Clogrennane Lime Ltd. Toonagh Lime Works AER Licence # P

Size: px

Start display at page:

Download "Clogrennane Lime Ltd. Toonagh Lime Works AER Licence # P"

Marvin Palmer
6 years ago
Views:

1 Clogrennane Lime Ltd Toonagh Lime Works AER 2010 Licence # P

2 Section 1 Overview Introduction 1.1 Description of Activities 1.2 Responsibility for Environmental Management 1.3 Environmental Policy Section 2 Emissions Emissions to Atmosphere 2.2 Noise Emissions & Tonal Noise 2.3 Dust Deposition & Annual PM 10 / 2.5 Section 3 Waste Management Waste Management Overview 3.2 Repak 3.3 Waste Register Section 4 Resource Consumption Section 5 Bund Integrity. 9 Section 6 Complaints / Incidents Section 7 Environmental Management Programme Review of 2010 Objectives and Targets (2 nd Schedule) Objectives and Targets (3 rd Schedule) Section 8 Reports Review of ELRA and CRAMP 8.2 Energy Efficiency Audit Summary 8.3 Bat Survey 8.4 WYG Report Section 9 Inspections.. 13 Appendix A Diesel Loss Overview Appendix B AER Contents as per Schedule D of Licence # P Appendix C PRTR 2010/2009 2

3 Section 1 Overview 1.0 Introduction IPPC Licence Register Number: P Licensee Name: Clogrennane Lime Ltd Site Name: Toonagh Lime Works Location: Toonagh Quarry, Ennis, County Clare 1.1 Description of Activities Production of lime in a kiln (POE 13.3). The activity at the plant consists of the calcining of limestone in a kiln to produce quicklime. The plant consists of a kiln, storage silos, a petcoke plant, workshop and office building. A weighbridge is in operation at the site. Stone is purchased from an adjacent quarry, stockpiled and fed into the kiln as required. Once inside the kiln, it is heated to ~ C. The final product is either sold as lump or crushed lime. The fuel source for the kiln is petcoke, which is dried and milled before combustion. Emissions from the site consist of emissions to atmosphere from the stack, fugitive dust emissions and noise emissions. There are no emissions to water or sewer. The site is also part of the GHG Scheme (IE-GHG ). The plant operates 24 hours a day, 365 days a year. It is primarily controlled via radio link from the control room in the Carlow plant, although Toonagh personnel can take control of the plant if necessary. 1.2 Responsibility for Environmental Management The responsibility for the Environmental Management of Toonagh Lime Works is as follows: (i) Location Manager, Mr. Bill Keogh (ii) Technical Manager, Mr. Joe Connolly (iii) Quality Technician, Mr. Mark Kennedy (iv) Managing Director, Mr. Larry Byrne 1.3 Environmental Policy Toonagh Lime Works operates an Environmental Management System to achieve its short and long term goals of Continuous Environmental Improvement. This Management System is in the form of an IPPC licence, which is supported by procedures from the Environmental Manual. 3

4 Section 2 Emissions 2.1 Emissions to Atmosphere Emission Source Reference A1.1 (Kiln). All emissions to atmosphere are within the ELV s as set out in Schedule B.1 of licence number P Parameter 1 st Half 2010 (mg / Nm 3 ) 2 nd Half 2010 (mg / Nm 3 ) Annual Average (mg / Nm 3 ) ELV s (mg/nm 3 ) Mass Emissions (2010) (tonnes per annum) Mass Emissions (2009) (tonnes per annum) Compliance (%) Particulates < PM PM Nitrogen Oxides (as NO2) Oxides of Sulphur (as SO2) < 5 < 5 <

5 2.2 Noise Emissions & Tonal Noise All noise measurements are compliant with the limits as set out in licence number P (Condition 4.5 & Schedule C.5). As per Condition 6.1, a tonal noise survey was carried out in No tonal noise was evident. All measurements are 30 minute LAeq db(a). Day Location Q1 Q2 Q3 Q4 ELV Compliance (%) NSL NSL Night Location Q1 Q2 Q3 Q4 ELV Compliance (%) NSL NSL

6 2.3 Dust Deposition & Annual PM 10 / 2.5 As per Schedule B1.2, dust deposition is measured once per quarter on a 30 day composite sample. Annual measurement of ambient PM 10 & 2.5 was carried out. Although no limits are set for these parameters in the licence, the results were still below national limits. A copy of this report is available on site for inspection. All dust deposition results are within the limits set out in the licence, as shown in the table below; Location Q1 Q2 Q3 Q4 ELV Compliance (%) AM AM AM AM * AM Note 1: All results in mg / m 2 / day * Note 2: AM 5 is not specified in the licence but is done in addition to AM 1-4, hence no limits are set for this location 6

7 Section 3 Waste Management 3.1 Waste Management Overview Toonagh Lime works follows acceptable principles of waste management and control. These principles are as follows: Prevent Reduce Re-Use Recycle Energy Recovery Disposal Prevention Toonagh Lime Works strives to prevent waste wherever possible. This principle is intrinsic to the efficient operation of the plant andd process. Since all raw materials are used during the process, there is no process waste Minimisation The efficient control of the plant and equipment ensures that the generation of material outside specification is kept to an absolute minimum Re-use All process materials are used within the process to produce the final products Recycling Waste materials generated will be recycled r where possible Energy Recovery Energy recovery from waste material does not apply to the operations at Toonagh Lime Works Disposal The production of waste is minimised through the efficient operating of all areas of production. With the reduction of waste through thee implementation of the above principles the disposal of waste is kept to a minimum 3.2 Repak We are members of the Repak scheme and post returns biannually 7

8 3.3 Waste Register The full Pollutant Release and Transfer Register can be found in Appendix C The table below gives a summary of physical wastes leaving the site Hazardous waste consisted of contaminated soil from the diesel loss incident as described in Appendix A Full C1 records are available on site Waste Description Hazardous (Yes / No) EWC Disposal/ Recovery Code Disposal Company Waste Transporter General Waste General waste from site and workshop No D1 Clare Waste Ltd Greyhound Recycling Clare Waste Ltd Clean Ireland Recycling Ltd Waste Wood Pallets etc No R3 Greyhound Recycling Clean Ireland Recycling Ltd Mixed Recyclables Dry office and packaging waste No R3 Greyhound Recycling Clean Ireland Recycling Ltd Contaminated Soil From diesel loss incident Yes * R5 ENVA Ltd ENVA Ltd Final Destination Ballinagun Landfill, Cree, Co. Clare Inagh Landfill, Co. Clare Finsa Ltd, Scariff, Co. Clare Clean Ireland Recycling, Cree, Co. Clare ENVA Portlaoise Quantity of Waste Produced 4.02 t 2.22 t 0.12 t 66.76t 8

9 Section 4 Resource Consumption The table below outlines the resource consumption at Toonagh Lime Works in 2010; Resource Units Petcoke tonnes Electricity GWh On-site ground water abstraction m 3 On-site surface abstraction 0 0 m 3 Municipal supply 0 0 m 3 The sole raw material for the process is limestone. 100% of raw material brought on site is consumed with no process waste generated. Section 5 Bund Integrity Toonagh Lime Works maintains two bunded areas on site; Bund 1 Oil storage bund Bund 2 Petcoke diesel bund Both bunds were tested for soundness in 2010 and were found to be impermeable to water loss Both bunds are due again for testing in Section 6 Complaints / Incidents There were no complaints in Toonagh Lime Works in 2010, or in any previous year of operation. There was one incident on site, as detailed in Appendix A. A non- compliance against Condition 5.1 of the licence was issued in inspection report reference # ((P )sm03vt)). 9

10 Section 7 Environmental Management Programme 7.1 Review of 2010 Objectives and Targets (2 nd Schedule) Area Objective Target Timeframe Responsibility Progress Environmental Manual Energy Usage Dust Training To establish an Environmental Manual and improve the EMS To identify areas where a reduction in energy consumption is possible To control fugitive emissions To keep all staff up to date with new and existing legislation and best practice methods To have a fully digital, company-wide Environmental Manual by 2012 To remain below the upper levels of energy consumption as found in the BREF for the lime industry To remain below the limits for dust deposition as set out in the licence To ensure that key management are fully aware, at a minimum, of key legislative issues Stage 1 July 2010 End 2010 Ongoing Mr. Joe Connolly Mr. Brendan Walsh Mr. Alan Ryan Mr. Bill Keogh Mr. Joe Connolly Mr. Bill Keogh Ongoing Mr. Joe Connolly Stage 1 completed Environmental Manual established Completed Site identified as being highly energy efficient Full report available on site for inspection Dust awareness program initiated No dust complaints in 2010 or any previous year Internal training was carried out in 2010 External training (EPA seminar) attended 10

11 Objectives and Targets (3 rd Schedule) Area Objective Target Timeframe Responsibility Environmental Manual Stage 2 to expand the existing Manual, focusing on emergency preparedness To have a fully digital, company-wide Environmental Manual by 2012 Stage 2 End 2011 Mr. Joe Connolly Mr. Brendan Walsh Mr. Mark Kennedy Mr. Bill Keogh Energy Usage To incorporate the findings of the energy usage survey carried out in 2010 into a full energy efficiency audit To remain below the upper levels of energy consumption as found in the BREF for the lime industry End 2011 Mr. Alan Ryan Mr. Joe Connolly Diesel Loss Training To fully comply with the recommendations of WYG in relation to the diesel loss incident in 2010 To keep all staff up to date with new and existing legislation and best practice methods To have completed off site monitoring and reduced on site monitoring by end of 2011 To ensure that key management are fully aware, at a minimum, of key legislative issues End 2011 Mr. Joe Connolly Mr. Mark Kennedy Mr Bill Keogh Ongoing Mr. Joe Connolly 11 Operational Means / Mechanism for Achievement Manual will be expanded and tied in with the OHSAS system for emergency response. General procedures will be expanded and updated. A full energy efficiency audit was last carried out in This desk based audit will be revised using the information from the energy usage survey carried out in Full consideration will be given to the final WYG report, due April 2011 Ongoing Adequate resources will be provided for any training required in this area

12 Section 8 Reports 8.1 Review of ELRA and CRAMP The original ELRA and CRAMP was completed and submitted to the Agency in The Financial Provisions in the original document are considered sufficient for the site at present. A new ELRA, incorporating Financial Provisions (2011) is currently being drafted and will be submitted to the Agency for approval in Q2 of this year. 8.2 Energy Efficiency Audit Summary An energy efficiency audit was carried out in This report was submitted to the Agency. The report found that no major savings could be made in the area of energy efficiency, although some minor modifications to the plant were recommended. Toonagh Lime Works operates a highly efficient dual shaft regenerative kiln, and the audit found that it is operating at levels considered to be those of an efficiently operated kiln, as found in the BREF for the lime industry (2001 version). An energy monitoring survey was carried out in Using the results from this survey it is planned to repeat the original energy use survey in Results from this will be compared to the typical results as found in the latest BREF (2010 version) for the lime industry. 8.3 Bat Survey As agreed in letter to the Agency dated 30 th June 2010, the bat survey is now required every second year instead of annually. Therefore no survey was carried out in A survey is planned for WYG Incident Report A report on the diesel loss incident was submitted to the Agency on the 26 th November This report contained an overview of the incident, the initial response and the proposed medium to long term plan. A second WYG report is expected in Q

13 Section 9 Inspections Two site inspection reports were issued in 2010; Inspection Reports SM02aJD SM03vt Date of Inspection 4/11/2009 3/11/2010 Date of report 12/11/ /11/2010 Non-compliances None One Audit observation 1 Storage of waste on site SO 2 test programme Audit observation 2 Records not available for inspection Oil and lubricant store Audit observation 3 SO 2 test programme Financial provision Audit observation 4 General housekeeping Audit observation 5 Diesel tank hose All points in both reports have been addressed and a response sent to the Agency 13

14 Appendix A Diesel Loss Incident Overview On the 28/29 th October 2010, an incident occurred on site at Toonagh Lime Works. An operator error resulted in the loss of approximately 2800 litres of diesel from a bunded storage tank on site As soon as the loss of diesel became apparent, an emergency response plan was initiated. The EPA, local County Council and the Inland Fisheries board were contacted WYG Environmental Consultants were brought in to project manage the incident response Response to incident The immediate response to the incident involved the collection of residual diesel on site and the monitoring of wells and springs both on and off site. Clogrennane Lime Ltd worked closely with the Agency and local County Council, with several meetings being held between the relevant parties In the medium to long term, monitoring wells were drilled on site with a view to establishing a pump and treat system for any diesel encountered. Inspection of off-site wells and springs continued on a routine basis Current standing No diesel was encountered at any monitoring location on or off site. The monitoring wells have not encountered any diesel contamination and there has been no evidence of diesel contamination in the groundwater The site itself sits on a massive limestone formation. The foundations of the kiln were built on this formation and surrounded by granular infill material. It is suspected that the diesel lost is held in the porous material at the foundations of the kiln Monitoring of the wells both on and off site will continue for a period as agreed with the Agency Correspondence with the Agency A joint Clogrennane Lime Ltd / WYG Incident Report was submitted to the Agency on the 26 th November This report contained an overview of the incident and the medium to long term incident response plan Site inspection report SM03vt was received from the Agency on the 22/11/2010, dealing mainly with the incident. A non-compliance was issued against Condition 5.1 of the licence 14

15 Appendix B AER Contents as per Schedule D Topic Emissions from installation Waste management record Resource consumption summary Schedule of environmental objectives Environmental management programme previous year Environmental management programme current year Pollution emission register previous year Pollution emission register current year Noise monitoring summary Ambient monitoring summary Tank and pipeline testing and inspection report Reported incidents summary Energy efficiency audit report summary Report on the assessment of the efficiency of use of raw materials in process and the reduction in waste generated Report on Progress Made and Proposals being developed to minimize Water Demand the Volume of Trade Effluent Discharged Review of residuals management plan Review of Environmental Liabilities including Financial Provision Comments (PRTR) (PRTR) (Section 5) (Appendix A) N/A 15

16 Appendix C Pollutant Release & Transfer Register 2010 & 2009

To reduce the consumption of energy and the emission of greenhouse gases associated with Transit Systems NSW s activities.

Transit Systems NSW Environmental Management Plan GOAL 1: REDUCE THE GREENHOUSE IMPACT OF ENERGY USE To reduce the consumption of energy and the emission of greenhouse gases associated with Transit Systems