ATTACHMENT No. I EXISTING ENVIRONMENT AND IMPACT OF THE ACTIVITY TABLE OF CONTENTS

Transcription

1 ATTACHMENT No. I EXISTING ENVIRONMENT AND IMPACT OF THE ACTIVITY TABLE OF CONTENTS I.1. Assessment of Atmospheric Emissions... 2 I.2. Assessment of Impact on Receiving Surface water I.3. Assessment of Impact of Discharge to Sewer I.4. Assessment of Impact of Emissions to Ground/Groundwater I.5. Groundwater Contamination I.6. Assessment of the Environmental Impact of On-site Waste Recovery and/or Disposal I.7. Noise Impact I.8. Environmental Considerations and BAT I.9. References I - 1 of 34 EPA Export :16:18:58

2 I.1. Assessment of Atmospheric Emissions I.1.1 Introduction No Change in Emissions from the use of Alternative Fuels. Subject to the IPPC licence review Irish Cement will introduce alternative fuels and operate the cement manufacturing works at Platin in accordance with Directive 2000/76/EC, the Waste Incineration Directive (WID). The WID was adopted to bring legal clarity across the EU in relation to waste incineration and co-processing of waste in industrial facilities such as cement plants and other combustion facilities. WID sets specific emission limit values for cement plants using alternative fuels. The two controls demanded by WID are that temperatures should exceed 850ºC (or 1,100ºC where hazardous wastes with a content of more than 1% of halogenated organic substances, expressed as chlorine are involved) and the gas residence time must exceed 2 seconds at these temperatures. In Platin the fuels will initially be introduced to the kiln system in the calciner where the temperature exceeds 1,000ºC and the residence time is over 8 seconds. The majority of the fossil fuels are used in this section of the system which is why substitution will commence here. At a later stage some of the fuels may also be introduced at the main burner where the gas temperatures exceed 2,000ºC and the residence time in the kiln is over 12 seconds. The conditions established by WID are exceeded by a significant safety factor in the kiln system in Platin. Much research has been carried out into combustion of alternative fuels in cement kilns and there is extensive evidence that emissions to atmosphere from the manufacture of cement are not altered by the introduction of alternative fuels [1]. Carbon dioxide emissions are reduced and it has been generally observed that emissions of nitrogen oxides are marginally reduced. The consistency of emissions for cement plants using varied fuel combinations arises primarily because of the combustion conditions that exist within the cement plant namely the high temperatures and long gas residence times. These features were identified in a paper examining air emissions from cement kilns, The conditions inside a modern cement plant are ideal for the safe processing of these fuels. The gas temperature in a kiln system can exceed 2000ºC. Material temperatures are maintained above 1450ºC in order for the clinker reaction to take place. These high temperatures together with the long residence time ensure the complete destruction of >99.99% of organic matter. [2] The UK s Committee on the Medical Effects of Air Pollution, (COMEAP) has stated that the use of waste derived fuels in cement kilns results in no changes in emissions that would be of significance to human health. Its most recent report, from 2008 on the use of Meat and Bonemeal, Processed Sewage Sludge and Refuse Derived Fuel (RDF) (referred to in this licence review as Solid Recovered Fuel (SRF)) by the cement industry echoed its positive findings from their 2005 report on the use of Rubber Tyres and Secondary Liquid Fuel (SLF) in the cement industry. COMEAP went on to confirm that the use of these fuels in combination by licensed cement kilns was also a safe practice [3]. Irish Cement operates its cement manufacturing facility in Platin in full compliance with an IPPC licence P Emissions are controlled and remain within permitted limits. As discussed earlier the co-processing of alternative fuels by the cement industry in Europe is controlled by the limits established under the Waste Incineration Directive (WID) 2000/76/EC. Emission limit values under WID are more restrictive than would be the case for a cement plant using only traditional fuels. The Directive also requires a wider range of emissions to be monitored and reported than in cement plants using only traditional fuels. I - 2 of 34 EPA Export :16:18:58

3 Within the EU alternative fuels have been in use by the cement industry for more than 30 years. Approximately 20% of the heat requirement for the European cement industry is currently provided by alternative fuels. All of the cement plants using alternative fuels are licensed by the respective environmental authorities and have been able to demonstrate compliance with relevant emission limit values. There is considerable evidence based on this experience that there are no increases in the nature or extent of emissions from cement plants following the introduction of alternative fuels. In a recent publication Sustainable Cement Production by the European Cement Association, Cembureau, it is concluded that The use of suitable alternative fuels does not have any negative impact on emissions [1]. The Report goes on to address individual emissions from the cement kilns and presents the follow impacts of co-processing alternative fuels which is reproduced here as Table I.1 below. Table I.1 Emission Sulphur oxides SO 2 Nitrogen oxides NO X Total organic carbon TOC Polychlorinated dibenzo-pdioxins and polychlorinated dibenzofurans (PCDD/PCDF) Hydrogen chloride HCl Hydrogen fluoride HF Heavy metals Dust Impact of Co-Processing on Kiln Emissions Impact Alternative fuels have no influence on total SO 2 emissions Alternative fuels do not lead to higher NO X emissions in some cases, NO X emissions can even be lower There is no correlation between the use of alternative fuels and emissions levels. No difference has been found in dioxin emissions when alternative fuels are used. HCl emissions are independent of the fuel used. There is no significant difference in HF emissions when using alternative fuels. Emissions are independent of the fuel used. However, nearly 100% of the heavy metals remain either in the cement clinker matrix or the cement kiln dust as non leachable compounds. The use of alternative fuels in clinker production does not lead to increases in dust emissions. I - 3 of 34 EPA Export :16:18:58

4 Experience from European Cement Plants using alternative fuels Irish Cement Platin operates in compliance with an IPPC licence from the EPA and the current review application is to allow for the inclusion of alternative fuels as part of the cement production process. There is much experience of alternative fuel use throughout the cement industry particularly in Europe which clearly demonstrates that plant emissions are not negatively impacted by the introduction of alternative fuels. Irish Cement, as part of the CRH Group of companies, has direct access to experience and data from the successful use of alternative fuels over many years from sister cement plants around Europe. This experience demonstrates how emission control in the plants is unaffected by the introduction of alternative fuels. Data is presented overleaf (Figure I.1) from one such CRH sister cement plant in Portugal and covers a 10 year period from 1997 to The three graphs show the results of an extensive emission monitoring programme at the plant for; o o o Heavy Metals (Sb+As+Pb+Cr+Cu+Co+Mn+Ni+V+Sn) Mercury Dioxins The data represents the transition from fossil fuel (traditional fuel) to the introduction of various alternative fuels. The Red Line on each graph represents the EU WID emission limits. I - 4 of 34 EPA Export :16:18:58

5 Figure I. 1 Emission Monitoring Results for Secil Cement Plant, Outao, Portugal ( ) Heavy Metal Metal Measurements- Cement Plant Portugal (Sb+As+Pb+Cr+Cu+Co+Mn+Ni+V+Sn) Concentração (mg/m 3 ) Emission 20 Limit Traditional fuel Traditional fuel with Alternative fuel (SRF, Tyres, MBM) Traditional fuel with Alternative fuel and Solvent (SLF) Concentração (mg/nm 3 ) Mercury Measurements - Cement Plant Portugal 0 0 Emussion Limit Traditional 60 fuel only Traditional fuel with Alternative fuels (SRF, Tyres, MBM) Dioxin Measurements - Cement Plant Portugal Traditiona fuel, Alternative fuel and Solvent (SLF) Concentration (ng/nm3) Emission Limit Traditional fuel only Traditional fuel with Alternative fuels (SRF, Tyres, MBM) Traditional fuel, Alternative fuel, and Solvent (SLF) This data above is presented with the kind permission of Secil - Companhia Geral de Cal e Cimento, S.A. Technical Centre Portugal I - 5 of 34 EPA Export :16:18:58

6 As part of the planning application to Meath County Council an Environmental Impact Statement (EIS) was prepared. Extensive work on monitoring and modelling of air emissions was carried out for the EIS and is reported in Chapter 7.0 Air Quality of the EIS included as part of this IPPC Application for Review. That chapter identifies the various air quality standards and details the results of the modelling for each emission species. In each case the predicted concentrations comply with all the relevant air quality standards and guidelines. Air dispersion modelling was also carried out as part of this Review. The report, Air Quality Modelling of Various Parameters (2008), on the software modelling of emissions from the plant is included in this Attachment. As with the EIS, it is predicted that Irish Cement Ltd. will continue to operate in compliance with all relevant air quality standards. I.1.2 Air Dispersion Modelling Air Dispersion modelling was carried out to predict the ground level concentrations of emissions from the works. Emissions were modelled on a highly cautious and conservative basis as follows: Emissions were assumed to occur at Waste Incineration Directive (WID) 2000/76/EC emission limit values (stack gas concentrations), whereas actual emission concentrations will be significantly below these limits. Emissions were assumed to occur 24 hours a day, 7 days a week, 365 days a year, whereas in practice the plant is shut down for short-term maintenance periodically and for an extended period for annual maintenance. The model predicts ground level concentrations (GLCs) for a large number of receptors extending to a distance 10 km from the works. The highest predicted GLC was then compared to the air quality standards. The model predicts GLCs for each hour of meteorological data over a five year period, i.e. over 40,000 hours. The result for the worst hour of meteorological data was compared to the air quality standards. In comparing NO 2 concentrations to the air quality standards, a conversion factor of 0.5 NO x to NO 2 was used in the EIS, as advised by the EPA in Following a request for further information by the EPA in 2007 relating to the Application for Review of IPPC Licence P , the impact of using a more conservative NO x to NO 2 conversion of 100% for long-term effects was assessed for that application. In light of this previous request for information the same more conservative 100% conversion for long tem effects has been used to assess compliance with NO 2 air quality standards in this Review (refer to attached Air Quality Modelling of Various Parameters (2009)). The model also takes into account the cumulative impact of all the planned and existing facilities locally. o Indaver - The predicted emissions from the Indaver facility, to be located to the West of the cement works, at the revised 200,000 tonnes level are also included. With respect to the cumulative impact of the ICL plant and the Indaver plant at Carranstown, the maximum ground level concentrations predicted for ICL and for Indaver were assumed to be coincident, that is, to occur at the same location and at the same time. This is highly conservative and would rarely if ever be realised in practice. I - 6 of 34 EPA Export :16:18:58

7 o The air emissions modelling which formed part of the EIS in support of Irish Cement Planning Application (Ref SA803066) to Meath County Council in November 2008 included the cumulative impacts of both the proposed Indaver facility and the proposed Platin Power/ SSE Power (Ref 99/2490) and amendment (Ref SA30213) plant to the South West of the cement plant. Planning lapsed on the 9 th of March 2009 for the proposed power plant and a second planning application (Ref SA/800968) was subsequently rejected by the Planning Authority. Therefore this development has not been included in the cumulative air emissions of the Air Quality Modelling of Various Parameters 2009, Arup Consulting Engineers. The original EIS is included as part of this Licence Review Application. The modelling shows that, on the basis of the most highly pessimistic and conservative assumptions described above, air quality standards and guidelines for the pollutants regulated by the WID will not be exceeded. The actual GLCs will be significantly below those predicted on this conservative basis so the results of the air dispersion modelling can be shown to be robust with an extremely high margin of confidence. Site Specific Emissions No additional emissions to atmosphere, waters or waste will arise on site due to the proposed development. In line with experience from the European cement industry it is expected that emissions of some materials to atmosphere will reduce (See Table I.1). The operating parameters of the cement manufacturing processes will not change with the introduction of alternative fuels as support fuels. The extreme temperatures (1,000 o C - 2,000 o C), long gas residence times (>8 seconds) and the high levels of oxygen in the kiln ensure complete combustion. Inorganic components and some of the available metal ions are incorporated into the clinker inside the kiln. Another unique feature of the cement manufacturing process is the counter-current nature of the gas and material flows. The hot kiln gases rise up through the system against the incoming powdered raw materials. This system ensures thorough mixing of the alkali raw material and the hot gases. This mixing has the primary advantage of pre-heating the incoming raw materials and allowing for the beneficial reuse of the excess heat. This mixing also permits the exchange of fine particles from the kiln gases across to the incoming raw material, where they are chemically incorporated into the final product. The exhaust gases are cooled rapidly and passed through a fabric filter to recover the fine particulate dust. This dust is captured and recycled back in to the process. The fabric filter provides BAT dust collection efficiencies for the cement plant. I - 7 of 34 EPA Export :16:18:58

8 Figure I.2 Diagrammatic illustration of Kiln 3, Platin with Proposed Fuel Input Locations Figure I.2 shows the two proposed fuel input locations and also graphically illustrates the internal temperature profile of the Kiln 3 in Irish Cement Ltd s (ICL s) Platin facility. The EU Directive 2000/76/EC requirements of a gas temperature of 850ºC for two seconds are achieved in both proposed fuel input locations. I - 8 of 34 EPA Export :16:18:58

9 I.1.3 Greenhouse Gas Emissions The ICL Platin Works is subject to S.I. No. 437 of 2004, the European Communities (Greenhouse Gas Trading) Regulations 2004 (refer also to Attachment No. L). As such, it holds a Greenhouse Gas Emissions Permit (refer to Attachment No. L ). This permit places an obligation on ICL to surrender emissions to EPA equal to the annual reportable emissions of CO 2 equivalent emitted each year. In line with government requirements and in order to reduce the carbon footprint of its products, Irish Cement has been replacing the traditional CEM I Bulk and Packed products with new CEM II Portland-Limestone green cements in recent years. Traditional CEM I cements are based mainly on clinker produced by burning limestone and silica materials at high temperatures in a kiln. This production process results in carbon dioxide emissions. In the new CEM II products, between 10% and 20% of the clinker is being substituted by finely milled un-burnt limestone, which is added in the production of the final cement product. This reduces both carbon dioxide emissions arising from limestone decarbonation and fuel emissions leading to a reduction in CO 2 emissions per tonne of cement produced. CEM II green cements now account for over 80% of the Irish Cement product portfolio. CEM II cements are only one part of Irish Cement Investing in Our Future strategy. Modernisation of its facilities focusing on energy efficient production and the introduction of alternative fuels make up the other key strategies in achieving world class sustainable cement production in Platin. I - 9 of 34 EPA Export :16:18:58

10 Figure I.3 Sustainable Cement Production Co-processing of Alternative Fuels and raw Materials in the European Cement Industry, Cembureau, 2009 [5] The primary advantages of using AF in the cement manufacturing process are; 1. Complete recovery of the energy value of the material due to the efficiency of the combustion process in the cement kilns 2. Reduction in CO 2 emissions; Indirectly by diverting material from landfill thereby reducing the potential for landfill gas production (refer to Figure I.3) Direct emissions due to the fuels lower carbon intensity The biomass fraction of the fuels is considered renewable and CO 2 free 3. Reduction in the dependency on imported fossil fuels I - 10 of 34 EPA Export :16:18:58

11 4. No residual wastes are produced from the cement manufacturing process. The organic fraction contributes to the combustion process and the inorganic components are incorporated into the cement product thereby eliminating the requirement for additional landfill capacity. 5. Complete destruction of the fuels due to the high temperatures, long residence times and high thermal inertia. 6. Reduction in the input of raw materials and additives due to the mineral contribution from AF 7. Contribution to Ireland s international obligations; Provides the most efficient energy recovery option without the need to export Assists in achieving our landfill diversion targets Assists in meeting our greenhouse gas reduction obligations I.1.4 Atmospheric Emissions Overall Summary The predicted concentrations of atmospheric emissions comply with the relevant air quality standards and guidelines, including the parameters for which an emission limit value is specified in Directive 2000/76/EC. This conclusion is based on: The detailed air emissions modelling exercise The results of measurements made on cement kilns throughout Europe, using a wide variety of alternative fuels in various proportions The results of baseline measurements made in Platin before Kiln 3 was commissioned The following conclusion can be drawn: the emissions of the parameters for which an emission limit value is specified in Directive 2000/76/EC will not increase to any significant extent. Furthermore, the emissions will comply with the emission limit values in the Directive. I - 11 of 34 EPA Export :16:18:58

12 I.2. Assessment of Impact on Receiving Surface water Details of the Surface water Management System The surface water management system consists of a box drain network throughout the site which diverts surface waters and some spent process water to the water treatment plant. Pumps located in the adjacent quarry also transfer surface water to the water treatment plant. The water treatment plant comprises of a storm balancing tank followed by sedimentation tanks. Oil and silt interceptors and floating oil absorbent booms are located throughout the surface water management system. The treated surface waters are discharged to the River Nanny. The proposed development will give rise to minor additional rainwater runoff as follows: - Roof of Solid Recovered Fuel store. - Roof of Chipped Tyre store The total additional impermeable area from these buildings will be 0.20 ha. With an impermeable area of approx ha for the developed area of the full site this represents a minor increase of 1.14%. The runoff from the roofs of the two buildings will be collected in a surface water drain which will be connected to the overall site box drainage network. The proposed facilities will have no significant impact on the site surface water management system. The surface water quality monitoring results are presented in Table I.2(i). An ecological and sediment study of the River Nanny was conducted by Ecofact Environmental Consultants on behalf of ICL Platin in This study focussed on 3 sites upstream (control) and 3 sites downstream (receptor) of the ICL Platin combined treated wastewater, surface and process water and groundwater outfall (IPPC licensed emission point SW4). Results of the assessment showed that the macroinvertebrate communities, biological water quality and sediment levels in the River Nanny are the same upstream and downstream of the ICL Platin Combined Treated Discharge to the River Nanny. Thus, the discharge from the ICL Platin facility is not having any significant environmental impact on the biological water quality of the downstream areas surveyed (refer to An Ecological and Sediment Study of the River Nanny near Duleek, Co. Meath provided in this Attachment). ICL Platin is compliant with the emission limit values for IPPC licensed emission point SW4, as specified by the Agency and specified in their IPPC Licence (Reg. No. P ). ICL Platin provides reports of analyses conducted at SW4 (discharge to surface water) to the Agency in the AER. Further details on emissions to surface water are provided in Attachment No. E. The alternative fuel delivery and storage systems are fully enclosed thereby preventing surface water contamination. The surface water is potentially at risk from any accidental spillage or contamination from fire-water arising at the facility. This risk is minimised by storing raw materials in covered areas where possible and by bunding potentially contaminating liquids I - 12 of 34 EPA Export :16:18:58

13 (refer to Section J.1.4). Surface water is collected on the factory impervious areas and drained to the balancing/settling tanks. Box drains and sewers (including stormwater settling tanks and sewage treatment plant) were designed to British Standards and good civil engineering practice under the supervision of consultants during the construction of the plant in 1968/1973 and 1974/1977. Figure J.1 shows the surface, process and groundwater conveyance system. The water is passed through the balancing/settling tanks before being discharged through the common effluent pipeline to the River Nanny. A Fire-water Risk Assessment Report has been prepared by Arup Consulting Engineers to take account of the proposed introduction of alternative fuels on-site. This is included in Attachment No. J. In accordance with the recommendations of this report, it is proposed to provide a remote underground fire-water retention tank in order to retain any fire-water run-off from the alternative fuels storage facilities. In the unlikely event of a fire on-site, any such run-off would be retained in the tank, tested and discharged or, in the event that it cannot be discharged, it would be disposed of off-site in agreement with the Agency. I - 13 of 34 EPA Export :16:18:58

14 I.3. Assessment of Impact of Discharge to Sewer This section is not applicable to the activity. There are no emissions to sewer from the ICL Platin site. I - 14 of 34 EPA Export :16:18:59

15 I.4. Assessment of Impact of Emissions to Ground/Groundwater I.4.1 Ground and/or Groundwater Contamination There are no emissions to ground or groundwater at the ICL Platin site. The groundwater is of potable quality. Groundwater quality is monitored bi-annually in accordance with IPPC Licence Reg. No. P The groundwater quality monitoring results are presented in Table I.4(i). Irish Cement will ensure that groundwater is not impacted by the proposal to use alternative fuels at Platin Works. All storage and vehicle unloading areas for the alternative fuels will be located on impermeable hard standing. In the event of spillages in other area of the sites, mobile spill control kits will continue to be strategically located and available for spill control management. I - 15 of 34 EPA Export :16:18:59

16 I.5. Groundwater Contamination There is no recorded groundwater contamination on the site. This groundwater is of potable quality. Groundwater quality is monitored bi-annually in accordance with IPPC Licence Reg. No. P I - 16 of 34 EPA Export :16:18:59

17 I.6. Assessment of the Environmental Impact of On-site Waste Recovery and/or Disposal Substitution of fossil fuels with alternative fuels will have no impact on the on-site waste recovery and/or disposal. Measures will be put in place to prevent as far as practicable spillage of the alternative fuels during offloading or transport throughout the site. Where spillages do occur all material will be recovered by mobile vacuum system and all recovered material will be returned to the appropriate fuel storage system. Post offloading visual inspections will be required before any of the trucks leave site to ensure residual material is not spilled as the trucks exit the facility. Non-conforming alternative fuel deliveries which are not accepted on site will be returned to the supplier to be reprocessed. Material that is accepted on site will be sampled, either manually or in the automatic sampling station on the basis of a sample per supplier per day. These samples will be combined to produce monthly supplier composite samples for the purpose of checking compliance with fuel specification as part of the ISO 9001 quality control system. Composite samples of the alternative fuels taken, will be stored in a designated area on-site. After the required storage period the samples will either be sent off site for disposal or will be returned to the appropriate fuel storage system on site for processing as fuel. I - 17 of 34 EPA Export :16:18:59

18 I.7. Noise Impact The main sources of noise from ICL Platin are shown in Figure I.4. The location used for the noise monitoring is shown in Figure I.5. The 2008 Annual Noise Survey is included in this Attachment. As the plant is a continuous process one, the noise emission is quasi steady state. Consequently the specific noise due to the plant at receptor points is best represented by the L (A90,15min) noise parameter. The maximum mean daytime and night time L (A90,15min) values off-site (400m east of plant) for 2006, 2007 and 2008 noise surveys are presented in Table I.2. Table I.2 Results of Off-site (Synnott s) Noise Monitoring 2006, 2007 and 2008 Year L (A90,15min) Daytime Mean L (A90,15min) Night-time Mean db(a) db(a) Average Current Licence Limit Not to be exceeded by more than 2dB The L A90 levels are in compliance with the off-site noise limits as specified in the IPPC Licence. Results of on-site noise monitoring for 2006, 2007 and 2008 also complied with the limits specified in the IPPC Licence. Results of blast monitoring for 2006, 2007 and 2008 are presented in Table I.3. For the four years, the vibration and air overpressure levels are in compliance with the Licence limits. Table I.3 Results of ICL Blast Monitoring 2006, 2007 and 2008 Year No. of Blasts Peak Particle Velocity ( not > 12mm/s) No Single Blast Overpressure > db(lin) 95% of Blast Overpressures not > 125 db(lin) Compliant Compliant Compliant Compliant Compliant Compliant Compliant Compliant Compliant As results have shown that noise and blast monitoring data complies with the limits set by the Agency, the impact of noise emissions from ICL Platin on the surrounding area is not significant. A summary of noise and blast monitoring data is included in the Annual Environmental Reports (AERs) submitted to the Agency (refer to Attachment No. F). It is not envisaged that the equipment associated with the proposed alternative fuels handling system will constitute licensable noise emission points. The main sources of noise will be from four comparatively small blowers. The combined sound power level of these units will be 86 dba re watts. With the commissioning of Kiln 3 the total sound power on-site will be 114 dba re watts. The addition of 86 dba re watts from the proposal will not increase the total sound power level on-site above 114 dba re watts. Consequently the I - 18 of 34 EPA Export :16:18:59

19 operation of the proposal will not cause any increase in the sound pressure level at the nearest noise sensitive location, Synnott s, 400 m to the east of the plant. I.7.1 I Noise Limits Noise Source Power Limits for Individual Pieces of Plant Machinery Table E.5(i) in Attachment No. E lists 19 Noise Sources for the Platin Works. I - 19 of 34 EPA Export :16:18:59

20 I.8. Environmental Considerations and BAT The following documents were considered in the assessment of environmental considerations and BAT at the Platin site: Article 3 of Council Directive 96/61/EC concerning integrated pollution prevention and control European Commission Integrated Pollution and Prevention Control Reference Document on Best Available Techniques in the Cement and Lime Manufacturing Industries 2001 Section 7 (Amendment of Section 5 of the Environmental Protection Agency Act 1992) of the Protection of the Environment Act 2003 Draft BAT Guidance Note on Best Available Techniques for the Production of Cement and for the Production of Lime in a Kiln ICL continually invests in BAT based technologies. Recent examples include: Replacement of the old Kiln 1 system with the new BAT based Kiln 3 system, which is currently being commissioned. This includes an energy efficient raw mill and coal mill and a multi-stage pre-calciner. For new plants and major upgrades the best available technique for the production of cement clinker is considered to be a dry process kiln with multi-stage preheating and precalcination. Kiln 3 is a dry process kiln. Extension of Kiln 2 electrostatic precipitator Complete replacement of Coal Mill 2 electrostatic precipitator with a bag filter Installation of high efficiency separators on all cement mills Installation of SNCR technology on Kiln 2 Development of techniques to maximise the use of overburden and so reduce the amount of quarried shale for use in the process represents BAT. Council Directive 96/61/EC General Obligations Article 3 of Council Directive 96/61/EC lists the general obligations on the operator to ensure that appropriate pollution prevention and control measures are put in place. Each of these obligations and the measures taken at the Platin site to address them are listed below: a. all the appropriate preventive measures are taken against pollution, in particular through application of the best available techniques; All the appropriate preventative measures taken against pollution at the Platin site relevant to the European Commission reference document on BAT (BREF) in the cement industry are listed in Table I.4. I - 20 of 34 EPA Export :16:18:59

21 Table I.4 Pollution Prevention Measures at the Platin Works and BAT for the Cement Industry Emission/Consumption Level BAT 1 Response at Platin Works Point Emission Particulate Emissions Fugitive Particulate Emissions NO X Particulate emissions from Kiln 2, Cement Mill 1, Kiln 2 Grate Cooler and Kiln 3 Grate Cooler are abated by electrostatic precipitators. Bag filters are installed on Coal Mill 2, Cement Mill 2 and 3 and Kiln 3, Kiln 3 Bypass, Coal Mill 3, Cement Mill 4. Fugitive dust is minimised by enclosing conveyors and spraying unpaved roads where possible. Dust management procedures are rigorously enforced and regularly reviewed as part of the Environmental Management Plan. Kiln 3 in-line calciner is designed to deliver optimal heat economy, power consumption and NO X reduction. Kiln 2 has burner pipes designed for optimal combustion to assist NO X reduction. Selective non-catalytic reduction (SNCR) systems are installed on Kilns 2 and 3. SO X SO 2 is absorbed onto alkaline materials in Kiln 2 and Kiln 3, therefore a dedicated SO X abatement technique is not required at Platin Works. SO X emissions were below the level of detection in 2008 and therefore comply with the BAT emission limit value. Energy Consumption Process Materials Kiln 3 in-line calciner is designed to deliver optimal heat economy and power consumption. Electricity consumption is also minimised on the Kiln 3 line through the use of an energy efficient vertical raw mill and a vertical coal mill. The preheater of the kiln system is a counter current, cyclone based heat exchanger where heat is recovered from exhaust gases to heat the kiln feed. Solid fuel use is minimised as the raw mills operate in the exhaust system of the kilns, thereby using available excess low grade heat for drying. Collected spillage sweepings are recycled with the raw materials or directly into the process. Kiln coating may be removed from the kiln during maintenance repairs and transferred to the quarry for subsequent reuse with the raw materials in the production process. By-pass and filter dusts generated are recycled in the process. 1 BAT according to the European Commission Integrated Pollution and Prevention Control Reference Document on Best Available Techniques in the Cement and Lime Manufacturing Industries (2001) I - 21 of 34 EPA Export :16:18:59

22 b. no significant pollution is caused; ICL Platin currently operates within the limits imposed by its IPPC Licence Reg. No. P IPPC limits are set by the Agency in order to prevent significant pollution as a result of industrial activities. Any exceedance of these limits is immediately investigated by ICL Platin and reported to the Agency. The results of all on-site monitoring and any exceedances of the limits are also reported in the Annual Environmental Report. An assessment of the impact on atmospheric emissions, surface water discharges, sewer discharge, groundwater emissions, waste and noise is provided in Sections I.1 to I.7 above. The proposal to use alternative fuels in the Kiln 3 system is assessed in these sections. c. waste production is avoided in accordance with Council Directive 75/442/EEC of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment; ICL Platin follows strict waste management guidelines as set out by the Agency and in accordance with Council Directive 75/442/EEC. No solid waste is produced by the cement production process. By-products from production are continually reintroduced into the process. The current alternative fuels proposal will not result in additional waste generation. The cement production process efficiently recovers the energy content of the alternative fuels and the mineral components of the alternative fuels are incorporated into the clinker. A detailed description including the source, quantity and ultimate destination of the wastes generated at the ICL site is provided in Attachment No. H. ICL Platin endeavours to recover and recycle waste where possible. Where this is not feasible, disposal of waste is conducted using licensed waste hauliers and licensed waste facilities in order to minimise any environmental impact. An assessment of the impact of on-site waste disposal is provided in Section I.6. d. energy is used efficiently; The ICL Environmental Policy requires all its facilities to optimise the use of energy and material resources. ICL Platin operates under IPPC Licence Reg. No. P The primary aim of IPPC licensing is to prevent or reduce emissions to air, water and land, to reduce waste and to use energy efficiently. ICL Platin achieves this by using the most advanced, energyefficient methods to create a range of high quality cements as well as operating under an established Environmental Management System (EMS). ICL Platin's EMS is accredited to international standard ISO14001, which strives to achieve continuous improvement in many environmental aspects, including energy use. An Environmental Management Plan (EMP) is agreed annually and provided to the Agency in the AER. The EMP sets targets and objectives for the year ahead and aims to achieve continuous improvement of the Environmental Management System, some examples (2009/2010) include, Continue commissioning and optimisation of Kiln 3, Raw Mill 3, Coal Mill 3 and Cement Mill 4 in 2009 Complete installation and commissioning of new equipment for production of CEM II cements with a reduced clinker content and thus reduced associated CO 2 emissions Develop a project to use alternative fuels in Kiln 3 to reduce dependence on imported fossil fuels and reduce CO 2 emissions I - 22 of 34 EPA Export :16:18:59

23 Develop new environmental monitoring reports on the new PCS27 Management Information System Continue to target increases in waste minimisation and so reduce waste disposal to landfill. Since IPPC Licence P was granted, ICL Platin has entered the Sustainable Energy Ireland (SEI) Energy Agreements Programme. This programme has been developed under the new Irish Energy Management Standard, IS 393 and provides companies with a structured approach to reducing energy costs through the implementation of a schedule of energy efficient measures. IS393 is shortly to be replaced by an updated European Energy Standard EN161001, Irish Cement is working towards accreditation to this new standard. e. the necessary measures are taken to prevent accidents and limit their consequences; A copy of ICL s Platin Works Emergency Response Procedure (Issue No. 3) is included in this Attachment. This document outlines the accident prevention and emergency response procedures in place at Platin in the event of a fire, a spill of flammable or environmentally harmful material, or any other major industrial accident. Emergency response training in the following procedures is also provided to all ICL employees: Excavation routes Alarm systems Reporting to supervisors Personal protective equipment Full details of the emergency response procedures at the Platin Works is provided in Attachment No. J. A Fire-water Risk Assessment Report has been prepared by Arup Consulting Engineers to take account of the proposed introduction of alternative fuels on-site. This is included in Attachment No. J. In accordance with the recommendations of this Report, it is proposed to provide a remote underground fire-water retention tank in order to retain any fire-water runoff from the alternative fuels storage facilities. In the unlikely event of a fire on-site, any such run-off would be retained in the tank, tested and discharged or in the event that it can not be discharged it will be disposed of off-site in agreement with the Agency. f. the necessary measures are taken upon definitive cessation of activities to avoid any pollution risk and return the site of operation to a satisfactory state. ICL intends to operate at the Platin site for the foreseeable future. However, in the event of definitive cessation of activities at the site, ICL Platin will ensure that appropriate measures are taken to avoid any pollution risk and return the site to a satisfactory state. A Closure, Restoration and Aftercare Management Plan (CRAMP) has been prepared for the facility. This document is included in this Attachment. The CRAMP and costs associated with its implementation will be reviewed annually. The document will be amended if necessary. Protection of the Environment Act 2003 Determination of BAT Section 7 of the Protection of the Environment Act 2003 lists the considerations to be taken into account when determining BAT. Each of these considerations is discussed below. I - 23 of 34 EPA Export :16:18:59

24 (i) the use of low-waste technology, The cement manufacturing process at the Platin Works generates very little waste. Limestone is extracted from the quarry and used directly for the production of raw meal. The use of overburden as a raw material is maximised and unused overburden is deposited on-site. The packaging plant operates under a highly automated control system in order to minimise potential waste. The entire operation at ICL Platin is controlled by a PLC based control system which monitors the process using a comprehensive array of analogue instruments and switches. (ii) the use of less hazardous substances, The hazardous materials at Platin are predominantly those used in the laboratories or in the maintenance workshop. These materials are used in relatively small quantities and are stored in secured areas only. Liquid fuels are stored in specific bunded areas as described in Attachment No. H. (iii) the furthering of recovery and recycling of substances generated and used in the process and of waste, where appropriate, Waste metals, paper, packaging material, batteries, fluorescent tubes and waste electrical and electronic equipment (WEEE) are all sent for recycling by ICL. In addition, process material spillages, kiln coating and by-pass dust are all recovered and recycled back into the process. The ultimate destination of each of the raw materials, intermediates and finished products generated and used at ICL Platin are provided in Tables G.1 (i) and G.1 (ii). (iv) comparable processes, facilities or methods of operation, which have been tried with success on an industrial scale, SNCR technology has being introduced to reduce NO X emissions. Limestone cements are being introduced to reduce energy use, optimise raw material usage and reduce CO 2 emissions (refer to Table I.8). In this application, permission is being requested to use Alternative Fuels, which have been tried and tested with success on an industrial scale throughout Europe. (v) technological advances and changes in scientific knowledge and understanding, The use of Best Available Techniques according to the European Commission reference document on BAT in the cement industry are discussed in Table I.8. (vi) the nature, effects and volume of the emissions concerned, The main emissions from the cement manufacturing process are emissions to atmosphere from combustion gases and emissions to water from the factory and quarry. The impact of these emissions is assessed in Section I.1 and I.2 above. The volumes of these emissions are currently regulated according to the existing IPPC Licence so that potential impacts on human health and the environment are minimised. (vii) the commissioning dates for new or existing activities, Commissioning of Kiln 3 commenced in late Kiln 1 was decommissioned in October Cement Mill 4 commissioning commenced in autumn (viii) the length of time needed to introduce the best available techniques, A number of best available techniques are already employed at ICL Platin (refer to Table I.8). (ix) the consumption and nature of raw materials (including water) used in the process and their energy efficiency, The principal raw material used in the cement making process is limestone. This is extracted directly from ICL Platin s quarry. Shale is also used to produce raw meal and is sourced from I - 24 of 34 EPA Export :16:18:59

25 external quarries. Clay overburden which substitutes for shale is sourced from the limestone quarry. Groundwater is pumped from the quarry to provide cooling water to the factory and keep the quarry void dry to allow for safe working. Energy efficiency at ICL Platin is described in Section d. above. (x) the need to prevent or reduce to a minimum the overall impact of the emissions on the environment and the risks to it, The risk to the environment posed by the facility is assessed in the Environmental Liability Risk Assessment. This document is provided in Attachment No. J. The impact of the emissions on the environment and the risk to the environment is low given the low quantity of hazardous substances used and generated and the environmental properties of these substances. The main emissions will be to air from combustion gases and have no significant impact on the environment. Platin operates in compliance with IPPC licence P This Application for Review is seeking permission to use specified alternative fuels to replace a proportion of the fossil fuels currently used in the production of clinker, This replacement of fuel type will not result in any significant negative impact of emissions to the environment. (xi) the need to prevent accidents and to minimise the consequences for the environment, and All operations and activities are carried out in accordance with the relevant ICL Platin procedures, which are designed to minimise accidents. The main accident scenarios that could occur at the site are fires, explosions and spills of harmful material. ICL Platin has developed the Platin Works Emergency Response Procedure (Issue No. 3) which sets out the responses to such events. A Fire-water Risk Assessment Report has been prepared by Arup Consulting Engineers to take account of the proposed introduction of alternative fuels on-site. In accordance with the recommendations of this report, it is proposed to provide a remote underground fire-water retention tank in order to retain any fire-water run-off from the alternative fuels storage facilities. In the unlikely event of a fire on-site, any such run-off would be retained in the tank, tested and discharged or, in the event that it cannot be discharged, it would be disposed of off-site in agreement with the Agency. Full details of the emergency response procedures at the Platin Works and the Fire-water Risk Assessment Report are provided in Attachment No. J. (xii) the information published by the Commission of the European Communities pursuant to any exchange of information between Member States and the industries concerned on best available techniques, associated monitoring, and developments in them, or by international organisations The activities carried out at ICL Platin are discussed with reference to the European Commission BREF document for the cement industry above. EPA BAT Guidance Note The EPA s BAT Guidance Note for the Production of Cement and Lime in a Kiln contains extensive reference to the BREF Note on the Cement and Lime Manufacturing Industries. BAT, as described in Table A.6, which references this BREF Note is therefore applicable in I - 25 of 34 EPA Export :16:18:59

26 the context of the EPA s Guidance Note. Additional techniques relevant to the activities at Irish Cement Limited as mentioned in the EPA s BAT Guidance Note are discussed below. BAT for the production of cement clinker is considered to be a dry process kiln with multistage preheating and precalcination. Irish Cement Limited Platin currently operates two dry kiln systems. A four stage system is installed for Kiln 2. Complete calcination and clinker formation occurs in the kiln process. The Kiln 3 preheater is a five stage cyclone preheater. Kiln 3 and associated equipment are being commissioned. Kiln 1 was decommissioned in October Kiln 3 commissioning commenced in December General primary optimisation measures which are considered BAT such as optimised cooler connections, consistency of raw mix and consistency of grind for solid fuels as listed in the EPA s Guidance are also employed at the Irish Cement Limited Platin site. Heat recovery from waste gases is also considered BAT according to the EPA s guidance. Irish Cement Limited Platin achieves this on-site by using the exhaust gases from all kilns to dry raw materials. Irish Cement Limited Platin has also recently developed a project to recover waste heat from Kiln 2 grate cooler for use in the cement mills. Careful selection and control of substances entering the kilns is achieved at Irish Cement Limited Platin by weighing and controlling the flow of raw meal on extraction from the feed hoppers before pneumatic transport into the kiln system. The proportions of mixing are controlled by chemical analysis. ICL Platin has made significant investment in BAT based technology in recent years. Notable examples are: Extension of Kiln 2 electrostatic precipitator Complete replacement of Coal Mill 2 electrostatic precipitator with a bag filter Installation of high efficiency separators on all cement mills Installation of SNCR technology on Kiln 2 Development of techniques to maximise the use of overburden and so reduce the amount of quarried shale for use in the process represents BAT. I - 26 of 34 EPA Export :16:18:59

27 I.9. References 1. Cembureau (2009) Sustainable Cement Production Co-processing of Alternative Fuels and Raw Materials in the European Cement Industry 2. Sidhu S., Kasti N., Edwards P. and Dellinger B. Hazardous air pollutants formation from reactions of raw meal organics in cement kilns. Chemosphere, 42, , Sustainable Cement Production Co-processing of Alternative Fuels and Raw Materials in the European Cement Industry, Cembureau, UK EA (2005) Conversion ratios for NOx and NO2, viewed 4.xii Sustainable Cement Production Co-processing of Alternative Fuels and raw Materials in the European Cement Industry, Cembureau, 2009 I - 27 of 34 EPA Export :16:18:59

28 IPPC Licence Application Tables I.2(i) I.4(i) I.4(ii) I.7(i) I - 28 of 34 EPA Export :16:19:00

29 Table I.2(i) SURFACE WATER QUALITY (Sheet 1 of 2) Monitoring Point/ Grid Reference: SW4 (combined treated effluent from SW1 and SW3 and quarry groundwater)_ Parameter Date Sept 2008 Date Oct 2008 Results (mg/l) Date Nov 2008 Date Dec 2008 Sampling method 2 (grab, drift etc.) Normal Analytical Range 2 Analysis method / technique ph Grab Sample Electrometry Temperature Electrical conductivity EC Ammoniacal nitrogen NH 4 - N Chemical oxygen demand Biochemical oxygen demand Dissolved oxygen DO Calcium Ca Cadmium Cd Chromium Cr Chloride Cl Copper Cu Mar Iron Fe Lead Pb Mar Magnesium Mg Manganese Mn Mercury Hg <2 <2 <2 <2 Grab Sample Electrometry Oct Oct Grab Sample ICPMS Grab Sample ICPMS I - 29 of 34 EPA Export :16:19:00

30 Surface water Quality (Sheet 2 of 2) Parameter Results (mg/l) Date Mar 2008 Date Oct 2008 Sampling method (grab, drift etc.) Normal Analytical Range Nickel Ni Potassium K Sodium Na Sulphate SO 4 Zinc Zn 0 0 Grab Sample ICPMS Total alkalinity (as CaCO 3 ) Total organic carbon TOC Total oxidised nitrogen TON Nitrite NO 2 Nitrate NO 3 Faecal coliforms (/100mls) Total coliforms ( /100mls) Phosphate PO 4 Analysis method / technique I - 30 of 34 EPA Export :16:19:00

31 Table I.4(i) GROUNDWATER QUALITY (Sheet 1 of 2) Monitoring Point/ Grid Reference: Parameter ph Temperature Electrical conductivity EC Ammoniacal nitrogen NH 4 - No Date Half Date Half Results (mg/l) Date Half Date Half Sampling method (composite etc.) Normal Analytical Range Analysis method / technique <0.09 <0.09 <0.09 <0.06 Discrete Colorimetry Dissolved oxygen DO Residue on evaporation (180 o C) Calcium Ca Discrete Cadmium Cd < < < <0.09 Discrete ICPMS Chromium Cr Discrete ICPMS Chloride Cl Discrete Spectrometry Copper Cu Discrete ICPMS Cyanide Cn, total Iron Fe <3.7 Discrete ICPMS Lead Pb <0.38 Discrete ICPMS Magnesium Mg Discrete ICPMS Manganese Mn Discrete ICPMS Mercury Hg < < Discrete ICPMS Nickel Ni < Discrete ICPMS Potassium K Discrete ICPMS Sodium Na Discrete ICPMS I - 31 of 34 EPA Export :16:19:00

32 GROUNDWATER QUALITY (SHEET 2 OF 2) Parameter Results (mg/l) Sampling method (composite, dipper etc.) Normal Analytical Range Analysis method / technique Date Half Date Half Date Half Date Half Phosphate PO Discrete Digestion/Colorimetry Sulphate SO Discrete Colorimetry Zinc Zn < Discrete ICPMS 46 Total alkalinity (as CaCO 3 ) Total organic carbon TOC Total oxidised nitrogen TON Arsenic As Discrete ICPMS Barium Ba Discrete ICPMS Boron B Discrete Fluoride F Phenol Phosphorus P Discrete Selenium Se Silver Ag Nitrite NO 2 <0.003 Nitrate NO Discrete Colorimetry Faecal coliforms ( /100mls) Total coliforms ( /100mls) Water level (m OD) I - 32 of 34 EPA Export :16:19:00

33 TABLE I.4(ii): LIST OF OWNERS/FARMERS OF LAND Not Applicable Land Owner Townlands where landspreading Map Reference Fertiliser P requirement for each farm *NMP must take account of on-farm slurry Total P requirement of the client List TABLE I.4(ii): LANDSPREADING Land Owner/Farmer Not Applicable Map Reference Field ID Total Area (ha) (a) Usable Area (ha) Soil P Test Mg/l Date of P test Crop P Required (kg P/ha) Volume of On-Farm Slurry Returned (m 3 /ha) Estimated P in On-Farm Slurry (kg P/ha) (b) Volume to be Applied (m 3 /ha) P Applied (kg P/ha) Total Volume of imported slurry per plot (m 3 ) Total volume that can be imported on to the farm: Concentration of P in landspread material - kg P/m 3 Concentration of N in landspread material - kg N/m 3 I - 33 of 34 EPA Export :16:19:00

34 N19 N6 N13 N12 N8 N11 N10 N7 N5 N2 N3 N4 N9 N15 N16 N14 N18 N17 N1 0 metres 60 Scale 1:1,500 Ordnance Survey Ireland Licence Number EN c Government of Ireland Noise Sources Irish Cement Ltd Review of IPPC Licence Reg. No. P D Figure I.4 EPA Export :16:19:00