from the vehicles of
PM10 and PM2.5. Construction transport vehicle movement will be significant during
such a large-scale construction programme but assessing only this impact of the
many construction phase impacts results in an inadequate statement and
assessment of potential impacts. As noted above, calculations executed for this
assessment suggests that the most significant construction traffic impacts have not
been evaluated and reported in the EIS.
The actual on-site construction activity will also give rise to emissions of dust and
fine particulate matter PM10 and PM2.5 which has not been assessed in the EIS. In my
opinion, the dust from the fixed site activities will be very significantly greater than
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that from the transport vehicles and the EIS therefore doesnt consider the most
significant dust impacts associated with the construction phase.
All vehicle movements will also lead to emissions of NO, NO2 and CO and again the
EIS does not consider these pollutants. When the cumulative impact of the existing
baseline air quality and emissions of all these substances from all sources is
considered, the predicted impact is likely to be far greater than that stated in the EIS.
For the Construction Phase, the impact of emissions such as Nitrogen oxides and CO
have not even been considered in the assessment.
The impact predictions given in Tables 12.13 and 12.14 of the EIS are extremely low
and are described as Imperceptible in terms of predicted impact. This is a significant
understatement of potential impact because all potential emission sources have not
been considered in the assessment all that was considered is some of the relatively
minor Construction Transport Vehicle contributions to Construction Phase emissions.
Some of the significant Construction Phase impacts which were not considered
include on-site construction activity, earthmoving and excavation, site construction
vehicles, wind-blow across exposed surfaces, materials unloading, stockpiled
materials, and removal of excavated materials. This proposed development is
substantial and the predicted impacts are significant the EIS does not reach this
conclusion because the most significant Construction Phase emission sources appear
not to have been evaluated.
The section of the EIS dealing with potential Construction Phase impacts on the
patients of St Jamess hospital (Page 9-17) does not consider all of the potential
sources of emissions associated with the Construction Phase and the potential
impact of the programme is therefore understated. I am also concerned that the
assessment methodology for those impacts that were considered is not appropriate
for the assessment and does not reliably predict the magnitude of air quality impacts
associated with the construction phase.
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5.4
Prediction and evaluation of Operation Phase impacts on air quality

5.4.1 Potential Operation Phase air quality impacts
Section 12.1.4 of the EIS identifies the potential air quality impacts associated with
the operation phases for assessment in the EIS. These are summarised as follows:
a) Operation Phase Building Services emissions
b) Operation Phase emissions of traffic-related pollutants from increased
traffic on public roads
I agree with these choices. Emissions from the Energy Centre are by far the most
significant of the emissions associated with the Operation Phase, so greater
attention is focused on these emissions in this impact assessment report.
5.4.2 Traffic emissions

The impact of traffic related emissions on air quality during the Operation Phase is
assessed and the findings are presented in section 12.1.7.2 of the EIS. The report
does not give the traffic figures used in the assessment so a direct comparison of the
emission projections is not possible. It is assumed that the traffic data provided in
Chapter 6 of the EIS was used but Chapter 12 states at section 12.1.7.2 that The
traffic data used in this assessment was provided by Arup Consulting Engineers. The
EIS assessment is based on the traffic projections from the authors of the traffic
impact assessment section of the EIS and Traffic Insights, who are reviewing this
proposal on behalf of the Jack and Jill Foundation have determined that the EIS
understates traffic impacts and traffic projections. It is therefore likely that traffic
impacts on air quality have been understated in the EIS.
There is a far greater concern about the reliability of the air quality impact
assessment which centres on the fact that no cumulative impact assessment was
carried out. A report on the assessment of emissions to atmosphere from the Energy
Centre was presented separate from the main impact assessment report in Chapter
12 of the EIS and no attempt was made to consider the cumulative impact of
emission from the traffic and energy sources on and associated with the site. This
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means that there is likely to be a significantly understated impact assessment as
noted in the following section of this report.
5.4.3 Energy Centre emissions

5.4.3.1 Assessment methodology
The approach adopted in this report to the assessment of the impact of the
emissions is to carry out a dispersion modelling assessment. This type of assessment
involves use of a computer Model to predict the impact of the emissions on air
quality by predicting the concentrations of pollutants that will arise as a result of the
emissions. For reasons already identified in this report, I am concerned that the
assessment reported in the EIS has significantly underestimated the impact of the
emissions. As a consequence, I have prepared a separate assessment to ensure that
a robust and reliable statement of air quality impacts is available to support the
decision making process.
Guidance Document AG4 (the Environmental Protection Agency Guidance Note on
Dispersion Modelling) gives guidance on the use of Dispersion Models which was
followed in the execution of this study. A detailed modelling assessment was
undertaken using the US EPA Model AERMOD with the current regulatory version of
this Model. The model computes average ground-level concentrations of pollutants
emitted from either elevated or ground-level emission sources. Separate utilities
associated with the dispersion modelling software allow computation of groundlevel concentrations of pollutants over defined statistical averaging periods, and
additional features permit suitable consideration to be given to building downwash
effects and the effects of elevated terrain in the vicinity of the plant.
Evaluation of the impact of the proposed development on air quality using
dispersion modelling requires information on the following:
Emissions characteristics
Site layout and topography
Climatological data
Averaging intervals
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Receptor locations
This data is summarised in the following sections of this report.
5.4.3.2 Emissions Characteristics

Information on dimensions and physical characteristics of the main emission sources
was obtained from the EIS. As noted in Section 5.2 it was difficult to find all of the
information required to allow this study to be completed. Relevant information was
found in Chapters 2, 6, 7, 10, 11, 12, 14 and 17 of the EIS and in Appendix 7.1 and
Appendix 12.3; however, some information is contradictory and there are also some
gaps in the information which was presented in the EIS. A summary of the emissions
characteristic data is presented in the following sections together with the rationale
used for for each selection.
Pollutants
Emissions to atmosphere from the Energy Centre are discussed in Section 5.2 of this
report. The most significant potential emissions arise from fuel combustion and are
particulate matter (PM10 and PM2.5) and combustion gases such as CO, SO2 and NO2
from the boilers and CHP engines. As noted in Section 5.2, Sulphur dioxide emissions
are significant when fuel oil is used and negligible when natural gas is in use as the
primary fuel. The EIS notes that the existing and proposed energy sources are all
dual-fuelled and can be run on either natural gas or diesel fuel for which significant
storage facilities are provided. Air Quality Standards are in force for all of these
substances so it is necessary to include all of them in the dispersion modelling
assessment.
NOx chemistry
A significant issue in respect of Model Input data for emissions from combustion
sources is the selection of NOx input data. In most combustion processes, NOx is
emitted almost totally in the form of nitric oxide (NO). Nitrogen oxides are very
reactive and also contribute, due to the formation of nitrogen dioxide from nitric
oxide,
to
the
phenomenon
of
photochemical
ozone
formation.
These
transformations are generally of greatest concern in the areas where the highest
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ozone concentrations occur for example, in rural areas in late afternoon in summer
time.
In the EPA Modelling Guideline AG4, the recommendation for screening assessments
is that a default annual NO2 / NOx ratio of 1.00 is used and a default hourly ratio of
0.5 is used; this is also the guidance given in the UK for dispersion modelling
assessments. AG4 notes that the AERMOD Modelling suite treats NO x emissions in
one of two ways:
All of the NOx emissions are treated as NO2 and an assumption is made
that a pre-determined ratio of NO2/NOx applies to the predictions; this is
where the default conversion rates noted above would apply;
The Plume Volume Molar Ratio Method (PVMRM) is used whereby an

assumption is made that the in-stack NO2/NOx ratio is 0.1 and the
equilibrium ratio is 0.90.
In our assessment, both methods are employed. The assumption made is that the
local NO2 / NOx ratio is 1 ie that 100% of the NOX is present in the form of NO2. This is
a conservative approach but given the significance of the emission sources it is
considered prudent; separate scenarios are modelled using 90% and 75% conversion
factors. THE PVMRM method is also used as a sensitivity check for the projections.
Pollutant concentrations
Appendix 12.3 provides information on the emission characteristics which were
modelled for the assessment carried out in the EIS. This data relates only to nitrogen
oxides. In my experience the levels given in the EIS are very low and may not be
accurate for the significant energy outputs from the various sources at the Energy
Centre. 33MW of gas input or c. 24 MW energy output is a significant energy output
which will consume a significant volume of fuel, either natural gas or diesel.
Emissions of nitrogen oxides and carbon monoxide will be essentially the same
regardless of fuel type, but SO2 emissions will be significant for diesel fuel and
negligible when natural gas is used. Scenarios will therefore be modelled for both
fuel types. Scenarios will be run for the NOx concentrations quoted in Appendix 12.3
TMS Environment Ltd
of the EIS and also for other emission scenarios.
The calculation of emissions to atmosphere from combustion plants is described in
several publications including the Corinair Combustion In Energy & Transformation
Industries (Emission Inventory Guidebook 15 February, 1996)7. This is a guidance
publication on calculating emissions from combustion plants which is recommended
by the EPA as useful guidance in preparing reports to the EPA on emissions to air.
The EPA have also published a spreadsheet tool which is used to calculate emissions
to atmosphere from combustion plant8. These references have been used to
estimate the emissions to atmosphere from the combustion plant at the proposed
childrens hospital.
The guidance requires the use of emissions factors for the various pollutants which
are sourced from the Corinair Publication. SO2 emissions are dependent on the
sulphur content of the fuel which is negligible for natural gas and limited for diesel
oil. For NOx and CO and particulate matter, the emission factors from the Corinair
Guidance are used. Using this methodology, and the information contained in the EIS
that 33MW of gas energy input is required to meet the combined requirements of
the St Jamess Hospital and the proposed Childrens Hospital and a future Maternity
Hospital, an estimate of the emissions of each major pollutant for each fuel type is
determined as shown in Table 5.
Since the emission rate projections are derived directly from the energy input and
fuel usage, the emissions projections are based on the energy requirements as
stated in the EIS. The only emission rate data provided in the EIS appears to be for
natural gas and is only given for NOx at 1.94 grams per second (Table 2, Appendix
12.3). This is significantly lower than the value given above and it is unclear from the
information presented in the EIS how such a significant discrepancy arises. The
estimates above for NOx emissions are up to 6 times higher than the EIS estimates
for the St Jamess Hospital & Childrens Hospital and the St Jamess & Childrens &
Maternity Hospital scenarios. Since the energy sources are all stated to be dual7
Accessible at http://www.epa.ie/pubs/reports/air/airemissions/epacorinaircombustionfactorspdf.html#.VgrHFI2FO71
Accessible at
http://www.epa.ie/pubs/reports/air/airemissions/epatemplatespreadsheetforcalculatingemissionsfromcombu
stionplantsxls.html#.Vgr4O42FPIU
8
TMS Environment Ltd
fuelled, and significant storage capacity for diesel oil is provided, an assessment of
the emissions to atmosphere from the use of this fuel is essential and does not
appear to have been completed in the EIS.
Table 5
Estimated emissions from the Energy Centre for different fuels

Pollutant
Emission rate, grams/second by Fuel Type

Natural Gas
Diesel Oil
Combined St Jamess Hospital and proposed Childrens Hospital

SO2
Negligible
0.183
NOx
8.72
9.17
CO
1.49
1.15
Particulate matter
0.025
1.05
Combined St Jamess, expanded Childrens Hospital and Maternity Hospital

SO2
Negligible
0.244
NOx
11.6
12.2
CO
1.98
1.53
Particulate matter
0.033
1.39
The emission rate projections given in Table 5 show the very significant emissions
that are associated with the Energy centre and also highlight the significant
difference between the data presented in the EIS and in this report.
Source characteristics
As noted in Section 5.2, there is conflicting information presented in the EIS about
the number of emission sources and the height above ground of these emission
sources. The number of flues ranges from 12 through 16, 20 and 25 depending on
which section of the EIS is considered. Most of the available information indicates
that there will be at least 16 flues from 16 emission sources. The flues will be
configured in a square arrangement near the Energy Centre and will discharge at a
height of 53 to 59m above ground level. Considering the uncertainty, scenarios will
be run with varying stack heights in this range. It is however noted that the
TMS Environment Ltd
dispersion modelling assessment presented in Appendix 12.3 of the EIS models
emissions from just 10 emission sources. It appears therefore that a further
understatement of emissions has been presented in the EIS.
Site Layout and Topography
The layout and area of the site and the dimensions of the various plant buildings
were obtained from the drawings submitted with the Planning Application.
Topographical information was obtained from a site survey and from maps,
orthographic photographs and digital Ordnance Survey data. Building downwash
effects are possible as a result of the buildings on site so possible downwash effects
were modeled using the modeling suite facilities.
The presence of terrain can lead to significantly higher ambient concentrations than
would occur in the absence of terrain features, especially if there is a significant
relative difference in elevation between the source and off-site receptors.
International Guidance, and the Agency Guidance Note AG4, suggests that when
modeling in a region of flat terrain, no digital mapping of terrain will be necessary. In
relation to AERMOD, the guidance in AG4 is that digital mapping of terrain should be
conducted where terrain features are greater than 10% of the effective stack height
within 5km of the stack (for effective stack heights of 100m or less). From a review it
is concluded that digital terrain data may be required and was used for the model.
The EIS does not specifically state that terrain data was used but the dispersion
modelling report does state that terrain elevations were obtained from Ordnance
Survey of Ireland and it is assumed therefore that terrain data was used in the
assessment.
Climatological Data
The meteorological data used as input to a dispersion model should be selected on
the basis of spatial and climatological (temporal) representativeness as well as the
ability of the selected parameters to characterise the transport and dispersion
conditions in the area under investigation. The selection of meteorological data for
the Model was discussed in Section 4.1. Meteorological data from Dublin Airport
TMS Environment Ltd
(2011 2013) was the primary data set used for the assessment and data for
Casement Aerodrome (2011 2013) was used for the sensitivity analysis.
Averaging intervals
The dispersion model was used to predict the incremental additions to ground level
concentrations of all substances emitted from the facility over defined averaging
periods. These averaging intervals were chosen to allow direct comparison of
predicted ground level concentrations with the relevant assessment criteria as
outlined in Section 5.2. In particular, 1-hour, 8-hour, 24-hour and annual average
ground level concentrations (GLCs) of various substances were calculated at various
distances from the site; percentiles of these average GLCs were also computed for
comparison with the relevant Air Quality Standards.
Receptor locations
Since the impact of the emissions can be observed at considerable distances from
the emission sources, a fine grid, 3km x 3km centred on the main emission sources
was constructed with receptors located at 50m intervals. A coarse grid, 6km x 6km,
was also constructed with receptors placed at 100m intervals to assess the extent of
dispersion of emissions from the proposed facility. In accordance with best practice
guidance, sensitive receptors in the vicinity of the emission sources are also
specifically identified and included in the Model. On-site receptors are selected to
represent particularly vulnerable locations such as the central garden courtyard, all
upper level terraces and balconies and each Ward Floor Level, and off-site residential
receptors are also included in the model.
Background ambient air quality
The predictions from the dispersion model are evaluated by comparison with Air
Quality Standards. The existing background concentrations of the various substances
must also be added to the predicted impact of the emissions. The existing ambient
air quality in the vicinity of the site has been characterised and a detailed discussion
of the data selection was presented in Section 4.2.
TMS Environment Ltd
Assessment criteria
The model predicts maximum ground level concentrations of substances over
specified averaging intervals; these values are then compared with the relevant Air
Quality Standards to verify that the Standards are not exceeded. In this report, the
predicted ground level concentrations are assessed against the Air Quality Standards
as set in Directive (2008/50/EC). Council Directive 2008/50/EC, known as the Clean
Air for Europe (CAFE) Directive was transposed into Irish law in June 2010. The limit
values imposed by Directive (2008/50/EC) are presented in Table 3. As noted earlier,
it is also appropriate to consider the WHO Guidelines in Table 4 in view of the
particular sensitivity of the development proposal and site.
5.4.3.3 Impact assessment predictions

The impact assessment involves execution of modelling runs to represent different
potential scenarios associated with the emissions. The following Scenarios were
considered in the runs.
(i) Fuel type Model Runs were executed for all Main emission sources running
on natural gas and separately on diesel fuel;
(ii) Stack height Model Runs were executed to consider the effect of varying
stack height on the impact predictions;
(iii) Meteorological data Model Runs were executed to consider the effect of
meteorological data set selection on the impact predictions;
(iv) NOx chemistry Model Runs were executed using the different approaches
for treating the conversion of NO to NO2;
(v) Pollutant concentrations Model Runs were executed to evaluate the effect
of varying pollutant emission rates on the impact predictions.
(vi) Expansion of the childrens hospital and future maternity hospital Model
Runs were executed to evaluate the effect of the proposed increase in
capacity and the location of a maternity hospital at the site.
The dispersion Modelling assessment completed for this impact assessment report
predicts a significantly greater impact of the emissions on air quality than that
TMS Environment Ltd
presented in the EIS. The predicted air quality impacts for NO2 for just the existing
facility plus the Childrens hospital without expansion, and without the maternity
hospital, is up to 10 times greater than the impact predictions presented for NOx in
the EIS. The annual mean predicted ground level concentration for NO2 when the
background concentration selected in section 4.2 is considered, is 32.1 g/m 3 which
is 80% of the Air Quality Standard. This does not take into account the future
expansion of the childrens hospital and the future location of the maternity hospital
at the campus. The predicted impact for continuous use of diesel oil as the fuel
results in even higher impact predictions.
The dispersion modelling impact assessment carried out for this assessment report
has led to significantly higher predicted impacts than those presented in the EIS. The
modelling results suggest that there is insufficient assimilative capacity in the
proposed city centre location to ensure that air quality standards are not exceeded
as a result of the very significant emissions that will be released from the Energy
Centre for the combined activities on the site. The results further suggest that when
the significantly higher emissions associated with the expansion of the proposed
childrens hospital and the future maternity hospital are considered, Air Quality
Standards could be exceeded as a result of the emissions. This leads to the
conclusion that the proposed city centre location is not a suitable location for the
proposed development. Areas removed from the city centre with lower baseline air
pollutant concentrations would have greater assimilative capacity and would be
more suitable from air quality impact considerations than the proposed city centre
location.
TMS Environment Ltd
The impact assessment methodology described in Section 12.1.2.3 of the EIS for the
prediction of air quality impacts focuses on the impact of emissions from transport
during the operation phase of the proposed development. The methodology is based
on the National Roads Authority Guidelines for the Treatment of Air Quality During
the Planning and Construction of Major Road Schemes. While this is an excellent
methodology for assessing the air quality impact of major road schemes, there are
very significant differences between a road scheme and a fixed site such as the site
of the proposed Childrens hospital at St Jamess Street. I am therefore concerned
that the methodology may not be the most appropriate for this assessment.
Operational Phase air quality impacts are discussed in Section 12.1.7.2 of the EIS.
The receptors chosen for the impact assessment are residential receptors along the
link roads to the Hospital site. The methodology adopted involves a prediction of the
effect on air quality of the traffic-derived pollutants and assesses significance in
terms of the magnitude of the increase in concentration of the pollutant in ambient
air. However, this is not a major road scheme development and for many reasons
the methodology may be inappropriate.
The use of the NRA Major Road Scheme methodology in the EIS only considers the
off-site impact of road transport on air quality. No on-site receptors appear to have
been chosen for this aspect of the assessment, and the methodology appears not to
have been applied to the evaluation of the air quality impact of increased traffic
movements on the St Jamess Street campus site. Therefore the predictions given in
Table 12.16 to 12.20 are likely to underestimate the potential impact of the trafficderived emissions on these receptors. This is of particular concern when the
sensitivity and vulnerability of the hospital patients is considered.
As noted in Section 4.2 of this report, the existing baseline concentrations of various
pollutants and especially the traffic-derived pollutants are understated in the EIS. I
have shown in Tables 1a to 1g and summarised in Table 2 the basis for my opinion
that the EIS understates the existing baseline levels of Nitrogen oxides, nitrogen
dioxide and PM10 by as much as 67%. Taking the baseline as data that includes the
traffic contributions for this urban site is critical for evaluating the potential impact
TMS Environment Ltd
of the emissions from this proposed activity on air quality and the EIS has failed to
consider this correctly. Although the relatively small traffic volumes mean that this is
not the most significant Operational Phase air quality impact, it is essential that the
assessment is carried out using the correct methodology, the correct baseline data
and that it leads to a reliable statement of potential impact.
The assessment of Operational Phase impacts on sensitive ecosystems is described
at Page 9-23 in Section 12.1.7.2 of the EIS. This section describes only the air quality
impact of Operational Phase traffic movements on the Grand Canal pNHA. It is
acknowledged in the EIS that the Air Quality Standard for NO x for the protection of
vegetation is exceeded for the Do Nothing scenario and also for the Do something
scenario, but the EIS concludes that there is no need for the ecologist to assess the
significance of the impact because the predicted impact is less than 2 g/m 3. This is
an incomplete assessment because not all sources of nitrogen oxides associated with
the development have been considered. Of far greater significance is the potential
impact of NOx emissions from the Energy Centre on ambient air quality but this has
not been mentioned or considered in the assessment in fact, the dispersion
modelling report (Appendix 12.3 ) specifically states that this is not considered in any
way. This is a very significant omission from the air quality impact assessment and I
am concerned that the potential impact is significantly understated.
The potential impact of emissions due to the energy requirements of the site is
considered in section 12.1.7.4 of the EIS. The single paragraph in the Air Quality
Impact Assessment Chapter of the EIS on this important subject states that
emissions of nitrogen oxides from the Boilers, generators and CHP engines will occur
and that Arup Engineers carried out a dispersion modelling study in relation to the
design of the new discharge flues. That dispersion model report is presented in
Appendix 12.3 of the EIS, and the EIS notes that it concluded that the predicted
ground level concentrations at the most sensitive receptors are in compliance with
the applicable air quality standards.
The emissions from the Energy Centre are the dominant emissions to atmosphere
from the existing and proposed campus. I am concerned that the assessment is
incomplete and that the impact of the most significant emissions from the proposed
TMS Environment Ltd
development is understated. I have reviewed the information presented in the EIS
very carefully and there are a considerable number of omissions and methodology
questions which lead me to conclude that the Appendix in the EIS which describes
the dispersion modelling assessment for the Energy Centre does not give a reliable
statement of the impact of emissions from this most significant source of emissions
associated with the Operational Phase of the development. The main concerns with
the assessment are summarised as follows:
The EIS only considers emissions of nitrogen oxides from the Energy Centre
and ignores the other potentially significant pollutants which include CO, SO2,
PM10 and PM2.5. There is no explanation given in the EIS for the omission.
The EIS does not consider the air quality impact of using diesel or gas oil
instead of natural gas;
The meteorological data selected in the dispersion modelling report is

different from the data used in the main Chapter of the EIS and is out of date
which means that best practice has not been utilised in the assessment.
The dispersion modelling assessment ignores the assessment of potential

emissions on sensitive ecosystems such as the Grand Canal pNHA. This is
especially surprising since the main section of the EIS does consider one
Operational Phase impact on the pNHA but ignores the most significant
potential impact on this sensitive receptor.
The baseline air quality data used in the dispersion modelling assessment is
inappropriate for the areas of potential maximum impact based on the data
presented in the modelling report. This means that the impact predictions
are understated.
It appears from the data presented in the dispersion modelling report that
only nitrogen dioxide has been modelled and not nitrogen oxides. This is
inappropriate and therefore the potential air quality impact may have been
understated.
The emission rate projections from the Energy Centre presented in Appendix
12.3 of the EIS and assessed in the modelling study are approximately 16% of
the levels estimated in this report; this extremely large difference in
TMS Environment Ltd
estimates requires detailed consideration to ensure that air quality impacts
are not understated.
The incremental contribution to emissions from the proposed Childrens

Hospital has not been specifically identified in the EIS which is inconsistent
with best practice. It is therefore not possible to determine the reliability of
the emissions projections since insufficient data was provided.
Appendix 12.3 notes that four Hot Water Boilers, two CHP engines and four
Steam Boilers will be required to serve the requirements of the site. However
elsewhere in the EIS it is stated that there will be a greater number of
emission sources (Section 5.2).
Emission rate data for NOx for each emission source considered are provided
but there is no rationale provided for how the data was derived. The
projections given in this report show that the figures that are given in the EIS
understate the magnitude of the emissions. The St Jamess Hospital Campus
is already a large complex and has very considerable energy requirements
resulting in significant emissions from the Energy Centre. Adding in the
proposed Childrens Hospital will more than double the energy requirement
for the site and a very significant level of emissions is expected.
The impact of emissions from traffic and the Energy Centre on on-site
receptors has not been fully assessed.
TMS Environment Ltd
6.0
Conclusions
The main conclusion drawn from this assessment of air quality impacts of the
proposed new childrens hospital is that the assessment presented in the EIS
understates the potential impact of the emissions. This conclusion is drawn because
the impacts of the most significant emissions from the facility have not been reliably
assessed and no cumulative impact assessment has been undertaken. There are also
significant concerns about the methodology adopted in the EIS for aspects of the air
quality impact assessment.
The assessment indicates that there is insufficient assimilative capacity in the
receiving environment to ensure that emissions to atmosphere from the proposed
development do not lead to an exceedance of Air Quality Standards (or Guidelines).
The assessment also suggests that the city centre location proposed for the national
childrens hospital is unsuitable due to the poorer air quality in the area, and that
there is insufficient capacity to allow for future expansion of the childrens hospital
or the or the new maternity hospital in the same area.

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AIR QUALITY IMPACT ASSESSMENT OF

THE JACK & JILL FOUNDATION

Report Ref 22577

Introduction and scope

The development proposal

Impact assessment approach

The receiving environment

Meteorological data for the air quality impact assessment

Baseline air quality in the receiving environment

Air quality impact assessment

Potential air quality impacts

Air Quality Standards and impact assessment criteria

Prediction and evaluation of Construction Phase impacts on air quality

5.3.1 Potential Construction Phase air quality impacts

Prediction and evaluation of Operation Phase air quality impacts

5.4.1 Potential Operation Phase air quality impacts

Report Ref 22577 Page 2 of 69

Characterise the receiving environment in terms of baseline air quality and

Report Ref 22577 Page 3 of 69

Report Ref 22577 Page 4 of 69

Report Ref 22577 Page 5 of 69

the magnitude of the emissions that were considered is underestimated;

Report Ref 22577 Page 6 of 69

Report Ref 22577 Page 7 of 69

Introduction and scope

Report Ref 22577 Page 8 of 69

The development proposal

Construction of a new childrens hospital building and associated helipad;

Construction of the Childrens Research and Innovation Centre;

Construction of a Family Accommodation Unit;

Public realm improvements including existing campus spine road, demolition

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

A new vehicular entrance from Mount Brown;

A realigned internal campus road;

A new shared flue stack for the campus;

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

Report Ref 22577 Page 9 of 69

Impact Assessment Approach

Air quality impact assessment approach

Characterise emissions & potential impacts

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

Report Ref 22577 Page 10 of 69

Report Ref 22577 Page 11 of 69

The receiving environment

Meteorological data for the air quality impact assessment

Report Ref 22577 Page 12 of 69

Windroses for Casement Aerodrome and Dublin Airport for 2010

Casement Aerodrome (2010)

Dublin Airport (2010)

Report Ref 22577 Page 13 of 69

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

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

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

Report Ref 22577 Page 14 of 69

Proximity of Diageo Roast House and Energy Centre to St Jamess

Hospital Energy Centre

Approximate distance from St Jamess

Distance from the Energy Centre

Report Ref 22577 Page 15 of 69

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

Report Ref 22577 Page 16 of 69