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IPPC LICENCE APPLICATION
Irish Cement Limited
Platin Works
IPPC Licence Reg. No. P0030-03
RESPONSE TO THE ENVIRONMENTAL PROTECTION AGENCY’S REQUEST FOR
FURTHER INFORMATION
December 2007
Irish Cement Limited
Platin
Drogheda
Co. Louth
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1. Provide details of the current and planned production capacity of cement clinker in each of
the kilns;
The EPA verified the capacity of Kiln 1 and Kiln 2 as 1396 tonnes/day and 4265 tonnes/day
respectively in 2006 during its invigilation of the installation’s Greenhouse Gas Emissions.
The new Kiln 3, currently under construction and due to be commissioned in late 2008, will
have a nominal capacity of 5,000 tonnes/day.
Irish Cement Limited (ICL) has no current plans to increase the capacity of the existing Kiln
2. However, cyclone up-grades, tertiary air duct installation and other potential modifications
are kept under constant review. In advance of any decision to increase capacity discussions
will be initiated with the Agency with a view to agreeing proposed modifications either
through Licence Review, Technical Amendment or Annual Environmental Management Plan.
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2. Provide geo-referenced digital drawing files (e.g AutoCAD files) in Irish Grid projection of
the site boundary and overall site plan, including labelled emission, monitoring and sampling
points. Please provide this data on a separate CD-ROM containing section B.2, E.6 and F.3
of the IPPC Licensing Application Form;
The information is provided on a separate CD-ROM accompanying this response.
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3. Describe in outline the main alternatives, if any, to the proposals contained in the application
which were studied by the applicant;
In 2006, following detailed consideration of a number of alternatives, ICL confirmed its
decision to build a new modern, state of the art kiln line at Platin Works and so increase the
company’s capacity to meet market demand with cement manufactured from clinker produced
in a modern energy efficient kiln.
The main alternatives to building a new modern cement kiln at Platin Works to meet market
demand included;
• continuing to import clinker and cement
• building a kiln line at Limerick Works
• increasing the capacity of existing kilns.
It was concluded, in order to ensure the continued availability of a sustainable supply of
cement to the Irish construction sector, with optimum benefits for the environment, excellence
in customer service and satisfactory capital expenditure payback, that an incremental capacity
unit at Platin Works (in close proximity to the Dublin market) represented the optimal
solution.
The new modern kiln line, currently under construction at Platin, has been designed to Best
Available Techniques (BAT) Standards. Key elements representing BAT include:
• Kiln 3 5-Stage Single String Preheater Kiln
• In-line Calciner
• Clinker Grate Cooler
• Vertical Raw Mill 3
• Vertical Coal Mill 3
• Vertical Cement Mill 4
• High Efficiency Separators on all Mills
• BAT Filters on all Major and Minor Emission Points
• Enclosed clinker store.
Kiln 3’s 5-Stage Single String Preheater system meets BAT and was chosen over alternatives
as it emits lower nitrogen oxides (NOX) concentrations, has better heat economy and lower
energy consumption than alternative Preheater kiln systems. SNCR technology, which
represents BAT, will be installed if required. The Kiln 3 process is dedusted with a bag filter,
which represents BAT, and is preferred over the alternative electrostatic precipitator filter due
to the fact that the possibility of filter trips is eliminated on the kiln system.
A Grate Cooler, which represents BAT, was chosen for Kiln 3. This type of cooler optimises
heat recovery/exchange with the kiln process. An electrostatic precipitator was chosen for the
Grate Cooler as this represents BAT for dedusting high temperature gas streams from coolers.
All mills chosen for the new project are “vertical” mills, which represent BAT and consume
less kWh/tonne than the alternative “horizontal” mills. All mills are fitted with high efficiency
separators to optimise power consumption and product performance. All mill processes are
dedusted by bag filters, which represent BAT.
New clinker storage capacity being installed as part of the development will improve
environmental performance by minimising the need for the external storage of the material.
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The increased milling capacity on site is essential to allow the Company to maximise the
production of CEM II cements using limestone as a main constituent with clinker in cement
production. The production and marketing of CEM II cements is being maximised to reduce
the carbon intensity of cements produced at Platin Works.
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4. Give details of the proposed SNCR to be installed on kiln 2 and on the proposed kiln 3.
Included information on the criteria for operation, control and management of the equipment
and BAT considerations made including those relating to the designed NOx reduction rate.
Provide a timeframe within which the SNCR will be operational on each kiln;
Kiln 2
Piping and Instrumentation flow diagrams for the Kiln 2 SNCR plant were submitted in the
IPPC Licence Application in Attachment F. These are included in the figures section.
The Kiln 2 SNCR plant is designed to reduce nitrogen oxides (NOX) from the combustion
process by using a 10–25 % solution of ammonia (as a reducing agent) and injecting it into
the flue gas.
NOX is reduced by reaction with the ammonia solution to form nitrogen gas and water. The
mass transportation process and the reaction kinetics of the reactants require specific
conditions regarding chemical composition in the flue gas, retention time and temperature. In
the riser duct after the kiln, the flue gas velocity is very high and retention time for the
chemical reaction is very short. The chemical NOX - reducing reaction is only active in a
narrow temperature interval. At the hot side of the temperature window a lower chemical
yield may occur i.e. giving an expensive and limited NOX reduction. At the “cold” side of the
temperature window, formation of N2O and ammonia slip may occur.
The ammonia is stored in two stainless steel, single skinned, tanks. The tanks are enclosed by
a reinforced concrete bund, which is designed to contain 110% of the capacity of the largest
tank. The ammonia solution is pumped from the storage tanks to the injectors. It is diluted
with de-ionised water.
Injection of the ammonia solution is carried out by means of up to 7 riser duct injectors,
installed in a specific configuration, at several points of the kiln riser duct. The injectors are
installed, directed and constructed in such a way that injection angle, droplet size distribution,
spray pattern and impulse assures a thorough mixing of the reduction chemical with the flue
gas at the right temperature and oxygen concentration.
A PLC based system is used to control the SNCR plant and undertakes automatic start up,
shut down and normal operation. Through the control system, it is possible to adjust set
points, control parameters, alarm limits, alarm delays and similar parameters, and to change
between manual and automatic mode. The injection equipment includes adequate
instrumentation for indication of flow, pressure etc.
Final commissioning of the SNCR system with the assistance of VDZ (The Research Institute
of the German Cement Industry) is planned for January 2008. This will include measurement
of ammonia slip as well as optimising the plant to ensure efficient NOX reduction. Plant
operating guidelines will be developed at this stage.
The EU BREF for cement manufacture states that there is a view that BAT levels should be
stated as 500-800 mg/Nm3. It has now understood that the Agency acknowledges this BAT
range and it is confidently predicted that in the long run, following commissioning, the NOX
emissions from Kiln 2 can be controlled below 800 mg/Nm3.
However, to allow for completion of commissioning and optimisation, it was requested in the
original IPPC licence application that an elevated limit of 1000 mg/Nm3, dry, 10 % O2 be
granted for the first 6 months of SNCR system operation.
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As discussed at the recent clarification meeting with the Agency it is intended, following the
granting of the IPPC Licence to run the system to meet an expected Emission Limit Value of
800mg/Nm3. However, during commissioning, daily average values above this value are
likely to occur as the system is further optimised. In practice injection rates and points will be
altered. It is not expected that this period of long term commissioning optimisation will
continue for more than six months.
Kiln 3
The new In-Line Calciner (ILC) technology being installed on the Kiln 3 Preheater system
represents BAT for reducing NOX formation in the Kiln Preheater Tower. Essentially, the
technology employed allows some of the NOX formed during the burning process to be
converted back to nitrogen and oxygen thus achieving a reduced NOX emission. The
suppliers are indicating that the ILC system should ensure BAT emission levels for NOX of
less than 800 mg/Nm3.
The Kiln 2 SNCR system is capable of feeding the Kiln 3 system and will be utilised if the
ILC system fails on commissioning to perform as expected. Should SNCR be installed on
Kiln 3 in the future, the Agency would be notified in advance.
In the original IPPC licence application, it was requested that an elevated limit of 1,300
mg/Nm3, dry, 10 % O2 be granted for the firts year of commissioning and operation of Kiln
3. This is proposed in order to allow for a practical approach to commissioning of a new kiln
system and the possible introduction of the SNCR technology.
As discussed at the recent clarification meeting with the Agency it is proposed to run the
system on start up to meet an expected Licence Limit of 800 mg/Nm3. However, during
commissioning and optimisation it is expected that daily average values above this level will
occur as the ILC optimisation process is developed and as the SNCR system, if installed, is
optimised.
Kiln 3 is a modern ILC Kiln, which is designed to operate with lower NOX emissions than
previous generations of cement kilns. While the technology has been tested and proven at a
number of other cement plants, the operating conditions of every plant are different and it is,
therefore, not possible to start up the plant fully optimised. The NOX reduction process is
influenced by a number of parameters all of which must be systematically tested and
optimised if the maximum possible NOX reduction is to be achieved. During this testing and
optimising phase it is not possible to guarantee that the BAT NOX emission levels will be met
on a daily basis. It is the opinion of ICL (and the equipment supplier) that a 1 year period
should be sufficient to carry out the testing and optimisation of the new kiln. It is on this
basis that ICL has requested an elevated emission limit on Kiln 3 of 1300 mg/Nm3, dry, 10 %
O2 for a period of 1 year.
Note
It should be specifically noted that in requesting NOX limits of 1,000 and 1,300 mg/Nm3, dry,
10 % O2 for Kiln 2 and Kiln 3 respectively during commissioning, ICL is not intending to
establish operating points close to these limits.
As stated above every effort will be made to run at BAT levels from start up of the SNCR
system on Kiln 2 and from start up of the Kiln 3 system. The request is made to ensure a
pragmatic approach is adopted to the commissioning of newly installed technology. It should
also be noted that stopping and starting to ensure compliance with low emission limits during
a commissioning phase may be counterproductive in environmental terms.
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Timeframe
The SNCR system will be operational from the granting of the Licence on Kiln 2. The ILC
system will be operational from the granting of the Licence on Kiln 3 and the SNCR system
will be brought into operation on Kiln 3 if required.
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5. In relation to the installation of SNCR technology on the proposed kiln 3 justify, in terms of
BAT, your proposal not to install SNCR prior to commissioning the proposed kiln;
This issue has been addressed in the response to 4 above.
The ILC system on Kiln 3 is designed to operate to BAT levels. However, due to the nature of
the raw materials and fuels and due to the particular plant configuration installed it may be
necessary to install SNCR to ensure consistent operation at these levels. Commissioning the
ILC Calciner without the additional complication of an SNCR system represents BAT in
terms of plant commissioning and will ensure the system delivers the optimum NOX reduction
rate in the long run.
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6. Justify, in terms of BAT, your proposed emission limit values for NOx for kiln 2 after
installation of SNCR and for the proposed kiln3.
This issue has been addressed in the response to 4 above.
The EU BREF recognises a view that 500 – 800 mg/Nm3 represents BAT for NOX
emission levels from modern cement kilns. It is understood that the Agency accepts this
position.
Initial trials with SNCR technology on ICL kilns indicated quite clearly that the above
BAT emission levels could be met but that long term experience with the system would
be required to establish operating levels, without significant ammonia slip.
As discussed in response to 4 above, higher daily average values may occur during
commissioning and optimisation of injection points and flow rates on the SNCR system.
Also, the ILC control system will need to be optimised.
In addition, it is noted that in cement plant operations it is generally accepted that running
at a marginally higher emission level is preferable from an environmental perspective to
start up and shut down in the case of a short term exceedence of a limit value. This is
because of the unsteady state conditions that occur under (stop-start) conditions.
In summary, in practical terms optimisation will best be achieved by allowing operation
during commissioning across a pragmatic range of operation. Also, during commissioning
stop-start conditions should be avoided as much as possible.
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7. Justify, in terms of BAT, your proposed emission limit values for SOx from the existing and
proposed kilns;
The Draft EPA BAT Guidance Note outlines the following BAT Levels for sulphur dioxide
(SO2) of 200-750 mg/Nm3 for existing facilities.
Emissions from Kiln 2 currently meet the proposed BAT requirements as the kiln acts as an
efficient scrubber of SOX and it is proposed that an Emission Limit Value of 750 mg/Nm3 be
applied.
The Draft EPA BAT Guidance Note outlines the following BAT levels for sulphur dioxide
(SO2) of 200 – 400 mg/Nm3 for new facilities.
Emissions from the new Kiln 3 are predicted to comply with BAT levels and it is proposed
that an Emission Limit Value of 400 mg/Nm3 be applied.
Raw materials with specific sulphur-containing minerals (pyrites) can give rise to higher SOX
emissions. Should such raw materials be encountered in the future the Agency will be
notified.
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8. Justify with further information, the interpretation sought for continuous air monitoring data
(NOX and particulates) having regard to BAT and sector standards (half hourly exceedences
of twice the emission limit value and a statistical approach). In addition, justify the request to
have an elevated emission limit value for up to one year to allow for commissioning of SNCR
technology;
Daily Average
The existing IPC Licence for Platin Works requires that 95% of the daily means of continuous
monitoring during steady state plant operation (excluding start-up and shut-down, and in the
case of dust safety trip outs) shall not exceed the emission limit value over a calendar year.
It is submitted that this statistical approach is appropriate to cement plant operations and
provides appropriate control and environmental protection.
Half Hourly Average
Irish Cement is not aware of a “sector standard” of half hourly exceedences being limited to
twice the daily average ELV.
It was submitted in the IPPC Licence Application that should the Agency require half hourly
limits, then they must be applied on a statistical basis. It was suggested that should a
compliance criterion be required, 90% of half hourly limits values should comply with a limit
of twice the daily ELV during steady state conditions.
In the Licence Application, it was submitted that half hourly averages have a wide
distribution of high and low values around the mean due to short term fluctuations. Statistical
graphs were submitted in Attachment No. I of the IPPC Licence Application indicating higher
standard deviations on half hourly average data than on daily average data, as shown in Table
1.
Table 1 2006 Kiln 1 and Kiln 2 Dust and NOX Monitoring Data
Standard
deviation of Kiln 1
dust data in 2006
Standard
deviation of Kiln
2 dust data in
2006
Standard
deviation of Kiln
1 NOX data in
2006
Standard
deviation of Kiln 2
NOX data in 2006
Half hourly data 9 19 261 272
Daily average data 6 13 197 147
Example of SNCR Maintenance
A study has been undertaken to demonstrate that SNCR maintenance should be carried out
during kiln operation and should not result in a kiln stop and subsequent kiln start-up. The
study also indicates that following maintenance, careful short term management of the
ammonia water injection rates would ensure that the Daily ELVs can be achieved despite
some half hourly average exceedences.
A study of kiln stop/restart data was undertaken in order to establish NOX variation as a result
of kiln stops. The study was divided into two groups of kiln stops - 4 hours duration and 2
hours duration. Data from 3 kiln stops of 4 hours duration and data from 3 kiln stops of 2
hours duration was analysed in terms of NOX level at steady state prior to the stoppage, the
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length of time to reach steady state conditions after the stop, the ½ hour NOX level during the
start up situation prior to steady state conditions being achieved and the number of times that
a possible ½ hour limit of 1,600mg/Nm3 (assuming an ELV of 800mg/Nm
3) might be
exceeded. Average data for the two sample groups is presented in Table 2 below.
Table 2 Kiln Stop NOX Monitoring Data – 2 Hour and 4 Hour Kiln Stop
NOX prior to
stop (mg/Nm3)
Mean NOX
during start up
(mg/Nm3)
Length of time
to reach steady
state (hours)
No. of ½ hour
exceedances
>1600 mg/Nm3
during start up
phase
2 hour stop 1,097 1,749 5 6
4 hour stop 1,057 1,736 4 6
The SNCR system will achieve NOX of 800 mg/Nm3. Based on the above data, two operating
scenarios were examined.
Scenario 1: The kiln stops and the SNCR system is shut down.
Scenario 2: The kiln continues whilst the SNCR fault is rectified.
Results are shown in Table 3 and Table 4, based on an assumed daily ELV of 800mg/Nm3.
Table 3 Kiln Stop NOX Monitoring Data – 2 Hour Kiln Stop
2 hour data
NOX
prior to
stop
(mg/Nm3)
Kiln Stop
(hours)
SNCR
Off/kiln
on
(hours)
NOX during
start up
situation/SNCR
off (mg/Nm3)
Calculated
24 hour
average
(mg/Nm3)
Scenario 1
2 hour Kiln stop 800 2 0 1,749 998
Scenario 2
2 hours SNCR off 800 0 2 1,097 825
Table 4 Kiln Stop NOX Monitoring Data – 4 Hour Kiln Stop
4 hour data
NOX prior
to stop
(mg/Nm3)
Kiln
Stop
(hours)
SNCR
Off/kiln on
(hours)
NOX during
start up
situation/SNC
R off
(mg/Nm3)
Calculated
24 hour
average
(mg/Nm3)
Scenario 1
4 hour Kiln stop 800 4 0 1,736 956
Scenario 2
4 hours SNCR off 800 0 4 1,057 843
It should be noted that it is assumed that the SNCR system is not reintroduced until the Kiln is
in a stable mode of operation i.e. steady state conditions exist.
In both data sets the calculated mean daily NOX emission is lower in the case of maintaining
the kiln in operation whilst the SNCR system is under repair. In practice, careful short-term
management of ammonia injection rates would ensure compliance with the Daily ELV.
While this example is theoretical it is based on operating data and we believe illustrates the
point that continued operation is preferable to shut down and start up from an environmental
perspective.
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Conclusion
It is submitted that daily average control is an appropriate parameter to ensure environmental
integrity.
It is also submitted that before proposing specific half hourly emission limit values, it would
be appropriate to build up plant data of the relationship between half hourly average and daily
average results at the new, significantly lower operating levels with which the plant will
comply under the new IPPC Licence.
Elevated Emission Limit Values (ELV) for NOX during commissioning
This issue has been addressed in the reponse to Question 4.
Kiln 2
To allow for completion of commissioning and optimisation, it was requested in the original
IPPC licence application that an elevated limit of 1000 mg/Nm3, dry, 10 % O2 be granted for
the first 6 months of SNCR system operation.
As discussed at the recent clarification meeting with the Agency it is intended, following the
granting of the IPPC Licence to run the system to meet an expected ELV of 800mg/Nm3.
However, during commissioning, daily average values above this value are likely to occur as
the system is further optimised. In practice injection rates and points will be altered. It is not
expected that this period of long term commissioning optimisation will continue for more
than six months.
Kiln 3
In the original IPPC licence application, it was requested that an elevated limit of 1,300
mg/Nm3, dry, 10 % O2 be granted for the first year of commissioning and operation of Kiln
3. This is proposed in order to allow for a practical approach to commissioning of a new kiln
system and the possible introduction of the SNCR technology.
As discussed at the recent clarification meeting with the Agency it is proposed to run the
system on start up to meet an expected Licence Limit of 800 mg/Nm3. However, during
commissioning and optimisation it is expected that daily average values above this level will
occur as the ILC optimisation process is developed and as the SNCR system, if installed, is
optimised.
Kiln 3 is a modern ILC Kiln, which is designed to operate with lower NOX emissions than
previous generations of cement kilns. While the technology has been tested and proven at a
number of other cement plants, the operating conditions of every plant are different and it is,
therefore, not possible to start up the plant fully optimised. The NOX reduction process is
influenced by a number of parameters all of which must be systematically tested and
optimised if the maximum possible NOx reduction is to be achieved. During this testing and
optimising phase it is not possible to guarantee that the BAT NOX emission levels will be met
on a daily basis. It is the opinion of Irish Cement Limited (and the equipment supplier) that a
1 year period should be sufficient to carry out the testing and optimisation of the new kiln. It
is on this basis that Irish Cement Limited has requested an elevated emission limit on Kiln 3
of 1,300 mg/Nm3, dry, 10 % O2 for a period of 1 year.
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9. Clarify the location of the by-pass emission points associated with kiln 2 and 3 (between the
kiln and pre-heater), also identify the frequency of these by-passes and the emissions
associated with such by-passes (concentration and volume of emission);
There are no by-pass emission points.
Kiln 2 by-pass gases are dedusted in the main Kiln 2 ESP and emitted through the Kiln 2
chimney with Kiln 2 exhaust gases.
Kiln 3 by-pass gases will be dedusted by a bag filter before being emitted through the Kiln 3
chimney with Kiln 3 exhaust gases.
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10. Complete Table E.1(ii) for emission point A2-01 (E- 12 of 50);
Table E.1(ii) is shown below for the emission point A2-01 with current characteristics and
with future characteristics. The two tables below both refer to the same emission point A2-
01, labelled as “A2-01 (Current) Kiln 1 (including Raw Mill 1 and Coal Mill 1 outlets after
ducting)” and as “A2-01 (Future) Raw Mill 1”.
This information was provided in the original Licence Application and the labelling of the
emission point has now been amended in response to this RFI.
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17
TABLE E
.1(ii) M
AIN
EM
ISSIO
NS
TO
ATM
OSPH
ERE
(1 P
ag
e f
or
ea
ch
em
issio
n p
oin
t)
Em
issio
n P
oin
t R
ef.
N
o:
A2
-01
(C
urr
en
t) K
iln
1 (
inclu
din
g R
aw
Mil
l 1
an
d C
oa
l M
ill
1 o
utl
ets
aft
er
du
cti
ng
)
So
urc
e o
f E
mis
sio
n:
Kil
n 1
, R
aw
Mil
l 1
, C
oa
l M
ill
1 (
ICL
Pla
nt
No
. 1
46
01
). R
aw
Mil
l 1
an
d C
oa
l M
ill
1 a
re b
ein
g d
ucte
d i
nto
Kil
n 1
.
Lo
ca
tio
n:
Kil
n 1
Sta
ck
in
fro
nt
of
bu
ild
ing
18
5
Gri
d R
ef.
(1
2 d
igit
, 6
E,6
N):
30
65
20
E
2
71
75
4N
Ve
nt
De
tail
s
Dia
me
ter:
H
eig
ht
ab
ov
e G
rou
nd
(m
):
2.3
8m
98
.01
m
Da
te o
f co
mm
en
ce
me
nt:
19
72
Characte
ris
tics o
f Em
issio
n:
(i)
Vo
lum
e t
o b
e e
mit
ted
:
Av
era
ge
/da
y
2.8
32
x 1
0 6
Nm
3/d
Ma
xim
um
/da
y
4.5
6 x
10
6
Nm
3/d
Ma
xim
um
ra
te/h
ou
r 1
90
,00
0 N
m3/h
M
in e
fflu
x v
elo
cit
y
9.0
m.s
ec
-1
(ii)
O
the
r fa
cto
rs
Te
mp
era
ture
21
6 o
C(m
ax
)1
10
oC
(min
) 1
21
oC
(av
g)
Fo
r C
om
bu
sti
on
So
urc
es:
Vo
lum
e t
erm
s e
xp
resse
d a
s:
� w
et.
dry
10
%O
2
(iii
)
Pe
rio
d o
r p
eri
od
s d
uri
ng
wh
ich
em
issio
ns a
re m
ad
e,
or
are
to
be
ma
de
, in
clu
din
g d
ail
y o
r se
aso
na
l v
ari
ati
on
s (start-up /shutdown to be
included):
Pe
rio
ds o
f E
mis
sio
n
(av
g)
60
min
/hr
24
hr/
da
y
36
5
d
ay
/yr
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:22:32:36
18
TABLE E
.1(ii) M
AIN
EM
ISSIO
NS
TO
ATM
OSPH
ERE
(1 P
ag
e f
or
ea
ch
em
issio
n p
oin
t)
Em
issio
n P
oin
t R
ef.
N
o:
A2
-01
(F
utu
re)
Ra
w M
ill
1
So
urc
e o
f E
mis
sio
n:
Ra
w M
ill
1.
Ra
w M
ill
1 d
ucte
d t
o K
iln
1 c
him
ne
y.
ICL
Pla
tin
wis
he
s t
o r
eta
in e
mis
sio
n p
oin
t A
2-0
1 a
s a
n e
mis
sio
n
po
int
for
Ra
w M
ill
1.
Ex
ha
ust
ga
se
s f
rom
th
e n
ew
Kiln
3 l
ine
ma
y b
e u
se
d t
o d
ry l
ime
sto
ne
be
ing
mille
d f
or
the
pro
du
cti
on
of
CE
M I
I ce
me
nts
in
th
e e
xis
tin
g R
aw
Mill
1.
In
th
is s
itu
ati
on
, it
is p
rop
ose
d t
o v
en
t th
e g
as a
t th
rou
gh
the
ex
isti
ng
Kiln
1 c
him
ne
y i
.e.
ma
in e
mis
sio
n p
oin
t A
2-0
1.
Lo
ca
tio
n:
Kil
n 1
Sta
ck
in
fro
nt
of
Bu
ild
ing
18
5
Gri
d R
ef.
(1
2 d
igit
, 6
E,6
N):
30
65
20
E
2
71
75
4N
Ve
nt
De
tail
s
Dia
me
ter:
H
eig
ht
ab
ov
e G
rou
nd
(m
):
2.3
8m
98
.01
m
Da
te o
f co
mm
en
ce
me
nt:
Po
st
20
08
Characte
ris
tics o
f Em
issio
n:
(i)
Vo
lum
e t
o b
e e
mit
ted
:
Av
era
ge
/da
y
1.0
8 x
10
6
Nm
3/d
Ma
xim
um
/da
y
1.1
8 x
10
6
Nm
3/d
Ma
xim
um
ra
te/h
ou
r 4
9,0
00
Nm
3/h
M
in e
fflu
x v
elo
cit
y
Ask
Un
a m
.se
c-1
(ii)
O
the
r fa
cto
rs
Te
mp
era
ture
11
8 o
C(m
ax
)7
6
oC
(min
) 8
7
oC
(av
g)
Fo
r C
om
bu
sti
on
So
urc
es:
Vo
lum
e t
erm
s e
xp
resse
d a
s:
� w
et.
dry
10
%O
2
(iii
)
Pe
rio
d o
r p
eri
od
s d
uri
ng
wh
ich
em
issio
ns a
re m
ad
e,
or
are
to
be
ma
de
, in
clu
din
g d
ail
y o
r se
aso
na
l v
ari
ati
on
s (start-up /shutdown to be
included):
Pe
rio
ds o
f E
mis
sio
n
(av
g)
60
min
/hr
24
hr/
da
y
36
5
d
ay
/yr
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:22:32:36
19
11. Complete Table E.1(iii) to include CO emissions associated with the emissions from kiln 1
(A2-01), kiln 2 (A2-02) and kiln 3 (A2-06);
Table E.1(iii) has been completed to include CO emissions associated with the emissions
from Kiln 1 (A2-01 current and A2-01 future) , Kiln 2 (A2-02) and Kiln 3 (A2-08).
Please note that since CO is associated with the combustion gases from the kilns, the tables
have been completed for emission point Kiln 3 (A2-08) rather than for A2-06 which is a
cement mill. (The labelling of the kiln emission point in the RFI question above is
inconsistent).
It should be noted that it is generally accepted that CO emissions can arise in cement kiln
systems from the raw materials as well as from the combustion process.
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:22:32:36
20
TABLE E
.1(iii)
: M
AIN
EM
ISSIO
NS T
O A
TM
OSPH
ERE -
Chem
ical characte
ris
tics o
f th
e e
mis
sio
n
(1 t
ab
le p
er
em
issio
n p
oin
t)
Emission Point Reference Number:
A2
-01
(C
urr
en
t) K
iln
1 (
inclu
din
g R
aw
Mil
l 1
an
d C
oa
l M
ill
1 o
utl
ets
aft
er
du
cti
ng
)
Pa
ram
ete
r P
rio
r to
tre
atm
en
t(1)
Bri
ef
A
s d
isch
arg
ed
(1)
m
g/N
m3
kg
/h
de
scri
pti
on
m
g/N
m3
kg
/h.
kg
/ye
ar
A
vg
M
ax
A
vg
M
ax
o
f tr
ea
tme
nt
Av
g.
Ma
x
Av
g.
Ma
x
Av
g.
Ma
x
Pa
rtic
ula
tes
40
35
7
40
35
7
47
62
7
66
8
Ex
ha
ust
ga
se
s a
re c
oo
led
by
a C
on
dit
ion
ing
To
we
r
an
d c
lea
ne
d b
y a
n
Ele
ctr
osta
tic P
recip
ita
tor.
Ty
pe
: F
.L.
Sm
idth
2F
AA
-36
36
36
-60
80
-1
Insta
lle
d:
19
71
ca
Co
nd
itio
nin
g t
ow
er
ad
de
d
in 2
00
1.
5.9
5
0
0.6
99
9
.5
61
27
8
3,2
20
NO
X
12
33
1
80
0
14
5
34
2
No
ne
1
23
3
18
00
1
45
2
52
1
.3 x
10
6
2.2
x1
06
SO
X
29
7
50
3
.4
14
3
Ab
so
rpti
on
occu
rs i
n t
he
pre
he
ate
r /
raw
mil
l
29
7
50
3
.4
14
3
29
78
4
1.2
x1
06
CO
1
00
1
00
0
11
.8
19
0
No
ne
1
00
1
00
0
11
.8
19
0
10
33
68
1
.7 x
10
6
1.
Co
nce
ntr
ati
on
s s
ho
uld
be
ba
se
d o
n N
orm
al
co
nd
itio
ns o
f te
mp
era
ture
an
d p
ressu
re,
(i.e
. 0
oC
,10
1.3
kP
a).
We
t/d
ry s
ho
uld
be
th
e s
am
e a
s g
ive
n i
n
Ta
ble
E.1
(ii)
un
less c
lea
rly
sta
ted
oth
erw
ise
.
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:22:32:36
21
TABLE E
.1(iii)
: M
AIN
EM
ISSIO
NS T
O A
TM
OSPH
ERE -
Chem
ical characte
ris
tics o
f th
e e
mis
sio
n
(1 t
ab
le p
er
em
issio
n p
oin
t)
Emission Point Reference Number:
A2
-01
(Fu
ture
) R
aw
Mill
1
ICL
Pla
tin
wis
he
s t
o r
eta
in e
mis
sio
n p
oin
t A
2-0
1 a
s a
n e
mis
sio
n p
oin
t fo
r R
aw
Mill
1.
Ex
ha
ust
ga
se
s f
rom
th
e n
ew
Kiln
3 l
ine
ma
y b
e u
se
d t
o d
ry l
ime
sto
ne
be
ing
mille
d f
or
the
pro
du
cti
on
of
CE
M I
I ce
me
nts
in
th
e e
xis
tin
g R
aw
Mill
1.
In
th
is s
itu
ati
on
, it
is p
rop
ose
d t
o v
en
t th
e g
as a
t th
rou
gh
th
e e
xis
tin
g K
iln
1
ch
imn
ey
i.e
. m
ain
em
issio
n p
oin
t A
2-0
1.
Pa
ram
ete
r P
rio
r to
tre
atm
en
t(1)
Bri
ef
A
s d
isch
arg
ed
(1)
m
g/N
m3
kg
/h
de
scri
pti
on
m
g/N
m3
kg
/h.
kg
/ye
ar
A
vg
M
ax
A
vg
M
ax
o
f tr
ea
tme
nt
Av
g.
Ma
x
Av
g.
Ma
x
Av
g.
Ma
x
Pa
rtic
ula
tes
60
,00
0
60
,00
0
27
0
29
40
E
xh
au
st
ga
se
s c
lea
ne
d b
y
an
Ele
ctr
osta
tic
Pre
cip
ita
tor.
Ty
pe
: F
.L.
Sm
idth
2F
AA
-36
36
36
-60
80
-1
Insta
lle
d:
19
71
ca
19
5
0
0.8
55
2
.45
7
,49
0
21
,46
2
NO
X
12
67
1
80
0
57
8
8
Lo
we
r N
OX p
reca
lcin
er
kil
n
an
d p
ossib
le S
NC
R
75
0
13
00
3
3.8
6
3.7
2
96
,08
8
55
8,0
12
SO
X
29
4
00
1
.3
19
.6
Ab
so
rpti
on
occu
rs i
n t
he
pre
he
ate
r /
raw
mil
l
29
4
00
1
.3
19
.6
11
,38
8
17
1,6
96
CO
2
50
1
00
0
11
.3
49
N
on
e
25
0
10
00
1
1.3
4
9
98
98
8
429240
1.
Co
nce
ntr
ati
on
s s
ho
uld
be
ba
se
d o
n N
orm
al
co
nd
itio
ns o
f te
mp
era
ture
an
d p
ressu
re,
(i.e
. 0
oC
,10
1.3
kP
a).
We
t/d
ry s
ho
uld
be
th
e s
am
e a
s g
ive
n i
n
Ta
ble
E.1
(ii)
un
less c
lea
rly
sta
ted
oth
erw
ise
.
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:22:32:36
22
TABLE E
.1(iii)
: M
AIN
EM
ISSIO
NS T
O A
TM
OSPH
ERE -
Chem
ical characte
ris
tics o
f th
e e
mis
sio
n
(1 t
ab
le p
er
em
issio
n p
oin
t)
Emission Point Reference Number:
A2
-02
- K
iln
2,
Ra
w M
ill
2 (
ICL
Pla
nt
No
. 2
46
01
)
Pa
ram
ete
r P
rio
r to
tre
atm
en
t(1)
Bri
ef
A
s d
isch
arg
ed
(1)
m
g/N
m3
kg
/h
de
scri
pti
on
m
g/N
m3
kg
/h.
kg
/ye
ar
A
vg
M
ax
A
vg
M
ax
o
f tr
ea
tme
nt
Av
g
Ma
x
Av
g
Ma
x
Av
g
Ma
x
Particulates
52
95
0
52
95
0
17
13
0
21
18
0
Ex
ha
ust
ga
se
s a
re c
lea
ne
d
by
ele
ctr
osta
tic
pre
cip
ita
tor.
Ty
pe
: F
.L.
Sm
idth
FA
A-4
04
04
0-1
50
90
-1
Insta
lle
d:
19
77
Ele
ctr
osta
tic P
recip
ita
tor
ex
ten
de
d i
n 2
00
7.
24
.2
50
7
.8
20
6
8,4
89
1
75
,20
0
NO
X
12
67
1
80
0
41
0
72
0
Se
lecti
ve
No
n C
ata
lyti
c
Re
du
cti
on
in
th
e P
reh
ea
ter
To
we
r
Insta
lle
d 2
00
7
75
0
10
00
2
43
4
00
2
.1 x
10
6
3.5
x1
06
SO
X
29
7
50
9
.4
30
0
Ab
so
rpti
on
occu
rs i
n t
he
pre
he
ate
r /
raw
mil
l
29
7
50
9
.4
30
0
29
78
4
2.6
x1
06
CO
2
50
1
00
0
80
.9
40
0
No
ne
2
50
1
00
0
80
.9
40
0
70
86
84
3.5 x 106
1.
Co
nce
ntr
ati
on
s s
ho
uld
be
ba
se
d o
n N
orm
al
co
nd
itio
ns o
f te
mp
era
ture
an
d p
ressu
re,
(i.e
. 0
oC
,10
1.3
kP
a).
We
t/d
ry s
ho
uld
be
th
e
sa
me
as g
ive
n i
n T
ab
le E
.1(i
i) u
nle
ss c
lea
rly
sta
ted
oth
erw
ise
.
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:22:32:36
23
TABLE E
.1(iii)
: M
AIN
EM
ISSIO
NS T
O A
TM
OSPH
ERE -
Chem
ical characte
ris
tics o
f th
e e
mis
sio
n
(1 t
ab
le p
er
em
issio
n p
oin
t)
Emission Point Reference Number:
A2
-08
-
Kil
n 3
, R
aw
Mil
l 3
, C
oa
l M
ill
3 a
nd
Kil
n 3
by
-pa
ss
Pa
ram
ete
r P
rio
r to
tre
atm
en
t(1)
Bri
ef
A
s d
isch
arg
ed
(1)
m
g/N
m3
kg
/h
de
scri
pti
on
m
g/N
m3
kg
/h.
kg
/ye
ar
A
vg
M
ax
A
vg
M
ax
o
f tr
ea
tme
nt
Av
g
Ma
x
Av
g
Ma
x
Av
g
Ma
x
Pa
rtic
ula
tes
97
56
1
97
56
1
38
66
9
40
00
0
Ex
ha
ust
ga
se
s a
re
cle
an
ed
by
a b
ag
fil
ter.
10
3
0
4.0
1
2.3
3
47
21
1
07
74
8
NO
X
12
67
1
80
0
50
2
73
8
Lo
we
r N
OX
Pre
ca
lcin
er
Kil
n a
nd
po
ssib
le S
NC
R–
Pla
nn
ed
fo
r la
te 2
00
8
75
0
13
00
2
97
5
33
2
.6
x1
06
4.7
x1
06
SO
X
29
4
00
1
1.5
1
64
A
bso
rpti
on
occu
rs i
n t
he
pre
he
ate
r /
raw
mil
l
29
4
00
1
1.5
1
64
1
00
74
0
1.4
x1
06
CO
2
50
1
00
0
99
4
10
N
on
e
25
0
10
00
9
9
41
0
86
42
40
3.6 x 106
1.
Co
nce
ntr
ati
on
s s
ho
uld
be
ba
se
d o
n N
orm
al
co
nd
itio
ns o
f te
mp
era
ture
an
d p
ressu
re,
(i.e
. 0
oC
,10
1.3
kP
a).
We
t/d
ry s
ho
uld
be
th
e s
am
e a
s
giv
en
in
Ta
ble
E.1
(ii)
un
less c
lea
rly
sta
ted
oth
erw
ise
.
For
insp
ectio
n pur
pose
s only
.
Conse
nt of
copy
right
owne
r req
uired
for a
ny ot
her u
se.
EPA Export 25-07-2013:22:32:36
24
12. Identify the location of the existing and proposed interceptors on the surface water drainage
system, provide details of the design and class of each interceptor;
The locations of the existing and proposed oil interceptors are shown in Figure 1. The details
and dimensions of the existing and proposed interceptor are shown in Figures 2 to 4.
The Settlement Tank Interceptor class is Class 2.
The Despatch Interceptor class is Class 1.
The proposed Garage Interceptor will be Class 1 and is due to be installed during 2008.
Within the surface water drainage system there are numerous manholes that act as silt traps.
In addition, the surface water treatment tanks use floating oil absorbent booms.
For
insp
ectio
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13. Provide details of ambient dust deposition monitoring undertaken in the vicinity of the
installation, including location of monitoring points and results of monitoring undertaken;
In the IPPC licence application, dust deposition gauges locations are shown on Figure F.2.
Dust deposits are analysed at least every quarter. The 2007 results are summarised in Table 5.
Table 5 2007 Dust Deposit Gauge Monitoring Results
IPC Code IPPC Code Gauge Location Insoluble, mg/m²/Day
JAN-FEB F1 AA1 Brady Beamore 10
FEB-APR F1 AA1 Brady Beamore 21
APR-MAY F1 AA1 Brady Beamore 92
MAY-JUL F1 AA1 Brady Beamore 43
IPC Code IPPC Code Gauge Location Insoluble, mg/m²/Day
JAN-FEB F2 AA2 Cruicerath Farm 6
FEB-APR F2 AA2 Cruicerath Farm 6
APR-MAY F2 AA2 Cruicerath Farm 335
MAY-JUL F2 AA2 Cruicerath Farm 8
IPC Code IPPC Code Gauge Location Insoluble, mg/m²/Day
JAN-FEB F3 AA3 James Carranstown 79
FEB-APR F3 AA3 James Carranstown 42
APR-MAY F3 AA3 James Carranstown 87
MAY-JUL F3 AA3 James Carranstown 261
IPC Code IPPC Code Gauge Location Insoluble, mg/m²/Day
JAN-FEB F4 AA4 O'Flynn Beamore 8
FEB-APR F4 AA4 O'Flynn Beamore 5
APR-MAY F4 AA4 O'Flynn Beamore 22
MAY-JUL F4 AA4 O'Flynn Beamore 128
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14. Clarify the timeframe associated with your proposal to remove asbestos waste from the
overburden landfill on-site, and provide an estimation of the quantity of asbestos within the
landfill;
A project will be developed in 2008 to remove fibre cement cladding buried in a specific cell
location in the landfill. This material arose from the removal of building cladding.
It is estimated that the quantity is of the order of 70 tonnes.
It is envisaged that all this material will be removed within an 18 month timeframe.
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15. Within the application it is proposed to store clinker outdoors. Identify the quantity and
frequency of outdoor storage and identify measures to be taken to avoid dust generation and
associate nuisance;
Due to the continuing strong demand for cement product, there has been a requirement to
import clinker and store clinker outdoors. The new kiln line project includes a new clinker
store of 60,000 tonnes capacity, which will reduce the requirement to import clinker and will
reduce the requirement to store clinker outdoors. The new kiln project is due to be
commissioned in late 2008.
Until the new clinker store is operational, it is expected that it would be necessary to maintain
a maximum outdoor clinker stock of the order of 80,000 tonnes at any one time. When the
clinker store is fully operational, it is expected that the quantity of outdoor clinker storage will
reduce to a maximum of 30,000 tonnes at any one time.
The site’s established measures for minimising fugitive clinker dust, which include the
following measures, will continue:
• use of dedusting equipment on the cement mill clinker intake conveyor
• movement of clinker according to strict environmental guidelines and instructions
• road spraying and sweeping as required.
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16. Clarify the capacity (hydraulic and BOD) of the installed domestic effluent treatment plant
compared to the load associated with the installation. Provide details of the investigation of
the plant following exceedences on the 13/03/2006 and 29/09/2006 and mitigation measures
taken thereafter;
The existing domestic effluent treatment plant was installed in late 2005 and was designed to
treat effluent with a BOD load of 7.5kg/day and a maximum flow of 25m3/day.
It has been established, following detailed investigations, that the plant is hydraulically under
designed. Engineering consultants are currently in the process of finalising an appropriate
upgrade.
Please refer to the consultant’s Report “Summary Report on the ICL Domestic Wastewater
Treatment Plant” in Appendix I, which was submitted to the Agency’s Site Inspector on 12th
October 2007.
It should be noted that the domestic effluent joins with other surface water effluent and quarry
water before discharge to a final emission point. The combined final emission point has a
history of compliance with Licence requirements.
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17. An increase in tolerance for noise and blasting emissions have been sought in the licence
application. Please justify these requests with further information having regard to BAT and
the sector standard;
A response has been prepared on this point by ICL’s acoustic consultant Eanna O’Kelly &
Associates and is attached in Appendix II.
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18. Revise Attachment J.1 Accidental Emissions of the application to include an assessment of
accidental emissions of dust. Describe the measures to be taken under abnormal operating
conditions, including start-up, shutdown, leaks, malfunctions, breakdowns and momentary
stoppages;
Revision to Attachment J.1 Accidental Emission of the IPPC Licence Application:
J1.4 Assessment of accidental emissions to air (in particular dust emissions):
Control System
The risk of an accidental air emission associated with plant operation has been minimised
over the years due to developments in control system technology and significant in-house
knowledge of control system optimisation through the use of interlocking and alarm systems.
During abnormal plant operating conditions, i.e. a start-up, shutdown, leaks, malfunction,
breakdowns and momentary stoppages, there is a potential for accidental air emissions, but as
mentioned due to sophisticated control system technology and in-house expertise, the risk has
been significantly reduced.
The original control system has evolved from a hardwired relay control system to today’s
state of the art software programmed computer control system. Today’s modern computerised
control system allows sophisticated interlocking of plant equipment, ensuring minimal upsets
during abnormal operating conditions. The control system logic applying to the conditions
noted and safety filter trips and coal mill overpressure is summarised below.
• Start ups
Start up procedures and interlocking is set up in a logical manner to ensure proper
sequential starting of equipment and minimizing accidental air emissions, e.g.
filters are started before main plant items and so ensure that process gases are treated in
the filter, prior to materials being processed.
• Shut downs, breakdowns, momentary stoppages
The interlocking for an automatic shutdown and a planned shut down is the same. All
standard interlocking is in place such that all equipment is stopped in a logical manner. In
the event of an unplanned stop or breakdown or momentary stop of a plant item, the
control system will detect a feedback fault and proceed to follow the automatic shut down
sequence.
• Malfunctions and leaks
Where potential malfunctions are known or have happened in the past the appropriate
corrective action has been incorporated into the control logic/interlocking.
For example in the event of the control system detecting a high exit temperature from the
grate cooler electrostatic precipitator, the control system will stop the excess air fan and
so protect the filter. As this in turn causes overpressure in the grate cooler, the corrective
action for this event is to automatically stop the grate cooler fans nos. 4 to 8 when the
excess air fan stops. This action successfully prevents major overpressure in the grate
cooler and so prevents leaks.
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• Safety Filter trips
The control system is interlocked to trip a kiln filter when the risk of an explosion to the
filter increases. While Safety Filter trips can be caused by a variety of events, the most
common cause for a filter trip is due to high levels of CO in the gas caused by a
fluctuation in the fuel supply to the kiln.
There are a number of actions that occur automatically in order to prevent the filter from tripping
as a result of fluctuations in fuel supply, for example:
o On the control system, if a fluctuation in the fuel supply generates a max. level alarm
deviation, then the fuel supply is automatically reduced by 30%.
o In addition, when a max. level alarm deviation on the fuel is detected, the back-end
fuel supply is automatically stopped.
o When a max. level alarm is generated from the fuel firing line pressure, the control
system will cause the fuel supply to be automatically reduced by 30%.
If high levels of CO are detected then the following actions occur:
o When a max. level 1 alarm for CO is triggered, then the fuel firing is automatically
reduced by 30% and further fuel increases are prevented.
o In addition, when the max. level 1 alarm for CO is triggered, the backend fuel firing
is stopped.
o When a max. level 2 alarm for CO is triggered, then the control system is interlocked
to trip the rectifiers on the filter to prevent an explosion.
• Coal Mill safety overpressure release vents
Safety coal mill overpressure release vents are activated when the overpressure in the system
increases to a point where the vents automatically open, so preventing an explosion. The
control system is programmed to minimise the occurrence of high overpressure and thus
prevent overpressure release vent activation, e.g. on Coal Mill 2 if the monitored pressure
exceeds the max. level 2 alarm, the fans and the mill are shut down in advance of the
overpressure release doors opening.
Maintenance
At Platin Works, a comprehensive preventative and predictive maintenance plan ensures plant
integrity, in turn minimising accidental emissions and maximising run factors and plant
output.
An example would be that the preventative and predictive maintenance plan for bag filters
ensures that filter bags are refitted at appropriate intervals to minimise accidental emissions
from a split filter bag.
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Conclusion
The performance of the plant in recent years under its existing IPC licence clearly
demonstrates that uncontrolled emissions with environmental significance do not occur at
Platin Works and demonstrates the efficiency of the control and maintenance systems outlined
above.
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19. With respect to the air dispersion report submitted please clarify the following:
(i) Assess the impact of using a more conservative NOx to NO2 conversion of 100% for
predicting the annual concentration;
(ii) The assessment of NO2 and PM10, under each scenario, should include a figure for short
term background concentrations, the short term background concentration can be
predicted based on the annual background concentration;
(iii) Consider the impact of the minor emissions to atmosphere on the predicted ground
level concentrations for PM10;
(iv) Elevated flowrates were provided for kiln 2, in the existing licence, when “back-end
firing” please clarify if the elevated flowrate are required. If an elevated flowrate are
required please update the modelling;
(v) In relation to PM10 the current Air Quality Standards are specified in S.I. No. 271 of
2002, therefore provide an assessment, for each scenario, of the predicted ground level
concentrations with regard to the existing air quality standards stage 1 and stage 2 (24
hour and calendar year). Please provide further information in relation to the CEC 2005
report referred to in your air assessment report.
(vi) Provide details of the report and methodology used to establish a conversion factor of
0.6 for the conversion of PM10 emissions to PM2.5;
(vii) The cumulative impact assessment provided only assesses the annual averages, and
the tables presented do not include the contributions from the Indaver Ireland or Scottish
and Southern Energy installations. Please re-assess the cumulative impact (annual
averages and short term) of the existing and proposed Irish Cement emissions and those
associated with Indaver Ireland and Scottish and Southern Energy. Clarify the emission
rates, concentrations, emission points (location and stack height) associated with the
proposed Indaver Irelamd and Scottish and Southern Energy installations. In relation to
the Indaver Ireland facility, confirm that the assessment is based on the currently
proposed development and associated emissions (planning reference SA60050); and
(viii) Provide in electronic format, copies of the complete input and output files and
meteorological data used in the air emission modelling assessments, including the above
clarifications.
INTRODUCTORY COMMENT
In addition to responding to these specific requests for information, we have provided an
updated report on “Air Quality Modelling of NOX and PM (2007)” in Appendix III. This
report has been prepared for the response to the RFI following clarification from the EPA as
to their exact requirements. This report updates the air quality modelling included in the EIS
and the IPPC Licence Application in line with specific requirements communicated by the
Agency.
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RESPONSE TO RFI
(i) Assess the impact of using a more conservative NOx to NO2 conversion of 100% for
predicting the annual concentration;
Refer to the air quality modelling report in Appendix III.
The impact of using a more conservative NOx to NO2 conversion of 100% for predicting the
annual concentration has been assessed in the revised air quality modelling report. The
predicted concentrations comply with the Irish Air Quality Standards (AQSs) Regulations
(2002).
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(ii) The assessment of NO2 and PM10, under each scenario, should include a figure for short
term background concentrations, the short term background concentration can be
predicted based on the annual background concentration;
Refer to the air quality modelling report in Appendix III.
Following clarification from the EPA, the short-term background concentration was taken to
be twice the long-term (annual mean) background concentration in the revised air quality
modelling report. This follows the UK EA (2002) guidance, “IPPC H1 Integrated Pollution
Prevention and Control (IPPC). Environmental Assessment and Appraisal of BAT”. There is no equivalent Irish methodology or EPA guidance.
The predicted concentrations comply with the Irish Air Quality Standards (AQSs) Regulations (2002).
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(iii) Consider the impact of the minor emissions to atmosphere on the predicted ground
level concentrations for PM10;
[
The 10 main emission points (A2-01 to A2-10) were included in the model assessment. Other
bag filters throughout the plant were not included in the model assessment because they are
regarded as minor emission points and as such were not deemed to be significant in the
context of air quality modelling.
Following this comment from the EPA in the RFI, Irish Cement Limited employed an
independent contractor to check the emissions from the minor emission points. The mean
concentration has been calculated from 11 of the minor emission points. These results ranged
from 0.1mg/Nm³ to 6.6mg/Nm³ with a weighted mean of 0.22mg/Nm³, which is significantly
below the limit of 50mg/Nm³ included in the current Licence. This supports the view that
these emission points are minor emission points.
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(iv) Elevated flowrates were provided for kiln 2, in the existing licence, when “back-end
firing” please clarify if the elevated flowrate are required. If an elevated flowrate are
required please update the modelling;
An elevated flowrate is not required.
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(v) In relation to PM10 the current Air Quality Standards are specified in S.I. No. 271 of
2002, therefore provide an assessment, for each scenario, of the predicted ground level
concentrations with regard to the existing air quality standards stage 1 and stage 2 (24
hour and calendar year). Please provide further information in relation to the CEC 2005
report referred to in your air assessment report.
Refer to the air quality modelling report in Appendix III.
The model results were compared with the Stage 1 AQS for PM10 in the air quality modelling
included in the IPPC Licence Application. Justification for this is followed by the
comparison with the Stage 2 AQS, as requested. The model results have been compared with
the Stage 1 and the Stage 2 AQS for PM10 in the revised air quality modelling report.
Explanation of comparison with the Stage 1 (2005) AQS
The Air Quality Standards (AQS) Regulations, 2002 (S.I. No. 271 of 2002) specify the Limit
Values for oxides of nitrogen (NOx), nitrogen dioxide (NO2) and particulate matter of
diameter less than 10 microns (PM10).
The Irish AQS Regulations (2002) are based on EU Directives 96/62/EC, 1999/30/EC and
2000/69/EC. They are made “for the purpose of giving effect to Council Directives
96/62/EC…, 1999/30/EC…, and 2000/69/EC” (S.I. No. 271 of 2002). It is proposed by the
EU to extend the PM10 Stage 1 AQS of 40µg/m3 to 2015 instead of introducing the Stage 2
AQS of 20µg/m3 (CEC, 2005). It is also proposed by the EU to introduce a concentration cap
for annual mean PM2.5 of 25µg/m3 to be attained by 1 January 2010 (CEC, 2005).
Limit Values for Particulate Matter (PM10) are set out in Annex III of EU Directive
1999/30/EC. The Irish AQS Regulations are “for the purpose of giving effect to Council
Directives…1999/30/EC” and follow the Stage 1 and Stage 2 approach for PM10 set out in
Annex III of EU Directive 1999/30/EC. Annex III (of EU Directive 1999/30/EC) includes the
caveat to the Stage 2 Limit Values that these are “Indicative limit values to be reviewed in the
light of further information on health and environmental effects, technical feasibility and
experience in the application of Stage 1 limit values in the Member States.” This caveat is not
included in the Irish AQS Regulations.
The review of the EU Stage 2 Limit Values resulted in the proposal to extend the PM10 Stage
1 AQS of 40µg/m3 to 2015 instead of introducing the Stage 2 AQS of 20µg/m
3 (CEC, 2005).
This proposal is included in the common position agreed between the Commission and the
Parliament (CEC, 2007).
The air quality section of the EPA website (EPA, 2007) reflects this:
“Legislation
In 2005 the black smoke standards were replaced by PM monitoring requirements based on
Directive 1999/30/EC (CEC, 1999). This Directive established limit values for PM10 mass
concentration levels. The PM10 daily mean limit of 50µg/m3 should not be exceeded more
than 35 times per calendar year. The annual mean PM10 limit value is 40µg/m3.”
Monitoring of ambient air quality in Ireland, carried out or coordinated by the EPA, will have
contributed to the EU database used in the review of the Stage 2 Limit Values. This review
resulted in the proposed decision to extend the PM10 Stage 1 AQS of 40µg/m3 to 2015 instead
of introducing the Stage 2 AQS of 20µg/m3 (CEC, 2005). Average concentrations per zone in
Ireland (EPA, 2007b) were 85% to 123% of the Stage 2 Limit Value of 20µg/m3.
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Comparison of all model results with the AQSs for particulate matter Stage 2 (2010)
Refer to the air quality modelling report in Appendix III.
The maximum ground-level concentrations due to the emissions have been compared to the
AQSs for PM10 for the protection of human health of 20µg/m³ over 1 year and 50µg/m³ over
24 hours (Schedule 3 of Irish AQS Regulations, 2002) in the revised air quality modelling
report. The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The
AQSs for PM10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations,
2002).
The predicted concentrations comply with the Irish Air Quality Standards (AQSs)
Regulations (2002).
CEC (2005)
The CEC (2005) document, as referenced in the report “Air Quality Modelling of NOx and
PM (2007)” in Attachment I of the IPPC Licence Application, is published by the
Commission of the European Communities as “Proposal for a Directive of the European
Parliament and of the Council on ambient air quality and cleaner air for Europe”, COM2005
447 (Provisional Version), 2005/0183 (COD), Brussels 21/09/2005. It is available from the
website of the European Commission at http://ec.europa.eu/ (viewed 3.xii.2007). The status
of the proposed Directive can be checked at
http://ec.europa.eu/prelex/detail_dossier_real.cfm?CL=en&DosId=193497 (viewed 3.xii.2007).
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(vi) Provide details of the report and methodology used to establish a conversion factor of
0.6 for the conversion of PM10 emissions to PM2.5;
The EC (2004) document, as referenced in the report “Air Quality Modelling of NOx and PM
(2007)” in Attachment I of the IPPC Licence Application, is published by the European
Commission. It is available from the website of the European Commission at
http://ec.europa.eu/environment/air/cafe/pdf/working_groups/2nd_position_paper_pm.pdf
(viewed 3.xii.2007).
The conversion factor of 0.6 was established based on the findings of the report, including the
following extracts:
• “Annual mean PM2.5 levels are roughly two-thirds those of PM10, but substantial
variations in space and time have been reported (ranging from 40% to 80% for
individual stations).” Section IV.10, page 11 of 231.
• “the overall PM mass decreases by about one third when going from PM10 to PM2.5”,
Section 3.1.5, page 45 of 231.
• “the mean PM2.5/PM10 ratio being approx. 0.65 (with a range from 0.4 to 0.8)”, Section
4.6.1, page 82 of 231.
• “The ratios PM2.5/PM10 varies throughout the different EU regions depending on the
type of site. Thus, at regional background sites PM2.5/PM10 were found to range from
0.7 to 0.8. At urban background sites the PM2.5/PM10 ratio ranged from 0.4-0.5 (in
Canary Islands and Southern Spain) to 0.8 in the Netherlands, Berlin and Northern and
Central areas from Spain. In the United Kingdom, Sweden and Eastern Iberian
Peninsula between 0.6 and 0.7 were measured. Finally, the PM2.5/PM10 ratios at
roadside sites were usually 0.6-0.7. The lowest ratios (0.4) were obtained at some
roadside sites in Sweden and at the Canary Islands, indicating the strength of road dust
emissions (road and tyre abrasion, sanding, salting) and the African dust inputs,
respectively.” Section 6.2, page 108 of 231.
This conversion factor of 0.6 is conservative compared to the ratio of 0.5 established by the
EPA (2007) in “Air Quality in Ireland 2006”. The EPA monitoring data shows that PM2.5
was 9µg/m³ compared to 17µg/m³ of PM10, which is a ratio of 0.53.
Particle size distribution analysis
The results presented in the air dispersion modelling report for the IPPC Licence Application
(Attachment I) were conservative, since 100% of total suspended particulates were assumed
to be PM10 and 60% were assumed to be PM2.5. From particle size distribution (PSD) analysis
carried out at Irish Cement Limerick in October 2007, 27% of total suspended particulates (or
49% of PM10) are PM2.5 (Table 6). This PSD analysis has been applied to the results: refer to
the revised air quality modelling report in Appendix III.
Table 6 Results of particulate size distribution analysis
TSP PM10 PM2.5
Assumed Attachment I 100% of TSP 100% of TSP 60% of TSP
Measured Particle size distribution 100% of TSP 54% of TSP 27% of TSP
49% of PM10
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(vii) The cumulative impact assessment provided only assesses the annual averages, and
the tables presented do not include the contributions from the Indaver Ireland or Scottish
and Southern Energy installations. Please re-assess the cumulative impact (annual
averages and short term) of the existing and proposed Irish Cement emissions and those
associated with Indaver Ireland and Scottish and Southern Energy. Clarify the emission
rates, concentrations, emission points (location and stack height) associated with the
proposed Indaver Irelamd and Scottish and Southern Energy installations. In relation to
the Indaver Ireland facility, confirm that the assessment is based on the currently
proposed development and associated emissions (planning reference SA60050); and
Refer to the air quality modelling report in Appendix III.
The tables presented for the cumulative impact assessment in the air quality modelling
included in the IPPC Licence Application do include the contributions from the Indaver
Ireland (Indaver) and from the Scottish and Southern Energy (SSE) installations.
Nonetheless, the cumulative impact has been reassessed as requested to include the
cumulative impact (annual averages and short term) of the existing and proposed Irish
Cement emissions and those associated with Indaver and SSE.
The planning permission for the SSE facility has lapsed and ICL has been advised by
consultants to SSE (2007) that they are not proceeding with this development. Since the
planning permission for the SSE facility has lapsed, therefore that development cannot
proceed. Nevertheless the predicted concentrations due to the SSE 400MW facility have been
included in the cumulative impact assessment, as provided in December 2007 by SSE through
their air dispersion modelling consultants.
The most recent data for the Indaver facility has been used, as provided in December 2007 by
Indaver through their air dispersion modelling consultants.
The emission rates, concentrations, emission points (location and stack height) associated
with the proposed Indaver and SSE are shown in Tables 7 and 8, as provided by their air
dispersion modelling consultants in December 2007.
Table 7 Emission rates, concentrations, emission points (location and stack height) for
Indaver
Location
(National Grid Co-ordinates)
306331.94
270963.46
Concentration (g/m3 from
flowrate and emission rate)
Stack Height above grade (m) 65 *
Flow rate at discharge conditions (m3/s)
55.8 *
NOx Mass Emission rate (g/s) 8.17 0.146
Dust (assumed PM10) Mass Emission Rate (g/s) 0.41 0.007
Table 8 Emission rates, concentrations, emission points (location and stack height) for SSE
Location
(National Grid Co-ordinates) 306782E, 270782N
Concentration (g/m3
from flowrate and
emission rate)
Stack Height above grade (m) 49.9 *
Flow rate at discharge conditions (m3/s)
793 *
NOx Mass Emission rate (g/s) 70.0 0.088
PM10 Mass Emission Rate (g/s) 29.2 0.037
The predicted concentrations comply with the Irish Air Quality Standards (AQSs)
Regulations (2002).
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(viii) Provide in electronic format, copies of the complete input and output files and
meteorological data used in the air emission modelling assessments, including the above
clarifications.
Input, output and meteorological files are supplied on CD-ROM in Appendix IV. Files have
been saved for Scenarios 1 to 6 for both pollutants modelled (NOx and PM) and for each of
the five years of meteorological data. Scenarios 1, 3 and 5 relate to NOx while Scenarios 2, 4
and 6 relate to PM. The input file names are as follows:
• Scenario 1 (NOx) 1998-2002 ICP083.dat-ICP087.dat
• Scenario 2 (PM) 1998-2002 ICP088.dat-ICP092.dat
• Scenario 2 with Cement Mill 4 (PM) 1998-2002 ICP158.dat-ICP162.dat
• Scenario 3 (NOx) 1998-2002 ICP093.dat-ICP097.dat
• Scenario 4 (PM) 1998-2002 ICP098.dat-ICP102.dat
• Scenario 5 (NOx) 1998-2002 ICP143.dat-ICP147.dat
• Scenario 6 (PM) 1998-2002 ICP148.dat-ICP152.dat
The above clarifications with regard to the cumulative impact assessment did not result in the
need to carry out further modelling. Predicted concentrations due to Indaver and SSE at each
of the locations of maximum GLCs have been provided to Irish Cement for the cumulative
impact assessment by Indaver and by SSE from their own air dispersion modelling. This approach is robust and allowed for a comprehensive cumulative impact assessment.
The meteorological data (1998 to 2002) has been included with the caveat that it must not be
used for any other purpose.
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43
Non - Technical Summary
The IPPC Licence Application to replace the existing IPC Licence (Reg. No. P0030-02),
was submitted to the EPA in September 2007. The Agency issued a Request for Further
Information on 15th November 2007. It was agreed in consultation with the Agency that a
prompt response would be made before the end of 2007 to facilitate the advancement of the
licensing process.
The request related to 19 points and a detailed response to each of the issues raised has been
prepared by Arup Consulting Engineers and Irish Cement Limited. Specific air emission
testing was carried out to support the Response. Arup Consulting Engineers carried out
further air quality assessment.
The issues raised and the responses to each can be summarised as follows:
Supplementary information files
Requested files, tables and drawings are provided in respect of:
• Geo-referenced digital drawing files relating to section B.2, E.6 and F.3 of the IPPC
licence application form are re-submitted on a separate CD-ROM. (2)
• Main Emissions to Atmosphere Table E.1 (ii) (10)
• Main Emissions to Atmosphere Table E.1 (iii) (11)
• Existing and proposed surface water interceptors (12)
• Dust Deposit Gauge Monitoring locations. (13)
• Environmental Consultant Report on Domestic Sewage Wastewater Treatment
Plant. (16)
• Acoustic Consultant Report on proposed IPPC licence noise and blasting limits.
(17)
• Air quality modelling report and modelling files (19).
Kiln capacity
Details of current and planned kiln clinker production capacity are provided. (1)
Alternative technologies
Alternatives to the new Kiln 3 system are discussed. (3)
NOX Abatement
Further information is provided on the recently constructed SNCR installation for Kiln 2
and its operation. Final test commissioning is scheduled for January 2008. (4)
The NOX abatement strategy for Kiln 3 is further explained and justified. (4, 5)
The proposed emission limit values for both Kiln 2 and Kiln 3 meet BAT. Elevated
emission limits values during new plant commissioning are justified (6, 8)
SOX Abatement
The proposed emission limit values for both Kiln 2 and Kiln 3 meet BAT. (7)
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44
BAT/ELVs
Further information and analysis is included to justify the approach recommended in the
Application to the establishment of ELVs. A specific analysis was undertaken in relation to
NOX abatement and kiln stop/starts, which indicates that continued operation during SNCR
maintenance is preferable to kiln shut down. (8)
By-pass
There are no by-pass emission points. (9)
Ambient Dust Deposit Monitoring
Summary information on monitoring and data in relation to the above is included. (13)
Waste construction materials containing asbestos
The quantity and timeframe associated with the removal of waste construction materials
containing asbestos from the overburden mound is provided. (14)
Outside Clinker Storage
The quantity and frequency of current and future outdoor clinker storage is clarified. (15)
Domestic Sewage Treatment Plant
A consultant’s report, which includes recommendations reviewing the performance of the
Domestic Sewage Treatment Plant, is provided. (16)
Noise and Blasting limits
Irish Cement’s Acoustic Consultant, Eanna O’ Kelly, has provided a response justifying
proposed noise and blasting limits. (17)
Accidental Emissions to Air
Attachment J.1 of the IPPC Licence Application has been revised to consider further
requests for information relating to accidental emissions to air. (18)
Air Quality Assessment
Further discussions were held with the Agency to clarify issues relating to this request.
Independent contractors were employed to measure minor emission point dust
concentrations and PM10 and PM2.5 at Irish Cement. The results of further modelling and
analysis of legislation are presented.
A detailed response to the issues raised is included in the Submission together with an
updated air quality modelling report and the model files. The cumulative impact of
potential new developments in the area is assessed.
The particle size distribution analysis allowed for revision of the predictions for particulate
matter, which were shown to have been extremely conservative.
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45
In summary, compliance with current and future air quality standards relating to NOX, NO2
and Particulates is demonstrated. (19)
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46
FIGURES Figure 1 Locations of existing and proposed interceptors Figure 2 Details and dimensions of the existing settlement tank interceptor Figure 3 Details and dimensions of the existing despatch interceptor Figure 4 Details and dimensions of the proposed garage interceptor Figures from Original IPPC Licence Application Figure F.2 Dust Deposit Gauge SNCR Piping and Instrumentation Diagrams
PID ICL Platin Works Tank-Pump Area PID ICL Platin Works Process Cabinet PID ICL Platin Works Injector Area PID ICL Platin Works Softened Water
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Grid Reference305294,271136
Ordnance Survey Ireland Licence NumberEN 0002807 c Government of Ireland
0 kilometres 2
Scale 1:50,000
Monitoring Locations
Permitted Quarry Area
ICL Platin Site Boundary
Dust Deposit Gauge Locations
Irish Cement Ltd Platin IPPC Licence Application
D5374.10 August 2007 Figure F.2
AA1
AA4
AA3
AA2
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47
APPENDICES
Appendix I Summary Report on the ICL Domestic Wastewater Treatment Plant
Appendix II Response from acoustic consultant (Eanna O’Kelly)
Appendix III “Air Quality Modelling of NOx and PM10 (2007)” – RFI Report (Dec 2007)
Appendix IV Air emissions modelling: input and output files and meteorological data
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48
APPENDIX I
Summary Report on the ICL Domestic
Wastewater Treatment Plant
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49
APPENDIX II
Response from acoustic consultant
(Eanna O’Kelly)
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Irish Cement Limited,
Platin Works
IPPC Licence Application
Request for Further Information
Noise Aspects
Report by Eanna O’ Kelly & Associates
December 2007
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Noise Tolerances:
The limits set out in IPC License Reg. No. P0030 - 02 in relation to noise emission at
residential premises is 57 dBA + 2 dBA, i.e. 59 dBA for daytime, 08:00 hours to 22:00 hours
and 47dBA + 2 dBA i.e 49 dBA at night-time, 22:00 hours to 08:00 hours.
These tolerances underestimate measurement and other uncertainties.
Cognizance must be taken of Paragraph 4 “Measurement Uncertainty” of International
Standard, 1996-2, the second edition of which was revised and published on the 15th of
March 2007. Guidelines on how to estimate the Measurement Uncertainty are given in Table
1 of this standard. The Standard Uncertainty of four factors are required to be taken into
account to derive the Combined Standard Uncertainty. These four factors are due to
instrumentation, due to operating conditions of the plant, due to weather and ground
conditions, and due to residual sound. The Combined Standard Uncertainty is the square root
of the sum of the squared values of the Standard Uncertainties of the four aspects mentioned
above.
The Expanded Measurement Uncertainty is based on the Combined Standard Uncertainty
multiplied by a coverage factor of 2. A coverage factor of 2 gives the coverage probability of
approximately 95%. Taking the Standard Measurement Uncertainty due to the
instrumentation alone ,using a Class 1 sound level meter conforming to IEC 61672 –1:2002,
would give an Expanded Measurement Uncertainty of + /- 2dBA. The inclusion of the
Standard Uncertainties due to plant operating conditions, due to weather and ground
conditions, and due to residual sound would be expected to increase the Expanded
Measurement Uncertainty to approximately +/- 4 dBA.
It is understood that the Agency is considering reducing licence limits to 55dBA and 45dBA
for day and night time respectively. It is essential that a +/- 4dBA tolerance be added to any
figures proposed as licence limits to take account of the above uncertainties.
Blasting Air Overpressure:
The recommended increase tolerance to 3 dB is in line with good professional practice.
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50
APPENDIX III
“Air Quality Modelling of NOx and PM10
(2007)” – RFI Report (Dec 2007)
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Irish Cement
Irish Cement Platin IPPC Licence Application
Air Quality Modelling of NOx and PM (2007)
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Irish Cement
Irish Cement Platin IPPC Licence Application
Air Quality Modelling of NOx and PM (2007)
Report for RFI (December 2007) December 2007
This report takes into account the
particular instructions and requirements of our client. It is not intended for and should not be relied upon by any third party and no responsibility is undertaken to any third party
Arup Consulting Engineers 10 Wellington Road, Dublin 4 Ireland Tel +353 1 614 4200 Fax +353 1 668 3169 www.arup.ie Job number D 5374/40
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
J:\D5300-D5399\D5374\5) DESIGN\40\AQ\AIR DISPERSION MODELLING REPORT 2007_D5374-10_ISSUE3.DOC
Arup Consulting EngineersIssue 3 20 December 2007
CONTENTS
Page
1. INTRODUCTION........................................................................................................................1
2. METHODOLOGY.......................................................................................................................1 2.1 Scenario 1 ..................................................................................................................................2 2.2 Scenario 2 ..................................................................................................................................2 2.3 Scenario 3 ..................................................................................................................................2 2.4 Scenario 4 ..................................................................................................................................2 2.5 Scenario 5 ..................................................................................................................................2 2.6 Scenario 6 ..................................................................................................................................2 2.7 Cumulative Impact Assessment.................................................................................................2
3. AIR QUALITY STANDARDS ....................................................................................................3 3.1 NO2 limit values (protection of human health) ...........................................................................3 3.2 NOx limit values (protection of vegetation).................................................................................3 3.3 PM10 limit values (protection of human health) ..........................................................................3
4. BACKGROUND CONCENTRATIONS......................................................................................4
5. DISPERSION MODELLING ......................................................................................................4 5.1 Emissions...................................................................................................................................5 5.2 Building Wake Effect..................................................................................................................7 5.3 Receptor Locations ....................................................................................................................7 5.4 Meteorological Data ...................................................................................................................7
6. RESULTS ..................................................................................................................................7 6.1 Scenario 1 ..................................................................................................................................7 6.2 Scenario 2 ................................................................................................................................10 6.3 Scenario 3 ................................................................................................................................14 6.4 Scenario 4 ................................................................................................................................16 6.5 Scenario 5 ................................................................................................................................18 6.6 Scenario 6 ................................................................................................................................21
7. CUMULATIVE IMPACT ASSESSMENT.................................................................................23 7.1 Location of Irish Cement maximum .........................................................................................24 7.2 Location of Indaver maximum..................................................................................................28 7.3 Location of SSE maximum.......................................................................................................33
8. CONCLUSIONS.......................................................................................................................37 8.1 Scenarios 1 to 6 .......................................................................................................................37 8.2 Cumulative Impact Assessment...............................................................................................38 8.3 EPA RFI ...................................................................................................................................38 8.4 Summary..................................................................................................................................39
9. REFERENCES.........................................................................................................................39 Figures Figure 1 Isopleths of predicted annual mean NO2: Scenario 1 Figure 2 Isopleths of predicted annual mean PM10: Scenario 2 Figure 3 Isopleths of predicted annual mean NO2: Scenario 3 Figure 4 Isopleths of predicted annual mean PM10: Scenario 4 Figure 5 Isopleths of predicted annual mean NO2: Scenario 5
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
J:\D5300-D5399\D5374\5) DESIGN\40\AQ\AIR DISPERSION MODELLING REPORT 2007_D5374-10_ISSUE3.DOC
Arup Consulting EngineersIssue 3 20 December 2007
Figure 6 Isopleths of predicted annual mean PM10: Scenario 6
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
J:\D5300-D5399\D5374\5) DESIGN\40\AQ\AIR DISPERSION MODELLING REPORT 2007_D5374-10_ISSUE3.DOC
Page 1 Arup Consulting EngineersIssue 3 20 December 2007
1. INTRODUCTION Irish Cement Ltd. operates a cement plant at Platin, Co. Meath. This study assesses the dispersion of emissions to air of oxides of nitrogen (NOx) and particulate matter (PM10).
This report has been prepared for the response to the EPA’s request dated 15 November 2007 for further information (RFI) following clarification from the EPA as to their exact requirements. It updates the air quality modelling included in the EIS and the IPPC Licence Application.
Several scenarios are presented because the current plant with the Kiln 1 Line will be operational only until the commissioning of the Kiln 3 Line in late 2008. Kiln 1 will operate with Kiln 2 until the commissioning of Kiln 3. On the start-up of Kiln 3, Kiln 1 will be decommissioned. Only Kiln 2 and Kiln 3 will operate thereafter.
Exhaust gases from the new Kiln 3 Line may be used to dry limestone being milled for the production of CEM II cements in the existing Raw Mill 1. In this situation, it is proposed to vent the gas at a high level through the existing Kiln 1 chimney. The modelling also deals with this situation (Scenarios 5 and 6).
2. METHODOLOGY Emissions from ten sources were modelled using AERMOD. Six scenarios were assessed.
Scenarios 1 and 2 reflect the operation of the Kiln 1 Line and the Kiln 2 Line, at expected licence flow and concentration limits. Scenario 1 addresses the NOx concentrations. Scenario 2 addresses the PM10 concentrations. The Kiln 1 Line and Kiln 2 Line will be operational together only until the commissioning of the Kiln 3 Line. Therefore Scenarios 1 and 2 apply until late 2008.
Scenarios 3 and 4 reflect the operation of the Kiln 2 Line and the Kiln 3 Line, at expected licence flow and concentration limits. Scenario 3 addresses the NOx concentrations. Scenario 4 addresses the PM10 concentrations. The Kiln 3 Line will be commissioned in late 2008. Therefore Scenarios 3 and 4 apply from late 2008.
Scenarios 5 and 6 are as Scenarios 3 and 4 but with exhaust gases from Kiln 3 used to dry limestone in Raw Mill 1 and these gases vented through the Kiln 1 chimney. Scenario 5 addresses the NOx concentrations. Scenario 6 addresses the PM10 concentrations. Scenarios 5 and 6 apply from late 2008.
NO2 concentrations were calculated from the predicted NOx concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied.
The results presented in the air dispersion modelling report for the IPPC Licence Application (Attachment I) were conservative, since 100% of total suspended particulates was assumed to be PM10 and 60% was assumed to be PM2.5. From particle size distribution (PSD) analysis carried out at Irish Cement Limerick in October 2007, 54% of total suspended particulates is PM10 and 27% of total suspended particulates (or 49% of PM10) is PM2.5. This PSD analysis has been applied to the results.
The modelling predictions represent the most conservative or worst-case concentrations which may arise. Several worst-case conditions are assumed to be coincident:
• Emission sources are operating at maximum flow rates, continuously;
• Emission sources are operating at maximum emission concentrations, rather than average emission concentrations;
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
J:\D5300-D5399\D5374\5) DESIGN\40\AQ\AIR DISPERSION MODELLING REPORT 2007_D5374-10_ISSUE3.DOC
Page 2 Arup Consulting EngineersIssue 3 20 December 2007
• Emission sources are operating for every hour of every day of the year;
• Meteorological conditions are those which give rise to the maximum predicted concentration, identifying the worst hour from five years of hourly meteorological data;
• Receptor location is that which experiences the maximum predicted concentration.
2.1 Scenario 1 NOx emissions from three sources: Kiln 1, Kiln 2 and Coal Mill 2. The Kiln 1 emission point incorporates emissions from Kiln 1, Raw Mill 1 and Coal Mill 1.
2.2 Scenario 2 PM emissions from seven sources: Kiln 1, Kiln 2, Coal Mill 2, Cement Mill 1, Cement Mill 2, Cement Mill 3 and Kiln 2 Grate Cooler. As in Scenario 1, the Kiln 1 emission point incorporates emissions from Kiln 1, Raw Mill 1 and Coal Mill 1.
2.3 Scenario 3 NOx emissions from three sources: Kiln 2, Kiln 3 and Coal Mill 2.
2.4 Scenario 4 PM emissions from nine sources: Kiln 2, Kiln 3, Coal Mill 2, Cement Mill 1, Cement Mill 2, Cement Mill 3, Kiln 2 Grate Cooler, Kiln 3 Grate Cooler and Cement Mill 4.
2.5 Scenario 5 NOx emissions from four sources: Kiln 2, Kiln 3, Coal Mill 2 and Raw Mill 1. The Raw Mill 1 emissions are routed through the Kiln 1 stack.
2.6 Scenario 6 PM emissions from ten sources: Kiln 2, Kiln 3, Coal Mill 2, Raw Mill 1, Cement Mill 1, Cement Mill 2, Cement Mill 3, Kiln 2 Grate Cooler, Kiln 3 Grate Cooler and Cement Mill 4. As in Scenario 5, the Raw Mill 1 emissions are routed through the Kiln 1 stack.
2.7 Cumulative Impact Assessment Following clarification from the EPA, the cumulative impact assessment has been revised and expanded.
Facilities have been proposed in the vicinity of Irish Cement’s site at Platin by Indaver Ireland at Carranstown and by Scottish and Southern Energy Plc. (SSE) between Carranstown and Caulstown.
The planning permission for the SSE facility has lapsed and ICL has been advised by consultants to SSE (2007) that they are not proceeding with this development. Since the planning permission for the SSE facility has lapsed that development cannot proceed without a further grant of planning permission. Nevertheless the predicted concentrations due to the SSE 400MW facility have been included in the cumulative impact assessment, as provided in December 2007 by SSE through their air dispersion modelling consultants.
The most recent data for the Indaver facility has been used, as provided by Indaver through their air dispersion modelling consultants (Indaver, 2007).
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
J:\D5300-D5399\D5374\5) DESIGN\40\AQ\AIR DISPERSION MODELLING REPORT 2007_D5374-10_ISSUE3.DOC
Page 3 Arup Consulting EngineersIssue 3 20 December 2007
3. AIR QUALITY STANDARDS The Air Quality Standards (AQS) Regulations, 2002 (S.I. No. 271 of 2002) specify the Limit Values for oxides of nitrogen (NOx), nitrogen dioxide (NO2) and particulate matter of diameter less than 10 microns (PM10). Table 1 shows the AQS Limit Values relevant to the assessment of the Irish Cement Platin facility. The Air Quality Standards Limit Values are referred to in this report as AQSs, to differentiate from the IPPC Licence Limit Values.
The Irish AQS Regulations (2002) are based on EU Directives 96/62/EC, 1999/30/EC and 2000/69/EC. It is proposed by the EU to extend the PM10 Stage 1 AQS of 40μg/m3 to 2015 instead of introducing the Stage 2 AQS of 20μg/m3 (CEC, 2005). It is also proposed by the EU to introduce a concentration cap for annual mean PM2.5 of 25μg/m3 to be attained by 1 January 2010 (CEC, 2005). There is no Irish AQS for PM2.5.
Table 1 Air Quality Standards (AQS Regulations S.I. No. 271 of 2002 and CEC 2005)
Pollutant Limit value
for the protection of:
Averaging period
Limit value
(μg/m3)
Basis of application of limit
value
Limit value attainment date
1-hour 200 ≤18 exceedances p.a. 1 January 2010
NO2 human health Calendar year 40 Annual mean “
NOx vegetation Calendar year 30 Annual mean 19 July 2001
24-hours 50 ≤35 exceedances p.a. 1 January 2005
Calendar year 40 Annual mean “
24-hours 50 ≤7 exceedances p.a. 1 January 2010 PM10 human health
Calendar year 20 Annual mean “
PM2.5 human health Calendar year 25 Concentration cap 1 January 2010
3.1 NO2 limit values (protection of human health) According to the Regulations, the AQSs for NO2 for the protection of human health are 40μg/m³ over 1 year and 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQSs for NO2 are to be attained by 1 January 2010.
3.2 NOx limit values (protection of vegetation) According to the Regulations, the AQS for NOx for the protection of vegetation is 30μg/m³ over 1 year, effective from 19 July 2001.
3.3 PM10 limit values (protection of human health) According to the Regulations, the AQSs for PM10 for the protection of human health are 40μg/m³ over 1 year and 50μg/m³ over 24 hours. The 24-hour AQS is not to be exceeded more than 35 times in a calendar year. The AQSs for PM10 have been effective from 1 January 2005.
According to the Regulations, from 1 January 2010 the AQSs for PM10 for the protection of human health will be 20μg/m³ over 1 year and 50μg/m³ over 24 hours, where the 24-hour AQS is not to be exceeded more than 7 times in a calendar year.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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AQSs for Particulate Matter (PM10) are set out in Annex III of EU Directive 1999/30/EC. The Irish AQS Regulations are “for the purpose of giving effect to Council Directives… 1999/30/EC” and follow the Stage 1 and Stage 2 approach for PM10 set out in Annex III of EU Directive 1999/30/EC. Annex III (of EU Directive 1999/30/EC) includes the caveat to the Stage 2 Limit Values that these are “Indicative limit values to be reviewed in the light of further information on health and environmental effects, technical feasibility and experience in the application of Stage 1 limit values in the Member States.” This caveat is not included in the Irish AQS Regulations.
The review of the EU Stage 2 Limit Values resulted in the proposal to extend the PM10 Stage 1 AQS of 40μg/m3 to 2015 instead of introducing the Stage 2 AQS of 20μg/m3 (CEC, 2005). This proposal is included in the common position agreed between the Commission and the Parliament (CEC, 2007).
Monitoring of ambient air quality in Ireland, carried out or coordinated by the EPA, will have contributed to the EU database used in the review of the Stage 2 Limit Values. This review resulted in the proposed decision to extend the PM10 Stage 1 AQS of 40μg/m3 to 2015 instead of introducing the Stage 2 AQS of 20μg/m3 (CEC, 2005). Average concentrations per zone in Ireland (EPA, 2007) were 85% to 123% of the Stage 2 Limit Value of 20μg/m3, which would allow little or no scope for source contributions over and above the background concentration.
4. BACKGROUND CONCENTRATIONS The site is classified as Zone D since it is outside Drogheda town (which is classified as Zone C). Concentrations measured in Zone D were taken to represent background concentrations, which were added to the annual mean ground-level concentrations predicted by modelling.
Relevant monitoring results recorded by the EPA in 2006 (EPA, 2007) were averaged for concentrations recorded at all relevant monitoring sites to represent typical annual mean background levels for NOx (8.3μg/m3), NO2 (5.7μg/m3) and PM10 (15.3μg/m3).
Average PM10 for Zone D has been calculated from 4 EPA monitoring stations in Zone D. Data from the Carnsore Point monitoring station has not been included since it is a coastal site whereas Irish Cement Platin is not a coastal site.
The annual mean concentration of PM10 at Carnsore Point was 1.5 to 2.7 times the concentration at the other (non-coastal) Zone D monitoring stations (EPA, 2007). Similarly, the annual mean concentration of PM10 at a Zone D coastal site was found to be 1.9 times the concentration at a non-coastal Zone D site (EPA, 2006). This may be due to naturally occurring sea-salt and organic materials.
PM2.5 has a proposed concentration cap rather than a limit value (CEC, 2005). The annual mean background concentration for PM2.5 (9.2 μg/m3) was derived from the PM10 concentrations using a ratio of 0.60 (EC, 2004).
Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance.
5. DISPERSION MODELLING Emissions were modelled using the model AERMOD, recommended by the EPA and the US EPA (2005). This is a computer model that predicts the ground level concentration due to pollutant emissions from specified sources. The model requires information on:
• Emission sources;
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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Page 5 Arup Consulting EngineersIssue 3 20 December 2007
• Neighbouring buildings;
• Receptor locations and;
• Meteorological conditions.
The model was used to predict ground level concentrations over 1-hour, 24-hour and annual averaging periods.
5.1 Emissions The emission sources for each of the six scenarios are given in Table 2. Scenarios 1, 3 and 5 assess the NOx emissions. Scenarios 2, 4 and 6 address the PM10 emissions.
The modelling predictions represent the most conservative or worst-case concentrations which may arise. Several worst-case conditions are assumed to be coincident:
• Emission sources are operating at maximum flow rates, continuously;
• Emission sources are operating at maximum emission concentrations, rather than average emission concentrations;
• Emission sources are operating for every hour of every day of the year;
• Meteorological conditions are those which give rise to the maximum predicted concentration, identifying the worst hour from five years of hourly meteorological data;
• Receptor location is that which experiences the maximum predicted concentration.
The model predictions are therefore extremely conservative, giving worst-case ground-level concentrations, which would never be realised in practice.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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Table 2 Emissions sources data
SOURCE NAME Kiln 1,
Raw Mill 1, Coal Mill 1
Kiln 2 Coal Mill 2 Cement Mill 1 Cement Mill
2 Cement Mill
3
Kiln 2 Grate Cooler
Kiln 3 Kiln 3 Grate Cooler
Cement Mill 4
Ref Base (m OD) +47.2 +50.33 +46.94 +47.3 +47.3 +50.76 +50.8 +45.2 +45.2 +50.9 H (m) 98.01 103.04 48.09 28.64 34.82 26.35 30.43 123 35 39 Diameter (m ID) 2.38 3.70 1.00 0.704 1.90 1.988 3.55 3.75 3.00 2.00 Volume flowrate (Nm3/hour, wet gas, actual O2)
- - - 18,500 120,000 135,000 210,000 - 219,000 110,000
Volume flowrate (Nm3/hour, dry gas, 10% O2)
190,000A
49,000B 400,000 31,000 - - - - 410,000 - -
Efflux velocity (m/s, wet, actual T, actual O2)
17.71A
5.86B 16.59 18.90 18.08 15.43 15.84 11.29 19.38 18.59 13.46
T (°C) 121A
118B 121 81 101 85 85 250 108 317 105
Scenario 1 NOx (mg/Nm3) 1800 1000 1000 - - - - - - -
Scenario 2 Particulates (mg/Nm3)
50 50 50 75 50 50 100 - - -
Scenario 3 NOx (mg/Nm3) - 1000 1000 - - - - 1300 - -
Scenario 4 Particulates (mg/Nm3)
- 50 50 75 50 50 100 30 30 30
Scenario 5 NOx (mg/Nm3) 1300 1000 1000 - - - - 1300 - -
Scenario 6 Particulates (mg/Nm3)
50 50 50 75 50 50 100 30 30 30
A Scenarios 1 and 2. B Scenarios 5 and 6. Scenarios 1a-4a, 5a.i & 6a.i.
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5.2 Building Wake Effect The length, width and height of buildings in the vicinity of the sources were taken into account in modelling. Building data was taken from information supplied by Irish Cement for this and previous assessments. AERMOD includes a software utility called BPIP to calculate direction-specific building downwash factors using the relative positions and dimensions of sources and neighbouring buildings.
5.3 Receptor Locations Two nested, Cartesian receptor grids were used, centred on the facility, as in previous assessments. One has receptors covering a 10km by 10km area at 1km intervals. The other has receptors covering a 2km by 2km area at 100m intervals. Elevations were taken from Ordnance Survey mapping as used in previous assessments.
5.4 Meteorological Data Meteorological data from Met Eireann’s synoptic station at Dublin Airport was used for 1998 to 2002 inclusive. The meteorological data includes hourly values for wind speed, wind direction, atmospheric stability, ambient temperature and mixing height.
6. RESULTS
6.1 Scenario 1 Scenario 1 represents the operation of the Kiln 1 Line and Kiln 2 Line, at expected licence flow and concentration limits. Scenario 1 applies until late 2008. NOx emissions were modelled for three sources (Table 2). The Kiln 1 emission point incorporates emissions from Kiln 1, Raw Mill 1 and Coal Mill 1.
6.1.1 Predicted concentrations of NO2 (protection of human health)
The maximum ground-level concentrations under Scenario 1 are compared to the AQS for NO2 for the protection of human health of 40μg/m³ over 1 year and 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQSs for NO2 are to be attained by 1 January 2010.
The maximum ground-level concentrations under Scenario 1 are predicted to be 52% of the AQS for 1-hour NO2 and 31% of the AQS for annual NO2. In the case of the annual concentration, 17% is due to the emissions from the cement works and 14% is due to the background concentration (Table 3).
EPA monitoring does not include 99.79th%ile 1-hour concentration and therefore it cannot be included as a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS.
Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied (Section 6.1.1.2) at a level of twice the annual average background concentration, according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance.
As stated in Section 2, nitrogen dioxide (NO2) concentrations were calculated from the predicted NOx concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied (UK EA, 2005) in Section 6.1.1.1.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour.
Figure 1 shows the isopleths (concentration contours) of predicted annual mean NO2 for Scenario 1 (excluding background concentration).
Table 3 Predicted concentrations of NO2 (μg/m3) for Scenario 1
Averaging period Concentration (NO2) (μg/m3)
Concentration as % of AQS
99.79th%ile 1-hour 104.9 52%
Calendar year 6.6 17%
Annual mean background (measured by EPA in 2006) 5.7 14%
Calendar year including annual mean background 12.3 31% ICP083.dat-ICP087.dat
6.1.1.1 Proportions of NOx to NO2
As stated in Section 2 and above, nitrogen dioxide (NO2) concentrations were calculated from the predicted NOx concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied (UK EA, 2005).
In Table 4 the short-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 0.5, whereas the long-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 1.0 (UK EA, 2005).
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour.
Table 4 Predicted concentrations of NO2 (μg/m3) for Scenario 1 (50% and 100%)
Averaging period Concentration (NO2) (μg/m3)
Concentration as % of AQS
99.79th%ile 1-hour 104.9 52%
Calendar year 13.1 33%
Annual mean background (measured by EPA in 2006) 5.7 14%
Calendar year including annual mean background 18.8 47% ICP083.dat-ICP087.dat
According to the same methodology (UK EA, 2005), conversion factors of 0.35 for short-term and 0.70 for long-term can also be applied. In Table 5 the short-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 0.35, whereas the long-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 0.7 (UK EA, 2005).
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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Table 5 Predicted concentrations of NO2 (μg/m3) for Scenario 1 (35% and 70%)
Averaging period Concentration (NO2) (μg/m3)
Concentration as % of AQS
99.79th%ile 1-hour 73.4 37%
Calendar year 9.2 23%
Annual mean background (measured by EPA in 2006) 5.7 14%
Calendar year including annual mean background 14.9 37% ICP083.dat-ICP087.dat
6.1.1.2 Short-term background concentration
EPA monitoring does not include 99.79th%ile 1-hour concentration and therefore it cannot be included as a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS.
Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied at a level of twice the annual average background concentration, according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance.
In Table 6 the short-term background concentration is taken to be twice the long-term background concentration. The short-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 0.5, which is conservative compared to the conversion factor of 0.35 also used by the UK EA (2005).
Table 6 Predicted concentrations of NO2 (μg/m3) for Scenario 1
Averaging period Concentration (NO2) (μg/m3)
Concentration as % of AQS
99.79th%ile 1-hour 104.9 52%
2 x Annual mean background (measured by EPA in 2006) 11.4 6%
Total 116.3 58% ICP083.dat-ICP087.dat
6.1.2 Predicted concentrations of NOx (protection of vegetation)
The maximum ground-level concentrations under Scenario 1 are compared to the AQS for NOx for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NOx has been in effect since 19 July 2001.
The maximum ground-level concentrations under Scenario 1 are predicted to be 71% of the AQS for annual NOx. Of this, 44% is due to the emissions from the cement works and 28% is due to the background concentration (Table 7).
The predicted concentrations comply with the AQS of 30μg/m³ over 1 year.
Table 7 Predicted concentrations of NOx (μg/m3) for Scenario 1
Averaging period Concentration (NOx) (μg/m3)
Concentration as % of AQS
Calendar year 13.1 44%
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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Annual mean background (measured by EPA in 2006) 8.3 28%
Calendar year including annual mean background 21.4 71% ICP083.dat-ICP087.dat
6.2 Scenario 2 Scenario 2 represents the operation of Kiln 1 Line and Kiln 2 Line, at expected licence flow and concentration limits. Scenario 2 applies until late 2008. PM emissions were modelled for seven sources (Table 2). The Kiln 1 emission point incorporates emissions from Kiln 1, Raw Mill 1 and Coal Mill 1.
The results presented in the air dispersion modelling report for the IPPC Licence Application (Attachment I) were conservative, since 100% of total suspended particulates were assumed to be PM10 and 60% were assumed to be PM2.5. From particle size distribution (PSD) analysis carried out at Irish Cement Limerick in October 2007, 27% of total suspended particulates (or 49% of PM10) are PM2.5 (Table 8). This PSD analysis has been applied to the results.
Table 8 Results of particulate size distribution analysis
TSP PM10 PM2.5
Assumed Attachment I 100% of TSP 100% of TSP 60% of TSP
Measured Particle size distribution 100% of TSP 54% of TSP 27% of TSP 49% of PM10
The maximum ground-level concentrations under Scenario 2 are compared to the AQSs for PM10 for the protection of human health of 40μg/m³ over 1 year and 50μg/m³ over 24 hours. The 24-hour AQS is not to be exceeded more than 35 times in a calendar year. The AQSs for PM10 have been effective from 1 January 2005.
The maximum ground-level concentrations under Scenario 2 are predicted to be 25% of the AQS for 24-hour PM10 and 49% of the AQS for annual PM10. In the case of the annual concentration, 11% is due to the emissions and 38% is due to the background concentration (Table 9).
EPA monitoring does not include a 24-hour concentration, and therefore it is not possible to include such a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS.
Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations at a level of twice the annual average background concentration, have also been applied (Section 6.2.1) according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance.
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 50μg/m³ over 24 hours.
Figure 2 shows the isopleths (concentration contours) of predicted annual mean PM10 for Scenario 2 (excluding background concentration).
It is also proposed by the EU to introduce a concentration cap for annual mean PM2.5 of 25μg/m3 to be attained by 1 January 2010 (CEC, 2005). There is no Irish AQS for PM2.5.
Concentrations for PM2.5 were derived from the PM concentrations using the PSD (Table 8). The background concentration of PM2.5 was derived from the PM10 concentrations measured by the EPA in 2006 (EPA, 2007) using a ratio of 0.60 (EC, 2004).
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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The predicted concentrations comply with the proposed concentration cap AQS of 25μg/m3 (Table 10).
Table 9 Predicted concentrations of PM10 (μg/m3) for Scenario 2
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
90.41st%ile 24-hour 12.4 25%
Calendar year 4.4 11%
Annual mean background (measured by EPA in 2006) 15.3 38%
Calendar year including annual mean background 19.7 49% ICP088.dat-ICP092.dat
Table 10 Predicted concentrations of PM2.5 (μg/m3) for Scenario 2
Averaging period Concentration (PM2.5) (μg/m3)
Concentration as % of AQS
Calendar year 2.2 9%
Annual mean background (measured by EPA in 2006) 9.2 37%
Calendar year including annual mean background 11.4 46% ICP088.dat-ICP092.dat
6.2.1 Short-term background concentration
Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied at a level of twice the annual average background concentration, according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance. In Table 11 the short-term background concentration is taken to be twice the long-term background concentration.
Table 11 Predicted concentrations of PM10 (μg/m3) for Scenario 2
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
90.41st%ile 24-hour 12.4 25%
2 x Annual mean background (measured by EPA in 2006) 30.6 61%
Total 43.0 86% ICP088.dat-ICP092.dat
6.2.2 Comparison with the AQSs for particulate matter Stage 2 (2010)
The maximum ground-level concentrations due to the emissions under Scenario 2 are compared to the AQSs for PM10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002).
The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in 2006. The Irish AQS Regulations (2002) do not refer to PM2.5.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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The maximum ground-level concentrations due to the emissions under Scenario 2 are predicted to be 93% of the AQS for annual PM10. Of this, 22% is due to the emissions and 71% is due to the background concentration.
The predicted concentrations comply with the AQS of 20μg/m³ over 1 year.
Table 12 Predicted concentrations of PM10 (μg/m3) for Scenario 2
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
Calendar year 4.4 22%
Annual mean background (2010) 14.1 71%
Total 18.5 93% ICP088.dat-ICP092.dat
Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied at a level of twice the annual average background concentration, according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance.
The maximum ground-level concentrations due to the emissions under Scenario 2 are predicted to be 93% of the AQS for 24-hour PM10. Of this, 36% is due to the source contributions and 71% is due to the background concentration.
The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours.
Table 13 Predicted concentrations of PM10 (μg/m3) for Scenario 2
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
98.08th%ile 24-hour 18.2 36%
2 x Annual mean background (2010) 28.2 71%
Total 46.4 93% ICP088.dat-ICP092.dat
6.2.3 Scenario 2 with Cement Mill 4
Scenario 2 was also modelled to include Cement Mill 4. This combination would arise in the event that Cement Mill 4 is operational during 2008 before the Kiln 1 Line is decommissioned in late 2008. Source data for this scenario is as per Scenario 2 with the addition of Cement Mill 4.
The maximum ground-level concentrations under “Scenario 2 with Cement Mill 4” are predicted to be 12.5μg/m3 for 90.41st%ile 24-hour PM10 and 4.4μg/m3 for annual PM10. These can be compared to the maximum ground-level concentrations under Scenario 2 of 12.4μg/m3
for 90.41st%ile 24-hour PM10 and 4.4μg/m3 for annual PM10.
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 50μg/m³ over 24 hours.
6.2.3.1 Short-term background concentration
Following consultation with the EPA, background concentrations for consideration with the short-term average PM10 concentration have also been applied at a level of twice the annual average background concentration (UK EA, 2002). In Table 14 the short-term background concentration is taken to be twice the long-term background concentration.
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Table 14 Predicted concentrations of PM10 (μg/m3) for Scenario 2 with Cement Mill 4
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
90.41st%ile 24-hour 12.5 25%
2 x Annual mean background (measured by EPA in 2006) 30.6 61%
Total 43.1 86% ICP158.dat-ICP162.dat
6.2.3.2 Comparison with the AQSs for particulate matter Stage 2 (2010)
The maximum ground-level concentrations due to the emissions under Scenario 2 with Cement Mill 4 are compared to the AQSs for PM10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002).
The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in 2006. The Irish AQS Regulations (2002) do not refer to PM2.5.
The maximum ground-level concentrations due to the emissions under Scenario 2 with Cement Mill 4 are predicted to be 93% of the AQS for annual PM10. Of this, 22% is due to the emissions and 71% is due to the background concentration.
The predicted concentrations comply with the AQS of 20μg/m³ over 1 year.
Table 15 Predicted concentrations of PM10 (μg/m3) for Scenario 2 with Cement Mill 4
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
Calendar year 4.4 22%
Annual mean background (2010) 14.1 71%
Total 18.5 93% ICP158.dat-ICP162.dat
The maximum ground-level concentrations due to the emissions under Scenario 2 with Cement Mill 4 are predicted to be 36% of the AQS for 24-hour PM10.
As per the EPA’s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the maximum ground-level concentrations due to the emissions under Scenario 2 with Cement Mill 4 are predicted to be 93% of the AQS for 24-hour PM10. Of this, 36% is due to the source contributions and 71% is due to the background concentration.
The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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Page 14 Arup Consulting EngineersIssue 3 20 December 2007
Table 16 Predicted concentrations of PM10 (μg/m3) for Scenario 2 with Cement Mill 4
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
98.08th%ile 24-hour 18.2 36%
2 x Annual mean background (2010) 28.2 71%
Total 46.4 93% ICP158.dat-ICP162.dat
6.3 Scenario 3 Scenario 3 represents the operation of the Kiln 2 Line and Kiln 3 Line, at expected licence flow and concentration limits. Scenario 3 applies from the commissioning of Kiln 3 in late 2008. NOx emissions were modelled for three sources (Table 2).
6.3.1 Predicted concentrations of NO2 (protection of human health)
The maximum ground-level concentrations under Scenario 3 are compared to the AQS for NO2 for the protection of human health of 40μg/m³ over 1 year and 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQSs for NO2 are to be attained by 1 January 2010.
The maximum ground-level concentrations under Scenario 3 are predicted to be 43% of the AQS for 1-hour NO2 and 29% of the AQS for annual NO2. In the case of the annual concentration, 14% is due to the emissions from the cement works and 14% is due to the background concentration.
EPA monitoring does not include 99.79th%ile 1-hour concentration and therefore it cannot be included as a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS.
Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied at a level of twice the annual average background concentration, (Section 6.3.1.2) according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance.
As stated in Section 2, nitrogen dioxide (NO2) concentrations were calculated from the predicted NOx concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied (UK EA, 2005) in Section 6.3.1.1.
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour.
Figure 3 shows the isopleths (concentration contours) of predicted annual mean NO2 for Scenario 3 (excluding background concentration).
Table 17 Predicted concentrations of NO2 (μg/m3) for Scenario 3
Averaging period Concentration (NO2) (μg/m3)
Concentration as % of AQS
99.79th%ile 1-hour 85.9 43%
Calendar year 5.8 14%
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Page 15 Arup Consulting EngineersIssue 3 20 December 2007
Annual mean background (measured by EPA in 2006) 5.7 14%
Calendar year including annual mean background 11.5 29% ICP093.dat-ICP097.dat
6.3.1.1 Proportions of NOx to NO2
As stated in Section 2 and above, nitrogen dioxide (NO2) concentrations were calculated from the predicted NOx concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied (UK EA, 2005).
In Table 18 the short-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 0.5, whereas the long-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 1.0. In Table 19 the short-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 0.35, whereas the long-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 0.7.
Table 18 Predicted concentrations of NO2 (μg/m3) for Scenario 3 (50% and 100%)
Averaging period Concentration (NO2) (μg/m3)
Concentration as % of AQS
99.79th%ile 1-hour 85.9 43%
Calendar year 11.5 29%
Annual mean background (measured by EPA in 2006) 5.7 14%
Calendar year including annual mean background 17.2 43% ICP093.dat-ICP097.dat
Table 19 Predicted concentrations of NO2 (μg/m3) for Scenario 3 (35% and 70%)
Averaging period Concentration (NO2) (μg/m3)
Concentration as % of AQS
99.79th%ile 1-hour 60.1 30%
Calendar year 8.1 20%
Annual mean background (measured by EPA in 2006) 5.7 14%
Calendar year including annual mean background 13.8 35% ICP093.dat-ICP097.dat
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour.
6.3.1.2 Short-term background concentration
Again, following consultation with the EPA, background concentrations for consideration with the short-term average NO2 concentration have also been applied (UK EA, 2002). In Table 20 the short-term background concentration is taken to be twice the long-term background concentration.
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Page 16 Arup Consulting EngineersIssue 3 20 December 2007
Table 20 Predicted concentrations of NO2 (μg/m3) for Scenario 3
Averaging period Concentration (NO2) (μg/m3)
Concentration as % of AQS
99.79th%ile 1-hour 85.9 43%
2 x Annual mean background (measured by EPA in 2006) 11.4 6%
Total 97.3 49% ICP093.dat-ICP097.dat
6.3.2 Predicted concentrations of NOx (protection of vegetation)
The maximum ground-level concentrations under Scenario 3 are compared to the AQS for NOx for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NOx has been in effect since 19 July 2001.
The maximum ground-level concentrations under Scenario 3 are predicted to be 66% of the AQS for annual NOx. Of this, 38% is due to the emissions from the cement works and 28% is due to the background concentration.
The predicted concentrations comply with the AQS of 30μg/m³ over 1 year.
Table 21 Predicted concentrations of NOx (μg/m3) for Scenario 3
Averaging period Concentration (NOx) (μg/m3)
Concentration as % of AQS
Calendar year 11.5 38%
Annual mean background (measured by EPA in 2006) 8.3 28%
Calendar year including annual mean background 19.8 66% ICP093.dat-ICP097.dat
6.4 Scenario 4 Scenario 4 represents the operation of the Kiln 2 Line and Kiln 3 Line, at expected licence flow and concentration limits. Scenario 4 applies from the commissioning of Kiln 3 in late 2008. PM emissions were modelled for nine sources (Table 2).
The results presented in the air dispersion modelling report for the IPPC Licence Application (Attachment I) were conservative, since 100% of total suspended particulates were assumed to be PM10 and 60% were assumed to be PM2.5. From particle size distribution (PSD) analysis carried out at Irish Cement Limerick in October 2007, 27% of total suspended particulates (or 49% of PM10) are PM2.5 (Table 8). This PSD analysis has been applied to the results.
The maximum ground-level concentrations under Scenario 4 are compared to the AQSs for PM10 for the protection of human health of 40μg/m³ over 1 year and 50μg/m³ over 24 hours. The 24-hour AQS is not to be exceeded more than 35 times in a calendar year. The AQSs for PM10 have been effective from 1 January 2005.
The maximum ground-level concentrations under Scenario 4 are predicted to be 25% of the AQS for 24-hour PM10 and 49% of the AQS for annual PM10. In the case of the annual concentration, 11% is due to the emissions and 38% is due to the background concentration.
EPA monitoring does not include a 24-hour concentration, and therefore it is not possible to include such a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS.
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Page 17 Arup Consulting EngineersIssue 3 20 December 2007
Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations have also been applied at a level of twice the annual average background concentration, (Section 6.4.1) according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance.
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 50μg/m³ over 24 hours.
Figure 4 shows the isopleths (concentration contours) of predicted annual mean PM10 for Scenario 4 (excluding background concentration).
It is also proposed by the EU to introduce a concentration cap for annual mean PM2.5 of 25μg/m3 to be attained by 1 January 2010 (CEC, 2005). ). There is no Irish AQS for PM2.5.
Concentrations for PM2.5 were derived from the PM concentrations using the PSD (Table 8). The background concentration of PM2.5 was derived from the PM10 concentrations measured by the EPA in 2006 (EPA, 2007) using a ratio of 0.60 (EC, 2004).
The predicted concentrations comply with the proposed concentration cap AQS of 25μg/m3.
Table 22 Predicted concentrations of PM10 (μg/m3) for Scenario 4
Averaging period Maximum Concentration
Concentration as % of AQS
90.41st%ile 24-hour 12.5 25%
Calendar year 4.5 11%
Annual mean background (measured by EPA in 2006) 15.3 38%
Calendar year including annual mean background 19.8 49% ICP098.dat-ICP102.dat
Table 23 Predicted concentrations of PM2.5 (μg/m3) for Scenario 4
Averaging period Concentration Concentration as % of AQS
Calendar year 2.2 9%
Annual mean background (measured by EPA in 2006) 9.2 37%
Calendar year including annual mean background 11.4 46% ICP098.dat-ICP102.dat
6.4.1 Short-term background concentration
Following consultation with the EPA, background concentrations for consideration with the short-term average PM10 concentration have also been applied (UK EA, 2002). In Table 24 the short-term background concentration is taken to be twice the long-term background concentration.
Table 24 Predicted concentrations of PM10 (μg/m3) for Scenario 4
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
90.41st%ile 24-hour 12.5 25%
2 x Annual mean background (measured by EPA in 2006) 30.6 61%
Total 43.1 86% ICP098.dat-ICP102.dat
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Page 18 Arup Consulting EngineersIssue 3 20 December 2007
6.4.2 Comparison with the AQSs for particulate matter Stage 2 (2010)
The maximum ground-level concentrations due to the emissions under Scenario 4 are compared to the AQSs for PM10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002).
The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in 2006. The Irish AQS Regulations (2002) do not refer to PM2.5.
The maximum ground-level concentrations due to the emissions under Scenario 4 are predicted to be 94% of the AQS for annual PM10. Of this, 23% is due to the emissions and 71% is due to the background concentration.
The predicted concentrations comply with the AQS of 20μg/m³ over 1 year.
Table 25 Predicted concentrations of PM10 (μg/m3) for Scenario 4
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
Calendar year 4.5 23%
Annual mean background (2010) 14.1 71%
Total 18.6 94% ICP098.dat-ICP102.dat
The maximum ground-level concentrations due to the emissions under Scenario 4 are predicted to be 37% of the AQS for 24-hour PM10.
As per the EPA’s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the maximum ground-level concentrations due to the emissions under Scenario 4 are predicted to be 93% of the AQS for 24-hour PM10. Of this, 37% is due to the source contributions and 56% is due to the background concentration.
The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours.
Table 26 Predicted concentrations of PM10 (μg/m3) for Scenario 4
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
98.08th%ile 24-hour 18.4 37%
2 x Annual mean background (2010) 28.2 56%
Total 46.6 93% ICP098.dat-ICP102.dat
6.5 Scenario 5 Scenario 5 represents the operation of the Kiln 2 Line and Kiln 3 Line, at expected licence flow and concentration limits, with exhaust gases from Kiln 3 used to dry limestone in Raw Mill 1 and these gases vented through the Kiln 1 chimney. Scenario 5 applies from the commissioning of Kiln 3 in late 2008. NOx emissions were modelled for four sources (Table 2).
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Page 19 Arup Consulting EngineersIssue 3 20 December 2007
6.5.1 Predicted concentrations of NO2 (protection of human health)
The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO2 for the protection of human health of 40μg/m³ over 1 year and 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQSs for NO2 are to be attained by 1 January 2010.
The maximum ground-level concentrations under Scenario 5 are predicted to be 43% of the AQS for 1-hour NO2 and 30% of the AQS for annual NO2. In the case of the annual concentration, 16% is due to the emissions from the cement works and 14% is due to the background concentration.
EPA monitoring does not include 99.79th%ile 1-hour concentration and therefore it cannot be included as a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS.
Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations at a level of twice the annual average background concentration, have also been applied (Section 6.5.1.2) according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance.
As stated in Section 2, nitrogen dioxide (NO2) concentrations were calculated from the predicted NOx concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied (UK EA, 2005) in Section 6.5.1.1.
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour.
Figure 5 shows the isopleths (concentration contours) of predicted annual mean NO2 for Scenario 5 (excluding background concentration).
Table 27 Predicted concentrations of NO2 (μg/m3) for Scenario 5
Averaging period Concentration (NO2) (μg/m3)
Concentration as % of AQS
99.79th%ile 1-hour 85.9 43%
Calendar year 6.2 16%
Annual mean background (measured by EPA in 2006) 5.7 14%
Calendar year including annual mean background 11.9 30% ICP143.dat-ICP147.dat
6.5.1.1 Proportions of NOx to NO2
As stated in Section 2 and above, nitrogen dioxide (NO2) concentrations were calculated from the predicted NOx concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, conversion factors from 0.35 to 1 have also been applied (UK EA, 2005).
In Table 28 the short-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 0.5, whereas the long-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 1.0. In Table 29 the short-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 0.35, whereas the long-term average NO2 concentration was calculated from the predicted NOx concentrations using a conversion factor of 0.7.
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Page 20 Arup Consulting EngineersIssue 3 20 December 2007
Table 28 Predicted concentrations of NO2 (μg/m3) for Scenario 5 (50% and 100%)
Averaging period Concentration (NO2) (μg/m3)
Concentration as % of AQS
99.79th%ile 1-hour 85.9 43%
Calendar year 12.5 31%
Annual mean background (measured by EPA in 2006) 5.7 14%
Calendar year including annual mean background 18.2 46% ICP143.dat-ICP147.dat
Table 29 Predicted concentrations of NO2 (μg/m3) for Scenario 5 (35% and 70%)
Averaging period Concentration (NO2) (μg/m3)
Concentration as % of AQS
99.79th%ile 1-hour 60.1 30%
Calendar year 8.8 22%
Annual mean background (measured by EPA in 2006) 5.7 14%
Calendar year including annual mean background 14.5 36% ICP143.dat-ICP147.dat
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 200μg/m³ over 1 hour.
6.5.1.2 Short-term background concentration
Again, following consultation with the EPA, background concentrations for consideration with the short-term average NO2 concentration have also been applied (UK EA, 2002). In Table 30 the short-term background concentration is taken to be twice the long-term background concentration.
Table 30 Predicted concentrations of NO2 (μg/m3) for Scenario 5
Averaging period Concentration (NO2) (μg/m3)
Concentration as % of AQS
99.79th%ile 1-hour 85.9 43%
2 x Annual mean background (measured by EPA in 2006) 11.4 6%
Total 97.3 49% ICP143.dat-ICP147.dat
6.5.2 Predicted concentrations of NOx (protection of vegetation)
The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NOx for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NOx has been in effect since 19 July 2001.
The maximum ground-level concentrations under Scenario 5 are predicted to be 69% of the AQS for annual NOx. Of this, 42% is due to the emissions from the cement works and 28% is due to the background concentration.
The predicted concentrations comply with the AQS of 30μg/m³ over 1 year.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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Page 21 Arup Consulting EngineersIssue 3 20 December 2007
Table 31 Predicted concentrations of NOx (μg/m3) for Scenario 5
Averaging period Concentration (NOx) (μg/m3)
Concentration as % of AQS
Calendar year 12.5 42%
Annual mean background (measured by EPA in 2006) 8.3 28%
Calendar year including annual mean background 20.8 69% ICP143.dat-ICP147.dat
6.6 Scenario 6 Scenario 6 represents the operation of the Kiln 2 Line and Kiln 3 Line, at expected licence flow and concentration limits, with exhaust gases from Kiln 3 used to dry limestone in Raw Mill 1 and these gases vented through the Kiln 1 chimney. Scenario 6 applies from the commissioning of Kiln 3 in late 2008. PM10 emissions were modelled for ten sources (Table 2).
The results presented in the air dispersion modelling report for the IPPC Licence Application (Attachment I) were conservative, since 100% of total suspended particulates were assumed to be PM10 and 60% were assumed to be PM2.5. From particle size distribution (PSD) analysis carried out at Irish Cement Limerick in October 2007, 27% of total suspended particulates (or 49% of PM10) are PM2.5 (Table 8). This PSD analysis has been applied to the results.
The maximum ground-level concentrations under Scenario 6 are compared to the AQSs for PM10 for the protection of human health of 40μg/m³ over 1 year and 50μg/m³ over 24 hours. The 24-hour AQS is not to be exceeded more than 35 times in a calendar year. The AQSs for PM10 have been effective from 1 January 2005.
The maximum ground-level concentrations under Scenario 6 are predicted to be 25% of the AQS for 24-hour PM10 and 49% of the AQS for annual PM10. In the case of the annual concentration, 11% is due to the emissions and 38% is due to the background concentration.
EPA monitoring does not include a 24-hour concentration, and therefore it is not possible to include such a background concentration. However, it is unlikely that the inclusion of background concentrations would result in exceedance of the AQS.
Following consultation with the EPA, background concentrations for consideration with the short-term average concentrations at a level of twice the annual average background concentration, have also been applied (Section 6.6.1) according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance.
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year and 50μg/m³ over 24 hours.
Figure 6 shows the isopleths (concentration contours) of predicted annual mean PM10 for Scenario 6 (excluding background concentration).
It is also proposed by the EU to introduce a concentration cap for annual mean PM2.5 of 25μg/m3 to be attained by 1 January 2010 (CEC, 2005). ). There is no Irish AQS for PM2.5.
Concentrations for PM2.5 were derived from the PM concentrations using the PSD (Table 8). The background concentration of PM2.5 was derived from the PM10 concentrations measured by the EPA in 2006 (EPA, 2007) using a ratio of 0.60 (EC, 2004).
The predicted concentrations comply with the proposed concentration cap AQS of 25μg/m3.
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Page 22 Arup Consulting EngineersIssue 3 20 December 2007
Table 32 Predicted concentrations of PM10 (μg/m3) for Scenario 6
Averaging period Maximum Concentration
Concentration as % of AQS
90.41st%ile 24-hour 12.6 25%
Calendar year 4.5 11%
Annual mean background (measured by EPA in 2006) 15.3 38%
Calendar year including annual mean background 19.8 49% ICP148.dat-ICP152.dat
Table 33 Predicted concentrations of PM2.5 (μg/m3) for Scenario 6
Averaging period Concentration Concentration as % of AQS
Calendar year 2.2 9%
Annual mean background (measured by EPA in 2006) 9.2 37%
Calendar year including annual mean background 11.4 46% ICP148.dat-ICP152.dat
6.6.1 Short-term background concentration
Following consultation with the EPA, background concentrations for consideration with the short-term average PM10 concentration have also been applied (UK EA, 2002). In Table 34 the short-term background concentration is taken to be twice the long-term background concentration.
Table 34 Predicted concentrations of PM10 (μg/m3) for Scenario 6
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
90.41st%ile 24-hour 12.6 25%
2 x Annual mean background (measured by EPA in 2006) 30.6 61%
Total 43.2 86% ICP148.dat-ICP152.dat
6.6.2 Comparison with the AQSs for particulate matter Stage 2 (2010)
The maximum ground-level concentrations due to the emissions under Scenario 6 are compared to the AQSs for PM10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002).
The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in 2006. The Irish AQS Regulations (2002) do not refer to PM2.5.
The maximum ground-level concentrations due to the emissions under Scenario 6 are predicted to be 94% of the AQS for annual PM10. Of this, 23% is due to the emissions and 71% is due to the background concentration.
The predicted concentrations comply with the AQS of 20μg/m³ over 1 year.
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Page 23 Arup Consulting EngineersIssue 3 20 December 2007
Table 35 Predicted concentrations of PM10 (μg/m3) for Scenario 6
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
Calendar year 4.5 23%
Annual mean background (2010) 14.1 71%
Total 18.6 94% ICP148.dat-ICP152.dat
The maximum ground-level concentrations due to the emissions under Scenario 6 are predicted to be 37% of the AQS for 24-hour PM10.
As per the EPA’s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the maximum ground-level concentrations due to the emissions under Scenario 6 are predicted to be 93% of the AQS for 24-hour PM10. Of this, 37% is due to the source contributions and 56% is due to the background concentration.
The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours.
Table 36 Predicted concentrations of PM10 (μg/m3) for Scenario 6
Averaging period Concentration (PM10) (μg/m3)
Concentration as % of AQS
98.08th%ile 24-hour 18.4 37%
2 x Annual mean background (2010) 28.2 56%
Total 46.6 93% ICP148.dat-ICP152.dat
7. CUMULATIVE IMPACT ASSESSMENT Facilities have been proposed in the vicinity of Irish Cement’s site at Platin by Indaver Ireland at Carranstown and by Scottish and Southern Energy Plc. (SSE) between Carranstown and Caulstown. The planning permission for the SSE facility has lapsed and ICL has been advised by consultants to SSE (2007) that they are not proceeding with this development.
At the request of the EPA, the cumulative effect of the proposed developments was assessed by considering the ambient air quality and the source contributions due to Irish Cement Platin, Indaver and SSE. The cumulative effects were assessed for the locations of the maximum concentrations due to each of the three sources. That is, the source contributions due to Irish Cement, Indaver and SSE at the location of the maximum concentration due to Irish Cement were summed with the background concentration to give the cumulative effect. This was repeated for the locations of the maximum concentration due to Indaver and to SSE.
Predicted concentrations due to Indaver and SSE at each of the locations of maximum GLCs have been provided to Irish Cement for this cumulative impact assessment by Indaver and by SSE from their own air dispersion modelling. This approach is robust and allowed for a comprehensive cumulative impact assessment.
The planning permission for the SSE 400MW facility has lapsed and therefore that development cannot proceed without a further grant of planning permission. Nevertheless the
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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Page 24 Arup Consulting EngineersIssue 3 20 December 2007
predicted concentrations due to the SSE 400MW facility have been included in the cumulative impact assessment.
The most recent data for the Indaver facility has been used, as provided by Indaver through their air dispersion modelling consultants (Indaver, 2007).
Following consultation with the EPA, background concentrations for consideration with the short-term average NO2 concentration have also been applied according to UK guidance (UK EA, 2002). There is no equivalent Irish methodology or EPA guidance.
7.1 Location of Irish Cement maximum 7.1.1 Predicted concentrations of annual mean NO2 (μg/m3)
The maximum concentration due to Irish Cement is predicted to occur at (307080, 272058). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to Irish Cement is shown in Table 37.
The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO2 for the protection of human health of 40μg/m³ over 1 year. The AQS for NO2 is to be attained by 1 January 2010.
The cumulative impact of the maximum ground-level concentrations is predicted to be 31% of the AQS for annual NO2. Of this, 17% is due to the source contributions and 14% is due to the background concentration.
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year.
Table 37 Predicted concentrations of NO2 (μg/m3) for Irish Cement maximum
Annual mean Concentration (NO2) (μg/m3)
Concentration as % of AQS
Irish Cement 6.2 16%
Indaver 0.3 1%
SSE 0.2 1%
Sum of source contributions 6.8 17%
Annual mean background (measured by EPA in 2006) 5.7 14%
Total 12.5 31% ICP143.dat, Indaver (2007) and SSE (2007)
7.1.1.1 Proportions of NOx to NO2
In Section 7.1.1 above, the nitrogen dioxide (NO2) concentrations were calculated from the predicted NOx concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, the most conservative approach has been taken: a conversion factor of 1 has also been applied to the long-term average concentration due to the sum of the source contributions (UK EA, 2005).
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
J:\D5300-D5399\D5374\5) DESIGN\40\AQ\AIR DISPERSION MODELLING REPORT 2007_D5374-10_ISSUE3.DOC
Page 25 Arup Consulting EngineersIssue 3 20 December 2007
Table 38 Predicted concentrations of NO2 (μg/m3) for for Irish Cement maximum
Annual mean Concentration (NO2) (μg/m3)
Concentration as % of AQS
Sum of source contributions 13.6 34%
Annual mean background (measured by EPA in 2006) 5.7 14%
Total 19.3 48% ICP143.dat, Indaver (2007) and SSE (2007)
7.1.2 Predicted concentrations of 1-hour NO2 (μg/m3)
The maximum concentration due to Irish Cement is predicted to occur at (307180, 271658). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to Irish Cement is shown in Table 39.
The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO2 for the protection of human health of 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQS for NO2 is to be attained by 1 January 2010.
The cumulative impact of the maximum ground-level concentrations is predicted to be 56% of the AQS for 1-hour NO2.
As per the EPA’s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 62% of the AQS for 1-hour NO2. Of this, 56% is due to the source contributions and 6% is due to the background concentration.
The predicted concentrations comply with the AQS of 200μg/m³ over 1 hour.
Table 39 Predicted concentrations of NO2 (μg/m3) for Irish Cement maximum
99.79th %ile 1-hour Concentration (NO2) (μg/m3)
Concentration as % of AQS
Irish Cement 85.9 43%
Indaver 4.9 2%
SSE 21.4 11%
Sum of source contributions 112.2 56%
2 x Annual mean background (measured by EPA in 2006) 11.4 6%
Total 123.6 62% ICP143.dat, Indaver (2007) and SSE (2007)
7.1.3 Predicted concentrations of NOx (μg/m3)
The maximum concentration due to Irish Cement is predicted to occur at (307080, 272058). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to Irish Cement is shown in Table 40.
The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NOx for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NOx has been effective since 19 July 2001.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
J:\D5300-D5399\D5374\5) DESIGN\40\AQ\AIR DISPERSION MODELLING REPORT 2007_D5374-10_ISSUE3.DOC
Page 26 Arup Consulting EngineersIssue 3 20 December 2007
The cumulative impact of the maximum ground-level concentrations is predicted to be 71% of the AQS for annual NO2. Of this, 44% is due to the source contributions and 28% is due to the background concentration.
The predicted concentrations comply with the AQS of 30μg/m³ over 1 year.
Table 40 Predicted concentrations of NOx (μg/m3) for Irish Cement maximum
Annual mean Concentration (NOx) (μg/m3)
Concentration as % of AQS
Irish Cement 12.5 42%
Indaver 0.4 1%
SSE 0.2 1%
Sum of source contributions 13.1 44%
Annual mean background (measured by EPA in 2006) 8.3 28%
Total 21.4 71% ICP143.dat, Indaver (2007) and SSE (2007)
7.1.4 Predicted concentrations of annual mean PM10 (μg/m3)
The maximum concentration due to Irish Cement is predicted to occur at (307080, 271958). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to Irish Cement is shown in Table 41.
The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM10 for the protection of human health of 40μg/m³ over 1 year. The AQSs for PM10 have been effective from 1 January 2005.
The cumulative impact of the maximum ground-level concentrations is predicted to be 50% of the AQS for annual PM10. Of this, 12% is due to the source contributions and 38% is due to the background concentration.
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year.
Table 41 Predicted concentrations of PM10 (μg/m3) for Irish Cement maximum
Annual mean Concentration (PM10) (μg/m3)
Concentration as % of AQS
Irish Cement 4.5 11%
Indaver 0.1 <1%
SSE 0.1 <1%
Sum of source contributions 4.6 12%
Annual mean background (measured by EPA in 2006) 15.3 38%
Total 19.9 50% ICP149.dat, Indaver (2007) and SSE (2007)
7.1.5 Predicted concentrations of 24-hour PM10 (μg/m3)
The maximum concentration due to Irish Cement is predicted to occur at (307080, 271958). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to Irish Cement is shown in Table 42.
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The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM10 for the protection of human health of 50μg/m³ over 24 hours. The 24-hour AQS is not to be exceeded more than 35 times in a calendar year. The AQSs for PM10 have been effective from 1 January 2005.
The cumulative impact of the maximum ground-level concentrations is predicted to be 26% of the AQS for 24-hour PM10.
As per the EPA’s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 87% of the AQS for 24-hour PM10. Of this, 26% is due to the source contributions and 61% is due to the background concentration.
The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours.
Table 42 Predicted concentrations of PM10 (μg/m3) for Irish Cement maximum
90.41st %ile 24-hour Concentration (PM10) (μg/m3)
Concentration as % of AQS
Irish Cement 12.6 25%
Indaver 0.1 <1%
SSE 0.4 1%
Sum of source contributions 13.0 26%
2 x Annual mean background (measured by EPA in 2006) 30.6 61%
Total 43.6 87% ICP149.dat, Indaver (2007) and SSE (2007)
7.1.6 Comparison with the AQSs for particulate matter Stage 2 (2010)
The maximum ground-level concentrations due to the emissions under Scenario 6 are compared to the AQSs for PM10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002).
The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in 2006. The Irish AQS Regulations (2002) do not refer to PM2.5.
The cumulative impact of the maximum ground-level concentrations is predicted to be 94% of the AQS for annual PM10. Of this, 23% is due to the source contributions and 71% is due to the background concentration.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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Page 28 Arup Consulting EngineersIssue 3 20 December 2007
The predicted concentrations comply with the AQS of 20μg/m³ over 1 year.
Table 43 Predicted concentrations of PM10 (μg/m3) for Irish Cement maximum
Annual mean Concentration (PM10) (μg/m3)
Concentration as % of AQS
Irish Cement 4.5 22%
Indaver 0.1 <1%
SSE 0.1 <1%
Sum of source contributions 4.6 23%
Annual mean background (2010) 14.1 71%
Total 18.7 94% ICP149.dat, Indaver (2007) and SSE (2007)
The cumulative impact of the maximum ground-level concentrations is predicted to be 40% of the AQS for 24-hour PM10.
As per the EPA’s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 96% of the AQS for 24-hour PM10. Of this, 40% is due to the source contributions and 56% is due to the background concentration.
The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours.
Table 44 Predicted concentrations of PM10 (μg/m3) for Irish Cement maximum
98.08th%ile 24-hour Concentration (PM10) (μg/m3)
Concentration as % of AQS
Irish Cement 18.4 37%
Indaver 0.2 <1%
SSE 1.4 3%
Sum of source contributions 19.9 40%
2 x Annual mean background (2010) 28.2 56%
Total 48.1 96% ICP149.dat, Indaver (2007) and SSE (2007)
7.2 Location of Indaver maximum 7.2.1 Predicted concentrations of annual mean NO2 (μg/m3)
The maximum concentration due to Indaver is predicted to occur at (306950, 271050). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to Indaver is shown in Table 45.
The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO2 for the protection of human health of 40μg/m³ over 1 year. The AQS for NO2 is to be attained by 1 January 2010.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
J:\D5300-D5399\D5374\5) DESIGN\40\AQ\AIR DISPERSION MODELLING REPORT 2007_D5374-10_ISSUE3.DOC
Page 29 Arup Consulting EngineersIssue 3 20 December 2007
The cumulative impact of the maximum ground-level concentrations is predicted to be 22% of the AQS for annual NO2. Of this, 7% is due to the source contributions and 14% is due to the background concentration.
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year.
Table 45 Predicted concentrations of NO2 (μg/m3) for Indaver maximum
Annual mean Concentration (NO2) (μg/m3)
Concentration as % of AQS
Irish Cement 1.6 4%
Indaver 1.1 3%
SSE 0.2 0%
Sum of source contributions 2.9 7%
Annual mean background (measured by EPA in 2006) 5.7 14%
Total 8.6 22% ICP143.dat, Indaver (2007) and SSE (2007)
7.2.1.1 Proportions of NOx to NO2
In Section 7.1.1 above, the nitrogen dioxide (NO2) concentrations were calculated from the predicted NOx concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, the most conservative approach has been taken: a conversion factor of 1 has also been applied to the long-term average concentration due to the sum of the source contributions (UK EA, 2005).
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year.
Table 46 Predicted concentrations of NO2 (μg/m3) for for Irish Cement maximum
Annual mean Concentration (NO2) (μg/m3)
Concentration as % of AQS
Sum of source contributions 5.8 15%
Annual mean background (measured by EPA in 2006) 5.7 14%
Total 11.5 29% ICP143.dat, Indaver (2007) and SSE (2007)
7.2.2 Predicted concentrations of 1-hour NO2 (μg/m3)
The maximum concentration due to Irish Cement is predicted to occur at (307180, 271658). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to Irish Cement is shown in Table 47.
The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO2 for the protection of human health of 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQS for NO2 is to be attained by 1 January 2010.
The cumulative impact of the maximum ground-level concentrations is predicted to be 39% of the AQS for 1-hour NO2.
As per the EPA’s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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Page 30 Arup Consulting EngineersIssue 3 20 December 2007
maximum ground-level concentrations is predicted to be 45% of the AQS for 1-hour NO2. Of this, 39% is due to the source contributions and 6% is due to the background concentration.
The predicted concentrations comply with the AQS of 200μg/m³ over 1 hour.
Table 47 Predicted concentrations of NO2 (μg/m3) for Indaver maximum
99.79th %ile 1-hour Concentration (NO2) (μg/m3)
Concentration as % of AQS
Irish Cement 40.6 20%
Indaver 19.0 10%
SSE 18.0 9%
Sum of source contributions 77.7 39%
2 x Annual mean background (measured by EPA in 2006) 11.4 6%
Total 89.1 45% ICP143.dat, Indaver (2007) and SSE (2007)
7.2.3 Predicted concentrations of NOx (μg/m3)
The maximum concentration due to Indaver is predicted to occur at (306950, 271050). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to Indaver is shown in Table 48.
The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NOx for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NOx has been effective since 19 July 2001.
The cumulative impact of the maximum ground-level concentrations is predicted to be 44% of the AQS for annual NO2. Of this, 16% is due to the source contributions and 28% is due to the background concentration.
The predicted concentrations comply with the AQS of 30μg/m³ over 1 year.
Table 48 Predicted concentrations of NOx (μg/m3) for Indaver maximum
Annual mean Concentration (NOx) (μg/m3)
Concentration as % of AQS
Irish Cement 3.3 11%
Indaver 1.5 5%
SSE 0.2 1%
Sum of source contributions 4.9 16%
Annual mean background (measured by EPA in 2006) 8.3 28%
Total 13.3 44% ICP143.dat, Indaver (2007) and SSE (2007)
7.2.4 Predicted concentrations of annual mean PM10 (μg/m3)
The maximum concentration due to Indaver is predicted to occur at (306950, 271050). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to Indaver is shown in Table 49.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
J:\D5300-D5399\D5374\5) DESIGN\40\AQ\AIR DISPERSION MODELLING REPORT 2007_D5374-10_ISSUE3.DOC
Page 31 Arup Consulting EngineersIssue 3 20 December 2007
The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM10 for the protection of human health of 40μg/m³ over 1 year. The AQSs for PM10 have been effective from 1 January 2005.
The cumulative impact of the maximum ground-level concentrations is predicted to be 40% of the AQS for annual PM10. Of this, 2% is due to the source contributions and 38% is due to the background concentration.
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year.
Table 49 Predicted concentrations of PM10 (μg/m3) for Indaver maximum
Annual mean Concentration (PM10) (μg/m3)
Concentration as % of AQS
Irish Cement 0.5 1%
Indaver 0.1 <1%
SSE 0.1 <1%
Sum of source contributions 0.6 2%
Annual mean background (measured by EPA in 2006) 15.3 38%
Total 15.9 40% ICP149.dat, Indaver (2007) and SSE (2007)
7.2.5 Predicted concentrations of 24-hour PM10 (μg/m3)
The maximum concentration due to Indaver is predicted to occur at (306950, 271100). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to Indaver is shown in Table 50.
The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM10 for the protection of human health of 50μg/m³ over 24 hours. The 24-hour AQS is not to be exceeded more than 35 times in a calendar year. The AQSs for PM10 have been effective from 1 January 2005.
The cumulative impact of the maximum ground-level concentrations is predicted to be 4% of the AQS for 24-hour PM10.
As per the EPA’s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 66% of the AQS for annual PM10. Of this, 4% is due to the source contributions and 61% is due to the background concentration.
The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours.
Table 50 Predicted concentrations of PM10 (μg/m3) for Indaver maximum
90.41st %ile 24-hour Concentration (PM10) (μg/m3)
Concentration as % of AQS
Irish Cement 1.9 4%
Indaver 0.2 <1%
SSE 0.2 <1%
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Page 32 Arup Consulting EngineersIssue 3 20 December 2007
Sum of source contributions 2.2 4%
2 x Annual mean background (measured by EPA in 2006) 30.6 61%
Total 32.8 66% ICP149.dat, Indaver (2007) and SSE (2007)
7.2.6 Comparison with the AQSs for particulate matter Stage 2 (2010)
The maximum ground-level concentrations due to the emissions under Scenario 6 are compared to the AQSs for PM10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002).
The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in 2006. The Irish AQS Regulations (2002) do not refer to PM2.5.
The cumulative impact of the maximum ground-level concentrations is predicted to be 74% of the AQS for annual PM10. Of this, 3% is due to the source contributions and 71% is due to the background concentration.
The predicted concentrations comply with the AQS of 20μg/m³ over 1 year.
Table 51 Predicted concentrations of PM10 (μg/m3) for Indaver maximum
Annual mean Concentration (PM10) (μg/m3)
Concentration as % of AQS
Irish Cement 0.5 2%
Indaver 0.1 <1%
SSE 0.1 <1%
Sum of source contributions 0.6 3%
Annual mean background (2010) 14.1 71%
Total 14.7 74% ICP149.dat, Indaver (2007) and SSE (2007)
The cumulative impact of the maximum ground-level concentrations is predicted to be 10% of the AQS for 24-hour PM10.
As per the EPA’s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 67% of the AQS for 24-hour PM10. Of this, 10% is due to the source contributions and 56% is due to the background concentration.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
J:\D5300-D5399\D5374\5) DESIGN\40\AQ\AIR DISPERSION MODELLING REPORT 2007_D5374-10_ISSUE3.DOC
Page 33 Arup Consulting EngineersIssue 3 20 December 2007
The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours.
Table 52 Predicted concentrations of PM10 (μg/m3) for Indaver maximum
98.08th%ile 24-hour Concentration (PM10) (μg/m3)
Concentration as % of AQS
Irish Cement 4.1 8%
Indaver 0.4 1%
SSE 0.7 1%
Sum of source contributions 5.2 10%
2 x Annual mean background (2010) 28.2 56%
Total 33.4 67% ICP149.dat, Indaver (2007) and SSE (2007)
7.3 Location of SSE maximum 7.3.1 Predicted concentrations of annual mean NO2 (μg/m3)
The maximum concentration due to SSE is predicted to occur at (307480, 271358). The maximum concentration due to Irish Cement Platin, Indaver and SSE at the location of the maximum concentration due to SSE is shown in Table 53.
The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO2 for the protection of human health of 40μg/m³ over 1 year. The AQS for NO2 is to be attained by 1 January 2010.
The cumulative impact of the maximum ground-level concentrations is predicted to be 23% of the AQS for annual NO2. Of this, 9% is due to the source contributions and 14% is due to the background concentration.
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year.
Table 53 Predicted concentrations of NO2 (μg/m3) for SSE maximum
Annual mean Concentration (NO2) (μg/m3)
Concentration as % of AQS
Irish Cement 2.1 5%
Indaver 0.7 2%
SSE 0.7 2%
Sum of source contributions 3.4 9%
Annual mean background (measured by EPA in 2006) 5.7 14%
Total 9.1 23% ICP143.dat, Indaver (2007) and SSE (2007)
7.3.1.1 Proportions of NOx to NO2
In Section 7.1.1 above, the nitrogen dioxide (NO2) concentrations were calculated from the predicted NOx concentrations using a conversion factor of 0.5 as advised by the EPA (2004). Following consultation with the EPA, the most conservative approach has been taken: a
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Page 34 Arup Consulting EngineersIssue 3 20 December 2007
conversion factor of 1 has also been applied to the long-term average concentration due to the sum of the source contributions (UK EA, 2005).
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year.
Table 54 Predicted concentrations of NO2 (μg/m3) for for Irish Cement maximum
Annual mean Concentration (NO2) (μg/m3)
Concentration as % of AQS
Sum of source contributions 6.8 17%
Annual mean background (measured by EPA in 2006) 5.7 14%
Total 12.5 31% ICP143.dat, Indaver (2007) and SSE (2007)
7.3.2 Predicted concentrations of 1-hour NO2 (μg/m3)
The maximum concentration due to SSE is predicted to occur at (308280, 271358). The maximum concentration due to Irish Cement Platin, Indaver and SSE at the location of the maximum concentration due to SSE is shown in Table 55.
The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NO2 for the protection of human health of 200μg/m³ over 1 hour. The hourly AQS is not to be exceeded more than 18 times in a calendar year. The AQS for NO2 is to be attained by 1 January 2010.
The cumulative impact of the maximum ground-level concentrations is predicted to be 41% of the AQS for 1-hour NO2.
As per the EPA’s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 46% of the AQS for 1-hour NO2. Of this, 41% is due to the source contributions and 6% is due to the background concentration.
The predicted concentrations comply with the AQS of 200μg/m³ over 1 hour.
Table 55 Predicted concentrations of NO2 (μg/m3) for SSE maximum
99.79th %ile 1-hour Concentration (NO2) (μg/m3)
Concentration as % of AQS
Irish Cement 46.6 23%
Indaver 3.3 2%
SSE 31.3 16%
Sum of source contributions 81.2 41%
2 x Annual mean background (measured by EPA in 2006) 11.4 6%
Total 92.6 46% ICP143.dat, Indaver (2007) and SSE (2007)
7.3.3 Predicted concentrations of NOx (μg/m3)
The maximum concentration due to SSE is predicted to occur at (307480, 271358). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to SSE is shown in Table 56.
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Irish Cement Irish Cement Platin IPPC Licence ApplicationAir Quality Modelling of NOx and PM (2007)
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Page 35 Arup Consulting EngineersIssue 3 20 December 2007
The maximum ground-level concentrations under Scenario 5 are compared to the AQS for NOx for the protection of vegetation of 30μg/m³ over 1 year. The AQS for NOx has been effective since 19 July 2001.
The cumulative impact of the maximum ground-level concentrations is predicted to be 47% of the AQS for annual NO2. Of this, 19% is due to the source contributions and 28% is due to the background concentration.
The predicted concentrations comply with the AQS of 30μg/m³ over 1 year.
Table 56 Predicted concentrations of NOx (μg/m3) for SSE maximum
Annual mean Concentration (NOx) (μg/m3)
Concentration as % of AQS
Irish Cement 4.1 14%
Indaver 0.9 3%
SSE 0.7 2%
Sum of source contributions 5.7 19%
Annual mean background (measured by EPA in 2006) 8.3 28%
Total 14.0 47% ICP143.dat, Indaver (2007) and SSE (2007)
7.3.4 Predicted concentrations of annual mean PM10 (μg/m3)
The maximum concentration due to SSE is predicted to occur at (307480, 271358). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to SSE is shown in Table 57.
The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM10 for the protection of human health of 40μg/m³ over 1 year. The AQSs for PM10 have been effective from 1 January 2005.
The cumulative impact of the maximum ground-level concentrations is predicted to be 42% of the AQS for annual PM10. Of this, 3% is due to the source contributions and 38% is due to the background concentration.
The predicted concentrations comply with the AQS of 40μg/m³ over 1 year.
Table 57 Predicted concentrations of PM10 (μg/m3) for SSE maximum
Annual mean Concentration (PM10) (μg/m3)
Concentration as % of AQS
Irish Cement 0.8 2%
Indaver 0.0 <1%
SSE 0.5 1%
Sum of source contributions 1.3 3%
Annual mean background (measured by EPA in 2006) 15.3 38%
Total 16.6 42% ICP149.dat, Indaver (2007) and SSE (2007)
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Page 36 Arup Consulting EngineersIssue 3 20 December 2007
7.3.5 Predicted concentrations of 24-hour PM10 (μg/m3)
The maximum concentration due to SSE is predicted to occur at (308180, 271058). The maximum concentration due to Irish Cement Platin, Indaver and SSE in the vicinity of the maximum concentration due to SSE is shown in Table 58.
The maximum ground-level concentrations under Scenario 6 are compared to the AQS for PM10 for the protection of human health of 50μg/m³ over 24 hours. The 24-hour AQS is not to be exceeded more than 35 times in a calendar year. The AQSs for PM10 have been effective from 1 January 2005.
The predicted concentration due to Indaver at the location of the maximum concentration due to SSE was not known. Therefore it was assumed to be the same as the maximum concentration due to Indaver, which is a conservative assumption.
The cumulative impact of the maximum ground-level concentrations is predicted to be 6% of the AQS for 24-hour PM10.
As per the EPA’s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 68% of the AQS for annual PM10. Of this, 6% is due to the source contributions and 61% is due to the background concentration.
The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours.
Table 58 Predicted concentrations of PM10 (μg/m3) for SSE maximum
90.41st %ile 24-hour Concentration (PM10) (μg/m3)
Concentration as % of AQS
Irish Cement 1.5 3%
Indaver (assumed to be maximum) 0.2 <1%
SSE 1.5 3%
Sum of source contributions 3.2 6%
2 x Annual mean background (measured by EPA in 2006) 30.6 61%
Total 33.8 68% ICP149.dat, Indaver (2007) and SSE (2007)
7.3.6 Comparison with the AQSs for particulate matter Stage 2 (2010)
The maximum ground-level concentrations due to the emissions under Scenario 6 are compared to the AQSs for PM10 for the protection of human health of 20μg/m³ over 1 year and 50μg/m³ over 24 hours (Schedule 3 of Irish AQS Regulations, 2002). The 24-hour AQS is not to be exceeded more than 7 times in a calendar year. The AQSs for PM10 will be effective from 1 January 2010 (Article 7(4) of Irish AQS Regulations, 2002).
The UK DEFRA Year Adjustment Calculator was used to predict concentrations for the year 2010 from the concentrations measured by the EPA in 2006. The Irish AQS Regulations (2002) do not refer to PM2.5.
The cumulative impact of the maximum ground-level concentrations is predicted to be 77% of the AQS for annual PM10. Of this, 7% is due to the source contributions and 71% is due to the background concentration.
The predicted concentrations comply with the AQS of 20μg/m³ over 1 year.
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Page 37 Arup Consulting EngineersIssue 3 20 December 2007
Table 59 Predicted concentrations of PM10 (μg/m3) for SSE maximum
Annual mean Concentration (PM10) (μg/m3)
Concentration as % of AQS
Irish Cement 0.8 4%
Indaver 0.0 <1%
SSE 0.5 3%
Sum of source contributions 1.3 7%
Annual mean background (2010) 14.1 71%
Total 15.4 77% ICP149.dat, Indaver (2007) and SSE (2007)
The cumulative impact of the maximum ground-level concentrations is predicted to be 19% of the AQS for 24-hour PM10.
As per the EPA’s RFI and clarification, a short-term background concentration has been included in the cumulative impact assessment, of twice the long-term background concentration. Including this background concentration, the cumulative impact of the maximum ground-level concentrations is predicted to be 75% of the AQS for 24-hour PM10. Of this, 19% is due to the source contributions and 56% is due to the background concentration.
The predicted concentrations comply with the AQS of 50μg/m³ over 24 hours.
Table 60 Predicted concentrations of PM10 (μg/m3) for SSE maximum
98.08th%ile 24-hour Concentration (PM10) (μg/m3)
Concentration as % of AQS
Irish Cement 6.0 12%
Indaver 0.2 <1%
SSE 3.1 6%
Sum of source contributions 9.3 19%
2 x Annual mean background (2010) 28.2 56%
Total 37.5 75% ICP149.dat, Indaver (2007) and SSE (2007)
8. CONCLUSIONS This report has been prepared for the response to the RFI following clarification from the EPA as to their exact requirements. It supersedes the air quality modelling included in the EIS and the IPPC Licence Application.
8.1 Scenarios 1 to 6 The concentrations of atmospheric pollutants predicted for Scenarios 1, 3 and 5 comply with the AQSs for NO2 for the protection of human health of 40μg/m³ over 1 year (including background concentrations) and 200μg/m³ over 1 hour.
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Page 38 Arup Consulting EngineersIssue 3 20 December 2007
The concentrations of atmospheric pollutants predicted for Scenarios 1, 3 and 5 comply with the AQS for NOx for the protection of vegetation of 30μg/m³ over 1 year (including background concentrations).
The concentrations of atmospheric pollutants predicted for Scenarios 2, 4 and 6 comply with the Stage 1 AQSs for PM10 for the protection of human health of 40μg/m³ over 1 year (including background concentrations) and 50μg/m³ over 24 hours.
The concentrations of atmospheric pollutants predicted for Scenarios 2, 4 and 6 comply with the Stage 2 AQSs for PM10 for the protection of human health of 20μg/m³ over 1 year (including background concentrations) and 50μg/m³ over 24 hours.
8.2 Cumulative Impact Assessment The cumulative impact assessment shows that the predicted concentrations due to Irish Cement, Indaver and SSE comply with the AQSs for NO2 for the protection of human health of 40μg/m³ over 1 year (including background concentrations) and 200μg/m³ over 1 hour.
The cumulative impact assessment shows that the predicted concentrations due to Irish Cement, Indaver and SSE comply with the AQSs for NOx for the protection of vegetation of 30μg/m³ over 1 year (including background concentrations).
The cumulative impact assessment shows that the predicted concentrations due to Irish Cement, Indaver and SSE comply with the Stage 1 AQSs for PM10 for the protection of human health of 40μg/m³ over 1 year (including background concentrations) and 50μg/m³ over 24 hours.
The cumulative impact assessment shows that the predicted concentrations due to Irish Cement, Indaver and SSE comply with the Stage 2 AQSs for PM10 for the protection of human health of 20μg/m³ over 1 year (including background concentrations) and 50μg/m³ over 24 hours.
8.3 EPA RFI As requested by the EPA, the impact of using a more conservative NOx to NO2 conversion of 100% for predicting the annual concentration has been assessed. The predicted concentrations comply with the Irish Air Quality Standards (AQSs) Regulations (2002).
As requested by the EPA, the short-term background concentration was taken to be twice the long-term (annual mean) background concentration in the revised air quality modelling report. This follows the UK EA (2002) guidance, “IPPC H1 Integrated Pollution Prevention and Control (IPPC). Environmental Assessment and Appraisal of BAT”. There is no equivalent Irish methodology or EPA guidance. The predicted concentrations comply with the Irish Air Quality Standards (AQSs) Regulations (2002).
As requested by the EPA, the cumulative impact has been reassessed as requested to include the cumulative impact (annual averages and short term) of the existing and proposed Irish Cement emissions and those associated with Indaver and SSE.
The planning permission for the SSE facility has lapsed and ICL has been advised by consultants to SSE (2007) that they are not proceeding with this development. Since the planning permission for the SSE facility has lapsed that development cannot proceed without a further grant of planning permission. Nevertheless the predicted concentrations due to the SSE 400MW facility have been included in the cumulative impact assessment, as provided in December 2007 by SSE through their air dispersion modelling consultants.
The most recent data for the Indaver facility has been used, as provided in December 2007 by Indaver through their air dispersion modelling consultants.
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Page 39 Arup Consulting EngineersIssue 3 20 December 2007
The predicted concentrations comply with the Irish Air Quality Standards (AQSs) Regulations (2002).
8.4 Summary The methodology applies highly conservative assumptions and shows that the predicted concentrations comply with the Irish Air Quality Standards (AQSs) Regulations (2002).
9. REFERENCES CEC Commission of the European Communities (2005) “Proposal for a Directive of the European Parliament and of the Council on ambient air quality and cleaner air for Europe”, COM2005 447 (Provisional Version), 2005/0183 (COD), Brussels 21/09/2005.
EC (European Commission) (2004) “Second Position Paper on Particulate Matter – Final”.
EPA (2004) Personal communication (D4265.11)
EPA (2006) Jennings, S.G. et al. “Air Pollution – Nature and Origin of PM10 and Smaller Particulate Matter in Urban Air (2000-LS-6.1-M1)”, Environmental Protection Agency, PO Box 3000, Johnstown Castle, Co Wexford.
EPA (2007) “Air Quality in Ireland 2006”.
Indaver (2007) Personal communication with AWN (Edward Porter), December 2007.
SSE (2007) Personal communication with PMG (Niall O’Loughlin), December 2007.
UK EA (Environment Agency) (2002) “IPPC H1 Integrated Pollution Prevention and Control (IPPC). Environmental Assessment and Appraisal of BAT”, UK EA, Scottish Environment Protection Agency (SEPA), Northern Ireland Environment and Heritage Service (NI EHS).
UK EA (2005) “Conversion ratios for NOx and NO2”, http://www.environment-agency.gov.uk/commondata/acrobat/noxno2conv2005_1233043.pdf, viewed 4.xii.2007.
US EPA (2005) “Appendix W to Part 51—Guideline on Air Quality Models. Part 51, chapter I, title 40 of the Code of Federal Regulations. 40 CFR Part 51 Revision to the Guideline on Air Quality Models: Adoption of a Preferred General Purpose (Flat and Complex Terrain) Dispersion Model and Other Revisions; Final Rule”.
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FIGURES
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Arup Consulting EngineersIssue 3 20 December 2007
Figure 1 Isopleths of predicted annual mean NO2: Scenario 1
Figure 2 Isopleths of predicted annual mean PM10: Scenario 2
Figure 3 Isopleths of predicted annual mean NO2: Scenario 3
Figure 4 Isopleths of predicted annual mean PM10: Scenario 4
Figure 5 Isopleths of predicted annual mean NO2: Scenario 5
Figure 6 Isopleths of predicted annual mean PM10: Scenario 6
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Isopleths of Annual Mean NO2 : Scenario 1
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Isopleths of Annual Mean PM10 : Scenario 2
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Isopleths of Annual Mean NO2 : Scenario 3
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Isopleths of Annual Mean PM10 : Scenario 4
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Isopleths of Annual Mean NO2 : Scenario 5
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Isopleths of Annual Mean PM10 : Scenario 6
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51
APPENDIX IV
Air emissions modelling: input and output files
and meteorological data
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![INDEX [] · In Case of Notified Industrial area, a copy of the Gazette Notification 19 (v) Existing Infrastructure 20 ... ILC In Line Calciner KLD Kilo Littre Per Day KM Kilo Metre](https://img.pdfslide.us/doc/110x75/5e7a09036982b0386e6121c4/index-in-case-of-notified-industrial-area-a-copy-of-the-gazette-notification.jpg)
