Environmental Protection Agency, Ireland - Accident Prevention & … · 2016. 5. 25. ·...

IEL P0378-02 Review Application May 2016

Attachment J i

Attachment J – Accident Prevention & Emergency Response

Table of Contents

Table of Contents................................................................................................................................................. i J.1 Introduction ............................................................................................................................................ 1 J.2 Environmental Accident Prevention .................................................................................................. 1

J.2.1 Plant Design and Current Accident Prevention Measures ........................................................... 1 Explosion ........................................................................................................................................................ 1 Fugitive Emissions ......................................................................................................................................... 2 Fire Risk .......................................................................................................................................................... 2 Hazardous Materials ...................................................................................................................................... 3 Plant Operation Controls ............................................................................................................................... 3 Material Storage ............................................................................................................................................. 5 Contamination from Fire Water ..................................................................................................................... 5 Environmental Accident Prevention Procedures ........................................................................................... 6

J.2.2 Proposed Plant Measures .................................................................................................................. 7 Meat and Bone Meal Silos .............................................................................................................................. 7 Liquid Fuel Tanks ........................................................................................................................................... 7 Fuel Storage Bay Extension (3 bunkers) ........................................................................................................ 9 Lime Silos ....................................................................................................................................................... 9 Induced Draught (ID) Fan / Calciner Upgrade ............................................................................................. 9

J.3 Emergency Response .......................................................................................................................... 10 J.3.1 Emergency Response Outside Normal Working Hours ............................................................. 10

J.4 Public Liability Insurance .................................................................................................................. 10 Appendices Appendix J.a Emergency Preparedness and Response Procedure

Appendix J.b Public Liability Insurance

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Attachment J 1

J.1 Introduction Quinn Cement has established and maintained procedures to identify the potential

for accidents and emergency situations which theoretically may occur at the

Ballyconnell facility. Quinn Cement currently has a detailed response procedure in

place to react to such situations.

It is considered that this response procedure is adequate and applicable to the

change in the process to reflect the addition of alternative fuels and alternative raw

materials for which this Attachment and the Industrial Emissions Licence

application relates.

The following sections outline the Environmental Accident Prevention Measures

which have been incorporated into the plant design, the written procedures in place

to prevent the occurrence of accidents, and, if an accident or emergency situation

should arise, the written response procedures which are in place in order to action

and remedy the situation.

J.2 Environmental Accident Prevention J.2.1 Plant Design and Current Accident Prevention Measures Consideration was given to the potential for accidental emissions within the original

Quinn Cement Ballyconnell plant design and layout, and also through recent

modifications to the plant to allow storage and combustion of SRF. Specific risks,

and how they are accounted for through plant design, are outlined as follows:

Explosion

Given the nature of pulverised coal, there is an inherent risk of explosion occurring

within the coal mill. The following coal mill design features are present to reduce

this risk:

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Attachment J 2

• All silos are designed for safe mass flow;

• Dust collectors and ducts are designed to prevent an accumulation of dust;

• Continuous monitoring of temperature is undertaken throughout the

system;

• An inert gas injection system is in place;

• Continuous monitoring of carbon monoxide (CO) concentrations is

undertaken;

• Use of a water spray injection system for regulation of temperature in the

coal mill;

• Vacuum breakers in coal meal bin outlets; and,

• Pneumatic shut-off valves at filter inlet and outlet points.

Fugitive Emissions

Enclosed rubber belt bucket elevators are utilised for transportation of materials

between the various unit operations. This transportation method was chosen over

cheaper pneumatic transportation methods such as air-lifts as it reduces the potential

for atmospheric dust emissions occurring as a result of worn pipelines.

Fire Risk

Adequate fire-fighting equipment is provided on site to deal with an emergency

situation. A comprehensive fire detection system is installed in all electrical rooms,

the service tunnel, laboratory, administration buildings and the stores and workshop

buildings. Fire alarm signals are displayed on a panel in the central control room.

The fire risks associated with the storage of SRF has been assessed. Although the

risks are considered to be very low, fire risk may arise from the following:

• Self ignition of SRF; and,

• Spark ignition of SRF.

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Attachment J 3

Self-ignition of the SRF may occur if stored material has not been used for several

weeks and the temperature rises due to biological processes within the SRF.

Spark ignition might occur if a metal component within the material extraction

system is torn off during operation and then creates a spark through contact with the

extractor. Although the nature of the SRF dust is such that it could be easily ignited,

it is not considered that a spark would contain sufficient energy to start a fire.

Despite the fire risks associated with the above being considered to be very low, the

following preventative measures are to be implemented:

• Camera surveillance;

• Heat, CO and flame detectors;

• Sprinklers and water cannon ejector units; and,

• Carbon dioxide (CO2) fire extinguisher and 30m hose reel.

Hazardous Materials

All hazardous material storage tanks are bunded to 110% of the volume of the

largest tank or 25% of the total volume and the bunds are integrity tested on a

regular basis. A record of the testing procedures of the bunds is presented within

Attachment H.1.

Spillage containment kits are located in close proximity to all oil and hazardous

storage areas.

Plant Operation Controls

Operation of the Quinn Cement Ballyconnell facility is controlled by the latest

edition of the FLS-Automation PLC-based control system with additional supporting

control and supervision system. This includes the following control systems:

• Fuzzy Expert Kiln Control;

• Fuzzy Expert Kiln Start-up;

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Attachment J 4

• Fuzzy Expert Cooler Control;

• Cem-Scanner and Refractory Management; and,

• Emission Monitoring, Control and Analysis System.

The Fuzzy Expert Kiln Start-up and Kiln Control ensures the maximum surveillance

of, and control over, the clinker production department i.e. Kiln Feed, Preheater with

Calciner, Kiln, Fuel Firing and Electrostatic Precipitator. Reference should be made

to Attachment F.1 for a more detailed description of the FLS-Automation control

system.

The main advantage of the supervisory control systems is its ability to immediately

respond to any deviation from the set control-points. As a result, any unstable

conditions can be brought under control at an early stage and thus act as a

preventative measure for any serious deviation in operational activity, such as

significant emissions release. An example of the FLS-Automation PLC-based control

system is the CO monitoring on the Electrostatic Precipitator, which automatically

shuts the process down when a CO concentration of 1.2% is monitored within the

exhaust flue gas. The control system reacts accordingly and terminates the process to

avoid an increase in the emission of CO.

Stop and start sequences are programmed in a safe and emission free manner. In the

event of faults or emergency situations, the control system completes a pre-

programmed stop procedure which is designed to minimise danger to the plant

equipment, personnel and the environment.

The control system incorporates alarm systems, which are normally activated in two

stages:

• Sounding of an alarm; and,

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Attachment J 5

• Cessation of equipment involved in the process where the error has been

identified, followed by a sequential cessation of interlinked equipment

subsequent to the process identified as experiencing the error.

All the alarms are audible and visually shown on the maintenance screens and are

printed in the alarm reporting system. Furthermore, the system allows for the

possibility of logging trend curves which assists in diagnosing the cause of the

alarm. This information can then be used for prevention against a repetition of

similar situations.

In most instances there is a sufficient time delay between the two alarm levels for the

automatic control system and/or the operator to take corrective action, and thereby

avoiding a situation where stoppage will occur. The operation of the control system

is supervised by process controllers, employees who are specially trained in the

operation of the cement making process. Specific written instructions for the control

system operation are made available in the central control room.

Material Storage

The material storage facilities are outlined within Attachment H.1. All hazardous

material storage tanks are bunded to 110% of the volume of the largest tank or 25%

of the total volume and the bunds are integrity tested on a regular basis.

Contamination from Fire Water

The surface water management system is designed to provide adequate provision

for fire-water run-off. The site has a natural inclination of 2.5% in the north/south

direction and 1.5% in the west/east direction in order to ensure drainage into the

correct system. The majority of the site drainage system is an open concrete trench

system covered by metallic grates, although there are a number of manholes on site.

The drainage system is connected to a settlement tank with a capacity of 5,400m3

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Attachment J 6

which allows for a two-hour retention time during peak rainfall, before discharge to

the Woodford River.

The Applicant is proposing to use the water from this settlement tank for the cement

manufacturing process, which would reduce the discharge rate to the Woodford

River. The water from the settlement tanks will be recycled back into the cement

manufacturing process through a proposed Surface Water Recycling Tank (SWRT),

thereby reducing the process water requirements from on-site boreholes.

Furthermore, it is proposed to install a separate Fire Water Retention Tank (FWRT)

with a capacity of 100 m3. In the event of a fire, the water discharge from the site can

be directed to this tank by opening a valve, which directs the water away from the

existing settlement tanks, through a bypass line, to the proposed FWRT. This

proposal will significantly reduce the potential volume of firewater to be disposed of

in the event of a fire or spillage accident on site.

A description of surface water emission abatement employed at the Quinn Cement

Ballyconnell facility is presented within Attachment F.1.

Environmental Accident Prevention Procedures

Quinn Cement have written procedures in place for prevention of environmental

accidents which are contained within the company Environmental Management

System (EMS).

The objective of the written procedures are to prevent the likelihood of

environmental contamination occurring. Should an environmental incident occur,

there are written procedures in place to prevent the incident from recurring.

A copy of the emergency preparedness and response procedure is contained within

Appendix J.a.

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Attachment J 7

J.2.2 Proposed Plant Measures

The following outlines the measures, in order to control the potential of an

accidental emission or spillage, for each item of plant being proposed to allow for the

use of an expanded range of alternative fuels. Meat and Bone Meal Silos Transport & Discharge:

• Meat and Bone Meal (MBM) is a dried sterilised material produced in

rendering facilities from animal tissue not used in food production. Only

MBM from Department of Agriculture approved rendering facilities will be

accepted at the cement plant. The MBM will have a low moisture content

(<10%) and will be of a uniform size.

• Transport to the cement plant will be via enclosed road tankers.

• Discharge from the road tanker to the 2 No. storage silos will be by a

pneumatic sealed system incorporating filtration to control the potential for

dust and odour emissions during the discharge process.

Storage & Feeding:

• The material in the storage silos will be fed via an enclosed transport system

to the kiln system for combustion.

Liquid Fuel Tanks Transport & Discharge:

• Liquid Fuels will include Secondary Liquid Fuel (SLF) which is a blend of

organic and solvent wastes blended to a defined specification as well as liquid

fuels derived from other sources (e.g. waste oils).

• The main source of SLF is solvents from the pharmaceutical industry. Other

industry sources also produce a variety of high calorific ingredients which are

suitable for blending.

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Attachment J 8

• Specialist waste management companies collect and blend these ingredients

to the fuel specification for the kiln system.

• The SLF will then be delivered by these specialist waste management

companies to the cement plant via enclosed road tankers.

• In order to prevent spillages during discharge, the liquid fuels will be

discharged via a closed system to on site storage tanks.

• Furthermore, the storage tanks will be located within a bunded compound.

Storage & Feeding:

• A blanketing gas suppression system will be installed as a fire prevention

method.

• The tanks will be built and installed to the manufacturers specification.

• Bunding will be in compliance with EPA requirements and bunds will be

regularly inspected. The bunded compound will be integrity tested as per

other bunds on site.

• The liquid fuels will be pumped from the storage silos to the kiln system via a

closed loop system thereby ensuring minimal risk of spillage.

• For the unlikely event of a fuel spillage a response plan has been proposed as

part of the Emergency Response Procedure for the site.

• All areas between the bunded storage compound and the kiln system will be

of an impermeable hardstand construction.

• The bunded compound will be covered in order to limit the potential for

rainwater ingression into the bund. This will ensure that contaminated water

generation is limited insofar as practicable. Any contaminated water will be

disposed of as hazardous waste.

• The storage tanks will be fitted with a high level alarm to prevent overfilling.

• Spill kits will be available on site and all leaks or spills will be cleaned up

immediately.

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Attachment J 9

Fuel Storage Bay Extension (3 bunkers) Transport & Discharge:

• Solid Fuels such as Solid Recovered Fuel (SRF), woodchip and Tyre Derived

Fuel (TDF) will be produced to an agreed specification by authorised

suppliers.

• Transport to the cement plant will be via tipper trucks or walking floor

trailers which will deliver to the fuel storage bunkers, via a feeder and drag

chain system.

Storage & Feeding:

• The proposed storage system is the same as the current system with an

additional three bunkers.

• The storage bunkers will be equipped with mechanical and pneumatic

feeding system to allow for flexibility in the delivery of the alternative fuels to

the kiln system for combustion.

Lime Silos

Quinn Cement is currently adding hydrated lime manually to the kiln feed to reduce

SO2 and HCl emissions. Two storage silos and an automatic feeding system are

proposed as part of this planning application which will optimise the hydrated lime

addition.

Induced Draught (ID) Fan / Calciner Upgrade

The proposed ID Fan and Calciner upgrade are not considered to have the potential

for accidental emission or spillage. These items of equipment are not storage related

and are items of process equipment central to the combustion environment.

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Attachment J 10

J.3 Emergency Response Quinn Cement have written procedures in place for emergency response which are

contained within the company EMS, as presented within Attachment C.2.

A copy of the emergency preparedness and response procedure is contained within

Appendix J.a.

J.3.1 Emergency Response Outside Normal Working Hours

The cement manufacturing process at Quinn Cement is 24 hours a day/7 days per

week. The site is therefore constantly occupied. Emergency response procedures

take account of these operating timeframes.

J.4 Public Liability Insurance Quinn Cement Ltd. which is a subsidiary company of Quinn industrial Holdings

Ltd. is adequately covered by public liability insurance to the sum of €13,000,000. A

copy of the insurance certificate is contained within Appendix J.b.

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Appendix J.a Emergency Preparedness and Response Procedure

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QQuuiinnnn CCeemmeenntt –– EEnnvviirroonnmmeennttaall MMaannaaggeemmeenntt

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Emergency Preparedness and Response Auth: CL Created by: Quinn Cement – May 2010 Revision: 2.9 Revised by: Quinn Cement – April 2016 Page 1 of 17

Emergency Preparedness and Response EMP009 1.0 Purpose

To establish and maintain procedures to identify potential for and response needed to react to accidents and emergency situations, and for preventing and mitigating the environmental impacts that may be associated with them. Also to minimise the impact on the Cement Division and to minimise the impact to personnel on site, and those on adjoining sites. This procedure covers the various steps to be followed in the event of an emergency evacuation, occupational accidents/incidents and environmental accidents/incidents.

2.0 Responsibilities The Divisional Manager is responsible for developing the plan details, providing the necessary infrastructure, and implementing the necessary training and organising evacuation drills. The Divisional Manager or his delegates will also act as the Emergency Controller in the event of an incident or emergency situation.

The Health and Safety Advisor is responsible for ensuring that an adequate emergency preparedness and response plan is in place and that all employees are familiar with its requirements. The Health and Safety Advisor is responsible for ensuring that the following information is up to date and easily accessible: • MSDS folder (\\srv-netapp01\Cement\DATA FOLDERS\MSDS) • Drawings showing plant layout • Map showing location of emergency equipment

The Emergency Response Team consists of:

• Members of Management • Health and Safety Advisor • Environmental Advisor • Supervisors • First Aiders • Fire wardens • Reception personnel • Emergency Services

The Emergency Response Team has various duties which are detailed below.

The Environmental Advisor is responsible for ensuring this procedure is followed in the evident of accident or incident when there is a potential risk to the environment.

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3.0 Instructions 3.1 AN EMERGENCY EVACUATION

In the event of a fire, explosion or other event that might necessitate an evacuation,

the fire alarm will either be activated automatically or be initiated by the Management who is responsible for co-ordinating the evacuation and communication with the external services or by the employee who is first made aware of the problem.

In the event of an evacuation situation it is the responsibility of management to

ensure that the following lists of priorities are followed:

• Safety and welfare of all employees (evacuation and first aid) • Minimise damage to equipment, property and the environment • Minimise loss of materials

On hearing the alarm a member of management must assess whether it is an actual evacuation or a “false alarm”. The Emergency Controller (Quinn Cement Management) must proceed to the area and assess the nature of the emergency or liaise with Control Room personnel who will have information on the location of the alarm.

3.1.1 Emergency Controller He/she must then decide on appropriate action i.e.;

• If it is a false alarm either cancel the alarm or treat like a drill. • Deal with the emergency in-house e.g. use of fire fighting equipment. • Contact the emergency services. • Assign a responsible person to await the arrival of the emergency services at the

weighbridge so to advise on the location of the accident/incident. • The Emergency Controller must liaise with; the Supervisor on duty, to establish

a head count, with emergency services to give details to them on last locations of unaccounted personnel, and the First Aider on duty, if there are any injuries.

• Consult with the emergency services to give the all clear to re-enter the building.

• Convene and chair de-briefing and investigation into the incident. • In the event of an environmental incident, the Emergency Controller must give

instruction to shift supervisor to shut off valves at settlement tank for surface water retention.

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3.1.2 Health & Safety Advisor

• On hearing the alarm evacuate the building via the nearest safety emergency exit.

• Report to your assembly point for head count. • Report headcount to a member of management • Prioritise the injured and co-ordinate the first aiders that report to the area. • Give additional first aid to those that require attention (if trained to do so) and

give assistance to the first aiders. • When the medical services arrive brief them as to the names of the injured, the

extent of the injuries and the type of first aid given on site. • Notify the families of injured persons of the extent of their injuries and their

location. • When any injured persons have been accounted for and treated the HSE

Advisor/Supervisors must prepare statements for the senior managers as to the extent of the emergency.

• Access MSDS folder and provide relevant MSDS to a member of management to give to the emergency services

3.1.3 First Aiders On hearing the fire alarm the certified first aiders should:

• Evacuate the building via the nearest safest exit taking with you the first aid box for the area, go to your designated assembly point and report to your supervisor/manager as a first aider.

• Then report to the Emergency Controller for further instructions. • Provide immediate first aid to any injured persons, prioritising their needs. • Report to the Health and Safety Advisor re: extent of injuries or if additional

medical assistance is required.

List Of First Aiders On Site

Name Contact

Michael McLoughlin 5375/Radio Sean Cooke 5375/Radio

Eamon Leonard 5375/Radio

Hubert McCaffrey 5375/Radio

Ciaran Traynor 5375/Radio

Kyle Warnock 5375/Radio

Pat Lunney 5375/Radio

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Martin Brady 5375/Radio

Paulius Sinskas 5375/Radio

Paddy Moran 5375/Radio

Gerry Gumley 5375/Radio

Martin McDermott 5375/Radio

Eamon McGovern 5375/Radio

Martin McKillion 5375/Radio

3.1.4 Reception/Administration Personnel

It is the responsibility of those at Reception to undertake the following duties: • Bring with them the Visitor sign in Log • Direct guests and personnel in the lobby outside to assembly areas • Check the meeting room, reception lobby and toilets –Office Fire Warden. • Report to assembly area and determine if all visitors have been evacuated. • Report any problems to Supervisors. 3.1.5 Fire Wardens • The Fire Wardens follows any instructions given by the Quinn Cement management

controlling the emergency. • Upon hearing the alarm the fire warden should: • Conduct a thorough search of his/her designated area, provided it is safe to do so,

following the search pattern below carefully ; • Check that all persons have evacuated his/her section • Check that nothing is left in a dangerous condition • Close all fire doors if possible • On completion of the search immediately report findings to management member

at assembly points. • Attend de-briefing meeting when convened.

The trained fire wardens on site are as follows;

Trained Fire Warden 1. Eamon Leonard 2. Pearse West 3. Martin McDermott 4. Sean Cooke 5. Vaidas Martisius 6. Ciaran Traynor 7. Hubert McCaffrey

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8. Brendan McKiernan 9. Garry McGrade 10. Brian Earley 11. Paddy Moran 12. Eamon McGovern 13. Greg Cassidy 14. Michael McLoughlin 15. Michael Rowan 16. Pat Lunny 17. Paul Tracey 18. Philip Kelly

3.1.6 Supervisors • Ensure that all staff in the department is familiar with their responsibilities under this

procedure. • Be aware of absences from your area during a normal working day. • Ensure the visitors book has been retrieved from reception. • Ensure that all in your area evacuate safely and successfully. • Conduct a head count at the assembly point. • Follow any additional instructions given by management. • Report to management either: that everyone in the department is accounted for or the

names and last known location of anyone not accounted for. • In the event of an environmental incident, the supervisor must shut off valves at

settlement tank for surface water retention on instruction from the Emergency Controller.

N.B. In the event of an Emergency Evacuation outside of normal working hours the Production Supervisors must take on the responsibilities of the Emergency Controller and the Health and Safety Advisor. 3.1.7 Employees Personnel who discover a fire or other emergency that necessitates an evacuation should: • Raise the alarm by activating the break glass unit at the nearest alarm call point or

contact the control room. • Leave the building via the nearest emergency exit and proceed to their designated

assembly point.

3.1.8 On hearing the alarm, personnel must: • Immediately leave the building via the nearest emergency exit in an orderly manner. • Chairs must be replaced at workstations do not block the evacuation path of others and

keep aisles clear. • Do not collect personal belongings.

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• Shut off equipment unless it is hazardous to do so or time consuming. • Walk -do NOT run and provide assistance to any disabled staff member/visitor. • Ensure that visitors are escorted off the premises in an orderly fashion. • Close all doors behind you-but do not lock them. • Do not use the lift to evacuate-use stairways only. • Touch doors with the back of your hand before opening them-do NOT open a door if it

is hot. • If you encounter thick smoke, stay close to the floor. Crawl if necessary. • Proceed to their designated assembly point and remain there while awaiting further

instructions. There will be a Safety Team Member there in charge of the situation. • Smoking is strictly prohibited during the evacuation • Follow the instructions of the Emergency Response Team. • Re-enter the building ONLY with the consent of management. 3.1.9 Contractors

It is the responsibility of the contractor to: • Know who is working for him on site at any given time • Ensure his employees are familiar with the exits • Know the designated assembly point for contractors • Account for his employees during the evacuation

On hearing the alarm contract employees should: • Shut off your equipment unless it is hazardous to do so • Proceed promptly in an orderly manner to the nearest suitable exit and go to the

assembly point • Do not attempt to gather personal belongings, carry any personal items or smoke at any

time during the emergency • Immediately upon your arrival at the assembly point report to your supervisor • Under no circumstances do you leave the safe area or attempt to re-enter the building

unless the all clear has been given 3.2 Medical Emergency

Personnel who come upon a medical emergency where urgent medical attention is needed, should proceed as follows: • Call the emergency number (5375 New Cement Control Room)/ (2338 Old Cement

Control Room) and request a First Aider or emergency services or else call 999 immediately). Lists of personnel who are certified in First Aid are posted throughout the facility.

• Leave your name and the location of the person needing attention. Give brief details of the situation to the operator.

• Send someone nearby to guide the first aiders or emergency services to the area. • Stay with the injured person and reassure them until a First Aider arrives.

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• First Aid personnel will administer or decide if medical services such as the HSE Advisor, doctor or an ambulance need to be called.

3.2.1 Occurrence of a minor Accident/Incident on site In the event of an occupational accident /incident occurring on site all employees must carry out the following; • Raise awareness of accident/incident* • Request First-Aid assistance • On completion of first aid report to Supervisor/Manager • Fill in all details of accident/incident on the appropriate forms • Submit form to HSE Advisor for record *If you are involved in the accident/incident alert another member by staff. All injuries and incidents must be reported to a supervisor. 3.3 Occurrence of incident at Neighbouring site In the event of an incident at a neighbouring site which necessitates an evacuation of the Quinn Cement site, this procedure should be followed. Should access to the site is compromised. The site can be evacuated via the mountain haul road. Where possible Quinn Cement will provide assistance at neighbouring sites while ensuring the Health & Safety of our staff is not compromised.

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Environmental Emergencies Only after the protection of human health and safety is assured can attention be focused on the Environmental requirements. The main Environmental Emergencies are identified by means of the Environmental Aspects most likely to give rise to Emergency conditions. These are:

• Fire/ Explosion • Dust Spill • Oil/Liquid Fuel/Chemical Spill

3.4 Fire/ Explosion • On detecting a fire the Health and Safety requirements detailed in Section 3 of this

document should be followed. Following this, after the area has been made safe, environmental considerations must be taken into account. The main action in the event of a fire is fire water retention.

• Fire water can have a significant environmental impact on surface water therefore fire

water containment is very important. Where possible surface water drains should be sealed off and fire water should be diverted to a containment area. If there is no feasible containment area on site fire water should be diverted to the Settlement tank through the Surface water drains. In this situation the shift supervisor is responsible for cutting off the discharge from the settlement tank in order to contain the fire water.

• For full details on cutting off the discharge from the settlement tank see EMP035 –

Settlement Tank Shut-off Procedure. • The settlement tank is a horizontal flow settlement tank of capacity 4,725 to 5,400m3

which allows for a two hour retention time during peak rainfall. There is an average discharge from the tank of between 10 – 20m3.hr-1. The tank incorporates a single compartment oil interceptor which has a volumetric capacity of 450m3, thus ensuring that any significant quantities of oil included within the site effluent that have occurred as a result of vehicular movement or minor spills are recovered for disposal prior to discharge into the existing water course.

• In the event of a fire or explosion the EPA/EA should be contacted without delay in

order to report the incident in accordance with Licence or Permit conditions and when necessary to seek advice on environmental precautions. See EMP016 - Environmental Incident Recording & Reporting Procedure. When the Environmental Advisor is not available for this duty the Shift Supervisor is responsible for contacting the relevant Competent Authority – see contacts in Emergency contacts list.

• Following a fire the contained fire water should be disposed of through a licenced

waste contractor in accordance with the Waste Management Procedure.

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• All incidents should be reported to the Environmental Advisor to allow recording and reporting procedures to be followed.

3.5 Dust/material Spill • For full details see EMP018 - Dealing with Dust/Material Spills Procedure. • On detecting a spill employees must inform their Supervisor of the spill, give details on

location, magnitude etc, • The Supervisor informs the Process Production manager who sends the site

maintenance team to the spillage. • If the dust is cold, the industrial vacuum unit is used to clean up spill. • If the dust is hot, water is used to cool and dampen the material before cleaning. • The excess dust/material is then recycled back into the process.

• All alternative fuels hauliers are required to control and tidy up spillages should they

occur immediately. All spillage shall be returned to the appropriate storage bay. • The supervisor submits details of the dust spill to the Environmental Advisor, who

reports it to the EPA. Incidents are reported in accordance with EMP016 - Environmental Incident Recording & Reporting.

3.6 Oil/Liquid Fuel/Chemical Spill • For full details see EMP017 - Spills Management and Clean-up Procedure • All major oil spills will require immediate containment, therefore all locations where

oil is stored is adequately bunded, to prevent spill from spreading and contaminating other locations on site.

• In the event of a major spill, the spill is controlled and contained as best as is

reasonably practicable, using the spill kits provided on site. • Where containment of the spill is not possible or has failed, the settlement tank can be

closed off to contain the spill and prevent oil reaching the Surface water discharge point.

• The spillage remains contained in an appropriate manner until ultimate disposal by an

approved waste contractor.

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• In event of a risk to the surrounding waterways the relevant Authority should be

contacted without delay – contacts are listed in Emergency Contact list. • Minor oil spills can be absorbed by using sand, absorbent materials or proprietary

granules. All absorbents used to clean up a spill major or minor are treated as hazardous material are stored appropriately prior to removal by an approved waste contractor.

• The chemical spill kit is only for use for ammonia spills in the SNCR building. Appropriate PPE should be worn.

• All incidents should be reported to the Environmental Advisor who in turns reports to the EPA in accordance with EMP016 - Environmental Incident Recording & Reporting.

Spill Response Team

Paul Prior Pauric McGovern Gerry Gumley Dermott Lyttle Damien McNamee Niall Faye Pat Lunney

3.7 ESP Trips • The control room system notifies the operator of an electrostatic precipitator (ESP) trip. • The cause of the trip is immediately identified, rectified and the Precip is restarted. • As of licence/permit conditions the plant will be shut down should a trip last longer

than 30 minutes. • ESP trips are recorded on CO/ESP Trips Form and reported to the Environmental

Advisor who in turns reports to the EPA in accordance with EMP016 - Environmental Incident Recording & Reporting.

3.8 Reporting and Recording • All incidents should be reported to the Environmental Advisor who in turn is

responsible for reporting to the relevant Competent Authority in accordance with Licence/Permit conditions and with EMP016 - Environmental Incident Recording & Reporting.

• The Environmental Advisor is also responsible for completing and Incident Report following such an incident.

• All incidents will be subject to a post-accident evaluation to establish and implement corrective and preventative actions

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4.0 Fire Procedure SRF Plant

In the event of a fire breaking out on any area or plant equipment relating to SRF (solid recovered fuel) the following steps should be taken

• If you are located within this area activate the nearest emergency stop or plant stop to stop transport system

• Sound the fire alarm within this area by activating the nearest break glass on the fire system

• Contact the central control room immediately and inform them of the location

• Control room to stop all transport equipment related to SRF plant and inform all personnel on site of the situation

• Call Fire Brigade

• There are number of steps that can be taken to try and contain fire within these areas.

Below is a photo of manual valves that are located beside main water tank

By opening reception manual valve this will spray water into Drag chain conveyor D1J11M1

By opening transport manual valve this will spray water into Drag chain conveyor D1J12M1

By opening bunker manual valve this will spray water into Reject Screen D1S12M1-D1S12M2 and Drag Chain Conveyor D1J13M1.

(Located at water treatment tank)

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Firefighting pump (D1K14M1) is water suppression to bunkers 1- 4 This will operate once a fire is detected in each bunker automatically; all alarms and operations can be viewed on the alternative fuel mimic on control system. (Water Suppression to SRF bunkers layout)

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D1L15 Bunker 1Reject Screen Area

D1L16 Bunker 2 Water Valve'sWater Tank

D1L17 Bunker 3 pumpD1K14M1 Water Treament Supply

D1L18 Bunker 4

Preheater Tower

Currently our fire detection and protection systems are under review and will be upgraded over the next few months.

It is with the up most importance that all general faults and alarms are investigated and rectified in order to maintain fire protection in all areas

5.0 Review The Emergency Preparedness and Response Procedure is live document. It is designed to be open for any discussion and changes whenever it is required to do so. The emergency response plan shall be reviewed and immediately amended whenever: • The plan fails in a drill or real emergency; • The facility changes in its design, construction, operation, maintenance, or any other

circumstances in a way that increases or changes the potential for fire, explosions, release of a hazardous substance or energy;

• The list of emergency contacts change; • A review of the Emergency Plan will be undertaken immediately after evacuation drills or after

an incident. 6.0 Testing • There will be an emergency drill carried out at least every three years. Records of such

drills will be maintained.

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Emergency Numbers Emergency Controllers: Ballyconnell TP Feehan 5243 (087- 7102266) Damien Reilly 5293 (087-2508937 ) Pat Lunney 5257 Paul Carron 5260 Production Supervisors 5375 ( CCR) Weighbridge 5219 Control Room 5275/5375 Derrylin Production Office 2708 Maintenance Office 2384 Production Managers office 2705 Electrical Manager office 2700 Production Supervisors 2325 ( CCR) Weighbridge 2215 Control Room 2338 Donal Kelly 5309 Colin Lunney 5212 Reception 0 Emergency Services Emergency Services 999/ 112(Republic only) Doctors Surgery (Ballyconnell) 049 - 952-2642 Dr. Kirby (Derrylin) 028/048 - 6774-8250 Enniskillen Hospital 028/048 - 6632-4711 Cavan Hospital 049 - 437-6000 Fire Brigade (Ballyconnell) 049 - 9526120 Fire Brigade (Enniskillen) 028/048 – 6634-6946 Gardai (Ballyconnell) 049 – 952-6102 PSNI (Enniskillen) 028/048 - 6632-2823 Fr. McMorrow (Teemore) 028/048 - 6774-8266 Fr. Kiernan (Derrylin) 028/048 - 6774-8315 Rector George (Davison Derrylin) 028/048 - 6774-8994 EPA - Fire 053-9160600/ 1890 335 599 Cavan County Council 049 4378486 ENVA – Major Oil Spill 057-8678600/ 1850 504 504 Health & Safety Authority 1890 289 389 / 0906 435599 028 from within Northern Ireland, 048 from within the Republic

Assembly Points Ballyconnell Assembly Point No.

Location Areas Serviced

1 Main Car Park Main building, workshop, canteen, raw mill, kiln area, coal mill, general area at top of the site.

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2 Outside Drivers Canteen

Cement Mill, Bagging Plant, PFA silo’s, Bulk cement Silo’s, Drivers canteen, General area to the bottom of the site

3

Front of Weighbridge Weighbridge, Incoming & Outgoing Lorries/Traffic.

4 Outside Crushing Plant General Area around Crusher

Assembly Points Derrylin Assembly Point No.

Location Areas Serviced

1 Main Car Park Cement Mill, Bagging Plant, PFA silo’s, Bulk cement Silo’s, Drivers canteen, General area to the bottom of the site

2 Outside Workers Canteen

Control Room Building, workshop, canteen, raw mill, kiln area, coal mill, general area at top of the site.

3

Front of Weighbridge Weighbridge, Incoming & Outgoing Lorries/Traffic.

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Emergency Preparedness and Response Auth: CL reated by: Quinn Cement – May 2010 Revision: 2.9 evised by: Quinn Cement – April 2016 Page 16 of 17

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7.0 Related Documents • Incident Log • Register of Bunds • Bund Draining Procedure • Delivery of Oils and Liquid Fuels • Spills Management and Clean-up • Dealing with Dust or Material Spills • Settlement Tank Shut-off Procedure • Training records • MSDS master list • First Aid Guidelines • Environmental Incident reporting and Recording • Incident report

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Appendix J.b Public Liability Insurance

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Karolina Sikorska ACII Client Advisor

Marsh Ireland 25-28 Adelaide Road Dublin 2 Ireland 353 1 604 8130 Fax 353 1 6048174 [email protected] http://www.marsh.ie

Directors: J.V. Barker (British), P.J. Box (British), M.C. Chessher (British), G.E. Davies (British), N.C. Frankland (British) J.C. Grogan (Irish), C.F. Kiddie (British), C.J. Lay (British), J.J. Nicholson (British), D. Pigot (British),

M.A. Weil (British), R.I. White (British), Marsh Ltd is a private limited company registered in England Number: 1507274, Registered Office: 1 Tower

Place West, Tower Place, London EC3R 5BU VAT number: IE 6333592O Marsh Ltd is registered as a branch in Ireland under reference 906457. Marsh Ireland is a trading name of

Marsh Limited Marsh Ltd, trading as Marsh Ireland, is authorised by the Financial Conduct Authority in the UK and is regulated by the Central Bank of Ireland for conduct of business rules.

TO WHOM IT MAY CONCERN

22 December, 2015

CONFIRMATION OF INSURANCE: Quinn Industrial Holdings Ltd & Subsidiary Companies

Dear Sirs,

As requested by the above client, we are writing to confirm that we act as Insurance Brokers to the client

and that we have arranged insurance(s) on its behalf as detailed below:

Classes of Insurance: Combined Liability, Motor (ROI & UK/NI) and Contractors All Risk.

Combined Liability

INSURER:

POLICY NUMBER:

PERIOD OF INSURANCE:

AIG

LMA42196

23rd

December 2015 to 22nd

December 2016, both dates

inclusive.

LIMIT OF INDEMNITY :

Employers Liability:

EUR13,000,000/STG10,000,000 any one event/unlimited

any one period;

Public Liability:

EUR13,000,000/STG10,000,000 any one event/unlimited

any one period;

Products Liability:

EUR13,000,000/STG10,000,000 any one occurrence and

in the aggregate in respect of Products Liability.

Motor Fleet – Republic of Ireland

INSURER:

POLICY NUMBER:


Zurich

59FMV5904573

23rd



inclusive.

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THIRD PARTY PROPERTY DAMAGE


DEDUCTIBLES:

Private Cars: EUR30,000,000

Commercial Vehicles: EUR6,500,000

Private Cars/Vans/ CVs 3.5T and below: EUR500 each and

every own damage, fire and theft and windscreen claim;

Heavy Goods Vehicles & Trailers: EUR10,000 each and

every fire and theft claim;

Third Party Excess: NIL.

Motor Fleet – UK/NI

INSURER:

POLICY NUMBER:


Zurich

7107607

23rd



inclusive.

THIRD PARTY PROPERTY DAMAGE


DEDUCTIBLES:

Private Cars: GBP20,000,000

Commercial Vehicles: GBP5,000,000

Private Cars/Vans/CVs 3.5T and below: GBP500 each and


Heavy Goods Vehicles & Trailers: GBP10,000 each and


Third Party Excess: NIL.

Contractors All Risk

INSURER:

POLICY NUMBER:


NMU

EAA151434210

23rd



inclusive.

SUM INSURED ON PERMANENT

TEMPORARY WORK :

EXCESS:

EUR5,000,000

EUR10,000 each and every claim

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We have placed the insurance which is the subject of this letter after consultation with the client and based

upon the client’s instructions only. Terms of coverage, including limits and deductibles, are based upon

information furnished to us by the client, which information we have not independently verified.

This letter is issued as a matter of information only and confers no right upon you other than those provided

by the policy. This letter does not amend, extend or alter the coverage afforded by the policies described

herein. Notwithstanding any requirement, term or condition of any contract or other document with respect

to which this letter may be issued or pertain, the insurance afforded by the policy (policies) described herein

is subject to all terms, conditions, limitations, exclusions and cancellation provisions and may also be

subject to warranties. Limits shown may have been reduced by paid claims.

We express no view and assume no liability with respect to the solvency or future ability to pay of any of the

insurance companies which have issued the insurance(s).

We assume no obligation to advise yourselves of any developments regarding the insurance(s) subsequent

to the date hereof. This letter is given on the condition that you forever waive any liability against us based

upon the placement of the insurance(s) and/or the statements made herein with the exception only of wilful

default, recklessness or fraud.

This letter may not be reproduced by you or used for any other purpose without our prior written consent.

This letter shall be governed by and shall be construed in accordance with Irish law.

Yours faithfully,

Karolina Sikorska ACII

Marsh Ireland

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Attachment K i

Attachment K – Remediation, Decommissioning, Restoration &

Aftercare Table of Contents

Table of Contents................................................................................................................................................. i K.1 Closure, Restoration and Aftercare Management Plan (CRAMP) ............................................... 1 K.2 Environmental Liabilities Risk Assessment (ELRA) ...................................................................... 1

Appendices Appendix K.1 Closure Restoration and Aftercare Management Plan (CRAMP) Appendix K.2 Environmental Liabilities Risk Assessment (ELRA)

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Attachment K 1

K.1 Closure, Restoration and Aftercare Management Plan (CRAMP) A Closure, Restoration and Aftercare Management Plan (CRAMP) as agreed with the

Agency is provided in Appendix K.1. It is proposed to update this CRAMP, as part of

the test programme to be agreed with the Agency, prior to the commencement of

acceptance of new alternative fuels and alternative raw materials at the site.

K.2 Environmental Liabilities Risk Assessment (ELRA) An Environmental Liabilities Risk Assessment (ELRA) as agreed with the Agency is

provided in Appendix K.1. It is proposed to update this ELRA, as part of the test

programme to be agreed with the Agency, prior to the commencement of acceptance

of new alternative fuels and alternative raw materials at the site. A copy of the

financial provision that covers the liabilities in the ELRA has been provided in

Appendix C.4 of Attachment C.

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Appendix K.1 Closure Restoration and Aftercare Management Plan(CRAMP)

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LICENCE REFERENCE No. Closure Plan REPORT VERSION

P0378-02 Stage 1 Step 1 Final

Closure Plan

Quinn Cement Ltd.

Ballyconnell, Co. Cavan

August 2014

P0378-02

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Closure Plan

Quinn Cement P0378-02

2 21st

August 2014

50410

Final

Project Title: Closure Plan

Licence No.

Project No:

P0378-02

50410

Contract No. 50410

Report Ref: Closure Plan

Status: Final v2

Client: Quinn Cement Ltd.

Client Details: Quinn Cement Ltd., Ballyconnell, Co. Cavan

Issued By: Verde Environmental Consultants Ltd. F27 Bullford Business Campus, Kilcoole, Co. Wicklow

Document Production / Approval Record

Name Signature Date Position %

Input

Prepared by

(consultant) Debbie Good

20th

August

2014

Senior

Consultant 70

Approved by

(consultant) Cian O’Hora

21st

August

2014

Project

Manager 30

Site Approval by

Michelle Cass 21st

August

2014

Environmental Advisor

N/A

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Closure Plan


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Final

TABLE OF CONTENTS

1.0 INTRODUCTION ........................................................................................................................... 7

1.1 SITE DESCRIPTION ...................................................................................................................................... 7 1.2 COMMENCEMENT OF OPERATIONS................................................................................................................. 7 1.3 CLASS OF ACTIVITY LICENSED ........................................................................................................................ 7 1.4 LICENCE REQUIREMENTS .............................................................................................................................. 7

2.0 SITE EVALUATION ...................................................................................................................... 8

2.1 OPERATOR PERFORMANCE ........................................................................................................................8 2.1.1 SITE EMISSIONS ...................................................................................................................................... 9 2.2 ENVIRONMENTAL PATHWAYS AND SENSITIVITY .......................................................................................... 12 2.3 ACTIVITY PROCESSES ............................................................................................................................. 14 2.4 INVENTORY OF BUILDINGS, EQUIPMENT AND PLANT .................................................................................... 17 2.5 INVENTORY OF RAW MATERIALS AND WASTE ............................................................................................. 18

3.0 CLOSURE TASKS AND PROGRAMMES ............................................................................................ 20

3.1 PROGRAMME......................................................................................................................................... 21

4.0 CRITERIA FOR SUCCESSFUL CLOSURE ....................................................................................... 22

5.0 CLOSURE PLAN VALIDATION ......................................................................................................... 22

6.0 CLOSURE PLAN COSTING .......................................................................................................... 22

8.0 FUTURE PROOFING COSTS ........................................................................................................ 30

9.0 FINANCIAL PROVISION .............................................................................................................. 30

10.0 BIBLIOGRAPHY .......................................................................................................................... 30

Figures

Figure 1 Site Location Plan and Sensitive Receptors

Figure 2 Site Layout Plan with Emission and Monitoring Points

Figure 3 Site Layout

Tables

Table 2.1 Surface Water ELVs

Table 2.2 Air Emission Points

Table 2.3 Potential Sensitive Receptors and Distance from Site

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Closure Plan


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Final

Table 2.4 Inventory of Raw Materials, Products

Table 2.5 Inventory of Waste Disposed of for 2013

Table 6.1 Closure Plan Costings

Table 8.1 Cost Adjustment for Inflation

Appendix

Appendix 1 Closure Plan Programme

Appendix 2 Schedule of tanks and bunds

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Final

EXECUTIVE SUMMARY

Activity Details

• Name: Quinn Cement Ltd.

• Address: Scotchtown, Ballyconnell, Co. Cavan

• Licence Number: P0378-02

• Activities Licensed:

o 3.1. Installations for the production of cement clinker in rotary kilns with a production capacity

exceeding 500 tonnes per day or lime in rotary kilns with a production capacity exceeding 50

tonnes per day or in other furnaces with a production capacity exceeding 50 tonnes per day

o 5.2 Installations for the incineration of municipal waste (household waste and similar

commercial, industrial and institutional waste) with a capacity exceeding 3 tonnes per hour

Report Preparation

This report was prepared on behalf of the operator by Verde Environmental Consultants Ltd.

• Address: F27 Bullford Business Campus, Kilcoole, Co. Wicklow

Comparison with Previous Plans

One previous closure/restoration and aftercare management plan was submitted for 2009, as summarised below:

Overview of the Plan

The closure plan has been prepared to satisfy condition 10 of the IED licence. The methodology for the

development of the Closure Plan follows the EPA Guidance Document; Guidance on Assessing and Costing

Environmental Liabilities (EPA 2014).

Scoping

The closure of a site can be defined as ‘clean closure’ or ‘non clean closure’ and the identification of such closure is

based on the presence of pollution or contamination on site. Non-clean closure is described as environmental

liabilities remaining on site following the closure and decommissioning of the facility that require a restoration /

aftercare plan. The closure of the site is based on clean closure therefore only a closure plan is required. Short term

measures have been included to close the site satisfactorily including decommissioning, demolition and residuals

management.

Year Closure and Restoration / Aftercare Cost

2009 €1,900,000

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Closure Plan


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Final

This closure plan is based on a sudden closure with no production wind down period to represent a worst case

scenario.

Cost Summary

The total closure costs have been calculated as €1,540,483(including contingency and adjusted for inflation).

Financial Provision

Quinn Cement will make the necessary financial provision to cover this liability.

Review

This closure plan will be reviewed annually and any updates will be notified to the EPA.

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Closure Plan


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Final

1.0 INTRODUCTION

Verde Environmental Consultants Ltd. (Verde) was commissioned by Quinn Cement Ltd. to update a Closure Plan

for their facility located at Scotchtown, Ballyconnell, Co. Cavan.

1 . 1 S i t e D e s c r i p t i o n

The facility is located approximately 3km north of the town of Ballyconnell (National Grid Reference 227500,

320500) and covers an area of approximately 35 hectares (see Figure 1 for site location). The site is located in an

area of pastoral agriculture with plantation woodland, mineral extraction and large industrial units. The site is

separated from the R205 road by a strip of approximately 250m of pastureland.

1 . 2 C o m m e n c e m e n t o f O p e r a t i o n s

The site was granted planning permission in 1997 for a 1.4M tonne/annum cement facility. Historical OSI aerial

images indicate that in 1995 the site was greenfield agricultural land. The site was issued its first IPPC licence

(P0378-01) in 1998 with the reviewed IPPC licence (P378-02) granted in 2012. The site’s licence was amended to an

Industrial Emissions Directive Licence (IED) by the EPA in January 2014 to bring it into line with the Industrial

Emissions Directive (2010/075/EU).

In accordance with the new IED licence (P0378-02 granted in 2012) modifications in fuel use have taken place on

site in order to substitute a percentage of coal with Solid Recovered Fuel (SRF) at the facility due to commence

end of 2014.

1 . 3 C l a s s o f A c t i v i t y L i c e n s e d

The activity is licensed as follows;

• 3.1. Installations for the production of cement clinker in rotary kilns with a production capacity exceeding

500 tonnes per day or lime in rotary kilns with a production capacity exceeding 50 tonnes per day or in

other furnaces with a production capacity exceeding 50 tonnes per day

• 5.2 Installations for the incineration of municipal waste (household waste and similar commercial,

industrial and institutional waste) with a capacity exceeding 3 tonnes per hour

1 . 4 L i c e n c e R e q u i r e m e n t s

This closure plan includes the proposed closure and decommissioning of the facility and associated infrastructure

of the site. Condition 10 of the IED licence outlines the requirement for a closure plan:

The licensee shall maintain, to the satisfaction of the Agency, a fully detailed and costed plan for the

decommissioning or closure of the site or part thereof. The plan shall be reviewed annually and proposed

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amendments thereto notified to the Agency for agreement as part of the AER. No amendments may be

implemented without the agreement of the Agency.

This report has been prepared to satisfy this condition of the IED licence. The methodology for the development of

the Closure Plan follows the EPA Guidance Document; Guidance on Assessing and Costing Environmental Liabilities

(EPA 2014).

Condition 10 of the IED Licence states that as a minimum the plan shall contain the following:

i. A scope statement for the plan

ii. The criteria that define the successful decommissioning of the activity or part thereof, which ensures

minimum impact on the environment

iii. A programme to achieve the stated criteria

iv. Where relevant, a test programme to demonstrate the successful implementation of the decommissioning

plan

v. Details of the costings for the plan and the financial provisions to underwrite those costs.

This closure plan will focus on the anticipated liabilities associated with a sudden closure and the required financial

provisions for these liabilities.

2.0 SITE EVALUATION

2 . 1 O p e r a t o r P e r f o r m a n c e

Quinn Cement is licensed under IED Licence No. P0378-02 by the EPA, with regard to activities occurring on the site,

which may have an impact on the environment. Quinn Cement complies with the conditions set out in the licence

thus ensuring activities on site have a minimal impact on the surrounding environment. Under conditions of the IED

Licence, all emissions from the site are monitored. In the event that emissions exceed these limits, corrective action

procedures are enforced to prevent such events re-occurring.

Quinn Cement maintains an Environmental Management System (EMS) with full ISO 14001 accreditation which

complies with Condition 2.2 of the IED Licence. A schedule of objectives and targets is maintained and is reviewed on an

annual basis.

A small fire occurred at the base of the Pan Conveyor in May 2010. The Pan Conveyor is located at the centre of

the site and is responsible for transporting clinker from the Grate Cooler building to the Clinker Store. The fire was

discovered by the Production Manager who mobilised the on-site fire team, the plant was immediately shutdown.

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As a precaution the local fire service were contacted. A small amount of foam was used by the fire services in

fighting the fire, there were no emissions to surface water arising from the fire-fighting effort therefore it was

decided by the Environmental Advisor and Plant Management there was no need to shut off the settlement tank

to retain fire water.

There has been no fuel or chemical spills on the site to date.

Quinn Cement was last inspected by the EPA on the 13/10/2013. A number of observations were noted in order to

ensure compliance, improve environmental performance of the facility and provide clarification on certain issues. The

observations related to the co-incineration project, solid recovered fuels specification, baseline monitoring of emissions

to air, environmental liability risk assessment, windsock and bunding. Quinn Cement has addressed all of the

observations raised by the EPA.

There were 15 environmental complaints in relation to the activity in 2013. All of the complaints were in relation to

dust and were investigated immediately. Corrective actions were put in place where deemed appropriate.

Ten environmental incidents were reported during the period of 2013, six in relation to air emission, two in relation to

uncontrolled release, one in relation to CEMs malfunction and one in relation to the 2013 noise survey. Seven

environmental incidents were reported during the period of 2012.

2 . 1 . 1 S i t e E m i s s i o n s

2.1.1.1 Surface Water Emissions

There is currently one emission point for surface water emissions, SW1, which discharges effluent from the site’s

settlement tank via a culvert into a ditch which links some 300m eastwards with the Woodford River (see Figure 2).

Surface water emissions from the site occur as a result of routine wash-down processes and also as a result of

storm water. There is no production water discharged to the settlement tank. As such, there are not considered to

be any harmful or highly toxic constituents present within the effluent.

The entire cement plant site is covered by one catchment area and an extensive drain network diverts all surface

water flow into a settlement tank. The settlement tank is a horizontal flow settlement tank of capacity 4,725 to

5,400m3 which allows for a two hour retention time during peak rainfall. There is an average discharge from the

tank of between 10 – 203/hr. The settlement tank extract solids and oil from the surface water drainage system

before discharge into the Woodford River. The tank incorporates a single compartment oil interceptor which has a

volumetric capacity of 450m3, thus ensuring that any significant quantities of oil included within the site effluent

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that have occurred as a result of vehicular movement or minor spills are recovered for disposal prior to discharge

into the existing water course.

The maximum daily discharge permitted from the site is 10,000m3 and the emission limit values are detailed in

Table 2.1.

Table 2.1 Surface water ELVs

Parameter Emission Limit Values

Temperature 25oC

pH 6-9

Toxicity 1 TU

BOD 10mg/l

Suspended solids 35mg/l

Aluminium 0.2mg/l

Chromium VI 0.03mg/l

Mineral oil 2mg/l

2.1.1.2 Groundwater Emissions

There are currently no emissions to ground within the facility.

2.1.1.3 Emissions to Sewer

Water is used within the cement production process at the Ballyconnell facility; however, no process wastewater is

generated by the site for discharge by sewer. Process water is either reused within a closed cooling system or

discharged to the atmosphere in the flue gases as water vapour. The only emissions to sewer are those of standard

sanitation and cleaning effluent. There are no process related emissions to sewer. There is currently one emission

point for sewer emissions, SE1, which discharges to the main district sewerage system. This sewage emission

point adjoins into the Cavan County Council main sewage system within a manhole located adjacent to the facility

works entrance.

2.1.1.4 Dust Emissions

Given the nature of the cement production process and vehicle movements across the site there is a certain

amount of dust generated on site. A number of dust suppression measures are in operation across the site to keep

dust levels to a minimum.

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Dust emissions are monitored at five locations across the site as illustrated on Figure 2. The dust emission limit

value for the site is 350mg/m2/day.

2.1.1.5 Noise Emissions

The cement plant operates on a continuous basis, 24-hours a day, 330-days per year. The cement plant equipment

consists of heavy industrial type machinery and there are multiple heavy vehicle movements associated with the

site. Therefore there are a considerable number of potential noise sources.

Noise monitoring takes place annually at the locations illustrated on Figure 2 and the limits are 55dB(A) Daytime

and 45dB(A) Night-time.

2.1.1.6 Emissions to Air

There are five major air emission points on site (see Figure 2 for locations) as follows:

Table 2.2 Air Emission Points

Identifier Source Pollutants Abatement System

A2-01 Raw Mill/Kiln Sulphur dioxide

Oxides of nitrogen

Particulate matter

Total Organic Carbon

Hydrogen chloride

Hydrogen fluoride

Cadmium and Thallium

Mercury

Metals (Antimony, Arsenic, Lead,

Chromium, Cobalt, Copper, Manganese,

Nickel and Vanadium) Dioxins and furans

Electrostatic precipitator

(deals with Particulate

Matter only)

Selective non-catalytic

reduction system (this is to

be installed prior to SRF

being processed on site)

A2-02 Clinker Grate Cooler Particulate matter Electrostatic precipitator

A2-03 Coal Mill Particulate matter Bag filter

A2-04 Cement Mill Particulate matter Bag filter

A2-05 Sepax Separator for Cement

Mill

Particulate matter Bag filter

Each emission point has been prescribed specific limit values and monitoring requirements to afford

environmental protection as detailed in Schedules B and C of the IED licence.

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2 . 2 E n v i r o n m e n t a l P a t h w a y s a n d S e n s i t i v i t y

2.2.1 Designated Areas & Ecology

None of the site lies within a designated Natural Heritage Area, Special Area of Conservation (SAC) or Special

Protection Area (SPA). Mullinacre Upper is a Natural Heritage Area (NHA) lying approximately 1km north-west of

the site. This is a moorland site overlying shale and with a fairly intact bog surface.

2.2.2 Hydrology

The facility is located upon the southeast-facing slope of Slieve Rushen Mountain, in the catchment of the

Woodford River. In the vicinity of the site, the Woodford River flows generally from south-west to north east,

veering east northeast. The river is situated some 400m to the south-east of the facility at its closest approach.

The Woodford River discharges to Upper Lough Erne. Its confluence with the lough is situated approximately

8.5km east northeast of the site. Significant reaches of the Woodford River including the stretch in closest

proximity to the site, have been canalised to create the Shannon-Erne Waterway.

There is a small pond located upon the boundary of the land holding, this is reported to have formerly been used

for collecting rainfall runoff, although it is no longer included in the site settlement system and is not considered

to be of ecological value. There are no other water bodies, other than the site settlement system, within 1km

standoff from the facility. The closest such feature is Annagh Lough, which is approximately 1.7km to the

southeast of the facility. The facility and the lough are situated on opposite sides of the Woodford River.

The closest EPA surface water quality monitoring point is located downstream of the site at Ballyconnell quay in

the town (EPA Ref W010400). The latest water quality report published by Cavan County Council reports this

station is of Good Status (Cavan COCO, 2012). The EPA’s Envision database shows the Woodford is expected to

achieve good status in line with the current Surface Water (Environmental Objectives) Regulations 2009.

2.2.3 Geology and Hydrogeology

The site is located upon the Dartry Limestone Formation which is of Carboniferous age. The bedrock has been

classified by the GSI as a regionally important, fissured bedrock aquifer. Due to the presence of a karstic flow

component, groundwater flow rates and levels may be anticipated to vary significantly for location to location

throughout the region. The vulnerability of the bedrock aquifer has been classified as high to extreme.

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The published GSI data indicate that the site is underlain by glaciofluvial ice-contact drift. Boreholes drilled to the

east of the site encountered a thick interbedded series of sands, sands and gravels, alluvium and clays extending

to a depth of circa 15m.

The sands and gravels have been classified as a regionally important gravel aquifer which would be highly

vulnerable to surface contamination.

There are a number of groundwater supply wells in close proximity to the site including two private groundwater

wells to the southwest at distances of 325m and 500m from the site. Cavan County Council operate a supply well

(within the Dartry Limestone) circa 500m to the south of the site.

A hydrogeological assessment which will involve drilling a number of additional monitoring wells is planned for

summer 2014 prior to SRF storage and processing activities on site. This plan will be updated should the

assessment find any existing groundwater issues at the site.

2.2.4 Potential Sensitive Receptors

The 2012 IPPC application and associated EIA identified a number of potential sensitive receptors associated with

the site as outlined in Table 2.3.

Table 2.3 Potential Sensitive Receptors and distance from site

Discrete Sensitive Receptors

IGR Distance from site

X Y km

R1 Doon Heights 227622 319400 1.4

R2 Doon Bog 227502 319110 1.3

R3 Court House 227219 318787 1.8

R4 Preaching House Lanve 227096 319080 1.5

R5 Church Street 227054 318825 1.8

R6 Main Street 227384 318845 1.6

R7 Market House 227339 318784 1.8

R8 Ballyconnell House 227527 318694 1.8

R9 Derryginny Gardens 227071 318440 2.1

R10 Farm 1 227094 319981 0.7

R11 Farm 2 227345 319572 0.9

R12 Farm 3 228330 320466 0.8

R13 Farm 4 229179 320629 1.7

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The location of these receptors is illustrated on Figure 2 and full descriptions are included in the application files

which are accessible through the EPA website.

2 . 3 A c t i v i t y P r o c e s s e s

The Ballyconnell facility produces Portland Cement (CEM1) and Portland Flyash Cement (CEMIA/V 6-20% flyash),

which are composite mixtures consisting of synthetic minerals exhibiting hydraulic properties upon mixing with

water. The main raw materials used in the process are limestone (rich in calcium) and shale (rich in silica). Small

quantities of other materials including sand, silt, bauxite and iron ore are used as additives in order to obtain the

required blend. The raw materials are processed by crushing, blending and milling to produce a homogenous ‘raw

meal’. This raw meal is then passed through a high temperature kiln, where a thermal process produces a

synthetic ‘clinker’. The clinker and additives are then milled into a fine powder ‘cement’.

The main unit operations carried out at the plant are:

� Raw material handling

� Raw milling

� Clinker production

� Cement milling

� Cement despatch

All process activities with the exception of cement despatch are controlled from the Central Control Room where

numerous critical plant operational parameters are monitored. The performance of the process is continuously

monitored by operatives and interventions are made where necessary to ensure process stability and product

quality.

2.3.1 Raw Material Handling

The main raw materials used within the process are limestone and shale. Limestone is blasted from a local quarry

and transported to the site by dumper trucks and emptied directly into concrete bunkers located within contained

enclosures. Crushed limestone is delivered to the site and loaded directly into hoppers, whilst the shale is loaded

into crushers. There are four intake hoppers for crushed limestone and sand and one shale crusher. The shale,

limestone and sand are tipped directly from dumpers into their respective hoppers for processing and transported

to the pre-blending store via enclosed rubber belt conveyors. The raw materials are mixed and blended within the

pre-blending store. Carefully proportioned quantities of each raw material are fed by conveyor belt, with ‘fine

tuning’ being undertaken through the addition of small amounts of other components including sand, silt, bauxite

and iron ore. Once an appropriate blend has been achieved it is stored prior to milling.

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2.3.2 Raw Milling

The raw material is extracted from the pre-blending store and transported to an intermediary steel bin before

being conveyed to the mill via a rotary sluice. The raw mill crushes and grinds the material to a very fine powder,

known as raw meal. The resulting material is lifted from the mill by circulation air and passed through a rotary

separator. Material that is too coarse falls from the circulation air and is returned to the mill for further grinding.

Due to the moisture content of the raw material, drying is undertaken using hot circulation gas from the kiln. A

series of cyclones are used to separate the raw meal from the circulation gas before transportation to a silo for

storage and homogenisation. A gravimetric feeding system is used to feed the raw meal to the next stage of the

process.

2.3.3 Clinker Production

The clinker production plant includes the following items;

� Kiln feed system

� Pre-heater

� Calciner

� Rotary kiln

� Clinker cooler

� Coal milling plant

� Coal firing system

� SRF firing system

The raw meal is extracted from the homogenisation silo and conveyed via bucket elevator to the pre-heating

tower. The raw meal enters the top of the cyclone pre-heater and travels down through five cyclones under the

force of gravity. The cyclone pre-heater is equipped with an in-line calciner where up to 60% of the fuel is

combusted. At 600°C the limestone decomposes to produce quicklime and carbon dioxide. After a residence time

of 1-minute, the material reaches the kiln inlet and is gradually moved down the rotating kiln. The temperature of

the raw meal is raised from 860°C to 1,500°C within the kiln, initiating the clinker production process in the lower

end of the kiln. For each 100 tonnes of raw meal processed within the system, 60 tonnes of clinker is produced

with 40% weight low due to decarbonisation.

The clinker passes through the cooling zone before leaving through the kiln outlet, where it falls down into the

grate cooler. The cooler recuperates heat from the clinker and recycles it back to the pre-heater, resulting in

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reduced heating costs and fuel consumption. Excess air from the cooler is passed through an electrostatic

precipitator to remove particulates before release to atmosphere. Once cooled, the clinker exits the cooler via a

hammer crusher and is conveyed to the clinker store. A series of bag filters are used to prevent fugitive dust

emissions arising from the conveyor system.

Coal is transported to site by trucks and stored within enclosed concrete bunkers. The coal is extracted by a side

scraper and transported to the coal mill via rubber belt conveyors. Any metal residue present within the coal is

detected and removed by a magnetic separator. The coal must be dried during the milling process due to the high

moisture content. This is undertaken by circulation of hot gas rising from waste gases from the kiln. There are two

separate ‘Swirlax’ systems for firing coal into the calciner and kiln. The pulverised coal is fed to the kiln and

calciner firing systems by means of dosing systems and blowers for transporting the coal meal in steel tubes.

In accordance with the new IED licence (P0378-02 granted in 2012) modifications in fuel use have taken place on

site in order to substitute a percentage of coal with Solid Recovered Fuel (SRF) at the facility. In order to

accommodate this modification in fuel use the following physical plant changes have taken place;

• New fuel storage and feeding system has been installed

• The bypass set up has been modified (with new conditioning tower and moving existing bypass filter)

• New Selective Non Catalytic Reduction System (SNCR) has been installed for NOx emission reductions

• A new by-pass dust silo has been installed at the cement mill

• There have been modifications to the existing abatement systems and new monitoring equipment has

been installed

The SRF is delivered to site by trucks equipped with walking floors and unloaded into covered receiving stations,

from which the material is transported to storage unit. SRF is extracted from this unit by a screw conveyor and

delivered to a dosing unit, which feeds the material via a hopper to a weigh feeder for transport to the calciner by

an air blower or chain conveyor.

2.3.4 Cement Milling and Dispatch

Clinker is mechanically extracted from the storage area and transported directly to the cement mill for grinding.

Within the mill, gypsum is added to control the settling time while flyash and ferrous sulphate are also added to

make cement. CEM II A/V uses filler to reduce the clinker content of cement therefore reducing the carbon

content. The gypsum, clinker, fly ash and ferrous sulphate are mixed to fine powder cement within the mill before

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transportation to three storage silos. Two of these silos are used for despatch of bulk cement, whilst the remaining

silo the outer ring is used for bulk cement whilst the inner ring is fed to the bagging plant.

2 . 4 I n v e n t o r y o f B u i l d i n g s , E q u i p m e n t a n d P l a n t

A summary of the infrastructure on site consists of the following;

• Limestone/shale crusher

• Raw material storage

• Preblend shed

• Additive bins

• Raw mill building

• Preheater building and kiln

• Electrostatic Precipitator Unit

• Conditioning Tower

• Coal bunkers

• Coal mill

• Grate cooler building

• Cement mill

• Cement silos

• PFA silo

• Ferrous Sulphate silo

• Grind aid storage

• Bagging Plant

• Mechanical workshop

• Stores

• Canteen

• Lorry drivers canteen

• Lubrication store

• Central control room

• Office building and laboratory

• Waste segregation area

• Weighbridge office

• Settlement tank

• Water treatment and storage

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• Diesel Tank storage

• SRF reception area

• SRF storage

• SNCR building and ammonia storage

• Electrical switch rooms (4 in total)

• ESB substation (not under site’s control)

• Kiln clinker dust silo

• CF silo

There are a number of storage tanks and associated bunds and sumps across the site including:

• 4 no. Stationary Bunds

• 1 no. Pump Sump

• 29 no. mobile bunds and

• 5 no. diesel tanks ranging from 2,000 to 30,000 l capacity

• 1 no. kerosene tank (2,000l)

• 1 no. Ammonia tanks (150,000)

• 2 no. Grinder Aid tanks (40,000l each)

A schedule of the current tanks and bunds on-site is included in Appendix 2.

2 . 5 I n v e n t o r y o f R a w M a t e r i a l s a n d W a s t e

Table 2.4 overleaf provides an inventory of raw materials on site. In the event of a closure all raw material will be

returned to the supplier or sold on. Table 2.5 provides an inventory of waste disposed of for 2013. For the purpose

of the Closure Plan costing the waste figures have been rounded up and a year’s figures have been included to

account for excess material that will arise during closure.

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Table 2.4 Inventory of Raw Materials

Table 2.3 Inventory of Waste Disposed for 2013

Type Storage Area Maximum Storage

Capacity

Measurement

Unit

Limestone H.G. Stockpile 70,000 Tonnes

Iron Ore Stockpile 5,000 Tonnes

Shale Crusher 1,000 Tonnes

Shale Stockpile 1,000 Tonnes

Bauxite Bin 6 300 Tonnes

Silt Raw material storage 500 Tonnes

Ferrous Sulphate Covered silo, cement mill 100 Tonnes

Description Quantity

(tonnes)

Disposal / Recover

Contractor

Cost for 2013

(€)

Hazardous

Waste oil 5.4 ENVA Ireland 3,273

Oil rags 0.92 ENVA Ireland

Aerosols 0.08 ENVA Ireland

Oil filters 0.41 ENVA Ireland

Fluorescent tubes 0.22 Irish Lamp Recycling 311

WEEE 2.25 Irish Lamp Recycling

Drum and IBC 2.56 RILTA Environmental Ltd. 1,499

Non

Hazardous

C & D 13.86 Wilton Waste Recycling 10,214

Scrap metals 142.1 Wilton Waste Recycling

General waste 84.93 Wilton Waste Recycling

Mixed packaging 13.36 Wilton Waste Recycling

Timber 25.26 Wilton Waste Recycling /

Mixed packaging 3.7 Envirogreen Recycling

Total 15,297

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In addition to raw material and site waste SRF will be stored on site prior to co-incineration. It is understood that

two days’ supply will be on site at any one time which equates to 720 tonnes. In the event of an unplanned closure

this material will have to be removed from site by a permitted contractor and sent for processing at an

appropriately licenced co-incineration site.

Waste water will be generated through site decontamination and it has been estimated that 90m3 will require

disposal as part of site decontamination works,

3.0 CLOSURE TASKS AND PROGRAMMES

Quinn Cement currently has no plans to decommission all or part of the site. Quinn Cement proposes to continue

operating the facility as a cement manufacturing plant for the foreseeable future.

In the event of closure of all or part of the facility, the Agency shall be informed at the earliest possible opportunity

of plans to decommission. Notification shall be provided in accordance with relevant guidance and in conjunction

with any additional advice or guidance from the Agency at that time.

For the purposes of this plan and to represent a worst case scenario it has been assumed that closure will occur

without a shutdown period. In this event remaining materials, stocks or substances will be returned to vendors or

resold where possible. All remaining materials will be disposed of appropriately. All plant and equipment will be

decommissioned and will be either resold or scrapped. All tanks, bunds and sumps will be integrity tested and or

inspected prior to decommission to assess if any leaks may have occurred. All buildings, structures and site

infrastructure will be removed down to slab level, demolished and disposed of in an appropriate and approved

manner. Once all elements of the facility have been removed down to current slab level and all environmental

monitoring/audit results and validation reporting has been completed the site can be reused as

Industrial/Commercial landuse.

It is not expected any soil remediation will be necessary however in the event that site remediation works are

required following the validation audit; they will be conducted in accordance with a methodology agreed with the

Agency.

This proposed future land-use i.e. continued use as industrial/commercial, is in line with the Cavan County

Development Plan 2014-2020.

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Final

3 . 1 P r o g r a m m e

The scope of this plan addresses the key issues which would occur in an orderly shutdown of all or part of the site

activities. It is estimated that a complete shutdown would take place with immediate effect. Site

decommissioning and licence surrender will be carried out on a phased basis over a period of 10 months (Refer to

Appendix 1 for Programme).

Step 1

The decision is made to cease activities on site. All the relevant authorities and the Agency are to be notified

immediately. All site activity will cease and normal Import and export of materials will stop.

Step 2

All raw materials, intermediates, fuels and product will be sold possibly to another division of the Quinn Group or

to an alternative buyer. All remaining stock such as parts, lubricating oils etc. should be returned to the supplier or

sold where possible. Remaining materials, products, stock etc. should be disposed of via the appropriate channels.

Step 3

Initial decommissioning of plant and equipment will begin at the crushers and pre-blending shed. Subsequently

the preheater, kiln, cooler and coal mill will be decommissioned. All equipment containing fuel or oils will be

depolluted and cleaned. Industrial cleaning equipment and cleaning protocols will be required to ensure all

environmental hazards associated with the plant are eliminated. Where possible, cleaned equipment will be

resold. In a situation where the plant cannot be sold off, it will be sent for recycling.

Step 4

Demolition of buildings will follow a logical sequence. Demolition will be carried out in a highly controlled manner

and all materials will be segregated on site to maximise recovery rates where possible. All site buildings are of a

new design containing concrete, steel work and cladding. No asbestos was used in construction. All steel work will

be sold as scrap and other material will be recycled or disposed of to licenced facilities.

Step 5

Once all residuals, plant, equipment and buildings have been decommissioned, site infrastructure and services will

be removed. Work will start at the furthest point from the entrance. It is not proposed to remove any hard

standing with the exception of any contaminated areas.

Step 6

A validation audit will be carried out and a site investigation carried out if required. A validation assessment will be

conducted to confirm the site is suitable for continued use as industrial/commercial.

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4.0 CRITERIA FOR SUCCESSFUL CLOSURE

Successful closure is based on the following criteria:

• Removal of all materials, intermediates and products from site.

• Decommissioning of all process equipment and plant using standard procedures.

• Removal of all buildings, structures and internal infrastructure by authorised contractors.

• Disposal of all decommissioning waste in accordance with Waste Management Legislation.

• Site is re-established to allow development for proposed future use.

Ultimately successful closure will be determined by no further environmental liabilities existing following

decommissioning.

5.0 CLOSURE PLAN VALIDATION

A closure plan validation audit will be carried out as part of the decommissioning programme. This will include an

inventory of all remaining assets at the site (raw materials, equipment, wastes etc.) and any environmental issues

associated with the site. The exit audit would be conducted by a suitably qualified and independent third party and

would be carried out at various stages of the closure process including before, during and after decommissioning.

The initial inventory will be the benchmark against which successful decommissioning will be assessed and the

programme will include all defined timeframes.

Environmental monitoring will be carried out in accordance with the requirements of the IED licence.

The final validation audit report will include a certificate of completion for the closure plan for all or part of the site

where necessary. This shall be submitted to the Agency for approval within three months of the execution of the

plan. Quinn Cement will carry out such tests, investigations or submit certification as requested by the Agency, to

confirm that there is no continuing risk from the site. The Agency will hold final judgement on the mitigation of

the site and measures that are required to ensure no continuing risk to the environment emanates from the site.

6.0 CLOSURE PLAN COSTING

The estimated costs associated with the closure plan implementation are outlined in Table 6.1.

A contingency of 20% has been included to allow for unplanned or unforeseeable items.

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Final

Table 6.1 Closure Costing

Task Description Quantity (No.) Measurement Unit Unit Rate (€) Cost (€) Source of Unit

Rates

Plant & Equipment

Decontamination

Limestone/Shale crusher 1

Day 1,870

1,870

Rilta

Environmental

Ltd. Note 1

Raw material storage 2 3,740

Preblend shed 6 11,220

Additive bins 1 1,870

Raw mill building 4 7,480

Pre-heater building and kiln 3 5,610

Coal bunkers 3 5,610

ESP 1 1,870

Conditioning Tower 3 5,610

Coal mill 8 14,960

Grate cooler building 2 3,740

Cement mill 7 13,090

Cement silos 5 9,350

PFA silos 5 9,350

Ferrous sulphate silo 2 3,740

Grinding aid storage 2 3,740

Bagging plant 5 9,350

Mechanical workshop 1 1,870

Stores 1 1,870

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Final

Canteen 1 1,870

Lorry drivers canteen 1 1,870

Lubrication store 1 1,870

Central control room 1 1,870

Office building and laboratory 3 5,610

Waste segregation area 2 3,740

Weighbridge office 2 3,740

Settlement tank 3 5,610

Water treatment and storage 4 7,480

Diesel tank storage 2 3,740

SRF reception 2 3,740

SRF storage 3 5,610

SNCR building and ammonia

storage 4 7,480

Electrical switch rooms 1 1,870

ESB substation (not under

company's control) 0 0

Kiln clinker dust silo 2 3,740

CF silo 2 3,740

Bunds (5) 7 13,090

Subtotal 192,610

Rock crusher

16,000

John Ryan

Group

Raw material storage 0

Preblend shed -10,000

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Final

Additive bins

40,000

Raw mill building 35,000

Pre-heater building and kiln -125,000

Coal bunkers 120,000

Coal mill 30,000

Grate cooler building 15,000

Cement mill 12,500

Cement silos 285,000

PFA silos 2,500

Ferrous sulphate silo 0

Grinding aid storage -6,000

Bagging plant -100,000

Mechanical workshop -11,500

Stores -6,000

Canteen -11,500

Lorry drivers canteen 1,250

Lubrication store 2,000

Central control room 1,500

Office building and laboratory 65,000

Waste segregation area 3,000

Weighbridge office 4,000

Settlement tank 57,500

Water treatment and storage 210,000

Diesel tank storage 3,500

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Final

SRF reception -13,000

SRF storage 65,000

SNCR building and ammonia

storage 2,300

Electrical switch rooms -11,500

ESB substation 0

Kiln clinker dust silo 0

CF silo 11,000

Bunds (5) 11,000

Removal of services 0

Removal of hard standing 0

Subtotal 682,550

Plant Disposal

Transport cost (including loading

and unloading) for

decommissioned plant and

equipment

inc included in

disposal

Recovery or Disposal cost for

decommissioned plant and

equipment

494,300

John Ryan

Group (inc in

demolition

total)

Subtotal 0

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Final

Raw Material Disposal

Disposal of all raw/stockpiled

materials na na na 0

All material to

be

sold/returned

to suppliers

Disposal of stockpiled SRF 720 tonnes 50 36,000 Quinn Cement

Subtotal 36,000

Waste Disposal and

Recovery (including

loading and TFS)

Waste Oil (13 02 08) 6 tonnes 481 2,886

ENVA Ireland Oil Rags (15 02 02) 1 tonnes 481 481

Aerosols 0.1 tonnes 481 48

Oil Filters 1 tonnes 481 481

Fluorescent tubes / WEEE (20 01

21 & 20 01 35) 3 tonnes 126 378

Irish Lamp

Recycling

Drum and IBC (15 01 10) 3 tonnes 586 1,758

Rilta

Environmental

Ltd.

C&D (17 09 04) 14 tonnes 75 1,050

Wilton Waste

Recycling

Scrap metals (20 01 40) 142 tonnes 0 0

General waste (20 03 01) 85 Tonnes 75 6,375

Mixed packaging (15 01 06) 14 Tonnes 75 1,050

Timber (20 01 38) 27 Tonnes 75 2,025

Mixed packaging (15 01 06) 4 tonnes 75 300 Envirogreen

Recycling

Waste Water 90 cu 220 19,800

Subtotal 36,632

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Final

Environmental

Monitoring

Groundwater and Surface Water 3 Event 2,500 7,500 QED / Biolabs

Air 3 Event 3,300 9,900

Catalyst

Environmental

/ Biolabs

Noise 1 Event 1,200 1,200

Noise &

Vibration

Consultant

Subtotal 18,600

Security Security personnel (Based on 24

hour security) 1 Person Year

Note 2 60,000 60,000 Quinn Cement

Integrity Testing

(bunds sumps and

pipelines)

Consultant Costs 1 Event 2000 2,000 Verde

Validation Audit Consultant Costs 10 Day 680 6,800 Verde

Management Site manager, site engineer and

environmental advisor 3 Person Year 60,000 180,000 Quinn Cement

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Final

Utility Costs Insurance 1

Public &

Environmental

Liabilits for 10

months

65,030 65,030 Quinn Cement

Overheads (utilities, services) 1 Esimate based on

current bills 82,660 82,660 Quinn Cement

Closure and Surrender Surrender of the licence to the

EPA 5 Day 680 3,400 Verde

Subtotal 399,890

Total 1,366,282

Contingency (10%) 136,628

Total including contingency 1,502,910

Note 1: Cost is based on the hire of a jet/vacuum tanker, one supervisor and two operatives.

Note 2: Personnel costs are included for one year to allow for possible over runs in the programme

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Final

8.0 FUTURE PROOFING COSTS

Table 8.1 Cost adjustment for inflation (rate 2.5%)

Year Task Closure Cost

2014 Financial Provision Established 1,502,910

2015 Cessation of Activity and Closure Implemented 1,540,483

Total Cost Adjusted for Inflation 1,540,483

9.0 FINANCIAL PROVISION

Quinn Cement will make the necessary financial provision to cover the closure requirements of €1,540,483

This closure plan should be reviewed annually and proposed amendments will require agreement with the EPA.

10.0 BIBLIOGRAPHY

• Quinn Cement Ltd. Annual Environmental Reports 2012, 2013

• IPPC Licence Review Application, Quinn Cement (WYG Environment 2009)

• EPA Guidance Document; Guidance on Assessing and Costing Environmental Liabilities (EPA 2014)

• EPA Licence P0378-02

• Quinn Cement Environmental Management System Documentation

• EPA Guidance Document, ‘Guidance on the Management of Contaminated Land and Groundwater at EPA

Licensed Sites’, EPA 2013

• Quinn Cement Register of Aspects and Impacts

• Environmental Impact Statement prepared for License Review Quinn Cement (various contributors).

• Verde, Environmental Liability Risk Assessment, 2013

• Quinn Cement Ltd., Site Closure, Restoration and Aftercare Management Plan, 2009

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C l o s u r e P l a n

AUGUST 2014

QUINN CEMENT

BALLYCONNELL CO. CAVAN

FIGURES

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www.verde.ieTel: + 353 1 201 1260 Date: Aug 2014 Job ref: 50410

Title:

Client: Quinn Cement Ltd.Verde

Not to Scale Figure 1

Sensitive Receptor Locations

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MUCKLAGH

SCOTCHTOWN

Not to Scalewww.verde.ie

Tel: + 353 1 201 1260 Date: Aug 2014 Job Ref: 50410

Title:


LEGENDDust Deposit GaugeNoise MonitorSurface Water Sample

Groundwater Sample

Air Emission Points

Site Boundary

A2-01 KilnA2-02 Grate CoolerA2-03 Coal MillA2-04 Cement MillA2-05 Sepax Filter

A2-01A2-03

A2-02

A2-05A2-04

D4 D2

D1

D5

SW

SW1

GW

GW1

N6

N6

N3

N4

N5

D4

D3

SettlementTank

Monitoring Locations Map

Figure No. 2

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��

��

www.verde.ieTel: + 353 1 201 1260 Date: June 2014 Job Ref: 50410

Title:

Client:

Site Layout Map

Quinn Cement Ltd.

Figure No. 3

Verde

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Closure Plan

AUGUST 2014

QUINN CEMENT


APPENDIX 1

CLOSURE PLAN PROGRAMME

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Closure Plan

Task

1 2 3 4 5 6 7 8 9 10

Inform Agency of intention to decommission

Materials and stocks (run down/returned to vendors/resold

Decommissioning of plant and equipment

Disposal of plant (sold/recycled)

Demolition

Removal of site infrastructure, services, hardstanding

Landscaping of site to original levels

Validation audit

Environmental monitoring

Closure and surrender of licence

Month

August 2014

50410

Final

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Closure Plan

AUGUST 2014

QUINN CEMENT


APPENDIX 2

SCHEDULE OF TANKS AND BUNDS

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Closure Plan

Description Location Label Integrity Tested

Decontamination

Wastewater Generated

(m3)

Stationary

Diesel Bund Beside Coal Mill N/A Yes 2

Grinding Aid Bund Clinker Store N/A Yes 1

IBC Bunded Store Clinker Store N/A Yes 1

Waste Oil Store Area Waste Segregation Area N/A Yes 1

Raw Mill Hydraulic pump sump Raw Mill N/A Yes 1

Mobile

Oil S 2 Yes 0

Oil S 3 Yes 0

Oil S 4 Yes 0

Oil S 5 Yes 0

Oil S 6 Yes 0

Oil S 7 Yes 0

Oil S10 Yes 0

Oil S 1 Yes 0

Oil S 8 Yes 0

Oil S 9 Yes

1 * Hyde yellow bund with black tray Oil Store 15 Yes 0

2 * PM Engineering blue steel bunds SK4 Yes 0

SK5 Yes 0

1 * Big yellow with black tray Waste Segregation Area 10 New 2013 0

1 * Big blue bund with black tray Waste Segregation Area 21 Yes 0

Register of Bunds

Oil Store

Oil Store

Cement Mill

6 * Blue steel bunds

3 * Grey steel bunds

August 2014

50410

Final

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Closure Plan

1 * PM Engineering blue steel bund Waste Segregation Area 14 Yes 0

1 * Hyde yellow bund Bunded Area of Waste Segregation Area 13 Yes 0

SK7 Yes 0

SK1 Yes

1 * Blue steel bund Workshop SK9 Yes 0

1 * Hyde yellow bund with black tray Stores 16 Yes 0

1 * Blue steel bund Preblending Shed SK10 Yes 0

1 * Yellow plastic bund Preblending Shed 31 Yes 0

1 * Hyde blue plastic bund (shallow) Bagging Plant 33 Yes 0

1 * Partswasher bund Beside Oil Store 12 New 2013 0

1 * Blue bund (shallow) Clinker Transport Shed 11 Yes 0

1 * Blue steel bund Coal Shed SK6 Yes 0

1 * Blue steel bund Grate Cooler SK2 Yes 0

1* IBC yellow bund New 2013 0

Raw Mill2 * PM Engineering blue steel bunds

August 2014

50410

Final

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Closure Plan

Description Location Capacity (l)

Decontamination

Wastewater Generated

(m3)

Kiln Diesel 1 30,000 1



Refueling Tank (Diesel) 2,728 1

Heating 1 (Diesel) 2,000 1

Heating 2 (Kerosene) 2,000 1

SNCR (Ammonia) Double Walled tank adjacent to SNCR 150,000 2

Settlement Tank 5,400,000 0

Interceptor 450,000 4

Register of Tanks

August 2014

50410

Final

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Appendix K.2 Environmental Liabilities Risk Assessment (ELRA)

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EPA Export 25-05-2016:01:00:09

LICENCE REFERENCE No. Environmental Liability Risk

Assessment REPORT VERSION

P0378-02 Stage 1 Step 1 Final

Environmental Liability Risk Assessment

Quinn Cement Ltd.

Ballyconnell, Co. Cavan

August 2014

P0378-02

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Quinn Cement Ltd. P0378-02

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Final

Project Title: Environmental Liability Risk Assessment

Licence No.

Project No:

P0378-02

50410

Contract No. 50410

Report Ref: Environmental Liability Risk Assessment

Status: Final_V2

Client: Quinn Cement Ltd.

Client Details: Quinn Cement Ltd., Ballyconnell, Co. Cavan

Issued By: Verde Environmental Consultants Ltd,

F27 Bullford Business Campus, Kilcoole, Co.Wicklow

Document Production / Approval Record

Name Signature Date Position %

Input

Prepared by (consultant)

Debbie Good

20th August

2014

Senior Consultant

70

Approved by (consultant)

Cian O’Hora

21st August

2014

Project Manager

30

Site Approval by

Michelle Cass 21st

August 2014

Environmental Advisor

N/A

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ...................................................................................................................... 4

1.0 INTRODUCTION .................................................................................................................... 6

2.0 SCOPING............................................................................................................................... 6

3.0 RISK IDENTIFICATION ............................................................................................................... 7

3.1 SITE OPERATION ........................................................................................................................................ 7 3.1.1 SITE LOCATION ........................................................................................................................................ 7 3.1.2 SITE ACTIVITIES ....................................................................................................................................... 7 3.1.3 SITE EMISSIONS AND ABATEMENT SYSTEMS .............................................................................................. 10 3.1.4 NATURE AND VOLUME OF WASTES GENERATED ......................................................................................... 14 3.2 OPERATOR PERFORMANCE ...................................................................................................................... 14 3.3 ENVIRONMENTAL SENSITIVITY ................................................................................................................. 15 3.3.1 DESIGNATED AREAS & ECOLOGY ............................................................................................................. 15 3.3.2 HYDOLOGY ........................................................................................................................................... 15 3.3.3 GEOLOGY AND HYDROGEOLOGY .............................................................................................................. 16 3.3.4 POTENTIAL SENSITIVE RECEPTORS ........................................................................................................... 17 3.4 RISK IDENTIFICATION .............................................................................................................................. 17 3.4.1 RAW MATERIAL HANDLING AND STORAGE – EMISSIONS TO AIR /SURFACE WATER / NOISE NUISANCE ................ 18 3.4.2 RAW MILLING - EMISSIONS TO AIR / NOISE NUISANCE ................................................................................. 19 3.4.3 CLINKER PRODUCTION – KILN, COOLER AND CLINKER STORE – EMISSIONS TO AIR / NOISE NUISANCE ................ 19 3.4.4 CLINKER PRODUCTION – COAL MILLING PLANT – EMISSIONS TO AIR / NOISE NUISANCE ................................... 20 3.4.5 CLINKER PRODUCTION – USE OF SRF ........................................................................................................ 21 3.4.6 OPERATION OF SNCR – EMISSIONS TO SURFACE WATER / SOILS / GROUNDWATER .......................................... 21 3.4.7 BULK FUEL (DIESEL AND KEROSENE)STORAGE AND DELIVERY – EMISSIONS TO SURFACE WATER / SOILS /

GROUNDWATER .................................................................................................................................................. 22 3.4.8 CEMENT MILLING – EMISSIONS TO AIR / NOISE NUISANCE ............................................................................ 23 3.4.9 CEMENT DESPATCH – BAGGING PLANT – EMISSIONS TO AIR ......................................................................... 23 3.4.10 HAZARDOUS WASTE STORAGE AND TRANSFER – EMISSIONS TO SOILS / GROUNDWATER / SURFACE WATER ........24 3.4.11 NON HAZARDOUS WASTE STORAGE AND TRANSFER ...................................................................................24 3.4.12 OIL STORAGE AND TRANSFER – EMISSIONS TO SURFACE WATER / SOILS / GROUNDWATER ............................... 25 3.4.13 EMERGENCY SITUATION (FIRE/EXPLOSION) – EMISSIONS TO AIR / SURFACE WATER ......................................... 25 3.4.14 DIESEL/AMMONIA TRANSFER – EMISSIONS TO SURFACE WATER /SOILS/GROUNDWATER ..................................26 3.4.15 DIESEL/AMMONIA TRANSFER – EMISSIONS TO SURFACE WATER / SOILS/GROUNDWATER ................................. 27 3.4.16 USE OF CHEMICALS WITHIN THE LAB – EMISSIONS TO SURFACE WATER/SOILS/GROUNDWATER ......................... 27 3.4.17 USE OF ENGINEERING MATERIALS WITHIN THE WORKSHOP – EMISSIONS TO SURFACE

WATER/SOILS/GROUNDWATER ............................................................................................................................. 28 3.4.18 COAL STORAGE – FIRE – EMISSIONS TO SURFACE WATER/AIR....................................................................... 28 3.4.19 SRF STORAGE AREA – FIRE – EMISSIONS TO SURFACE WATER/AIR ................................................................29 3.4.20 FAILURE OF SURFACE WATER DRAINAGE NETWORK – EMISSIONS TO SURFACE WATER/SOILS/GROUNDWATER ....29 3.4.21 OVERFLOW OF CEMENT SILO – EMISSIONS TO AIR ...................................................................................... 30 3.4.22 CONTRACTOR ACTIVITIES – EMISSIONS TO SURFACE WATER/SOILS/GROUNDWATER/AIR .................................. 30 3.4.23 GRINDING AID STORAGE AND DELIVERY – EMISSIONS TO SURFACE WATER/SOILS/GROUNDWATER .................... 30

4.0 RISK ANALYSIS .................................................................................................................... 31

5.0 RISK EVALUATION .................................................................................................................. 39

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5.1 RISK MATRIX ......................................................................................................................................... 43

6.0 RISK TREATMENT ............................................................................................................... 44

7.0 IDENTIFICATION OF PLAUSIBLE WORST CASE SCENARIO ........................................................ 51

8.0 QUANTIFICATION AND COSTING ......................................................................................... 51

9.0 CONCLUSION ....................................................................................................................... 53

10.0 BIBLIOGRAPHY .................................................................................................................... 53

Figures

Figure 1 - Site Location Plan and Sensitive Receptors

Figure 2 - Site Layout Plan with Emission and Monitoring Points

Figure 3 - Site Layout

Tables

Table 3.1 - Surface Water ELVs

Table 3.2 - Air Emission Points

Table 3.3 - Inventory of Waste Disposed for 2013

Table 3.4 - Potential Sensitive Receptors

Table 4.1 - Risk Classification Table – Likelihood

Table 4.2 - Risk Classification Table – Consequence

Table 4.3 - Risk Analysis

Table 5.1 - Risk Evaluation

Table 5.2 - Risk Matrix

Table 6.1 - Statement of Measures

Table 8.1 - Quantification and Costing of Plausible Worst Case Scenario

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EXECUTIVE SUMMARY

Activity Details

Name: Quinn Cement Ltd.

Address: Scotchtown, Ballyconnell, Co. Cavan

Licence Number: PO378-02

Activities Licensed:

o 10.2. Production of cement clinker in rotary kilns with a production capacity exceeding 500

tonnes per day or in other kilns with a production capacity exceeding 50 tonnes per day.

o 11.3 (a) Disposal or recovery of waste in waste incineration plants or in waste co-incineration

plants for non-hazardous waste with a capacity exceeding 3 tonnes per hour.

Report Preparation

The report was prepared on behalf of the operator by Verde Environmental Consultants Ltd.

Address: F27 Bullford Business Campus, Kilcoole, Co. Wicklow.

Comparison with Previous ELRAs

One previous ELRA was submitted for 2009 as summarized below:

Year Cost Financial Provision

2009 €3,142,000 Liability Insurance

It should be noted that the 2009 ELRA estimated the cost of the unknown environmental liabilities associated

with the facility based on the worst case scenario for all the risks identified. For the purpose of this report the

financial provision has been estimated based on the plausible worst case scenario in line with the current EPA

Guidance Document as discussed below.

Overview of the Plan

This report has been prepared to satisfy condition 12.2.2 of the IED licence. The methodology for the

development of the ELRA follows the EPA Guidance Document; Guidance on Assessing and Costing

Environmental Liabilities (EPA 2014). The ELRA has been prepared to accurately reflect the risks of unplanned

but plausible incidents occurring.

The following steps were undertaken during the study:

Task 1: Scoping to determine the type of environmental liabilities to be covered.

Task 2: Risk identification, i.e. the systematic identification of plausible risks, the sensitivity of the

receiving environment and the potential pathway for the activity to impact on the environment.

Task 3: Risk analysis to determine the likelihood and consequences for the identified risks.

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Task 4: Risk evaluation to rank and present the risks to allow for prioritisation of the risk treatment

programme.

Task 5: Risk treatment in order to mitigate risks.

Task 6: Identification, quantification and costing of a plausible worst case scenario for financial

provision.

Financial Provision

The financial provision is based on the plausible worst case scenario. This is the maximum liability that may be

incurred and is calculated at €277,497. Quinn Cement will make the necessary financial provision to cover this

liability.

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1.0 INTRODUCTION

Verde Environmental Consultants Ltd. (Verde) was commissioned by Quinn Cement Ltd. to carry out an

Environmental Liability Risk Assessment (ELRA) for their facility located at Scotchtown, Ballyconnell, Co.

Cavan. The assessment is required by Condition 12.2.2 of the site’s Licence No. P0378-02, which was granted

in July 2012. The site’s licence was amended to an Industrial Emissions Directive Licence (IED) by the EPA in

January 2014 to bring it into line with the Industrial Emissions Directive (2010/075/EU). The recently granted

revised licence was applied for to allow modifications in fuel on site in order to substitute a percentage of coal

with Solid Recovered Fuel (SRF) at the facility.

Condition 12.2.2 of the licence states the following;

12.2.2 The licensee shall arrange for the completion, by an independent and appropriate qualified consultant,

of a comprehensive and fully costed Environmental Liabilities Risk Assessment (ELRA) to address the

liabilities from past and present activities. The assessment shall include those liabilities and costs

identified in Condition 10 for the execution of the DMP. A report on this assessment shall be submitted to

the Agency for agreement in advance of the commencement of waste acceptance. The ELRA shall be

reviewed as necessary to reflect any significant changes on site, and in any case every three years

following initial agreement. The results of the review shall be notified as part of the AER.

Condition 10 is cross referenced in 12.2.2 refers to Decommissioning & Residual Management of the site. It is

a requirement of the condition that the licensee shall maintain an approved fully detailed and costed plan for

the decommissioning and closure of the site. The plan is to be reviewed annually and any armaments shall be

agreed with the Agency.

This report has been prepared to satisfy this condition of the IED licence. The methodology for the

development of the ELRA follows the EPA Guidance Document; Guidance on Assessing and Costing

Environmental Liabilities (EPA 2014).

The ELRA has been prepared to accurately reflect the risks of unplanned but plausible incidents occurring.

2.0 SCOPING

The licence condition for the activity states that the ELRA should address the liabilities from past and present

activities. In this regard all aspects of the historic operation and current site operation that pose a plausible

risk to the environment are covered in this ELRA.

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Planned liabilities associated with closure are not considered in this ELRA and have been addressed in the

costed Closure Plan prepared in accordance with Condition 10 of the licence and the recent EPA guidance.

The reviewed Closure Plan will be submitted to the Agency in July 2014 for agreement.

The following steps were undertaken during the study:

Task 1: Scoping to determine the type of environmental liabilities to be covered.

Task 2: Risk identification, i.e. the systematic identification of plausible risks, the sensitivity of the

receiving environment and the potential pathway for the activity to impact on the environment.

Task 3: Risk analysis to determine the likelihood and consequences for the identified risks

Task 4: Risk evaluation to rank and present the risks to allow for prioritisation of the risk treatment

programme.

Task 5: Risk treatment in order to mitigate risks.

Task 6: Identification, quantification and costing of a plausible worst case scenario for financial

provision.

Information for this assessment was gained from the sites’ Environmental Advisor, Annual Environmental

Reports and the report prepared by WYG Environment in 2009 to accompany the Licence review application;

including an Environmental Impact Statement prepared by Quarryplan on behalf of Quinn Cement.

3.0 RISK IDENTIFICATION

3 . 1 S i t e O p e r a t i o n

3 . 1 . 1 S i t e L o c a t i o n Quinn Cement Ltd. operates a cement manufacturing facility at Scotchtown, Ballyconnell, County Cavan. The

facility is located approximately 3km north of the town of Ballyconnell (National Grid Reference 227500,

320500) and covers an area of approximately 35 hectares (see Figure 1 for site location). The site is located in

an area of pastoral agriculture with plantation woodland, mineral extraction and large industrial units. The

site is separated from the R205 road by a strip of approximately 250m of pastureland.

3 . 1 . 2 S i t e A c t i v i t i e s

The Ballyconnell facility produces Portland Cement (CEM1) and Portland Flyash Cement (CEMIA/V 6-20%

flyash), which are composite mixtures consisting of synthetic minerals exhibiting hydraulic properties upon

mixing with water. The main raw materials used in the process are limestone (rich in calcium) and shale (rich

in silica). Small quantities of other materials including sand, silt, bauxite and iron ore are used as additives in

order to obtain the required blend.

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The raw materials are processed by crushing, blending and milling to produce a homogenous ‘raw meal’. This

raw meal is then passed through a high temperature kiln, where a thermal process produces a synthetic

‘clinker’. The clinker and additives are then milled into a fine powder ‘cement’.

The main unit operations carried out at the plant are:

Raw material handling

Raw milling

Clinker production

Cement milling

Cement despatch

All process activities with the exception of cement despatch are controlled from the Central Control Room

where numerous critical plant operational parameters are monitored. The performance of the process is

continuously monitored by operatives and interventions are made where necessary to ensure process stability

and product quality.

3.1.2.1 Raw Material Handling

The main raw materials used within the process are limestone and shale. Limestone is blasted from a local

quarry and transported to the site by dumper trucks and emptied directly into concrete bunkers located

within contained enclosures. Crushed limestone is delivered to the site and loaded directly into hoppers,

whilst the shale is loaded into crushers. There are four intake hoppers for crushed limestone and sand and one

shale crusher. The shale, limestone and sand are tipped directly from dumpers into their respective hoppers

for processing and transported to the pre-blending store via enclosed rubber belt conveyors. The raw

materials are mixed and blended within the pre-blending store. Carefully proportioned quantities of each raw

material are fed by conveyor belt, with ‘fine tuning’ being undertaken through the addition of small amounts

of other components including sand, silt, bauxite and iron ore. Once an appropriate blend has been achieved

it is stored prior to milling.

3.1.2.2 Raw Milling

The raw material is extracted from the pre-blending store and transported to an intermediary steel bin before

being conveyed to the mill via a rotary sluice. The raw mill crushes and grinds the material to a very fine

powder, known as raw meal. The resulting material is lifted from the mill by circulation air and passed through

a rotary separator. Material that is too coarse falls from the circulation air and is returned to the mill for

further grinding. Due to the moisture content of the raw material, drying is undertaken using hot circulation

gas from the kiln. A series of cyclones are used to separate the raw meal from the circulation gas before

transportation to a silo for storage and homogenisation. A gravimetric feeding system is used to feed the raw

meal to the next stage of the process.

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3.1.2.3 Clinker Production

The clinker production plant includes the following items;

Kiln feed system

Pre-heater

Calciner

Rotary kiln

Clinker cooler

Coal milling plant

Coal firing system

SRF firing system


tower. The raw meal enters the top of the cyclone pre-heater and travels down through five cyclones under

the force of gravity. The cyclone pre-heater is equipped with an in-line calciner where up to 60% of the fuel is

combusted. At 600°C the limestone decomposes to produce quicklime and carbon dioxide. After a residence

time of 1-minute, the material reaches the kiln inlet and is gradually moved down the rotating kiln. The

temperature of the raw meal is raised from 860°C to 1,500°C within the kiln, initiating the clinker production

process in the lower end of the kiln. For each 100 tonnes of raw meal processed within the system, 60 tonnes

of clinker is produced with 40% weight low due to decarbonisation.

The clinker passes through the cooling zone before leaving through the kiln outlet, where it falls down into

the grate cooler. The cooler recuperates heat from the clinker and recycles it back to the pre-heater, resulting

in reduced heating costs and fuel consumption. Excess air from the cooler is passed through an electrostatic

precipitator to remove particulates before release to atmosphere. Once cooled, the clinker exits the cooler via

a hammer crusher and is conveyed to the clinker store. A series of bag filters are used to prevent fugitive dust

emissions arising from the conveyor system.

Coal is transported to site by trucks and stored within enclosed concrete bunkers. The coal is extracted by a

side scraper and transported to the coal mill via rubber belt conveyors. Any metal residue present within the

coal is detected and removed by a magnetic separator. The coal must be dried during the milling process due

to the high moisture content. This is undertaken by circulation of hot gas rising from waste gases from the

kiln. There are two separate ‘Swirlax’ systems for firing coal into the calciner and kiln. The pulverised coal is

fed to the kiln and calciner firing systems by means of dosing systems and blowers for transporting the coal

meal in steel tubes.

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In accordance with the current IED licence modifications in fuel use have taken place on site in order to

substitute a percentage of coal with Solid Recovered Fuel (SRF) at the facility. In order to accommodate this

modification in fuel use the following physical plant changes have taken place;

New fuel storage and feeding system has been installed

The bypass set up has been modified (with new conditioning tower and moving existing bypass filter)

New Selective Non Catalytic Reduction System (SNCR) has been installed for NOx emission

reductions

A new by-pass dust silo has been installed at the cement mill

There have been modifications to the existing abatement systems and new monitoring equipment

has been installed

The SRF is delivered to site by trucks equipped with walking floors and unloaded into covered receiving

station, from which the material is transported to the storage unit (all enclosed). SRF is extracted from the

unit by a screw conveyor and delivered to a dosing unit, which feeds the material via a hopper to a weigh

feeder for transport to the calciner by an air blower or chain conveyor.

3.1.2.4 Cement Milling and Dispatch

Clinker is mechanically extracted from the storage area and transported directly to the cement mill for

grinding. Within the mill, gypsum is added to control the settling time while flyash and ferrous sulphate are

also added to the cement. CEM II A/V uses filler to reduce the clinker content of cement therefore reducing

the carbon content. The gypsum, clinker, fly ash and ferrous sulphate are mixed to fine powder cement within

the mill before transportation to three storage silos. Two of these silos are used for despatch of bulk cement,

whilst the remaining silo the outer ring is used for bulk cement whilst the inner ring is fed to the bagging

plant.

3 . 1 . 3 S i t e E m i s s i o n s a n d A b a t e m e n t S y s t e m s

3.1.3.1 Surface Water Emissions

There is currently one emission point for surface water emissions, SW1, which discharges effluent from the

site’s settlement tank via a culvert into a ditch which links some 300m eastwards with the Woodford River

(see Figure 2).

Surface water emissions from the site occur as a result of routine wash-down processes and also as a result of

storm water. There is no production water discharged to the settlement tank. As such, there are not

considered to be any harmful or highly toxic constituents present within the effluent.

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The entire cement plant site is covered by one catchment area and an extensive drain network diverts all

surface water flow into a settlement tank. The settlement tank is a horizontal flow settlement tank of capacity

4,725 to 5,400m3 which allows for a two hour retention time during peak rainfall. There is an average

discharge from the tank of between 10 – 203/hr. The settlement tank extract solids and oil from the surface

water drainage system before discharge into the Woodford River. The tank incorporates a single

compartment oil interceptor which has a volumetric capacity of 450m3, thus ensuring that any significant

quantities of oil included within the site effluent that have occurred as a result of vehicular movement or

minor spills are recovered for disposal prior to discharge into the existing water course.

The maximum daily discharge permitted from the site is 10,000m3 and the emission limit values are detailed

in Table 3.1.

Table 3.1 – Surface water ELVs

Parameter Emission Limit Values

Temperature 25oC

pH 6-9

Toxicity 1 TU

BOD 10mg/l

Suspended solids 35mg/l

Aluminium 0.2mg/l

Chromium VI 0.03mg/l

Mineral oil 2mg/l

3.1.3.2 Groundwater Emissions

There are currently no emissions to ground within the facility.

3.1.3.3 Emissions to Sewer

Water is used within the cement production process at the Ballyconnell facility; however, no process

wastewater is generated by the site for discharge by sewer. Process water is either reused within a closed

cooling system or discharged to the atmosphere in the flue gases as water vapour. The only emissions to

sewer are those of standard sanitation and cleaning effluent. There are no process related emissions to sewer.

There is currently one emission point for sewer emissions, SE1, which discharges to the main district

sewerage system. This sewage emission point adjoins into the Cavan County Council main sewage system

within a manhole located adjacent to the facility works entrance.

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3.1.3.4 Dust Emissions

Given the nature of the cement production process and vehicle movements across the site there is a certain

amount of dust generated on site. A number of dust suppression measures are in operation across the site to

keep dust levels to a minimum. Bag filters are used for removing particulates from dust laden exhaust air at

the major atmospheric monitoring points A2-03 and A2-04. Smaller bag filters are used at minor atmospheric

emission points, except on boilers, to prevent fugitive dust emissions occurring during transportation of

materials between the various unit operations. Dust emissions from all major atmospheric emission points are

continuously monitored from the central control room. If increased dust emissions are noted at any emission

point, the bag filter is inspected and replaced if necessary.

Dust emissions are monitored at five locations across the site as illustrated on Figure 2. The dust emission

limit value for the site is 350mg/m2/day.

3.1.3.5 Noise Emissions

The cement plant operates on a continuous basis, 24-hours a day, 330-days per year. The cement plant

equipment consists of heavy industrial type machinery and there are multiple heavy vehicle movements

associated with the site. Therefore there are a considerable number of potential noise sources. Various noise

abatement measures have been implemented at the plant since operations commenced. These include but is

not limited to the following;

The north side kiln motor is encased within an acoustic envelope

The clinker motors are housed

Replacement of hydraulic kiln drive with electric drive

The majority of louvers within the grate cooler house have been replaced with special acoustic

louvers to reduce noise emissions

Noise suppression panels have been placed onto the cement mill intake fans

Silencers have been installed on the bagging plant extraction fans

Noise monitoring takes place annually at the locations illustrated on Figure 2 and the limits are 55dB(A)

Daytime and 45dB(A) Night-time.

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3.1.3.6 Emissions to Air

There are five major air emission points on site (see Figure 2 for locations) as follows:

Table 3.2 - Air Emission Points

Identifier Source Pollutants Abatement System

A2-01 Raw Mill/Kiln Sulphur dioxide

Oxides of nitrogen

Particulate matter

Total Organic Carbon

Hydrogen chloride

Hydrogen fluoride

Cadmium and Thallium

Mercury

Metals (Antimony, Arsenic, Lead,

Chromium, Cobalt, Copper,

Manganese, Nickel and Vanadium)

Dioxins and furans

Electrostatic precipitator

(deals with Particulate

Matter only)

Selective non-catalytic

reduction system for

NOx reduction

A2-02 Clinker Grate Cooler Particulate matter Electrostatic precipitator

A2-03 Coal Mill Particulate matter Bag filter

A2-04 Cement Mill Particulate matter Bag filter

A2-05 Sepax Separator for

Cement Mill

Particulate matter Bag filter

Electrostatic precipitators are used for removing particles from exhaust gases at the major emission points

A2-01 and A2-02, which are related to the raw mill / kiln exhaust and grate cooler exhaust respectively. NOx is

abated by a combination of a calciner which is designed to minimise emissions and the SNCR system installed

in the calciner specifically to reduce NOx levels when required.

Each emission point has been prescribed specific limit values and monitoring requirements to afford

environmental protection as detailed in Schedules B and C of the IED licence.

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3 . 1 . 4 N a t u r e a n d V o l u m e o f W a s t e s G e n e r a t e d

Table 3.3 provides an inventory of waste disposed of for 2013.

Table 3.3 Inventory of Waste Disposed for 2013

3 . 2 O p e r a t o r P e r f o r m a n c e

Quinn Cement is licensed under IED Licence No. P0378-02 by the EPA with regard to activities occurring on

the site that may have an impact on the environment. Quinn Cement complies with the conditions set out in

the licence thus ensuring activities on site have a minimal impact on the surrounding environment. Under

conditions of the Licence, all emissions from the site are monitored. In the event that emissions exceed these

limits, corrective action procedures are enforced to prevent such events re-occurring.

Quinn Cement maintains an Environmental Management System (EMS) with full ISO 14001 accreditation which

complies with Condition 2.2 of the IED Licence, a schedule of objectives and targets is maintained and is reviewed

on an annual basis.

Description Quantity (tonnes)

Disposal / Recover Contractor

Cost for 2013 (€)

Hazardous

Waste oil 5.4 ENVA Ireland 3,273

Oil rags 0.92 ENVA Ireland

Aerosols 0.08 ENVA Ireland

Oil filters 0.41 ENVA Ireland

Fluorescent tubes 0.22 Irish Lamp Recycling 311

WEEE 2.25 Irish Lamp Recycling

Drum and IBC 2.56 RILTA Environmental Ltd.

1,499

Non Hazardous

C & D 13.86 Wilton Waste Recycling 10,214

Scrap metals 142.1 Wilton Waste Recycling

General waste 84.93 Wilton Waste Recycling

Mixed packaging 13.36 Wilton Waste Recycling

Timber 25.26 Wilton Waste Recycling /

Mixed packaging 3.7 Envirogreen Recycling

Total 15,297

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A small fire occurred at the base of the Pan Conveyor in May 2010. The Pan Conveyor is located at the centre

of the site and is responsible for transporting clinker from the Grate Cooler building to the Clinker Store. The

fire was discovered by the Production Manager who mobilised the on-site fire team, the plant was

immediately shutdown. As a precaution the local fire service were contacted. A small amount of foam was

used by the fire services in fighting the fire, there were no emissions to surface water arising from the fire-

fighting effort therefore it was decided by the Environmental Advisor and Plant Management there was no

need to shut off the settlement tank to retain fire water.

There has been no fuel or chemical spills on the site to date.

Quinn Cement was last inspected by the EPA on the 13/10/2013. A number of observations were noted in order to

ensure compliance, improve environmental performance of the facility and provide clarification on certain issues.

The observations related to the co-incineration project, solid recovered fuels specification, baseline monitoring of

emissions to air, environmental liability risk assessment, windsock and bunding. Quinn Cement has addressed all

of the observations raised by the EPA.

There were 15 environmental complaints in relation to the activity in 2013. All of the complaints were in relation to

dust and were investigated immediately. Corrective actions were put in place where deemed appropriate.

Ten environmental incidents were reported during the period of 2013, six in relation to air emission, two in relation

to uncontrolled release, one in relation to CEMs malfunction and one in relation to the 2013 noise survey. Seven

environmental incidents were reported during the period of 2012.

3 . 3 E n v i r o n m e n t a l S e n s i t i v i t y 3 . 3 . 1 D e s i g n a t e d A r e a s & E c o l o g y

None of the site lies within a designated Natural Heritage Area, Special Area of Conservation (SAC) or Special

Protection Area (SPA). Mullinacre Upper is a Natural Heritage Area (NHA) lying approximately 1km north-

west of the site. This is a moorland site overlying shale and with a fairly intact bog surface.

3 . 3 . 2 H y d o l o g y

The facility is located upon the southeast-facing slope of Slieve Rushen Mountain, in the catchment of the

Woodford River. In the vicinity of the site, the Woodford River flows generally from south-west to north east,

veering east northeast. The river is situated some 400m to the south-east of the facility at its closest

approach. The Woodford River discharges to Upper Lough Erne. Its confluence with the lough is situated

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approximately 8.5km east northeast of the site. Significant reaches of the Woodford River including the

stretch in closest proximity to the site, have been canalised to create the Shannon-Erne Waterway.

There is a small pond located upon the boundary of the land holding, this is reported to have formerly been

used for collecting rainfall runoff, although it is no longer included in the site settlement system and is not

considered to be of ecological value. There are no other water bodies, other than the site settlement system,

within 1km standoff from the facility. The closest such feature is Annagh Lough, which is approximately 1.7km

to the southeast of the facility. The facility and the lough are situated on opposite sides of the Woodford

River.

The closest EPA surface water quality monitoring point is located downstream of the site at Ballyconnell quay

in the town (EPA Ref W010400). The latest water quality report published by Cavan County Council reports

this station is of Good Status (Cavan COCO, 2012). The EPA’s Envision database shows the Woodford is

expected to achieve good status in line with the current Surface Water (Environmental Objectives)

Regulations 2009.

There is no known flooding reported in the vicinity of the site as verified by the Office of Public Works Flood

Map Reporting Tool. There has been no impact to the site during the last few years of adverse weather

conditions including periods of heavy rainfall and cold snaps.

3 . 3 . 3 G e o l o g y a n d H y d r o g e o l o g y

The site is located upon the Dartry Limestone Formation which is of Carboniferous age. The bedrock has been

classified by the GSI as a regionally important, fissured bedrock aquifer. Due to the presence of a karstic flow

component, groundwater flow rates and levels may be anticipated to vary significantly for location to location

throughout the region. The vulnerability of the bedrock aquifer has been classified as high to extreme.

The published GSI data indicate that the site is underlain by glaciofluvial ice-contact drift. Boreholes drilled to

the east of the site encountered a thick interbedded series of sands, sands and gravels, alluvium and clays

extending to a depth of circa 15m.

The sands and gravels have been classified as a regionally important gravel aquifer which would be highly

vulnerable to surface contamination.

There are a number of groundwater supply wells in close proximity to the site including two private

groundwater wells to the southwest at distances of 325m and 500m from the site. Cavan County Council

operate a supply well (within the Dartry Limestone) circa 500m to the south of the site.

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A hydrogeological assessment which will involve drilling a number of additional monitoring wells is planned

for summer 2014 prior to SRF storage and processing activities on site.

3 . 3 . 4 P o t e n t i a l S e n s i t i v e R e c e p t o r s

The Licence application and associated EIA identified a number of potential sensitive receptors associated

with the site as outlined in Table 3.4.

Table 3.4 Potential Sensitive Receptors and distance from site

Discrete Sensitive Receptors

IGR Distance from site

X Y km

R1 Doon Heights 227622 319400 1.4

R2 Doon Bog 227502 319110 1.3

R3 Court House 227219 318787 1.8

R4 Preaching House Lanve 227096 319080 1.5

R5 Church Street 227054 318825 1.8

R6 Main Street 227384 318845 1.6

R7 Market House 227339 318784 1.8

R8 Ballyconnell House 227527 318694 1.8

R9 Derryginny Gardens 227071 318440 2.1

R10 Farm 1 227094 319981 0.7

R11 Farm 2 227345 319572 0.9

R12 Farm 3 228330 320466 0.8

R13 Farm 4 229179 320629 1.7

The location of these receptors is illustrated on Figure 2 and full descriptions are included in the application

files which are accessible through the EPA website.

3 . 4 R i s k I d e n t i f i c a t i o n

A number of processes are carried out during the operation of the facility, which may effect the environment.

These have been identified and are listed below.

Raw material handling

Raw milling

Clinker production – kiln, coolers and clinker store

Clinker production – coal milling plant

Clinker production – SRF

Cement milling

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Cement despatch

Bulk fuel storage and delivery

Hazardous waste storage and transfer

Oil storage and transfer

Emergency situation

Hazards are identified in relation to each process outlined above. Any possible cause of failure of the process

is identified and the effects on each environmental receptor are considered.

3 . 4 . 1 R a w M a t e r i a l H a n d l i n g a n d S t o r a g e – E m i s s i o n s t o A i r / S u r f a c e

W a t e r / N o i s e N u i s a n c e

The main raw materials used within the process are limestone and shale. Limestone is stored in concrete

bunkers located within contained enclosures. There are four intake hoppers for crushed limestone and sand

and one shale crusher. The shale, limestone and sand are tipped directly from dumpers into their respective

hoppers for processing and transport to the pre-blending store via enclosed rubber belt conveyors. The

potential hazard would be fugitive dust emissions arising from the raw material stock piles due to failure of

the bag filters and the transportation of raw materials between the various unit operations. Dust could also be

generated by the movement of vehicles on site transporting the raw materials. Noise could be generated

from the plant and from vehicle movements in this area of the facility. There is also the potential for storm

water runoff. The environmental effect would be a direct effect causing contamination of surface water, air

emissions and a noise nuisance.

Controls

Fully competent operatives (certified where applicable).

All personnel are trained.

Bag filters are visually inspected weekly and maintenance carried out when necessary.

All transport systems (rubber belt conveyors) are enclosed.

Larger materials which are less airborne are stock piled externally. The majority of materials are

stored in silos, bunkers, bins or sheds.

Materials containing potential pollutant parameters are stored under cover.

A settlement tank is in place for site run-off.

All plant in this area is in enclosed to reduce the noise levels.

Site operatives are only on site during daytime hours and no unnecessary maintenance is carried out

during evening or night time hours.

A sprinkler system is in place on the mountain haul road to reduce dust from vehicle movements.

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Air emission monitoring is carried out on a continuous, quarterly and annual basis for a number of

parameters.

Monitoring of surface water discharge is carried out on a continuous, weekly, monthly and quarterly

basis for a number of parameters.

Noise monitoring is undertaken on an annual basis.

3 . 4 . 2 R a w M i l l i n g - E m i s s i o n s t o A i r / N o i s e N u i s a n c e

The raw mill crushes and grinds the material to a very fine powder, known as raw meal. The resulting material

is lifted from the mill by circulation gas and passed through a rotary separator. Material that is too coarse falls

from the circulation gas and is returned to the mill for further grinding. The potential hazards associated with

this stage of the process relate to emissions to air from damaged bag filters, emissions of main particulates

from the main stack due to failure of the Electrostatic Precipitator (ESP). There may also be fugitive emissions

from the process and from transport systems. Noise from this area of the facility may also lead to a noise

nuisance. The environmental effect from this stage of the process would be a direct impact causing

contamination of air and a noise nuisance.

Controls



Bag filters are visually inspected weekly and maintenance carried out when necessary.

All transport systems are enclosed.

A five stage preheater tower with calciner and low NOx burner is in place.

Fugitive emissions from the process are controlled as it is an enclosed process.

Excess gas from the process is passed through an ESP to remove particulates before release to

atmosphere.

A plant maintenance system is in place to minimise ESP trips and to provide control of material to

prevent build ups and blockages. The plant is shut down manually upon trip of the ESP.

The raw mill is enclosed and acoustic roller doors are fitted on the entrance.

Air emission monitoring is carried out on a continuous, quarterly and annual basis.


3 . 4 . 3 C l i n k e r P r o d u c t i o n – K i l n , C o o l e r a n d C l i n k e r S t o r e – E m i s s i o n s t o

A i r / N o i s e N u i s a n c e


tower. Once the material reaches the kiln inlet and it gradually moves down the coal/SRF fired rotating kiln.

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The temperature of the raw meal is raised from 860°C to 1,500°C in the kiln, initiating the clinker production

process. The clinker passes through the cooling zone before leaving through the kiln outlet, where it falls

down into the grate cooler. Once cooled, the clinker exits the cooler via a hammer crusher and is conveyed to

the clinker store. The potential hazards associated with this stage of the process relate to emissions of

particulates from the grate cooler stack, a trip of the ESP, fugitive emissions from damaged bag filters and

from the transport system. There is also the potential hazard of noise emissions from the kiln drive. The

environmental effect from this stage of the process would be a direct impact causing contamination of air and

a noise nuisance.

Controls



Bag filters which are used to prevent fugitive dust emissions arising from the conveyor system are

visually inspected weekly and maintenance carried out when necessary.

Fugitive emissions from the process are controlled as it is an enclosed process.

Emissions from the grate cooler stack are passed through the ESP to remove particulates before

release to atmosphere.

A plant maintenance system is in place to minimise ESP trips and to provide control of material to

prevent build ups and blockages. The plant is shut down manually upon trip of the ESP.

A noise barrier (plastic curtains) is in place at the kiln drive.

Regular maintenance reduces the noise levels from this stage of the process.



3 . 4 . 4 C l i n k e r P r o d u c t i o n – C o a l M i l l i n g P l a n t – E m i s s i o n s t o A i r / N o i s e

N u i s a n c e

The coal mill consists of a vertical roller mill comprising a built in separator and circulation fan. The raw coal is

ground to a powder between a grinding table and three stationary fixed rollers. The ground material is lifted

by circulating gas, passes through the rotary separator and is extracted from the circulated gas by a bag filter

installation and transported to bins via screw conveyors. The pulverised coal is fed to the kiln and calciner

firing systems by means of dosing systems and blowers for transporting the coal meal in steel tubes. The

potential hazards associated with this stage of the process relate to emissions of particulates from the coal

mill stack / damaged bag filters and fugitive emissions from the transport system. There is also the potential

hazard of noise emissions from mill. The environmental effect from this stage of the process would be a direct

impact causing contamination of air and a noise nuisance.

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Controls



Continuous monitoring is in place on the main bag filters in the coal mill.


The coal mill is fully enclosed which prevents noise emissions.

Air emission monitoring is carried out on a continuous, quarterly and annual basis. Spot checks are

also carried out by the EPA.


3 . 4 . 5 C l i n k e r P r o d u c t i o n – U s e o f S R F

SRF is delivered to site by trucks equipped with walking floors and unloaded into covered receiving station,

from which the material is transported to storage units. SRF is extracted from these units by a screw conveyor

and delivered to a dosing unit, which feeds the material via a hopper to a weigh feeder for transport to the

calciner by an air blower or chain conveyor. The potential hazards associated with this stage of the process

include fugitive dust emissions during delivery of SRF to site and transportation of SRF to the calciner,

emissions from the kiln stack and clinker cooler and NOx emissions from flue gases. The environmental effect

from this stage of the process would be a direct impact causing contamination of air.

Controls



SRF receiving station is operated under negative pressure.

Bag filters are used to prevent dust emissions during transportation of SRF within conveyor systems.

A bag filter is used in the kiln to abate bypass flow dust emissions.

Electrostatic precipitators are used to abate emissions from the kiln stack and clinker cooler.

A SNCR system is in place to reduce NOx emissions within the flue gases.

Air emission monitoring is carried out on a continuous, quarterly and annual basis. Spot checks are

also carried out by the EPA.

3 . 4 . 6 O p e r a t i o n o f S N C R – E m i s s i o n s t o S u r f a c e W a t e r / S o i l s /

G r o u n d w a t e r

A SNCR system has been installed as an environmental mitigation measure. This process is a recognised

technology that reduces the oxides of nitrogen collectively known as NOx within exhaust gases into its

molecular nitrogen form. The SNCR plant is a dosing mechanism that introduces a technical quality aqueous

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solution of ammonia for the reduction of the NOx within the flue gases. The ammonia solution is stored in a

non-pressurized stainless steel storage tank, designed for filling from road tankers via a special pump module

contained within the SNCR plant. The tank and auxiliary equipment are covered by a shelter to protect from

rainfall and to prevent release of vapours occurring from overheating from the direct exposure to sunlight.

The potential hazard would be a spill due to unloading and a spill due to failure of the bund. The

environmental effect would be a direct impact causing contamination of soils, groundwater and surface

water. There is a potential for a large volume of pollutants with the volume of the ammonia tank at 150,000

litres.

Controls



Ammonia tank is bunded and an integrity test is carried out once every three years.

During delivery the nozzle attaches within the confines of the bund.

Decentralised machine control module in place which controls the processes and communicates with

the central control room computer. If a leak should occur, an alarm will be generated based on a level

switch between the storage tank and the bund.

Spill kits are located on site and the bund is visually inspected once a week.

In the event of an emergency the settlement tank can be closed off to prevent discharge entering the

river.

Groundwater monitoring is carried out on a biannual basis.



3 . 4 . 7 B u l k F u e l ( D i e s e l a n d K e r o s e n e ) S t o r a g e a n d D e l i v e r y – E m i s s i o n s

t o S u r f a c e W a t e r / S o i l s / G r o u n d w a t e r

There are three kiln diesel tanks located on site with a total capacity of 90,000 litres, there is one 2,728 litre

diesel tank for onsite machinery, one diesel tank with a capacity of 2,000 litres for heating and one kerosene

tank with a capacity of 2,000 litres for heating. The potential hazards would be a fuel spill during unloading

and a spill due to failure of the bunds. The environmental effect would be a direct impact causing

contamination of soils, groundwater and surface water. There is potential for a large volume of pollutants

with the volume of the six bulk fuel tanks ranging from 2,000 litres to 30,000 litres.

Controls



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Diesel tanks are bunded and an integrity test is carried out once every three years.

During fuel delivery the fuel nozzle attaches within the confines of the bund.



river.




3 . 4 . 8 C e m e n t M i l l i n g – E m i s s i o n s t o A i r / N o i s e N u i s a n c e

The cement mill consists of a two-chamber cylindrical ball mill which is a closed circuit grinding mill. Gypsum

and clinker are mixed to fine powder along with flyash and ferrous sulphate to produce cement. A negative

pressure is maintained in the cement mill system by the circulation fan which also transports an amount of

finished product out of the mill. The potential hazards associated with this stage of the process relate to

emissions of particulates from the cement mill stack / damaged bag filters. There is also the potential hazard

of noise emissions from mill. The environmental effect from this stage of the process would be a direct impact

causing contamination of air and a noise nuisance.

Controls



Continuous monitoring is in place on the main bag filters in the cement mill.


An automated system is in place involving the use of a weighbridge which controls the over filling of

tankers. Any malfunction in the system causes an automatic shutdown.

An automated system is in place which controls the over filling of bags. Any malfunction in the

system causes an automatic shutdown.

The mill has an acoustic door and is fully enclosed to prevent noise emissions.

Speed restrictions are in place, one way system eliminating the need for reverse sirens.



3 . 4 . 9 C e m e n t D e s p a t c h – B a g g i n g P l a n t – E m i s s i o n s t o A i r

Cement is packed into bags at a rate of 4,000 bags.hour-1

. A maximum of approximately 7,000 tonnes of

cement is stored in the bagging plant. The potential hazards associated with this stage of the process relate to

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fugitive emissions from damaged bag filters. There is also the potential hazard of noise emissions from the

bagging plant blower and from vehicle movement. The environmental effect from this stage of the process

would be a direct impact causing contamination of air and a noise nuisance.

Controls



Bag filters are visually inspected weekly and maintenance is carried out when necessary.

A lorry wash is available for vehicles to clear any dust from vehicles.

Despatch bays are enclosed.

A roller door is in place to enclose the blower fan.



3 . 4 . 1 0 H a z a r d o u s W a s t e S t o r a g e a n d T r a n s f e r – E m i s s i o n s t o S o i l s /

G r o u n d w a t e r / S u r f a c e W a t e r

Hazardous waste on site includes waste oil, batteries, grease cartridges, rags, filters and florescent tubes. The

potential hazards would be a spill from the hazardous waste storage area and a spill of hazardous waste

during transfer on site. The environmental effect would be a direct impact causing contamination of soils,

groundwater and surface water.

Controls



Hazardous materials are stored in a bunded area.

Spill procedures are in place.

Emergency response procedures are in place.

An inventory of waste is maintained on site.

A waste management programme is in place which includes procedures for handling and disposal of

wastes.

A weekly check is carried out of the hazardous waste storage area.

3 . 4 . 1 1 N o n H a z a r d o u s W a s t e S t o r a g e a n d T r a n s f e r

Non-hazardous waste on site consists of recyclable materials, WEEE, scrap metal, timber and pallets, waste

for baling and ink cartridges. All material waste is recyclable back through the system. There are no major

environmental liabilities associated with general waste storage.

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Controls



An inventory of waste is maintained on site.

A waste management programme is in place which includes procedures for handling and disposal of

wastes.

3 . 4 . 1 2 O i l S t o r a g e a n d T r a n s f e r – E m i s s i o n s t o S u r f a c e W a t e r /

S o i l s / G r o u n d w a t e r

A number of engineering materials are stored in a bunded area in the Store / Workshop in 208 litre barrels.

The potential hazards would be a spill during unloading and a spill due to failure of the bund. The

environmental effect would be a direct impact causing contamination of soils, groundwater and surface

water.

Controls


All personnel trained.

The storage area is bunded and an integrity test is carried out once every three years.

Spill kits are located on site and bunds are visually inspected once a week.


river.




3 . 4 . 1 3 E m e r g e n c y S i t u a t i o n ( F i r e / E x p l o s i o n ) – E m i s s i o n s t o A i r /

S u r f a c e W a t e r

Accidental emissions to air could arise in the event of fires or explosions occurring at the facility. The

occurrence of a fire or explosion is not specific to any one process on site. The main risks are concerned with

oil, gas, chemical storage and use, mechanical/electrical failure resulting in fire/explosion, the generation of

dust resulting in dust explosions and locations where hot work is taking place.

The principal environmental hazard associated with a fire or explosion is the potential for gaseous releases of

toxic or pollutant matter to the atmosphere and also contaminated fire water. The release of gaseous

emissions during a fire would temporarily deteriorate local air quality and impact on the atmosphere. Some

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materials may emit hazardous decomposition products during a fire. Therefore, these releases may

potentially raise health and safety issues for human receptors and carry potential liabilities.

There is no feasible technical method of containment or remediation of releases to atmosphere during a fire.

However, comprehensive fire prevention and fire fighting systems are in place to prevent and control the

occurrence of fires anywhere within the site. These include fire detection and alarm systems, explosion

suppression systems, fire doors, fire hydrants, hose reels and portable fire extinguishers.

With respect to environmental liability, it is possible that firewater may flow to the drainage system. However

current procedure is that once the Emergency Controller has confirmed a fire on site the Shift Supervisor is

responsible for cutting off the discharge from the settlement tank in order to contain the firewater.

Controls


An emergency response plan and team are in place.

Emergency response training is carried out.

Bunding is in place.

A settlement tank in place for retention of fire water.

The operation of the facility is controlled by the latest edition of the FLS-Automation PLC based

control system with additional supporting control and supervision system.

Fire suppression systems are in place.

Bi-annual fire drills are carried out.

The site’s Firewater Risk Assessment has been reviewed and will be submitted to the Agency for approval in

July 2014.

3 . 4 . 1 4 D i e s e l / A m m o n i a T r a n s f e r – E m i s s i o n s t o S u r f a c e W a t e r

/ S o i l s / G r o u n d w a t e r

The potential hazard would be a leak from a diesel or ammonia tanker within the site boundary. The

environmental effect would be a direct impact causing contamination of surface water, soils and

groundwater.

Controls



Spill kits are located on site

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river.




3 . 4 . 1 5 D i e s e l / A m m o n i a T r a n s f e r – E m i s s i o n s t o S u r f a c e W a t e r /

S o i l s / G r o u n d w a t e r

The potential hazard would be a diesel or ammonia tanker crashing within the site boundary causing a release

of diesel or ammonia. The environmental effect would be a direct impact causing contamination of surface

water, soils and groundwater.

Controls





river.




3 . 4 . 1 6 U s e o f C h e m i c a l s w i t h i n t h e L a b – E m i s s i o n s t o S u r f a c e

W a t e r / S o i l s / G r o u n d w a t e r

A number of chemicals such as dilithium tetraborate, lilithium tetraborate, ethyl glycol, propanol and silica gel

are stored in a dedicated storage area in the laboratory. The potential hazard would be a spill of these

chemicals during their use within the lab. The environmental effect would be a direct impact causing

contamination of surface water, soils and groundwater.

Controls



Laboratory chemicals are stored in a specific bunded storage area


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river.




3 . 4 . 1 7 U s e o f E n g i n e e r i n g M a t e r i a l s w i t h i n t h e W o r k s h o p –

E m i s s i o n s t o S u r f a c e W a t e r / S o i l s / G r o u n d w a t e r

The following engineering materials are stored in a bunded area in the Store / Workshop; MobilGear 630,

MobilGear 632, MobilGear 634, MobilGear 636, Delvac Super, Mobil Almo 527, Mobil DTE 25, Mobil DTE 24,

Mobil DTE Medium, DTE AA, Mobil Hydraulic Oil 32, Mobilux EP2 and Mobilux EP3. The potential hazard

would be a spill of these materials during their use within the workshop. The environmental effect would be a

direct impact causing contamination of surface water, soils and groundwater.

Controls



Engineering materials are stored in a specific bunded storage area



river.




3 . 4 . 1 8 C o a l S t o r a g e – F i r e – E m i s s i o n s t o S u r f a c e W a t e r / A i r

The potential hazard would be a fire in the coal storage area leading to accidental emissions to air and release

of firewater to surface water. The environmental effect would be a direct impact causing contamination of air

and surface water.

Controls






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3 . 4 . 1 9 S R F S t o r a g e A r e a – F i r e – E m i s s i o n s t o S u r f a c e W a t e r / A i r

The potential hazard would be a fire in the SRF storage area leading to accidental emissions to air and release

of firewater to surface water. The environmental effect would be a direct impact causing contamination of air

and surface water.

Controls










3 . 4 . 2 0 F a i l u r e o f S u r f a c e W a t e r D r a i n a g e N e t w o r k – E m i s s i o n s t o

S u r f a c e W a t e r / S o i l s / G r o u n d w a t e r

The potential hazard would be failure of the surface water drainage network. The environmental effect would

be a direct impact causing contamination of surface water, soils and groundwater.

Controls



The drainage network is visually inspected on a weekly basis




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3 . 4 . 2 1 O v e r f l o w o f C e m e n t S i l o – E m i s s i o n s t o A i r

The cement is conveyed to three cement storage silos for storage. All three silos are used for despatch of bulk

cement, with the inner ring of silo no. 3 being automatically fed to the bagging plant for use as bag cement.

The potential hazard would be an overflow of the silo. The environmental effect would be a direct impact

causing windborne dust nuisance.

Controls



An automated system is in place which controls the overfilling of silos. Any malfunction in the system

causes an automatic shutdown.

3 . 4 . 2 2 C o n t r a c t o r A c t i v i t i e s – E m i s s i o n s t o S u r f a c e

W a t e r / S o i l s / G r o u n d w a t e r / A i r

The potential hazard would be as part of construction, contractor activities, building sites and contractor

compounds could generate dust and noise emissions.

Controls



Contractor induction programme in place.

Project meetings, hazops on new projects and reviews of existing systems carried out.

Frequent on site audits of equipment carried out.

3 . 4 . 2 3 G r i n d i n g A i d S t o r a g e a n d D e l i v e r y – E m i s s i o n s t o S u r f a c e

W a t e r / S o i l s / G r o u n d w a t e r

There are two grinding aid tanks located on site with a capacity of 40,000 litres each. The potential hazards

would be a spill of grinding aid during unloading and a spill due to failure of the bund. The environmental

effect would be a direct impact causing contamination of soils, groundwater and surface water.

Controls



Grinding aid tanks are bunded and an integrity test is carried out once every three years.



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4.0 RISK ANALYSIS

The risks above were assessed against likelihood and consequence as per tables 4.1 and 4.2. The results are

presented in Table 4.3.

Table 4.1 – Risk Classification Table – Likelihood

Table 4.2 – Risk Classification Table – Consequence

Rating

Likelihood

Category Description

1 Very Low Very low chance of hazard occurring

2 Low Low chance of hazard occurring

3 Medium Medium chance of hazard occurring

4 High High chance of hazard occurring

5 Very High Very high chance of hazard occurring

Rating

Severity

Category Description

1 Trivial No damage or negligible change to environment

2 Minor Minor impact / localised or nuisance

3 Moderate Moderate impact to environment

4 Major Severe impact to environment

5 Massive Massive impact to a large area, irreversible in medium term

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Table 4.3 – Risk Analysis

Risk ID

Process Potential Hazards Environmental

Effect Consequence

Rating Basis of Consequence

Likelihood Rating

Basis of Likelihood Risk Score

(Consequence x Likelihood)

1 Raw Material Handling

and Storage

Failure of bag filters at raw

material storage leading to

fugitive dust emissions

Emissions to air 2

No method of

containing emissions to

air, mitigated by dilution

in air

3

Fully competent

operatives, bag filters

are visually inspected

weekly

6


and Storage

Transport of raw materials

between unit operations Emissions to air 3

No method of



in air

2 All transport systems are

enclosed 6


and Storage

Movement of vehicles on

site transporting raw

materials

Emissions to air 1

No method of



in air

2

A sprinkler system is in

place on the mountain

haul road to reduce dust

from vehicle

movements

2


and Storage

Generation of noise from

the plant Noise Nuisance 2

Slight impact on nearest

sensitive receptors 2

Plant in this area is

enclosed, site operatives

are only on site during

daytime hours, nearest

sensitive receptor is

approximately 1.3km

from the facility

4


and Storage


vehicle movements Noise Nuisance 2



Site operatives are only

on site during daytime

hours, nearest sensitive

receptor is

approximately 1.3km

from the facility

4


and Storage

Surface water runoff from

external stock piles

Emissions to

surface water 1

Raw materials present

are not harmful to the

environment

2

Materials containing

potential pollutant

parameters are stored

under cover. A

2

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Risk ID


Effect Consequence


Likelihood Rating



settlement tank is in

place for site run-off.

7 Raw Milling Failure of bag filters Emissions to air 2

No method of



in air

3

Fully competent



weekly

6

8 Raw Milling

Failure of ESP leading to

emissions of main

particulates from the main

stack

Emissions to air 2

No method of



in air

5

Historical incidents

involving a trip of the

ESP

10

9 Raw Milling Fugitive air emissions from

the transport system Emissions to air 3

No method of



in air


enclosed 6

10 Raw Milling Fugitive air emissions from

the process Emissions to air 2

No method of



in air

2 Enclosed process 4

11 Raw Milling Generation of noise from

the plant Noise Nuisance 2



Raw mill is enclosed and

acoustic roller doors are

fitted on the entrance

4

12 Clinker Production –

Kiln, Cooler and

Clinker Store

Failure of bag filters Emissions to air 2

No method of



in air

3

Fully competent



weekly

6


Kiln, Cooler and

Clinker Store

Emissions of particulates

from the grate cooler / A

trip of the ESP

Emissions to air 2

No method of



in air

5



ESP

10


Kiln, Cooler and

Fugitive air emissions from


No method of

containing emissions to 2

All transport systems are

enclosed 6

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Final

Risk ID


Effect Consequence


Likelihood Rating



Clinker Store air, mitigated by dilution

in air


Kiln, Cooler and

Clinker Store


the kiln drive Noise Nuisance 2



A noise barrier (plastic

curtains) is in place,

regular maintenance is

carried out

4


Coal Milling Plant


from the coal mill stack /

Failure of bag filters

Emissions to air 2

No method of



in air

3

Fully competent

operatives, continuous

monitoring is in place on

the main bag filters

6


Coal Milling Plant

Fugitive air emissions from


No method of



in air


enclosed 6


Coal Milling Plant

Generation of noise

emissions from the mill. Noise Nuisance 2



The coal mill is fully

enclosed 4


Use of SRF Failure of bag filters Emissions to air 2

No method of



in air

3

Fully competent


are inspected weekly

6


Use of SRF Failure of ESP Emissions to air 2

No method of



in air

5



ESP

10


Use of SRF Failure of SNCR system Emissions to air 2

No method of



in air

2

A decentralised machine

control module controls

the processes and

communicates with the

central control room

computer.

4

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Risk ID


Effect Consequence


Likelihood Rating



22 Operation of SNCR Spill of ammonia during

unloading

Emissions to soil,

groundwater and

surface water

3

Immediate detection

likely. Cost of site

investigation and

remediation

2

Fully competent

operatives, bunded area,

nozzle attaches within

the confines of the bund

6

23 Operation of SNCR Spill of ammonia due to

failure of the bund

Emissions to soil,

groundwater and

surface water

4 150,000 litre tank 1

Integrity tested once

every 3 years, visually

inspected weekly, leaks

will trigger an alarm

4

24 Bulk Fuel Storage and

Delivery Fuel spill during unloading

Emissions to soil,

groundwater and

surface water

3

Immediate detection


investigation and

remediation

2

Fully competent


fuel nozzle attaches

within the confines of

the bund, monthly

deliveries

6

25 Bulk Fuel Storage and

Delivery

Fuel spill due to failure of

the bunds

Emissions to soil,

groundwater and

surface water

4

Six tanks, quantity of

tanks ranging from

2,000 litres to 30,000

litres

2

Integrity test carried out

once every three years,

visually inspected

weekly

8

26 Cement Milling

Failure of bag filters /


from the cement mill stack

Emissions to air 2

No method of



in air

3

Fully competent

operatives, continuous

monitoring is in place on

the main bag filters

6

27 Cement Milling

Fugitive emissions to air

from the cement dispatch

system

Emissions to air 3

No method of



in air

2

Automated system to

control over filling of

tankers and the over

filling of bags.

6

28 Cement Milling Generation of noise

emissions from the mill. Noise Nuisance 2



Acoustic door and fully

enclosed. One way

system eliminating the

need for reverse sirens.

4

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Risk ID


Effect Consequence


Likelihood Rating



29 Cement Despatch Failure of bag filters Emissions to air 2

No method of



in air

3

Fully competent



weekly

6

30 Cement Despatch

Generation of noise

emissions from bagging

plant blower

Noise Nuisance 2 Slight impact on nearest


A roller door is in place

to enclose the blower

fan

4

31 Cement Despatch

Generation of noise

emissions from vehicle

movement

Noise Nuisance 2 Slight impact on nearest


One way system

eliminating the need for

reverse sirens.

4

32 Hazardous Waste

Storage and Transfer

Spill from the hazardous

waste storage area

Emissions to soil,

groundwater and

surface water

3 Cost of site investigation

and remediation 2

Fully competent


weekly checks carried

out

6

33 Hazardous Waste

Storage and Transfer

Spill of hazardous waste

during transfer

Emissions to soil,

groundwater and

surface water

3

Immediate detection


investigation and

remediation

3

Fully competent

operatives, containment

reduced during transfer

9

34 Oil Storage and

Transfer

Spill during unloading and

transfer

Emissions to soil,

groundwater and

surface water

3

Immediate detection


investigation and

remediation

3

Fully competent

operatives, containment

reduced during transfer

9

35 Oil Storage and

Transfer

Spill due to failure of the

bund

Emissions to soil,

groundwater and

surface water


and remediation 2

Integrity test carried out

once every three years,

visually inspected

weekly

6

36 All processes where a

fire risk occurs

Fire explosion resulting

from significant fire risks Emissions to air 2

No method of



in air

2

Fire prevention,

detection and

extinguishing systems in

place

4

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Risk ID


Effect Consequence


Likelihood Rating



37 All processes where a

fire risk occurs

Fire explosion resulting

from significant fire risks

Firewater

emissions to

surface water

4

Cost of remediation if

contaminated firewater

is released from site

2

Fire prevention,

detection and


place, alarms and

controls on the surface

water drainage system

8

38 Diesel/Ammonia

Transfer

Spill of diesel/ammonia

during transfer within the

site boundary

Emissions to soil,

groundwater and

surface water

3

Immediate detection


investigation and

remediation

2

Fully competent

operatives, monthly

deliveries

6

39 Diesel/Ammonia

Transfer

Spill of diesel/ammonia as a

result of a tanker crashing

on site

Emissions to soil,

groundwater and

surface water

3

Immediate detection


investigation and

remediation

2

Fully competent

operatives, monthly

deliveries

6

40 Use of Chemicals

within the Lab

Spill of chemicals during

handling

Emissions to soil,

groundwater and

surface water

3

Immediate detection


investigation and

remediation

2

Fully competent

operatives, chemicals

stored in bunded areas

6

41 Use of Engineering

Materials within the

Workshop

Spill of engineering

materials during handling

Emissions to soil,

groundwater and

surface water

3

Immediate detection


investigation and

remediation

2

Fully competent

operatives, engineering

materials stored in

bunded areas.

6

42 Coal Storage Fire in the coal storage area

Emissions to

surface water and

air

4




2

Fire prevention,

detection and


place, alarms and



8

43 SRF Storage Fire in the SRF storage area

Emissions to

surface water and

air

4




2

Fire prevention,

detection and


8

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st August 2014

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Final

Risk ID


Effect Consequence


Likelihood Rating



place, alarms and



44 General Operation Failure of the surface water

drainage network

Emissions to soil,

groundwater and

surface water


and remediation 2

Visually inspected on a

weekly basis, alarms and



6

45 Cement Storage Overflow of cement silo Emissions to air 2

No method of



in air

2

Automated system in

place to control the over

filling of silos. Any

malfunction causes an

automatic shutdown.

4

46 Site Works Contractor activities

Emissions to air,

generation of

noise

2

No method of



in air. Slight impact on

nearest sensitive

receptors.

2

Contractor induction

carried out, frequent

audits carried out

4

47 Grinding Aid Delivery Spill during unloading

Emissions to soil,

groundwater and

surface water

3

Immediate detection


investigation and

remediation.

2

Fully competent


spill kits in place.

6

48 Grinding Aid Storage Spill due to failure of the

bund

Emissions to soil,

groundwater and

surface water

4 80,000 litre capacity

tank 2

Integrity tested once

every three years,

visually inspected

weekly

8

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Final

5.0 RISK EVALUATION

Table 5.1 – Risk Evaluation Table

Risk ID Description Consequence Rating Likelihood Rating Risk Score

8 Failure of ESP at the raw milling stage leading to emissions to air 2 5 10

13 A trip of the ESP during the clinker production stage leading to emissions to air 2 5 10

20 A trip of ESP during clinker production stage (using SRF) leading to emissions to air 2 5 10

33 Spill of hazardous waste during transfer resulting in emissions to soil, groundwater and surface water

3 3 9

34 Oil spill during loading and unloading resulting in emissions to soil, groundwater and surface water

3 3 9

25 Fuel spill due to failure of bunds resulting in emissions to soil, groundwater and surface water 4 2 8

37 Fire / explosion resulting in emissions of contaminated firewater to surface water 4 2 8

42 Fire in the coal storage area resulting in emissions to surface water and air 4 2 8

43 Fire in SRF storage area resulting in emissions to surface water and air 4 2 8

48 Spill of grinding aid due to failure of bund resulting in emissions to soil, groundwater and surface water

4 2 8

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22 Spill of ammonia during unloading 3 2 6

24 Fuel spill during unloading resulting in emissions to soil, groundwater and surface water 3 2 6

32 Spill from the hazardous waste storage area resulting in emissions to soil, groundwater and surface water

3 2 6

35 Oil spill due to failure of the bund resulting in emissions to soil, groundwater and surface water

3 2 6

9 Fugitive air emissions from the transport system of the raw milling stage 3 2 6

14 Fugitive emissions from the transport system for clinker production leading to emissions to air

3 2 6

17 Fugitive air emissions from the transport system for clinker production 3 2 6

27 Fugitive emissions to air from the cement despatch system 3 2 6

2 Transport of raw materials between unit operations leading to emissions to air 3 2 6

1 Failure of bag filters at raw material storage leading to fugitive dust emissions 2 3 6

7 Failure of the bag filters in the raw mill resulting in emissions to air 2 3 6

12 Failure of bag filters in clinker production leading to emissions to air 2 3 6

16 Failure of bag filters in the coal milling plant leading to emissions to air 2 3 6

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19 Failure of bag filters leading to emissions to air 2 3 6

26 Failure of bag filters in the cement mill leading to emissions to air 2 3 6

29 Failure of bag filters at cement despatch leading to emissions to air 2 3 6

38 Leak from diesel/ammonia tanker within the site boundary 3 2 6

39 Spill of diesel/ammonia as a result of a tanker crashing within the site boundary 3 2 6

40 Spill of chemicals during handling within the lab 3 2 6

41 Spill of engineering materials during handling within the workshop 3 2 6

44 Failure of surface water drainage network 3 2 6

47 Spill of grinding aid during unloading resulting in emissions to soil, groundwater and surface water

3 2 6

4 Generation of noise from the raw material handling and storage area 2 2 4

5 Generation of noise from movement of vehicles at the raw material handling and storage area 2 2 4

10 Fugitive air emissions from the raw milling process 2 2 4

11 Generation of noise from the raw milling stage 2 2 4

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15 Generation of noise from the kiln drive 2 2 4

18 Generation of noise from clinker production 2 2 4

21 Failure of SNCR system leading to emissions to air 2 2 4

23 Spill of ammonia due to failure of the bund 4 1 4

28 Generation of noise from the cement mill 2 2 4

30 Generation of noise at the cement despatch stage of the process 2 2 4

31 Generation of noise from vehicle movements at cement despatch 2 2 4

36 Fire / explosions resulting in emissions to air 2 2 4

37 Overflow of cement silo resulting in emissions to air 2 2 4

38 Contractor activities resulting in the generation of noise and dust 2 2 4

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43 21st

August 2014

50410

Final

5 . 1 R i s k M a t r i x

A risk matrix has been developed to display the risks visually with colour coding to give an indication of the critical

nature of each risk (Table 5.2).

Table 5.2 – Risk Matrix

LIK

EL

IHO

OD

V High 5 8,13, 20

High 4

Medium 3 1,7,12,16,19,

26,29

33, 34

Low 2 4,5,10-11, 15,

18,21, 28, 30,

31, 36,45,46

2,9,14, 17, 22,

24,27,32,35,38

39,40,41,44,47

25, 37,42,43,

48

V. Low 1 23

Trivial Minor Moderate Major Massive

1 2 3 4 5

CONSEQUENCE

The risk matrix is displayed in Table 5.2. The risks have been colour coded in the matrix to provide a broad

indication of the critical nature of each risk in order to facilitate prioritisation of risks for treatment. The risk matrix

indicates that there no risks in the red zone, there are ten risks located in the amber zone requiring treatment

through mitigation or management action. All other risks are located in the green zone, indicating the need for

continuing awareness and monitoring on a regular basis.

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44 21st

August 2014

50410

Final

6.0 RISK TREATMENT

The output of the risk treatment process is the development of a statement of measures to be taken to minimise

the environmental risk of the activity. The statement of measures is presented in Table 6.1 where a set of

appropriate and achievable mitigation measures are assigned to each risk, with a risk owner responsibility for the

ongoing management of the risk and a timeframe for implementation of the risk mitigation measure.

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45

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August 2014

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Final

Table 6.1 – Statement of Measures

Risk ID

Potential Risk Risk Score

Mitigation Measures to be taken Outcome Action Date for Completion

Owner / Contact Person

1. Raw Material Handling and Storage; Failure of bag filters at raw material storage leading to fugitive dust emissions

6

Bag filters are visually checked on a weekly basis and preventative maintenance is carried out, no further mitigation measures are necessary

Reduced potential for breaches of ELV

Continue with existing controls

On-going Engineering Manager

2. Raw Material Handling and Storage; Transport of raw materials between unit operations

6

All conveyors on site are enclosed to prevent fugitive emissions to air, no further mitigation measures are necessary

Not applicable Not applicable Not applicable

Not applicable

3. Raw Material Handling and Storage; Movement of vehicles on site transporting raw materials

2

A sprinkler system is in place on the mountain haul road which will continue to be used to reduce dust from vehicle movements, no further mitigation measures are necessary




4. Raw Material Handling and Storage; Generation of noise from the plant

4

Plant in this area is enclosed and operatives are only on site during daytime hours, no further mitigation measures necessary


Not applicable

5. Raw Material Handling and Storage; Generation of noise from vehicle movements

4

Operatives are only on site during daytime hours and the nearest sensitive receptor is approximately 1.3km from the site, no further mitigation measures necessary


Not applicable

6. Raw Material Handling and Storage; Surface water runoff from external stock piles

2 Settlement tank in place for site run-off, no further mitigation measures are necessary


Not applicable

7. Raw Milling; Failure of bag filters 6



Not applicable On-going Engineering Manager

8. Raw Milling; Failure of ESP leading to emissions of main particulates from the

10 A plant maintenance system is in place to minimise ESP trips. A




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46

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August 2014

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Final

Risk ID




main stack procedure is in place to shut down the plant immediately on trip of the ESP. No further mitigation measures are necessary

9. Raw Milling; Fugitive air emissions from the transport system

6



Not applicable

10. Raw Milling; Fugitive air emissions from the process

4

Enclosed process, potential fugitive emissions during maintenance work, no further mitigation measures necessary


Not applicable

11. Raw Milling; Generation of noise from the plant

4 No further action required Not applicable Not applicable Not applicable

Not applicable

12. Clinker Production – Kiln, Cooler and Clinker Store; Failure of bag filters

6





13. Emissions of particulates from the grate cooler / A trip of the ESP

10

A plant maintenance system is in place to minimise ESP trips. A procedure is in place to shut down the plant immediately on trip of the ESP. No further mitigation measures are necessary




14. Clinker Production – Kiln, Cooler and Clinker Store; Fugitive air emissions from the transport system

6



Not applicable

15. Clinker Production – Kiln, Cooler and Clinker Store ; Generation of noise from the kiln drive

4

A noise barrier is in place at the kiln drive and the chain and disk conveyor under the Grate Cooler has been enclosed. No further mitigation measures are necessary.


Not applicable

16. Clinker Production – Coal Milling Plant; Emissions of particulates from the coal mill

4 Continuous monitoring is in place on the bag filters and displayed in


Not applicable

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47

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August 2014

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Final

Risk ID




stack / Failure of bag filters the control room, any fault is detected immediately. No further mitigation measures are necessary

17. Clinker Production – Coal Milling Plant; Fugitive air emissions from the transport system

6



Not applicable

18. Clinker Production – Coal Milling Plant; Generation of noise emissions from the mill.

4 The sheeting at the coal mill has been replaced, no further mitigation measures are necessary


Not applicable

19. Clinker Production – Use of SRF; failure of bag filters

6

Continuous monitoring is in place on the bag filters and displayed in the control room, any fault is detected immediately. No further mitigation measures are necessary


Not applicable

20. Clinker Production – Use of SRF; trip of ESP

10

A plant maintenance system is in place to minimise ESP trips. A procedure is in place to shut down the plant immediately on trip of the ESP. No further mitigation measures are necessary




21. Clinker Production – Use of SRF; failure of SNCR

4

Continuous monitoring is in place and displayed in the control room, any fault is detected immediately. No further mitigation measures are necessary


Not applicable

22. Spill of ammonia during unloading 6 Continued supervision by Quinn Cement of contractors during unloading

Reduced potential for spillage during unloading


On-going Not applicable

23. Ammonia spill due to failure of bund 4 Alarm is triggered by any leak. No further mitigation measures are necessary


Not applicable

24. Bulk Fuel Storage and Delivery; Fuel spill during unloading

6 Continued supervision by Quinn Cement of contractors during unloading

Reduced potential for spillage during unloading



25. Bulk Fuel Storage and Delivery; Fuel spill 8 Continue to carry out visual checks Reduced potential for spillage Continue with existing On-going Engineering

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Final

Risk ID




due to failure of the bunds of bunds on a weekly basis, integrity testing will continue to be carried out every three years

during delivery and storage controls Manager

26. Cement Milling; Failure of bag filters / Emissions of particulates from the cement mill stack

6

Continuous monitoring is in place on the bag filters and displayed in the control room, any fault is detected immediately. No further mitigation measures are necessary




27. Cement Milling; Fugitive emissions to air from the cement dispatch system

6

Automated system to control over filling of tankers and over filling of bags, any fault is detected immediately. No further mitigation measures are necessary




28. Cement Milling; Generation of noise emissions from the mill.

4

A curtain has been installed on the door at the cement mill east of PFA silo to minimise noise breakout from the building. No further mitigation measures are necessary.


Not applicable

29. Cement Despatch; Failure of bag filters 6





30. Cement Despatch; Generation of noise emissions from bagging plant blower

4

A roller door is in place to enclose the blower fan and a roller shutter door is in place at the bagging Plant blower on Silo 3. No further mitigation measures are necessary


Not applicable

31. Cement Despatch; Generation of noise emissions from vehicle movement

4

One way system is in place eliminating the need for reverse sirens, no further mitigation measures are necessary


Not applicable

32. Hazardous Waste Storage and Transfer; Spill from the hazardous waste storage area

6 The area will continue to be checked on a weekly basis

Reduced potential of spill during storage



33. Hazardous Waste Storage and Transfer; 9 Ensure waste is packaged correctly Reduced potential of spill Continue with existing On-going Engineering

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Final

Risk ID




Spill of hazardous waste during transfer during transfer to reduce the risk of spills

during transfer controls Manager

34. Oil Storage and Transfer; Spill during unloading and transfer


Reduced potential of spill during unloading and transfer



35. Oil Storage and Transfer; Spill due to failure of the bund

6

Continue to carry out visual checks of bunds on a weekly basis, integrity testing will continue to be carried out every three years

Reduced potential of spill during storage



36. All processes where a fire risk occurs; Fire explosion resulting from significant fire risks

4 Continue to maintain fire prevention, detection and extinguishing systems in place

Reduced potential of fire Continue with existing controls


37. All processes where a fire risk occurs; Fire explosion resulting from significant fire risks

8

Continue to maintain fire prevention, detection and extinguishing systems in place. A ‘cutting off the discharge’ drill has been incorporated into the training of all shift supervisors in relation to the control on the surface water drainage system.



38. Leak from ammonia/diesel tanker within the site boundary


Reduced potential for spillage Continue with existing controls


39. Spill from ammonia/diesel tanker as a result of a tanker crashing on site




40. Spill of chemicals during handling within the lab

6

Stored in bunded area, staff are fully trained, spill kits in the areas, no further mitigation measures are necessary


Not applicable

41. Spill of engineering materials during handling within the workshop

6

Stored in bunded area, staff are fully trained, spill kits in the areas, no further mitigation measures are necessary


Not applicable

42. Fire at the coal storage area 8 Continue to maintain fire prevention, detection and


Ongoing Engineering Manager

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50

21st

August 2014

50410

Final

Risk ID




extinguishing systems in place. A ‘cutting off the discharge’ drill has been incorporated into the training of all shift supervisors in relation to the control on the surface water drainage system.

43. Fire at the SRF storage area 8

Continue to maintain fire prevention, detection and extinguishing systems in place. A ‘cutting off the discharge’ drill has been incorporated into the training of all shift supervisors in relation to the control on the surface water drainage system.



44. Failure of surface water drainage system 6 Visual checks carried out on a weekly basis. No further mitigation measures are necessary.


Not applicable

45. Overflow of cement silo 4

Automated system in place to control the over filling of silos. No further mitigation measures are necessary.


Not applicable

46. Contractor activities 4 Contractor induction carried out, regular audits. No further mitigation measures are necessary.


Not applicable

47. Spill of grinding aid during unloading 6 Continued supervision by Quinn Cement of contractors during unloading



48. Spill of grinding aid due to failure of the bund

8

Continue to carry out visual checks of bunds on a weekly basis, integrity testing will continue to be carried out every three years



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51 21st

August 2014

50410

Final

7.0 IDENTIFICATION OF PLAUSIBLE WORST CASE SCENARIO

The ELRA for this activity identified six risks with a major consequence;

Risk ID 23: Spill of ammonia due to failure of bund

Risk ID 25: Fuel spill due to failure of bund

Risk ID 37: Fire explosion resulting from significant fire risks

Risk ID 42: Fire in the coal storage area

Risk ID 43: Fire in the SRF storage area

Risk ID 48: Spill of grinding aid due to failure of bund

Further analysis was conducted to determine the plausible worst case scenario. It was determined that there may

be a domino effect between Risk ID 37 and 23. In that a fire in the SNCR (Risk ID 37) could trigger Risk ID 23 spill of

ammonia due to failure of the bund. This is considered plausible as the ammonia tank is incorporated into the

SNCR and would be impacted by a fire in this area. These combined risks are considered the plausible worst case

scenario for the activity and are quantified and costed for the purposes of financial provision below.

8.0 QUANTIFICATION AND COSTING

The plausible worst case scenario (combined event of Risk ID 37 and 23) has been quantified and costed in Table

8.1. The plausible worst case scenario is predicted to involve:

Generation of fire water which would be contained

Ammonia spill due to failure of bund

Contamination of soil

Potential contamination of groundwater and surface water

Generation of waste due to decontamination of buildings

In addition to containment, excavation, transport and disposal of those losses, additional control and

remediation measures include;

o Fire fighting

o Site investigation

o Remediation

o Monitoring

o Consultancy

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52 20th

August 2014

50410

Final

Table 8.1 – Quantification and Costing of Plausible Worst Case Scenario

Task Description Quantity

(No.) Measurement

Unit Unit Rate (€) Cost (€) Source of Unit Rates

Response to Fire in

SNCR and

Response to loss

from ammonia

tank

Fire Fighting 1 Event 2,000 2,000 Cavan Fire Service

Transport and disposal of firewater 220 Tonne 200 44,000 Rilta Environmental Ltd.

Decontamination of building 4 Day 1870 7,480 Rilta Environmental Services

Transport and disposal of decontamination wastes 50 Tonne 450 22,500 Rilta Environmental Services

Environmental monitoring (groundwater and surface water) 4 Event 2,500 10,000 QED / Biolabs

Air 4 Event 3,300 13,200 Catalyst Environmental /Biolabs

Consultancy costs 3 Day 680 2,040 Verde Environmental

Phase I preliminary risk assessment and Phase II site

investigation for GQRA

1 Event 20,000 20,000 Verde Remediation Services

Phase III DQRA & Phase IV remedial option study and design 1 Event 10,000 10,000 Verde Remediation Services

Remediation programme 1 Event 50,000 50,000 Verde Remediation Services

Excavation of contaminated soil 5 Day 1,000 5,000 Verde Remediation Services

Transport and disposal of contaminated soil 250 Tonne 135 33,750 Rilta Environmental Ltd.

Importation of topsoil 250 Tonne 50 12,500 Landscape Depot

Validation testing 1 Event 5,000 5,000 Verde Remediation Services

Landscaping 4 Day 500 2,000 Verde Remediation Services

Long term groundwater monitoring (quarterly for 2 years) 8 Event 1,600 12,800 Verde Environmental

Subtotal 252,270

Contingency (10%) 25,270

Total 277,497

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53 21st

August 2014

50410

Final

9.0 CONCLUSION

An environmental liabilities risk assessment has been carried out for the activity in accordance with the EPA

Guidance.

The financial provision has been based on the risk that poses the plausible worst case scenario. This is the

maximum liability that may be incurred and as such, financial provision is calculated at €277,497 based on this

event.

Quinn Cement will make the necessary financial provision to cover this liability.

The risk management at the activity is a dynamic process and will be updated through the addition of new risks or

the omission of redundant risks. The financial provision will be reviewed in accordance with Condition 12 to ensure

it continues to cover the environmental liabilities.

10.0 BIBLIOGRAPHY

Quinn Cement Ltd. Annual Environmental Reports 2013, 2012

IPPC Licence Review Application, Quinn Cement (WYG Environment 2009)

EPA Guidance Document; Guidance on Assessing and Costing Environmental Liabilities (EPA 2014)

EPA Licence P0378-02

Quinn Cement Environmental Management System Documentation

Quinn Cement Register of Aspects and Impacts

Environmental Impact Statement prepared for License Review Quinn Cement (various contributors).

Verde, Quinn Cement Ltd. Environmental Liability Risk Assessment, 2013

Quinn Cement Ltd., Site Closure Plan, 2009

Verde, Quinn Cement Ltd. Firewater Risk Assessment, 2014

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E n v i r o n m e n t a l L i a b i l i t y R i s k A s s e s s m e n t

AUGUST 2014

QUINN CEMENT


FIGURES

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www.verde.ieTel: + 353 1 201 1260 Date: Feb. 2013 Job Ref: 50112

Title:


Not to Scale Figure 1

Sensitive Receptor Locations

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MUCKLAGH

SCOTCHTOWN

Not to Scalewww.verde.ie

Tel: + 353 1 201 1260 Date: June 2014 Job Ref: 50410

Title:


LEGENDDust Deposit GaugeNoise MonitorSurface Water Sample

Groundwater Sample

Air Emission Points

Site Boundary

A2-01 KilnA2-02 Grate CoolerA2-03 Coal MillA2-04 Cement MillA2-05 Sepax Filter

A2-01A2-03

A2-02

A2-05A2-04

D4 D2

D1

D5

SW

SW1

GW

GW1

N6

N6

N3

N4

N5

D4

D3

SettlementTank

Monitoring Locations Map

Figure No. 2

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E n v i r o n m e n t a l L i a b i l i t y R i s k A s s e s s m e n t

AUGUST 2014

QUINN CEMENT


Figure 3: Please refer to Quinn Cement layout drawing supplied

alongside this report

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Attachment L i

Attachment L – Statutory Requirements Table of Contents

Table of Contents................................................................................................................................................. i Statutory Requirements ..................................................................................................................................... 1

Air Emissions ................................................................................................................................................... 1 Water Emissions............................................................................................................................................... 2 Regulations Under European Communities Act 1972 ................................................................................ 4 Noise Emissions ............................................................................................................................................... 5

Prevention of Significant Environmental Pollution .................................................................................... 5 Waste ................................................................................................................................................................. 6 Energy Efficiency ............................................................................................................................................. 7 Accidents ........................................................................................................................................................... 8 Cessation of Activity ....................................................................................................................................... 8

Fit and Proper Persons .................................................................................................................................... 9 Best Available Techniques .............................................................................................................................. 9 EU Habitats Directive .................................................................................................................................... 10 Best Environmental Practice for control of Diffuse Emissions ................................................................ 10

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Attachment L 1

Statutory Requirements Section 83(3)(5) of the Environmental Protection Agency Act (1992) and Protection of

the Environment Act (2003) outline statutory requirements which must be met in

order that an IE Licence will be granted by the Environmental Protection Agency

(EPA). Upon review of Section 83(3)(5)(a)(i) to(v) and (vii) to (xa) it is evident that

many of the requirements are already addressed through the various sections of the

IE Licence application form.

This attachment therefore outlines the statutory requirements and how these will be

achieved by Quinn Cement Ltd at the Ballyconnell facility. Furthermore, and in

accordance with Article 13(5) of the Industrial Emissions Directive, reference should

be made to Attachment I.8 where specific treatment is given to the relevant BAT

conclusions.

Air Emissions

Section 83(5)(a)(i) of the Environmental Protection Agency Act (1992) and Protection

of the Environment Act (2003) states the following:

“The Agency shall not grant a licence or revised licence for an activity—

(a) unless it is satisfied that—

(i) any emissions from the activity will not result in the contravention of any relevant air

quality standard specified under section 50 of the Air Pollution Act 1987, and will comply

with any relevant emission limit value specified under section 51 of the Air Pollution Act

1987.”

Air Quality Standards (AQS), as outlined under the Air Pollution Act (1987) (S.I

244/1987), cover sulphur dioxide (SO2), suspended particulates, lead (Pb) and

nitrogen dioxide (NO2). These standards have been continuously modified towards

the air quality assessment year 2010. Within the most recently issued air quality

legislation, Air Quality Standards Regulations (2007), limit values and AQS are now

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Attachment L 2

also prescribed for maximum concentrations of benzene (C6H6) and carbon monoxide

(CO) within ambient air.

The Air Quality Standards Regulations (2011) (S.I. No. 180 of 2011) came into force on

19th April 2011 and transpose EU Directive 2008/50/EC into Irish law. AQLVs were

published in these regulations for seven pollutants and critical levels for the protection

of vegetation were included for two species (sulphur dioxide, nitrogen dioxide and

oxides of nitrogen, particulate matter, lead, benzene and carbon monoxide with NOx

and SO2 critical levels for the protection of vegetation).

A detailed air dispersion modelling assessment has been undertaken using the

AERMOD software in order to assess the potential impact associated with

atmospheric emissions arising from the Quinn Cement Ballyconnell facility and the

revision to the process. The results of the assessment have been reviewed in the

context of relevant National and European Legislation

The results of this modelling, together with an assessment of the likely environmental

impacts associated with these emissions is included within Attachment I.1.

Water Emissions

Section 83(5)(a)(ii) of the Environmental Protection Act (1992) and Protection of the

Environment Act (2003) states the following:

“The Agency shall not grant a licence or revised licence for an activity


(ii) any emissions from the activity will comply with, or will not result in the; contravention

of, any relevant quality standard for waters, trade effluents; and, sewage effluents and

standards in relation to treatment of such effluents prescribed under section 26 of the Local

Government (Water Pollution) Act 1977.”

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Attachment L 3

In this context relevant water quality regulations were reviewed by BCL Consultant

Hydrogeologists in their hydrogeological and hydrological review of the proposal

with regards to surface water and groundwater. The laboratory data as part of this

study has been compared with the relevant standards put forward in the EPA

Document “Parameters of Water Quality: Interpretation and Standards” (2001); also

the Interim Guideline Values (IGV) as detailed in the EPA’s “Interim report towards

setting guideline values for the protection of groundwater in Ireland” (2003);

Groundwater Regulation Threshold Values under S.I. 9 of 2010; and Drinking Water

Regulation under S.I. 122 of 2014.

The activity will not have an adverse effect on water quality as defined by S.I. No. 258

of 1998 (Local Government (Water Pollution) Act, 1977 (Water Quality Standards for

Phosphorus) Regulations, 1998) as effluent containing phosphorus does not arise from

the facility.

In relation to the EC Environmental Objectives (Surface Water) Regulations (S.I. 272

of 2009) emissions monitoring at emission point SW1 were within relevant EQS as

follows:

Parameter (ug/l) SW1 (2015) EQS (2009)

Lead and its Compounds <0.3 7.2

Copper and its

Compounds <3 5 to 30

Zinc and its Compunds 1.5 8 to 100

There are no adverse impacts anticipated to surface water from run-off from the site.

The activity is not liable to have an adverse effect on water quality in light of the

European Communities Environmental Objectives (Surface Water) Regulations 2009

(S.I. No. 272 of 2009).

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Attachment L 4

Emissions to sewer are standard domestic sewerage discharges and are treated in the

local Ballyconnell WWTW. Emissions to sewer do not arise from process activities and

it was therefore concluded that there was no potential to impact with respect to

sewage effluent.

There are no adverse impacts to groundwater anticipated from the site. The activity is

not liable to have an adverse effect on water quality in light of the European

Communities Environmental Objectives (Ground Water) Regulations 2010 (S.I. No. 9

of 2010). There are deemed to be sufficient controls through mitigation and

monitoring proposals.

Substances emitted to air and water from Quinn Cement which fall under the

Schedule of the EPA (Industrial Emissions) (Licensing) 2013, S.I. No. 137 of 2013 are

as per Licence Application Tables E1(iii)(iv)(v) and E2(ii).

Regulations Under European Communities Act 1972

Section 83(5)(a)(iii) of the Environmental Protection Act (1992) and Protection of the




(iii) any emissions from the activity or any premises, plant, methods, processes, operating

procedures or other factors which affect such emissions will comply with, or will not result in

the contravention of, any relevant standard including any standard for an environmental

medium prescribed under regulations made under the European Communities Act 1972, or

under any other enactment.”

Further to the discussion in relation to Air emissions and water emissions above, other

relevant guidelines in relation to other relevant environmental media are discussed

hereafter.

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Attachment L 5

Noise Emissions

Section 83(5)(a)(iv) of the Environmental Protection Act (1992) and Protection of the




(iv) any noise from the activity will comply with, or will not result in the contravention of, any

regulations under section 106.”

The most recent annual noise assessment undertaken in 2016 at sensitive locations in

the vicinity of the Ballyconnell plant, has demonstrated compliance with the relevant

guidance levels.

Prevention of Significant Environmental Pollution

Section 83(5)(a)(v) of the Environmental Protection Act (1992) and Protection of the




(v) any emissions from the activity will not cause significant environmental pollution.”

The existing operations at the Ballyconnell facility do not cause any significant

environmental pollution, as demonstrated within past Quinn Cement Annual

Environmental Reports (AERs).

A detailed dispersion modelling assessment of atmospheric emissions has been

undertaken as a result of the change to the Ballyconnell facility, as presented within

Attachment I. This assessment has assessed the impact of atmospheric emissions

associated with the operation of the Ballyconnell facility against the appropriate

AQSs.

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Attachment L 6

Annual monitoring of emissions to surface water, as presented within Attachment E.2,

show no annual exceedences for 2015.

As referenced within Attachment E.4, there are currently no emissions to

groundwater. Furthermore, it is not considered that there will be any new emissions

to groundwater as a result of this application for an IE licence review. However,

groundwater is analysed for pollutants on a bi-annual basis in accordance with

conditions within the current licence. The site has additional GW monitoring capacity

through recent investment in peripheral wells at the site boundary.

The most recent annual noise assessment undertaken in 2016 at sensitive locations in

the vicinity of the Ballyconnell plant, has demonstrated compliance with the guidance

levels.

Waste

Section 83(5)(a)(vii) of the Environmental Protection Act (1992) and Protection of the




(vii) having regard to Part III of the Act of 1996, production of waste in the carrying on of the

activity will be prevented or minimised or, where waste is produced, it will be recovered or,

where that is not technically or economically possible, disposed of in a manner which will

prevent or minimise any impact on the environment,

(viia) without prejudice to subparagraph (vii), waste generated in the carrying on of an

industrial emissions directive activity, in order of priority in accordance with section 21A

(inserted by Regulation 7 of the European Communities (Waste Directive) Regulations 2011)

of the Act of 1996, will be prepared for re-use, recycled, recovered or, where that is not

technically or economically possible, disposed of in a manner which will prevent or minimise

any impact on the environment”

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Attachment L 7

Quinn Cement have implemented a hierarchy principle for waste management at the

Ballyconnell facility, which promotes re-use, recovery and recycling of waste which is

actively promoted on site. This hierarchy has been outlined within Attachment C.

Quinn Cement has installed an enclosed waste segregation area at the Ballyconnell

facility containing waste baling equipment. A designated member of staff has been

assigned responsibility for maintenance of this waste segregation area. Dedicated bins

have been placed at the points of main waste production to enable segregation of

waste at source.

All raw materials collected by abatement systems are recycled back into the process.

In order to minimise any impact upon the environment, waste which requires disposal

is transported from site by licensed waste carriers for disposal within licensed

facilities. Details of all waste streams generated, together with quantities, the waste

carrier company and final destination is contained within Attachment H. All waste

disposal is undertaken in accordance with the Waste Management Act (1996).

Energy Efficiency

Section 83(5)(a)(viii) of the Environmental Protection Act (1992) and Protection of the




(viii) energy will be used efficiently in the carrying on of the activity.”

Quinn Cement is fully committed to maximising energy efficiency throughout all

plant operations. The company has an Energy Management System in place to the

criteria of ISO50001 (Energy Management Systems). Reference should be made to

Attachment G for an outline of existing and proposed energy efficiency measures at

the plant.

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Attachment L 8

Accidents

Section 83(5)(a)(viii) of Environmental Protection Act (1992) and Protection of the




necessary measures will be taken to prevent accidents in the carrying on of the activity and,

where an accident occurs, to limit its consequences for the environment and, in so far as it does

have such consequences, to remedy those consequences.”

Quinn Cement Ltd has written procedures for accident prevention and an emergency

response, which are contained within the company Environmental Management

System (EMS). These procedures are outlined within Attachment J and Attachment C,

respectively. The Company has carried out an Environmental Liability Risk

Assessment (ELRA) as outlined in Attachment K.

Cessation of Activity

Section 83(5)(a)(x) of the Environmental Protection Act (1992) and Protection of the




(x) necessary measures will be taken upon the permanent cessation of the activity (including

such a cessation resulting from the abandonment of the activity) to avoid any risk of

environmental pollution and return the site of the activity to a satisfactory state.”

Quinn Cement has completed a site closure remediation and aftercare management

plan (CRAMP) in accordance with the EPA Guidance. A copy of this is contained

within Attachment K.

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Attachment L 9

Fit and Proper Persons


unless it is satisfied that—

(xi) the applicant or licensee or transferee, as the case may be, is a fit and proper person to hold

a licence, and, where appropriate, the Agency shall attach conditions relating to the matters

specified in the foregoing subparagraphs to the licence or revised licence,”

As outlined in Attachment C the facility, whilst under interim management, was

prosecuted for a dust exceedance incident which occurred in September 2014. The

original management, who designed, built and operated the facility since 2000, have

since December 2014 taken over management control at the facility once again. Under

current management there have been no convictions in relation to the facility from

2000 to 2013 and from 2015 to present.

During the first shutdown in January 2015, upon resuming management of the Plant,

over €2 million alone was spent on upgrading the plant’s dust abatement system.

Details of the qualifications, technical knowledge and experience of relevant staff is

provided in Attachment C.

Best Available Techniques

Section 5(3)(a) of the EPA Act’s, 1992 and 2003 specify the relevant BAT Conclusions

as a basis for ELV setting. In these circumstances the relevant BAT Conclusions have

been reviewed at Appendix I8: “Commission Implementing Decision of 26th March 2013

establishing the Best Available Techniques (BAT) conclusions under Directive 2010/75/EU of

the European Parliament and of the Council on Industrial emissions for the production of

cement, lime and magnesium oxide (2013/163/EU).

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Attachment L 10

EU Habitats Directive

Screening for Appropriate Assessment indicated that the proposal has the potential to

result in negative long term impacts which are considered to be of minor significance

to ecological features of interest that are of international significance namely the

Moninea Bog SAC as a result of acid gas air emissions. No mitigation measures were

deemed necessary for this impact. Consequently, this will result in a minor negative

residual impact.

The proposal also has the potential to result in the positive long term impacts which

are considered to be of minor significance/negligible significance to ecological

features of interest that are of both International and national importance, namely the

Upper Lough Erne SAC and the Upper Lough Erne - Crom ASSI. These positive

impacts arise as a result of water reuse proposals at the cement plant which will reduce

the discharge rate to the Woodford River and downstream impact at these receptors.

A Natura Impact Statement (NIS) has been completed which provides for a full

assessment of the potential impacts on Natura 2000 and Ramsar sites identified as

being at risk of impacts from air emissions. The NIS concludes that there is no

potential for adverse impacts on any Natura 2000 or Ramsar site identified as a result

of the proposed changes to the Ballyconnell cement plant. The NIS is provided in

Appendix B.6(f).

Best Environmental Practice for control of Diffuse Emissions

Best environmental practices will be put in place for control of diffuse emissions from

the installation as set out in the following legislation:

• BAT Conclusions Implementing Decision published by the EC Commission

Implementing Decision of 26th March 2013 establishing the Best Available

Techniques (BAT) conclusions under Directive 2010/75/EU of the European

Parliament and of the Council on Industrial emissions for the production of

cement, lime and magnesium oxide (2013/163/EU);

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Attachment L 11

• The BAT Guidance Note for the Cement and Lime Sector 2008 in accordance

with Section 5 of the Environmental Protection Agency Act 1992 as amended;

• The following regulations are not relevant to this facility: Urban Waste Water

Treatment Regulations 2001 (S.I. No. 254 of 2001) as amended by the Urban

Waste Water Treatment (Amendment) Regulations 2004 (S.I. No. 440 of 2004)

or any future amendment thereof;

• The following regulations are not relevant to this facility: European

Communities (Good Agricultural Practice for Protection of Waters)

Regulations 20 (S.I. No. 610 of 2010) or any future amendment thereof;

• Local Government (Water Pollution) Act, 1977 (Control of Cadmium

Discharges) Regulations 1985 (S.I. No. 294 of 1985) – Quinn Cement are

compliant with the limits in these regulations;

• Local Government (Water Pollution) Act, 1977 (Control of

Hexachlorocyclohexane and Mercury Discharges) Regulations 1986 (S.I. No. 55

of 1986) - Quinn Cement are compliant with the limits for mercury in these

regulations;

• The following regulations are not relevant to this facility: Local Government

(Water Pollution) Acts, 1977 and 1990 (Control of Carbon Tetrachloride, DDT

and Pentachlorophenol Discharges) Regulations 1994 (S.I. No. 43 of 1994);

• Measures or controls identified in a pollution reduction plan for the river basin

district prepared in accordance with Part V of the EC Environmental Objectives

(Surface Waters) Regulations 2009 S.I. No. 272 of 2009 for the reduction of

pollution by priority substances or the ceasing or phasing out of emissions,

discharges and losses of priority hazardous substances – no specific measures

or controls were identified in a River Basin Management Plan relevant to the

facility.

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