NATURA IMPACT STATEMENT SECTION 30 DEROGATION PROPOSED DEMOLITION WORKS BLACKROCK BATHING POOL, BLACKROCK, CO.

DUBLIN

DUN LAOGHAIRE-RATHDOWN COUNTY COUNCIL

Rev. D01

Status Final

Author PS

Reviewed By AC

Approved By AC

Issue Date 04/09/12

Scott Cawley, 27 Lower Baggot Street, Dublin 2, Ireland Tel+353(1)676-9815 Fax +353(1) 676-9816

TABLE OF CONTENTS
1 2 3 4 5 Introduction ................................................................................................................................... 3 Methodology .................................................................................................................................. 3 Overview of Proposed Works......................................................................................................... 4 Overview of Receiving Environment .............................................................................................. 9 Appropriate Assessment of Relevant Sites .................................................................................. 15 5.1 Understanding of Site Condition, sensitivities and threats to integrity. ...................................... 15 5.1.1 South Dublin Bay cSAC (000210)............................................................................................... 15 5.1.2 South Dublin Bay and Tolka Estuary SPA (004024) ................................................................... 17 5.2 Impact Prediction and Mitigation ................................................................................................. 20 5.2.1 Impacts mitigated by design and timing ................................................................................... 20 5.2.2 Impacts mitigated by other measures. ..................................................................................... 21 5.2.3 Implementation of Mitigation measures .................................................................................. 21 5.2.4 Degree of confidence in the likely success of the mitigation measures ................................... 21 5.2.5 Proposed monitoring of the mitigation measures.................................................................... 21 6 Conclusions of Assessment Process .................................................................................................. 22 7 References .................................................................................................................................... 23

LIST OF TABLES Table 1 Table 2 Table 3 Identification of relevant Natura 2000 Sites ......................................................................... 13 cSAC Sites Detail.................................................................................................................... 16 SPA Site Detail ....................................................................................................................... 18

LIST OF APPENDICES APPENDIX A ........................................................................................................................................... 24 Method Statement................................................................................................................................ 24 APPENDIX 2 ........................................................................................................................................... 25 Drawing CL1631-01 showing site layout ............................................................................................... 25

Project Purple IDA Business Park, Co. Kilkenny

Appropriate Assessment PM Group

Introduction

This Natura Impact Statement (NIS), which contains information required for the National Parks and Wildlife Service under Section 30 of the European Communities (Birds and Habitats) Regulations, 2011 (S.I. No. 477 of 2011) has been prepared by Scott Cawley Ltd. on behalf of Dun Laoghaire-Rathdown County Council. It provides information on and assesses the potential for the proposed activity to impact on Natura 2000 sites1. The information in this NIS forms part of and should be read in conjunction with the attached documentation including the Method Statement and maps being submitted to the NPWS. 2 2.1 Methodology Guidance and Approach

This NIS has been prepared with regard to the following guidance documents where relevant: Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities. (Department of Environment, Heritage and Local Government, 2010 revision). Appropriate Assessment under Article 6 of the Habitats Directive: Guidance for Planning Authorities. Circular NPW 1/10 & PSSP 2/10. Assessment of Plans and Projects Significantly Affecting Natura 2000 sites: Methodological Guidance on the Provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC (European Commission Environment Directorate-General, 2001); hereafter referred to as the EC Article 6 Guidance Document. (The guidance within this document provides a non-mandatory methodology for carrying out assessments required under Article 6(3) and (4) of the Habitats Directive.) Managing Natura 2000 Sites: The Provisions of Article 6 of the Habitats Directive 92/43/EEC (EC Environment Directorate-General, 2000); hereafter referred to as MN2000. Guidelines for Good Practice Appropriate Assessment of Plans Under Article 6(3) Habitats Directive (findings of International Workshop on Assessment of Plans under the Habitats Directive, Oxford 2010)

In this NIS, guidance which has been followed in determining magnitude and significance of impacts as well as in proposing mitigation measures, where relevant to Natura 2000 site qualifying interests, include: 2.2 NRA Series of Environmental Planning and Construction Guidelines (2005 2010), including Guidelines for assessment of Ecological Impacts of National Road Schemes (NRA, 2009) Guidelines for Ecological Impact Assessment in the United Kingdom (Institute of Ecology and Environmental Assessment, 2006)

Site Surveys

This NIS was based on a desktop study as well as site walkover surveys undertaken in September 2012. Ecological information has been provided by consultation with National Parks and Wildlife Service and by our familiarity with ecological issues, threats and sensitivities at the location of the proposed works.

Natura 2000 sites are part of an EU-wide network of nature protection areas established under the EU Habitats Directive. The aim of the network is to aid the long-term survival of Europe's most valuable and threatened species and habitats. In Ireland it is comprised of Special Areas of Conservation (and candidate Special Areas of Conservation) designated as per the requirements of the Habitats Directive, and also incorporates Special Protection Areas designated as per the EU Birds Directive. Blackrock Baths Appropriate Assessment 3 DLRCC

2.3

Desktop Study

Sources of Desktop Data relied upon in producing this NIS are listed below: Online data available on Natura 2000 sites as held by the National Parks and Wildlife Service (NPWS) (www.npws.ie) Status of EU Protected Habitats in Ireland - Backing Volumes 1, 2 & 3 (NPWS, 2007) Documents, Article 17 forms & Maps

Status of EU Protected Habitats in Ireland. (NPWS, 2008) Ordnance Survey Ireland maps and aerial photography (www.osi.ie) MyPlan website (www.myplan.ie) Information on water quality in the area available from the Environmental Protection Agency (EPA) (www.epa.ie) and from the applicants design team Information on the South Eastern River Basin District from www.wfdireland.ie All-Ireland Birds of Conservation Concern list 2008-2013 (Lynas et al., 2007) British Trust for Ornithology and Birdwatch Ireland Bird Atlas 2007-2011 Data for Tetrad O22H. Available online at http://blx1.bto.org/atlas/square-access/num-square-summ.jsp Accessed 16/05/2012 Information on the location, nature and design of the proposed development supplied by the applicants design team. Other relevant ecological publications, reports and literature (as provided in the Reference list at the end of this report).

2.4

Consultation

Consultation was undertaken by telephone with Oscar Merne, consultant ornithologist on bird movements at the location of the proposed works. Informal consultation was also undertaken by telephone with the National Parks and Wildlife Service. 3 Overview of Proposed Works

The works comprise the following: 1. Breach of north side of bathing pool wall to enter bath complex and to install machinery. 2. Demolition of Diving boards and part of grandstand on south side both of which are deemed to be in dangerous condition. 3. Demolition waste will consist of metal-reinforced concrete and metal. 4. Waste to be removed from the Baths to Merrion Gates via an identified haul route. Site setting out: Demolition waste holding area and compound will be demarcated at the strand line at Merrion Gates. Haul route will be identified and set out by ecologist using moveable markers such as concretefilled tyres + marker posts. The optimum route has been identified as heading around the sand spit to the NE to avoid any areas of Zostera, Salicornia or dune systems. The haul route is entirely
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on intertidal sand/mudflat. The site setup will be checked by an ecologist each day. Up to four streams have to be crossed and can be done safely in the intertidal area. Site compound (toilets etc) to be set up in Blackrock nr the DART station. Refueling will take place at the baths with double-bunded tank placed on level concrete ground with spill-kit in place. Refuelling will also take place at Merrion gates but in hardstanding ground away from the shoreline.

Movement of machinery: 25 tonne excavator to enter strand via Merrion Gates and to pass along haul route. Will remain on site until completion of works. Dumper trucks with wide rubber tyres will move waste from baths to Merrion gates storage area, max speed 20km. No stopping permitted unless in emergencies. Tracked machine will load waste from storage area to waste transfer off-site. It is envisaged that the two dumper trucks would average an approx. 20 no loads between them on a daily basis. It is expected that the majority of loads would be removed off site over a 4 day period. Period of disturbance will be 6-7 hours per day in daylight- thereby avoiding impacts on tern roost at sand spit Works at the baths at high tide may take place but will be temporary in duration and only in daylight hours.

Photo 1: View from top of area to be removed.

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Photo 2: View of diving board and grandstand.

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Photo 3: View of proposed demolition area.

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Zostera beds

Salt marsh

Sand dune

Photo 4 Location of haul route (red dotted line) around Salt marsh and sand dune habitats.

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4 4.1

Overview of Receiving Environment Brief Site Description

The proposed works footprint includes the former Blackrock bathing pool (the baths) and the area occupied by the proposed access/haul route from Merrion gates, across the intertidal zone to the baths. The baths themselves are not within the boundary of a European Site but are surrounded by the South Dublin Bay cSAC and the South Dublin Bay and River Tolka Estuary SPA, on all but its landward side. The baths comprise of concrete and metal structures although the central bathing area has become infilled with sand somewhat. The lands between the baths and the access point at Merrion gates are typical of South Dublin Bay with a steep sea wall (CC1) with occasional vegetation cover leading to intertidal sediments mainly sandy shore and muddy sand shore habitats. Marine invertebrate life is rich with evidence of Lugworm Arenicola marina and sand mason worms Lanice conchilega being particularly obvious. This habitat stretches to the northwest where after approximately 2km a raised bank of sand dune habitat has been formed by the deposition of sediment. This raised area has a clearly- identifiable belt of sandy shore (LS2) habitat which is interspersed with softer muddy-sand sediments (LS3) lower down the shoreline. The proposed haul route will avoid the softer areas close to the edge of the strandline. The sand spit that occurs at this location has recently been re-shaped by wave and currents in Dublin Bay. Much of the extended sandy shore feature that extended northwards has been lost, leaving behind a lower flattened area of intertidal mud/sand sediments. At the time of the walkover survey there were small flocks of Oystercatcher, Ringer Plover and Black-headed gulls at the low tide mark. The proposed haul route follows the sand shore and muddy sand shore habitats up to Merrion gates. At this point the route crosses the strandline. A demolition waste holding area approximately 16m x 20m will be located between the strandline and the edge of the vegetation at Merrion gates. Whilst not typical dune habitat, there are elements of the upper shore that are embryonic dune and these will be avoided. The haul route will cross a short area of amenity grassland before reaching the road at Merrion gates. The zone of influence of the proposed development is more or less limited to the Baths and the haul route in terms of physical disturbance. However, potential vibration, noise and pollution events from surface, ground, air and waste discharges could potentially extend beyond the boundaries of the proposed activity footprint.

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Photo 5: Location of Turning point A, 50m north of salt marsh habitat, looking at mouth of Elm Park Stream outflow.

Photo 6: Location of Turning point A looking toward Merrion gates.

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Photo 7: Location of Turning Point A looking toward Blackrock baths.

Photo 8: Edge of dune habitat looking north. Dotted line marks route of haul route.

4.2

Features of the Surrounding Environment

The intertidal habitat continues to the NW to the low water mark, much of which is used by waders and small numbers of wildfowl at this time of year (early September). From October to March, there are large numbers of overwintering waders and wildfowl using this area of intertidal and coastal habitat for roosting and feeding. In late August-early September the sand spit is known to host several thousand Terns (mostly Common with occasional Arctic, Roseate and Sandwich Terns) which use the area above the tide for roosting at night, prior to their autumn migration. The sand spit supports intertidal habitats and dune habitat including embryonic, marram and fixed dunes as well as upper salt marsh habitat. This salt marsh habitat is found on the NW side of the dune area and
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flanks the outflow of the Elm Park Stream. The muddy sediments here support frequent clumps of Salicornia sp.- suggesting ongoing evolution of lower salt marsh communities. There are no areas of Salicornia sp. or organic-rich sediment within 50m of the proposed haul route. Further to the NW of Merrion Gates there is an area of muddy shore which is colonised by Eelgrass Zostera sp and is known to be a feeding ground for Pale-bellied Brent Geese. It is located c.100m from any element of the proposed activity. 4.3 Other development nearby which may lead to cumulative impacts upon local ecology

The proposed works are to take place as soon as possible, with the aim of completion by the end of September to avoid conflicts with the arrival of overwintering waders and wildfowl. There are no other known developments along the foreshore that would be expected to occur at the same time as the proposed activities. 4.4 Location of European sites

Designated sites within 1km, 5km and 15km of the proposed development site are shown in Figure 1. The overlap between the proposed activities and the cSAC and SPA warrants these two designations to be focus for the remainder of the assessment. 4.5 Summary of AA Screening Conclusions

As can be seen from Table 1 there is a potential for significant negative impacts on European sites and the need for AA of these sites has been acknowledged. Therefore more detailed assessment of potential impacts on these sites is taken forward in Section 4.

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Table 1

Identification of relevant Natura 2000 Sites

& Distance from Development Qualifying Interests (i.e. reasons for designation) (* = Priority Annex I Habitats, ! = Species/habitats which are listed either on http://www.npws.ie/protectedsites/ as Features of Interest, or on the NPWS Conservation Objectives published on dates stated below, but not both; given this discrepancy all such species/habitats are assumed to be Qualifying Interests) Mudflats and sandflats not covered by seawater at low tide [1140]. Natura of potential source-pathwayreceptor links exist between the proposed development and the Natura 2000 site?

(Natura 2000 sites are considered relevant where a source-pathway-receptor link2 exists between the proposed development and Natura 2000 sites.) Site Name Code

candidate Special Areas of Conservation (cSAC) South Dublin Bay cSAC (000210) Immediately adjacent. Yes- direct, temporary disturbance of mudflat habitat by movement of trucks over the period of works.

Special Protection Areas (SPA) South Dublin Bay Tolka Estuary SPA (004024) Immediately adjacent. Branta bernicla hrota [wintering] Haematopus ostralegus [wintering] Charadrius hiaticula [wintering] Pluvialis squatarola [wintering] Calidris canutus [wintering] Calidris alba [wintering] Calidris alpina [wintering] Limosa lapponica [wintering] Tringa totanus [wintering]
2

Yes- direct, temporary disturbance of birds at low tide during movements of trucks. Temporary disturbance of birds at high tide roosts near baths due to demolition works.

In ecological and environmental impact assessment, for an impact to occur there must be a risk enabled by having a 'source' (e.g. construction works at a proposed development site), a 'receptor' (e.g. a SAC or other ecologically sensitive feature), and a pathway between the source and the receptor (i.e. a watercourse which connects the proposed development site to the SAC). The risk of the impact does not automatically mean it will occur, nor that it will be significant. However, identification of the risk does mean that there is a possibility of ecological or environmental damage occurring, with the level and significance of the impact depending upon the nature and exposure to the risk and the characteristics of the receptor. Blackrock Baths Appropriate Assessment 13 DLRCC

Table 1

Identification of relevant Natura 2000 Sites

& Distance from Development Qualifying Interests (i.e. reasons for designation) (* = Priority Annex I Habitats, ! = Species/habitats which are listed either on http://www.npws.ie/protectedsites/ as Features of Interest, or on the NPWS Conservation Objectives published on dates stated below, but not both; given this discrepancy all such species/habitats are assumed to be Qualifying Interests) Larus ridibundus [wintering] Sterna dougallii [passage] Sterna hirundo [breeding] Sterna hirundo [passage ] Sterna paradisaea [passage] Wetland habitats Natura of potential source-pathwayreceptor links exist between the proposed development and the Natura 2000 site?

(Natura 2000 sites are considered relevant where a source-pathway-receptor link2 exists between the proposed development and Natura 2000 sites.) Site Name Code

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Appropriate Assessment of Relevant Sites

Detailed information on the two Natura 2000 sites for which the likelihood of significant negative impacts could not be ruled out are provided below. This information is required to be able to identify and assess potential impacts which may arise from the proposed development, or cumulatively with other developments, and includes: Qualifying interests and conservation objectives for the Natura 2000 sites (i.e. reasons for the designation of the Natura 2000 sites); Current conservation status of qualifying interests; Conditions underpinning or required for favourable conservation status of the qualifying interests and/or overall site integrity; and Known threats to the qualifying interests and/or overall site integrity.

5.1

Understanding of Site Condition, sensitivities and threats to integrity. This Section summarises an understanding of the European site in terms of its conservation interests, the environmental conditions that maintain population and ecosystem integrity and the threats to those environmental conditions. Once these are understood it can then be determined how the proposed development may affect these sensitivities and how they can be mitigated.

5.1.1

South Dublin Bay cSAC (000210)

The site synopsis for the European Site includes the following relevant information: The sediments are predominantly sands but grade to sandy muds near the shore at Merrion gates. There is a bed of Eelgrass (Zostera noltii) below Merrion Gates which is the largest stand on the east coast. A small area of pioneer salt marsh now occurs in the lee of an embryonic sand dune just north of Booterstown Station. This early stage of salt marsh development is here characterised by the presence of pioneer stands of Glasswort (Salicornia spp.) occurring below an area of drift line vegetation. As this is of very recent origin, it covers a small area but ample areas of substrate and shelter are available for the further development of this habitat. The small gastropod Hydrobia ulvae occurs on the muddy sands off Merrion Gates.

Table 2 sets out the details regarding the conservation management objectives for the site.

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cSAC Sites Detail

Qualifying Interests Current Conservation Status3
Poor

Site Name & Distance from Code Development

Conservation Management Objectives

To maintain or restore the favourable conservation condition of the Annex I habitat for which the SAC has been selected: Mudflats and sandfl

Conditions underpinning site integrity

Tidal influence Nutrient influx Water quality Lack of disturbance by currents or extraction.

Threats to site integrity4

candidate Special Areas of Conservation (cSAC) South Dublin Bay cSAC (000210) Immediately adjacent. Mudflats and sandflats not covered by seawater at low tide [1140].
200 Aquaculture 210 Professional fishing 221 Bait digging 244 Removal of fauna 300 Aggregate extraction (removal of beach material) 422 Disposal of industrial waste 490 Industrialisation 504 Port/Marina 509 Communications networks 802 Reclamation of land 870 Coastal protection works 954 Invasion by a species

ats not covered by s eawater at low tide [1140].

3 Sourced from Status of EU Protected Habitats and Species in Ireland (NPWS, 2007). 4 Sourced from Status of EU Protected Habitats and Species in Ireland (NPWS, 2007) and/or Natura 2000 Standard Data Forms (NPWS, 2011). Blackrock Baths Appropriate Assessment 16 DLRCC

5.1.2

South Dublin Bay and Tolka Estuary SPA (004024)

The site synopsis for the European Site includes the following relevant information: The sediments are predominantly well-aerated sands. Several permanent channels exist, the largest being Cockle Lake. A small sandy beach occurs at Merrion Gates, while some bedrock shore occurs near Dun Laoghaire. The landward boundary is now almost entirely artificially embanked. There is a bed of Dwarf Eelgrass (Zostera noltii) below Merrion Gates which is the largest stand on the east coast. The macro-invertebrate fauna is well-developed, and is characterised by annelids such as Lugworm (Arenicola marina), Nephthys spp. and Sand Mason (Lanice conchilega), and bivalves, especially Cockle (Cerastoderma edule) and Baltic Tellin (Macoma balthica). The small gastropod Spire Shell (Hydrobia ulvae) occurs on the muddy sands off Merrion Gates, along with the crustacean Corophium volutator. The site is a Special Protection Area (SPA) under the E.U. Birds Directive, of special conservation interest for the following species: Light-bellied Brent Goose, Oystercatcher, Ringed Plover, Golden Plover, Grey Plover, Knot, Sanderling, Dunlin, Bartailed Godwit, Redshank, Black-headed Gull, Roseate Tern, Common Tern and Arctic Tern. The E.U. Birds Directive pays particular attention to wetlands, and as these form part of the SPA, the site and its associated waterbirds are of special conservation interest for Wetland & Waterbirds. An internationally important population of Light-bellied Brent Goose (525) occurs regularly and newly arrived birds in the autumn feed on the Eelgrass bed at Merrion. The south bay is an important tern roost in the autumn (mostly late July to September). Birds also use the Dalkey Islands to the south. The origin of many of the birds is likely to be the Dublin breeding sites (Rockabill and the Dublin Docks)though numbers suggest that the site is also used by birds from other sites, perhaps outside the state. More than 10,000 terns have been recorded, consisting of Common, Arctic and Roseate terns.

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Table 3

SPA Site Detail

Qualifying Interests Current Conservation Status5 Conservation Management Objectives
To maintain or restore the favourable conservation condition of the bird species listed as Special Conservation Interests for this SPA (see first column)

Site Name & Distance from Code Development Special Protection Areas (SPA) South Dublin Bay Tolka Estuary SPA (004024) Immediately adjacent.

Conditions underpinning site integrity

Lack of disturbance Food supply High and low tide roosts Lack of predation Shelter from adverse weather Protection from exploitation.

Threats to site integrity6

Branta bernicla hrota [wintering] Haematopus ostralegus [wintering] Charadrius hiaticula [wintering] Pluvialis squatarola [wintering] Calidris canutus [wintering] Calidris alba [wintering] Calidris alpina [wintering] Limosa lapponica [wintering] Tringa totanus [wintering] Larus ridibundus [wintering] Sterna dougallii

Least Concern Least Concern Least Concern Least Concern Least Concern Least Concern Least Concern Least Concern Least Concern Least Concern Least Concern

All species Climate change altering breeding/wintering habitat and feeding resources Habitat Loss Pollution Human disturbance including disturbance from vehicles, walkers and dogs Over-fishing Soil erosion Extreme weather events Hunting Species-specific Eelgrass disease (B.B.hrota) Thinning of egg shells due to chemical pollution

5 Sourced from Status of EU Protected Habitats and Species in Ireland (NPWS, 2007). 6 Sourced from Status of EU Protected Habitats and Species in Ireland (NPWS, 2007) and/or Natura 2000 Standard Data Forms (NPWS, 2011). Blackrock Baths Appropriate Assessment 18 DLRCC

Table 3

SPA Site Detail

Qualifying Interests Current Conservation Status5 Conservation Management Objectives Conditions underpinning site integrity Threats to site integrity6
(Sterna sp.) Least Concern Least Concern Least Concern Egg predation by rats, Peregrine Falcon, Falco peregrinus and foxes Vulpes vulpes (Sterna spp.) Scrub overgrowth (C.hiaticula)

Site Name & Distance from Code Development

[passage] Sterna hirundo [breeding] Sterna hirundo [passage ] Sterna paradisaea [passage]

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5.2

Impact Prediction and Mitigation

An analysis of impact assessment typically requires the identification of the type and magnitude of potential impacts; direct and indirect; short and long term; construction, operational and decommissioning effects; and isolated, interactive and cumulative effects. In this instance the assessment requires the identification of the impacts on the cSAC and the SPA as a result of the proposed activities. These are described below. For each potentially significant impact there is a proposed mitigation measures that will avoid, reduce / minimise or remediate the significance of the potential impact. Some of the potential impacts have already been avoided by the design and timing of the works. These are listed below in 5.2.1. Mitigation measures have been placed in boxes for easy reference. 5.2.1 Impacts mitigated by design and timing

Habitat loss: There is not predicted to be any permanent habitat loss as a result of the proposed activity. The location of the site compound on the sandy shoreline at Merrion gates (above MHWM) avoids both the mud shore/mudflat habitat and the embryonic sand dune habitat. There will be demolition waste stored at the compound and removal of this will disrupt the underlying sand. However this disruption can be easily repaired by machine and then hand following completion of the activity. Restoration of the dune habitat is not as easy or as successful. The site compound cannot be below the MHWM. Movement of the tracked excavator and the Dumper trucks is not expected to cause permanent loss of habitat. Whilst all vehicle movements will be around low tide, there will be temporary and localised compression of the upper layers of sand but this is unlikely to result in significant invertebrate mortality. Vehicle movements will avoid all dunes, salt marsh habitat and Zostera beds. This will be enforced by setting out the site by an ecologist who will also carry out periodic checks of vehicle movements.

Bird Disturbance: Significant disturbances to bird species that constitute the list of conservation interests of the SPA will be avoided by timing the works prior to the main influx of migratory birds to the area. Whilst there are many of these species already present in roosting and feeding flocks in Dublin Bay, their numbers will be swelled by winter migrants and birds coming to the coast from inland breeding sites in October. All works will aim to be completed by the end of September. Disturbance of the tern roost will be avoided by ensuring that all works are completed two hours before sunset and commence no earlier than one hour after sunrise. This will be enforced by an ecologist who will visit the site at such times to ensure no works are occurring. Some disturbance of birds at low tide is inevitable and an ecologist will log any patterns of disturbance such as repeated displacement of birds as such information is useful for the management of the SPA in the future. Works at high tide at the baths (but not along the haul route) may have to take place to ensure that the works can be completed by the end of September. These may lead to temporary displacement of the Black-headed, Common and Herring Gulls that use this at high tide. Such an impact not regarded to be significant. Bird disturbance by staff moving around will be limited to the baths area as all staff not driving the dumper trucks will enter and leave the working area at Blackrock.

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5.2.2

Impacts mitigated by other measures.

The following measures have been agreed with DLRCC and are contained within the Method Statement attached in Appendix A. Habitat disturbance at watercourse crossings: Localised physical disruption of the softer sediment may occur at the four watercourse crossings during the movement of the tracked vehicles. A heavy-duty geotextile membrane will be on site to be laid down at these locations where required. There will be no laying of stone or other material.

Spillages of fuel: Fuelling of vehicles and machinery will primarily take place at the baths location via a diesel fuel store. This is a safer location than the sloping ground at Merrion gates where any spillage would be difficult to control. A spill kit will be at hand at this location and the tank will be double- bunded. Fuelling will also take place at the Merrion gates location, at the hardstanding area near the entrance, so that any spillages can be prevented from reaching the shoreline. The measures listed above will avoid creating the threats that could disrupt the conditions underpinning site integrity. The timing of the works and the careful routing of the vehicles will ensure that the most sensitive period of the year and the most sensitive habitats are avoided.

5.2.3

Implementation of Mitigation measures The measures will be implemented by the Contractors: enforcement by DLRCC and Scott Cawley Ltd Staff. Hegarty Demolition Ltd under

A Scott Cawley Ltd ecologist will be on site at the commencement and termination of the setting up stage and then at periods when the material is being removed. An on-site presence is not deemed necessary but this will be reviewed if required.

5.2.4

Degree of confidence in the likely success of the mitigation measures Since much of the mitigation relies upon avoidance by timing of the works and physical avoidance of the sensitive habitats, these measures are relatively easy to enforce which should make their success easily achievable. The short duration of the works is also a factor in raising confidence in success.

5.2.5

Proposed monitoring of the mitigation measures Scott Cawley Ltd will maintain a daily log of observation on site and will also include observations of bird species seen on site and how they react to demolition noise and movements of trucks over the short period of the works. This will be sent to the National Parks and Wildlife Service at the completion of the activity. Scott Cawley Ltd ecologists will revisit the location of the site in October to take photographs of the haul route to assess natural recovery of the sediments, as suggested by lugworm cast density relative to the surrounding area.

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Conclusions of Assessment Process This report provides information to the National Parks and Wildlife Service to allow their determination of derogation under Section 30 of the Regulations. It has set out the proposed methodology for the activity and has described how the timing and design of the works will not result in adverse effects on the integrity of the South Dublin bay cSAC and the South Dublin and Tolka Estuary SPA. Any adverse impacts are deemed to be temporary and reversible in nature.

Blackrock Baths 22

Appropriate Assessment DLRCC

References Byrne, A., Moorkens, E.A., Anderson, R., Killeen, I.J. & Regan, E.C. (2009) Ireland Red List No. 2 Non-Marine Molluscs. National Parks and Wildlife Service, Department of the Environment, Heritage and Local Government, Dublin, Ireland. DoEHLG (2010) Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities (Department of Environment, Heritage and Local Government, Rev Feb 2010) European Commission (2000). Communication from the Commission on the precautionary principle European Commission (2001) Assessment of Plans and Projects Significantly Affecting Natura 2000 sites: Methodological Guidance on the Provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC (European Commission Environment Directorate-General,); European Commission (2000) Managing Natura 2000 sites: The Provisions of Article 6 of the Habitats Directive 92/43/EEC (EC Environment Directorate-General, 2000); hereinafter referred to as MN2000 Environmental Protection Agency (2002). Guidelines on the information to be contained in Environmental Impact Statement. Wexford: Environmental Protection Agency. Available at: http://www.epa.ie/downloads/advice/ea/guidelines/epa_guidelines_eis_2002.pdf Environmental Protection Agency (2011). EPA ENVision Service (internet-based environmental information portal). Available online at: http://maps.epa.ie/internetmapviewer/mapviewer.aspx (Accessed October 2011). Geological Survey of Ireland (2011). GSI Datasets Public Viewer. Available online at http://www.gsi.ie/Mapping.htm. (Accessed October 2011). IEEM (2006). Guidelines for Ecological Impact Assessment. Institute of Ecology and Environmental Management. Institute of Ecology and Environmental Management (2006). Guidelines for Ecological Impact Assessment. Institute of Ecology and Environmental Management. National Parks & Wildlife Service (2010) Circular NPW 1/10 & PSSP 2/10 Appropriate Assessment under Article 6 of the Habitats Directive: Guidance for Planning Authorities. (Department of Environment, Heritage and Local Government). National Parks & Wildlife Service (2007). The Status of EU Protected Habitats and Species in Ireland. Volume 1, 2 ,3. Unpublished Reports National Parks & Wildlife Service. NATURA 2000 Data Form. Available online at http://www.npws.ie/. (Accessed September 2011). NPWS (2011) Conservation objectives for South Dublin Bay SAC [000210]. Generic Version 3.0. Depart ment of Arts, Heritage & the Gaeltacht. NPWS (2011) Conservation objectives for South Dublin Bay and River Tolka Estuary SPA [004024]. Gen eric Version 4.0. Department of Arts, Heritage & the Gaeltacht. National Roads Authority (NRA) 2009. Guidelines for Assessment of Ecological Impacts of National Road Schemes. NRA 2005-2009. Environmental Construction Guidelines Series, available online at: http://www.nra.ie/Publications/Environment/#d.en.3463. (Accessed October 2011).

Blackrock Baths 23

Appropriate Assessment DLRCC

APPENDIX A

Method Statement and Health and Safety Plan

Blackrock Baths 24

Appropriate Assessment DLRCC

Document: Title: Number:

Form Method Statement F 29

Revision Status: 2nd Issue Issue Date: 04/07/2011

METHOD STATEMENT
Contractor Details Name:

Hegarty Demolition Ltd www.hegartydemolition.ie

Project Name: Description of the Task/Activity:

Address: 17 Main Street, Rathfarnham Village, Dublin 14

Tel: 01 490 5058 Fax: 01 4905678 E-mail: noel@hegartydemolition.ie micheal.earley@hegartyde molition.ie

Demolition of Blackrock Baths

Document Number:

HDL MS 01

Risk Assessment Attached?

Yes

The proposed works consist of ; Creating HDL Works zone & Temporary Compound, exclusion consisting of standard type HERAS fencing, Safety Signage and Temporary Physical Protection. Demarcating of Proposed movement routes along the Strand. Mobilisation of Plant & Equipment to the Compound & Works Areas. Mechanical Demolition of Bath structures. Processing and Removal of Rubble to collection and loading areas. Start Date/Time: Finish Date/Time Permits No:
LSS Mechanical

Site Address/Location:

Blackrock Baths, Merrion Road, Dublin 4

TBA TBA TBC

EEW General Permit MEWP Access

Permits Required for the activity? General Project Permits required for the activity Others Permits:

Yes , as per PSCS & Client Requirements

Hot Work Confined Space Excavation Concrete penetration Roof Opes

Yes

Department permit required in accordance with DLRCC & D&D

Name Role/Trade

Liam Hogan Joe Coleman

Personnel Involved

Contracts Director Projects Supervisor EHS Manager General Gangerman General Operative, CSCS Skilled machine Operative General Operative, CSCS Skilled Operator General Operative, CSCS Skilled Operator

Noel Gill Gabriel Bleznuic TBA TBA TBA

Document: Title: Number:

Form Method Statement F 29

Revision Status: 2nd Issue Issue Date: 04/07/2011

METHOD STATEMENT
Contact Tel No: Site Supervisor:

Joe Coleman
Contact Tel No:

086 2624485 086 3862196

Contact Tel No:

Safety Officer

Micheal Earley

Project Manager Details of Crew Personnel specific certification (e.g. CSCS Cards, MEWP driver certification etc)

Liam Hogan PSCS Induction HDL Safety Task Briefing Safe Pass Manual Handling Signaler, Slinger Articulated Dump Trucks 360 Tracked & Wheeled Excavators
(i.e. access platforms/winches/ladders, etc)

086 2562118

Key Plant , Tools and equipment (Attach Certification as required)

Barriers, Signage, Protection Standard Heras Fence with Debris Netting Fitted, Protective Geotextile Membrane, Double Skinned Re-fuelling Tank. Full P.PE as per Specific Works Requirements. 2 no A35 7 CM Volvo Dump Trucks, 1 no 20t Tracked Excavator with muncher attachment, 1 no 16t wheeled excavator with bucket attachments, Spill Kits x 3-4 no. Tipper Trucks.

Safe Working Loads (SWLs) for Lifting Equipment:

(Detail any limits on the loadings applicable to temporary plant/equipment or fixed elements of the structure where the work is taking place)

ALL HDL Excavators are certified with Hoistech, Certbank of lifting gear is available on line and at the M/C Request.

Specific Identified Residual Hazards: (or refer to the task specific risk assessment(s))

Hazards associated with this work; Working near & Adjacent to LIVE services Demolition Work at a Height Operating Heavy Plant & Machinery Movement of heavy plant & machinery Working near live Public Areas Working near live Rail line Working and access through national parks & wildlife areas. Manual Handling

Document: Title: Number:

Form Method Statement F 29

Revision Status: 2nd Issue Issue Date: 04/07/2011

METHOD STATEMENT
Hand Injuries Access & Egress Using hand tools Poor housekeeping/Slips, Trips & Falls Unauthorised persons/interface with other personnel Dust Noise
Specific Training required for Activity:

CSCS for Plant Operators. Safe Pass Manual Handling CSCS Sign Lighting and Guarding of Roadworks

Comments or additional Information above: Pre - Requisites: All Works to be supervised by experienced HDL Project Manager - Project foreman Section Foreman- Project Engineer lead by Joe Coleman HDL All HDL employees to be inducted by the main contractor on site prior to commencement. Additional daily pre-task project specific awareness talks will be issued to HDL operatives by Site Safety Officer in light of the conditions and areas where work is being carried out on a daily basis. All operatives will wear the Required PPE including safety boots, hard hat and high visibility vests (Gloves and Safety Glasses are all mandatory also). Additional PPE may be required for tasks specific jobs. This also shall be reviewed as task specific requirements. 1. The Compound area and proposed haul access routes to and from the Baths will be walked & agreed with HDL & Paul Scott prior to commencement and on a daily basis thereafter to coincide with the daily changes and in particular reference to the current wildlife sanctuary and protected areas in place. Primary Access will be via the Merrion Gate entrance, Here in agreement with DLRCC, HDL will locate a temporary compound enclosed within a Heras Fenced area secured at all times. HDL will then set down with Plant within an agreed area and maneuver them to the compound.

Sequence of Operations: (Include sketches if required)

2.

Document: Title: Number:

Form Method Statement F 29

Revision Status: 2nd Issue Issue Date: 04/07/2011

METHOD STATEMENT
3. From the Compound area, a 4km Route will then be reviewed and marked out with Paul Scott & DLRCC officials for HDL to track a 25t tracked excavator from the compound to the site location. Along the route there are storm water outfall locations, these will have a heavy duty geotextile membrane laid across temporarily to protect as these are maneuvered across. The Plant will continue to the works area, in accordance with the tidal times, works will commence with the formation of entrance to the baths at the wall on the North West elevation. This section of wall is deemed to be severely cracked, a safe section will be removed leaving a buttress to either side. Within the Bath area, HDL will locate a double bunded Diesel tank with pump for refueling the tracked excavator on site only. This will be accompanied by 3no Spill kits around the perimeter which will be used in the event of an untimely spillage. All other re-fueling will be carried out within the compound at merrion gate using a re-fuelling delivery lorry. The section of wall will be removed using the 25t tracked excavator and muncher attachment, rubble will be pulled to one side where it will be loaded in to one of two Volvo A35 Dump Trucks. Two no Volvo A35 articulated Dump trucks will be used on site to transport rubble from the demolition zone along the strand to a temporary transfer area into Tipper trucks at the Compound. It is envisaged that the two no trucks would average an approx. 20 no loads between them on a daily basis. It is expected that the majority of loads would be removed off site over a 4 day period. As the Rubble is removed to the compound it will then be loaded into tipper trucks using a 16t wheeled excavator, from here the tipper trucks will removed to rubble to a recycling facility at road stone. Demolition works will proceed to the West Wall where the seating slab, columns will be demolished and removed using mechanical demolition, munching. At the close interfacing area along the perimeter of the rail line, the proposed cut line will be marked and agreed on site. HDL will locate a Spotter when working near this boundary. Some Manual demolition works may need to be carried out along this elevation; this will be reviewed again on site and amended to this methodology. 4

4.

5.

6. 7.

8.

9.

10.

11. 12.

Document: Title: Number:

Form Method Statement F 29

Revision Status: 2nd Issue Issue Date: 04/07/2011

METHOD STATEMENT
13. At the end of each day the tracked excavator will remain on site set down and demobilized in an agreed location with D&D. the Dump trucks will be removed to the compound for securing overnight. Dust suppression will be at source with mechanical water jets fitted to the Muncher attachment as demolition works are ongoing.

14.

Additional Items & Comments:

Temporary Supports and Props needed to facilitate the works: Note: any temporary design requirements must be detailed Method of Access and Egress to the work area: Fall Protection Measures: (Where work at height cannot be eliminated consider both Personnel & Materials) Are any Hazardous

(if none, state none)

No Temporary Works or supports are envisaged for this sequence of works

(i.e. Ladders/MEWPS/Scaffold/Trestles/Step Ladder, etc)

Designated walkways to and from the works areas.

(i.e. Guard Rails/Toe Boards/Brick Guard/Safety Harnesses/Exclusion Zones, etc.)

Non/Applicable

(If yes complete attached Chemical Risk Assessment summary information form)

Document: Title: Number:

Form Method Statement F 29

Revision Status: 2nd Issue Issue Date: 04/07/2011

METHOD STATEMENT
Substances to be used/present/potent ially present for the Activity?

Diesel Oil

Required Personnel Protective Equipment: Safety Boots YES Hard Hats YES Safety Gloves YES Hearing Protection YES Eye Protection YES

Respiratory Protection NO

Hi-Vis Clothing YES

Please Tick: / X Other :

Ear Muffs will be worn by the operator when the saw is in operation. Ear plugs will be available to all other personnel not directly involved in the works.

Emergency Procedures:

(Must be specific to the activity what can go wrong? what emergency procedures are in place? e.g. chemical spill response, rescue of personnel from heights, removal from an area in event of medical incident etc)

A HDL Supervisor Joe Coleman will be assigned to the work crew. The site manager will be permitted to use a mobile phone. In the event of an emergency, Emergency Number 112/999 will be contacted from the mobile phone. All personnel are issued with a contact list to attach to their badges for use in emergency situations.

First Aid Facilities:

Name of First Aider:

Main Contractor

First Aid Box Location:

Site Works Area First Aid box in compound Grab Bag at the workplace. N/A works are outside and do not involve chemicals.

Location of Nearest Safety Shower: Welfare Requirements: Monitoring / inspection requirements for the activity: (e.g. noise / dust

Welfare arrangements are in place in PSCS compounds. Toilets and washing facilities are provided by Dunwoody & Dobson on site

As necessary by HDL,

Document: Title: Number:

Form Method Statement F 29

Revision Status: 2nd Issue Issue Date: 04/07/2011

METHOD STATEMENT
monitoring / safety inspections by EHS etc) Housekeeping Control Measures: A clean as you go policy will be enforced at all stages of the works. Minimal waste will be generated during these works but any that is will be segregated and disposed of correctly. Housekeeping and general tidiness of the work area will be prioritized at all times. All tools and equipment will be brought to the works area at the start of the shift and removed to a secure area at the end of each day. Material and plant will not be left unattended at any time

Traffic management requirements: Waste Management requirements: Classification of waste generated: (hazardous or non-hazardous) Segregation methods: How waste is transported to designated waste collection areas etc:

All Plant must have a spotter as it is being transported on any Access Road within the plant, strict speed limit of 15kph is enforced at all times.

Non hazardous

By Hand

Tipper Trucks

Other environmental controls to be put in place:

(e.g. secondary containment / drip trays for equipment with hazardous materials content, environmental noise controls etc) All work will be carried out in accordance with the Environmental Management Plan and Waste management plan and HDL Quality, Safety, Health & Environmental Management System which is certified to ISO 14001 Dust will be minimized using water. Noise and vibration will be kept to a minimum Refueling of Plant will be done in a designated bunded area Fuel storage on site will be kept to a minimum. Any fuel to be stored on site will be stored in steel gerry cans. These will be stored on drip trays when away from, a lock-up during working hours. All containers will be clearly marked with contents e.g Diesel All items of plant when used (e.g. generators, compressors) will be stored over a drip tray at all times in case of fuel leaks

Services to be supplied by Others:

N/A

Other information

BRIEFING ARRANGEMENTS 7

Document: Title: Number:

Form Method Statement F 29

Revision Status: 2nd Issue Issue Date: 04/07/2011

METHOD STATEMENT
& Comments: Briefing Responsibility The HDL Site Supervisor & Safety officer will be responsible for ensuring the briefing of this method statement is carried out to all site personal involved in these works How is understanding confirmed All operatives, after the briefing will sign the Method Statement Briefing sheet attached to the back of this method statement

METHOD STATEMENT

METHOD STATEMENT
All work will be undertaken by qualified competent persons with experience of the type of work described above, and in all cases in full accordance with safety procedures specified in the companys Health and Safety Statement and the Project Health & Safety Plan. Noel Gill Hegarty Demolition Ltd Prepared by: Position: Reviewed by: Position: Works Supervisor: Joe Coleman Safety Management: Micheal Earley & Noel Gill Approved by Sisk: EHS Manager Liam Hogan HDL Director Date: 3/09/12 Date: 3/09/12

Items Attached: Sketches / drawings / P&IDs / Isometrics etc All relevant Material Safety Data Sheets Certification of Plant etc. Program of Work Activity Specific Risk Assessments

Yes

No

N/A N/A Yes n/a Yes

10

METHOD STATEMENT
We (the undersigned) have read and understood the attached method statement and will comply with the specified requirements and control measures. If the work activity changes or deviates from that originally envisaged, we will seek further advice and request an amended method statement. Name (Print) Signature Date

Main Contractor Sign Off Reviewer Dept Reviewer Name (Print) Signed Date Status

Reviewers Status Codes & Descriptions 1 = Approved 2 = Revise / Resubmit

11

Form QM 4.3(a)

KAVANAGH MANSFIELD & PARTNERS

CONSULTING STRUCTURAL AND CIVIL ENGINEERS

Safety Health and Welfare at Work (Construction) Regulations 2006

PRELIMINARY SAFETY AND HEALTH PLAN

i.e. a safety and health plan prepared on a preliminary b asis and for the purpose of providing information for the Project Supervisor for the Construction Stage [regulation 12].

Project :

Demolition Blackrock Baths

Signed : for KAVANAGH MANSFIELD & PARTNERS

Job No: CL 1631 Date: 4 September 2012

76 Merrion Road, Ballsbridge, Dublin 4. Tel: 01-6606966 Fax: 01-6606758 email: kmp@kmp.ie
Directors: James G. Mansfield (Managing) CEng, BE, FIEI, MIStructE, RConsEI; Stephen F. Bowe (Secretary)BSc(Mngt), FCCA, MMII; Niall Clarke CEng, BSc(Eng), DipEng, MIStructE, MIEI; Gerard Donnelly CEng, MIEI. Consultant: J A. Kavanagh CEng, BE, MEngSc, Eur lng, FIAE, FIEI, FIStructE, FICE, RConsEI. Piconsult Limited trading as Kavanagh Mansfield & Partners. Registered number: 136271. Registered office : 76 Merrion Road, Ballsbridge, Dublin 4, Ireland.

Form QM 4.3(a) Prelim H&S Plan

CONTENTS

Section 1.0

Description of Project / Project Details etc. Clients considerations and management requirements

Section 2.0

Section 3.0

Existing on-site hazards and environmental restrictions: (a) Information regarding SAFETY HAZARDS (b) Information regarding HEALTH HAZARDS

Section 4.0

Design assumptions; and significant construction hazards identified by designers

Section 5.0

Miscellaneous

APPENDIX A

Information provided to the PSDP by particular designer(s)

Copyright. No part of this document may be re-produced or transmitted in any form or stored in any retrieval system of any nature without the written permi ssion of Piconsult Ltd t/a Kavanagh Mansfield & Partners as copyright holder except as agreed for use on the project for which the document was originally issued.
Page 2 of 14

Form QM 4.3(a) Prelim H&S Plan

INTRODUCTION

Kavanagh Mansfield and Partners [KMP] is appointed as project supervisor fo r the design process [PSDP] for this project in accordance with the provisions of the Safety Health and Welfare at W ork (Construction) Regulations 2006 [Regulations]. This safety and health plan has been prepared by us on a preliminary basis and for the purpose of providing information for the Project Supervisor for the Construction Stage [PSCS] in accordance with the provisions of regulation 12(1). It has been prepared taking account of the HSAs Guidelines to the Regulations, and of relevant advice and guidance published jointly by the professional bodies: Engineers Ireland, the ACEI and the RIAI. In particular, the format is based on HSAs Guidelines Appendix 3: Suggested Contents of the Preliminary Safety and Health Plan .

This preliminary safety and health plan is based on information known to us as PSDP at the time of its preparation and prior to work commencing on site; it can not take account of any design changes or other matters that may arise or take place subsequently. Generic information and information which we believe is or should be routinely known to the PSCS and to competent contractors is, generally, not included.

This is not a contract document. However, it must be read in conjunction with the drawings, specifications and the other contract documents.

Terms used herein should be deemed to have the meanings/interpretations adopted in the Regulations unless the context requires otherwise.

Page 3 of 14

Form QM 4.3(a) Prelim H&S Plan

1.0

Description of Project / Project Details etc.

1.1

Project location/address Summary description of project

Blackrock Baths, Blackrock, Co Dublin

1.2

Demolition of former terraced seating area, diving platform and other ancillary works.

1.3

Client (under the Regulations) Intended time to completion of Project

Dun Laoghaire Rathdown Co Council

1.4

28 days
(Note: The basis upon which this time was estimated was allowing for the tender period, for assessing tenders, for contractors mobilisation and preparation time (incl. preparation of the developed H & S Plan by the PSCS), for construction time itself (see Planned Programme below), for retention period and for any other period before the project as defined in the regulations may be finished.)

1.5

Planned Construction Contract Programme Proposed contract commencement date Proposed contract completion date

Note: timescales quoted here are strictly provisional and subject to definitive assessment and confirmation by the PSCS .

6/9/2012

29/9/2012

1.6

Project Supervisor for the Design Process (PSDP) Employer: (under the main construction contract) Employers Consultants Project Manager: Lead designer: Design brief:

Kavanagh Mansfield & Partners

1.7

Dun Laoghaire Rathdown Co council

1.8

Kavanagh Mansfield and Partners Kavanagh Mansfield and Partners Provision of the normal engineering design services in accordance with Engineers Ireland Agreement SE 9101. Dun Laoghaire Rathdown Co Council Architects Department Agreement on finishes, state of premises when work is complete etc, Scott Cawley, Ecological Consultants Advice on ecological issues including liaison with MWS
Page 4 of 14

Employers other designers and their design briefs:

Form QM 4.3(a) Prelim H&S Plan

service and Department of Marine 1.9 Other identified project designers See the main construction contract documents for elements/features of the project requiring design by contractors and specialist suppliers. X None known to exist

1.10

Existing Relevant Safety File (if any) Other Existing Records and Plans

1.11

See the main construction contract documents including survey drawings. Refer also to appended information provided by designers. Refer also to utility suppliers records. See section 3(a) below also. Existing Live Dart Railway line adjacent to site. Site services on site disconnected, Welfare facilities to be provided in adjacent carparking area.

1.12

Location of existing site services, where appropriate, to facilitate welfare facilities during construction Any known work activities on or adjacent to site during construction by parties not involved in the project.

1.13

X There are no known work activities (which are not part of the Project or set out in 2.9) which will or may be carried out on or adjacent to the site during the period of construction of the project. The following work activities (which are not part of the Project nor set out in 2.9) will or may be carried out on or adjacent to the site during the period of construction of the project:

1.14

Communication arrangements: Communication with PSDP and between designers Before any person commences design work on the project they shall inform the PSDP. Any person engaging or permitting a person to carry out design work on the project shall promptly inform the PSDP of the design work to be carried out by the said designer and shall arrange for the designer to contact the PSDP before any design work commences. All designers, including contractors and specialist suppliers with design duties and their appointed consultants, shall cooperate with all other designers on the project as required by the Regulations. All designers and other duty holders under the regulations shall keep the PSDP fully informed at all times as required by the Regulations in order for the PSDP to carry out its duties. This includes providing copies of all drawings, specifications and other directions/advice issued by every designer, and details of all other communications verbal or written between
Page 5 of 14

Form QM 4.3(a) Prelim H&S Plan

the designer and other designers (or between the designer and other duty holders under the regulations) that may relate to health and safety during construction. In particular, any proposed design changes/reappraisals due to unforeseen eventualities arising during construction stage or due to any other cause shall be referred immediately to the PSDP; where these materially affect the information already provided to the PSDP by a designer the designer shall review, revise and re-issue appropriate information to allow th e PSDP to comply with its duties. Otherwise: as directed from time to time by the PSDP. Communication between PSCS and others Procedures to be determined by the PSCS in liaison with the PSDP.

Page 6 of 14

Form QM 4.3(a) Prelim H&S Plan

2.0

Clients considerations and management requirements

(in addition to any stipulated in the main construction contract documents)

2.1

Clients contact person

The Clients first-point contact person in respect of the project is: Pamela OConnor, Dun Laoghaire Rathdown Co Council Architects Department Any relevant and necessary details of the Clients structure and organization details can be obtained from the client contact person. The objective of the Client is to facilitate those involved in the design and construction of the project to carry out their respective duties safely as required by the Regulations. The client has appointed designers and consultants to monitor and review on his behalf the construction of the project as described in the main construction contract documents and in section 1.0 above. No particular requirements apply. Any relevant and necessary details of the Clients procedures that may come to be required can be obtained from the clients contact person. No particular procedures apply. Any relevant and necessary details of the Clients procedures that may come to be required can be obtained from the clients contact person. Any client restrictions on contractor's working hours/days are set down in the main construction contract documents. Hours of work will be restricted by tidal conditions as access to the site can only be obtained within a time window either side of low tide. Hours of work are restricted to daylight hours only and should not take place before 7.30 a m or after 7.30 pm. All works will aim to be completed by the end of September. Disturbance of the tern roost will be avoided by ensuring that works cease two hours before sunset and commence one hour after sunrise.

2.2

Clients structure and organization

2.3

Clients safety objectives for the project

2.4

Clients arrangements for monitoring and review

2.5

Clients permits and authorization requirements

2.6

Clients emergency procedures

2.7

Clients restrictions on working hours

2.8

Clients site access rules and restrictions.

Any client-imposed restrictions on contractors, suppliers and/or others in respect of accessing or use of any part of the site during construction are stipulated in the main
Page 7 of 14

Form QM 4.3(a) Prelim H&S Plan

construction contract documents. Access to project to be from Merrion Gates on a Left in , left out basis only. Tidal restrictions will apply and the route is as marked out on Kavanagh Mansfield & Partners drawing CL 1631/01 or as otherwise agreed with Scott Cawley, Ecological Consultants. No access across Dart line at Blackrock except for pedestrian foot traffic, No machinery to cross Dart Line except at Merrion Gates. 2.9 Clients own work activities, if any, on or adjacent to the site during the construction contract Clients requirements in respect of liaison between parties The Client will not be carrying out its own work activities on or adjacent to the site during the period of construction of the project.

2.10

The client imposes no particular requirements in respect of liaison between the client and the parties involved in the design and construction of the project other than those stipulated in the main construction contract documents. No particular requirements apply. Any relevant and necessary details of the Clients procedures that may be required can be obtained from the clients contact person. Site security to be maintained on site at all times during duration of the works.

2.11

Clients security arrangements

2.12

Clients required phasing of W orks (if any)

The client imposes no particular requirements in respect of phasing of construction of the project other than those stipulated in main construction contract documents. The work is to be completed within time scale set out in contract documents.

Page 8 of 14

Form QM 4.3(a) Prelim H&S Plan

3.0

Existing on-site hazards and environmental restrictions:

i.e. significant on-site hazards and environmental restrictions known to exist at this time (based in part on relevant information gathered by the project designers for the purpose of carrying out their design duties to dat e). It should be noted by contractors that it is not possible in practice to comprehensively identify and list at design stage all existing on-site hazards and environmental restrictions .

(a) (i)

Information regarding SAFETY HAZARDS Site boundaries and access (incl. temporary access) The site is defined by the existing boundary walls to the Blackrock Baths complex. It is adjacent to public access to the beach which is accessed by a pedestrian bridge at Blackrock, by other pedestrian bridges at Williamstown and Booterstown and by vehicular and pedestrian access at Merrion Gates. The site is separated from The Dart line at Blackrock Station by a public pathway about 1.8m wide. Vehicular Access for the works shall be from Merrion Gates only and arrangements will need to be made with Dublin City Council in respect of access through their barrier at Merrion Gates. A speed limit of 15km/h shall apply to all vehicles on the beach. Pedestrian access will be allowed at Blackrock to members of the construction staff. See also the main construction contract drawings and other documents. Three sides of the bath complex are on the beach and may be under water at various stages of the tide. There is public access to the beach and this shall continue but the pathway between the site and Blackrock Dart station shall be closed off. The steps adjacent to the baths on the northern side shall be closed off while the steps on the southern side shall be hoarded or fenced off for the duration of the works in such a manner as to permit the public to access the beach by a 1.2m section of the steps . Heras type fencing to be used to protect working area from public. Some of this may be temporary depending on work being carried out and the effect of tide or weather conditions. Warning signs are to be erected in appropriate positions, at Blackrock, Williamstown, Booterstown and Merrion. A site for storage is to be provided at or close to Merrion Gates. This is to be provided during working hours and protected from the public by Heras type fencing.

Page 9 of 14

Form QM 4.3(a) Prelim H&S Plan

Vehicles or plant, if any, left at Merrion Gates overnight shall be in location approved by Ecological consultant. At some points along the access route, the route will pass over outfall streams. Suitable precautions will need to be taken at these points including the provision of a geotextile membrane. Access to the interior of the bath complex will be at the location of a breach in the existing sea wall. This shall be opened up and a ramp provided on both sides of the wall. This breach shall be closed in before completion of the project. (ii) Adjacent land uses Existing Dart station at Blackrock which is live. No access is allowed to this and this must not be affected in any way. Precautions may need to be taken to avoid demolition dust affecting the lines or the use of the station, including the stairs and lift. No significant 'hazardous material' known to be stored on site Sand infilling of the bath complex has taken place. In parts this may be soft and is to be tested before work commences. Location of fuel store to be agreed. Fuel store to be located within bath complex at poolside level. This to be provided with spill trays etc and precautions in place in the event of fuel spills. This shall apply at Blackrock. At Merrion, fuel shall not be stored but all filling arrangements from tankers etc shall take place in accordance with Industry rules. This shall take place in a hardstanding area at the entrance using a refueling truck. See method statement by Hegarty Demolition Limited in respect of measures to be put in place. As far as is known, these have been disconnected but the services should be checked on site be fore commencement of demolition. High tension cables on Dart line. No site investigation has taken place but the site is located on the foreshore on a beach. There are areas of soft sand near the railway line which should be avoided by trucks. The building and site are in very poor condition with corroding steel, decayed concrete, sections of sea wall subject to erosion, steps and walkways without barriers or with barriers severely corroded. See section 1.10 and 1.11 above also. (viii) Information regarding other existing on-site safety hazards known to exist. The site has been deemed a dangerous building and all elements are suspect and liable to fail. The site has the potential for falling from a height and the site has open water which could be very deep at times.
Page 10 of 14

(iii)

Existing storage of hazardous materials

(iv)

Location of existing site services

(v)

Ground conditions

(vii)

Condition of existing structures (incl. services).

Form QM 4.3(a) Prelim H&S Plan

(b) (i)

Information regarding HEALTH HAZARDS Existing storage of hazardous materials No significant 'hazardous material' known to be stored on site Storage of fuel on site to be in location to be agreed See 3(a) 'Ground Conditions' above A service area at the baths has not been accessed. There may be a possibility of the discovery of oil from previous heating systems which may be a contaminant. There are some remaining defunct services. No asbestos survey has taken place and is not known.

(ii)

Contaminated land

(iii)

Existing structures (incl. services) hazardous materials Asbestos On-site health risks from clients activities Information regarding other existing on-site health hazards known to exist.

(iv) (v)

If any known, dealt with above None

(vi)

See above

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Form QM 4.3(a) Prelim H&S Plan

4.0

Design assumptions; and significant construction hazards identified by designers which might not be apparent to a competent contractor

4.1

Design criteria adopted by respective designers Assumed on-site control measures

Refer to the appended information provided by the project designers Refer to the appended information provided by the project designers Access only during appropriate tidal conditions. Speed limit on beach for construction traffic. Erection of warning signs for public. Site access controlled at Merrion Gates
Notes in this respect: While control of risk on site is the contractors responsibility, if, when carrying out their design activities , a designer assumed the adoption by the contractor of specific risk control measures which are unusual for the type of project and which would not be apparent to a competent contractor, then the designer is obliged to provide pertinent information in respect of these assumed measures. Similarly, If a designer assumed the adoption by the contractor of a particular construction method or erection sequence which is unusual for the type of project and which would not be apparent from the drawings and other contract documents to a competent contractor, then the designer is obliged to provide pertinent information in respect of these. Where contractors/sub-contractors may require fixing facilities for temporary protective measures, such as hooks welded to steelwork for attaching safety netting or fixings into concrete or masonry members for guardrails, such requirements should be determined in good time by the PSCS, in liaison with the contractors/sub -contractors, to allow early consent to be sought from the designers.

4.2

4.3

Arrangements for coordination of ongoing design work and design changes Information identified during design on particular risks to the safety, health and welfare of persons at work. Materials requiring particular precautions

See 1.14 above To be notified, if required, by Kavanagh Mansfield & Partners. Refer to the appended information provided by the project designers

4.4

4.5

Refer to the appended information provided by the project designers. (Note that almost all materials can be hazardous and
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Form QM 4.3(a) Prelim H&S Plan

must be used strictly in accordance with the manufacturers recommendations and good practice generally.)

5.0

Miscellaneous

5.1

Safety File on completion

For the purposes of the PSDP preparing the Safety File on completion, information shall be provided to the PSDP by all duty holders as required by the Regulations, in particular Regulation 21. Also, information shall be provided to the PSDP by the main contractor as stipulated in the main construction contract documents. Natura Impact statement is being prepared by Scott Cawley. All measures within this sh all be followed by relevant personnel.

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Form QM 4.3(a) Prelim H&S Plan

APPENDIX

Information provided to the PSDP by particular designer(s) for the purposes of the PSDP preparing the preliminary health and safety plan

TO BE APPENDED provided by: Kavanagh Mansfield & Partners

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APPENDIX 2 Drawing CL1631-01 showing site layout

Blackrock Baths 25

Appropriate Assessment DLRCC