Irish Cement Limited Objector Address

Objection Objector: Mr. Seamus Breen Organisation Name: Irish Cement Limited Castlemungret, Mungret, Limerick, Limerick, Co. Objector Address: Limerick. Objection #OS005830 - Applicant objection for Reg Objection Title: No:[P0029-06] Objection Reference No.: OS005830 Objection Received: 14 October 2019 Objector Type: Applicant Oral Hearing Requested? No Application Applicant: Irish Cement Limited Reg. No.: P0029-06

See below for Objection details.

Attachments are displayed on the following page(s).

Objection OS005830 Page 1 of 22 Office of Environmental Sustainability, Environmental Protection Agency, Johnstown Castle Estate, County Wexford

14 October 2019 Re: Reference Number P0029-06 Irish Cement Limited, Limerick Works Objection (submission) to Proposed Licence Determination

Dear Sir or Madam,

I refer to your letter of 18 September 2019 enclosing the Proposed Determination of an IE licence for the above facility.

The objection (submission) is being lodged for clarification of a number of items in the Proposed Determination and our Submission outlining the grounds is enclosed for consideration by the Agency.

Our payment of the relevant fee has been made on line.

We trust that this is in order and we would appreciate acknowledgement of receipt of this payment at your earliest convenience. Please address all correspondence to the undersigned.

Yours sincerely,

______Head of Quality and Sustainability Irish Cement Limited

Objection OS005830 Page 2 of 22

Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

Report Ref

Issue | 14 October 2019

This report takes into account the particular instructions and requirements of our client. It is not intended for and should not be relied upon by any third party and no responsibility is undertaken to any third party.

Job number 325373-00

Ove Arup & Partners Ireland Ltd

Arup 50 Ringsend Road Dublin 4 D04 T6X0 Ireland www.arup.com Objection OS005830 Page 3 of 22

Document verification

Job title Proposed Determination of Licence Number Job number P0029-06 325373-00 Document title Objection (Submission) to PD File reference

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Signature Issue 14 Oct Filename ICL PD objection final.docx 2019 Description Issue

Prepared by Checked by Approved by Name Cormac McKenna Sinead Whyte Sinead Whyte

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Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

Contents

Page

1 Introduction 1

2 Nitrogen oxides (as NO2) emission limit value for emission point A2- 01, Kiln 6/ Rawmill 2

3 Noise conditions 4 3.1 FFT analysis 4 3.2 Clarification on clearly audible tones 5

4 The retention time of records 6

5 Emission Points A2-01 and A2-02 7

6 Typographical amendment (Nitrite/Nitrate) 8

Appendices

Appendix A Updated PD with amendment to schedules C.1.1 and C.1.2

Appendix B Noise condition

Appendix C Typographical Amendment (Nitrite/Nitrate)

Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

1 Introduction

On 18 September 2019, the Environmental Protection Agency (EPA) issued a Proposed Determination (PD) for Industrial Emissions Licence P0029-06 for Irish Cement Limerick. Irish Cement wishes to clarify the following items contained in the PD:

• Nitrogen oxides (as NO2) emission limit value for emission point A2-01, Kiln 6/ Rawmill; • Aspects relating to the measurement / monitoring of noise; • The retention time of records; • Emission Points A2-01 and A2-02; • Typographical amendment - Nitrite/Nitrate.

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Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

2 Nitrogen oxides (as NO2) emission limit value for emission point A2-01, Kiln 6/ Rawmill

Table 2 of the (BAT) conclusions under Directive 2010/75/EU of the European Parliament and of the Council on industrial emissions for the production of cement, lime and magnesium oxide outlines the associated emission levels for NOx from the flue-gases of kiln firing and/or preheating/precalcining processes in the cement industry, as presented below.

The BAT-AEL (daily average value) range outlined in Table 2 is <200 – 450 mg/Nm3 for preheater kilns, as applicable to the Irish Cement Limerick Facility. Footnote 1 (above) explains that if the initial NOx level after primary techniques is greater than 1,000 mg/Nm3, an upper level of the BAT-AEL range of 500 3 mg/Nm , is assigned. Therefore, as the initial NOx level after primary techniques is greater 1,000 mg/Nm3, the upper level of the BAT-AEL range of 500 mg/Nm3 should be assigned.

We also wish to reference the BAT Review Application (February 2017) as part of Licence P0029-05, BAT 19 Response, outlined below, which reinforces this position.

BAT 19 Response NOx emissions are abated using selective non-catalytic reduction (SNCR) on Kiln 6. The NOx limit of 500mg/m3 is applicable as Kiln 6 is a preheater kiln with an initial level after primary techniques of >1,000mg/m3. As the initial value for NOx is greater than 1,000 mg/Nm3, ICL is expecting a BAT AEL of 500 mg/Nm3 for Kiln 6. Measured NOx emissions on Kiln 6 were measured at in excess of 1,000 mg/Nm3 pre-2009, when the SNCR was installed on Kiln 6.

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Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

The Compliance Report submitted with the BAT review application (February 2017) included the following in Section 2.1.2:

3 The NOx limit of 500mg/m is applicable as Kiln 6 is a preheater kiln with an 3 initial level after primary techniques of >1,000mg/m . As the initial value for NOx is greater than 1,000 mg/Nm3, ICL is expecting a BAT AEL of 500 mg/Nm3 for Kiln 6. Details of NOx emissions from Kiln 6 since 2004 are provided in Table 1. The SNCR was installed on Kiln 6 in 2009. Pre-2009 and hence prior to 3 treatment, NOx concentrations are shown to be in excess of 1,000 mg/Nm . Table 1: Historical NOx monitoring data for Kiln 6 (SNCR installed in 2009)

Year (SNCR installed in Concentrations of nitrogen Nitrogen oxides limit 2009) oxides (mg/Nm3) (mg/Nm3) 2004 1,117 1,800 2005 1,216 1,800 2006 1,133 1,800 2007 1,097 1,800 2008 1,082 1,800 2009 934 1,800 2010 760 800 2011 763 800 2012 768 800 2013 725 800 2014 761 800 2015 763 800 2016 731 800

Therefore, according to Note 1 of BAT 19, the Limerick Factory satisfies the condition that the upper level of the BAT-AEL range is 500 mg/Nm³, if the initial NOx level after primary techniques is > 1,000 mg/Nm³. On this basis, we strongly believe that a NOx ELV of 500 mg/Nm³ is the relevant limit to be applied to NOx emissions from Kiln 6 on the basis of BAT 19, refer to Appendix A for proposed amended Schedule C.1.1 The modelling assessment submitted to the EPA in December 2018, is based on an emission limit value of 500 mg/Nm³.

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Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

3 Noise conditions

3.1 FFT analysis Schedule C.4.1 Noise monitoring of the PD, requires the completion of monitoring using ‘Fast Fourier Transform (FFT) Analysis’. As outlined in Condition 6.19.1 of the PD, the licensee shall carry out a noise survey of the site operations biannually, unless otherwise approved by the Agency. The survey programme shall be undertaken in accordance with the methodology specified in the 'Guidance Note for Noise: Licence Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4)' as published by the Agency. In consideration of the above, it is noted that Section 5.1 of NG4 states the following: A tonal noise source can normally be subjectively identified by a competent person familiar with noise impact assessments. However, prior to the application of a rating penalty the Agency would recommend adoption of the simplified methodology for the objective identification of tones that is advocated in BS 4142: 2014: Annex C (normative): Objective method for assessing the audibility of tones in sound: One-third octave method. This methodology requires that for a prominent, discrete tone to be identified as present, the time-averaged linear sound pressure level in the one-third-octave band of interest is required to exceed the time-averaged linear sound pressure levels of both adjacent one-third octave bands by some constant level difference. The section goes on to state: that the approach described here will suffice for the majority of situations where tonal noise is suspected to be present. In the event, however, that there is a difficulty in identifying a tonal noise source using this method, or there is disagreement over the presence of tonal noise, then the recommended approach is to adopt the methodology outlined in BS 4142: 2014: Annex D (normative): Objective method for assessing the audibility of tones in sound: Reference method. The following examples illustrate when it may be appropriate to apply the more detailed reference method as opposed to the one-third octave method: • In the event that an interested party believes that a tone is clearly audible even though the one-third method suggests that a tone is not present; • If measurements conducted under different conditions and/or at different times return contradictory findings, i.e. application of the one-third method suggests the presence of a tone for one or more measurements whilst also suggesting the absence of a tone for another measurement (or measurements), and; • If the level differences are within +2dB of the values stated above and there is a dispute over the presence or otherwise of a tone. It is further noted that Annex D of BS4142:2014 states that if the presence of audible tones is in dispute, the measurement procedure in this annex can be used

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Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

to verify their presence…. the aim of the reference method is to assess the prominence of tones in the same way as listeners do on average. Therefore, three steps are applied in the methodology: a) narrow-band frequency analysis (preferably Fast Fourier Transform analysis); b) determination of the average sound pressure level of the tone(s) and of the masking sound within the critical band around the tone(s); and c) calculation of the tonal audibility, ΔLta, and the adjustment, K Irish Cement strongly seeks that an amendment be included in the PD to allow the presence of tones to be determined in accordance with the requirements of NG4 and BS4142:2014. This amendment should remove reference to Fast Fourier Transform (FFT) in Schedule C.4.1. This removal will allow the biannual noise survey to be carried out in accordance with NG4, i.e. the BS4142:2014 Annex D method would only be applied where there is a difficulty in identifying a tonal noise source using the Annex C method or where there is disagreement over the presence of tonal noise. Refer to Appendix B for suggested amendment.

3.2 Clarification on clearly audible tones Schedule C.4.1 of the PD states that for tonal/impulsive components, there can be ‘none’ contained in the measurement at sensitive receptor locations. NG4 defines tonal as: Sounds which cover a range of only a few Hz which contains a clearly audible tone, i.e. distinguishable, discrete or continuous noise (whine, hiss, screech, or hum etc.) are referred to as being ‘tonal’. Therefore, as the definition included in NG4 for tonal includes for ‘clearly audible tones’, Irish Cement strongly seeks that an amendment to the PD is made to reflect this position and that ‘none’ in Schedule C.4.1 should be replaced by ‘no clearly audible’. Refer to Appendix B for suggested amendment.

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Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

4 The retention time of records

Condition 2.2.2.8 (Environmental Management Programme), outlines that these reports shall be retained on-site for a period of not less than seven years and shall be available for inspection by authorised persons of the Agency. Irish Cement wish to seek the amendment of this condition so that for consistency it applies to all relevant licensing documentation on-site. The following is suggested as an amendment to Condition 2.2.2.9 (change highlighted in blue): 2.2.2.9 Documentation i. The licensee shall maintain and implement an environmental management documentation system. ii. The licensee shall issue a copy of this licence to all relevant personnel whose duties relate to any condition of this licence. iii. The licensee shall retain all relevant licensing documentation on site for a period of not less than seven years.

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Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

5 Emission Points A2-01 and A2-02

As outlined in Irish Cement’s Response to Request for Further Information 1st November 2018, submitted to the EPA in December 2018, we wish to note the intention to duct the Coal Mill (A2-02) stack into the Kiln 6 / Rawmill stack (A2- 01). This ducting work can be completed six months following the receipt of the licence final determination /or at a date to be agreed with the Agency. The Coal Mill stack will be decommissioned thereafter and Kiln 6 / Rawmill (A2-01) should be renamed as Kiln 6 / Rawmill / Coal Mill. Refer to Appendix A for proposed changes to Schedules C.1.1 and C.1.2.

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Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

6 Typographical amendment (Nitrite/Nitrate)

We believe that this is a simple clerical error where the trigger level and the threshold value should apply to “nitrite” and not “nitrate”. In accordance with the EPA Guidance1, the Nitrite Interim Guideline Value is 0.1mg/l and the Nitrate Interim Guideline Value is 25mg/l. Therefore, we wish to clarify that the groundwater trigger level of 0.1mg/l and groundwater threshold value of 37.5mg/l applies to nitrite and not nitrate as outlined in the PD. Appendix C of this appeal contains an updated Schedule C.7.1 of the PD with the correction of the nitrite typographical amendment. The relevant nitrate trigger level and threshold values are also included.

1 EPA, Towards Setting Guideline Values For The Protection Of Groundwater In Ireland, Interim Report, available at https://www.epa.ie/pubs/advice/water/ground/EPA_proposed_interim_values_protection_groundw ater_guidelines.pdf

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Appendix A Updated PD with amendment to schedules C.1.1 and C.1.2

Objection OS005830 Page 14 of 22

Proposed changes to Schedule C.1.1 and C.1.2 (changes highlighted in blue type)

C.1.1 Description, limit values and monitoring at emission point reference number A2-01 Emission point reference number: A2-01

Description: Kiln 6 / Rawmill / Coal Mill Note 3

Emission point location: 153344 E, 154790 N

Monitoring point location: 153344 E, 154790 N 98 m above Ordnance Datum Minimum discharge height:

Maximum in any one day: 12,000,000 Nm3 Volume to be emitted: Maximum rate per hour: 500,000Nm3 ' Monitorin2: Emission Limit Parameter Analysis Value Period Frequency Method/technique 250 mg/Nm3 24-hour mean BAT Oxides of sulphur (as SO ) 2 BAT21 21

500 mg/Nm3 24-hour mean BAT Nitrogen oxides (as NO ) 2 BAT19 19

20 mg/Nm3 24-hour mean BAT Dust / Particulates BAT 17 17

Carbon monoxide 1,500 mg/Nm 3 24-hour mean Continuous

BAT 5 3 Total organic carbon (TOC) 40 mg/Nm 24-hour mean EN standards are to 10 mg/Nm3 24-hour mean BAT be used or, if EN Hydrogen chloride (HCI) BAT25 25 standards not available, ISO, l mg /N/m 3 24-hour mean BAT Hydrogen fluoride (HF) BAT26 national or other 26 international 50 mg/Nm3 24-hour mean standards that Ammonia slip (NH3) BAT20 BAT20 ensure the provision Average over the of data of an Dioxins and furans 0.1 ng/Nm3 sampling period (6 - equivalent scientific (PCDD/F) BAT27 8 hours) BAT 27 quality may be used

Mercury (Hg) and its 0.05 mg/Nm3 BAT 5 Note l compounds BAT 28 Average over the Quarterly Note2 The sum of cadmium (Cd) sampling period 0.05 mg /Nm3 BAT 5 and thallium (TI) and their (spot measurements, BAT28 compounds for at least half an hour) BAT28 The sum of antimony (Sb), arsenic (As), lead (Pb), chromium (Cr), cobalt (Co), 0.5 mg/Nm 3 copper (Cu), manganese BAT28 (Mn), nickel (Ni), vanadium (V)

Note 3: A2-01 shall be renamed as Kiln 6 / Rawmill / Coal Mill following the decommissioning of Coal mill 6 stack (A2-02)

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Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

C.1.2 Description, limit values and monitoring at emission point reference number A2- 02

Emission point reference number: A2-02

Description: Coal / Pet Coke Mill

Emission point location: 153414 E, 154785 N

Monitoring point location: 153414 E, 154785 N

Minimum discharge height: 40 m above Ordnance Datum

Maximum in any one day: 840,000Nm3 Volume to be emitted: Maximum rate per hour: 35,000Nm3

Parameter Emission Limit Value Period Monitoring Ana Frequency s

Method/Techni que Continuous 20 mg/Nm3 24-hour mean Dust/ Particulates BAT 5g BAT17 BAT17

Average over the sampling period (spot Carbon monoxide 1,500 mg/Nm3 measurements, for at least half an hour) Average over the sampling 3 10 mg/Nm period (spot Hydrogen chloride (HCI) EN standards are BAT25 measurements, for to be used or, if at least half an EN standards hour) not available, Average over ISO, national or the sampling period 1 mg/Nm3 (spot measurements, other Hydrogen fluoride (HF) BAT26 for at least half an international hour) Quarterly standards that ensure the provision of data Average over the of an equivalent sampling period scientific quality 50 mg/Nm3 (spot Ammonia slip (NH3) BAT20 measurements, may be used for at least half an BAT 5 hour) Average over the 0.1 ng/Nm3 sampling period Dioxins and furans (PCDD/F) BAT27 (6 - 8 hours) BAT 27

Average over the

sampling period Total organic carbon (TOC) - (spot measurements, for at least half an hour)

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Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

Average over the sampling 3 0.05 mg/Nm BAT period (spot Note 1 Mercury (Hg) and its compounds 28 measurements, for at least half an hour) BAT 28

3 The sum of cadmium (Cd) and 0.05 mg/Nm Average over thallium (Tl) and their compounds BAT28 the sampling period (6 - 8 hours) BAT 27 Average over the The sum of antimony (Sb), arsenic (As), lead (Pb), chromium (Cr), sampling period 3 cobalt (Co), copper (Cu), 0.5 mg/Nm (spot manganese (Mn), nickel (Ni), BAT28 measurements, vanadium (V) for at least half an hour)

3 Note 1: The licensee shall investigate emission values higher than 0.03mgHg/Nm , the objective being to identify the source of the emission and reduce the emission level. BAT 28. Note 2: Schedule C2.1 shall be removed within six months following the receipt of the licence final determination /or at a date to be agreed with the Agency. Coal mill 6 stack will be decommissioned thereafter. ------::.------

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Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

Appendix B Noise condition

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Irish Cement Proposed Determination of Licence Number P0029-06 Objection (Submission) to PD

Proposed changes to Schedule C.1.1 (changes highlighted in blue type)

C.1 Noise Emissions C.1.1 Noise Monitoring

Monitoring Locations: Noise Sensitive Locations and any Location as required by the Agency

Emission limit value Monitoring Note 3 Daytime dB Evening time dB Night time dB Tonal / Measurement Frequency LAr,T (30 LAr,T (30 LAr,T (15-30 Impulsive minutes) minutes) minutes) component

LAeq,T LA90 LA10 55 50 45 No clearly 1/3 Octave Band audible Analysis Bi-annually Fast Fourier Transform (FFT) Analysis

2 Period Minimum Survey Duration Note Daytime A minimum of 3 sampling periods at each noise monitoring location Evening-time A minimum of 1 sampling period at each noise monitoring location. Night-time Note 1 A minimum of 2 sampling periods at each noise monitoring location. Note 1: Night-time measurements should be made between 2300hrs and 0400hrs, Sunday to Thursday, with 2300hrs being the preferred start time. Note 2: The survey specified in Condition 6.19.1 shall be undertaken in accordance with the methodology specified in the 'Guidance Note for Noise: Licence Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4)' as published by the Agency. Note 3: The frequency of monitoring may be amended with approval of the Agency as per Condition 6.10

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Appendix C Typographical Amendment (Nitrite/Nitrate)

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Objection OS005830 Page 20 of 22

Proposed changes to Schedule C.7.1 (changes highlighted in blue type)

C. 7 Ambient Monitoring

C.7.1 Groundwater Monitoring and Trigger Levels

Locations: Quarry groundwater extraction well (quarry sump) GWI, GW2 & GW4

Groundwater Groundwater Monitoring Analysis Parameter Trigger Level Threshold Note4 Values Frequency Method/Technique Water level - - Biannually Dip meter pH 8.0 > 6.5 - < 9.5 Biannually pH electrode/meter Conductivity 1,500 µS/cm 800-1,875 Biannually Standard Method µS/cm Total ammonia Biannually Standard Method Chloride 250 mg/l 24-187.5 mg/l Biannually Standard Method Major Anions - - Biannually Standard Method Major Cations - - Biannually Standard Method Individual heavy - - Biannually Atomic Absorption/ICP metals Note 1 Trace Organics Note 2 - - Biannually GC-MS Calcium 200 mg/l - Annually Standard Method Magnesium 50mg/l - Annually Standard Method Sodium 150 mg/l 150 mg/l Annually Standard Method Potassium 25 mg/l - Annually Standard Method Sulphate 200mg/l 187.5 mg/l Annually Standard Method Nitrate 25 mg/l - Annually Standard Method Nitrite 0.1mg/l 37.5mg/l Annually Standard Method Aluminum 0.2 mg/l - Annually Standard Method Fluoride 1.0 mg/l - Annually Standard Method Boron 1.0mg/1 0.75 mg/l Annually Standard Method Total Hydrocarbons 0.0l mg/l - Annually Standard Method Visual Any change - Annually Standard Method Odours Any change - Annually Standard Method Other Note3 - - As maybe To be approved by the required Agency

Note 1: Antimony, arsenic, cadmium, chromium, copper, lead, mercury, nickel, selenium, molybdenum and zinc. Note 2: Screening for priority pollutant list substances (such as US EPA volatile and/or semi-volatile compounds). Note 3: Other parameters as may be agreed by the Agency. Note 4: Groundwater Trigger Levels as agreed by the Agency on the 2nd September 2011.

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Irish Cement Proposed Determination of Licence Number P0029-06 Appeal

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