This report has been cleared for submission to the Board by the Program e Manager Frank Cli on. & Date= D SING E- l& Signe

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I To: Directors

From: Brian Meaney - LICENSING UNIT 11 I Date: 20/07/2010

Application for review of an IPPC Licence from IRISH CEMENT, Platin, Co. Meath, Licence Register Number POO30-04

RE:

Classes of activity:

Category of activity under IPPC Directive (2008/1/EC):

Section 90( l)(b) notice sent: Licence application received: EIS received: Notices under Article 90 issued: Information under Article 90 received: Submissions received: Site notice inspected: Site visits:

Class 10.1 The production of cement. Class 11.1 The recovery or disposal of waste in a facility, within the meaning of the Act of 1996, which facility is connected or associated with another activity specified in this Schedule in respect of which a licence or revised licence under Part IV is in force or in respect of which a licence under the said Part is or will be required. 3.1 Installations for the production of cement clinker in rotary kilns with a production capacity exceeding 500 tonnes per day or lime in rotary kilns with a production capacity exceeding 50 tonnes per day or in other furnaces with a production capacity exceeding 50 tonnes per day. 21 October 2009 23 October 2009 23 October 2009 15 December 2009,23 March 2010, 16 June 2010

27 January 2010,22 April 2010,28 June 2010

One No 15 July 2009 (pre-application meeting) 31 March2010

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Irish Cement operates two cement kilns in Ireland - at Platin, Co. Meath and at Mungret, near Limerick city. This application relates solely to a review of the IPPC licence (POO30-03) granted in June 2008 in respect of Irish Cement’s Platin facility which has been in operation at the location since 1972.

The Platin facility is located on the R152 Drogheda-Duleek road, 3km from Drogheda and 2.5km from Duleek. It is adjacent to the site of the proposed Indaver incineration facility at Carranstown (waste licence register number WO 167-0 l), currently under construction. It is also adjacent to a proposed power plant - Scottish and Southern Energy plc, IPPC licence reg. no. PO683-01 - on which planning consent has lapsed. The location is rural and the facility is surrounded primarily by agricultural land, although urban settlement is nearby. There are residential properties c.300 meters from the facility. Figure 1 shows the Irish Cement facility and its surrounds.

Irish Cement’s property at Platin covers an area of approximately 385 hectares, a small proportion of which is developed to date. The developments include the cement factory, the quarry and the overburden mound, all of which are subject to control under the existing IPPC licence.

This licence review primarily concerns Irish Cement’s desire to accept waste for combustion as a fuel in the cement factory. Specifically, Irish Cement propose to source and accept the following materials to be used as fuel and to displace fossil fuels:

- meat and bone meal’;

- chipped tyres; and - solid recovered fuel (also known as refuse derived hel).

Irish Cement was granted planning permission for the proposed activity (combustion of up to 120,000 tonnes of alternative fuels, as listed above) by Meath County Council in April 2009 (planning reference SA803066). No appeal was made to An Bord Pleanala. Irish Cement subsequently sought and was granted a modification to the permission allowing for the introduction of alternative hels at the main burner.

Irish Cement is authorised (in the existing licence, POO30-03) for a class 11.1 (waste) activity. This activity is currently limited to the operation of an on-site waste disposal area known locally as the overburden mound and regulated in the existing licence as a landfill. On foot of a review of Irish Cement’s Landfill Conditioning Plan2 by the Office of Environmental Enforcement, the Environmental Licensing Programme took the initiative to consider the operation and regulation of the landfill in the context of the Landfill Directive and an alternative regulatory instrument, the Extractive Waste Regulations. It is recommended in this report that the disposal facility be regulated under the Extractive Waste Regulations (as opposed to the Landfill Directive) for reasons set out below.

Irish Cement Platin is located within the catchment of the River Nanny to the south to which a surface water discharge is made.

Category 3 meat and bone meal is not classified as waste (Department of the Environment, Heritage and Local Government correspondence dated 26 September 2006).

’ Irish Cement prepared a Landfill Conditioning Plan in accordance with the Landfill Directive.

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Reason for Licence Review

Irish Cement requested a licence review to permit the acceptance of three types of waste for use as alternative fuel in the production of cement in kiln 3 - the new kiln.

Process Description

There are three cement kilns at the installation, two of which are operational. Kiln 1 permanently ceased operation in October 2008. It is still present at the facility and has not been dismantled or removed. The kiln 1 stack is still in use for the emission of kiln 3 exhaust gases when these are used as a drying medium in raw mill 1 and coal mill 1. Kiln 2 remains operational. Kiln 3 commenced in December 2008 and its proposed operation was the substantive part of the last IPPC licence review (POO30-03).

The manufacture of cement is a material and energy intensive activity. The production process is a series of size reduction and mixing processes leading to a thermal process followed by a final size reduction. The main stages in the process and emissions are described briefly under the following headings:

Quarrying

Quarrying at the Platin facility involves the stripping of overburden and its extraction along with limestone. Quarried shale is imported to the site. Blasting, plant and machinery noise, dust and quarry dewatering emissions are associated with quarrying activities at Platin.

Rawmilling

Limestone, overburdedshale, bauxite and iron oxide are extracted from on-site stores and conveyed to the raw mills. The materials are mixed and milled to produce a finely ground, dry, homogenised raw material known as raw-meal which is conveyed to the raw-meal silos. There are three operational raw mills. The waste gases from the kilns are used to dry the raw-meal in the rawmills. Supplementary furnaces are also available. The main emission from rawmilling is particulate emissions to atmosphere.

Cement clinker making

Raw-meal is extracted from the raw mill silos and conveyed to the operational kilns: - -

kiln 2 is a double string four stage cyclone pre-heater kiln; and

kiln 3 is a pre-calciner single string 5-stage pre-heater kiln.

In the pre-heaters any residual moisture is driven off before the temperature rises rapidly. Calcination begins in the pre-heater system. The material then enters the rotary kiln where the calcination process is completed and the transformation into clinker occurs at a material temperature of c.i450°C.

The kilns are primarily fuelled on solid fuel: currently pet coke. The kilns are lit using LPG and oil. The solid fuel is stored in outside piles before being milled in coal mills. The coal mills are ventilated by the kiln exhaust gases and emissions are discharged through an electrostatic precipitator (coal mill 1) or bag filters (coal mills 2 and 3).

The main emission from the kiln process is the discharge of combustion gases. Combustion emissions from kiln 2 are dedusted by electrostatic precipitators and from kiln 3 by bag filter. NO, emissions from kilns 2 and 3 are abated using selective non catalytic reduction (SNCR) which involves the injection of ammonia solution (1 0-25% solution) into the flue gas. NO, is reduced by reaction with the ammonia solution to

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form nitrogen gas and water. SO, emissions are abated by the availability of an alkaline environment in the kilns that remove S02. No dedicated SO, abatement technique is required.

Clinker discharged fiom kilns 2 and 3 is cooled in grate coolers (emissions from which are dedusted in electrostatic precipitators) and conveyed to storage.

Cement Milling

Metered quantities of gypsum and raw meal or limestone are added prior to milling (size reduction) in cement mills. The main emission associated with the cement mills is particulate emissions. There are four cement mills. Particulate emissions from cement mill 1 are controlled by electrostatic precipitator and from all others by bag filter. Following milling the cement is conveyed to the cement silos for storage. The cement is bulk loaded for roadhail transport or packed in 25kg bags for dispatch.

Solid recovered fuel (SRF) Tyre chips

Proposed introduction of alternative fuels

The following alternative fuels are proposed for acceptance and combustion:

Up to 90,000 tonnes Up to 30,000 tonnes

I Alternative fuel I Quantity (tonnes per year) I

Meat and bone meal (MBM) Maximum proposed

Up to 40,000 tonnes 120,000 tonnes per year

With the exception of category 3 meat and bone meal, the alternative fuels are classified as waste. Alternative fuels will be introduced to kiln 3 only. Alternative fuels will be supplied under contract to Irish Cement according to a technical specification (condition 8.9). No processing of waste will be carried out at the installation.

Solid recovered fuel - E WC code I 9 I2 I O

SRF is manufactured by the mechanical treatment of residual municipal waste. It contains paper, cardboard, plastic, textiles and timber to a maximum particle size of 50mm. Irish Cement’s supply specification will set limits for calorific value (16- 22MJ/kg), moisture (<15%), ash and biomass content. SRF will be delivered by road and will be stored in a dedicated, purpose-built building. Prior to conveyance to kiln 3, magnetic separators will be used to remove any remaining metal fragments.

Chipped tyres - E WC code 16 01 03

Irish Cement’s supply specification for chipped tyres will be principally concerned with particle size (<50mm x 50mm) and calorific value (24-29MJ/kg). Tyre chips will be delivered by road and will be stored inside a purpose-built covered store.

Meat and bone meal - EWC code 02 02 03

Irish Cement’s supply specification for meat and bone meal will be principally concerned with calorific value (14-18MJ/kg), moisture and fat content. Meat and bone meal will be delivered in road tankers and unloaded pneumatically by a sealed automatic system to one of two storage silos. Head space air from the storage silos

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will be vented directly to the kiln to avoid odour emissions. Alternatively, a carbon filter is available to remove odours from vented gases.

Conveyance of alternative fuels from storage to the pre-calciner and/or kiln will be in covered conveyors ventilated under negative pressure to avoid fugitive emissions. There are no discrete emission points associated with alternative fuels storage and conveying.

Emissions

Emissions to Air

In the context of this licence review, the principal emissions of concern where waste is to be introduced as alternative fuels are those made to air. Irish Cement contends that there will no deterioration in the standard of air emissions from the installation following introduction of alternative fuels. CRH plants operating across Europe routinely burn alternative fuels. An illustrated case study from a Portugese plant that accepts alternative fuels shows no exceedence of emission limits for heavy metals and dioxins in air emissions. The licence application quotes that alternative fuels account for approximately 20% of fuel consumed in the European cement industry. German, Swiss and Dutch cement industries have achieved over 50% substitution of fossil fuels with alternative fuels.

Irish Cement emits to atmosphere through a large number of emission points, including 10 major emission points and 93 minor emission points, all controlled by emission limit values. For all minor emission points and 6 major emission points, particulates are the sole controlled contaminant. Emissions of combustion gases at four major emission points have additional limits on emissions of SO, and NO, in the existing licence. Of these four major emissions points, two (A2-O13 and A2-084) will emit combustion gases resulting from combustion of waste. The Waste Incineration Directive (WID) imposes limit values for hydrogen chloride, hydrogen fluoride, heavy metals, total organic carbon, carbon monoxide and dioxins and furans on these emissions. WID emission limit values will apply when waste is being combusted. In 2009, particulate and NO2 emissions from kiln 3 exceeded permissible emission limits on two occasions. Kiln 2 did not operate in 2009, but in 2008 a small number of exceedences were reported in the Annual Environmental Report.

The revised BREF (May 2010) for the cement industry sets BAT for NOx emissions in the range 200-450 mg/Nm3. National BAT sets the range 200-500 mg/m3 for “facilities where SNCR is BAT”. As SNCR is installed and operational on both kilns at Irish Cement, the NOx emission limit value is to be reduced from the existing 800 mg/m3 to 500 mg/m3 (see Schedule B.1 Emissions to Air of the RD).

Particulates are controlled in the major emissions by either electrostatic precipitator or bag filter. Particulates are controlled in all minor emissions using bag filters. Either technique represents BAT and emission limit values for particulates are within BAT ranges. A monitoring programme to demonstrate compliance with emission limits at minor emission points is required under condition 6.17.5 of the RD.

The old kiln 1 stack. Kiln 1 is decommissioned, but its stack is now used for ventilation of raw mill 1 ,

Kiln 3 stack. Waste will be combusted in kiln 3 only.

coal mill 1 and for drying limestone using exhaust gases from kiln 3, where waste will be combusted. 4

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Fugitive dust emissions can arise from vehicle movements and outdoor storage of process materials and control mechanisms are in place to minimise fugitive emissions. No new fugitive emissions (dust or odour) are expected from the indoor storage of alternative fuels.

Parameter

Nitrogen oxides (as NO21

Impact of Air Emissions on the Receiving Environment.

An air dispersion model was carried out on the projected emissions concerning the use of alternative fuels. The Breeze AERMOD software package was used to predict ground level concentrations over 1 -hour, 24-hour and annual averaging periods. The model used mass emission rates calculated from maximum volumetric flow rates from Irish Cement’s current licence (for existing parameters) and emission limit values from the Waste Incineration Directive (Annex 11.1). The modelled scenario is conservative for several reasons, including:

1. Particulate matter and oxides of nitrogen were modelled at the existing licence’s emission limit values. These are greater than the equivalent emission limit values allowed in the Waste Incineration Directive;

2. The model assumes that emission sources are operating at maximum flow rates and concentrations continuously under least favourable (worst in five years) meteorological conditions;

3. Locally measured background concentrations of hydrogen chloride, hydrogen fluoride, heavy metals and dioxins (where no national background data exists) are inclusive of actual emissions from the facility prior to commissioning of kiln 3, and thus include the now decommissioned kiln 1. Modelling these backgrounds with projected emissions from kiln 3 (where waste will be burned) means double counting of actual factory emissions (other than kiln 3); and

4. The cumulative impact of emissions from the adjacent Indaver Carranstown incinerator (using similar assumptions as in item 2 above) were modelled.

Table 1 shows the predicted ground level concentrations combined with background concentrations and compared to the air quality standards. The standards are taken from a range of sources including EU and Irish legislation, guidelines from other jurisdictions and the World Health Organisation. The results show that Irish Cement will not contribute to air pollution to an extent that air quality standards will be exceeded.

Predicted ground level

concentration Predicted Air Quality g c,

E Modelled (Irish Background plus Standard Impact Cement) concentration background (AQS)

pg/m3 pg/m3 pg/m3 pg/m3

1 4 Calendar year 9.2 6 15.2 40

Table 1 Predicted ground level concentration of modelled parameters - Not including cumulative impacts. - Only those elements/compounds whose ‘predicted plus background’ value is greater

than 1% of the AOS are shown.

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Predicted ground level

concentration (Irish

Cement) pg/m3

64 (99.79Ih %ile

of 1 -hour)

9.2

Predicted plus

background pg/m3

76

Modelled Impact

Background concentration

pg/m3 Parameter

Nitrogen oxides (as N02) Nitrogen oxides (as NO,)

PMlO

200 1 ; 1 -hour 12

1 30 Calendar year 8.5 17.7

14 Calendar year 19.5

40.2

5.5

12.2 (90.41th %ile of 24-hour)

2.8

24-hour 28

Calendar year PM2.5 9 11.8

Calendar year and winter

Mar)

24-hour

(1 Oct-31 8.5 4.5 13

so2 9 51.1 42.1

121.8 (99Ih %ile of

1 -hour) 1 -hour 9 130.8

HF (fluoride as F)

Calendar year (long term

EAL) 0.0034 <0.03 <0.033

Dioxins 3.4 x 10-l0 7.5 7.8 3 1 0 - ~ I 9 Calendar year

Cadmium Calendar year 0.00003 <0.00055 <0.00058 0.005 1 7

Arsenic Calendar year 0.00001 <0.00055 <0.00056 0.006 I 7

Manganese Calendar year 0.00027 0.00393 0.0042 0.15 I 8

Nickel Calendar year 0.00017 0.00083 0.00 1 0.02 1 7

Vanadium 24-hour

1 -hour (short term EAL)

0.0297

0.03

0.00034

0.0007 1

0.02932

0.02932 l 6 Vanadium

Note 1: Source of AQS: Air Quality Standards Regulations (S.I. No.271 of 2002) Note 2: This is an AQS for the protection of vegetation or ecosystems rather than for the protection of human health. Note 3: Stage 1 -to be attained by 2005; Stage 2 -to be attained by 2010. The 20 pg/m3 stage 2 AQS currently remains in national law. However, Directive 2008/50/EC will retain the 40pg/m3 stage 1 AQS. The Directive is due to be transposed into national law by June 20 10. Note 4: Source of AQS: Directive 2008/50/EC (due to be transposed into national law by June 2010) Note 5: Stage 1 -target value for 2010, limit value for 2015; Stage 2 - limit value for 2020 (subject to review by the Commission in 20 13).

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Note 6: Source of AQS: Environment Agency of England and Wales, 2002 Note 7: Source of AQS: Directive 2004/107/EC Note 8: Source of AQS: WHO, 2000 Note 9: Source of AQS: WHO, 2000, indicative value

HC1 HF 1-hour Cd 1-hour

Calendar year and 1 -hour

T1 Calendar year and 1-hour Hg Calendar year Sb Calendar year and 1-hour As 1-hour

Modelling of the following elements/compounds showed ‘predicted plus background’

Pb Cr CO c u Mn Ni V

Calendar year Calendar year Calendar year Calendar year 1 -hour 1 -hour Calendar year

Cumulative impacts were examined, taking into account 1 e projected emissions from the adjacent Indaver incineration plant operating at a capacity of 200,000 tonnes of waste per annum, currently being constructed. The predicted ground level concentration for each relevant parameter from Indaver was added to the predicted ground level concentration contribution from Irish Cement (from Table 1 above) and to the measured background level. The results of the analysis show that no modelled cumulative impact would exceed the air quality standards.

Monitoring of Air Emissions

The existing licence requires continuous monitoring of exhaust volume (or alternative estimation method), temperature, humidity, 0 2 , CO, NO, and particulate matter from the main combustion emissions in accordance with BREF/BAT. Differential pressure on all fabric filters is to be monitored continuously as is the voltage across electrodes and the current through electrostatic precipitators. SO2 emissions are monitored quarterly from the main combustion emission points. Emissions of particulate matter in exhaust from mills and grate coolers are monitored quarterly. In accordance with the Waste Incineration Directive, the following new monitoring requirements are proposed in Schedule C. 1.2 Monitoring of Emissions to Air:

continuous monitoring of sulphur dioxide, carbon dioxide, HC1, HF and total organic carbon; and quarterly monitoring of heavy metals and dioxins and furans.

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Technical amendment request regarding emissions interpretation

On 18 January 201 0, the licensee requested a technical amendment to condition 4.1.1 of the existing licence that requires, in relation to continuous monitoring of stack emissions, that “no 30 minute mean value shall exceed twice the emission limit value.” The request for technical amendment has been incorporated into this licence review. Irish Cement points out that during start-up and shutdown periods on both operational kilns (2 and 3), NOx emissions can exceed twice the emission limit value.

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The problem arose following reduction of the NOx emission limit value to 800 mg/m3 during the last licence review. It was not a problem with the old limit value of 1,800 mg/m3. Also, during electrostatic precipitator trips, dust emissions from kiln 2 can exceed twice the emission limit value. Bag filters are used on the stack emissions from kiln 3 so the problem with particulates doesn’t arise there.

In relation to NOx emissions, Irish Cement states that the emissions are unavoidable and are a fbnction of the need at start-up, for safety and operational reasons, to ramp up air, fuel and feed in a particular sequence and at particular rates. This ramping up of material feed results in unsteady state operation and exceedences in NOx. A document provided from the German cement industry umbrella group quotes German law that provides for and allows for these exceedences.

In relation to dust emissions, trips on the electrostatic precipitator (ESP) have been reduced between 2000 and 2007 from 126 per annum to 1 1. The cause of trips has been studied and found to be predominantly due to high CO readings on the ESP continuous monitor. High CO can cause explosive conditions in the ESP and current must be cut off during high CO periods. Considerable experience has been developed on managing fuel feed to the kiln to limit emissions of CO.

The licensee has proposed amendment to condition 4.1.1 (iii) to add a clause that the limitation on the emission limit value excludes start-up and shutdown periods for NOx emissions on kiln 2 and kiln 3, and safety trip-outs for dust emissions on kiln 2. I recommend making this amendment and have proposed the text requested by Irish Cement in condition 4.1.1 (iii) of the RD. For clarity and to avoid ambiguity, I propose new definitions for shutdown and start- up of the cement kiln in the Glossary of Terms as follows:

Shutdown Shut-down is that period of time during which the cement kiln is allowed to cool from operating temperature to a lower temperature.

Start-up is that period of time during which the cement kiln is heated to operating temperature from a lower temperature.

Start-up

Emissions to Sewer

There are no emissions to sewer from the facility.

Emissions to Surface Water

Irish Cement makes one combined discharge to the River Nanny. The combined discharge is made up of three separate discharges from within the facility:

discharge from settlement tanks for spent process water and surface water run- off; discharge from a proprietary sewage treatment plant for on-site welfare facilities; and pumped groundwater discharge from beneath the quarry floor (untreated),

0

0

and is made through a single discharge point (SW4) controlled by the existing licence. The discharge is conveyed in a 2,637m, 610mm underground pipeline south to the

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River Nanny. There are no new or varied emissions to surface water proposed in this licence review. The introduction of alternative fuels will not result in any additional emissions to surface water.

The European Communities Environmental Objectives (Surface Water) Regulations, 2009, require that discharges to surface waters are controlled such that environmental objectives and environmental quality standards are achieved. An aquatic monitoring survey carried out for Irish Cement in 2008 concludes that the receiving surface water (R. 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. It is evident from Irish Cement’s commissioned report that the discharge is not having an impact on the quality of the river. The maximum allowable discharge from Irish Cement to the River Nanny is 28,000 m3/day, e uivalent to an average of 0.32 m3/s. (The average discharge in 2009 was 12,885 m /day). By comparison, the calculated 95 percentile (%ile) flow in the river is 0.06 m3/s. Based on these flowrates, combined with water quality data5, an assimilate capacity calculation shows that the existing emission limit value of 6 mg/l BOD, if emitted at maximum allowable discharge volumes, would result in the 95%ile EQS of 2.6 mg/l for BOD being exceeded. Therefore it is necessary to reduce the emission limit value for BOD to 2.6 mg/l to ensure the EQS is not exceeded. Similarly, it is necessary under the Regulations to propose new limit values for copper, zinc and lead in Schedule B.2 Emissions to Water of the RD. As water hardness in the R. Nanny is consistently over 100mgA as CaC03, emission limits of 30yg/1 for copper and 1 OOpg/l for zinc are proposed. An emission limit value of 7.2ygA for lead is also proposed. These compare to the existing limits of 100ygll for copper, 500pg/1 for zinc and 100pgA for lead.

Irish Cement proposes installing fire water retention capacity to contain any fire water arising from the proposed alternative fuels (SRF and chipped tyres) storage areas. See condition 3.9 of the RD.

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Emissions to Ground

There are no discharges to ground or groundwater. The existing licence’s requirement for biannual monitoring of groundwater extracted from beneath the quarry floor is maintained in the RD. Groundwater monitoring shows no indication of contamination from the cement factory or the overburden mound.

Waste Generated at the Facilitv

Non-hazardous (municipal, packaging, construction and demolition) and hazardous (e.g. mineral oils) wastes are generated at the facility and dispatched for recovery and disposal by authorised contractors. The proposed use of alternative fuels (meat and bone meal, chipped tyres and solid recovered fuel) will not result in the generation of new waste streams that require management by Irish Cement.

EPA monitoring approximately 6km downstream at Julianstown and Meath County Council 5

monitoring approximately 300m upstream of the discharge point.

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Overburden - a naturally occurring material of soil and stone - from the on-site quarry has historically been deposited at an overburden mound within the licensed area of the installation. Overburden is now commonly used in the cement manufacturing process as an alternative to imported shale. However there remains a quantity of material that is surplus and requires disposal. In 2009, 16,700 tonnes of overburden were deposited at the overburden mound and 1 19,000 tonnes in 2008.

Process residues are, where possible, reintroduced to the kilns as raw materials although they have in the past been disposed of in the overburden mound.

A programme of work is complete for the removal of approximately 70 tonnes of asbestos waste deposited in the overburden mound. The asbestos is currently stockpiled on site awaiting approval for export. Irish Cement expect the work to be finished during 2010. A deposit of filter bags was also removed from the mound and was dispatched from site.

Noise Three noise complaints were received in 2008 and one in 2009. Noise surveys carried out at the nearest noise sensitive location show that the LAeq limit values set in the existing licence are not met. However it is claimed by Irish Cement that the LA90 values obtained in the noise surveys are more representative and are within the limit values. It would seem unlikely that the proposed new activities will cause any additional noise emissions beyond the boundary of the facility. However it is proposed through Schedule C.5 that a comprehensive survey of noise at noise sensitive locations be carried out annually.

Use of Resources

The manufacture of cement is a resource and energy intensive process. A great part of the raw materials used in cement manufacture are sourced directly on-site. In 2009, 76,126 tonnes of petcoke/coal; 1,536 tonnes of diesel/light he1 oil; 1.15 million tonnes of limestone, shale and overburden; 75,446 tonnes of bauxite, iron ore and gypsum; and 120 million kWh were consumed. A 1 lOkV electricity station is used to supply power to the plant. Three liquefied petroleum gasoline (LPG) tanks provide gas for firing during kiln start up and for filling propane cylinders. Process water is obtained internally from the pumped supply from beneath the quarry The public water supply from Drogheda is used as back up for process water. Water for domestic uses is taken from a Meath County Council main. The RD proposes no new conditions regarding resource use.

Greenhouse gas emissions

With regard to reducing the climate impact of the installation under IPPC, the RD requires a renewed energy efficiency audit and an assessment of resource use efficiency. The RD sets an ELV for nitrogen oxides, which is a specified greenhouse gas, to ensure that air quality standards are observed. Irish Cement claim that the use of 120,000 tonnes of alternative fuels has the potential, depending on the alternative fuels’ biomass content, to reduce CO2 emissions by up to 100,000 tonnes per annum.

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Compliance with EU Directives

IPPC Directive (91/61/EC) This installation falls within the scope of category 3.1 (Installations for the production of cement clinker in rotary kilns with a production capacity exceeding 500 tonnes per day) of Annex I of Council Directive 2008/1/EC concerning integrated pollution prevention and control. The Proposed Determination as drafted takes account of the requirements of the Directive.

Waste Incineration Directive (2000/76/EC)

With the introduction of alternative fuels - principally derived from waste - the facility will be regulated in accordance with the Waste Incineration Directive. Irish Cement’s proposal comprises co-incineration which is defined in the Directive (and I paraphrase) as an activity where the main purpose is the production of material products (clinker) and waste is used as a regular or additional fuel. Some of the principal provisions of the Directive proposed in the RD are as follows:

temperature of 850°C for two seconds to be maintained on all combustion gases resulting from combustion of waste;

control of waste feed to ensure these conditions can be met;

emission limit values from Annex 11.1 of the Directive;

measurement and monitoring of air pollutants; and

procedures to respond to abnormal operating conditions.

-

-

-

-

- Air dispersion modelling, described above, carried out by Irish Cement show that the combustion of waste will not have a detrimental impact on the surrounding environment.

Landfill Directive (1 999/31/EC) and Extractive Waste Directive (2006/21/EC)

Irish Cement operate a waste disposal facility at Platin for the overburden stripped from land when the quarry moves into a new area. The facility is regulated in the existing licence as a landfill and is known at the installation as the overburden mound. Table 2 sets out Irish Cement’s best estimate of the quantity of different materials deposited at the overburden mound since 1996, before which reliable records are not available. Irish Cement estimate that pre-1996 (when the facility was first the subject of an IPC licence) up to 84 tonnes of waste per annum (other than overburden) might have been deposited in the overburden mound; however, there is no information to substantiate this or otherwise verify exactly what and how much waste was actually deposited pre-1996.

Table 2 Materials deposited in the overburden mound since 1996

Material

Overburden I Description Estimated quantity Percentage

(tonnes) of total

Naturally occurring soil and stone stripped from land to allow 1 5,000,000 1 99.96

I quarrying of limestone

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Clay/gyp sum

Concrete and bricks

Kiln refractoryhrick Lining materials from the inside of 1 the kiln wall

660 0.0 1

560 0.0 1

Mixtures of clay and naturally occurring gypsum material Material arising from construction projects at the Platin site

668

Construction waste

1 0.01 I 40 <0.01 Material arising from construction

projects at the Platin site Engineering waste Wastes from the engineering

department comprising refractory and filter bags

2

Process waste Inert process dusts extracted from the plant during routine maintenance operations

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With the facility defined as a landfill for the purposes of regulation under the existing IPPC licence, Irish Cement were obliged to prepare a Landfill Conditioning Plan in 2002. Assessment of the Landfill Conditioning Plan and the IPPC licence led to a recommendation of issues that should be addressed by licence review, including:

monitoring and testing of waste prior to deposit, other than certain inert wastes; - - capping of the landfill; - - -

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assurance of stability of the landfill, in particular the avoidance of slippages;

topographical surveys of the facility;

security and access to the landfill; and

groundwater monitoring and the setting of groundwater trigger levels;

However, before I address these issues, I would raise the question as to whether the Landfill Directive is the appropriate instrument for regulating the overburden facility. In 2006, a Directive on the management of waste from extractive industries was made6. The Directive has been implemented in Ireland by the Waste Management (Management of Waste from the Extractive Industries) Regulations, 2009, S.I. No. 566 of 2009, and these Regulations have come into force since Irish Cement’s IPPC licence was last reviewed in 2008. The Extractive Waste Directive and Regulations deal with waste facilities used for the deposit of extractive waste from extractive activities. The Directive and Regulations define extractive wastes and extractive waste facilities and Irish Cement’s overburden and overburden mound meet these definitions. The overburden from the quarry is an extractive waste and its deposit at the overburden mound would render that an extractive waste facility. However, overburden is not the only material to have been deposited at the facility over the years. Materials such as process waste and construction and demolition waste have also been deposited, albeit in relatively small quantities compared to the total deposited. There are indications that small quantities of canteen and office waste, packaging (paper, plastic and wood) and some potentially hazardous materials (“adzorb/oil/process materials” - up to 6 tonnes per annum7) were disposed of before

Directive 2006/21/EC of the European Parliament and of the Council of 15 March 2006 on the

An internet search shows that adzorb is a material used, amongst other things, for absorbing oil spills.

management of waste from extractive industries and amending Directive 2004/35/EC. 7

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1996. Some of the deposited materials (asbestos and filter bags) have been removed. The use of an extractive waste facility for the deposit of material other than extractive waste renders the facility a landfill, and subject to the Landfill Directive. However the quantity of non-extractive waste in this case is extremely small.

Where does the balance lie? As presented in Table 2, an extremely small proportion of non-extractive wastes have been deposited at the facility since 1996 (less than 0.04%). At 84 tonnes per annum, it may be that up to 2,000 tonnes of waste were deposited in the 24 years between 1972 and 1996 (approximately 0.04% of the total deposited). Since 1996, the deposited wastes are said by Irish Cement to be for the most part inert and, based on their description of the deposited materials, I am inclined to agree that they are unlikely to have any long term environmental impact from the confines of the overburden mound. Data on water quality beneath the overburden mound (see below) show no cause for concern regarding materials that may have been deposited pre-1996. On this basis, and in an attempt to take a pragmatic approach to the future management of the facility, I consider the overburden mound to be most appropriately regulated under the Extractive Waste Regulations. The implications are such that the facility is wholly outside the scope of the Landfill Directive. Considerable environmental protection is provided by the Extractive Waste Regulations and it is proportionate protection given that only unpolluted soil is to be deposited at the facility (under the conditions of the RD) and forms by far the vast bulk (>99.9%) of the material already deposited.

Some parts of the Extractive Waste Regulations do not apply to facilities for the management of unpolluted soils. It is however recognised that a ‘heap’* of unpolluted soil can have an environmental impact in terms of environmental emissions and risk of collapse. In that context, the following are the principal requirements proposed for the revised licence on foot of the Extractive Waste Regulations:

prohibit waste other than extractive waste being deposited at the facility (condition 8.20);

prepare an extractive waste management plan for the minimisation, treatment, recovery and disposal of extractive waste (condition 2.3) to be reviewed at least once every five years and to include a proposed risk categorisation for the extractive waste facility.

Surface water and groundwater are passively managed in the context of the overburden mound. The Cruicerath River, flowing from the west towards the overburden mound, disappears underground through a swallow hole at the south- western corner of the overburden mound. Overland flow from the mound area preferentially follows this route down the swallow hole - whose subterranean flow was intercepted with the opening of the upper levels of the quarry (which is now approximately -20mOD) - and is captured in the quarry’s pumped drainage system. In heavy rainfall or overland flow events, a lined pond constructed between the mound and the quarry captures excess surface run-off and protects against localised flooding. The water in the pond is pumped periodically to the quarry drainage system. The overburden deposited at the facility is low permeability boulder clay (ca lxlO-’m/s) and is unlikely to allow significant infiltration of rainwater through the overburden mound. Any water that exits the overburden mound via its base may enter the

-

-

‘Heap’ is defined in the Extractive Waste Regulations as an engineered facility for the deposit of solid 8

waste on the surface.

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groundwater flow beneath the mound and travel in the direction of the quarry floor. Groundwater is continuously pumped from beneath the quarry floor and this has formed a large cone of depression in groundwater extending 1.5-2km from the quarry. Therefore all groundwater and surface water from the overburden mound is captured in the quarry’s pumped water system. The captured water is allowed to settle before being discharged to the River Nanny via emission point SW4. Irish Cement is required under the existing licence to monitor the pumped groundwater twice a year and the discharge to surface water quarterly. The chemical data shows the groundwater to be for the most part within the interim guideline values set out in Towards Setting Guideline Values for the Protection of Groundwater in Ireland (EPA, 2003).

Large Combustion Plant Directive (2001 /80/EC)

The Large Combustion Plant Directive 2001/80/EC does not apply to combustion of fuel in cement plants.

Solvents Directive (1 999/13/EC)

The processes carried out do not fall within the scope of EU Council Directive 1999/13/EC on the limitation of emission of volatile organic compounds due to the use of organic solvents in certain activities and installations.

Seveso Directive (96/82/EC)

The licensee has given details of an assessment of on-site storage with the requirements of S.I. 74 of 2006. The assessment concludes that the activity is classified as not requiring compliance with Articles 6, 7 and 9 of Seveso 11. The National Authority for Occupational Safety and Health (NAOSH) is the competent authority responsible for administration and enforcement of these regulations.

Air Qualitv Directive (1 999/30/EC)

Emissions to air from the combustion activities, including combustion of waste, were assessed by the applicant in the form of predicted ground level concentrations of a wide range of compounds for which air quality standards are set by the Directive. The assessment indicates compliance with the air quality standards.

Emissions Trading Directive (2003/87/EC)

Irish Cement Limited holds a Green House Gas Permit, IE-GHG043-06, issued by the EPA in November 2009. The permit is held under the name of CRH plc.

Environmental Liabilitv Directive (2004/35/CE]

As an IPPC licensed activity, Irish Cement’s facility is within scope of the Environmental Liability Directive. The existing licence requires the preparation of an environmental liabilities risk assessment and making of financial provision against potential environmental liabilities. These measures will be carried forward into the

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revised licence. The licence imposes a preventive approach to environmental protection and requires that any environmental incidents (as defined in the licence) are reported to the Agency.

Water Framework Directive (2000/60/EC)

This report has discussed the impact of the European Communities Environmental Objectives (Surface Water) Regulations, 2009, on the licence and recommendations are made in the RD to ensure that the Regulations’ environmental quality standards are demonstrably met.

Groundwater Directive (80/68/EEC)

There are no emissions to groundwater permitted.

Danqerous Substances Directive (200611 I/EC)

The discharge of three list I1 substances, copper, zinc and lead, to the River Nanny are controlled by the licence. The RD proposes new emission limit values for these emissions that comply with the requirements of the European Communities Environmental Objectives (Surface Water) Regulations, 2009. The RD also proposes the continuation of the existing monitoring requirement for organic compounds in the effluent and adds a screening for heavy metals (condition 6.14.5).

EU Animal Bv-Products Regulation (EC No. 1774/2002)

As an animal by-product, the management of meat and bone meal at the facility will require confirmation by the licensee of controls subject to regulation by the Department of Agriculture, Fisheries and Food. Condition 1.6 of the RD ensures no ambiguity regarding the licensee’s statutory obligations or requirements under any other enactments or regulations not dealt with in the IPPC licence.

Habitats Directive (92/43/EC) & Birds Directive (79/409/EEC)

Several protected areas lie within 5km of the centre of the Irish Cement site:

0 Dowth Wetland (pNHA site code 00 186 1) Boyne Rivier Islands (pNHA site code 001 862) Duleek Commons (pNHA site code 00 1578) Thomastown Bog (pNHA site code 001 593) River Boyne and River Blackwater (SAC site code 002299)

Water discharges are to the River Nanny which flows directly to the Irish Sea at Laytown. Air emissions have been modelled and are predicted to be within relevant air quality standards. There are no discharges to groundwater. The activity and its emissions are not predicted to negatively impact on these protected sites.

Cross Office Liaison

I have consulted with the Office of Environmental Enforcement inspectors for the facility, Mr. Patrick Kenny and Ms. Mary Gurrie, regarding the operation of the on-

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site 1andfiWoverburden mound and the removal of asbestos waste from same and perspective in the enforcement and compliance history at the facility overall. Sectoral expert Mr. John McEntagart assisted in the assessment of the air dispersion model. Sectoral expert Mr. Michael Owens assisted in interpreting the Extractive Waste Directive and Extractive Waste Regulations. Sectoral experts Mr. Colman Concannon, Ms. Cara O’Loughlin, Ms. Rebecca Quinn and Mr Martin McGarrigle of the Office of Environmental Assessment provided surface water monitoring and flow data for the River Nanny and assisted in its interpretation.

Best Available Techniques (BAT)

I have examined and assessed the application documentation and I am satisfied that the site, technologies and techniques specified in the application and as confirmed, modified or specified in the attached Recommended Decision comply with the requirements and principles of BAT. I consider the technologies and techniques as described in the application, in this report, and in the RD, to be the most effective in achieving a high general level of protection of the environment having regard - as may be relevant - to the way the facility is located, designed, built, managed, maintained, operated and decommissioned.

Environmental Impact Statement

I have examined and assessed the EIS and having regard to the statutory responsibilities of the EPA, I am satisfied that it complies with Article 94 and Schedule 6 of the Planning and Development Regulations 2001 (SI 600 of 2001) and EPA Licensing Regulations (SI 85 of 1994, as amended).

Fit & Proper Person Assessment

The Fit & Proper Person test requires three elements of examination:

0 technical ability; 0 legal standing; and 0 financial standing.

It is my view, and having regard to the provisions of Section 84(5) of the EPA Acts and the Conditions of the RD, that the applicant can be deemed a Fit & Proper Person for the purpose of this review.

Compliance Record

The compliance history at the Irish Cement site is generally good.

Complaints

Six complaints were received in 2008 relating to noise (3 complaints, including one relating to a quarry blast), odour of oil (l), and other matters (2, including one relating to the visual impact of the facility).

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Submissions

One submission was received from Sindad McNally, Environmental Health Officer, Health Services Executive, Environmental Health Service, County Clinic, Navan, Co. Meath.

The HSE, as statutory consultee for the Environmental Impact Statement, comments that there is insufficient detailed information in the EIS to fully assess the proposal. Ms McNally for the HSE raises the following points.

“The applicant has failed to submit data regarding the types of emissions which may be emitted during the combustion of the alternative fuel sources.” Ms McNally considers it necessary to set out the “combustion process for each of the fuels and the resultant by-products” along with a risk assessment of each stage of the process and treatment methods to ensure compliance with Air Quality Standards.

Comment: Irish Cement have pointed out that fuel constitutes 6% of material inputs to the cement kilns. Replacing half of the fuel with alternative fuels will result in 3% of material inputs constituting wastes. I do not consider it possible to itemise the emissions resulting from the combustion of alternative fuels in the context of the complex chemistry taking place in a cement kiln. The air dispersion model predicts compliance with standards. The RD sets out the emission limit values for the waste combustion activity.

The HSE does not consider it adequate to use generalised background levels for particulate matter, N02, NO, and S02. On-site measurements should be used to establish background levels of these emissions “and accurately predict concentrations in the future.”

Comment: While Irish Cement in the air dispersion model used EPA monitoring data for the parameters mentioned above, local measurements were used for a range of other parameters including HC1, HF, heavy metals and dioxins. The EPA data would not take into account the existing emissions from the cement plant while the local measurements would. What this means is that the local measurements lead to a more conservative approach to modelling. The application of the data in the model shows that the expected impact from the emissions is added to the background levels (which will include existing emissions). Thus emissions are taken into account twice to all intents and purposes. Air dispersion modelling found no emission to be of concern in the context of air quality.

The HSE considers that using one noise sensitive location in the EIS is inadequate and a detailed noise survey of the existing development should be carried out.

Comment: The EIS and licence application consider the nearest noise sensitive location at 600m distant from the centre of the manufacturing plant. Noise monitoring was carried out for a one week period in February 2008. Average daytime levels of 56.2dBA(L~eq, 15 min) and 49dBA(L~90, 15 min) and night-time levels of 51.2 dBA(LAeq, 15 min) and 44.5 ~ B A ( L A ~ ~ , 15 min) were recorded. The noise emission limit values

(i)

(ii)

(iii)

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specified in Irish Cement’s existing licence (POO30-03) are ~ ~ ~ B A ( L A ~ ~ , 30 min) daytime and ~ ~ ~ B A ( L A , , , 30 min) night-time with a 2dBA exceedence tolerance. The 2008 Annual Environmental Report for the facility quotes the LA90 levels as being in compliance with the licence LAeq limits on the basis of the presence of extraneous noise making the LA90 value more representative of actual noise emissions from the facility.

Notwithstanding the above, I consider it appropriate that a formal schedule of noise monitoring at three noise sensitive locations outside the site boundary be implemented. See Schedule C. 5 of the RD. The HSE raises concerns regarding the control of fugitive emissions and spillages from the transfer of meat and bone meal from vehicles to storage silos.

Comment: Irish Cement states that the material will be unloaded pneumatically by a sealed automatic system into the silos and that headgases from the silos will be diverted to the kiln or a carbon filter. The RD requires protection against spillage when loading, unloading and storing meat and bone meal (conditions 8.4 and 8.5) and the supervision of all meat and bone meal unloading operations (condition 8.14).

The HSE requests proposals “regarding emergency control procedures in the event of a breakdown, temperature failure incident at the facility.’’

Comment: Irish Cement provided information in the application on emergency control procedures regarding the feed of waste to the kiln. Condition 3.16.4 of the RD requires that the licensee maintain and operate an automatic system to prevent waste feed:

at start-up, until the temperature of >85O”C has been reached;

whenever the temperature falls below 850°C;

whenever the continuous measurements show that any emission limit value is exceeded;

whenever stoppages, disturbances or failure of the purification devices or the measurement devices may result in the exceedence of the emission limit values; or

in the case of a breakdown or incident.

(iv)

(v)

0

(vi) The HSE suggests that Irish Cement should submit proposals for the control of odours in the proposed alternative fuel storage units.

Comment: Irish Cement claim that the use of solid recovered fuel (SRF) will not give rise to odour emissions if the material conforms to the supply specification for the following reasons:

- the SRF fuel store and conveyance system is fully enclosed;

- the moisture content of the SRF is low - 15-25%;

- organic content is controlled thus minimising biological degradation;

storage capacity typically represents 48 hours operating time. -

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(vii)

All SRF stocks will be run down before any planned extended shutdown. Unplanned shutdowns average 5 hours in duration. Irish Cement have stated that no problems with odour have been experienced at sister plants in Portugal and Finland where similar equipment has already been installed.

The HSE requests that Irish Cement submit proposals regarding a quarantine area for non-complying waste loads which may arrive at the facility.

Comment: Condition 8.16 provides for the storage of rejected loads of waste in a quarantine area.

Recommended Determination (RD) In preparing this report and the Recommended Determination I have consulted with Agency technical and sectoral advisors as set out above. The RD permits the Irish Cement to develop it alternative fuels strategy subject to the controls proposed in the RD. The RD gives effect to the requirements of the POE Act 2003. The RD has regard to submissions made.

Charges

The charge levied in 2010 under licence register number POO30-03 was €23,791. The RD proposes a charge of €36,3 19 due to an anticipated increased enforcement effort during the test programme and additional emissions monitoring, including dioxins, as a result of co-incineration of waste-derived fuels.

Recommendation

I recommend that a Proposed Determination be issued subject to the conditions and for the reasons as drafted in the RD.

Signed

Brian Meaney

Procedural Note

In the event that no objections are received to the Proposed Determination of the application, a licence will be granted in accordance with Section 87(4) of the Environmental Protection Agency Acts 1992 and 2003 as soon as may be after the expiration of the appropriate period.

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