Irish Cement Limited: Alternative Fuels and use of Alternative Raw Materials Environmental Impact Statement
WATER AND HYDROLOGY
7.1 Introduction This chapter assesses the construction and operational impacts of the proposed development on hydrology, surface water and drainage.
7.2 Methodology This chapter has been completed in accordance with the applicable guidelines as presented in the following section.
Environmental Protection Agency (EPA) Guidance
Legislation and Guidance The EU Water Framework Directive 2000/60/EC came into force on 22 December 2000, and was transposed into Irish legislation by the European Communities (Water Policy) Regulations 2003 (SI 722 of 2003). This legislation provides a co-ordinated approach across Europe for all water policies, establishing a management structure for future water policy.
Key objectives of the Directive are to:
. Protect all waters, including rivers, lakes, groundwater, transitional and coastal waters. . Achieve “good status” in all waters by 2015, and maintaining “high status” where the status already exists. . Have water management programmes and strategies based on the whole River Basin Districts (RBD). Earlier legislation includes: For inspection purposes only. Consent of copyright owner required for any other use. . European Communities (Quality of Salmonid Waters) Regulations 1988 (SI 293 of 1988). . Local Government (Water Pollution) Acts 1977 – 1990. . Water Quality Standards for Phosphorus Regulations 1998 (SI 258 of 1998).
The implementation of the Water Framework Directive and its associated policies has necessitated the introduction of new regulations in Ireland including:
. European Communities Environmental Objectives (Surface Waters) Regulations 2009 (SI 272 of 2009). Under the Water Framework Directive, and the European Communities (Water Policy) Regulations 2003 (SI 722 of 2003), the water quality of River Basin Districts is assessed biologically, physically and chemically. Assessment using surveys is predominately conducted by the EPA and local authorities, and complemented by other government bodies including the Central Fisheries Board and the Marine Institute. Table 7.1 summarises the quality classes used to establish and monitor the condition of rivers and streams in Ireland.
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Table 7.1: River and Stream Water Quality Classes (EPA, 2012)
Q Value1 WFD Status Pollution Status Condition2
Q5, Q4-5 High Unpolluted Satisfactory
Q4 Good Unpolluted Satisfactory
Q3-4 Moderate Slightly polluted Unsatisfactory
Q3, Q2-3 Poor Moderately polluted Unsatisfactory
Q2, Q1-2, Q1 Bad Seriously polluted Unsatisfactory
where: Biotic indices or Quality (Q) value indicates specified groups of macro- invertebrates sensitivity to pollution, with:
Q5 = Mostly pollution sensitive, a few to numerous less pollution sensitive, a few pollution tolerant, and no very pollution tolerant or most pollution tolerant macro-invertebrate species.
Q4 = At least one pollution sensitive, few to numerous less pollution sensitive, numerous pollution tolerant, and a few or no very pollution tolerant or mostly tolerant macro-invertebrate species.
Q3 = No pollution sensitive, few or no less pollution sensitive, dominant in pollution tolerant, a few to common in very pollution tolerant, and few or no most pollution tolerant macro-invertebrate species.
Q2 = No pollution sensitive or less sensitive, few or no pollution tolerant, dominant in very pollution tolerant, and few to common in most pollution tolerantFor inspection macropurposes only.-invertebrate species. Consent of copyright owner required for any other use.
Q1 = No pollution sensitive, less sensitive, and pollution tolerant, a few to no very pollution tolerant, and dominant in most pollution tolerant macro- invertebrate species. Note 1: These values are based primarily on the relative proportions of pollution sensitive to tolerant macroinvertebrates resident at a river site. Note 2: "Condition" refers to the likelihood of interference with beneficial or potential beneficial uses.
Existing pollution has an impact on the quality of surface waters and this has been taken into account when characterising individual surface water systems in the following section.
The existing adverse effects are reflected in the EPA Q-Value, which describes the biological status of the watercourse. In general, lower Q-values in a watercourse are associated with higher levels of pollution in a watercourse. The Q-value reflects impacts from surface water run-off (including run-off from agricultural land which may contain nutrients and urban run- off from roads and buildings which may contain solids, hydrocarbons and heavy metals).
The potential for flooding due to the proposed development is considered in relation to the existing situation.
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7.3 Existing Environment The following section describes the existing environment in terms of surface water, drainage systems and attenuation.
Surface water
Introduction The Cement works at Limerick comprises a large land-bank located in the townlands of Bunlicky, Castlemungret and Conigar south of the River Shannon and to the southwest of Limerick City. The site is bounded on the south by the N69 road from Limerick to Foynes.
Mungret Village lies close to the southern boundary of the site. An additional intermittent residential development is located to the southwest of the site. To the east and southeast of the site lie the residential areas of Dooradoyle and Gouldavoher.
In general, the landscape to the south and west is gently undulating agricultural land of medium sized fields with hedgerows and clumps of trees. The site itself is predominately flat to undulating. An active quarry, associated with the Cement Works is in operation on the western side while the disused Bunlicky Clayfield Pond, which drains into the River Shannon, is located to the northeast of the Works. The proposed development is located close to the N69 roadway within the existing developed footprint of the Cement Works and where all existing structures and buildings associated within the cement production process are located.
Bunlicky Pond is located on the landholding of Irish Cement Ltd. It is situated in the floodplain of the Shannon estuary approximately 3km west of Limerick City. The pond is man-made and was formed as a result of the extraction of clay used for the cement production process between 1938 and 1981. It is contained within the boundary of the Inner Shannon Estuary – South Shore pNHA and partly contained within the Fergus Estuary and Inner Shannon For inspection purposes only. North Shore SPA. The pondConsent can of copyrighthold a owner volume required forof any approximately other use. 2.5million m³. There are three sources of water inflow at the lake from ICL:
. Groundwater diverted from the quarry; . Discharges and surface water run-off from the cement works; and . Process water from the cement works.
Surface waters and drainage from other sources not owned or controlled by ICL also drain to Bunlicky Pond including the following:
. Surface water run-off from the N18 (which crosses the middle of the pond on a constructed causeway; . Two discharges from drainage ditches serving the Limerick Municipal Wastewater Treatment Plant; and . A number of other land drains and ditches.
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Bunlicky Pond discharges into the River Shannon via an adjustable weir and flap valves which are intended to prevent the Shannon flowing into the pond at high tide. However, these are not 100% efficient and saline water from the Shannon estuary flows into Bunlicky Pond at high tide.
Water Quality Surface water is discharged from the Limerick Cement Works facility through two emission points, SW1 and SW2 (refer to Figure 7.1). Spent cooling water, quarry water and surface run-off from the facility are discharged through these points.
All surface water runoff passes through a settling tank and interceptor prior to discharge into Bunlicky pond. Monitoring data recorded in 2014 (annual average) is provided in Table 7.2 and 7.3 for SW1 and SW2 and compared to licence limits (P0029-03) respectively, where applicable.
All monitored data is in compliance with licensed limits.
Table 7.2: Monitoring data for SW1
Parameter Limit SW1 monitoring results (2014 annual average)
Temperature 25C 12.2C
pH 6-9 8.1
Biochemical Oxygen 10mg/l 3 mg/l Demand
Mineral oil 12mg/l 0.0 mg/l
Suspended solids - 6.2mg/l Average daily flow 18,000m3/day 1,138 m3/day For inspection purposes only. Consent of copyright owner required for any other use. Table 7.3: Monitoring data for SW2
Parameter Limit SW2 monitoring results (2014 annual average) pH 6-9 7.9
Biochemical Oxygen 6mg/l <2 mg/l Demand
Mineral oil 10mg/l <0.02 mg/l Suspended solids 35 mg/l 6 mg/l
River Shannon The River Shannon drains a catchment of approximately 17,000km2. It rises in County Cavan and flows south for approximately 360km to its discharge point into the Atlantic Ocean.
The Office of Public Works (OPW) operates a number of gauging stations on the River Shannon, however none of these stations are located south of Athlone town and therefore no estimation of low flows can be made.
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Scale at A4 Date Arup, 50 Ringsend Road NTS April 2016 Dublin 4 Discipline Tel +353(0)1 233 4455 Environmental www.arup.ie Figure: 7.1 EPA Monitoring Points Job No Drawing Status Client Title Job Title 325373-47 Report Irish Cement Ltd Irish Cement and Emission Points Alternative Drawing No Issue Fuels Facility N2007 P2
N (2060) Incherky Quay
(2500) Castleconnel: Worlds End
(2600) Athlunkard Bridge
For inspection purposes only. Consent of copyright owner required for any other use.
SW1 & SW2 Discharge Point \\dubnts03\Dublin_Jobs\D5300-D5399\D5373\4) Drawings\f) Environmental\47\N4007_325373-47_R2_Fig7.1.dwg Do not scale 2UGQDQFH6XUYH\,UHODQG/LFHQFH1R(1*RYHUQPHQWRI,UHODQG $UXS EPA Export 19-05-2016:01:25:10 Irish Cement Limited: Alternative Fuels and use of Alternative Raw Materials Environmental Impact Statement
Water Quality The Environmental Protection Agency (EPA) conducts water quality assessment for both physical-chemical and biological water quality at various locations along the River Shannon. Due to the tidal effects in the Shannon estuary, the furthest downstream monitoring station operated by the EPA Is located at Athlunkard Bridge (X: 158805 Y: 159031) and therefore, no EPA station monitors the water quality downstream of the discharge point from Bunlicky pond. The monitoring stations upstream of the proposed development are as follows and as shown on Figure 7.1: . (2060) Incherky Quay (X:195210 Y:214290) . (2500) Castleconnell: Worlds End (X:165836 Y:163576) . (2600) Athlunkard Bridge (X:158805 Y:159031) The most recent EPA survey of the River Shannon took place in 2014 and indicated that water quality at Incherky Quay was considered good. South of Lough Derg, the last survey indicated that the water quality at Castleconnell was considered moderate. Other previously reported years’ survey Q (Quality) ratings are indicated in Table 7.4.
Table 7.4: River Shannon Biological Quality Ratings (EPA, 2014)
Biological Quality Rating (Q Value)
Station Year 1993 1996 1999 2002 2008 2011 2012 2014
2060 - - - - 3-4 4 - 4
2500 3-4 3-4 3-4 4 3-4 - 3-4 - 2600 3-4 3-4 3-4 3-4 - - - -
Flood Risk For inspection purposes only. There is no record of floodConsent events of copyright in the owner vicinity required for of any the other use.Irish Cement site contained on the
OPW database of events (ref. www.floodmaps.ie). On this basis, flood risk is not considered further as no measures are proposed that may increase the risk of flooding in the area.
Irish Cement Drainage System and Attenuation Surface water is discharged to Bunlicky Pond from the Cement Works facility through two emission points, SW1 and SW2. SW1 comprises surface water run-off from site, storm water and spent cooling water. SW2 emission comprises the discharge from a pump sump in the limestone quarry which also discharges to Bunlicky Pond via enclosed pipe and eventually to an open trench.
Water discharged from SW1 and SW2 passes through settling tanks and interceptors prior to discharge into Bunlicky pond (refer to Figure 7.1). The separators are Class 1 full retention separators and the settling tanks and interceptor are in accordance with I.S.EN-858-2:2008 (separator systems for light liquids). The interceptors have been installed and maintained in compliance with the Industrial Emissions licence (Register Number P0029-03) requirements.
Silt traps and an oil separator have been installed as follows:
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. Silt traps to ensure that all storm water discharges, from the installation pass through a silt trap in advance of discharge; . An oil separator on the storm water discharge from yard areas. The separator is a Class I full retention separator.
Full details of the frequency and method of monitoring are outlined in Tables 7.5 and 7.6 for SW-1 and SW-2.
Table 7.5 Monitoring of emission parameters from SW-1
Parameter Monitoring frequency Technique
Flow Continuous daily On-line flow meter with recorder
Temperature Monthly Temperature probe
pH Monthly pH meter
Biochemical oxygen demand Monthly Standard method
Suspended solids Monthly Standard method Mineral oil Monthly Standard method
Toxicity Annually To be agreed by the Agency
Visual inspection Weekly Sample and examine for colour and odour
Table 7.6 Monitoring of emission parameters from SW-2
Parameter Monitoring frequency Technique
pH Quarterly pH meter Conductivity Quarterly Conductivity meter
Biochemical oxygen demand Quarterly Standard method For inspection purposes only. Consent of copyright owner required for any other use. Suspended solids Quarterly Standard method Mineral oil Quarterly Standard method
Foul water discharge Foul water effluent is comprised of domestic wastewater and utilities wastewater from laboratories. The wastewater is pumped to the Limerick County Council / Irish Water Municipal Wastewater Treatment Plant at Bunlicky. In addition, four septic tanks are in operation. The septic tanks are emptied by a bowser when they reach capacity. The contents are then transferred to a holding tank and then pumped to the Council wastewater treatment plant.
7.4 Potential Impacts of the Proposed Development The following sections examine the potential impacts of the proposed development.
‘Do Nothing’ or ‘As It Exists’ Scenario The do-nothing scenario is described in the existing environment section above.
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Construction Phase All construction activities will be carried out within the catchment area of the site drainage system. All surface water from the site passes through silt traps and Class I full retention separators.
Surface construction activities pose a potentially risk to all watercourses as these sites will be exposed to rainfall which has the potential to produce run-off. Surface water run-off from surface construction activities has the potential to become contaminated. The main contaminants arising from surface construction activities include: . Suspended solids: arising from ground disturbance and excavation; . Hydrocarbons: accidental spillage from construction plant and storage depots; . Faecal coliforms: contamination from coliforms can arise if there is inadequate containment and treatment of on-site toilet and washing facilities; and . Concrete/ cementitious products: arising from construction materials. These pollutants pose a temporary risk to surface water quality for the duration of construction if not properly contained and managed. Suspended solids, which can include silt, affect surface water turbidity and are considered to be the most significant risk to surface water quality from construction activities. Suspended Solids can also reduce light penetration, visually impact the receiving water and damage the ecosystem. Potential activities that could generate suspended solids include:
. Water removal from surface excavations as a result of rainfall or groundwater seepage; . Runoff from exposed work areas and excavated material storage areas ;and . Cement washdown areas: The potential for washdown containing cement to increase the pH of water above a neutral range, that is typically pH 6 to 9, could pose a threat to aquatic species living in a watercourse. For inspection purposes only. Potential activities that couldConsent generate of copyright ownerother required pollutants for any other listeduse. above may include:
. Inappropriate handling and storage; . Leakage of temporary foul water services; and . Solid (municipal) wastes entering watercourses or drainage systems. All construction activities will be carried out within the catchment area of the site drainage system. All surface water from the site passes through Class I full retention separators and silt traps prior to discharge.
Operational Phase The proposed development will give rise to minor additional rainwater runoff from the roofs of the proposed main structures/areas as outlined below:
. Tyre storage handling area; . Pumpable fluids storage area; . Fine solids handling building; . Raw materials store; . Free flowing solids store; . Bypass filter and cooling tower;
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. Fine solids building; . Course solids building.
The total additional impermeable area from these buildings will be c.1.5 ha. The new buildings will generally be located on ground that is currently hard-standing. The runoff from the roofs of new buildings will be collected in a storm water drain which will be connected to the overall site box drainage network. All new liquid alternative fuels and alternative raw materials will be stored in tanks/silos which will be bunded, so no potential impact on surface water is envisaged.
The introduction of up to 90,000 tonnes of Alternative Fuels will also include the provision of three new fire water retention tanks:
. A 25.6m x 10.6m x 2.5m tank associated with the tyre storage / handling area; . A 10.6m x 9.6m x 2.5m tank associated with the fine solids handling building; . A 9.6m x 9.6m x 2.5m tank associated with the coarse solids building.
Fire Water Retention Tanks are connected to the surface water drainage network. This drainage network has an open/shut valve which under normal circumstances is open to allow for the drainage of surface water. In the event of a fire, the drainage valve closes to allow for the retention of all potentially contaminated surface water. This water is then tested and approved for release, treated on-site or removed from the site for treatment, as required.
In addition, the Limerick Cement Works will be obliged to continue to comply with the limits outlined in the Industrial Emissions licence for the facility. The facility currently operates well within licence parameters and will continue to comply with the proposed development in place.
Worst case Scenario For inspection purposes only. Consent of copyright owner required for any other use. The worst-case scenario is considered in the assessment outlined in Section 7.4.3.
7.5 Mitigation Measures
Construction Phase Prior to construction the Contractor will be required to develop an Environmental Management Plan which will incorporate the mitigation measures detailed below. These mitigation measures apply for the prevention of pollution to all waters during construction. Prepare an Emergency Response Plan detailing the procedures to be undertaken in the event of flooding, a spill of chemical, fuel or other hazardous wastes, a fire, or non- compliance incident. This plan will contain the following information: . Containment measures; . List of appropriate equipment and clean-up materials; . Maintenance schedule for equipment; . Details of trained staff, location, and provision for 24-hour cover; . Details of staff responsibilities; . Notification procedures to inform the relevant environmental authorities;
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. Audit and review schedule; . Telephone numbers of LCCC Drainage and Pollution Control Divisions; and . List of specialist pollution clean-up companies and their telephone numbers.
Ensure site staff are trained in the implementation of the Emergency Response Plan and the use of any spill control equipment as necessary;
Prepare method statements for the control, treatment and disposal of potentially contaminated surface water;
Prepare a site plan showing the location of all surface water drainage lines and proposed infiltration areas/discharge to combined sewer. This shall include the location of all existing and proposed surface water protection measures, including monitoring points and treatment facilities;
Ensure that all appropriate licences required for construction are obtained from the relevant authorities;
The Contractor will comply with the following guidance documents: . CIRIA – Guideline Document C532 Control of Water Pollution from Construction Sites (CIRIA, 2001) and . CIRIA – Guideline Document C624 Development and Flood Risk - guidance for the construction industry (CIRIA, 2004).
Operational Phase There will be no significant change in the nature or quantity of runoff to surface waters as a result of the proposed use of alternative fuels and raw materials on site.
For inspection purposes only. 7.6 Residual Impacts Consent of copyright owner required for any other use.
There will be no residual impact on water and hydrology as a result of the proposed development.
7.7 References EPA, (2015) Revised Guidelines on the Information to be contained in Environmental Impact Statements, DRAFT. Johnstown Castle, Co. Wexford
EU Council Directive 2000/60/EC of 22 December 2000 establishing a new framework for Community action in the field of water policy (Water Framework Directive and associated Annexes including Directive 2007/60/EC on the assessment and management of flood risks). Government Publications, Dublin, Ireland.
European Communities (Water Policy) Regulations 2003 – 2005. (S.I. No. 722 of 2003). Government Publications, Dublin, Ireland.
EPA, (2015). Environmental Monitoring River Quality Surveys: Biological Website http://www.epa.ie/QValue/webusers
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Irish Cement Industrial Emissions License Reg No. P0029-03
Local Government (Water Pollution) Act 1977. (S.I. No. 1 of 1977). Government Publications, Dublin, Ireland.
Local Government (Water Pollution) (Amendment) Act 1990. (S.I. No. 21 of 1990). Government Publications, Dublin, Ireland.
Local Government (Water Pollution) Act, 1977 (Water Quality Standards for Phosphorus) Regulations 1998, (S.I. No. 258 of 1998). Government Publications, Dublin, Ireland.
European Communities (Quality of Salmonid Waters) Regulations 1988, (S.I. No. 293 of 1988). Government Publications, Dublin, Ireland.
For inspection purposes only. Consent of copyright owner required for any other use.
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8 AIR QUALITY & CLIMATE
8.1 Introduction Irish Cement Limited (ICL) is licenced by the Environmental Protection Agency (EPA) - Industrial Emissions (IE) Licence Register Number P0029-03) to operate a cement manufacturing facility at Castlemungret, Co. Limerick. Under this application, ICL proposes to introduce the use of alternative fuels and raw materials at the facility. This section assesses the impact of emissions from the facility on air quality and climate. In addition, an air quality impact assessment of the change in traffic volumes due to the development is considered. Construction impacts are also assessed. This section also assesses the impact of the development on carbon emissions (greenhouse gases).
8.2 Methodology
8.2.1 Introduction The impact on air quality is assessed by comparing existing predicted ground level concentrations (GLCs) of pollutants emitted from Limerick Cement Works with those from the proposed scenario. The ICL IE licence will be reviewed by the EPA to take account of the introduction of alternative fuels and raw materials. In addition to these changes, other amendments will be made to the licence to ensure compliance with relevant new legislation and guidance, including: . Industrial Emissions Directive 2010/75/EU . BAT Conclusion on the Production of Cement, Lime and Magnesium Oxide, 2013 The limits that ICL will be required to comply with in the new licence are considered in the proposed scenario assessed in Section 8.4.3. These limits are more stringent than the limits currently imposed by the existing licence. ICL will be obliged to comply with these limits when For inspection purposes only. the new licence is issued followingConsent of the copyright current owner required licence for any review other use. process for the use of new fuels and raw materials. In addition, ICL proposes to increase the volumetric flow rate limits included in the current licence for kiln 6, cement mill 6 and cement mill 7. This increase does require any new structures or changes to the existing process. Air emissions are modelled using Breeze AERMOD computer package at licenced limits. These are considered as worst-case emissions. Stack air emissions monitoring completed in 2014 show ICL to be in compliance with licence limits. Cumulative levels have been considered through a review of other major emitters in the area. This study has been completed in accordance with the Environmental Protection Agency (EPA) Guidance, Air Dispersion Modelling from Industrial Installations Guidance Note (AG4). Potential impacts due to construction activities and due to traffic accessing the site during the construction and operational phases are also considered. The climate impact assessment considers the changes in carbon emissions arising from the replacement of a portion of fossil fuels with alternative fuels.
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EPA Export 19-05-2016:01:25:10 8.2.2 Air Quality Standards and Limit Values In order to reduce the risk to human health and the environment due to poor air quality, national and European statutory bodies have set limit values for a range of air pollutants in ambient air. These limit values or Air Quality Standards (AQS) are defined for the protection of human health and ecosystems. For other pollutants, air quality guidelines are recommended by the World Health Organisation (WHO, 2000) and the UK Environment Agency (UK EA, 2011).
Statutory Air Quality Standards The Air Quality Standards Regulations 2011 (S.I. No. 180 of 2011) transpose EU Directive 2008/50/EC into Irish law. The purpose of the 2011 regulations is to establish limit values and alert thresholds for concentrations of certain pollutants, to provide for the assessment of certain pollutants using methods and criteria common to other European Member States, to ensure that adequate information on certain pollutant concentrations is obtained and made publically available and to provide for the maintenance and improvement of ambient air quality where necessary. The Arsenic, Cadmium, Mercury, Nickel and Polycyclic Aromatic Hydrocarbons in Ambient Air Regulations 2009 (SI 58 of 2009) provide limit values for Cadmium, Arsenic, Lead and Nickel.
The limit values established under both sets of regulations are included in Table 8.1 below
Table 8.1 Air Quality Standards (AQS) from S.I. No. 180 of 2011 and S.I. No. 58 of 2009
Pollutant Limit value for Averaging Limit Basis of application of Limit value the protection period value limit value attainment date of: (μg/m3)
NO2 Human Health 1-hour 200 ≤18 exceedances p.a. 1 January 2010 (99.79 %ile)
Calendar year 40 Annual mean 1 January 2010
NOx Protection of Calendar year 30 Annual mean 1 January 2010 vegetation
PM10 Human Health 24 - hours For inspection purposes50 only. ≤35 exceedances p.a. 1 January 2005 Consent of copyright owner required for any (90%ile)other use.
Calendar year 40 Annual mean 1 January 2005
2 PM2.5 Human Health Calendar year 20 Annual mean 1 January 2020
SO2 Human Health One-hour 350 ≤24 exceedances p.a. 1 January 2020 (99%ile)
Human Health Calendar year 125 ≤3 exceedances p.a. 1 January 2020 (90.41 %ile)
Protection of Calendar year 20 Annual mean 1 January 2020 vegetation
Lead Human Health Calendar year 0.5 Annual mean 1 January 2010
As (arsenic) Human health Calendar year 0.006 Annual mean 31 December 2012 Cd Human health Calendar year 0.005 Annual mean 31 December 2012 (cadmium)
Ni (nickel) Human health Calendar year 0.02 Annual mean 31 December 2012
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EPA Export 19-05-2016:01:25:10 Air Quality guidelines No air quality standards currently exist for the following pollutants: . Hydrogen chloride (HCl) . Hydrogen fluoride (HF) . Thallium . Mercury . Antimony and other heavy metals . Dioxins and furans. Relevant guidelines are therefore taken from guidance issued by the UK Environment Agency and the World Health Organisation, refer to Table 8.2 below. The table includes both short and long term environmental assessment levels (EALs) which are compared to the predicted one hour and annual concentrations respectively. Currently no internationally recognised air quality standards are prescribed for dioxins in ambient air. The WHO guidance states that “concentrations of 0.3pg/m3 or higher are indications of local emission sources that need to be identified and controlled”. This is described as an “indicative value”.
For inspection purposes only. Consent of copyright owner required for any other use.
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EPA Export 19-05-2016:01:25:10 Table 8.2: Air Quality Guidelines
Parameter Limit value (μg/m3) Averaging period Source of Guideline
HCl 750 1 hour (Short term EAL) UK EA (2011)
HF 16 Monthly (Long term EAL) UK EA (2011)
HF 160 1 hour (Short term EAL) UK EA (2011)
Calendar year (Long term Tl (thallium) 1 UK EA (2002) EAL)
Tl (thallium) 30 1 hour (Short term EAL) UK EA (2002)
Mercury 1 Calendar year WHO (2000)
Calendar year (Long term Sb (antimony) 5 UK EA (2011) EAL)
Sb (antimony) 150 1 hour (Short term EAL) UK EA (2011)
Calendar year (Long term Cr (chromium) 5 UK EA (2011) EAL)
Cr (chromium) 150 1 hour (Short term EAL) UK EA (2011)
Calendar year (Long term Co (cobalt) 0.2 UK EA (2002) EAL)
Calendar year (Long term Cu (copper) 10 (dust and mist) UK EA (2011) EAL)
Cu (copper) 200 (dust and mist) 1 hour (Short term EAL) UK EA (2011)
Calendar year (Long term Mn (manganese) 0.15 UK EA (2011) EAL)
Mn (manganese) 1,500 1 hour (Short term EAL) UK EA (2011) UK EA (2011) V (vanadium) 1 For inspection purposes only.24 hours Consent of copyright owner required for any other use.
Calendar year (Long term UK EA (2011) V (vanadium) 5 EAL)
V (vanadium) 1 1 hour (Short term EAL) UK EA (2002) WHO (2000) Calendar year Dioxins 0.0000003 Indicative value
Long term EAL (annual 180 average GLC) Ammonia UK EA (2011) 2,500 Short term EAL (1-hour average)
Dust deposition monitoring on a quarterly basis is required by the Irish Cement Industrial Emission licence with a limit of 240mg/m2/day (based on a 30 day composite sample) at the site boundary. The impact of the use of alternative fuels on sensitive ecological sites is also assessed. Predicted nitrogen deposition values are compared to the UNECE (2003) Critical Loads for Nitrogen for Permanent oligotrophic waters, softwater lakes of 5-10 kg (N) ha-1yr-1 at Bunlicky Pond which
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EPA Export 19-05-2016:01:25:10 forms part of the Inner Shannon Estuary – South Shore NHA and is partially included in the Fergus Estuary and Inner Shannon, North Shore SPA.
8.2.3 Construction Phase Methodology Dust emissions are likely to arise from the following activities: . Site earthworks . Handling of construction materials . Construction works . Construction traffic movements In general, any additional airborne concentrations of particulate matter arising from construction would be small and very local to the construction activity (minimising human exposure). Particles generated by most construction activities tend to be larger than 10μm in diameter which are not considered harmful to health. As stated in the Transport Infrastructure Ireland, TII, (formerly National Roads Authority (NRA)) document 'Guidelines for the Treatment of Air Quality during the Planning and Construction of National Road Schemes’, 2011 it is “very difficult to accurately quantify dust emissions arising from construction activities”. “A semi quantitative approach is recommended to determine the likelihood of a significant impact, which should be combined with an assessment of the proposed mitigation measures”. The semi-quantitative assessment methodology outlined in Table 8.3 is used to assess the impact of dust during the construction phase. This approach considers sensitive receptors in the vicinity of the construction site. The TII guidance defines sensitive receptors as locations including residential housing, schools, hospitals, places of worship, sports centres and shopping areas, i.e. locations where members of the public are likely to be regularly present. The guidance states that dust emissions from construction sites can lead impacts at nearby properties. The assessment criteria, taken from the TII guidance, are outlined in Table 8.3 below.
Table 8.3: Assessment criteria for the impact of dust emissions from construction activities with standard mitigation For inspection purposes only. in place Consent of copyright owner required for any other use. Source Potential distance for Significant Effects (Distance from Source) a Scale Description Soiling PM10 Vegetation Effects Major Large construction sites, with high use of haul 100 m 25 m 25 m routes Moderate Moderate sized construction sites, with moderate 50 m 15 m 15 m use of haul routes Minor Minor construction sites, with limited use of haul 25 m 10 m 10 m routes a Significance based on the PM10 Limit Values specified in SI No. 180 of 2011, which allows 35 daily exceedances/year of 50 μg/m³
The impact of dust emissions during the construction phase is assessed by estimating the area over which there is a risk of significant impacts, in line with the TII guidance. In accordance with TII guidance, emissions from construction vehicles are assessed where construction traffic results in a significant (>10%) increase in AADT (annual average daily traffic) flows near sensitive receptors.
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Introduction The air dispersion modelling study has been carried out in accordance with the EPA AG4 guidelines. The EPA approved Breeze AERMOD computer package (Version 09292) was used to predict the effect of emissions on ambient air quality. The modelling predictions represent the most conservative or worst-case concentrations which could arise. Several worst-case conditions are assumed to be coincident: . Emission sources are operating at maximum flow rates; . Emission sources are operating at maximum permitted emission concentrations, rather than average actual emission concentrations; . Emission sources are operating for every hour of every day of the year; . The assessment is based on the meteorological conditions that give rise to the maximum predicted concentration over a five year period; . Receptor location is that which experiences the maximum predicted concentration The model predictions are therefore extremely conservative, giving worst-case ground-level concentrations, which are unlikely to be realised in practice. Breeze AERMOD is a computer model that predicts the ground level concentration due to pollutant emissions from specified sources. The model requires information on: . Neighbouring buildings; . Receptor locations; . Meteorological conditions;
. Conversion of NOx to NO2; . Emission sources. The model was used to predict ground level concentrations over 1-hour, 8-hour 24-hour and annual averaging period and relevant For inspectionpercentiles. purposes only. Consent of copyright owner required for any other use.
Building Wake Effect The length, width and height of buildings in the vicinity of the sources were taken into account in modelling. Building data was taken from information supplied by Irish Cement for the current situation and for the proposed development. AERMOD includes a software utility called BPIP to calculate direction-specific building downwash factors using the relative positions and dimensions of sources and neighbouring buildings.
Receptor locations Two nested, Cartesian receptor grids were used, centred on the Cement Works, as in previous assessments. One has receptors covering a 10km by 10km area at 500m intervals. The other has receptors covering a 2km by 2km area at 100m intervals. Elevations were taken from Ordnance Survey mapping.
Meteorological data Meteorological data from Met Éireann’s synoptic station at Shannon Airport was used for 2003 to 2007 inclusive. The meteorological data includes hourly values for wind speed, wind direction, atmospheric stability, ambient temperature and mixing height.
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EPA Export 19-05-2016:01:25:10 Conversion of NOx to NO2
The EPA Guidance AG4 advises that detailed modelling of NO2/NOx chemistry should use the Plume Volume Molar Ratio Method (PVMRM) in AERMOD. This method takes account of the complex and reversible chemical reactions between the oxides of nitrogen, oxygen and ozone. The PVMRM uses both plume size and ozone (O3) concentration to derive the amount of O3 available for the reaction between NO and O3. For a given NOx emission rate and ambient ozone concentration, the NO2/NOx conversion ratio is primarily controlled by the volume of the plume. This method has been shown to give better agreement with monitoring data. For the PVMRM calculation, the following assumptions are made, as advised by EPA guidance: . Background ozone is 56.5µg/m3 (average of Zone C monitoring from EPA long term data).
. NO2/NOx equilibrium ratio = 0.90.
. NO2/NOx in-stack ratio = 0.10.
Emission Sources The emission source characteristics are given in Tables 8.4 and 8.5 for the existing situation and for the proposed scenario respectively. The existing scenario is based on the existing permitted emission limit values obtained from the Industrial Emissions licence (No. P0029-03). The proposed scenario considers emission limit values as specified in Annex VI, Part 4 of Directive 2010/75/EU and the more stringent ELVs outlined in the BAT Conclusion on the Production of Cement Lime and Magnesium Oxide, 2013. As kiln combustion gases are used on Coal Mill 6 to provide heat and dry the fuel during milling, the Directive limits are applied for this source also in the proposed scenario. Directive 2010/75/EU sets an ELV for the sum of cadmium and thallium of 0.05mg/Nm3. The air quality standard is set for cadmium only and a UK EAL is published for thallium, refer to Tables 8.1 and 8.2. The proportion of cadmium and thallium has been monitored in Kiln 6 to be <1% and >99% respectively. Therefore cadmium is modelled at <1% of the ELV and thallium at >99% of the ELV. By modelling cadmium and thallium separately, the predicted concentrations can then be compared with the relevant AQS for each. The same methodology is applied for the sum of antimony and other metals.
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Table 8.4 Existing Emissions Sources Data
Source Name Kiln 6 Coal Mill 6 Cement Mill 5 Cement Mill 6 Cement Mill 7 Separator 7 Separator 6
Ref A2-01 A2-02 A2-03 A2-04 A2-06 A2-07 A2-05
Easting (m) 153,344 153,414 153,538 153,458 153,465 153,486 153,482
Northing (m) 154,790 154,785 154,597 154,653 154,665 154,664 154,626 Base (mOD) 10.5 10.5 5.01 4.8 4.8 4.8 4.8
Height (m) 87.7 30.4 29.15 29 29 35.2 40.2
Diameter (m) 2.6 0.788 0.701 0.892 0.892 1.69 1.69 Volumetric flowrate (Nm3/hr) 335,000 35,000 17,000 25,500 25,500 85,000 85,000
Efflux velocity (m/s) 27.15 26.87 16.49 15.9 15.9 13.8 13.8
Temperature (ºC) 150 95 95 110 110 85 85
NOx concentration (mg/Nm³) 800 800 - - - - -
NOx emission rate (g/s) 74.44 7.78 - - - - -
For inspection purposes only. PM10 concentration (mg/Nm³) 50 50 Consent50 of copyright owner required50 for any other use. 50 50 50
PM10 emission rate (g/s) 4.65 0.49 0.24 0.35 0.35 1.18 1.18
SO2 concentration (mg/Nm³) 200 200 - - - - -
SO2 emission rate (g/s) 18.611 1.94 - - - - -
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Table 8.5 Proposed Emissions Sources Data
Source Name Kiln 6 Coal Mill 6 Cement Mill 5 Cement Mill 6 Cement Mill 7 Separator 7 Separator 6
Ref A2-01 A2-02 A2-03 A2-04 A2-06 A2-07 A2-05
Easting (m) 153,344 153,414 153,538 153,458 153,465 153,486 153,482
Northing (m) 154,790 154,785 154,597 154,653 154,665 154,664 154,626
Base (mOD) 10.5 10.5 5.01 4.8 4.8 4.8 4.8
Height (m) 87.7 30.4 29.15 29 29 35.2 40.2
Diameter (m) 2.6 0.788 0.701 0.892 0.892 1.69 1.69
Normalised flow rate (Nm³/hr) 500,000 35,000 17,000 30,000 30,000 85,000 85,000
Efflux Velocity (m/s) 40.52 26.87 16.49 18.7 18.7 13.8 13.8 Temp (ºC) 150 95 95 110 110 85 85
1 NOx concentration (mg/Nm³) 500 500 - - - - - For inspection purposes only. Consent of copyright owner required for any other use. NOx emission rate (g/s) 69.4 4.9 - - - - -
1 SO2 concentration (mg/Nm³) 50 50 - - - - -
SO2 emission rate (g/s) 6.9 0.49 - - - - -
2 PM10 concentration (mg/Nm³) 20 20 20 20 20 20 20
PM10 emission rate (g/s) 2.8 0.19 0.09 0.17 0.17 0.47 0.47
HCl concentration (mg/Nm³)1 10 10 - - - - - HCl emission rate (g/s) 1.4 0.097 - - - - -
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Source Name Kiln 6 Coal Mill 6 Cement Mill 5 Cement Mill 6 Cement Mill 7 Separator 7 Separator 6
Ref A2-01 A2-02 A2-03 A2-04 A2-06 A2-07 A2-05 HF concentration (mg/Nm³)1 1 1 - - - - - HF emission rate (g/s) 0.14 0.0097 - - - - -
Cd concentration (mg/Nm³)1 0.0002 0.0002 - - - - - Cd emission rate (g/s) 0.000028 0.000002 - - - - - Tl concentration (mg/Nm³)1 0.05 0.05 - - - - -
Tl emission rate (g/s) 0.0069 0.0005 - - - - -
Hg concentration (mg/Nm³)1 0.05 0.05 - - - - -
Hg emission rate (g/s) 0.0069 0.0005 - - - - -
Sb concentration (mg/Nm³)1 0.0065 0.0065 - - - - -
Sb emission rate (g/s) 0.0009 0.0001 - - - - -
As concentration (mg/Nm³)1 0.016 0.016 - - - - - For inspection purposes only. Consent of copyright owner required for any other use. As emission rate (g/s) 0.0022 0.0002 - - - - - Pb concentration (mg/Nm³)1 0.072 0.072 - - - - - Pb emission rate (g/s) 0.01 0.0007 - - - - -
Cr concentration (mg/Nm³)1 0.14 0.14 - - - - -
Cr emission rate (g/s) 0.02 0.0014 - - - - - Co concentration (mg/Nm³)1 0.003 0.003 - - - - - Co emission rate (g/s) 0.0004 0.00003 - - - - -
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Source Name Kiln 6 Coal Mill 6 Cement Mill 5 Cement Mill 6 Cement Mill 7 Separator 7 Separator 6
Ref A2-01 A2-02 A2-03 A2-04 A2-06 A2-07 A2-05 Cu concentration (mg/Nm³)1 0.047 0.047 - - - - -
Cu emission rate (g/s) 0.0065 0.0005 - - - - -
Mn concentration (mg/Nm³)1 0.074 0.074 - - - - -
Mn emission rate (g/s) 0.01 0.0007 - - - - -
Ni concentration (mg/Nm³)1 0.094 0.094 - - - - -
Ni emission rate (g/s) 0.013 0.0009 - - - - -
V concentration (mg/Nm³)1 0.044 0.044 - - - - -
V emission rate (g/s) 0.006 0.0004 - - - - -
Dioxins and Furans 0.0000001 0.0000001 - - - - - concentration (mg/Nm³)1 For inspection purposes only. Consent of copyright owner required for any other use. Dioxins and Furans emission 1.4E-8 9.7E-10 - - - - - rate (g/s) Ammonia concentration 50 50 - - - - - (mg/Nm³) Ammonia emission rate (g/s) 6.9 0.49 - - - - -
1 Emission limit values from Directive 2010/75/EU 2 BAT Conclusion on the Production of Cement Lime and Magnesium, 2013
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8.2.5 Operational Traffic Methodology The TII Guidelines for the Treatment of Air Quality during the Planning and Construction of National Road Schemes advise that an air quality impact assessment should be completed on road links where a greater than 5% change in flows occurs during the operational phase. As outlined in Chapter 12, Traffic and Transportation, no roads are predicted to experience increases of greater than 5% during the operational phase and operational traffic impacts are not considered further.
8.2.6 Climate Assessment Methodology While coal has previously been used and could be used again in the future, imported Petroleum Coke (petcoke), a carbon residue left after the oil refining process, is the fossil fuel currently in use at Limerick. After years operating at reduced output, the factory is returning to normal production levels. The proposed development seeks to introduce the use of Alternative Fuels (AF) so as to reduce fossil fuel use at Limerick Cement Works. The proposed development also seeks to introduce alternative raw materials to the cement making process. In total, permission is being sought for a maximum of 90,000 tonnes per annum of alternative fuels and alternative raw materials. The balance of the heat needed for the production process will continue to be sourced from imported fossil fuels. In addition, circa 75,000 tonnes per annum of petcoke will continue to be utilised. For the purposes of the climate impact assessment, the plant running at maximum output under the existing scenario (ie only petcoke) is compared against the proposed maximum output scenario ( reduced quantity of petcoke and 90,000 tonnes of AF per annum).
8.3 Existing Environment
8.3.1 Air Quality S.I. No. 180 of 2011 established a zoning system for areas of Ireland for air quality purposes. For inspection purposes only. Zone C is defined as other citiesConsent [i.e. of copyrightother owner than required Dublin for any and other Cork]use. and large towns and includes Limerick and environs.
Levels of NO2, NOx, SO2, PM10, PM2.5, benzene, mercury, lead, arsenic, cadmium and nickel measured by the EPA in Zone C in 2014, 2013 and 2012 (EPA, 2015, 2014 and 2013) were averaged to represent typical mean background levels, refer to Table 8.6. Where no Zone C data is available from the EPA, monitoring results for Zone B (Cork City) or Zone D (rural) were used. Table 8.7 provides measured concentrations recorded on-site by ICL in 2008.
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Table 8.6: EPA monitoring results for Zone C
Annual mean 2014 Annual mean 2012 Average annual mean Pollutant Annual mean 2013 (2012-2014)
5 µg/m3 5 µg/m3 4 µg/m3 4.6µg/m3 NO2
8 µg/m3 9 µg/m3 7 µg/m3 8µg/m3 NOx
4 µg/m3 3 µg/m3 3 µg/m3 3.3 µg/m3 SO2
21 µg/m3 19µg/m3 17.3 µg/m3 19.1 µg/m3 PM10
12µg/m3 12µg/m3 12µg/m3 12µg/m3 PM2.5
3 3 1 3 3 Benzene 0.1µg/m 0.5µg/m 0.6 µg/m 0.4µg/m
3 3 3 3 Lead3 1.8 ng/m 2.2 ng/m 8.1 ng/m 4ng/m
3 3 3 3 Arsenic3 0.4 ng/m 3.6 ng/m 1ng/m 1.7 ng/m
3 3 3 3 Cadmium3 0.2 ng/m 0.2 ng/m 0.4 ng/m 0.27ng/m
3 3 3 3 Nickel3 1.6 ng/m 1.3 ng/m 1.6 ng/m 1.5 ng/m
3 3 3 3 Mercury3 1.4ng/m 1.5 ng/m 1.5ng/m 1.5ng/m 1 EPA Zone B averages, as insufficient data or no data for Zone C 2 EPA Zone D averages, as insufficient data or no data for Zone C 3 Monthly levels
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Table 8.7: ICL Monitored Background Pollutant Concentrations (µg/m³)
3 Pollutant Background Concentration – two-month average (µg/m )
HCl 0.97
HF <0.0155
Cd (cadmium <0.00059
Tl (thallium) <0.00059
Mercury <0.00059
Sb (antimony) 0.00416
As (arsenic) <0.00059
Pb (lead) 0.00163
Cr (chromium) 0.00089
Co (cobalt) <0.00059
Cu (copper) <0.00059
Mn (manganese) 0.0046
Ni (nickel) <0.00059
V (vanadium) <0.00059
Dioxins 0.000000006
8.3.2 Climate Irish Cement is permitted to emit carbon dioxide by the EPA under Greenhouse Gas Emissions Permit No IE-GHG042-10363-3. The permits allows CO2 emissions from the following sources: For inspection purposes only. Consent of copyright owner required for any other use. . Kiln 6/Coal Mill stack . Kiln emergency generator . Acetylene – mobile welding In April 2015, the EPA stated that participants in the EU Emissions Trading Scheme (EUETS) based in Ireland reported an increase of 1.7% in greenhouse gas emissions in 2014 compared to 2013. This is compared to a decrease of approximately 4% across the EU. An increase of 31% was reported for the Cement industry as it recovers from a deep recession. Data for 2013 demonstrates that even though accounted for under two different systems ( ie Traded(EUETS) and Non-Traded) the CO2 from the cement industry represents just 3% of the aggregated total for Ireland.
Participants in the EU Emissions Trading Scheme in Ireland reported 15.95 Mtonnes CO2 for 2014 in contrast to the 15.68 Mtonnes CO2 in 2013.
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8.4 Predicted Impacts of the Proposed Development
8.4.1 Construction Phase Based on the definitions provided in Table 8.3, the proposed construction site is considered to be at a ‘minor’ scale. This category of site has the potential for significant soiling impacts within 25m; PM10 impacts within 10m; and vegetation impacts within 10m of the site boundary if standard mitigation measures are in place. As no sensitive receptors are located within 25m of the areas of the proposed construction works, no significant impacts due to construction activities are envisaged. It should be noted that the development will occur over a number of construction stages; each likely to be of approximately 6 to 9 months duration.
8.4.2 Operational Phase The use of alternative fuels and alternative raw materials will result in a number of positive indirect effects on air quality and climate, for example: . reduced use of natural raw materials, . reduced energy requirement for blasting and crushing. An assessment of the direct effects are considered below. The maximum predicted ground- level concentrations (GLCs) are presented in Table 8.8 for the existing and the proposed scenarios. The percentage change in pollutant concentrations is calculated relative to the air quality standards.
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Table 8.8 Predicted ground level concentrations for the existing and proposed scenarios
Parameter Air Quality Background Predicted existing Predicted Total Total Percentage of Percentage Standard (µg/m3) Concentration concentration proposed concentration for concentration for proposed scenario difference (µg/m3) (µg/m3) concentration existing scenario proposed scenario relative to AQS (%) between existing (µg/m3) (µg/m3) (µg/m3) and proposed scenarios relative to AQS (%) PM10 40 (Annual) 19.1 3.1 1.2 22.2 20.3 50.6 -4.8 50 (24-hour) (90.41st 19.1 10.6 4.2 29.7 23.3 46.6 -12.8 percentile) PM2.5 25 (Annual) 12 2.1 0.8 14.1 12.8 51.2 -5.2 Nitrogen 40 (Annual) 4.6 1.3 1.1 5.9 5.7 14.2 -0.5 Dioxide 200 (99.79 9.2 38.2 29.8 47.4 39 19.5 -4.2 percentile) Nitrogen 30 (Annual) 8 6.2 3.8 14.2 11.8 39.5 -7.9 Oxides Sulphur 20 (Annual) 3.3 1.6 0.4 4.9 3.7 18.4 -5.8 Dioxide 125 (24-hour) (99.18th 3.3 13.5 3.4 16.8 6.7 5.3 -8.1 percentile) 350 (1-hour) (99.73rd 6.6 51.1 12.7 57.7 19.3 5.5 -11.0 For inspection purposes only. percentile) Consent of copyright owner required for any other use. 20 (Annual) 0.97 - 0.08 - 1.05 5.2 - Hydrogen 750 (1-hour) - Chloride 1.94 - 4.23 6.2 <1 - Hydrogen 1 (Annual) 0.0155 - 0.008 - 0.024 2.3 - Fluoride 160 (1-hour) 0.031 - 0.42 - 0.45 <1 - Cadmium 0.005 (Annual) 0.00059 - 0.000001 - 0.00059 11.8 - 1.5 (1-hour) 0.00118 - 0.00009 - 0.0013 <1 - Thallium 1 (Annual) 0.00059 - 0.00041 - 0.00098 <1 - 30 (1-hour) 0.00118 - 0.0218 - 0.02298 <1 - Mercury 1 (Annual) 0.00059 - 0.00041 - 0.00098 <1 - Antimony 5 (Annual) 0.00416 - 0.00008 - 0.00423 <1 - 150 (1-hour) 0.00832 - 0.00436 - 0.01268 <1 -
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Parameter Air Quality Background Predicted existing Predicted Total Total Percentage of Percentage Standard (µg/m3) Concentration concentration proposed concentration for concentration for proposed scenario difference (µg/m3) (µg/m3) concentration existing scenario proposed scenario relative to AQS (%) between existing (µg/m3) (µg/m3) (µg/m3) and proposed scenarios relative to AQS (%) Arsenic 0.006 (Annual) 0.00059 - 0.00016 - 0.00074 12.5 - 15 (1-hour) 0.00118 - 0.00872 - 0.0099 <1 - Lead 0.5 (Annual) 0.00163 - 0.00058 - 0.00218 <1 - Chromium 5 (Annual) 0.00089 - 0.00116 - 0.002 <1 - 150 (1 hour) 0.00178 - 0.061 - 0.06283 <1 - Cobalt 0.2 (Annual) 0.00059 - 0.00002 - 0.0019 <1 - Copper 10 (Annual) 0.00059 - 0.0004 - 0.00098 <1 - 200 (dust and - 0.00118 - 0.0218 0.02298 <1 mist) - Manganese 0.15 (Annual) 0.0046 - 0.00056 - 0.00516 3.4 - 1500 (1-hour) 0.0092 - 0.03052 - 0.03972 <1 - Nickel 0.02 (Annual) 0.00059 - 0.00071 - 0.0013 6.5 - 300 0.00118 - 0.03925 - 0.04043 <1 - Vanadium 5 (Annual) 0.00059 - 0.00034 - 0.00091 <1 - 1 (24-hour) 0.00118 - 0.0047 - 0.00519 <1 - 1 (1-hour) 0.00118 - 0.01744 - 0.01862 1.9 - Dioxins 0.0000003 - 6.00E-09 - 4.5E-13 6.00E-09 2.0 (Annual) For inspection purposes only. Ammonia Consent of copyright owner required for any other use. - 180 (annual) n/a <1 0.402 0.402 2,500 (1 hour) n/a - 21.19 - 21.19 <1
1 Twice the annual mean background concentration (EPA guidance)
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Particulate Matter (PM10 and PM2.5)
The maximum GLC of PM10 is predicted to be 50.6% of the AQS for the annual mean for the proposed scenario. Of this, 47.8% is due to the background concentrations and 2.8% is potentially due to ICL. The predicted concentrations comply with the AQS.
The maximum 24-hour average GLC of PM10 is predicted to be 46.6% of the AQS for the 24- hour mean for the do-something scenario. Of this, 38.2% is due to the background concentration and 8.4% is potentially due to ICL. The predicted concentrations comply with the AQSs.
The maximum GLC of PM2.5 is predicted to be 51.2% of the AQS for the annual mean, refer to Figure 8.1. Of this, 48% is due to the background concentration and 3.2% is potentially due to ICL. The predicted concentrations comply with the AQS. Predicted concentrations are expected to decrease in the proposed scenario relative to the existing scenario due to the required implementation of more stringent emission limit values from the Industrial Emissions Directive 2010/75/EU and BAT Conclusion on the Production of Cement, Lime and Magnesium Oxide.
Oxides of Nitrogen (NO2 and NOx)
The maximum GLC of NO2 is predicted to be 14.2% of the AQS for the annual mean, refer to Figure 8.2. Of this, 11.5% is due to the background concentration and 2.7% is potentially due to ICL. The predicted concentrations comply with the AQS.
th The maximum GLC of NO2 is predicted to be 19.5% of the AQS, for the 99.79 percentile of 1-hour mean values. Of this, 4.6% is due to the background concentration and 14.9% is potentially due to ICL.
The maximum GLC of NOx is predicted to be 39.5% of the AQS for the annual mean for the protection of vegetation. Of this, 26.7% is due to the background concentration and 12.8% is potentially due to ICL. The predicted concentrations comply with the AQS. In general, predicted concentrations are expected to decrease in the proposed scenario relative to the existing scenario due to the required implementation of more stringent emission limit values from the Industrial Emissions Directive 2010/75/EU and BAT For inspection purposes only. Conclusion on the ProductionConsent of of Cementcopyright owner, Lime required and for any Magnesium other use. Oxide.
Sulphur Dioxide (SO2)
The maximum GLC of SO2 is predicted to be 18.4% of the AQS for the annual mean. Of this, 16.5% is due to the background concentration and 1.9% is potentially due to ICL. The predicted concentrations comply with the AQS.
th The maximum GLC of SO2 is predicted to be 5.3% of the AQS for the 99.18 percentile of 24- hour mean values. Of this, 2.6% is due to the background concentration and 2.7% is potentially due to ICL.
rd The maximum GLC of SO2 is predicted to be 5.5% of the AQS for the 99.73 percentile of 1- hour mean values. Of this, 1.9% is due to the background concentration and 3.6% is potentially due to ICL. The predicted concentrations comply with the AQS. Predicted concentrations are expected to decrease in the proposed scenario relative to the existing scenario due to the required implementation of more stringent emission limit values by ICL. The impact of HCl emissions is predicted to be <1% of the limit for the 1-hour mean and 5.2% of the annual limit, including background concentrations.
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Scale at A4 Date Arup, 50 Ringsend Road NTS April 2016 Dublin 4 Discipline Tel +353(0)1 233 4455 Environmental www.arup.ie Figure: 8.1 Job No Drawing Status Client Title Job Title 325374-47 Report Irish Cement Ltd Air Dispersion Modelling Drawing No Issue Assessment N2005 R2
N
For inspection purposes only. Consent of copyright owner required for any other use.
Figure 8.1: Isopleth of 90.41st percentile of 24-hr ground level concentrations of PM10 \\dubnts03\Dublin_Jobs\D5300-D5399\D5374\4) Drawings\f) Environmental\47\N2005_325374-47_R2.dwg 22 Dec 2015 15:57:21 Do not scale 2UGQDQFH6XUYH\,UHODQG/LFHQFH1R(1*RYHUQPHQWRI,UHODQG $UXS
EPA Export 19-05-2016:01:25:11 Created using CADplot http://www.oasys-software.com/cadplot/ A4
Scale at A4 Date Arup, 50 Ringsend Road NTS April 2016 Dublin 4 Discipline Tel +353(0)1 233 4455 Environmental www.arup.ie Figure: 8.2 Job No Drawing Status Client Title Job Title 325374-47 Report Irish Cement Ltd Air Dispersion Modelling Drawing No Issue Assessment N2006 R2
N
For inspection purposes only. Consent of copyright owner required for any other use.
Figure 8.2: Isopleth of 99.79th Percentile of 1-hr Ground Level Concentrations of NO2 \\dubnts03\Dublin_Jobs\D5300-D5399\D5374\4) Drawings\f) Environmental\47\N2006_325374-47_R2.dwg 22 Dec 2015 15:57:15 Do not scale 2UGQDQFH6XUYH\,UHODQG/LFHQFH1R(1*RYHUQPHQWRI,UHODQG $UXS
EPA Export 19-05-2016:01:25:11 Created using CADplot http://www.oasys-software.com/cadplot/ Irish Cement Limited: Expansion of Alternative Fuels and use of Alternative Raw Materials Environmental Impact Statement
Hydrogen Chloride (HCl) The impact of HCl emissions is predicted to be <1% of the limit for the 1-hour mean and 5.2% of the annual limit, including background concentrations.
Hydrogen Fluoride (HF) The impact of HF emissions is predicted to be <1% of the limit for the 1-hour mean and 2.3% of the limit value for the annual mean.
Cadmium (Cd) The impact of Cd emissions, including the background concentration, is predicted to be <1% for the 1-hour mean and <12% of the limit value for the annual mean; of this, >11% is due to the background concentration.
Thallium (Tl) The impact of Tl emissions, including the background concentration, is predicted to be <1% of the limit value for the annual mean and the hourly mean
Mercury (Hg) The impact of Hg emissions, including the background concentration, is predicted to be <1% of the limit value for the annual mean.
Antimony (Sb) The impact of Sb emissions is predicted to be <1% of the limit value for the hourly mean and annual mean.
Arsenic (As) The impact of As emissions is predicted to be <1% of the limit for the 1-hour mean and 12.5% of the limit value for the annual mean; of this, 9.8% is due to the background concentration.
Lead (Pb) The impact of Pb emissions is predicted to be <2% of the AQS for the annual mean. For inspection purposes only. Consent of copyright owner required for any other use. Chromium (Cr) The impact of Cr emissions, including the background concentration, is predicted to be <1% of the limit value for the annual mean and <1% of the limit value for the annual mean.
Cobalt (Co) The impact of Co emissions, including the background concentration, is predicted to be <1% of the limit value for the annual mean.
Copper (Cu) The impact of Cu emissions, including the background concentration, is predicted to be <1% of the limit value for the annual mean and <1% of the limit value for the annual mean.
Manganese (Mn) The impact of Mn emissions, including the background concentration, is predicted to be <4% of the limit value for the annual mean and <1% of the 1-hour mean value.
Nickel (Ni) The impact of Ni emissions is predicted to be <1% of the 1-hour mean value and 6.5% of the limit value for the annual mean; of this, 3% is due to the background concentration.
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Vanadium (V) The impact of V emissions, including the background concentration, is predicted to be <1% of the limit value for the annual mean and of the 24-hour mean value and <2% of the hourly mean.
Dioxins and Furans The impact of dioxin emissions is predicted to be 2% of the WHO (2000) indicative value for the annual mean.
Carbon Monoxide The impact of CO emissions is predicted to be <4% of the 8-hour average; of this, <2% is due to the background concentration.
Ammonia The impact of the ammonia emissions, including the background concentration, is predicted to be <1% of the limit value for the annual mean and <1% of the hourly mean.
8.4.3 Cumulative Impacts The cumulative impacts have been considered through the addition of process emissions from ICL and background levels. No other major emitters are considered likely to contribute to maximum predicted values due to the separation from the ICL site, as follows: . Tarbert – 45km . Moneypoint – 45km . Aughinish Alumina – 20km
8.4.4 Assessment of ecologically sensitive sites 3 The maximum GLC of NOx is predicted to be 13.54μg/m at Bunlicky Pond including a background level of 8 μg/m3. This amounts to 45.1% of the AQS for the annual mean for the protection of vegetation. The predicted concentrations comply with the AQS for the For inspection purposes only. protection of vegetation. ConsentThis worstof copyright-case owner valuerequired foris any predicted other use. on the southern boundary of Bunlicky Pond. Assuming a deposition velocity of 0.001 m/s the nitrogen deposition at Bunlicky Pond is calculated based on the following:
3 -1 -1 1 μg/m NO2 = 0.1 kg N ha yr This results in a value of 1.4 kg N ha-1 yr-1. This is less than the UNECE critical load for nitrogen of 5-10 Kg (N) ha-1/yr-1 for permanent oligotrophic waters.
8.4.5 Odour impact assessment There is the potential for odour emissions due to the storage of alternative fuels. However, potential emissions will be minimised through the containment of fuels in silos, tanks and enclosed buildings.
8.4.6 Climate Impact Assessment Currently, ICL is not permitted to use alternative fuels at Limerick Cement Works. It is proposed to reduce the amount of fossil fuels through the use of alternative fuels and alternative raw materials in the future (90,000 tonnes per annum).
The following CO2 emissions are calculated for the existing and proposed scenarios:
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Existing: 392,000 tonnes/annum Proposed: 352,000 tonnes/annum
The decrease in CO2 by introducing the use of alternative fuels and raw materials on site amounts to 40,000 tonnes per annum resulting in a positive impact on climate. As outlined previously, the increases in operational traffic volumes as a result of the proposed development is not considered significant, therefore no climatic impacts are envisaged.
8.5 Mitigation Measures
8.5.1 Construction Phase As outlined in Section 8.7, no sensitive receptors are located within 25m of the areas of the proposed construction works, and therefore no significant impacts due to construction activities are envisaged. However, measures will be undertaken during the construction works to minimise dust generation. The following measures will be implemented at a minimum: . Spraying of exposed earthwork activities and site haul roads during dry weather. . Control of vehicle speeds on site. . Sweeping of hard surfaces on-site and in the surrounding area, as required. Dust deposition monitoring is required by the Irish Cement Industrial Emission licence on a quarterly basis. Dust deposition monitoring will be carried out and compared to the limit of 240mg/m2/day (based on a 30 day composite sample) to ensure the effectiveness of the measures outlined above.
8.5.2 Operational Phase As outlined in Section 8.7, the modelling work predicts that all air quality standards will be complied with, therefore no mitigation measures are proposed as part of this development. For inspection purposes only. However, a number of mitigationConsent of copyright measures owner required are currentlyfor any other use. in place to reduce emissions from sources. These include a selective non catalytic reduction (SNCR) and a bag filter on kiln 6 and bag / hybrid filters on other sources.
8.6 Worst case scenario The worst-case scenario has been assessed in Section 8.4. As outlined in Section 8.2.5, the modelling predictions represent the most conservative or worst-case concentrations which could arise. Several worst-case conditions are assumed to be coincident: . Emission sources are operating at maximum flow rates; . Emission sources are operating at maximum emission concentrations, rather than average emission concentrations; . Emission sources are operating for every hour of every day of the year; . The assessment is based on the meteorological conditions that give rise to the maximum predicted concentration over a five year period; . Receptor location is that which experiences the maximum predicted concentration. The model predictions are therefore extremely conservative, giving worst-case ground-level concentrations, which are unlikely to be realised in practice.
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8.7 Residual Impacts
8.7.1 Construction Phase No significant residual impact on air quality and climate is likely following the implementation of mitigation measures outlined above.
8.7.2 Operational Phase No significant residual impact on air quality and climate is likely following the implementation of mitigation measures outlined above.
8.8 References EPA, Industrial Emissions Licence Register Number P0029-03 EU, Industrial Emissions Directive (2010/75/EU) Environmental Protection Agency (EPA) Air Dispersion Modelling from Industrial Installations Guidance Note (AG4), 2009 Air Quality Standards Regulations 2011 (S.I. No. 180 of 2011) Arsenic, Cadmium, Mercury, Nickel and Polycyclic Aromatic Hydrocarbons in Ambient Air Regulations 2009 (SI 58 of 2009) UK Environment Agency (EA) (2002, 2011) "Integrated Pollution Prevention and Control (IPPC) Environmental Appraisal and Assessment of BAT; Horizontal Guidance Note IPPC H1" WHO air quality guidelines for Europe, 2nd edition, 2000 (WHO, 2000) EU, BAT Conclusion on the Production of Cement Lime and Magnesium Oxide, 2013 Greenhouse Gas Emissions Permit No IE-GHG043-10364 EPA, Air Quality in Ireland 2014, Key Indicators of Ambient Air Quality, 2015
EPA, Air Quality in Ireland 2013 , ForKey inspection Indicators purposes only. of Ambient Air Quality, 2014 Consent of copyright owner required for any other use. EPA, Air Quality in Ireland 2012, Key Indicators of Ambient Air Quality, 2013 TII, Guidelines for the Treatment of Air Quality during the Planning and Construction of National Road Schemes, 2011
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9 NOISE AND VIBRATION
9.1 Introduction This chapter assesses the potential impact of noise and vibration on the environment due to the proposed development during the construction and operational phases.
9.2 Methodology
9.2.1 Environmental Noise Survey Methodology Noise was measured using a methodology that was accordance with ISO 1996: 2007 Acoustics – Description and Measurement of Environmental Noise Parts 1 – 4.
All day time and night-time measurements were expressed as LAeqT,30 mins as stated in the guidance documentation.
9.2.2 Monitoring locations Figure 9.1 shows the five monitoring locations where baseline monitoring was undertaken. These locations are referred to as:
. NM1 – Located near the N69 on sports field to south of the site; . NM 2 – Cul-de-sac on Barrack Road to southwest of the site . NM3 – Conigar Road to the west of the site; and. . NM 4 – located on the eastern side of the site adjacent to the gate office . NM 5 – located at northern end of Tervoe Road (close to River Shannon) to the northwest of the site
9.2.3 Instrumentation For inspection purposes only. Consent of copyright owner required for any other use. The instrumentation used during the attended daytime and night-time monitoring are presented in Table 9.1 below.
Table 9.1 Instrumentation used during the attended daytime and night-time surveys. Manufacturer Instrument Type Calibrator Type Calibrated reference 2 x Cirrus Optimus CR:171B , B&K CR:515 Acoustic 7 April 2015 Cert No. S6450 Green 4180 Microphone Calibrator 5 September 2014, Cert no. 198890
9.2.4 Monitoring Procedure During the surveys, the meter microphone was attached to a tripod extending to more than 1.5m above ground floor level and the meter was set up approximately 3.5 meters from any reflective surface. Measurement locations at residential properties were at the property boundaries. The measurement locations are shown in Figure 9.1.
9.2.5 Measurement Parameters The noise survey results are presented in terms of the following three parameters:
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Scale at A4 Date Arup, 50 Ringsend Road 1:50000 April 2016 Dublin 4 Discipline Tel +353(0)1 233 4455 Environmental www.arup.ie Figure: 9.1 Noise Monitoring Job No Drawing Status Client Title Job Title 325373-47 Report Irish Cement Ltd Irish Cement Locations Alternative Drawing No Issue Fuels Facility N4005 P2
N
NM5
NM4 NM3 For inspection purposes only. Consent of copyright owner required for any other use.
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. LAeq is the equivalent continuous sound level. It can be considered as the ‘average’ and is used to describe a fluctuating noise in terms of a single noise level over the sample period. It is typically used as a descriptor for ambient noise. . LAmaxis the sound maximum sound pressure level that is recorded over a period. . LA90 is the sound level that is exceeded for 90% of the sample period. It is typically used as a descriptor for background noise.
The “A” suffix denotes the fact that the sound levels have been “A-weighted” in order to account for the non-linear nature of human hearing. All sound levels in this report are expressed in terms of decibels (dB) relative to 2x10-5 Pa.
At locations where the presence of an audible tone could be disruptive to neighbouring properties, an octave band measurement was completed at the residential dwellings to establish if such pure tones were present.
9.2.6 Assessment Criteria
9.2.6.1 Noise Limerick Cement Factory is licenced by the EPA to operate under Industrial Emissions Licence Register No. P0029-03. The licence states that “the licensee shall carry out a noise survey of the site operations annually. The survey programme shall be undertaken in accordance with the methodology specified in the 'Environmental Noise Survey Guidance Document' as published by the Agency”. Table 9.2 below presents the noise emission limits for the site for both daytime and night-time.
Table 9.2 Daytime and night-time noise emission limits Daytime dB(A) LAeq (30 minutes) Night-time dB(A) LAeq (30 minutes) 55Note1 45Note1
Note 1: There shall be no clearly audible loud component or impulsive component in the noise emission from the activity of any noise- sensitive location. For inspection purposes only. Consent of copyright owner required for any other use.
Daytime is defined as between 08:00 and 22:00 and night time as between 22:00 and 08:00.
In accordance with the Industrial Emissions Licence, noise monitoring is carried out at three noise sensitive locations (NSL) outlined in Section 9.2.2. Furthermore, Section 4.5 of Licence states that “Noise from the installation shall not give rise to sound pressure levels (LAeq,T) measured at Noise Sensitive Locations (NSL) of the installation which exceed the limit value(s))”. The “Design Manual for Roads and Bridges (DMRB) Volume 11”, Section 3, Part 7, HD 213/11, Noise and Vibration states that an increase of 25% in total traffic flows is considered approximately equivalent to a +1dB change in noise levels, above which a detailed assessment is required. Where increases in total traffic flow greater than the 25% are predicted to occur, detailed modelling is carried out using Calculation of Road Traffic Noise (CRTN, 1998) methodology.
9.2.6.2 Vibration Table 9.3 below presents the vibration and air overpressure limits for the site.
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Table 9.3 Vibration and air overpressure limits Peak particle velocity limit Air overpressure limit Operation Location value value
Blasting Noise Sensitive Location 12mm/sec 125dB (Lin)max peak
Section 4.6 of the Industrial Emissions licence for the facility states, the ‘blasting operations at the installation shall not give rise to vibration levels or air over-pressure values measured at noise sensitive locations in excess of the vibration limit value or overpressure value, subject to the following:
(i) Vibration levels measured at noise sensitive location(s) shall not exceed the specified limit values; (ii) 95% of all air over-pressure levels measured at noise sensitive locations(s) shall conform to the specified limit value. No individual air over-pressure value shall exceed the limit value by more than 2.5dB(lin).’
9.3 Existing Environment In order to establish the existing environment, a series of noise surveys were carried out during daytime and night-time at five noise sensitive locations (see Figure 9.1). Daytime and night-time noise measurements were undertaken on the 7 May 2015. Surveys were carried out on a week-day and during time periods which were selected in order to provide a typical snapshot of the existing baseline noise climate.
9.3.1 Measurement Locations and Noise Description
9.3.1.1 Weather Report Daytime and night-time noise monitoring was carried out on the 7 May 2015. Weather details for both the daytime and For night inspection-time purposes surveys only. are presented in Table 9.4 below. Consent of copyright owner required for any other use.
Table 9.4 Weather as recorded using an anemometer during the day- and night-time monitoring and a brief overview of localised conditions at each location. Wind speed Date / Period Locations Temp (C) (m/s) Precipitation 07/05/15 All locations 10 0.0 - 3.7 None Daytime
07/05/15 All locations 5 0.0 - 3.7 None Night-time
9.3.1.2 NM1 This monitoring point is located south of the site in a sports field near the N69 which is the main road between Limerick City and Foynes.
Daytime Survey The main source of noise at this point was the almost continuous movements of traffic on the nearby N69. Other sources of noise during the survey included birds chirping in
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the surrounding vegetation and a low operational noise from the Limerick Cement Factory.
Night-time Survey Sources of noise during the night survey included regular traffic movements on the N69 and operational noise from the Limerick Cement Factory. Traffic volumes were less on the road as it had been during the daytime survey and so the noise from the Limerick Cement Factory was more audible.
9.3.1.3 NM2 This monitoring point is a noise sensitive location, situated in a cul- de-sac, on Barrack Road southwest of the site. The monitoring equipment was set up approximately 10 meters in front of a dwelling.
Daytime survey Occasional noise was generated due to activities associated with a residential area such as dogs barking and conversation.
Night-time survey For the night-time survey the main source of noise were both regional traffic on the N69 and local traffic on Barrack road. Several dogs were barking intermittently during the noise survey. No noise was recorded from the Limerick Cement Factory.
9.3.1.4 NM3 NM3 is situated at a noise sensitive location, to the west of the Cement Factory on the Conigar Road. The monitoring point was set up on the roadside in front of a house.
Daytime Survey The main source of noise at this point was the regular movements of traffic. Additionally, birds were heard chirping in nearby vegetation, traffic could be heard on the For inspection purposes only. N69. No noise was audibleConsent from of copyright the Limerick owner required Cement for any other Factory use. site.
Night-time survey Traffic could be heard throughout the survey both on the adjacent Conigar Road and on the N69 further away. Other sources included dogs barking and conversation.
9.3.1.5 NM4 This boundary monitoring location is situated near the automatic barrier, along the access lane to the Limerick Cement Factory. This point is not a noise sensitive location as it is located with the Cement Factory and there are no noise sensitive receptors nearby.
Daytime survey The greatest source of noise at this point was the almost continuous movements of traffic on the N69 and vehicles entering/exiting the Limerick Cement Factory site. The automatic gate made a significant amount of noise as it opened and closed regularly to allow for site traffic. Other sources of noise included conversation and bird song.
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Night-time Survey The most significant source of noise during the night time noise survey was traffic movements on the N69. There was also low operational noise emanating from the Limerick Cement Factory and a slight wind rustling trees nearby. There was also some noise from the automatic barrier as it opened and closed to allow traffic on and off the Cement Factory site.
9.3.1.6 NM 5
NM5 is situated north / northwest of the Cement Factory, close to the River Shannon end of Tervoe Road. The lane is used by the public for walking.
Daytime Survey
Operational noise from the Limerick Cement Factory was slightly audible. Birds were heard chirping in the surrounding area.
Night-time Survey During the night time noise survey the main source of noise was a slight operational noise from the Cement Factory. Other sources included animal life and a car accessing the area.
9.3.2 Measurement Results
9.3.2.1 Daytime monitoring Table 9.5 presents the daytime monitoring results for all five locations.
Table 9.5 Daytime monitoring results. Daytime I.D. limit dB(A) Date For inspection purposesLAeq (dB)only. LAFmax (dB) LA90 (dB) Consent of copyright owner required for any other use. NM1 55 7/05/2015 71 92 49 * NM2 55 7/05/2015 65 87 43 NM3 55 7/05/2015 68 91 43 NM4 55 7/05/2015 32 82 39 * NM5 55 7/05/2015 40 60 33 * attenuated level
As outlined above, traffic noise dominates the noise environment at NM1, NM2 and NM3 resulting in an elevated LAeq values. Noise sources from the Cement Factory are likely to be dominated by continuous noise sources such as fans. The measurement of these noise levels is best represented by the LA90 background value. All LA90 values are below the daytime limit values.
9.3.2.2 Night-time monitoring Table 9.6 presents the night-time monitoring results for all five locations.
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Table 9.6 Night-time monitoring results. Night-time I.D. limit dB(A) Date LAeq (dB) LAFmax (dB) LA90 (dB) NM1 45 7/05/2015 61 80 41 * NM2 45 7/05/2015 44 73 38 NM3 45 7/05/2015 61 84 38 NM4 45 7/05/2015 48 74 39 * NM5 45 7/05/2015 41 63 38 * attenuated level
As outlined above, traffic noise dominates the noise environment at all locations resulting in elevated LAeq values, particularly at NM1 and NM3. Noise sources from the Cement Factory are likely to be dominated by continuous noise sources such as fans. The measurement of these noise levels is best represented by the LA90 background value. All LA90 values are below night-time limit values.
9.4 Potential Impacts of the Proposed Development
9.4.1 Construction Phase The construction phase of the proposed development will involve site clearance, excavation and the construction of buildings and structures associated with the proposed development. A variety of items of mobile plant will be in use, such as excavators, lifting equipment, dumper trucks, compressors, and generators.
There will be vehicular movements to and from the site that will make use of the existing roads and site access points.
No routes are predicted to experience increases of more than 25% in total traffic flows during the construction phase, For thereforeinspection purposes, no only. detailed assessment is required (DMRB Consent of copyright owner required for any other use. Guidelines), refer to Chapter 12, Traffic and Transportation.
9.4.2 Operational Phase Only one new major noise source will be provided as part of the proposed development, i.e. the kiln bypass cooling tower. Based on a typical specification for a 100kW cooling tower, a sound power level of 101dB can be assumed. At a separation of 500m from the nearest sensitive receiver (NM2), a sound pressure level of 39dB is predicted at this location. Adding this level to an existing night-time baseline of 38dBLA90 at this location results in a cumulative value of 42dB. This levels remains in compliance with the licence limit value.
The development mainly consists of the provision of buildings for the storage, handling and introduction of alternative fuels and raw materials. Additional conveyors, including a tyre conveyor, will also be provided to transfer fuels and materials to Kiln 6. These conveyors, of which there are similar structures on site already, will be enclosed and are not likely to generate significant noise.
The EPA Guidance Note for Noise: License Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4) 2012 specifies the following noise limits:
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. Daytime (07:00 to 19:00) – 55dB LAr,T; . Evening (19:00 to 23:00) – 50dB LAr,T; . Nighttime (23:00 to 07:00) – 45dB LAeq,T.
It is likely that these limits will be applied to a new licence that will be issued for the Cement Factory as part of an Industrial Emissions licence review. All current LA90 monitoring results are below the evening time limit of 50dB. The inclusion of the cooling tower is predicted to result in continued compliance with this limit value.
It should be noted that the Cement Factory operates on a 24-hour basis with a continuous kiln process ongoing at the facility. This is monitored and controlled by the IE licence for the facility.
In terms of traffic, no routes are predicted to experience increases of more than 25%, (in fact the maximum predicted maximum of increase of 1.3% is significantly below the 25% limit), in total traffic flows during the operational phase, therefore no detailed assessment is required (DMRB Guidelines), refer to Chapter 12, Traffic and Transportation.
9.5 Worst case Scenario The worst case scenario has been considered in Section 9.4 above.
9.6 Mitigation Measures
9.6.1 Construction Phase The following text outlines typical measures that will be employed by the contractor in order to minimise the potential for noise disturbance in the surrounding area and to ensure compliance with the construction noise limits outlined in Table 9.2. BS 5228: (2009+2014) Code of practice for noise and vibration control on construction and open sites For inspection purposes only. – Part 1: Noise provides Consent guidance of copyright on owner the required implementation for any other use. of measures to reduce the
impact of construction noise. The measures to be implemented include, but are not limited to;
9.6.1.1 Selection of plant/location of plant Where possible, plant which will have the least impact in term of noise should be selected. In addition, plant will only be left running during construction hours and will be switched off at all other times. Plant will not be left running idle.
9.6.1.2 Hours of work Irish Cement will be required to comply with current Industrial Licence limits during the construction phase of the development.
9.6.2 Operational Phase No mitigation measures, over and above normal existing operational practices and compliance with its existing IE Licence, are required or proposed for the operational phase of the proposed development at Limerick Cement Factory.
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9.7 Residual Impacts No residual impacts are predicted as a result of the proposed development as Irish Cement is obliged to continue to comply with noise limits specified in the Industrial Emissions Licence.
9.8 References AXIS Environmental Service, 2015. Annual Environmental Noise Report, Noise Survey 2015, Old Cratloe Road, Co. Limerick.
British Standards Institution (BSI), 2009+2014. BS 5228-1: 2009 Code of practice for Noise Vibration Control on Construction and Open Sites - Noise. British Standards Institution, United Kingdom.
British Standards Institution (BSI), 2009. BS 5228-2: 2009 Code of Practice for Noise and Vibration Control on Construction and Open Sites - Vibration. British Standards Institution, United Kingdom.
Design Manual for Roads and Bridges (DMRB) Volume 11”, Section 3, Part 7, HD 213/11, Noise and Vibration, United Kingdom.
EPA, 2012. Guidance Note for Noise: Licence Applications, Surveys and Assessments in relation to Scheduled Activities (NG4). Environmental Protection Agency, Wexford, Ireland.
EPA, (2015) Revised Guidelines on the Information to be contained in Environmental Impact Statements, DRAFT. Johnstown Castle, Co. Wexford
International Standards Organisation (ISO), 1996:2007: Acoustics – Description, measurement and assessment of environmental noise - Part 1-4. ISO, Geneva, Switzerland.
For inspection purposes only. Consent of copyright owner required for any other use. Irish Cement, 2014. Irish Cement Ltd. Limerick Works - Annual Environmental Report 2014, Castlemungret, Co. Limerick.
EPA, 2013. Industrial Emission Licence (Irish Cement Limited, P0029-03), Johnstown Castle Estate, Co. Wexford.
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LANDSCAPE AND VISUAL ASSESSMENT
10.1 Introduction This report assesses the landscape and visual impact of the proposal to introduce alternative fuels and alternative raw materials to the cement production process at Limerick Cement Factory. The proposed development comprises the installation of a variety of new buildings, and structures, including conveyors and mechanical equipment as detailed in Chapter 3 of the EIS.
The assessment involved reviewing plans of the existing site, together with plans, elevations and sections of the proposed development; reviewing various statutory and other publications and visits to the site and its environs.
A series of photomontages (refer to Appendix 10-1) are provided illustrating the physical and visual nature of the existing cement factory and the cement factory with the proposed development.
10.2 Methodology The assessment is made with regard to the sensitivity of the landscape and its vulnerability to change, taking consideration of the location of visual receptors relative to the proposed development.
The methodology used is based on the EPA publications: . EPA Guidelines on Information to be Contained in Environmental Impact Statements (2002) and . EPA Advice Notes on Current Practice in the Preparation of Environmental Impact Statements” (2003), For inspection purposes only. . EPA Revised ConsultationConsent of copyright Draft owner Guidelines required for any on other the use. Information to be contained in Environmental Impact Statements. (2015)
Landscape has two separate but closely related aspects. The first is visual impact, i.e. the extent to which a new development can be seen in the landscape. The second is impact on landscape character, i.e. impact on responses that are felt towards the landscape, drawing on the appearance of the land, including shape, form and colour, and the interaction of these elements to create specific patterns and pictures that are distinctive to particular localities.
Visual impacts are defined under visual intrusion and/or visual obstruction where:
. visual intrusion involves impact on a view but avoiding blocking thereof, and . visual obstruction involves impact on a view with at least some degree of blocking.
The character of the existing landscape setting is evaluated taking account of the various natural and man-made features, such as topography, landform, land-use, vegetation, built environment, etc. together with the visibility of and the views to and from the landscape. In addition aspects relating to the landscape planning environment are considered on a national, regional and local basis.
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10.2.1 Significance Assessment Criteria The significance criteria used for the landscape (and visual) impact assessment are based on those given in “Guidelines on the Information to be Contained in Environmental Impact Statements” as set out in Table 10.1 Significance Criteria.
The impact of the proposed development is assessed at two distinct stages:
. Construction Stage: impact arising during the period of initial site setup works up to the opening of the facility to normal operation, and . Operation Stage: impact arising during the period of normal operation of the facility.
The ratings may have negative, neutral or positive applications where:
. Positive impact – A change that improves the quality of the environment. . Neutral impact – A change that does not affect the quality of the environment. . Negative impact – A change that reduces the quality of the environment.
Terms relating to the duration of impacts are as described in the EPA Guidelines as: . Temporary Impact - lasting one year or less. . Short-term Impact - lasting one to seven years. . Medium-term Impact - lasting seven to fifteen years. . Long-term Impact - lasting fifteen to sixty years. . Permanent Impact - lasting over sixty years.
Table 10.1: Significance Criteria Impact Level Definition An impact capable of measurement but without noticeable Imperceptible consequences. An impact which causes noticeable changes in the character of the Slight environment without For inspection affecting purposes only. its sensitivities. Consent of copyright owner required for any other use. An impact that alters the character of the environment in a manner that Moderate is consistent with the existing and emerging trends. An impact which, by its character, magnitude, duration or intensity alters Significant a sensitive aspect of the environment. Profound An impact which obliterates sensitive characteristics.
10.3 Receiving Environment The site forms part of the Irish Cement holding at Castlemungret. The site is within the Cement Factory that lies north of the N69 Limerick – Foynes Road, south of the River Shannon and east of Mungret village approximately 2km west of Limerick City, as shown on Figure 10.1 Site Location.
The existing buildings and structures are clustered together and visually dominate the skyline to the west and south-west of the city. They form a complex of large buildings rising to a maximum of 87.5m high (98m above ordnance datum –AOD).
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Figure 10.1 Site Location
A large rock quarry is located to the west of the Cement Factory. The river Shannon lies to the north, while Bunlicky Clayfield Ponds and the N18 National Primary Road lies to the east. Extensive areas of woodland and other planting surround the actual Cement Factory and along the northern side of the N69.
While visually prominent, the Cement Facility tends to move in and out of views along the main roads around the site. This ‘glimpsing effect’ is particularly evident travelling along the N69 south and west of the site and the N18 to the east of the site.
For inspection purposes only. Extensive landscaping has Consentbeen of carried copyright owner out required in and for any around other use. the cement factory in particular between Mungret Village and the factory and along the western boundary of the existing quarry area. As it matures, the planting has gradually ‘softened’ the appearance of the facility. The effect is more noticeable at proximity and assisted where the planting is viewed in combination with intervening tree-lined hedgerows.
The entrance to the Irish Cement Facility, which is north off a roundabout at the N18, N69, R510 junction, is an attractive feature with low stone walling fronting a large densely planted screen and avenue-style access road. The landscaping has the effect of significantly reducing the visual scale of the main buildings and structures especially when viewed from the Dock Road or other areas in proximity to the facility.
The Dock Road leading east from the Cement Factory into the city is an increasingly industrialised corridor. In the vicinity of the cement factory, the Shannon is a wide and gently meandering river, physically and visually contained within flood protection embankments. The embankments are commonly used as walking amenities and offer wide panoramic views over the river, its extensive riparian habitats and the wider landscape/cityscape.
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Mungret village is located south-west of the site and residential development is prominent along many local roads in the area including the N69 between Mungret and Clarina, and roads in and around Tervoe. Large residential areas, in effect outliers of the city, lie south- east of the cement factory at Dooradoyle and Gouldavoher.
In general, the landscape to the south and west of the facility is of undulating agricultural land of medium sized fields with tree-lined hedgerows and occasional clumps of trees providing the main enclosure and sense of scale. Prominent hills are characteristic of the area to the south of the Dock Road at Ballykeefe and west of cement factory at Carrigogunnell, Carrig East and Tervoe.
10.3.1 Landscape Planning Context The site lies within the Limerick County Development Plan area and also the Southern Environs Local Area Plan 2011-2017 area. The boundary to the Limerick City Development Plan area is less than 1km north of the application site which is defined by the path of River Shannon.
The Limerick County Development Plan, 2010-2016 identifies the site as being within the Shannon Integrated Coastal Management Zone (ICMZ) landscape character area. The objective of the landscape character assessment is to identify the value, importance and sensitivity of each landscape character type and the potential capacity to accommodate development. This landscape character area is described as below:
‘This zone comprises a large area of northern part of county Limerick and is bounded on one side by the Shannon Estuary while its southern boundary is defined by the gradually rising ground, which leads onto the agricultural zone and the western hills zoned to the south. One of the main features of the area is the presence of the estuary, which is perhaps the defining characteristic of the region. The landscape itself is generally that of an enclosed farm type, essentially that of a hedgerow dominant landscape. This differs from the other agricultural For inspection landscapes purposes only. of the County in that the field patterns, Consent of copyright owner required for any other use. particularly close to the estuary, tend to be less regular than those elsewhere in the County.’
The site is zoned for ‘Industrial’ use in the Limerick County Development Plan (and in the Southern Environs Local Area Plan Zoning Map). In landscape and visual terms there are no scenic routes, listed views and prospects, or tree preservation objectives pertaining to the site or the larger cement factory holding. However, as previously noted the Shannon is a major local amenity with walking, boating and fishing all common. Observing wild birds is also common both along the Shannon and at Bunlicky Pond. Reed harvesting for thatching purposes is practiced along various stretches of the river and creeks in the general area.
Castle Mungret (Mungret College) is a protected structure to the south of the site. However no visual impact arises from the proposed development due to the nature of the existing and proposed development and screening provided intervening vegetation locations.
10.3.2 Summary The existing cement factory comprises many large-scale structures of significant bulk and height with a large associated rock quarry located immediately to the west. The principal structures are all clustered within the eastern edge of the holding with the tallest features
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centrally located within the overall built environment of the factory. The existing facility is a prominent feature within its local context and forms a dominant visual reference.
Extensive landscaping undertaken around the facility is notably more effective at proximity and where viewed in combination with surrounding tree-lined hedgerows. By comparison, the landscaping is less effective in screening when viewed within more open, flat, panoramic views from a distance. However, in general the ever maturing planting is providing valuable ‘softening’ and integration of the facility within its surrounds.
10.4 Characteristics of the Proposed Development In visual terms the main features of the proposal include:
. Tyre Storage and Handling Facility . Coarse Solids Handling Building. (max. height of 12.15m) . A Raw Material building (to be located close to the existing Quarry Area) (max. height 14.3m) . Pumpable Fluids Storage tank (max. height of 9.02m); and Unloading Area; (max. height of 6.15); . Free-flowing Solids silos (max. height of 26.23m) . Fine solids handling/screening building (max. height 18.59m) and truck unloading area; . By-Pass Filter (c.21.45m high) and Cooling Tower (max. height of 55.92m – c.3m diameter) . Associated conveyors, mechanical equipment and ancillary works.
As previously noted the subject site comprises a small part of the overall cement factory holding centred on the principal buildings. The existing buildings, which visually dominate the skyline to the west and south-west of the city, form a complex of large buildings rising to a maximum of 87.5m high (98m AOD) in the case of the pre-heater tower on Kiln 6. For inspection purposes only. Consent of copyright owner required for any other use. The proposed development entails a variety of structures all located within and closely adjoining the existing developed footprint of the Cement Factory. The majority of new structures are significantly smaller than existing structures and the taller elements (Cooling tower) are relatively slim.
10.5 Impact of the Development Given the context of the existing Cement Factory and the many structures that comprise the existing facility, the proposed development and new structures will not give rise to significant visual impacts.
The proposed development is for the most part located on existing developed or cleared footprint in and around the existing Cement Factory. Minimal vegetation removal is required – mainly on the edge of existing plantings and for access etc. – and as such potential landscape impacts are considered to be negligible.
The proposed structures will be located to the north, northeast and northwest of the existing built facility. The Raw Materials Store is furthest to the west where it is sited on a lower area of site close to the existing quarry area. The 14.3m high Coarse Solids Building will be located
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furthest to the east, where it is located within an open cleared area surrounded by screening woodland planting. The Fine Solids building, the Free-flowing Solids silos, the Pumpable Fluids tank and the Bypass and Cooling Tower are all more centrally located to the immediate north of the core of the existing Cement Factory. The tyre storage and handling area is located to the north of the cement factory in an area currently used for parking and temporary storage of materials.
The height and scale of the proposed structures will be relatively low and small in scale particularly given the context of the existing facility and the proximity to the much taller structures. The Cooling Tower and Bypass Filter is the tallest element at 55.9m in height, however depending on the direction of view, it will generally be viewed directly adjacent to, hidden, or against the backdrop of the larger existing pre-heater tower.
The construction effects will be similar in nature and impact to the operational effects due to the surrounding industrial context, height of existing structures and existing movement of large trucks and occasional cranes.
The visual impact from surrounding areas will be minimal. The existing facility already presents a significant and prominent built form within the landscape.
10.5.1 Visual Impact Assessment: Photomontages A series of Photomontages have been prepared being representative of a selection of the most open views from the surrounding landscape. These views and their location are provided in Appendix 10.1 to the EIS. The following presents an overview of the visual impact from particular areas and a summary of the Photomontages is provided in Table 10.2.
Some of the most open views of the existing Cement Factory on the skyline are available from the Limerick Southern Ring Road to the south and southwest of the city. However, the proposed development is located north of the existing structures and as such will not be visual in views from the south and For inspectionsoutheast. purposes Photomontageonly. 2, (Figure 1.2.1, 1.2.2 & 1.2.3, Consent of copyright owner required for any other use. Appendix 10.1) as taken from the Ballykeeffe road overbridge on the N18 illustrates this effect.
From the N69/ R510 Dock Road existing views are generally glimpsed as the cement factory moves in and out of view, although there are some continuous clear views towards the existing structures from stretches of the road. From the east when leaving Limerick City, the by-pass system would be the most visible proposed element although it would be seen against the context of the larger pre-heater tower (see Photomontage 2, Figure 1.2.1, 1.2.2 & 1.2.3, Appendix 10.1). The other elements would be visible but the difference in view would not be discernable. While the existing plant is openly visible, the proposed additions to the facility would be slight to imperceptible and have a neutral visual impact during construction and operation.
The most open and closest views of the existing facility will be experienced by road users on the N18 east of the site. A typical view from near this location is shown in Photomontage 3, (see Figure 10.3.1, 10.3.2 & 10.3.3, Appendix 10.1). This viewpoint is typical of views from the Bunlicky Pond and amenity area and the southern edge River Shannon. In this view the proposed bypass structure will be visible adjacent to existing taller structures. Consequently
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there will be a slight to imperceptible, neutral visual impact during construction and operation from this close adjacent area.
As the N69 passes close to the site many of the views are more effectively screened by the surrounding vegetation. Further to the west when on the N69 travelling towards Limerick City the views of the existing structures are clearly visible, however the proposed structures will predominantly be screened beyond these existing structures and viewers will experience an imperceptible, neutral impact during construction and operation due to the existing context (see Photomontages 5 & 6 from the vicinity of Mungret Village, Figures 1.5.1, 1.5.2 & 1.5.3 and 1.6.1, 1.6.2 & 1.6.3, Appendix 10.1).
There will be other views from the surrounding landscape from most directions due to the relatively flat landscape context and the visual prominence of the existing facility. Views will include some more open from the north, e.g. from Coonagh, (Photomontage 4, Figures 1.4.1, 1.4.2 & 1.4.3, Appendix 10.1) and more limited glimpses from the south (Photomontage 7, Figures 1.7.1, 1.7.2 & 1.7.3, Appendix 10.1). Likewise there is little or impact from the vicinity of Mungret College. (Photomontage 8, Figures 1.8.1, 1.8.2 & 1.8.3, Appendix 10.1)
The proposed structures will generally be screened by the existing structures when viewed from the south and west. However, in all views the proposed development will be seen within the confines of the existing built environment of the Cement Factory. The proposed structures will have little to no landscape or visual relevance outside of the actual site.
Table 10.2: Review of Photomontages View Comment View 1: Figure 1.1.1: shows the existing view of the Cement Factory from the Ballykeeffe Ballykeeffe Overbridge. Overbridge Figure 1.1.2: outlines in red the location of the proposed development - all of For inspection purposes only. on the N18 which is locatedConsent ofto copyright the north owner requiredof the for existing any other use. development and as such is effectively screened. Figure 1.1.3 shows the proposed view without the red outline. Summary: The change in the view is Imperceptible.
View 2: Figure 1.2.1: shows the existing view of the Cement Factory from the Dock Road R510 Dock travelling west from Limerick City. Road Figure 1.2.2: outlines in red the location of the proposed development - all of which is effectively screened by intervening vegetation and development. Figure 1.2.3 shows the proposed view without the red outline. Summary: The change in the view is Imperceptible.
View 3: Figure 1.3.1: shows the existing view of the Cement Factory across Bunlicky Access Road Clayfield Pond from the access road to Shannon embankment. to Shannon Figure 1.3.2: outlines in red the location of the proposed development - upper Embankment elements of the development are visible. along N18 Figure 1.3.3 shows the proposed development without the red outline. Summary: The change in this view is slight
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View Comment View 4: Figure 1.4.1: shows the existing view of the Cement Factory from N18 Coonagh N18 Coonagh Interchange. Interchange Figure 1.4.2: outlines in red the location of the proposed development - all of which are screened by intervening vegetation Figure 1.4.3 shows the proposed development when built without the red outline of the proposed elements. Summary: The change is Imperceptible.
View 5: Figure 1.5.1: shows the existing view of the Cement Factory from the N69, west N69 West of of Mungret Village. Mungret Figure 1.5.2: outlines in red the location of the proposed development - all of Village which is screened by intervening vegetation or existing development within the Cement Factory. Figure 1.5.3: shows the proposed development without the red outline. Summary: The change is Imperceptible.
View 6: Figure 1.6.1: shows the existing view of the Cement Factory from Mungret Mungret Village. Village Figure 1.6.2: outlines in red the location of the proposed development - all of which is effectively screened by intervening vegetation and existing development within the Cement Factory. Figure 1.6.3: shows the proposed development without the red outline. Summary: The change is Imperceptible.
View 7: Figure 1.7.1: shows the existing view of the Cement Factory from the R510, east R510 East of of Mungret Village. Mungret Figure 1.7.2: outlines in red the location of the proposed development – the Village majority of which is effectively screened by intervening vegetation and existing development within the Cement Factory. Upper aspects of Cooling Tower will be visible close to taller structures. Figure 1.7.3: shows the proposed development without the red outline. For inspection purposes only. Summary: TheConsent change of copyright in ownerthe view required is for Slight any other to use. Imperceptible.
View 8: Figure 1.8.1: shows the existing view of the Cement Factory from Mungret Mungret College College Figure 1.8.2: outlines in red the location of the proposed development - all of which is screened by intervening vegetation and existing development within the Cement Factory. Figure 1.8.3: shows the proposed development without the red outline. Summary: The change is Imperceptible.
10.5.2 Impact on landscape Planning Context The proposed development will have a neutral impact on landscape planning aspects. The existing and proposed development site is located within a landscape character area defined as ‘Integrated Coastal Management Zone’ in the County Development Plan 2005-2011 due to the influence of the River Shannon. Although the surrounding areas are industrial in nature, this landscape has a moderate value, high sensitivity and is of regional importance due to the river. However, the proposed development will have no additional impact on landscape character.
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The proposed development will have no impact on preservation objectives for trees and woodland.
The proposed development will have no negative impact on scenic routes, designated views and prospects and no direct landscape impact on the Natural Heritage Area/ Special Area of Conservation, although there will be views from this major amenity area. Although this area is directly adjacent to the proposed development, the views are not deemed to be significantly different from the existing situation (Viewpoint 2, Figure 11.3 illustrates the view from close to Bunlicky Pond / River Shannon).
10.5.3 Summary In summary, the proposed development will not give rise to any significant additional landscape or visual impact. The scale and nature of the change will be relatively small and, within the overall context of the existing facility, will have a negligible or imperceptible visual impact.
In the medium and longer-term, given the presence of the existing facility and other proposed developments, there will be no appreciable change within existing views. It is considered that negative landscape or visual impact will not arise from the proposed development.
10.5.4 Mitigation Measures Because of the height and scale of the proposed development and given the context of the existing situation, complete screening of the proposed structures or indeed the overall development is not feasible.
Significant landscape screening has already been undertaken in and around the plant and along the boundaries of the facility. This planting has developed and is becoming increasingly successful in screening a significant portion of lower levels of the structures including most For inspection purposes only. single storey buildings andConsent the of copyright quarry owner proper. required for This any other screening use. and planting will function similarly for the new elements which make up the proposed development.
The continuing establishment of the existing planting will have an increasingly more pronounced effect in the screening and softening of the mass of the facility. All of the landscape areas are managed and maintained under on-going landscape maintenance contracts. The landscape and general plantings will continue to be managed so as to maximise this effect. No other planting measures are required.
In terms of finishes, the proposed structures will be similar in colouring and finishing to the existing structures, though being of new build they will initially be somewhat brighter and lighter in contrast to the existing elements. This contrast will fade gradually with time.
10.5.5 Residual Impact The construction of the proposed development will have an imperceptible landscape and visual impact. Given the nature and mass of existing structures on the site, the proposed development, representing relatively small scale additions, will not result in any residual adverse landscape or visual impacts.
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10.6 References Together with various landscape publications and information relating to the locality, the following lists the main texts reviewed in the course of the study.
. Advice Notes on Current Practice (in the preparation of Environmental Impact Statements) (2003), Environmental Protection Agency. . Guidelines on Information to be contained in Environmental Impact Statements (2002), Environmental Protection Agency. . Draft Advice Notes on Current Practice in the preparation of Environmental Impact Statements. (2015) Environmental Protection Agency. . Draft Revised Guidelines on Information to be contained in Environmental Impact Statements. (2015) Environmental Protection Agency. . Landscape Institute and the Institute of Environmental Assessment: Guidelines for Landscape and Visual Impact Assessment, Third Edition 2013. . Limerick County Development Plan, 2010 – 2016 . Southern Environs Local Area Plan 2011-2017, Limerick County Council. . Limerick City Development Plan 2010-2016
For inspection purposes only. Consent of copyright owner required for any other use.
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