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An Gnoiomhornorhl urn Olaomlnl Comhshooil , 7 This Report has been cleared for submission to the Board by the Programme Manager P. Nolan Signed: &fq Date: ds/b/O8 LIC -m--...- H RESOURCE USE R /I To: Directors A ENVIRONMENTAL LICENSING PROGRAMME 1 From: Ann Marie Donlon Date: 16TH JUNE 2008 RE: Application for review of an IPPC Licence from Irish Cement Limited, Licence Register POO29-02 11 .I The recovery or disposal of waste in a facility, within the meaning of the Waste Management Act, 1996, which facility is connected or associated with another activity specified in this Schedule in respect of which a licence or revised licence under Part IV is in force or in respect of which a licence under the said Part is or will be Castlemungret, Co. Limerick 29/08/2007, 11/12/2007 09111/2007, 07/03/2008 1. Company Irish Cement Limited (ICL) has been producing cement at its site in Castlemungret, Co. Limerick since 1938. The site comprises of a limestone open cast quarry, the cement works Last Update: December 2006 1

From: PROGRAMME - Environmental Protection Agency · the Programme Manager P. Nolan ... A selective non-catalytic reduction ... However the limits are subject to review of the Reference

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An Gnoiomhornorhl urn Olaomlnl Comhshooil

,, 7

This Report has been cleared for submission to the Board by the Programme Manager P. Nolan Signed: &fq Date: ds/b/O8

LIC - m - - . . . - H

RESOURCE USE

R /I To: Directors

A ENVIRONMENTAL LICENSING PROGRAMME 1 From: Ann Marie Donlon

Date: 16TH JUNE 2008

RE: Application for review of an IPPC Licence from Irish Cement Limited, Licence Register POO29-02

11 .I The recovery or disposal of waste in a facility, within the meaning of the Waste Management Act, 1996, which facility is connected or associated with another activity specified in this Schedule in respect of which a licence or revised licence under Part IV is in force or in respect of which a licence under the said Part is or will be

Castlemungret, Co. Limerick

29/08/2007, 1 1/12/2007

0911 1/2007, 07/03/2008

1. Company Irish Cement Limited (ICL) has been producing cement at its site in Castlemungret, Co. Limerick since 1938. The site comprises of a limestone open cast quarry, the cement works

Last Update: December 2006 1

and the Bunlicky clayfield pond (the landfill: class 11.1) and occupies an area in excess of 346 hectares.

The village of Mungret lies close to the southern site boundary, the river Shannon lies to the north and the centre of Limerick City is within 5 km. The Limerick Southern Ring Road is currently being constructed through Bunlicky pond. Bunlicky pond has been divided in half by this road, however the pond remains hydraulically linked across the road by culverts. The company employ between 150 - 170 employees and operate on a 24 hours, 7 days basis.

Cement works infrastructure includes a rotating kiln, mills and storage silos. The production capacity of the rotary kiln is 3,218 tonnes per day cement clinker. Inert waste is disposed to the on-site landfill. Asbestos waste disposal to the on-site landfill has ceased and the cells are to be removed and disposed to a licensed landfill.

The company has put in place an Environmental Management System with an Environmental Management Programme.

Planning permission was granted in 2005 for an additional kiln and associated works. Irish Cement Limited has no current plans to increase the installation capacity. The licensee applied for planning permission in February 2008 for the provision of an additional clinker silo, cement silo, transfer station and associated conveyors. An Environmental Impact Statement (EIS) was submitted with the planning application and accompanied this review application in March 2008. Planning permission was granted for the additional infrastructure in May 2008.

An IPC licence was first granted on 19/05/96. This review is for the purposes of compliance with the IPPC Directive (1 996/6 l/EC) and the changes to Class 1 1 of the EPA Act.

2. Process Description Limestone is quarried and crushed at the installation.

Cement production involves three stages:

Rawmilling: Limestone, shale, iron ore, pulverised fly ash are milled into a finely ground, dry and intimately mixed material known as rawmeal. Kiln exhaust gases are used for drying the mixture. The rawmeal is stored in silos.

Cement clinker: The rawmeal is mixed with fuel (oil or petroleum coke) and charged to, a horizontal inclined rotating kiln. Fuel is added at both ends and petroleum coke is milled prior to use. The heat develops a chemical reaction necessary to produce cement clinker. Evaporation and partial calcination of the rawmeal occurs in the preheater to the kiln. Calcination process is completed as the material travels down the rotary luln where clinker minerals occur at 1500°C. The rotary kiln comprises of refractory materials that are replaced annually. The clinker is cooled by passing through planetary coolers attached to the end of the kdn.

Cement millinp: Clinker and gypsum (with the assistance of grinding aids) are ground into a fine powder. Tin sulphate and ferrous sulphate are added to the final product as chrome reducing agents. The cement product is stored in silos prior to dispatch. Cement is dispatched either in bulk or 25kg bags via road or rail.

Blasting, noise and dust is associated with the quarry activities. The cement works generates air borne dusts and exhaust gases from the kiln. Water from the quarry is used as cooling water for various process plant. The landfilling of inert materials to Bunlicky Pond is undertaken twice yearly.

Last Update: December 2006 2

. . . . . . . . . . . . . . .. -- - .

3. Compliance with Directives/Regulations IPPC Directive: This installation falls within the scope of category 3.1 (Installations for the production of cement clinker in rotary kilns with a production capacity exceeding 500 tonnes per day or lime in rotary kilns with a production capacity exceeding 50 tonnes per day or in other furnaces with a production capacity exceeding 50 tonnes per day). Emissions Trading: EC (Greenhouse Gas Emissions Trading) Regulations, 2004 applies to this installation. Landfill Directive (1999/3 I/EC): The on-site landfill falls within the scope of this Directive and has been classified as a landfill for inert waste.

4. Scope The licensee proposes to reduce the extent of the installation from that covered under the existing licence to exclude the land sold for the Limerick Southern Ring Road and other agricultural land located to the east of the cement works, Bunliclq Pond is not proposed for exclusion. The Office of Environmental Enforcement approved the exclusion under the requirements of Condition 14 (Closure, Restoration and Aftercare) of the existing licence. The Recommended Determination (RD) specifies the extent of the installation to this new site boundary.

5. Use of Resources Cement clinker is produced from natural resources of limestone and shale. The company is currently moving to the production of CEMII cements where limestone is used as a constituent of cement (as well as clinker and gypsum) and therefore less carbon dioxide per tonne of cement is produced. Another cement product using pulverised fly ash (PFA) as a constituent of cement is also under consideration. The PFA is sourced from Moneypoint power station and this material will redirect waste from landfill as well as reducing the use of natural resources. The PFA is defined in cement standard I.S. E.N. 197-1:2001 and has a product standard under I.S. EN450-1:2005. In these circumstances the use of PFA in cement manufacture is not regarded as a waste recovery activity.

The main energy efficiency consideration taken by the company is the use of the dry cement process, which uses 40% less fuel than the wet cement process. Grinding aids are employed to improve milling efficiency. Separators have been installed on the raw and cement mills to improve grinding efficiency.

Kiln exhaust gases are used for drying in the rawmilling operation.

Fuel: Approximately 1,350 tonnes of light fuel oil and diesel and 95,000 tonnes of petroleum coke are consumed per year.

Electricity: electrical demand for the site is 25MW.

Materials: The raw materials used that carry the risk phrase of 52, 53, or 51/53 are light fuel oil and diesel (1 38 tonnes stored on-site). Water consumption is approximately 41,500m3 per year and predominately used for cooling.

6. Emissions 6.1Air The main emission to air is from the kiln. Ten percent of the off-gases from the kiln are directed to the coal mill to maintain an inert atmosphere. Kiln off-gases contain particulates, sulphur dioxide and nitrogen oxides. Sulphur dioxide emissions are not significant as they are scrubbed from the gases due to the alkaline environment in the kiln. Sulphur dioxide emissions are reported to be 10 ppm (28.57mg/m3). The RD specifies an emission limit value (ELV) of 200mg/m3 SOz in line with the draft BAT guidance Note (August, 2007).

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I

Emissions are currently abated using an electrostatic precipitator (ESP) or a bag filter in the case of the coal mill. It is proposed to install a bag filter (to replace the ESP) and a selective non-catalytic reduction (SNCR) system to reduce NO, emissions.

1 2

SNCR and NO, A selective non-catalytic reduction (SNCR) system is in the process of being commissioned

Interpretation sought Rationale 30 minute mean > 2 x ELV 30 minute mean > 2 x ELV

New limit of 800mg/m3N0,. Due to start-up/shut-down of kiln.

to reduce nitrogen oxide emissions (by reaction with ammonia to form nitrogen gas and water).

Ammonia is injected into the riser duct (preheater) after the kiln under programmable logic control (PLC). The critical parameter is temperature (800-1000°C). At low temperatures, ammonia slip may occur and at high temperature the ammonia is oxidised. A reduction rate of 50% in nitrogen oxides is being targeted. No performance data is available to date. The company hold the view that 800mg/m3NOx as NOz can be achieved with SNCR and do not accept the 200-500mg/m3 BAT associated limit value specified in the draft BAT Note August 2007. The BAT associated limits have been revised in the final draft of the BAT Note to 200- 800mg/m3. However the limits are subject to review of the Reference Document on BAT in the Cement and Lime Industries, 2001 (the BREF document). The BREF document identifies BAT as reduction efficiencies of 60%. The RD specifies an ELV of 800 mg/m3 NO, and requires SNCR reduction efficiencies of 60% to be an objective of the EMP.

The company requests a limit of 1000mg/m3 for the first six months of commissioning. An air dispersion model of nitrogen oxide emissions of 1 000mg/m3 was undertaken and the results of the model indicate that air quality standards will be observed (Table 2). A conversion factor of 0.5 was used for the predicted nitrogen dioxide ground level concentrations. It was proposed to commission the SNCR in November/December 2007 and therefore a higher limit for six months is not justified. The ELV is specified as 800mg/m3 for NO, and this will reduce the predicted impact by approximately 20%.

' 95% of daily values shall not exceed the

The licensee requests the following in relation to the interpretation of ELV's for the Kiln: Table1 : Requested interpretation

Current licence requirement.

4

5

13 I ELV Appropriate to cement plants.

A statistical approach is also appropriate to 30 minute mean values Continue kiln operation in steady state operation rather than shutdown while fault is being rectified as careful management will ensure compliance with daily ELV and 30 minute mean will comply with 2 x ELV.

SNCR 50% NO, reduction. --

SNCR off-line due to fault.

The interpretation in the RD is as follows:

4.1.1 Continuous Monitoring , (i) No 24 hour mean value shall exceed the emission limit value.

97% of all 30 minute mean values taken continuously over an annual period (excluding start-up and shutdown of kiln) shall not exceed 1.2 times the emission limit value. No 30 minute mean value shall exceed twice the emission limit value.

(ii)

(iii) With regard to points 1 and 2:

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The ELVs applies to stable kiln operation and do not apply during start-up and shutdown. The interpretation of results in the RD makes this clear. Operating close to process set points is not only a BAT requirement but will not likely give rise to wide ranging emissions. The RD requires the recording of start-ups and shutdown periods.

With regard to points 3 and 4:

Monitoring indicates that all daily averages were within the ELV and a statistical approach is not warranted nor does the draft BAT guidance note provide for it.

With regard to point 5:

It is reasonable to continue kiln operation while the SNCR is being repaired and the RD provides the scope. The RD requires that 97% of 30 minute mean values shall not exceed 1.2 times the ELV and therefore the licence limits the frequency to SNCR off line to 3% of the time.

Further, such interpretation of emissions monitoring has already been applied to cement producer licences register number PO487-04, PO378-01 and POO30-02.

Parameter

Nitrogen Oxides (asN02)

Modelled Predicted Background Air impact GLC Crg/m3 Quality

Pdm3 Standard pg/m3 200 Note 1: 99.79%ile 123.9 33-67

hourly 1 hourmax 221.5 N/a

Nitrogen Oxides (asNO,) Particulates

Last Update: December 2006 5

40 Note 1:

30 Note 1:

Annual 5.2 5.7 Annual 10.4 8.3

90.41%ile 24 15.4 50 Note 1:

(PM 10) hour

24-hour max I I I I 40120 Note 1: I Annual I 5.4 I 15.3

44.9 N/a

Particulates (PM 2.5)

The replacement of the kiln ESP with a bag filter will further reduce particulate emissions and the predicted impact. The Irish air quality standards (S.I. No. 271 of 2002) for particulate matter are set to reduce under Stage 2 (2010) and it is not clear from the assessment whether the 24 hour PMlo limit value will be observed. It should be noted that this reducing air quality standard is not specified in the proposed Air Quality Directive (CEC 2005). Given the uncertainty in relation to air quality standards from 20 10 onwards the RD requires, ambient PMlo monitoring at the location predicted to have the highest ground level concentration in the model.

Only the luln and cement mill separator No. 7 are monitored continuously for particulates. The RD requires continuous monitoring of particulate emissions from Mills and Separators within three months of date of grant of licence in line with BAT requirements.

25 Note2 , Annual 3.2 9.2 concentration

There are 47 other emission points fitted with bag filters around the installation and these are regarded by the licensee as minor emission points. There are 6 proposed new emissions points associated with the new silos and these emissions are also regarded as minor. These emission points include hoppers, conveyors and silos fitted with filters to abate particulates. The existing licence specifies an ELV of 50mg/m3 for these points but does not require monitoring. The air dispersion model assessment did not consider these emission points as the licensee did not deem them to be significant.

Twenty four of the 53 points (existing and proposed) have flowrates in excess of 10,000m3/hr. The licensee has assessed 12 of these points and dusts emissions are less than 10mg/m3 (1 to 4mg/m3). The current ELV for each point is 50mg/m3, which equates to emission load of 33kg/hr. At this level the particulate emissions from the installation would almost double the loading considered by the dispersion model. The licensee states that the low particulate results confirm their position as to the minor nature of these points. The RD specifies an ELV of 10mg/m3 (6 kg/hr) particulate and requires an annual survey of emissions in line with BAT requirements.

Dust Quarry and landfilling activities are area sources of particulate/dust emissions and have not been quantified. Fugitive dust emissions also arise from stockpiles of materials located in the open, openings on enclosed buildings and site traffic.

The licensee has undertaken ambient monitoring of dust deposition at eleven locations both on and off-site. Recent results indicate ihat dust deposition levels range from 54.9 - 205 .5mg/m2/day. The environmental liabilities risk assessment (ELRA) identified the top three risks related to wind-borne dust dispersion. Given the extent of dust generating activities and its risk score (ELRA), the RD specifies an ELV for dust deposition in line with draft Landfill BAT Guidance Note, 2003 (240mg/m2/day) and requires ambient monitoring at the 11 locations specified in the application.

A standby diesel generator of 500kW is used in the event of loss of mains electrical supply.

Last Update: December 2006 6

6.2 Emissions to Sewer Since 2004 sanitary effluent and laboratory sinks are discharged to Limerick County Council sewer for treatment at a municipal works.

6.3 Emissions to Waters Water generated from quarry activities is used as cooling water in the process prior to discharge to Bunlicky pond via emissions point SW1 (WE1 Drain A). Site storm water discharges to Bunlicky pond through SW 1. Excess quarry water is occasionally discharged directly to Bunlicky pond SW2 (WE2 drain B).

There is one oil interceptor and another proposed oil interceptor on-site. There is one silt trap but numerous manholes on the drainage system act as silt traps. Ultimately Bunlicky pond acts as settlement pond for silt from the installation. Suspended solids levels can be as high as 600mg/l. Siltation of the drain, leading to the pond was observed during the site visit. The pond is in effect a control system for settling solids generated in process effluent.

Both emission points to Bunlicky pond are limited in the current licence. Monitoring data indicates that the average BOD of the SWl discharges is around 4mg/l. The RD specifies limits for toxicity and mineral oil in line with the existing licence and the final draft BAT Guidance Note (November, 2007) for both emission points. The RD reduces BOD limit to 1Omg/l from 25mg/l on SW1 and specifies suspended solids limits for SW2.

The water level in the pond is controlled by a sluice gate, which prevents flood water from the Shannon entering the pond during high tides. The water level is maintained at OmOD by a spillway. Consequently there may be no water flow from the lake even at low tide. There are 3 water sources of inflow into the lake which delivers approximately 14,000m3 per day of water to the pond; . . .

Ground water diverted from the quarry (SW2)

Process water from the cement works (SW1)

Surface water run-off from the catchment of 6km2.

Under worst case conditions of heavy rainfall (65.5mm) and closed sluice gate, the water level would rise approximately 0.8,. Water. level in the pond is generally OmOD during summer and 0.45mOD during winter and ground level around the pond is 1.5mOD. Therefore the pond will not flood under current conditions. Water quality of the pond is very good and is characterised by elevated chloride levels (-75mg/l). The discharge from the cement works does not adversely affect water quality in the pond. Consequently there is no adverse effect of discharges from Bunlicky pond on the River Shannon.

Last Update: December 2006 7

6.4 Emissions to qround Four septic tanks remain in operation on-site. There are no other direct emissions to ground.

There is potential for groundgroundwater contamination from spillages in pervious areas and leaks from underground service pipes. There is a 60m underground diesel pipe which was pressure tested upon installation 4 to 5 years ago. The RD requires integnty testing of underground pipes.

The Bunliclq pond is clay-lined which limits connectivity between pond water and groundwater. The quarry groundwater extraction well is the only groundwater being monitored on-site. The impact of landfilling activities on groundwater is discussed in more detail below.

6.5 Noise There are no significant changes in the quantity and nature of noise from the installation. The licensee was required under the existing licence to implement a noise reduction programme. Measures undertaken to date include acoustic housing for two fan motors, acoustic hoods on compressors, silencer fitted to fan and housing of blowers.

The licensee has indicated that they can achieve the sound pressure levels, air over pressure and peak particle velocity limits set out in the EPA Guidance Note for Noise in relation to schedule activities, 2nd edition 2006, provided that there is no new noise sensitive locations positioned near the plant and that a 3dBA adjustment applies to off-site noise limits. This latter requirement provides for measurement uncertainty due to instrumentation, operating conditions, weather, ground conditions and residual noise.

Off-site development is a matter outside the scope of licensing and the EPA Environmental Noise Survey Guidance document addresses monitoring for the purposes of demonstrating compliance with licence limits. The RD specifies noise limit of 55/45 dB(A) for day and night-time at noise sensitive locations with no adjustment factor.

The licensee considers sound power limits on items of plants as specified in the current licence to be unworkable and unrealistic. EPA guidance on planning and managing noise control for an activity identifies that the establishment of target noise levels for key equipment is an important step. However controlling noise at source is complex as it can affect plant efficiency. The RD replaces specified limits for items of plant with a requirement to have a noise mitigation and control programme.

In relation to blasting, the licensee seeks a 95% confidence limit on air overpressure with no individual result exceeding the limit by 3dB linear. EPA guidance recognises the effect of atmospheric conditions and minor changes in blast design particularly in relation quarrying. Blast monitoring is carried out at one on-site permanent location and on occasion at noise sensitive locations. A number of complaints have been received in relation to blasts. The RD specifies vibration and air over pressure limits in accordance with EPA noise guidance document (12mds and 125 dB(Lin)M,, peak air overpressure (95%ile value)). It further limits the exceedance of an individual air over pressure value to 2.5dB (lin) of the limit (maximum value 127.5dB (lin)) in line with licences for other cement plants. The RD requires monitoring of vibration and air overpressure at the fixed monitor and at least two noise sensitive locations per blast.

The RD specifies noise limit of 55/45 &(A) for day and night-time, 12mds and 125 dB(Lin)M,, peak air overpressure (95%ile value) which are reductions on current limits. These requirements are in line with EPA Guidance Note for Noise in relation to schedule activities, 2nd edition 2006.

6.6 Waste Hazardous waste such as waste oils and batteries are sent for recovery off-site. Replacement and repair to the preheater system of the pet coke mill generates radioactive substances which are disposed off-site. Non-hazardous waste is predominantly reused into the cement works or

Last Update: December 2006 8

recycled to the quarry. waste and cement waste are landfilled on-site.

Landfill (Class 11.1)

The licensee proposes to restrict waste landfilled to the following inert materials and reports the current quantities deposited to date as follows:

Wastes such as weakened clinker, spent refractories, demolition

RocWdemolition waste (Concrete, bricks, mixture of

EWC Code Quantities

17.01.01, 17.01.02, 110 - 130 tonnes /year

concrete, bricks, tiles and ceramics, soil and stone)

Spent refractories

Wedoff spec raw meal

Off spec clinker and kiln coating

General dust

Filter dust and cooling tower dust

Last Update: December 2006

17.01.07, 17.05.04

16.1 1.06 400 - 497

10.13.0 1

10.13.04

10.13.06

10.13.13

9

Landfilling is the direct addition of material to the shore of the pond and thus creates elevated levels of suspended solids in the vicinity of the shore and likely to affect pH. Water quality monitoring of the pond as a whole indicates that there is no adverse effect on water quality from landfilling. Capping of the landfill annually will reduce water infiltration and promote surface drainage. The RD requires water quality monitoring of the pond at the outflow point.

Landfilling of inert materials can generate dust. These may be controlled by wetting and prompt compaction. The RD specifies ambient limits for dust and requires monitoring.

The landfill is currently operated in accordance with the Conditioning Plan, the existing licence and the on-site Environmental Guidelines. To provide for the full provisions of the Landfill Directive and the Council Decision on waste acceptance, the RD requires an updated operational plan.

The landfill and pond are both within the scope of a proposed natural heritage area known as the Inner Shannon Estuary South Shore. Having consulted with the National Parks and Wildlife Service (NPWS), the priority is to protect the cormorant roost colony located to the east of the new road and away from the current infilling area. The NPWS have noted to the company that operations should not have a significant impact on the cormorant roost. The RD prohibits landfilling from interfering with the cormorant colony.

6. Measures to prevent accidents and limit their consequences The company has prepared an emergency response plan and procedures for the site. Measures to prevent accidents includes 24 hour surveillance by trained employees. Appropriate training of drivers and personnel is provided. There are temperature, pressure and high level sensors on plant with automatic shut-off control.

There are fourteen tanks on-site mostly storing diesel oil. Half of these tanks are bunded and the remainder are double walled tanks. Of the latter, four need to be fitted with leak detection in line with EPA guidance on storage. The RD requires leak detection on double walled tanks within six months.

An environmental liabilities risk assessment has been undertaken to identify potential risks. A fire associated with the garage/workshop and coal plant has been identified as a risk. In the event of a fire, firewater will flow to Bunlicky pond. The licensee considers that contaminated firewater will be adequately accommodated in the pond and diluted by its volume. Consequently, the impact is considered low and groundwater will not be affected. The licensee proposes two 3 metre absorbent booms at surface water outlets and a permanent 30 metre containment boom on the Pond. The licensee does not propose to shut off the sluice valves on the outlet from the Pond to the River Shannon.

The RD requires the absorbent and containment booms and the sluice gates to be closed in the event of a fire. Following assessment of the pond water, safe disposal of firewater will be undertaken.

7. Cultural Heritage, Habitats & Protected Species The installation is bounded to the north by the River Shannon. Four proposed NHAs, one proposed candidate SAC and one SPA lie within 5 km of the site. More significantly, the following three designated sites lie within or adjacent to the installation boundary: . pNHA, site code 000435; Inner Shannon Estuary South Shore

Although this pNHA covers a large area including the whole of Bunlicky pond and environs, the NPWS have advised the licensee and confirmed with the Agency their concern is restricted to the cormorant roost and nesting colony. The narrow spit on Bunlicky pond occupied by the cormorants lies to the east of the new road. No activities are carried out in the area. The NPWS do not envisage disturbance to be an issue here. . cSAC Site Code 002 165: Lower River Shannon

Last Update: December 2006 10

This is a very extensive candidate SAC which covers the embankment, river and a small portion of Bunlicky pond. The habitat in this area of the SAC is estuarine mudflats and fringing reed swamp. The protected plant triangular clubrush also occurs here. The area is important for wintering waterfowl. . SPA site code 004077: River Shannon and River Fergus SPA

The SPA covers an area adjacent to the site boundary and the habitat again is estuarine mudflats and fringing reed swamp. The protected plant triangular clubrush also occurs here. The area is important for wintering waterfowl.

Land reclamation for both the cSAC and SPA have been identified by the NPWS as threats to these areas. The infilling of the pond by inert material will not have an adverse effect on the SPA but may affect the small area of the cSAC within the installation boundary.

The RD requires that landfilling will not interfere with the cSAC or the cormorant roost within the installation boundary.

8. Fit & Proper Person Assessment The licensee was convicted under the Air Pollution Act, 1987 in June 2007 for an incident involving a significant dust release to air.

The company and other relevant persons have experience in the industry. Irish Cement Limited is a subsidiary of CRH plc which has annual sales of over €1 1 billion. The Closure, Restoration and Aftercare Management Plan will be underwritten by CRH plc.

Having regard to the provisions of Section 84(5) of the EPA Acts and the Conditions of the RD, the licensee can be deemed a Fit & Proper Person for the purpose of this licence.

9. Best Available Techniques (BAT) BAT is taken as guidance set out in EPA draft BAT Guidance Note for the Cement and Lime Sector, November 2007, the EIPPCB IPPC Reference Document (BREF) on BAT for Cement and Lime, December 2001 and the EPA draft BAT Guidance Note for the Waste Sector: Landfill Activities, April 2003. Regard was also had for the EPA Landfill Manuals.

I have examined and assessed the application documentation and I am satisfied that the site, technologies and techniques specified in the application and as confirmed, modified or specified in the attached Recommended Determination comply with the requirements and principles of BAT. I consider the technologies and techniques as described in the application, in this report, and in the RD, to be the most effective in achieving a high general level of protection of the environment having regard to the way the installation is located, designed, built, managed, maintained, operated and decommissioned.

I O . Compliance Record An audit of the installation was undertaken in November 2007 and was found to be compliant.

1 I. Complaints Since the beginning of 2006, the Agency has received twelve complaints in relation to the impact of blasting. The RD requires the licensee to cany out monitoring at least 2 noise sensitive locations during a blast event.

The Agency received 27 complaints as a result of the incident involving a significant dust release in October 2007 which the licensee was prosecuted subsequently.

12. Submissions No submissions have been received.

Last Update: December 2006 11