EIS Non-Technical Summary May 2016
Proposal to increase the range and quantity of alternative fuels and alternative raw materials
at
Quinn Cement, Ballyconnell, Co. Cavan.
EIS Non-Technical Summary
For inspection purposes only. Consent of copyright owner required for any other use.
Prepared by:
May 2016
Enervise Limited i
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016
Table of Contents
Table of Contents ...... ii 1.0 Introduction ...... 3 2.0 Proposed Project ...... 4 2.0 Policy and Alternatives ...... 6 3.0 Environmental Assessment ...... 6 3.1 Geology ...... 7 3.2 Water Environment ...... 8 3.3 Air Quality ...... 9 3.4 Noise ...... 10 3.5 Landscape ...... 11 3.6 Ecology ...... 11 3.7 Traffic ...... 12 3.8 Natural Resources ...... 13 3.9 Human Beings: Socio Economic ...... 13 3.10 Cultural Heritage ...... 14 4.0 Conclusions ...... 15
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited ii
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016
1.0 Introduction This Environmental Impact Statement (EIS) accompanies a planning application being submitted to Cavan County Council to increase the range and quantity of alternative fuels and alternative raw materials for use at the Quinn Cement Works, Ballyconnell, Co. Cavan. The Quinn Cement site is located immediately to the south of the Fermanagh/Cavan border, approximately 2 km north of the centre of the Town of Ballyconnell, Co. Cavan and 6.5km south of the village of Derrylin, Co. Fermanagh. The precise location of the site’s application area can be seen from Figure 1.
For inspection purposes only. Consent of copyright owner required for any other use.
Figure 1: Site Location
Enervise Limited 3
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016
2.0 Proposed Project The proposed project seeks to improve the sustainability of the Ballyconnell cement plant, through the use of an increased range of waste derived alternative raw materials and fuels with the long term aim of displacing almost all fossil fuels at the plant (a limited proportion of fossil fuels will be required during process start up and for process optimisation/stabilisation). The use of these alternatives will equate to 300,000 tonnes per annum at maximum substitution.
A range of suitable materials are proposed for acceptance at the plant which can be summarised as follows: Solid Fuels – including Solid Recovered Fuel (SRF) which is currently authorised for use at the plant, as well as a range of suitable fuels derived from other sources including: o Meat and Bone Meal (MBM); o Tyre Derived Fuel (TDF); o Biomass Fuels; o Sludges and Filter Cakes. Liquid Fuels – including Secondary Liquid Fuel (SLF) which is a blend of For inspection purposes only. Consent of copyright owner required for any other use. organic and solvent wastes blended to a defined specification as well as liquid fuels derived from other sources (e.g. waste oils). Alternative Raw Materials (e.g. muds, minerals, sludges).
The full range of waste derived fuels must be authorised with the Environmental Protection Agency (EPA) and it is also proposed to include natural gas and petcoke as additional fuels in the Industrial Emissions (IE) Licence, regulated by the EPA. This is to provide flexibility for any future fossil fuel requirement.
The proposed development, to which this Planning Application relates i.e. the land use development, is for the physical engineering alteration to the plant in order to
Enervise Limited 4
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016 accept the introduction of alternative fuels and alternative raw materials as direct replacement for coal and virgin raw materials respectively. The proposed plant changes are set out at Table 1 below. This Table also indicates where the equipment was previously authorised under planning reference (09/456) which has now lapsed. This permission allowed for the use of Solid Recovered Fuel (SRF) at the plant but some of the equipment was not constructed in 2014 when the Quinn Cement plant was under different management. The current management view it as essential in order to maximise coal displacement with alternative fuels. For this reason, the current application is seeking planning permission for this equipment once again, albeit in some instances with minor modifications to the proposals put forward in 2009.
The below proposed structures are highlighted in green on the planning drawings.
Equipment Requirement Previously authorised under Planning Ref: 09/456 Bunded Liquid Fuel tanks SLF and other liquid No and associated feeding fuels Storage system For inspection purposes only. Consent of copyright owner required for any other use.
Meat & Bonemeal silos and MBM Storage No associated feeding system Lime silos and associated Reduce SOx emissions No feeding system Extension to existing SRF and other Solid Yes, albeit slightly modified in Storage bays and associated Alternative fuels this planning application feeding system (footprint reduced). Induced Draught (ID) Fan Process Yes, no change. Calciner Process Yes, albeit slightly modified in this planning application (elevation reduced). Table 1: Proposed New Equipment
Enervise Limited 5
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016
2.0 Policy and Alternatives In order to improve the sustainability of the existing Ballyconnell Cement Plant by using alternative fuels and alternative raw materials, it is not possible to propose an alternative location for this to occur. It must be at the existing cement plant. The plant is currently fuelled by a combination of coal and Solid Recovered Fuel (SRF) – a fuel derived from the portion of municipal solid waste that cannot be recycled. The SRF is sourced locally from waste management contractors but the coal is sourced from South Africa. The delivery of coal over such great distances is considered to be unsustainable, hence why Quinn Cement want to further replace the fossil fuels used with a wider range of alternative fuels.
The EIS has reviewed relevant policy and legislation in relation to planning, waste management and energy efficiency at an international, national and local perspective and finds that the proposed project contributes positively in this regard.
3.0 Environmental Assessment The EIS considers the various elements of the proposed project, including the transport of the alternative materials, the engineering changes required to the plant For inspection purposes only. Consent of copyright owner required for any other use. and the use of the alternative materials in the context of the potential impacts that could arise for the various aspects of the environment. It identifies suitable mitigation measures, if necessary and appropriate, to ensure that the development would have no significant or unacceptable adverse impacts.
A number of specific environmental aspects have been identified for in-depth study as follows:
Water Environment Air Quality and Climate Noise Ecology
Enervise Limited 6
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016
Traffic Impacts
Other less significant areas that have been considered include Geology, the integration of the proposed alteration into the Landscape, Natural Resources, Cultural Heritage and potential for Socio Economic Impact.
A summary of each of the above is provided in the following sections:
3.1 Geology
This chapter of the EIS deals with the geological setting of the site in terms of solid geology and drift geology as set out by BCL Hydrogeologists Ltd in their Hydrogeological and Hydrological Assessment which can be found at Appendix 1 of the main EIS.
All of the proposed engineering alterations are to be contained within the existing permitted footprint of the Cement Works, with all the infrastructure being situated at ground level (bar the calciner upgrades), in the confines of the existing plant.
For inspection purposes only. Consent of copyright owner required for any other use.
There will be a requirement for minor civil engineering works to maintain the structural integrity of the proposed infrastructure. However, no significant movement of overburden is envisaged.
Therefore, as a result of work previously undertaken when establishing the current site curtilage the proposed development will not impact on either drift or solid geology.
Enervise Limited 7
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016
3.2 Water Environment An assessment was undertaken by BCL Hydrogeologists Ltd to establish the possible effects from the proposed development upon the water environment. The full assessment can be found as Appendix 1 of the EIS. A combination of desktop survey, field work, evaluation of previous site investigations and the continuous water monitoring required under the existing Cement Plants environmental licence, have led to the following conclusions.
The incoming waste is delivered into purpose built enclosed storage facilities which is bunded where appropriate. The exclusion of rainwater is determined as an effective measure of avoiding the creation of any waste-water and there will be no wastewater arising from the use of the alternative materials.
There will be no change in the demand for water and the monitoring of groundwater levels will continue to confirm this statement.
The proposal does not involve any change in the surface water run-off pattern at the cement works i.e. no change in the overall size of the rainfall catchment area; no For inspection purposes only. Consent of copyright owner required for any other use. change in the gradient of the area; and no change in the percentage of hard surfaced area. Therefore the existing drainage infrastructure will receive no additional/new input of surface water run-off. Furthermore, Quinn Cement propose to reuse a proportion of the surface water on site which will reduce the discharge to the Woodford River and reduce the consumption of water from on site boreholes.
The implementation of the treatment systems, engineering measures, fluids handling protocol and monitoring schedule proposed to protect groundwater quality will, in turn, serve to safeguard the surface water environment and water supplies.
Enervise Limited 8
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016
3.3 Air Quality An assessment was undertaken by Redmore Environmental Ltd to establish the possible effects from the proposed development in the context of relevant Air Quality Standards (AQSs). The full assessment can be found as Appendix 2 of the EIS. An Air Quality Assessment was required in order to determine baseline conditions and assess the contribution of the installation to ambient pollutant concentrations using dispersion modelling.
Impacts on existing pollutant concentrations were not predicted to be significant at any sensitive human receptor location within the assessment extents.
Impacts were also predicted at the relevant ecological sites. Results indicated that emissions from the installation would not significantly affect existing conditions at the majority of designations. Due to the extreme sensitivity of the nearest receptor to potential impacts (Moninea Bog SAC) an additional analysis of potential emissions was undertaken. This indicated that emissions of all species, with the exception of acid gases, would not cause significant impacts. The predicted effects on acid deposition were partly due to the very low designated air quality criteria and the For inspection purposes only. Consent of copyright owner required for any other use. cumulative nature of impacts. It is noted that the Ballyconnell cement plant already emits acid gases and therefore impacts at the ecological sites will already be accounted for within the background concentrations. This introduces an element of double counting within the results. As such, actual deposition rates are likely to be lower than those predicted. The majority of impacts were predicted based on a worst-case assessment scenario of the facility constantly emitting the maximum permitted concentration of each pollutant throughout an entire year. As such, predicted concentrations and deposition rates are likely to overestimate actual impacts.
In order to further determine the level of impact on Moninea Bog SAC a Natura Impact Assessment has been carried out. It concludes that there is no potential for
Enervise Limited 9
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016 adverse impacts on Moninea Bog, or any other Natura 2000 or Ramsar site as a result of the proposed changes to the Ballyconnell cement plant. The Natura Impact Statement is submitted as part of this planning application.
3.4 Noise The Noise Impact Assessment Report has been produced by Allegro Acoustics. A full copy of the assessment can be found as Appendix 3 of the EIS. The purpose of the assessment is to predict the specific noise levels at façades of nearby residential receptors as a result of the proposed development.
A 3D environmental noise model was developed for the Ballyconnell Cement Plant to predict the noise levels attributable to the new items of plant to be installed as part of the proposed development.
The predicted noise levels for the new items of plant were added to the measured specific noise level due to the existing Cement Plant as measured by Noise and Vibration Consultants Ltd during the 2016 environmental noise survey. The noise model predicted that the noise level attributable to the proposed new items of plant For inspection purposes only. Consent of copyright owner required for any other use. will be negligible and will not cause any noticeable change to the noise levels due to the existing Cement Plant.
The cumulative noise emissions from the existing Cement Plant and the proposed new items of plant are predicted to remain below the day, evening and night noise limit values of 55dB, 50dB and 45dB as outlined by the EPA in Guidance Note for Noise (NG4) at all of the nearest noise sensitive locations.
In addition to NG4, reference was also made to British Standard BS 4142: Methods for rating and assessing industrial and commercial sound. Using this methodology for assessing likelihood of complaint, it was found that the addition of the new plant
Enervise Limited 10
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016 will not increase the likelihood of complaint due to the operation of the Cement Plant.
3.5 Landscape This section considered the potential impact that the proposed development may have on landscape and visual impact. All of the proposed engineering alterations are to be contained within the existing permitted footprint of the Cement Works, with all the infrastructure being situated at ground level (bar the calciner upgrade), in the confines of the existing plant. The calciner upgrade is located to the west of the pre- heater tower with the pre-heater tower shielding views from both the Quinn Cement offices and from further outside the site boundary along the R205. This is best illustrated by the planning elevation drawing P15001/AF2/EL/01, which confirms that the impact of the calciner upgrade will not increase the existing visual impact of the pre-heater tower.
It is considered that the new structures proposed as part of this planning application, will have a negligible impact in visual terms. Furthermore, the proposed change of fuel will not necessitate any form of ground disturbance outside the existing For inspection purposes only. Consent of copyright owner required for any other use. industrial foot print. Accordingly, it is considered that the proposed arrangement of plant will have a negligible impact on the landscape and on visual impact.
3.6 Ecology An Ecological Impact Assessment was undertaken by Woodrow Sustainable Solutions to assess the existing and potential ecological impact of the development on the nearby habitats, protected species and the receiving environment. The full assessment can be found as Appendix 4 of the EIS.
A combination of desk top studies and field surveys were undertaken to determine the potential impact of the proposed development.
Enervise Limited 11
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016
It was determined that there were minor positive impacts for the Upper Lough Erne SAC and the Upper Lough Erne - Crom ASSI which arise as a result of water reuse proposals at the cement plant which will reduce the discharge rate to the Woodford River and downstream impact at these receptors.
The loss of an area of immature woodland for locating the Liquid Fuel Tanks will result in a minor negative impact. It is recommended that no clearance occurs during the bird breeding season (March to August inclusive). This will result in a neutral impact on local breeding birds.
It was determined that the proposed project has the potential to result in negative long term impacts which are considered to be of minor significance to ecological features of interest that are of international significance namely the Moninea Bog SAC. These potential impacts are caused as a result of emissions from the cement plant. No mitigation measures are required for this impact. Consequently, this will result in a minor negative residual impact.
A Natura Impact Statement (NIS) has been completed which provides for a full For inspection purposes only. Consent of copyright owner required for any other use. assessment of the potential impacts on Natura 2000 and Ramsar sites identified as being at risk of impacts from air emissions. It concludes that there is no potential for adverse impacts on any Natura 2000 or Ramsar site identified as a result of the proposed changes to the Ballyconnell cement plant.
3.7 Traffic The Hurlstone Partnership was commissioned to undertake an assessment of the existing road network and the potential impact as a result of the proposed development. The full assessment can be found as Appendix 5 of the EIS.
As a result of the proposed development at the Cement Works, to enable the plant to be able to accept and accommodate a wider range of alternative fuels and raw
Enervise Limited 12
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016 materials, the plant will attract additional HGV deliveries. The distribution of traffic is such that the highest average hourly increase on any given link is up to 6 movements (3 in/3 out) per hour, which equates to 1 movement every 10 minutes. However, this increase on the road network to the south of the site may be partially offset by a reduction in HGV traffic to the north.
When assessed against the baseline flows on the network and the reserve capacity available on the local roads, it is concluded that the increased traffic would have an insignificant impact on the area.
3.8 Natural Resources This chapter considered the impact of the proposed development on Natural Resources, looking specifically at Natural Resources in terms of virgin raw materials (limestone, clay, silt, shale, iron ore and bauxite) used for the production of cement as well as fossil fuels used for the heating of the process (predominately coal).
It can be concluded that the proposed development will have a positive impact from a natural resource perspective by significantly reducing the importation and use of For inspection purposes only. Consent of copyright owner required for any other use. imported fossil fuels through the use of a wider range of alternative fuels. The proposed development will also reduce the reliance on virgin raw materials by using alternative raw materials. Furthermore, the use of these alternatives is considered more sustainable when compared against the sourcing and transportation requirements of existing fossil fuels (mainly coal from South Africa) used at the plant.
3.9 Human Beings: Socio Economic It is considered that the specific subject area with potential to impact on Human Beings has been considered in the preceding sections of this EIS, with particular attention being paid in the areas of Air Emissions, Noise and Traffic.
Enervise Limited 13
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016
Currently employing 80 full-time positions in managing a 24-hour operation, and providing approximately 250 positions in local service supply companies, the Quinn Cement plant plays an important role in sustaining critical mass in the Ballyconnell area, thereby achieving more balanced regional development in line with the National Spatial Strategy for Ireland (2002 – 2020).
It is noted that Cavan County generally, but also the Ballyconnell area in particular, has seen significant population growth and that this population growth is estimated to rise in the period 2011-2020.
It is considered that the employment provided by the Cement plant, both directly and indirectly, along with the associated expenditure in the local community have helped fuel this growth and therefore it is considered that this proposal: to burn a controlled fuel derived from waste, to replace a finite hydrocarbon resource, whilst providing a solution to waste management issues and improving the economic capacity of the Cement Plant,
For inspection purposes only. Consent of copyright owner required for any other use. is of tangible benefit to local communities.
3.10 Cultural Heritage This chapter considers the potential impact that the proposed development may have on Cultural Heritage.
The original EIA for the existing cement works found the potential for archaeological impact to be low and as a precautionary approach archaeological monitoring was carried out in advance of the construction stage for the whole of the existing industrialised area of the cement plant.
Enervise Limited 14
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016
All of the proposed engineering alterations proposed as part of this planning application are to be contained within the same existing permitted footprint of the Cement Works, with all the infrastructure being situated at ground level (bar the calciner upgrades), in the confines of the existing plant.
As the proposed development will result in no alternation to the existing developed footprint it is considered that there is no potential for impacts upon Cultural Heritage in this instance.
4.0 Conclusions The EIS considers the environmental aspects within and around the site, which potentially could experience impact as a result of the proposed development.
The Statement considers all potential areas of impact, with particular reference to Water Quality, Air Emissions, Ecology, Noise and Traffic movements that are the elements that have the potential to alter significantly. The findings can be concluded as follows.
For inspection purposes only. Consent of copyright owner required for any other use. The Water Assessment concludes that the incoming materials are delivered and stored in enclosed areas and there will be no wastewater arising from their use. 1. There will be no change in the demand for water and water will be reused as a result of the proposed development; 2. The existing drainage infrastructure will receive no additional/new input of surface water run-off; 3. The implementation of the treatment systems, engineering measures, fluids handling protocol and monitoring schedule proposed to protect groundwater quality will continue to safeguard the surface water environment and water supplies.
Enervise Limited 15
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016
The results of Air dispersion modelling indicate that: 1. Impacts on existing pollutant concentrations were not predicted to be significant at any sensitive human receptor location within the assessment extents; 2. In relation to ecological receptors that emissions from the installation would not significantly affect existing conditions at the majority of designations, with the exception of Moninea Bog SAC where the significance criteria was slightly exceeded for acid gases.
Further to above, from an ecological perspective a Natura Impact Assessment has been carried out to determine the level of impact on Moninea Bog SAC. It concludes that there is no potential for adverse impacts on Moninea Bog, or any other Natura 2000 or Ramsar site, as a result of the proposed development.
An assessment of the potential noise impact from the proposed alterations has predicted that the plant will remain below the day, evening and night noise limit values of 55dB, 50dB and 45dB as outlined by the EPA in Guidance Note For inspection purposes only. Consent of copyright owner required for any other use. for Noise (NG4) at all of the nearest noise sensitive locations.
It is acknowledged that the proposed development will generate additional HGV deliveries. However, it is concluded that the increased traffic would have an insignificant impact on the area when assessed against the baseline flows and the reserve capacity available on the local roads.
As a result of proposed engineering alterations being proposed within the existing permitted footprint of the plant, and work previously undertaken when establishing that site curtilage, the proposed development will not impact on:
1. Either drift or solid geology; or
Enervise Limited 16
EPA Export 25-05-2016:01:00:34
EIS Non-Technical Summary May 2016
2. Cultural Heritage.
It is considered that the proposed arrangement of plant will have a negligible impact on the landscape and on visual impact.
The proposed development is considered to have a positive impact from a:
1. Natural resource perspective: through savings on virgin raw materials and imported fossil fuels through the use of waste derived alternative raw materials and fuels respectively; and from a 2. Socio-economic perspective: through employment opportunities provided both directly and indirectly as a result of the proposed development.
Accordingly, it is considered that the proposed development which satisfies local, regional and national policy without having significant or adverse impact on the surrounding environment, can further improve the sustainability of the Ballyconnell cement works.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 17
EPA Export 25-05-2016:01:00:35
EIS Non-Technical Summary May 2016
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 18
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
Proposal to increase the range and quantity of alternative fuels and alternative raw materials
at
Quinn Cement, Ballyconnell, Co. Cavan.
Environmental Impact Statement
For inspection purposes only. Consent of copyright owner required for any other use.
Prepared by:
May 2016
Enervise Limited i
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
Table of Contents
Table of Contents ...... ii List of Tables ...... vi List of Figures ...... vii List of Appendices ...... viii 1.0 Introduction ...... 1 1.1 Development Context ...... 2 1.2 Legislative Context ...... 5 1.3 EIS Format and Structure ...... 7 1.4 Pre application Consultations ...... 9 1.5 Specialist Reports ...... 9 1.6 Trans-boundary Issues ...... 10 2.0 Scope of the Environmental Impact Assessment ...... 11 2.1 Alternatives ...... 11 2.1.2 Alternatives Assessed ...... 12 2.2 EIA Scope Determination ...... 15 3.0 Planning and Policy ...... 19 3.1 International Policy ...... 19 3.1.1 COP21 ...... 19 3.1.2 Circular economy Strategy ...... 20 3.2 National Policy ...... 21 3.2.1 Sustainable Development – A Strategy for Ireland (1997) ...... 21 3.2.2 National Spatial Strategy (NSS) for Ireland (2002 – 2020) ...... 22 For inspection purposes only. Consent of copyright owner required for any other use. 3.2.3 National Climate Change Policy ...... 23 3.2.4 National Waste Policy ...... 23 3.2.4.1 Changing Our Ways (1998) ...... 23 3.2.4.2 Delivering Change – Preventing and Recycling Waste (2002) ...... 24 3.2.4.3 Waste Management – Taking Stock and Moving Forward (2004) ...... 24 3.2.4.4 A Resource Opportunity – Waste Management Policy in Ireland (2012) ...... 24 3.2.4.5 Exporting a Resource Opportunity - Discussion Paper (2015) ...... 25 3.2.5 National Energy Policy ...... 25 3.2.5.1 National Renewable Energy Action Plan (NREAP) ...... 25 3.2.5.2 National Energy Efficiency Action Plan (NEEAP) ...... 26 3.2.5.3 Energy White Paper ...... 26 3.3 Regional Policy ...... 28 3.3.1 Border Regional Authority Planning Guidelines 2010 – 2022 ...... 28 3.3.2 Regional Waste Management Plan ...... 29 3.3.2.1 Connacht Ulster Waste Region ...... 29
Enervise Limited ii
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
3.4 Local Policy ...... 32 3.4.1 Cavan County Development Plan 2014 – 2020 ...... 32 3.4.1.1 Waste Management ...... 32 3.4.1.2 Energy ...... 33 4.0 Project Summary and Objectives ...... 35 4.1 Introduction ...... 35 4.2 Proposed Alternative Fuels and Raw Materials ...... 35 4.3 Proposed Plant Changes ...... 36 4.3.1 Meat and Bone Meal Silos ...... 38 4.3.2 Liquid Fuel Tanks ...... 38 4.3.3 Fuel Storage Bay Extension (3 bunkers) ...... 40 4.3.4 Lime Silos ...... 40 4.3.5 Induced Draught (ID) Fan ...... 40 4.3.6 Calciner Upgrade ...... 41 4.4 Summary and Objectives ...... 41 5.0 Geology ...... 43 5.1 Site Context ...... 43 5.1.1 Solid Geology ...... 43 5.1.2 Drift Geology ...... 44 5.2 Previous Geology Assessments ...... 45 5.3 Proposed Development Context ...... 45 5.4 Conclusion ...... 48 6.0 Water Environment ...... 49 6.1 Site Context ...... For inspection purposes only...... 49 Consent of copyright owner required for any other use. 6.1.1 Surface Water ...... 49 6.1.2 Hydrogeological Setting ...... 50 6.2 Development Context ...... 51 6.2.1 Fuel transfer and storage ...... 51 6.2.2 Surface Water Reuse/Fire Water Retention ...... 52 6.3 Methodology ...... 53 6.4 Results ...... 54 6.4 Impact Assessment...... 55 6.5 Conclusion ...... 57 7.0 Air Quality ...... 59 8.0 Noise ...... 61 8.1 Development Context ...... 61 8.2 Methodology ...... 62 8.2.1 Noise Monitoring ...... 62 8.2.2 Predictive Noise Model ...... 62
Enervise Limited iii
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
8.3 Results ...... 63 8.3.1 Noise Survey Results ...... 63 8.3.2 Predictive Noise Modelling ...... 64 8.3.3 Cumulative Noise Levels ...... 65 8.4 Impact Assessment...... 66 8.5 Conclusion ...... 67 9.0 Landscape ...... 69 9.1 Site Context ...... 69 9.2 Previous Landscape and Visual Impact Assessments ...... 69 9.2.1 Original EIS 1997 ...... 69 9.2.2 EIS 2009 ...... 70 9.3 Proposed Plant Alterations ...... 71 9.4 Conclusion ...... 74 10.0 Ecology...... 75 10.1 Methodology ...... 75 10.2 Main Findings ...... 75 10.3 Natura Impact Statement ...... 76 11.0 Traffic ...... 77 11.1 Local Network ...... 77 11.2 Baseline Traffic Flows ...... 77 11.2.1 Traffic Activity Levels ...... 78 11.3 Proposed Development Traffic ...... 79 11.3.1 Traffic Distribution ...... 81 For inspection purposes only. 11.4 Conclusion ...... Consent...... of copyright owner required...... for any other use...... 82
12.0 Natural Resources ...... 83 12.1 Introduction ...... 83 12.2 Cement Production Process ...... 83 12.2.1 Raw Material Handling ...... 84 12.2.2 Raw Milling ...... 84 12.2.3 Clinker Production ...... 85 12.2.4 Cement Milling and Dispatch ...... 85 12.3 Natural Resource Requirements ...... 86 12.4 Impact of Proposed Development ...... 87 12.4.1 Alternative Raw Materials ...... 88 12.4.2 Alternative Fuels ...... 89 12.5 Conclusion ...... 90 13.0 Human Beings: Socio Economic ...... 91 13.1 Introduction ...... 91
Enervise Limited iv
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
13.2 Methodology ...... 91 13.3 Existing Environment ...... 91 13.3.1 Population ...... 93 13.3.2 Settlement ...... 93 13.3.3 Employment ...... 94 13.4 Proposed Development ...... 94 13.4.1 Employment & Economic Opportunity ...... 95 13.5 Conclusion ...... 96 14.0 Cultural Heritage ...... 99 14.1 Previous Archaeological Assessments ...... 99 14.1.1 Original EIS 1997 ...... 99 14.2.1 EIS 2009 ...... 100 14.2 Proposed Development Context ...... 100 14.3 Conclusion ...... 102 15.0 Interactions of the Foregoing ...... 105 16.0 Conclusions ...... 107 Appendices ...... 111
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited v
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
List of Tables
Table 1: Proposed New Equipment ...... 4 Table 2: Sections within EIS that cover the required Aspects under the Regulations ...... 9 Table 3: EIS Contributors ...... 10 Table 4: Environmental Assessment of Alternatives ...... 13 Table 5: Identification of Potential Impacts and Receptors ...... 16 Table 6: Scoping Matrix ...... 16 Table 7: Summary of proposed Noise Sources ...... 62 Table 8: Predicted noise levels at NSL1 – NSL6 attributable to proposed additions to the existing Cement Plant...... 65 Table 9: Calculated cumulative noise level from both the existing Cement Plant and the addition of new plant ...... 66 Table 10: BS 4142 assessment showing that the likelihood of complaint from the new plant items ...... 67 Table 11: Raw Material Use (tonnes) – Clinker Production (2013-2015) ...... 86 Table 12: Clinker Additives (tonnes) – Cement Production (2013-2015) ...... 87 Table 13: Population & Population Change Indicators (Source CSO) ...... 93 Table 14: Interactions of EIA elements ...... 106
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited vi
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
List of Figures
Figure 1: Site Location ...... 3 Figure 2: Benefits of Co processing in the Cement Industry (Source www.cement.ie ) ...... 33 Figure 3: 3D graphic from the SoundPLAN environmental noise model ...... 63 Figure 4: Extract from 2016 Environmental Noise Survey at Quinn Cement carried out by Noise and Vibration Consultants Ltd showing measured day time noise levels at NSL1 – NSL6...... 64 Figure 5: Extract from 2016 Environmental Noise Survey at Quinn Cement carried out by Noise and Vibration Consultants Ltd showing measured night time noise levels at NSL1 – NSL6...... 64
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited vii
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
List of Appendices
Appendix 1 Hydrogeological and Hydrological Assessment BCL Consultant Hydrogeologists Limited
Appendix 2 Air Quality Impact Report Redmore Environmental
Appendix 3 Noise Impact Assessment Allegro Acoustics
Appendix 4 Ecological Impact Assessment Woodrow Sustainable Solutions
Appendix 5 Traffic Impact Assessment The Hurlstone Partnership
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited viii
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
1.0 Introduction This Environmental Impact Statement (EIS) accompanies a planning application being submitted to Cavan County Council to increase the range and quantity of alternative fuels and alternative raw materials for use at the Quinn Cement Works, Ballyconnell, Co. Cavan.
The proposed project seeks to improve the sustainability of the Ballyconnell cement plant, through the use of an increased range of waste derived alternative raw materials and fuels with the long term aim of displacing almost all fossil fuels at the plant (a limited proportion of fossil fuels will be required during process start up and for process optimisation/stabilisation). The use of these alternatives will equate to 300,000 tonnes per annum at maximum substitution.
A range of suitable materials are proposed for acceptance at the plant which can be summarised as follows: Solid Fuels – including Solid Recovered Fuel (SRF) which is currently authorised for use at the plant, as well as a range of suitable fuels derived from other sources including: For inspection purposes only. Consent of copyright owner required for any other use. o Meat and Bone Meal (MBM); o Tyre Derived Fuel (TDF); o Biomass Fuels; o Sludges and Filter Cakes. Liquid Fuels – including Secondary Liquid Fuel (SLF) which is a blend of organic and solvent wastes blended to a defined specification as well as liquid fuels derived from other sources (e.g. waste oils). Alternative Raw Materials (e.g. muds, minerals, sludges).
Enervise Limited 1
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
Each waste derived material is assigned a LoW (List of Waste) code, which can only be used at the cement plant following authorisation by the Environmental Protection Agency (EPA). A full list of LoW codes proposed for use at the plant is included in the Industrial Emissions (IE) Licence application being made concurrent to this planning application.
It is also proposed to include natural gas and petcoke as additional fuels in the Industrial Emissions (IE) Licence, regulated by the EPA. This is to provide flexibility for any future fossil fuel requirement.
1.1 Development Context The Quinn Cement site is located immediately to the south of the Fermanagh/Cavan border, approximately 2 km north of the centre of the Town of Ballyconnell, Co. Cavan and 6.5km south of the village of Derrylin, Co. Fermanagh. The precise location of the site’s application area can be seen from Figure 1.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 2
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
For inspection purposes only. Consent of copyright owner required for any other use.
Figure 1: Site Location
The proposed development, to which this Planning Application relates i.e. the land use development, is for the physical engineering alteration to the plant in order to accept the introduction of alternative fuels and alternative raw materials as direct replacement for coal and virgin raw materials respectively.
The proposed engineering solutions all reside within the permitted footprint of the Cement Works (00/1384), with the vast majority of the infrastructure being situated at ground level in the centre of the existing plant. As a result, ostensibly there will
Enervise Limited 3
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016 be very little alteration to the external appearance from outside the plant. The proposed plant changes are set out at Table 1 below. This Table also indicates where the equipment was previously authorised under planning reference (09/456) which has now lapsed. This permission allowed for the use of Solid Recovered Fuel (SRF) at the plant. The equipment, which previously received planning permission in 2009, was not constructed in 2014 when the Quinn Cement plant was under different management. Planning permission has now lapsed for this equipment but the current management view it as essential in order to maximise coal displacement with alternative fuels. For this reason, the current application is seeking planning permission for this equipment once again, albeit in some instances with minor modifications to the proposals put forward in 2009.
Equipment Requirement Previously authorised under Planning Ref: 09/456 Bunded Liquid Fuel tanks SLF and other liquid No and associated feeding fuels Storage system Meat & Bonemeal silos and MBM Storage No associated feeding system For inspection purposes only. Consent of copyright owner required for any other use. Lime silos and associated Reduce SOx emissions No feeding system Extension to existing SRF and other Solid Yes, albeit slightly modified in Storage bays and associated Alternative fuels this planning application feeding system (footprint reduced). Induced Draught (ID) Fan Process Yes, no change. Calciner Process Yes, albeit slightly modified in this planning application (elevation reduced). Table 1: Proposed New Equipment
Enervise Limited 4
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
1.2 Legislative Context Following consultation with Cavan County Council and the Environmental Protection Agency it was determined that the proposed development would be subject to the Environmental Impact Assessment process. To ensure continuity of approach, the Environmental Impact Statements produced in 1997 and 2009 for the facility have been reviewed, with information integrated where relevant in to this Environmental Impact Statement.
EIA requirements, including requirements for information to be contained in EISs, derive from the European Commission’s EIA Directive 85/337/EEC and the subsequent amendments by Directives 97/11/EC, 2003/35/EC and 2009/31/EC. The primary objective of the EIA Directives is to ensure that projects which are likely to have significant effects on the environment are subject to an assessment of their likely impacts.
The initial EIA Directive of 1985 along with the 3 subsequent amendments have been codified by Directive 2011/92/EU. Directive 2011/92/EU has been amended in 2014 by Directive 2014/52/EU. Member States have until April 2017 to transpose the For inspection purposes only. Consent of copyright owner required for any other use. provisions of Directive 2014/52/EU.
These EIA Directives are transposed in to Irish legislation through the Planning & Development Act 2000 (as amended) and the Planning & Development Regulations 2001 (as amended).
This EIS has been prepared in accordance with the relevant provisions set out in the Planning and Development Regulations 2001 (as amended). Schedule 6 of these Regulations specifies the information to be contained in an EIS, as follows:
“(a) A description of the proposed development comprising information on the site, design and size of the proposed development.
Enervise Limited 5
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
(b) A description of the measures envisaged in order to avoid, reduce and, if possible, remedy significant adverse effects. (c) The data required to identify and assess the main effects which the proposed development is likely to have on the environment. (d) An outline of the main alternatives studied by the developer and an indication of the main reasons for his or her choice, taking into account the effects on the environment.”
The following further information is also required, where considered relevant: “(a)(i) a description of the physical characteristics of the whole proposed development and the land-use requirements during the construction and operational phases; (ii) a description of the main characteristics of the production processes, for instance, nature and quantity of the materials used; (iii) an estimate, by type and quantity, of expected residues and emissions (including water, air and soil pollution, noise, vibration, light, heat and radiation) resulting from the operation of the proposed development; (b) a description of the aspects of the environment likely to be significantly affected by the proposed development, including in particular:
- human beings, fauna Forand inspection flora, purposes only. Consent of copyright owner required for any other use.
- soil, water, air, climatic factors and the landscape, - material assets, including the architectural and archaeological heritage, and the cultural heritage, - the inter-relationship between the above factors; (c) a description of the likely significant effects (including direct, indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative) of the proposed development on the environment resulting from: - the existence of the proposed development, - the use of natural resources, - the emission of pollutants, the creation of nuisances and the elimination of waste, and a description of the forecasting methods used to assess the effects on the environment;
Enervise Limited 6
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
(d) an indication of any difficulties (technical deficiencies or lack of know-how) encountered by the developer in compiling the required information.”
Finally, the EIS should contain a summary in non-technical language of the aforementioned information.
1.3 EIS Format and Structure Although certain headings within this EIS may be altered from the standard headings outlined in the 2001 regulations, the overall structuring and scope of the report has regard to the informational requirements of the EC Directives and Irish Statutory Regulations.
This statement has been compiled and presented in as transparent and as open a manner as possible. The various authors involved in its compilation have attempted to present their findings and recommendations in a clear and unambiguous fashion.
The EIS comprises three parts, namely The Non-Technical Summary, the Main Report and the Appendices. For inspection purposes only. Consent of copyright owner required for any other use.
The EIS is presented in the following format:
PART I Non-Technical Summary.
PART II Section 1 The Introduction outlines the background and terms of reference for the EIS and outlines the format and the assumptions that underpin the statement.
Enervise Limited 7
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
Section 2 Review of the alternatives investigated by the applicant and the scope of the assessment with respect to the sites particular characteristics.
Section 3 Defines the planning and development context in which the planning application is assessed.
Section 4 Describes the features of the proposed development in relation to the characteristics of the fuels proposed and their transport, storage and feeding requirements.
PART III Sections 5-15 Incorporates the main body of the EIS and outlines the aspects of the environment likely to be significantly affected by the proposed development, as identified in Schedule 6 of the Planning and Development Regulations 2001 (as amended) “human beings, fauna and flora, soil, water, air, climatic factors and the landscape, material assets, including the architectural and For inspection purposes only. archaeologicalConsent of heritage, copyright owner cultural required for any heritage, other use. and the inter-relationship
between the above factors;”
The EIS is produced in the Grouped Format Structure as outlined in Section 1.7.2 of the EPA Guidelines March 2002. As a result of this approach topics such as human beings are covered to varying degrees in most of the individual Sections, whereas other specific areas required under legislation fall almost exclusively into one Section. For those aspects of the environment likely to be significantly affected by the proposed development, that fall neatly into one or two sections the sections within which they are covered are shown below in Table 2.
Enervise Limited 8
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
Section Heading Aspects Required to be covered under the Regulations 5 Geological Assessment Soil 6 Water Environment Water 7 Air Quality & Climate Air, Climatic Factors 8 Noise Human Beings 9 Landscape Landscape 10 Ecology Flora and Fauna 11 Traffic Impacts Material Assets 12 Natural Resources Material Assets 13 Socio-Economic Impacts Human Beings 14 Cultural Heritage Archaeological and Cultural Heritage 15 Interactions Inter-relationship of above factors Table 2: Sections within EIS that cover the required Aspects under the Regulations
1.4 Pre application Consultations Pre application consultations were held with Cavan County Council (various Departments) and the Environmental Protection Agency (EPA).
The consultation with the EPA is of particular relevance as the existing emissions For inspection purposes only. Consent of copyright owner required for any other use. and any future emissions are regulated by the EPA. An application for a review of the current Industrial Emission Licence (IEL No. P0378-02) for the facility is being made concurrently to the EPA.
1.5 Specialist Reports The production of this Environmental Impact Statement has been project managed by Enervise Limited. All external consultants have been appointed and project managed by Enervise. The specialist reports, held within the Appendices, have been reviewed and summarised by Enervise in Sections 5-15 of the document for ease of reading, however, the full reports are held in Sections 17 onwards.
Enervise Limited 9
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
Provided below at Table 3 is the contributor to each Section of the Statement. Section Heading Specialist Contributor 1 Introduction Enervise Limited 2 Scope & Alternatives Enervise Limited 3 Planning & Policy Enervise Limited 4 Project Description Enervise Limited 5 Geological Setting BCL Hydrogeologists Limited 6 Water Environment BCL Hydrogeologists Limited 7 Air Quality & Climate Redmore Environmental 8 Noise Vibration Allegro Acoustics 9 Landscape Enervise Limited 10 Ecology Woodrow Sustainable Solutions 11 Traffic Impacts Hurlstone Partnership Limited 12 Natural Resources Enervise Limited 13 Socio-Economic Impacts Enervise Limited 14 Cultural Heritage Enervise Limited 15 Interactions Enervise Limited Table 3: EIS Contributors
No significant difficulties were encountered while compiling the necessary For inspection purposes only. Consent of copyright owner required for any other use. information for the EIS.
1.6 Trans-boundary Issues Due to the northern boundary of the proposed development site being contiguous with that of the national boundary between two member states, namely Northern Ireland and the Republic of Ireland, there will be areas where trans-boundary effects are inevitable.
These areas have been dealt with, where they occur, in each individual report for example in the areas of traffic, air quality & climate, noise and ecology where the potential impacts have no regard for boundaries.
Enervise Limited 10
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
2.0 Scope of the Environmental Impact Assessment In establishing the scope of the Environmental Impact Assessment process, consideration must be given at the earliest opportunity to all elements that the proposed development may impact upon. This Section of the EIS deals with the alternatives considered as relevant to the proposed development. It also explains the process by which the scope of the Environmental Impact Assessment was determined.
2.1 Alternatives The EIA Directive requires an EIS to contain:
“A description of the reasonable alternatives (for example in terms of project design, technology, location, size and scale) studied by the developer, which are relevant to the proposed project and its specific characteristics, and an indication of the main reasons for selecting the chosen option, including a comparison of the environmental effects.”
Cement manufacturing is an energy intensive process. The cement plant in Ballyconnell is an established facility since 2000, and as a result the consideration of For inspection purposes only. Consent of copyright owner required for any other use. alternative locations is not possible. Therefore, it is incumbent on the operators to improve the sustainability of the existing facility.
Prior to the use of Solid Recovered Fuel at the Ballyconnell cement plant, the process was 100% reliant on imported fossil fuels for thermal requirements. Since 2014 the plant has been using Solid Recovered Fuel (SRF) to displace the use of fossil fuels and is currently authorised to use 127,875 tonnes of SRF at the plant, which equates to 55% fossil fuel substitution at maximum production. The proposed development seeks to improve the sustainability of the Ballyconnell cement plant, through the use of an increased range of waste derived alternative fuels with the long term aim of displacing almost all fossil fuels at the plant. Furthermore, the proposed project
Enervise Limited 11
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016 seeks to reduce the use of virgin raw materials by using alternative raw materials in the process.
In this overall context, various alternatives were considered during the design phase of the proposed project as described below. The reasons for progressing with the development as proposed are outlined, along with an initial comparison of the environmental effects of the ‘as proposed’ development versus the alternatives.
2.1.2 Alternatives Assessed The main alternatives considered were: 1. ‘Do nothing’ alternative: It is regarded as best practice within the EIA process to consider this alternative. The ‘do nothing’ scenario would be described as using a combination of SRF and coal with the existing plant and equipment on site. 2. ‘Maximise SRF’ alternative: This scenario considered maximising the use of Solid Recovered Fuel (SRF) as the only alternative fuel at the plant. This project would require the construction of the calciner upgrade, the new ID fan, the lime silos and the extension to the SRF storage bunkers (all of which For inspection purposes only. Consent of copyright owner required for any other use. form part of this planning application). It would seek to increase the current authorised limit of SRF from 127,875 tonnes per annum to circa 160,000 tonnes per annum which would equate to approximately 70% coal displacement at maximum production. This scenario would rely on fossil fuel (predominately imported coal) for the remaining thermal requirement. 3. ‘Maximise AF/ARM’ alternative: This scenario considered maximising Alternative Fuel (AF) use at the plant by widening the range of possible alternative fuels to include a range of solid and liquid alternative fuels which could maximise fossil fuel displacement in both the kiln and in an upgraded calciner. It also considered displacing a proportion of virgin raw materials through the use of alternative raw materials.
Enervise Limited 12
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
EIA Element Alternative 1: Alternative 2: Maximise Alternative 3: Maximise Do Nothing SRF AF/ARM Planning/Policy No change Moderate positive (in Significant positive (in relation to waste/energy relation to waste/energy targets) targets) Geology No change Neutral (within site Neutral (within site curtilage - no impact on curtilage - no impact on geology) geology) Climate No change Moderate positive Significant positive
(potential to reduce CO2 (potential to reduce CO2 emissions by circa. 78,000 emissions by circa. 177,000 tonnes per annum) tonnes per annum) Air Quality No change Neutral (must comply with Neutral (must comply with EPA licence requirements) EPA licence requirements) Noise No change Neutral (must comply with Neutral (must comply with EPA licence requirements) EPA licence requirements) Landscape No change Negligible impact (due to Negligible impact (due to additional structures) additional structures) Ecology No change Neutral (no impact on site Neutral (no impact on site
Forecology) inspection purposes only. ecology) Consent of copyright owner required for any other use.
Traffic No change Neutral (due to reserve Neutral (due to reserve network capacity) network capacity) Natural No change Moderate positive (in terms Significant positive (in Resources of fossil fuels saved) terms of fossil fuels and virgin raw materials saved) Human Beings: No change Moderate positive Significant positive Socio Economic (potential for indirect (potential for direct and employment) indirect employment) Cultural No change No change No change Heritage Table 4: Environmental Assessment of Alternatives
Enervise Limited 13
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
As can be seen from Table 4, the initial environmental assessment of alternatives indicated that Alternative 1: “Do Nothing” would see no change to existing environmental conditions at the site. Furthermore, the potential for utilisation of the authorised SRF tonnage would be curtailed due to storage and process limitations, which Alternatives 2 and 3 sought to address.
Alternatives 2 and 3 would require the physical development of new plant to address current process limitations in storage, feeding and combustion of SRF and other alternative fuels. Alternative 2 “Maximise SRF” would require the construction of the calciner upgrade, the new ID fan, the lime silos and the extension to the SRF storage bunkers. Some additional equipment (Liquid Fuels tanks and Meat and Bone Meal silos) would be required for Alternative 3 “Maximise Alternative Fuel & Alternative Raw Materials”. Both Alternatives 2 and 3 would therefore result in a negligible impact in landscape/visual impact terms due to these new structures.
Alternatives 2 “Maximise SRF” showed the potential for positive impacts over the “Do Nothing” alternative. Alternative 2 showed the potential for moderate positive impacts in contributing to relevant policy targets in relation to waste and energy, For inspection purposes only. Consent of copyright owner required for any other use. CO2 reduction, savings in fossil fuels and potential to maintain/slightly increase indirect employment in the provision of SRF.
Alternative 3 showed the potential for significant positive impact in each of the aforementioned areas with the potential to: Contribute significantly to policy targets on waste and energy;
Reduce circa. 177,000 tonnes of CO2 versus the “Do Nothing” scenario; Reduce reliance on fossil fuels and virgin raw materials through the use of alternative fuels and alternative raw materials respectively; Increase the potential for direct employment at the cement plant (7 additional employees) as well as providing the potential for indirect employment in the waste industry through processing of the alternative fuels and raw materials.
Enervise Limited 14
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
It was on the basis of the above that Alternative 3 “Maximise Alternative Fuel & Alternative Raw Materials” was progressed through to the EIA scope determination and subsequent assessment stages.
2.2 EIA Scope Determination As set out at Schedule 6 of the Planning and Development Regulations 2001 (as amended) the scope of an EIS will need to be determined by evaluating the aspects of the environment likely to be significantly affected by the development with reference to the following:
“human beings, fauna and flora, soil, water, air, climatic factors and the landscape, material assets, including the architectural and archaeological heritage, cultural heritage, and the inter-relationship between the above factors;”
The scoping exercise involved a review of information relevant to the existing facility including previous Environmental Impact Statements, historic monitoring data and reports, as well as consultation with the Regulators. It also considered the potential impacts associated with the proposed development. For inspection purposes only. Consent of copyright owner required for any other use.
To determine the environmental aspects that should be addressed within this EIA, each of the main activities within the development were examined and potential impacts arising from those activities were identified, together with receptors of any such impacts. The main site activities, impacts and receptors are identified within Table 5 below.
Enervise Limited 15
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
Proposed Activity Potential to Impact Potential Receptors
Initial development, plant erection. Ecology Flora/Fauna Noise Humans Visual Landscape Commissioning of plant and use of Air Quality Air alternative fuels and alternative raw Humans Humans materials. Noise Water Traffic Water Quality Table 5: Identification of Potential Impacts and Receptors
From the identification of potential impacts and receptors, a scoping matrix has been compiled which gives a clear indication of the main impacts to be assessed within this EIA. The scoping matrix is set out below in Table 6 and has been prepared as a result of consultations with the Regulators (EPA and Cavan County Council).
Potential Receptor
Potential Source of Agriculture Archaeology Humans Landscape Water Ecology Air Environment Impact For inspection purposes only. Consent of copyright owner required for any other use. Construction
Visual
Noise
Air emissions Traffic
Water emissions After Use
Table 6: Scoping Matrix
Enervise Limited 16
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
The EPA Guidelines on the information to be contained in an Environmental Impact Statement (March 2002) makes reference in Section 3 to the importance of keeping the EIS as tightly focused as possible. This objective can be achieved by avoidance of re-inventing the wheel and by focusing upon the “Likely and Significant” effects of a development. These elements need to be discussed in detail whereas other issues, with little or no significance, may require a brief investigation. This will indicate that an area has been given due consideration, but has been rejected from requiring a full investigation.
The existing site was the subject of a planning application accompanied by an EIS, upon which An Bord Pleanala issued a decision in May 1998. Therefore certain elements of the EIS process relating to the development life cycle were covered by that application and EIS. Items such as the:
Initial landtake and its effects on - Ecology; Archaeology; Existing Water Environment; Construction of the facility and its effects on - Landscape; For inspection purposes only. Consent of copyright owner required for any other use. Closure of the plant and site restoration effects on - Agriculture; and Ecology have all previously been considered and none of these aspects have changed.
Furthermore, an Environmental Impact Statement was submitted as part of a planning application permitted by Cavan County Council in 2009 to displace 55% of the coal used at the cement plant with SRF. That Environmental Impact Statement considered the potential impact of many of the structures which again form part of this planning application. Therefore, that 2009 EIS has been revisited and updated as part of this assessment process.
Enervise Limited 17
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
The environmental elements chosen for the most detailed scrutiny therefore are as follows:
Ecology (Flora and Fauna) Air Quality Noise Water Environment (Surface and Groundwater) Traffic Other less significant areas include, Human Beings, Material Assets, Landscape
Separate reports have been prepared for each of the significant elements by specialist consultants. Each report considers the following: baseline study; identifying potential impacts predicting and evaluating the magnitude and significance of impacts; proposing mitigation measures.
The remit of the EIA process is to consider all environmental aspects, which could For inspection purposes only. Consent of copyright owner required for any other use. experience impact from the proposed development, from which the identification of mitigation measures can be undertaken.
The purpose of the mitigation measures are to ensure that the development can be undertaken without creating any significant or unacceptable adverse impacts on the environment or amenity of the area.
Enervise Limited 18
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
3.0 Planning and Policy This chapter of the EIS considers the proposed development in the context of International, National, Regional and Local policy.
3.1 International Policy 3.1.1 COP21 In 1992 the Rio Earth Summit saw an international political response to climate change with the adoption of the UN Framework on Climate Change (UNFCCC). Known as the “Rio Convention”, it set out a framework for action aimed at stabilising atmospheric concentrations of greenhouse gases (GHGs) to avoid dangerous manmade interference with the climate system.
The Conference of Parties (COP) is the governing body of the UN Framework on Climate Change (UNFCCC) which meets annually. The main objective of the annual Conference of Parties (COP) is to review the Convention’s implementation. In 2015 the COP meeting took place in Paris (COP21), and resulted in the 2015 Paris Agreement. The main aim of the agreement is to keep a global temperature rise this century well below 2 degrees Celsius and to drive efforts to limit the temperature For inspection purposes only. Consent of copyright owner required for any other use. increase even further to 1.5 degrees Celsius above pre-industrial levels.
In order to achieve this aim the Agreement established the requirement for binding commitments by all parties to make “nationally determined contributions” (NDCs) to reduce emissions and to pursue domestic measures aimed at achieving them. The proposed development by Quinn Cement, which has the long term aim of displacing almost all fossil fuels at the plant, is aligned with this policy objective and will assist Ireland in fulfilling its obligations.
Enervise Limited 19
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
3.1.2 Circular economy Strategy In an attempt to move away from the “take, make and dispose” or linear economic model whereby large amounts of energy is used and a large amount of waste is generated, the European Commission introduced the Circular Economy Package. This Circular Economy Package consists of an EU action plan which sets out measures from a lifecycle perspective: from production and consumption to waste management and the market for secondary raw materials. These measures aim to “close the loop” whereby greater recycling and reuse is supported which will bring benefit to the economy and the environment.
The Circular Economy Package includes revised legislative proposals on waste which the proposed development is aligned to; the most relevant are set out below: A common EU target for recycling 65% of municipal waste by 2030; A common EU target for recycling 75% of packaging waste by 2030; A binding landfill target to reduce landfill to maximum of 10% of all waste by 2030; A ban on landfilling of separately collected waste; Promotion of economic instruments to discourage landfilling; For inspection purposes only. Consent of copyright owner required for any other use. Concrete measures to promote re-use and stimulate industrial symbiosis - turning one industry's by-product into another industry's raw material.
Enervise Limited 20
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
3.2 National Policy 3.2.1 Sustainable Development – A Strategy for Ireland (1997) The Department of the Environment published Sustainable Development – A Strategy for Ireland in 1997. This policy document looked to promote proper planning and sustainable development within the various sectors of the economy. Of particular relevance to the proposed development are the following which were outlined as key strategic actions at the time for the industrial sector: Increased focus through the Waste Management Act 1996 on recovering, rather than disposing of, by-products, products, packaging and wastes from industrial sources; Encouragement of Producer Responsibility Initiatives to increase the reuse and recycling of wastes; Coordination of cleaner production mechanisms to ensure maximum efficiency and value in the uptake and replication of initiatives; Development of a materials and energy balance for industry to determine the full extent of industry's environmental/natural resource impacts and advise on targets for greater eco-efficiency.
For inspection purposes only. Consent of copyright owner required for any other use. The strategy also made reference to the importance of minimising emissions to the environment from the industrial sector as well reducing the consumption of natural resources as set out below from pg.89 of the Strategy:
“Consumption of finite natural resources (both indigenous and imported) is a major issue for sustainable development.”
The proposed project looks to improve the sustainability of the cement plant by reducing the reliance on imported coal by using alternative fuels as well as reducing reliance on indigenous virgin raw materials by replacing with alternative raw materials.
Enervise Limited 21
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
3.2.2 National Spatial Strategy (NSS) for Ireland (2002 – 2020) The National Spatial Strategy for Ireland (2002 – 2020) was published by the Department of the Environment and Local Government in 2002 as a twenty-year planning framework aimed at promoting a better balance of social, economic, physical development and population growth between regions.
Located in Ballyconnell Co. Cavan the Quinn Cement plant is located within the Border Region. In an effort to achieve balanced development in this region Letterkenny/Derry, Sligo and Dundalk were designated as new gateways to drive development through “enhanced critical mass, accessibility and capacity for development”.
Other towns, villages and rural areas (which would include Ballyconnell town and the adjoining area where the cement plant is located) were identified as needing to develop roles complementary to those of the gateways to ensure that a wider area will benefit from the “critical mass” in the region provided by the gateways. Review of the strategy indicates that:
“Critical mass relates to size and concentration of population that enables a range of For inspection purposes only. Consent of copyright owner required for any other use. services and facilities to be supported. This in turn can attract and support higher levels of economic activity and improved quality of life.”
Employing 80 full-time positions in managing a 24-hour operation, and providing approximately 250 positions in local service supply companies, the Quinn Cement plant plays an important role in sustaining critical mass in the Ballyconnell area, thereby achieving more balanced regional development.
Whilst the NSS does not aim to “replace or restate environmental policies” it does make specific reference to the fact that development arising from the NSS will “be implemented within the framework of strong and ambitious policies for the protection of the environment” and that “Policy and action in this regard will focus, on limitations on
Enervise Limited 22
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016 greenhouse gas emissions in the context of the National Climate Change Strategy (2000)”. In line with this, the proposed development aims to reduce greenhouse gas emissions by expanding the range of alternative fuels and raw materials used at the facility.
3.2.3 National Climate Change Policy The “National Policy Position on Climate Action and Low Carbon Development” as published in April 2014 provides a high-level policy direction for the adoption and implementation of plans to enable Ireland to move to a low carbon economy by 2050. Statutory authority for the plans is set out in the Climate Action and Low Carbon Development Act 2015. This legislation allows for the making of five-yearly National Mitigation Plans in order to reduce greenhouse gas emissions. It is understood that work is currently underway on developing the first National Mitigation Plan.
The Quinn Cement facility is required to take part in the European Union Emissions
Trading Scheme (EUETS). The proposed development aims to further reduce CO2 emissions from the facility. Furthermore, the proposed development will indirectly reduce greenhouse gas emissions from the waste sector, through the avoidance of landfilling and export of waste. For inspection purposes only. Consent of copyright owner required for any other use.
3.2.4 National Waste Policy The following sections set out the Irish waste policy provisions most relevant to the proposed development.
3.2.4.1 Changing Our Ways (1998) This was the first major policy document on the management of waste in Ireland and was based on the waste management hierarchy with greatest emphasis on waste prevention, followed by minimisation, re-use, recycling, energy recovery and environmentally sustainable disposal of waste which cannot be prevented or recovered. It also set out the importance of an integrated waste management approach.
Enervise Limited 23
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
Of specific relevance to the proposed development, it gave early indication of the potential role that cement manufacture could play in the area of waste management:
“There is scope for the use of waste (and residual materials from certain waste treatments) as a fuel in other combustion processes, including power generation and cement manufacture, subject to appropriate controls and emission standards. Elsewhere in the EU, cement kilns have traditionally burned a wide range of wastes, including tyres, oils and plastics, and this option merits investigation, where circumstances are appropriate.”
3.2.4.2 Delivering Change – Preventing and Recycling Waste (2002) This government policy document built on the “Changing Our Ways” policy document, reiterating the elements of the waste management hierarchy and outlining proposals to give regulators more power to tackle the problem of waste.
3.2.4.3 Waste Management – Taking Stock and Moving Forward (2004) This government policy document reviewed the situation at the time with respect to waste management in Ireland. It acknowledged good progress in relation to
For inspection purposes only. recycling but indicated that Consentgreater of copyright advances owner required were for any otherrequired use. in other areas such as waste prevention and minimisation, and thermal treatment.
3.2.4.4 A Resource Opportunity – Waste Management Policy in Ireland (2012) With a clear focus on resource efficiency, this policy document set out the measures by which Ireland will make further process on recycling and the virtual elimination of landfilling of waste. It outlines the role that various technologies, including cement kilns, can play in recovering energy from waste. The proposed development seeks to improve resource efficiency by using an extended range of alternative fuels and alternative raw materials, thereby limiting the requirement to use virgin fossil fuels and virgin raw materials whilst simultaneously reducing the amount of waste sent to landfill.
Enervise Limited 24
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
3.2.4.5 Exporting a Resource Opportunity - Discussion Paper (2015) The Department of the Environment, Community and Local Government launched a public consultation in November 2015 in relation to the fact that large volumes of waste are being exported from Ireland in the form of Refuse Derived Fuel (RDF), Solid Recovered Fuel (SRF) and residual Municipal Solid Waste (MSW) for energy recovery abroad. The paper sets out that exports have increased substantially in recent years from a near zero base in 2009 to 347,000 tonnes in 2013. It claims that these exported resources could be used domestically to generate employment, boost economic activity and contribute to the circular economy.
The discussion paper acknowledges the strides made by the Cement Industry in Ireland in developing the use of SRF and poses the question as to whether public procurement contracts, and the suggestion that even all construction, should specify “greener cement”. It suggests that a clear timeline should be developed and communicated to the cement industry in this regard given the potential CO2 reduction benefits of the proposal. The proposed development would result in Quinn Cement producing “greener cement” in keeping with any future specification or procurement developments in this area. For inspection purposes only. Consent of copyright owner required for any other use.
3.2.5 National Energy Policy 3.2.5.1 National Renewable Energy Action Plan (NREAP) The Renewables Directive (2009/28/EC) requires that each Member State adopt a National Renewable Energy Action Plan (NREAP) and submit it to the European Commission. The NREAP sets out the National Targets for the share of renewable energy to be consumed in the heating/cooling, transport and electricity sectors in 2020.
The biodegradable share of waste used in the cement industry is determined through BS EN15440:2011 - Solid Recovered Fuel, Methods for the Determination of Biomass Content. This biodegradable content is then accounted towards meeting
Enervise Limited 25
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
Ireland’s target of 12% of final heat demand from renewable energy sources (RES-H) by 2020. The proposed development, through the use of a wider range of alternative fuels, some of which are carbon neutral (e.g. Meat and Bonemeal, Biofuels), will further assist Ireland in meeting RES-H targets set under the NREAP.
3.2.5.2 National Energy Efficiency Action Plan (NEEAP) The Energy Efficiency Directive (2012/27/EU) has an aim of helping all stakeholders to better manage their energy consumption. The Directive outlines the challenges that Europe faces in terms of:
“..increased dependence on energy imports and scarce energy resources, and the need to limit climate change and to overcome the economic crisis.”
In an effort to meet these challenges Ireland has set a national target to reduce energy demand by 20% of the historic average energy use during the period 2000– 2005 through energy efficiency measures. These measures are set out in the National Energy Efficiency Action Plan (NEEAP) which is in response to the Energy Efficiency Directive. The proposed development seeks to improve the energy For inspection purposes only. efficiency of the BallyconnellConsent cement of copyright plantowner required in for this any other national use. context by reducing energy imports and using otherwise wasted resources as alternative raw materials and alternative fuels.
3.2.5.3 Energy White Paper The Energy White Paper - Ireland’s Transition to a Low Carbon Energy Future 2015- 2030, sets out a framework for Irish Energy policy up to 2030. The policy document sets out that non-renewables currently account for over 90% of energy consumption within Ireland. Chapter 3 of the Policy document looks to Ireland having a low carbon energy system by 2050, whereby greenhouse gas emissions will be reduced by 80-95%. Of particular relevance to the proposed development is the assertion that
Enervise Limited 26
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
“There will be substantial increases in the cost of carbon, in the short and medium- term, through the EU Emissions Trading Scheme.”
This is a particular driver for the proposed development in that Quinn Cement will be able to maintain competitiveness through carbon cost savings of moving from fossil fuels to alternative fuels.
The policy document further outlines that in order to reduce greenhouse gas emissions by 80-95% as set out, an energy transition is required which will see a move to lower emission fuels and then an ultimate move away from fossil fuels altogether. In is in this context that Quinn Cement are proposing this development, which seeks to improve the sustainability of the Ballyconnell plant, through the use of an increased range of waste derived alternative raw materials and fuels with the long term aim of displacing almost all fossil fuels at the plant.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 27
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
3.3 Regional Policy The Quinn cement plant, located in Ballyconnell Co. Cavan, falls within the former Border Regional Authority, which was one of eight Regional Authorities established under the Local Government Act 1991. Prior to its dissolution as part of Local Government reform, the Border Regional Authority produced Regional Planning Guidelines which remain in force until they are replaced by new Regional Spatial & Economic Strategies.
3.3.1 Border Regional Authority Planning Guidelines 2010 – 2022 The Border Regional Authority Planning Guidelines 2010-2022 include the geographical area of Counties Cavan, Donegal, Leitrim, Louth, Monaghan and Sligo. Specific policies relevant to the proposed development include: ENVP3 Reduce demands on non – renewable resources and promote the use of sustainable resources; INFP24 Promote and support an optimal mix of renewable energy generation within the Region; INFP25 The Border Regional Authority will prepare an Energy Strategy during the life of these Guidelines. Local Authorities shall comply with the For inspection purposes only. Consent of copyright owner required for any other use. proposed integrated regional energy strategy on energy conservation and renewable energy generation; INFP26 Local Authorities should support and promote a move away from fossil-fuel energy production through investment in renewable energy and the creation of more ‘green collar jobs’. INFP28 Facilitate the provision of waste management facilities identified as necessary in Regional Waste Management Plans through the planning system, subject to the requirements of the Habitats Directive; INFP29 Local Authorities within the Region should explore and develop waste management practices on an inter-regional and on a cross border basis;
Enervise Limited 28
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
INFP30 Energy Recovery and Thermal treatment of waste must be incorporated into relevant Waste Management Plans, subject to necessary environmental assessments.
3.3.2 Regional Waste Management Plan For the purposes of waste management, Ireland is divided into three planning areas: Southern Region Eastern-Midlands Region Connacht-Ulster Region The Quinn cement plant, located in Ballyconnell Co. Cavan, falls within the Connacht-Ulster Region
3.3.2.1 Connacht Ulster Waste Region Established in 2013 the Connacht Ulster Waste Region is one of three waste regions in Ireland and incorporates nine local authority areas: Cavan, Donegal, Galway City, Galway County, Leitrim, Mayo, Monaghan, Roscommon and Sligo. In addition to mandatory national targets, the following three specific targets have been set for the plan which the local authorities aim to meet: For inspection purposes only. Consent of copyright owner required for any other use. 1% reduction per annum in the quantity of household waste generated per capita over the period of the plan; Achieve a recycling rate of 50% of managed municipal waste by 2020; Reduce to 0% the direct disposal of unprocessed residual Municipal waste to landfill (from 2016 onwards) in favour of higher value pre-treatment processes and indigenous recovery practices.
Some of the relevant measures contained in the plan to meet the aforementioned performance targets are outlined below: Plan and develop higher quality waste treatment infrastructure including new reprocessing, biological treatment, thermal recovery and pre-treatment facilities;
Enervise Limited 29
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
Support the development of thermal recovery in the region which meets the needs of the region and the State in reducing the export of residual wastes for treatment abroad; Ensure existing and future waste facilities do not impact on environmentally sensitive sites through proper assessments and siting; Grow the waste management sector into a prosperous and sustainable industry which creates and maintains healthy employment.
The waste plan supports the development of additional thermal recovery capacity as set out by below policies:
“E15a. The waste plan supports the development of up to 300,000 tonnes of additional thermal recovery capacity for the treatment of non-hazardous wastes nationally….” Quinn Cement is currently authorised to accept 127,875 tonnes of Solid Recovered Fuel (SRF) at the Ballyconnell facility. The proposed project seeks to further improve the sustainability of the cement plant, through the use of an increased range of waste derived alternative raw materials and fuels with the long term aim of displacing For inspection purposes only. Consent of copyright owner required for any other use. almost all fossil fuels at the plant. The use of these alternatives will equate to 300,000 tonnes per annum at maximum substitution, with 127,875 tonnes of this 300,000 tonnes already permitted. The proposed development is therefore below the 300,000 tonnes threshold of additional thermal recovery capacity as set out in Policy E15a.
The proposed development is also in keeping with Policy E15b which supports the need for thermal recovery capacity for industrial process wastes and Policy E16 which supports the development of up to 50,000 tonnes of additional thermal recovery capacity for the treatment of hazardous wastes nationally.
It is therefore concluded that the proposed development is in keeping with the requirements of the Connacht Ulster Region Waste Management Plan and can play a
Enervise Limited 30
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016 significant role in meeting the needs of the region and the State through sustainable waste management.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 31
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
3.4 Local Policy The following section sets out the elements of the proposed development with reference to the relevant sections/policies of the County Development plan.
3.4.1 Cavan County Development Plan 2014 – 2020 3.4.1.1 Waste Management Section 4.6 of the Cavan County Development Plan 2014-2020 makes reference to the fact that Cavan is among a new cohort of nine counties in the Connaught / Ulster Region and a new regional waste management plan is being prepared for 2014. This plan has been discussed at Section 3.3.2 above.
The objectives which are considered relevant to the proposed development are set out below along with a commentary as to how the proposed development relates:
PIO96 To have regard to the following in the assessment of planning applications for waste management facilities: o North East Waste Management Plan 2005 -2010 (or any subsequent Regional Waste Plan that relates to County Cavan). For inspection purposes only. o Consent of copyright owner required for any other use. Waste Management Act 1996 (as amended). o EU Landfill Directive. o EPA Landfill Manuals. o EU Packaging and Packaging Waste Directive. o DOEHLG policy statements including ‘Changing Our Ways’ and ‘Preventing and Recycling Waste-Delivering Change’.
This EIS has considered National Waste Policy and the Connacht Ulster Region Waste Management Plan in the context of the proposed development. Furthermore, the proposed development is subject to a review of the Industrial Emissions Licence for the facility, which will run concurrently with the planning application, and will
Enervise Limited 32
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016 take regard of the Waste Management Act 1996 (as amended) and other relevant legislation.
PIO99 To encourage waste prevention, minimisation, reuse, recycling and recovery as methods of managing waste. The proposed development seeks to co-process alternative fuels in the existing cement plant. Co-processing overlaps both the energy recovery and material recycling tiers of the EU waste hierarchy. As can be seen from Figure 1 below energy is recovered and the fuel ashes are fully consumed and become part of the cement product.
For inspection purposes only. Consent of copyright owner required for any other use.
Figure 2: Benefits of Co processing in the Cement Industry (Source www.cement.ie )
3.4.1.2 Energy Section 4.7 of the Cavan County Development Plan 2014-2020 sets out the following specific objectives in relation to energy.
PIO103 Encourage and support efforts to reduce energy consumption across all sectors in support of the implementation of the ‘National Energy Efficiency Action Plan’ 2007 -2020.
Enervise Limited 33
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
PIO104 Promote renewable energy policies in the county and ensure that Council staff are given the necessary training to implement this policy. PIO105 Promote energy conservation through a reduction in consumption and by incorporating renewable energy technology into building design standards.
Section 3.2.5.2 of this EIS deals specifically with the National Energy Efficiency Action Plan 2007-2020 which is the basis of policies PIO103 and PIO105 with respect to energy consumption and energy conservation respectively. This section outlines that the proposed development seeks to improve the energy efficiency of the Ballyconnell cement plant by reducing energy imports and using otherwise wasted resources as alternative raw materials and alternative fuels.
In relation to the promotion of renewable energy policies and the incorporation of renewable energy technology as set out in policies PIO104 and PIO105 respectively, Section 3.2.5.1 sets out that the proposed development will contribute towards the 12% target of final heat demand from renewable energy sources (RES-H) by 2020.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 34
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
4.0 Project Summary and Objectives 4.1 Introduction This Environmental Impact Assessment considers the environmental effects from the proposed alteration to activities at Quinn Cement that would allow alteration of the fuel source from the current position (where a combination of coal and Solid Recovered Fuel (SRF) are used for the thermal requirements) to an ultimate aimed position where almost all fossil fuels will be displaced at the plant with alternative fuels and a proportion of the virgin raw materials will be replaced with alternative raw materials. The use of these alternatives will equate to 300,000 tonnes per annum at maximum substitution.
4.2 Proposed Alternative Fuels and Raw Materials A range of suitable materials are proposed for acceptance at the plant which can be summarised as follows: Solid Fuels – including Solid Recovered Fuel (SRF) which is currently authorised for use at the plant, as well as a range of suitable fuels derived from other sources including: o Meat and Bone Meal (MBM); For inspection purposes only. Consent of copyright owner required for any other use. o Tyre Derived Fuel (TDF); o Biomass Fuels; o Sludges and Filter Cakes. Liquid Fuels – including Secondary Liquid Fuel (SLF) which is a blend of organic and solvent wastes blended to a defined specification as well as liquid fuels derived from other sources (e.g. waste oils). Alternative Raw Materials (e.g. muds, minerals, sludges).
It is also proposed to include natural gas and petcoke as additional fuels in the Industrial Emission Licence, regulated by the EPA. This is to provide flexibility for any future fossil fuel requirement.
Enervise Limited 35
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
4.3 Proposed Plant Changes The proposed development, to which this Planning Application relates i.e the land use development, is for the physical engineering alteration to the plant in order to accept the introduction of alternative fuels and alternative raw materials as direct replacement for coal and virgin raw materials respectively.
The plant alterations have been engineered by FLSmidth who are internationally renowned for their supply of, and engineering solutions for, Cement Manufacturing Plants.
High standard measurement techniques have been employed and FLSmidth have carried out extensive investigation to predict the impact that the proposed alternative fuels will have on the process and to ensure compliance with the appropriate emission limit values.
Compliance with the emission limit values as laid down by Directive 2000/76/EC of 4th December 2000 on the incineration of waste and the requirements of Decision 2013/163/EU establishing the best available techniques (BAT) conclusions under For inspection purposes only. Consent of copyright owner required for any other use. Directive 2010/75/EU on industrial emissions for the production of cement, lime and magnesium oxide were regarded during the design of the equipment. The particular elements with respect to potential emissions will be investigated in detail in Section 7 and the full Emissions report is contained within Section 18 and forms Appendix 2.
In order that the existing plant can accept the proposed alternative fuels, it is necessary to upgrade elements of the existing plant, whilst providing some limited additional storage capacity for the alternative fuels.
The main visible alterations and additions to the plant are provided in Table 1 which is reproduced again below for ease of reference. This Table also indicates where the
Enervise Limited 36
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016 equipment was previously authorised under planning reference (09/456) which has now lapsed. This equipment, which previously received planning permission in 2009, was not constructed in 2014 when the Quinn Cement plant was under different management. Planning permission has now lapsed for this equipment but the current management view it as essential in order to maximise coal displacement with alternative fuels. For this reason, the current application is seeking planning permission for this equipment once again, albeit in some instances with minor modifications to the proposals put forward in 2009.
Equipment Requirement Previously authorised under Planning Ref: 09/456 Bunded Liquid Fuel tanks SLF and other liquid No and associated feeding fuels Storage system Meat & Bonemeal silos and MBM Storage No associated feeding system Lime silos and associated Reduce SOx emissions No feeding system Extension to existing SRF and other Solid Yes, albeit slightly modified in For inspection purposes only. Consent of copyright owner required for any other use. Storage bays and associated Alternative fuels this planning application feeding system (footprint reduced). Induced Draught (ID) Fan Process Yes, no change. Calciner Process Yes, albeit slightly modified in this planning application (elevation reduced).
These alterations to the plant and how the fuels will be used in the process will be discussed hereafter.
Enervise Limited 37
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
4.3.1 Meat and Bone Meal Silos
4.3.1.1 Transport & Discharge: Meat and Bone Meal (MBM) is a dried sterilised material produced in rendering facilities from animal tissue not used in food production. Only MBM from Department of Agriculture approved rendering facilities will be accepted at the cement plant. The MBM will have a low moisture content (<10%) and will be of a uniform size. Transport to the cement plant will be via enclosed road tankers. Discharge from the road tanker to the 2 No. storage silos will be by a pneumatic sealed system incorporating filtration to control the potential for dust and odour emissions during the discharge process.
4.3.1.2 Storage & Feeding: The material in the storage silos will be fed via an enclosed transport system to the kiln system for combustion.
4.3.2 Liquid Fuel Tanks
For inspection purposes only. 4.3.2.1 Transport & Discharge: Consent of copyright owner required for any other use.
Liquid Fuels will include Secondary Liquid Fuel (SLF) which is a blend of organic and solvent wastes blended to a defined specification as well as liquid fuels derived from other sources (e.g. waste oils). The main source of SLF is solvents from the pharmaceutical industry. Other industry sources also produce a variety of high calorific ingredients which are suitable for blending. Specialist waste management companies collect and blend these ingredients to the fuel specification for the kiln system. The SLF will then be delivered by these specialist waste management companies to the cement plant via enclosed road tankers.
Enervise Limited 38
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
In order to prevent spillages during discharge, the liquid fuels will be discharged via a closed system to on site storage tanks. Furthermore, the storage tanks will be located within a bunded compound.
4.3.2.2. Storage & Feeding: A blanketing gas suppression system will be installed as a fire prevention method. The tanks will be built and installed to the manufacturers specification. Bunding will be in compliance with EPA requirements and bunds will be regularly inspected. The bunded compound will be integrity tested as per other bunds on site. The liquid fuels will be pumped from the storage silos to the kiln system via a closed loop system thereby ensuring minimal risk of spillage. For the unlikely event of a fuel spillage a response plan has been proposed as part of the Emergency Response Procedure for the site. All areas between the bunded storage compound and the kiln system will be of an impermeable hardstand construction. The bunded compound will be covered in order to limit the potential for For inspection purposes only. Consent of copyright owner required for any other use. rainwater ingression into the bund. This will ensure that contaminated water generation is limited insofar as practicable. Any contaminated water will be disposed of as hazardous waste. The storage tanks will be fitted with a high level alarm to prevent overfilling. Spill kits will be available on site and all leaks or spills will be cleaned up immediately.
Enervise Limited 39
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
4.3.3 Fuel Storage Bay Extension (3 bunkers)
4.3.3.1 Transport & Discharge: Solid Fuels such as Solid Recovered Fuel (SRF), woodchip and Tyre Derived Fuel (TDF) will be produced to an agreed specification by authorised suppliers. Transport to the cement plant will be via tipper trucks or walking floor trailers which will deliver to the fuel storage bunkers, via a feeder and drag chain system.
4.3.3.2 Storage & Feeding: The proposed storage system is the same as the current system with an additional three bunkers. The storage bunkers will be equipped with mechanical and pneumatic feeding system to allow for flexibility in the delivery of the alternative fuels to the kiln system for combustion.
4.3.4 Lime Silos
Quinn Cement is currently adding For hydrated inspection purposes lime only. manually to the kiln feed to reduce Consent of copyright owner required for any other use.
SO2 and HCl emissions. Two storage silos and an automatic feeding system are proposed as part of this planning application which will optimise the hydrated lime addition.
4.3.5 Induced Draught (ID) Fan The existing ID fan is at full capacity. To avoid a significant decrease in production capacity as a result of increasing the use of alternative fuel, a new and larger ID Fan has been designed into the production process. The location, within the existing compound and adjacent to the main pre-heater tower, is as previously proposed under Planning Reference 09/456.
Enervise Limited 40
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
4.3.6 Calciner Upgrade The existing calciner at Quinn Cement is an old ILC flat roof calciner. This calciner is designed for a short retention time and is used for traditional fuels such as coal. For firing of SRF and other alternative fuels, FLSmidth recommends a retention time in the calciner of at least 5 seconds. The higher gas retention time is required to ensure time for sufficient drying of the high moisture content in alternative fuels like SRF, and for a complete burnout of larger fuel particles.
In 2009 planning permission was received under Planning Reference 09/456 for a "new calciner" placed outside the existing pre heater tower. Rather than build this new calciner now, it is proposed to extend the existing calciner to increase the volume and retention time. This upgrade will not interfere with the bottom part of the existing calciner or the kiln riser. The extension will begin at the roof of the old calciner and run out of the preheater tower where it will make a u-bend and go down into the bottom stage cyclone. This proposed upgrade has a smaller volume than the "new calciner" permitted in 2009 and as a result this smaller structure will have a lesser impact than that previously permitted in terms of visual impact.
For inspection purposes only. Consent of copyright owner required for any other use. 4.4 Summary and Objectives Section 2 of this Environmental Impact Statement considered the reasonable alternatives examined by the developer in terms of project design. That process identified the most appropriate approach for the development as a result of a preliminary assessment of the relevant environmental aspects.
Section 3 of this EIS then considered the proposed development in the context of International, National, Regional and Local policy. Section 4, this section of the EIS, presented the project design which will now be considered in further detail in the following sections which deal specifically with each aspect of the environment likely to be significantly affected by the proposed development
Enervise Limited 41
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 42
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
5.0 Geology This chapter of the EIS deals with the geological setting of the site in terms of solid geology and drift geology as set out by BCL Hydrogeologists Ltd in their Hydrogeological and Hydrological Assessment which can be found at Appendix 1 (Section 17).
5.1 Site Context 5.1.1 Solid Geology The Planning Application Area is sited upon the Dartry Limestone Formation, which is of Carboniferous (Visean) age. The Dartry Limestone is a dark grey, fine-grained cherty limestone with associated mudstone. The regional thickness of the Dartry Limestone is reported as 220m, while its outcrop in the vicinity of the site is some 3-4 km wide.
Boreholes that have been drilled at or towards the foot of Slieve Rushen (in the vicinity of the Application Area) encountered an extremely weathered upper section of Dartry Limestone directly beneath drift deposits. This weathered section of the Dartry Formation, ranging in thickness between 9 m and 18 m within the boreholes, For inspection purposes only. Consent of copyright owner required for any other use. is present as an almost entirely disaggregated calcareous sand and gravel with no apparent consolidated structure or cohesive strength.
The Meenymore Formation overlies the Dartry Limestone and comprises sandstone, siltstone, mudstone and evaporitic and marine limestones. The boundary between the Dartry Limestone and Meenymore Formations is unconformable; its surface expression passing approximately 650 m to the northwest of the Planning Application Area, at closest approach.
The Dartry Limestone and Meenymore Formations are underlain by the Benbulben Shale Formation, which consists of dark grey fossiliferous mudstone and thin
Enervise Limited 43
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016 bioclastic limestones. In turn, this is underlain by the Bundoran Shale Formation, which is a grey mudstone and bedded fossiliferous limestone. A fault some 2 km to the southeast of the Planning Application Area brings the outcrop of the Bundoran Shale Formation against the Dartry Limestone, without the Benbulben Shale Formation in between.
The formations form approximately parallel layers, which dip slightly to the west (with dip measurements of 5-15°) in the vicinity of the site. Each outcrops in an approximately north-south orientation in the vicinity of the site, on the eastern side of the Slieve Rushen Mountain.
5.1.2 Drift Geology The published mapping data shows the Quaternary drift cover, overlying the solid geology, is of variable composition and extent. The Planning Application Area (and the valley to the east) is underlain by glaciofluvial ice-contact drift.
Boreholes drilled to the east of the Application Area encountered a thick interbedded series of sands, sands and gravels, alluvium and clays, extending to a For inspection purposes only. Consent of copyright owner required for any other use. depth of some 15 m below the thin soil cover.
These deposits occur across an irregularly shaped area, generally some 1 km wide and aligned roughly north-south along the break of the slope at the eastern edge of the Planning Application Area.
To the west of the cement works, the land is indicated to have a till cover, although there are patches where the till is shown to be absent above the Meenymore Formation.
Along most of the line of the Woodford River, the mapped drift deposit is lacustrine alluvium.
Enervise Limited 44
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
5.2 Previous Geology Assessments The 2009 EIS concluded that the then proposed development would have no impact on either drift or solid geology based on the following: The proposed development provided exclusively for engineering alterations to the existing plant and the associated additional vehicle movements and resultant emissions. The proposed engineering alterations were all to be contained within the existing permitted footprint of the Cement Works, with the vast majority of the infrastructure being situated at ground level in the centre of the existing plant. In order for the structures to be accommodated a requirement was indicated for additional civil engineering work to maintain their structural integrity. There was no significant movement of overburden envisaged, with only a limited element of cut and fill in the vicinity of the proposed unloading stations. Therefore, as a result of work previously undertaken when establishing the site curtilage, there would be no impact on either drift or solid geology.
For inspection purposes only. Consent of copyright owner required for any other use. 5.3 Proposed Development Context It is now proposed to improve the sustainability of the cement plant, through the use of an increased range of waste derived alternative raw materials and fuels with the long term aim of displacing almost all fossil fuels at the plant (a limited proportion of fossil fuels will be required during process start up and for process optimisation/stabilisation). The use of these alternatives will equate to 300,000 tonnes per annum at maximum substitution.
A range of suitable materials are proposed for acceptance at the plant which can be summarised as follows:
Enervise Limited 45
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
Solid Fuels – including Solid Recovered Fuel (SRF) which is currently authorised for use at the plant, as well as a range of suitable fuels derived from other sources including: o Meat and Bone Meal (MBM); o Tyre Derived Fuel (TDF); o Biomass Fuels; o Sludges and Filter Cakes. Liquid Fuels – including Secondary Liquid Fuel (SLF) which is a blend of organic and solvent wastes blended to a defined specification as well as liquid fuels derived from other sources (e.g. waste oils). Alternative Raw Materials (e.g. muds, minerals, sludges).
It is also proposed to include natural gas and petcoke as additional fuels in the Industrial Emission Licence, regulated by the EPA. This is to provide flexibility for any future fossil fuel requirement.
In order to facilitate the use of the aforementioned alternative fuels certain changes are required to the plant as set out at Table 1 which is reproduced again below for For inspection purposes only. Consent of copyright owner required for any other use. ease of reference. This also indicates where the equipment was previously authorised under planning reference 09456 which has now lapsed.
Enervise Limited 46
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
Equipment Requirement Previously authorised under Planning Ref: 09/456 Bunded Liquid Fuel tanks SLF and other liquid No and associated feeding fuels Storage system Meat & Bonemeal silos and MBM Storage No associated feeding system Lime silos and associated Reduce SOx emissions No feeding system Extension to existing SRF and other Solid Yes, albeit slightly modified in Storage bays and associated Alternative fuels this planning application feeding system (footprint reduced). Induced Draught (ID) Fan Process Yes, no change. Calciner Process Yes, albeit slightly modified in this planning application (elevation reduced).
Based on above it can be seen that the extension to the fuel storage bays, new ID Fan and Calciner were previously assessed in the 2009 EIS and were subsequently
For inspection purposes only. authorised under planning referenceConsent of copyright 09456. owner required These for any structures other use. are again proposed in the same locations, albeit being slightly modified in design.
The following additional equipment is also proposed: Bunded Liquid Fuel tanks and associated feeding system; Meat & Bonemeal silos and associated feeding system; Lime silo and associated feeding system.
All of the proposed engineering alterations are to be contained within the existing permitted footprint of the Cement Works, with all the infrastructure being situated at ground level (bar the calciner upgrade), in the confines of the existing plant. There will be a requirement for minor civil engineering works to maintain the structural
Enervise Limited 47
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016 integrity of the proposed infrastructure. However, no significant movement of overburden is envisaged.
5.4 Conclusion All of the proposed engineering alterations are to be contained within the existing permitted footprint of the Cement Works, with all the infrastructure being situated at ground level (bar the calciner upgrades), in the confines of the existing plant.
There will be a requirement for minor civil engineering works to maintain the structural integrity of the proposed infrastructure. However, no significant movement of overburden is envisaged.
Therefore, as a result of work previously undertaken when establishing the current site curtilage the proposed development will not impact on either drift or solid geology.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 48
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
6.0 Water Environment An assessment was undertaken by BCL Hydrogeologists Ltd to establish the possible effects from the proposed development upon the water environment. The full assessment can be found as Appendix 1 of this Environmental Impact Statement, held in Section 17.
6.1 Site Context The Site is located upon the southeast facing aspect of Slieve Rushen Mountain. Ground elevations within the boundaries of the Site fall from some 110 maOD upon the north-western boundary to some 60 maOD at the southern and eastern boundaries.
The cement plant is located upon a strip of land (approximately 250 m in width), which extends across the central part of Site, at an elevation of 80-90 maOD. The Woodford River (Shannon-Erne Waterway) is some 400 m to the southeast of the Site, at its closest approach. Locally, the Woodford River drains from southwest to northeast. Ground elevation upon the closest stretch of floodplain equates to circa 50 maOD, which is 10 m below the lowest point on the Site boundary. For inspection purposes only. Consent of copyright owner required for any other use.
6.1.1 Surface Water All surface water runoff arising within the cement works during rainfall events is piped across to the Woodford River. Before being discharged into the pipe, the runoff is directed through settlement tanks to ensure that the suspended solids content of the water is reduced to an acceptable limit. The settlement tanks include flow balancing capacity (to control the rate of discharge during storm events) and oil interceptor facilities.
With regard to monitoring the risk posed by current operations at the cement works, the key Water Quality Indicators are listed in Section B.2 “Emissions to Water” of the
Enervise Limited 49
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
IE Licence (Reg. No. P0378-02). Where tested, these were in compliance with the limits specified in the licence.
Annagh Lough lies some 1.7 km to the southeast of the Site. The cement works and lough are situated on opposite sides of the Woodford River. There are no other waterbodies within 1 km standoff from the development.
6.1.2 Hydrogeological Setting With respect to the hydrogeological setting of the cement works, the Dartry Limestone Formation is classified by the GSI as a regionally important, fissured bedrock aquifer. The groundwater flow direction is towards the southeast, declining from 130 maOD at the contact between the Dartry Limestone and the overlying Meenymore Shales (650 m to the northwest of the Site), down to 50 maOD in the vicinity of the Ballyconnell-Derrylin Road. Based upon the available piezometer data, the typical long-term range between minimum and maximum groundwater levels is between 2 m and 6.5 m. Values of hydraulic conductivity obtained for the competent section of the Dartry Limestone were extremely low, circa 0.03 m/d. For the disaggregated limestone (mantling the solid strata of the valley floor), the For inspection purposes only. Consent of copyright owner required for any other use. calculated value of hydraulic conductivity equated to 3.4 m/d. The watercourses upon the flanks of Slieve Rushen exist a significant distance above the watertable. Thus, these streams cannot accrete flow from groundwater. Upon the valley floor, there is diffuse seepage from the drift deposits into the Woodford River.
In terms of abstraction from the Dartry Limestone, aside from the Applicant’s boreholes, the closest private groundwater supply boreholes are located at the Kearns property at Gortoorlan (325 m SW of the Site) and the neighbouring Maguire property (500 m SW of the Site). There is a borehole located adjacent to the Ballyconnell to Gortoorlan Road, which is now disused, having historically been operated by Cavan County Council for groundwater abstraction. It is approximately 500 m standoff to the south of the cement works.
Enervise Limited 50
EPA Export 25-05-2016:01:00:35
Environmental Impact Statement May 2016
6.2 Development Context It is proposed to improve the sustainability of the cement plant through the use of an increased range of waste-derived alternative raw materials and fuels with the long- term aim of displacing almost all fossil fuels at the plant (a limited proportion of fossil fuels will be required during process start-up and for process optimisation/stabilisation). The use of these alternatives will equate to 300,000 tonnes per annum at maximum substitution.
6.2.1 Fuel transfer and storage
Meat and Bone Meal (MBM) is a dried sterilised material produced in rendering facilities from animal tissue not used in food production. Only MBM from Department of Agriculture approved rendering facilities will be accepted at the cement plant. The MBM will have a low moisture content (<10%) and will be of a uniform size. Transport to the cement plant will be via enclosed road tankers. Discharge from the road tanker to the storage silos will be by a pneumatic sealed system incorporating filtration to control the potential for dust and odour emissions during the discharge process. The
material in the storage silo Forwill inspection be fed purposes via only. an enclosed transport system to the Consent of copyright owner required for any other use.
kiln system for combustion. Tyre Derived Fuel (TDF) will be produced to an agreed specification by authorised suppliers. Transport to the cement plant will be via tipper trucks or walking floor trailers, which will deliver to the fuel storage bunkers. The TDF will be fed mechanically to the kiln system for combustion. Liquid Fuels will include Secondary Liquid Fuel (SLF), which is a blend of organic and solvent wastes mixed to a defined specification, as well as liquid fuels derived from other sources (e.g. waste oils). The main source of SLF is solvents from the pharmaceutical industry. Other industry sources also produce a variety of high calorific ingredients which are suitable for blending. Specialist waste management companies collect and blend these ingredients
Enervise Limited 51
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
to the fuel specification for the kiln system. The SLF will then be delivered by these specialist waste management companies to the cement plant via enclosed road tankers. In order to prevent spillages during discharge, the liquid fuels will be discharged via a closed system to on-site storage tanks. Furthermore, the storage tanks will be located within a bunded compound. A blanketing gas suppression system will be installed as a fire prevention method. The tanks will be built and installed to the manufacturer’s specification. Bunding will be in compliance with EPA requirements and bunds will be regularly inspected. The bunded compound will be integrity- tested as per other bunds at the plant. The liquid fuels will be pumped from the storage silos to the kiln system via a closed loop system, so that there is minimal risk of spillage. In the unlikely event of a fuel spillage, a response plan has been proposed as part of the Emergency Response Procedure for the Site. All areas between the bunded storage compound and the kiln system will be of an impermeable hardstand construction. The bunded compound will be covered in order to limit the potential for rainwater ingression into the bund. This will ensure that contaminated water generation is limited insofar as practicable. Any contaminated water will be disposed of as hazardous For inspection purposes only. Consent of copyright owner required for any other use. waste. The storage tanks will be fitted with a high level alarm to prevent overfilling. Spill kits will be available at the plant and all leaks or spills will be cleaned up immediately.
6.2.2 Surface Water Reuse/Fire Water Retention The Applicant is proposing to use the water from the settlement tank for the cement manufacturing process, which would reduce the discharge rate to the Woodford River. The water from the settlement tanks will be recycled back into the cement manufacturing process through a proposed Surface Water Recycling Tank (SWRT), thereby reducing the process water requirements from on-site boreholes. Furthermore, it is proposed to install a separate Fire Water Retention Tank (FWRT) with a capacity of 100 m3. In the event of a fire, the water discharge from the site can
Enervise Limited 52
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 be directed to this tank by opening a valve, which directs the water away from the existing settlement tanks, through a bypass line, to the proposed FWRT. This proposal will significantly reduce the potential volume of firewater to be disposed of in the event of a fire or spillage accident on site.
6.3 Methodology The results of baseline groundwater quality sampling are detailed in the following reports: “New Cement Works, Scotchtown, Ballyconnell: Hydrogeological and Hydrological Assessment” (November 2005), prepared by BCL. “Ballyconnell Cement Works - Proposal to use Solid Recovered Fuel for the Cement Plant: Hydrogeological and Hydrological Assessment” (April 2009). “Hydrogeological Assessment Report” (ref: 50453) prepared by Verdé Environmental Consultants Ltd in January 2015. IE Licence No. P0378-02: Annual Environmental Report, 2014 (submitted on 31st March 2015).
Further to above, groundwater samples were collected from the monitoring network For inspection purposes only. Consent of copyright owner required for any other use. on 20th February 2016. The sampling locations include GW-1, BH-02, BH-03, BH-04, BH-05 and P05-6. GW-1 is the main abstraction well for process water; BH-02, BH- 03, BH-04 and BH-05 are peripheral wells, drilled in agreement with the Agency as part of the study informing the “Hydrogeological Assessment Report” completed by Verdé under P0378-02 licence conditions; and P05-06 is an upstream location (replacing BH-01, which has collapsed).
They were submitted for laboratory analysis to provide a record of background concentrations for key parameters relating to the Development Proposal. In addition to the Water Quality Indicators given in Section B.2 “Emissions to Water” of the IE Licence (Reg. No. P0378-02), the analysis schedule was expanded to include Volatile Organic Compounds (VOC), Semi Volatile Organic Compounds (SVOC), Extractable
Enervise Limited 53
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
Petroleum Hydrocarbons (EPH), Gasoline Range Organics (GRO), Alcohols, Acetates and Acetonitrile.
6.4 Results The laboratory data have been compared with the relevant standards put forward in the EPA Document “Parameters of Water Quality: Interpretation and Standards” (2001); also the Interim Guideline Values (IGV) as detailed in the EPA’s “Interim report towards setting guideline values for the protection of groundwater in Ireland” (2003); Groundwater Regulation Threshold Values under S.I. 9 of 2010; and Drinking Water Regulation under S.I. 122 of 2014.
The pH results ranged 5.88 to 7.63. The pH parameter measured in BH-04 (5.88) was slightly below the lower threshold value indicated by the IGV and Drinking Water Standards (DWS). The remaining five pH values remained within the normal range for groundwater.
An elevated concentration of dissolved manganese (4,017 μg/l) was reported in the groundwater sample BH-02, exceeding both IGV and drinking water standards. BH- For inspection purposes only. Consent of copyright owner required for any other use. 03 and BH-05 presented some low concentrations of dissolved manganese (9 μg/l and 34 μg/l respectively), which did not exceed the relevant standards. In the remaining two groundwater samples, this parameter was below the laboratory detection limit. Manganese is naturally occurring in the limestone bedrock.
Dissolved potassium was detected in BH-02 at 18.1 mg/l and BH-05 at 37.9 mg/l. The remaining four groundwater samples presented concentrations of dissolved potassium that were below the recommended limit.
The dissolved nickel reading at BH-05 is 23 μg/l, marginally exceeding the IGV and DWS of 20 μg/l. All other nickel data collected during this round of sampling (20th
Enervise Limited 54
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
February 2016) and the previous round (August 2014) are in compliance with the standards.
Parameters relating to the Development Proposal include VOC, SVOC, EPH, GRO, Alcohols, Acetates and Acetonitrile. The baseline data for these parameters are below the limit of detection.
The results for Chemical Oxygen Demand (COD) ranged from 8 mg/l to 67 mg/l. There is no Emission Limit Value (ELV) for COD on the IE Licence; and there is no Groundwater Regulation Threshold Value under S.I. 9 of 2010.
In the context of the Water Framework Directive, EPA mapping indicates that the Dartry Limestone Aquifer at Newtown-Ballyconnell is “At risk of not achieving good status”.
6.4 Impact Assessment There are two abstraction boreholes (GW-1 and GW-2), which supply the raw water requirement (cooling water, process water and dust suppression) for the cement For inspection purposes only. Consent of copyright owner required for any other use. manufacturing process; and a separate abstraction well for the lorry wash. The boreholes are installed within the Dartry Limestone Formation. There will be no change in the demand for water; the pre-existing abstraction rate will be reduced in the context of the surface water re-use proposal; therefore, the current status of neighbouring supplies should be protected. The current schedule of monitoring of groundwater level within these boreholes will be continued to confirm this assessment.
The risk of spillages will be minimised by enforcing working procedures that conform to the Fluids Handing Protocol as outlined in the main report. Trained personnel will undertake all re-fuelling and maintenance, following relevant environmental standards. In the unlikely event of a hydrocarbon spillage, a
Enervise Limited 55
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 contingency plan will be followed for containing and safely disposing of any contaminant. All surface water runoff arising within the cement works during rainfall events is directed to settlement tanks. This is to ensure that the suspended solids content of the water is reduced to an acceptable limit prior to being discharged into the receiving watercourse (Woodford River). The settlement tanks include flow balancing capacity (to control the rate of discharge during storm events) and oil interceptor facilities.
The proposed development does not involve any change in the surface water runoff pattern at the cement works i.e. no change in the overall size of the rainfall catchment area; no change in the gradient of the area; and no change in the percentage of impermeable area. The pre-existing drainage infrastructure will receive no input of additional/new contaminants within the surface water run-off. Therefore, there will be no reduction in the quality of runoff being discharged off Site.
With regard to incoming waste handling, transfer and storage areas: The exclusion of rainwater (by erecting roofed and walled enclosures for the receiving hoppers) is For inspection purposes only. Consent of copyright owner required for any other use. judged to be an effective means of avoiding problems such as the generation and emission of leachate. In the event of firefighting (or accidental mixing of waste with rainwater), containment/controlled drainage is required to prevent the unregulated discharge of polluted firefighting water/chemicals (or other wastewater) from the receiving/storage areas. Any contaminated water must be disposed from Site in accordance with the prevailing legislation.
To confirm the efficacy of these measures, it is recommended that the monitoring schedule be revised to include testing of additional parameters at key locations, namely: the Discharge Point (SW-1); Woodford River (upstream and downstream locations); and the peripheral wells Q05-06 and BH-02 to BH-05. This was the agreed
Enervise Limited 56
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 coverage for the Verdé “Hydrogeological Assessment Report” and the additional monitoring on 20th February 2016.
The additional chemical species should be appropriate to types of fuel being brought on to the Site. As outlined earlier, the laboratory schedule (appendix 2 of main report) has been expanded to include Volatile Organic Compounds (VOC), Semi Volatile Organic Compounds (SVOC), Extractable Petroleum Hydrocarbons (EPH), Gasoline Range Organics (GRO), Alcohols, Acetates and Acetonitrile.
The implementation of the treatment systems, engineering measures, fluids handling protocol and monitoring schedule advanced to protect groundwater quality will, in turn, serve to safeguard the surface water environment and water supplies. This will protect water quality in downstream receptors (Woodford River) and designated sites, such as Moninea Bog ASSI - SAC (alongside Drumderg Lough).
In terms of flood risk, there is no risk of fluvial flooding at the Site (allowing for climate change). Ground elevation upon the closest stretch of floodplain equates to circa 50 maOD, which is 10 m below the lowest point on the Site boundary. The For inspection purposes only. Consent of copyright owner required for any other use. Proposal Site constitutes a sub-catchment that is largely isolated from runoff from adjacent lands due to the existing surface water drainage network. There will be no change in the surface water run-off pattern on the land uphill/upstream from the cement works; therefore, there will be no increased risk of floodwater coming on to Site from the hillside overlooking the cement works. The depth to groundwater (as recorded in the Site piezometers) shows that the watercourses upon the flanks of Slieve Rushen exist a significant distance above the watertable. There is considered to be no risk of flooding from groundwater at the cement works.
6.5 Conclusion On the basis of baseline study and subsequent impact assessment, there are considered to be no over-riding hydrological or hydrogeological related reasons why
Enervise Limited 57
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 the Proposed Development should not proceed in the manner described by the Application.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 58
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
7.0 Air Quality An assessment was undertaken by Redmore Environmental Ltd to establish the possible effects from the proposed development in the context of relevant Air Quality Standards (AQSs). The full assessment can be found as Appendix 2 of this Environmental Impact Statement, held in Section 18.
The proposed development has the potential to cause air quality impacts as a result of atmospheric emissions from the facility. As such, an Air Quality Assessment was required in order to determine baseline conditions and assess the contribution of the installation to ambient pollutant concentrations using dispersion modelling.
The Process Contribution (PC) from the cement plant was not predicted to be significant at any sensitive human receptor location within the assessment extents in accordance with the EPA criteria for any pollutant or averaging period of interest.
Impacts were also predicted at the relevant ecological receptors. The results indicated that effects at all sites with the exception of the one closest to the Ballyconnell cement plant (Moninea Bog SAC) were not considered to be significant. For inspection purposes only. Consent of copyright owner required for any other use.
Additional consideration was provided to potential NH3 concentrations and nitrogen and acid deposition at Moninea Bog. This included modelling of a more realistic emission profile. The outputs indicated that impacts on NH3 concentrations and nitrogen deposition were not considered to be significant.
Predicted levels of acid deposition were found to vary between the five meteorological data sets modelled. However, the predicted PC still slightly exceeded the 1% significance criteria utilised by the UK Environment Agency at this receptor. This is partly due to the very low designated Environmental Quality Standard (EQS) and the cumulative nature of acid deposition impacts. It is noted that the Ballyconnell cement plant already emits acid gases and therefore impacts at the
Enervise Limited 59
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 ecological sites will already be accounted for within the background concentrations. This introduces an element of double counting within the results. As such, actual deposition rates are likely to be lower than those predicted.
An assessment of potential cumulative impacts associated with emissions from both the Ballyconnell and Gortmullan cement plants was undertaken. This also indicated the PC was not predicted to be significant at any sensitive human receptor location within the assessment extents in accordance with the EPA criteria for any pollutant or averaging period of interest.
Similar levels to the individual assessment were predicted at the ecological receptors, with the largest PC at Moninea Bog. The majority of impacts were predicted based on a worst-case assessment scenario of the facility constantly emitting the maximum permitted concentration of each pollutant throughout an entire year. As such, the presented concentrations and deposition rates are likely to overestimate actual impacts.
As the predicted PC slightly exceeded the 1% significance criteria utilised by the UK For inspection purposes only. Consent of copyright owner required for any other use. Environment Agency for the acid deposition EQS at Moninea Bog, a Natura Impact Assessment has been carried out. The full Natura Impact Statement can be found as a separate document as part of the planning application.
Enervise Limited 60
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
8.0 Noise The Noise Impact Assessment Report has been produced by Allegro Acoustics as a technical document to support this EIS and the Industrial Emissions Licence application to the EPA. A full copy of the assessment can be found in Section 19 Appendix 3 of this document.
The purpose of the assessment is to predict the specific noise levels at façades of nearby residential receptors as a result of the proposed development.
8.1 Development Context The proposed location for the new plant is within the confines of the existing industrial cement manufacturing facility. Table 7 below provides a summary of the noise sources associated with the proposed plant changes. Sound Pressure Source Noise Source Specific Item Level at 1m Description
dB Lp Bunded Liquid Fuel tanks Small Pump at Ground Point Source at and associated feeding For inspection purposes only. 40 Consent of copyright owner required for any other use. Level a height of 1m. system Point Source at Pfister Feeder Type Pump 72 a height of 2m. Meat & Bonemeal silos and Point Source at associated feeding system Dust Filter Reverse Jet 75 a height of Complete with Silencer 26m. Point Source at Pfister Feeder Type Pump 72 a height of 2m. Lime silo and associated Point Source at feeding system Dust Filter Reverse Jet a height of 75 Complete with Silencer 22m.
Enervise Limited 61
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
No significant noise source Extension to existing Storage - low noise, slow running bays and associated feeding - - plant located inside storage system buildings Existing Fan already accounted for Existing ID Fan to be ID Fan 93 in the specific replaced noise level for the existing plant. Calciner No significant noise source - - Table 7: Summary of proposed Noise Sources
8.2 Methodology 8.2.1 Noise Monitoring Environmental noise monitoring was carried out in March 2016 by Noise and Vibration Consultants Ltd to verify if the existing Cement Plant is operating within the environmental noise limits outlined in Guidance Note for Noise: License
For inspection purposes only. Applications, Surveys and AssessmentsConsent of copyright in owner relation required for to any Scheduother use. led Activities (NG4) (EPA
2016). The specific noise level as deemed attributable to the existing Cement Plant from this noise monitoring was used to represent the noise attributable to the existing Cement Plant at each of the nearest noise sensitive locations.
8.2.2 Predictive Noise Model The 3D environmental noise model for the Cement Plant was developed using SoundPLAN Version 7.3 environmental noise modelling software. This software implements the calculation and prediction methodologies outlined in ISO 9613. Contoured elevation data for the study area was implemented to the model to develop a topographical profile of the Ballyconnell Cement Plant and surrounding area. Plan view drawings and building heights of the Cement Plant were used to
Enervise Limited 62
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 develop the various elements of the Cement Plant in the model. Sound Pressure data was used to represent the various noise sources in the model. Using all of this information, a comprehensive and detailed prediction model was developed for the site. The model includes all objects which form barriers for noise including buildings and plant. Figure 3 shows a 3D graphic from the SoundPLAN environmental noise model showing the Ballyconnell Cement Plant and nearby roads and buildings including NSL1 – NSL6.
For inspection purposes only. Consent of copyright owner required for any other use.
Figure 3: 3D graphic from the SoundPLAN environmental noise model
8.3 Results 8.3.1 Noise Survey Results Figure 4 and 5 below detail the measured noise levels taken during the 2016 annual environmental noise survey carried out by Noise and Vibration Consultants Ltd. The
LA90 noise level indicator which is typically an indicator of the constant background noise level, is deemed an appropriate representative in most cases of the noise level attributable to the existing Cement Plant.
Enervise Limited 63
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
Figure 4: Extract from 2016 Environmental Noise Survey at Quinn Cement carried out by Noise and Vibration Consultants Ltd showing measured day time noise levels at NSL1 – NSL6.
For inspection purposes only. Consent of copyright owner required for any other use.
Figure 5: Extract from 2016 Environmental Noise Survey at Quinn Cement carried out by Noise and Vibration Consultants Ltd showing measured night time noise levels at NSL1 – NSL6.
8.3.2 Predictive Noise Modelling A 3D environmental noise model of the Ballyconnell Cement Plant was used to predict noise levels attributable to the new items of plant, at the façade of the nearest
Enervise Limited 64
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 noise sensitive locations (NSL1 – NSL6). These predicted noise levels are shown in Table 8 below. SoundPLAN Noise Model - Predicted noise levels at nearest noise sensitive locations
Receiver LAeq dB(A) NSL1 1 NSL2 12.4 NSL3 23.3 NSL4 25.8 NSL5 (On Site) 11.3 NSL6 13.8 Table 8: Predicted noise levels at NSL1 – NSL6 attributable to proposed additions to the existing Cement Plant.
8.3.3 Cumulative Noise Levels Table 9 below shows the cumulative levels of both the measured noise level of the existing plant and the predicted noise level of the new plant items. The cumulative noise level was calculated using logarithmic addition. It can be seen in Table 9 below that the new plant has a negligible impact on the overall noise level at each noise sensitive location as the noise levels from the new plant are quite low in comparison
For inspection purposes only. to the noise from the existingConsent Cement of copyright Plant. owner required for any other use.
NSL5 is located on site and is not a noise sensitive location. It is included for indicative purposes only. Measured Specific Predicted dB Cumulative dB Location Period Noise Level Existing LAeq LAeq Cement Plant dB Day 34.3 34.3 NSL1 1 Night 32.3 32.3 Day 41.9 41.9 NSL2 12.4 Night 36.2 36.2 Day 48.6 48.6 NSL3 23.3 Night 41.6 41.7
Enervise Limited 65
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
Day 48.6 48.6 NSL4 25.8 Night 44.5 44.6 NSL5 (On Day 55.7 55.7 11.3 Site) Night 55.9 55.9 Day 43.8 43.8 NSL6 13.8 Night 44.4 44.4 Table 9: Calculated cumulative noise level from both the existing Cement Plant and the addition of new plant
8.4 Impact Assessment The noise from the new plant is not expected to be tonal or impulsive in character and by viewing the predicted noise levels and the Cumulative noise levels above, it can be seen that the noise contribution from the new plant items at the nearest noise sensitive locations as predicted by the noise model is not expected to cause a breach in the day, evening or night time noise levels of 55dB, 50dB and 45dB respectively as outlined in Guidance Note for Noise (NG4).
Table 10 below details the BS 4142 assessment of the noise impact upon the nearest residential receptors due to the addition of the new items of plant to be installed at For inspection purposes only. the Cement Plant. There wereConsent no of copyrightpenalties owner required added for any to other the use. specific noise level of the new plant items, as there are no sources of tonal or impulsive noise to be installed at the Cement Plant.
Enervise Limited 66
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
BS 4142 Assessment NSL1 NSL2 NSL3 NSL4 NSL5 NSL6 Predicted Specific Noise Level 1 12.4 23.3 25.8 11.3 13.8 of new Plant Items (dB LAeq) Rating Penalties 0 0 0 0 0 0
Rated Noise Level (dB LAr,T) 1.0 12.4 23.3 25.8 11.3 13.8 Measured Existing Level (dB 32.3 36.2 41.7 44.5 55.9 44.4 LA90) Difference (dB) -31.3 -23.8 -18.4 -18.7 -44.6 -30.6 Low Low Low Low Low Low Expected Level of Impact Impact Impact Impact Impact Impact Impact
Likelihood of Complaint Unlikely Unlikely Unlikely Unlikely Unlikely Unlikely Table 10: BS 4142 assessment showing that the likelihood of complaint from the new plant items
It can be seen from Table 10 above, the Rated Noise Level for new plant is significantly lower than the current existing noise level at every location as measured by Noise and Vibration Consultants Ltd during the 2016 environmental noise survey. Using the BS4142 method for assessing likelihood of complaint, there is a positive indication that the addition of the new plant will not increase the likelihood of complaint from the Cement Plant. For inspection purposes only. Consent of copyright owner required for any other use.
8.5 Conclusion A 3D environmental noise model was developed for the Ballyconnell Cement Plant to predict the noise levels attributable to a number of new items of plant to be installed as part of an upgrade that will increase the range and quantity of alternative fuels and alternative raw materials used by the plant.
The predicted noise levels for the new items of plant were added to the measured specific noise level due to the existing Cement Plant as measured by Noise and Vibration Consultants Ltd during the 2016 environmental noise survey. The noise model predicted that the noise level attributable to the proposed new items of plant
Enervise Limited 67
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 will be negligible and will not cause any noticeable change to the noise levels due to the existing Cement Plant.
The cumulative noise emissions from the existing Cement Plant and the proposed new items of plant are predicted to remain below the day, evening and night noise limit values of 55dB, 50dB and 45dB as outlined by the EPA in Guidance Note for Noise (NG4) at all of the nearest noise sensitive locations.
In addition to NG4, reference was also made to British Standard BS 4142: Methods for rating and assessing industrial and commercial sound. Using this methodology for assessing likelihood of complaint, it was found that the addition of the new plant will not increase the likelihood of complaint due to the operation of the Cement Plant.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 68
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
9.0 Landscape This section considers the potential impact that the proposed development may have on landscape and visual impact.
9.1 Site Context The Quinn Cement facility is located at the south eastern foot of the Slieve Rushen mountain. The facility has been constructed on a level plateau in generally undulating hedged and wooded pastureland to the north of the derelict Slieve Russell House.
The facility is separated from the R205 by a strip of some 250m of farmland. The site topography was a significant factor in the original placement of the plant on the site in order to minimise visual impact.
None of the land within the site is subject to any landscape or conservation designation.
9.2 Previous Landscape and Visual Impact Assessments
For inspection purposes only. Consent of copyright owner required for any other use. 9.2.1 Original EIS 1997 A landscape and visual impact assessment (LVIA) of the site was included in the EIS prepared and submitted by Kirk McClure Morton Consulting Engineers (now RPS Ireland) with the original application for the Scotchtown Cement plant in September 1997.
The LVIA concluded that there were 4 main receptor groups as follows: Ballyconnell Residents Travellers on the R205 adjacent to the plant Residents of dwellings adjacent to the R205 Tourists on the Canal
Enervise Limited 69
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 and that the site location and the plant placement did much to avoid impacts on all but the last of these.
Overall the landscape and mitigation measures assisted with screening the development from view from Ballyconnell, the R205 road, dwellings adjacent to the site frontage and the Shannon – Erne Canal.
Simon Clear (Senior Planning Inspector – An Bord Pleanála) agreed with this position in his report dated May 1998:
“The proposed location has a superior visual disposition. On the site proposed it is possible to locate the main plant a significant distance from the roadside, behind the existing vegetation and beyond the break in slope from the roadside to the plateau on which the plant is proposed to be located. Whilst silos, and the flue, in particular, would be very tall buildings, they would be located approximately 1 kilometre from both Ballyconnell Village and the Shannon - Erne Navigation, which would be the locations at which the most sensitive receptors, from a visual viewpoint, would be located.”
For inspection purposes only. Consent of copyright owner required for any other use.
9.2.2 EIS 2009 The EIS as prepared in 2009 for the introduction of Solid Recovered Fuel (SRF) at the facility outlined that the proposed change of fuel would not necessitate any form of ground disturbance outside the existing industrial foot print and that the proposed structures were to be constructed within the confines of the existing plant. It reviewed each proposed structure in the context of the existing plant near to it. As a result, it determined that the structures proposed as part of that planning application would have a negligible impact on the landscape and on visual impact. In that context it concluded that the findings of the original Landscape and Visual Impact report and the Senior Planning Inspector, as set out above, remained valid.
Enervise Limited 70
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
9.3 Proposed Plant Alterations It is now proposed to improve the sustainability of the cement plant, through the use of an increased range of waste derived alternative raw materials and fuels with the long term aim of displacing almost all fossil fuels at the plant (a limited proportion of fossil fuels will be required during process start up and for process optimisation/stabilisation). The use of these alternatives will equate to 300,000 tonnes per annum at maximum substitution.
A range of suitable materials are proposed for acceptance at the plant which can be summarised as follows: Solid Fuels – including Solid Recovered Fuel (SRF) which is currently authorised for use at the plant, as well as a range of suitable fuels derived from other sources including: o Meat and Bone Meal (MBM); o Tyre Derived Fuel (TDF); o Biomass Fuels; o Sludges and Filter Cakes. Liquid Fuels – including Secondary Liquid Fuel (SLF) which is a blend of For inspection purposes only. Consent of copyright owner required for any other use. organic and solvent wastes blended to a defined specification as well as liquid fuels derived from other sources (e.g. waste oils). Alternative Raw Materials (e.g. muds, minerals, sludges).
It is also proposed to include natural gas and petcoke as additional fuels in the Industrial Emission Licence, regulated by the EPA. This is to provide flexibility for any future fossil fuel requirement.
In order to facilitate the use of the aforementioned alternative fuels certain changes are required to the plant as set out at Table 1, which is reproduced below for ease of reference. This also indicates where the equipment was previously authorised under planning reference 09456 which has now lapsed.
Enervise Limited 71
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
Equipment Requirement Previously authorised under Planning Ref: 09/456 Bunded Liquid Fuel tanks SLF and other liquid No and associated feeding fuels Storage system Meat & Bonemeal silos and MBM Storage No associated feeding system Lime silos and associated Reduce SOx emissions No feeding system Extension to existing SRF and other Solid Yes, albeit slightly modified in Storage bays and associated Alternative fuels this planning application feeding system (footprint reduced). Induced Draught (ID) Fan Process Yes, no change. Calciner Process Yes, albeit slightly modified in this planning application (elevation reduced).
Based on above it can be seen that the extension to the fuel storage bays, new ID Fan and Calciner were previously assessed in the 2009 EIS and were subsequently
For inspection purposes only. authorised under planning referenceConsent of copyright 09456. owner required These for any structures other use. are again proposed in the same locations, albeit being slightly modified in design.
The following additional equipment is also proposed: Bunded Liquid Fuel tanks and associated feeding system; Meat & Bonemeal silos and associated feeding system; Lime silo and associated feeding system.
All of the proposed engineering alterations are to be contained within the existing permitted footprint of the Cement Works, with all the infrastructure being situated at ground level (bar the calciner upgrade), in the confines of the existing plant.
Enervise Limited 72
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
The extension to existing storage bays are proposed within the centre of the plant site and will be completely encapsulated from all external views by the existing plant.
In 2009 planning permission was received under Planning Reference 09/456 for a "new calciner" placed outside the existing pre heater tower. Rather than build this new calciner now, it is proposed to extend the existing calciner to increase the volume and retention time. This upgrade will not interfere with the bottom part of the existing calciner or the kiln riser. The extension will begin at the roof of the old calciner and run out of the preheater tower where it will make a u-bend and go down into the bottom stage cyclone. This proposed upgrade has a smaller volume than the "new calciner" permitted in 2009 and as a result this smaller structure will have a lesser impact than that previously permitted in terms of visual impact. The calciner upgrade is located to the west of the pre-heater tower with the pre-heater tower shielding views from both the Quinn Cement offices and from further outside the site boundary along the R205. This is best illustrated by the planning elevation drawing P15001/AF2/EL/01, which confirms that the impact of the calciner upgrade will not increase the existing visual impact of the pre-heater tower. For inspection purposes only. Consent of copyright owner required for any other use.
The new ID Fan, with increased efficiency, upgrades the existing fan. The fan will be located in the same location but at a lower elevation, accordingly it is considered to have no potential to increase the visual impact of the works.
The lime dosing silos are proposed at the north eastern end of the site to the east of the existing conditioning tower and Electrostatic Precipitator (ESP) structures. It is considered that the proposed lime dosing silos will merge into the backdrop of the considerably larger structures behind them from external viewpoints.
The MBM silos are proposed in the centre of the plant site to the north of the grate cooler Electrostatic Precipitator (ESP) with the main burner building partially
Enervise Limited 73
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 blocking their view from external viewpoints. When set against the context of the raw materials preparation and feeding area behind them, which is situated at a higher level, it is considered that these structures will merge in with surrounding structures.
The Liquid Fuel Tanks are proposed at the south western extent of the development to the west of the large clinker storage shed. These tanks are proposed within a small area of immature woodland, dominated by immature trees that have not yet reached the threshold height of 5m. These trees will be maintained along the southern and western extents of the Liquid Fuel Tanks bunded area and will act to screen the proposed development area. Furthermore, these tanks are dwarfed against the existing clinker store to the west, and plant site directly to the north and will therefore merge in with surrounding structures.
9.4 Conclusion It is considered that the new structures proposed as part of this planning application, will have a negligible impact in visual terms. Furthermore, the proposed change of fuel will not necessitate any form of ground disturbance outside the existing For inspection purposes only. Consent of copyright owner required for any other use. industrial foot print.
Accordingly it is considered that the proposed arrangement of plant will have a negligible impact on the landscape and on visual impact.
Enervise Limited 74
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
10.0 Ecology An Ecological Impact Assessment was undertaken by Woodrow Sustainable Solutions to to assess the existing and potential ecological impact of the development on the nearby habitats, protected species and the receiving environment. The full assessment can be found as Appendix 4 of this Environmental Impact Statement, held in Section 20.
10.1 Methodology A combination of desk top studies and field surveys were undertaken to determine the potential impact of the proposed development.
10.2 Main Findings It is concluded that the proposal has the potential to result in negative long term impacts which are considered to be of minor significance to ecological features of interest that are of international significance namely the Moninea Bog SAC. These potential impacts are caused by emissions from the cement plant as set out at Chapter 7 in the air report. No mitigation measures are required for this impact. Consequently, this will result in a minor negative residual impact. For inspection purposes only. Consent of copyright owner required for any other use.
The proposal also has the potential to result in the positive long term impacts which are considered to be of minor significance/negligible significance to ecological features of interest that are of both International and national importance, namely the Upper Lough Erne SAC and the Upper Lough Erne - Crom ASSI. These positive impacts arise as a result of water reuse proposals at the cement plant which will reduce the discharge rate to the Woodford River and downstream impact at these receptors.
The proposal also has the potential to result in the permanent loss of an area of habitat classified as Immature woodland (WS2) for the development of the bunded liquid fuel tanks. This impact is considered to be of minor significance and no
Enervise Limited 75
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 mitigation is recommended due to the small area of habitat involved. Consequently, this will result in a minor negative residual impact.
The loss of this area of habitat may also have a short term impact on local breeding bird assemblages. This unmitigated potential impact is considered to be minor in significance. It is recommended that no clearance of immature woodland will be undertaken during the bird breeding season (March to August inclusive). Consequently, this will result in a neutral impact on local breeding bird assemblages.
10.3 Natura Impact Statement A Natura Impact Statement (NIS) has been completed which provides for a full assessment of the potential impacts on Natura 2000 and Ramsar sites identified as being at risk of impacts from air emissions. Due to its complexity, the information contained within the NIS has not been repeated here, but is submitted as a standalone document as part of the planning submission.
The NIS concludes that there is no potential for adverse impacts on any Natura 2000 or Ramsar site identified as a result of the proposed changes to the Ballyconnell For inspection purposes only. Consent of copyright owner required for any other use. cement plant.
Enervise Limited 76
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
11.0 Traffic In order to allow the local highway authority, Cavan County Council, to consider the impact of the proposed development, The Hurlstone Partnership was commissioned to undertake an assessment of the existing road network and the potential impact as a result of the proposed development. The full assessment can be found as Appendix 5 of this Environmental Impact Statement held in Section 21.
The traffic assessment adheres to the following structure: A review of the local highway network An assessment of the baseline traffic flows A review of the Development Traffic and its potential impact Summary and conclusion
11.1 Local Network A comprehensive review of the local highway network was undertaken with each route being examined. The study considered the impact of development traffic on the local road network including the site access, the R205 to the south through and beyond Ballyconnell, the R205/B127 to the north up to Derrylin and the N87 to the For inspection purposes only. Consent of copyright owner required for any other use. southeast of Ballyconnell, which connects to the N3 near Belturbet. Particular emphasis was placed on highway widths, junction layouts and capacities.
11.2 Baseline Traffic Flows In order to establish baseline traffic flows on the local network a transport assessment was carried out in 2005 for an increase in production capacity at the Quinn Cement Facility. As part of this assessment a comprehensive traffic survey was undertaken at strategic locations with Automated Traffic Counters (ATCs) installed to record traffic flows. The ATCs recorded directional flows and vehicle classifications over a one-week period from the 15th – 23rd October 2005 inclusive, along the following links: -
Enervise Limited 77
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
A509 800m South of Teemore Crossroads Teemore Road West of the A509 Junction Teemore Road east of the B127 Junction B127 North of Teemore Road junction (800m North of Quinn Glass access) B127 North of New Cement Works access at Gortineddan R205 South of New Cement Works access R205 1000m South of Ballyconnell
The ATCs recorded all vehicle movements in hourly time intervals 24 hours per day over a nine-day survey period.
Since the Company survey work was undertaken, new surveys have been carried out on behalf of Cavan County Council in order to assist in the assessment of the approved Ballyconnell Inner Relief Road scheme. Cavan County Council kindly provided a copy of traffic survey data from February 2007 and June 2007. These more recent flows have been compared with those of 2005. Cavan County Council has confirmed that these are the most recent traffic counts available in the area.
For inspection purposes only. Consent of copyright owner required for any other use. 11.2.1 Traffic Activity Levels The survey results demonstrated that there is a wide variation in traffic volumes on the local road network. Notwithstanding the wide variation in traffic flows, it is apparent that all of the routes were relatively lightly trafficked when compared to their respective design capacities.
When considering the capacity of the local highway network and the level of traffic observed to be travelling on it, it is apparent that a significant level of reserve capacity exists, even when allowing for any reasonable levels of traffic growth during the intervening period.
Enervise Limited 78
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
It was found that the traffic flows on all links of the network fluctuated significantly from day to day, both in terms of total flow and HGV content.
11.3 Proposed Development Traffic The proposed development would result in an additional 7 people being employed, resulting in additional trips. However, due to their working hours, the impact of these trips on the road network would be limited as they would primarily occur off- peak. However, the proposed development does result in increased HGV traffic to the site.
To establish the number of additional HGVs travelling on the network, Quinn Cement Ltd reviewed its records of distribution, collections and deliveries of materials.
It was found that the substitution of 95% of coal with alternative fuels and the use of alternative raw materials would result in an additional 20 HGVs (40 movements) per day travelling on the local road network when compared to the scenario whereby the site is fuelled 100% by coal. When compared with the permitted scenario of 55% For inspection purposes only. Consent of copyright owner required for any other use. of coal being replaced by SRF, the increase in HGV traffic reduces to 9 loads / 18 movements per day. This was calculated as follows:
In terms of coal imports, the annual consumption at the site associated with the production of 1.4 million tonnes of cement is 155,000 tonnes. This is currently imported in 30 tonne payloads giving a total of 5167 loads per annum or an average of 19 loads per day based on the deliveries taking place 5.5 days per week for 51 weeks per annum.
In terms of the alternative fuels, taking the worst case scenario in terms of traffic increases, whereby 95% of the coal consumption is replaced, it is
Enervise Limited 79
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
calculated that the equivalent of 147,250 tonnes of coal would be replaced by the sustainable alternatives.
Based on an alternative fuel with the lowest calorific value acceptable to the plant, an additional 50% of alternative fuels would be required to generate the equivalent energy as coal i.e. for every 1 tonne of coal 1.5 tonnes of alternative fuel is required. Some of the alternative fuels will have a higher calorific value resulting in improved coal displacement ratios, resulting in less alternative fuel being required and therefore less haulage traffic. Therefore, the following calculations represent the worst case scenario in terms of predicted increases in vehicle movements.
The displaced 147,250 tonnes of coal therefore equates to 220,875 tonnes of alternative fuel. When taking into account the 24 tonne payload, a total of 9203 loads would be imported annually. This equates to 28 loads per working day and 56 movements when taking into account the 330 days over which the alternative fuels are imported.
For inspection purposes only. Consent of copyright owner required for any other use. The balance of the 300,000 tonnes of imported alternative materials (79,125 tonnes) would comprise alternative raw materials. When taking into account the 24 tonne payload and 330 days per annum over which it would be imported, this equates to 3,297 loads per annum and 10 loads/20 movements per day.
In addition, the residual coal requirement of 7,750 tonnes would be transported over 280.5 days in 30 tonne loads, resulting in 259 loads annually and 1 load/2 movements per day.
Enervise Limited 80
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
This increase in HGV traffic of 9 loads / 18 movements per day over the current permitted scenario may be compared with the additional 19 loads / 38 HGV movements approved at the site related to the Mixed Bottle Recycling Plant (Planning Ref. No. 10/71), which was never implemented. Having considered the foregoing, it is apparent that the overall quantum of traffic associated with the proposed development would be 10 loads / 20 movements less than the cumulative attractions to the site historically accepted on the local road network.
11.3.1 Traffic Distribution When taking into account the directional distribution at the site access, it was established there would be a reduction of up to 8 loads / 16 movements per day on the R205 / B127 and A509 to the north of the site (as a result of reduced coal traffic from Derry port).
To the south of the site there would be an increase of between 17 loads / 34 HGV movements and 23 loads / 46 HGV movements per day when compared with the 55% replacement of coal with SRF (as approved) and 100% fuelling by coal respectively. This increase would occur along the R205 between the site access and For inspection purposes only. Consent of copyright owner required for any other use. Ballyconnell Inner Relief Road, along the Inner Relief Road itself and thereafter along the N87 en-route to the N3 at Belturbet.
This equates to between 1 – 3 loads / 2 – 6 HGV movements per hour when spread over a typical working day, or up to one HGV movement every 10 minutes.
When considering the permitted replacement of 55% of coal with SRF as the baseline scenario, on all links along which the development traffic would travel, the quantum of development traffic falls within the range of existing day-to-day and hour to hour variations in HGV activity. If assessed against the 100% fuelling by coal, the proposed development traffic represents 6 HGVs per 12 hour day more than the 40
Enervise Limited 81
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
HGV movements observed in 2005, but the variation remains within those observed on an hour to hour basis.
The increase in traffic associated with the proposed development would not have a significant detrimental impact on highway capacity on any links considered within the study area as a significant level of reserve capacity would be retained.
11.4 Conclusion As a result of the proposed development at the Cement Works, to enable the plant to be able to accept and accommodate a wider range of alternative fuels and raw materials, the plant will attract additional HGV deliveries.
The distribution of traffic is such that the highest average hourly increase on any given link is up to 6 movements (3 in/3 out) per hour, which equates to 1 movement every 10 minutes. However, this increase to the south of the site may be partially offset by a reduction in HGV traffic to the north.
Comparison of empirical traffic flow data revealed that the proposed quantum of For inspection purposes only. Consent of copyright owner required for any other use. HGV traffic falls within the range of observed day to day variations on the local highway network and the cumulative total remains below those previously approved on routes which retain significant levels of reserve capacity.
When assessed against the baseline flows on the network and the reserve capacity available on the local roads, it is concluded that the increased traffic would have an insignificant impact on the area.
Enervise Limited 82
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
12.0 Natural Resources 12.1 Introduction This chapter of the Environmental Impact Statement considers the impact of the proposed development on Natural Resources. In this context it looks specifically at Natural Resources in terms of virgin raw materials (limestone, clay, silt, shale, iron ore and bauxite) used for the production of cement as well as fossil fuels used for the heating of the process (predominately coal). In order to understand the natural resource requirements in the production of cement it is important to understand the cement manufacturing process as outlined below.
12.2 Cement Production Process The Ballyconnell facility currently produces Portland cement, which is a composite mixture consisting of synthetic minerals exhibiting hydraulic properties upon mixing with water.
The main raw materials used in the process are limestone (rich in calcium) and shale (rich in silica). As the chemical composition of these materials can be variable, small quantities of other materials including sand, clay, silt, bauxite and iron ore are used For inspection purposes only. Consent of copyright owner required for any other use. as additives in order to obtain the required blend.
The raw materials are processed by crushing, blending and milling to produce a homogenous “raw meal”. This raw meal is then passed through a high temperature kiln, where a thermal process produces a synthetic mineral “clinker”. The clinker and additives are then milled into a fine powder - “cement”.
The main unit operations that are carried out at the plant include the following which are explained briefly in the following sections: Raw material handling; Raw milling; Clinker production;
Enervise Limited 83
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
Cement milling and dispatch.
12.2.1 Raw Material Handling The main raw materials used within the process are limestone and shale, obtained from local quarries, which account for the majority of the raw material. Limestone is blasted from a local quarry. All materials are transported to the site by dumper trucks and emptied directly into concrete bunkers located within contained enclosures.
Limestone arrives at the site ready crushed and is loaded directly into hoppers, whilst the shale is loaded into specialised crushers. The shale, limestone and sand are tipped directly from dumpers into their respective hoppers for processing and transport to the pre-blending store via enclosed rubber belt conveyors.
The raw materials are mixed and blended within the pre-blending store. Carefully proportioned quantities of each raw material are fed by conveyor belt to the pre- blending store, with “fine-tuning” being undertaken through the addition of small amounts of other components including sand, silt and iron ore. Once an appropriate For inspection purposes only. Consent of copyright owner required for any other use. blend has been achieved it is stored prior to milling.
12.2.2 Raw Milling The Raw Mill crushes and grinds the raw material mix to a very fine powder, known as raw meal. The raw mill contains an air-swept vertical roller mill which grinds the raw material between a rotating grinding table and three stationary grinding rollers. The resulting material is lifted from the mill by circulation air and passed through a rotary separator. Material that is too coarse falls from the circulation air and is returned to the mill for further grinding. Due to the moisture content of the raw material, drying is undertaken using hot circulation air from the kiln.
Enervise Limited 84
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
A series of cyclones are used to separate the raw meal from the circulation air before transportation to a silo for storage and homogenisation. A gravimetric feeding system is used to feed the raw meal to the next stage of the process.
12.2.3 Clinker Production The raw meal enters the top of the cyclone pre-heater and travels down through five cyclones under the force of gravity. The cyclone pre-heater is equipped with an in- line calciner within which up to 60% of the fuel is combusted. This initiates the start of the chemical pyro-process and reduces oxides of nitrogen in the flue gases. At
o 600 C the calcium carbonate (CaCO3) in the limestone decomposes to produce quicklime and carbon dioxide. After a residence time of 1-minute, the material reaches the kiln inlet, at a temperature of approximately 860ºC. The material is also 95% calcined at this point. The heated material gradually moves down the rotating kiln.
The temperature of the raw meal is raised from 860ºC to 1,500ºC within the kiln, which initiates the chemical reactions that are required for the clinker production process to take place. For inspection purposes only. Consent of copyright owner required for any other use.
Currently coal and Solid Recovered Fuel (SRF) provide the heating requirements for this process.
12.2.4 Cement Milling and Dispatch Clinker is extracted mechanically from the clinker store and transported directly to the cement mill for grinding.
Within the mill, the clinker is mixed with gypsum to control the setting time of the finished cement and fly ash and limestone chips are added to produce CEM II cement. CEM II uses fillers such as fly ash and limestone chips to reduce the clinker
Enervise Limited 85
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 content of the cement and, therefore, reduces the carbon content of the finished cement product.
Gypsum is transported to the site in covered trucks and stored in enclosed concrete bunkers. The gypsum is extracted from the bunkers by vibration feeders and transported to an intermediate bin by a rubber belt conveying system. The gypsum is extracted from the bin by a weight-feeder and transported to the mill for grinding together with the clinker.
The flyash is a filler material, used to substitute a portion of the clinker without reducing the quality of the end product.
The limestone chips are sourced from the local quarry.
The clinker and addtives are mixed to fine powder cement within the cement mill before transportation to three cement storage silos for storage. Two of these silos are used for despatch of bulk cement, whilst the remaining silo is fed to a bagging plant. Cement is packed at a rate of 2,000bags/hour. For inspection purposes only. Consent of copyright owner required for any other use.
12.3 Natural Resource Requirements Table 11 below shows the raw material used in the manufacture of clinker for the years 2013-2015 inclusive:
Year Limestone Clay/Silt Shale Iron Ore Bauxite
2013 537,576 19,618 80,428 782 13,361 2014 847,171 30,916 126,747 1,233 21,056 2015 1,017,342 37,127 152,207 1,480 25,286 Table 11: Raw Material Use (tonnes) – Clinker Production (2013-2015)
Enervise Limited 86
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
As can be seen from Table 11 the main raw materials used include Limestone (approximately 83%) and Shale (approximately 12%) with clay/silt, iron ore and bauxite contributing to the remainder.
Table 12 below shows the additives to clinker in the manufacture of cement for the years 2013-2015 inclusive:
Year Gypsum Flyash Limestone Chips Ferrous Sulphate
2013 29,001 39,043 13,718 726 2014 31,936 40,044 16,222 828 2015 41,458 30,217 38,438 1,146 Table 12: Clinker Additives (tonnes) – Cement Production (2013-2015)
At full capacity the Quinn Cement Ballyconnell facility has a requirement of approximately 155,000 tonnes of coal per annum. This figure is based on no alternative fuels being used at the plant.
12.4 Impact of Proposed Development The proposed project seeks to improve the sustainability of the Ballyconnell cement For inspection purposes only. Consent of copyright owner required for any other use. plant, through the use of an increased range of waste derived alternative raw materials and fuels with the long term aim of displacing almost all fossil fuels at the plant (a limited proportion of fossil fuels will be required during process start up and for process optimisation/stabilisation). The use of these alternatives will equate to 300,000 tonnes per annum at maximum substitution.
A range of suitable materials are proposed for acceptance at the plant which can be summarised as follows: Solid Fuels – including Solid Recovered Fuel (SRF) which is currently authorised for use at the plant, as well as a range of suitable fuels derived from other sources including: o Meat and Bone Meal (MBM);
Enervise Limited 87
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
o Tyre Derived Fuel (TDF); o Biomass Fuels; o Sludges and Filter Cakes. Liquid Fuels – including Secondary Liquid Fuel (SLF) which is a blend of organic and solvent wastes blended to a defined specification as well as liquid fuels derived from other sources (e.g. waste oils). Alternative Raw Materials (e.g. muds, minerals, sludges).
It is also proposed to include natural gas and petcoke as additional fuels in the Industrial Emission Licence, regulated by the EPA. This is to provide flexibility for any future fossil fuel requirement.
12.4.1 Alternative Raw Materials As demonstrated at Section 12.3 the Quinn Cement plant currently relies on substantial quantities of virgin raw materials for the production of clinker. Table 11 shows that in 2015 alone, a total of 1,233,441 tonnes of raw materials were used in clinker production. It should be noted that in 2015 the cement plant was only at 60% of maximum production capacity, due to depressed economic factors which limited For inspection purposes only. Consent of copyright owner required for any other use. the requirement for cement. Therefore this raw material requirement will be set to rise in the coming years as the economy recovers and the demand for cement increases. It is therefore incumbent on Quinn Cement to consider the use of alternative raw materials to offset the requirement for virgin raw materials.
A number of suitable alternative raw materials have been identified that have a chemical composition and mineral content suitable for cement production. Examples of these alternative raw materials include water treatment sludge which is high in aluminium; and clays, soils, muds and stones that can provide some of the mineral content required for the cement process. The use of these alternative raw materials, whilst not offsetting totally the requirement for virgin raw materials, can go some way towards reducing them.
Enervise Limited 88
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
12.4.2 Alternative Fuels It is important that Quinn Cement continually improve upon the environmental performance of the site, both in terms of its Carbon Footprint and with respect to the Company’s own Environmental Policy. This will assist in the long term sustainable production of cement in to the future, whilst contributing to the management of waste arisings throughout the Island of Ireland.
The proposal to broaden the range of alternative fuels, with the long term aim of displacing almost all fossil fuels at the plant is a major step forward in this direction. At full capacity, Quinn Cement burns approximately 155,000 tonnes of coal per annum to heat the cement process. Currently, Quinn Cement are authorised to displace 55% of this coal requirement with SRF. The remainder of the coal is currently sourced from South Africa. From a natural resource perspective the proposed development, which seeks to displace almost all fossil fuels at the facility with alternative fuels, will have a positive impact as it will save on non-renewable fossil fuels which are also a finite resource.
Furthermore, transporting coal from South Africa to Ireland is a complex process. For inspection purposes only. Consent of copyright owner required for any other use. Shipped from Richards Bay Port in South Africa direct from the mine to Derry port, each cargo is typically of the order of 30,000 to 40,000 tonnes. A calculation provided by www.ports.com/sea-route estimates that the coal will travel some 8068 nautical miles from Port of Richards Bay to Port of Londonderry, taking over 1 month to complete the trip. Thereafter it is road hauled the remaining 80 miles to Quinn Cement at Ballyconnell. In comparison the proposed alternative fuels and alternative raw materials will be sourced within the Island of Ireland. This will provide the additional benefit of reducing waste export as outlined in Section 3.2.4.5. Here it was identified that large volumes of waste are being exported from Ireland in the form of Refuse Derived Fuel (RDF), Solid Recovered Fuel (SRF) and residual Municipal Solid Waste (MSW) for energy recovery abroad with 347,000 tonnes exported in 2013. It
Enervise Limited 89
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 claims that these exported resources could be used domestically to generate employment, boost economic activity and contribute to the circular economy.
12.5 Conclusion It can be concluded that the proposed development will have a positive impact from a natural resource perspective by significantly reducing the importation and use of fossil fuels through the use of a wider range of alternative fuels. The proposed development will also reduce the reliance on virgin raw materials by using alternative raw materials. Furthermore, the use of these alternatives is considered more sustainable when compared against the sourcing and transportation requirements of existing fossil fuels used at the plant.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 90
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
13.0 Human Beings: Socio Economic 13.1 Introduction Human Beings represent one of the most important aspects of the environment to be considered in the Environmental Impact Assessment process. As outlined in Section 1, this Environmental Impact Statement is produced in the grouped format structure; therefore impacts upon Human Beings are also addressed in other relevant chapters such as those on Air Quality, Water Environment, Noise and Traffic.
This chapter deals specifically with the potential impacts of the proposed development on Human Beings with respect to socio economic indicators. The primary socio economic indicators which are examined in this chapter relate to population, settlement, employment and economic activity.
13.2 Methodology This chapter concentrates on the population aspects of the existing environment and the potential for impacts on population, settlement, employment and economic opportunities as a result of the proposed development.
For inspection purposes only. Consent of copyright owner required for any other use. The information sources used to prepare this chapter include: Census and employment information from the Central Statistics Office (CSO); National and Regional Development Plans; Cavan County Development Plan 2014–2020; Cavan County Council Website www.cavancoco.ie
13.3 Existing Environment The Ballyconnell cement facility is located in a semi-rural location, less than 2 km from the northern extent of Ballyconnell Town. The Cavan County Council Development Plan 2014-2020 identifies Ballyconnell as a medium sized town in the Settlement Framework. It is situated in the west of County Cavan close to the border
Enervise Limited 91
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 with County Fermanagh. It is located on the Woodford River, which is part of the Shannon-Erne Waterway at the crossroads of the N87 and the R205.
The National Spatial Strategy for Ireland (2002 – 2020) was published by the Department of the Environment and Local Government in 2002 as a twenty-year planning framework aimed at promoting a better balance of social, economic, physical development and population growth between regions.
Located in Ballyconnell Co. Cavan the Quinn Cement plant is located within the Border Region. In an effort to achieve balanced development in this region Letterkenny/Derry, Sligo and Dundalk were designated as new gateways to drive development through “enhanced critical mass, accessibility and capacity for development”.
Other towns, villages and rural areas (which would include Ballyconnell town and the adjoining area where the cement plant is located) were identified as needing to develop roles complementary to those of the gateways to ensure that a wider area will benefit from the “critical mass” in the region provided by the gateways. Review of the strategy indicates that: For inspection purposes only. Consent of copyright owner required for any other use.
“Critical mass relates to size and concentration of population that enables a range of services and facilities to be supported. This in turn can attract and support higher levels of economic activity and improved quality of life.”
Employing 80 full-time positions in managing a 24-hour operation, and providing approximately 250 positions in local service supply companies, the Quinn Cement plant plays an important role in sustaining critical mass in the Ballyconnell area, thereby achieving more balanced regional development.
Enervise Limited 92
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
13.3.1 Population Table 13 provides an analysis of population change for the Island of Ireland and at National, Regional, County and Ballyconnell Town levels from 2002 to 2011. Area 2002 2006 % Change 2011 % Change 2002-2006 2006-2011 All Island 5,603,030 5,984,925 6.8 6,399,152 6.9 Ireland (ROI) 3,917,203 4,239,848 8.2 4,588,252 8.2 Border Region 432,534 468,375 8.3 514,891 10.1 County Cavan 56,546 64,003 13.2 73,183 14.3 Ballyconnell 572 747 30.6 1,061 42 Table 13: Population & Population Change Indicators (Source CSO)
These population statistics show significant increases in population in all areas. In 2011 the population in County Cavan was 73,183 which was a 14.3% increase on the 2006 population. Ballyconnell town showed a 42% increase during the same time period, with the population increasing from 747 in 2006 to 1,061 in 2011. The Cavan County Council Development Plan 2014-2020 acknowledges this population growth for Ballyconnell indicating that:
For inspection purposes only. Consent of copyright owner required for any other use. “Ballyconnell continues to experience strong population growth, in the 2011 census the population had grown by 42%, significantly higher than the county average, higher than Cavan Town & Environs and the growth experienced in the previous census period.”
13.3.2 Settlement Cavan remains a predominantly rural County but has seen a significant increase in the percentage of those choosing to live in urban rather than rural areas. The towns with the largest percentage population increase were Mullagh (67.5%), Ballyjamesduff (52%) and Ballyconnell (42%).
Enervise Limited 93
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
A settlement hierarchy has been put forward in the County Development plan which sees Cavan Town as a Hub town within the Border Region. Large towns within the County are envisaged to act as drivers of growth within the County and support the role of Cavan Town. Ballyconnell is considered a medium size town. Medium size towns have a similar role to large towns in acting as drivers of growth within the County. However, this growth would typically be at more moderate levels in medium size towns due to factors such as their size, social and economic profile and in some cases development pressure.
An estimate of population growth between 2011 and 20120 has been put forward at Section 2.5.2 of the County Development Plan to inform zoning of proposed residential land. It serves as a useful indicator to estimate future population trends and settlement patterns. It estimates 8,143 additional persons in County Cavan for the period 2011-2020, with 325 additional persons estimated for Ballyconnell.
13.3.3 Employment Quinn Cement would be considered a major employer in the Ballyconnell area. The plant currently employs 80 full time positions and provides approximately 250 For inspection purposes only. Consent of copyright owner required for any other use. positions in local service supply companies. Furthermore, Quinn Industrial Holdings are a significant employer in the area with employment sustained in a number of manufacturing facilities including Quinn Lite, Quinn Precast, Quinn Quarries, Quinn Rooftiles, Quinn Tarmac, Quinn Therm and Quinn Packgaing. Other employers in the area include Boxmore Plastics, Ballytherm, the Slieve Russell Hotel, the glass manufacturing facility as well as services provided within and on the outskirts of the Town.
13.4 Proposed Development The proposed development seeks to improve the sustainability of the Ballyconnell cement plant, through the use of an increased range of waste derived alternative raw materials and fuels with the long term aim of displacing almost all fossil fuels at the
Enervise Limited 94
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 plant (a limited proportion of fossil fuels will be required during process start up and for process optimisation/stabilisation). The use of these alternatives will equate to 300,000 tonnes per annum at maximum substitution.
A range of suitable materials are proposed for acceptance at the plant which can be summarised as follows: Solid Fuels – including Solid Recovered Fuel (SRF) which is currently authorised for use at the plant, as well as a range of suitable fuels derived from other sources including: o Meat and Bone Meal (MBM); o Tyre Derived Fuel (TDF); o Biomass Fuels; o Sludges and Filter Cakes. Liquid Fuels – including Secondary Liquid Fuel (SLF) which is a blend of organic and solvent wastes blended to a defined specification as well as liquid fuels derived from other sources (e.g. waste oils). Alternative Raw Materials (e.g. muds, minerals, sludges).
For inspection purposes only. Consent of copyright owner required for any other use. 13.4.1 Employment & Economic Opportunity There will be an additional 7 full time employment opportunities at the Ballyconnell facility which will be directly associated with the proposed development. Furthermore, the project will involve the provision of direct and indirect jobs both on and off site, over the construction period. Employment will be created by the construction of the proposed development. Indirect employment and economic activity in local shops, restaurants and hotels is likely to be sustained as a result of the construction project and its employees being located in the area.
Finally, the proposed development will see employment sustained, with the potential for additional employment and economic opportunities to be developed, in the waste industry. All of the proposed alternative fuels and alternative raw
Enervise Limited 95
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016 materials will arrive to site already processed and ready to use with no processing required on site. Therefore the proposed development will sustain and potentially stimulate additional employment and economic opportunity in the waste industry both locally and nationally. The national ‘Action Plan for Jobs 2015’ recognised the importance of the waste recovery industry in generating Irish employment and greening the economy. It cites the National Competitiveness Council’s assessment that Irish infrastructure still lags other countries and recommends that expenditure levels mirror that of comparable countries, particularly in key economic areas such as waste management.
13.5 Conclusion It is considered that the specific subject area with potential to impact on Human Beings has been considered in the preceding sections of this EIS, with particular attention being paid in the areas of Air Emissions, Noise and Traffic.
Currently employing 80 full-time positions in managing a 24-hour operation, and providing approximately 250 positions in local service supply companies, the Quinn Cement plant plays an important role in sustaining critical mass in the Ballyconnell For inspection purposes only. Consent of copyright owner required for any other use. area, thereby achieving more balanced regional development in line with the National Spatial Strategy for Ireland (2002 – 2020).
It is noted that Cavan County generally, but also the Ballyconnell area in particular, has seen significant population growth and that this population growth is estimated to rise in the period 2011-2020.
It is considered that the employment provided by the Cement plant, both directly and indirectly, along with the associated expenditure in the local community have helped fuel this growth and therefore it is considered that this proposal: to burn a controlled fuel derived from waste, to replace a finite hydrocarbon resource,
Enervise Limited 96
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
whilst providing a solution to waste management issues and improving the economic capacity of the Cement Plant, is of tangible benefit to local communities.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 97
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 98
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
14.0 Cultural Heritage This chapter considers the potential impact that the proposed development may have on Cultural Heritage.
14.1 Previous Archaeological Assessments
14.1.1 Original EIS 1997 An EIS accompanied the planning application to Cavan County Council for the development of the existing Cement plant. The Decision (97/682) was appealed and was re-issued by An Bord Pleanála in its decision in 1998 (PL 02.105076).
An Archaeological Assessment was carried out as part of this original EIA process for the proposed cement works. It reviewed the Sites and Monuments Records and concluded that
“there is no evidence of any archaeological remains on or in the area surrounding the site, this does not preclude remains being found during earthworks operations in the development phase of the site”
For inspection purposes only. Consent of copyright owner required for any other use.
Simon Clear, Senior Planning Inspector concurred with the position adopted by Cavan County Council, regarding the potential for archaeological impact and as a result a standard watching brief condition was imposed.
7. The developer shall facilitate the planning authority in preserving, recording or otherwise protecting archaeological materials or features that may exist within the site. In this regard, the developer shall – (a) notify the planning authority in writing at least four weeks in advance of the commencement of any site operation (including hydrological and geotechnical investigations) relating to the proposed development,
Enervise Limited 99
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
(b) employ a suitably qualified archaeologist who shall monitor all site investigations and other excavation works, and (c) provide satisfactory arrangements for the recording and removal of any archaeological material which may be considered appropriate to remove.
14.2.1 EIS 2009 The EIS as prepared in 2009 for the introduction of Solid Recovered Fuel (SRF) at the facility outlined that the proposed development would see all forms of construction take place within the operational confines of the existing Cement Facility. Furthermore, all proposed structures were to be erected on lands that were previously disturbed and archaeologically monitored as part of the erection of the existing facility. Accordingly, it concluded that, there was no potential for impacts upon Cultural Heritage as a result of the proposed development.
14.2 Proposed Development Context It is now proposed to improve the sustainability of the cement plant, through the use of an increased range of waste derived alternative raw materials and fuels with the long term aim of displacing almost all fossil fuels at the plant (a limited proportion
For inspection purposes only. of fossil fuels will be requiredConsent of copyright during owner required process for any other use. start up and for process optimisation/stabilisation). The use of these alternatives will equate to 300,000 tonnes per annum at maximum substitution.
A range of suitable materials are proposed for acceptance at the plant which can be summarised as follows: Solid Fuels – including Solid Recovered Fuel (SRF) which is currently authorised for use at the plant, as well as a range of suitable fuels derived from other sources including: o Meat and Bone Meal (MBM); o Tyre Derived Fuel (TDF); o Biomass Fuels;
Enervise Limited 100
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
o Sludges and Filter Cakes. Liquid Fuels – including Secondary Liquid Fuel (SLF) which is a blend of organic and solvent wastes blended to a defined specification as well as liquid fuels derived from other sources (e.g. waste oils). Alternative Raw Materials (e.g. muds, minerals, sludges).
It is also proposed to include natural gas and petcoke as additional fuels in the Industrial Emission Licence, regulated by the EPA. This is to provide flexibility for any future fossil fuel requirement.
In order to facilitate the use of the aforementioned alternative fuels certain changes are required to the plant as set out at Table 1 which is reproduced again below for ease of reference. This also indicates where the equipment was previously authorised under planning reference 09456 which has now lapsed. Equipment Requirement Previously authorised under Planning Ref: 09/456 Bunded Liquid Fuel tanks SLF and other liquid No and associated feeding fuels Storage
For inspection purposes only. system Consent of copyright owner required for any other use.
Meat & Bonemeal silos and MBM Storage No associated feeding system Lime silos and associated Reduce SOx emissions No feeding system Extension to existing SRF and other Solid Yes, albeit slightly modified in Storage bays and associated Alternative fuels this planning application feeding system (footprint reduced). Induced Draught (ID) Fan Process Yes, no change. Calciner Process Yes, albeit slightly modified in this planning application (elevation reduced).
Enervise Limited 101
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
Based on above it can be seen that the extension to the fuel storage bays, new ID Fan and Calciner were previously assessed in the 2009 EIS and were subsequently authorised under planning reference 09456. These structures are again proposed in the same locations, albeit being slightly modified in design.
The following additional equipment is also proposed: Bunded Liquid Fuel tanks and associated feeding system; Meat & Bonemeal silos and associated feeding system; Lime silo and associated feeding system.
All of the proposed engineering alterations are to be contained within the existing permitted footprint of the Cement Works, with all the infrastructure being situated at ground level (bar the calciner upgrade), in the confines of the existing plant. There will be a requirement for minor civil engineering works to maintain the structural integrity of the proposed infrastructure. However, no significant movement of overburden is envisaged.
14.3 Conclusion For inspection purposes only. Consent of copyright owner required for any other use. The original EIA for the existing cement works found the potential for archaeological impact to be low and as a precautionary approach, a negative condition was imposed that archaeological monitoring be carried out in advance of the construction stage for the whole of the existing industrialised curtilage.
All of the proposed engineering alterations proposed as part of this planning application are to be contained within the same existing permitted footprint of the Cement Works, with all the infrastructure being situated at ground level (bar the calciner upgrades), in the confines of the existing plant.
Enervise Limited 102
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
As the proposed development will result in no alternation to the existing developed footprint it is considered that there is no potential for impacts upon Cultural Heritage in this instance.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 103
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 104
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
15.0 Interactions of the Foregoing The purpose of this Section is to review the inter-relationships, where they exist, of the elements that were deemed to have the potential to have a likely and significant effect, as a result of the Scoping Exercise documented in Section 2 and have been the subject of assessment at Sections 6, 7, 8, 10 & 11 of this Statement and form the Appendices 1 – 5.
It is considered that all of the significant areas have been reviewed in detail and any likely impacts have been recorded and mitigation measures proposed where applicable.
All interactions have been discussed in the relevant Sections and in greater detail within the individual Specialist Reports held as Appendices. However, for ease of reference and to indicate the natural overlap between the potentially significant areas as covered in the Sections outlined above, Table 14 below illustrates the areas of commonality within each Section with respect to the eight specific topic areas, as provided for by the Regulations.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 105
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
Section Section Human Flora Fauna Soil Water Air Climate Landscape Materials Assets/ Headings Beings Archaeology/ in EIS Cultural Heritage
4.0 Planning & √ √ √ √ √ √ √ √ √ Development 6.0 Water Context √ √ √ √ √ √ Environment 7.0 Air Quality & √ √ √ √ √ √ √ Climate 8.0 Noise √ √
10.0 Ecology √ √ √ √ √ √ For inspection purposes only. Consent of copyright owner required for any other use.
11.0 Traffic Impacts √ √ √ √ √ √ √
Table 14: Interactions of EIA elements
Enervise Limited 106
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
16.0 Conclusions This Environmental Impact Statement (EIS) has been prepared on behalf of Quinn Cement Limited.
The EIS considers the environmental aspects within and around the site, which potentially could experience impact as a result of the proposed development.
The Statement considers all potential areas of impact, with particular reference to Water Quality, Air Emissions, Ecology, Noise and Traffic movements that are the elements that have the potential to alter significantly. The findings can be concluded as follows.
The Water Assessment concludes that the incoming materials are delivered and stored in enclosed areas and there will be no wastewater arising from their use. 1. There will be no change in the demand for water and water will be reused as a result of the proposed development; 2. The existing drainage infrastructure will receive no additional/new For inspection purposes only. Consent of copyright owner required for any other use. input of surface water run-off; 3. The implementation of the treatment systems, engineering measures, fluids handling protocol and monitoring schedule proposed to protect groundwater quality will continue to safeguard the surface water environment and water supplies.
The results of Air dispersion modelling indicate that: 1. Impacts on existing pollutant concentrations were not predicted to be significant at any sensitive human receptor location within the assessment extents; 2. In relation to ecological receptors that emissions from the installation would not significantly affect existing conditions at the majority of
Enervise Limited 107
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
designations, with the exception of Moninea Bog SAC where the significance criteria was slightly exceeded for acid gases.
Further to above, from an ecological perspective a Natura Impact Assessment has been carried out to determine the level of impact on Moninea Bog SAC. It concludes that there is no potential for adverse impacts on Moninea Bog, or any other Natura 2000 or Ramsar site, as a result of the proposed development.
An assessment of the potential noise impact from the proposed alterations has predicted that the plant will remain below the day, evening and night noise limit values of 55dB, 50dB and 45dB as outlined by the EPA in Guidance Note for Noise (NG4) at all of the nearest noise sensitive locations.
It is acknowledged that the proposed development will generate additional HGV deliveries. However, it is concluded that the increased traffic would have an insignificant impact on the area when assessed against the baseline flows and the reserve capacity available on the local roads. For inspection purposes only. Consent of copyright owner required for any other use.
As a result of proposed engineering alterations being proposed within the existing permitted footprint of the plant, and work previously undertaken when establishing that site curtilage, the proposed development will not impact on:
1. Either drift or solid geology; or 2. Cultural Heritage.
It is considered that the proposed arrangement of plant will have a negligible impact on the landscape and on visual impact.
Enervise Limited 108
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
The proposed development is considered to have a positive impact from a: 1. Natural resource perspective: through savings on virgin raw materials and imported fossil fuels through the use of waste derived alternative raw materials and fuels respectively; and from a 2. Socio-economic perspective: through employment opportunities provided both directly and indirectly as a result of the proposed development.
Accordingly, it is considered that the proposed development which satisfies local, regional and national policy without having significant or adverse impact on the surrounding environment, can further improve the sustainability of the Ballyconnell cement works.
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 109
EPA Export 25-05-2016:01:00:36
Environmental Impact Statement May 2016
For inspection purposes only. Consent of copyright owner required for any other use.
Enervise Limited 110
EPA Export 25-05-2016:01:00:37