1.1 PREFACE1. Increase the emission limit value for Total Organic Carbon from 10 mg/m3 to 40mg/Nm3...
Transcript of 1.1 PREFACE1. Increase the emission limit value for Total Organic Carbon from 10 mg/m3 to 40mg/Nm3...
I INTRODUCTION 1.1 PREFACE
This application for an Integrated Pollution, Prevention and Control (IPPC) Licence has been prepared
in order to update and revise the existing IPPC Licence (Licence Register Number W487-06) which
was granted by the Environmental Protection Agency (EPA) in March 2012.
Lagan Cement was first granted an IPPC Licence on 21 May 2001. Register Number P-0487-01, for
the manufacture of cement and the operation of two quarries at the installation. The licence was
since reviewed as follows;
Licence Revision
No.
P-0487-02
P-0487-03
P-0487-04
P-0487-05
P-0487-06
Date Granted
November 2003
May 2006
May 2008
January 2009
March 2012
Principal Reason for Review of Licence
Increase production of cement from 450,000 tonnes per
annum to 6000,000 tonnes per annum.
Burn waste and bone meal as a fuel
Introduce waste as raw material and fuel sources.
Increase cement production form 6000,000 tonnes per
annum to 7000,000 tonnes per annum. New concrete
products production plant - dry mortar plant, paving plant
and tiling plant.
Facilitate the introduction of additional wastes types,
namely SRF (solid recovered fuel and TDF (tyre derived
fuel)
Facilitate the introduction of additional wastes types,
namely LRF (liquid recovered fuel) and to increase the
extent of the quarrying operations over lands to the north,
east and south.
This IPPC Licence Review application is primarily being submitted in order to repeal the Air
Overpressure limits at the nearest sensitive locations which were reduced by the EPA in the most
recent IPPC Licence for the site - PO487-06 from 125dB(lin) max. peak to 120dB(lin) max. peak.
I n addition, the licensee also seeks the following amendments:-
section 1: Introduction IPPC Licence -7-06 - Review
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1. Increase the emission limit value for Total Organic Carbon from 10 mg/m3 to 40mg/Nm3 for
emission point A2-01 for the co-incineration of waste in order to accommodate varying
organic fractions within the raw materials and to bring the licence into line with TOC limits
recently granted to another Republic of Ireland based cement producer.
2. Amend the storage volumes permitted for Liquid Recovered Fuel (LRF) in Condition 8.9(b) of
PO487-06 from 20,000 litres to 150m3. The permitted use of LRF in PO487-06 is 20,000
tonnes per annum. This equates to a use of approximately 60 tonnes per day. Therefore, the
permitted storage of 20 tonnes is inadequate.
The previous IPPC Review requested an increase the extent of the existing quarrying operations at
the Lagan Cement manufacturing facility in Killaskillen, Co. Meath, the planning application for which
required the preparation of an Environmental Impact Statement (EIS). The previous IPPC Review also
broadened the range of alternative fuels used as part of Lagan Cement’s sustainable fuel programme,
including up to 20,000 tonnes of Liquid Recovered Fuels (LRF). The purpose of the sustainable fuel
programme is to further reduce Lagan Cement‘s dependence on imported fossil fuels. Lagan Cement
is currently licensed to use 95,000 tonnes of alternative fuels per annum and the most recent IPPC
Licence review did not alter the volume of alternative fuels used on site. The complete list of
European Waste Catalogue Codes permitted for use on site can be seen in detail in Attachment H.
This IPPC Licence review for the Lagan Cement manufacturing facility in Killaskillen, Co. Meath, has
not required a planning application or the preparation of an Environmental Impact Statement (EIS).
IPPC Lice- pw87-06 - Review
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Lagan Cement Ltd has operated the Lansdown Cement Works and associated limestone and shale
quarries on their lands at Killaskillen, Kinnegad, CO Meath since August 2002. The cement works
comprises state of the art facilities that have been designed by an international authority on cement
works equipment and accommodates the most modern environmental protection measures. It is a
€100 million development providing a total of approximately 100 no. jobs directly and further
significant employment for local service industries such as contract haulage and quarrying activities.
Lagan Cement Ltd is the most modern cement manufacturing plant in Ireland and at present, the
plant produces approximately 700,000 tonnes of cement per annum.
The site on which the plant is located covers 264.06 hectares and contains a shale quarry, a
limestone quarry, both of which supply raw materials for the cement manufacturing process, and
lands in agricultural use. It lies southwest of Kinnegad and north of Ballinabrackey in County Meath.
It is approximately 60km by road from Dublin and Athlone, and Mullingar is located approximately
17km to the northwest. The Site Location and the layout of the site are detailed in Attachment B.l.
Lagan Cement Ltd has previously undergone IPPC Licence reviews to permit the use of alternative
fuels at their facility in Kinnegad. The most recently permitted fuels comprise of Solid Recovered Fuel
(SRF), Tyre Derived Fuel (TDF) and Liquid Recovered Fuels (LRF) as well as a range of carbon neutral
biofuels including wood chips, recycled wood including construction and demolition (C & D) timber,
sawdust, and residues derived from the sawmill and forestry industry; agricultural products and
residues such as energy crops, cereals and grains; bio-sludge from the water treatment industry; and
biodiesel and bioethanol, and their derivatives. Lagan Cement Ltd already has permission to burn
coal, Pet Coke, fuel oil and meat and bone meal (MBM) and has over six years experience of using
MBM as an alternative fuel source in the cement kiln.
The cement manufacturing facility has been 100% compliant with the requirements of the Waste
Incineration Directive as managed through their IPPC Licence since they commenced burning
alternative fuels (MBM) in 2006. The Waste Incineration Directive sets out the legal operational and
environmental standards which the facility must comply with when burning any form of waste derived
alternative fuel material.
Section 1: Introductkn IPPC licence W487-06 - Review PaOe 3
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1.3 QUARRYING ACTIVITES
The area of the Lagan Cement Ltd. overall landholding in the vicinity of Kinnegad is 264.06 hectares.
The area of the most recently permitted quarry extension site is 109.451 hectares. The lands
surrounding the quarry area can be described as rural in character and the nearby residential
dwellings can be described as one-off dwellings fronting onto county roads outside the perimeter of
the site. The village of Ballinabrackey is located between approximately 300 - 600m south of the
quarry application site. The lands into which the quarry has extended to date and will continue to do
so in the future predominantly comprise of agricultural lands. However, there is also an area of
cutover peat bog to the south of the existing limestone quarry. The further quarry extension will
require the rerouting of llOkv ESB lines in the long term.
The existing limestone quarry and cement works were granted planning permission by Meath County
Council in April 1999 and this decision was subsequently upheld by An Bord Pleanala in April 2000. The existing quarry is permitted over an area of 24.8 hectares and to a depth of 75 metres, i.e. 5 benches at 15 metre intervals to a depth of approximately 10 AOD. The existing limestone quarry is
permitted over an area of 24.8 hectares and to a depth of 75 metres (i.e. 5 no. benches at 15 metre
in terva Is).
section 1: Intraductkn Ippc Licence PO487-06 - Review psge 4
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Figure 1.1: Previously permitted Limestone Quarry illustrating the Final Quarry Void
a
Source.: Environmental Impact Statement (Meath County Council Planning Reg. Ref. No. 98/2026 and An Bord Plean6la Ref.
No. PL 17.111198); Extract from Drawlng No. 2.1.16.
Lagan Cement Ltd. will extend the existing quarry over lands to the north, east and south. The
extension to the existing limestone quarry will be to a depth of 1 bench at approximately 70 metres
AOD. This extension will increase the surface area of the quarry by approximately 52.45 hectares
over 3 No. phases. The extension will result in a final overall extracted area of 77.25 hectares and
extend the life of the quarry by up to 20 years. The extension will not result in any increase to the
associated permitted production capacity of the cement plant.
The extension of the quarry over a single bench will safeguard the strategic limestone reserve
available to Lagan Cement Ltd. The quarry extension will also help Lagan Cement Ltd to produce
cement more efficiently, based on the following:
section 1: Inboduction
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1) It makes better economic and operational sense to quarry the limestone from a wider
footprint, before starting to quarry at greater depths. For example, a consequence of going to
deeper benches is that Lagan Cement Ltd would have to increase the size of their vehicle fleet, at
considerable cost, to compensate for the longer journeys between the working quarry faces and the
crusher. This would also result in higher COz emissions.
2) Working a quarry over a single bench for a longer period simplifies quarry management and
will reduce the number of times that the existing crushing plant and conveying equipment will have to
be moved. Moving installed crushing and conveying plant is expensive and time consuming, and the
relocation of this plant can take several months.
The workings of the quarry extension area will be continued as follows:
1. Blasting of rock faces,
2. Transport to crusher,
3. Crushing,
Stockpiling, and
5. Conveying to the cement plant.
Each of these steps is summarised below.
J. Blastina of rock faces To provide limestone feed to the cement mill, the active rock face must be blasted, at regular
intervals, using an ammonium nitrate fuel oil mix. Using specialist blasting contractors, holes are
drilled in the rock face and the blasting mix is added. - Once blasting has occurred, large rock chunks are transported, using very large (60 tonne) mobile
equipment, to a crusher, which is located on the quarry floor.
3. Crushinq
There are two crushing stages, primary crushing and secondary crushing. Each crusher consists of a
set of electrically operated rotating drums, which function to reduce the particle size of the rock to a
scale that can be easily transported using belt conveyors.
4. Stockding
IPPC Ucence poru)7-06 - Revlew
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An essential part of quarry operation is the stockpiling of crushed material. These stockpiles act as
reserves in the event of a crusher or mobile equipment failure.
5. Convevi ng A long belt-conveyor is attached to the out feed point of the crushing equipment. This conveyor
transports the crushed rock to the cement mill for further processing.
1.3.1 Quarrying Operational Plan
The operational plan for the quarry has been upgraded in light of the planned development of the
quarry extension. Each of the three phases of the proposed operation are summarised below.
Phase 1: Deve loment o f Northe rn Extension to a Depth of 70 metres AOD
Initially, limestone will be extracted in a northerly direction to the maximum permitted lateral extent
of the quarry. This bench will be worked to a depth of approximately 70 metres AOD and therefore
represents a continuation of the first production bench currently being worked at the quarry. The
production benches will be at least 30 metres wide and will have sub-vertical faces. All production
benches will be subject to ongoing geo-technical monitoring on a regular basis in keeping with the
highest industry standards, best industry practice, and current health and safety regulations and
guidelines (SXety, Health and Welhte at Wok (Quamess) Regula~ons, 2008 (S.I. No. 28 of 2008)).
unce the production benches have been extended to their permitted limits, two new haul
roads/ramps will be constructed to a maximum width of 20 metres with sufficient space for a
protective barrier and drainage, with a down-ramp slope of 1 in 12 to the 70 metres AOD level along
the western side of the quarry. These ramps will act as the main access routes to both the northern
and southern parts of the quarry void.
On reaching their maximum permitted extraction limits, production benches will have final bench
widths of 7.5 metres, final maximum bench heights of 15 metres and final bench slopes of about -70'
from the horizontal, depending on the geo-technical quality of the rock. This will ensure the long-
term stability, integrity and safety of the final quarry design.
IPPC licence -7-06 - Review
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Overburden will be stripped in a controlled and phased manner ahead of the quarry face with batters
of 1 in 2 being proposed. Materials from the stripping will be used in the construction of additional
screening berms along the northern side of the site (with batters of 1 in 2.5 being proposed).
Berms are a common tool used in the quarrying process. These landforms are constructed of
'overburden' material recovered from above the rock suitable for extraction. This overburden consists
of topsoils and subsoils which are valuable for final restoration purposes. The material is therefore
carefully maintained and managed in berms or bunds which are usually located at the boundaries of
quarry site, The berms (bunds) perform a number of tasks besides that of maintaining soil fertility, in
that they act as visual, aural and environmental barriers for neighbouring land uses.
Figure 1.2: Phase 1 of Proposed Quarry Extension (Northern Extension)
L.
Source: SM Bennet & Co LM (December 2008)
IPPC Ucenca PWE7-06 - R e W
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Cement
Phase 2: Develooment of South -Eastern and South-Western Extensions to a Dent h of 70
metres AOD
Towards the completion of Phase 1, overburden will be stripped in a controlled and phased manner in
a south-easterly and south-westerly direction and will be used in the construction of screening berms
around the south-western and south-eastern boundaries of the site. Topsoil and overburden used in
the construction of the screening berms will be used in the final restoration of the quarry void and the
site as a whole.
Limestone will be extracted in a south-westerly and south-easterly direction towards the maximum
permitted lateral extent of the quarry down to a depth of about c.70m AOD and will be a continuation
of the production bench currently being worked at the quarry. The production benches will be at
least 30 metres wide and will have sub-vertical faces. All production benches will be subject to
ongoing geo-technical monitoring on a regular basis. Production benches will have final bench widths
of 7.5171, final maximum bench heights of 15m and final bench slopes of about -70' from the
horizontal, depending on the geo-technical quality of the rock. This will ensure long term stability,
integrity and safety of the final faces. It is proposed to extract limestone from around the asphalt
plant complex during this phase of the development.
Figure 1.3: Phase 2 of Proposed Quarry Extension (South-Eastern and South-Western
X
Source: SM Bennet & CO Ltd (December 2008)
section 1: Introduction IPFC Licence -7-06 - Review
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Phase 3 : Removal of AsL..alt Plant anc Subseauent DeVelODmefi, of t..e Ouarw ..I a
Southerlv Diredypnto a DeDth of 70 metres AOD . .
As Phase 2C of the proposed development nears completion, it is proposed to decommission and
remove the asphalt plant (Phase 3A). Once the plant is removed, the area around it will be extracted
to the 70 metres AOD level (Phase 38). Towards the completion of Phase 2 and the removal of the
asphalt plant complex, overburden will be stripped in a controlled and phased manner in a southerly
direction and will be used in the construction of screening berms around the southern boundaries of
the site. The timing and scheduling of the topsoil and overburden stripping will be dependent on the
prevailing economic conditions at the time. For the purposes of this application, the stripping of
topsoil and overburden has been divided into 6 sub-phases (3C' to 3cb). Topsoil and overburden
used in the construction of the screening berms will be used in the final restoration of the quarry void
and the site as a whole. The production benches will be at least 30 metres wide and will have sub-
vertical faces. All production benches will be subject to ongoing geo-technical monitoring on a
regular basis.
Figure 1.4: Phase 3 of Proposed Quarry Extension (Southern Extension)
Source: SM Bennet & CO Ltd (December 2008)
Section 1: Inhoductkn IPPC licence PO487-06 - Review Page 10
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Lagan Cement'
As already outlined, production benches will have final bench widths of 7.5 metres, final maximum
bench heights of 15 metres and final bench slopes of about -70' from the horizontal, depending on
the geo-technical quality of the rock. This will ensure long-term stability, integrity and safety of the
final quarry design.
The phasing of the extraction allows for multiple faces to be opened-up and worked at any given
time, thereby enabling the blending of materials from the quarry, essential to the continued efficient
operation of the cement plant.
Early and ongoing restoration and planting of final benches with stockpiled materials, including
previously stripped and stored overburden and topsoil will occur as areas of the quarry become
worked out.
The estimated reserve levels within the area of the proposed quarry extension suggest that the
subject site will take between 15 and 20 years to excavate over a single bench level. Given this
projected life span for the development and the unknown economic conditions over its lifetime, the
creation of more than 3 primary operational phases would be arbitrary and would complicate and
compromise the operational efficiency of the site.
1.3.2 Overburden Disposal
Overburden will be removed to permanent landscaped locations wnicn will act as new screening
berms for the southern and eastern areas of the proposed quarry extension. The overburden to be
removed includes a significant proportion of free draining materials. The mounds will be constructed
with long-term stability being a key consideration. Detailed stability and construction reports will be
prepared prior to bund construction to ensure that the structures are secure.
Soft clays, silts and peaty materials will be bunded inside containing cell walls and where appropriate,
drainage blankets will be placed following the removal to top and sub-soils from the areas where
bunds are to be built. Top and subsoils will be separately stored to assist in revegetation of
completed screening banks and bunds. Since silt may be suspended in surface water run-off from
the large screening bunds, silt traps will be employed before discharge into existing watercourses
until surface plant growth has been established.
section 1: Introduction Page 11
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1.3.3 Quarry Operations
It is proposed that the quarry extension will be operated along the same lines as the existing
permitted quarry operation. I n this regard, the working of the quarry extension will take place
between 07:OO and 19:OO hours on Monday to Saturday. Except in emergency, and then on advice
to the Planning Authority, working will not take place on Sundays and Bank Holidays. Pumping may
take place continuously and some maintenance will occur at weekends.
The reef limestone will require ground preparation by drilling and blasting. Initially, the quarry
extension will be worked using conventional hard-rock equipment induding hydraulic loading shovels
and 50 - 70 tonne dump trucks.
Blast design will be based on careful monitoring of the initial blasts using low charge weights of
explosive per delay. Based on the experience of the existing operational quarry, blast vibrations can
be kept below 12mm per second at a distance of 300m using a maximum charge delay of 1OOkg. A
maximum charge per delay of 50kg would maintain the same vibration limit at a distance of 140m
from the point of blasting.
1.3.4 Quarry Safety & Security
There are a number of safety and security measures in place for the existing quarrying operations on
the subject site. In this regard, fences are located and regularly maintained around the perimeter of
the site inside existing hedgerows, thereby discouraging inadvertent access to the quarries and the
water retention structures. The screening berms being constructed as part of the proposed quarry
extension will be subject to separate investigation and reporting before construction. There is
sufficient granular material to ensure adequate drainage in the structures, with weaker, softer soils
being contained in internal cells.
1.3.5 Quarry Restoration
The restoration of the proposed quarry extension will be undertaken in accordance with that of the
existing permitted quarry. I n accordance with the restoration proposal for the existing limestone
quarry, a Restoration Plan has been prepared by David Jarvis & Associates
saction 1: Inhoduction Page 11
1)
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I n IPPC Licence PO487-05 Review Application, Lagan Cement Ltd. added Liquid Recovered Fuel (LRF)
and additional alternative fuels to their previous list of alternative fuels for use at their facility. Lagan
Cement Ltd. use up to a maximum of 95,000 tonnes per annum of any ambination of the full list of
non-fossil, alternative fuels, but with LRF usage being limited to 20,000 tonnes per annum. The
alternative fuels consumed in the kiln, now include LRF and the previously permitted Solid Recovered
Fuel (SRF), Tyre Derived Fuel (TDF), Meat and Bone Meal and carbon-neutral biofuels. Market
conditions dictate which combination of fuel types is used at any given time.
By maximising the use of these alternative fuels Lagan Cement Ltd, reduces the amount of imported
virgin fossil fuels needed, reduces COz emissions, improves economic and environmental sustainability
of operations and assists national energy security. Alternative fuel use also reduces the associated
environmental impacts of finding, producing, transporting, and burning these fuels and reduced
dependence on landfill.. Lagan Cement Ltd. sees this use of alternative energy and the 'closed loop'
of resource usage as an essential step in improving the sustainability of its cement manufacturing
operation and reducing its emissions of greenhouse gases to the atmosphere.
The existing alternative fuels used by Lagan Cement (IPPC Licence PO 487-06) comprise the
European Waste Catalogue codes which are listed in Table 1 below according to their respective
codes from the European Waste Catalogue.
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Table 1: Summary of Existing Waste Categories for Acceptance at the Lagan Cement plant (IPPC
Licence PO -487-06). (The maximum capacity of 95,000 tonnes of alternative fuels per annum shall
not be exceeded).
02 01 03,02 01 07,02 01 09,02 02 03,02 02 04,02 03 04,02 03 05,02 04 02,02 05 02,02 07 04,
02 07 05, 03 01 01,03 01 05,03 03 01,03 03 08,
05 01 03, 06 02 01,06 02 03,06 02 04,06 02 05,06 09 04,06 08 99,
07 01 01,07 01 04,07 05 01,07 05 03,07 05 10,07 05 12,07 05 13,07 05 14,07 06 99,07 07 01, 07 07 04,
08 01 11,08 01 12,
09 01 01,09 01 02,09 01 03,09 01 04,09 01 05,09 01 06,09 01 13,
10 01 01,lO 01 02,lO 01 03, 10 01 15,lO 01 17,lO 02 01,lO 02 02,lO 03 05,lO 03 17, 10 03 18,
10 03 26,lO 08 04, 10 01 15,lO 01 17,lO 10 03,lO 10 08,lO 09 03,lO 09 06,lO 11 03,lO 11 12,
10 12 03,lO 12 06,
11 01 10, 12 01 01, 15 01 01,15 01 03,15 01 10, 16 01 03, 17 01 06,17 02 01,17 02 02,17 05 03,17 05 04,17 05 05, 17 05 06,17 08 02, 18 01 06,18 01 07,18 01 09,18 02 05,18 02 06,18 02 08, 19 01 12,19 01 14,19 01 18, 19 01 19,19 02 03,19 02 06, 19 02 07,19 03 05,19 06 03, 19 05 01,
19 05 02,19 05 03, 19 07 02, 19 07 03,19 08 02,19 08 05, 19 08 10,19 10 04,19 13 02, 19 13 04,
19 08 12,19 08 14,19 09 01, 19 09 02,19 12 01,19 12 04,19 12 05, 19 12 07,19 12 09,19 12 10,
19 12 12,
20 01 01,20 01 02,20 01 13,20 01 25,20 01 27,20 01 28,20 01 32,20 01 38,20 01 39
Lagan Cement Ltd. use alternative fuels inclusive of European Waste Catalogue codes from Chapters
1, 2, 3, 5, 6, 7,8, 9, 10, 11, 12, 15, 17, 18, 19 and 20.
Lagan Cement Ltd. propose that the quantum of alternative fuels to be co-fuelled in the cement kiln
will be comprised of considerably less than 40% hazardous waste. Therefore, in accordance with
Article 7(2) of the Waste Incineration Directive (WID) the emission limit values (ELVs) as outlined in
Annex I1 of the WID will not be exceeded in the exhaust gas.
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The use of 95,000 tonnes of alternative fuels per annum, inclusive of 20,000 tonnes of Liquid
Recovered Fuels (LRF), falls under the scope of the Annex I1 ELVs as the resulting heat release will
come from the co-fuelling with less than of 40% of hazardous waste (Article 7(2)). All alternative
fuels used onsite will contain less than 1% of halogenated organic substances (expressed as
chlorine).
Lagan Cement has strict abatement systems and operational procedures in place in order to control
atmospheric emissions. All alternative fuels are fully treated to enhance their combustion qualities
prior to their acceptance at the Lagan facility.
The use of alternative fuel increases the sustainability of the cement manufacturing facility and
represents further progress by the company in the direction of the Governments objective of
delivering a sustainable energy future for Ireland. Lagan Cement Ltd believe that they will be able to
manage a highly energy intensive operation, the manufacturing of cement, with a safe and secure
supply of energy in a sustainable and environmentally friendly manner while still achieving economic
competitiveness. Sustainable management of the energy requirements at Lagan Cement Ltd. is
intended to 0 reduce CO2 emissions from the facility
secure and stabilise energy supply for the long term 0
0 reduce reliance on expensive fossil fuel imports and
invest and assist in Irelands indigenous renewable energy projects which are often in rural 0
and less developed areas
Lagan Cement Ltd is very conscious of the fact that using resources more efficiently is an essential
step toward creating a more sustainable society. I n effect this ‘eco-efficiency’ means producing more
energy with less waste and pollution, and uses fewer resources. This not only helps to break the link
between economic growth and environmental pollution, but can also help companies improve
financial performance as they pay less for resource inputs and pay less for waste management and
pollution control.
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Cement is produced in a kiln at very high temperatures (up to 2000 degrees centigrade) from a
mixture of raw materials. For the production of cement, the principal raw materials are limestone and
shale, which are extracted from the existing quarries on the site, and some imported raw materials
are also used.
A schematic representation of the process is presented in Appendix D1 of Attachment D. The raw
materials used in the process are finely ground and mixed in precise proportions depending on their
exact chemical composition before entering the kilning process in a dry state. The mix of raw
materials, known as raw meal, is pre-heated and calcined at 500 - 900°C when carbon dioxide is
driven off; the meal is then sintered at temperatures of about 1400 - 1500°C when a calcium silicate
clinker is formed in the form of 3 - 25mm granules. Gypsum, added in order to control the setting
time of the cement, is then mixed with the clinker and ground to produce cement. Coal, fuel oil, meat
& bone meal (MBM), Solid Recovered Fuel (SRF) and Tyre Derived Fuel (TDF) and a range of carbon
neutral biofuels including wood chips, recycled wood including construction and demolition (C & D)
timber, sawdust, and residues derived from the sawmill and forestry industry; agricultural products
and residues such as energy crops, cereals and grains; bio-sludge from the water treatment industry;
and biodiesel and bioethanol, and their derivatives are currently the fuels used for the manufacture of
cement at the site as alternative fuels in place of a portion of the existing coal supply. Lagan Cement
Ltd are currently permitted to burn a total of 95,000 tonnes per annum of these renewable alternative
fuels.
There are eight stages in the cement manufacturing process:
Raw material preparation
Raw material analysis and blending
Raw meal milling and mixing
Raw meal kilning
Clinker cooling and handling
Clinker grinding
Coal preparation
Storage and handling of cement
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A comprehensive description of the process is presented in Attachment No D of this Licence
Application. A brief description of the main elements of the manufacturing process is presented
below.
1.5.2 Raw Material Preparation & Handling
The principal raw materials required for the process are recovered on site with some additional raw
materials being imported as required. The raw materials are handled in the Raw Material Compound
located between the cement works and the limestone quarry. Raw materials are stored in stockpiles
constructed for this purpose in the Raw Material Compound. Stores of finer material and crushed
shale and limestone are housed to minimise dust emissions and the two crushers required for the
processing of the raw materials are also housed. All material conveyance to the Blending Bed is under
cover.
Materials are blended to the required composition in the Blending House before being conveyed into
the Raw Mill for crushing and drying. The Raw Meal produced is stored in silos until required for
processing in the manufacturing process.
A more detailed description of the operation of the two quarries and a detailed description of the raw
material preparation and handling operations is also presented in Attachment No D.
Alternative raw materials are also permitted at the facility. Recycled gypsum, filter cake from the
drinking water treatment industry, recycled glass, recycled ash are amongst the renewable raw
materials, which may be used as raw material substitutes in the production of cement. These
materials will be transported to the site in covered, leak-proof container trucks and will be visually
inspected and cross-checked against the Quality Control Specification Sheet before being allowed to
unload on site. Alternative raw materials will all be stored in the existing covered raw material storage
areas and will be introduced into the process at the raw materials intake area.
Improved energy efficiency in cement production equates to lower COz and lower costs. Therefore,
Lagan Cement Ltd. has an incentive to maximise the tonnes of product produced / unit of energy
spent.
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In cement manufacture, CO2 emissions arise as a result of the Combustion of fuels and from a
process known as calcination, where CaCa, present in the raw materials, is converted into CaO,
which is the main component of cement. Because a significant portion of the CO2 emissions from
cement plants are from the calcination process, any mechanism that allows lesser raw material to be
calcined will have a significant role in reducing the overall CO2 emissions. As calcination only occurs at
very high temperatures, any reduction in the volumes of material requiring calcination will also serve
to reduce the energy inputs associated with cement production. Therefore, anything that will
displace an equivalent amount of clinker, such as blending of waste gypsum or filler (rock or mineral
materials), will result in lower CO2 emissions from the cement plant and will reduce energy usage and
therefore, be more cost effective.
Lagan Cement Ltd. propose to import waste gypsum or filler (rock or mineral materials such as ash or
slags) to the existing site and incorporate this material into the cement making process "post kiln".
Therefore, these materials are not alternative fuels in the process but are merely an alternative raw
material to the quarried products of the existing limestone and shale quarries.
Gypsum is mixed with the clinker and ground to produce cement. It is added in order to control the
setting time of the cement. Lagan Cement Ltd. propose to source this gypsum or filler material from
a variety of sources such as casting moulds, construction and demolition wastes and flue gas
desulphurisation processes.
Raw Meal from the storage silos is fed to the preheater stage of the kiln and travels downward
through the Preheater Tower or Heat kchange Tower to the Kiln. Clinker is produced by the calcining
of the Raw Meal at high temperatures. The Clinker is cooled and crushed before being conveyed for
storage in Clinker silos until required for use in the cement manufacturing process. A separate silo is
provided for clinker produced during start-ups which need to be re-blended.
A detailed description of the processes involved in the production of clinker is presented in
Attachment No D.
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Cement is produced by grinding the clinker produced in the earlier manufacturing stages in the
Cement Mill. Gypsum and fillers may be added prior to milling if necessary to produce the required
formulation. The facility produces both CEM I and CEM I1 type cements. CEM I has a clinker content
of approximately 91% with the remainder being made up of limestone and gypsum in almost equal
proportions. CEM I1 has a clinker content of approximately 81% and is made up of 15% limestone
and 4% gypsum.
Cement is stored in silos prior to transport to the bagging plant or for direct loading onto container
trucks. A detailed description of the processes involved is presented in Attachment No D.
Fuel Preparation & Use
Approximately 80,000 tonnes of coal per annum is delivered to the site by truck and is stored in one
of the two coal silos located in close proximity to the kiln. The coal is conveyed as needed to a feed
bin, which in turn feeds the coal to the coal mill. Coal is ground to a fine powder to facilitate
combustion in the kiln. The high temperatures required in the cement kiln can only be achieved by
using coal dust which is blown in to the kiln through a burner pipe. The flame reaches temperatures
in excess of 2,OOOOC. The coal mill operation is similar to the raw meal mill, only significantly smaller
in capacity and specially designed to grind coal safely.
I n the kiln, coal is burned only when temperatures are high enough for safe combustion. To start-up
the installation fuel oil or natural gas is used to preheat the areas where coal combustion takes place
which is required for safety reasons.
Lagan Cement Ltd also has permission to use a range of alternative fuels in the kiln including meat
and bonemeal, renewable wood sources (such as wood chips recycled wood, sawdust and residues
derived from the sawmill and forestry industry), agricultural products and residues, bio-sludge from
the water treatment industry and biomass fuels such as biodiesel and bioethanol.
Alternative liquid fuels will be transported to the site by road tanker in the same manner as the gas
oil supply is currently delivered to the site and will only be accepted onto the site following an offsite
quality control check.
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Lagancement 4 L-11 crRqlul1r
Alternative solid fuels will be transported to the site in covered, leak-proof container trucks. All solid
fuels are visually inspected and cross-checked against the Quality Control Specification Sheet before
being allowed to unload on site. Solid fuels are stored under cover in segregated sections for each
fuel type. As the solid fuels are being fed into the process they will be further inspected to ensure
that no contamination is present in the fuel load. If any contaminant material is found to be present
then the affected section of the load will be removed to the quarantine area for storage and will be
returned to the supplier on the next load that arrives in to the facility.
1.5.6 Dry Mortar Manufacturing Process
The facility has permission to operate a dry mortar and will produce an output of 70,000 tonnes of
mortar product per annum once up and running. The mortar plant will be configured as a high level
mixing plant for dry mortar and plaster. The aggregates will be delivered from the raw material
storage stockpiles, which will be fed from the on-site quarries, and loaded into the inlet funnel
(receiving hopper) by truck or front-end loader. Materials will then be transported from the receiver
hopper up to the Fluid Bed Dryer/Cooler by belt conveyors. The Fluid Bed Oryer/Cooler is connected
with a belt bucket elevator which charges the storage silos within the mixing tower. The aggregates,
binders and additives will be weighed in a weighing hopper and the whole batch will then be released
into a single shaft mixer. Following batching, the homogenised material will be distributed by a belt
conveyor either to the packing plant, to the bulk loading or to the finished product silos.
All process equipment within the dry mortar plant including storage silos, additive bunkers, weigh
hoppers for aggregates, binders and additives, mixer, mixer bunker, fluid bed dryer, and loading
spouts are equipped with individual filters and will ensure that the residual dust quantity in the filter
outlet will be I 10mg/Nm3. The equipment is de-dusted at the particular point of dust generation and
therefore the collected dust is returned into the process and is not released into the atmosphere.
1.5.7 Paving Plant Manufacturing Process
Lagan Cement Ltd have permission to operate a paving block plant is a high volume production
process and will produce a variety of different concrete floor paving block ranges, up to a total of
100,000 tonnes per annum. The entire mixing process is totally automated and computer controlled
to ensure consistency of manufacture and orderly storage and curing of the blocks.
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LaganCement
The raw materials for production will be delivered from the raw material storage stockpiles, which are
fed from the on-site quarries. From here the aggregates for production will be delivered by truck into
a ground feed hopper from which each material is fed into covered storage bins. A batching system
will dispense the exact quantity of each material by measuring the weight of the aggregate with load
cells beneath the conveyor. The mixed aggregates are then transferred into a holding hopper above
the concrete mixer. Cement is fed to the mixer and water is added in an automated manner so that
the resulting concrete has the correct moisture content and consistency. Pigment is also added to the
mix during the mixing process.
At the start of the process, a palette is moved into position in the block press, the mould-box is
lowered onto the palette and the feed drawer fills the mould box with mixed concrete. Flat
compaction heads are lowered onto the mould and heavy vibration is applied to compact the block to
size. The mould is then lifted and the palette containing the wet paving block moves down the
production line.
Palettes containing the formed paving blocks are moved to a storage elevator. When the storage
elevator is full, a finger car automatically lifts the palettes and transfers them to one of the curing
chambers. During the following 24-hour period, the heat developed by the hydration of the cement
cures the paving blocks. The curing chambers are highly insulated to contain the heat and humidity
produced during the curing cycle.
After curing, the paving blocks are transferred by the finger car to the board lowerators where the
product is continually inspected and sampled for laboratory testing. Hydraulic grabs lift the blocks
from the palette and stack them into cubes which are strapped and wrapped for protection during
storage. Each cube is individually tagged with both a tracking code and a product description prior to
being moved from the conveyor for storage in the yard. The blocks are kept in storage until the
appropriate strengths have developed.
Lagan cement Ltd has permission to operate a tiling plant that will produce up to 50,000 tonnes of
roof tiles per annum. The raw materials for production will be delivered from the raw material
storage stockpiles, which are fed from the on-site quarries. From here the aggregates for production
will be delivered by truck through a screen and up to the Holding Hopper where it is then weighed up
on the weighing system and blended together to the mixer. The Cement is brought up by means of a
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cement screw. The Cement is discharged into the mixer and pigment slurry is added. The hydronix
system then takes a moisture reading and water is then added to the settings required.
The mix is then dropped into a hopper above the conveyor and fed to the Tile Extruder. The tile
mould is fed towards the extruder and is sprayed with release oil. Over spray from the release oil is
filtered and put back into the release oil tank.
The mix is then dropped into a hopper above the conveyor and fed to the Tile Extruder. The tiles are
then loaded and pushed into the Carousel Rotary.
By this stage, the tiles have reached the exit point of the Rotary. Each rack holds 200 tiles, which are
then pushed out by the cured tile pusher onto a conveyor.
The tiles are then fed towards the depalleter. The tile is split from the mould and the mould is fed
back round to the Tile Extruder. The tile is then sent in another direction to the Paint Booth before
being stored for transport.
xctlon 1: Introduction IPPC Ucence PO487-06 - Review Page 22
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Attachment NP A.1
NON-TECHNICAL SUM MARY
IPPC LICENCE APPLICATION
icence Register Number PO487-06 REVIEW
Prepared by: Envest Environmental Ltd. @ S T Environmental
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Attachment NP A.
NON-TECHNICAL SUMMARY
Table of Contents
Section Page
1.0 Introduction ............................................................................................... 1
2.0 Increase in the Emission (ELV) for Total Organic Carbon (TOC) ... 2
3.0 Air Overpressure Limit
4.0 Conclusions ............................................................................................... 5
section A.l: Nan-Technical Summary
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e
1.0 Introduction
This application for an Integrated Pollution, Prevention and Control (IPPC) Licence has been prepared
in order to update and revise the existing IPPC Licence (Licence Register Number W487-06) which
was granted by the Environmental Protection Agency (EPA) in March 2012.
This IPPC Licence Review application is primarily being submitted in order to repeal the Air
Overpressure limits at the nearest sensitive locations which were reduced by the EPA in the most
recent IPPC Licence for the site - PO487-06 from 125dB(lin) max. peak to 120dB(lin) max. peak.
I n addition, the licensee also seeks the following amendments:-
1. Increase the emission limit value for Total Organic Carbon from 10 mg/m3 to 40mg/Nm3 for
emission point A2-01 for the co-incineration of waste in order to accommodate varying
organic fractions within the raw materials and to bring the licence into line with TOC limits
recently granted to another Republic of Ireland based cement producer.
2. Amend the storage volumes permitted for Liquid Recovered Fuel (LRF) in Condition 8.9(b) of
PO487-06 from 20,000 litres to 150rn’. The permitted use of LRF in W487-06 is 20,000
tonnes per annum. This equates to a use of approximately 60 tonnes per day. Therefore, the
permitted storage of 20 tonnes is inadequate.
The previous IPPC Review requested an increase the extent of the existing quarrying o
the Lagan Cement manufacturing facility in Killaskillen, Co. Meath, the planning application for which
required the preparation of an Environmental Impact Statement (EIS). The previous IPPC Review also
broadened the range of alternative fuels used as part of Lagan Cement’s sustainable fuel programme,
including up to 20,000 tonnes of Liquid Recovered Fuels (LRF). The purpose of the sustainable fuel
programme is to further reduce Lagan Cement‘s dependence on imported fossil fuels. Lagan Cement
is currently licensed to use 95,000 tonnes of alternative fuels per annum and the most recent IPPC
Licence review did not alter the volume of alternative fuels used on site. The complete list of
European Waste Catalogue Codes permitted for use on site can be seen in detail in Attachment H.
This IPPC Licence review for the Lagan Cement manufacturing facility in Killaskillen, Co. Meath, has
not required a planning application or the preparation of an Environmental Impact Statement (EIS).
Section A.l: Non-Technical Summary
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2.0 Increase in the Emission Limit Value (ELV) for Total Organic
Carbon (TOC)
The potential impact of a possible increase in the Emission Limit Value (ELV) for Total Organic Carbon
(TOC) emissions from 10mg/m3 to 40mg/m3 from the cement plant has been reviewed in relation to
the air quality impact.
In February 2010 when the application for permission to use Liquid Recovered Fuel (LRF) as an
alternative fuel at the facility was being prepared a very comprehensive assessment of air quality
impacts associated with the use of a range of fuels at the facility was completed. That assessment
included a comprehensive evaluation of the potential impacts on air quality as a result of emissions
from the proposed use of LRF and other additional ONC codes as alternative fuel sources in the
cement kiln. The combined impacts of emissions from existing activities at the site were also
considered in the assessment.
The dispersion modelling study demonstrated that the existing stack height of 125m for the cement
kiln provides effective dispersion of pollutants emitted from the facility under normal and maximum
possible operating conditions. The results of the study demonstrated that there will be no adverse
impacts on ambient air quality in the vicinity of the facility as a result of emissions from either existing
or proposed activities at the site. The assessments were completed under the worst possible
emissions scenarios, as well as typical emissions conditions, in order to assess the maximum potential
impact on ambient air quality; the use of maximum possible emission conditions ensures that the
impact assessments are reliable and may overestimate the actual projected impact of the
development.
The results of this extensive study demonstrated that there will be no adverse impacts on ambient air
quality in the vicinity of the facility, on local residences or on local agriculture as a result of emissions
from either the existing or the proposed activities at the site. This included in respect of emissions to
atmosphere of TOC. The modelling results have been compared with the air quality standard for
environmentally significant organic compounds using the German TA Luft Technical Instructions on
Air Quality Control. Even using this stringent assessment criterion, the predicted ambient TOC
concentrations are very substantially lower than the relevant air quality limit value.
I n terms of the assessment of the impact of an increase in the ELV for TOC from 10mg/m3 to
40mg/m3, the impact of such an increase can be extrapolated from the previous model results. A
Sactian A.l: Non-Technical Summary IPPC LiceMC PO487-06 - ReViW
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fourfold increase in the emissions would see a corresponding fourfold increase in the predicted
ground level concentrations. Even at this increased emission rate, the predicted ground level
concentration, after taking account of the existing background, is very significantly lower than even
the most stringent air quality standard.
I n conclusion, the assessment has shown that there is no adverse impact associated with an increase
in the ELV for TOC from 10 mg/m3 to 40mg/m3 and the change in predicted ground level air quality is
insignificant and imperceptible relative to the existing situation.
3.0 Air Overpressure Limits
This IPPC Licence Review application is primarily being submitted in order to repeal the Air
Overpressure limits at the nearest sensitive locations which were reduced by the EPA in the most
recent IPPC Licence for the site - PO487-06 from 125dB(lin) max. peak to 120dB(lin) max. peak.
The recommendation of the EPA Technical Committee to reduce Air Overpressure Limits to 120
dB(lin) max peak at the nearest noise sensitive location outlines a significant change from the draft
licence 487-06 and the licence conditions pertaining to the quarrying operations at the Lagan Cement
facility in Kinnegad, Co. Westmeath, for the previous 5 licences, which outlined a limit of 125 dB(lin)
max peak. It would appear that the technical committee did not take into account actual AOP
measurements, taken on behalf of Lagan Cement, over an almost 10 year period, which shows 100%
compliance with 125dB, but with a significant number of excursions above 120dB. The Lagan
Cement facility already operates to limits of 8 mm/s and 125 dB(Lin) for blasting which occurs
typically on average every 2-3 weeks in the limestone quarry and once per annum in the shale
quarry. This is a rigorous standard, already more stringent than all of their competitors. Lagan
Cement presently inform all nearby sensitive residential properties in writing in advance of quarry
blasts and also sound a warning siren prior to blasting. Similar installations to the Lagan Cement
quarry at Kinnegad, Co. Westmeath have either an air over pressure limit of 125 dB (lin) maximum
peak or no relevant limit at all.
A summary review of worldwide limits reveals a wide range of formal limits, ranging from 115 d6
(lin). max. peak (with 5% exceedence permitted to 120 dBL) in some operations in Australia, to 133
dB (lin). max. peak in the USA. It is reported that in certain cases a guideline limit of 120 dB (lin).
max. peak has been applied in many blasting operations in Australia, the USA, Canada and the United
Section A.l: Non-Technical Summary IPPC Licence PO487-06 - Review pape 3
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Kingdom and conformance with this guideline limit has been successful in reducing complaints to an
acceptable level. However, the Australian, US and Canadian limits are unlikely to be directly
comparable to the Irish scenario due to the vastness of these countries and the remoteness of many
such quarries from residential properties. Also, more importantly the typical climatic conditions
experienced in Ireland differs very significantly from that which tends to prevail in countries such as
Australia, the US and Canada.
Weather conditions, such as high humidity, rainfall, or the presence of cloud cover, can cause the
levels of overpressure to seem more severe than there would be on a day when the humidity is low
and there is lack of cloud cover. Overall, it can be summarised that air overpressure levels are higher
during blasting episodes when weather conditions include the following:
significant temperature inversions
foggy or hazy conditions with little or no wind
still, cloudy days with a low cloud ceiling
Low cloud ceiling, strong breeze / wind blowing directly towards sensitive receiver
The blasting at the Lagan Cement quarry is most likely to be conducted during weather conditions
which are representative of one or more of the weather conditions outlined above. Therefore, it is
very difficult for Lagan Cement to meet more onerous licence conditions when such weather
conditions are so prevalent and existing air overpressure levels are already typically in excess of the
recently revised lower limit but in accordance with the former limit value of 125 dB (lin) max. peak.
Lagan Cement has been highly proactive in employing a variety of measures, which constitute BAT,
towards mitigating the vibration and AOP issues associated with blasting. This is evidenced by their
strong compliance history to date. However, it is important to note that climatic conditions may
negate mitigation measures taken. It is also important to note that Lagan Cement is of the view that
no further measures can be reasonably taken to further mitigate AOP.
it is widely reported that the susceptibility of individuals to vibration varies from person to person
depending on factors such as age, health and, to a large extent, previous exposure. It is also widely
reported that it is usually the case that adverse comments are less likely once a neighbour has
become accustomed to the perceived effects of blasting and the resident is regularly informed of
progress updates and warnings with regard to blasting. This is presently undertaken by Lagan
Cement Ltd. with a blasting conducted as a single event every 2-3 weeks with regards to which
residents are notified in writing and a warning siren is sounded in advance of blasts.
Section A.1: Non-Technical Summary IPPC Ucanca PO487-06 - Review Paw 4
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Lagan Cement
4.0 Conclusions
A comprehensive assessment of potential environmental impacts of the increase in the extent of the
existing quarrying operations at the Lagan Cement manufacturing facility and the use of alternative
fuels has been carried out as part of the ongoing review of Lagan Cement Ltd. IPPC Licences since
2001. The most recent IPPC Licence review application involving the extension of the quarrying
activities and the use of Liquid Recovered Fuels as an alternative fuel source at the cement facility
has shown that there will be no adverse impacts on the environment as a result of the proposed
developments at the Lagan Cement Ltd facility.
As part of this application, the nature and quantities of emissions from quarrying and cement
manufacture at the installation into all environmental media have been considered. It has been
shown that the existing mitigation measures and the proposed techniques for preventing and/or
reducing emissions from the plant will ensure that Lagan Cement Ltd are capable of and will fully
comply with the legal requirements of the Waste Incineration Directive, the Animal By-product
Regulations and any other relevant legal requirements.
Section A.1: Non-Technical Summary IPPC licence PW87-06 - Review
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