Irish Cement Ltd Platin Works IPPC Licence Application ...

Irish Cement Ltd Platin Works IPPC Licence Application Attachment No. G

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ATTACHMENT No. G

RESOURCE USE AND ENERGY EFFICIENCY

TABLE OF CONTENTS

G.1. Raw Materials, Intermediates and Products .........................................................2

G.2. Energy Efficiency........................................................................................................2

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G.1. Raw Materials, Intermediates and Products

G.1.1 Raw Materials and Process Materials

The principal raw materials, by-products and ancillary materials used at Irish Cement Ltd Platin (ICL Platin) are listed in Tables G.1(i) and G.1(ii). The associated risk and safety phrases have been obtained from the relevant Safety Data Sheets.

G.1.2 Process Intermediates

There are three process intermediates associated with ICL Platin’s activities. They are:

• Raw meal

• Clinker

• By-pass and filter dusts

Raw meal is the product of primary crushing of limestone, shale, bauxite and iron oxide. The Raw meal is blended in homogenising silos before being converted to cement clinker in the kiln systems.

Clinker is the main component of cement.

By-pass dust and filter dust are generated in the by-pass and filter systems. This material is all transported by screw conveyor and then returned into the process stream.

G.1.3 Finished Products

Five types of finished product cement are produced at ICL Platin. They are:

• CEM I Normal Portland Cement

• CEM II Portland Limestone Cement

• CEM I Rapid Hardening Portland Cement

• Sulphate Resisting Portland Cement

• Slag Binder

• Specials according to market requirements

G.2 Energy Efficiency

G.2.1 Energy Usage

Energy is consumed at ICL Platin in the form of petroleum coke (coal may also be used), diesel oil and electricity. Small quantities of propane gas are consumed.

Energy consumption data is provided to the Agency in the Annual Environmental Reports (AERs) for the facility. Table G.1 summarises the energy consumption at the site for 2006.

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Table G.1 Energy Consumption (2006) at ICL Platin

Energy Source Unit Consumption

Petroleum coke / coal tonnes 187,034

Diesel / light fuel oil tonnes 1,224

Electricity MWh 219,948

G.2.2 Energy Saving Measures

The ICL environmental policy requires all its facilities to optimise the use of energy and material resources. ICL Platin operates under EPA Licence Reg. No. P0030-02. The primary aim of IPC/IPPC licensing is to prevent or reduce emissions to air, water and land, to reduce waste and to use energy efficiently. ICL Platin achieves this by using advanced, energy-efficient methods to create a range of high quality cements as well as operating under an established Environmental Management System (EMS). ICL Platin's EMS is to international standard ISO 14001, which strives to achieve continuous improvement in many environmental aspects, including energy use.

An Environmental Management Plan (EMP) is agreed annually and provided to the Agency. The EMP sets targets and objectives for the year ahead and aims to achieve continuous improvement of the Environmental Management System, some examples (2006) include,

• Install and commission Kiln 3 in late 2008. Kiln 3 will be designed as a state of the art plant to achieve optimum energy efficiency in electrical power consumption and fuel consumption (heat economy optimised).

• Install and commission Raw Mill 3, Coal Mill 3 and Cement Mill 4, which will have optimum energy efficiency.

• Continue to upgrade the plc control system, which leads to optimum energy efficiency throughout the factory.

• Continue to optimise kiln feed quality and so optimise energy efficiency in the clinker production process

• Continue to maximise overburden use as a raw material and reduce the requirements of transporting shales over longer distances, so optimising energy efficiency.

ICL Platin is also committed to entering the Sustainable Energy Ireland (SEI) Energy Agreements Programme. This programme has been developed under the new Irish Energy Management Standard, IS 393 and provides companies with a structured approach to reducing energy costs and improving energy management through the implementation of a schedule of energy efficient measures.

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IPPC Licence Application Tables

G.1(i)

G.1(ii)

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Table G.1(i) Details of Process related Raw Materials, Intermediates, Products, etc., used or generated on the site

Ref. No or

Material/ Substance(1)

CAS Number

Danger(2) Category

Amount Stored

Annual Usage

Nature of Use R(3) - Phrase S(3) - Phrase

Code (tonnes) (tonnes) 1 Limestone N/A None 30,000 2,171,451 Cement production N/A N/A 2 Shale N/A None 20,000 121,717 Cement production N/A N/A

3 Clay Overburden N/A None 40,000 m3 443,368 Cement production N/A N/A

4 Ground granulated Blast Furnace Slag N/A Irritant 1,500 39,474 Foundry by-product N/A N/A

5 Bauxite (Aluminium hydroxide) 21645-51-2 Irritant 2,000 m3 45,000 Process intermediate R36 S26

6 Iron (III) oxide 1309-37-1 Irritant 400 m3 5,000 Process intermediate R36/37/38 S26 7 Pulverised Fly Ash N/A None 0 0 Cement production None None 8 Raw Meal N/A None 35,000 2,600,000 Process intermediate None None 9 Clinker N/A None 120,000 1,600,000 Process intermediate None None

10 Cement Mixture Irritant 60,000 <0.1 Finished product R36, R37, R38

S24, S25, S26, S36, S37, S39

11 Gypsum N/A None 6,000 80,374 Intermediate Product N/A N/A

12 Coal N/A None 0 0 Combustion for heat generation purposes N/A N/A

13 Petroleum Coke 64741-79-3 None 14,000 18,607 Kiln fuel N/A N/A

14 Light Fuel Oil N/A Toxic 0 0 Burner fuel R45, R52, R53 S45, S53, S61

15 Diesel N/A Harmful 1.44 x 106 L

406.3 x 106 L

Burner fuel / diesel engines R40 N/A

16 Propane 74-98-6 Extremely flammable 6,000 L 3,585 L Burner fuel R12 S2, S9, S16

17 Ammonia water solution <25% 001336-21-6 Corrosive 100 1,300 Process intermediate

for NOX reduction R34 S26-36/37/39-45-61

18 Grinding aid Type 1 Mixture Harmful 30,000L 240L Process Intermediate R22 S 25, 36, 60

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Ref. No or


CAS Number

Danger(2) Category

Amount Stored

Annual Usage


Code (tonnes) (tonnes) 19 Grinding aid Type 2 Mixture Irritant 30,000L <0.1 Process Intermediate R36 S 23, 26, 60 20 Tin Sulphate 7488-55-3 Irritant 5 180 Process Intermediate R36/37 S22/26 21 Ferrous Sulphate 7720-78-7 Harmful 60 515 Cement additive R22/38, R37 S2, S46 22 Acetic Acid 64-19-7 Corrosive, Flammable 2.5 L 2.5 L Laboratory chemical R10, R35 S2, S23, S26

23 Ammonia Soln. 35% 1336-21-6 Corrosive, Dangerous for the environment 2.5 L 0.1 L Laboratory chemical R34-50

S26-36/37/39-45-61

24 Ethylene Glycol 107-21-1 Harmful 2,000 L 4,000 L Laboratory chemical R22 S2 25 Hydrochloric Acid 7647-01-0 Corrosive 50 L 160 L Laboratory chemical R34, R37 S2, S26 26 Kerosene/Parafin 8008-20-6 Flammable, Harmful 5 L 2 L Laboratory chemical R10, R38 S16, S36

27 Kerosene for degreasing (Safety Kleen) 64742-47-8 Harmful, Flammable 0 500 L Degreasing machine

parts

R10, R38, R51/53, R65,66

S16, 23, 24, 43, 61, 62

28 Methylated Spirit 99% 64-17-5 Highly flammable, Harmful 100 L 50 L Laboratory chemical

R11-20/21/22-68/20/21/22

S16, 23, 24, 33, 36/37-45

29 Nitric Acid 7697-37-2 Oxidising, Corrosive 7.5 L 0.5 L Laboratory chemical R8, R35 S23, S26, S36

30 Potassium Hydroxide 40% 1310-58-3 Harmful, Corrosive 2.5 L 2.5 L Laboratory chemical R20, R21, R22, R35, R41

S26, S36, S37, S39, S45

31 Triethanolamine 102-71-6 None 100 L 1 L Chemical Regent R36, R38 S26, S36

32 Lithium Tetraborate 12007-60-2 None 0.07 0.11 Laboratory chemical R36, R37, R38 None

33 Parafin/Binding Wax 8002-74-2 None 0.025 0.07 Laboratory chemical None None 34 Sodium Carbonate 497-19-8 None 0.005 0.0025 Laboratory chemical R36, R37 S22, S26

35 Barium Chloride 10326-27-9 Dangerous for the environment, Harmful 0.001 L <0.1 L Laboratory chemical R20, R22,

R53 S28

36 Ammonium thiocyanate 1762-95-4 Harmful 2.5 L <0.1 L Laboratory chemical R20, R21, R22, R37, S26, S36

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Ref. No or


CAS Number

Danger(2) Category

Amount Stored

Annual Usage


Code (tonnes) (tonnes) R38

37 Silver Nitrate 7761-88-8 Harmful, Oxidising, Corrosive 2.5 L <0.1 L Laboratory chemical

R22, R34, R36, R37, R38

S26, S45

38 Acetone 67-64-1 Highly flammable 2.5 L 10 L Laboratory chemical R 11-36-66-67 S 9-16-26

39 Citric acid monohydrate 5949-29-1 Irritant 0.01 0.001 Laboratory chemical R37 R38 R41 S26 S36

40 Mercury 7439-97-6 Toxic (Re-usable) 0.002 0.002 Laboratory chemical R21, R22, R23, R33 S7-45-60-61

41 Tickopur RW77 Mixture Irritant 5 L 1 L Laboratory chemical R36/38 S2 S26-37/38 42 Tickopur R27 Mixture Corrosive 5 L 1 L Laboratory chemical R34 S2 S26-37/39

43 Hydrochloric acid 0.1N 7647-01-0 Corrosive, Toxic 15 L 50 L Laboratory chemical R23 R24 R25 R34 R36 R37 R38

S26 S36 S37 S39 S45

44 Hydrochloric acid 37% 7647-01-1 Corrosive, Toxic 15 L 20 L Laboratory chemical R23 R24 R25 R34 R36 R37 R39

S26 S36 S37 S39 S46

45 Sulphuric acid (98%) 7664-93-9 Corrosive, Toxic 6 L 6 L Laboratory chemical R23 R24 R25 R35 R36 R37 R38 R49

S23 S30 S36 S37 S39 S45

46 Nitric acid (70%) 7697-37-2 Harmful, Oxidising, Corrosive 5 L 0.5 L Laboratory chemical R8 R23 R24

R25 R34 R41 S23 S26 S36 S37 S39 S45

47 Xylene 108-38-3 Flammable, Harmful, Toxic 2.5 L <0.1 L Laboratory chemical R10, R11,

R38 S25

48 Kerosin 8008-20-6 Flammable, Harmful 5 L 2 L Laboratory chemical R10, R38 S16, S36

49 Hydrogen peroxide solution 5 % 7722-84-1 Irritant, Oxidising 50 L 20 L Laboratory chemical R8, R36/38 S3, S17, S20,

23, S26, S60 50 Nitrogen Gas 7727-37-9 None 20 L <0.1 L Laboratory chemical None S38 51 Oxygen (High purity) 7782-44-7 Oxidising 21.2 m3 65 m3 Laboratory chemical R8 S9, S17

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Ref. No or


CAS Number

Danger(2) Category

Amount Stored

Annual Usage


Code (tonnes) (tonnes) 52 Butane 106-97-8 Highly flammable 0.025 0.1 Laboratory chemical R 12 S9 S16 S33 53 Aluminium oxide 1344-28-1 Irritant 0.01 <0.1 L Laboratory chemical None S22 S36 S38 54 Shell Corena oil P68 N/A None 5 L 5 L Laboratory chemical None None 55 Duckhams admix B3 N/A None 0.025 0.003 Laboratory chemical None None

56 Castrol castcon 51 68334-30-5 Harmful 20 L 6 L Laboratory chemical R40, R65, R16,

S23, S28, S36, S37, S39, S55, S56, S61, 62

57 Sikament HE 200 N/A None 25 L <0.1 L Additative, accelerator None None 58 DP Lubricant blue N/A Flammable 0.00005 0.00002 Laboratory chemical None None

59 EDTA titration solution (0.2N) 60-00-4 Irritant 1 L <0.1 L Laboratory chemical R26 S26

60 Hydrofluoric acid (48%) 7664-39-3 Corrosive, Very Toxic 2 L <0.1 L Laboratory chemical R26/27/28-35

S26-28-36/37/39-45

61 Argon (90%) – Methane (10%) mixture gas 7440-37-1 Flammable 60 m3 400 m3 Laboratory chemical None S38

62 Oxalic acid 144-62-7 Corrosive 0.0005 <0.1 L Laboratory chemical R20 R21 R22 R34 S24 S25

63 Diethyl ether 60-29-7 Highly flammable, Corrosive 2 L <0.1 L Laboratory chemical R12 R19 R22

R66 R67 S9 S16 S29 S33

64 1,1,1-Trichloroethan 71-55-6 Harmful 2.5 L <0.1 L Laboratory chemical R20-59 S24, 25-59-61 65 Titanium dioxide 13463-67-7 None 0.0005 <0.1 L Laboratory chemical None None 66 Zinc - granulated 7440-66-6 Highly flammable 0.0001 <0.1 L Laboratory chemical R11 S7 S8 S43

67 Thymolphthalein - indicator 125-20-2 None 0.00002 0.00005 Laboratory chemical None S22-24/25

68 Quartz fine granular 14808-60-7 None 0.00125 <0.1 L Laboratory chemical R48/20 S22

69 Silica gel 112926-00-8 None 0.003 0.0005 Laboratory chemical None S22 S36 S37 S45 S53

70 Total Hardness indicator tablets N/A None 0.0001 <0.1 L Laboratory chemical None S26

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Ref. No or


CAS Number

Danger(2) Category

Amount Stored

Annual Usage


Code (tonnes) (tonnes) 71 Benzoic acid 65-85-0 Harmful 0.0001 <0.1 L Laboratory chemical R22 R36 R37 S26 72 Methyl red indicator 943-52-7 None 0.00002 <0.1 L Laboratory chemical None S22-24/25

73 Phenolphthalein 77-09-8 None 0.00002 0.00005 Laboratory chemical R36, R37, R38 S26

74 High vacuum grease N/A None 0.00005 0.0002 Laboratory chemical None None 75 Aluminium foil 7429-90-5 None 0.00025 0.00001 Laboratory chemical None None

76 Potassium hydrogen sulphate 7646-93-7 Corrosive 0.0005 <0.1 L Laboratory chemical R34-37 S26-36/ 37/

39 - 45

77 Calcium Carbonate 471-34-1 None 0.0001 0.000025 Laboratory chemical R36, R37, R38 S26 S36

78 Sodium Chloride 7647-14-5 None 0.0005 0.00001 Laboratory chemical R36 S26 S36

79 Cupric Sulphate 7758-99-8 Harmful, dangerous to environment 0.0001 0.00005 Laboratory chemical R22 R36 R38

R50 R53 S22 S60 S61

80 Sodium Hydroxide pellets 1310-73-2 Harmful, Corrosive 0.001 0.00002 Laboratory chemical R35 S26 S37 S39 S45

81 Di-n-butyl phthalate 84-74-2 Toxic, Dangerous to Env. 0.1 L <0.1 L Laboratory chemical R60-50-62 S53-45-61

82 Bromo cresol green indicator 76-60-8 Highly Flammable,

Toxic 0.00005 0.000005 Laboratory chemical R11-23/25-36/38

S7-16-24-33-45

83 Buffer solution pH 10 N/A Irritant 1 L 0.5 L Laboratory chemical R36/38 S26 84 Buffer solution pH 4 N/A Irritant 1 L 0.5 L Laboratory chemical None None

85 Potassium hydroxide soln. 40% 1310-58-3 Corrosive, Harmful 2 L 0.5 L Laboratory chemical R35 S26-

36/37/39-45

86 Sodium hydrogen Carbonate 144-55-8 None 0.0002 0.000025 Laboratory chemical None None

87 Potassium hydroxide pellets Granulated 1310-58-3 Corrosive 0.0005 <0.1 L Laboratory chemical R35 S26-37/39-45

88 Ammonium Iron (III) Sulphate dodecahydrate 7783-83-7 Irritant 0.0005 <0.1 L Laboratory chemical R36/38 S26-36/37

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Ref. No or


CAS Number

Danger(2) Category

Amount Stored

Annual Usage


Code (tonnes) (tonnes) 89 1,5-DiphenylCarbazide 140-22-7 Irritant 0.000025 <0.1 L Laboratory chemical R36-37-38 S22-36

90 Potassium dichromate 7778-50-9 Toxic, Dangerous to Env 0.001 0.00002 Laboratory chemical R49-46-21-25-26-37/38-41-43 50/53

S53-45-60-61 M1

91 Pyrogallol solution 60% w/v 87-66-1 Corrosive, Harmful 0.5 L 0.1 L Laboratory chemical R20/21/22

R52/53-68 S36/37-61

92 Sulphamic acid 5329-14-6 Irritant 2.5 L <0.1 L Laboratory chemical R36/38 – 52/523 S23-26-45

93 Ammonium thiocyanate (0.1N) 1762-95-4 Harmful 2.5 L <0.1 L Laboratory chemical 20/21/22 –

32-52/53 S13-61

94 Boric acid 10043-35-3 None 0.002 <0.1 L Laboratory chemical None None

95 Manometervaeske MF 0,88 ROD Indeholder petroleum - DiBromethan

106-93-4 Toxic, Dangerous for the environment 1 L 0.1 L Laboratory chemical

R45- 23/24/25 –36/37/38 –51/53

S53-45-61

96 Lecocel II accelerator N/A None 0.005 0.001 Laboratory chemical None None

97 Potassium chloride 7447-40-7 None 0.0001 <0.1 L Laboratory chemical R36 S22, S24, S25, S26, S36

98 Pureshield argon 07440-37-1 None 11 m3 30 m3 Compressed Air None S9, S23 99 Propane 74-98-6 Extremely flammable 0 <0.1 L Compressed Air R12 S2, S9, S16

100 Nitrogen 07727-37-9 None 70 m3 600 m3 Compressed Air None S9, S23 101 Conplas 717 admixture N/A None 6 L 20 L Engineering material None None 102 Acetylene 00074-86-2 Extremely flammable 400 m3 800 m3 Compressed Air R5, R6, R12 S9, S16, S33 103 Oxygen 07782-44-7 Oxidising 660 m3 3,500 m3 Compressed Air R8 S9, S17 104 Carbon dioxide 00124-38-9 None 200 m3 200 m3 Compressed Air None S9, S23 105 Alumina Refractory Bricks N/A None 3,600 550 Refractory material None None

106 Mag. Spinel Refractory Bricks Mixture None 600 100 Refractory material None None

107 Lightweight Refractory Mixture None 30 35 Refractory material None None

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Ref. No or


CAS Number

Danger(2) Category

Amount Stored

Annual Usage


Code (tonnes) (tonnes) Bricks

108 Refractory Castable N/A None 20 25 Refractory material None None

109 Sodium Silicate 1344-09-8 Harmful, Corrosive 2.2 3.5 Brick installation R22, R34, R38, R41

S23, S24, S25, S26, S27, S36, S37, S39

110 Ag Mortar 1309-48-4 None 6 6 Used for laying refractory bricks. None None

111 Ox Mortar Mixture None 5 5 Used for laying lightweight refractory bricks.

None None

112 Dsf. 80 P Cement Mixture None 4 4 Used in laying high alumina refractory mills.

R37, R40 None

113 Mobilplex 47 N/A None 0 <0.1 L Engineering material None None 114 Mobil Rarus SHC 1024 Oil N/A None 208 L <0.1 L Engineering material None None 115 Magna 68 - 208 litre barrel N/A None 416 L <0.1 L Engineering material None None

116 Castrol Aircol Pd46 - 208 litre barrel N/A None 208 L 1,000 L Engineering material None None

117 Castrol Perfecto T68 - 208 liter barrel N/A None 832 L <0.1 L Engineering material None None

118 Super Cylinder 600W oil- 208 liter barrel N/A None 624 L <0.1 L Engineering material None None

119 Castrol TFC 410 - 208 barrel (Was TFC 310) N/A None 416 L 800 L Engineering material None None

120 Cooledge BI (was FE) 25 liter drum) N/A None 50 L <0.1 L Engineering material None None

121 Cresta SHS - 208 litre barrel N/A None 208 L <0.1 L Engineering material None None

122 Creasta VA 3008 - 208 liter N/A None 208 L <0.1 L Engineering material None None

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Ref. No or


CAS Number

Danger(2) Category

Amount Stored

Annual Usage


Code (tonnes) (tonnes) barrel

123 Castrol RX 10 - 208L barrel N/A None 208 L <0.1 L Engineering material None None

124 Alpha Sp 68 208 L barrel N/A None 400 L <0.1 L Engineering material None None

125 Hyspin Aws 100 Liter barrel N/A None 210 L <0.1 L Engineering material None None

126 Agri Powertrans plus 10W30 - 208 liter barrel N/A None 600 L <0.1 L Engineering material None None

127 Airline oil series 200, No.097079 - 25 L N/A None 50 L <0.1 L Engineering material None None

128 Syntheso D 680 EP -180kg drum N/A None 0.18 0.18 Engineering material None None

129 Alpha Sp 1000 - 208 L N/A None 416 L <0.1 L Engineering material None None

130 Acheson kiln tyre lubricant - 20kg N/A None 0.14 <0.1 L Engineering material None None

131 Hyvis 7000/45 (Polybutene) - 5 gallon drum

9003-29-6 None 15 L <0.1 L

Engineering material None None

132 Alpha SP100 - 25 liter drum N/A None 25 L <0.1 L Engineering material None None

133 Syntheso D 1000 -180kg drum N/A None 0.36 1 Engineering material None None

134 Hyspin VG 32 oil - 25L drum N/A None 25 L <0.1 L Engineering material None None

135 Castrol VT2 Oil - 208 L N/A None 208 L <0.1 L Engineering material None None

136 Chevron Cetus PAO 46 oil (was synerol 32) - 25 liter Mixture None 100 L 400 L Engineering material None None

137 Castrol 50W TFC450, transmission oil - 208 L N/A None 624 L 1875 L Engineering material None None

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Ref. No or


CAS Number

Danger(2) Category

Amount Stored

Annual Usage


Code (tonnes) (tonnes)

138 Kaeser sigma fluid S-460-200 L N/A None 800 L 8800 L Engineering material None None

139 Mobil 10W40 Oil N/A None 25 L 25 L Engineering material None None

140 Optimal Optiflex A680 Oil - 18 L drums N/A None 36 L <0.1 L Engineering material None None

141 Agri HT Trans oil 205L barrell N/A None 205 L <0.1 L Engineering material None None

142 Hyspin Awh -M 46 - 25 L N/A None 50 L <0.1 L Engineering material None None 143 Castrol Aircol Pd32 N/A None 50 L <0.1 L Engineering material None None 144 Hyspin Aws 150 N/A None 416 L <0.1 L Engineering material None None 145 Hyspin Aws 10 N/A None 400 L 800 L Engineering material None None 146 Hyspin Aws 46 N/A None 624 L 625 L Engineering material None None 147 Hyspin Aws 32 N/A None 800 L 4000 L Engineering material None None 148 Castrol SRG Grease N/A Irritant 0.0125 <0.1 L Engineering material None None

149 Spheerol MP 2 Grease 50 kg N/A None 0.015 0.00005 Engineering material None None

150 Ceplattyn KG 10 Grease 200kg Drum N/A None 0 0 Engineering material None None

151 Fuchs Grease 50 kg drum N/A None 0.25 0.25 Engineering material None None

152 Ceplattyn RN (einlauf) 190 kg Drum N/A None 0.19 <0.1 L Engineering material None None

153 Kluberfluid CF2 Ultra 16517 Coal Mill N/A None 0.18 0.18 Engineering material None None

154 Grafloscon BF1 for 26617 Coal Mill N/A None 2.5 <0.1 L Engineering material None None

155 Ceplattyn 300 15 kg drum N/A None 0.00003 <0.1 L Engineering material None None

156 Ceplattyn KG 10HMF2500 Grease 190 kg drum N/A None 0.38 <0.1 L Engineering material None None

157 Moly grease 12.5 kg N/A None 0.075 <0.1 L Engineering material None None

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Ref. No or


CAS Number

Danger(2) Category

Amount Stored

Annual Usage


Code (tonnes) (tonnes)

158 Ceplattyn Grease KG10HMF2500, 610kg tank

N/A None 0.122 2.5 Engineering material None None

159 Matrix grease N/A None 0.032 1.98 Engineering material None None

160 Spheerol L EP2 Grease 50kg drum N/A None 0.25 <0.1 L Engineering material None None

161 MobilgreaseXPH222 180kg drums N/A None 0 <0.1 L Engineering material None None

162 ROCOL BRB Grease N/A None 0 <0.1 L Engineering material None None 163 Wire rope lubricant N/A None 0 <0.1 L Engineering material None None 164 Alpha Sp 150 N/A None 416 L <0.1 L Engineering material None None

165 Alpha max Sp 220 optigear BM220 N/A None 0.72 2.5 Engineering material None None

166 Alpha max Sp 320 optigear BM320 N/A None 0.36 3.5 Engineering material None None

167 Grippa 33 64741-56-6 Harmful 0 <0.1 L Engineering material R21, R40 S37

168 Grippa 60 S 400 g Mixture Harmful, Flammable 0 <0.1 L Engineering material R13, R20, R40/21, R59 None

169 Adzorb N/A None 0.125 0.005 Oil Absorbent Material None None 170 Supersil 14808-60-7 None 60 L 190 L Silicone Sealant None None

171 Kemex N/A Explosive 0 336 Explosive Used in Limestone Quarry None None

172 Highnoon N/A None 5 L 20 L Cleaner None None

173 Evan Lift cleaner N/A Irritant 5 L 20 L Cleaner R 36/38 S 2, 24/25, 26, 48

174 Evan Clean and shine 68439-46-3 Harmful 5 L 20 L Cleaner R22, R41 S2, 46 175 Cleanfast N/A None 5 L 20 L Cleaner R2, R46 S2, S 46 176 Time Buster Stripper N/A None 5 L 20 L Cleaner None None 177 Sprint glass cleaner N/A None 5 L 20 L Cleaner R36, R67 None

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EPA Export 25-07-2013:22:12:31


G - 15 of 32

Ref. No or


CAS Number

Danger(2) Category

Amount Stored

Annual Usage


Code (tonnes) (tonnes) 178 Ironstone acrylic seal N/A None 5 L 20 L Cleaner None None 179 Speedball N/A None 5 L 20 L Cleaner R 36/38 S23 26 37 51

180 Jam – 3005 Cleaner WB II 0178-901-29 Harmful 100 L 60 L Ink Cleaner in packing plant

R36/37/38, R43

S24/25, 26, S37

181 Black Ink 105-902-29 Harmful 50 L 250 L Ink in packing plant R36/37/38, S 37, 24/25, 26

182 Shell Transformer oil 148 25 L N/A None 75 L 150 L Transformer oil None None

183 Silica gel with humidity indicator N/A None 0.01 0.001 Engineering material None None

184 ALBIDA RL2 Grease N/A None 0.0125 0.0125 Engineering material None None 186 Chesterton cleaner 273 N/A None 1 L 1 L Non-solvent cleaner None None

187 Contract Hard surface cleaner N/A None 5 L 20 L Cleaner None None

189 Evans Clear N/A None 0.5 L 1 L Cleaner None None 190 Dextra Duo N/A None 0.5 L 2 L Soap/Shampoo None None 191 Dextra Anti-Bac N/A None 0.5 L 3 L Hand Cleaner None None 192 Johnson Glade Spring 106-97-8 Extremely Flammable, 0.5 L 5 L Air freshener aerosol R12 None 193 Contract Bleach None Harmful to skin 5 L 20 L Bleach Cleaner None None 194 Galtec Dextra mild None None 5 L 20 L Hand Cleaner None None

195 Cleanline lavender polish mixture Extremely flammable, pressurised container 0.25 L 2 L Furniture polish R12, 66 S16, 2, 23A,

51 196 E-Pine Disinfectant None none 5 L 20 L disinfectant None S2, S26, S46 197 Pink pearl soaps None None 5 L 20 L Hand and body soap None None 198 Calgonite Lemon Gel None None 5 L 20 L Hard surface cleaner None None

199 Sundance Floor cleaner 68439-50-9 None 5 L 20 L Concentrated floor cleaner None None

200 TTC Cleaner None Irritant 1 L 10 L Toilet cleaner and descaler None None

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EPA Export 25-07-2013:22:12:31


G - 16 of 32

Ref. No or


CAS Number

Danger(2) Category

Amount Stored

Annual Usage


Code (tonnes) (tonnes) 201 Suma Max D9.2 None Irritant 5 L 10 L Kitchen Cleaner R 36/38 S23,26,37,51 202 Suma Scale D5.2 None Irritant 5 L 10 L Kitchen Cleaner R 36/38 S23,26,37,51 203 Suma Inox Classic D.7 None None 5 L 10 L Kitchen Cleaner None None 204 Suma Multi Conc. D.2 None Harmful 5 L 10 L Kitchen Cleaner R22,37/38,41 S23,26,37/39

205 Suma Bac Multi Conc. D.10 None Corrosive 5 L 10 L Kitchen Cleaner R34 S26,28,

36/37/39, 45

206 Suma Lima L3 None Corrosive 25 L 50 L Dishwasher detergent R31, 35 S26,28, 36/37/39,45

207 Suma Rince aid A5 None None 25 L 50 L Dishwasher detergent R 38, 41 S22, 26, 37/39

208 Suma Shine K2 None Irritant 5 L 10 L Kitchen cleaner R 38, 41 S22, 26

209 Cleanline stainless steel cleaner mixture Extremely flammable,

pressurised container 0.25 L 1 L Stainless steel cleaner R12, 66 S16, 2, 23A, 51

210 Descale 7647-01-0 Irritant 40 L 120 L Descaler R36/38 S1/2,24/25, 26, 36/37

211 Organic acid ZC 40 Mixture None 300 L 500 L Cleaning agent None None 212 Con-clean None Irritant 200 L 400 L Cleaning Agent None None

213 Kluberfluid CF3 ultra – 180 kg None None 180 kg 180 kg Engineering material None None

Notes: 1. In cases where a material comprises a number of distinct and available dangerous substances, please give details for each component substance. 2. c.f. Article 2(2) of SI No 77/94

3. c.f. Schedules 9 and 10 of SI No 62/2004

Table G.1(ii) Details of Process related Raw Materials, Intermediates, Products, etc., used or generated on the site

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EPA Export 25-07-2013:22:12:31


G - 17 of 32

Ref. No or

Material/

TA Luft Class 1,

Odour EU Lists I and II (Tick and specify Group/Family Number)

Code Substance(1) 2 or 3 Odourous Yes/No

Description

Threshold

Dangerous Substances Directive

76/464/EEC

Groundwater Directive

80/68/EEC µg/m3 List I List II

+1294 List I List II

1 Limestone - No Not applicable - - - - - 2 Shale - No Not applicable - - - - - 3 Clay Overburden - No Not applicable - - - - -

4 Ground granulated Blast Furnace Slag - No Not applicable - - - - -

5 Bauxite (Aluminium hydroxide) - No Not applicable - - - - -

6 Iron (III) oxide - Not available - - - - - 7 Pulverised fly ash - No Not applicable - - - - - 8 Raw Meal - No Not applicable - - - - - 9 Clinker - No Not applicable - - - - -

10 Cement - No Not applicable - - - - -

11 Gypsum - Yes Slight musty odour Not available - - - -

12 Coal - No Not applicable - (7) - (7) - 13 Petroleum Coke - No Not applicable - (7) - (7) -

14 Light Fuel Oil - Yes Asphaltic odour Not available (7) - (7) -

15 Diesel - Yes Pungent petroleum odour

Not available (7) - (7) -

16 Propane - No Not applicable - - - - -

17 Ammonia water soln 24.5% - Yes Ammonia odour Not

available - - - (7)

18 Grinding aid Type 1 - Yes Slightly ammonical Not available - - - -

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G - 18 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




19 Grinding aid Type 2 - Yes Characteristic Not available - - - -

20 Tin Sulphate - No Not applicable - - (1) - (1) 21 Ferrous Sulphate - No Not applicable - - - -

22 Acetic Acid II Yes Strong, vinegar - like Not Available - (3) - (3)

23 Ammonia Soln. 35% - Yes Pungent characteristic odour

Not Available - (8) - (7)

24 Ethylene Glycol III Yes Almost odourless - - - - -

25 Hydrochloric Acid - Yes Pungent

Not Available - - - -

26 Kerosene/Parafin III Yes Petroleum hydrocarbon odour

Not

Available (7) - (7) -

27 Kerosene for degreasing (Safety Kleen) III Yes Petroleum

hydrocarbon odour Not

available (7) - (7) -

28 Methylated Spirit 99% I Yes Fresh, characteristic Not available

- - - -

29 Nitric Acid - Yes Pungent Not available

- - - -

30 Potassium Hydroxide 40% - No Not applicable - - - - -

31 Triethanolamine - No Not applicable - - - - - 32 Lithium Tetraborate - No Not applicable - - - - -

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G - 19 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




33 Parafin/Binding Wax III No Not applicable - - - - - 34 Sodium Carbonate - No Not applicable - - - - - 35 Barium Chloride - No Not applicable - - - - -

36 Ammonium thiocyanate - Yes Slight ammonia odour Not available

- - - -

37 Silver Nitrate - No Not applicable - - (1) - (1)

38 Acetone III Yes Fragrant, mint-like Not available

- - - -

39 Citric acid monohydrate - No Not applicable - - - - - 40 Mercury - No Not applicable - (5) - (5)

41 Tickopur RW77 - Yes

Weak ammonia odour

Not available - - - -

42 Tickopur R27 - Yes Weak characteristic odour

Not available

- - - -

43 Hydrochloric acid 0.1N - Yes Pungent odour Not available

- - - -

44 Hydrochloric acid 37% - Yes Pungent odour Not available

- - - -

45 Sulphuric acid (98%) - No Not applicable - - - - -

46 Nitric acid (70%) - Yes Pungent Not available - - - -

47 Xylene II Yes Light, aromatic Not available - - -

48 Kerosin (Kerosene) III Yes Petroleum Not (7) - (7) -

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G - 20 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




hydrocarbon odour Available

49 Hydrogen peroxide soln. 5 % - Yes Slight acrid odour Not

available - - - -

50 Nitrogen Gas - No Not applicable - - - - - 51 Oxygen (High purity) - No Not applicable - - - -

52 Butane - Yes Slight Not available - - - -

53 Aluminium oxide - No Not applicable - - - - -

54 Shell Corena Oil P68 - Yes Low odour Not available (7) - (7) -

55 Duckhams admix B3 - No Not applicable - - - - - 56 Castrol castcon 51 - Yes Sharp - (7) - (7) -

57 Sikament HE 200 - Yes Pungent Not available - - - -

58 DP Lubricant blue - Yes Alcohol odour Not available - - - -

59 EDTA titration solution (0.2N) - No Not applicable - - - - -

60 Hydrofluoric acid (48%) - Yes Acrid odour Not available - - - -

61 Argon (90%) – Methane (10%) mixture gas - No Not applicable - - - - -

62 Oxalic acid - No Not applicable - - - - -

63 Diethyl ether - Yes Sweetish, pungent, ethereal


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G - 21 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




64 1,1,1-Trichloroethan - Yes Sweet

Not available - - -

65 Titanium dioxide - No Not applicable - - (1) - (1) 66 Zinc - granulated - No Not applicable - - (1) - (1)

67 Thymolphthalein - indicator - No Not applicable - - - - -

68 Quartz fine granular - No Not applicable - - - - - 69 Silica gel - No Not applicable - - (4) - (4)

70 Total Hardness indicator tablets - No Not applicable - - - - -

71 Benzoic acid - Not available - - - - -

72 Methyl red indicator - Yes Alcohol odour Not available - - - -

73 Phenolphthalein - No Not applicable - - - - - 74 High vacuum grease - No Not applicable - - - - - 75 Aluminium foil - No Not applicable - - - - -

76 Potassium hydrogen sulphate - No Not applicable - - - - -

77 Calcium Carbonate - No Not applicable - - - - - 78 Sodium Chloride - No Not applicable - - - - - 79 Cupric Sulphate - No Not applicable - - - - -

80 Sodium Hydroxide pellets - No Not applicable - - - - -

81 Di-n-butyl phthalate - Yes Slight aromatic odour Not available - - - -

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G - 22 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




82 Bromo cresol green indicator - No Not applicable - - - - -

83 Buffer solution pH 10 - No Not applicable - - - - -

84 Buffer solution pH 4 - Yes Slight thymol odour Not available - - - -

85 Potassium hydroxide soln. 40% - No Not applicable - - - - -

86 Sodium hydrogen carbonate - No Not applicable - - - - -

87 Potassium hydroxide pellets Granulated - No Not applicable - - - - -

88 Ammonium Iron (III) Sulphate dodecahydrate - No

Not applicable

- - - - -

89 1,5-DiphenylCarbazide - Not available - - - - - 90 Potassium dichromate - No Not applicable - - - - -

91 Pyrogallol solution 60% w/v - Not available - - - - -

92 Sulphamic acid - No Not applicable - - - - -

93 Ammonium thiocyanate (0.1N) - No Not applicable - - - - -

94 Boric acid - No Not applicable - - - - -

95 Manometervaeske MF 0,88 ROD Indeholder petroleum -

- No Not applicable - - - - -

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G - 23 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




DiBromethane 96 Lecocel II accelerator - No Not Applicable - - - - - 97 Potassium chloride - No Not applicable - - - - - 98 Pureshield argon - No Not applicable - - - - - 99 Propane - No Not applicable - - - - -

100 Nitrogen - No Not applicable - - - - - 101 Conplas 717 admixture - No Not applicable - - - - -

102 Acetylene - Yes Garlic like Not available - - - -

103 Oxygen - No Not applicable - - - - -

104 Carbon dioxide - Yes Sharp in high concentrations


105 Alumina Refractory Bricks - No

Not applicable

- - - - -

106 Mag. Spinel Refractory Bricks - No Not applicable - - - - -

107 Lightweight Refractory Bricks - No Not applicable - - - - -

108 Refractory Castable - No Not applicable - - - - - 109 Sodium Silicate - No Not applicable - - - - - 110 Ag Mortar - No Not applicable - - - - - 111 Ox Mortar - No Not applicable - - - - - 112 Dsf. 80 P Cement - Not available - - - - - 113 Mobilplex 47 - Yes Mild Not (7) - (7) -

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EPA Export 25-07-2013:22:12:32


G - 24 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




available

114 Mobil Rarus SHC 1024 Oil - Yes Mild Not


115 Magna 68 - 208 litre barrel - Yes Mild Not


116 Castrol Aircol Pd46 - 208 litre barrel - Yes Mild Not


117 Perfecto T68 - 208 liter barrel - Yes Oily Not


118 Super Cylinder 600W oil- 208 liter barrel - Yes Petroleum oil odour Not


119 Castrol TFC 410 - 208 barrel - Yes Mild Not


120 Cooledge BI (was FE) 25 liter drum) - Yes Mild Not


121 Cresta SHS - 208 litre barrel - Yes Mild Not


122 Creasta VA 3008 - 208 liter barrel - Yes Mild Not


123 Castrol RX 10 - 208L barrel - Yes Mild Not


124 Alpha Sp 68 208 L barrel - Yes Mild Not available (7) - (7) -

125 Hyspin Aws 10 208L Liter barrel - Yes Mild Not


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EPA Export 25-07-2013:22:12:32


G - 25 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




126 Agri Powertrans plus 10W30 - 208 liter barrel - Yes Mild Not


127 Airline oil series 200, No.097079 - 25 L - Yes Mild Not


128 Syntheso D 680 EP -180kg drum - Yes Product specific Not


129 Alpha Sp 1000 - Yes Mild Not available (7) - (7) -

130 Acheson kiln tyre lubricant - Yes Mineral oil Not

available - - - -

131 Hyvis 7000/45 (polybutene) - Yes Characteristic Not


132 Alpha SP100 - 25 liter drum - Yes Mild Not


133 Syntheso D 1000 -180kg drum - Yes Product specific Not


134 Hyspin VG 32 oil - 25L drum - Yes Mild Not


135 Castrol VT2 Oil - 208 L - Yes Mild Not available (7) - (7) -

136 Chevron Cetus PA046 oil (was synerol 32) - 25 liter - Yes Hydro carbon odour Not


137 Castrol 50W TFC450, transmission oil - 208 L - Yes Mild Not


138 Kaeser sigma fluid S-460 - Yes Mild hydrocarbon Not (7) - (7) -

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EPA Export 25-07-2013:22:12:32


G - 26 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




- 200 L available

139 Mobil 10W40 Oil - Yes Mild

Not available (7) - (7) -

140 Optimal Optiflex A680 Oil - 18 L drums - Yes Mild Not


141 Agri HT Trans oil 205L barrell - Yes Mild Not


142 Hyspin Awh -M 46 - 25 L - Yes Mild Not available (7) - (7) -

143 Castrol Aircol Pd32 - Yes Mild Not available (7) - (7) -

144 Hyspin Aws 150 - Yes Mild Not available (7) - (7) -




148 Castrol SRG Grease - Yes Mild Not available (7) - (7) -

149 Spheerol MP 2 Grease 50 kg - Yes Mild Not


150 Ceplattyn KG 10 Grease - Yes Mineral oil Not (7) - (7) -

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EPA Export 25-07-2013:22:12:32


G - 27 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




200kg Drum available

151 Fuchs Grease 50 kg drum - Yes Characteristic Not available (7) - (7) -

152 Ceplattyn RN (einlauf) 190 kg Drum - Yes Mineral oil Not


153 Kluberfluid CF2 Ultra 16517 Coal Mill - Yes Product specific Not


154 Grafloscon BF1 for 26617 Coal Mill - No Not applicable - (7) - (7) -

155 Ceplattyn 300 15 kg drum - Yes Mineral oil Not


156 Ceplattyn KG 10HMF2500 Grease 190 kg drum

- Yes Mineral oil Not available (7) - (7) -

157 Moly grease 12.5 kg - Yes Mild Not available (7) - (7) -

158 Ceplattyn Grease KG10HMF2500, 610kg tank

- Yes Mineral oil Not available (7) - (7) -

159 Matrix grease 16.5 kg drums - Yes Mineral oil Not


160 Spheerol L EP2 Grease 50kg drum - Yes Mild Not


161 MobilgreaseXPH222 180kg drums - Yes Characteristic Not


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EPA Export 25-07-2013:22:12:32


G - 28 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




162 ROCOL BRB Grease - Yes Faint Not available (7) - (7) -

163 Wire rope lubricant - Yes Pleasant, mild odour Not available - - - -

164 Alpha Sp 150 - Yes Mild Not available (7) - (7) -

165 Alpha max Sp 220 optigear BM220 - Yes Mild Not


166 Alpha max Sp 320 optigear BM320 - Yes Mild Not


167 Grippa 33 - Yes Mild Not applicable (7) - (7) -

168 Grippa 60 S 400 g - Yes Sharp Not available (7) - (7) -

169 Adzorb - Not available - - - - 170 Supersil - No Not applicable - 171 Kemex - No Not applicable - - - - -

172 Highnoon - Yes Mild ammonia Not applicable - - - -

173 Evan Lift cleaner - Yes Faint Solvent Not

application

- - - -

174 Evan Clean and shine - Yes Floral Not applicable - - - -

175 Cleanfast - Yes Fragrant odour Not - - - -

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G - 29 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




applicable

176 Time Buster StripperYes - Yes Solvent odour Not available - - - -

177 Sprint glass cleaner - Yes Spearmint Not available - - - -

178 Ironstone acrylic seal - Yes Mild, ammonia Not available - - - -

179 Speedball - Yes Slightly perfumed Not available - - - -

180 Jam – 3005 Cleaner WB II - No Not available - - - - - 181 Black Ink - No Not available - - - - -

182 Shell Transformer oil 148 25 L - Yes Oil-type odour Not


183 Silica gel with humidity indicator - No Not applicable - - - - -

184 ALBIDA RL2 Grease - Yes Slight hydrocarbon odour

Not applicable (7) - (7) -

185 Chesterton cleaner 273 - Yes Mild odour Not available - - - -

186 Contract Hard surface cleaner - No Not applicable - - - - -

187 Evans Clear - Yes Alcoholic Not available - - - -

188 Dextra Duo - Yes Fragranced Not available - - - -

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G - 30 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




189 Dextra Anti-Bac - Yes Very mild fragranced Not available - - - -

192 Johnson Glade Spring - Yes Characteristic


193 Contract Bleach - Yes Odour of hypochlorites Not available - - - -

194 Galtec Dextra mild - Yes Fragranced Not available - - - -

195 Cleanline lavender polish - Yes Lavender Not

available - - - -

196 E-Pine Disinfectant - Yes Fresh pine Not available - - - -

197 Pink pearl soaps - Yes Floral Not available - - - -

198 Calgonite Lemon Gel - Yes Citrus Not available - - - -

199 Sundance Floor cleaner - Yes Characteristic Not available - - - -

200 TTC Cleaner - Yes Violet Not available - - - -

201 Suma Max D9.2 - Yes Characteristic Not available - - - -

202 Suma Scale D5.2 - Yes Characteristic Not available - - - -

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G - 31 of 32

Ref. No or

Material/

TA Luft Class 1,



Description

Threshold


76/464/EEC




203 Suma Inox Classic D.7 - Yes Characteristic Not available - - - -

204 Suma Multi Conc. D.2 - Yes Slightly perfumed Not available - - - -

205 Suma Bac Multi Conc. D.10 - Yes Characteristic Not

available - - - -

206 Suma Lima L3 - Yes Chlorine like Not available - - - -

207 Suma Rince aid A5 - Yes Characteristic Not available - - - -

208 Suma Shine K2 - Yes Characteristic Not available - - - -

209 Cleanline stainless steel cleaner - Yes Characteristic Not

available - - - -

210 Descale - No Odourless Not available - - - -

211 Organic acid ZC 40 - Yes Characteristic Not available - - - -

212 Con-clean - Yes Pleasant Not available - - - -

213 Kluberfluid CF3 180 kg - Yes Product specific Not available - - - -

Notes (cont.): 4. The European Commission priority candidate list 76/464/EEC List I (7): Persistent mineral oils and hydrocarbons of petroleum origin 76/464/EEC List I (5): Mercury and its compounds

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EPA Export 25-07-2013:22:12:32


G - 32 of 32

76/464/EEC List II (1): Listed metalloids and their compounds 76/464/EEC List II (3): Substances which have a deleterious effect on the taste and/or smell of the products for human consumption derived from the aquatic environment, and compounds liable to give rise to such substances in water 76/464/EEC List II (4): Toxic or persistent organic compounds of silicon, and substances which may give rise to such compounds in water, excluding those which are biologically harmless and are rapidly converted in water into harmless substances. 76/464/EEC List II (8): Substances which have an adverse effect on the oxygen balance, particularly : ammonia, nitrites. 80/68/EEC List I (7): Mineral oils and hydrocarbons 80/68/EEC List I (5): Mercury and its compounds 80/68/EEC List II (3): Substances which have a deleterious effect on the taste and/or odour of groundwater, and compounds liable to cause the formation of such substances in such water and to render it unfit for human consumption 80/68/EEC List II (7): Ammonia and nitrites 80/68/EEC List II (1): Listed metalloids and metals and their compounds 80/68/EEC List II (4): Toxic or persistent organic compounds of silicon, and substances which may cause the formation of such compounds in water, excluding those which are biologically harmless or are rapidly converted in water into harmless substances

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EPA Export 25-07-2013:22:12:32

Irish Cement Ltd Platin IPPC Licence Application Attachment No. H

H - 1 of 22

ATTACHMENT No. H

MATERIALS HANDLING

TABLE OF CONTENTS

H.1. Raw Materials, Intermediates and Products Handling...................................... 2

H.2. Waste Handling......................................................................................................... 6

H.3. Waste Disposal by On-Site Landfilling.............................................................. 11

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H.1. Raw Materials, Intermediates and Products Handling

H.1.1 Raw Materials

All raw materials in use at the Irish Cement Platin Ltd (ICL Platin) site are listed in Table G.(i) and G.(ii) of Attachment No. G. The storage locations of each of these materials are listed in Table H.1.

Table H.1 Storage Location of Materials at ICL Platin

Material Storage Location

Limestone Limestone Store / Emergency Stockpile and Quarry

Shale Shale Store

Overburden Overburden Stockpiles

Bauxite Bauxite Store

Iron Oxide Iron Oxide Store

Gypsum Gypsum Store

Ground Granulated Blast Furnace Slag (GGBS) GGBS Storage Silo

Engineering Materials Bunded Stores

Laboratory Chemicals Laboratory Chemical Store

Process Liquid Chemicals Bunded Storage Tanks

Refractory Materials Designated Shed

Compressed Gas/Air Cylinders Designated Cylinders

Ferrous Sulphate Ferrous Sulphate Silo

Tin Sulphate Tin Sulphate Hopper and IBCs

Grinding Aids Grinding Aid Tanks

The waste material storage locations are shown in Figure H.1.

Limestone is drilled and blasted at the quarry. Diesel fuelled wheel loaders load off-highway dump trucks for transport of the stone to the crushing plant, which has a capacity of 1,000 tonnes per hour. During operation the crushed limestone is brought to the limestone store; a facility to feed an off-line emergency stockpile is available. Stone can be retrieved from the outside pile via a mechanical infeeder.

Clay/overburden is extracted from the quarry and pre-homogenised in piles prior to crushing with shale. Shale is hauled by road from quarries near Donore and Denhamstown. A two stage crushing system is operated with a capacity of 500 tonnes per hour. The crushed overburden/shale is blended and stored in a homogenising store of capacity 11,000 tonnes.

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Limestone and overburden/shale are extracted from the homogenising stores by specially designed reclaimers and conveyed to separate mill feed hoppers. From the hoppers, these materials are conveyed together by belt to the raw mills.

Gyspum is added at the cement mill to control the setting time of the final cement. A gypsum store is available for strategic stocks. On occasions this material is imported.

The slag is transported from the slag storage silo to a receiving hopper in the mixing plant. Once the slag and cement bins are full the flow gates into the mixer are opened to allow the slag cement mix to be formed.

Other raw materials such as tin sulphate are stored in a designated area in sealed storage bags and ferrous sulphate which is stored in a designated silo. Tin sulphate is transported by forklift and fully trained operator using a safety harness frame and appropriate personal protection equipment. Ferrous sulphate is transported to site by tanker, which is unloaded into a silo by pumping. It is released mechanically as needed and the material is not manually handled at any stage.

Grinding aids are transported to site in tankers where they are mechanically unloaded by pump into bunded storage tanks (refer to Section H.1.5). This material is transported and dosed by pump as needed. These materials are not manually handled at any stage during the process in line with standard health and safety practice.

H.1.2 Process Materials

The storage locations of all process materials are listed in Table H.2.

Table H.2 Storage Locations of Process Materials at ICL Platin


Pet Coke Designated Pet Coke Stockpiles

Diesel Oil Bunded Diesel Storage Tanks

Oils / Grease Bunded Storage

Laboratory Chemicals Bunded Storage

Process Chemicals Bunded Storage

Refractory Materials Storage Shed

Compressed Gas/Air Cylinders Designated Gas/Air Cylinders

Oils and greases and other engineering materials e.g. oils, grease, lubricants or diesel are stored in designated secure bunded storage areas on site (refer to Section H.1.5). These materials are transported throughout the site by forklift on bunded pallets or by a designated oil/grease truck. The materials are pumped or sucked using compressors from storage containers to machines. Diesel is stored in bunded tanks (refer to Section H.1.5) and transported where necessary onsite by a fuel browser.

Laboratory chemicals are stored either in an external locked bunded laboratory chemical store or internally in secure presses in the laboratory. Laboratory chemicals

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are transported via hand trucks or forklift where necessary. All chemicals are handled according to standard laboratory practice.

Process chemicals e.g. ammonia water are transported to site in tankers where they are mechanically unloaded by pump into bunded storage tanks. This material is transported and dosed by pump as needed. These materials are not manually handled at any stage during the process in line with standard health and safety practice.

Refractory materials are stored inside a designated shed. These materials are transported by forklift when necessary to their designated sites where they are manually handled into position using standard health and safety practices.

Compressed gas/air cylinders are stored in a designated area. They are stored upright and secured on cylinders, which are transported by a special hand trucks or by forklift.

H.1.3 Process Intermediates

The storage locations of all process intermediates are listed in Table H.3.

Table H.3 Storage Locations of Process Intermediates at ICL Platin


Raw meal Raw meal storage silos

Clinker Clinker Storage Silos

Bypass and Filter Dusts Direct Transfer for Reuse in Process

The raw meal produced in the rawmills is conveyed to homogenising and storage silos by a combination of pneumatic and mechanical equipment. There are 7 homogenising and storage silos at the site. Homogenising takes place in the upper chamber. The homogenised raw meal is then dropped by gravity into the lower storage chamber.

Clinker from the kiln is transported by a metal pan conveyor to the storage silos. Clinker may occasionally be stored in external stockpiles on the quarry floor or at the factory to facilitate maintenance or market demands.

Kiln 2 is equipped with a bypass system which allows a portion of the dust laden process gas to be removed from the kiln system between the kiln and the preheater system. The bypass system removes a controlled amount of process gas from the system, treats it by air quenching, conditioning and electrostatic precipitation before venting it to atmosphere. The bypass dust collected is returned to the process.

H.1.4 Finished Products

There are ten cement storage silos at the site. Two of the silos are used for the storage and direct dispatch of bulk cement by road. Each of these silos has two truck loading bays. Six of the silos are used for buffer storage, to supply the four bulk truck loading bays, supply of cement to the packing plant, transfer of cement to the rail silo and for storage of special cements. The rail silo is dedicated to the storage and

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dispatch of bulk cement by rail, with a dedicated weighbridge. The final silo is allocated for the storage of slag binder, with a dedicated weighbridge.

Finished products are transported onsite by air-slides, screw conveyors, conveyor belts or enclosed air transport pipes to storage silos where they are pumped to bulk dispatch areas or to the packaging plant and mechanically bagged and packed by an automatic bagger, packer and palletiser. These packed products are transported by forklift and dispatched on trucks.

H.1.5 Bunding

There are 8 bunded areas and one double-skinned arrangement at the ICL Platin site. The location, capacity and materials stored in each area are shown in Table H.4.

Table H.4 Bunding Arrangements at ICL Platin

Substance

Maximum Tank Capacity (litres) Tank Location Tank Material Containment

Taxed diesel 113,500 Opposite garage Steel Concrete bund

Untaxed Diesel

Quarry untaxed diesel 113,500 Top of quarry Steel Concrete bund

Production untaxed diesel 114,300 Beside Raw

Mill 1 building Steel Concrete bund

Untaxed Diesel and Grinding Aid

Diesel tanks 59,010 Under old Kiln 2 platform Steel Concrete bund

CEM I Grinding aid tanks

2 x 30,000 (60,000)

Above old Kiln 2 platform

Orthophthalic GRP Concrete bund

CEM II Grinding aid tanks

2x 30,000 (60,000)

Adjacent to grate cooler DB room

Orthophthalic GRP Concrete bund

Central heating oil 6,000 East of

limestone store Steel Double skinned

Ammonia water (<25%)

2 x 120,000 (240,000)

Beside Raw Mill 1 building Stainless Steel Concrete bund

A new bund was constructed in 2006 for the CEM II grinding aid tanks. A bund integrity test was carried out in September 2006. The new bund was found to be watertight. Bund integrity testing was carried out on all bunds in August/September 2005. The new ammonia water tank bund was tested in January 2007. All bunds were demonstrated to be watertight.

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H.2. Waste Handling

H.2.1 Waste Handling at ICL Platin

Details of waste recovery/disposal are provided in Tables H.1(i) and H.1(ii). Waste generated at the ICL Platin can be categorised into:

• Non-hazardous waste which includes municipal waste, non-hazardous industrial waste and other wastes

• Hazardous waste as defined in the EC Directive 91/689/EEC.

Segregation of waste occurs where practicable and resultant waste streams are either recovered or disposed of internally or externally, following strict waste management guidelines set out by the Environmental Protection Agency (EPA). The quantities of waste disposed of on and off site are reported to the EPA in the AER.

Non-Hazardous Waste

Details of the non-hazardous waste storage areas at ICL Platin are provided in Table H.5.

Table H.5 Storage of Non- Hazardous Waste at ICL Platin Site

EWC Code Waste Description Storage Location

17 01 07 Dust and Stone

Excess Limestone /

Shale and Process Dust

Designated Collection Point at West of Raw Mill 2

17 02 01 Timber Timber Pallets Designated Timber Skip in On-Site Recycling Centre

17 04 07 Metal Waste Metal Material

Central Waste Metal Skip Area

15 01 03 Cardboard Waste

Cardboard Packaging

Baled and Stored in Designated Area in Stores

15 01 01 Paper Waste Paper Baled and Stored in Designated Area in Stores

16 01 03 Rubber Used Tyres Designated Storage Area in Garage

17 02 03 Plastic Waste Plastic Designated Areas in the Stores and Packing Plant

20 01 08 General and Canteen Waste

Office and Canteen Waste

Portable General Waste Compactor

19 11 06 Sewage Sludge Domestic sewage

Domestic sewage treatment tank

17 01 07 Construction

and Demolition Waste

Civil Construction

Waste

Designated Area at Project Site

Dust and stone materials are gathered using mechanical mobile plant or stored in red skips located around the site. These are transported by forklift to a designated collection point on the West side of Raw Mill 2 where the material is emptied and

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stored until it is loaded mechanically by a loading shovel and transported to the quarry for re-use in the process.

Timber packaging associated with the supply of paper sacks is returned to the supplier for reuse. Clients return pallets for reuse to the site. Damaged pallets are returned to the supplier for repair. Waste timber and non-repairable pallets are transported by forklift to the site’s Waste Recycling Centre. These are stored in a Timber skip and removed from site by a licensed waste haulier to a licensed waste contractor.

Metal waste material on- site is gathered at various segregation sites around the factory in small blue bins. These are transported to the central waste metal skip area by forklift where they are mechanically loaded into low-sided skips. These are removed from site for recycling by a licensed waste haulier to a licensed waste contractor.

Cardboard and paper is gathered and baled in a designated area in the stores. The bales are stored onsite and removed from site by a licensed waste haulier to a licensed waste contractor.

Plastic is collected in a designated area of the Stores and the Packing Plant. The plastic is removed from site by a licensed waste haulier to a licensed waste contractor.

Used tyres are stored in the tyre storage area at the Garage and removed from site for recycling by a licensed waste haulier to a licensed waste contractor.

General and canteen waste is gathered from the offices and canteens around the site in designated purple bins. The office general bins are emptied into these purple bins, which are then transported by forklift to the portable general waste compacter where they are mechanically emptied. The compactor is serviced when full and removed from site for recycling by a licensed waste haulier to a licensed waste contractor.

Dry Mixed Recyclables include paper, cardboard, clear plastic, tin cans, tetra packs and plastic bottles and so will replace some of the segregation described above. It is planned to collect Dry mixed recyclables in green bins at various segregation centres. These will then be transported by forklift to a static recycling compactor where they are mechanically emptied. The compactor is serviced when full and removed from site for recycling by a licensed waste haulier to a licensed waste contractor.

Waste Control Measures

Some of the established measures for waste control and minimisation at ICL Platin are as follows:

• Off-specification and intermediate and final product materials are recycled/blended in accordance with procedures specified in the Quality Management System.

• Collected spillages sweepings are recycled with the raw materials or directly into the process steam.

• Overburden removed prior to quarrying limestone and which cannot be used in the process is placed in an overburden mound together with small quantities of process wastes which cannot be recycled. The location of the overburden mound is shown in Figure H.2.

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All wastes described above are transferred in accordance with local and European waste legislation. The waste permit numbers of the collection contractor and the licence or permit number for the ultimate destination is provided to the Agency in the AER.

Hazardous Waste

Details of the hazardous waste storage areas at ICL Platin are provided in Table H.6

Table H.6 Hazardous Waste Storage at ICL Platin

EWC Code Waste Description Storage Location

13 02 08* Waste Fuel Oils Waste Vehicle and Kiln Fuel

Tanks/Drums on Waste Oil Storage Area

16 06 01* Batteries Waste Vehicle Batteries and

Small Batteries

Designated Bunded Areas in Garage / Stores Area

20 01 35* Electronics Waste Electronic Equipment Cages in Stores Area

20 01 21* Fluorescent Tubes / Lamps

Waste Fluorescent

Tubes and Lamps

Designated Storage Bins in Stores Area

13 08 99* Grease Waste Grease Water Bunded Pallets

16 01 99* Chemicals Laboratory Waste Bunded Containers

17 06 01* / 17 06 05*

Fibre Cement Cladding

Containing Asbestos

Asbestos cement sheeting or

asbestos insulation board wrapped in UN

approved packaging

Overburden mound (ICL Platin intend to have asbestos removed by

licensed waste contractor in future)

Waste fuel oils are collected and stored in UN double skinned approved tanks/drums in the oil collection point in the Waste Oil storage area. These are removed from site for recycling by a licensed haulier and are refined and recovered where appropriate by a licensed waste contractor.

Waste vehicle batteries are stored in a designated bunded container in the Garage area. Small batteries are collected and stored in an allocated bunded battery bin in the Stores area. Electronic equipment and waste fluorescent tubes and lamps are also collected and stored in allocated cages and bins in the Stores Area. All of these materials are removed from site for recycling by a licensed haulier and are recovered by a licensed waste contractor.

Grease is collected in barrels and stored on bunded pallets. Laboratory chemicals are stored in a suitable bunded container. These are removed from the site by a licensed waste haulier.

All wastes described above are transferred in accordance with local and European waste legislation. The waste permit numbers of the collection contractor and the

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licence or permit number for the ultimate destination is provided to the Agency in the AER.

H.2.2 Waste Licence / Permit Details

The waste collection permit details for current contractors at the ICL Platin site are presented in Table H.7. Waste collection permits are reviewed every 2 years in accordance with EPA requirements. Waste license details and relevant expiry dates for each facility is provided in Table H.8.

Table H.7 Waste Collection Permit Details

Contractor Address Permit Number

Greenstar Ltd. Unit 6 Ballyogan Business Park, Sandyford, Dublin 18 MH / 2005 /63B

Nurendale Ltd., T/A Panda waste

Rathdrainagh, Beauparc, Co Meath. MH / 2001 / 01C

Returnbatt Ltd. Old Mill Industrial estate, Kill, Co. Kildare MH / 2001 / 61C

Irish Lamp Recycling Ltd. Blackpark, Athy, Co. Kildare MH / 2001 / 101C Crumb Rubber Ireland Ltd. Dundalk, Co. Louth MH / 2003 / 03C R&M Willich Industrial Services Ltd. 15 Crag Terrace, Dublin 22 MH / 2004 / 25C

South Coast Transport Ltd./ Safeway Warehousing Ltd. Corrin, Fermoy, Co. Cork. MH / 2001 / 10C

Johnston Logistics Ltd. Rathcoole, Co. Dublin. MH / 2001 / 58C Cara Environmental Technology Ltd.

Parkview House, Clonskeagh, Dublin 4 MH / 2001 / 82B

Height for Hire(Environmental) Ltd.

Killineer, Drogheda, Co. Louth. MH / 2005 / 44B

A1 Metal Recycling Ltd. Acragar, Mountmellick, Co.Laois MH / 2001 / 62C

York Civil Engineering Ltd. Unit 7A, East Coast Business Park, Drogheda, Co. Louth MH / 2005 / 80B

Pat Fallon T/A Pat Fallon Construction Ltd.

Unit 3, Newgrange Business Park, Drogheda, Co. Louth MH / 2003 / 63C

The Hammond Lane Metal Company Ltd. Pigeon House Rd., Dublin 4 MH / 2004 / 83B

Doherty Quarries and Waste Management Ltd. T/A Jumbo Bins

Cruicetown, Stackhallen, Slane, Co. Meath MH / 2006 / 48B

McKenna Waste Paper Recycling Company Ltd.

Drogheda Rd., Duleek, Co. Meath MH / 2006 / 48B

Patrick Tinnelly T/A John Tinnelly & Sons Ltd.

Newtowncloughogue, Newry, Co. Down MH / 2001 / 21C

Atlas Environmental Ireland Ltd.T/A Atlas Ireland, Envirotech, ENVA and Shannon Environmental Services.

Clominam Industrial Estate, Portloaise, Co. Laois MH / 2001 / 107C

M.McGuire Haulage Ltd. Abenure, Callan, Co. Kilkenny MH / 2004 / 43B Keegan Oils Ltd. T/A Allied Toberona, Castletown, MH / 2006 / 09B

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Contractor Address Permit Number Tank and Drain Cleaning. Dundalk, Co. Louth Rialta T/A SITA Environmental Ltd.

Block 402, Greenogue Business Park, Rathcoole, Co.Dublin. MH / 2006 / 32B

Safety Kleen Ireland Ltd. Unit 5, Airton Rd, Tallaght, Dublin 24 MH / 2001 / 94C

All Away waste T/A Laraugh Plant Limited

84E Pigeon House Road, Ringsend, Dublin 4 CPD 2482

Table H.8 Waste Permit Details

Contractor Address Licence Number Expiry Date

Greenstar Ltd. Bray Depot, Co. Wicklow W0053-03 Not Applicable

Greenstar Ltd Knockharley Landfill, Navan, Co. Meath W146-01 Not Applicable

Greenstar Ltd. Millennium Business Park, Grange, D11 W183-01 Not Applicable

KTK Landfill Limited Kilcullen, Co. Kildare W081-03 February 2008

Nurendale Ltd., T/A Panda waste

Rathdrainagh, Beauparc, Co. Meath W0140-03 Not Applicable

Returnbatt Ltd. Kildare Enterprise Centre, Co. Kildare 97/2002 Not Applicable

Irish Lamp Recycling Ltd.

Blackpark, Athy, Co. Kildare 02/2000B Not Applicable

Crumb Rubber Ireland Ltd.

Mooretown, Dundalk, Co. Louth WP 2005/20 Jan 2009

Sorundon Ltd. T/A Environmental Services Ltd

520 Beech Rd. Western Industrial Estate, Dublin 12

WP0040-01 Not Applicable

AVR, Safeway Warehousing Ltd.

Corrin, Fermoy, Co Cork W0050-02 Not Applicable

Height for Hire Ltd. Drogheda, Co. Louth WP2003/14 Not Applicable A1 Metal Recycling Ltd.

Mountmellick, Co. Laois ATF WMP 007D January 2010

Roadstone Provinces Limited

C/O TES Consulting Engineer, Blanchardstown, D15

WMP 2004/42 January 2008

Clearway Disposals Ltd T/A The Hammond Lane Metal Company

Pigeon House Rd., Dublin 4 WP 98107 October 2009

Doherty Quarries and Waste Management Ltd.T/A Jumbo Bins

Cruicetown, Stackkallen, Slane, Co. Meath

WMP 2001/34 Not Applicable

Patrick Tinnelly T/A John Tinnelly &

Newtowncloughogue, Newry, Co. Down

exempt cert. WMEX 22/01 July 2008

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Contractor Address Licence Number Expiry Date Sons

Enva Ireland Ltd. Clominam Industrial estate, Portloaise, Co. Laois

W0184-1 Not Applicable

Rialta T/A SITA Environmental Ltd.

Greenogue Business Park, Rathcoole, Co. Dublin.

W0192-01 Under Review

Safety Kleen Ireland Ltd.

Unit 5, Airton Rd, Tallaght, Dublin 24. W099-01 Not Applicable

All Away waste T/A Laraugh Plant Limited

84E Pigeon House Road, Ringsend, Dublin 5

WP 98058 July 2008

H.3. Waste Disposal by On-Site Landfilling

H.3.1 ICL Platin On-Site Landfill

Permitted non-hazardous wastes are disposed of on-site in the IPC licensed overburden mound/on-site landfill (refer to Figure H.1).

The main component of the landfill is overburden. This is essentially being repositioned and is consistent with the soils at the disposal site. Small quantities of other non-hazardous factory process materials such as waste rock, limestone, shale, raw meal and clinker are also deposited in the mound in accordance with the IPC Licence.

Fibre cement cladding containing asbestos has in recent years been landfilled in a specific location in the overburden mound. ICL Platin intends to remove this material for disposal off site in a licensed waste facility.

In general, the total material deposited on the mound has a very low organic content and is almost entirely inert (refer to Table H.9).

Table H.9 Total Quantities of Waste Disposed of in Overburden Mound 2006

EWC Code Material Tonnes

01 04 08 & 01 04 09 Limestone/Overburden 60,450

17 08 02 Clay/Gypsum 600

10 13 99 Filter Bags 0.45

The overburden mound would remain intact upon closure of the facility. Reinstatement of the mound is ongoing through hydro-seeding and tree planting in accordance with the principles described in the 1994 Environmental Impact Statement for the extension of the mound and the quarry. Upon closure of the facility, the mound would be fully reinstated through spreading of topsoil, fertilisation, seeding, planting and regrading as necessary in accordance with a methodology to be agreed with the Agency.

Groundwater monitoring is currently conducted bi-annually at ICL Platin in accordance with the provisions of the IPC Licence. Continued monitoring of

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groundwater would be carried out during the decommissioning phase of the development. If contamination was recorded, site remediation works would be carried out in accordance with a methodology agreed with the Agency. Due to the nature of the activities outlined above, contamination is unlikely. As the mound is comprised predominantly of inert material, no gas or leachate management is required.

A conditioning plan for the overburden mound was completed in 2002 and forwarded to the agency. A copy is included in this Attachment.

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IPPC Licence Application Tables

H.1(i)

H.1(ii)

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TABLE H.1(i): WASTE - Hazardous Waste Recovery/Disposal

Waste material EWC Code Main source1 Quantity

On-site Recovery /Disposal

Off-site Recovery, reuse or recycling

Off-site Disposal

Tonnes / month (2006)

m3 / month

(Method & Location )

(Method, Location & Undertaker)

(Method, Location &

Undertaker) Waste Oil Filters

16 01 07* Garage / Workshop

0.125 Not applicable

R9 Used oil re-refining or other reuses of previously used oil. Atlas Oil, Portlaoise, Co. Laois.

Not applicable

Waste Oil 13 02 08* Garage / Workshop

1.16 Not applicable

R9 Used oil re-refining or other reuses of previously used oil. Atlas Oil, Portlaoise, Co. Laois.

Not applicable

Waste Oil / Grease Water


2.51 Not applicable

R9 Used oil re-refining or other reuses of previously used oil. Recyfuel S.A., Engis, Belgium.

Not applicable

Waste Heavy Fuel Oil


1.125

Not applicable

R9 Used oil re-refining or other reuses of previously used oil. Recyfuel S.A., Engis, Belgium

Not applicable

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Off-site Disposal


m3 / month



(Method, Location &

Undertaker) and ATM, Moerdikk, Netherlands.

Waste Kerosene Degreaser

11 01 13* Garage / workshop

0.04 Not applicable

R9 Used oil re-refining or other reuses of previously used oil. Used Oil to ENVA, Portlaoise, Co. Laois.

Not applicable

Other Electronic Waste

20 01 35* Offices/ Engineering

0.04 Not applicable

R5 Recycling/reclamation of other inorganic materials. Glass (Shot Glass Germany), PCB (Techmatic, Co. Dublin) and Metal (Midland Scrap Metal, Co. Laois).

Not applicable

Monitors 21 01 35* Offices 0.02 Not applicable

R5 Recycling/reclamation of other inorganic

Not applicable

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Off-site Disposal


m3 / month



(Method, Location &

Undertaker) materials. Glass (Shot Glass Germany), PCB (Techmatic, Co. Dublin) and Metal (Midland Scrap Metal, Co. Laois).

Fluorescent Tubes


0.03 Not applicable

R5 Recycling/reclamation of other inorganic materials. Mercury component (Claushuis Metaals, Holland), Glass (Shott Glass, Germany), End caps (Midland scrap metal, Co. Laois).

Not applicable

Lead/Acid Batteries


0.05 Not applicable

R5 Recycling/reclamation of other inorganic materials. HJ Enthoven and Sons

Not applicable

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Off-site Disposal


m3 / month



(Method, Location &

Undertaker) Ltd, Derbyshire, UK.

Primary Batteries

16 06 03*/4 Offices/ Engineering

0.02 Not applicable

R5 Recycling/reclamation of other inorganic materials. Accurec GmBH, Mulheim, Germany.

Not applicable

Waste chemicals

16 01 99 Laboratories 0.2 Not applicable

R5 Recycling/reclamation of other inorganic materials. AVR Safeway, Fermoy, Co. Cork

Not applicable

1 A reference should be made to the main activity / process for each waste.

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TABLE H.1(ii) WASTE - Other Waste Recovery/Disposal


On-site recovery/disposal2


Off-site Disposal

Tonnes / month

m3 / month

(Method & Location)

(Method, Location &

Undertaker)

(Method, Location &

Undertaker) Biodegradable Kitchen and Canteen Waste

20 01 08 Kitchen / Canteen

10.9 Not applicable Not applicable D1 Deposit on, in or under land. Knockharley Landfill, Co. Meath

Paper (packaging)

15 01 01 Packaging 2.2 Not applicable Not applicable D1 Deposit on, in or under land. Knockharley Landfill, Co. Meath

Wood (packaging)


Plastic (packaging)


Wood (C&D) 17 02 01 Pallets 6.1 Not applicable Not applicable D1 Deposit on, in or under land. Knockharley Landfill, Co. Meath

Plastic (C&D) 17 02 03 Packaging 4.07 Not applicable Not applicable D1 Deposit on, in or under land.

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Off-site Disposal

Tonnes / month

m3 / month

(Method & Location)

(Method, Location &

Undertaker)

(Method, Location &

Undertaker) Knockharley Landfill, Co. Meath

C&D Mixed Waste

17 01 07 Construction / Demolition Activities

136.95 Not applicable R3 Recycling / reclamation of organic substances which are not used as solvents. Concrete/clay to Roadstone Provinces, Mullachrone and metal to Munster Metals.

Not applicable

Construction Wood

17 02 01 Construction / Demolition Activities

5.28 Not applicable R3 Recycling / reclamation of organic substances which are not used as solvents. Greenstar Ltd, Millenium Park, Co Dublin

D1 Deposit on, in or under land. KTK Landfill. D1 Deposit on, in or under land. Knockharley Landfill, Co Meath

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Off-site Disposal

Tonnes / month

m3 / month

(Method & Location)

(Method, Location &

Undertaker)

(Method, Location &

Undertaker)

Scrap Metal 17 04 07 Facilities Maintenance

74.8 Not applicable R4 Recycling / reclamation of metals and metal compounds. Greenstar Ltd, Millenium Park, Co Dublin

Not applicable

Used Tyres 16 01 03 Maintenance Garage

1.45 Not applicable R5 Recycling / reclamation of other inorganic materials. Crumb Rubber Ireland, Dundalk, Co. Louth.

Not applicable

Paper and Cardboard Packaging

15 01 01 Packaging 0.55 Not applicable R5 Recycling / reclamation of other inorganic materials. Greenstar Limited, Millenium Park, Co. Dublin

Not applicable

Plastic Packaging

15 01 02 Packaging 0.22 Not applicable R5 Recycling / reclamation of

Not applicable

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Off-site Disposal

Tonnes / month

m3 / month

(Method & Location)

(Method, Location &

Undertaker)

(Method, Location &

Undertaker) other inorganic materials. Greenstar Limited. Millenium Park, Co. Dublin

Dewatered Sludge

02 03 04 Sanitary Wastewater Treatment

system

4.25 Not applicable D8 Biological treatment not specified elsewhere in this Annex which results in final compounds or mixtures which are discarded by means of any of the operations numbered D1- D12. Ringsend WWTP, Dublin.

Not applicable

1 A reference should be made to the main activity/ process for each waste.

2 The method of disposal or recovery should be clearly described and referenced to Attachment H.1

3 There was a once off removal of contaminated soil from site during 2006. This was related to on-site projects and was reported in the AER.

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4 There was a once off removal during 2006 of scrap copper and lead. This was related to on-site projects and was reported in the AER.

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2

3

9

1

1

6

4

1

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17

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1

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11

101

1

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Waste Materials Storage Locations

Irish Cement Ltd Platin IPPC Licence Application

D5374.10 August 2007 Figure H.1

Legend

1 Departmental segregation areas2 Waste tyre storage3 Bunded waste oils & grease4 Waste lead acid batteries5 Waste flouresant tubes storage coffin6 Bunded primary batteries storage7 Cardboard baler8 Large skip area9 General waste compactor10 dry mixed recycables compactor11 Waste dust & stone storage area12 Large skip area

0 metres 400

Scale 1:10,000

Not To Scale

0 kilometres 8

Scale 1:200,000

0 metres 100

Scale 1:2,500

Ordnance Survey Ireland Licence NumberEN 0002807 c Government of Ireland

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Quarry

Cement Factory

Overburden Mound

Location of Overburden Mound (On-site Landfill)


D5374.10 August 2007 Figure H.2

0 metres 400

Scale 1:10,000

Not To Scale

0 kilometres 8

Scale 1:200,000

0 metres 200

Scale 1:5,000


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Landfill Conditioning Plan

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Irish Cement Ltd Platin Works IPPC Licence Application Attachment No. I

I - 1 of 26

ATTACHMENT No. I

EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY

TABLE OF CONTENTS

I.1. Assessment of Atmospheric Emissions ............................................................ 2

I.2. Assessment of Impact on Receiving Surface Water ....................................... 5

I.3. Assessment of Impact of Discharge to Sewer.................................................. 6

I.4. Assessment of Impact of Ground/Groundwater Emissions ......................... 6

I.5. Ground and/or Groundwater Contamination ................................................. 6

I.6. Assessment of the Environmental Impact of On-site Waste Recovery and/or Disposal...................................................................................................... 6

I.7. Noise Impact .......................................................................................................... 8

I.8. Environmental Considerations and BAT ....................................................... 12

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I.1. Assessment of Atmospheric Emissions

Air dispersion modelling of emissions from the Works of oxides of nitrogen (NOX) and particulate matter has been undertaken. The results indicate that the emissions have no significant environmental effect and will not result in any breach of the existing and proposed statutory Air Quality Standards. The Air Dispersion Modelling Report is provided in this Attachment.

Irish Cement Ltd Platin’s (ICL Platin) rationale for proposed IPPC Licence emission limit values (ELVs) for the Works is described below.

Nitrogen Oxides (NOX) As can be seen from the attached air dispersion modelling report, running at a NOX concentration of 1,800 mg/Nm3 for Kiln 1, 1,000 mg/Nm3 for Kiln 2 and 1,300 mg/Nm3 for Kiln 3 and at maximum flow rates, the relevant air quality standards are complied with. The maximum daily averages and maximum half hourly averages for Kiln 1 and Kiln 2 for each month in 2006 are shown in the attached statistics. Future NOX Abatement Strategy The 2006/07 Environmental Management Plan (EMP) for the facility, submitted to the Agency as part of the 2005 and 2006 Annual Environmental Report (AER), committed to installation of selective non-catalytic reduction (SNCR) for Kiln 2. The operational characteristic of a SNCR Plant is that the Process NOX level can be controlled by injection of Ammonia Water into the process, which reduces NOX to N2. This is in the process of being commissioned and is expected to be operational by the time the licence application has been reviewed by the Agency. Kiln 1 cannot be adapted to SNCR technology. However, Kiln 3 will replace Kiln 1 in late 2008, where Kiln 3 will have both a low NOX precalciner and SNCR technology (if required). BAT NOX ELV The Agency’s Draft Best Available Techniques (BAT) Guidance Note currently stipulates BAT levels for SNCR installations as 200-500mg/Nm3. This is not accepted by the European Cement Industry and does not take into account the position outlined in the EC BAT Reference (BREF) Document for cement manufacture that there is an alternative view that BAT levels for SNCR installations are 500-800mg/Nm3. ICL is of the view, based on an assessment by VDZ (Research Institute of the German Cement Industry) that it will be possible to reduce daily average NOX levels to below 800mg/Nm3 @10% O2 following commissioning of the SNCR system on Kiln 2. ICL does not believe it is possible to give any further commitment until after commissioning has taken place and for the potential for unacceptable ammonia emissions due to ammonia slip has been fully evaluated.

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Daily Average ELV It will be possible to reduce daily NOX levels to below 800mg/Nm3 @10% O2. ICL Platin requests that the Agency accepts operating levels during the commissioning phase operation of 1,000 mg/Nm3 @ 10% O2 on Kiln 2 and 1300 mg/Nm3 @ 10% O2 on Kiln 3. ICL Platin believes that a period of at least 6 months will be required for commissioning of the SNCR system on Kiln 2 and 1 year on Kiln 3. When commissioning is finalised it is expected that it will be possible to reduce 95% of daily average NOX levels on Kiln 2 and Kiln 3 to below 800mg/Nm3 @ 10% O2

during steady state conditions. Steady state conditions do not include start-ups and shut downs. Half Hourly Average ELV In the past, the Agency has required compliance to a half hourly ELV, which was twice the daily ELV. In this licence application, it is suggested that a half hourly ELV should not be applied. The justification for not applying a half hourly ELV is based on ICL Platin’s commitment to investing in BAT SNCR technologies which will achieve a daily NOX concentration of <800mg/Nm3 @ 10% O2 during steady state conditions. ICL Platin is committed to achieving these daily NOX concentrations even during days when routine maintenance of the SNCR system is required. It is proposed to achieve this by temporarily increasing the level of ammonia water injection following maintenance, such that the daily NOX concentration is maintained at less than 800mg/Nm3 @ 10% O2. It should be noted that it will be necessary to carry out maintenance of the SNCR system during kiln operation. Shutting down the kiln and any subsequent start-ups could result in unsteady state conditions and ultimately higher daily NOX concentrations than would result from carrying out SNCR maintenance during kiln operation. Conclusion It is therefore proposed that NOX levels be controlled on the basis of a daily ELV. It is proposed that half hourly ELVs are not applied. If the Agency requires half hourly limits for NOX then they must be applied on a statistical basis. Because of maintenance interruptions to the SNCR system, we would suggest that 90% of half hourly values comply with a limit of twice the daily ELV during steady state conditions to be applied, subject to meeting the daily average. Steady state conditions do not include start-ups and shut downs.

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Particulates As can be seen from the attached air dispersion modelling report, running at particulate concentrations of 50 mg/Nm3 for Kiln 1, Kiln 2, Coal Mill 2, Cement Mill 2, Cement Mill 3, 75 mg/Nm3 for Cement Mill 1, 100 mg/Nm3 for Kiln 2 Grate Cooler, and future emissions of 30 mg/Nm3 for Kiln 3, Kiln 3 Grate Cooler and Cement Mill 4 at maximum flow rates the relevant air quality standards are complied with. Particulate Abatement Strategy The 2006/07 Environmental Management Plan (EMP) for the facility, submitted to the Agency as part of the 2005 and 2006 Annual Environmental Report (AER), committed to installing an extension of Kiln 2 Electrostatic Precipitator which was completed in April 2007, achieving BAT on this filter. Coal Mill 2 filter was completely replaced with a Bag Filter in April 2007, achieving BAT on this filter. In addition, to reduce the number of emission points on-site Raw Mill 1 and Coal Mill 1 are currently being ducted to Kiln 1 emission point. In 2004, a new Cooling Tower was installed on Kiln 1 Electrostatic Precipitator, achieving BAT on this filter. In late 2008, it is planned to replace Kiln 1 with Kiln 3, which will have BAT abatement systems - a Bag Filter on Kiln 3, an Electrostatic Precipitator on Kiln 3 Grate Cooler and a Bag Filter on Cement Mill 4. Daily Average ELV Following recent BAT investment in the existing plant, it is known that lower daily average emissions can be achieved during steady state conditions. i.e. concentrations of 50 mg/Nm3 for Kiln 1, Kiln 2, Coal Mill 2, Cement Mill 2, Cement Mill 3, 75 mg/Nm3 for Cement Mill 1 and 100 mg/Nm3 for Kiln 2 Grate Cooler. It is expected that future plant investments will achieve lower daily average concentrations during steady state conditions i.e. concentrations of 30 mg/Nm3 for Kiln 3, Kiln 3 Grate Cooler and Cement Mill 4. Therefore it is expected that it will be possible to achieve 95% of the daily averages particulate levels during steady state conditions within the ELVs set out above. Steady state conditions do not include start-ups, shut downs or filter safety trip-outs. Half Hourly Average ELV In the past, the Agency has required compliance to a half hourly ELV, which was twice the daily ELV. In this licence application, it is suggested that a half hourly ELV should not be applied. The justification for not applying a half hourly ELV is based on ICL Platin’s commitment to investing in BAT technologies and so achieving lower daily average particulates concentrations during steady state conditions and even during short-term interruptions with the filter. The characteristic of a filter is such that daily particulate ELVs are achievable, however half hourly particulate concentrations can more frequently exceed a half hourly ELV that is twice the daily ELV. This is due to a wide distribution of high and low half hourly values around the mean. Reasons for short-term fluctuations in the performance of a filter relate to the large number of factors that can influence the

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I - 5 of 26

filter performance, including gas flows, gas temperatures, gas moisture, dust particle resistivity and mechanical and electrical equipment on the filter. Conclusion Therefore it is proposed that particulate levels be controlled on the basis of daily ELV. It is proposed that half hourly particulate ELVs not be applied. If the Agency requires half hourly particulate ELVs, then they must be applied on a statistical basis. Because of the operating characteristics of the filter, it is suggested that during steady state conditions that 90% of half hourly values comply with a limit of twice the daily ELV during steady state conditions, subject to meeting the daily average. Steady state conditions do not include start-ups, shut downs or filter safety trip-outs. Sulphur Oxides (SOX)

The Draft EPA BAT Guidance Note outlines the following ELVs for sulphur dioxide (SO2) of 200-400 mg/Nm3 for new facilities and 200-750 mg/Nm3 for existing facilities. Emissions from the kilns at Platin will meet the proposed BAT requirements as the kilns act as an efficient scrubber of SOX.

I.1.1 Greenhouse Gas Emissions

ICL Platin is subject to S.I. No. 437 of 2004, the European Communities (Greenhouse Gas Trading) Regulations 2004 (refer also to Attachment No. L). As such, a statutory limit is set on carbon dioxide emissions (CO2) from the Works. In line with government requirements, Irish Cement Ltd Platin (ICL Platin) is currently moving to the production of CEM II cements whereby limestone is used together with clinker as one of the main constituents of cement. This leads to a reduction in specific CO2 emissions per tonne of cement produced. CEM II cements based on clinker and PFA are also under consideration.

I.2. Assessment of Impact on Receiving Surface Water

The surface water quality monitoring results are presented in Table I.2(i).

An ecological and sediment study of the River Nanny was conducted by Ecofact Environmental Consultants on behalf of ICL Platin in November 2006. This study focussed on 3 sites upstream (control) and 3 sites downstream (receptor) of the ICL Platin combined treated wastewater, surface and process water and groundwater outfall (IPC licensed emission point W4). Results of the assessment showed that the macroinvertebrate communities, biological water quality and sediment levels in the River Nanny are the same upstream and downstream of the ICL Platin Combined Treated Discharge to the River Nanny. Thus, the discharge from the ICL Platin facility is not having any significant environmental impact on the biological water quality of the downstream areas surveyed (refer to “An Ecological and Sediment Study of the River Nanny near Duleek, Co. Meath” provided in this Attachment).

In addition, ICL Platin is also compliant with the emission limit values for IPC licensed emission point W4, as specified by the Agency and specified in their IPC

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Licence (Reg. No. P0030-02). ICL Platin provides reports of analyses conducted at W4 (discharge to surface water) to the Agency in the AER. Further details on emissions to surface water are provided in Attachment No. E.

The environmental impact of emissions to surface waters associated with ICL Platin’s activities is not significant.

I.3. Assessment of Impact of Discharge to Sewer

This section is not applicable to the activity. There are no emissions to sewer from the ICL Platin site.

I.4. Assessment of Impact of Ground/Groundwater Emissions

This section is not applicable to the activity. There are no emissions to ground or groundwater at the ICL Platin site.

I.5. Ground and/or Groundwater Contamination

The groundwater quality monitoring results are presented in Table I.4(i).

There have been no environmental incidents at the site that have adversely affected the environment or human health or that could have a residual environmental impact.

Between October 2006 and February 2007, Mouchel Parkman were appointed by ICL Platin to implement a ground works remediation strategy at Donnelly’s Hollow, a bunded area located adjacent to the Navan/Drogheda freight railway line at the ICL Platin site. The purpose of this remediation strategy was to investigate the soil conditions around an old Heavy Fuel Oil (HFO) tank that was being demolished.

The results of the on-site Total Petroleum Hydrocarbons (TPH) screening of soil material also complied with the Remediation Target Values (RTV) level and it was considered that the site was suitable for its proposed end use. Therefore there is no significant risk to the underlying aquifer.

I.6. Assessment of the Environmental Impact of On-site Waste Recovery and/or Disposal

I.6.1 Environmental Impact of On-Site Waste Recovery/Recycling

ICL Platin annually reviews the Environmental Management Plan (EMP) to produce a series of objectives and targets. The status of these objectives and targets are outlined and sent to the Agency in the AER. An ongoing objective is the reduction and elimination of waste where possible in order to reduce the environmental impact. The targets and objectives set by ICL Platin in the 2007/08 EMP relating to waste management include,

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• Install and commission Kiln 3 in late 2008. Kiln 3 will be designed to achieve optimum energy efficiency and reduced waste generation, i.e. reduced waste kiln bricks, reduced waste kiln coating and reduced waste used oil and grease.

• Install and commission Raw Mill 3, Coal Mill 3 and Cement Mill 4, which will have optimum energy efficiency and reduced waste generation, i.e. reduced waste oil/grease and reduced electricity usage per tonne of product

• Continue to upgrade the plc control system, which leads to optimum energy efficiency and reduced waste generation throughout the factory.

• Continue to optimise kiln feed quality and so optimise kiln stability and energy efficiency in the Kiln clinker process, which would lead to a reduced possibility of making off specification clinker

• Continue to maximise overburden which was once considered a waste material and is now being used as a raw material in the process.

• Establish a Continuous Improvement Group for the Environment with representatives from each Factory department, who will focus on optimising site waste management.

• Carry out a trial with a new Waste Management Contractor, focused on improving segregation of waste, increasing recycling, awareness and training.

• Continue the ongoing training of plant personnel in waste segregation and recycling.

ICL Platin commits to reusing, recycling and recovering waste where possible to reduce the environmental impact of its activities. Reuse of materials is achieved by continually maximising the use of quarry overburden in raw meal and collection of bypass dust for use in the process. Recycling, recovery and disposal of wastes off-site is handled by licensed waste contractors and hauliers. A number of procedures for handling the waste streams and for ensuring compliance with relevant national and European legislation are also in place at ICL Platin.

Waste management at ICL Platin strives to segregate wastes to increase re-use/recycling/recovery and minimise wastes for energy recovery and landfill. The Waste management segregation system at ICL Platin ensures that the environmental impact of sending waste to landfill is minimised.

The bunding and storage arrangements for the various waste streams at ICL Platin also provide for secure containment and the prevention of spills and ensure minimal environmental impact. Further details are provided in Attachment No. H.

I.6.2 Environmental Impact of On-Site Waste Disposal

The main component of the on-site landfill is overburden. This material is essentially being repositioned and is consistent with the soils at the disposal site. Inert wastes such as limestone, shale, overburden, process materials (that cannot be recycled in the process) and filter bags are deposited in this on-site landfill.

Fibre cement cladding containing asbestos has in recent years been landfilled in a specific location in the overburden mound. ICL Platin intends to remove this material for disposal off-site in a licensed waste facility.

In general, the material deposited on the mound has a very low organic content and is almost entirely inert (refer to Table H.7). Results of groundwater monitoring

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I - 8 of 26

conducted throughout the site as required by the IPC Licence have also shown no signs of any adverse environmental impact from the on-site landfill.

I.7. Noise Impact

The main sources of noise from ICL Platin are shown in Figure I.1. The location used for the noise monitoring is shown in Figure I.2.

As the plant is a continuous process one, the noise emission is quasi steady state. Consequently the specific noise due to the plant at receptor points is best represented by the L(A90,15min) noise parameter.

Condition 10 of ICL Platin’s IPC Licence (Reg. No. P0030-02) requires that a noise survey of site operations be carried out annually. A copy of the 2006 noise survey is included in this Attachment. The maximum mean daytime and nighttime L(A90,15min) values off site (400m east of plant) for 2004, 2005 and 2006 noise surveys are presented in Table I.1.

Table I.1 Results of Off Site (Synott’s) Noise Monitoring 2004, 2005 & 2006

Year L(A90,15min) Daytime Mean dB(A)

L(A90,15min) Nighttime Mean dB(A)

2004 50 44.8 2005 52.9 45.2 2006 48.9 44

Average 50.6 44.7 Licensed Limit 57 47

The LA90 levels are in compliance with the off-site noise limits as specified in the IPC Licence (Reg. No. P0030-02). Results of on-site noise monitoring for 2004, 2005 and 2006 also complied with the limits as specified in the IPC Licence.

The results of the ambient noise assessment for the facility are not presented in the IPPC Application Form V1/07 Table I.7(i) as the methodology stipulated in the Form was not used. The methodology used and the background rationale are described in this Attachment (refer to additional information included in this Attachment).

Results of blast monitoring for 2004, 2005 and 2006 are presented in Table I.2. For the three years, the vibration and air overpressure levels are in compliance with the Licence limits.

Table I.2 Results of ICL Blast Monitoring 2004, 2005 & 2006

Year No. of Blasts Peak Particle Velocity ( not

> 12mm/s)

No Single Blast Overpressure > 127.5 dB(lin)

95% of Blast Overpressure’s

not > 125 dB(lin)

2004 70 Complies Complies Complies 2005 70 Complies Complies Complies 2006 71 Complies Complies Complies

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As results have shown that noise and blast monitoring data complies with the limits set by the Agency, the impact of noise emissions from ICL Platin on the surrounding area is not significant.

A summary of noise and blast monitoring data is included in the Annual Environmental Reports (AERs) submitted to the Agency (refer to Attachment No. F).

ICL Platin’s IPC licence P0030-02, Condition 8, sets out conditions for noise, i.e.

1. Noise Source Power limits for individual pieces of plant machinery 2. Day and night-time off-site noise at the nearest noise sensitive location 3. Quarry blasting vibration/air overpressure at the nearest noise sensitive

location I.7.1 Noise Limits

ICL Platin’s rationale for the proposed IPPC Licence noise limits for the Works, as advised by Acoustic Consultants Eanna O’Kelly and Associates, is described below.

I.7.1.1 Noise Source Power Limits for Individual Pieces of Plant Machinery Table E.5(i) lists 19 Noise Sources for ICL Platin, including 6 Noise Sources which will be associated with Kiln 3/Cement Mill 4. The 2006 Annual Noise Survey is included in this Attachment and shows compliance with existing IPC Licence limits.

It is stated in the EPA Publication “Guidance Note For Noise In Relation to Scheduled Activities”, 2nd Edition Para at 3.4 “Setting Limits on Noise Emissions” that typically limits may be set at the boundary of industrial estates, or at the nearest noise sensitive locations for one off developments. Alternatively, noise limits may be set on individual sources of noise, taking cognisance of the target limit levels to be achieved either at the boundary, or the nearest sensitive location. It is stated categorically that this approach would normally only be considered if there were difficulties in obtaining reliable noise data at the site boundary or at noise sensitive locations. It has been demonstrated repeatedly over a number of years that there is no difficulty in obtaining reliable and consistent data at the nearest noise sensitive location and consequently, in this particular case the concept of setting noise limits on the individual sources of noise should be abandoned. In addition, it is proposed that narrowband spectrum analysis shall be carried out at the nearest noise sensitive location for the detection of tones in accordance with the procedure set out in Annex C - Objective method of assessing the audibility of tones in noise - Reference method: International Standard 1996-2 Part 2 Determination of environmental noise levels. I.7.1.2 Day and Night-time Off-site Noise at the Nearest Noise Sensitive Location

• Current IPC Licence P0030-02: o In the current IPC Licence P0030-02, Schedule 4 (ii), off-site noise

limits are set out at noise sensitive locations in the vicinity of the plant. These limits are stated as sound pressure levels of 57 dBA for daytime, 08:00 to 22:00 hours, and 47 dBA for night time, 22:00 to 08:00 hours.

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In Condition 3.4.2 it is stated that sound pressure levels measured at the nearest noise sensitive locations should not exceed the specified sound pressure limit value by more than 2 dBA. This effectively sets the noise limits at noise sensitive locations at 57 +/- 2 dBA for daytime and 47 +/-2 dBA for night time.

o The methodology used in assessing compliance with the noise limits

at noise sensitive locations is to monitor continuously the noise levels over seven consecutive 24-hour intervals at the nearest Noise sensitive location. As the noise emission from the plant is quasi steady state, the noise parameter best used to assess the noise emission from the plant is the mean night time value of the L (A90,15min) level. This is the fairly steady background noise level due to the plant.

o During the Years 1996 to 1999, the noise sensitive location selected

was Mr Curran's house. This residence is situated north west of the plant, at a distance of 220 metres from the boundary of the plant and at a distance of 440 metres from the acoustic centre of the plant. There is a grain drying plant located behind Curran's house, which is owned by Mr Curran. It is a significant source of noise particularly during and after harvest time. It also operates at other times during the year. On a number of occasions it was found to be unsuitable due to the presence of noise from the grain drying plant. Monitoring at this location was discontinued after 1999.

During the years 2000 to the current year, noise monitoring was carried out at the next nearest noise senssitive location, which is Synnott’s house, located to the east of the plant at a distance of 320 metres from the plant boundary and 600 metres from the acoustic centre of the plant. There is no fixed mechanical plant, which might give rise to noise in the vicinity of this house. During the year 2000, at the request of the EPA, unattended noise monitoring was also carried out at two other houses. These were McKenna’s and McGuinness’s which are situated to the south of the plant on the R152 regional road and a distance of 700 metres and 850 metres respectively from the acoustic centre of the plant. Noise due to road traffic dominates at both locations, particularly at McKenna’s where the front facade of the house is located 3 metres from the edge of the carriageway, and to a lesser extent at McGuinness’s where the front facade is about 35 metres from the edge of the carriageway. The results of the noise monitoring is contained in a report “Review of Annual Noise Surveys for IPC Licence Number 268 Compliance 1996 to 2002”, which is included in this Attachment.

• Future IPPC Licence:

o In the future, it is proposed to monitor exclusively at Synnotts Residence, as this is considered to be the best location for monitoring at the nearest noise sensitive location. The results show consistency and repeatability. In this location, the microphone is placed 6 metres from facade of the house facing the plant and at height of 1.5 m above ground level. The house is not located along the R152 road but on a

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minor road where the noise level due to road traffic at nighttimes is not significant.

o It is understood that the Agency may be considering the reduction of

the noise limits for daytime from 57 dBA to 55 dBA and at nighttime from 47 dBA to 45 dBA at the nearest noise sensitive location. It has been shown that the noise level at the Synnotts Residence would be very close to a night time limit of 45 dBA, see Table I.1. At ICL Platin, there are a larger number of noise sources that contribute around the same levels of broadband noise. It should be noted that to make a worthwhile reduction to noise at noise sensitive locations, it would be necessary to achieve a noise reduction at all the items of the plant involved. In these circumstances, the technical difficulties and costs may be very significant. From theoretical studies it can be shown that the decommissioning of Kiln 1 and the commissioning of Kiln 3 should not increase the overall sound power emission from the plant. However, we could conservatively predict that on the commissioning of the Kiln 3 project a marginal increase of up to 1 to 2 dBA may be expected at the nearest noise sensitive location, Synotts Residence, even allowing for the fact that the design of Kiln 3 has been based upon BAT considerations. The Kiln 3 project includes the elimination of planetary coolers, which were a major noise source, and the incorporation of modern design features, resulting in a reduction in total fan power. The imposition of a nighttime noise limit of 45 dBA at the nearest noise sense of location may therefore be difficult to achieve.

o In determining compliance with noise limits, it is essential that the

methodology employed be practical, feasible and reliable within stated statistical limits.

It is proposed that if the Agency decides to reduce the noise limits for daytime to 55dBA and at nighttime to 45dBA, that a tolerance of + 4 dBA be applied to both limits, which would be consistent with the reference to measurement uncertainty, as described in Paragraph 4, of ISO 1996-2: Acoustics – Description, measurement and assessment of environmental noise - Part 2: Determination of environmental noise levels. This tolerance considers measurement uncertainty, i.e. instrumentation, operating conditions, weather conditions, ground conditions, and residual noise conditions.

Conclusion: In conclusion, it is proposed that if the Agency decides to reduce the noise limits for daytime to 55dBA and at nighttime to 45dBA, that a tolerance of + 4 dBA be applied to both limits. The methodology to be used to show compliance should incorporate continuous noise monitoring of the LAeq,15min and the LA90,15min parameters over seven consecutive 24-hour intervals at the nearest noise sensitive location, Synnotts Residence. The data should be quality controlled using wind speed and rainfall data from the Met Station at Dublin Airport. Where

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wind speeds exceed 7 metres per second or where there is significant rainfall, the noise data should be excluded, as wind speed conditions in excess of this value give rise to extraneous wind generated noise, and rainfall may also affect the reliability of the data.

In addition, narrowband spectrum analysis should be carried out at the nearest noise sensitive location for the detection of tones in accordance with the procedure set out in Annex C - Objective method of assessing the audibility of tones in noise - Reference method: International Standard 1996-2 Part 2 Determination of environmental noise levels. It should be noted that Platin Works has no ongoing history of noise complaints.

I.7.1.3 Quarry Blasting Vibration/Air Overpressure at the Nearest Noise Sensitive Location

In blasting air over pressure is generally more difficult to control than ground transmitted vibration due to blasting. If these limits are to be reviewed, a 95% confidence limit for air overpressure should be set at 125 dB linear as at present and that no individual blast should exceed the limit by 3 dB linear, rather than 2.5 dB linear. The resolution to 0.5 dB has no real practical import or significance.

I.8. Environmental Considerations and BAT

The following documents were considered in the assessment of environmental considerations and BAT at the ICL Platin site:

Article 3 of Council Directive 96/61/EC concerning integrated pollution prevention and control

European Commission Integrated Pollution and Prevention Control Reference Document on Best Available Techniques in the Cement and Lime Manufacturing Industries 2001

Section 7 (Amendment of Section 5 of the Environmental Protection Agency Act 1992) of the Protection of the Environment Act 2003

Draft BAT Guidance Note on Best Available Techniques for the Production of Cement and for the Production of Lime in a Kiln

ICL Platin has continually invested in BAT based technologies. Recent examples include:

• installation of cooling tower on Kiln 1 system • ducting of low level emissions points on Kiln 1 system to Kiln 1 chimney • extension of Kiln 2 electrostatic precipitator • complete replacement of Coal Mill 2 electrostatic precipitator with a bag filter • installation of high efficiency separators on all cement mills • installation of SNCR technology on Kiln 2

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• development of techniques to maximise the use of overburden and so reduce the amount of quarried shale for use in the process represents BAT.

Council Directive 96/61/EC – General Obligations

Article 3 of Council Directive 96/61/EC lists the general obligations on the operator to ensure that appropriate pollution prevention and control measures are put in place. Each of these obligations and the measures taken at the ICL site to address them are listed below:

a. all the appropriate preventive measures are taken against pollution, in particular through application of the best available techniques;

All the appropriate preventative measures taken against pollution at the ICL Platin site relevant to the European Commission reference document on BAT (BREF) in the cement industry are listed in Table I.3.

Table I.3 Pollution Prevention Measures at ICL Platin and BAT for the Cement Industry

BAT1 ICL

NOX Control Kiln 3 in-line calciner is designed to deliver optimal heat economy, power consumption and NOX reduction. Kiln 2 has burner pipes designed for optimal combustion to assist NOX reduction. Kiln 3 burner pipe will also be designed for optimal combustion.

NOX emissions from Kiln 2 (and Kiln 3 if required) will be abated using selective non-catalytic reduction.

Point Emission Particulate Controls Particulate emissions from Kiln 1, Kiln 2, Cement Mill 1, Kiln 2 Grate Cooler (K3 Grate Cooler in future) are abated by electrostatic precipitator.

Bag filters on Coal Mill 2, Cement Mill 2 and 3 (Kiln 3, Kiln 3 Bypass, Coal Mill 3, Cement Mill 4 in future)

Fugitive Particulate Controls Fugitive dust is minimised by enclosing conveyors and spraying unpaved roads where possible. Dust management procedures are rigorously enforced and regularly reviewed as part of the Environmental Management Plan.

SOX Control SO2 is absorbed onto alkaline materials in Kilns 1, 2 and 3.

Waste Re-use Collected spillage sweepings are recycled with the raw materials or directly into the process steam. Kiln coating may be cleaned from the kiln during maintenance repairs and transferred to the quarry for reuse with the raw

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BAT1 ICL

materials in the production process.

By-pass and filter dusts generated are recycled in the process.

1 BAT according to the “European Commission Integrated Pollution and Prevention Control Reference Document on Best Available Techniques in the Cement and Lime Manufacturing Industries” (2001)

b. no significant pollution is caused;

ICL Platin currently operates within the limits imposed by its IPC Licence (Reg. No. P0030-02). These limits are set by the Agency in order to prevent significant pollution as a result of ICL Platin’s activities. Any exceedance of these limits is immediately investigated by ICL Platin and reported to the Agency. The results of all on-site monitoring and any exceedances of the limits are also reported in the AER.

An assessment of the impact of atmospheric emissions, surface water discharges, sewer discharge, groundwater emissions, waste and noise is provided in Sections I.1 to I.7 above.

c. waste production is avoided in accordance with Council Directive 75/442/EEC of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment;

ICL Platin follows strict waste management guidelines as set out by the Agency and in accordance with Council Directive 75/442/EEC. This waste management strategy includes:

A detailed description including the source, quantity and ultimate destination of the waste generated at the ICL site is provided in Attachment No. H. ICL Platin endeavours to recover and recycle waste where possible. Where this is not feasible, disposal of waste is conducted using licensed waste hauliers and licensed waste facilities in order to minimise any environmental impact. An assessment of the impact of on-site waste disposal is provided in Section I.6.

d. energy is used efficiently;

The ICL environmental policy requires all its facilities to optimise the use of energy and material resources. ICL Platin operates under EPA Licence Reg. No. P0030-02. The primary aim of IPC/IPPC licensing is to prevent or reduce emissions to air, water and land, to reduce waste and to use energy efficiently. ICL Platin achieve this by using the most advanced, energy-efficient methods to create a range of high quality cements as well as operating under an established Environmental Management System (EMS). ICL Platin's EMS is to international standard ISO14001, which strives to achieve continuous improvement in many environmental aspects, including energy use.

An Environmental Management Plan (EMP) is agreed annually and provided to the Agency in the AER. The EMP sets targets and objectives for the year ahead and aims to achieve continuous improvement of the Environmental Management System, some examples (2006) include,

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• Install and commission Kiln 3 in late 2008. Kiln 3 will be designed to achieve optimum energy efficiency in electrical power consumption and fuel consumption (heat economy optimised).

• Install and commission Raw Mill 3, Coal Mill 3 and Cement Mill 4, which will have optimum energy efficiency.

• Continue to upgrade the plc control system, which leads to optimum energy efficiency throughout the factory.

• Continue to optimise kiln feed quality and so optimise energy efficiency in the Kiln clinker process

• Continue to maximise overburden and reduce the requirements of transporting shales over longer distances, so optimising energy efficiency.

ICL Platin has also committed to entering the Sustainable Energy Ireland (SEI) Energy Agreements Programme. This programme has been developed under the new Irish Energy Management Standard, IS 393 and provides companies with a structured approach to reducing energy costs through the implementation of a schedule of energy efficient measures.

e. the necessary measures are taken to prevent accidents and limit their consequences;

A copy of ICL’s Platin Works Emergency Response Procedure (Issue No. 3) is provided in Attachment No. J. This document outlines the accident prevention and emergency response procedures in place at ICL Platin in the event of a fire, a spill of flammable or environmentally harmful material, or any other major industrial accident. Emergency response training in the following procedures is also provided to all ICL employees:

• Excavation routes

• Alarm systems

• Reporting to supervisors

• Personal protective equipment

Full details of the emergency response procedures at ICL Platin is provided in Attachment No. J.

f. the necessary measures are taken upon definitive cessation of activities to avoid any pollution risk and return the site of operation to a satisfactory state.

ICL Platin intends to operate at the Platin site for the foreseeable future. However, in the event of definitive cessation of activities at the site, ICL Platin will ensure that appropriate measures are taken to avoid any pollution risk and return the site to a satisfactory state. A copy of the Closure, Restoration and Aftercare Management Plan (CRAMP) is provided in Attachment No. K.

Protection of the Environment Act 2003 – Determination of BAT

Section 7 of the Protection of the Environment Act 2003 lists the considerations to be taken into account when determining BAT. Each of these considerations is discussed below.

(i) the use of low-waste technology,

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The cement manufacturing process at ICL Platin generates very little waste. Limestone is extracted from the quarry and used directly for the production of raw meal. The use of overburden as a raw material is maximised and unused overburden is landfilled on-site. The packaging plant operates under a highly automated control system in order to minimise potential waste. The entire operation at ICL Platin is controlled by a PLC based control system which monitors the process by a comprehensive array of analogue instruments and switches.

(ii) the use of less hazardous substances,

The hazardous materials at ICL Platin are predominantly those used in the laboratories or in the maintenance workshop. These materials are used in relatively small quantities and are stored in secured areas only. Fuels are stored in specific bunded areas as described in Attachment No. H.

(iii) the furthering of recovery and recycling of substances generated and used in the process and of waste, where appropriate,

Waste metals, paper, packaging material, batteries, fluorescent tubes and waste electrical and electronic equipment (WEEE) are all sent for recycling by ICL Platin. In addition, process material spillages, kiln coating and by-pass dust are all recovered and recycled back into the process. The ultimate destination of each of the raw materials, intermediates and finished products generated and used at ICL Platin are provided in Tables G.1 (i) and G.1 (ii).

(iv) comparable processes, facilities or methods of operation, which have been tried with success on an industrial scale,

SNCR technology is being introduced to reduce NOX emissions. Limestone cements are being introduced to reduce energy use, optimise raw material usage and reduce CO2 emissions (refer to Table I.3).

(v) technological advances and changes in scientific knowledge and understanding,

The use of Best Available Techniques according to the European Commission reference document on BAT in the cement industry are discussed in Table I.3.

(vi) the nature, effects and volume of the emissions concerned,

The main emissions from the cement manufacturing process are emissions to atmosphere from combustion gases and emissions to water from the factory and quarry. The impact of these emissions is assessed in Section I.1 and I.2 above. The volumes of these emissions are currently regulated according to the existing IPC Licence so that potential impacts on human health and the environment are minimised.

(vii) the commissioning dates for new or existing activities,

ICL intends to commission Kiln 3 in late 2008. Kiln 1 will be decommissioned prior to the commissioning of Kiln 3. Cement Mill 4 will be commissioned in summer 2008.

(viii) the length of time needed to introduce the best available techniques,

A number of best available techniques are already employed at ICL Platin (refer to Table I.1). The commissioning of the new kiln (Kiln 3) in 2008 will also employ best available techniques.

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(ix) the consumption and nature of raw materials (including water) used in the process and their energy efficiency,

The principal raw material used in the cement making process is limestone. This is extracted directly from ICL Platin’s quarry. Shale is also used to produce raw meal and is sourced from remote quarries. Clay overburden is sourced from the limestone quarry.

Groundwater is pumped from the quarry to provide cooling water to the factory.

Energy efficiency at ICL Platin is described in Section d. above.

(x) the need to prevent or reduce to a minimum the overall impact of the emissions on the environment and the risks to it,

The risk to the environment posed by the facility is assessed in the Environmental Liability Risk Assessment (refer to Attachment No. J). The impact of the emissions on the environment and the risk to the environment is low given the low quantity of hazardous substances used and generated and the environmental properties of these substances. The main emissions will be to air from combustion gases. However, given the limits imposed by the current licence these emissions are considered to have little significant impact on the environment.

(xi) the need to prevent accidents and to minimise the consequences for the environment, and

All operations and activities are carried out in accordance with the relevant ICL Platin procedures, which are designed to minimise accidents. The main accident scenarios that could occur at the site are fires, explosions and spills of harmful material. ICL Platin has developed the Platin Works Emergency Response Procedure (Issue No. 3) which sets out the responses to such events.

Full details of the emergency response procedures at ICL Platin are provided in Attachment No. J.

(xii) the information published by the Commission of the European Communities pursuant to any exchange of information between Member States and the industries concerned on best available techniques, associated monitoring, and developments in them, or by international organisations

The activities carried out at ICL Platin are discussed with reference to the European Commission BREF document for the cement industry above.

EPA Draft BAT Guidance Note

The Agency’s draft BAT Guidance Note for the Production of Cement and Lime in a Kiln contains extensive reference to the BREF Note on the Cement and Lime Manufacturing Industries. BAT as described in Table I.3 which references this BREF Note is therefore applicable in the context of the Agency’s Guidance Note. Additional techniques relevant to the activities at ICL as mentioned in the Agency’s Draft BAT Guidance Note are discussed below.

BAT for the production of cement clinker is considered to be a dry process kiln with multi-stage preheating and precalcination. ICL Platin currently employs 2 kiln systems. Kiln 1 is a single stage cyclone preheater kiln in which evaporation of residual moisture and partial calcination of the meal occurs. Complete calcination and clinker formation occurs in the kiln process. A four stage system is installed for

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Kiln 2. The Kiln 3 preheater is a five stage cyclone preheater. Kiln 3 and associated equipment have not yet been commissioned. Kiln 1 will be decommissioned prior to commissioning of Kiln 3 in 2008.

General primary optimisation measures which are considered BAT such as optimised cooler connections, consistency of raw mix and consistency of grind for solid fuels as listed in the Agency’s Draft Guidance are also employed at the ICL Platin site. Heat recovery from waste gases is also considered BAT according to the Agency’s draft guidance. ICL Platin achieves this on site by using the exhaust gases from all kilns to dry raw materials.

Careful selection and control of substances entering the kilns is achieved at ICL Platin by weighing and controlling the flow of raw meal on extraction from the feed hoppers before pneumatic transport into the kiln system.

ICL Platin has made significant investment in BAT based technology in recent years. Notable examples are:

• installation of cooling tower on Kiln 1 system • ducting of low level emissions points on Kiln 1 system to Kiln 1 chimney • extension of Kiln 2 electrostatic precipitator • complete replacement of Coal Mill 2 electrostatic precipitator with a bag filter • installation of high efficiency separators on all cement mills • installation of SNCR technology on Kiln 2 • development of techniques to maximise the use of overburden and so reduce

the amount of quarried shale for use in the process represents BAT.

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IPPC Licence Application Tables I.2(i) I.4(i) I.4(ii) I.7(i)

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Table I.2(i) SURFACE WATER QUALITY (Sheet 1 of 2) Monitoring Point/ Grid Reference: ____SW1 (IPC Licence P0030-02 emission point W4, combined treated effluent from W1 and W3 and quarry groundwater)__ Parameter Results

(mg/l) Sampling method2 (grab, drift etc.)

Normal Analytical Range2

Analysis method / technique

Date Dec

2006

Date Nov 2006

Date Oct

2006

Date Sept 2006

pH 7.8 7.6 7.9 7.8 Grab/ Composite Sampling

External Laboratory - Electrometry

Temperature Electrical conductivity EC Ammoniacal nitrogen NH4-N

Chemical oxygen demand Biochemical oxygen demand

2 2 2 1.5 Grab/ Composite Sampling

External laboratory- Standard method for water and wastewater analysis

Dissolved oxygen DO Calcium Ca Cadmium Cd Chromium Cr Chloride Cl

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Parameter Results

(mg/l) Sampling method2 (grab, drift etc.)

Normal Analytical Range2


Date Dec

2006

Date June 2006

Date Dec

2005

Date June 2005

Copper Cu 0.01 0.01 0.01 0.01 Grab Sample External Laboratory – ICP Mass Spectrometry

Iron Fe Lead Pb 0.02 0.02 0.02 0.02 Grab Sample External

Laboratory – ICP Mass Spectrometry

Magnesium Mg Manganese Mn Mercury Hg

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Surface Water Quality (Sheet 2 of 2) Parameter Results

(mg/l) Sampling method (grab, drift etc.)

Normal Analytical Range


Date Dec

2006

Date June 2006

Date Dec

2005

Date June 2005

Nickel Ni Potassium K Sodium Na Sulphate SO4 Zinc Zn 0.01 0.01 0.01 0.01 Grab Sample External

Laboratory – ICP Mass Spectrometry

Total alkalinity (as CaCO3) Total organic carbon TOC Total oxidised nitrogen TON

Nitrite NO2 Nitrate NO3 Faecal coliforms ( /100mls)

Total coliforms ( /100mls) Phosphate PO4

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Table I.4(i) GROUNDWATER QUALITY (Sheet 1 of 2) Monitoring Point/ Grid Reference: Parameter Results

(mg/l) Sampling method (composite etc.)



Date 9/05/ 2006

Date 13/10/ 2005

Date 12/05/ 2005

Date

pH Temperature Electrical conductivity EC Ammoniacal nitrogen NH4-N

<0.05 <0.1 <0.1 Grab External laboratory

Dissolved oxygen DO Residue on evaporation (180oC)

Calcium Ca 101 102 102 Grab External laboratory Cadmium Cd <0.005 <0.005 <0.005 Grab External laboratory Chromium Cr <0.01 <0.01 <0.01 Grab External laboratory Chloride Cl 19 28 32 Grab External laboratory Copper Cu <0.01 <0.01 <0.01 Grab External laboratory Cyanide Cn, total Iron Fe 0.01 0.14 0.14 Grab External laboratory Lead Pb <0.02 <0.02 <0.02 Grab External laboratory Magnesium Mg 11 11 11 Grab External laboratory Manganese Mn <0.01 <0.01 <0.01 Grab External laboratory Mercury Hg <0.05 <0.05 <0.05 Grab External laboratory Nickel Ni <0.01 <0.01 <0.01 Grab External laboratory Potassium K 3.5 2.7 2.7 Grab External laboratory Sodium Na 12 12 12 Grab External laboratory

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GROUNDWATER QUALITY (SHEET 2 OF 2)

Parameter Results (mg/l)

Sampling method (composite, dipper etc.)



Date 9/05/ 2006

Date 13/10/ 2005

Date 12/05/ 2005

Date

Phosphate PO4 Sulphate SO4 24 20 Grab External laboratory Zinc Zn <0.01 <0.01 <0.01 Grab External laboratory Total alkalinity (as CaCO3) Total organic carbon TOC Total oxidised nitrogen TON

Arsenic As <0.05 <0.05 <0.05 Grab External laboratory Barium Ba <0.01 <0.01 <0.01 Grab External laboratory Boron B <0.1 <0.1 <0.1 Grab External laboratory Fluoride F Phenol Phosphorus P <0.05 <0.05 <0.05 Grab External laboratory Selenium Se Silver Ag Nitrite NO2 Nitrate NO3 20 20 21 Grab External laboratory Faecal coliforms ( /100mls)

Total coliforms ( /100mls) Water level (m OD)

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I - 25 of 26

TABLE I.4(ii): LIST OF OWNERS/FARMERS OF LAND Not Applicable Land Owner

Townlands where landspreading Map

Reference Fertiliser P requirement for each farm

*NMP must take account of on-farm slurry

Total P requirement of the client List _____________ TABLE I.4(ii): LANDSPREADING Land Owner/Farmer_________Not Applicable _______________________ Map Reference_______________________

Field ID

Total Area (ha)

(a) Usable Area (ha)

Soil P Test Mg/l

Date of P test

Crop P Required (kg P/ha)

Volume of On-Farm Slurry Returned (m3/ha)

Estimated P in On-Farm Slurry (kg P/ha)

(b) Volume to be Applied (m3/ha)

P Applied (kg P/ha)

Total Volume of imported slurry per plot (m3)

Total volume that can be imported on to the farm:

Concentration of P in landspread material - kg P/m3

Concentration of N in landspread material - kg N/m3

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I - 26 of 26

Table I.7(i): AMBIENT NOISE ASSESSMENT – Refer to Attachment No. I, Section I.7.1. Third Octave analysis for noise emissions should be used to determine tonal noises

National Grid Reference

Sound Pressure Levels

(6N, 6E) L(A)eq L(A)10 L(A)90 1. SITE

BOUNDARY

Location 1: Location 2: Location 3: Location 4: 2. NOISE

SENSITIVE LOCATIONS

Location 1: Location 2: Location 3: Location 4:

NOTE: All locations should be identified on accompanying drawings.

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N1

N2 N3

N11

N12

N4

N5

N13

N15

N16

N14

N17

N18

N19

N6

N7

N8

N9

N10

Noise Sources (including noise sources associated with Kiln 3)


D5374.10 August 2007 Figure I.1

0 metres 400

Scale 1:10,000

Not To Scale

0 kilometres 8

Scale 1:200,000

0 metres 60

Scale 1:1,500


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N20

Noise Monitoring Location


D5374.10 August 2007 Figure I.2


0 kilometres 2

Scale 1:50,000

0 metres 400

Scale 1:10,000

Not To Scale

0 kilometres 8

Scale 1:200,000

Permitted Quarry Area

ICL Platin PropertyBoundary

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Air Dispersion Modelling Report

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Irish Cement

Irish Cement Platin IPPC Licence Application

Air Quality Modelling of NOx and PM (2007)

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Irish Cement

Irish Cement Platin IPPC Licence Application

Air Quality Modelling of NOx and PM (2007)

September 2007

This report takes into account the

particular instructions and requirements of our client. It is not intended for and should not be relied upon by any third party and no responsibility is undertaken to any third party

Arup Consulting Engineers 10 Wellington Road, Dublin 4 Ireland Tel +353 1 614 4200 Fax +353 1 668 3169 www.arup.ie Job number D 5374/10

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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)

J:\D5300-D5399\D5374\5) DESIGN\10\AERMOD\AIR DISPERSION MODELLING REPORT 2007_D5374-10_ISSUE2 DRAFT1.DOC

Arup Consulting EngineersIssue2 19 September 2007

CONTENTS

Page

1. INTRODUCTION .................................................................................................................... 1

2. METHODOLOGY ................................................................................................................... 1 2.1 Scenario 1 .............................................................................................................................. 1 2.2 Scenario 2 .............................................................................................................................. 2 2.3 Scenario 3 .............................................................................................................................. 2 2.4 Scenario 4 .............................................................................................................................. 2 2.5 Scenario 5 .............................................................................................................................. 2 2.6 Scenario 6 .............................................................................................................................. 2

3. AIR QUALITY STANDARDS ................................................................................................. 2 3.1 NO2 limit values (protection of human health)......................................................................... 3 3.2 NOx limit values (protection of vegetation) .............................................................................. 3 3.3 PM10 limit values (protection of human health)........................................................................ 3

4. BACKGROUND CONCENTRATIONS................................................................................... 3

5. DISPERSION MODELLING ................................................................................................... 3 5.1 Emissions ............................................................................................................................... 4 5.2 Building Wake Effect............................................................................................................... 6 5.3 Receptor Locations................................................................................................................. 6 5.4 Meteorological Data................................................................................................................ 6

6. RESULTS............................................................................................................................... 6 6.1 Scenario 1 .............................................................................................................................. 6 6.2 Scenario 2 .............................................................................................................................. 7 6.3 Scenario 3 .............................................................................................................................. 8 6.4 Scenario 4 ............................................................................................................................ 10 6.5 Scenario 5 ............................................................................................................................ 11 6.6 Scenario 6 ............................................................................................................................ 12

7. CUMULATIVE IMPACT ASSESSMENT .............................................................................. 13 7.1 Predicted concentrations of NO2 (μg/m3): Indaver ................................................................ 13 7.2 Predicted concentrations of PM10 (μg/m3): Indaver ............................................................... 13 7.3 Predicted concentrations of NO2 (μg/m3): SSE ..................................................................... 14 7.4 Predicted concentrations of PM10 (μg/m3): SSE.................................................................... 14

8. CONCLUSIONS ................................................................................................................... 15

9. REFERENCES ..................................................................................................................... 15 Figures Figure 1 Isopleths of predicted annual mean NO2: Scenario 1 Figure 2 Isopleths of predicted annual mean PM10: Scenario 2 Figure 3 Isopleths of predicted annual mean NO2: Scenario 3 Figure 4 Isopleths of predicted annual mean PM10: Scenario 4 Figure 5 Isopleths of predicted annual mean NO2: Scenario 5 Figure 6 Isopleths of predicted annual mean PM10: Scenario 6

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Page 1 Arup Consulting EngineersIssue2 19 September 2007

1. INTRODUCTION Irish Cement Ltd. operates a cement plant at Platin, Co. Meath. This study assesses the dispersion of emissions to air of oxides of nitrogen (NOx) and particulate matter (PM10).

Several scenarios are presented since the current plant with the Kiln 1 Line will be operational only until the commissioning of the Kiln 3 Line in late 2008. Kiln 1 will operate with Kiln 2 until the commissioning of Kiln 3. On the start-up of Kiln 3, Kiln 1 will be decommissioned. Only Kiln 2 and Kiln 3 will operate thereafter.

Exhaust gases from the new Kiln 3 Line may be used to dry limestone being milled for the production of CEM II cements in the existing Raw Mill 1. In this situation, it is proposed to vent the gas at a high level through the existing Kiln 1 chimney. The modelling also deals with this situation (Scenarios 5 and 6).

2. METHODOLOGY Emissions from ten sources were modelled using AERMOD. Six scenarios were assessed.

Scenarios 1 and 2 reflect the operation of the Kiln 1 Line and the Kiln 2 Line, at expected licence flow and concentration limits. Scenario 1 addresses the NOx concentrations. Scenario 2 addresses the PM10 concentrations. The Kiln 1 Line and Kiln 2 Line will be operational together only until the commissioning of the Kiln 3 Line. Therefore Scenarios 1 and 2 apply until late 2008.

Scenarios 3 and 4 reflect the operation of the Kiln 2 Line and the Kiln 3 Line, at expected licence flow and concentration limits. Scenario 3 addresses the NOx concentrations. Scenario 4 addresses the PM10 concentrations. The Kiln 3 Line will be commissioned in late 2008. Therefore Scenarios 3 and 4 apply from late 2008.

Scenarios 5 and 6 are as Scenarios 3 and 4 but with exhaust gases from Kiln 3 used to dry limestone in Raw Mill 1 and these gases vented through the Kiln 1 chimney. Scenario 5 addresses the NOx concentrations. Scenario 6 addresses the PM10 concentrations. Scenarios 5 and 6 apply from late 2008.

NO2 concentrations were calculated from the predicted NOx concentrations using a conversion factor of 0.5 as advised by the EPA (2004).

The modelling predictions represent the most conservative or worst-case concentrations which may arise. Several worst-case conditions are assumed to be coincident:

• Emission sources are operating at maximum flow rates, continuously;

• Emission sources are operating at maximum emission concentrations, rather than average emission concentrations;

• Emission sources are operating for every hour of every day of the year;

• Meteorological conditions are those which give rise to the maximum predicted concentration, identifying the worst hour from five years of hourly meteorological data;

• Receptor location is that which experiences the maximum predicted concentration.

2.1 Scenario 1 NOx emissions from three sources: Kiln 1, Kiln 2 and Coal Mill 2. The Kiln 1 emission point incorporates emissions from Kiln 1, Raw Mill 1 and Coal Mill 1.

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2.2 Scenario 2 PM emissions from seven sources: Kiln 1, Kiln 2, Coal Mill 2, Cement Mill 1, Cement Mill 2, Cement Mill 3 and Kiln 2 Grate Cooler. As in Scenario 1, the Kiln 1 emission point incorporates emissions from Kiln 1, Raw Mill 1 and Coal Mill 1.

2.3 Scenario 3 NOx emissions from three sources: Kiln 2, Kiln 3 and Coal Mill 2.

2.4 Scenario 4 PM emissions from nine sources: Kiln 2, Kiln 3, Coal Mill 2, Cement Mill 1, Cement Mill 2, Cement Mill 3, Kiln 2 Grate Cooler, Kiln 3 Grate Cooler and Cement Mill 4.

2.5 Scenario 5 NOx emissions from four sources: Kiln 2, Kiln 3, Coal Mill 2 and Raw Mill 1. The Raw Mill 1 emissions are routed through the Kiln 1 stack.

2.6 Scenario 6 PM emissions from ten sources: Kiln 2, Kiln 3, Coal Mill 2, Raw Mill 1, Cement Mill 1, Cement Mill 2, Cement Mill 3, Kiln 2 Grate Cooler, Kiln 3 Grate Cooler and Cement Mill 4. As in Scenario 5, the Raw Mill 1 emissions are routed through the Kiln 1 stack.

3. AIR QUALITY STANDARDS The Air Quality Standards (AQS) Regulations, 2002 (S.I. No. 271 of 2002) specify the Limit Values for oxides of nitrogen (NOx), nitrogen dioxide (NO2) and particulate matter of diameter less than 10 microns (PM10). Table 1 shows the AQS Limit Values relevant to the assessment of the Irish Cement Platin facility. The Air Quality Standards Limit Values are referred to in this report as AQS, to differentiate from the IPPC Licence Limit Values.

The Irish AQS Regulations (2002) are based on EU Directives 96/62/EC, 1999/30/EC and 2000/69/EC. It is proposed by the EU to extend the PM10 Stage 1 AQS of 40μg/m3 to 2015 instead of introducing the Stage 2 AQS of 20μg/m3 (CEC, 2005). It is also proposed by the EU to introduce a concentration cap for annual mean PM2.5 of 25μg/m3 to be attained by 1 January 2010 (CEC, 2005).

Table 1 Air Quality Standards (AQS Regulations S.I. No. 271 of 2002 and CEC 2005)

Pollutant Limit value for the

protection of:

Averaging period

Limit value

(μg/m3)

Basis of application of limit

value

Limit value attainment date

1-hour 200 ≤18 exceedances p.a.

1 January 2010 NO2 human health

Calendar year 40 Annual mean “

NOx vegetation Calendar year 30 Annual mean 19 July 2001

24-hours 50 ≤35 exceedances p.a.

1 January 2005 PM10 human health

Calendar year 40 Annual mean “

PM2.5 human health Calendar year 25 Concentration cap 1 January 2010

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3.1 NO2 limit values (protection of human health) According to the Regulations, the AQSs for NO2 for the protection of human health are 40μg/m³ over 1 year and 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQSs for NO2 are to be attained by 1 January 2010.

3.2 NOx limit values (protection of vegetation) According to the Regulations, the AQS for NOx for the protection of vegetation is 30μg/m³ over 1 year, effective from 19 July 2001.

3.3 PM10 limit values (protection of human health) According to the Regulations, the AQSs for PM10 for the protection of human health are 40μg/m³ over 1 year and 50μg/m³ over 24 hours. The 24-hour AQS is not to be exceeded more than 35 times in a calendar year. The AQSs for PM10 have been effective from 1 January 2005.

4. BACKGROUND CONCENTRATIONS The site is classified as Zone D since it is outside Drogheda town (which is classified as Zone C). Concentrations measured in Zone D were taken to represent background concentrations, which were added to the annual mean ground-level concentrations predicted by modelling.

Relevant monitoring results recorded by the EPA in 2006 (EPA, 2007) were averaged for concentrations recorded at all relevant monitoring sites to represent typical annual mean background levels for NOx (8.3μg/m3), NO2 (5.7μg/m3) and PM10 (15.3μg/m3).

Average PM10 for Zone D has been calculated from 4 EPA monitoring stations in Zone D. Data from the Carnsore Point monitoring station has not been included since it is a coastal site whereas Irish Cement Platin is not a coastal site.

The annual mean concentration of PM10 at Carnsore Point was 1.5 to 2.7 times the concentration at the other (non-coastal) Zone D monitoring stations (EPA, 2007). Similarly, the annual mean concentration of PM10 at a Zone D coastal site was found to be 1.9 times the concentration at a non-coastal Zone D site (EPA, 2006). This may be due to naturally occurring sea-salt and organic materials.

PM2.5 has a proposed concentration cap rather than a limit value (CEC, 2005). The annual mean background concentration for PM2.5 (9.2 μg/m3) was derived from the PM10 concentrations using a ratio of 0.60 (EC, 2004).

5. DISPERSION MODELLING Emissions were modelled using the model AERMOD, recommended by the EPA and the US EPA (2005). This is a computer model that predicts the ground level concentration due to pollutant emissions from specified sources. The model requires information on:

• Emission sources;

• Neighbouring buildings;

• Receptor locations and;

• Meteorological conditions.

The model was used to predict ground level concentrations over 1-hour, 24-hour and annual averaging periods.

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5.1 Emissions The emission sources for each of the six scenarios are given in Table 2. Scenarios 1, 3 and 5 assess the NOx emissions. Scenarios 2, 4 and 6 address the PM10 emissions.

The modelling predictions represent the most conservative or worst-case concentrations which may arise. Several worst-case conditions are assumed to be coincident:

• Emission sources are operating at maximum flow rates, continuously;

• Emission sources are operating at maximum emission concentrations, rather than average emission concentrations;

• Emission sources are operating for every hour of every day of the year;

• Meteorological conditions are those which give rise to the maximum predicted concentration, identifying the worst hour from five years of hourly meteorological data;

• Receptor location is that which experiences the maximum predicted concentration.

The model predictions are therefore extremely conservative, giving worst-case ground-level concentrations, which should never be realised in practice.

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Table 2 Emissions sources data

SOURCE NAME Kiln 1,

Raw Mill 1, Coal Mill 1

Kiln 2 Coal Mill 2 Cement Mill 1 Cement Mill

2 Cement Mill

3

Kiln 2 Grate Cooler

Kiln 3 Kiln 3 Grate Cooler

Cement Mill 4

Ref Base (m OD) +47.2 +50.33 +46.94 +47.3 +47.3 +50.76 +50.8 +45.2 +45.2 +50.9 H (m) 98.01 103.04 48.09 28.64 34.82 26.35 30.43 123 35 39 Diameter (m ID) 2.38 3.70 1.00 0.704 1.90 1.988 3.55 3.75 3.00 2.00 Volume flowrate (Nm3/hour, wet gas, actual O2)

- - - 18,500 120,000 135,000 210,000 - 219,000 110,000

Volume flowrate (Nm3/hour, dry gas, 10% O2)

190,000A

49,000B 400,000 31,000 - - - - 410,000 - -

Efflux velocity (m/s, wet, actual T, actual O2)

17.71A

5.86B 16.59 18.90 18.08 15.43 15.84 11.29 19.38 18.59 13.46

T (°C) 121A

118B 121 81 101 85 85 250 108 317 105

Scenario 1 NOx (mg/Nm3) 1800 1000 1000 - - - - - - -

Scenario 2 Particulates (mg/Nm3)

50 50 50 75 50 50 100 - - -

Scenario 3 NOx (mg/Nm3) - 1000 1000 - - - - 1300 - -


- 50 50 75 50 50 100 30 30 30

Scenario 5 NOx (mg/Nm3) 1300 1000 1000 - - - - 1300 - -


50 50 50 75 50 50 100 30 30 30

A Scenarios 1 and 2. B Scenarios 5 and 6. Scenarios 1a-4a, 5a.i & 6a.i.

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5.2 Building Wake Effect The length, width and height of buildings in the vicinity of the sources were taken into account in modelling. Building data was taken from information supplied by Irish Cement for this and previous assessments. AERMOD includes a software utility called BPIP to calculate direction-specific building downwash factors using the relative positions and dimensions of sources and neighbouring buildings.

5.3 Receptor Locations Two nested, Cartesian receptor grids were used, centred on the facility, as in previous assessments. One has receptors covering a 10km by 10km area at 1km intervals. The other has receptors covering a 2km by 2km area at 100m intervals. Elevations were taken from Ordnance Survey mapping as used in previous assessments.

5.4 Meteorological Data Meteorological data from Met Eireann’s synoptic station at Dublin Airport was used for 1998 to 2002 inclusive. The meteorological data includes hourly values for wind speed, wind direction, atmospheric stability, ambient temperature and mixing height.

6. RESULTS

6.1 Scenario 1 Scenario 1 represents the operation of the Kiln 1 Line and Kiln 2 Line, at expected licence flow and concentration limits. Scenario 1 applies until late 2008. NOx emissions were modelled for three sources (Table 2). The Kiln 1 emission point incorporates emissions from Kiln 1, Raw Mill 1 and Coal Mill 1.

6.1.1 Predicted concentrations of NO2 (protection of human health)

The maximum ground-level concentrations under Scenario 1 are compared to the AQS for NO2 for the protection of human health of 40μg/m³ over 1 year and 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQSs for NO2 are to be attained by 1 January 2010.

The maximum ground-level concentrations under Scenario 1 are predicted to be 52% of the AQS for 1-hour NO2 and 31% of the AQS for annual NO2. In the case of the annual concentration, 17% is due to the emissions from the cement works and 14% is due to the background concentration (Table 3).

EPA monitoring does not include 99.79th%ile 1-hour concentration and therefore it cannot be included as a background concentration. As stated in Section 2, nitrogen dioxide (NO2) concentrations were calculated from the predicted NOx concentrations using a conversion factor of 0.5 as advised by the EPA (2004).

The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour.

Figure 1 shows the isopleths (concentration contours) of predicted annual mean NO2 for Scenario 1 (excluding background concentration).

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Table 3 Predicted concentrations of NO2 (μg/m3) for Scenario 1

Averaging period Concentration (NO2) (μg/m3)

Concentration as % of AQS

1-hour 122.8 NA

99.79th%ile 1-hour 104.9 52%

Calendar year 6.6 17%

Annual mean background (measured by EPA in 2006) 5.7 14%

Calendar year including annual mean background 12.3 31% ICP083.dat-ICP087.dat

6.1.2 Predicted concentrations of NOx (protection of vegetation)

The maximum ground-level concentrations under Scenario 1 are compared to the AQS for NOx for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NOx has been in effect since 19 July 2001.

The maximum ground-level concentrations under Scenario 1 are predicted to be 71% of the AQS for annual NOx. Of this, 44% is due to the emissions from the cement works and 28% is due to the background concentration (Table 4).

The predicted concentrations comply with the AQS of 30μg/m³ over 1 year.

Table 4 Predicted concentrations of NOx (μg/m3) for Scenario 1

Averaging period Concentration (NOx) (μg/m3)





6.2 Scenario 2 Scenario 2 represents the operation of Kiln 1 Line and Kiln 2 Line, at expected licence flow and concentration limits. Scenario 2 applies until late 2008. PM10 emissions were modelled for seven sources (Table 2). The Kiln 1 emission point incorporates emissions from Kiln 1, Raw Mill 1 and Coal Mill 1.

The maximum ground-level concentrations under Scenario 2 are compared to the AQSs for PM10 for the protection of human health of 40μg/m³ over 1 year and 50μg/m³ over 24 hours. The 24-hour AQS is not to be exceeded more than 35 times in a calendar year. The AQSs for PM10 have been effective from 1 January 2005.

The maximum ground-level concentrations under Scenario 2 are predicted to be 46% of the AQS for 24-hour PM10 and 59% of the AQS for annual PM10. In the case of the annual concentration, 21% is due to the emissions and 38% is due to the background concentration (Table 5).

EPA monitoring does not include a 24-hour concentration, and therefore it is not possible to include such a background concentration.

The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 50μg/m³ over 24 hours.

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Figure 2 shows the isopleths (concentration contours) of predicted annual mean PM10 for Scenario 2 (excluding background concentration).

It is also proposed by the EU to introduce a concentration cap for annual mean PM2.5 of 25μg/m3 to be attained by 1 January 2010 (CEC, 2005). Concentrations for PM2.5 were derived from the PM10 concentrations using a ratio of 0.60 (EC, 2004). The predicted concentrations comply with the proposed concentration cap AQS of 25μg/m3 (Table 6).

Table 5 Predicted concentrations of PM10 (μg/m3) for Scenario 2

Averaging period Maximum Concentration


1-hour 157.4 NA

24-hour 62.5 NA

90.41st%ile 24-hour 23.0 46%




Table 6 Predicted concentrations of PM2.5 (μg/m3) for Scenario 2

Averaging period Concentration Concentration as % of AQS




6.2.1 Scenario 2 with Cement Mill 4

Scenario 2 was also modelled to include Cement Mill 4. This combination would arise in the event that Cement Mill 4 is operational during 2008 before the Kiln 1 Line is decommissioned in late 2008. Source data for this scenario is as per Scenario 2 with the addition of Cement Mill 4.

The maximum ground-level concentrations under “Scenario 2 with Cement Mill 4” are predicted to be 23.2μg/m3 for 90.41st%ile 24-hour PM10 and 8.2μg/m3 for annual PM10. These can be compared to the maximum ground-level concentrations under Scenario 2 of 23.0μg/m3

for 90.41st%ile 24-hour PM10 and 8.2μg/m3 for annual PM10 (Table 5).


6.3 Scenario 3 Scenario 3 represents the operation of the Kiln 2 Line and Kiln 3 Line, at expected licence flow and concentration limits. Scenario 3 applies from the commissioning of Kiln 3 in late 2008. NOx emissions were modelled for three sources (Table 2).


The maximum ground-level concentrations under Scenario 3 are compared to the AQS for NO2 for the protection of human health of 40μg/m³ over 1 year and 200μg/m³ over 1 hour.

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The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQSs for NO2 are to be attained by 1 January 2010.








1-hour 109.2 NA

99.79th%ile 1-hour 85.9 43%














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6.4 Scenario 4 Scenario 4 represents the operation of the Kiln 2 Line and Kiln 3 Line, at expected licence flow and concentration limits. Scenario 4 applies from the commissioning of Kiln 3 in late 2008. PM10 emissions were modelled for nine sources (Table 2).










1-hour 157.8 NA

24-hour 62.6 NA

90.41st%ile 24-hour 23.2 46%









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6.5 Scenario 5 Scenario 5 represents the operation of the Kiln 2 Line and Kiln 3 Line, at expected licence flow and concentration limits, with exhaust gases from Kiln 3 used to dry limestone in Raw Mill 1 and these gases vented through the Kiln 1 chimney. Scenario 5 applies from the commissioning of Kiln 3 in late 2008. NOx emissions were modelled for four sources (Table 2).


The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO2 for the protection of human health of 40μg/m³ over 1 year and 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQSs for NO2 are to be attained by 1 January 2010.








1-hour 120.8 NA

99.79th%ile 1-hour 85.9 43%








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6.6 Scenario 6 Scenario 6 represents the operation of the Kiln 2 Line and Kiln 3 Line, at expected licence flow and concentration limits, with exhaust gases from Kiln 3 used to dry limestone in Raw Mill 1 and these gases vented through the Kiln 1 chimney. Scenario 6 applies from the commissioning of Kiln 3 in late 2008. PM10 emissions were modelled for ten sources (Table 2).










1-hour 157.8 NA

24-hour 62.6 NA

90.41st%ile 24-hour 23.3 47%




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7. CUMULATIVE IMPACT ASSESSMENT Facilities have been proposed in the vicinity of Irish Cement’s site at Platin by Indaver Ireland at Carranstown and by Scottish and Southern Energy Plc. (SSE) between Carranstown and Caulstown.

The cumulative effect of the proposed developments was assessed by considering the ambient air quality and the source contributions due to Irish Cement Platin, Indaver and SSE.

7.1 Predicted concentrations of NO2 (μg/m3): Indaver The maximum concentration due to Indaver is predicted to occur at (306950, 271050). The maximum concentration due to Irish Cement Platin in the vicinity of the maximum concentration due to Indaver is shown in Table 15.

The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO2 for the protection of human health of 40μg/m³ over 1 year. The AQS for NO2 is to be attained by 1 January 2010.

The cumulative impact of the maximum ground-level concentrations is predicted to be 21% of the AQS for annual NO2. Of this, 7% is due to the emissions from Indaver and the cement works and 14% is due to the background concentration (Table 15).


Table 15 Predicted concentrations of NO2 (μg/m3) for Indaver maximum





Calendar year including annual mean background 8.4 21% ICP143.dat and Indaver 2005 EIS Waste to Energy (Table 7.15)

7.2 Predicted concentrations of PM10 (μg/m3): Indaver The maximum concentration due to Indaver is predicted to occur at (306950, 271050). The maximum concentration due to Irish Cement Platin in the vicinity of the maximum concentration due to Indaver is shown in Table 16.

The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM10 for the protection of human health of 40μg/m³ over 1 year. The AQSs for PM10 have been effective from 1 January 2005.

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The cumulative impact of the maximum ground-level concentrations is predicted to be 41% of the AQS for annual PM10. Of this, 3% is due to the emissions and 38% is due to the background concentration (Table 16).


Table 16 Predicted concentrations of PM10 (μg/m3) for Indaver maximum

Averaging period Concentration

(PM10) (μg/m3)




Calendar year including annual mean background 16.3 41% ICP149.dat and Indaver 2005 EIS Waste to Energy (Table 7.20)

7.3 Predicted concentrations of NO2 (μg/m3): SSE The maximum concentration due to SSE is predicted to occur at (307380, 270958). The maximum concentration due to Irish Cement Platin at the location of the maximum concentration due to SSE is shown in Table 17.

The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO2 for the protection of human health of 40μg/m³ over 1 year. The AQS for NO2 is to be attained by 1 January 2010.

The cumulative impact of the maximum ground-level concentrations is predicted to be 21% of the AQS for annual NO2. Of this, 7% is due to the emissions from SSE and the cement works and 14% is due to the background concentration (Table 17).


Table 17 Predicted concentrations of NO2 (μg/m3) for SSE maximum





Calendar year including annual mean background 8.5 21% ICP143.dat and J:\D4000-D4099\D4058\4) Design\Incoming\RP002b Air Dispersion Modelling Report.doc

7.4 Predicted concentrations of PM10 (μg/m3): SSE The maximum concentration due to SSE is predicted to occur at (307280, 271958). The maximum concentration due to Irish Cement Platin at the location of the maximum concentration due to SSE is shown in Table 18.

The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM10 for the protection of human health of 40μg/m³ over 1 year. The AQSs for PM10 have been effective from 1 January 2005.

The cumulative impact of the maximum ground-level concentrations is predicted to be 54% of the AQS for annual PM10. Of this, 16% is due to the emissions and 38% is due to the background concentration (Table 18).


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Table 18 Predicted concentrations of PM10 (μg/m3) for SSE maximum

Averaging period Concentration

(PM10) (μg/m3)




Calendar year including annual mean background 21.6 54% ICP149.dat and J:\D4000-D4099\D4058\4) Design\Incoming\RP002b Air Dispersion Modelling Report.doc

8. CONCLUSIONS The concentrations of atmospheric pollutants predicted for Scenarios 1, 3 and 5 comply with the AQSs for NO2 for the protection of human health of 40μg/m³ over 1 year (including background concentrations) and 200μg/m³ over 1 hour.

The concentrations of atmospheric pollutants predicted for Scenarios 1, 3 and 5 comply with the AQS for NOx for the protection of vegetation of 30μg/m³ over 1 year (including background concentrations).

The concentrations of atmospheric pollutants predicted for Scenarios 2, 4 and 6 comply with the AQSs for PM10 for the protection of human health of 40μg/m³ over 1 year (including background concentrations) and 50μg/m³ over 24 hours.

9. REFERENCES CEC Commission of the European Communities (2005) “Proposal for a Directive of the European Parliament and of the Council on ambient air quality and cleaner air for Europe”, COM2005 447 (Provisional Version), 2005/0183 (COD), Brussels 21/09/2005.

EC (European Commission) (2004) “Second Position Paper on Particulate Matter – Final”.

EPA (2004) Personal communication (D4265.11)

EPA (2006) Jennings, S.G. et al. “Air Pollution – Nature and Origin of PM10 and Smaller Particulate Matter in Urban Air (2000-LS-6.1-M1)”, Environmental Protection Agency, PO Box 3000, Johnstown Castle, Co Wexford.

EPA (2007) Personal communication (18.vi.2007).

US EPA (2005) “Appendix W to Part 51—Guideline on Air Quality Models. Part 51, chapter I, title 40 of the Code of Federal Regulations. 40 CFR Part 51 Revision to the Guideline on Air Quality Models: Adoption of a Preferred General Purpose (Flat and Complex Terrain) Dispersion Model and Other Revisions; Final Rule”.

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FIGURES

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Arup Consulting EngineersIssue2 19 September 2007

Figure 1 Isopleths of predicted annual mean NO2: Scenario 1

Figure 2 Isopleths of predicted annual mean PM10: Scenario 2





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Isopleths of Annual Mean NO2 : Scenario 1

Irish Cement Platin

D5374.10 Figure 1August 2007

298000 300000 302000 304000 306000 308000 310000 312000 314000 316000

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Isopleths of Annual Mean PM10 : Scenario 2

Irish Cement Platin


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Irish Cement Platin


298000 300000 302000 304000 306000 308000 310000 312000 314000 316000

metres

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Irish Cement Platin


298000 300000 302000 304000 306000 308000 310000 312000 314000 316000

metres

262000

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Irish Cement Platin


298000 300000 302000 304000 306000 308000 310000 312000 314000 316000

metres

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Irish Cement Platin


298000 300000 302000 304000 306000 308000 310000 312000 314000 316000

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Air Emissions Monitoring Statistics

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2006 Monthly Kiln 1 Dust Particulates max daily averages and max 1/2 hourly average

0

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50

75

100

125

150Ja

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Jul

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Max. HalfHour

Limit 240

Limit 120

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97.60%

0.90% 1.50% 0.00% 0.00% 0.00% 0.00%

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

90.00%

100.00%

<20 20-40 40-60 60-80 80-100 100-120 >120

Daily average Kiln 1 Dust 2006 mg/Nm3

Limit 120 mg/Nm3

<2020-4040-6060-8080-100100-120>120

Daily average K1 Dust 2006 mg/Nm3

Average: 4 Standard deviation: 6 Minimum: 1 Maximum: 57 Count: 333 Days

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EPA Export 25-07-2013:22:12:35

97.35%

1.48% 0.50% 0.32% 0.18% 0.17% 0.01%

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

90.00%

100.00%

<20 20-40 40-60 60-80 80-100 100-240 >240

2006 Kiln 1 Half Hourly Dust mg/Nm3

Limit 240 mg/Nm3

<2020-4040-6060-8080-100100-240>240

1 Incidence


Average: 4Standard Deviation: 9Minimum: 0Maximum: 250Count: 16,114 Half Hours

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2006 Monthly Kiln 2 Dust Particulates max daily average and max 1/2 hourly average

0

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100

125

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Jul

Aug

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Max HalfHourly

LimitLimit

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EPA Export 25-07-2013:22:12:35

34.01%

47.97%

16.28%

1.45% 0.29% 0.00%

0.00%

10.00%

20.00%

30.00%

40.00%

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80.00%

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<20 20-40 40-60 60-80 80-100 >100

Daily average Kiln 2 Dust 2006 mg/Nm3

Limit 100 mg/Nm3

<2020-4040-6060-8080-100>100

Daily average K2 Dust 2006 mg/Nm3

Average: 29 Standard deviation: 13 Minimum: 11 Maximum: 82 Count: 344 Days

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EPA Export 25-07-2013:22:12:35

40.01% 38.66%

15.25%

3.98%1.20% 0.86%

0.04%

0.00%

10.00%

20.00%

30.00%

40.00%

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<20 20-40 40-60 60-80 80-100 100-200 >200


Limit 200 mg/Nm3

<2020-4040-6060-8080-100100-200>200


Average: 30Standard Deviation: 19Minimum: 1Maximum: 297Count: 14,326 Half Hours

6 Incidences

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2006 Monthly Kiln 1 NOx max daily average and max 1/2 hourly average

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Max HalfHourly

Limit 3600

Limit 1800

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EPA Export 25-07-2013:22:12:35

17.35%

34.71%31.18%

13.82%

2.65%0.29%

0.00%

10.00%

20.00%

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40.00%

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Daily average Kiln 1 2006 NOx [mgNO2/Nm3 @ 10% O2]Limit 1800 [mgNO2/Nm3 @ 10% O2]

<10001000-12001200-14001400-16001600-1800>1800

1 Incidence

Daily average K1 2006 NOx [mgNO2/Nm3 @ 10% O2]Average: 1203 Standard deviation: 197 Minimum: 823Maximum: 1900 Count: 340 Days

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EPA Export 25-07-2013:22:12:35

18.29%

30.07% 29.51%

15.14%

4.34%2.20%

0.00%

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

90.00%

100.00%

<1000 1000-1200 1200-1400 1400-1600 1600-1800 1800-3600 >3600

2006 Kiln 1 Half Hourly NOx [mgNO2/Nm3 @ 10% O2]Limit 3600 [mg/NO2/Nm3 @ 10% O2]

<10001000-12001200-14001400-16001600-18001800-3600>3600

2006 Kiln 1 Half Hourly NOx [mgNO2/Nm3 @ 10% O2]Average: 1226Standard Deviation: 261Minimum: 4Maximum: 3388Count: 16,114 Half Hours

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EPA Export 25-07-2013:22:12:35

2006 Monthly Kiln 2 NOx max daily average and max 1/2 hourly average

0

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1500

2000Ja

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2000

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4000

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Max HalfHourly

Limit 3600

Limit 1800

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EPA Export 25-07-2013:22:12:35

2.02%

34.68%

49.42%

11.85%

2.02%0.00%

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

90.00%

100.00%

<1000 1000-1200 1200-1400 1400-1600 1600-1800 >1800

Daily average Kiln 2 2006 NOx [mgNO2/Nm3 @ 10% O2]Limit 1800 [mgNO2/Nm3 @ 10% O2]

<1000

1000-1200

1200-1400

1400-1600

1600-1800

>1800

Daily average K2 2006 NOx [mgNO2/Nm3 @ 10% O2]Average: 1241 Standard deviation: 147 Minimum: 456Maximum: 1790 Count: 346 Days

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EPA Export 25-07-2013:22:12:35

9.72%

33.06%37.55%

12.37%

3.81% 3.48%0.01%

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%

90.00%

100.00%

<1000 1000-1200 1200-1400 1400-1600 1600-1800 1800-3600 >3600

2006 Kiln 2 Half Hourly NOx [mgNO2/Nm3 @ 10% O2]Limit 3600 [mgNO2/Nm3 @ 10% O2]

<10001000-12001200-14001400-16001600-18001800-3600>3600

2006 Kiln 2 Half Hourly NOx [mgNO2/Nm3 @ 10% O2]Average: 1260Standard Deviation: 272Minimum: 12Maximum: 3700Count: 15,661 Half Hours

1 Incidence

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EPA Export 25-07-2013:22:12:35

Ecofact: An Ecological and Sediment Study of the River Nanny Near Duleek, Co. Meath

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EPA Export 25-07-2013:22:12:35

PB950900006N 1

Mr. Barry Leonard, Irish Cement Limited, Platin Works, Drogheda, County Meath. 22nd June 2007

Reference: Discolouration of the River Nanny, Duleek, County Meath

Dear Mr. Leonard, Introduction Following a complaint received by Irish Cement Limited (hereafter referred to as ICL) from the Eastern Regional Fisheries Board on the 24th January 2006 concerning the presence of a visible plume adjacent to the ICL discharge point, the company commissioned Mott MacDonald Pettit Limited, Consulting Engineers, (hereafter referred to as MPI) to undertake a comprehensive investigation into evaluating the source, characteristics and implications of the plume observed adjacent to the ICL discharge point. We have been requested to provide an update following the completion of extensive trials and investigations during the last 12 months. Source The source of the discharge to the River Nanny consists of three well defined constituent streams arising from surface water run-off, deep well quarry water and domestic nature wastewater. All three streams are monitored in accordance with the requirements of Integrated Pollution Control Licence Register Reference P0030-02 as specified by the Environmental Protection Agency. Based on a critical review of the monitoring data for the final discharge point, it has been concluded that ICL are compliant with the Licence discharge and monitoring requirements. Characteristics At varying times during our assessment process MPI professional scientists observed the plume referred to by the Eastern Regional Fisheries Board. The plume was characterized by the presence of very fine particles of colloidal/suspended solids. However, the presence of the plume varied with time and flow conditions in the River Nanny and typically appeared as fine and ‘smokey’ in nature. As part of the work completed by MPI on-site the efficacy of the settlement tanks on site was reviewed and several trials to enhance their performance were completed during last summer. These trials included the use of chemical flocculant dosing and advanced filtration trials to reduce the levels of very fine particles in the final discharge. Based on the trials conducted it was concluded that the use of advanced treatment would not result in an appreciable increase in performance of the surface water treatment at Platin.

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EPA Export 25-07-2013:22:12:35

PB950900006N 2

Implications It is our opinion that whilst the plume in the River Nanny could be considered as presenting a minor visual impact, the characteristics of the suspended/colloidal solids were unlikely to present a risk to fish movement, predation or habitat value. In fact it is considered that the discharge of significant volumes of deep well groundwater from the quarry dewatering activity is of benefit to the receiving watercourse. River Nanny Assessment To supplement and confirm this assertion, Dr. William O’Connor, an expert fisheries biologist with Ecofact Environmental Consultants was commissioned to undertake an assessment of the River Nanny upstream and downstream of the ICL discharge point (survey extent 1 kilometre). Dr. O’Connor’s extensive assessment which included macroinvertebrate sampling, identification and classification (using the Biological Monitoring Working Party Score, the Trent Biotic Index, Q-Rating and Chandler Biotic Score), sediment sampling, water quality and habitat survey concluded that both upstream and downstream of the discharge point, the sampling stations were dominated by cobbles and gravel with all sites being generally similar and dominated by grey sandy, slightly gravelly, silt/clay. The results obtained confirmed that the River Nanny is significantly silted both upstream and downstream of the ICL discharge point as a result of background contributions of organic matter in the local catchment. Biological water quality indices obtained from all sample stations highlighted the degraded quality of the River Nanny with all stations downstream of the ICL discharge point being moderately polluted and the upstream stations ranging from moderately polluted to seriously polluted. To this extent it has been demonstrated that the discharge from ICL is having no affect on the overall biological quality of the River Nanny. Overall it is considered that the results obtained suggest an unpredictable supply of invertebrate food is available for juvenile trout at all sites investigated, threatening the river’s status as a fishery and indicating that the River Nanny upstream and downstream of the ICL discharge to be in a moderately polluted state and under considerable ecological stress. A copy of the Ecofact River Nanny Report is attached for your information. Summary In summary, we can state that ICL is compliant with the requirements of their Integrated Pollution Control Licence applying to Platin Cement Works. As part of the ongoing investment into projects which optimise environmental performance (including the upgrade to the sewage works treatment plant and storm tank maintenance), we have been assured that ICL is committed to enhancing the performance of all on-site waste water treatment facilities and continues investment in this regard. In addition, we understand that ICL commit to completing biological water quality monitoring of the River Nanny on a three-yearly basis. MPI are confident that ICL’s ongoing actions will ensure that the discharge from the Platin site will have no significant negative impacts on the water quality of the River Nanny. We trust that the above information is to your satisfaction and if you require any additional information, please do not hesitate to contact the undersigned. Kind Regards, Yours sincerely, For & on behalf of: Mott MacDonald Pettit ____________________________ Paul Kelly B.Sc., H.Dip., M.Sc. Director Environmental Sciences

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EPA Export 25-07-2013:22:12:35

Mott MacDonald Pettit Ltd. Irish Cement Ltd.

AN ECOLOGICAL AND SEDIMENT STUDY OF THE RIVER NANNY NEAR DULEEK, CO MEATH

Final Report

26th June 2007

Tait Business Centre, Dominic Street, Limerick City, Ireland.

t. +353 61 313519, f. +353 61 414315 e. [email protected]

w. www.ecofact.ie

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River Nanny Ecological and Sediment Study November 2006 -------------------------------------------------------------------------------------------------------------------------------------

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TABLE OF CONTENTS 1. INTRODUCTION .......................................................................................................................... 3

1.1 SCOPE ................................................................................................................................... 3 1.2 SITE DESCRIPTION ................................................................................................................ 3 1.3 EXISTING SURFACE WATER RUN-OFF AND WASTE WATER TREATMENT ON SITE .............. 3 1.4 WATER LICENSING REQUIREMENTS ..................................................................................... 4 1.5 THE RIVER NANNY................................................................................................................. 4

2. METHODS ..................................................................................................................................... 6 2.1 BIOLOGICAL ASSESSMENTS ................................................................................................. 6

2.1.1 Macroinvertebrate sampling............................................................................................. 6 2.1.2 Macroinvertebrate Identification ...................................................................................... 6 2.1.3 Biotic Indices .................................................................................................................... 6 2.1.4 Functional Group Analyses............................................................................................... 7

2.2 SEDIMENT SAMPLING ............................................................................................................ 7 2.3 HABITAT SURVEY .................................................................................................................. 8 2.4 OTHER WQ PARAMETERS..................................................................................................... 8

3 RESULTS ...................................................................................................................................... 9 3.1 PHYSICAL HABITAT ............................................................................................................... 9 3.2 TEMPERATURE, CONDUCTIVITY AND DISSOLVED OXYGEN.................................................. 9 3.3 SEDIMENT PSD ..................................................................................................................... 9 3.4 MACROINVERTEBRATE DIVERSITY AND ABUNDANCE ........................................................ 10 3.5 BIOLOGICAL WATER QUALITY ............................................................................................ 10 3.6 FUNCTIONAL GROUPS......................................................................................................... 10

4 SUMMARY AND CONCLUSIONS .......................................................................................... 23 5 RECOMMENDATIONS ............................................................................................................. 24 REFERENCES ..................................................................................................................................... 28 APPENDIX 1 EPA WATER QUALITY DATA FOR THE RIVER NANNY. ................................. 30 APPENDIX 2 BIOTIC INDICES......................................................................................................... 31

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1. INTRODUCTION 1.1 Scope On 24th January 2006 the Eastern Regional Fisheries Board (ERFB) wrote to Irish Cement Limited (hereafter referred to as ICL) and requested that observed discolouration in the River Nanny adjacent to an outfall pipe utilised by ICL be investigated. According to the ERFB, blanketing of the River Nanny bed by fine solids downstream of the outfall point was also taking place. The ERFB requested that this issue is investigated and the plume eliminated. On receipt of this letter and further to a request from ICL, technical personnel from Mott MacDonald Pettit Limited (hereafter referred to as MPI) visited Platin Works site on 13th March 2006 to initiate an investigation into evaluating the source, characteristics and implications of the plume observed adjacent to the ICL Discharge Point. In November 2006, MPI contracted Ecofact Environmental Consultants to undertake an assessment of the River Nanny. It was decided to look in detail at the macroinvertebrate communities in the River Nanny, both upstream and downstream of the discharge, as these fauna are indicators of ecological and water quality status The initial assessment technique used for assessing the macroinvertebrate communities was the Quality Rating (Q) System (used by the EPA to assess water quality during their national roll over survey of Irish Rivers), which is based on the responses of macroinvertebrates to pollution (See Appendix 2). However, because of the degraded nature of the River Nanny, it was decided that the resolution of the Q-rating system was too low to detect changes in areas of the river upstream and downstream of the Irish Cement outflow. For this reason a number of additional biotic indices were also used; BMWP Score, Trent Biotic Index and the Chandler Biotic Index. In addition, Functional Group analysis – a classification technique for stream macroinvertebrates which involves the functional analysis of invertebrate feeding, based on morpho-behavioural mechanisms of food acquisition – was also used. In addition to detailed assessments of macroinvertebrate communities, sediment samples from sites upstream and downstream of the outfall were also collected and subjected to Particle Size Distribution Analyses (PSD). The purpose of this assessment was to see if there were significant differences in the sediments from sites located upstream and downstream of the outfall. All investigations were undertaken within 0.5 km upstream and downstream of the outfall. A detailed description of how the samples were collected and analysed is given in Section 2. 1.2 Site Description ICL operates Platin Works in Drogheda, County Meath, a large limestone quarry which supplies the raw materials to the cement manufacturing plant. The whole site extends to 426 Hectares (ha). Of this area, the quarry makes up 319 ha (not all of this area is currently being quarried), the cement plant covers 23 ha and the railway line which runs through the Platin site (and is used for the bulk transfer of materials including cement) accounts for a further 12 ha. The remainder of the land is used for agriculture. The site is situated west of the R152 regional road (Duleek to Drogheda), approximately 3km south west of Drogheda 1.3 Existing Surface Water Run-off and Waste Water Treatment on site Management of surface water run-off on site consists of a surface water collection system which diverts surface water run-off into a storm balancing tank followed by a sedimentation tank, both of which are used here to reduce the levels of suspended solids. Deep well water from the quarry is managed through continuous pumping out of groundwater from the deep well in the quarry floor. It does not receive any treatment. Domestic effluent is treated in a purpose built package waste water treatment plant on site. Surface water run-off discharges from the sedimentation tank and confluences with deep well water from the quarry and treated

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domestic effluent to form the final effluent which discharges to the outfall point into the River Nanny via a designated pipeline. The W4 final effluent is discharged through 2,637m of 610 mm pipeline which runs underground from the cement manufacturing factory to the outfall point into the receiving waters of the River Nanny. The outfall pipe runs under roads and agricultural land and outfalls into the River Nanny south of the factory, just off the R150 regional road. 1.4 Water Licensing Requirements ICL is licensed by the Environmental Protection Agency (EPA) under Integrated Pollution Control (IPC) Licence Register Number P0030-02. Emission Limit Values specified for the Total Combined Effluent to the River Nanny (Emission Point W4) are set out in Table 1 IPC Licence Emission Limit Values. Based on the information reviewed as part of this project (presented elsewhere), ICL are compliant with their IPC licence emission limit values at W4. Table 1 IPC Licence Emission Limit Values. Parameter Emission Limit Value Concentration (mg/l) Flow 15,000m³/day Suspended Solids 35 BOD (when rate of discharge is < 200m³/hr) 10.0 BOD (when rate of discharge is > 200m³/hr) 6.0 Mineral Oil 2.0 Lead (as Pb) 0.1 Copper (as Cu) 0.1 Zinc (as Zn) 0.5 pH 6 – 9 Temperature 25°C Number of Toxicity Units 1.0 1.5 The River Nanny The River Nanny (OS Catchment No: 160; EPA code: 08N01) is located in County Meath in the Eastern River Basin District (Hydrometric Area 8). The Nanny rises near Kentstown and flows east through Duleek and Julianstown to enter the sea at Laytown, roughly 6 km south of Drogheda. Overall it has a total length of 28 km and a catchment area of 239 km2 (McGinnity et al, 2003). The River Nanny has a long history of pollution; mainly from agricultural sources (McGarrigle et al, 2004; Ecofact 2006). In Appendix 1 a summary of water quality in the River Nanny along with overall water quality in hydrometric area 8 during the most recently published EPA survey is presented. A total of 18% of the river channel of the River Nanny was rated as being Class C or Moderately Polluted at that time, with 3% of the channel rated as being Class D - Seriously Polluted. None of the channel length was rated a being Class A. In Appendix 1 detailed biological water quality results from the River Nanny during the period 1971-2005 are also given.

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Figure 1 Map of the study area with the location of the Irish Cement outfall highlighted. Three sites were located upstream of the ICL outfall (controls) and three sites were located downstream of the ICL outfall (receptors). OS license number to be supplied by client before publication.

ICL Outfall Point

Extent of study area

Receptor sites (3) Control sites (3)

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2. METHODS 2.1 Biological Assessments 2.1.1 Macroinvertebrate sampling

Semi-quantitative sampling of benthic macroinvertebrates was undertaken at the six sites using kick or sweep sampling (Toner et al, 2005). Sampling was undertaken on the 11th and 12th November 2006 during normal river flows. A total of three sites were located within a 0.5 km section of river extending upstream of the Irish Cement ICL discharge point (control sites), and three sites were located over a similar distance downstream (receptor sites) (see Figure 1). Representative riffle1, glide2 and pool3 habitats (EA, 2003) were sampled at both control and receptor locations. The best approximations to these habitat types in the study area were investigated. Site photographs are provided in Plates 1 to 6. Site 1 was located immediately downstream of an old mill dam while Site 2 was located immediately above this impoundment. The presence of this weir on the section can be expected to influence local sedimentation rates. The procedure followed at each site involved the use of a ‘D’ shaped hand net (mesh size 0.5 mm; 350 mm diameter) which was submerged on the river bed with its mouth directed upstream. The substrate upstream of the net was then kicked for one minute in order to dislodge invertebrates, which were subsequently caught in the net. This procedure was undertaken at three points along/across the watercourse. Stone washings and vegetation sweeps were also undertaken over a further 1 minute period to ensure a representative sample of the fauna present at each site was collected. All three samples of invertebrates from each substation were combined and live sorted on the river bank for 20 minutes with the assistance of a headband magnifier. Specimens were fixed in a 10% formalin solution. Identification was undertaken in the laboratory using high-power and low-power binocular microscopes. All collected samples have been archived and will be retained for 1 year. 2.1.2 Macroinvertebrate Identification Specimens were identified using the keys produced by the Freshwater Biological Association. These keys included Elliott & Humpesch (1988) for mayflies, Edington & Hildrew (1995) and Wallace et al (2003) for caddis fly larvae, Gledhill et al (1993) for crustaceans, Macan (1994) for snails, Hynes (1977) for stoneflies, Savage (1989, 1999) for bugs and Elliott & Mann (1979) for leeches. 2.1.3 Biotic Indices The Quality Rating (Q) System The Quality Rating (Q) System (Toner et al, 2005) is the standard biotic index which is used by the EPA. This method categorises invertebrates into one of five groups, depending on their sensitivity to pollution. Further details on the Q-rating system are provided in Appendix 2. BMWP (Biological Monitoring Working Party) Score

1 A riffle is a shallow stretch of a river, where the current is above the average stream velocity and where the water forms small rippled waves as a result. 2 Depth of flow in a glide/run is greater than that of riffles and slope of the bed is less than that of riffles. 3 Pools are the deepest locations of the reach. Water surface slope of pools at normal flows is near zero.

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The BMWP scheme (Armitage et al, 1983) is used to deduce a biotic index of water quality. This scheme requires the identification of specimens to family level and each family is assigned a score. The BMWP score is the sum of the individual scores of the families recorded at each site. The BMWP scoring system is shown in Appendix 2. Trent Biotic Index The Trent Biotic Index (Woodiwiss, 1960) is based on the number of defined taxa of benthic invertebrates in relation to the presence of six key organisms found in the fauna of the sample site. Depending on the number of taxonomic groups present and the key organisms found in the fauna, the index ranges from ten for clean water, to zero for polluted water. Chandler Biotic Score The Chandler Biotic Score (Chandler, 1970) also assigns values to taxonomic groups ranked in terms of pollution sensitivity but, in addition, provides scores for each species which is present in the taxonomic groups. This is a more powerful, albeit more taxonomically demanding, system than the previous biotic indices. Each group is given a score according to its abundance. The total score represents the index and the higher the score the cleaner the water. 2.1.4 Functional Group Analyses Functional Group analysis is a classification technique for stream macroinvertebrates which involves the functional analysis of invertebrate feeding, based on morpho-behavioural mechanisms of food acquisition. A number of functional feeding groups of invertebrates occur in streams. These are Shredders, Collectors (or filterers), Scrapers (or grazers), and Predators. Shredders chew, mine, bore and gouge large particles such as leaves, sterns and branches which may be dead or alive. Filterers filter particulate matter, alive or dead, from the water. Collectors again feed on small particulate matter but gather the fine detritus off the sediment or other surfaces rather than from the open water. Grazers graze and scrape the periphyton off other surfaces. Predators are subdivided into engulfers, which eat the whole prey item swallowing it whole or by chewing, and piercers, which pierce the prey and suck fluids out. Food sources vary along the length of a river. Narrow upland streams, for example, rely heavily on allochthonous leaf debris (known as CPOM or Coarse Particulate Organic Matter) which can be used by shredders. In downstream areas, the fine debris of demolished leaves (known as FPOM or Fine particulate Organic Matter) will support collectors. Changes in functional groups reflect changes in food sources, nutrient processing and energy flow in the river system. Human influences on a river can dramatically alter food sources in turn affect the trophic groups. This method of analyses was therefore used as it provides a high resolution insight into the ecology of a river and has the ability to detect more subtle changes in community structure than would be apparent from biotic indices. 2.2 Sediment Sampling A sediment sample was also obtained for analyses at each of the six sites using a hand held grab. Three sub-samples were taken and combined into a composite sample for each site. Each sub-sample was taken from undisturbed relatively homogeneous sediment deposits at the site. Each sample was placed into a mixing bowl and large objects such as sticks, leaves or stones, etc. were removed as necessary. The sample was then stirred thoroughly with a mixing spoon to homogenize. The sample was then placed into a glass sample jar and delivered to the lab (Alcontrol Geochem Ltd.) for analysis. During sampling appropriate measures to prevent contamination from other sources was undertaken, and all sampling equipment had been cleaned thoroughly in advance.

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2.3 Habitat Survey Physical habitat assessments were undertaken at the six biological sampling sites. Habitat has a key influence on the macroinvertebrate communities, which occur in rivers and streams. The physical habitats of study sites were assessed in relation to macroinvertebrates using a method given by Barbour and Stribling (1991). A table showing how habitats are assessed using this method is provided in Appendix 2. This method assesses habitat parameters and rates each parameter as optimal, sub-optimal, marginal or poor (scores 5, 10, 15 and 20 respectively). The scores for each parameter are then added up to give an overall habitat score. 2.4 Other WQ parameters During the current survey Conductivity (µs cm-1), Water Temperature (oC), and Dissolved Oxygen (mg l-1 and % Saturation) were measured using on-site using portable meters.

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3 RESULTS 3.1 Physical Habitat The physical habitat characteristics of the six sites assessed during the November 2006 survey are presented in Table 2. Wetted width and mean depth ranged from 1m to 12m and 35cm to 100cm respectively at the six sites. In Figure 2, the substrate composition at the six sites investigated is presented. Substrates at all sites were dominated by cobbles and gravel. Fine substrate composition ranged from 5% to 15% at the six sites. The highest proportion of fine substrate was found at Site N2 (Glide, Receptor). This site was located immediately upstream of an old mill system so increased sedimentation would be expected in this area. In Table 3 the physical habitat assessment of the six sites for their suitability for macroinvertebrate production is presented. All sites were rated as being sub-optimal habitats for macroinvertebrate production. 3.2 Temperature, Conductivity and Dissolved Oxygen Table 4 presents the results of the November 2006 on-site water quality assessments. Dissolved oxygen was present at saturated levels except at Sites N4 (Control, Pool) and N5 (Control, Glide) were the levels was 85.5% (9.71 mg/l). These are considered to be slightly depressed levels and are indicative of at least slightly polluted conditions. These two sites were located upstream of the Irish Cement outfall so would not have been affected by the discharge. 3.3 Sediment PSD The results of the particle size distribution analyses of fine sediments sampled at the six survey sites during November 2006 are presented in Table 5. Receptor sites N1, N2 and N3 were all classified as having grey sandy, slightly gravelly, silt/clay. Site N4 (Pool, Control) was classified as having grey/black sandy, slightly gravelly, silt/clay. Site N5 (Glide, Control) was classified as having grey sandy, slightly gravelly, silt/clay material similar to the receptor sites, while Site N6 was classified as having grey slightly clayey/silty very sandy gravel. The fine sediments at all sites were generally similar and dominated by grey sandy, slightly gravelly, silt/clay. There was however some differences between the samples at receptor and control pool sites. One of these differences was related to the sediments sampled from the control glide site having a darker colour than those obtained from the receptor glide site. However, despite the slight difference in sediment colour the particle size distribution of sediments from both glide sites was almost identical. There were also differences however between the two riffle samples. The sediment sample from the control riffle sample was dominated by sandy gravel while the sample from the receptor site was dominated by silt/clay. The variation between the fine sediments at the two sites is likely to have resulted from hydraulic differences between the two sites. The control site was located on the main channel of the River Nanny and is subjected to the full erosive power of the river. However, the receptor site is located downstream of an old mill complex on one of two distributary channels. Reduced erosion on this section of river can explain the dominance of finer substrates at this site. Overall, there is no evidence from the current sediment survey that suggests the discharge from the Irish Cement facility is having any significant impact on the composition or abundance of sediments in downstream habitats. The River Nanny is significantly silted both upstream and downstream of the discharge as a result of background organic pollution levels in the catchment. Even at the control riffle site, which was dominated by sandy gravel, significant siltation has occurred - during the survey a large plume of silt extended downstream during the kick-sampling highlighting the degraded conditions in this part of the river.

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3.4 Macroinvertebrate Diversity and Abundance Table 6 presents the schedule of results of the on-site macroinvertebrate survey at the six survey sites on the River Nanny during November 2006. Macroinvertebrate diversity and abundance at each of the six sampling sites is illustrated in Figure 3. Overall a total of 835 macroinvertebrates comprising 32 families and over 45 species were identified. The number of families recorded at each site ranged from 10 families at the receptor glide to 20 families at the control pool. A total of 11 and 13 families were respectively recorded at receptor and control sites. The highest number of individuals were recorded at the control sites (n=559). A total of 276 individual macroinvertebrates were recorded at the receptor sites. A total of 113 and 198 individual macroinvertebrates were recorded at receptor riffle and control riffle sites respectively. The diversity and abundance levels recorded were considered to be typical of an organically polluted lowland Irish River. The fauna was dominated by pollution tolerant organisms and no invertebrates of any notable status were recorded. The differences in the number of families and individuals recorded between upstream and downstream sites derive mainly from the results obtained in the receptor and control glide sites. These sites differed physically in terms of wetted width and depth. The receptor site was also located immediately upstream of the old mill site so flows were more sluggish here than at the control site. It is thought that these physical differences at the site coupled with slight differences in sampling effort due to the greater depths at Site 2 explain the reduced numbers of macroinvertebrates obtained at this site. 3.5 Biological Water Quality The biological water quality evaluations for the six survey sites on the River Nanny are given in Table 7. Table 8 presents the classification of macroinvertebrate species recorded at each site in terms of their pollution sensitivity (EPA methods). Figure 4 illustrates the variation of the BMWP Score, Trent Biotic Index and Chandler Biotic Index at the six survey sites, while Figure 5 shows the percentage occurrences of macroinvertebrate species of differing pollution sensitivity at the sites investigated. The results of this investigation again highlight the degraded water quality of the River Nanny. All the receptor sites were rated as being moderately polluted (Q3) under the EPA Q-rating system with the control sites ranging from seriously polluted (Q2) to moderately polluted (Q3). The BMWP index rated sites upstream and downstream as ranging from Poor to Good, with the Chandler index rating the receptor sites as doubtful to clean, and the control sites as fairly clean to clean. The BMWP and Chandler scores are strongly influenced by the reduced diversity of invertebrates recorded at the receptor glide site. Overall, the results confirm that biological water quality in the River Nanny is the same upstream and downstream of the Irish Cement discharge. The Q-value ratings for control and receptor riffles were identical; Q3 Moderately Polluted. Indeed, the BMWP score for the receptor riffle (9.27) was higher than that at the control riffle (82.3). The Chandler index obtained for receptor and control riffles was the same (930). Likewise, the Trent Biotic index for both riffle sites was the same (7). 3.6 Functional Groups A summary of the Functional Group Analyses of macroinvertebrate species recorded at each site is provided in Table 9. Figure 6 shows the percentage occurrences of macroinvertebrate functional groups at each of the study sites. Figure 7 and 8 respectively show the overall classification of macroinvertebrate species present in terms of their pollution sensitivity (EPA methods), and the overall Functional Group Analyses of macroinvertebrates collected from

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receptor and control sites sampled. Table 10 presents the functional group characteristics of the six survey sites. The study section of the River Nanny is a sub-optimal habitat for macro-invertebrates and is degraded biologically due to water pollution. The macroinvertebrate community present is dominated by the invertebrates that specialise in the consumption of settled Coarse Particulate Organic Matter (CPOM) and Fine Particulate Organic Matter (FPOM), known respectively as collectors and shredders. The CPOM and FPOM present in this stretch of river derives primarily from upstream allochthonous inputs4 such as leaves from trees and pollution sources and the ecosystem is highly heterotrophic. The total absence of pollution sensitive grazers, such as the Heptageniidae mayfly larvae, is a reflection of the poor water quality and supporting habitats at all of the sites investigated. The presence of predators in such high numbers at both receptor (34.4%) and control (32.5%) locations suggest that the ecology of the River Nanny in the study area is under considerable stress. Table 11 presents a juvenile salmonid (salmon and trout) food index which assesses the likelihood of a predictable invertebrate food supply being available for juvenile salmonids at the six survey sites. The results predict that an unpredictable supply of autochothonous5 food available at all sites investigated, with the exception of the riffle habitat located downstream of the Irish Cement discharge point. Overall, the poor supporting habitats, degraded water quality and limited food supply for salmonids along the study stretch of river have significant consequences for the fishery status of the River Nanny. Table 2 Physical characteristics at the six November 2006 sampling sites. Parameter N1 N2 N3 N4 N5 N6 Habitat Category Riffle Glide Pool Pool Glide Riffle

Sample type Receptor Receptor Receptor Control Control Control

Wetted width (m) 7 12 10 6 7 7 Bank height (cm) 130 130 120 100 180 55 Bank cover (%) 100 100 100 100 100 100 Bank slope (degrees) 50 65 70 80 65 40 Canopy cover (%) 5 5 5 5 0 0 Flow (cm/s) 40 10 15 15 20 40 Riffle (%) 40 0 0 0 5 60 Glide (%) 30 55 20 20 0 30 Pool (%) 30 95 80 80 100 10 Mean depth (cm) 20 100 60 50 60 35 Maximum depth (cm) 35 150 100 80 100 60 Rock (%) 10 20 40 30 15 5 Cobble (%) 35 50 35 35 20 15 Gravel (%) 50 15 15 30 55 75 Fine (%) 5 15 10 5 10 5 In-stream vegetation (%) 15 15 20 30 5 30

4 Organic matter that originates from the outside the system. 5 Originating from within the system.

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0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Receptor(Riffle)

Receptor(Glide)

Receptor(Pool)

Control(Pool)

Control(Glide)

Control(Riffle)

% C

ompo

sitio

n

Fine (%)

Gravel (%)

Cobble (%)

Rock (%)

Figure 2 Substrate composition at the six sites investigated on the River Nanny during the

November 2006 survey. Table 3 Physical habitat assessment of the six sites for their suitability for

macroinvertebrate production (adapted from Barbour and Stribling, 1991). Site N1 N2 N3 N4 N5 N6

Habitat Category Riffle Glide Pool Pool Glide Riffle


Bottom substrate

20 20 15 15 15 15

Habitat complexity

15 15 10 10 10 15

Pool quality 10 10 10 10 10 10

Bank stability 20 20 20 20 20 20

Bank protection 20 20 20 20 20 20

Canopy 5 10 10 10 10 5

Score 90 95 85 85 85 85 Assessment Suboptimal Suboptimal Suboptimal Suboptimal Suboptimal Suboptimal

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Table 4 Results of the November 2006 on-site water quality assessments. Parameter N1 N2 N3 N4 N5 N6 Date sampled 12-Nov-

06 12-Nov-06

12-Nov-06

11-Nov-06

11-Nov-06

11-Nov-06

Habitat Category Riffle Glide Pool Pool Glide Riffle


Conductivity (µS) 741 740 739 740 749 749 Temperature (ºC) 8.7 8.7 8.7 8.7 9.3 8.8 Dissolved Oxygen (%) 103.4 103 102.8 85.5 85.5 100.29 Dissolved Oxygen (mg/l) 12.01 12.01 10.2 9.71 9.71 11.59

Table 5 Results of the Particle Size Distribution Analyses of fine sediments sampled at

the six survey sites.

Samples Category Particle Size (mm) N1 N2 N3 N4 N6 N5

Habitat type Riffle Glide Pool Riffle Glide Pool Sample type Receptor Receptor Receptor Control Control Control

% Passing % Passing % Passing % Passing % Passing % Passing Cobbles 75 100 100 100 100 100 100 Gravel 63 100 100 100 100 100 100 50 100 100 100 100 100 100 37.5 100 100 100 100 100 100 28 100 100 100 100 100 100 20 100 100 100 100 100 100 14 100 100 100 93 100 100 10 100 100 100 82 100 100 6.3 92.6 99.7 99.2 69 100 99.6 5 91.7 99.7 98 58 99.6 99.5 3.35 91 98.8 96.5 41 99.6 99 Sand 2 88 97.3 93.3 25 98.7 98 1.18 84.5 95.4 88.9 16 96.4 96.6 0.6 78.2 91.4 81.8 10 91.4 93.3 0.425 75.3 87.8 77.4 9 89 89.2 0.3 71 81 71.5 8 85.3 82.6 0.15 52 63.2 62.6 6 77.2 68.3 Silt/Clay 0.063 49.1 46.2 50.8 4 65.5 51.4 0.035 42.8 44.1 42.6 - 56.1 44.3 0.025 38.7 41.9 40.7 - 49.4 39.7 0.016 35 37.4 38.8 - 44 36.8 0.01 27.4 34.3 31.5 - 35.5 30 0.007 23.2 31.1 27.8 - 31.7 26.5 0.004 20.6 27.5 24.2 - 27.3 23.6 0.002 12.2 19.6 14.8 - 16.2 14.2

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Table 6 Results of the on-site macroinvertebrate survey at the six survey sites on the River Nanny during November 2006. Pollution sensitivity

group Functional group Site N1 Site N2 Site N3 Site N4 Site N5 Site N6

Habitat Category Riffle Glide Pool Pool Glide Riffle Sample type Receptor Receptor Receptor Control Control Control SEGMENTED WORMS (Annelida, Clitellata) Oligochaeta E Gathering

Collector 4 1

Sludge Worms (Family Tubificidae) E Shredder 12 1 7 16 29 LEECHES (Hirudinea) Family Glossiphoniidae Helobdella stagnalis D Predator 2 Glossiphonia complanata D Predator 1 1 6 5 Batrocobdella paludosa D Predator 1 1 8 Family Erpobdellidae Erpobdella octoculata D Predator 8 15 19 SNAILS (Mollusca, Gastropoda) Family Lymnaeidae Wandering Snail (Lymnaea peregra) D Shredder 1 1 1 Great Pond Snail (Lymnaea stagnalis) C Shredder 1 Family Planorbiidae Keeled ramshorn Snail (Planorbis carinatus) C Grazer 1 2 1 6 2 Planorbis contortus C Grazer 4 Family Ancylidae River limpet (Ancylus fluviatilis) C Shredder 1 4 Family Valvatidae Valve Snail (Valvata piscinalis) C Shredder 1 1 2 Family Hydrobiidae Taylor’s Spire Shell (Bythinella scholtzi) C Shredder 1 Common Bithynia (Bithynia tentaculata) C Shredder 2 8 7 3 Family Physidae Bladder Snail (Physa fontinalis) D Shredder 1 4 5 MUSSELS (Mollucsa, Lamellibranchiata) Orb/ Pea Mussels (Family Sphaeridae) D Filtering Collector 20 4 24 15 CRUSTACEANS (Crustacea, Malostraca)

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Pollution sensitivity group

Functional group Site N1 Site N2 Site N3 Site N4 Site N5 Site N6

Habitat Category Riffle Glide Pool Pool Glide Riffle Sample type Receptor Receptor Receptor Control Control Control Amphipods (Amphipoda, Gammaridae) Freshwater Shrimp (Gammarus duebeni) C Shredder 1 3 Freshwater Shrimp (Gammarus pulex) C Shredder 1 1 Isopods (Order Isopoda, Family Asellidae) Water Slater or Hog Louse (Asellus aquaticus) D Shredder 13 24 12 25 67 50 MAYFLIES (Uniramia, Ephemeroptera) Family Baetidae Baetis rhodani C Gathering

Collector 8 1 4

Family Caenidae Caenis robusta. C Gathering

Collector 1 6 12 11

CASELESS CADDIS FLIES (Trichoptera) Grey flag (Family Hydropsychidae) Hydropsyche siltala C Filtering Collector 4 Hydropsyche pellucidula C Filtering Collector 14 3 Hydropsyche angustipennis C Filtering Collector 16 18 Trumpet-net Caddisflies (Family Polycentropodidae) Polycentropus kingi C Filtering Collector 1 1 Family Psychomyiidae Tinodes rostocki C Filtering Collector 1 Family Rhyacophilidae Rhyacophila dorsalis C Predator 8 CASED CADDIS FLIES (Tricoptera) Family Limnephilidae Micropterna sequax B Shredder 4 Micropterna lateralis B Shredder 3 Goerid Caddisflies (Family Goeridae) Silo nigricornis B Scraper 1 1 Family Glossosomatidae Indeterminate sp.(Undergoing metamorphosis) B Gathering

Collector 6

Family Sericostomatidae

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Pollution sensitivity group

Functional group Site N1 Site N2 Site N3 Site N4 Site N5 Site N6

Habitat Category Riffle Glide Pool Pool Glide Riffle Sample type Receptor Receptor Receptor Control Control Control Sericostoma personatum B Shredder 2 4 Family Phryganeidae Great Red Sedge (Phryganea bipunctata) B Shredder 2 2 3 TRUE FLIES (Diptera) Reed Smuts (Family Simulidae) C Filtering Collector 1 28 1 Family Chironomidae Midge/Buzzer (Chironomous sp.) E Filtering Collector 1 3 1 Cranefly larvae (Family Tipulidae) C Predator 3 1 4 Family Muscidae C Predator 3 BEETLES (Coleoptera) Riffle Beetle (Family Elmidae, larvae) C Predator 4 Diving Beetle (Family Dysticidae, larvae) C Predator 3 1 1 1 Marsh beetle (Family Limnichidae, larvae) C Scraper 1 3 BUGS (Hemiptera) Lesser Water Boatman, (Family Corixidae) Sigara dorsalis C Predator 41 10 70 42 Callicorixa praeusta C Predator 2 1 2 ALDERFLIES (Megaloptera) Alderfly larvae (Family Sialidae) D Predator 10 1 2

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Table 7 Biological water quality at the six survey sites on the River Nanny during November 2006.

Site Number Site 1 Site 2 Site 3 Site 4 Site 5 Site 6 Habitat Category Riffle Glide Pool Pool Glide Riffle Sample type Receptor Receptor Receptor Control Control Control Total Number of Individuals (N)

113 79 84 119 242 198

Number of Families 11 10 13 20 15 13 Q-Value Q3 Q3 Q2-3 Q3 Q2 Q2-3 Q-Value Description Moderately

Polluted Moderately

Polluted Moderately

Polluted Moderately

Polluted Moderately

Polluted Moderately

Polluted BMWP Score 92.7 30.4 52.5 64.8 57.7 82.3 Trent Biotic Index 7 4 6 6 6 7 Chandler Biotic Index 930 318 560 481 563 930

0

50

100

150

200

250

300

Receptor(Riffle)

Receptor(Glide)

Receptor(Pool)

Control(Pool)

Control(Glide)

Control(Riffle)

Num

ber (

N)

0

5

10

15

20

25Individuals (N)Families (N)

Figure 3 Macroinvertebrate diversity and abundance at each of the six sampling sites.

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Figure 4 Variation of the BMWP Score, Trent Biotic Index and Chandler Biotic Index at the

six survey sites.

0

10

20

30

40

50

60

70

80

90

100

Receptor (Rif f le) Receptor (Glide) Receptor (Pool) Control (Pool) Control (Glide) Control (Riff le)

Inde

x

BMWP Score

0

1

2

3

4

5

6

7

8

Receptor(Riffle)

Receptor(Glide)

Receptor(Pool)

Control (Pool) Control (Glide) Control (Riffle)

Inde

x

Trent Biotic Index

0100200300400500600700800900

1000

Receptor(Riffle)

Receptor(Glide)

Receptor(Pool)

Control (Pool) Control (Glide) Control (Riffle)

Inde

x

Chandler Biotic Index

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Table 8 Classification of macroinvertebrate species recorded at each site in terms of their pollution sensitivity (EPA methods).

Pollution Indicator Group Site 1 Site 2 Site 3 Site 4 Site 5 Site 6

Group B (Less Sensitive) 7 2 2 5 12 Group C (Tolerant) 66 49 27 82 107 54 Group D (Very Tolerant) 24 26 45 31 119 102 Group E (Most Tolerant) 16 2 10 1 16 29 Total 113 79 84 119 242 198 Table 9 Functional Group Analyses of macroinvertebrate species recorded at each site. Functional Group Site 1 Site 2 Site 3 Site 4 Site 5 Site 6

Filtering Collector 37 1 23 6 52 37 Gathering Collectors 18 1 6 13 16 Grazer 1 2 1 10 2 Predator 25 46 24 75 71 36 Scraper 2 4 Shredder 31 31 34 31 96 103 Total 113 79 84 119 242 198 Table 10 Functional Group characteristics of the six survey sites. Dominant FFG (%)

(Dominant group and its mean relative %); P/R (ratio of Scrapers to total collectors + shredders, a surrogate for ratio of gross primary production to community respiration); Heterotrophy vs Autotrophy based on a P/R threshold of > 0.75 = autotrophic) (Rabenil et al, 2005).

Site Type Location Dominant FFG (%) P/R Heterotrophy Vs

Autotrophy N1 Riffle Receptor Filtering Collector (52.7%) 0.023 Highly Heterotrophic N2 Glide Receptor Predator (58.2%) - Highly Heterotrophic N3 Pool Receptor Shredder (40.4%) - Highly Heterotrophic N4 Pool Control Predator (63.0%) - Highly Heterotrophic N5 Glide Control Shredder (39.6%) - Highly Heterotrophic N6 Riffle Control Shredder (52.0%) 0.026 Highly Heterotrophic

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0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Receptor(Riffle)

Receptor(Glide)

Receptor(Pool)

Control(Pool)

Control(Glide)

Control(Riffle)

Perc

enta

ge

Group E (Most Tolerant)Group D (Very Tolerant)Group C (Tolerant)Group B (Less Sensitive)

Figure 5 Percentage occurrences of macroinvertebrate species of differing pollution

sensitivity (EPA methods).

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Receptor(Riffle)

Receptor(Glide)

Receptor(Pool)

Control(Pool)

Control(Glide)

Control(Riffle)

Perc

enta

ge

ShredderScraperPredatorGrazer

Gathering CollectorsFiltering Collector

Figure 6 Percentage occurrences of macroinvertebrate functional groups at each of the

study sites.

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Receptor, n=276

Group D (Very Tolerant)34%

Group C (Tolerant)52%

Group B (Less Sensitive)

4%Group E (Most Tolerant)10%


Group C (Tolerant)Group D (Very Tolerant)

Group E (Most Tolerant)

Control, n=559

Group E (Most Tolerant)8%


3%

Group C (Tolerant)44%

Group D (Very Tolerant)45%

Group B (Less Sensitive)Group C (Tolerant)

Group D (Very Tolerant)

Group E (Most Tolerant)

Figure 7 Overall classification of macroinvertebrate species present in terms of their

pollution sensitivity (EPA methods).

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Receptor, n=276

Predator34%

Scraper1%

Shredder35%

Filtering Collector22%

Gathering Collectors7%

Grazer1%

Filtering Collector

Gathering Collectors

Grazer

Predator

Scraper

Shredder

Control, n=559

Shredder41%

Scraper1%

Predator33%

Grazer2%

Gathering Collectors6%

Filtering Collector17%

Filtering Collector

Gathering Collectors

Grazer

Predator

ScraperShredder

Figure 8 Overall Functional Group Analyses of macroinvertebrates collected from receptor

and control sites sampled on the River Nanny during November 2006.

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Table 11 Juvenile salmonid food index. Predictable invertebrate supply is the ratio of behavioral drifters (filtering and gathering collectors) to accidental drifters (scrapers, shredders and predators). Based on a threshold of >0.50 for predictable supply (Rabenil et al, 2005).

Site Type Location Behavioral

drifters/accidental drifters

Predictable Vs Unpredictable

N1 Riffle Receptor 0.95 Predictable N2 Glide Receptor 0.01 Unpredictable N3 Pool Receptor 0.41 Unpredictable N4 Pool Control 0.11 Unpredictable N5 Glide Control 0.38 Unpredictable N6 Riffle Control 0.37 Unpredictable 4 SUMMARY AND CONCLUSIONS

• The River Nanny has a long history of pollution. In the most recently published EPA survey, a total of 18% of the river channel of the River Nanny was rated as being Class C or Moderately Polluted at that time, with 3% of the channel rated as being Class D - Seriously Polluted. The main source of pollution in the catchment is thought to be agricultural activities.

• Following a complaint from the Eastern Regional Fisheries Board in January 2006, it was

decided to undertake a detailed study of the local areas of the River Nanny to assess the impacts, if any, that the ICL discharge was having on aquatic ecology. The macroinvertebrate community and sediments at six sites located within 500m upstream and downstream of the outflow were investigated during November 2006.

• Substrates at all sites were found to be dominated by cobbles and gravel. Fine substrate

composition ranged from 5% to 15% at the six sites. The fine sediments at all sites were generally similar and dominated by grey sandy, slightly gravelly, silt/clay. It was confirmed that the River Nanny is significantly silted both upstream and downstream of the Irish Cement discharge as a result of background organic pollution levels in the catchment.

• The diversity and abundance levels of macroinvertebrates recorded at all sites were

considered to be typical of an organically polluted lowland Irish river. The fauna was dominated by pollution tolerant organisms and no invertebrates of any notable status were recorded.

• Biological water quality indices obtained from all sites highlighted the degraded water

quality of the River Nanny. All the sites located downstream of the Irish cement discharge point were rated as being moderately polluted (Q3) under the EPA Q-rating system with the sites located upstream of the discharge point ranging from seriously polluted (Q2) to moderately polluted (Q3). Overall, there is no evidence from the current study that suggests the discharge from the Irish Cement facility is having any significant impact on the biological water quality of the downstream areas surveyed.

• The macroinvertebrate community present is dominated by the invertebrates that

specialise in the consumption of organic matter deriving from external inputs such as leaves and pollution sources. The total absence of pollution sensitive grazers, such as

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the Heptageniidae mayfly larvae, is a reflection of the poor water quality and supporting habitats at all of the sites investigated.

• Predator invertebrate groups were present in very high numbers at both receptor and

control locations. This confirms that the ecology of the River Nanny in the study area is under considerable stress. The results suggest that an unpredictable supply of invertebrate food is available for juvenile trout at all sites investigated, threatening the rivers status as a fishery.

• Overall, it is concluded that this area of the River Nanny is in a moderately polluted state

and under considerable ecological stress. The results confirm that macroinvertebrate communities, biological water quality and sediment levels in the River Nanny are the same upstream and downstream of the Irish Cement discharge point.

5 RECOMMENDATIONS

• Irish Cement Ltd. should continue monitoring chemical water quality upstream and downstream of their outfall site on the River Nanny so as to understand on an ongoing basis the river quality upstream and downstream of the outfall. The biological monitoring initiated during the current survey should be continued intermittently to ensure that the discharge continues to have a neutral impact on the aquatic ecology of local areas of the River Nanny.

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Plate 1 Site N1: Receptor riffle site downstream of the weir near the footbridge (NOS grid ref O07976 69254).

Plate 2 Site N2: Receptor pool site downstream of the outfall (NOS grid ref O07865 69186).

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Plate 3 Site N3: Receptor glide site (NOS grid ref O07783 69171).

Plate 4 Site N4: Control pool site (NOS grid ref O07589 69186).

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Plate 5 Site N5: Control glide site (NOS grid ref O07537 69165).

Plate 6 Control riffle site located immediately downstream of the minor road bridge to Bellewstown O07349 69166).

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REFERENCES Armitage, P. D.; Moss, D.; Wright, J. F. and Furse, M. T. (1983) The performance of a new

biological water quality score system based on macroinvertebrates over a wide range of unpolluted running-water sites. Water Res., 17 (3), 333-347.

Barbour, M.T. and J.B. Stribling. 1991. Use of Habitat Assessment in Evaluating the Biological

Integrity of StreamCommunities. Biological Criteria: Research and Regulation: 25-38. EPA-440/5-91-005. Washington, DC: Office of Water, US EPA

Bass J.(1998) Last-Instar Larvae and Pupae of the Simuliidae of Britain and Ireland: a Key with

Brief Ecological Notes 1998, 104pp. Chandler, J.R. (1970) A Biological Approach to water Quality Management. Water Poll. Cont.

69:415-421. Cranston P.S. (1982) A Key to the Larvae of the British Orthocladiinae (Chironomidae) 1982,

152pp + 1 plate. Disney R.H.L. (1999) British Dixidae (Meniscus Midges) and Thaumaleidae (Trickle Midges):

Keys with Ecological Notes 1999, 128pp. EA. (2003) River Habitat Survey in Britain and Ireland: Field Survey Guidance Manual. River

Habitat Survey Manual: 2003 version, Environment Agency, 136 pp Edington J.M. & A.G. Hildrew (1995) A Revised Key to the Caseless Caddis Larvae of the British

Isles, with Notes on their Ecology 1995, 134pp. Elliott J.M. & K.H. Mann (1979) A Key to the British Freshwater Leeches, with Notes on their Life

Cycles and Ecology. 1979 (reprinted 1998), 72pp. Elliott J.M. & U.H. Humpesch (1988) A Key to the Larvae of the British Ephemeroptera, with

Notes on their Ecology1983, 101pp + 1 plate. Gledhill, T., D.W. Sutcliffe & W.D. Williams (1993) British Freshwater Crustacea Malacostraca: a

Key with Ecological Notes 1993, 176pp. Hynes H.B.N. (1977) A Key to the Adults and Nymphs of the British Stoneflies (Plecoptera), with

Notes on their Ecology and Distribution. Third edition, 1977 (reprinted 1993), 92pp. Macan T.T. (1994) A Key to the British Fresh- and Brackish-Water Gastropods, with Notes on

their EcologyFourth edition, 1977 (reprinted 1994), 46pp. McGarrigle, M.L., Bowman, J.J., Clabby, K.J., Lucy, P., Cunningham, M., MacCarthaigh, M.,

Keegan, M., Cantrell, B., Lehane, M., Clenaghan, C., Toner, P.F. (2002) Water Quality in Ireland 1998-2000. Second (Revised) Edition. Environmental Protection Agency.

Ecofact (2005) Biological Assessment of Kentstown Stream and Nanny River. Annual Report

2004. Greenstar Knockharley Landfill Site (146-1). Ecofact (2006) Biological Assessment of Kentstown Stream and Nanny River. Annual Report

2005. Greenstar Knockharley Landfill Site (146-1).

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Rabenil, C.F.,, Doisy, K.E. and Zweig, L.D. (2005) Stream invertebrate community functional responses to deposited sediment Journal of Aquatic Sciences. 67(4):395-402.

Savage A.A. (1989) Adults of the British Aquatic Hemiptera Heteroptera: a Key with Ecological Notes1989, 173pp.

Savage A.A. (1999) Keys to the Larvae of British Corixidae1999, 56pp. Wallace, I.D., B. Wallace & G.N. Philipson (2003) Keys to the Case-bearing Caddis Larvae of

Britain and Ireland 2003, 259pp. Walley W.J. and Hawkes H.A. (1997) A computer-based development of the Biological

Monitoring Working Party score system incorporating abundance rating, biotope type and indicator value. Water Research, 31 (2), 201-210.

Woodiwiss, F. (1960) Trent Biotic Index of Pollution. Second Quinquennial Abstract of Statistics

Relating to the Trent Watershed. Trent River Authority. England.

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Appendix 1 EPA Water Quality Data for the River Nanny. Table A1.1 Water quality in the River Nanny along with overall water quality in hydrometric area 8 (adapted from Toner et al, 2005). Catchment Class A Class B Class C Class D Total (km) Nanny (km) 0 7 18.0 3.0 28.0 Nanny (%) 0.0% 25.0% 64.3% 10.7% Hydrometric Area 8 (km)

11.0 28.0 80.0 3.0 122

Hydrometric Area 8 (%)

9 23 66 2

Table A1.2 Biological Water Quality in the River Nanny (1971-2005). (from Toner et al, 2005 and unpublished EPA data for 2005). Sampling Stations Biological Quality Ratings (Q Values) No. 1971 1974 1978 1980 1982 1986 1988 1991 1996 1998 2001 2005 0040 - - - - - - - - 2-3 2-3 2 2-3 0090 - - - - - - 2-3 2-3 - - 0100 - - - - - - - - - - 0110 - - - - - - 3 3 3 2-3 2-3 2-3 0200 - - - 3-4 2-3 3 3-4 3-4 - - 0280 - - - - - - 3 3 3 3-4 3-4 4 0300 5 4-5 3-4 3 1-2 2 - 3 - - 0400 4-5 3-4 4 3-4 4 3-4 2-3 3 - - 0500 3 1-2 3 3 3-4 3-4 3 3-4 3 3-4 3-4 3-4 0600 - - - 3-4 3 3-4 3 - - - 0650 - - - - - 3-4 3-4 3-4 4 4 3 0700 4 3-4 3 3 3-4 3-4 3-4 3 3-4 3-4 3 3-4 No. Location No. Location 0040 Folistown Br 0300 Bridge near Deenes 0090 East Bridge, S. of Brownstown 0400 Upstream Bridge, Duleek 0100 West Br Kentstown 0500 Bridge N.E. of Bellewstown Ho 0110 East Bridge, Kentstown 0600 Beaumont Bridge 0200 Br just S. of Balrath X-Roads 0650 Dardistown Bridge 0280 Bridge d/s Nanny Bridge 0700 Bridge at Julianstown

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Appendix 2 Biotic Indices. Table A2.1 Biological River Quality Classification (Q-Values). ‘Q’ value Community

Diversity Water Quality

Condition* Status Quality

Q5 High Good Satisfactory Unpolluted Class A Q4 Reduced Fair Satisfactory Unpolluted Class A Q3 Much Reduced Doubtful Unsatisfactory Slightly Polluted Class B Q2 Low Poor Unsatisfactory Moderately Polluted Class C Q1 Very Low Bad Unsatisfactory Seriously Polluted Class D * ‘Condition’ refers to the likelihood of interference with beneficial or potential beneficial use. Table A2.2 BMWP Scoring System. BMWP score Category Interpretation 0-10 Very poor Heavily polluted 11-40 Poor Polluted or impacted 41-70 Moderate Moderately impacted 71-100 Good Clean but slightly impacted >100 Very good Unpolluted, unimpacted Table A2.3 Trent Biotic Index. Trent Index BOD (mg/l) Status 9-10 2 Very Clean 7-10 2-3 Clean 6-8 2-3 Clean 5-6 3-5 Fairly Clean 3-5 5-10 Doubtful 2-4 5-10 Doubtful 1-3 10+ Bad 0-1 10+ Bad

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Table A2.4 Physical habitat assessment of streams for their suitability for macroinvertebrate production (adapted from Barbour and Stribling, 1991).

Optimal Suboptimal Marginal Poor

Score 20 15 10 5

Bottom substrate

More than 60% of bottom is gravel, cobble, and boulders. Even mix of substratum size classes.

30-60% of bottom is cobble or boulder substrata. Substrate may be dominated by one size class.

10-30% of substrata consists of large materials. Silt or sand accounts for 70-90% of bottom.

Substrate dominated by silt and sand. Gravel, cobble and larger substrate sizes <10%.

Habitat complexity

A variety of types and sizes of material form a diverse habitat.

Structural types or sizes of material are less than optimum but adequate cover still provided.

Habitat dominated by only one or two structural components. Amount of cover is limited.

Monotonous habitat with little diversity. Silt and sand dominate and reduce habitat diversity and complexity.

Pool quality 25% of the pools are as wide or wider than the mean stream width and area >1m deep.

<5% of the pools are >1m deep and wider than the mean stream width.

<1% of the pools are >1m deep and wider than the mean stream width. Pools present may be very deep or very shallow. Variety of pools or quality is fair.

Majority of pools are small and shallow. Pools may be absent.

Bank stability Little evidence of past bank failure and little potential for future mass wasting into channel.

Infrequent or very small slides. Low future potential of slides.

Mass wasting moderate in frequency and size. Raw spots eroded during high floods.

Frequent or large slides. Banks unstable and contributing sediment to the stream.

Bank protection Over 80% of streambank surfaces are covered by vegetation, boulders, bedrock, or other stable materials.

50-80% of the streambanks covered with vegetation, cobble, or larger material.

25-50% of the streambank is covered by vegetation.

<25% of the streambank is covered by vegetation or stable materials.

Canopy Vegetation of various heights provides a mix of shade and filtering light to water surface.

Discontinuous vegetation provides areas of shade alternating with areas of full exposure. Or filtering shade occurs <6h/day.

Shading is complete and dense. Or filtering shade occurs <3h/day.

Water surface is exposed to full sun nearly all day long.

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Additional Information re: International Standard 1996-2 Part 2 Determination of

environmental noise levels

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Re: IPPC Application Form V1/07 – Table 1.7(i) - Ambient Noise Assessment In the Guidance Note for Noise in Relation to Schedule Activities, 2nd Edition (EPA) Par 3.2 “Rating Levels for Tonal and Impulsive Noise” it is stated that ISO 1996 -2(1987) provides that if the level in a one third octave band is 5 dB (or more) higher than the level in the two adjacent bands, then there is a potential for the sound to be penalised by the addition of 5-6 dB if the tonal components are clearly audible. ISO 1996 -2(1987) has been withdrawn and has been replaced by ISO 1996-2(2007). In Annex D “Objective method for assessing the audibility of tones in noise - Simplified method”, the level difference between adjacent one third octave bands is dependant on frequency as follows;

15 dB in the low frequency bands 25 Hz to 125 Hz 8 dB in the middle frequency bands 160 Hz to 400 Hz

5 dB in a frequency bands 500 Hz to 10,000 Hz

For these reasons, the methodology set out in Annex C of ISO 1996 -2(2007) “Objective method object for assessing the audibility of tones in noise- Reference method” was used. This method requires three steps

a. narrowband frequency analysis b. determination of the average sound pressure level of the tones and the

masking noise within the critical band around the tones c. calculation of the tonal audibility ∆Lta and adjustment K

for ∆Lta less than 4dB, K is equally zero dB

for ∆ Lta between 4 dB and 10 dB, K= ∆Lta -4 dB for ∆Lta greater than 10 dB, K= 6dB

An assessment using the Reference method in annex C ISO 1996 -2(2007) was carried out at six locations along the boundary and at N18 Synnotts. The narrowband spectra are attached. The ∆Lta and K values in dB are shown in the bottom left-hand corner of the plots. The following are the values of the K adjustments.

Location K dB N18 0.0 Entrance to head office 0.0 Entrance to employees car park 0.0 Main entrance 4.6 Entrance materials Weighbridge 0.9 North East off site 5.7 North of plant 0.0

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Eanna O’Kelly and Associates Client: Irish Cement Platin Consultant Acoustic Engineers Noise Source: Ambient Measurement Location: Outside Synnotts Data File: Test 02 Measurement Date: 29-June-2007

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Frequency Span: 1250 Hz Record Length: 341 ms Frequency Resolution: 2.930 Hz Noise Bandwidth: 4.395 Hz Centre Frequency: 629 Hz Window: Hanning Averaging: Exponential Average Spectra: 300 Average Time: 34.2 s Pre-Weighting: None High Pass Filter: 5 Hz Time: 00:32 Plant Audible: No ∆Lta: 0.0 dB K: 0.0 dB

Narrow Band Noise Spectrum

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Eanna O’Kelly and Associates Client: Irish Cement Platin Consultant Acoustic Engineers Noise Source: Ambient Measurement Location: Entrance to Head Office Data File: Test 03 Measurement Date: 29-June-2007

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Frequency Span: 1250 Hz Record Length: 341 ms Frequency Resolution: 2.930 Hz Noise Bandwidth: 4.395 Hz Centre Frequency: 629 Hz Window: Hanning Averaging: Exponential Average Spectra: 300 Average Time: 34.2 s Pre-Weighting: None High Pass Filter: 5 Hz Time: 00:36 Plant Audible: Yes ∆Lta: 0.0 dB K: 0.0 dB


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Eanna O’Kelly and Associates Client: Irish Cement Platin Consultant Acoustic Engineers Noise Source: Ambient Measurement Location: Entrance to Employees Car Park Data File: Test 05 Measurement Date: 29-June-2007

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Eanna O’Kelly and Associates Client: Irish Cement Platin Consultant Acoustic Engineers Noise Source: Ambient Measurement Location: Main Entrance Data File: Test 06 Measurement Date: 29-June-2007

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Eanna O’Kelly and Associates Client: Irish Cement Platin Consultant Acoustic Engineers Noise Source: Ambient Measurement Location: Entrance Materials Weighbridge Data File: Test 07 Measurement Date: 29-June-2007

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Frequency Span: 1250 Hz Record Length: 341 ms Frequency Resolution: 2.930 Hz Noise Bandwidth: 4.395 Hz Centre Frequency: 629 Hz Window: Hanning Averaging: Exponential Average Spectra: 300 Average Time: 34.2 s Pre-Weighting: None High Pass Filter: 5 Hz Time: 00:35 Plant Audible:Yes ∆Lta: 4.9 dB K: 0.9 dB


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Eanna O’Kelly and Associates Client: Irish Cement Platin Consultant Acoustic Engineers Noise Source: Ambient Measurement Location: North East of Site Data File: Test 08 Measurement Date: 29-June-2007

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Eanna O’Kelly and Associates Client: Irish Cement Platin Consultant Acoustic Engineers Noise Source: Ambient Measurement Location: North of Plant Data File: Test 09 Measurement Date: 29-June-2007

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Frequency Span: 1250 Hz Record Length: 341 ms Frequency Resolution: 2.930 Hz Noise Bandwidth: 4.395 Hz Centre Frequency: 629 Hz Window: Hanning Averaging: Exponential Average Spectra: 300 Average Time: 34.2 s Pre-Weighting: None High Pass Filter: 5 Hz Time: 00:36 Plant Audible: No ∆Lta: -2.4 dB K: 0.0 dB


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Eanna O’Kelly and Associates: Noise Survey at Irish Cement Ltd Platin Works Drogheda – Compliance with IPC Licence Noise Aspects

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EPA Export 25-07-2013:22:12:37

Review of Annual Noise Surveys for IPC Licence No. 268 Compliance (1996 to 2002)

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Eanna O'Kelly B.E. M Acoustical Society of America Gavan O'Kelly B.Sc Applied Physics AMIOA Donat O'Kelly B.A. B.A.I.

Eanna O’Kelly and Associates

Consultant Acoustic Engineers Date: 22nd August 2002 Ref: ICP 459

Phone: +353 (1) 8494500 Fax: +353 (1) 8494859 Mobile: 087 2430872 087 2310487 E-mail: [email protected]

Review of Annual Noise Surveys for IPC Licence No. 268 Compliance (1996 to 2002)

Report by: Eanna O'Kelly

24 Strand Street, Skerries, Co. Dublin.

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Review of Annual Noise surveys for IPC Licence No. 286 Compliance

(1996 to 2002)

1. Noise Limits The noise limits due to activities on site received at the nearest noise sensitive location are set out in pars 3.4.2(1), 8.3 and schedule 4(ii) of the licence. These limits are 57dBA for daytime, 08:00 to 22:00 hours, and 47dBA for night-time 22:00 to 08:00 hours, with a tolerance of +2dBA.

2. Noise Sensitive Locations

2.1 The nearest noise sensitive location is Mr.Currans house which is situated to

the north west at a distance of 220 metres from the boundary of the plant and at a distance of 440 metres from the acoustic centre of the plant, which is taken as being located between Kiln 1 and Kiln 2. There is a grain drying plant located behind Curran's house. The plant is owned by Mr.Curran. It is a significant source of noise particularly during and after harvest time. It may also operate at other times of the year. Unattended noise monitoring was carried out at this location outside the house for the years 1996, 1997, 1998 and 1999. On a number of occasions it was found to be unsuitable due to the presence of noise from the grain drying plant.

2.2 The next nearest noise sensitive location is Synnott's house located almost

due east of the plant at a distance of 350 metres from the boundary of the plant and 650 metres from the acoustic centre of the plant. Unattended noise monitoring was carried out at Synnotts for the years 2000, 2001 and 2002. There is no fixed mechanical plant which might give rise to noise in the vicinity of this house. For the year 2002 at the request of the E.P.A. unattended noise monitoring was carried out at two other houses, McKenna's and McGuinness's. These houses are situated to the south of the plant along the R152 regional road at a distance of 700 metres and 830 metres respectively from the acoustic centre of the plant. Noise due to road traffic dominates at both locations, particularly at McKenna's, the front façade of which is located 3 metres from the edge of the carriageway, and to a lesser extent at McGuinness's where the front façade is about 35 metres from the edge of the carriageway.

3. Interpretation and Methodology

3.1 The noise limits are set out in simplistic terms. There is no acoustic

parameter or measuring time interval specified. The reference interval is specified, daytime 08:00 to 22:00 hours, and night-time 22:00 to 08:00 hours. There is also no reference to the characteristics of the noise, e.g. absence of impulsive elements and that tones should not be clearly audible.

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3.2 International Standard 1996: "Acoustics - Description and measurement of environmental noise" - states that the equivalent continuous sound pressure level (LAeq,T) be generally used or other descriptors that may be deemed to be appropriate.

3.3 Ambient noise is defined as the totally encompassing sound in a given

situation at a given time usually composed of sound from many sources near and far. Specific noise is defined as a component of the ambient noise which can be specifically identified by acoustic means and may be associated with a specific source. The specific noise due to the activities within the plant is what is required to be determined. As the operation of the plant is quasi steady state, the specific noise due to the plant is best represented by the L(A90,15min) parameter, i.e. the noise level in dBA equalled or exceeded for 90% of a measurement interval of 15 minutes. For compliance the mean value of the L(A90,15min) is determined over seven reference intervals for night-time, 22:00 to 08:00 hours. If there is compliance for night-time, it follows that there is compliance also for daytime as the noise limit is 10dBA higher for daytime.

3.4 Wind speeds in excess of 5 metres per second can give rise to extraneous

noise. Where this occurs measurement may be deemed to be void.

4. Results

4.1 1996 - Location Currans - Survey date 31st August to 5th September The mean night-time L(A90,15min) was 50dBA. The night-time limit of 49dBA was marginally exceeded by 1dBA. This exceedance was due to the presence of noise from the grain drying plant.

4.2 1997 - Location Currans - Survey dates 18th to 30th June, 31st July to 8th

August and 22nd to 28th October. Adverse weather conditions consisting of heavy and prolonged rain and high wind speeds were experienced during all three survey periods. There were also a number of occasions when there was significant noise from the grain drying plant. Favourable weather conditions occurred on the 26th October. The mean night-time L(A90,15min) was 47dBA. This complies with the limit.

4.3 1998 - Location Currans - Survey date 7th to 14th August.

Wind speeds in excess of 5m/sec occurred for most of the period with the exception of 10/11 August. The mean night-time L(A90,15min) was 45dBA. This complies with the limit.

4.4 1999 - Location Currans - Survey date 15th to 21st July.

The mean night-time L(A90,15min) was 45dBA. This complies with the limit.

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4.5 2000 - Location Synnotts - Survey date 12th to 16th May.

Mean night-time L(A90,15min) was 40.3dBA. This complies with the limit.

4.6 2001 - Location Synnotts - Survey date 18th to 25th July.

Mean night-time L(A90,15min) was 44.3dBA. This complies with the limit.

4.7 2002 - Locations Synnotts, McKenna's, McGuinness's. - Survey date for

all three locations 20th to 26th July. Mean night-time L(A90,15min) were as follows: Synnott's 42.6dBA McKenna's 37.9dBA McGuinness's 34.9dBA There was compliance with the limit at all locations.

5. Comment

5.1 A detailed assessment of the variation in the measured L(A90,15min) levels at

Synnotts was carried out for the 2000, 2001 and 2002 surveys. Wind speed and direction data from Dublin Airport was compared with the noise data. Maximum noise propagation occurs during positive wind vector condition i.e. with the wind blowing from the direction of the plant to Synnotts. This occurs with the wind coming from the sector 2470 to 3130. Minimum propagation occurs during negative wind vector condition i.e. with the wind coming from the sector 350 to 1650. The variation in L(A90,15min) levels under positive and negative wind vector conditions is around 5dBA. This is borne out by the survey results. For the year 2002 the mean night-time L(A90,15min) level was 40.3dBA. Negative wind vector conditions mostly prevailed. The corresponding levels for 2001 was 44.3dBA with positive wind conditions occurring throughout the measuring period. For the year 2002 the mean night-time L(A90,15min) levels was 42.6dBA under a mixture of positive and negative wind vector conditions.

5.2 The noise emission from the plant is stable and complies with the night-time

noise limit and consequently with the daytime limit with a comfortable margin.

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Irish Cement Ltd Platin Works IPPC Licence Application ...

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