Coversheet July08 Objection - epa.ie · PDF fileP0029-05 Irish Cement Ltd Objection to Proposed Determination ... from Kiln 6 whereas periodic monitoring also complies with ... (also

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Patrick Doyle

From: Seamus Breen <[email protected]>Sent: 27 July 2017 14:15To: Licensing StaffSubject: New Applicant objection entered for Reg no: P0029-05. (Reference Number:

P0029-05-170727021350)Attachments: P0029-05 Irish Cement Objection.pdf

Importance: High

Follow Up Flag: Follow upFlag Status: Flagged

Objection submitted on: 27/07/2017 14:13

Title: Mr

First Name: Seamus

SurName: Breen

Organisation Name: Irish Cement Limited

Address Line 1: Platin

Address Line 2: Drogheda

Address Line 3:

County: Louth

Post Code: 0000

Email:

Objector Type: Applicant

Oral Hearing: No

______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________

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Objection of Irish Cement Limited to the Proposed Determination of IPPC Licence Register No. P0029-05 for Limerick Cement Works

Licensee:Irish Cement Limited, Platin, Drogheda, Co. Louth

Location of Installation:Limerick Works, Castlemungret, Co. Limerick

Objector name and address: Irish Cement Limited, Platin, Drogheda, Co. Louth

Reference number: P0029-05

Grounds, reasons and arguments: contained herein

Accompanying fee: €253

July 2017D5373-47

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Liz Leacy, Program Officer, Environmental Licencing Program, Office of Environmental Sustainability, Environmental Protection Agency, Johnstown Castle Estate, County Wexford

27th July 2017

Re: Reference Number P0029-05 Irish Cement Limited, Limerick Works

Objection of Irish Cement Limited to Proposed Licence Determination Dear Miss Leacy. I refer to your letter of 4th July enclosing the Proposed Determination of an IE licence for the above facility. Irish Cement Limited wishes to lodge an objection to the Proposed Determination and our Submission outlining the grounds for the objection is enclosed for consideration by the Agency. Our payment of the relevant fee has been made on line. We trust that this is in order and we would appreciate acknowledgement of receipt of this payment at your earliest convenience. Please address all correspondence to the undersigned. Yours sincerely,

__________________________

Head of Quality and Sustainability

Irish Cement Limited

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P0029-05 Irish Cement Ltd Objection to Proposed Determination

Submission of Irish Cement Limited

to

Environmental Protection Agency

Objection to the Proposed Determination of

Industrial Emissions Licence Reg. No. P0029-05 for Limerick Cement Works

24 July 2017

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Irish Cement Limited wishes to lodge a specific objection to the Proposed

Determination of Industrial Emissions Licence P0029-05 for Limerick Cement

Works notified by the Agency on 4 July 2017

Irish Cement Limited respectfully requests the Agency to consider this Submission

and incorporate appropriate amendments in the final Licence Determination.

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P0029-05 Irish Cement Ltd Objection to Proposed Determination Page | 1

1. Introduction

The EPA initiated a review of Industrial Emissions licence register number P0029-03 for

the purposes of updating the licence to incorporate the requirements of Commission

Implementation Decision 201 3/163/EU of 26 March 2013, establishing the best

available techniques (BAT) conclusions under Directive 2010/75/EU of the European

Parliament and of the Council on industrial emissions for the production of cement, lime

and magnesium oxide. Irish Cement Ltd (ICL), Limerick received a Proposed

Determination (PD) of its application for a revised Industrial Emissions Licence, Register

No P0029-05 on the 5 July 2017.

It is the opinion of ICL that a number of the BAT Conclusions have not been correctly

applied in the Proposed Determination (PD) for Irish Cement Limerick works.

The following specific issues arise with regard to the PD of the revised Industrial

Emissions Licence, Register No P0029-05:

1. Incorrect interpretation of reference oxygen as described in the ‘General

Considerations’ of the BAT Conclusions.

2. Incorrect application of BAT 5 for emission point A2-02 (Coal Mill);

3. Incorrect BAT 19 ELV for NOX at A2-01 (Kiln 6);

4. Inclusion of requirement for continuous monitoring of emissions of HCl and HF

from Kiln 6 whereas periodic monitoring also complies with BAT 5;

Irish Cement is also of the opinion that the principle that the Industrial Emissions

Directive (IED) should lead to a largely level playing field in the EU has not been applied

in this PD.

The licence should be founded on the IED and on the BAT Conclusions as these are the

legal instruments that must underpin the decisions of the competent authority, the

Environmental Protection Agency (EPA).

These objections are described in more detail below.

2. Background

The main aim of the Industrial Emissions Directive is to prevent, reduce, and as far as

possible eliminate pollution arising from industrial activities1. The development of an

integrated approach to controlling emissions will also contribute to the achievement of a

level playing field in the Union by aligning environmental performance requirements for

industrial installations.2

Following on from the Industrial Emissions Directive, BAT Reference Documents

(BREFs) have been developed for various industries; the BAT conclusions contained are

adopted by the Commission as Implementing Decisions3. The IED requires that these

1 Preamble (2) 2 Preamble (3) 3 Preamble (13) and Article 13.5

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BAT conclusions are the reference for setting permit conditions.4 The introduction to the

BAT conclusions on industrial emissions for the production of cement, lime and

magnesium oxide states the following:

Article 16(1) of Directive 2010/75/EU provides that the monitoring requirements in

the permit referred to in point (c) of Article 14(1) of the Directive are to be based on

the conclusions on monitoring as described in the BAT conclusions.

3. Summary of Objection

ICL wishes to object to and appeal the following conditions attached to Proposed

Determination Register No P0029-05 – Irish Cement Limerick Works:

1. Basis of standardisation of kiln activities to reference oxygen concentration

(Proposed Condition 4.2.2).

2. 2 Monitoring Requirements for the Coal Mill as set out in the Proposed

Schedule C.1.2;

3. Emission Limit Value for NOX for Kiln 6 (Proposed Schedule C.1.1);

4. Monitoring of Kiln 6 (Proposed Schedule C.1.1);

Each of these four points of objection is addressed in detail below.

4 Article 14.3

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4 Objection No 1 : Basis of Standardisation of Emissions from Kiln Activities to

Reference Oxygen Concentration

4.1 Introduction

The formula for standardising concentrations of substances in combustion gases has been

well-established for many years. The methodology for standardising concentrations of

substances in combustion gases to a reference oxygen concentration is to allow for

varying oxygen concentrations and to take account of any dilution air.

4.2 Proposed Condition

Proposed Condition 4.2.2 sets out the basis for correcting of concentrations measured in

emissions to atmosphere with respect to temperature pressure and oxygen.

4.2.2 From combustion sources (kiln activities):

Temperature 273K, Pressure 101.3 kPa, dry gas; 10% oxygen.

The standardisation of gas volumes to this oxygen reference value shall be

done only if the oxygen content measured over the relevant sample period

exceeds the reference oxygen value.

4.3 BAT

The methodology for expressing concentrations at a standard reference concentration is

set out on pages 7 and 8 (BAT Conclusions)

Emission levels associated with the best available techniques (BAT-AELs) given

in these BAT conclusions refer to standard conditions: dry gas at a temperature

of 273 K, and a pressure of 1 013 hPa.

Values given in concentrations apply under the following reference conditions:

Kiln activities in the cement industry: 10% oxygen by volume

…

Conversion to reference oxygen concentration

The formula for calculating the emissions concentration at a reference oxygen

level is shown below:

Where:

ER (mg/Nm³): emissions concentration related to the reference oxygen level OR

OR (vol %): reference oxygen level

EM (mg/Nm³): emissions concentration related to the measured oxygen level OM

OM (vol %): measured oxygen level

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The BAT Conclusions do not allow for any deviation from this formula if the

concentration of oxygen is less than 10%.

4.4 Discussion

The formula for standardising concentrations of substances in combustion gases has been

well-established for many years.

• The methodology for standardising concentrations of substances in combustion

gases to is set out in the EPA Air Emissions Monitoring Guidance Note AG2

(2014).

• As mentioned above, BAT Conclusions for the cement industry (2013) (pp. 7 and

8) state:

Emission levels associated with the best available techniques (BAT-AELs)

given in these BAT conclusions refer to standard conditions: dry gas at a

temperature of 273 K, and a pressure of 1 013 hPa.

Values given in concentrations apply under the following reference

conditions:

Kiln activities in the cement industry: 10% oxygen by volume

• The IED (2010) states in ANNEX VI - Technical provisions relating to waste

incineration plants and waste co-incineration plants, Part 4, 2.1:

2.1 All values are standardised at 10 % oxygen.

The preamble in Proposed Condition 4.2 correctly refers to the need to exclude

any dilution air (also called “false air”) that may be introduced to the process after

combustion has taken place. Minimisation of dilution air or false air is energy-

efficient and should not be discouraged by failing to give credit by allowing

correction to the standard of 10% v/v oxygen if the actual concentration is below

this.

• The German TA Luft (2002) specifies the same methodology for standardising

concentrations of substances in combustion gases

None of these publications includes separate requirements where the oxygen

concentration is less than the reference concentration.

Irish Cement believes that the Agency has misapplied BAT in including this proposed

condition.

This proposed condition is not workable. It cannot be complied with. Furthermore, it is

not included in the BAT Conclusions for the cement industry.

Further, reduction of dilution air (also known as false air) is a measure to improve energy

efficiency. Failure to allow correction to 10% oxygen of concentrations of substances

when the oxygen level is below 10% is a disincentive to achieve further energy efficiency

by reduction of dilution air or false air.

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Irish Cement further notes that this incorrect proposed condition has not been universally

applied for all cement manufacturing facilities.

4.5 Appeal

Accordingly Irish Cement requests the deletion of the final paragraph of Proposed

Condition 4.2.2:

The standardisation of gas volumes to this oxygen reference value shall be done

only if the oxygen content measured over the relevant sample period exceeds the

reference oxygen value.

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5 Objection Point No. 2 Emission Limit Values and Associated Monitoring

Requirements for Coal Mill

5.1 Introduction

Irish Cement has made extensive inquiries with other cement manufacturers in the EU

and has found that no cement plants in the EU have had ELVs imposed for continuous

monitoring of atmospheric emissions from coal mills other than particulates, including

when emissions from kiln activities are vented through coal mills. In Germany,

monitoring of particulates and spot measurements for the other parameters are carried out

in coal mills. See note from VDZ, German Cement Association, attached as an appendix.

In particular, ICL notes that the Agency has imposed ELVs on coal mills at other cement

facilities for particulates only and that the required monitoring of particulates is periodic

with quarterly frequency only. This discrepancy is in conflict with the aim of the IED to

achieve a level playing field by aligning environmental performance requirements.

The Agency should not depart from the approach of applying BATC in a balanced

manner to all cement plants without a good objective reason.

This misapplication of BATC is a fundamental flaw in the approach of the Agency in

drafting the PD for Irish Cement Limerick, as this results in a PD that is in sharp contrast

to PDs issued to other cement manufacturers.

The direct monitoring of Kiln 6 gases fulfils completely the requirements of BAT5

regarding kiln processes. The coal mill requires exhaust gas from Kiln 6 so as to create

an inert atmosphere for safe operation. This exhaust gas is supplied to the coal mill post

abatement in the kiln itself and in the SNCR unit. Monitoring of Coal Mill 6 gases is

therefore not required as it would merely duplicate monitoring of Kiln 6 gases. (see

Figure 1 attached).

5.2 Proposed Licence Condition

Emission Limit Values and monitoring requirements for the Coal Mill (A2-02) are set out

in the PD – Proposed SCHEDULE C: Emissions, Monitoring and Control, C.1 Emissions

to Air, C.1:2 Description, limit values and monitoring at emission point reference

number A2-02 and referenced in Proposed Conditions 1.6, 5.1 and 6.1).

Emission limit values and monitoring requirements are specified for the following

parameters:

• Oxides of sulphur (as SO2)

• Nitrogen oxides (as NO2)

• Dust / Particulates

• Carbon monoxide

• Hydrogen chloride (HCI)

• Hydrogen fluoride (HF)

• Ammonia slip (NH3)

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• Dioxins and furans (PCDD/F)

• Total organic carbon (TOC)

• Mercury (Hg) and its compounds

• The sum of cadmium (Cd) and thallium (TI) and their compounds

• The sum of antimony (Sb), arsenic (As), lead (Pb), chromium (Cr), cobalt (CO),

copper (Cu), manganese (Mn), nickel (Ni), vanadium (V)

5.3 BAT

BAT is defined for cement plants by Commission Implementing Decision of 26 March

2013 establishing the best available techniques (BAT) conclusions under Directive

2010/75/EU of the European Parliament and of the Council on industrial emissions for

the production of cement, lime and magnesium oxide (OJ No L100, vol 56, 1-45, 9 April

2013), referred to in this Objection document as BATC.

Paragraph 1.2.2 of BATC (Monitoring) states:

BAT is to carry out the monitoring and measurements of process parameters and

emissions on a regular basis and to monitor emissions in accordance with the

relevant EN standards or, if EN standards are not available, ISO, national or

other international standards that ensure the provision of data of an equivalent

scientific quality …

BAT5 outlines the applicability of various forms of monitoring and scope of monitoring,

refer to Table 1.

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Table 1: BAT5 monitoring requirements

Technique

Applicability Description

Type of

Monitoring Parameters

a Process parameters

demonstrating the

process stability

Continuous temperature, O2

content, pressure and

flowrate

Generally applicable

b Monitoring and

stabilising critical

process parameters

homogenous raw

material mix and fuel

feed, regular dosage

and excess oxygen

Generally applicable

c When SNCR is

applied

Continuous NH3 Generally applicable

d Continuous dust, NOX, SOX, and

CO

Applicable to kiln processes e Periodic PCDD/F and metal

f Continuous or

periodic

HCl, HF and TOC

g Continuous or

periodic

Dust Applicable to non-kiln

activities.

For small sources (<10 000

Nm³/h) from dusty

operations other than cooling

and the main milling

processes, the frequency of

measurements or

performance checks should

5.4 Discussion

See attached Figure 1 for a schematic representation of the relevant equipment and

monitoring points for Kiln 6 and Coal Mill 6.

No chemical processes take place in the Coal Mill. No substances are added to the gas

stream in the coal mill other than particulates. The only process that occurs in the coal

mill is a physical process, that of size reduction i.e. grinding/milling. Post the kiln

activity, part (approximately 10%) of the gases from Kiln 6 pass through the Coal Mill to

provide an inert atmosphere within the coal mill and thereby minimise the risk of a coal

dust explosion. Gases from Kiln 6 are abated and monitored in accordance with the

provisions of BAT5.

The monitoring of the Kiln 6 gases post abatement fulfils the requirements of BAT5

regarding monitoring of kiln activities. As the coal mill uses a portion of the kiln gases

that have been abated in the kiln itself and in the SNCR unit it is not necessary to

duplicate the monitoring of the coal mill gases, other than for particulates (as particulates

are generated in the coal mill). The proposed schedule for monitoring as presented in the

PD for Coal Mill 6 is not in accordance with BAT requirements.

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BAT5 d, e and f refer to the monitoring of dust, NOX, SOX, PCDD/F, HCl, HF, TOC and

CO emissions and are clearly applicable to kiln processes only. BAT5g which relates

only to the monitoring of dust is applicable to non-kiln activities.

BAT18 provides emission levels for dust emissions from the flue gases of cooling and

milling processes:

The BAT-AEL for dust emissions from the flue-gases of cooling and milling

processes is <10 – 20 mg/Nm³, as the daily average value or average over the

sampling period (spot measurements for at least half an hour). When applying

fabric filters or new or upgraded ESPs, the lower level is achieved.

To impose ELVs and require monitoring for any emission parameters from coal mills

other than particulates is in conflict with the BAT Conclusions for the cement sector.

Irish Cement notes that other cement producers in Ireland are required only to measure

particulates quarterly. A continuous particulate monitor is operating on Coal Mill 6 and

although in Irish Cement’s view periodic measurement of particulates would comply with

BAT, it is proposed that this monitoring regime would continue because the monitoring

equipment is already in operation.

Although not required by BAT5, Irish Cement would not oppose a requirement that in

addition to the above that Coal Mill emissions be monitored quarterly for the first 12

months of the licence and, with approval of the Agency, annually thereafter for the

emission parameters that are required to be monitored in in the Kiln 6 stack. This would

be consistent with current European practice.

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5.5 Appeal Submission

Irish Cement Ltd requests that Proposed Schedule C.1.2 be amended so that the only

ELV for the Coal Mill be for particulates, that monitoring of emissions other than for

particulates from the Coal Mill be annual not continuous, as outlined the following table:

Emission point reference number A2-02

Parameter Emission Limit

Value

Monitoring Period Frequency Analysis Method/

Technique

Dust / Particulates 20 mg/m³

BAT 17

24-hour mean

BAT 17 Continuous

EN standards are to

be used or, if EN

standards not

available, ISO,

national or other

international

standards that ensure

the provision of data

of an equivalent

scientific quality may

be used BAT 5

Oxides of sulphur

(as SO2)

Nitrogen oxides

(as NO2)

Carbon monoxide

Hydrogen

chloride (HCl)

Hydrogen

fluoride (HF)

Ammonia slip

(NH3)

Total organic

carbon (TOC)

Mercury (Hg) and

its compounds

The sum of

cadmium (Cd)

and thallium (TI)

and their

compounds

The sum of

antimony (Sb),

arsenic (As), lead

(Pb), chromium

(Cr), cobalt (CO),

copper (Cu),

manganese (Mn),

nickel mi),

vanadium (V)

-

Average over the

sampling period (spot

measurements, for at

least half an hour) Annual (Note

1)

Dioxins and

furans (PCDD/F)

- Average over the

sampling period (6-8

hours)

Note 1 Quarterly for first 12 months of the licence and, with approval of the Agency,

annually thereafter

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6 Objection Point No. 3: Emission Limit Value for NOX for Kiln 6

6.1 Introduction

The proposed ELV outlined in Proposed Schedule C.1.1 for nitrogen oxides (NOX)

applies to Kiln 6 gases is 450 mg/Nm³. Irish Cement believes that the Agency has

misinterpreted the information in the application submitted to the Agency as part of the

BAT review. The information, included in Irish Cement Annual Environmental Reports,

shows that the initial NOX level after primary techniques is > 1 000 mg/Nm³ and the plant

therefore qualifies for the higher BAT-AEL of 500 mg/Nm³.


Emission Limit Values and monitoring requirements for Kiln 6 (A2-01) are set out in

Proposed Schedule C: Emissions, Monitoring and Control, C.1 Emissions to Air, C.1.1

Description, limit values and monitoring at emission point reference number A2-01 and

referenced in Proposed Conditions 1.6, 5.1 and 6.1).

The ELV for NOX emissions from Kiln 6 has been reduced from 800 mg/Nm³ (in Licence

Register No P0029-03) to 450 mg/Nm³ (24-hour mean).

6.3 BAT

BAT 19 specifies BAT-associated emission levels for NOX from the flue-gases of kiln

firing and /or preheating/precalcining processes in the cement industry which are as

follows:

Table 2

BAT-associated emission levels for NOX from the flue-gases of kiln firing and/or

preheating/precalcining processes in the cement industry

Kiln type Unit BAT-AEL (daily average

value)

Preheater kilns mg/Nm³ < 200 – 450 (1) (2)

(1) The upper level of the BAT-AEL range is 500 mg/Nm³, if the initial NOX level

after primary techniques is > 1 000 mg/Nm³.

(2) Existing kiln system design, fuel mix properties including waste and raw material

burnability (e.g. special cement or white cement clinker) can influence the ability

to be within the range. Levels below 350 mg/Nm³ are achieved at kilns with

favourable conditions when using SNCR. In 2008, the lower value of 200 mg/Nm³

has been reported as a monthly average for three plants (easy burning mix used)

using SNCR.

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6.4 Discussion

This discussion focuses on two aspects:

• The relevant ELV to be applied to Kiln 6, and

• The time required to ensure compliance with the revised limit.

6.4.1 ELV

The Compliance Report submitted with the BAT review application included the

following in Section 2.1.2:

The NOx limit of 500mg/m3 is applicable as Kiln 6 is a preheater kiln with an

initial level after primary techniques of >1,000mg/m3. As the initial value for

NOx is greater than 1,000 mg/Nm3, ICL is expecting a BAT AEL of 500 mg/Nm3

for Kiln 6. Details of NOx emissions from Kiln 6 since 2004 are provided in Table

1. The SNCR was installed on Kiln 6 in 2009. Pre-2009 and hence prior to

treatment, NOx concentrations are shown to be in excess of 1,000 mg/Nm3.

Irish Cement has a concern that this explanation may have been misunderstood. Irish

Cement wishes to clarify why an ELV of 500 mg/Nm³ is appropriate and in accordance

with BAT19.

Table A below is the first part of the above-referenced Table 1 (as submitted in the BAT

compliance report) and shows that for the years 2004-2008, prior to the installation of the

SNCR, the initial concentration of NOx was above 1,000 mg/Nm³ after primary

techniques. See Note 1 in Table 2 from BAT Conclusions above.

Table A: Historical NOX monitoring data for Kiln 6 before SNCR installed

Year (SNCR installed

in 2009)

Concentrations of

nitrogen oxides

(mg/Nm³)

Nitrogen oxides limit

(mg/Nm³)

2004 1,117 1800

2005 1,216 1800

2006 1,133 1800

2007 1,097 1800

2008 1,082 1800

Therefore Irish Cement qualifies for an ELV at the upper level of BAT-AEL 500

mg/Nm³.

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Table B below is the second part of the above-referenced Table 1 (as submitted in the

BAT compliance report) and is included to show the success of the NOX abatement

system for the year in which SNCR was installed (2009) and subsequent years.

Table B: Historical NOX monitoring data for Kiln 6 after SNCR installed

Year (SNCR installed

in 2009)

Concentrations of

nitrogen oxides

(mg/Nm³)

Nitrogen oxides limit

(mg/Nm³)

2009 934 1800

2010 760 800

2011 763 800

2012 768 800

2013 725 800

2014 761 800

2015 763 800

2016 731 800

The monitoring results for 2009 and subsequent years do not show the concentration of

NOX before SNCR, rather after SNCR.

Therefore, according to Note 1 of BAT 19, Irish Cement satisfy the condition that the

upper level of the BAT-AEL range is 500 mg/Nm³, if the initial NOx level after primary

techniques is > 1 000 mg/Nm³”. On this basis, Irish Cement strongly believes that a NOx

ELV of 500 mg/Nm³ is the relevant limit to be applied to NOx emissions from Kiln 6 on

the basis of BAT 19.

Irish Cement Ltd is committed to reducing the concentration of nitrogen oxide in the

emissions from Kiln 6 to achieve compliance with the BAT19 ELV of 500 mg/Nm³.

6.4.2 Time required to comply

The Inspector’s report on the Proposed Determination states that:

…the CID establishing BAT conclusions under Directive 2010/75/EU on industrial

emissions for the production of cement was published in 2013. A four-year period

was allowed for installations to bring their activities into compliance. The licensee

has not provided adequate technical justification for the existing limit to continue for

a period.

While the intent of the BAT Conclusions is outlined in the BATC document, it was not

known which ELV in the permitted range the EPA would actually propose to impose in

its licence. This lack of certainty directly impacts the licensee in making preparations for

installing equipment to meet a future unknown ELV. Without sight of the PD ELVs,

ordering of equipment would have resulted in the licensee procuring and installing

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equipment that might not be required or might not be sufficient to ensure that emissions

would meet the actual imposed ELV.

Irish Cement is committed to taking measures to reduce emissions of nitrogen oxides

from the Kiln 6 stack by upgrading the SNCR NOX suppression system. The programme

has already been commenced and, in light of the comments of the Inspector referred to

above, the Agency's attention is drawn to S.86(1)(b)(xvii). We set out below the entire

programme for this with dates for completion.

Description of Work

Install additional ammonium hydroxide storage capacity

required by increased usage of ammonium hydroxide

30th September 2017

Carry out process optimization – this would be by the vendor,

ABC&I, working with Irish Cement

31st October 2017

Carry out any equipment alterations or replacements

identified by ABC&I Ltd required to ensure compliance with

the new ELV without reducing operating capacity and

impacting on economic performance.

31st January 2018

Commission the upgraded NOX suppression system 28th February 2018

It should be noted that the report on air dispersion modelling carried out for the facility

has shown that air quality standards are not exceeded, even if emissions continue at the

current ELV of 800 mg/Nm³.

4.4 Appeal

Accordingly, Irish Cement Ltd requests that Kiln 6 Emission Limit Value for nitrogen

oxides be 500 mg/Nm³ with a derogation of 6 months during which the ELV will be 800

mg/Nm³.

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7 Objection Point No.4:Monitoring of Kiln 6

7.1 Introduction

Irish Cement currently continuously monitors nitrogen oxides (NOX) and particulates in

Kiln 6 gases in accordance with its IE licence P0029-03. It also monitors continuously

carbon monoxide (CO) and oxygen (O2) in these gases.

Irish Cement was not aware until 4th July 2017 the full monitoring requirements that

would be required by the Agency in respect of Kiln 6 gases. In addition to what is

currently continuously monitored, the PD requires Irish Cement to monitor continuously

sulphur oxides (SOX), hydrogen chloride (HCl), hydrogen fluoride (HF) and ammonia

(NH3).

While the requirement for continuous monitoring of some parameters was known, it

would not have made sense to install a Continuous Environmental Monitoring System

(CEMS) and later change or upgrade the CEMS to monitor other parameters until the

monitoring requirements of PD were known. The correct approach was to do this once

when all parameters were identified as having to be continuously monitored.

Once notified, Irish Cement immediately put in place a programme to specify, procure,

install and commission the equipment needed to continuously monitor the specified

parameters.

Until this equipment is installed, Irish Cement proposes to monitor Kiln 6 gases for SOX,

NH3, HCl, HF and TOC periodically (quarterly). Irish Cement notes that BAT5 allows

for periodic monitoring of HCl, HF and TOC.

Irish Cement requires an amendment of the PD to permit periodic monitoring of SOX,

NH3, HCl and HF for a period of 6 months to allow procurement, installation and

commissioning of the necessary equipment, the specification of which could not be

foreseen.


Emission Limit Values and monitoring requirements for Kiln 6 are set out in Proposed

Schedule C: Emissions, Monitoring and Control, C.1 Emissions to Air, C.1:1

Description, limit values and monitoring at emission point reference number A2-01 and

referenced in Proposed Conditions 1.6, 5.1 and 6.1). The licence requires inter alia

continuous monitoring of SOX, NH3, HCl and HF.

7.3 BAT

BAT 5f allows for periodic or continuous monitoring of HCl, TOC and HF in relation to

kiln processes, as outlined in Table 1. P0029-05 requires continuous monitoring of HF

and HCl.

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7.4 Discussion

Irish Cement is preparing to install continuous monitoring in accordance with Schedule C

of the PD. An order will be placed for the equipment by 4th August 2017. However, the

equipment and software cannot be installed immediately as the ELV and frequency of

monitoring have just been published in the PD. Irish Cement had no way of knowing in

advance of the PD all the parameters that would require continuous monitoring.

Irish Cement is committed to installing continuous monitoring equipment at A2-01 as

required by the PD. Irish Cement requests a derogation to allow for the lead-in time of 6

months.

The programme for procuring, installing and commissioning continuous monitoring

equipment is as follows:

Description of Work

Equipment specification and placement of Purchase Order 4th August 2017

Procurement (vendor to manufacture/QC and deliver to site) 30th November 2017

Installation 31st December 2017

Commissioning, (includes for Kiln outage) 31st January 2018

Irish Cement confirms that it is implementing the above programme as rapidly as

possible.

7.5 Appeal

Accordingly Irish Cement requests that the monitoring of SOX, NH3, HCl and HF from

Kiln 6 be periodic until continuous monitoring equipment has been installed and

commissioned. Time to comply of 6 months is requested.

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Kiln 6 Current continuous

monitoring of particulates

Kiln 6 Current periodic monitoring

of particulates,SO

X

NH

3

Kiln 6 Future continuous monitoring

of monitoring of particulates, NO

X

,

CO, O

2

, HCl, HF, SO

X

, NH

3

Kiln 6 Future periodic monitoring

of TOC, metals, PCDD/Fs)

Kiln 6 Bag Filter

Current Kiln 6 Continuous

Monitoring for NO

X

, CO, O

2

Kiln 6

Coal

Mill 6

NOx

Abatement

Kiln 6

Stack

Coal Mill 6 Hybrid Filter

Coal Mill 6 continuous

monitoring of particulates

A4

Do not scale

Job TitleClient

© Arup

Job No

Discipline

Scale at A4

Drawing No Issue

Drawing Status

Drawing Title

N5002 R1

NTS

Report

Environmental

325373-47

Figure 1

Kiln 6 / Coal Mill 6

Equipment and Monitoring

Irish Cement Ltd

Industrial Emissions Licence

Proposed Determination

P0029-05 Objection

Arup, 50 Ringsend Road

Dublin, D04 T6X0

www.arup.ie

Tel +353(0)1 233 4455 Fax +353(0)1 668 3169

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Date

July 2017

Created using CADplot http://www.oasys-software.com/cadplot/

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