Environmental Protection AgencyHeadquarters PO Box 3000Johnstown Castle Estate,County Wexford

13h October 2006

Attn: Ms. Liz Leacy

Re IPCL Review Register No. P003$04

Dear Ms. Leacy

^lNA.VV

Aughinish AluminaAughinish Alumina LimitedAughinish lslandAskeatonCo, Limericklreland

Teleohone: 061-604000

Facsimile:-.Adminiskation/Plantotfice 061-604001. Accounts 061 -604031. Purchasing 061-604023

Website; www.auqhinish.com

DIRECTORS:Chairman: S, Blumgart (South Akican), Managing: D,A Clancy,D, Goldberg (South Atrican), V, Bosino (ltalian),

Reg in lrsland No 59982 Beg, ollicei Aughinish lsland, Ask8aton, Co Limeilck, keland

Further to your Dr. Derham's letter of 29h September 2006 to our Mr. Fleming requiring specificinformation to be supplied in accordance with Article 14(2) (b) of the Licensing Regulations,Aughinish Alumina submits the following attached response in relation to the future wastemanagement requirements for the facility beyond the planned life expectancy of the applicationcurrently before the Agency i.e the extended Phases 1 and2 Bauxite Residue DisposalAreas.

Aughinish Alumina does not propose to change the Non Technical Summary of the EIS on whichLimerick County Gouncil gave planning permission and which decision is cunently beingappealed by third parties to An Bord Pleanala for the following reasons :

o The issues raised by the Agency with regard to the waste management reguirementspost 2026 would require a separate planning application including an Environmentallmpact Statement submitted to Limerick County Council as well as a future application tothe Agency for a review of the future IPPC License. The issues to be studied in such afuture EIS could not be accurately summarised in the current EIS as it's scope can onlyaccurately assess the likely significant impacts of this current development underreview by the Agency and also pending planning permission from An Bord Pleanala.

o The issues which are raised in summary form in the attached response are in fact some ifnot all of the altematives to be studied in the context of a future feasibility report forresidue disposal and storage post 2026. On the basis that these would be thealtematives for the possible waste management scenario post 2026, they are not theMain Altematives for this cunent EIS which the Applicant is obliged to have studied indetail in the curent ElS, which addresses the impact of residue disposal in the period2009 to 2026.

o Notwithstanding the above, even lf the information being submitted to Agency now hadalready been contained albeit in the attached summary form in the original Volume 2 ofthe ElS, this particular information would not have been summarised to be specificallyincluded in the existing Non TechnicalSummary.

o The Applicant cannot make an unqualified statement at this stage that there will be adefinite requirement for residue disposal in the period post 2026.

I encfose as requested 1 signed original, 2hard copies and 18 electronic searchable PDF copieson CD-ROM. Please contact Mr. Fleming or myself if you require any clarification of the attached.

Consultant EngineerAughinish Alumina Ltd

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Reg No. P0035-04 Submission to the Agency October 2006

SUBMISSION TO THE AGENCY OCTOBER 2006

Agency Question March 2006

1. The proposed extension is suggested to take the red mud disposal capacity availability up to the year 2025. Noting the pollution control infrastructure proposed, please document what the likely disposal requirements would be (under expected operational conditions) for the period beyond 2025; and, having regard to the arguments in Section 5.3.1 of the ElS, where would this(ese) landfill(s) likely be located?

The residue disposal requirements will at a minimum in quantity terms remain the same post 2026 as per

• Table H(i) and Table H(ii) of the Review Application

• The alumina production quantities stated in the table in Sections’ 2.1 of both Attachment D1 and Attachment D2 of the Review Application

There will be no change in the type and variety of residue to be disposed post 2026 as outlined in those tables above. The Applicant cannot propose any alumina or residue production data in excess of the values in the referred tables because any such production scenario would require a separate planning application and probably an EIS to the Planning Authority. Such a scenario cannot be contemplated nor has not been studied at this stage.

It is very unlikely that the alumina plant will have the appropriate equipment installed and the existing processing equipment de-bottlenecked to enable the production capacity of 1.95 million tonnes per annum before the year 2010 to be implemented. The effect of seeking to increase production beyond 1.95 mtpa at some period post 2010 would inevitably reduce the storage life of an extended Phase 1 and 2 BRDA and would require additional study to determine the investment return on such capacity replacement and other factors for such a scenario. Such a scenario has not been investigated in 2006.

However whereas the possible residue disposal requirements post 2026 are listed above the residue storage capacity locations post 2026 are also influenced by several factors.

1. The principal business factor affecting that scenario would be the cost of developing such residue disposal capacity and the projected effect of such a cost on the competitiveness of the ongoing alumina production operation.

2. The nature conservation and habitat (Natural Heritage Area, candidate Special Area of Conservation, Special Protection Area) pNHA, cSAC and SPA designations respectively immediately in and around Aughinish Island are shown in Figures 12.1 to 12.3 of Volume 2 of the EIS. The location and context of the Aughinish Alumina manufacturing facility and its current land bank has recently become landlocked within the SPA and cSAC habitat designations is shown in Figures 1.1 and Drawing 00-G-1107 ROO attached.

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Reg No. P0035-04 Submission to the Agency October 2006

3. The footprint of the combined Phase 1 and Phase 2 BRDA is also subject to a number of physical constraints The site of this current proposed extended Phase 1 and Phase 2 BRDA is restricted to land already in the ownership of AAL and is physically bounded by :

• Bird Sanctuary (cSAC) and River Shannon (cSAC & SPA) to the north

• Robertstown River (cSAC & SPA) to the west,

• The railway line to the south

• The Limerick County Council (LCC) rising water main also to the south, as well as to the south east and north east

• The LCC water treatment plant to the south east,

• The Sports Complex and also the disused quarry to the east and this quarry have been recently preserved by Aughinish Alumina in conjunction with Bird Watch Ireland as a butterfly sanctuary.

Section 4.1 and Table 4.1 of The Update of the Residuals Management Plan submitted in Attachment K of the Review Application indicates that the BRDA will reach it full capacity in approximately 2026.

As regards the scenario post 2026, the obvious various options would be examined and in conjunction with the information available to AAL, the statutory authorities and other stakeholders at that stage, would either be dismissed or considered as possible or probable options. The development of such bauxite residue disposal capacity for this scenario would require a separate and future planning application and a further review of the future Integrated Pollution Prevention and Control License and the necessary definitive feasibility studies and other reports for such a post 2026 scenario have not been initiated at this stage in 2006.

CONCLUSION

The option of taking the extended Phases 1 & 2 BRDA beyond Stage 10 could only deliver a marginal, short term increase in residue storage capacity and this option would not secure either the medium term or long term future of residue storage and therefore the lifespan of the alumina plant post 2026.

The option of developing a Phase 3 BRDA site within the existing land bank will only be viable if a suitable site can be found inside and around the locations that are currently landlocked by the cSAC and SPA habitat designations and it is extremely unlikely that these habitat designation will be removed in the future or that NPWS would agree to development on these habitats to enable suitable sites to be enlarged. The remaining areas not affected by the cSAC constraint do not appear at this stage to be large enough and therefore it is extremely unlikely that it would be contemplated just to get less than 3 years or so of further extended BRDA capacity.

The option of developing a Phase 3 BRDA outside the existing land bank could be possible only if a suitable site was identified. Management of local resident community issues would be an integral and challenging part of the feasibility of such a development.

The option of the closure of the entire production plant following Phase 2 BRDA capacity consumption cannot be accurately forecasted at this time.

On that basis, following a future feasibility study Aughinish Alumina will seek to develop a Phase 3 BRDA if it is possible and if the cost of developing and operating the Phase 3 BRDA does not significantly erode its competitive position in the market place.

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F l o o d s

HW

M

MORGANS NORTH

MORGANS SOUTH

GLENBANE EAST

Spring

t o

L i a b l e

FAWNAMORE

HW

M

P o

u l a

w e

a l a

C

r e

e k

Quarry

Quay

on SM

HWM

Quarry

Pond

Quarry

GLENBANE WEST

Liable to floods

Waterworks

HW

M

HW

M

HW

M

Causeway

Sprin

g Tid

es

Complex

HWM

HW

M

Mud

Covered by Spring Tides

Mud

Sluice

Covered by

Spring Tides

Mud

Sports

AUGHINISH EAST

Sports Ground

Mud

Covered by

ISLAND MAC

TEIGE

Sluice

Rober tstown River

Pipe

CHURCHFIELD

Pond

POND

Pond

Pond

POND

MU

D D

RAIN

POND

RO

BER

TSTO

WN

RIV

ER

ARDANEER

Scale: NTS

Notes

Approved:

Checked:

Title

Project

Issue Details

Drawn:

1. This drawing is the property of RPS Group Ltd. It is a confidential document and must not be copied, used, or its contents divulged without prior written consent.2. All levels are referred to Ordnance Datum, Malin Head.3. NOT TO SCALE, use figured dimensions only, if in doubt ask.4. Ordnance Survey Ireland Licence No. EN 0005005 Copyright Government of Ireland.

Figure

Physical Constraintson Phase 2 BRDA

Boundaries

IPCL Review Register no. 754

1.1

Rev.

File Ref.

Date: 09/05/2006

AG/MC

D01

SK Project No. MDE0168

Drawing No.

MI0059

West Pier Business CampusDun LaoghaireCo. DublinIrelandPhone: 01 - 2884499Fax No. 01 - 2835676rpsmcos@rpsgroup.ie

MDE0168MI0059D01

Aughinish Alumina Ltd.

LCC Water Pipe LCC Water Pipe LCC Water Pipe

LCC Water Treatment Plant LCC Water Treatment Plant LCC Water Treatment Plant

24" Water main into Plant 24" Water main into Plant 24" Water main into Plant

Legend

All_SAC Legend

Legend

Proposed Phase2BRDA Boundary

SACs

SPAs

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