Specialists in laboratory analysis, monitoring and environmental consultancy CLOSURE PLAN FOR LAGAN CEMENT KINNEGAD CO WESTMEATH

Transcription

1 tms environment ltd Specialists in laboratory analysis, monitoring and environmental consultancy TMS Environment Ltd 53 Broomhill Drive Tallaght Dublin 24 Phone: Fax: Web: CLOSURE PLAN FOR LAGAN CEMENT KINNEGAD CO WESTMEATH Mr. Brian Reynolds Report Ref TMS Environment Ltd. Issued: 18 th June 2015 Approved By: Date: Tom Ryan Senior Environmental Consultant

2 CONTENTS TABLE Executive Summary 1.0 Introduction 2.0 Site Evaluation 2.1 Operator Performance 2.2 Environmental Pathways and Sensitivity 2.3 Activity Process and Activities 2.4 Inventory of Buildings, Equipment and Plant 2.5 Inventory of Raw Materials, Products and Wastes 3.0 Closure Tasks and Programmes 3.1 Introduction 3.2 Decommissioning Programme 4.0 Criteria for Successful Decommissioning 5.0 Closure Plan Validation 6.0 Closure Plan Costing 7.0 Closure Plan Update and Review 8.0 Closure Plan Implementation 9.0 Environmental Monitoring During Decommissioning 10.0 Financial Provision Appendix 1 Scenario 1 Site Restoration Plan TMS Environment Ltd Ref Page 2 of 25

3 Executive Summary Activity Details Name: Lagan Cement (LC) Address: Killaskillen, Kinnegad, Co. Meath. Licence Number: P Activities Licensed: 10.2: Production of cement clinker in rotary kilns with a production capacity exceeding 500 tonnes per day or in other kilns with a production capacity exceeding 50 tonnes per day 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. 11.2(c): Disposal or recovery of hazardous waste with a capacity exceeding 10 tonnes per day involving blending or mixing prior to submission to any of the other activities listed in paragraph 11.2 or (a): Disposal or recovery of waste in waste incineration plants or in waste co-incineration plants for non-hazardous waste with a capacity exceeding 3 tonnes per hour. 11.3(b): Disposal or recovery of waste in waste incineration plants or in waste co-incineration plants for hazardous waste with a capacity exceeding 10 tonnes per day. 11.6: Temporary storage of hazardous waste, (other than waste referred to in paragraph 11.5) pending any of the activities referred to in paragraph 11.2, 11.3, 11.5 or 11.7 with a total capacity exceeding 50 tonnes, other than temporary storage, pending collection, on the site where the waste is generated. RBME Category: B2 Year: For 2015 Report Preparation This report was prepared on behalf of LC by TMS Environment Ltd. Consultant Name: TMS Environment Ltd (TMS) Address: 53 Broomhill Drive, Tallaght, Dublin 24. TMS Environment Ltd Ref Page 3 of 25

4 Comparison with Previous Plans One previous closure plan was submitted in 2011 and is summarised below Year Closure Cost Financial Provision Expiry Date of Financial Provision 2002 Not finalised Company capital NA ,000 Company capital NA 2015 (Scenario 1) 2015 (Scenario 2) Overview of the Plan 1,555,556 Company guarantee Ongoing 515,606 Company guarantee Ongoing This closure plan was prepared in accordance with Condition 10 of the LC Industrial Emissions Licence (IEL). The methodology for the development of the closure plan follows the EPA Guidance Document Guidance on Assessing and Costing Environmental Liabilities (2014). This report has been prepared by an independent and appropriately qualified consultant. Scoping Scoping has determined that the site will have no landfilling concerns or long-term liabilities such as land contamination and the site is suitable for clean closure. There are two quarries located on the site and therefore there will be a requirement for restoration on the site but there is no Aftercare Management Plan required. Cost Summary Two scenarios have been costed as follows: Scenario 1 covers the cost for the closure of the whole site to include the demolition of all structures and buildings and the full removal of all site infrastructure. Scenario 2 covers the cost for the closure of the whole site but does not account for the demolition of buildings at the site. All buildings will be fully decommissioned and rendered safe and secure following closure works. Clean closure of the site would involve leaving buildings and roads in place and the site would be considered more valuable with this infrastructure in place. The total closure costs have been calculated at 1,555,556 for Scenario 1 and 515,606 for scenario 2. Financial Provision LC proposes to make the necessary financial provision to cover closure by means of a Parent Company Guarantee. The Lagan Group is of sufficient financial strength to TMS Environment Ltd Ref Page 4 of 25

5 back the potential exposure under the guarantee and there is no risk to the EPA regarding legal enforcement of the guarantee. Review This closure plan will be reviewed annually and any updates will be notified to the EPA. TMS Environment Ltd Ref Page 5 of 25

6 1.0 Introduction Lagan Cement (LC) has operated the Lansdown Cement Works and associated limestone and shale quarries on their lands at Killaskillen, Kinnegad, Co Meath since August The cement works comprises state of the art facilities that have been designed by an international authority on cement works equipment and accommodates the most modern environmental protection measures. It is a 100 million development providing a total of approximately 100 no. jobs directly and further employment for local service industries. The Lagan Cement plant is permitted to produce 700,000 tonnes of cement per annum. The site on which the plant is located contains a shale quarry, a limestone quarry, both of which supply raw materials for the cement manufacturing process, and lands in agricultural use. It lies between 2.5 and 4.5 km southwest of Kinnegad and 1.2 to 3.5 km north of Ballinabrackey in County Meath. It is approximately 60km by road from Dublin and Athlone, and Mullingar is located approximately 17km to the northwest. The Lagan Cement facility is operated under the terms and conditions of Industrial Emissions Licence (IEL) Register Number P as amended and issued by the Environmental Protection Agency (EPA) on the 6 th of January The site is licensed by the EPA to carry out the following activities: the production of cement clinker in rotary kilns with a production capacity exceeding 500 tonnes per day or in other kilns with a production capacity exceeding 50 tonnes per day; 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; the disposal or recovery of hazardous waste with a capacity exceeding 10 tonnes per day involving blending or mixing prior to submission to any of the other activities listed in paragraph 11.2 or 11.3; the disposal or recovery of waste in waste incineration plants or in waste coincineration plants for non-hazardous waste with a capacity exceeding 3 tonnes per hour; the disposal or recovery of waste in waste incineration plants or in waste coincineration plants for hazardous waste with a capacity exceeding 10 tonnes per day; the temporary storage of hazardous waste, (other than waste referred to in paragraph 11.5) pending any of the activities referred to in paragraph 11.2, 11.3, 11.5 or 11.7 with a total capacity exceeding 50 tonnes, other than temporary storage, pending collection, on the site where the waste is generated. Condition 10 of the IEL requires the company to prepare a Closure Plan (Decommissioning Management Plan). The specific IEL conditions are as follows: 10.2 Decommissioning Management Plan: TMS Environment Ltd Ref Page 6 of 25

7 The licensee shall prepare, to the satisfaction of the Agency, a fully detailed and costed plan for the decommissioning or closure of the site or part thereof. This plan shall be submitted to the Agency for agreement within six months of the date of grant of this licence The plan shall be reviewed annually and proposed amendments thereto notified to the Agency for agreement as part of the AER. No amendments may be implemented without the agreement of the Agency The Licensee shall have regard to the Environmental Protection Agency guidance on Environmental Liability Risk Assessment, Decommissioning Management Plans and Financial Provision when implementing Condition above The Decommissioning Management Plan shall include as a minimum, the following: (i) A scope statement for the plan. (ii) The criteria, which define the successful decommissioning of the activity or part thereof, which ensures minimum impact on the environment. (iii) A programme to achieve the stated criteria (iv) Where relevant, a test programme to demonstrate the successful implementation of the decommissioning plan. (v) Details of the costings for the plan and the financial provisions to underwrite those costs. This report has been prepared in accordance with the EPA Guidance Document Guidance on Assessing and Costing Environmental Liabilities (2014). Lagan Cement is an ongoing concern and currently has no current or future plans to decommission any part of the production processes or plant at their facility in Kinnegad. It is not possible to determine which part of the plant might be decommissioned in the future as any such decision would be based on market conditions and the economic circumstances of the company. The scope of this Closure Plan addresses the key issues that would occur in the orderly shut-down of all of site activities. 2.0 Site Evaluation 2.1 Operator Performance The facility maintains an Environmental Management System (EMS) with full ISO accreditation, in compliance with Condition 2.2 of the IEL (P ), maintaining a schedule of Environmental Objectives and Targets, which is reviewed on an annual basis. There is also a Quality Management System in place at LC which is accredited to ISO9001 standards and the company has achieved the standard BES 6001 Responsible Sourcing of Construction Products to a very good standard. The Environmental Management System incorporates the procedures and controls to reflect specific environmental aspects and impacts identified and the legislative requirements applicable to the facility. A company-wide Environmental Policy has been established, which declares the company s commitment to the environment and to continual improvement of environmental practices. TMS Environment Ltd Ref Page 7 of 25

8 A key benefit of operating an EMS is to review regularly all processes on the site and arising impacts on the environment and make assessment on how they can be reduced. LC therefore, in addition to complying with its IEL requirements also self regulates against its own environmental benchmarks. The company maintains a system of continuing improvement and strives to ensure it meets all environmental commitments and license conditions. There have been a small number of environmental complaints in relation to the activity over the last number of years. All complaints are immediately responded to and all have been closed out satisfactorily. There were no significant environmental incidents reported since the licence was issued in There have been no non-compliances relevant to the site closure issued by the EPA since operations began at the site. The surface water management system at the existing facility was designed to ensure that surface water discharges do not cause pollution of the receiving surface water bodies and also to prevent accidental discharges from the site. The system is very effective in achieving these objectives as has been shown by the comprehensive environmental monitoring programme undertaken at the site since June There were no exceedances of the IEL limits at SW1 or SW2 during the 2014 monitoring programme. There are no process effluent emissions to sewer at the site. Groundwater monitoring is carried out at up to 18 different locations for a host of parameters on a biannual basis. Groundwater quality is good at the site and no evidence of contamination has been seen in the monitoring data to date. There are currently 20 licensed stack emission points at the Lagan Cement facility. The main emission point at the site (A2-1) discharges at 125m above ground level and captures the emissions from the cement kiln system. Extensive monitoring is carried out here both continuously and at routine intervals. There are 18 other active emission points across the site and all relate to bag filter exhaust emissions at the various stages of the production process. Particulates are monitored at these locations ranging from quarterly monitoring to annual monitoring. All emissions to air monitoring carried out in 2014 was compliant with the conditions as set out in the facility s IEL. Noise monitoring is carried out at nominated noise sensitive receptor locations in the vicinity of the site on an annual basis and facility operations are fully compliant with the noise limits imposed on an on-going basis. Dust deposition monitoring is carried out at the site on an ongoing basis and the site has shown 100% compliance with the dust deposition limits imposed for 2014 monitoring year. 2.2 Environmental Pathways and Sensitivity TMS Environment Ltd Ref Page 8 of 25

9 The general geological setting of the Killaskillen-Kinnegad area shows that the LC site mostly lies within the Waulsortian (Reef) Limestone but the southern extremities encroach onto the Biociastic Limestone while the northern boundary approaches the Tober Colleen Formation. The Waulsortian limestones are generally pale grey, poorly bedded, pure limestones. The limestones can have steep depositional dips reflecting their original mound-form topography on the scale of a few meters to over 100m. The Waulsortian Limestone is included in the Dinantian Pure Unbedded Limestones (DPUL) Rock Unit Group. The Waulsortian Limestone in the area of Kinnegad is classified as Locally Important Aquifers, moderately productive only in local zones (Ll). Groundwater resources in the regional area are considered limited. There are no major aquifers of regional significance. The water table in the limestones in the area is generally shallow (<10m below ground), however the drawdown effect of the limestone quarry on the water table means that groundwater is drained locally into the quarry. There is an advanced surface water management system in operation at the site which includes three main sumps for surface water management: the terrace sump manages surface water run-off in the plant area, the shale quarry sump and limestone quarry sump manage groundwater pumped from the two quarries. Water is pumped forward from the terrace sump to the balancing pond and is also pumped from the limestone quarry sump to the balancing pond; water flows by gravity from the balancing pond into the settlement lagoon. The settlement lagoons are the main features of the surface water management system at the site. The lagoons are located just north of the shale quarry and discharge into the Kinnegad River. Also monitoring location SW2 is used to monitor the land drainage and drainage from the bog, which lies to the south of the site, into the western tributary which borders the site. Monitoring is carried on a continuous, daily, weekly, monthly and quarterly basis at SW1, the main surface water discharge which discharges into the Kinnegad River and at more occasionally at SW2. The site is located in a rural area and the nearest population centre is the town of Kinnegad which is situated approximately 3km northeast of the site. There are no designated areas (SPAs, SACs or NHAs) within a 5kms radius of the site according to the National Parks and Wildlife Services protected sites maps. Table 1 below summaries the licensed emission points at the site. TMS Environment Ltd Ref Page 9 of 25

10 Table 1 Licensed Emissions Points ID No. Emission Destination of Emission Location A2-01 ESP exhaust from raw mill and cement kiln air centre of site A2-02 Cement mill bag filter exhaust air centre of site A2-03 Coal mill bag filter exhaust air centre of site A2-04 Kiln feed bag filter exhaust air centre of site A2-05 Clinker cooler bag filter exhaust air centre of site A2-06 Clinker conveyer bag filter exhaust air centre of site A3-01 to A3-14 Process bag fileters air centre of site SW1 SW discharge to Kinnegad River water north boundary SW2 SW discharge to western tributary water west boundary N1 to N9 Noise emissions from site environment site vicinity 2.3 Activity Processes and Activities Production processes at the Lagan Cement facility are discussed below and presented graphically in the Production Process Chart presented in Appendix 1. Administration Building The administration building is located to the north of the main production area. All of the company s administration function is carried out here. There are no manufacturing processes carried out at this location. Raw Material Preparation Limestone from the on-site quarry is passed through a primary and then through a secondary crusher where the shale produced in the onsite quarry is also crushed. The imported shale, sand and bauxite are also added in at the secondary crusher stage. The raw materials are crushed to a 100mm mix. Crushed material is then transported via a covered conveyor to the blending shed. The conveyor is fitted with neutron type analysers for continuous measurement of calcium, silica, iron and alumina in the raw feed. Blending The raw material mix which has been transported from the secondary crushers are blended in the blending shed reducing fluctuations by laying a large number of layers on a stockpile within the shed. This is now referred to as the blended raw mix. Material is reclaimed off the pile and fed to the raw mill at an average rate of about 37tonnes per hour. Raw Meal Milling and Mixing TMS Environment Ltd Ref Page 10 of 25

11 A belt conveyor feeds the blended raw mix reclaimed from the blending shed to the raw mix feed bin. From the feed bin the material is fed to a raw mill for grinding and drying to a fine dust called raw meal. Raw Meal Kilning The installation consists of three major sections, the preheater, the kiln and the clinker cooler. The raw meal is drawn from the raw meal feed silos through discharge hoppers to a weighing bin and is introduced close to the top of the column in the kiln pre-heater. As it is guided down through the cyclones in the system, it picks up heat from the hot gases produced in the kiln. At the bottom of the pre-heater the hot material is introduced into the kiln where it s temperature is gradually brought up to 1420 C utilizing flame temperatures of up to 2000 C. As the kiln rotates the material inside tumbles, following a spiral path on the inside of the kiln shell, finally reaching the outlet where it drops into the clinker cooler. Here the intermediate product, clinker, is abruptly cooled to 600 C and then down to 100 C at a slower pace. The heat of the material is recovered, heating the air needed for combustion. Clinker Cooling and Handling From the end of the kiln, clinker drops out into the clinker cooler. The cooler is a cross flow heat exchanger where ambient air is blown through a moving grate and through the clinker to cool it at a forced high rate from 1350 O C down to 600 O C and then on to lower temperatures at a slower pace. The clinker is crushed by a rollerbreaker to remove large lumps and is transported with special heat resistant conveyors to clinker silos for storage. From the clinker silos, clinker is fed to the cement mill for grinding to cement as and when required. Clinker Grinding Cement is produced by grinding the intermediate product, clinker, with gypsum in the correct proportions. Cem II clinker content can range from 80-94%, with limestone comprising 6-20%. Cem I clinker contents range from 95% - 100%, with limestone comprising up to 5%. In addition both Cem I and Cem II also contain approximately 4% gypsum, which is added at the clinker grinding stage to control the setting characteristics of the final cement. Cement grinding is done in a ball mill which is a metal tube lined with special cast steel liner plates designed to help lift the grinding media (steel balls) in the mill as it is turned. The mill is internally divided into two chambers with a diaphragm separating the unequally sized compartments. The first compartment pre-grinds the coarse material while the second compartment completes the grinding process. To improve efficiency, air flowing through the mill cools the material being ground and moves material faster through the system. With the help of an air separator the fine ground material is removed as finished product while coarse material is returned to the mill at the feed end. Material continues circulating in a closed circuit until it reaches the required fineness. The finished product from the clinker grinding is transferred to the cement silos. Storage and Handling of Cement From the cement silos, cement is drawn pneumatically and conveyed by air slides into bucket elevators for bagging and pallet loading in the packing plant or for direct loading in to container trucks. The packing machine fills 25kg bags at a rate of up to TMS Environment Ltd Ref Page 11 of 25

12 2,400 bags per hour which are conveyed to a palletising machine. Pallets are either loaded immediately for sale or stocked. Fuel Preparation and Use Coal is delivered to the site by truck and is stored a dedicated coal shed. The coal is conveyed as needed to the coal mill, were the coal is ground to a fine powder to facilitate combustion in the kiln. Material temperatures within the kiln are in excess of 1400 C. The kiln flame itself operates at temperatures of 2000 C, which ensures that all combustible fuel material is rendered entirely inorganic. The coal mill operation is similar to the raw meal mill, only significantly smaller in capacity and specially designed to grind coal safely. To start-up the installation fuel oil is used to preheat the kiln until suitable temperature are reached to combust coal and alternative fuels. Alternative fuels such as meat & bone meal, Solid Recovered Fuel (SRF), Liquid Recovered Fuel (LRF) and Low Carbon Fuel (LCF) are transported to the site by both road tanker and covered trailers. These fuels are only accepted onto the site following an offsite quality control check. These are stored in material specific tankers or bays and are fed into the kiln via covered conveyer, pumped or blown from where they are combusted in the same manner as coal above. There are no asbestos or PCBs contained in the buildings or plant located on the site. TMS Environment Ltd Ref Page 12 of 25

13 2.4 Inventory of Buildings, Equipment and Plant Table 2 List of Site Buildings and Main Plant on the LC Facility Building / Plant Area Administration Building Function Main office and admin area including toilets, canteen etc Primary Crusher Production (see section 2.3) Secondary Crusher Production (see section 2.3) Blending Shed Production (see section 2.3) Raw mill Production (see section 2.3) Raw meal silo Production (see section 2.3) Preheater tower Production (see section 2.3) Kiln Production (see section 2.3) Oil & LRF tanks Storage of oil & LRF used onsite Coal store building Production (see section 2.3) Coal Mill Production (see section 2.3) Clinker Cooler Production (see section 2.3) Gypsum store Production (see section 2.3) SRF & LCF storage bays Storage of alternative fuels onsite Cement mill Production (see section 2.3) Electricity sub station Delivery of electrical services to the site Cement silos Production (see section 2.3) Clinker Silo Production (see section 2.3) Packing and Bulk Loading Production (see section 2.3) Stores building Workshop Storage and delivery of non-bulk materials used in production Repairs to plant and machinery Facilities Building Weighbridge Vehicles Washes Control Room & laboratory Mobile Plant Bunded areas General maintenance of plant operations Weighing of trucks Washing of site vehicles Supervision of production and laboratory analysis Transport of raw materials onsite Containment of spillages TMS Environment Ltd Ref Page 13 of 25

14 2.5 Inventory of Raw Materials, Products, Fuels/Alternative Fuels and Waste The main plant raw materials, products, fuels/alternative fuels and wastes stored onsite are presented below in Tables 3 and 4. The figures presented represent the typical quantities / volumes etc that are held onsite at any one time. Table 3 Inventory of Main Raw Materials, Fuels/Alternative Fuels and Products Stored on the LC Site Raw Material Quantity Held On-site / tonnes Limestone 40,000 Shale 5,000 Bauxite 2,000 Clay 5,000 Gypsum 3,000 Sand 200 Raw Mix 40,000 Raw Meal 10,000 Clinker 20,000 Cement (CEM I & CEM II) 30,000 Argon 24m 3 Oxygen 480m 3 Nitrogen 50m 3 Propane 850m 3 Acetylene 150m 3 Oils and Grease 1 Coal 10,000 Meat & bone meal 150 SRF 200 LCF 30 LRF 150 Fuel Oil 180 Lubrication Oils 30 TMS Environment Ltd Ref Page 14 of 25

15 Table 4 Summary of Approximate Annual Waste Arisings On-site Waste Type Quantity (Tonnes) Disposal Route Waste Oil 16 Off-site recovery Oily Water 1.5 Off-site recovery Solid Oily Waste 3.0 Off-site recovery Oil Filters 0.75 Off-site recovery Paint Related Material 0.2 Off-site recovery Timber 25 Off-site recovery Cardboard 5.0 Off-site recovery Mixed Municipal 100 Off-site disposal Gas Discharge Lamps 0.1 Off-site recovery Batteries 0.1 Off-site recovery Metal 130 Off-site recovery TMS Environment Ltd Ref Page 15 of 25

16 3.0 Closure Tasks and Programmes 3.1 Introduction Scoping has determined that the site will have no landfilling concerns or long-term liabilities such as land contamination and the site is suitable for clean closure. There are two quarries located on the site and therefore there will be a requirement for restoration on the site but there is no Aftercare Management Plan required. Following permanent closure of the facility there are two possible site outcomes: Scenario 1 - Full restoration of the site to a greenfield status. (Refer to Appendix I). Scenario 2 - Decommissioning of the site to allow possible sale of the land for development subject to Agency approval and appropriate zoning and planning consent. Clean Closure is envisaged for the site; that is upon cessation of operations and subsequent decommissioning at the facility, there will be no remaining environmental liabilities. The closure plan includes the decommissioning and decontamination of all above- and below-ground structures and the management and safe removal of any residual arising as a result of decommissioning. LC proposes to manage and execute the Closure Plan using internal resources, supplemented as necessary and appropriately with external resources. All external resources used for cleaning, waste disposal and transport will be fully approved and licensed as appropriate. A Decommissioning Management Team will be created to manage and execute the entire project and key activities will be supervised by personnel with appropriate experience and expertise. Only suitably qualified personnel will carry out decontamination works. Options that will be used to manage the various residuals that will arise are as follows: Reuse Any plant items that can be removed from the site for reuse at other production facilities will be and if not then they will be returned to the supplier; Recovery/Recycling Any plant items that can be recovered or recycled will be by selling to a third-party or by agreeing transport costs with the third party; Disposal The final option will be to dispose of plant items as waste. Waste sent off-site for recovery, recycling or disposal will only be transported by a permitted waste contractor and will be transported from the plant site to the destination site in a manner that will not adversely affect the environment. All waste materials being removed from the site will be handled according to Condition 8 of the IEL. TMS Environment Ltd Ref Page 16 of 25 EPA Export :01:29:05

17 3.2 Decommissioning Programme Closure considerations can be divided into underground decommission and surface decommissioning. The vast majority of the decommissioning programme at the LC facility will be carried out at surface level and there is only a minor amount of underground decommissioning to be considered. Once the Closure Plan is activated, site management will be responsible for ensuring an orderly cessation of production at the facility. The plan will be effectively carried out by following a specific sequence of activities. These activities will include the following: Termination of all relevant incoming deliveries to the facility; Termination of all contracts other than those concerned with site closure. Contracts will not be terminated if there is any risk to personnel at the site or to the environment; Cessation of quarrying at the site and usage of existing stockpiles of raw materials and fuels in storage where possible; Termination of production; Distribution of all finished product; Return of materials to suppliers where possible, for resale or reuse; Removal of remaining raw materials from site; Isolation and purging of transfer lines from bulk storage and to return pipe contents back to bulk storage; Draining and cleaning of residues from fuel tanks (oil and LRF) and cleaning and blanking of fuel lines; Decontamination and decommissioning of all bulk storage tanks onsite. No residuals to remain in tanks or pipelines. Residuals to be disposed of off-site at appropriate facilities; Cleaning and decontamination of plant and equipment; Clear and clean all office and administration areas. WEEE to be removed by authorised contractor. Cleaning, decontamination and inspection of bunds, sumps and drainage system; Isolation and disconnection of electrical supplies; Maintenance of site drainage system and oil interceptors during decommissioning activities; Secure archiving of all relevant documentation including drawings, instrumentation diagrams, validation documentation, vendor manuals and data, project files, maintenance records, inspection records, material transfer records, waste disposal records and other appropriate documentation; Provision of site security Underground Decommissioning There is no underground decommissioning works to be completed. The only underground works required is the cleaning of the surface water drainage network and the associated interceptors. TMS Environment Ltd Ref Page 17 of 25 EPA Export :01:29:05

18 3.2.2 Surface Decommissioning Decontamination Works An assessment of the level of contamination will be made for residues associated with fuels, oils, emulsions, process chemicals and any liquid effluents. All contaminants will be removed, drained or flushed from all relevant plant, tanks and pipelines and residues containing fuels, oils and other contaminants will be removed off-site for recovery or disposal. All buildings, structures, tanks, plant and surfaces will be hosed down or flushed out with high pressure water if deemed necessary. Any areas of ground with visual contamination will be excavated directly for off-site treatment and risk assessments will be carried out to establish the most suitable method of remediation. It is anticipated that any necessary decontamination of plant and equipment will be carried out on site. It will primarily involve cleaning in place and power washing of internal and external surfaces. LC will seek approval from the EPA for any decontamination procedures and monitoring requirements to be employed. A disposal route for all wash waters generated during decommissioning will be agreed with the Agency prior to disposal. Residual Oil, Tanks & Pipe-lines The maximum quantity of oil will be used prior to the cessation of activities so that the minimum quantity of unused oil remains on site. All pipelines and tanks will be drained using pumps where possible to minimise the remaining fuel residues in tanks and pipe-work. The oil tanks will be scrubbed and flushed using a light, petroleum based liquid. The residual oils will then be pumped to a tanker for treatment and re-separation/re-use of oil fractions and the tanks will be jet washed with a detergent-water mix to remove remaining residues. The tanks can then be assessed for non-hazardous disposal. Chemicals and Other Residuals Small quantities of chemicals are stored in the laboratory and these will be disposed of accordingly by a licensed contractor. Cleaning of the area around coal mills with a truck mounted mobile industrial vacuum cleaner will be carried out and this material disposed of off-site. Liquid Recovered Fuel(LRF) will be used up onsite where possible and any remaining LRF will be returned to the supplier via supplier delivery trucks Surface Plant Mobile plant items used on site will be sold to third parties. Fixed plant items are listed above in Table 2. All fixed plant will be drained of liquids including oils and chemicals and will be decontaminated and sent for or re-sale or scrap if resale is not viable. The majority of surface plant is mobile and usable on other sites and will have high resale potential. These plant items will not for the most part require any specialist TMS Environment Ltd Ref Page 18 of 25 EPA Export :01:29:05

19 cleaning and it is envisaged that the vast majority of both the mobile and fixed plant at the Lagan site will be sold on for use elsewhere Building Decommissioning The main buildings as described in Table 3 will be decommissioned in a logical sequence. The sequence for each production building is as follows; Emptying and decontamination of buildings. Final cleaning of building including floors and walls. The buildings will then be tested and certified as decontaminated. Depending on the final outcome of the site post-closure, the buildings themselves may or may not be demolished but this cannot be determined at this stage. Therefore, this report presents 2 scenarios where in the first case, the site will be returned back to its Greenfield status and all buildings, infrastructure etc will be removed from the site footprint. The second scenario sees the site decommissioned and rendered safe and not posing any environmental risk while leaving the building structures and associated infrastructure in place. Any demolition work to be carried out at the site will be carried out in accordance with the Department of the Environment Heritage and Local Government document entitled Best Practice Guidelines on the Preparation of Waste Management Plans for Construction and Demolition Projects. This document will be used to draw up a Project Construction & Demolition Waste Management Plan to plan demolition work. The Plan will ensure proper segregation of all materials such as steelwork, masonry and wood and that proper and effective recycling and/or recovery will be carried out. It is envisaged that all the concrete buildings would be demolished, crushed and graded and used as structural material in the regarding and restructuring of the quarry walls Removal of Infrastructure and Services The site drainage system involves an extensive surface water system, which is fully protected, that discharges to the Kinnegad River. All drainage and sump systems will be carefully removed. All quarry dewatering will cease to allow a natural equilibrium return to the hydraulic system and the lagoons and quarry areas will be developed according to the site restoration plan presented in Appendix I Materials and Residues Provision is made for the appropriate and authorised disposal of the following: Process chemicals including amines, hydrochloric acid and calcium chloride; Oils; Operational equipment wastes; Detailed inventories of the specific types and quantities of the major raw materials and wastes are presented above in Tables 3 and 4. TMS Environment Ltd Ref Page 19 of 25 EPA Export :01:29:05

20 4.0 Criteria for Successful Closure The criteria for successful decommissioning to ensure minimum impact to the environment with respect to management of the site closure are as follows: The appropriate decontamination of all plant and equipment; Documented reports of all raw materials dispatched from the site; Documented reports on the disposal of hazardous and non-hazardous waste including all certification required under regulations in force at the time; The appropriate decommissioning of all buildings; Continued implementation of the existing Environmental Management System (EMS) during the decommissioning process and maintaining the EMS postclosure of the site until required; Independent verification that no soil or groundwater contamination exists onsite upon decommissioning through additional site investigations if deemed necessary; The risk of environmental pollution is addressed and the EPA is satisfied that the site has been returned to a satisfactory state; Sufficient funds available to cover the full costs of closure and Independent verification and certification of clean closure status. Furthermore, the areas occupied by all site facilities and ancillary areas will be decommissioned and rehabilitated to a condition as close as possible to a greenfield site so that there are no constraints on future land use due to residual contamination or structures. Materials will be treated in such a manner that: Equipment and uncontaminated materials will be resold or reused; Uncontaminated materials that cannot be reused will be recycled; Contaminated or un-recyclable materials will be disposed of using authorized waste contractors. The overall objective is for clean closure of the site with no residual liabilities or constraints. 5.0 Closure Plan Validation Following implementation of the Closure Plan, LC will conduct a validation audit to demonstrate successful implementation of the closure plan to the EPA. The qualification and experience of the auditor will be provided and agreed with the EPA prior to the validation commencing. A validation report will be submitted to the EPA upon completion. 6.0 Closure Plan Costing Estimates of projected costs associated with site decommissioning and closure are outlined in this section. As there are no current plans for the closure of any part of the site and it is also currently impossible to determine which part(s) of the site could be closed down in the future there are two scenarios presented for costing purposes. TMS Environment Ltd Ref Page 20 of 25 EPA Export :01:29:05

21 Scenario 1 as presented in Table 5 presents an estimate of the cost for the closure of the whole site to include the demolition of all structures and buildings and the full removal of all infrastructure. The Restoration Plan for this scenario is presented in Appendix I. Scenario 2 as presented in Table 6 presents an estimate of the cost for the closure of the whole site but does not account for the demolition of buildings at the site. All buildings will be fully decommissioned and rendered safe and secure following closure works. Clean closure of the site would involve leaving buildings and roads in place and the site would be considered more valuable with this infrastructure in place. In this scenario the restoration element of the Closure Plan is costed to account for the re-grading of the quarry overburden slopes, planting of the overburden slopes around the margins, re-grading and re-shaping of the shale quarry and settlement lagoons. The two quarries will be allowed flood to create two significant water bodies with enhanced natural habitat potential. TMS Environment Ltd Ref Page 21 of 25 EPA Export :01:29:05

22 Table 5 Scenario 1 - Site Closure Costs (Estimates) Task Description Quantity (No) Measurement Unit Unit Rate Cost Source of Rates Plant & Equipment Decontamination Plant & Equipment Decommissioning Plant Disposal Removal of Electrical Supply Demolition and Removal of Buildings Removal of Surfaces Waste Disposal Environmental Monitoring Bulk storage tanks, pipelines and Buildings (1 supervisor, 6 operatives) 10 day 1,500 15,000 TMS Surface drainage network 5 day 1,500 7,500 TMS All Plant, Tanks, Buildings (1 supervisor, 9 operatives) including electrical services 110 day 2, ,000 TMS Nil cost as value far exceeds transport/shipping costs LC Across complete site (1 team of electrical specialists) 40 day 4, ,000 TMS All Structures & Buildings (1 team of demolition specialists) 40 day 2, ,000 TMS Removal, crushing and depositing (1 supervisor, 9 operatives) 125 day 2, ,000 TMS Across complete site (1 supervisor, 9 operatives) 50 day 2, ,000 TMS Hazardous Waste Disposal 120 tonnes ,800 TMS Hazardous Waste Transport 120 tonnes 50 6,000 TMS Non-Hazardous Waste Disposal 1000 tonnes 25 25,000 TMS Non-Hazardous Waste Transport 1000 tonnes 25 25,000 TMS Surface Water Monitoring 24 sample TMS Noise Monitoring 1 event TMS Dust Deposition Monitoring 6 event 200 1,200 TMS Groundwater Monitoring 2 sample TMS Site Security Contract Security Service 12 month 1,500 18,000 TMS Validation Audit Consultancy Costs 10 days 600 6,000 TMS Licence Surrender Fee to EPA 1 fee 12,697 12,697 EPA Site Restoration Restoration landscaping works 60 day 2, ,000 TMS TMS Environment Ltd Ref Page 22 of 25 EPA Export :01:29:05

23 Table 5 Continued Scenario 1 - Site Closure Costs (Estimates) Task Description Quantity (No) Measurement Unit Unit Rate Cost Source of Rates Management & Utility Costs Management 1 Person year 50,000 50,000 LC General Administration 50 days 125 6,250 LC Power 100,000 kwh ,000 TMS Project Insurance 1 unit 50,000 50,000 TMS Fuel 60,000 litres ,000 TMS Total 1,296,297 Plus Contingency at 20% 259,259 Total Including Contingency 1,555,556 TMS Environment Ltd Ref Page 23 of 25 EPA Export :01:29:05

24 Table 6 Scenario 2 - Site Closure Costs (Estimates) Task Description Quantity (No) Measurement Unit Unit Rate Cost Source of Rates Plant & Equipment Decontamination Plant & Equipment Decommissioning Plant Disposal Waste Disposal Environmental Monitoring Bulk storage tanks, pipelines and Buildings (1 supervisor, 6 operatives) 10 day 1,500 15,000 TMS Surface drainage network 5 day 1,500 7,500 TMS All Plant, Tanks, Buildings (1 supervisor, 9 operatives) including electrical services 110 day 2, ,000 TMS Nil cost as value far exceeds transport/shipping costs LC Hazardous Waste Disposal 120 tonnes ,800 TMS Hazardous Waste Transport 120 tonnes 50 6,000 TMS Non-Hazardous Waste Disposal 300 tonnes 25 7,500 TMS Non-Hazardous Waste Transport 300 tonnes 25 7,500 TMS Surface Water Monitoring 24 sample TMS Noise Monitoring 1 event TMS Dust Deposition Monitoring 6 event 200 1,200 TMS Groundwater Monitoring 2 sample TMS Site Security Contract Security Service 6 month 1,500 9,000 TMS Validation Audit Consultancy Costs 10 days 600 6,000 TMS Licence Surrender Fee to EPA 1 fee 12,697 12,697 EPA Site Restoration Restoration landscaping works 30 day 1,000 30,000 TMS Management 0.5 Person year 50,000 25,000 LC Management & Utility Costs General Administration 25 days 125 3,125 LC Power 50,000 kwh ,000 TMS Project Insurance 1 unit 25,000 25,000 TMS Fuel 30,000 litres ,500 TMS Total 429,672 Plus Contingency at 20% 85,934 Total Including Contingency 515,606 TMS Environment Ltd Ref Page 24 of 25 EPA Export :01:29:05

25 7.0 Closure Plan Update and Review The Closure Plan will be reviewed annually and updated accordingly. This review will address all developments at the LC site in Kinnegad and evaluate the scope of the Plan in the context of any environmental incidents at the site. The updated and reviewed Plan will take account of any site or process changes, technology changes and costing changes. 8.0 Closure Plan Implementation There are currently no plans for closure of any part of the site but the Environmental Protection Agency (EPA) will be given three months notice and six months notice of any partial or full closures respectively. The form of notice given will be in accordance with prevailing guidance and in accordance with consultations with the EPA. Other statutory bodies including the local authority will be notified of plans to cease operation and proposed decommissioning timeframe. 9.0 Environmental Monitoring During Decommissioning An Environmental Exit Audit of the site will be carried out following the announcement of closure and prior to actual decommissioning and closure operations taking place. The audit will devise an accurate inventory of all plant, equipment and wastes on the site. This inventory will be used as a benchmark against which successful decommissioning will be assessed. All IEL monitoring for the site with respect to surface water, groundwater and waste management will remain in effect over the course of the decommissioning phase Financial Provision The figure of 1,555,556 for Scenario 1 and 515,606 for Scenario 2 calculated for the implementation of the closure plan represents the present value of the current estimate of the costs for closure of the LC site. LC has adequate financial resources to implement the closure plan through to completion and will make specific financial provision for closure of the site. The Annual Environmental Report for the site shall contain a statement as to the financial provisions in place to meet these costs. The Closure Plan and cost estimates will be reviewed yearly and revised if required. The financial provision will be updated accordingly to reflect the current level of known environmental liabilities. TMS Environment Ltd Ref Page 25 of 25 EPA Export :01:29:05

26 APPENDIX 1 SCEANRIO 2 RESTORATION PLAN EPA Export :01:29:05

27 EPA Export :01:29:05 to f c Fo op r i yr ns ig pe ht ct ow ion ne pu r r rp eq os ui es re o d nl fo y. ra ny ns en Co. se ru he ot