APPENDIX V. Response to Meath County Council s Request for Further Information on the Environmental Impact Statement for Platin Cement Works Extension

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1 APPENDIX V Response to Meath County Council s Request for Further Information on the Environmental Impact Statement for Platin Cement Works Extension For inspection purposes only. 19

2 Response to Request for Further Information: from Meath County Council On 19 th January 2006 Irish Cement Ltd. Planning Application (Reg. Ref: SA50448) for: Planning permission to extend the existing Platin Cement Works, Platin, Co. Meath, by provision of a limestone store, transport conveyors and transfer station, raw mill building, raw materials store, preheater tower and stack, kiln and filter, grate cooler and filter, coal mill building, clinker storage silo and cement mill building. The proposed location for the new kiln line, which will replace an existing kiln, which will be decommissioned, requires the demolition of an existing building that accommodates factory offices, stores and maintenance workshops. As part of this development, a replacement factory office and separate new workshop / stores building and car parking spaces will be constructed on site. Demolition of a redundant boiler house and oil storage tank will be carried out as part of the proposed development. The development will also include miscellaneous buildings, structures and services and will include site works and reconfiguration of the internal road network. For inspection purposes only. March 2006

3 March 2006 Platin Cement Works Extension Irish Cement Ltd. TABLE OF CONTENTS Item 1a Response 4679L301 Brú Na Boinne World Heritage Site Location 4679L302 Site plan of proposed and alternative locations of Preheater Tower B9378-A-503 Alternative 1 - South Elevation B9378-A-504 Alternative 1 - East & West Elevations B9378-A-505 B9378-A-506 B9378-A-501 B9378-A-502 Alternative 2 - South Elevation Alternative 2 - East & West Elevations Alternative 3 - South Elevation Alternative 3 - East & West Elevations B9378-A-516 Alternative 4 - South Elevation (as planning application drg A-023) B9378-A-517 Alternative 4 - East & West Elevations (as planning application drg A-204) B9378-A-514 B9378-A-515 B9378-A-518 B9378-A-519 Alternative 5 - South Elevation Alternative 5 - East & West Elevations Alternative 6 - South Elevation Alternative 6 - East & West Elevations Item 1b Item 1c Item 1d Item 1e Item 1f Item 1g Item 1h Item 1i Item 1j Item 2 Versions of Photomontage 7 (from Newgrange): View of Alternative 1 View of Alternative 2 View of Alternative 3 View of Alternative 4 - As proposed View of Alternative 5 View of Alternative 6 Comparison View of Alternatives 1, 2, 3 & 4 Comparison View of Alternatives 4, 5 & 6 Response Response Response Response Drawing 4679L303 Drawing 4679L304 Response Response Figure 5.1 Site Context Response Response Response Response For inspection purposes only. Reg Ref: SA50448 Page 1

4 March 2006 Platin Cement Works Extension Irish Cement Ltd. PREAMBLE The following response to the Meath County Council request for additional information has been prepared on behalf of Irish Cement Ltd, by the following contributors: Don Menzies Arup Menzies Air Quality Assessment Sinead Whyte Arup Menzies Air Quality Assessment Dr. Charles Mount Archaeologist Archaeological Assessment Thomas Burns Brady Shipman Martin Landscape & Visual Assessment John Kelly Brady Shipman Martin Photomontages Tom Bolger E.G Pettit & Company Plant Design Ivor Rees Irish Cement Ltd. Plant Design Colm Bannon Irish Cement Ltd. Coordination of response Dearbhla Walshe Brady Shipman Martin Coordination of response For inspection purposes only. Reg Ref: SA50448 Page 2

5 March 2006 Platin Cement Works Extension Irish Cement Ltd. The Planning Authority considers that the planning application and accompanying Environmental Impact Statement are lacking in a number of regards. You are requested to address the following: Item 1a The 2002 Environmental Protection Agency Guidelines on Environmental Impact Statements states that the presentation and consideration of the various alternatives investigated by the applicant is an important requirement of the Environmental Impact Assessment process. The Planning Authority notes that no proper presentation and consideration of various alternatives investigated by the applicant has been provided for in the Environmental Impact Statement (EIS). Whilst the Planning Authority accepts that the proposed preheater tower and stack needs to be provided within the confines of the applicants landholding, the Authority considers that it has not been demonstrated in the EIS what alternative locations within the site were considered in order to minimise/ obliterate the visual impact of the preheater tower and stack from Brú Na Boinne World Heritage Site and, in particular, Newgrange. Furthermore, the Planning Authority notes that it has not been demonstrated why the said structures need to be c.20 meters higher than the existing stacks on site. You are requested to address the above. Having regard to the landscape sensitivity of the area, the Planning Authority must stress the importance of minimising/obliterating the visual impact of the proposed development from the World Heritage Site. General Comments Platin Cement Works is the largest cement producing facility in the country and is a major contributor to the Irish economy and a significant source of employment. The cement works is a highly functional, managed operation representing a major investment in terms of employment, infrastructure, operation and management. Platin Cement Works comprises a complex of existing structures, buildings and infrastructure including kilns, two tall stacks, various silos and buildings such as a limestone store, offices, etc. In addition, the cement works has various entrances and access routes and includes a significant section of the rail-line (freight only) from Drogheda to Navan. Platin Cement Works is sited within the general rural and agricultural landscape of County Meath, i.e. Area of Visual Quality 11 as designated within the Meath County Development Plan - an area of overall low landscape sensitivity. The River Boyne and its high amenity landscape, which includes the Brú na Boinne World Heritage site and the principal sites of Newgrange, Dowth and Knowth, all lie at some distance to the west/northwest of the Works. Within this context the site of the proposed development is approximately 3.5 km from the nearest point of the World Heritage Site and indeed is 1.5km from the nearest point of the buffer zone which surrounds the World Heritage Site. See Figure 4679L301. For inspection purposes only. The landscape is broadly undulating and includes prominent ridges such as Bellewstown and Red Mountain together with enclosed valleys, the most significant of which is associated with the River Boyne. The landscape is pastoral and comprises typically rural tree-lined hedgerows and dispersed copses or small plantations of deciduous and mixed woodlands. Platin Cement Works is a significant visual reference within this landscape mosaic openly visible and dominant within a wide landscape especially east, southeast and south of the facility. The facility is significantly less dominant in views from the north and from west of Red Mountain. Where visible from the west, Platin Cement Works forms a prominent element within generally expansive panoramic views of the general landscape. Within this context the facility is more visually open from upper valley areas to the north of the World Heritage Site including Knowth and Dowth. Further south along the upper valley, including from Newgrange, it is increasingly only the upper aspects of the two stacks which appear above the intervening ridge of Red Mountain. However, there is little or no view of the facility from lower within the valley landscape and there is no view from the immediate river setting or from the site of the Brú na Boinne Visitors Centre. Reg Ref: SA50448 Page 3

6 March 2006 Platin Cement Works Extension Irish Cement Ltd. During preparation of the EIS that accompanied the planning application in November 2005, photomontages were prepared from 10 locations surrounding the cement works including from the listed view and prospect from Bellewstown Ridge. Three of the views (Views 7, 8 and 9) are from within the Brú na Boinne site at the principal monuments of Newgrange, Dowth and Knowth. These sites were selected for many reasons as they are; located at high elevations within WHS; are the principal monuments within the WHS; are readily recognisable features and are the sites of greatest viewer potential. As previously noted the Brú na Boinne visitor centre and the river itself are set low in the valley and have no views of either the existing or proposed works. For these reasons the selected photomontage locations are deemed appropriate as they present the greatest potential for visual impact from within the WHS and the greatest potential for viewing by the general public from within the WHS. Alternatives General Technology and Licencing Considerations Platin Cement Works operates under licence granted by the Environmental Protection Agency (EPA). The operation of the proposed plant will require renewal of Irish Cement Ltd s IPPC licence under the EU Integrated Pollution Prevention and Control (IPPC) Directive. This licence will ensure that the Platin Cement Works operates to standards of Best Available Technology (BAT) to minimise emissions of NO x, SO x and Particulates and to maximise energy efficiency, thus reducing CO 2 emissions. In this regard, the EU has published a Reference Document that outlines BAT for the cement industry. To meet BAT requirements for NOx emissions, to maximise thermal efficiency and to minimise CO 2 emissions the proposed new line at Platin will be required to include an additional fifth cyclone stage (the existing kiln 2, built in the late 1970 s, has four cyclone stages). It is also required to install an In- Line Calciner at the base of the Preheater Tower to minimise NOx emissions. All of these requirements in combination with the physical arrangement and dimensions of plant components dictate the height of the proposed Preheater Tower. In addition the height of the chimney is dictated by the requirement for it to clear the Preheater Tower so as to ensure dispersion is not adversely affected by items of plant. The arrangement as proposed for the Preheater Tower represents the only solution which will enable the proposed new kiln line at Platin Cement Works to fully comply with the EU IPPC Directive and with BAT requirements for new cement plants. Therefore, with the overall height of the tower dictated by other requirements, it is within the operational and landscape and visual context that alternatives for the proposed development were considered. Such alternatives were considered initially at the pre-application stage prior to submission for planning permission. The issue of alternatives was again reviewed in light of the subject request for additional information. For inspection purposes only. Alternatives Considered - Pre-application Stage An Alternatives Study was undertaken at the beginning of the design stage for the project. This focused on three aspects, namely operational/site constraints, landscape and visual constraints and IPPC Directive & BAT requirements. As previously noted, the composition and height of the proposed tower has been dictated by the requirements of BAT and the Directive in seeking to minimise NOx and CO2 emissions and in maximising energy efficiency. In addition for reasons of good design, minimising visual impact and in avoiding unnecessary cost, the tower was designed to be at the lowest elevation required for the operation of the facility within the demands of BAT and the IPPC Directive. Given that the proposed development must conform to BAT and the IPPC Directive, a series of alternative locations for the tower were assessed based on operational efficiency and visual considerations. A total of 4 alternative locations were considered during the pre-application design stage review. The plan location of the four alternatives is shown on Drawing 4679L302. Elevations of the four alternatives are also provided on Drawings B9378-A-501 to B9378-A-506, B9378-A-516 and B9378-A-517. Reg Ref: SA50448 Page 4

7 March 2006 Platin Cement Works Extension Irish Cement Ltd. Alternative 1 - Build over the existing Kiln 1 Line (See Drawings B9378-A-503 & B9378-A-504) From an operational and cost efficiency point of view the preferred location for the tower would be on the line of the existing Kiln 1. This entails replacement of part of an existing overall production line, thereby reducing additional conveyor runs and associated operating costs. Visually this would retain a compact arrangement of tall structures on the site. However, the tower would be located at a relatively high elevation within the site and the top of the tower would be at an elevation of m above ordnance datum (AOD Malin Head). In a visual assessment of Alternative 1 it is clear that the tower sits close to the existing stacks presenting a compact arrangement of tall structures. However, its elevated setting means that it also rises to almost 25m higher than that of the existing tallest structure - stack 2 (which is at m AOD). From the Brú na Boinne sites of Dowth and Knowth the existing facility (see EIS Photomontages 8 & 9 as existing views) is openly visible as a prominent element on a small section of the skyline within an otherwise expansive panoramic view. It is clear that almost all of the proposed development would be similarly visible slightly to the left of the existing plant and the proposed structure would increase the visual bulk and height of development at Platin as viewed from these locations. From Newgrange only the upper sections of the two existing stacks (see EIS Photomontage 7 as existing view) are visible from this heritage site. The significant remainder of existing plant is screened by the intervening ridge of Red Mountain. By contrast and despite being in-line with existing stack 1, the proposed development would increase the visual presence and prominence of the Platin Works as viewed from Newgrange. By virtue of its increased elevation, up to 47m of the proposed tower (including 22m of the top of the bulky tower structure) would be visible above the ridge of Red Mountain. The visual nature of this alternative is illustrated in RFI Photomontage 7 Alternative 1. Alternative 2 - Up-grade the existing Kiln 2 Line (See Drawings B9378-A-505 & B9378-A-506) In seeking to retain a compact arrangement an alternative which would see the proposed tower located on the line of existing Kiln 2 was also considered. However, in sitting on top of the existing kiln the proposed tower would require to be set at a higher elevation placing the top of the proposed fluestack at an elevation of m AOD. For inspection purposes only. This option would be less energy efficient than the as proposed (Alternative 4 below) solution and would not represent Best Available Technology (BAT) within the cement industry. The alternative would also entail long production outage during construction and commissioning. In a visual assessment of Alternative 2 it is clear that the tower sits close to the existing stacks presenting a compact arrangement of tall structures. However, its elevated siting means that it also rises to over 26.5m higher than that of the existing tallest element - stack 2 (153.37m AOD). From the Brú na Boinne sites of Dowth and Knowth the existing facility (see EIS Photomontages 8 & 9 as existing views) is openly visible as a prominent element on a small section of the skyline within an otherwise expansive panoramic view. Almost all of the proposed development would be visible slightly to the left of the existing stacks and the structure would increase the visual bulk and height of development at Platin as viewed from these locations. From Newgrange only the upper sections of the two existing stacks (see EIS Photomontage 7 as existing view) are visible from this heritage site. The significant remainder of existing plant is screened by the intervening ridge of Red Mountain. Alternative 2, with its increased elevation, would have the top 49m of the proposed tower, including 24m of the top of the bulky tower structure, clearly visible above the ridgeline. Again this would increase the visual presence and prominence of the development as viewed from Newgrange. The visual nature of this alternative is illustrated in RFI Photomontage 7 Alternative 2. Reg Ref: SA50448 Page 5

8 March 2006 Platin Cement Works Extension Irish Cement Ltd. Alternative 3 - Build at a location north of the existing Kiln 2 Line See Drawings B9378-A-501 & B9378-A-502 In considering off-line arrangements Alternative 3 was located to the north of the existing kilns. However, ground level rises northwards through the cement works and therefore the development would be sited on higher ground and would appear visually higher than if sited in locations further south. In effect, despite an off-line location, the top of the proposed flue-stack would be at an elevation of m AOD. The building would also be close to the site boundary and would give rise to significant site access difficulties. Some maintenance procedures would likely require road closures. It would not represent BAT in terms of the siting of a kiln line within a modern cement works. In a visual assessment of Alternative 3 the tower would lie furthest from the existing stacks and particularly in east-west viewing as from Brú na Boinne, would significantly increase the visual expanse of skyline development. In addition its elevated siting means that it also rises to almost 25m higher than that of the existing tallest element - stack 2 (153.37m AOD). From the Brú na Boinne sites of Dowth and Knowth the existing facility (see EIS Photomontages 8 & 9 as existing views) is openly visible as a prominent element on a small section of the skyline within an expansive panoramic view. Almost all of the proposed development would be visible entirely to the left of the existing stacks and the structure would appreciably increase the visual bulk and height of development at Platin as viewed from these locations. From Newgrange only the upper sections of the two existing stacks (see EIS Photomontage 7 as existing view) are visible from this heritage site. The significant remainder of existing plant is screened by the intervening ridge of Red Mountain. Alternative 3, with its increased elevation and more northerly location, would have the top 55m of the proposed tower (including 30m of the top of the bulky tower structure), clearly visible above the ridgeline. This would undoubtedly increase the visual presence and prominence of the development as viewed from Newgrange. The visual nature of this alternative is illustrated in RFI Photomontage 7 Alternative 3. Alternative 4 As Proposed A location to the south of the existing Kiln lines See Drawings B9378-A-516 & B9378-A-517 For inspection purposes only. Following a review of the above it was clear that moving the proposed development to the south would be preferable in both setting the tower on lower ground elevation due to falling topography and in locating the proposed development more effectively behind the ridge of Red Mountain as viewed from Newgrange. A fourth location was therefore selected, set as far south as possible within the confines and constraints of the existing built development and infrastructure at Platin Cement Works. Moving further south was prohibited by the presence of the existing limestone store (a significant building in its own right), and the railway. The selected location would already require demolition and re-siting of existing assets with replacement costs of the order of 15m. In selecting this lower level location the proposed development has a lower base elevation and thus the top of the proposed flue-stack would be at an elevation of m AOD some 8 to 9m lower than for Alternatives 1, 2 and 3 above. In addition the tower would remain sufficiently close to the existing stacks so as to retain a relatively compact view of tall structures. In a visual assessment of Alternative 4, the tower would lie close to the existing stacks and at significantly lower elevation than within Alternatives 1, 2 and 3. In effect its lower siting means that the tower rises to just over 16m higher than that of the existing tallest element - stack 2 (153.37m AOD). From the Brú na Boinne sites of Dowth and Knowth the existing facility (see EIS Photomontages 8 & 9 as existing views) is openly visible as a prominent element on a small section of the skyline within an otherwise expansive panoramic view. Almost all of the proposed development would be visible Reg Ref: SA50448 Page 6

9 March 2006 Platin Cement Works Extension Irish Cement Ltd. slightly to the right of the existing stacks though being lower in elevation has marginally less impact on the skyline than Alternatives 1, 2 and 3. From Newgrange only the upper sections of the two existing stacks (see EIS Photomontage 7 as existing view) are visible from this heritage site. The significant remainder of existing plant is screened by the intervening ridge of Red Mountain. Alternative 4, with its lower elevation and, significantly, its more southerly siting, is substantially set behind the ridge of Red Mountain. Only the top 30m of the proposed tower (including only 5m of the top of the bulky tower structure) would be visible above the ridgeline. While this adds to the visual presence of the development as viewed from Newgrange, the overall change in this expansive and panoramic view, where existing structures at Platin are already visible, is slight. The visual nature of this alternative is illustrated in RFI Photomontage 7 Alternative 4 (also EIS Photomontage 7 as proposed ). This is the alternative that was selected and submitted for planning permission in November Summary On the basis of the pre-application Alternatives Study the findings concluded that Alternative 4 was the preferred location for the proposed development. The conclusion took account of its lower site elevation and proximity to existing stacks which retain an overall compact arrangement of tall structures whilst minimising additional visual impact from the surrounding landscape. In particular Alternative 4 was significantly more advantageous in minimising additional visual impact from the Brú na Boinne site of Newgrange, as the development is substantially screened by the ridge of Red Mountain. Alternative 4 as described above was incorporated into the overall development and formed the basis of the submission for planning permission (lodged in November 2005). Alternatives Considered Request for Further Information Stage On receipt of the subject request for further information (RFI) and following a meeting with Meath County Council (17 th February 2006) a further review of alternative locations was undertaken. However, as expressed above potential locations for this essential infrastructure is limited by many constraints including BAT, operational and visual considerations. In this regard, the site as selected is the most preferable location for such development on this site. For inspection purposes only. Given that expressed concern was noted in relation to impact on views from Brú na Boinne and Newgrange in particular, specific attention was again taken of this sensitive site. In addition to reviewing site locations, a complete review of the tower structure was also undertaken. This review highlighted a potential to reduce the height of the overall tower by up to 2m. On this basis 2 further alternative arrangements are now considered; Alternative 5, a location to the west of the as proposed (Alternative 4) location and Alternative 6, incorporating the reduced overall height at the existing as proposed location. In considering alternative site locations it should be noted that the development as proposed is an integral part of the cement works and this, together with the requirements arising from the physical operation of the Platin complex, means it is not possible to site the proposed plant outside the curtilage of the existing cement works area. It is acknowledged that in the absence of other site constraints, a more southerly location would result in slightly less of the tower visible from Newgrange. This would arise as a result of benefiting from lower ground levels and increased screening from the ridge on Red Mountain as viewed from Newgrange. However, more southerly locations are not available for consideration due to the presence of existing buildings and structures including the significant limestone store building and the railway line. In any case, the benefit gained from a lower site elevation and better screening from Red Mountain within any more southerly location, would still not fully remove views of the proposed tower, which Reg Ref: SA50448 Page 7

10 March 2006 Platin Cement Works Extension Irish Cement Ltd. would always appear to a greater or lesser degree above the ridge. Importantly, as can be appreciated from any of the Photomontage views from Newgrange, the ridge of Red Mountain shallows-off to the right of Platin Cement Works (as seen in the views) and provides decreasing benefit in potential for screening development. Furthermore, selecting locations further south will increase the potential for adverse visual impact from properties further south of Platin and most especially in views from the east, including from Bellewstown Ridge (a listed View and Prospect). As the location for the development moves south, the new tower will increasingly expand the overall bulk and scale of tall development on the site with a corresponding increase in adverse visual impact. The following describes the 2 additional Alternatives considered at the RFI stage. Alternative 5 A location to the west of the As Proposed location (Alternative 4 above) (See Drawings B9378-A-514 & B9378-A-515) A location further west was considered as having potential for reduced visual impact as viewed from Newgrange. Following a review of site, an alternative potential location was identified some 20m west of the existing as submitted (Alternative 4) scheme. This site would be located at a similar ground elevation as Alternative 4 but incorporates the potential for an overall height reduction of 2m, as described above. Therefore the top of the proposed fluestack would be at an elevation of m AOD. From the Brú na Boinne sites of Dowth and Knowth the existing facility (see EIS Photomontages 8 & 9 as existing views) is openly visible as a prominent element on a small section of the skyline within an otherwise expansive panoramic view. Almost all of the proposed development would be visible further right of, and separated from the existing stacks, thereby slightly increasing the expanse of visible development. From Newgrange only the upper sections of the two existing stacks (see EIS Photomontage 7 as existing view) are visible from the heritage site. The significant remainder of existing plant is screened by the intervening ridge of Red Mountain. Alternative 5 as with the As Submitted (Alternative 4) scheme - is substantially set behind the ridge of Red Mountain. However, no perceptible visual benefit is gained in selecting the more westward location as the tower just moves slightly closer along the same view-line. The top 28m of the proposed tower - including only 3m of the top of the bulky tower structure would be visible above the ridgeline. The visual nature of this alternative is illustrated in RFI Photomontage 7 Alternative 5. For inspection purposes only. While the 2m reduction in overall height has a marginal visual benefit, the westward movement has no benefit and would result in significant additional costs in terms of facility operation and rearrangement of layout. Alternative 6 Location as submitted (Alternative 4 above) but incorporating the 2m overall height reduction (See Drawings B9378-A-518 & B9378-A-519) The westward movement of the development location had no discernible visual benefit. However, it is considered that the potential for a 2m reduction in the overall height of the tower should be incorporated into the as submitted (Alternative 4) scheme. Therefore Alternative 6 is fixed at the same location as the as submitted Alternative 4 option but incorporates the potential for an overall height reduction of 2m. Consequently the top of the proposed flue-stack would be at an elevation of m AOD. From the Brú na Boinne sites of Dowth, Knowth and Newgrange, Alternative 6 is generally as per the as submitted Alternative 4 scheme but with the marginally improved benefit of a 2m height reduction. This reduction in elevation is more apparent from Newgrange as the development would already be Reg Ref: SA50448 Page 8

11 March 2006 Platin Cement Works Extension Irish Cement Ltd. significantly screened by the ridge of Red Mountain. The visual nature of this alternative is illustrated in RFI Photomontage 7 Alternative 6. Summary On the basis of the overall Alternatives Study it is considered that the location for the development as submitted is the best available taking account of BAT, visual and operation constraints. However, on further review the as submitted scheme could incorporate a 2m reduction in overall elevation with marginal benefit in comparison to the as submitted (Alternative 4) development. In addition, should Meath County Council see benefit in conditioning same, Irish Cement Ltd. would accept the decommissioning and removal of the existing kiln 1 stack, as and when production levels within the proposed development achieve that of the existing kiln 1 output. This would remove one of the existing tall stacks in views from the Brú na Boinne WHS. The effect of such removal is represented in RFI Photomontage Alternative 6. Height of Preheater Tower and associated Chimney Stack The highest point of the proposal is only 17m higher (15m in Alternative 6 described above) than the highest existing point (Stack 2) on the site. The reason for the proposed height is related to the requirement to ensure that the plant is licensed to the IPPC Directive and is operated to Best Available Technology (BAT) standards in order to minimise emissions of NOx, SOx and Particulates and to maximise energy efficiency, thus reducing CO 2 emissions. The EPA in granting renewal of Irish Cement Ltd. s IPPC licence under the EU Integrated Pollution Prevention and Control (IPPC) Directive is required to ensure that the plant meets these standards. The EU has published a BAT Reference Document which outlines BAT for the cement industry. To meet BAT for NOx emissions, to maximise thermal efficiency and to minimise CO 2 emissions the new line will need to include an additional fifth cyclone stage (the existing kiln 2, built in the late 1970 s, has four cyclone stages) and will also require an In-Line Calciner at the base of the Preheater Tower to minimise NOx emissions. In simple terms, the proposal for the Preheater Tower represents the only solution that permits the plant to fully comply with the EU IPPC Directive and with BAT requirements for new cement plants, due to the physical dimensions of the plant components required. The chimney is required to clear the Preheater Tower to ensure that dispersion is not adversely affected by items of plant within the complex. For inspection purposes only. Reg Ref: SA50448 Page 9

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13 Alternatives considered pre-application Alternative as proposed for development Alternative 3 Alternatives considered following request for Further Information Alternative 2 Alternative 1 Alternative 5 Alternative 4 - 'as proposed' Alternative 6 For inspection purposes only. Drawing 4679L302 Proposed and Alternative Preheater Locations Date FEB 2006 Status RFI Drn DW Checked MG PLATIN CEMENT WORKS EXTENSION - FURTHER INFORMATION Job No 4679 Drawing No L302

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