APPENDIX III. Air Quality Modelling of NO X and PM 10 (2007) RFI Report (Dec 2007)

Transcription

1 APPENDIX III Air Quality Modelling of NO X and PM 10 (2007) RFI Report (Dec 2007) 17 EPA Export :22:32:47

2 Platin IPPC Licence Application Air Quality Modelling of NOx and PM (2007) EPA Export :22:32:47

3 Platin IPPC Licence Application Air Quality Modelling of NOx and PM (2007) Report for RFI (December 2007) December 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 10 Wellington Road, responsibility is undertaken to any third party Dublin 4 Ireland Tel Fax Job number D 5374/40 EPA Export :22:32:47

4 Platin IPPC Licence Application CONTENTS 1. INTRODUCTION METHODOLOGY Scenario Scenario Scenario Scenario Scenario Scenario Cumulative Impact Assessment AIR QUALITY STANDARDS NO 2 limit values (protection of human health) NO x limit values (protection of vegetation) PM 10 limit values (protection of human health) BACKGROUND CONCENTRATIONS DISPERSION MODELLING Emissions Building Wake Effect Receptor Locations Meteorological Data RESULTS Scenario Scenario Scenario Scenario Scenario Scenario CUMULATIVE IMPACT ASSESSMENT Location of maximum Location of Indaver maximum Location of SSE maximum CONCLUSIONS Scenarios 1 to Cumulative Impact Assessment EPA RFI Summary REFERENCES...39 Figures Page Figure 1 Isopleths of predicted annual mean NO 2 : Scenario 1 Figure 2 Isopleths of predicted annual mean PM 10 : Scenario 2 Figure 3 Isopleths of predicted annual mean NO 2 : Scenario 3 Figure 4 Isopleths of predicted annual mean PM 10 : Scenario 4 Figure 5 Isopleths of predicted annual mean NO 2 : Scenario 5 REPORT 2007_D _ISSUE3.DOC EPA Export :22:32:47

5 Platin IPPC Licence Application Figure 6 Isopleths of predicted annual mean PM 10 : Scenario 6 REPORT 2007_D _ISSUE3.DOC EPA Export :22:32:47

6 Platin IPPC Licence Application 1. INTRODUCTION Ltd. operates a cement plant at Platin, Co. Meath. This study assesses the dispersion of emissions to air of oxides of nitrogen (NO x ) and particulate matter (PM 10 ). This report has been prepared for the response to the EPA s request dated 15 November 2007 for further information (RFI) following clarification from the EPA as to their exact requirements. It updates the air quality modelling included in the EIS and the IPPC Licence Application. Several scenarios are presented because the current plant with the Kiln 1 Line will be operational only until the commissioning of the Kiln 3 Line in late 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 NO x concentrations. Scenario 2 addresses the PM 10 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 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 NO x concentrations. Scenario 4 addresses the PM 10 concentrations. The Kiln 3 Line will be commissioned in late Therefore Scenarios 3 and 4 apply from late 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 NO x concentrations. Scenario 6 addresses the PM 10 concentrations. Scenarios 5 and 6 apply from late NO 2 concentrations were calculated from the predicted NO x concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied. The results presented in the air dispersion modelling report for the IPPC Licence Application (Attachment I) were conservative, since 100% of total suspended particulates was assumed to be PM 10 and 60% was assumed to be PM 2.5. From particle size distribution (PSD) analysis carried out at Limerick in October 2007, 54% of total suspended particulates is PM 10 and 27% of total suspended particulates (or 49% of PM 10 ) is PM 2.5. This PSD analysis has been applied to the results. 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; Page 1 EPA Export :22:32:47

7 Platin IPPC Licence Application 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 NO x 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 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 Scenario 3 NO x emissions from three sources: Kiln 2, Kiln 3 and Coal Mill 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 Scenario 5 NO x 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. 2.7 Cumulative Impact Assessment Following clarification from the EPA, the cumulative impact assessment has been revised and expanded. Facilities have been proposed in the vicinity of s site at Platin by Indaver Ireland at Carranstown and by Scottish and Southern Energy Plc. (SSE) between Carranstown and Caulstown. The planning permission for the SSE facility has lapsed and ICL has been advised by consultants to SSE (2007) that they are not proceeding with this development. Since the planning permission for the SSE facility has lapsed that development cannot proceed without a further grant of planning permission. Nevertheless the predicted concentrations due to the SSE 400MW facility have been included in the cumulative impact assessment, as provided in December 2007 by SSE through their air dispersion modelling consultants. The most recent data for the Indaver facility has been used, as provided by Indaver through their air dispersion modelling consultants (Indaver, 2007). Page 2 EPA Export :22:32:47

8 Platin IPPC Licence Application 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 (NO x ), nitrogen dioxide (NO 2 ) and particulate matter of diameter less than 10 microns (PM 10 ). Table 1 shows the AQS Limit Values relevant to the assessment of the Platin facility. The Air Quality Standards Limit Values are referred to in this report as AQSs, 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 PM 10 Stage 1 AQS of 40μg/m 3 to 2015 instead of introducing the Stage 2 AQS of 20μg/m 3 (CEC, 2005). It is also proposed by the EU to introduce a concentration cap for annual mean PM 2.5 of 25μg/m 3 to be attained by 1 January 2010 (CEC, 2005). There is no Irish AQS for PM 2.5. Table 1 Air Quality Standards (AQS Regulations S.I. No. 271 of 2002 and CEC 2005) Pollutant NO 2 Limit value for the protection of: human health Averaging period Limit value (μg/m 3 ) 1-hour 200 Basis of application of limit value 18 exceedances p.a. Limit value attainment date 1 January 2010 Calendar year 40 Annual mean NO x vegetation Calendar year 30 Annual mean 19 July 2001 PM 10 human health 24-hours exceedances p.a. 1 January 2005 Calendar year 40 Annual mean 24-hours 50 7 exceedances p.a. 1 January 2010 Calendar year 20 Annual mean PM 2.5 human health Calendar year 25 cap 1 January NO 2 limit values (protection of human health) According to the Regulations, the AQSs for NO 2 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 NO 2 are to be attained by 1 January NO x limit values (protection of vegetation) According to the Regulations, the AQS for NO x for the protection of vegetation is 30μg/m³ over 1 year, effective from 19 July PM 10 limit values (protection of human health) According to the Regulations, the AQSs for PM 10 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 PM 10 have been effective from 1 January According to the Regulations, from 1 January 2010 the AQSs for PM 10 for the protection of human health will be 20μg/m³ over 1 year and 50μg/m³ over 24 hours, where the 24-hour AQS is not to be exceeded more than 7 times in a calendar year. Page 3 EPA Export :22:32:47

9 Platin IPPC Licence Application AQSs for Particulate Matter (PM 10 ) are set out in Annex III of EU Directive 1999/30/EC. The Irish AQS Regulations are for the purpose of giving effect to Council Directives 1999/30/EC and follow the Stage 1 and Stage 2 approach for PM 10 set out in Annex III of EU Directive 1999/30/EC. Annex III (of EU Directive 1999/30/EC) includes the caveat to the Stage 2 Limit Values that these are Indicative limit values to be reviewed in the light of further information on health and environmental effects, technical feasibility and experience in the application of Stage 1 limit values in the Member States. This caveat is not included in the Irish AQS Regulations. The review of the EU Stage 2 Limit Values resulted in the proposal to extend the PM 10 Stage 1 AQS of 40μg/m 3 to 2015 instead of introducing the Stage 2 AQS of 20μg/m 3 (CEC, 2005). This proposal is included in the common position agreed between the Commission and the Parliament (CEC, 2007). Monitoring of ambient air quality in Ireland, carried out or coordinated by the EPA, will have contributed to the EU database used in the review of the Stage 2 Limit Values. This review resulted in the proposed decision to extend the PM 10 Stage 1 AQS of 40μg/m 3 to 2015 instead of introducing the Stage 2 AQS of 20μg/m 3 (CEC, 2005). Average concentrations per zone in Ireland (EPA, 2007) were 85% to 123% of the Stage 2 Limit Value of 20μg/m 3, which would allow little or no scope for source contributions over and above the background concentration. 4. BACKGROUND CONCENTRATIONS The site is classified as Zone D since it is outside Drogheda town (which is classified as Zone C). s 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 NO x (8.3μg/m 3 ), NO 2 (5.7μg/m 3 ) and PM 10 (15.3μg/m 3 ). Average PM 10 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 Platin is not a coastal site. The annual mean concentration of PM 10 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 PM 10 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. PM 2.5 has a proposed concentration cap rather than a limit value (CEC, 2005). The annual mean background concentration for PM 2.5 (9.2 μg/m 3 ) was derived from the PM 10 concentrations using a ratio of 0.60 (EC, 2004). Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance. 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; Page 4 EPA Export :22:32:47

10 Platin IPPC Licence Application 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. 5.1 Emissions The emission sources for each of the six scenarios are given in Table 2. Scenarios 1, 3 and 5 assess the NO x emissions. Scenarios 2, 4 and 6 address the PM 10 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 would never be realised in practice. Page 5 EPA Export :22:32:47

11 Platin IPPC Licence Application 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) H (m) Diameter (m ID) Volume flowrate (Nm 3 /hour, wet gas, actual O 2 ) Volume flowrate (Nm 3 /hour, dry gas, 10% O 2 ) Efflux velocity (m/s, wet, actual T, actual O 2 ) T ( C) Scenario 1 NOx (mg/nm 3 ) Scenario 2 Particulates (mg/nm 3 ) Scenario 3 NOx (mg/nm 3 ) Scenario 4 Particulates (mg/nm 3 ) Scenario 5 NOx (mg/nm 3 ) Scenario 6 Particulates (mg/nm 3 ) , , , , , , ,000 A 400,000 31, , A A 118 B A Scenarios 1 and 2. B Scenarios 5 and 6. Scenarios 1a-4a, 5a.i & 6a.i. Page 6 EPA Export :22:32:47

12 Platin IPPC Licence Application 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 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 NO x emissions were modelled for three sources (Table 2). The Kiln 1 emission point incorporates emissions from Kiln 1, Raw Mill 1 and Coal Mill Predicted concentrations of NO 2 (protection of human health) The maximum ground-level concentrations under Scenario 1 are compared to the AQS for NO 2 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 NO 2 are to be attained by 1 January The maximum ground-level concentrations under Scenario 1 are predicted to be 52% of the AQS for 1-hour NO 2 and 31% of the AQS for annual NO 2. 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 th %ile 1-hour concentration and therefore it cannot be included as a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS. Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied (Section ) at a level of twice the annual average background concentration, according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance. As stated in Section 2, nitrogen dioxide (NO 2 ) concentrations were calculated from the predicted NO x concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied (UK EA, 2005) in Section Page 7

13 Platin IPPC Licence Application 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 NO 2 for Scenario 1 (excluding background concentration). Table 3 Predicted concentrations of NO 2 (μg/m 3 ) for Scenario 1 (NO 2 ) (μg/m 3 ) th %ile 1-hour % Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP083.dat-ICP087.dat Proportions of NO x to NO 2 As stated in Section 2 and above, nitrogen dioxide (NO 2 ) concentrations were calculated from the predicted NO x concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied (UK EA, 2005). In Table 4 the short-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 0.5, whereas the long-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 1.0 (UK EA, 2005). The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour. Table 4 Predicted concentrations of NO 2 (μg/m 3 ) for Scenario 1 (50% and 100%) (NO 2 ) (μg/m 3 ) as % of AQS th %ile 1-hour % Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP083.dat-ICP087.dat According to the same methodology (UK EA, 2005), conversion factors of 0.35 for short-term and 0.70 for long-term can also be applied. In Table 5 the short-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 0.35, whereas the long-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 0.7 (UK EA, 2005). The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour. Page 8

14 Platin IPPC Licence Application Table 5 Predicted concentrations of NO 2 (μg/m 3 ) for Scenario 1 (35% and 70%) (NO 2 ) (μg/m 3 ) as % of AQS th %ile 1-hour % Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP083.dat-ICP087.dat Short-term background concentration EPA monitoring does not include th %ile 1-hour concentration and therefore it cannot be included as a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS. Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied at a level of twice the annual average background concentration, according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance. In Table 6 the short-term background concentration is taken to be twice the long-term background concentration. The short-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 0.5, which is conservative compared to the conversion factor of 0.35 also used by the UK EA (2005). Table 6 Predicted concentrations of NO 2 (μg/m 3 ) for Scenario 1 (NO 2 ) (μg/m 3 ) th %ile 1-hour % 2 x Annual mean background (measured by EPA in 2006) % ICP083.dat-ICP087.dat Total % Predicted concentrations of NO x (protection of vegetation) The maximum ground-level concentrations under Scenario 1 are compared to the AQS for NO x for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NO x has been in effect since 19 July The maximum ground-level concentrations under Scenario 1 are predicted to be 71% of the AQS for annual NO x. Of this, 44% is due to the emissions from the cement works and 28% is due to the background concentration (Table 7). The predicted concentrations comply with the AQS of 30μg/m³ over 1 year. Table 7 Predicted concentrations of NO x (μg/m 3 ) for Scenario 1 (NO x ) (μg/m 3 ) Calendar year % Page 9

15 Platin IPPC Licence Application Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP083.dat-ICP087.dat 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 PM 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 results presented in the air dispersion modelling report for the IPPC Licence Application (Attachment I) were conservative, since 100% of total suspended particulates were assumed to be PM 10 and 60% were assumed to be PM 2.5. From particle size distribution (PSD) analysis carried out at Limerick in October 2007, 27% of total suspended particulates (or 49% of PM 10 ) are PM 2.5 (Table 8). This PSD analysis has been applied to the results. Table 8 Results of particulate size distribution analysis TSP PM10 PM2.5 Assumed Attachment I 100% of TSP 100% of TSP 60% of TSP Measured Particle size distribution 100% of TSP 54% of TSP 27% of TSP 49% of PM10 The maximum ground-level concentrations under Scenario 2 are compared to the AQSs for PM 10 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 PM 10 have been effective from 1 January The maximum ground-level concentrations under Scenario 2 are predicted to be 25% of the AQS for 24-hour PM 10 and 49% of the AQS for annual PM 10. In the case of the annual concentration, 11% is due to the emissions and 38% is due to the background concentration (Table 9). EPA monitoring does not include a 24-hour concentration, and therefore it is not possible to include such a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS. Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations at a level of twice the annual average background concentration, have also been applied (Section 6.2.1) according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance. The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 50μg/m³ over 24 hours. Figure 2 shows the isopleths (concentration contours) of predicted annual mean PM 10 for Scenario 2 (excluding background concentration). It is also proposed by the EU to introduce a concentration cap for annual mean PM 2.5 of 25μg/m 3 to be attained by 1 January 2010 (CEC, 2005). There is no Irish AQS for PM 2.5. s for PM 2.5 were derived from the PM concentrations using the PSD (Table 8). The background concentration of PM 2.5 was derived from the PM 10 concentrations measured by the EPA in 2006 (EPA, 2007) using a ratio of 0.60 (EC, 2004). Page 10

16 Platin IPPC Licence Application The predicted concentrations comply with the proposed concentration cap AQS of 25μg/m 3 (Table 10). Table 9 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 2 (PM 10 ) (μg/m 3 ) st %ile 24-hour % Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP088.dat-ICP092.dat Table 10 Predicted concentrations of PM 2.5 (μg/m 3 ) for Scenario 2 (PM 2.5 ) (μg/m 3 ) Calendar year 2.2 9% Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP088.dat-ICP092.dat Short-term background concentration Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied at a level of twice the annual average background concentration, according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance. In Table 11 the short-term background concentration is taken to be twice the long-term background concentration. Table 11 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 2 (PM 10 ) (μg/m 3 ) st %ile 24-hour % 2 x Annual mean background (measured by EPA in 2006) % ICP088.dat-ICP092.dat Total % Comparison with the AQSs for particulate matter Stage 2 (2010) The maximum ground-level concentrations due to the emissions under Scenario 2 are compared to the AQSs for PM 10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM 10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002). The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in The Irish AQS Regulations (2002) do not refer to PM 2.5. Page 11

17 Platin IPPC Licence Application The maximum ground-level concentrations due to the emissions under Scenario 2 are predicted to be 93% of the AQS for annual PM 10. Of this, 22% is due to the emissions and 71% is due to the background concentration. The predicted concentrations comply with the AQS of 20μg/m³ over 1 year. Table 12 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 2 ICP088.dat-ICP092.dat (PM 10 ) (μg/m 3 ) Calendar year % Annual mean background (2010) % Total % Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied at a level of twice the annual average background concentration, according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance. The maximum ground-level concentrations due to the emissions under Scenario 2 are predicted to be 93% of the AQS for 24-hour PM 10. Of this, 36% is due to the source contributions and 71% is due to the background concentration. The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours. Table 13 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 2 ICP088.dat-ICP092.dat (PM 10 ) (μg/m 3 ) 98.08th%ile 24-hour % 2 x Annual mean background (2010) % Total % 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 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 12.5μg/m 3 for st %ile 24-hour PM 10 and 4.4μg/m 3 for annual PM 10. These can be compared to the maximum ground-level concentrations under Scenario 2 of 12.4μg/m 3 for st %ile 24-hour PM 10 and 4.4μg/m 3 for annual PM 10. The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 50μg/m³ over 24 hours Short-term background concentration Following consultation with the EPA, background concentrations for consideration with the short-term average PM 10 concentration have also been applied at a level of twice the annual average background concentration (UK EA, 2002). In Table 14 the short-term background concentration is taken to be twice the long-term background concentration. Page 12

18 Platin IPPC Licence Application Table 14 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 2 with Cement Mill 4 (PM 10 ) (μg/m 3 ) st %ile 24-hour % 2 x Annual mean background (measured by EPA in 2006) % ICP158.dat-ICP162.dat Total % Comparison with the AQSs for particulate matter Stage 2 (2010) The maximum ground-level concentrations due to the emissions under Scenario 2 with Cement Mill 4 are compared to the AQSs for PM 10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM 10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002). The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in The Irish AQS Regulations (2002) do not refer to PM 2.5. The maximum ground-level concentrations due to the emissions under Scenario 2 with Cement Mill 4 are predicted to be 93% of the AQS for annual PM 10. Of this, 22% is due to the emissions and 71% is due to the background concentration. The predicted concentrations comply with the AQS of 20μg/m³ over 1 year. Table 15 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 2 with Cement Mill 4 ICP158.dat-ICP162.dat (PM 10 ) (μg/m 3 ) Calendar year % Annual mean background (2010) % Total % The maximum ground-level concentrations due to the emissions under Scenario 2 with Cement Mill 4 are predicted to be 36% of the AQS for 24-hour PM 10. As per the EPA s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the maximum ground-level concentrations due to the emissions under Scenario 2 with Cement Mill 4 are predicted to be 93% of the AQS for 24-hour PM 10. Of this, 36% is due to the source contributions and 71% is due to the background concentration. The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours. Page 13

19 Platin IPPC Licence Application Table 16 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 2 with Cement Mill 4 ICP158.dat-ICP162.dat (PM 10 ) (μg/m 3 ) 98.08th%ile 24-hour % 2 x Annual mean background (2010) % Total % 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 NO x emissions were modelled for three sources (Table 2) Predicted concentrations of NO 2 (protection of human health) The maximum ground-level concentrations under Scenario 3 are compared to the AQS for NO 2 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 NO 2 are to be attained by 1 January The maximum ground-level concentrations under Scenario 3 are predicted to be 43% of the AQS for 1-hour NO 2 and 29% of the AQS for annual NO 2. In the case of the annual concentration, 14% is due to the emissions from the cement works and 14% is due to the background concentration. EPA monitoring does not include th %ile 1-hour concentration and therefore it cannot be included as a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS. Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied at a level of twice the annual average background concentration, (Section ) according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance. As stated in Section 2, nitrogen dioxide (NO 2 ) concentrations were calculated from the predicted NO x concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied (UK EA, 2005) in Section The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour. Figure 3 shows the isopleths (concentration contours) of predicted annual mean NO 2 for Scenario 3 (excluding background concentration). Table 17 Predicted concentrations of NO 2 (μg/m 3 ) for Scenario 3 (NO 2 ) (μg/m 3 ) th %ile 1-hour % Calendar year % Page 14

20 Platin IPPC Licence Application Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP093.dat-ICP097.dat Proportions of NO x to NO 2 As stated in Section 2 and above, nitrogen dioxide (NO 2 ) concentrations were calculated from the predicted NO x concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied (UK EA, 2005). In Table 18 the short-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 0.5, whereas the long-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 1.0. In Table 19 the short-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 0.35, whereas the long-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 0.7. Table 18 Predicted concentrations of NO 2 (μg/m 3 ) for Scenario 3 (50% and 100%) (NO 2 ) (μg/m 3 ) th %ile 1-hour % Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP093.dat-ICP097.dat Table 19 Predicted concentrations of NO 2 (μg/m 3 ) for Scenario 3 (35% and 70%) (NO 2 ) (μg/m 3 ) th %ile 1-hour % Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP093.dat-ICP097.dat The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour Short-term background concentration Again, following consultation with the EPA, background concentrations for consideration with the short-term average NO 2 concentration have also been applied (UK EA, 2002). In Table 20 the short-term background concentration is taken to be twice the long-term background concentration. Page 15

21 Platin IPPC Licence Application Table 20 Predicted concentrations of NO 2 (μg/m 3 ) for Scenario 3 (NO 2 ) (μg/m 3 ) th %ile 1-hour % 2 x Annual mean background (measured by EPA in 2006) % ICP093.dat-ICP097.dat Total % Predicted concentrations of NO x (protection of vegetation) The maximum ground-level concentrations under Scenario 3 are compared to the AQS for NO x for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NO x has been in effect since 19 July The maximum ground-level concentrations under Scenario 3 are predicted to be 66% of the AQS for annual NO x. Of this, 38% is due to the emissions from the cement works and 28% is due to the background concentration. The predicted concentrations comply with the AQS of 30μg/m³ over 1 year. Table 21 Predicted concentrations of NO x (μg/m 3 ) for Scenario 3 (NO x ) (μg/m 3 ) Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP093.dat-ICP097.dat 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 PM emissions were modelled for nine sources (Table 2). The results presented in the air dispersion modelling report for the IPPC Licence Application (Attachment I) were conservative, since 100% of total suspended particulates were assumed to be PM 10 and 60% were assumed to be PM 2.5. From particle size distribution (PSD) analysis carried out at Limerick in October 2007, 27% of total suspended particulates (or 49% of PM 10 ) are PM 2.5 (Table 8). This PSD analysis has been applied to the results. The maximum ground-level concentrations under Scenario 4 are compared to the AQSs for PM 10 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 PM 10 have been effective from 1 January The maximum ground-level concentrations under Scenario 4 are predicted to be 25% of the AQS for 24-hour PM 10 and 49% of the AQS for annual PM 10. In the case of the annual concentration, 11% is due to the emissions and 38% is due to the background concentration. EPA monitoring does not include a 24-hour concentration, and therefore it is not possible to include such a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS. Page 16

22 Platin IPPC Licence Application Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied at a level of twice the annual average background concentration, (Section 6.4.1) according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance. The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 50μg/m³ over 24 hours. Figure 4 shows the isopleths (concentration contours) of predicted annual mean PM 10 for Scenario 4 (excluding background concentration). It is also proposed by the EU to introduce a concentration cap for annual mean PM 2.5 of 25μg/m 3 to be attained by 1 January 2010 (CEC, 2005). ). There is no Irish AQS for PM 2.5. s for PM 2.5 were derived from the PM concentrations using the PSD (Table 8). The background concentration of PM 2.5 was derived from the PM 10 concentrations measured by the EPA in 2006 (EPA, 2007) using a ratio of 0.60 (EC, 2004). The predicted concentrations comply with the proposed concentration cap AQS of 25μg/m 3. Table 22 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 4 Maximum st %ile 24-hour % Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP098.dat-ICP102.dat Table 23 Predicted concentrations of PM 2.5 (μg/m 3 ) for Scenario 4 Calendar year 2.2 9% Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP098.dat-ICP102.dat Short-term background concentration Following consultation with the EPA, background concentrations for consideration with the short-term average PM 10 concentration have also been applied (UK EA, 2002). In Table 24 the short-term background concentration is taken to be twice the long-term background concentration. Table 24 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 4 (PM 10 ) (μg/m 3 ) st %ile 24-hour % 2 x Annual mean background (measured by EPA in 2006) % ICP098.dat-ICP102.dat Total % Page 17

23 Platin IPPC Licence Application Comparison with the AQSs for particulate matter Stage 2 (2010) The maximum ground-level concentrations due to the emissions under Scenario 4 are compared to the AQSs for PM 10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM 10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002). The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in The Irish AQS Regulations (2002) do not refer to PM 2.5. The maximum ground-level concentrations due to the emissions under Scenario 4 are predicted to be 94% of the AQS for annual PM 10. Of this, 23% is due to the emissions and 71% is due to the background concentration. The predicted concentrations comply with the AQS of 20μg/m³ over 1 year. Table 25 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 4 ICP098.dat-ICP102.dat (PM 10 ) (μg/m 3 ) Calendar year % Annual mean background (2010) % Total % The maximum ground-level concentrations due to the emissions under Scenario 4 are predicted to be 37% of the AQS for 24-hour PM 10. As per the EPA s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the maximum ground-level concentrations due to the emissions under Scenario 4 are predicted to be 93% of the AQS for 24-hour PM 10. Of this, 37% is due to the source contributions and 56% is due to the background concentration. The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours. Table 26 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 4 ICP098.dat-ICP102.dat 6.5 Scenario 5 (PM 10 ) (μg/m 3 ) 98.08th%ile 24-hour % 2 x Annual mean background (2010) % Total % 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 NO x emissions were modelled for four sources (Table 2). Page 18

24 Platin IPPC Licence Application Predicted concentrations of NO 2 (protection of human health) The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO 2 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 NO 2 are to be attained by 1 January The maximum ground-level concentrations under Scenario 5 are predicted to be 43% of the AQS for 1-hour NO 2 and 30% of the AQS for annual NO 2. In the case of the annual concentration, 16% is due to the emissions from the cement works and 14% is due to the background concentration. EPA monitoring does not include th %ile 1-hour concentration and therefore it cannot be included as a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS. Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations at a level of twice the annual average background concentration, have also been applied (Section ) according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance. As stated in Section 2, nitrogen dioxide (NO 2 ) concentrations were calculated from the predicted NO x concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied (UK EA, 2005) in Section The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour. Figure 5 shows the isopleths (concentration contours) of predicted annual mean NO 2 for Scenario 5 (excluding background concentration). Table 27 Predicted concentrations of NO 2 (μg/m 3 ) for Scenario 5 (NO 2 ) (μg/m 3 ) th %ile 1-hour % Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP143.dat-ICP147.dat Proportions of NO x to NO 2 As stated in Section 2 and above, nitrogen dioxide (NO 2 ) concentrations were calculated from the predicted NO x concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied (UK EA, 2005). In Table 28 the short-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 0.5, whereas the long-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 1.0. In Table 29 the short-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 0.35, whereas the long-term average NO 2 concentration was calculated from the predicted NO x concentrations using a conversion factor of 0.7. Page 19

25 Platin IPPC Licence Application Table 28 Predicted concentrations of NO 2 (μg/m 3 ) for Scenario 5 (50% and 100%) (NO 2 ) (μg/m 3 ) th %ile 1-hour % Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP143.dat-ICP147.dat Table 29 Predicted concentrations of NO 2 (μg/m 3 ) for Scenario 5 (35% and 70%) (NO 2 ) (μg/m 3 ) th %ile 1-hour % Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP143.dat-ICP147.dat The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour Short-term background concentration Again, following consultation with the EPA, background concentrations for consideration with the short-term average NO 2 concentration have also been applied (UK EA, 2002). In Table 30 the short-term background concentration is taken to be twice the long-term background concentration. Table 30 Predicted concentrations of NO 2 (μg/m 3 ) for Scenario 5 (NO 2 ) (μg/m 3 ) th %ile 1-hour % 2 x Annual mean background (measured by EPA in 2006) % ICP143.dat-ICP147.dat Total % Predicted concentrations of NO x (protection of vegetation) The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO x for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NO x has been in effect since 19 July The maximum ground-level concentrations under Scenario 5 are predicted to be 69% of the AQS for annual NO x. Of this, 42% is due to the emissions from the cement works and 28% is due to the background concentration. The predicted concentrations comply with the AQS of 30μg/m³ over 1 year. Page 20

26 Platin IPPC Licence Application Table 31 Predicted concentrations of NO x (μg/m 3 ) for Scenario 5 (NO x ) (μg/m 3 ) Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP143.dat-ICP147.dat 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 PM 10 emissions were modelled for ten sources (Table 2). The results presented in the air dispersion modelling report for the IPPC Licence Application (Attachment I) were conservative, since 100% of total suspended particulates were assumed to be PM 10 and 60% were assumed to be PM 2.5. From particle size distribution (PSD) analysis carried out at Limerick in October 2007, 27% of total suspended particulates (or 49% of PM 10 ) are PM 2.5 (Table 8). This PSD analysis has been applied to the results. The maximum ground-level concentrations under Scenario 6 are compared to the AQSs for PM 10 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 PM 10 have been effective from 1 January The maximum ground-level concentrations under Scenario 6 are predicted to be 25% of the AQS for 24-hour PM 10 and 49% of the AQS for annual PM 10. In the case of the annual concentration, 11% is due to the emissions and 38% is due to the background concentration. EPA monitoring does not include a 24-hour concentration, and therefore it is not possible to include such a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS. Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations at a level of twice the annual average background concentration, have also been applied (Section 6.6.1) according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance. The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 50μg/m³ over 24 hours. Figure 6 shows the isopleths (concentration contours) of predicted annual mean PM 10 for Scenario 6 (excluding background concentration). It is also proposed by the EU to introduce a concentration cap for annual mean PM 2.5 of 25μg/m 3 to be attained by 1 January 2010 (CEC, 2005). ). There is no Irish AQS for PM 2.5. s for PM 2.5 were derived from the PM concentrations using the PSD (Table 8). The background concentration of PM 2.5 was derived from the PM 10 concentrations measured by the EPA in 2006 (EPA, 2007) using a ratio of 0.60 (EC, 2004). The predicted concentrations comply with the proposed concentration cap AQS of 25μg/m 3. Page 21

27 Platin IPPC Licence Application Table 32 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 6 Maximum st %ile 24-hour % Calendar year % Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP148.dat-ICP152.dat Table 33 Predicted concentrations of PM 2.5 (μg/m 3 ) for Scenario 6 Calendar year 2.2 9% Annual mean background (measured by EPA in 2006) % Calendar year including annual mean background % ICP148.dat-ICP152.dat Short-term background concentration Following consultation with the EPA, background concentrations for consideration with the short-term average PM 10 concentration have also been applied (UK EA, 2002). In Table 34 the short-term background concentration is taken to be twice the long-term background concentration. Table 34 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 6 (PM 10 ) (μg/m 3 ) st %ile 24-hour % 2 x Annual mean background (measured by EPA in 2006) % ICP148.dat-ICP152.dat Total % Comparison with the AQSs for particulate matter Stage 2 (2010) The maximum ground-level concentrations due to the emissions under Scenario 6 are compared to the AQSs for PM 10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM 10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002). The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in The Irish AQS Regulations (2002) do not refer to PM 2.5. The maximum ground-level concentrations due to the emissions under Scenario 6 are predicted to be 94% of the AQS for annual PM 10. Of this, 23% is due to the emissions and 71% is due to the background concentration. The predicted concentrations comply with the AQS of 20μg/m³ over 1 year. Page 22

28 Platin IPPC Licence Application Table 35 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 6 ICP148.dat-ICP152.dat (PM 10 ) (μg/m 3 ) Calendar year % Annual mean background (2010) % Total % The maximum ground-level concentrations due to the emissions under Scenario 6 are predicted to be 37% of the AQS for 24-hour PM 10. As per the EPA s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the maximum ground-level concentrations due to the emissions under Scenario 6 are predicted to be 93% of the AQS for 24-hour PM 10. Of this, 37% is due to the source contributions and 56% is due to the background concentration. The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours. Table 36 Predicted concentrations of PM 10 (μg/m 3 ) for Scenario 6 ICP148.dat-ICP152.dat (PM 10 ) (μg/m 3 ) 98.08th%ile 24-hour % 2 x Annual mean background (2010) % Total % 7. CUMULATIVE IMPACT ASSESSMENT Facilities have been proposed in the vicinity of s site at Platin by Indaver Ireland at Carranstown and by Scottish and Southern Energy Plc. (SSE) between Carranstown and Caulstown. The planning permission for the SSE facility has lapsed and ICL has been advised by consultants to SSE (2007) that they are not proceeding with this development. At the request of the EPA, the cumulative effect of the proposed developments was assessed by considering the ambient air quality and the source contributions due to Platin, Indaver and SSE. The cumulative effects were assessed for the locations of the maximum concentrations due to each of the three sources. That is, the source contributions due to Irish Cement, Indaver and SSE at the location of the maximum concentration due to were summed with the background concentration to give the cumulative effect. This was repeated for the locations of the maximum concentration due to Indaver and to SSE. Predicted concentrations due to Indaver and SSE at each of the locations of maximum GLCs have been provided to for this cumulative impact assessment by Indaver and by SSE from their own air dispersion modelling. This approach is robust and allowed for a comprehensive cumulative impact assessment. The planning permission for the SSE 400MW facility has lapsed and therefore that development cannot proceed without a further grant of planning permission. Nevertheless the Page 23

29 Platin IPPC Licence Application predicted concentrations due to the SSE 400MW facility have been included in the cumulative impact assessment. The most recent data for the Indaver facility has been used, as provided by Indaver through their air dispersion modelling consultants (Indaver, 2007). Following consultation with the EPA, background concentrations for consideration with the short-term average NO 2 concentration have also been applied according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance. 7.1 Location of maximum Predicted concentrations of annual mean NO 2 (μg/m 3 ) The maximum concentration due to is predicted to occur at (307080, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to is shown in Table 37. The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO 2 for the protection of human health of 40μg/m³ over 1 year. The AQS for NO 2 is to be attained by 1 January The cumulative impact of the maximum ground-level concentrations is predicted to be 31% of the AQS for annual NO 2. Of this, 17% is due to the source contributions and 14% is due to the background concentration. The predicted concentrations comply with the AQS of 40μg/m³ over 1 year. Table 37 Predicted concentrations of NO 2 (μg/m 3 ) for maximum Annual mean (NO 2 ) (μg/m 3 ) % Indaver 0.3 1% SSE 0.2 1% Sum of source contributions % Annual mean background (measured by EPA in 2006) % ICP143.dat, Indaver (2007) and SSE (2007) Proportions of NO x to NO 2 Total % In Section above, the nitrogen dioxide (NO 2 ) concentrations were calculated from the predicted NO x concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, the most conservative approach has been taken: a conversion factor of 1 has also been applied to the long-term average concentration due to the sum of the source contributions (UK EA, 2005). The predicted concentrations comply with the AQS of 40μg/m³ over 1 year. Page 24

30 Platin IPPC Licence Application Table 38 Predicted concentrations of NO 2 (μg/m 3 ) for for maximum Annual mean (NO 2 ) (μg/m 3 ) Sum of source contributions % Annual mean background (measured by EPA in 2006) % ICP143.dat, Indaver (2007) and SSE (2007) Total % Predicted concentrations of 1-hour NO 2 (μg/m 3 ) The maximum concentration due to is predicted to occur at (307180, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to is shown in Table 39. The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO 2 for the protection of human health of 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQS for NO 2 is to be attained by 1 January The cumulative impact of the maximum ground-level concentrations is predicted to be 56% of the AQS for 1-hour NO 2. As per the EPA s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 62% of the AQS for 1-hour NO 2. Of this, 56% is due to the source contributions and 6% is due to the background concentration. The predicted concentrations comply with the AQS of 200μg/m³ over 1 hour. Table 39 Predicted concentrations of NO 2 (μg/m 3 ) for maximum th %ile 1-hour (NO 2 ) (μg/m 3 ) % Indaver 4.9 2% SSE % Sum of source contributions % 2 x Annual mean background (measured by EPA in 2006) % ICP143.dat, Indaver (2007) and SSE (2007) Predicted concentrations of NO x (μg/m 3 ) Total % The maximum concentration due to is predicted to occur at (307080, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to is shown in Table 40. The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO x for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NO x has been effective since 19 July Page 25

31 Platin IPPC Licence Application The cumulative impact of the maximum ground-level concentrations is predicted to be 71% of the AQS for annual NO 2. Of this, 44% is due to the source contributions and 28% is due to the background concentration. The predicted concentrations comply with the AQS of 30μg/m³ over 1 year. Table 40 Predicted concentrations of NO x (μg/m 3 ) for maximum Annual mean (NO x ) (μg/m 3 ) % Indaver 0.4 1% SSE 0.2 1% Sum of source contributions % Annual mean background (measured by EPA in 2006) % ICP143.dat, Indaver (2007) and SSE (2007) Total % Predicted concentrations of annual mean PM 10 (μg/m 3 ) The maximum concentration due to is predicted to occur at (307080, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to is shown in Table 41. The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM 10 for the protection of human health of 40μg/m³ over 1 year. The AQSs for PM 10 have been effective from 1 January The cumulative impact of the maximum ground-level concentrations is predicted to be 50% of the AQS for annual PM 10. Of this, 12% is due to the source contributions and 38% is due to the background concentration. The predicted concentrations comply with the AQS of 40μg/m³ over 1 year. Table 41 Predicted concentrations of PM 10 (μg/m 3 ) for maximum Annual mean (PM 10 ) (μg/m 3 ) % Indaver 0.1 <1% SSE 0.1 <1% Sum of source contributions % Annual mean background (measured by EPA in 2006) % ICP149.dat, Indaver (2007) and SSE (2007) Total % Predicted concentrations of 24-hour PM 10 (μg/m 3 ) The maximum concentration due to is predicted to occur at (307080, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to is shown in Table 42. Page 26

32 Platin IPPC Licence Application The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM 10 for the protection of human health of 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 PM 10 have been effective from 1 January The cumulative impact of the maximum ground-level concentrations is predicted to be 26% of the AQS for 24-hour PM 10. As per the EPA s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 87% of the AQS for 24-hour PM 10. Of this, 26% is due to the source contributions and 61% is due to the background concentration. The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours. Table 42 Predicted concentrations of PM 10 (μg/m 3 ) for maximum st %ile 24-hour (PM 10 ) (μg/m 3 ) % Indaver 0.1 <1% SSE 0.4 1% Sum of source contributions % 2 x Annual mean background (measured by EPA in 2006) % ICP149.dat, Indaver (2007) and SSE (2007) Total % Comparison with the AQSs for particulate matter Stage 2 (2010) The maximum ground-level concentrations due to the emissions under Scenario 6 are compared to the AQSs for PM 10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM 10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002). The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in The Irish AQS Regulations (2002) do not refer to PM 2.5. The cumulative impact of the maximum ground-level concentrations is predicted to be 94% of the AQS for annual PM 10. Of this, 23% is due to the source contributions and 71% is due to the background concentration. Page 27

33 Platin IPPC Licence Application The predicted concentrations comply with the AQS of 20μg/m³ over 1 year. Table 43 Predicted concentrations of PM 10 (μg/m 3 ) for maximum Annual mean (PM 10 ) (μg/m 3 ) % Indaver 0.1 <1% SSE 0.1 <1% Sum of source contributions % Annual mean background (2010) % ICP149.dat, Indaver (2007) and SSE (2007) Total % The cumulative impact of the maximum ground-level concentrations is predicted to be 40% of the AQS for 24-hour PM 10. As per the EPA s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 96% of the AQS for 24-hour PM 10. Of this, 40% is due to the source contributions and 56% is due to the background concentration. The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours. Table 44 Predicted concentrations of PM 10 (μg/m 3 ) for maximum 98.08th%ile 24-hour (PM 10 ) (μg/m 3 ) % Indaver 0.2 <1% SSE 1.4 3% Sum of source contributions % 2 x Annual mean background (2010) % ICP149.dat, Indaver (2007) and SSE (2007) Total % 7.2 Location of Indaver maximum Predicted concentrations of annual mean NO 2 (μg/m 3 ) The maximum concentration due to Indaver is predicted to occur at (306950, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to Indaver is shown in Table 45. The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO 2 for the protection of human health of 40μg/m³ over 1 year. The AQS for NO 2 is to be attained by 1 January Page 28

34 Platin IPPC Licence Application The cumulative impact of the maximum ground-level concentrations is predicted to be 22% of the AQS for annual NO 2. Of this, 7% is due to the source contributions and 14% is due to the background concentration. The predicted concentrations comply with the AQS of 40μg/m³ over 1 year. Table 45 Predicted concentrations of NO 2 (μg/m 3 ) for Indaver maximum Annual mean (NO 2 ) (μg/m 3 ) 1.6 4% Indaver 1.1 3% SSE 0.2 0% Sum of source contributions 2.9 7% Annual mean background (measured by EPA in 2006) % ICP143.dat, Indaver (2007) and SSE (2007) Proportions of NO x to NO 2 Total % In Section above, the nitrogen dioxide (NO 2 ) concentrations were calculated from the predicted NO x concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, the most conservative approach has been taken: a conversion factor of 1 has also been applied to the long-term average concentration due to the sum of the source contributions (UK EA, 2005). The predicted concentrations comply with the AQS of 40μg/m³ over 1 year. Table 46 Predicted concentrations of NO 2 (μg/m 3 ) for for maximum Annual mean (NO 2 ) (μg/m 3 ) Sum of source contributions % Annual mean background (measured by EPA in 2006) % ICP143.dat, Indaver (2007) and SSE (2007) Total % Predicted concentrations of 1-hour NO 2 (μg/m 3 ) The maximum concentration due to is predicted to occur at (307180, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to is shown in Table 47. The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO 2 for the protection of human health of 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQS for NO 2 is to be attained by 1 January The cumulative impact of the maximum ground-level concentrations is predicted to be 39% of the AQS for 1-hour NO 2. As per the EPA s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the Page 29

35 Platin IPPC Licence Application maximum ground-level concentrations is predicted to be 45% of the AQS for 1-hour NO 2. Of this, 39% is due to the source contributions and 6% is due to the background concentration. The predicted concentrations comply with the AQS of 200μg/m³ over 1 hour. Table 47 Predicted concentrations of NO 2 (μg/m 3 ) for Indaver maximum th %ile 1-hour (NO 2 ) (μg/m 3 ) % Indaver % SSE % Sum of source contributions % 2 x Annual mean background (measured by EPA in 2006) % ICP143.dat, Indaver (2007) and SSE (2007) Predicted concentrations of NO x (μg/m 3 ) Total % The maximum concentration due to Indaver is predicted to occur at (306950, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to Indaver is shown in Table 48. The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO x for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NO x has been effective since 19 July The cumulative impact of the maximum ground-level concentrations is predicted to be 44% of the AQS for annual NO 2. Of this, 16% is due to the source contributions and 28% is due to the background concentration. The predicted concentrations comply with the AQS of 30μg/m³ over 1 year. Table 48 Predicted concentrations of NO x (μg/m 3 ) for Indaver maximum Annual mean (NO x ) (μg/m 3 ) % Indaver 1.5 5% SSE 0.2 1% Sum of source contributions % Annual mean background (measured by EPA in 2006) % ICP143.dat, Indaver (2007) and SSE (2007) Total % Predicted concentrations of annual mean PM 10 (μg/m 3 ) The maximum concentration due to Indaver is predicted to occur at (306950, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to Indaver is shown in Table 49. Page 30

36 Platin IPPC Licence Application The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM 10 for the protection of human health of 40μg/m³ over 1 year. The AQSs for PM 10 have been effective from 1 January The cumulative impact of the maximum ground-level concentrations is predicted to be 40% of the AQS for annual PM 10. Of this, 2% is due to the source contributions and 38% is due to the background concentration. The predicted concentrations comply with the AQS of 40μg/m³ over 1 year. Table 49 Predicted concentrations of PM 10 (μg/m 3 ) for Indaver maximum Annual mean (PM 10 ) (μg/m 3 ) 0.5 1% Indaver 0.1 <1% SSE 0.1 <1% Sum of source contributions 0.6 2% Annual mean background (measured by EPA in 2006) % ICP149.dat, Indaver (2007) and SSE (2007) Total % Predicted concentrations of 24-hour PM 10 (μg/m 3 ) The maximum concentration due to Indaver is predicted to occur at (306950, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to Indaver is shown in Table 50. The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM 10 for the protection of human health of 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 PM 10 have been effective from 1 January The cumulative impact of the maximum ground-level concentrations is predicted to be 4% of the AQS for 24-hour PM 10. As per the EPA s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 66% of the AQS for annual PM 10. Of this, 4% is due to the source contributions and 61% is due to the background concentration. The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours. Table 50 Predicted concentrations of PM 10 (μg/m 3 ) for Indaver maximum st %ile 24-hour (PM 10 ) (μg/m 3 ) 1.9 4% Indaver 0.2 <1% SSE 0.2 <1% Page 31

37 Platin IPPC Licence Application Sum of source contributions 2.2 4% 2 x Annual mean background (measured by EPA in 2006) % ICP149.dat, Indaver (2007) and SSE (2007) Total % Comparison with the AQSs for particulate matter Stage 2 (2010) The maximum ground-level concentrations due to the emissions under Scenario 6 are compared to the AQSs for PM 10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM 10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002). The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in The Irish AQS Regulations (2002) do not refer to PM 2.5. The cumulative impact of the maximum ground-level concentrations is predicted to be 74% of the AQS for annual PM 10. Of this, 3% is due to the source contributions and 71% is due to the background concentration. The predicted concentrations comply with the AQS of 20μg/m³ over 1 year. Table 51 Predicted concentrations of PM 10 (μg/m 3 ) for Indaver maximum Annual mean (PM 10 ) (μg/m 3 ) 0.5 2% Indaver 0.1 <1% SSE 0.1 <1% Sum of source contributions 0.6 3% Annual mean background (2010) % ICP149.dat, Indaver (2007) and SSE (2007) Total % The cumulative impact of the maximum ground-level concentrations is predicted to be 10% of the AQS for 24-hour PM 10. As per the EPA s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 67% of the AQS for 24-hour PM 10. Of this, 10% is due to the source contributions and 56% is due to the background concentration. Page 32

38 Platin IPPC Licence Application The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours. Table 52 Predicted concentrations of PM 10 (μg/m 3 ) for Indaver maximum 98.08th%ile 24-hour (PM 10 ) (μg/m 3 ) 4.1 8% Indaver 0.4 1% SSE 0.7 1% Sum of source contributions % 2 x Annual mean background (2010) % Total % ICP149.dat, Indaver (2007) and SSE (2007) 7.3 Location of SSE maximum Predicted concentrations of annual mean NO 2 (μg/m 3 ) The maximum concentration due to SSE is predicted to occur at (307480, ). The maximum concentration due to Platin, Indaver and SSE at the location of the maximum concentration due to SSE is shown in Table 53. The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO 2 for the protection of human health of 40μg/m³ over 1 year. The AQS for NO 2 is to be attained by 1 January The cumulative impact of the maximum ground-level concentrations is predicted to be 23% of the AQS for annual NO 2. Of this, 9% is due to the source contributions and 14% is due to the background concentration. The predicted concentrations comply with the AQS of 40μg/m³ over 1 year. Table 53 Predicted concentrations of NO 2 (μg/m 3 ) for SSE maximum Annual mean (NO 2 ) (μg/m 3 ) 2.1 5% Indaver 0.7 2% SSE 0.7 2% Sum of source contributions 3.4 9% Annual mean background (measured by EPA in 2006) % Total % ICP143.dat, Indaver (2007) and SSE (2007) Proportions of NO x to NO 2 In Section above, the nitrogen dioxide (NO 2 ) concentrations were calculated from the predicted NO x concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, the most conservative approach has been taken: a Page 33

39 Platin IPPC Licence Application conversion factor of 1 has also been applied to the long-term average concentration due to the sum of the source contributions (UK EA, 2005). The predicted concentrations comply with the AQS of 40μg/m³ over 1 year. Table 54 Predicted concentrations of NO 2 (μg/m 3 ) for for maximum Annual mean (NO 2 ) (μg/m 3 ) Sum of source contributions % Annual mean background (measured by EPA in 2006) % ICP143.dat, Indaver (2007) and SSE (2007) Total % Predicted concentrations of 1-hour NO 2 (μg/m 3 ) The maximum concentration due to SSE is predicted to occur at (308280, ). The maximum concentration due to Platin, Indaver and SSE at the location of the maximum concentration due to SSE is shown in Table 55. The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO 2 for the protection of human health of 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQS for NO 2 is to be attained by 1 January The cumulative impact of the maximum ground-level concentrations is predicted to be 41% of the AQS for 1-hour NO 2. As per the EPA s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 46% of the AQS for 1-hour NO 2. Of this, 41% is due to the source contributions and 6% is due to the background concentration. The predicted concentrations comply with the AQS of 200μg/m³ over 1 hour. Table 55 Predicted concentrations of NO 2 (μg/m 3 ) for SSE maximum th %ile 1-hour (NO 2 ) (μg/m 3 ) % Indaver 3.3 2% SSE % Sum of source contributions % 2 x Annual mean background (measured by EPA in 2006) % ICP143.dat, Indaver (2007) and SSE (2007) Predicted concentrations of NO x (μg/m 3 ) Total % The maximum concentration due to SSE is predicted to occur at (307480, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to SSE is shown in Table 56. Page 34

40 Platin IPPC Licence Application The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO x for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NO x has been effective since 19 July The cumulative impact of the maximum ground-level concentrations is predicted to be 47% of the AQS for annual NO 2. Of this, 19% is due to the source contributions and 28% is due to the background concentration. The predicted concentrations comply with the AQS of 30μg/m³ over 1 year. Table 56 Predicted concentrations of NO x (μg/m 3 ) for SSE maximum Annual mean (NO x ) (μg/m 3 ) % Indaver 0.9 3% SSE 0.7 2% Sum of source contributions % Annual mean background (measured by EPA in 2006) % ICP143.dat, Indaver (2007) and SSE (2007) Total % Predicted concentrations of annual mean PM 10 (μg/m 3 ) The maximum concentration due to SSE is predicted to occur at (307480, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to SSE is shown in Table 57. The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM 10 for the protection of human health of 40μg/m³ over 1 year. The AQSs for PM 10 have been effective from 1 January The cumulative impact of the maximum ground-level concentrations is predicted to be 42% of the AQS for annual PM 10. Of this, 3% is due to the source contributions and 38% is due to the background concentration. The predicted concentrations comply with the AQS of 40μg/m³ over 1 year. Table 57 Predicted concentrations of PM 10 (μg/m 3 ) for SSE maximum Annual mean (PM 10 ) (μg/m 3 ) 0.8 2% Indaver 0.0 <1% SSE 0.5 1% Sum of source contributions 1.3 3% Annual mean background (measured by EPA in 2006) % ICP149.dat, Indaver (2007) and SSE (2007) Total % Page 35

41 Platin IPPC Licence Application Predicted concentrations of 24-hour PM 10 (μg/m 3 ) The maximum concentration due to SSE is predicted to occur at (308180, ). The maximum concentration due to Platin, Indaver and SSE in the vicinity of the maximum concentration due to SSE is shown in Table 58. The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM 10 for the protection of human health of 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 PM 10 have been effective from 1 January The predicted concentration due to Indaver at the location of the maximum concentration due to SSE was not known. Therefore it was assumed to be the same as the maximum concentration due to Indaver, which is a conservative assumption. The cumulative impact of the maximum ground-level concentrations is predicted to be 6% of the AQS for 24-hour PM 10. As per the EPA s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 68% of the AQS for annual PM 10. Of this, 6% is due to the source contributions and 61% is due to the background concentration. The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours. Table 58 Predicted concentrations of PM 10 (μg/m 3 ) for SSE maximum st %ile 24-hour (PM 10 ) (μg/m 3 ) 1.5 3% Indaver (assumed to be maximum) 0.2 <1% SSE 1.5 3% Sum of source contributions 3.2 6% 2 x Annual mean background (measured by EPA in 2006) % ICP149.dat, Indaver (2007) and SSE (2007) Total % Comparison with the AQSs for particulate matter Stage 2 (2010) The maximum ground-level concentrations due to the emissions under Scenario 6 are compared to the AQSs for PM 10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM 10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002). The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in The Irish AQS Regulations (2002) do not refer to PM 2.5. The cumulative impact of the maximum ground-level concentrations is predicted to be 77% of the AQS for annual PM 10. Of this, 7% is due to the source contributions and 71% is due to the background concentration. The predicted concentrations comply with the AQS of 20μg/m³ over 1 year. Page 36

42 Platin IPPC Licence Application Table 59 Predicted concentrations of PM 10 (μg/m 3 ) for SSE maximum Annual mean (PM 10 ) (μg/m 3 ) 0.8 4% Indaver 0.0 <1% SSE 0.5 3% Sum of source contributions 1.3 7% Annual mean background (2010) % Total % ICP149.dat, Indaver (2007) and SSE (2007) The cumulative impact of the maximum ground-level concentrations is predicted to be 19% of the AQS for 24-hour PM 10. As per the EPA s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 75% of the AQS for 24-hour PM 10. Of this, 19% is due to the source contributions and 56% is due to the background concentration. The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours. Table 60 Predicted concentrations of PM 10 (μg/m 3 ) for SSE maximum 98.08th%ile 24-hour (PM 10 ) (μg/m 3 ) % Indaver 0.2 <1% SSE 3.1 6% Sum of source contributions % 2 x Annual mean background (2010) % ICP149.dat, Indaver (2007) and SSE (2007) Total % 8. CONCLUSIONS This report has been prepared for the response to the RFI following clarification from the EPA as to their exact requirements. It supersedes the air quality modelling included in the EIS and the IPPC Licence Application. 8.1 Scenarios 1 to 6 The concentrations of atmospheric pollutants predicted for Scenarios 1, 3 and 5 comply with the AQSs for NO 2 for the protection of human health of 40μg/m³ over 1 year (including background concentrations) and 200μg/m³ over 1 hour. Page 37

43 Platin IPPC Licence Application The concentrations of atmospheric pollutants predicted for Scenarios 1, 3 and 5 comply with the AQS for NO x 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 Stage 1 AQSs for PM 10 for the protection of human health of 40μg/m³ over 1 year (including background concentrations) and 50μg/m³ over 24 hours. The concentrations of atmospheric pollutants predicted for Scenarios 2, 4 and 6 comply with the Stage 2 AQSs for PM 10 for the protection of human health of 20μg/m³ over 1 year (including background concentrations) and 50μg/m³ over 24 hours. 8.2 Cumulative Impact Assessment 8.3 EPA RFI The cumulative impact assessment shows that the predicted concentrations due to Irish Cement, Indaver and SSE comply with the AQSs for NO 2 for the protection of human health of 40μg/m³ over 1 year (including background concentrations) and 200μg/m³ over 1 hour. The cumulative impact assessment shows that the predicted concentrations due to Irish Cement, Indaver and SSE comply with the AQSs for NO x for the protection of vegetation of 30μg/m³ over 1 year (including background concentrations). The cumulative impact assessment shows that the predicted concentrations due to Irish Cement, Indaver and SSE comply with the Stage 1 AQSs for PM 10 for the protection of human health of 40μg/m³ over 1 year (including background concentrations) and 50μg/m³ over 24 hours. The cumulative impact assessment shows that the predicted concentrations due to Irish Cement, Indaver and SSE comply with the Stage 2 AQSs for PM 10 for the protection of human health of 20μg/m³ over 1 year (including background concentrations) and 50μg/m³ over 24 hours. As requested by the EPA, the impact of using a more conservative NO x to NO 2 conversion of 100% for predicting the annual concentration has been assessed. The predicted concentrations comply with the Irish Air Quality Standards (AQSs) Regulations (2002). As requested by the EPA, the short-term background concentration was taken to be twice the long-term (annual mean) background concentration in the revised air quality modelling report. This follows the UK EA (2002) guidance, IPPC H1 Integrated Pollution Prevention and Control (IPPC). Environmental Assessment and Appraisal of BAT. There is no equivalent Irish methodology or EPA guidance. The predicted concentrations comply with the Irish Air Quality Standards (AQSs) Regulations (2002). As requested by the EPA, the cumulative impact has been reassessed as requested to include the cumulative impact (annual averages and short term) of the existing and proposed Irish Cement emissions and those associated with Indaver and SSE. The planning permission for the SSE facility has lapsed and ICL has been advised by consultants to SSE (2007) that they are not proceeding with this development. Since the planning permission for the SSE facility has lapsed that development cannot proceed without a further grant of planning permission. Nevertheless the predicted concentrations due to the SSE 400MW facility have been included in the cumulative impact assessment, as provided in December 2007 by SSE through their air dispersion modelling consultants. The most recent data for the Indaver facility has been used, as provided in December 2007 by Indaver through their air dispersion modelling consultants. Page 38

44 Platin IPPC Licence Application The predicted concentrations comply with the Irish Air Quality Standards (AQSs) Regulations (2002). 8.4 Summary The methodology applies highly conservative assumptions and shows that the predicted concentrations comply with the Irish Air Quality Standards (AQSs) Regulations (2002). 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, COM (Provisional Version), 2005/0183 (COD), Brussels 21/09/2005. EC (European Commission) (2004) Second Position Paper on Particulate Matter Final. EPA (2004) Personal communication (D ) EPA (2006) Jennings, S.G. et al. Air Pollution Nature and Origin of PM 10 and Smaller Particulate Matter in Urban Air (2000-LS-6.1-M1), Environmental Protection Agency, PO Box 3000, Johnstown Castle, Co Wexford. EPA (2007) Air Quality in Ireland Indaver (2007) Personal communication with AWN (Edward Porter), December SSE (2007) Personal communication with PMG (Niall O Loughlin), December UK EA (Environment Agency) (2002) IPPC H1 Integrated Pollution Prevention and Control (IPPC). Environmental Assessment and Appraisal of BAT, UK EA, Scottish Environment Protection Agency (SEPA), Northern Ireland Environment and Heritage Service (NI EHS). UK EA (2005) Conversion ratios for NOx and NO2, viewed 4.xii 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. Page 39

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46 FIGURES

47

48 Platin IPPC Licence Application Figure 1 Isopleths of predicted annual mean NO 2 : Scenario 1 Figure 2 Isopleths of predicted annual mean PM 10 : Scenario 2 Figure 3 Isopleths of predicted annual mean NO 2 : Scenario 3 Figure 4 Isopleths of predicted annual mean PM 10 : Scenario 4 Figure 5 Isopleths of predicted annual mean NO 2 : Scenario 5 Figure 6 Isopleths of predicted annual mean PM 10 : Scenario 6

49 Legend 1 ug/m 3 5 ug/m 3 0 kilometres 5 Scale 1:133,333 Ordnance Survey Ireland Licence Number EN c Government of Ireland metres metres ICP083.dat Isopleths of Annual Mean NO 2 : Scenario 1 Platin D August 2007 Figure 1

50 Legend 1 ug/m 3 5 ug/m 3 0 kilometres 5 Scale 1:133,333 Ordnance Survey Ireland Licence Number EN c Government of Ireland metres metres ICP089.dat Isopleths of Annual Mean PM 10 : Scenario 2 Platin D August 2007 Figure 2

51 Legend 1 ug/m 3 0 kilometres 5 Scale 1:133,333 Ordnance Survey Ireland Licence Number EN c Government of Ireland metres metres ICP093.dat Isopleths of Annual Mean NO 2 : Scenario 3 Platin D August 2007 Figure 3

52 Legend 1 ug/m 3 5 ug/m 3 0 kilometres 5 Scale 1:133,333 Ordnance Survey Ireland Licence Number EN c Government of Ireland metres metres ICP099.dat Isopleths of Annual Mean PM 10 : Scenario 4 Platin D August 2007 Figure 4

53 Legend 1 ug/m 3 5 ug/m 3 0 kilometres 5 Scale 1:133,333 Ordnance Survey Ireland Licence Number EN c Government of Ireland metres metres ICP143.dat Isopleths of Annual Mean NO 2 : Scenario 5 Platin D August 2007 Figure 5

54 Legend 1 ug/m 3 5 ug/m 3 0 kilometres 5 Scale 1:133,333 Ordnance Survey Ireland Licence Number EN c Government of Ireland metres metres ICP149.dat Isopleths of Annual Mean PM 10 : Scenario 6 Platin D August 2007 Figure 6 EPA Export :22:32:49