IPPC Licence Application Attachment Jthe FLS-Automation PLC-based control system is the CO monitoring on the Electrostatic Precipitator, which automatically shuts the process down

IPPC Licence Application Attachment J

Quinn Cement Ltd

IPPC Licence Application

ATTACHMENT No JACCIDENT PREVENTION AND EMERGENCY RESPONSE

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Contents

1 ACCIDENT PREVENTION AND EMERGENCY RESPONSE........................................................ 1 Introduction..................................................................................................................... 1

2 ENVIRONMENTAL ACCIDENT PREVENTION ........................................................................ 2 Plant Design and Current Accident Prevention Measures ...................................................... 2 Proposed Accident Prevention Measures ............................................................................. 3

Plant Operation....................................................................................................... 3 Material Storage...................................................................................................... 5 Contamination from Fire Water................................................................................. 5 Environmental Accident Prevention Procedures .......................................................... 6

3 EMERGENCY RESPONSE.................................................................................................... 7 4 PUBLIC LIABILITY INSURANCE.......................................................................................... 8

Appendices

Appendix J.a Accident Prevention and Emergency Response Procedures Appendix J.b - Public Liability Insurance Certificate


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1 ACCIDENT PREVENTION AND EMERGENCY RESPONSE

INTRODUCTION

1.1 Quinn Cement Ltd (Quinn Cement) has established and maintained procedures to identify the

potential for accidents and emergency situations which theoretically may occur at the

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

react to such situations.

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

process to reflect the addition of Solid Recovered Fuel (SRF) for which this Attachment and the

IPPC licence application relates.

1.3 The following sections outline the Environmental Accident Prevention Measures which have

been incorporated into the plant design, the written procedures in place to prevent the

occurrence of accidents, and, if an accident or emergency situation should arise, the written

response procedures which are in place in order to action and remedy the situation.

WYG Environment part of the WYG Group 1 creative minds safe hands

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2 ENVIRONMENTAL ACCIDENT PREVENTION

PLANT DESIGN AND CURRENT ACCIDENT PREVENTION MEASURES

2.1 Consideration was given to the potential for accidental emissions within the original Quinn

Cement Ballyconnell plant design and layout.

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

coal mill. The following coal mill design features are present to reduce this risk:

• All silos are designed for safe mass flow;

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

• Continuous monitoring of temperature is undertaken throughout the system;

• An inert gas injection system is in place;

• Continuous monitoring of carbon monoxide (CO) concentrations is undertaken;

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

• Vacuum breakers in coal meal bin outlets; and,

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

2.3 Enclosed rubber belt bucket elevators are utilised for transportation of materials between the

various unit operations. This transportation method was chosen over cheaper pneumatic

transportation methods such as air-lifts as it reduces the potential for atmospheric dust

emissions occurring as a result of worn pipelines.

2.4 Adequate fire-fighting equipment is provided on site to deal with an emergency situation. A

comprehensive fire detection system is installed in all electrical rooms, the service tunnel,

laboratory, administration buildings and the stores and workshop buildings. Fire alarm signals

are displayed on a panel in the central control room.

2.5 All hazardous material storage tanks are bunded to 110% of the volume of the largest tank or

25% of the total volume and the bunds are integrity tested on a regular basis. A record of the

testing procedures of the bunds is presented within Attachment H.1.

2.6 Spillage containment kits are located in close proximity to all oil storage areas.


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PROPOSED ACCIDENT PREVENTION MEASURES

2.7 The fire risks associated with the storage of SRF have been assessed. Although the risks are

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

• Self ignition of SRF; and,

• Spark ignition of SRF.

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

the temperature rises due to biological processes within the SRF.

2.9 Spark ignition might occur if a metal component within the material extraction system is torn

off during operation and then creates a spark through contact with the extractor. Although the

nature of the SRF dust is such that it could be easily ignited, it is not considered that a spark

would contain sufficient energy to start a fire.

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

preventative measures are to be implemented:

• Camera surveillance;

• Heat, CO and flame detectors;

• Sprinklers and water cannon ejector units; and,

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

Plant Operation

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

FLS-Automation PLC-based control system with additional supporting control and supervision

system. This includes the following control systems:

• Fuzzy Expert Kiln Control;

• Fuzzy Expert Kiln Start-up;

• Fuzzy Expert Cooler Control;

• Cem-Scanner and Refractory Management; and,

• Emission Monitoring, Control and Analysis System.


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

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

Coal Firing and Electrostatic Precipitator.

2.13 Reference should be made to Attachment F.1 for a more detailed description of the FLS-

Automation control system.

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

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

be brought under control at an early stage and thus act as a preventative measure for any

serious deviation in operational activity, such as significant emissions release. An example of

the FLS-Automation PLC-based control system is the CO monitoring on the Electrostatic

Precipitator, which automatically shuts the process down when a CO concentration of 1.2% is

monitored within the exhaust flue gas. The control system reacts accordingly and terminates

the process to avoid an increase in the emission of CO.

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

faults or emergency situations, the control system completes a pre-programmed stop

procedure which is designed to minimise danger to the plant equipment, personnel and the

environment.

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

• Sounding of an alarm; and,

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

followed by a sequential cessation of interlinked equipment subsequent to the process

identified as experiencing the error.

2.17 All the alarms are audible and visually shown on the maintenance screens and are printed in

the alarm reporting system. Furthermore, the system allows for the possibility of logging trend

curves which assists in diagnosing the cause of the alarm. This information can then be used

for prevention against a repetition of similar situations.

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

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

situation where stoppage will occur.


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2.19 The operation of the control system is supervised by process controllers, employees who are

specially trained in the operation of the cement making process. Specific written instructions

for the control system operation are made available in the central control room.

Material Storage

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

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

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

Contamination from Fire Water

2.21 The water settlement tank is designed to provide adequate provision for fire-water run-off.

The site has a natural inclination of 2.5% in the north/south direction and 1.5% in the

west/east direction in order to ensure drainage into the correct system.

2.22 Fire-water is collected within the plant drainage system and discharged via the water

settlement tank following treatment. If required, discharge from the water settlement tank can

be stopped and firewater can then be removed and treated. The majority of the site drainage

system is an open concrete trench system covered by metallic grates, although there are a

number of manholes on site. The settlement tank is a horizontal flow settlement tank of

capacity 4,725 to 5,400m3 which allows for a two hour retention time during peak rainfall.

2.23 This settlement tank conforms to the requirements of the Environmental Protection Agency

(EPA) draft Guidance Note to Industry on the Requirements for Fire-Water Retention

Facilities1.

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

facility is presented within Attachment F.1.

1 Draft Guidance Note to Industry on the Requirements for Fire-Water Retention Facilities, Environmental Protection

Agency, 1995.

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Environmental Accident Prevention Procedures

2.25 Quinn Cement have written procedures in place for prevention of environmental accidents

which are contained within the company Environmental Management System (EMS). These

procedures cover the following aspects:

• Delivery of oils and liquid fuels;

• Bund draining procedure; and,

• Environmental incident recording and reporting.

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

contamination occurring. Should an environmental incident occur, there are written procedures

in place to prevent the incident from recurring.

2.27 A copy of these written procedures is contained within Appendix J.a.


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3 EMERGENCY RESPONSE 3.1 Quinn Cement have written procedures in place for emergency response which are contained

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

3.2 A copy of these written procedures is contained within Appendix J.a.

3.3 The procedures include details on emergency response procedure covering the following

aspects:

• Emergency response team;

• Evacuation procedures;

• Fire wardens;

• First aiders;

• Supervisor responsibilities;

• Employee responsibilities;

• Medical emergencies;

• Occurrence of minor accidents/incidents;

• Emergency contact numbers;

• Assembly points; and,

• Spillage response.


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4 PUBLIC LIABILITY INSURANCE 4.1 Quinn Cement Ltd is adequately covered by public liability insurance to the sum of

£10,000,000. A copy of this insurance certificate is contained within Appendix J.b.

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APPENDIX J.a

Accident Prevention and Emergency Response

Procedures

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Quinn Cement – Environmental Management

System

Emergency Preparedness and Response

Created by: Brendan O’Neill, Quinn Group HSE Manager – 26/10/05

Revised by: Anna McNally, Quinn Cement Environmental Advisor – 14/08/09 Page 1 of 11

Version No. 002 Issue date: 30.04.2008

Emergency Preparedness and Response EMP010

1.0 Purpose

To establish and maintain procedures to identify potential for and response needed

to react to accidents and emergency situations, and for preventing and mitigating

the environmental impacts that may be associated with them. Also to minimise the

impact on the Cement Division and to minimise the impact to personnel on site,

and those on adjoining sites and on the Cement Divisional plan. This procedure

covers the various steps to be followed in the event of an emergency evacuation,

occupational accidents/incidents and environmental accidents/incidents.

2.0 Responsibilities

The Divisional Manager is responsible for developing the plan details, providing

the necessary infrastructure, and implementing the necessary training and

organising evacuation drills. The Divisional Manager or his delegates will also act

as the Emergency Controller in the event of an incident or emergency situation.

The Environmental Advisor is responsible for ensuring that an adequate emergency

preparedness and response plan is in place and that all employees are familiar with

its requirements. The Health and Safety Advisor is responsible for ensuring that the

following information is up to date and easily accessible:

• MSDS folder

• Drawings showing plant layout

• Map showing location of emergency equipment

The Emergency Response Team consists of:

• Members of Management

• Health and Safety Advisor

• Environmental Advisor

• Supervisors

• First Aiders

• Fire wardens

• Reception personnel

• Emergency Services

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

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3.0 Instructions

3.1 AN EMERGENCY EVACUATION

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

the fire alarm will either be activated automatically or be initiated by the

Management who is responsible for co-ordinating the evacuation and

communication with the external services or by the employee who is first made

aware of the problem.

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

ensure that the following lists of priorities are followed:

• Safety and welfare of all employees (evacuation and first aid)

• Minimise damage to equipment, property and the environment

• Minimise loss of materials

On hearing the alarm a member of management must assess whether it is an actual

evacuation or a “false alarm”. The Emergency Controller (Quinn Cement

Management) must proceed to the area and assess the nature of the emergency or

liaise with Control Room personnel who will have information on the location of

the alarm.

3.1.1 Emergency Controller

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

• If it is a false alarm either cancel the alarm or treat like a drill.

• Deal with the emergency in-house e.g. use of fire fighting equipment.

• Contact the emergency services.

• Assign a responsible person to await the arrival of the emergency services at the

weighbridge so to advise on the location of the accident/incident.

• The Emergency Controller must liaise with; the Supervisor on duty, to establish

a head count, with emergency services to give details to them on last locations

of unaccounted personnel, and the First Aider on duty, if there are any injuries.

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

building.

• Convene and chair de-briefing and investigation into the incident.

3.1.2 Health & Safety Advisor

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

exit.

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• Report to your assembly point for head count.

• Report headcount to a member of management

• Prioritise the injured and co-ordinate the first aiders that report to the area.

• Give additional first aid to those that require attention and give assistance to the

first aiders.

• When the medical services arrive brief them as to the names of the injured, the

extent of the injuries and the type of first aid given on site.

• Notify the families of injured persons of the extent of their injuries and their

location.

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

Advisor/Supervisors must prepare statements for the senior managers as to the

extent of the emergency.

3.1.3 First Aiders

On hearing the fire alarm the certified first aiders should:

• Evacuate the building via the nearest safest exit taking with you the first aid box for

the area, go to your designated assembly point and report to your

supervisor/manager as a first aider.

• Then report to the Emergency Controller for further instructions.

• Provide immediate first aid to any injured persons, prioritising their needs.

• Report to Health and Safety Advisor re extent of injuries or if additional medical

assistance is required

3.1.4 Reception/Administration Personnel

It is the responsibility of those at Reception to undertake the following duties:

• Bring with them the Visitor sign in Log and MSDS folder

• Direct guests and personnel in the lobby outside to assembly areas

• Check the meeting room, reception lobby and toilets

• Report to assembly area and determine if all visitors have been evacuated.

• Deliver MSDS folder to a member of management to give to the emergency services

• Report any problems to Supervisors.

3.1.5 Fire Wardens

• The Fire Wardens follows any instructions given by the Quinn Cement management

controlling the emergency.

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• Upon hearing the alarm the fire warden should:

• Conduct a thorough search of his/her designated area, provided it is safe to do so,

following the search pattern below carefully ;

• Check that all persons have evacuated his/her section

• Check that nothing is left in a dangerous condition

• Close all fire doors if possible

• On completion of the search immediately report findings to management member at

assembly points.

• Attend de-briefing meeting when convened.

The trained fire wardens on site are as follows;

Trained Fire Warden

Ballyconnell Derrylin

Brendan Meehan Ryszard Suplicki Brian Earley Miroslaw Moksiewicz Ciaran Traynor Pawel Kubiak Tom O'Brien Graeme Simpson Hubert McCaffrey

Michael McLoughlin

Sean Cooke

Eamon Leonard

3.1.6 Supervisors

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

procedure.

• Be aware of absences from your area during a normal working day.

• Ensure that all in your area evacuate safely and successfully.

• Conduct a head count at the assembly point.

• Follow any additional instructions given by management.

• Report to management either: that everyone in the department is accounted for or the

names and last known location of anyone not accounted for.

N.B. In the event of an Emergency Evacuation outside of normal working hours the

Production Supervisors must take on the responsibilities of the Emergency Controller and

the Health and Safety Advisor.

3.1.7 Employees

Personnel who discover a fire or other emergency that necessitates an evacuation should:

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• Raise the alarm by activating the break glass unit at the nearest alarm call point

• Leave the building via the nearest emergency exit and proceed to their designated

assembly point.

3.1.8 On hearing the alarm, personnel must:

• Immediately leave the building via the nearest emergency exit in an orderly manner

• Chairs must be replaced at workstations do not block the evacuation path of others and

keep aisles clear

• Do not collect personal belongings

• Shut off equipment unless it is hazardous to do so or time consuming

• Walk - do NOT run and provide assistance to any disabled staff member or visitor as

required

• Ensure that visitors are escorted off the premises in an orderly fashion

• Close all doors behind you-but do not lock them

• Do not use the lift to evacuate-use stairways only

• Touch doors with the back of your hand before opening them-do NOT open a door if it

is hot

• If you encounter thick smoke, stay close to the floor. Crawl if necessary

• Proceed to their designated assembly point and remain there while awaiting further

instructions. There will be a Safety Team Member there in charge of the situation

• Smoking is strictly prohibited during the evacuation

• Follow the instructions of the Emergency Response Team.

• Re-enter the building ONLY with the consent of management.

3.1.9 Contractors

It is the responsibility of the contractor to:

• Know who is working for him on site at any given time

• Ensure his employees are familiar with the exits

• Know the designated assembly point for contractors

• Account for his employees during the evacuation

On hearing the alarm contract employees should:

• Shut off your equipment unless it is hazardous to do so

• Proceed promptly in an orderly manner to the nearest suitable exit and go to the

assembly point

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

time during the emergency

• Immediately upon your arrival at the assembly point report to your supervisor

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• Under no circumstances do you leave the safe area or attempt to re-enter the building

unless the all clear has been given

3.2 Medical Emergency

Personnel who come upon a medical emergency where urgent medical attention is needed,

should proceed as follows:

• Call the emergency number ( 5275 and request a First Aider or emergency services or

else call 999 immediately). Lists of personnel who are certified in First Aid are posted

throughout the facility.

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

the situation to the operator.

• Send someone nearby to guide the first aiders or emergency to the area.

• Stay with the injured person and reassure them until a First Aider arrives.

• First Aid personnel will administer or decide if medical services such as the HSE

Advisor, doctor or an ambulance need to be called.

3.2.1 Occurrence of a minor Accident/Incident on site

In the event of an occupational accident /incident occurring on site all employees must

carry out the following;

• Raise awareness of accident/incident*

• Request First-Aid assistance

• On completion of first aid report to Supervisor/Manager

• Fill in all details of accident/incident on the appropriate forms

• Submit form to HSE Advisor for record

*If you are involved in the accident/incident alert another member by staff.

All injuries and incidents must be reported to a supervisor.

3.3 Dust Spill

• On detecting a dust spill employees must inform their Supervisor of spill, give details

on location, magnitude etc,

• The supervisor generates a work request – job card.

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• The Process Production manager approves the work request and sends the site

maintenance team to the spillage.

• If the dust is cold, the industrial vacuum unit is used to clean up spill.

• If the dust is hot, water is used to cool and dampen the material before cleaning.

• The excess dust/material is then recycled back into the process and the work request is

completed.

• The supervisor submits details of the dust spill to the Environmental Advisor, who

reports it to the EPA.

3.4 Oil Spills

• All major oil spills will require immediate containment, therefore all locations where

oil is stored is adequately bunded, to prevent spill from spreading and contaminating

other locations on site.

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

reasonably practicable, using the spill kits provided on site.

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

approved waste contractor

• Minor oil spills can be absorbed by using sand, saw-dust or proprietary granules. All

absorbents used are stored in a contained, segregated area, until collection by a licensed

waste contractor.

Emergency Numbers Emergency Controllers:

Ballyconnell

T.P. Feehan 5243 ( 087-2706088)

Damien Reilly 5293 (087-250-8937 )

Pat Lunney 5257

Dermott Smith 5261 (087-250-8926)

Paul Carron 5260

Production Supervisors 5275 ( CCR)

Weighbridge 5219

Control Room 5275

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Derrylin

Tom Cox 2702 (077-68531948)

Brian Maguire 2708

Pat O’Callaghan 2384 (079-00917536)

Eoghan Doonan 2705 (087-2508933)

Tom Leonard 2700 (079-00916849)

Production Supervisors 2325 ( CCR)

Weighbridge 2215

Control Room 2325

Donal Kelly 5309

Anna Mc Nally 5295

Reception 0

Emergency Services Emergency Services 999/ 112(Republic only)

Doctors Surgery (Ballyconnell) 049 - 952-2642

Dr. Kirby (Derrylin) 028/048 - 6774-8250

Enniskillen Hospital 028/048 - 6632-4711

Cavan Hospital 049 - 437-6000

Fire Brigade (Ballyconnell) 049 - 9526120

Fire Brigade (Enniskillen) 028/048 – 6634-6946

Gardai (Ballyconnell) 049 – 952-6102

PSNI (Enniskillen) 028/048 - 6632-2823

Fr. McMorrow (Teemore) 028/048 - 6774-8266

Fr. Kiernan (Derrylin) 028/048 - 6774-8315

Rector George (Davison Derrylin) 028/048 - 6774-8994

028 from within Northern Ireland, 048 from within the Republic

List of First Aiders on Site Name Contact Name Contact

Ballyconnell Derrylin

Michael

McLoughlin

5275/Radio Brian Maguire

2708/Radio

Sean Cooke 5275/Radio Marek Jendrzej 2325/Radio

Eamonn Leonard 5275/Radio Wojciech

Malicki

2325/Radio

Hubert

McCaffery

5275/Radio Kevin Martin

2325/Radio

Ciaran Traynor 5275/Radio Ronan McBrien 2325/Radio

Brendan Meehan 5275/Radio Marian Moskwa 2325/Radio

Kyle Warnock 5275/Radio Piotr Bojczuk 2325/Radio

Pat Lunney 5257/Radio

Martin Brady 5275/Radio

Adrian McAloon 5275/Radio

Tom O'Brien 5275/Radio

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Assembly Points Ballyconnell Assembly Point

No.

Location Areas Serviced

1 Main Car Park Main building, workshop, canteen,

raw mill, kiln area, coal mill, general

area at top of the site.

2 Outside Drivers

Canteen

Cement Mill, Bagging Plant, PFA

silo’s, Bulk cement Silo’s, Drivers

canteen, General area to the bottom of

the site

3

Front of Weighbridge Weighbridge, Incoming & Outgoing

Lorries/Traffic.

4 Outside Crushing Plant General Area around Crusher

Assembly Points Derrylin Assembly Point

No.

Location Areas Serviced

1 Main Car Park Main building, workshop, canteen,

raw mill, kiln area, coal mill, general

area at top of the site.

2 Outside Workers

Canteen

Cement Mill, Bagging Plant, PFA

silo’s, Bulk cement Silo’s, Drivers

canteen, General area to the bottom of

the site

3

Front of Weighbridge Weighbridge, Incoming & Outgoing

Lorries/Traffic.

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System





Location Of Fire Hydrants

LOCATION OF ASSEMBLY POINTS

Stores&

Canteen

WorkshopOffice

Bagging Plant Washer

Drivers

Canteen

Switch RoomRaw Mill & Preheater

Stores&

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WorkshopOffice

Bagging Plant Washer

Drivers

Canteen

Switch RoomRaw Mill & Preheater

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System





4.0 Related Documents

• Incident Log

• Bund Draining Procedure

• Delivery of Oils and Liquid Fuels

• Spills Management and Clean-up

• Dealing with Dust or Material Spills

• Training records

• MSDS master list

• First Aid Guidelines

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APPENDIX J.b

Public Liability Insurance Certificate

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IPPC Licence Application Attachment K

Quinn Cement Ltd


ATTACHMENT No KREMEDIATION, DECOMMISSIONING, RESTORATION, AND

AFTERCARE – CESSATION OF ACTIVITY


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Contents

1 CESSATION OF ACTIVITY ................................................................................................. 3

Appendices Appendix K.a - Site Closure Plan


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1 CESSATION OF ACTIVITY 1.1 Quinn Cement Ltd. have formulated a full closure plan in accordance with guidance contained

within the EPA Guidance on Environmental Liability Risk Assessment, Residuals Management

Plan and Financial Provision1.

1.2 A copy of this plan is contained within Appendix K.a.

1 Guidance on Environmental Liability Risk Assessment, Residuals Management Plan and Financial Provision, Environmental

Protection Agency, 2006.

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APPENDIX K.a

Site Closure Plan

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IPPC Licence Application Attachment L

Quinn Cement Ltd


ATTACHMENT No LSTATUTORY REQUIREMENTS


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Contents

1 STATUTORY REQUIREMENTS............................................................................................ 1 Air Emissions.................................................................................................................... 1 Water Emissions............................................................................................................... 2 Regulations Under European Communities Act 1972 ............................................................ 3 Noise Emissions................................................................................................................ 3 Prevention of Significant Environmental Pollution ................................................................ 4 Waste.............................................................................................................................. 6 Energy Efficiency .............................................................................................................. 7 Accidents......................................................................................................................... 7 Cessation of Activity.......................................................................................................... 8 Designated Areas ............................................................................................................. 8 Fit and Proper Person ....................................................................................................... 8


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1 STATUTORY REQUIREMENTS 1.1 Section 83 of the Environmental Protection Agency Act (1992) and Protection of the

Environment Act (2003) outline statutory requirements which must be met in order

that an IPPC Licence will be granted by the Environmental Protection Agency (EPA).

1.2 This attachment outlines the statutory requirements and how these will be achieved

by Quinn Cement Ltd at the Ballyconnell facility.

AIR EMISSIONS

1.3 Section 83(5)(a)(i) of the Environmental Protection Agency Act (1992) and Protection

of the Environment Act (2003) states the following:

“The Agency shall not grant a licence or revised licence for an activity—

(a) unless it is satisfied that—

(i) any emissions from the activity will not result in the

contravention of any relevant air quality standard specified

under section 50 of the Air Pollution Act 1987, and will

comply with any relevant emission limit value specified

under section 51 of the Air Pollution Act 1987.”

1.4 Air Quality Standards (AQS), as outlined under the Air Pollution Act (1987) (S.I

244/1987), cover sulphur dioxide (SO2), suspended particulates, lead (Pb) and

nitrogen dioxide (NO2). These standards have been continuously modified towards the

air quality assessment year 2010. Within the most recently issued air quality

legislation, Air Quality Standards Regulations (2007), limit values and AQS are now

also prescribed for maximum concentrations of benzene (C6H6) and carbon monoxide

(CO) within ambient air.

1.5 A detailed air dispersion modelling assessment has been undertaken using the

Breeze-AERMOD software in order to assess the potential impact associated with

atmospheric emissions arising from the Quinn Cement Ballyconnell facility and the

revision to the process. The proposed new Solid Recovered Fuel (SRF) co-fuelled

facility is covered by the Waste Incineration Directive (WID) (2000/76/EC). Emissions

to atmosphere were calculated based upon maximum permitted Emission Limit Values


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(ELVs) contained within the WID. Impacts of the operation of the Ballyconnell facility

have been compared against the limit values and Air Quality Standards (AQS)

prescribed within the Environmental Protection Agency Act, 1992 (Ambient Air Quality

Assessment and Management) Regulations (1999) (SI 33 of 1999).

1.6 The results of this modelling, together with an assessment of the likely environmental

impacts associated with these emissions is included within Attachment I.1.

1.7 Review of S.I No. 394/2004 has determined that substances which are emitted to air

as specified within the schedule of S.I. No. 394/2004 includes oxides of nitrogen

(NOX), oxides of sulphur (SOX), CO, volatile organic compounds (VOCs), dust, chlorine

(Cl), fluorine (F), polychlorinated dibenzodioxins (PCDD) and polychlorinated

dibenzofurans (PCDF).

WATER EMISSIONS

1.8 Section 83(5)(a)(ii) of the Environmental Protection Act (1992) and Protection of the

Environment Act (2003) states the following:

“The Agency shall not grant a licence or revised licence for an activity


(ii) any emissions from the activity will comply with, or will

not result in the;

contravention of, any relevant quality standard for waters,

trade effluents; and,

sewage effluents and standards in relation to treatment of

such effluents prescribed under section 26 of the Local

Government (Water Pollution) Act 1977.”

1.9 Section 26 of The Local Government (Water Pollution) Act (1977) states the following:

“The Minister may, after consultation with the Minister for Fisheries,

the Minister for Industry and Commerce, any other Minister who

appears to him to be interested and the Water Pollution Advisory

Council, prescribe for the purposes of this Act quality standards for

waters, trade effluents and sewage effluents and standards in relation

to methods of treatment of such effluents.”


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1.10 Within Section 26, the only standards covered are The Local Government (Water

Pollution) Act (1977) (Water Quality Standards for Phosphorus) Regulations (1998).

There will be no discharges of phosphorous (P) to water, since P compounds are not

used within the cement manufacturing process.

1.11 Consultation with S.I No. 394/2004 has determined that substances which are emitted

to water as specified within the schedule of S.I. No. 394/2004 includes materials in

suspension, substances which contribute to eutrophication and substances which

have a unfavourable influence on the oxygen (O) balance.

REGULATIONS UNDER EUROPEAN COMMUNITIES ACT 1972

1.12 Section 83(5)(a)(iii) of the Environmental Protection Act (1992) and Protection of the




(iii) any emissions from the activity or any premises,

plant, methods, comply with, or will not result in the

contravention of, any relevant standard including any

standard for an environmental medium prescribed under

regulations made under the European Communities Act

1972, or under any other enactment.”

1.13 The operation of the Quinn Cement Ballyconnell facility does not contravene and

complies with the regulations made under the European Communities Act (1972).

NOISE EMISSIONS

1.14 Section 83(5)(a)(iv) of the Environmental Protection Act (1992) and Protection of the




(iv) any noise from the activity will comply with, or will not

result in the contravention of, any regulations under

section 106.”


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1.15 Although there are no national regulations outlined for noise, the EPA Guidance Note

on Noise in Relation to Scheduled Activities1 has been consulted. This guidance note

includes the following general guidance in regards to acceptable noise levels at

sensitive receptor locations:

“While BAT must be applied on a case by case basis, the noise

attributable to on-site activities should not generally exceed a free-

field LAr,T value of 55 dB by daytime (08:00 – 22:00), at any noise

sensitive location. During night-time (22:00 – 08:00), the noise

attributable to on-site activities should not exceed a free-field LAeq, T

value of 45 dB.”

1.16 The most recent annual noise assessment undertaken in 2008 at sensitive locations in

the vicinity of the Ballyconnell plant, has demonstrated compliance with the day time

guidance levels. Although night-time noise levels are exceeded in 1No. location,

ameliorative measures are continuously being implemented at the plant, as contained

within the company Environmental Management Plan (presented within Attachment

C).

1.17 Further mitigation measures with regards to noise reduction will be implemented

following the recommendations of the most recent noise survey. Ameliorative

measures previously implemented, together with proposed noise abatement measures

are contained within Attachment I.7. Additionally, Attachment I.7 presents a noise

assessment of the revised Ballyconnell facility, with consideration of the SRF co-

fuelled kiln, together with an assessment of the likely environmental impacts

associated with these noise emissions.

PREVENTION OF SIGNIFICANT ENVIRONMENTAL POLLUTION

1.18 Section 83(5)(a)(v) of the Environmental Protection Act (1992) and Protection of the




1 Guidance Note for Noise in Relation to Scheduled Activities, Environmental Protection Agency, 2006.

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(v) any emissions from the activity will not cause

significant environmental pollution.”

1.19 The existing operations at the Ballyconnell facility do not cause any significant

environmental pollution, as demonstrated within past Quinn Cement Annual

Environmental Reports (AERs). Details of previous annual emissions are contained

within Attachment E.

1.20 Emissions to atmosphere, presented within Attachment E.1, illustrate an historic

annual compliance with the ELVs prescribed within the current IPPC licence. A

detailed dispersion modelling assessment of atmospheric emissions has been

undertaken as a result of the change to the Ballyconnell facility, as presented within

Attachment I.1. This assessment has assessed the impact of atmospheric emissions

associated with the operation of the Ballyconnell facility against the appropriate AQSs.

1.21 Annual monitoring of emissions to surface water, as presented within Attachment E.2,

show no annual exceedences of the BAT guidance limits. Therefore, as the proposed

introduction of SRF co-fuelling will not result in a change in surface water emissions,

no assessment of the impact on the Woodford River has been deemed necessary.

1.22 As referenced within Attachment E.4, there are currently no emissions to

groundwater. Furthermore, it is not considered that there will be any new emissions

to groundwater as a result of this application for an IPPC licence. However,

groundwater is analysed for pollutants on a bi-annual basis in accordance with

conditions within the current licence.

1.23 Although noise emissions exceed night-time guidance levels at 1No. sensitive

locations (at location N6), Quinn Cement is committed to implementing recommended

measures to reduce resulting noise levels to below guidance levels as demonstrated

by progress to date and proposed measures contained within the Environmental

Management Programme (presented within Attachment C). The Site is considered to

be doing all that is reasonably practicable to achieve its legal obligations with regard

to noise levels.


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1.24 The proposed SRF co-fuelling will not result in significant environmental pollution, as

demonstrated by Attachment I. Furthermore, the use of SRF to co-fuel the kiln will

result in a significant reduction in greenhouse gas emissions from the plant.

WASTE

1.25 Section 83(5)(a)(vii) of the Environmental Protection Act (1992) and Protection of the




(vii) having regard to Part III of the Act of 1996,

production of waste in the carrying on of the activity will be

prevented or minimised or, where waste is produced, it will

be recovered or, where that is not technically or

economically possible, disposed of in a manner which will

prevent or minimise any impact on the environment.”

1.26 Quinn Cement have implemented a hierarchy principle for waste management at the

Ballyconnell facility, which promotes re-use, recovery and recycling of waste which is

actively promoted on site. This hierarchy has been outlined within Attachment C.

1.27 Quinn Cement has installed an enclosed waste segregation area at the Ballyconnell

facility containing waste baling equipment. A designated member of staff has been

assigned responsibility for maintenance of this waste segregation area. Dedicated bins

have been placed at the points of main waste production to enable segregation of

waste at source.

1.28 All raw materials collected by abatement systems are recycled back into the process.

1.29 In order to minimise any impact upon the environment, waste which requires disposal

is transported from site by licensed waste carriers for disposal within licensed

facilities. Details of all waste streams generated, together with quantities, the waste

carrier company and final destination is contained within Attachment H. All waste

disposal is undertaken in accordance with the Waste Management Act (1996).


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ENERGY EFFICIENCY

1.30 Section 83(5)(a)(viii) of the Environmental Protection Act (1992) and Protection of the




(viii) energy will be used efficiently in the carrying on of

the activity.”

1.31 Quinn Cement is fully committed to maximising energy efficiency throughout all plant

operations. The company has signed up to the energy agreements programme which

is managed by Sustainable Energy Ireland (SEI). This is a three year agreement with

the ultimate goal to achieve accreditation to the IS-393 standard. Reference should

be made to Attachment G for an outline of existing and proposed energy efficiency

measures at the plant.

ACCIDENTS

1.32 Section 83(5)(a)(viii) of Environmental Protection Act (1992) and Protection of the




necessary measures will be taken to prevent accidents in

the carrying on of the activity and, where an accident

occurs, to limit its consequences for the environment and,

in so far as it does have such consequences, to remedy

those consequences.”

1.33 Quinn Cement Ltd has written procedures for accident prevention and an emergency

response, which are contained within the company Environmental Management

System (EMS). These procedures are outlined within Attachment J and Attachment C,

respectively.


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CESSATION OF ACTIVITY

1.34 Section 83(5)(a)(x) of the Environmental Protection Act (1992) and Protection of the




(x) necessary measures will be taken upon the permanent

cessation of the activity (including such a cessation resulting from

the abandonment of the activity) to avoid any risk of environmental

pollution and return the site of the activity to a satisfactory state.”

1.35 As a requirement of the PoE Act in Section 83(5)(xi), Quinn Cement has

completed a site closure plan in accordance with the EPA Guidance on Environmental

Liability Risk Assessment, Residuals Management Plans and Financial Provision2. A

copy of this is contained within Attachment K.

DESIGNATED AREAS

1.36 The Quinn Cement Balyconnell facility does not carry out an activity or is located such

that it is liable to have an adverse effect on designated areas specified within the

following:

• A site placed on a list in accordance with Chapter 1 of SI 94 of 1997;

• A site where consultation has been initiated in accordance with Article 5 of the

European Union Habitats Directive (92/43/EEC); or,

• A European site as defined in Article 2 of SI 94 of 1997.

FIT AND PROPER PERSON

1.37 Reference should be made to Attachment C for the relevant experience of the

applicant and the personnel working within the Quinn Cement Ballyconnell facility.

1.38 Neither the applicant or any other relevant person working at the Ballyconnell facility

has been convicted under the PoE Act, the Waste Management Act 1996, the

2 Guidance on Environmental Liability Risk Assessment, Residuals Management Plan and Financial Provision,

Environmental Protection Agency, 2006.

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www.wyg.com

Local Government (Water pollution) Acts 1977 and 1990 or the Air

Pollution Act 1987.

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Attachment E.6 Tabular Data on Emission Points

Eastings (m) Northings (m)

A1-01 A 227643 320305 YesA1-02 A 227693 320352 YesA1-03 A 227685 320400 YesA1-04 A 227703 320396 Yes

A2-01 A 227605 320380 Yes

A2-02 A 227555 320285 YesA2-03 A 227565 320255 YesA2-04 A 227575 320155 YesA2-05 A 227540 320155 YesA3-01 A 227318 320428 YesA3-02 A 227339 320478 YesA3-03 A 227447 320455 YesA3-04 A 227538 320434 YesA3-05 A 227617 320414 YesA3-06 A 227621 320379 YesA3-07 A 227607 320386 YesA3-08 A 227604 320399 YesA3-09 A 227600 320386 YesA3-10 A 227558 320354 YesA3-11 A 227560 320203 YesA3-12 A 227552 320238 YesA3-13 A 227567 320234 YesA3-14 A 227581 320226 YesA3-15 A 227487 320267 YesA3-16 A 227479 320218 YesA3-17 A 227534 320254 YesA3-18 A 227521 320205 YesA3-19 A 227605 320241 YesA3-20 A 227584 320148 YesA3-21 A 227511 320155 YesA3-22 A 227549 320138 YesA3-23 A 227565 320113 YesA3-24 A 227582 320094 YesA3-25 A 227565 320113 YesA3-26 A 227565 320113 YesA3-27 A 227565 320113 YesA3-28 A 227582 320094 YesA3-29 A 227582 320094 YesA3-30 A 227582 320094 YesA3-31 A 227595 320078 YesA3-32 A 227595 320078 YesA3-33 A 227595 320078 YesA3-34 A 227595 320078 YesA3-35 A 227595 320078 YesA3-36 A 227517 320140 YesA3-37 A 227517 320140 YesA3-38 A 227525 320138 YesA3-39 A 227525 320138 YesA3-40 A 227613 320151 YesA3-41 A 227646 320169 YesA3-42 A 227654 320200 YesA3-43 A 227641 320148 Yes

IPC Point Code Point TypeIrish Grid Reference Location

Verified

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A3-44 A 227573 320309 YesA3-45 A 227630 320403 YesA3-46 A 227576 320272 YesSE1 SE 227697 319906 Yes

SW1 SW 227738 319971 Yes

Ne1 N 227352 320536 YesNe2 N 227355 320532 YesNe3 N 227532 320433 YesNe4 N 227495 320314 YesNe5 N 227615 320408 YesNe6 N 227626 320414 YesNe7 N 227655 320407 YesNe8 N 227645 320409 YesNe9 N 227622 320399 YesNe10 N 227616 320371 YesNe11 N 227636 320355 YesNe12 N 227642 320357 YesNe13 N 227642 320376 YesNe14 N 227631 320386 YesNe15 N 227605 320386 YesNe16 N 227636 320391 YesNe17 N 227612 320380 YesNe18 N 227596 320384 YesNe19 N 227602 320381 YesNe20 N 227594 320401 YesNe21 N 227581 320294 YesNe22 N 227592 320346 YesNe23 N 227446 320452 YesNe24 N 227588 320438 YesNe25 N 227514 320154 YesNe26 N 227561 320146 YesNe27 N 227596 320079 YesNe28 N 227559 320293 YesNe29 N 227563 320286 YesNe30 N 227552 320272 YesNe31 N 227556 320345 YesNe32 N 227588 320381 YesNe33 N 227531 320415 YesNe34 N 227528 320473 YesNe35 N 227560 320203 YesNe36 N 227578 320284 YesNe37 N 227566 320286 YesNe38 N 227554 320241 YesNe39 N 227567 320234 YesNe40 N 227582 320235 YesNe41 N 227548 320294 YesNe42 N 227600 320379 YesNe43 N 227600 320378 YesNe44 N 227567 320345 YesNe45 N 227571 320350 YesNe46 N 227565 320331 YesNe47 N 227552 320149 YesNe48 N 227565 320113 YesNe49 N 227636 320162 YesNe50 N 227622 320455 Yes

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Oxides of nitrogen (NOX); Sulphur oxide (SOX); and, Particulate matter (PM)

PMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPMPM

Emission

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PMPMPM

Standard effluentMineral oils; Ammonium (NH4); Chromium

(Cr); and, Aluminium (Al)NoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoiseNoise

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Attachment F.3 Tabular Data on Monitoring and Sampling Points

Eastings (m) Northings (m)

A2-2 M 227555 320285 YesA2-3 M 227565 320255 YesA2-4 M 227575 320155 YesA2-5 M 227540 320155 Yes

N1 M 226411 319232 YesN2 M 227769 319320 YesN3 M 227758 319925 YesN4 M 227983 320231 YesN5 M 227612 320354 YesN6 M 227070 319977 Yes

DG1 S 227737 320411 YesDG2 S 227170 320481 YesDG3 S 227436 320033 YesDG4 S 227677 320193 YesDG5 S 227377 320568 Yes

IPC Point Code Point TypeIrish Grid Reference Location

Verified

Yes

SW1 S 227738 319971 Yes

A2-1 M 227605 320380

YesGW1 S 227693 319981

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Oxides of nitrogen (NOX);

Sulphur oxide (SOX); and,Particulate (PM)

PMPMPMPM

Biological Oxygen Demand (BOD);Suspended Solids (SS);

Aluminium (Al);Hexavalent Chromium (Cr VI);

Chemical Oxygen Demand (COD);Total Dissolved Solids (TDS);

Ammonium (NH4) as N;Mineral Oils; and,Organohalogens

Total Organic Carbon (TOC); Conductivity;

Total Ammonia (NH3) as N;Total Nitrogen (N);

Cr VI;Al;

Hydrocarbons; and,Organohalogens

NoiseNoiseNoiseNoiseNoiseNoisePMPMPMPMPM

Emission

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