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Licensing Administration Office of Climate, Licensing & Resource Use Environmental Protection Agency PO Box 3000 Johnstown Castle Estate County Wexford
11 June 2012
Re: Reg. No. PO519-03
Dear Michael
BioCore Environmental Limited has been appointed by Gypsum Industries Limited (GIL) in relation to IPPC licence review application Reg. No. PO519-02. Please find additional information in response to your request dated 13" March 201 2.
Yours sincerely
w Peter Carey
BioCore Environmental Limited
cc Limited
Catherina McGuirk, Safety, Health, Environment and Quality Manager, Gypsum Industries
BioCore Environmental Ltd t/a 5ioCore
Clarity House, 1'' Floor, Befgard Road, Tallaght, Dublin 24, Ireland. Conipany registration no. 487194, VAT no. 9755921M
Directors: Mr. Wayne Byrne, Mr. Evan Dolan, Mr. Peter Carey, Mr. Declan Murray
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1. Site boundaries Please submit updated drawings clearly illustrating in red the boundaries of both elements of the installation (i.e. mine site and processing site).
Drawings illustrating the site boundaries, shown in red, for both elements of the installation (i.e. mine site and processing site) are attached.
2. Planning and EIA (i) developments and activities that are currently before the Agency.
Please confirm whether planning permission is in place or is required for all proposed
The only additional activity proposed is to accept and recover waste gypsum at the facility. Infrastructure is already in place for the recovery of the gypsum.
(ii) planning Inspector’s Report.
Where planning permission(s) has been obtained, please provide a copy of the relevant
A list of known planning pennissions has been included in Table 1. It is an extensive list reflecting the time period that this facility has been in operation.
(iii) existing IPPC licence.
Provide an update on any new planning permissions sought or granted since grant of the
A list of known planning permissions has been included in Table 1, which includes planning permissions since the existing IPPC licence was granted on 18/2/2005.
(iv) Please provide written confirmation from the Planning Authority as to whether or not, in their view, an En vironmental Impact Assessment is required for the proposed additional waste gypsum recovery activity.
The letter to the Planning Authority and the response received, which indicates an Environmental Impact Statement is not required, are attached
3. Extractive waste Please provide confirmation as to whether there are heaps or mounds of overburden (Le. soils and stones) at the mine site.
Please see attached Report ‘Classification of Mine Waste Facilities and Operations ’ dated 24/1/2011 relating to the Waste Management (Management of Waste from the Extractive Industries) Regulations, 2009.
The report illustrates that no waste material is generated from quanyingl mining of the gypsum.
To date GIL have not backfilled to the mine. Prior to backfilling GIL will submit a proposal to the EPA for its agreement.
BioCore Environniental Ltd t/a BioCore
Clarity House, 1” Floor, Belgard Road, Tallaght, Dublin 24, Ireland. Conipany registration no. 467194, VAT no. 9755921M
Directors: Mr. Wayne Byrne, Mr. Evan Dolan, Mr. Peter Carey, Mr. Declan Murray
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I Local Authority
Meath CO CO I
Council
Planning Ref No KA I20002
KA I00634
FS7308
FS7310 FS73 I I FS73 12 FS73 I3
KA6048 1
FS6065 U 5 0 2 I I U 5 0 I03
FS4298 U 4 0 4 0 6
U 3 0 I47
I244 97 I32 9683 95358 94955 Q07
87655 861314 80/123 I 7910397
7430
51245
3578 93225 90372 88373
Table 1: A list of planning permissions Date Permission Detail Granted 28/03/20 I2 demolition of an existing storage warehouse and the construction of a rock
stnraoe facilitv includino all ancillarv works 03/09/20 I O of retention modifications to existing car park entrance, retention of extra car
parking spaces, retention of security fencing and security gates and the closure of existing entrance to car park. Also permission to erect 2 no. traffic management signs along main road adjacent to factory, all in the interests of
I safety I Extension to existing offices attached to factory and provision for new changing 25/10/2007 _ _
rooins and training room within existing factory building Construction of 2 new gatehouses for main truck entry and exit routes. New Building for testing and display of products. New single storey office for the recording of goods to and from the factory. Demolition of wing of existing office. and the construction of new wing
25/10/2007 25/10/2007 25/10/2007 25/10/2007
28/02/2007 including canteen i n ground ioor with ortice space above. the demolition of some ancillary buildings, renovations to the facades to main office, construction of new buildings, including new two-storey wing to main office, new goods receivables office, new staff amenities and training room within existing factory, new extension to existing warehouse ancillary offices, new factory shed building for product testing and practical training, new sewage treatment plant, two new gate houses and new internal road arrangement including upgrade ofexisting entrance/exit roads off RI62 and new adjacent exiffentrance roads, parking areas and pedestrian zones, including pedestrian tunnel with revised plans from that submitted under current planning application W 6 0 4 8 1 to include revised site layout and revised site boundaries showing alterations to the red line boundary to include the northern entry/exit for trucks and modifications to the existing telegraph poles, hedgerow and fence, to
I
improve the vehicular sight lines for this exit 2 storey extension to existing western elevation of plaster inill facility the demolition ofexisting uninhabited house the erection of a 4in high extension to its existing steam emission stack at its factory a single storey extension to the side of an existing plaster inill the part demolition of an existing complete stores and partial workshop and extension to the exisiting plaster inill demolishing of existing uninhabitable dwelling house and thereafter restore site
09/05/2006 04/08/2005 09/06/2005
14/02/2005 1811 1/2004
23/07/2003
05/09/2007 Extend the extraction area of the existing permitted opencast gypsum mine to allow for extraction and associated works within the company's property boundary to the permitted dateof2018 (Ref. No.: 83/461). The proposed development area extends to 54.86 hectares (135.56 acres), which includes the permitted extraction area, the proposed extraction area and earthworks associated with this application. An Environmental Impact Statement has been submitted with this application. This application relates to an activity for which an integrated pollution license under part iv of the EPA Act 1992, is required. erect a gypsum rock storage shed , adjacent to it's quarrying facility in Drummond, Magherac loone
2 I /02/2006
7nin7imn~
24/09/1993 I retention of temporary entrance in.0.p. 270/93 10/01/1991 28/10/1988
I retention of ieinporary entrance in o p 530/90 I provision oiteinpornry cntrnnce in o p 393188
BioCore Environmental Ltd Va BioCore
Clarity House, Ti Floor, Belgard Road, Tallaght, Dublin 24, Ireland. Company registration no. 487194, VAT no. 9755921M
Directon: Mr. Wayne Byrne, Mr. Evan Dolan, Mr. Peter Carey, Mr. Declan Murray
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Monaghan CO CO
Monaghan CO CO
8641 5
8346 I
09/04/1987
25/07/1985
erection of processing facilities for opencast gypsum mine at knocknacran east, knocknacran west, derrynascobe, druminond, enaghderrynaglagh and clontrain. development of opencast gypsum mine in townlands of knocknacran west, knocknacran east. derrvnascobe. druminond. derrvnalaeh and enaeh. extension
I 28/02/1966 I erection of leachine nlanr ino.l5/66 I
Monaghan CO C Monaghan CO CO Monaghan CO CO Monaehan Co Co
BioCore Environmental Ltd t/a BioCore
Clarity House, 1" Floor, Belgard Road, Tallaght, Dublin 24, Ireland. Conipany registration no. 467194, VAT no. 9755921M
Directors: Mr. Wayne Byrne, Mr. Evan Dolan, Mr. Peter Carey, Mr. Declan Murray
I I " of time for issuing decision agreed until oct.161984. in.0.p 328/84
83248 29/07/1983 erect dbouse m.0.p.. 278/83 83 158 08/07/1983 erect dbouse m.0.p. 248/83 72498 29/03/1973 extension to dbouse in.o.p36/73 65 I76
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l i
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Comhuirle Chontae na Mi /
Roinn Pleanail, Meallna Mainstreach, Bdthama Mainstreach
An Uaimh, Contae na Mi
R-phost: [email protected] Web: www.rneath. ie F h : 046 - 9097500/F~:046 - 9097001
Mr. Peter Carey, BioCare Environmental Ltd, Clarity House, 1st Floor, Belgard rd, Tallag ht, D.24
Re: Gypsum Industries Ltd, Lisnabow, Kilmainham, Kells, CO Meath Review of IPPC License No PO519-02
Dear Mr. Carey,
I refer to your letter dated 27" April 2012 requesting the following information which has been sought by the Environmental Protection Agency: 'Confirmation, from the Planning Authority, as to whether or not, in their view an Environmental lmpact Statement is required for the proposed additional waste gypsum recovery activity. '
The Planning Authority wish to respond as follows:
The content of your letter dated 27"' April 2012 sets out your opinion that the acceptance of waste gypsum at the existing gypsum recycling plant is not a class of project within Part 1 or Part 2 of Schedule 5 of the Planning and Development Regulations 2001. Your letter also addresses whether or not the acceptance of waste gypsum at the existing gypsum recycling plant requires EIA under the criteria for sub threshold development. Your letter concludes that neither EIA or sub threshold EIA are required.
Based on the information contained in your letter the Planning Authority concur with the opinion expressed there was no statutory requirement for an Environmental lmpact Statement in respect of the acceptance of waste gypsum at the existing gypsum recycling plant.
n Yours sincer 6 1 ly, -- Senior Execu ve Officer,
Planning an ransportation Department
c
Meath County Council \ Planning Dept.,
Abbey Mall, Abbey Road, Navan, Co. Meath.
Tel: 046 - 9097SOO/Far: 046- 9097001 E-mail: info@rneathcoco. ie Web: W O . meath .9
L
5" June 201 2
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Mr Michael Griffin Senior Executive Officer Planning Department Meath County Council County Hall Navan County Meath
27 April 2012
Dear Mr Griffin,
We act on behalf of Gypsum Industries Limited, Lisnabow, Kilmainham, Kells, County Meath. Gypsum Industries has applied to the Environmental Protection Agency (EPA) for a Review of their IPPC Licence PO5 19-02. The application is available to view at http://www.epa.ie/tenninalfour/ir>r>c/ippc- view.isv?renno=P05 19-03. The review application includes allowing for the acceptance of gypsum waste at the existing gypsum recovery facility.
I was given your name as the relevant contact within Meath County Council by Mr. Jim Corcoran, Planning Department, Meath County Council in relation to the request for further information detailed below from the EPA.
Gypsum Industries has received a request for firther information from the EPA, which is attached. This includes a request to:
2(iv) Please provide written confirmation from the Planning Authority as to whether or not, in their view, an Environmental Impact Assessment is required for the proposed additional waste gypsum recovery activity.
We are seeking your concurrence that the acceptance of waste gypsum at the existing gypsum recycling plant does not require an Environmental Impact Assessment (EM).
Background to the Review Applicution Gypsum Industries have an existing gypsum recycling plant located at the process site, that is currently recycling approximately 500 tonnes per month of gypsum process waste (board plant dry waste, board plant wet waste and plaster products dry waste) generated on site. The gypsum recycling plant has additional capacity of approximately 1,500 tonnes per month available. The recycling plant has enabled the installation to close the on site landfill and reduce traditional raw material (gypsum rock) usage. Utilisation of the available capacity at the recycling plant will reduce further use of traditional raw material. Gypsum Industries is aware that there are limited recovery facilities to deal with gypsum waste and there are no disposal facilities for waste gypsum in Ireland.
The gypsum waste material is stored in storage bunkers on a concreted surface prior to processing. The finished product from the recycling process is stored in a covered storage building prior to use in the production process or as a soil conditioner for agriculture.
In order for Gypsum Industries to accept waste gypsum from external sources, the EPA advised that they needed to apply for a review IPPC licence to include Class 1 1.1 ‘The recovery or disposal of waste in a facility’.
BioCore Environmental Ltd Va BioCore
Clarity House, 1’‘ Floor, Belgard Road, Tallaght, Dublin 24, Ireland. Company registration no. 4S7194, VAT no. 9755921M
Directom Mr. Wayne Byrne, Mr. Evan Dolan, Mr. Peter Carey, Mr. Declan Murray
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Matters for Considerations Gypsum Industries is the market leader in plasterboard and plaster, serving the Irish construction industry since 1936. Gypsum Industries processes some 300,000 to 500,000 tonnes of gypsum annually at the plant at Lisnabow, Kilmainham. This material is transported from the mining and quarrying operations that take place at extraction sites located some 4.5km southwest of Carrickmacross, County Monaghan. Clearly, the amounts for recovery are small compared to the imported raw material tonnages.
Gypsum Industries operated an on-site landfill at the Lisnabow site since about 1936 although records of wastes deposited began in only 1970. The landfill was used for the disposal of waste plaster and plasterboard. In the past it was also used for construction and demolition waste, wooden pallets, plastics, and domestic type wastes. This is noted in the EPA’s Inspector Report dated 16th January 2002, relating to the first IPPC application for the premises. Clearly there is a historic precedent for accepting waste to the premises. Gypsum Industries indicates that there was always some recovery of gypsum since start up of the premises, with greater emphasis in later years in line with resource recovery priorities. Since the early 80’s recovered gypsum has been stored in the storage building, which was granted planning permission in 1980 (planning file ref no. 80/1231).
Gypsum Industries have taken a producer responsibility initiative to take back waste gypsum for recovery. In the absence of such an initiative Gypsum Industries is aware that there are limited recovery facilities to deal with gypsum waste and there are no disposal facilities for waste gypsum in Ireland. Gypsum Industries are under increasing pressure from customers to provide a sustainable solution to manage waste plaster and plasterboard. This initiative will provide a much needed facility to ensure proper management of waste gypsum. It has many environmental benefits most notably the recovery of gypsum as opposed to its disposal.
Potential emissions from the recovery process include emissions to water and emissions to air. However, it is not likely that there will be emissions as the gypsum waste material is stored in storage bunkers on a concreted surface prior to processing. The finished product from the recycling process is stored in a covered storage building prior to use in the production process or as a soil conditioner for agriculture. In any event surface water drains to a storage lagoon, where it is reused in the gypsum process or tested prior to release to water body in accordance with existing licence emission limit values. The existing P P C licence requires ongoing ambient monitoring and monitoring of emissions from the entire process plant. Monitoring has not indicated any issues with regards to the existing gypsum recycling plant.
Regulatory Requirements for an Environmental Impact Assessment The acceptance of waste gypsum at the existing gypsum recycling plant is not a class of project within Part 1 or Part 2 of Schedule 5 of the Planning & Development Regulations for which an Environmental Impact Statement (EIS) must be prepared. The criteria governing the need for sub threshold EIA in Schedule 7 of the Planning & Development Regulations and in ‘Environmental Impact Assessment (EIA) - Guidance for Consent Authorities regarding Sub-Threshold Development’ (DOE, 2003) include development characteristics, the sensitivity of the location, and the nature of any impacts. The characteristics of the existing gypsum recycling plant and the overall processing plant; location and nature of impacts have been briefly discussed above. It is considered that the acceptance of waste gypsum at the existing gypsum recycling plant does not require an EIA under the criteria for a sub threshold EIA.
BioCore Environniental Ltd t/a BioCore
Clarity House, 1“ Floor, Belgard Road, Tallaght, Dublin 24, Ireland. Company registration no. 457194, VAT no. 9755921 M
Directors: Mr. Wayne Byrne, Mr. Evan Dolan, Mr. Peter Carey, Mr. Declan Murray
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Your concurrence with the above opinion expressed in this communication is sought. Please contact me at 087 2849490 with any queries concerning this matter or the content of this letter.
With kind regards,
Peter Carey
cc Limited
Catherina McGuirk, Safety, Health, Environment and Quality Manager, Gypsum Industries
BioCore Environmental Ltd tj‘a BioCore
Clarity House, 1” Floor, Belgard Road, Tallaght, Dublin 24, Ireland. Company registration no. 457194, VAT no. 9755921M
Directors: Mr. Wayne Byrne, Mr. Evan Dolan, Mr. Peter Carey, Mr. Declan Murray
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Ms. Catherina McGuirk SHE and Quality Manager Gypsum Industries Ltd Kingscourt Co. Cavan
a Environmental Protection Agency An Ghnlomhoireocht urn ChDomhns Com)uhrroil
13'h March 2012 Reg No: PO5 19-03
Dear Mr. O'Reilly
I refer to your application for a review of your Integrated Pollution Prevention and Control (IPPC) licence, which was received on 19'h January 2012.
I am to advise that in accordance with the provisions of Section 90 of the EPA Acts 1992 to 2007, you are requested to supply additional information so that the Agency may complete a comprehensive assessment of the IPPC application.
1. Site boundaries
Please submit updated drawings clearly illustrating in red the boundaries of both elements of the installation (i.e. mine site and processing site).
2. Planning and EIA
Please confirm whether planning permission is in place or is required for all proposed developments and activities that are currently before the Agency.
Where planning permission(s) has been obtained, please provide a copy of the relevant planning Inspector's Report.
Provide an update on any new planning permissions sought or granted since grant of the existing P P C licence.
Please provide written confirmation from the Planning Authority as to whether or not, in their view, an Environmental Impact Assessment is required for the proposed additional waste gypsum recovery activity.
3. Extractive waste
Please provide confirmation as to whether there are heaps or mounds of overburden (i.e. soils and stones) at the mine site.
Note: Any telephone enquiries in relation to the above should be directed to Michael Owens at the number above. All written communications and replies should be directed to Anne Kehoe, Office of Climate, Licensing & Resource Use, EPA, PO Box 3000, Johnstown Castle Estate, County Wexford.
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You should make immediate arrangements to have the required information (1 signed original, 1 hardcopv and 2 copies of all files in electronic searchable PDF format on CD-ROM) submitted to the Agency without delay. Your response to this request should be directed to Anne Kehoe Administration Officer, Office of Climate, Licensing & Resource Use.
You are requested to submit the infomation by Monday 161h April. Please note that additional notices under Section 90 of the EPA Acts 1992 to 2007 may issue to you as required during the review process.
Yours sincerely,
Inspector Name Michael Owens Office of Climate, Licensing & Resource Use U
Note: Any telephone enquiries in relation to the above should be directed to Michael Owens at the number above. All written communications and replies should be directed to Anne Kehoe, Office of Climate, Licensing & Resource Use, EPA, PO Box 3000, Johnstown Castle Estate, County Wexford.
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Irish Gypsum Ltd. Magheracloone, Co. Monaghan
Classification of Mine Waste Facilities and Operations
Report Date
24'h January 201 1
KD Environmental
17 Eastham Court, Bettystown, Co. Meath
Report No 201 1/10/01
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KD Environmental Irish Gypsum Ltd.
I .O Introduction
KD Environmental were commissioned by Catherina McGuirk of Gypsum Industries Ltd. to conduct an assessment of Mine Waste facilities and Waste Management operations at the Irish Gypsum Ltd. mine site at Magheracloone, Co. Monaghan. This report addresses a request by the EPA to perform such an assessment in order to determine if the Gypsum Industries mine be classified as a Category A site under the Waste Management (Management of Waste from the Extractive Industries) Regulations, 2009.
An on site assessment was performed by David Kelly of KD Environmental on 1 7‘h January 201 1. Areas assessed included Site Processes, Waste Facilities, Surface Waters and Environmental Receptors in the vicinity of the site. During the site assessment information was provided by the Mine Manager, Dave Edwards, and Mine Surveyor, Andrew Ellis.
2.0 Background
Regulation 9(l)(a) of the Waste Management (Management of Waste from the Extractive Industries) Regulations, 2009 requires Mining Companies and facilities to perform an assessment of mine waste produced, mine waste facilities and mine waste management in order to determine if the facility can be classified as a Category A site under the Waste Management (Management of Waste from the Extractive Industries) Regulations, 2009.
Under these regulations the following definitions are given to the extractive industry and extractive waste;
“extractive industries” means all establishments and undertakings engaged in surface or underground exfraction of mineral resources for commercial purposes, including extraction by drilling boreholes, or treatment of the extracted mate rial; “extractive waste” means waste from the extractive industries within the meaning and the scope of these Regulations;
Under Schedule 3 of these regulations, a waste facility is classified as category A if:
a) a failure or incorrect operation, e.g. the collapse of a heap or the bursting of a dam, could give rise to a major accident, on the basis of a risk assessment taking into account factors such as the present or future size, the location and the environmental impact of the waste facility; or
b) it contains waste classified as hazardous under Directive 91/969/EEC above a certain threshold ;or
c) it contains substances or preparations classified as dangerous under Directives 67/548/EEC or 1999/45/EC above a certain threshold.
Report No. 207 111 0/07 Mine Waste Facilities Classification
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KD Environmental lrish Gv~surn Ltd.
EC Decision 2009/337/EC details the criteria for the classification of waste facilities and areas to be assessed in performing this classification. It outlines under what circumstances a facility is classified as Category A. This is seen as being the case if;
a) There is a non-negligible potential loss of life, or b) serious danger to human health, or c) serious danger to the environment.
Under 2009/337/EC the structural integrity of waste facilities, operation of waste facilities, potential danger to the environment, potential for loss of life, integrity of mine tailings dams, the integrity of waste heaps and hazardous and dangerous waste contained at mine facilities is assessed.
3.0 Areas Assessed
In providing for the classification of the waste facilities at the Gypsum Industries mine site the following areas were assessed;
General operations and processes performed on site
Structure and Integrity of Waste facilities and buildings on site
Operation and design of waste facilities on site
Immediate environmental receptors to waste generated on site. RiversNVaterwa ys/La kes Public Roads Surrounding lands and there use Areas of residence and public amenity SAC and Conservations areas
Assessment of the environmental impact on receptors in the event of a structural failure or poor waste management.
Clean up requirement and duration of impact in the event of a structural failure or poor waste management.
Assessment of the threat to human life in the event of a structural failure or poor waste management.
h) Content of dangerous or hazardous waste produced during mining operations
Repolt No. 201 1/10/01 Mine Waste Facilities Classification
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KD Environmental /fish Gypsum Ltd.
4.0 Gypsum Industries Mine Site Assessment
4.1 Gypsum Deposits at the Site
The Gypsum deposit at the Irish Gypsum Ltd. mine at Magheracloone, Co. Monaghan is the largest gypsum deposit in Ireland. The mine site covers a total area of 84 hectares. The fact that the gypsum lies relatively close to the surface makes the gypsum commercially attractive to mine and gypsum can be extracted using open cast mining and underground mining. There is both an open cast and underground mine at the site. Gypsum is removed from the open cast mine at present. There are 2 layers of naturally occurring Gypsum at the site. An upper seam of Gypsum occurs between 1 Om and 40m below ground level and is approximately 1 Om in depth. An interseam of mainly Dolerite and red Marl separates the upper and lower seams of Gypsum. The interseam is approximately 10m deep. The lower gypsum seam is approximately 20-25m deep. The quarry bed comprises of mostly Shale and Basalt.
There is an estimated 3 to 4 years of operating life left in the open cast mine. A further 20 years operating life is left in the underground gypsum mine. In 201 0, approximately 320,000 tonnes of Gypsum was removed from the open cast for processing.
4.2 Mining Operations
Gypsum is removed from the open cast mine at present. Mining operations are summarized as follows;
e Removal of Topsoil and Interseam: The first seam of Gypsum lies below 10 - 40m of topsoil or glacial material. Topsoil is removed using mobile excavators and loaders. Removed topsoil is placed on another area of the quarry floor not currently being excavated. The lower gypsum seam lies below 10m of interseam material comprising mainly of Dolerite and red Marl. This interseam is excavated using mobile excavators and removed by excavators and haul trucks to gain access to the lower gypsum seam. Removed interseam material is placed on another area of the quarry floor not currently being excavated
e Drilling: 100 mm blast holes are drilled in Gypsum deposits to determine the quality and depth of the deposit and to allow for breaking the rock with explosives.
Blasting: The Gypsum deposit is then blasted using commercially available explosives. Each blast will produce approximately 10 - 15 thousand tonnes of materiaVgypsum.
Removal of gypsum rock: Gypsum from blasting is then removed from the quarry using mobile excavators and loaders. Oversized material is further broken down using a hydraulic hammer fitted to an excavator, prior to loading.
Report No. 201 1/10/01 Mine Waste Facilities Classification
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KD Environmental Irish Gypsum Ltd.
0 Crushing: Gypsum rock is crushed using primary and secondary mechanical crushing. This reduces the Gypsum to approx. 75mm rocks.
0 Blending: Crushed gypsum rock is then blended or homogenized in a closed building. Here, gypsum rock is piled to a maximum height of 9 metres. If the homogenizer building is full, excess crushed gypsum is stored in a metal constructed and roofed shed.
A schematic of mine operations is included as Appendix 1 of this report.
The Gypsum is then stockpiled in a metal constructed and roofed shed, closed on 3 sides with an open front for loading access. Gypsum is piled up to a height of approx. 10m. It is then either transported to the Gypsum Industries factory for processing or transported directly to customers for processing. Approximately 20% of material removed from quarrying is gypsum used in processing. The remaining 80% of material comprises of clay, glacial fill, basalt, dolerite, red marl and topsoil. This material stays within the quarry boundary. Topsoil and interseam material removed to gain access to the gypsum upper and lower seams is taken from the quarry floor and filled back into the excavated areas. Therefore, no waste material is generated from quarrying of the gypsum.
4.3 Surface Waters
Surface waters and settled surface water solids are not seen as waste from the site, however they are detailed here as sulphate concentrations in the surface water may be elevated as a result of mining operations. Under Section 13 (1) of the Waste Management (Management of Waste from the Extractive Industries) Regulations, 2009, the operator should take appropriate measures to prevent surface and ground water from being contaminated by extraction waste.
Surface waters that are in contact with gypsum that has been mined are collected from mined areas and pumped to 3 x surface water settling lagoons. Suspended solids are allowed settle before the surface water passes to a final holding lagoon where surface water is held prior to being discharged to the River Bursk. These surface waters may be high in Sulphate as a result of being in contact with exposed gypsum. The surface water is sampled at point MSEl when being discharged from the final settling lagoon. The level of Sulphate in the River Lagan is monitored at point CP1, 70 meters downstream from the discharge point. The River Bursk forms part of the River Lagan catchment area. The river flow level must be sufficient to dilute sulphate to within acceptable levels before the discharge of surface waters. Should the level of sulphate in the river exceed 180 mg/L the discharge from the final lagoon is stopped and the sulphate in the river allowed to return to lower concentrations.
Some surface waters from the site do not come into contact with mined gypsum and are therefore not expected to be high in sulphate. They are generally the surface waters collected from the perimeter of the quarry and are held in a separate lagoon at the North West side of the quarry. Intermittently, these surface waters are analyzed for sulphate concentrations before being discharged to the River Lagan.
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4.4 Structure and Integrity of Waste Facilities
No raw waste is produced from quarrying and processing of gypsum at the mine site. Material is physically removed from the ground, gypsum mechanically sorted from removed material and non-gypsum material is then filled back into the excavated areas.
As in all manufacturing sites, there is some general municipal waste from canteen and washroom facilities. Canteen and domestic waste is removed by a licensed waste contractor. Waste water from washroom facilities is treated at a municipal WWTP. There is also some waste oils and chemicals produced from the workshop on site. These are stored in a designated bunded area and removed from the site by a licensed waste contractor. Oil and diesel bunds have been integrity tested.
Surface waters that are in contact with gypsum that has been mined will have elevated sulphate levels. However, the discharge of surface waters that have elevated sulphate levels is strictly controlled with sulphate levels in the receiving waterbody, the River Lagan, closely monitored. The River Bursk forms part of the River Lagan catchment area. Three lagoons on site hold surface waters to allow solids to settle before the surface water is discharged to the River Bursk. These settling lagoons are not lined and have bases constructed of red Marl stone which occurs naturally on site. Red Marl has a low porosity. The lagoons are flanked on one side by the quarry and on another by the underground mine. Therefore, any leaching surface water from settling lagoons will pass back into the quarry or mine and will re- enter lagoons. This is also the case if surface water should leach from the final holding lagoon. The two initial settling lagoons are 50m x 15m to a depth of 3m with a live capacity of 1 ,000m3. The final settling lagoon is 100m x 15m with a depth of 3m giving a live capacity of 2,250 m3. The holding lagoon is 40m x 40m with a depth of 6m giving a capacity of 4,400 m3.
4.5 Operation of Waste Facilities
There are no leaching operations at the mine site. Mined gypsum is not chemically processed and there are no tailings ponds containing leaching waste water. Gypsum is mined and processed mechanically; it is simply removed from the land and processed as detailed in section 4.2 of this report. There Is no waste generated from mining operations. Any material that is removed from the ground that is not gypsum for processing is filled back into the ground.
Surface waters that are in contact with exposed gypsum deposits are contained on site and only released into the River Bursk when the receiving River Lagan has flow levels sufficient to dilute sulphate levels to within acceptable limits. The surface water lagoons are emptied and settled surface water sediment is removed annually. The removed sediment is filled back into excavated areas of the quarry. The procedure followed in cleaning lagoons is included as Appendix 4 of this report. Removed lagoon sediment is tested for a range of parameters to determine whether it can be classed as inert, stable or hazardous waste. Analysis results are given as Appendix 5 of this report. The sulphate concentration in the sediment breaches Inert waste limits (limit 1,000 mg/Kg, result 15,800 mglKg). However, the sulphate is naturally occurring in Gypsum deposits and the sediment is not a waste. It is refilled back into Report No. 2011/10/01 Mine Waste facilities Classification
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excavation voids in the quarry and not removed from the site. The sulphate level in the sediment is within the hazardous waste limit of 50,000 mglKg and so does not fall within this category. It may therefore be classed as stable non-hazardous waste which has a sulphate limit of 20,000 mg/Kg. The Total Dissolved Solids result is also in excess of the Inert waste criteria and may be classed as stable non-hazardous waste. TDS and sulphate levels are directly related to each other.
Therefore, no waste is generated from mining the gypsum. Material removed is either processed or put back into the site.
4.6 Environmental Receptors
Surface water from the mine site is discharged after settling to the River Bursk. The nearest point on the river to the mine site is approx. 700m. The River Bursk forms part of the River Lagan catchment area that rises in Cavan and enters the sea at Dundalk Bay. Sulphate levels in the river are monitored and surface waters are only discharged when sulphate concentrations are low enough in the river to allow for discharge, ensuring river sulphate levels remain within acceptable limits.
The nearest residential dwelling to the mine site is approximately 150 metres from the boundary of the site. The nearest area of public assembly is the Magheracloone community centre approximately 300 metres from the quarry boundary. The nearest school is approx. 2 Km from the mine.
The R179 Carrickmacross to Kingscourt road runs adjacent to the mine. It is stipulated in planning permission for the mine site that the outer boundary of the quarry excavation cannot come within 20 metres of this road.
There are no Special Areas of Conservation (SAC) in the vicinity of the mine.
4.7 Assessment of Environmental Impact
Raw unprocessed Gypsum is classed as an inert material. Other materials excavated during mining such as clean topsoil and rock (marl, basalt, shale etc ...) are also inert.
Under the Waste Management (Management of Waste from the Extractive Industries) Regulations, 2009, inert waste is defined as;
"inert waste" means waste that does not undergo any significant physical, chemical or biological transformations. Inert waste will not dissolve, burn or otherwise physically or chemically react, biodegrade or adversely affect other matter with which it comes into contact in a way likely to give rise to environmental pollution or harm human health. The total leachabi/ity and pollutant content of the waste and the ecotoxicity of the leachate must be insignificant, and in particular not endanger the quality of surface water andor groundwater. The waste shall fulfil all of the criteria detailed in Commission Decision (EC) No. 2009/359/€C7 or any amendment thereto;
There is little or no mine waste produced during mining operations as material is physically excavated and processed.
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Under Section 13 (1) of the Waste Management (Management of Waste from the Extractive Industries) Regulations, 2009, the operator should take appropriate measures to preveqt surface and ground water from being contaminated by extraction waste. Surface waters that are in contact with gypsum that has been mined will have elevated sulphate levels. However, the discharge of surface waters that have elevated sulphate levels is strictly controlled with sulphate levels in the receiving waterbody, the River Lagan, closely monitored.
4.8 Assessment of Threat to Human Life
The nearest residential dwelling to the mine operation is approximately 150 metres from the boundary of the quarry site. The nearest area of public assembly is the Magheracloone community centre approximately 300 metres from the quarry boundary. There are no large heaps or piles of mined material that pose a threat to human life due collapse. There is no tailings pond or tanks that could pose a risk to human life as a result of tanks bursting or dams breaking. Therefore the threat to human life from mine waste at the Gypsum Industries mine is negligible or non existent.
5.0 Conclusion - Site Classification
The waste facility at the Gypsum Industries mine is not classed as Category A under Schedule 3 of the Waste Management (Management of Waste from the Extractive Industries) Regulations, 2009. None of the below criteria amlv to the Gwsum Industries mine site at Maaheracloone.
a) a failure or incorrect operation, e.g. the collapse of a heap or the bursting of a dam, could give rise to a major accident, on the basis of a risk assessment taking into account factors such as the present or future size, the location and the environmental impact of the waste facility; or
b) it contains waste classified as hazardous under Directive 91/689/EEC above a certain threshold * ;or
c) it contains substances or preparations classified as dangerous under Directives 67/548/EEC or 1999/45/EC above a certain threshold.
(* where the dry matter weight ratio of waste classified as hazardous under 91/689/EEC is less than 5% of total waste weight, the facility shall not be classed as Category A)
The waste facility at the Gypsum Industries mine is not classed as Category A under Article 1 of EC Decision 2009/337/EC. None of the below criteria awlv to the Gvpsum Industries mine site at Maaheracloone.
a) There is a non-negligible potential loss of life, or b) serious danger to human health, or c) serious danger to the environment.
Article 2 of 2009/337/EC is concerned with the structural integrity of waste facilities on site. There are no real waste facilities on site for mine waste as no mine waste is
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produced. Surface water lagoons on site hold all surface water in contact with mined gypsum before discharge to the receiving waterbody.
Article 3 of 2009/337/EC refers to the incorrect operation of waste facilities posing a risk to the environment or human health. There are no mine waste facilities at the mine site as no mine waste is produced. This is therefore not an issue for the Gypsum Industries mine.
Article 4 of 2009/337/EC refers to loss of waste facility structural integrity posing a risk to the environment or human health. Again, there are no mine waste facilities at the mine site as no mine waste is produced. This is therefore not an issue for the Gypsum Industries mine.
Article 5 of 2009/337/EC refers to loss of structural integrity of tailings dams posing a risk to the environment or human health. This is not applicable to the Gypsum Industries mine.
Article 6 of 2009/337/EC refers to waste heap slides posing a risk to the environment or human health. This is not applicable to the Gypsum Industries mine.
Article 7 of 2009/337/EC refers to waste classed as hazardous or dangerous posing a risk to the environment or human health. This is not applicable to the Gypsum Industries mine as no hazardous or dangerous waste is produced from mining gypsum at the site.
Article 8 of 2009/337/EC refers to integrity checks and required procedures for operation of tailings dams. This is not applicable to the Gypsum Industries mine.
Article 9 of 2009/337/EC states that articles 7 and 8 shall not apply to waste facilities containing inert waste or unpolluted soil.
In final conclusion, operations at the Gypsum Industries mine site at Magheracloone, Co. Monaghan determine that the site is not considered a Category A site under the Waste Management (Management of Waste from the Extractive Industries) Regulations, 2009 or under 2009/337/EC.
David Kelly Technical Manager KD Environmental
24th January 201 1
Report No. 201 1/10/01 Mine Waste Facilities Classification
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Appendix 1
Mine Operations Schematic
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Appendix 2
Schedule 3 of the Waste Management (Management of Waste from the Extractive Industries) Regulations, 2009
Report No. 201 7/10/07 Mine Waste Facilities Classification
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Schedule 3
Criteria for determining the classification of waste facilities
A waste facility shall be classified under category A i f
(a ) a failure or incorrect operation, e.g. the collapse of a heap or the bursting of a dam, could give rise to a major accident. on thc basis of a risk assessment taking into account factors such as the present or futurc size, the location and the environmental impact of the waste facility; or
( b ) it contains waste classificd as hazardous under Directive 91/689/EEC"' above a certain threshold: or J ' ?
(c) it contains substances or preparations classified as dangerous under Directives 67/548/EEC' or 1999/45/EC" above a certain threshold.
@ Given under my Official Seal this, 23 December 2009
JOHN GORMLEY. Minister for the Environment. Heritage and Local
Government
"'OJ L377. 31.12.1991. p.20-27 'OJ L 196, 16.8.1967. p. I . Directive as last amended by Commission Directive 2004/73/EC (0.l L
"OJ L 200. 30.07.1999. p.1 Directive as last amended by Commission Directive 2006/S/EC (OJ L 152. ~0.4.2004. p.1)
19.24.1.2006. p.12)
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Appendix 3
Extract from 2009/337/EC
Report No. 20 1 l / l 0/0 1 Mine Waste Facilities Classification
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Extract from 20Q9/ 337/ EC Decision
Article 1
1. A waste facility shall be classified under Category A in accordance with the first indent of Annex I11 of Directive 2006/21/EC if the predicted consequences in the short or the long term of a failure due to loss of structural integrity, or due to incorrect operation of a waste facility could lead to:
(a) non-negligible potential for loss of life;
(b) serious danger to human health;
(c) serious danger to the environment.
2. For the purpose of the classification referred to in paragraph 1, the entire life- cycle of the facility, including the after-closure phase, shall be considered in the evaluation of the hazard potential of the facility.
Article 2
1. For the purpose of this Decision, structural integrity of a waste facility shall mean its ability to contain the waste within the boundaries of the facility in the manner for which it was designed.
2. The loss of structural integrity shall cover all possible failure mechanisms relevant to the structures of the waste facility concerned.
3. An evaluation of the consequences of the loss of structural integrity shall comprise the immediate impact of any material transported from the facility as a consequence of the failure and the resulting short and long term effects.
Article 3
1. For the purpose of this Decision, incorrect operation of the waste facility shall mean any operation which may give rise to a major accident, including the malfunction of environmental protection measures and faulty or insufficient design.
2. An assessment of the release of contaminants resulting from incorrect operation shall comprise the effects of short-term pulses as well as of the long-term release of contaminants. That assessment shall cover the operational period of the facility and as well as the long-term period following closure. It shall include an evaluation of the potential hazards constituted by facilities containing reactive waste, regardless of the classification of the waste as hazardous or non-hazardous under Council Directive 91/689/EEC [3].
Article 4
1. Member States shall assess the consequences of a failure due to loss of structural integrity or incorrect operation of a waste facility in accordance with paragraphs 2, 3 and 4.
2. The potential for loss of life or danger to human health shall be considered to be negligible or not serious if people other than workers operating the facility that might be affected are not expected to be present permanently or for prolonged periods in the potentially affected area. Injuries leading to disability or prolonged states of ill-health shall count as serious dangers to human health.
3. The potential danger for the environment shall be considered to be not serious if:
(a) the intensity of the potential contaminant source strength is decreasing significantly within a short time;
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(b) the failure does not lead to any permanent or long-lasting environmental damage;
(c) the affected environment can be restored through minor clean-up and restoration efforts.
4. I n establishing the potential for loss of life or danger to human health or to the environment, the specific evaluations of the extent of the potential impacts shall be considered in the context of the source-pathway-receptor chain.
Where there is no pathway between the source and the receptor, the facility concerned shall not be classified as Category A on the basis of failure due to loss of structural integrity or incorrect operation.
Article 5
1. In the case of loss of structural integrity for tailings dams, human lives shall be deemed to be threatened where water or slurry levels are at least 0,7 m above ground or where water or slurry velocities exceed 0,s m/s.
2. The assessment of the potential for loss of life and danger to human health, shall comprise at least the following factors:
(a) the size and properties of the facility including its design;
(b) the quantity and quality including physical and chemical properties of the waste in the facility;
(c) the topography of the facility site, including damping features;
(d) the travel time of a potential flood-wave to areas where people are present;
(e) the propagation velocity of the flood-wave;
(f) the predicted water or slurry level;
(9) the rising rate of water or slurry levels;
(h) any relevant, site-specific factors that may influence the potential for loss- of- life or for danger to human health.
Article 6
1. In the case of waste heap slides any waste-mass in movement shall be deemed likely to threaten human lives if people are staying within range of the moving waste-mass.
2. The assessment of the potential for loss of life and danger to human health shall comprise a t least the following factors:
(a) the size and properties of the facility including its design;
(b) the quantity and quality including physical and chemical properties of the waste in the facility;
(c) slope angle of heap;
(d) potential to build up internal groundwater within the heap;
(e) underground stability;
(9 topography;
(9) proximity to water courses, constructions, buildings;
(h) mine workings;
(i) any other site-specific factors that may significantly contribute to the risk posed by the structure.
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Article 7
1. The threshold referred to in the second indent of Annex I11 of Direchve 2006/21/EC shall be determined, as the ratio of the weight on a dry matter basis of:
(a) all waste classified as hazardous in accordance with Directive 91/689/EEC and expected to be present in the facility at the end of the planned period of operation, and
(b) waste expected to be present in the facility at the end of the planned period of operation.
2. Where the ratio referred to in paragraph 1 exceeds 50 YO, the facility shall be classified as Category A.
3. Where the ratio referred to paragraph 1 is between 5 O/O and 50 YO, the facility shall be classified as Category A.
However, that facility may not be classified as Category A where it is justified on the basis of a site specific risk assessment, with specific focus on the effects of the hazardous waste, carried out as part of the classification based on the consequences of failure due to loss of integrity or incorrect operation, and demonstrating that the facility should not be classified as Category A on the basis of the contents of hazardous waste.
4. Where the ratio referred in paragraph 1 is less than 5 %, then the facility shall not be classified as Category A on the basis of the contents of hazardous waste.
Article 8
1. Member States shall assess whether the criterion set out in the third indent of Annex I11 of Directive 2006/21/EC is met in accordance with the considerations set out in paragraphs 2, 3, and 4.
2. For planned tailing ponds, the following methodology shall be used:
(a) an inventory shall be carried out of the substances and preparations which are used in the processing and which are subsequently discharged with the tailings slurry to the tailings pond;
(b) for each substance and preparation, the yearly quantities used in the process shall be estimated out for each year of the planned duration of operation;
(c) for each substance and preparation, it shall be determined whether it is a dangerous substance or preparation within the meaning of Council Directive 67/548/EEC [4] and of Directive 1999/45/EC of the European Parliament and of the Council [5];
(d) for each year of planned operation, the yearly increase in stored water (AQi) within the tailings pond shall be calculated under steady state conditions according to the formula set out in Annex I;
(e) for each dangerous substance or preparation identified in accordance with point (c), the maximum yearly concentration (C max) in the aqueous phase shall be estimated according to the formula set out in Annex 11.
If, on the basis of the estimation of the maximum yearly concentrations (C max), the aqueous phase is considered to be "dangerous" within the meaning of Directives 1999/45/EC or 67/548/EEC, the facility shall be classified as a Category A facility.
3. For operating tailings ponds, the classification of the facility shall be based on the methodology set out in paragraph 2, or on direct chemical analysis of the water and solids contained in the facility. I f the aqueous phase and its contents have to be considered as dangerous preparation within the meaning of Directive 1999/45/EC or 67/548/EEC, the facility shall be classified as a Category A facility.
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4. For heap leaching facilities, where metals are extracted from ore heaps by percolating leach solutions, Member States shall undertake a screening for dangerous substances at closure based on an inventory of used leach chemicals and the residual concentrations of these leach chemicals in the drainage after washing has been finalised. I f these leachates have to be considered as dangerous preparation within the meaning of Directives 1999/45/EC or 67/548/EEC, the facility shall be classified as a Category A facility.
Article 9
Article 7 and 8 of this Decision shall not apply to waste facilities containing inert waste or unpolluted soil only.
Article 10
A review of the classification shall be carried out by the competent authority within the meaning of Directive 2006/21/EC where the permit is substantially modified or the operational conditions have changed significantly.
That review shall be carried out at the latest at the end of the operational period of the facility.
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Appendix 4
Gypsum Industries Lagoon Cleaning Procedure
Report No. 201 111 0/01 Mine Waste Facilities Classification
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Subject
Owner: Author: Date of Issue:
1.
1.
2.
Lagoon and Drain Cleaning Procedure Dave Edwards Document No. ENV40 Kingscourt Debra O’Reilly Rev. 1 Park West 09 August 2010 Mining J
Purpose
The purpose of this procedure is to ensure that lagoon and drain cleaning is carried out to minimize
the amount of settleable and suspended solids discharged at MSE-1.
Scope
2.1 This document applies to the lagoons located at the mine site and also the drains, and grit traps at
both the wheel washes and at the quarry.
3. Responsibility
3.1 Mine Manager
3.2 Maintenance co-ordinator
3.2 Environmental Manager
4. General
4.2 Each lagoon must be fully inspected and cleaned out as required every second year, Grit traps, and
4.3 It is the responsibility of the mine manager to ensure that this inspection/ cleaning is carried out.
4.3 Quarterly preventative maintenance tasks have been set up on Pemac to clean the grit traps at the
wheel wash, the lagoon drains and drains at the quarry. This is completed in order to reduce the
amount of settleable and suspended solids discharged at MSE-1 to ensure that they do not give
rise to settleable solids of greater than 5mg/l or suspended solids of greater than 25mg/l as per our
IPPC licence PO519-02
drains are cleaned out every quarter.
4.4 The following equipment is required for lagoon cleaning:
0 Dieci teleporter
0 Tractor with water pump
0 A25 & A40 dump truck with tailgates
4/ 20 ton excavator x 2
0 Tractor with water tanker
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Subject
Owner: Author: Date of Issue:
5. Procedure:
Lagoon and Drain Cleaning Procedure
09 August 2010 Mining J
Dave Edwards Document No. ENV40 Kingscourt Debra O’Reilly Rev. 1 Park West
5.1 To clean the large lagoon:
0 The flow of water to the large lagoon is stopped by closing the main drain supply & closing the
gate valve which links large lagoon to the smaller lagoons.
The dieci teleporter lowers a water suction hose into the large lagoon below the water line, this
is then connected to the suction side of a water pump which is connected to a tractor for power,
a water hose is attached to the outlet of the pump & placed in the smaller lagoons.
The water is then pumped from the large lagoon to the smaller lagoons and a 20 ton excavator
with bucket removes the silt from the lagoon & places it in the rear of A25 & A40 trucks.
The trucks then take the silt to a purpose built containment area with bund controls.
A25 & A40 dump trucks with tailgates; to prevent silt spillage between the lagoon & containment
area are used on site to transport the silt.
Internal roads are watered to keep dust down while the slit is being transported.
0
0
e
o
0
5.2 To clean the small lagoons the steps above are repeated, with the exception that the water is
pumped from the smaller lagoons into the larger lagoon.
5.3 To clean the open drains and sumps:
e Prior to cleaning, ensure that discharge from MSE-1 is stopped and that the final lagoon level is
reading less than 20% full, this allows adequate settling time for solids agitated during cleaning
to settle out.
Prior to pump installation sumps are dug out to size in consultation with the Site Surveyor who
will give specific depths.
0 All quarry pumps are, on installation, placed on a float switch with consideration being given to
expected volumes of water.
0 All sumps and drains are inspected on a daily basis by the Quarry Team Leader.
0 Cleaning is carried out as and when required (where earthworks are being carried out the the
frequency will increase if required) subject to the above inspection and on approval from the
Quarry Superintendent.
Cleaning is carried out in dry weather where possible.
0
0
Sumps drained.
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vi! Procedure
Gypsum Industries
0
0
0
0
All Quarry pumps switched off.
Cleaning of open drains and sumps carried out using Cat Excavator and Volvo A40E.
Silt is removed to bunded area.
On completion an inspection is carried out by the Team Leader to ensure that depths and
banks have not being compromised.
Float switches are then raised to maximum to allow sufficient settlement time.
Test the lagoon contents for suspended solids and ensure that sample obtained is below 25mg/l
prior to allowing discharge at MSE-1 to recommence.
0
0
Subject
Owner: Author: Date of Issue:
5.4 To clean pipe drains and grit traps:
0
e
J.C drains are contracted to clean site drainage pipes and the grit traps.
Prior to cleaning, ensure that discharge from MSE-1 is stopped and that the final lagoon level is
reading less than 20% full, this allows adequate settling time for solids agitated during cleaning
to settle out.
Test the lagoon contents for suspended solids and ensure that sample obtained is below 25mg/l
prior to allowing discharge at MSE-1 to recommence.
0
Lagoon and Drain Cleaning Procedure
09 August 2010 Mining J
Dave Edwards Document No. ENV40 Kingscourt Debra O’Reilly Rev. 1 Park West
Description Frequency Plant item Number
Large Lagoon Every 2 years 1 10-9000-00
Job Number
19
Table 7.7 Lagoon and drain cleaning details
Small Lagoons
Drain
Grit Trap
Last Printed: 17/01/2011 Paae 3 of 3 Document No:ENV40 Rev 1
Every 2 years 1 10-9000-00 20
Quarterly 1 10-9000-00 06
Quarterly 1 10-9000-00 06
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EPA Export 23-06-2012:04:37:04
KD Environmental Irish Gypsum Ltd.
Appendix 5
Settlement Lagoon Sediment Analysis
Report No. 201 1/10/01 Mine Waste Facilities Classification
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