I INTRODUCTION 1.1 PREFACE

This application for an Integrated Pollution, Prevention and Control (IPPC) Licence has been prepared

in order to update and revise the existing IPPC Licence (Licence Register Number W487-06) which

was granted by the Environmental Protection Agency (EPA) in March 2012.

Lagan Cement was first granted an IPPC Licence on 21 May 2001. Register Number P-0487-01, for

the manufacture of cement and the operation of two quarries at the installation. The licence was

since reviewed as follows;

Licence Revision

No.

P-0487-02

P-0487-03

P-0487-04

P-0487-05

P-0487-06

Date Granted

November 2003

May 2006

May 2008

January 2009

March 2012

Principal Reason for Review of Licence

Increase production of cement from 450,000 tonnes per

annum to 6000,000 tonnes per annum.

Burn waste and bone meal as a fuel

Introduce waste as raw material and fuel sources.

Increase cement production form 6000,000 tonnes per

annum to 7000,000 tonnes per annum. New concrete

products production plant - dry mortar plant, paving plant

and tiling plant.

Facilitate the introduction of additional wastes types,

namely SRF (solid recovered fuel and TDF (tyre derived

fuel)

Facilitate the introduction of additional wastes types,

namely LRF (liquid recovered fuel) and to increase the

extent of the quarrying operations over lands to the north,

east and south.

This IPPC Licence Review application is primarily being submitted in order to repeal the Air

Overpressure limits at the nearest sensitive locations which were reduced by the EPA in the most

recent IPPC Licence for the site - PO487-06 from 125dB(lin) max. peak to 120dB(lin) max. peak.

I n addition, the licensee also seeks the following amendments:-

section 1: Introduction IPPC Licence -7-06 - Review

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1. Increase the emission limit value for Total Organic Carbon from 10 mg/m3 to 40mg/Nm3 for

emission point A2-01 for the co-incineration of waste in order to accommodate varying

organic fractions within the raw materials and to bring the licence into line with TOC limits

recently granted to another Republic of Ireland based cement producer.

2. Amend the storage volumes permitted for Liquid Recovered Fuel (LRF) in Condition 8.9(b) of

PO487-06 from 20,000 litres to 150m3. The permitted use of LRF in PO487-06 is 20,000

tonnes per annum. This equates to a use of approximately 60 tonnes per day. Therefore, the

permitted storage of 20 tonnes is inadequate.

The previous IPPC Review requested an increase the extent of the existing quarrying operations at

the Lagan Cement manufacturing facility in Killaskillen, Co. Meath, the planning application for which

required the preparation of an Environmental Impact Statement (EIS). The previous IPPC Review also

broadened the range of alternative fuels used as part of Lagan Cement’s sustainable fuel programme,

including up to 20,000 tonnes of Liquid Recovered Fuels (LRF). The purpose of the sustainable fuel

programme is to further reduce Lagan Cement‘s dependence on imported fossil fuels. Lagan Cement

is currently licensed to use 95,000 tonnes of alternative fuels per annum and the most recent IPPC

Licence review did not alter the volume of alternative fuels used on site. The complete list of

European Waste Catalogue Codes permitted for use on site can be seen in detail in Attachment H.

This IPPC Licence review for the Lagan Cement manufacturing facility in Killaskillen, Co. Meath, has

not required a planning application or the preparation of an Environmental Impact Statement (EIS).

IPPC Lice- pw87-06 - Review

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Lagan Cement Ltd has operated the Lansdown Cement Works and associated limestone and shale

quarries on their lands at Killaskillen, Kinnegad, CO Meath since August 2002. The cement works

comprises state of the art facilities that have been designed by an international authority on cement

works equipment and accommodates the most modern environmental protection measures. It is a

€100 million development providing a total of approximately 100 no. jobs directly and further

significant employment for local service industries such as contract haulage and quarrying activities.

Lagan Cement Ltd is the most modern cement manufacturing plant in Ireland and at present, the

plant produces approximately 700,000 tonnes of cement per annum.

The site on which the plant is located covers 264.06 hectares and contains a shale quarry, a

limestone quarry, both of which supply raw materials for the cement manufacturing process, and

lands in agricultural use. It lies southwest of Kinnegad and north of Ballinabrackey in County Meath.

It is approximately 60km by road from Dublin and Athlone, and Mullingar is located approximately

17km to the northwest. The Site Location and the layout of the site are detailed in Attachment B.l.

Lagan Cement Ltd has previously undergone IPPC Licence reviews to permit the use of alternative

fuels at their facility in Kinnegad. The most recently permitted fuels comprise of Solid Recovered Fuel

(SRF), Tyre Derived Fuel (TDF) and Liquid Recovered Fuels (LRF) as well as a range of carbon neutral

biofuels including wood chips, recycled wood including construction and demolition (C & D) timber,

sawdust, and residues derived from the sawmill and forestry industry; agricultural products and

residues such as energy crops, cereals and grains; bio-sludge from the water treatment industry; and

biodiesel and bioethanol, and their derivatives. Lagan Cement Ltd already has permission to burn

coal, Pet Coke, fuel oil and meat and bone meal (MBM) and has over six years experience of using

MBM as an alternative fuel source in the cement kiln.

The cement manufacturing facility has been 100% compliant with the requirements of the Waste

Incineration Directive as managed through their IPPC Licence since they commenced burning

alternative fuels (MBM) in 2006. The Waste Incineration Directive sets out the legal operational and

environmental standards which the facility must comply with when burning any form of waste derived

alternative fuel material.

Section 1: Introductkn IPPC licence W487-06 - Review PaOe 3

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1.3 QUARRYING ACTIVITES

The area of the Lagan Cement Ltd. overall landholding in the vicinity of Kinnegad is 264.06 hectares.

The area of the most recently permitted quarry extension site is 109.451 hectares. The lands

surrounding the quarry area can be described as rural in character and the nearby residential

dwellings can be described as one-off dwellings fronting onto county roads outside the perimeter of

the site. The village of Ballinabrackey is located between approximately 300 - 600m south of the

quarry application site. The lands into which the quarry has extended to date and will continue to do

so in the future predominantly comprise of agricultural lands. However, there is also an area of

cutover peat bog to the south of the existing limestone quarry. The further quarry extension will

require the rerouting of llOkv ESB lines in the long term.

The existing limestone quarry and cement works were granted planning permission by Meath County

Council in April 1999 and this decision was subsequently upheld by An Bord Pleanala in April 2000. The existing quarry is permitted over an area of 24.8 hectares and to a depth of 75 metres, i.e. 5 benches at 15 metre intervals to a depth of approximately 10 AOD. The existing limestone quarry is

permitted over an area of 24.8 hectares and to a depth of 75 metres (i.e. 5 no. benches at 15 metre

in terva Is).

section 1: Intraductkn Ippc Licence PO487-06 - Review psge 4

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Figure 1.1: Previously permitted Limestone Quarry illustrating the Final Quarry Void

a

Source.: Environmental Impact Statement (Meath County Council Planning Reg. Ref. No. 98/2026 and An Bord Plean6la Ref.

No. PL 17.111198); Extract from Drawlng No. 2.1.16.

Lagan Cement Ltd. will extend the existing quarry over lands to the north, east and south. The

extension to the existing limestone quarry will be to a depth of 1 bench at approximately 70 metres

AOD. This extension will increase the surface area of the quarry by approximately 52.45 hectares

over 3 No. phases. The extension will result in a final overall extracted area of 77.25 hectares and

extend the life of the quarry by up to 20 years. The extension will not result in any increase to the

associated permitted production capacity of the cement plant.

The extension of the quarry over a single bench will safeguard the strategic limestone reserve

available to Lagan Cement Ltd. The quarry extension will also help Lagan Cement Ltd to produce

cement more efficiently, based on the following:

section 1: Inboduction

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1) It makes better economic and operational sense to quarry the limestone from a wider

footprint, before starting to quarry at greater depths. For example, a consequence of going to

deeper benches is that Lagan Cement Ltd would have to increase the size of their vehicle fleet, at

considerable cost, to compensate for the longer journeys between the working quarry faces and the

crusher. This would also result in higher COz emissions.

2) Working a quarry over a single bench for a longer period simplifies quarry management and

will reduce the number of times that the existing crushing plant and conveying equipment will have to

be moved. Moving installed crushing and conveying plant is expensive and time consuming, and the

relocation of this plant can take several months.

The workings of the quarry extension area will be continued as follows:

1. Blasting of rock faces,

2. Transport to crusher,

3. Crushing,

Stockpiling, and

5. Conveying to the cement plant.

Each of these steps is summarised below.

J. Blastina of rock faces To provide limestone feed to the cement mill, the active rock face must be blasted, at regular

intervals, using an ammonium nitrate fuel oil mix. Using specialist blasting contractors, holes are

drilled in the rock face and the blasting mix is added. - Once blasting has occurred, large rock chunks are transported, using very large (60 tonne) mobile

equipment, to a crusher, which is located on the quarry floor.

3. Crushinq

There are two crushing stages, primary crushing and secondary crushing. Each crusher consists of a

set of electrically operated rotating drums, which function to reduce the particle size of the rock to a

scale that can be easily transported using belt conveyors.

4. Stockding

IPPC Ucence poru)7-06 - Revlew

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An essential part of quarry operation is the stockpiling of crushed material. These stockpiles act as

reserves in the event of a crusher or mobile equipment failure.

5. Convevi ng A long belt-conveyor is attached to the out feed point of the crushing equipment. This conveyor

transports the crushed rock to the cement mill for further processing.

1.3.1 Quarrying Operational Plan

The operational plan for the quarry has been upgraded in light of the planned development of the

quarry extension. Each of the three phases of the proposed operation are summarised below.

Phase 1: Deve loment o f Northe rn Extension to a Depth of 70 metres AOD

Initially, limestone will be extracted in a northerly direction to the maximum permitted lateral extent

of the quarry. This bench will be worked to a depth of approximately 70 metres AOD and therefore

represents a continuation of the first production bench currently being worked at the quarry. The

production benches will be at least 30 metres wide and will have sub-vertical faces. All production

benches will be subject to ongoing geo-technical monitoring on a regular basis in keeping with the

highest industry standards, best industry practice, and current health and safety regulations and

guidelines (SXety, Health and Welhte at Wok (Quamess) Regula~ons, 2008 (S.I. No. 28 of 2008)).

unce the production benches have been extended to their permitted limits, two new haul

roads/ramps will be constructed to a maximum width of 20 metres with sufficient space for a

protective barrier and drainage, with a down-ramp slope of 1 in 12 to the 70 metres AOD level along

the western side of the quarry. These ramps will act as the main access routes to both the northern

and southern parts of the quarry void.

On reaching their maximum permitted extraction limits, production benches will have final bench

widths of 7.5 metres, final maximum bench heights of 15 metres and final bench slopes of about -70'

from the horizontal, depending on the geo-technical quality of the rock. This will ensure the long-

term stability, integrity and safety of the final quarry design.

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Overburden will be stripped in a controlled and phased manner ahead of the quarry face with batters

of 1 in 2 being proposed. Materials from the stripping will be used in the construction of additional

screening berms along the northern side of the site (with batters of 1 in 2.5 being proposed).

Berms are a common tool used in the quarrying process. These landforms are constructed of

'overburden' material recovered from above the rock suitable for extraction. This overburden consists

of topsoils and subsoils which are valuable for final restoration purposes. The material is therefore

carefully maintained and managed in berms or bunds which are usually located at the boundaries of

quarry site, The berms (bunds) perform a number of tasks besides that of maintaining soil fertility, in

that they act as visual, aural and environmental barriers for neighbouring land uses.

Figure 1.2: Phase 1 of Proposed Quarry Extension (Northern Extension)

L.

Source: SM Bennet & Co LM (December 2008)

IPPC Ucenca PWE7-06 - R e W

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Cement

Phase 2: Develooment of South -Eastern and South-Western Extensions to a Dent h of 70

metres AOD

Towards the completion of Phase 1, overburden will be stripped in a controlled and phased manner in

a south-easterly and south-westerly direction and will be used in the construction of screening berms

around the south-western and south-eastern boundaries of the site. Topsoil and overburden used in

the construction of the screening berms will be used in the final restoration of the quarry void and the

site as a whole.

Limestone will be extracted in a south-westerly and south-easterly direction towards the maximum

permitted lateral extent of the quarry down to a depth of about c.70m AOD and will be a continuation

of the production bench currently being worked at the quarry. The production benches will be at

least 30 metres wide and will have sub-vertical faces. All production benches will be subject to

ongoing geo-technical monitoring on a regular basis. Production benches will have final bench widths

of 7.5171, final maximum bench heights of 15m and final bench slopes of about -70' from the

horizontal, depending on the geo-technical quality of the rock. This will ensure long term stability,

integrity and safety of the final faces. It is proposed to extract limestone from around the asphalt

plant complex during this phase of the development.

Figure 1.3: Phase 2 of Proposed Quarry Extension (South-Eastern and South-Western

X

Source: SM Bennet & CO Ltd (December 2008)

section 1: Introduction IPFC Licence -7-06 - Review

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Phase 3 : Removal of AsL..alt Plant anc Subseauent DeVelODmefi, of t..e Ouarw ..I a

Southerlv Diredypnto a DeDth of 70 metres AOD . .

As Phase 2C of the proposed development nears completion, it is proposed to decommission and

remove the asphalt plant (Phase 3A). Once the plant is removed, the area around it will be extracted

to the 70 metres AOD level (Phase 38). Towards the completion of Phase 2 and the removal of the

asphalt plant complex, overburden will be stripped in a controlled and phased manner in a southerly

direction and will be used in the construction of screening berms around the southern boundaries of

the site. The timing and scheduling of the topsoil and overburden stripping will be dependent on the

prevailing economic conditions at the time. For the purposes of this application, the stripping of

topsoil and overburden has been divided into 6 sub-phases (3C' to 3cb). Topsoil and overburden

used in the construction of the screening berms will be used in the final restoration of the quarry void

and the site as a whole. The production benches will be at least 30 metres wide and will have sub-

vertical faces. All production benches will be subject to ongoing geo-technical monitoring on a

regular basis.

Figure 1.4: Phase 3 of Proposed Quarry Extension (Southern Extension)

Source: SM Bennet & CO Ltd (December 2008)

Section 1: Inhoductkn IPPC licence PO487-06 - Review Page 10

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Lagan Cement'

As already outlined, production benches will have final bench widths of 7.5 metres, final maximum

bench heights of 15 metres and final bench slopes of about -70' from the horizontal, depending on

the geo-technical quality of the rock. This will ensure long-term stability, integrity and safety of the

final quarry design.

The phasing of the extraction allows for multiple faces to be opened-up and worked at any given

time, thereby enabling the blending of materials from the quarry, essential to the continued efficient

operation of the cement plant.

Early and ongoing restoration and planting of final benches with stockpiled materials, including

previously stripped and stored overburden and topsoil will occur as areas of the quarry become

worked out.

The estimated reserve levels within the area of the proposed quarry extension suggest that the

subject site will take between 15 and 20 years to excavate over a single bench level. Given this

projected life span for the development and the unknown economic conditions over its lifetime, the

creation of more than 3 primary operational phases would be arbitrary and would complicate and

compromise the operational efficiency of the site.

1.3.2 Overburden Disposal

Overburden will be removed to permanent landscaped locations wnicn will act as new screening

berms for the southern and eastern areas of the proposed quarry extension. The overburden to be

removed includes a significant proportion of free draining materials. The mounds will be constructed

with long-term stability being a key consideration. Detailed stability and construction reports will be

prepared prior to bund construction to ensure that the structures are secure.

Soft clays, silts and peaty materials will be bunded inside containing cell walls and where appropriate,

drainage blankets will be placed following the removal to top and sub-soils from the areas where

bunds are to be built. Top and subsoils will be separately stored to assist in revegetation of

completed screening banks and bunds. Since silt may be suspended in surface water run-off from

the large screening bunds, silt traps will be employed before discharge into existing watercourses

until surface plant growth has been established.

section 1: Introduction Page 11

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1.3.3 Quarry Operations

It is proposed that the quarry extension will be operated along the same lines as the existing

permitted quarry operation. I n this regard, the working of the quarry extension will take place

between 07:OO and 19:OO hours on Monday to Saturday. Except in emergency, and then on advice

to the Planning Authority, working will not take place on Sundays and Bank Holidays. Pumping may

take place continuously and some maintenance will occur at weekends.

The reef limestone will require ground preparation by drilling and blasting. Initially, the quarry

extension will be worked using conventional hard-rock equipment induding hydraulic loading shovels

and 50 - 70 tonne dump trucks.

Blast design will be based on careful monitoring of the initial blasts using low charge weights of

explosive per delay. Based on the experience of the existing operational quarry, blast vibrations can

be kept below 12mm per second at a distance of 300m using a maximum charge delay of 1OOkg. A

maximum charge per delay of 50kg would maintain the same vibration limit at a distance of 140m

from the point of blasting.

1.3.4 Quarry Safety & Security

There are a number of safety and security measures in place for the existing quarrying operations on

the subject site. In this regard, fences are located and regularly maintained around the perimeter of

the site inside existing hedgerows, thereby discouraging inadvertent access to the quarries and the

water retention structures. The screening berms being constructed as part of the proposed quarry

extension will be subject to separate investigation and reporting before construction. There is

sufficient granular material to ensure adequate drainage in the structures, with weaker, softer soils

being contained in internal cells.

1.3.5 Quarry Restoration

The restoration of the proposed quarry extension will be undertaken in accordance with that of the

existing permitted quarry. I n accordance with the restoration proposal for the existing limestone

quarry, a Restoration Plan has been prepared by David Jarvis & Associates

saction 1: Inhoduction Page 11

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I n IPPC Licence PO487-05 Review Application, Lagan Cement Ltd. added Liquid Recovered Fuel (LRF)

and additional alternative fuels to their previous list of alternative fuels for use at their facility. Lagan

Cement Ltd. use up to a maximum of 95,000 tonnes per annum of any ambination of the full list of

non-fossil, alternative fuels, but with LRF usage being limited to 20,000 tonnes per annum. The

alternative fuels consumed in the kiln, now include LRF and the previously permitted Solid Recovered

Fuel (SRF), Tyre Derived Fuel (TDF), Meat and Bone Meal and carbon-neutral biofuels. Market

conditions dictate which combination of fuel types is used at any given time.

By maximising the use of these alternative fuels Lagan Cement Ltd, reduces the amount of imported

virgin fossil fuels needed, reduces COz emissions, improves economic and environmental sustainability

of operations and assists national energy security. Alternative fuel use also reduces the associated

environmental impacts of finding, producing, transporting, and burning these fuels and reduced

dependence on landfill.. Lagan Cement Ltd. sees this use of alternative energy and the 'closed loop'

of resource usage as an essential step in improving the sustainability of its cement manufacturing

operation and reducing its emissions of greenhouse gases to the atmosphere.

The existing alternative fuels used by Lagan Cement (IPPC Licence PO 487-06) comprise the

European Waste Catalogue codes which are listed in Table 1 below according to their respective

codes from the European Waste Catalogue.

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Table 1: Summary of Existing Waste Categories for Acceptance at the Lagan Cement plant (IPPC

Licence PO -487-06). (The maximum capacity of 95,000 tonnes of alternative fuels per annum shall

not be exceeded).

02 01 03,02 01 07,02 01 09,02 02 03,02 02 04,02 03 04,02 03 05,02 04 02,02 05 02,02 07 04,

02 07 05, 03 01 01,03 01 05,03 03 01,03 03 08,

05 01 03, 06 02 01,06 02 03,06 02 04,06 02 05,06 09 04,06 08 99,

07 01 01,07 01 04,07 05 01,07 05 03,07 05 10,07 05 12,07 05 13,07 05 14,07 06 99,07 07 01, 07 07 04,

08 01 11,08 01 12,

09 01 01,09 01 02,09 01 03,09 01 04,09 01 05,09 01 06,09 01 13,

10 01 01,lO 01 02,lO 01 03, 10 01 15,lO 01 17,lO 02 01,lO 02 02,lO 03 05,lO 03 17, 10 03 18,

10 03 26,lO 08 04, 10 01 15,lO 01 17,lO 10 03,lO 10 08,lO 09 03,lO 09 06,lO 11 03,lO 11 12,

10 12 03,lO 12 06,

11 01 10, 12 01 01, 15 01 01,15 01 03,15 01 10, 16 01 03, 17 01 06,17 02 01,17 02 02,17 05 03,17 05 04,17 05 05, 17 05 06,17 08 02, 18 01 06,18 01 07,18 01 09,18 02 05,18 02 06,18 02 08, 19 01 12,19 01 14,19 01 18, 19 01 19,19 02 03,19 02 06, 19 02 07,19 03 05,19 06 03, 19 05 01,

19 05 02,19 05 03, 19 07 02, 19 07 03,19 08 02,19 08 05, 19 08 10,19 10 04,19 13 02, 19 13 04,

19 08 12,19 08 14,19 09 01, 19 09 02,19 12 01,19 12 04,19 12 05, 19 12 07,19 12 09,19 12 10,

19 12 12,

20 01 01,20 01 02,20 01 13,20 01 25,20 01 27,20 01 28,20 01 32,20 01 38,20 01 39

Lagan Cement Ltd. use alternative fuels inclusive of European Waste Catalogue codes from Chapters

1, 2, 3, 5, 6, 7,8, 9, 10, 11, 12, 15, 17, 18, 19 and 20.

Lagan Cement Ltd. propose that the quantum of alternative fuels to be co-fuelled in the cement kiln

will be comprised of considerably less than 40% hazardous waste. Therefore, in accordance with

Article 7(2) of the Waste Incineration Directive (WID) the emission limit values (ELVs) as outlined in

Annex I1 of the WID will not be exceeded in the exhaust gas.

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The use of 95,000 tonnes of alternative fuels per annum, inclusive of 20,000 tonnes of Liquid

Recovered Fuels (LRF), falls under the scope of the Annex I1 ELVs as the resulting heat release will

come from the co-fuelling with less than of 40% of hazardous waste (Article 7(2)). All alternative

fuels used onsite will contain less than 1% of halogenated organic substances (expressed as

chlorine).

Lagan Cement has strict abatement systems and operational procedures in place in order to control

atmospheric emissions. All alternative fuels are fully treated to enhance their combustion qualities

prior to their acceptance at the Lagan facility.

The use of alternative fuel increases the sustainability of the cement manufacturing facility and

represents further progress by the company in the direction of the Governments objective of

delivering a sustainable energy future for Ireland. Lagan Cement Ltd believe that they will be able to

manage a highly energy intensive operation, the manufacturing of cement, with a safe and secure

supply of energy in a sustainable and environmentally friendly manner while still achieving economic

competitiveness. Sustainable management of the energy requirements at Lagan Cement Ltd. is

intended to 0 reduce CO2 emissions from the facility

secure and stabilise energy supply for the long term 0

0 reduce reliance on expensive fossil fuel imports and

invest and assist in Irelands indigenous renewable energy projects which are often in rural 0

and less developed areas

Lagan Cement Ltd is very conscious of the fact that using resources more efficiently is an essential

step toward creating a more sustainable society. I n effect this ‘eco-efficiency’ means producing more

energy with less waste and pollution, and uses fewer resources. This not only helps to break the link

between economic growth and environmental pollution, but can also help companies improve

financial performance as they pay less for resource inputs and pay less for waste management and

pollution control.

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Cement is produced in a kiln at very high temperatures (up to 2000 degrees centigrade) from a

mixture of raw materials. For the production of cement, the principal raw materials are limestone and

shale, which are extracted from the existing quarries on the site, and some imported raw materials

are also used.

A schematic representation of the process is presented in Appendix D1 of Attachment D. The raw

materials used in the process are finely ground and mixed in precise proportions depending on their

exact chemical composition before entering the kilning process in a dry state. The mix of raw

materials, known as raw meal, is pre-heated and calcined at 500 - 900°C when carbon dioxide is

driven off; the meal is then sintered at temperatures of about 1400 - 1500°C when a calcium silicate

clinker is formed in the form of 3 - 25mm granules. Gypsum, added in order to control the setting

time of the cement, is then mixed with the clinker and ground to produce cement. Coal, fuel oil, meat

& bone meal (MBM), Solid Recovered Fuel (SRF) and Tyre Derived Fuel (TDF) and a range of carbon

neutral biofuels including wood chips, recycled wood including construction and demolition (C & D)

timber, sawdust, and residues derived from the sawmill and forestry industry; agricultural products

and residues such as energy crops, cereals and grains; bio-sludge from the water treatment industry;

and biodiesel and bioethanol, and their derivatives are currently the fuels used for the manufacture of

cement at the site as alternative fuels in place of a portion of the existing coal supply. Lagan Cement

Ltd are currently permitted to burn a total of 95,000 tonnes per annum of these renewable alternative

fuels.

There are eight stages in the cement manufacturing process:

Raw material preparation

Raw material analysis and blending

Raw meal milling and mixing

Raw meal kilning

Clinker cooling and handling

Clinker grinding

Coal preparation

Storage and handling of cement

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A comprehensive description of the process is presented in Attachment No D of this Licence

Application. A brief description of the main elements of the manufacturing process is presented

below.

1.5.2 Raw Material Preparation & Handling

The principal raw materials required for the process are recovered on site with some additional raw

materials being imported as required. The raw materials are handled in the Raw Material Compound

located between the cement works and the limestone quarry. Raw materials are stored in stockpiles

constructed for this purpose in the Raw Material Compound. Stores of finer material and crushed

shale and limestone are housed to minimise dust emissions and the two crushers required for the

processing of the raw materials are also housed. All material conveyance to the Blending Bed is under

cover.

Materials are blended to the required composition in the Blending House before being conveyed into

the Raw Mill for crushing and drying. The Raw Meal produced is stored in silos until required for

processing in the manufacturing process.

A more detailed description of the operation of the two quarries and a detailed description of the raw

material preparation and handling operations is also presented in Attachment No D.

Alternative raw materials are also permitted at the facility. Recycled gypsum, filter cake from the

drinking water treatment industry, recycled glass, recycled ash are amongst the renewable raw

materials, which may be used as raw material substitutes in the production of cement. These

materials will be transported to the site in covered, leak-proof container trucks and will be visually

inspected and cross-checked against the Quality Control Specification Sheet before being allowed to

unload on site. Alternative raw materials will all be stored in the existing covered raw material storage

areas and will be introduced into the process at the raw materials intake area.

Improved energy efficiency in cement production equates to lower COz and lower costs. Therefore,

Lagan Cement Ltd. has an incentive to maximise the tonnes of product produced / unit of energy

spent.

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In cement manufacture, CO2 emissions arise as a result of the Combustion of fuels and from a

process known as calcination, where CaCa, present in the raw materials, is converted into CaO,

which is the main component of cement. Because a significant portion of the CO2 emissions from

cement plants are from the calcination process, any mechanism that allows lesser raw material to be

calcined will have a significant role in reducing the overall CO2 emissions. As calcination only occurs at

very high temperatures, any reduction in the volumes of material requiring calcination will also serve

to reduce the energy inputs associated with cement production. Therefore, anything that will

displace an equivalent amount of clinker, such as blending of waste gypsum or filler (rock or mineral

materials), will result in lower CO2 emissions from the cement plant and will reduce energy usage and

therefore, be more cost effective.

Lagan Cement Ltd. propose to import waste gypsum or filler (rock or mineral materials such as ash or

slags) to the existing site and incorporate this material into the cement making process "post kiln".

Therefore, these materials are not alternative fuels in the process but are merely an alternative raw

material to the quarried products of the existing limestone and shale quarries.

Gypsum is mixed with the clinker and ground to produce cement. It is added in order to control the

setting time of the cement. Lagan Cement Ltd. propose to source this gypsum or filler material from

a variety of sources such as casting moulds, construction and demolition wastes and flue gas

desulphurisation processes.

Raw Meal from the storage silos is fed to the preheater stage of the kiln and travels downward

through the Preheater Tower or Heat kchange Tower to the Kiln. Clinker is produced by the calcining

of the Raw Meal at high temperatures. The Clinker is cooled and crushed before being conveyed for

storage in Clinker silos until required for use in the cement manufacturing process. A separate silo is

provided for clinker produced during start-ups which need to be re-blended.

A detailed description of the processes involved in the production of clinker is presented in

Attachment No D.

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Cement is produced by grinding the clinker produced in the earlier manufacturing stages in the

Cement Mill. Gypsum and fillers may be added prior to milling if necessary to produce the required

formulation. The facility produces both CEM I and CEM I1 type cements. CEM I has a clinker content

of approximately 91% with the remainder being made up of limestone and gypsum in almost equal

proportions. CEM I1 has a clinker content of approximately 81% and is made up of 15% limestone

and 4% gypsum.

Cement is stored in silos prior to transport to the bagging plant or for direct loading onto container

trucks. A detailed description of the processes involved is presented in Attachment No D.

Fuel Preparation & Use

Approximately 80,000 tonnes of coal per annum is delivered to the site by truck and is stored in one

of the two coal silos located in close proximity to the kiln. The coal is conveyed as needed to a feed

bin, which in turn feeds the coal to the coal mill. Coal is ground to a fine powder to facilitate

combustion in the kiln. The high temperatures required in the cement kiln can only be achieved by

using coal dust which is blown in to the kiln through a burner pipe. The flame reaches temperatures

in excess of 2,OOOOC. The coal mill operation is similar to the raw meal mill, only significantly smaller

in capacity and specially designed to grind coal safely.

I n the kiln, coal is burned only when temperatures are high enough for safe combustion. To start-up

the installation fuel oil or natural gas is used to preheat the areas where coal combustion takes place

which is required for safety reasons.

Lagan Cement Ltd also has permission to use a range of alternative fuels in the kiln including meat

and bonemeal, renewable wood sources (such as wood chips recycled wood, sawdust and residues

derived from the sawmill and forestry industry), agricultural products and residues, bio-sludge from

the water treatment industry and biomass fuels such as biodiesel and bioethanol.

Alternative liquid fuels will be transported to the site by road tanker in the same manner as the gas

oil supply is currently delivered to the site and will only be accepted onto the site following an offsite

quality control check.

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Lagancement 4 L-11 crRqlul1r

Alternative solid fuels will be transported to the site in covered, leak-proof container trucks. All solid

fuels are visually inspected and cross-checked against the Quality Control Specification Sheet before

being allowed to unload on site. Solid fuels are stored under cover in segregated sections for each

fuel type. As the solid fuels are being fed into the process they will be further inspected to ensure

that no contamination is present in the fuel load. If any contaminant material is found to be present

then the affected section of the load will be removed to the quarantine area for storage and will be

returned to the supplier on the next load that arrives in to the facility.

1.5.6 Dry Mortar Manufacturing Process

The facility has permission to operate a dry mortar and will produce an output of 70,000 tonnes of

mortar product per annum once up and running. The mortar plant will be configured as a high level

mixing plant for dry mortar and plaster. The aggregates will be delivered from the raw material

storage stockpiles, which will be fed from the on-site quarries, and loaded into the inlet funnel

(receiving hopper) by truck or front-end loader. Materials will then be transported from the receiver

hopper up to the Fluid Bed Dryer/Cooler by belt conveyors. The Fluid Bed Oryer/Cooler is connected

with a belt bucket elevator which charges the storage silos within the mixing tower. The aggregates,

binders and additives will be weighed in a weighing hopper and the whole batch will then be released

into a single shaft mixer. Following batching, the homogenised material will be distributed by a belt

conveyor either to the packing plant, to the bulk loading or to the finished product silos.

All process equipment within the dry mortar plant including storage silos, additive bunkers, weigh

hoppers for aggregates, binders and additives, mixer, mixer bunker, fluid bed dryer, and loading

spouts are equipped with individual filters and will ensure that the residual dust quantity in the filter

outlet will be I 10mg/Nm3. The equipment is de-dusted at the particular point of dust generation and

therefore the collected dust is returned into the process and is not released into the atmosphere.

1.5.7 Paving Plant Manufacturing Process

Lagan Cement Ltd have permission to operate a paving block plant is a high volume production

process and will produce a variety of different concrete floor paving block ranges, up to a total of

100,000 tonnes per annum. The entire mixing process is totally automated and computer controlled

to ensure consistency of manufacture and orderly storage and curing of the blocks.

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LaganCement

The raw materials for production will be delivered from the raw material storage stockpiles, which are

fed from the on-site quarries. From here the aggregates for production will be delivered by truck into

a ground feed hopper from which each material is fed into covered storage bins. A batching system

will dispense the exact quantity of each material by measuring the weight of the aggregate with load

cells beneath the conveyor. The mixed aggregates are then transferred into a holding hopper above

the concrete mixer. Cement is fed to the mixer and water is added in an automated manner so that

the resulting concrete has the correct moisture content and consistency. Pigment is also added to the

mix during the mixing process.

At the start of the process, a palette is moved into position in the block press, the mould-box is

lowered onto the palette and the feed drawer fills the mould box with mixed concrete. Flat

compaction heads are lowered onto the mould and heavy vibration is applied to compact the block to

size. The mould is then lifted and the palette containing the wet paving block moves down the

production line.

Palettes containing the formed paving blocks are moved to a storage elevator. When the storage

elevator is full, a finger car automatically lifts the palettes and transfers them to one of the curing

chambers. During the following 24-hour period, the heat developed by the hydration of the cement

cures the paving blocks. The curing chambers are highly insulated to contain the heat and humidity

produced during the curing cycle.

After curing, the paving blocks are transferred by the finger car to the board lowerators where the

product is continually inspected and sampled for laboratory testing. Hydraulic grabs lift the blocks

from the palette and stack them into cubes which are strapped and wrapped for protection during

storage. Each cube is individually tagged with both a tracking code and a product description prior to

being moved from the conveyor for storage in the yard. The blocks are kept in storage until the

appropriate strengths have developed.

Lagan cement Ltd has permission to operate a tiling plant that will produce up to 50,000 tonnes of

roof tiles per annum. The raw materials for production will be delivered from the raw material

storage stockpiles, which are fed from the on-site quarries. From here the aggregates for production

will be delivered by truck through a screen and up to the Holding Hopper where it is then weighed up

on the weighing system and blended together to the mixer. The Cement is brought up by means of a

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cement screw. The Cement is discharged into the mixer and pigment slurry is added. The hydronix

system then takes a moisture reading and water is then added to the settings required.

The mix is then dropped into a hopper above the conveyor and fed to the Tile Extruder. The tile

mould is fed towards the extruder and is sprayed with release oil. Over spray from the release oil is

filtered and put back into the release oil tank.

The mix is then dropped into a hopper above the conveyor and fed to the Tile Extruder. The tiles are

then loaded and pushed into the Carousel Rotary.

By this stage, the tiles have reached the exit point of the Rotary. Each rack holds 200 tiles, which are

then pushed out by the cured tile pusher onto a conveyor.

The tiles are then fed towards the depalleter. The tile is split from the mould and the mould is fed

back round to the Tile Extruder. The tile is then sent in another direction to the Paint Booth before

being stored for transport.

xctlon 1: Introduction IPPC Ucence PO487-06 - Review Page 22

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Attachment NP A.1

NON-TECHNICAL SUM MARY

IPPC LICENCE APPLICATION

icence Register Number PO487-06 REVIEW

Prepared by: Envest Environmental Ltd. @ S T Environmental

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Attachment NP A.

NON-TECHNICAL SUMMARY

Table of Contents

Section Page

1.0 Introduction ............................................................................................... 1

2.0 Increase in the Emission (ELV) for Total Organic Carbon (TOC) ... 2

3.0 Air Overpressure Limit

4.0 Conclusions ............................................................................................... 5

section A.l: Nan-Technical Summary

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e

1.0 Introduction

This application for an Integrated Pollution, Prevention and Control (IPPC) Licence has been prepared

in order to update and revise the existing IPPC Licence (Licence Register Number W487-06) which

was granted by the Environmental Protection Agency (EPA) in March 2012.

This IPPC Licence Review application is primarily being submitted in order to repeal the Air

Overpressure limits at the nearest sensitive locations which were reduced by the EPA in the most

recent IPPC Licence for the site - PO487-06 from 125dB(lin) max. peak to 120dB(lin) max. peak.

I n addition, the licensee also seeks the following amendments:-

1. Increase the emission limit value for Total Organic Carbon from 10 mg/m3 to 40mg/Nm3 for

emission point A2-01 for the co-incineration of waste in order to accommodate varying

organic fractions within the raw materials and to bring the licence into line with TOC limits

recently granted to another Republic of Ireland based cement producer.

2. Amend the storage volumes permitted for Liquid Recovered Fuel (LRF) in Condition 8.9(b) of

PO487-06 from 20,000 litres to 150rn’. The permitted use of LRF in W487-06 is 20,000

tonnes per annum. This equates to a use of approximately 60 tonnes per day. Therefore, the

permitted storage of 20 tonnes is inadequate.

The previous IPPC Review requested an increase the extent of the existing quarrying o

the Lagan Cement manufacturing facility in Killaskillen, Co. Meath, the planning application for which

required the preparation of an Environmental Impact Statement (EIS). The previous IPPC Review also

broadened the range of alternative fuels used as part of Lagan Cement’s sustainable fuel programme,

including up to 20,000 tonnes of Liquid Recovered Fuels (LRF). The purpose of the sustainable fuel

programme is to further reduce Lagan Cement‘s dependence on imported fossil fuels. Lagan Cement

is currently licensed to use 95,000 tonnes of alternative fuels per annum and the most recent IPPC

Licence review did not alter the volume of alternative fuels used on site. The complete list of

European Waste Catalogue Codes permitted for use on site can be seen in detail in Attachment H.

This IPPC Licence review for the Lagan Cement manufacturing facility in Killaskillen, Co. Meath, has

not required a planning application or the preparation of an Environmental Impact Statement (EIS).

Section A.l: Non-Technical Summary

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2.0 Increase in the Emission Limit Value (ELV) for Total Organic

Carbon (TOC)

The potential impact of a possible increase in the Emission Limit Value (ELV) for Total Organic Carbon

(TOC) emissions from 10mg/m3 to 40mg/m3 from the cement plant has been reviewed in relation to

the air quality impact.

In February 2010 when the application for permission to use Liquid Recovered Fuel (LRF) as an

alternative fuel at the facility was being prepared a very comprehensive assessment of air quality

impacts associated with the use of a range of fuels at the facility was completed. That assessment

included a comprehensive evaluation of the potential impacts on air quality as a result of emissions

from the proposed use of LRF and other additional ONC codes as alternative fuel sources in the

cement kiln. The combined impacts of emissions from existing activities at the site were also

considered in the assessment.

The dispersion modelling study demonstrated that the existing stack height of 125m for the cement

kiln provides effective dispersion of pollutants emitted from the facility under normal and maximum

possible operating conditions. The results of the study demonstrated that there will be no adverse

impacts on ambient air quality in the vicinity of the facility as a result of emissions from either existing

or proposed activities at the site. The assessments were completed under the worst possible

emissions scenarios, as well as typical emissions conditions, in order to assess the maximum potential

impact on ambient air quality; the use of maximum possible emission conditions ensures that the

impact assessments are reliable and may overestimate the actual projected impact of the

development.

The results of this extensive study demonstrated that there will be no adverse impacts on ambient air

quality in the vicinity of the facility, on local residences or on local agriculture as a result of emissions

from either the existing or the proposed activities at the site. This included in respect of emissions to

atmosphere of TOC. The modelling results have been compared with the air quality standard for

environmentally significant organic compounds using the German TA Luft Technical Instructions on

Air Quality Control. Even using this stringent assessment criterion, the predicted ambient TOC

concentrations are very substantially lower than the relevant air quality limit value.

I n terms of the assessment of the impact of an increase in the ELV for TOC from 10mg/m3 to

40mg/m3, the impact of such an increase can be extrapolated from the previous model results. A

Sactian A.l: Non-Technical Summary IPPC LiceMC PO487-06 - ReViW

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fourfold increase in the emissions would see a corresponding fourfold increase in the predicted

ground level concentrations. Even at this increased emission rate, the predicted ground level

concentration, after taking account of the existing background, is very significantly lower than even

the most stringent air quality standard.

I n conclusion, the assessment has shown that there is no adverse impact associated with an increase

in the ELV for TOC from 10 mg/m3 to 40mg/m3 and the change in predicted ground level air quality is

insignificant and imperceptible relative to the existing situation.

3.0 Air Overpressure Limits

This IPPC Licence Review application is primarily being submitted in order to repeal the Air

Overpressure limits at the nearest sensitive locations which were reduced by the EPA in the most

recent IPPC Licence for the site - PO487-06 from 125dB(lin) max. peak to 120dB(lin) max. peak.

The recommendation of the EPA Technical Committee to reduce Air Overpressure Limits to 120

dB(lin) max peak at the nearest noise sensitive location outlines a significant change from the draft

licence 487-06 and the licence conditions pertaining to the quarrying operations at the Lagan Cement

facility in Kinnegad, Co. Westmeath, for the previous 5 licences, which outlined a limit of 125 dB(lin)

max peak. It would appear that the technical committee did not take into account actual AOP

measurements, taken on behalf of Lagan Cement, over an almost 10 year period, which shows 100%

compliance with 125dB, but with a significant number of excursions above 120dB. The Lagan

Cement facility already operates to limits of 8 mm/s and 125 dB(Lin) for blasting which occurs

typically on average every 2-3 weeks in the limestone quarry and once per annum in the shale

quarry. This is a rigorous standard, already more stringent than all of their competitors. Lagan

Cement presently inform all nearby sensitive residential properties in writing in advance of quarry

blasts and also sound a warning siren prior to blasting. Similar installations to the Lagan Cement

quarry at Kinnegad, Co. Westmeath have either an air over pressure limit of 125 dB (lin) maximum

peak or no relevant limit at all.

A summary review of worldwide limits reveals a wide range of formal limits, ranging from 115 d6

(lin). max. peak (with 5% exceedence permitted to 120 dBL) in some operations in Australia, to 133

dB (lin). max. peak in the USA. It is reported that in certain cases a guideline limit of 120 dB (lin).

max. peak has been applied in many blasting operations in Australia, the USA, Canada and the United

Section A.l: Non-Technical Summary IPPC Licence PO487-06 - Review pape 3

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Kingdom and conformance with this guideline limit has been successful in reducing complaints to an

acceptable level. However, the Australian, US and Canadian limits are unlikely to be directly

comparable to the Irish scenario due to the vastness of these countries and the remoteness of many

such quarries from residential properties. Also, more importantly the typical climatic conditions

experienced in Ireland differs very significantly from that which tends to prevail in countries such as

Australia, the US and Canada.

Weather conditions, such as high humidity, rainfall, or the presence of cloud cover, can cause the

levels of overpressure to seem more severe than there would be on a day when the humidity is low

and there is lack of cloud cover. Overall, it can be summarised that air overpressure levels are higher

during blasting episodes when weather conditions include the following:

significant temperature inversions

foggy or hazy conditions with little or no wind

still, cloudy days with a low cloud ceiling

Low cloud ceiling, strong breeze / wind blowing directly towards sensitive receiver

The blasting at the Lagan Cement quarry is most likely to be conducted during weather conditions

which are representative of one or more of the weather conditions outlined above. Therefore, it is

very difficult for Lagan Cement to meet more onerous licence conditions when such weather

conditions are so prevalent and existing air overpressure levels are already typically in excess of the

recently revised lower limit but in accordance with the former limit value of 125 dB (lin) max. peak.

Lagan Cement has been highly proactive in employing a variety of measures, which constitute BAT,

towards mitigating the vibration and AOP issues associated with blasting. This is evidenced by their

strong compliance history to date. However, it is important to note that climatic conditions may

negate mitigation measures taken. It is also important to note that Lagan Cement is of the view that

no further measures can be reasonably taken to further mitigate AOP.

it is widely reported that the susceptibility of individuals to vibration varies from person to person

depending on factors such as age, health and, to a large extent, previous exposure. It is also widely

reported that it is usually the case that adverse comments are less likely once a neighbour has

become accustomed to the perceived effects of blasting and the resident is regularly informed of

progress updates and warnings with regard to blasting. This is presently undertaken by Lagan

Cement Ltd. with a blasting conducted as a single event every 2-3 weeks with regards to which

residents are notified in writing and a warning siren is sounded in advance of blasts.

Section A.1: Non-Technical Summary IPPC Ucanca PO487-06 - Review Paw 4

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Lagan Cement

4.0 Conclusions

A comprehensive assessment of potential environmental impacts of the increase in the extent of the

existing quarrying operations at the Lagan Cement manufacturing facility and the use of alternative

fuels has been carried out as part of the ongoing review of Lagan Cement Ltd. IPPC Licences since

2001. The most recent IPPC Licence review application involving the extension of the quarrying

activities and the use of Liquid Recovered Fuels as an alternative fuel source at the cement facility

has shown that there will be no adverse impacts on the environment as a result of the proposed

developments at the Lagan Cement Ltd facility.

As part of this application, the nature and quantities of emissions from quarrying and cement

manufacture at the installation into all environmental media have been considered. It has been

shown that the existing mitigation measures and the proposed techniques for preventing and/or

reducing emissions from the plant will ensure that Lagan Cement Ltd are capable of and will fully

comply with the legal requirements of the Waste Incineration Directive, the Animal By-product

Regulations and any other relevant legal requirements.

Section A.1: Non-Technical Summary IPPC licence PW87-06 - Review

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