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RUSAL .4 U c, 1-1 1 N I s 1-1

Aughinish AI mina Lt Askeaton, CO, Limerick

IPPC Licence Review Application

Gas-Fired Boiler 4B

May 201 3

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EPA Export 06-06-2013:23:45:07

onmental Protection Agency An Ghniornhoireocht urn Chaomhnd Cornhshaoil

PC) Li

Application Form

€PA Reg. NP: (Office use only)

Environmental Protection Agency P.O. Box 3000, Johnstown Castle Estate, Co. Wexford

Web: www.eDa.ie Ernail: info@eDa.ie Lo Call: 1890 335599 Telephone: 053-9160600 Fax: 053-9160699

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IPPC Application Form V4/12

CONTENTS

SECTION A: NON-TECHNICAL SUMMARY ................................. 1 SECTION B: GENERAL .............................................................. 4 SECTION C: MANAGEMENT OF THE INSTALLATION ............... 12 SECTION D: INFRASTRUCTURE & OPERATION ....................... 13 SECTION E: EMISSIONS ........................................................ 15 SECTION F: CONTROL & MONITORING .................................. 18 SECTION 6: RESOURCE USE AND ENERGY EFFICIENCY ......... 20

SECTION H: MATERIALS HANDLING ...................................... 20

SECTION I: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY .............................................................................. 21

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SECTION 3: ACCIDENT PREWENTION & EMERGENCY RESPONSE ............................................................................................. 23

SECTION K: REMEDIATION. DECOMMISSIONING. RESTORATION & AFTERCARE ................................................ 24 SECTION L: STATUTORY REQUIREMENTS .............................. 24 SECTION M: ADDITIONAL MISCELLANEOUS REEQUESTS ....... 29

SECTION N: DECLARATION .................................................... 31 ANNEX I : TABLES/ATTACHMENTS ........................................... 32 ANNEX 2: CHECKLIST FOR ARTICLE 10 COMPLIANCE .................. 40

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IPPC Application Form V4/12

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i SECTION A: NON-TECHNICAL SUMMARY

This application requests permission to install and operate a new gas boiler of 150 tonnes of steam per hour capacity. This new boiler in combination with the gas boiler permitted in the current IPPC licence (Reg. No. POO35-05), will replace the existing three Heavy Fuel Oil (HFO) fired boilers to supplement CHP steam to meet the steam demands of the alumina production plant at Aughinish Alumina Ltd.

Aughinish Alumina processes bauxite ore from Guinea in West Africa and Trombetas in Brazil to extract its alumina. The alumina is shipped to smelters in Western Europe and Russia to convert i t into aluminium. The conventional Bayer process for alumina production is employed at Aughinish. This entails heating a large recirculating caustic solution stream to 250°Celsius to dissolve the alumina from the bauxite ore followed by residue (mud) separation and then cooling of the caustic aluminate solution to recover pure crystalline alumina hydrate. Following washing to remove entrained caustic, the alumina hydrate is calcined at 1000"Celsius via direct contact with the combustion gas in one of three stationary fluid bed calciners. This de-hydrates the alumina hydrate and converts it into the required gamma alumina crystalline form.

At Aughinish, 450 tonnes per hour of high pressure (HP) steam is required to heat the recirculating caustic stream. This steam is generated at present via:

A Combined Heat and Power facility consisting of two gas turbines and two heat recovery steam generators that produce 160 MW of power and 300 tonnes per hour steam in total. Operation of two (of three available) conventional heavy fuel oil (HFO) boilers with capacity of 200 tonnes per hour steam each. The required 150 tonnes per hour of HP top-up steam is generated in this manner so that if one HFO boiler trips the other operating boiler can increase steam output automatically and avoid a steam supply interruption. When a CHP unit is out of service it is normal to operate all three HFO boilers for the same reason.

Calcination of alumina hydrate into gamma alumina requires a further 75 kg HFO/tonne alumina or 3.1 GJ natural gas/tonne alumina.

The' new gas boilers (i.e. the yet-to-be-constructed gas boiler 4A and the proposed gas boiler 4B addressed in this application) will be located, to the immediate south of the existing three HFO boilers.

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The new boiler will be equipped for natural gas firing only and will incorporate flue gas recirculation and low NOx burner technology. They will be compliant with the future ELV's to be introduced in 2016 under the EU Industrial Emissions Directive (2010/75/EU), which is currently being transposed into Irish legislation. The ELV for NOx will be 100 mg/Nm3 compared with 750 mg/Nm3 for the existing HFO boilers. The HFO boilers will be retained as strategic back-up steam generators.

The above project has been facilitated by the availability of a natural gas supply to Aughinish as part of the construction of a large CHP plant which commenced operation in 2006. The gas pipeline was sized to accommodate future possible use of natural gas in both calcination and in the boiler-house. Conversion of the calciners to dual fuel capability (i.e. natural gas and HFO) has taken place in the past number of years and is permitted and has already led to a significant reduction in SOX emissions from the Aughinish facility.

This project will increase the environmental and economic sustainability of the Aughinish Alumina plant. It is vital to Rusal Aughinish Alumina's economic sustainability that it can capitalise quickly on this opportunity to make significant energy cost savings and at the same time configure the plant for improved environmental performance.

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IPPC Application Form V4/12

Economic Importance of the Project

The principal uses of energy in the Bayer process are for:

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Steam generation to heat the caustic solution in digestion Heat energy to calcine the intermediate alumina hydrate Electrical power to drive conveyors, crushers, grinding mills, pumps, agitators etc.

The digestion process at Aughinish requires 5.8 GJ of steam /tonne of alumina or 450 tonnes/hour of high pressure steam. Aughinish is equipped with 2 CHP units that generate 160 MW of power and produce 300 tonnes/hour of high pressure steam. The balance of 150 tonnes/hour of steam comes from three HFO boilers. For process security Aughinish operates 2 of the 3 HFO boilers at reduced rates.

Calcination requires 3.1 GJ of heat per tonne of alumina. This was provided by 75 kg of HFO per tonne alumina until 2011 when Aughinish converted the calciners to natural gas.

Electrical power usage at Aughinish is 200 kWhr/tonne.

Energy costs account for almost 35% of the total operating cost at Aughinish. Approximately one quarter of the 35% relates to the use of relatively expensive HFO in the 2 top-up steam boilers. Over the past 2 years the price of natural gas has reduced due to the advent of shale gas whereas the price of HFO has almost doubled due to political unrest in the Middle East. By installing gas fired boilers to replace the existing HFO boilers, the cost of the top-up steam will be reduced dramatically. Overall i t will reduce the energy costs from 35% to approximately 31% of total cost. I n money terms this represents an operating cost saving of €16 million per annum. This is a significant saving at any time but in the present depressed alumina market it will move Aughinish from a loss making position to close-to breakeven. A t present the cost differential in the fuels gives this project a 15 month payback.

Environmental Benefit of the Project

A further significant benefit of installing new gas fired boilers now is that i t will enable Aughinish to comply with the onerous ELV's for large combustion plant required under the Industrial Emissions Directive (IED). Aughinish has evaluated the feasibility of converting the existing HFO boilers to fire natural gas in order to secure the energy cost savings and to prepare for the IED. This study has concluded that the least cost and least risk approach is to build two new stand-alone gas fired boilers and to mothball the three existing HFO boilers. This is due to the following:

(1) Difficulty of retrofitting 30 year old HFO boilers to comply with the IED ELV's. (2) Risk of converting an operating HFO boiler house to natural gas without incurring

production down-time. (3) Possibility to retain the mothballed HFO boilers as strategic back-up to natural gas

via the flexibilities available under the IED. This would not be possible if the existing boilers were converted to natural gas (due to the Common Stack ruling).

An estimate of the impact of one and then two gas fired boilers on emissions to air is shown in the Table below.

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~ _ _ _ ~

IPPC Application Form V4/12

. . Site total with l G a s boiler

Site total with 2 gas boilers .____.l______.l__l_._______._._.._ _ _ _ i _ _ _ E!-_/ ~

% reduction ! 38%1 88%! 34% I 255 I

Table 1 - Impact of gas boilers on site emissions to air *tpy = tonnes per year

Use o f natural gas imposes a number of significant design, operational and maintenance requirements on an industrial facility. All of these requirements are well understood at Aughinish Alumina as the plant has operated a natural gas fired CHP facility since 2006 and the calciner units were converted to natural gas during 2010 and 2011. All of the ATEX requirements fo r gas firing plant will also be incorporated into the proposed new gas fired boilers. 0

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IPPC Application Form V4/12

SECTION B: GENERAL

6.1. Owner/Operator

Name*: Auqhinish Alumina Limited Address: Auqhinish Island

As kea ton Co. Limerick

Tel: 061-604000 Fax: 061-604242 e-mail: Lia m . f lem i ng @auq h .com

Name and Address for Correspondence

Name: As above Address:

Tel: Fax: e-mail:

CRO No. and address of registered or principal office of Body Corporate

CRO No. 59982 Address: As above

Tel: Fax: e-mail:

A Certified Copy of the Certificate of Incorporation is included as Attachment 6.1.

Name and address of the proprietor(s) of the Land on which the Activity is situated (if different from applicant named above):

Proprietor’s Name: As above Address: As above

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Fax: e-mail:

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IPPC Application Form V4/12

National Grid Reference (12 digit 6E,6N)

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128047E 153392N (centre of site)

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Name o f geo-referenced digital drawinq files Name of CD-Rom with diqital drawinq files

Name and address of the owner(s) of the building and ancillary plant in which the activity is situated:

IPPCL 00IPPCL092.DWG

Digital Drawing File & Table E.6/F.3

Name: As above Address: As above

I Tel: Fax: e-mail:

A map showing the extent of the landholding owned by Aughinish (outlined in blue) is included as Attachment B.2 Map 1.

8.2. Location of Activity ~~ ~

Name: Auqhinish Alumina Limited Add ress : Aughinish East, Aughinish West, Island Mac Teige, Glenbane

West, Fawnamore As kea ton

A site location map showing the boundary of the licensed activities in red is included as Attachment B.2 Map 2 (Figure A.2.1).

A site plan showing the location of the proposed boiler, the associated stack emission point and all the main licensed air emission points, is included as Attachment 8.2 Drawing 1 (Figure 8.2.2).

The corresponding digital drawing file (IPPCL 00IPPCL092.DWG) is included on a separate CD-Rom containing sections 8.2, E.6 and F.3.

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IPPC Application Form V4/12

B.S.(a) is not required

B.5. (c) is beinq processed B.5.(b) has been obtained

B.3. Class of Activity

4

5.13 (e)

Local Authority Planning File Reference NQ:

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Description The production of basic inorganic chemicals such as: non- metals, metal oxides or other inorganic compounds such as calcium carbide, silicon, silicon carbide [Principal Class] The operation of combustion installations with a rated thermal input equal to or qreater than 50 MW The recovery or disposal of waste in a facility, within the meaning of the Act of 1996, which facility is connected or associated with another activity specified in this Schedule in respect of which a licence or revised licence under Part I V is or will be required.

13/164

6.4. Employees/ Capital Cost

I I Number of Employees (existing facilities): 1 450 I I Gross Capital Cost (new proposals) C If10 million

8.5. Relevant Planning Authority and/or Public Authority

Give the name of the planning authority in whose functional area the activity is or will be carried out.

Name: Limerick County Council Address: County Hall

Dooradoyle Co. Limerick

Tel: 061-496000 Fax: 06 1-49600 1.

Planning Permission relating to this application:

B. 51b 1 Planninu permission already wanted

Planning permission (File No, 13/164 amending File No. 12/343) has been granted by Limerick County Council for the second of two proposed gas boilers (Gas Boiler 48, emission point ref. A4-B) for which IPPC approval is sought in this application. Planning permission (File No. 12/343) has also been granted by Limerick County Council for the other proposed gas boiler (Gas Boiler 4A, emission point ref. A4-A), which is permitted under the current IPPC Licence POO35-05. Attachment B.5.1 contains the report by planning consultants Tom Phillips & Associates which accompanied the planning application. Attachment 8.5.2 contains a copy of the grant of planning permission by Limerick County Council and Attachment B.5.3 contains a copy of the planning report and confirmation from LCC that an EIS was not required for the proposed development by or under the Planning and Development Act 2000, as amended.

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IPPC Application Form V4/12

A summary of all previous planning permissions granted for the site of the activity is given below:

Planning File No.

Decision Date Description Status

Amendment of planning reference no. 12/343 for provision of 2 no. 150 tonne per hour gas- fired steam boilers, all within a maximum width of 30.00m and maximum height above ground of 18.00m; including 2 no. 32m high exhaust stacks with an external diameter of 3.0m each; and all other associated site development works above and below qround Demolition of all structures within a disused farm complex, including a disused dwelling house, 7 no. outbuildings/sheds, a corrugated iron clad barn and the concrete walls surrounding the yard areas. The development will also consist of the breaking up of concrete hardstandings and yard areas and restoration of the site to a qreenfield state. Installation of a 150 tonne per hour gas-fired .

steam boiler with a maximum length of 31.32m, maximum width of 24.15m and maximum height above ground of 18.00m, and a 32m high exhaust stack with an external diameter of 3.0m and all other site development works above or below qround Construction of a Bauxite Residue Disposal Area (circa 80 hectares in area to 32m in height above mean sea level) on adjoining lands to south of existing Bauxite Residue Disposal Area etc. Construction of a) extensions to north and south ends of existing bauxite storage shed no. 2; b) covered and elevated conveyor; c) bauxite storage silo; d) grinding mill building; e) slurry storaqe tank Construction of a 300 megawatt combined Heat & Electrical Power Generation Plant & conversion later to a 390 megawatt gas turbine station to include a gas turbine generator, stacks, control building, gas & switchgear compounds, oil tank, etc.

Extension to existing sports complex

Ground floor & first floor extension to existing Local Two Amenitv Buildina

Permission Granted 1 6/ 0 5/20 1 3 13/164

13/161

12/343

0 Permission Granted 16/05/2013

Permission Granted 25/06/20 12

Permission Granted 35/1836 15/05/2006

0 Permission Granted 341262 2 6/0 3/20 04

Permission Granted 30/900 0 9/06/2 00 0

Permission Granted Perm i ssi o n Granted

371672

371961

2 7/06/ 199 7

10/ 10/1997

30/08/ 1996

2 6/07/ 199 6

96/2165 Erection of Hydrate storage building Permission Granted Permission Granted Permission Granted

96/1946 Extension to Red Mud Processing building

961 178 1 Construction of first floor extension to existing marine termina I administration building

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IPPC Application Form V4/12

Decision Date

Planning File No. [cont. )

3511021

351839

Description

Extension to sports complex

Status

'e r m i ssi o n 3ra n ted 'erm ission 3 ranted

29/09/1995

[nstallation of product conveyor and loading machine at marine terminal Zonstruction of alumina hydrate seed filtration Aant Extension of existing bauxite residue storage area. Was accompanied by EIS. A condition limited the height of the extended BRDA to 26m (27m AMSL). Zonstruction and operation of a clarifier feedwater surge pond as part of effluent treatment system Erection of single storey instrument/electricaI maintenance workshop within Section 1 of existinq alumina plant Erection of one storey office and control room building within section 5 of existing Aughinish Alumina Plant Construction and operation of an auxiliary liquor quality control facility within existing Alumina Extraction Plant Construction of second storey office extension over existing single storey service building Erection of single storey metal corrosion testing shed Upgrade existing alumina plant to a rated processing capability of one million metric tonnes alumina per annum Erection of 3 heater towers adjacent to existing bauxite pre-desilication tanks and a replace men t sand classification bu i Id i nq Erection of three bay portal framed sheeted shed over retained in-site cast concrete for slab for filter sand drainaqe

Erection of sports complex and site works

Partial change of location of Bauxite Impoundment Area on Aughinish Island to move same further in on island. The conditions also referred to environmental and developmental issues in the plant. Erection of sign adjoining public road indicating Aughinish Alumina Project Complete plant for processing of bauxite to alumina including ship berthing piers, bulk storages, handling services and all ancillary equipment and buildings necessary for an integrated plant at Aughinish Island, Co. Limerick. The permission related to the construction of a plant for the production of 800,000 metric tonnes of alumina per annum.

11/08/1995

21/07/1995 'ermission I

3ra n ted

Derm i ss i o n Sra nted

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351737

12/11/1993

21/05/1993

3311133

331465 De r m i ss i o n S ra n ted

Der m i ss i o n Sra n ted 1 5/0 2/ 199 1 311154

Derm ission Sra nted

Permission S ra n ted

Permission Sra n ted Permission Granted

Permission Granted

Perm i ss i o n Granted

31/08/1990 901966

0 3/ 0 8/ 1990 901871

2 0/07/ 199 0 90181 1

16/0 3/ 199 0 901242

26/05/1989 891511 ~

891510

88129312

26/05/1989

Permission Granted 02/ 12/ 1988

Permission Granted

Perm iss i o n Granted

03/08/ 1984 8412446 1

09/02/1979 79115737

Permission Granted

Permission Granted

09/0 2/ 1979 7911 5820

30/09/1974 7418580

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IPPC Application Form V4/12

Environmental Impact Statement

Section 5 (pages 10-13) of Attachment 8.5.1 explains the basis for determining that an EIS was not required. Firstly, the proposed development, considered both as a standalone development and in combination with the previously permitted and licensed gas boiler 4A, does not meet the thresholds (for MW heat output and increases in size) under Schedule 5 of the Planning and Development Regulations 2001-2012 which sets out the relevant thresholds for different classes of development for the purposes of establishing if an Environmental Impact Assessment is required. ( In point of fact as there is no change in the Production Capacity permitted the project merely replaces HFO generated steam by natural gas generated steam). On that basis, it is concluded that an EIA is not required. Note that an EIS accompanied the planning application and subsequent IPPC application for the construction of a 300MW natural-gas fired CHP plant in 2000 (planning ref. 00/900) and that the constructed and commissioned plant utilises only 160MW of the permitted capacity which was subjected to an EIA.

The Planning Application report also concluded that the proposed boiler will not have 'a significant effect on the environment. On the contrary, the shift from the use of heavy fuel oil to cleaner, more efficient gas will contribute to the achievement of significant reductions in the associated air emissions. As there will no significant adverse impact, the proposed development would not be subject to the requirement for a sub-threshold EIS (required in certain circumstances where the development is likely to have significant effects on the environment).

Article 8 sub-article 5 of the European Union (Environmental Impact Assessment) (Integrated Pollution Prevention and Control) Regulations 2012 requires the planning authority (in this case Limerick County Council) to request observations from the EPA to determine whether an EIS was required to accompany planning application 13/164. Page 2 of the planners report in Attachment 8.5.3 indicates that Limerick County Council consulted the EPA about the proposed development.

Licences and Dermits

Attachment 8.5.4 contains a table of references to all licences and permits past and presently in force at the time of submission.

ApDropriate Assessment . .

As the Aughinish Alumina plant is located close to two Natura 2000 sites (River Shannon and River Fergus Estuaries SPA8 and the Lower River Shannon cSAC9), an Appropriate Assessment Screening Report for the proposed development, was carried out by RPS. The Screening Report has been prepared with reference to all relevant National and European guidance documents and assesses the potential impacts - both direct and indirect - of the proposed works on the above-mentioned Natura 2000 sites', Having undertaken this assessment, the Screening Report concludes that: "It is not considered that the construction or operation of the proposed gas fired boiler and exhaust stack could result in any negative impact on the Conservation Objectives of either the Lower River Shannon cSAC or the River Shannon and River Fergus Estuaries SPA. As no impacts, either significant or non-significant, have been identified, significant cumulative impact with other plans and projects cannot occur. Stage 2 Appropriate Assessment of the proposed project is therefore not required". A copy of the RPS Appropriate Assessment Screening Report is in Attachment 8.5.5.

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IPPC Application Form V4/12

8.6. Relevant Water Services Authority

Aughinish Alumina does not discharge effluent to a local authority sewer. Aughinish Alumina has its own on-site treatment plants for process and sanitary effluents and treated effluent is discharged to the Shannon Estuary under the conditions of the IPPC I ice nce . Name: Not Applicable Add ress:

Tel: Fax:

8.7. Relevant Regional Health Service Executive

The applicant should indicate the Regional Health Service Executive where the activity is or will be located.

Name: Health Service Executive West Address: Ashbourne Hall

Ashbourne Business Park Dock Road Limerick

Tel: 061-461 505 Fax: . 061-461503

B.8 Site Notice, Newspaper Advertisement and Planning Authority Notice

Attachment B.8 contains a copy of the text of the site notice, a map showing its location on site (in accordance with Article 7 of the Regulations) and a copy of the newspaper advertisement. A copy of the notice sent to Limerick County Council Planning Department is also included.

B.9 Seveso I1 Regulations

The EC (Control of Major Accident Hazards involving Dangerous Substances): Regulations (S.I. No. 74 of 2006) does not apply to the activity/establishment.

I n Sections B.10 and B.11, the activities of the installation/industrial facility at Aughinish are categorised in accordance with those specified in both the IPPC Directive (2008/1/EC) and the Industrial Emissions Directive (2010/75/EU). I t is understood that the Industrial Emissions Directive (and legislation transposing i t in Ireland) will supersede the IPPC Directive.

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IPPC Application Form V4/12

Ca teqory Description Chemical installations for the production of basic inorganic chemicals such as: non-metals, metal oxides or other inorganic compounds such as calcium carbide, silicon, silicon carbide [Principal Cateqory]

Combustion installations with a rated thermal input exceeding 50MW

4.2(e) -

1.1

B.10 IPPC Directive

Category

4.2 (e)

1.1

5.1

5.4

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Description Production of inorganic chemicals such as: non-metals, metal oxides or other inorganic compounds such as calcium carbide, silicon, silicon carbide [ Pri nci pa I L a teqory]

Combustion of fuels in installations with a rated thermal input of 50MW or more

Disposal or recovery of hazardous waste with a capacity exceeding 10 tonnes per day involving one or more of the activities listed in 5.1 (a) - (k) Landfills, as defined in Article 2(g) of Council Directive 1999/31/EC on the landfill of waste, receiving more than 10 tonnes per day or with a total capacity exceeding 25,000 tonnes excluding landfills of inert waste.

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The installation falls under the following categories of activity referred to in Annex I of the IPPC Directive (2008/1/EC):

Installations for the disposal or recovery of hazardous waste as defined in the list referred to in Article l ( 4 ) of Directive 91/689/EEC, as defined in Annexes I1 A and I1 B (operations R1, R5, R6, R8 and R9) to Directive 2006/12/EC and in Council Directive 75/439/EEC of 16 June 1975 on the disposal of waste oils with a capacity exceeding 10 tonnes per day

Landfills receiving more than 10 tonnes per day or with a total capacity exceeding 25,000 tonnes, excluding landfills of inert waste

5.1

5.4

Note: Submission being made t o Agency t o determine whether Categories 5.1 and 5.4 still apply in l ight of categorisation of Aughinish Bauxite Residue Disposal Area (BRDA) as Category A under Extractive Waste Directive

B.11 Industrial Emissions Directive

The activity falls under the following categories of industrial activity referred to in Annex I of the Industrial Emissions Directive (2010/75/EU) and in Article 23 of the European Union (Industrial Emissions) Regulations 2013 (S.I. No. 138 of 2013) amending the First Schedule of the 1992 EPA Act:

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IPPC Application Form V4/12

SECTION C: MANAGEMENT OF THE INSTALLATION

c. 1 Site Management & Control

The proposed development will not involve any changes to the management structures for the activity detailed in previous licence applications. Emissions monitoring and control procedures will be similar to existing procedures and will be incorporated into the environmental management system. The site Environmental Management System (EMS) Manual is included as Attachment C.1. This describes the management structure (page 18) and contains organisational charts, the environmental management policy statement (page 12) and includes details of on- going assessment of environmental performance.

c.2 Environmental Management System (EMS)

The facility is accredited to IS0 14001 - certificate included as Attachment C.2

c.3 Hours of Operation

a) Proposed hours of operation: 24 hours per day, 365 days per year b) Proposed hours of construction and development works and timeframes: 12-18

months c) Any other relevant hours of operation expected: N/A

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SECTION D: INFRASTRUCTURE & OPERATION

I

D. 1 Operational Information Requirements

D . l . l Existing

The Bayer process is employed at Aughinish Alumina to produce smelter grade alumina. A site plan is provided as Attachment D Drawing 2, The process consists of crushing and grinding of bauxite ore to facilitate selective extraction of the approximate 50% available alumina in a caustic aluminate solution. This alumina dissolution or 'digestion' is conducted at 250" Celsius to give acceptable kinetics and a high alumina content per unit of caustic solution. After digestion, the insolubles present in the bauxite are separated from the aluminate solution and sent to the mud circuit for thorough washing and disposal. The clarified caustic aluminate stream is then sent to a tank farm of 'precipitators' where it is cooled and seeded to crystallise out the alumina as alumina hydrate. The alumina hydrate is then washed, dried on filters and then fired in a direct contact fluidised bed to produce smelter grade gamma alumina. The alumina is shipped to various aluminium smelters in Western Europe and Russia for electrolytic reduction into pure aluminium metal.

At Aughinish, 450 tonnes per hour of high pressure (HP) steam is required to heat the recirculating caustic stream. This steam is generated at present via:

0 A Combined Heat and Power facility consisting of two gas turbines and two heat recovery steam generators that produce 160 MW of power and 300 tonnes per hour steam in total. Operation of two (of three available) conventional heavy fuel oil (HFO) boilers of capacity 200 tonnes per hour steam each. The required 150 tonnes per hour of HP (high pressure) top-up steam is generated in this manner.

0

Calcination of alumina hydrate into alumina requires a further 75 kg HFO/tonne alumina or 3.1 GJ natural gas/tonne alumina.

At present the generation of the top-up steam via HFO boilers is excessively costly and also involves the emission of SOX, NOx and dust due to the nature of HFO. Furthermore CO2 is emitted at the rate of 3.25 tonnes per tonne of HFO combusted. Aughinish wishes . to improve its cost of energy and reduce associated emissions by converting from HFO to natural gas.

D.1.2 Proposed

This licence application addresses the installation of one new stand-alone gas fired boiler of 150 tonnes steam per hour capacity, which, in combination with the licensed gas boiler, will replace the three existing HFO boilers in terms of steam generation for use in production. The two new gas boilers will be located to the immediate south of the existing three HFO boilers. They will provide the required top-up steam and the HFO boilers will be mothballed but maintained as a strategic back-up in the event of a prolonged natural gas outage or shortage. There is also the possibility that one HFO boiler will be operated whenever one of the gas boilers or CHP units if offline for planned mai ntenance . Unlike the CHP Plant (Emission Point Refs. A3-A and A3-B), which is also powered by natural gas, distillate oil back-up to the new gas boilers will not be required given that the existing HFO boilers will remain on stand-by.

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The new boilers will be equipped for natural gas firing only and will incorporate flue gas recirculation and low NOx burner technology. They will be compliant with the future ELV's to be introduced in 2016 under the Industrial Emissions Directive. The ELV for NOx will be 100 mg/Nm3 compared with 750 mg/nm3 for the existing HFO boilers. Attachment D contains schematics, drawings and 3D model images of both the licensed gas boiler (4A) and the proposed gas boiler (4B). Drawings illustrating the layout of the gas supply infrastructure are also included.

Attachment D Drawing 2 Attachment D Drawing 3 Attachment D Drawing 4 Attachment D Drawing 5 Attachment D Drawing 6 Attachment D Drawing 7 Attachment D Drawing 8 Attachment D Drawing 9 Attachment D Drawing 10 Attachment D Drawing 11 Attachment D Drawing 12

Attachment D Drawing 13

Attachment D Drawing 14

Attachment D 3D Images

Pictorial View of the Plant Schematic of Existing Utility Plant Configuration Schematic of Licensed & Proposed Gas Boilers Site Location Plan of Proposed Gas Boiler Site Layout Site Section A-A looking west Site Section B-B looking north Contextual Elevations 1-1/ 2-2 Contextual Elevations 3-3/ 4-4 Plan of Proposed Gas Boiler Drawing of Bord Gais Gas Supply into Aughinish Above Ground Installation (AGI) Drawing of Gas Pipebridge from AGI to Existing Combined Heat and Power Plant (CHP) Schematic of Gas Pipeline to Existing Calciners and Boiler-house 3D Model Images of Licensed & Proposed Gas Boilers

D.2 Development & Operational History of the Site

Aughinish Alumina commenced operation in 1983 as a 800,000 tpa (tonnes per annum) alumina refinery. In the intervening years, the refinery has been modernised and expanded and is now operating at 1.95 million tpa alumina production rate. Originally a joint development between Alcan, Billiton and Anaconda, Aughinish became wholly owned by United Company RUSAL in 2008. UC Rusal is one of the largest integrated a Iu mi niu m com pa ny worldwide.

Approximately 70% of the bauxite processed by AAL is imported from Guinea in West Africa with the remainder coming from Trombetas i n , Brazil. The finished product, alumina, is exported for further processing through smelting to aluminium metal. Aughinish currently accounts for more than 35% of EU alumina production.

The Aughinish plant received an IPPC licence from the EPA for the first time in 1998. This licence was updated in 2004 to incorporate a new 160' MWe gas fired Combined Heat and Power Plant and again in 2008 to incorporate a 78 hectare extension to the BRDA. The most recent licence review, carried out in 2012, incorporated new requirements related to new Extractive Waste, Surface Water and Groundwater Regulations. This review classified the Aughinish BRDA as a Category A extractive waste facility. A t the same time a 150 tph (tonnes per hour) steam gas fired boiler was incorporated into the licence.

AAL operates under an onerous IPPC licence as befits an energy intensive facility producing a high volume of alumina and landfilling the resultant extractive waste on- site. Despite this AAL achieves a high level of compliance and this is recognised by the EPA through the routine compliance monitoring and on-site auditing conducted by the Agency. Since first being licenced in 1998 AAL has not received any Section' notices. The only significant licence non-compliance in the history of the plant was an

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administrative ‘Failure to notify the Agency as soon as practicable‘ following a spillage of dilute caustic during re-start of the plant following the annual shutdown in 2001.

SECTION E: EMISSIONS

E . l . Emissions t o Atmosphere

E.1.A. Details of all Point Emissions to Atmosuhere

Condition 5 and Schedule B . l (Attachment E . l . l ) of the current IPPC Licence detail the emission requirements and emission limits for all existing emissions to atmosphere. There are 17 IPPC licensed point emissions to air at Aughinish. The 5 primary sources of emissions to air are the existing HFO Boilers (Emission Point Ref. A l ) ; the Calciners (Emission Point Ref. A2); the Combined Heat and Power Plant (CHP) or Gas Turbines (Emission Point Refs. A3-A and A3-B) and the new Gas Boiler (A4-A) which is yet to be commissioned. The remaining 12 emission points include 9 dust extraction units associated with bauxite and alumina handling and conveying operations at the plant (Emission Point Refs. 5, 6, 8, 11, 12, 16, 17, 18 and 19) and 3 diesel fired boilers for heating buildings (Emission Point Refs. 13, 14 and 15).

The only change requested to Schedule B . l (Attachment E. l .1 ) is the addition of emission point A4-B.

There is one proposed new emission point A4-B associated with the new natural gas fired boiler. As combustion of natural gas does not generate any meaningful levels of SOX or particulates the main emission of interest will be NOx. These new boilers will be specified to utilise BAT for emission control and comply with the ELVs associated with the Industrial Emissions Directive 2010/75/EU. The NOx ELV of 100 mg/Nm3 will be achieved via a combination of flue gas recirculation and dry low NOx burners.

Details of the new and modified point emissions to atmosphere for the new gas boiler are appended in Table E.l(i).

A summary Table of new/modified emission points and the corresponding drawing are both included in Attachment E.1.2.

E.l.B. Fuaitive and Potential emissions

The only (minor) change in fugitive and potential emissions arise in the gas supply to the new boiler. The gas pressure reduction station is equipped with a vent to atmosphere. This vent is activated when the double block valves are closed to shutoff gas to the pressure reduction station. I n this scenario, a 2” bleed valve situated between the block valves opens to vent the contents contained between the two block valves (approximately 1 litre) safely to atmosphere. A similar double block and bleed arrangement will be employed on the gas supply to the new gas fired boiler.

Details of fugitive and potential emissions are listed in Table E. l (v) and illustrated in Attachment E.1.3 Drawing 15.

E.2 Emissions t o Surface Waters

There will be no new emissions to surface waters arising from the proposed gas boiler. Emissions will remain unchanged from what is permitted under the current IPPC Licence. Emission limits are specified in Schedule 6.2 and control and monitoring requirements are specified in Schedule C.2.1, C.2.2 and C.2.3.

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E.3 Emissions to Sewer

There will be no emissions to sewer from the proposed gas boiler installation. There are no emissions to public sewer at Aughinish. There is an on-site effluent treatment plant for the treatment of sanitary effluent on-site. The treated effluent is discharged in combination with treated industrial effluent at licensed emission point W1-1.

E.4 Emissions to Ground

There are no emissions to ground at Aughinish and there will be no emissions to ground associated with the proposed gas boiler.

A network of groundwater monitoring wells is in place to monitor groundwater quality in accordance with Condition 6.15 and Schedule C.8 of the current IPPCL POO35-05. No changes are proposed as part of this application.

Small quantities of excess sanitary sludge from the aeration tank in the biological sanitary treatment plant are land-spread periodically on fallow lands in the north- western part of the site. This activity was permitted in earlier licences granted to Aughinish Alumina by the Agency but is not mentioned in the current licence (P0035- 05). Aughinish will make a separate submission regarding this activity in due course.

E.5 Noise Emissions

AAL is required to carry out an annual noise survey in accordance with Conditions 4.5 and 6.16 of the current IPPC Licence. Schedule 8.4 sets out the relevant noise limits at off-site noise sensitive locations (NSL) as:

0 Day-time: 55 dB (A) Le, 0 Night-time: 45 dB (A) Le,

Aughinish complies with the above limits and submits the survey reports as part of the Annual Environmental Report.

As part of the 2012 annual noise survey required by the existing licence, Aughinish undertook an evening-time noise survey (time period 19:OO - 23:OOhrs) and compared the results to the new evening-time guideline value of 50dB(A) specified in The Agency’s Guidance Note for Noise: Licence Applications, Surveys and Assessments in Relation to Scheduled Activities (NG4) (2012). The survey concluded that Aughinish was in compliance with the evening guideline value of 50 dB(A).

The new boiler will be specified to comply with applicable Health & Safety requirements, with existing day-time (55dB(A)) and night-time (45dB(A)) IPPC licence noise limits and with the new evening-time guideline value of 5OdB(A). The stack tip noise level will be less than 99 dBA at 1 metre. The forced draft fans supplying combustion air shall be less than 85 dBA at 1 metre. The boiler relief valves shall be equipped with silencers.

E.6 Tabular Data on Emission Points

The new and modified emission points are summarised in Table E.6.

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0 Parameter

Nitroqen Oxides (as NOz) Carbon Monoxide Oxides of Sulphur (as SOz)

IPPC Application Form V4/12

Emission Limit Value ( mg/m3)

100 100 35

E.7 Sum ma ry

Should this application for a new gas boiler meet with Agency approval, Aughinish propose the insertion of the following text to Schedule B . l of the current IPPC Licence.

Schedule 6: Emission Limits

6.1 Emissions to Air

Emission Point Reference No. : Location : Volume to be emitted: Maximum rate per hour: 130,000m3 Minimum discharge height:

A4-B (Gas Boiler No. 2 Stack) Boiler House Area 14

32m above ground

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SECTION F: CONTROL & MONITORING

F. 1 Treatment, Abatement and Control Systems

The three existing boilers are fuelled by heavy fuel oil and the main resultant pollutants are oxides of sulphur (as SO2)! nitrogen oxides (NO,) and particulates. Compliance with the SOz ELV of 1700 mg/Nm3 is achieved by combusting low S HFO. The NOx ELV of 750 mg/Nm3 is achieved through use of low NOx burners and advanced regulatory combustion control to reduce the air:fuel ratio in order to minimise NOx and achieve the target low excess O2 in the stack gas. Feedback tr im from both CO and opacity monitors ensures that the air:fuel ratio does not reduce below the minimum for full stoichiometric combustion. Particulate emissions are minimised via contractual limits on sediment and ash in the HFO. All three boiler flues emit via a common stack.

The three calciners are equipped with high efficiency Electro-static Precipitators (ESP’s) which are considered BAT for particulate emissions control and achieve particulate emission levels significantly below the ELV of 50mg/ Nm3. The calciners can be operated on HFO or natural gas and the three flues also emit via a common stack.

The CHP plant consists of 2 gas turbines with a capacity of -80MW each utilising natural gas with distillate oil available for back-up purposes. The turbines drive generators to generate electricity and the exhaust gases are recovered via heat recovery steam generators (HRSG’s) to generate 150 tph each of steam at high pressure which is subsequently used in the process plant. Exhaust gases exit to the atmosphere via two stacks, one for each turbine. The use of natural gas as the main fuel instead of oil eliminates SOX emissions and the use of low NOx burners reduces NOx emissions.

The three small diesel boilers used for heating buildings are fired on gas oil with less than 0.2% sulphur. There are no emission limits set for these small boilers and there is no requirement to monitor emissions.

Existing control and monitoring requirements as per Schedule C . l . l and C.1.2 are provided in Attachment F . l . l . The only change requested is the addition of control and monitoring requirements for the proposed new emission point A4-B.

The new gas fired boilers will be equipped with flue gas recirculation and dry low NOx staged combustion burners in order to comply with the strict ELV of 100 mg/Nm3. Advanced regulatory control will be utilised in a similar manner to combustion control of the existing HFO boilers. I n this manner, the combustion control system will reduce the air:fuel ratio in order to minimise NOx and achieve the target low excess O2 in the stack gas. Feedback trim from both CO and opacity monitors will ensure that the air:fuel ratio does not reduce below the minimum for full stoichiometric combustion. Each boiler will exhaust to a stand-alone stack.

F.2 Emissions Monitoring and Sampling Points

The monitoring and sampling point for emissions to air from the proposed gas boiler is listed in Tables F2(i), F2(ii) and F2(iii).

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As emissions to air reduce through switching from HFO to natural gas, the existing ambient air monitoring programme is adequate and will remain unchanged.

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Control Parameter

N OX

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Monitoring Key Equipment Note

Routine inspection of equipment

Dry low NOx burners

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CO, 02, temperature, pressure, water vapour Note '

F.3

Table F.3 lists the new emission point - the new gas fired boiler stack (A4-B).

F.4 Summary

Should this application for a new gas boiler meet with Agency approval, Aughinish propose the insertion of the following text to Schedule C of the current IPPC Licence.

Tabular Data on Monitoring and Sampling Points

L

Continuous mon i tori nq Continuous monitoring Com bustion

management

Schedule C: Control & Monitoring

Opacity

C. l . l Control of Emissions to Air

Continuous passive Opacity meter

Emission Point Reference No. : A4- B Description of Treatment: Gas Boiler Stack Dispersion

Flame Photo-cell permissive Flame scanner

Parameter

Nitrogen Oxides (as NOz)

Carbon Monoxide

Oxides of Sulphur (as SO2)

Dust

Monitoring Frequency Analysis Met hod /Tec h n iq ue

Continuous I R absorption analyser

Continuous

Biannually

Biannually

To be agreed by the Agency To be agreed by the Agency To be agreed by the Aqency

I I Note 1: The licensee shall maintain appropriate access to standby and/or spares to ensure the operation

of the abatement system. Note 2: Continuous measurement of water vapour content is not required where the sampled gas is

dried before analysis.

C. 1.2 Monitoring of Emissions to Air

Emission Point' Reference No. : A4-6

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SECTION G: RESOURCE USE AND ENERGY EFFICIENCY

G . l and energy which will be produced by or utilised in the activity.

List of the raw and ancillary materials, substances, preparations, fuels

The Bayer process is an energy intensive hydro-metallurgical process. The principal uses of energy in the Bayer process are for:

Steam generation by boilers and gas turbines to heat the caustic solution in digestion; Direct heat energy to calcine the intermediate alumina hydrate and convert it into gamma alumina; Electrical power to drive conveyors, crushers, grinding mills, pumps, agitators and other electrical equipment.

- - - -

The Aughinish site uses both natural gas and HFO for combustion at present. Conversion of the site to natural gas as the primary fuel with HFO facilities retained as strategic back-up for boilers and calciners will not alter the chemicals or materials used within the refinery.

6.2 Energy Efficiency

Aughinish Alumina is certified to IS0 9001 and IS0 14001. The plant also operates a formal energy management system. This was certified to the Danish Energy Standard DS2403. This certification was dropped for cost cutting reasons in 2009. However the management system is still being maintained and following a baseline audit at the end 2012 it will be certified to IS0 50001 during 2013.

The energy management system defines energy targets for each configuration of the plant, The target energy for each month is based on the forecast production rate for each day of the month combined with the forecast maintenance outages of each piece of plant during the month. At month end the variance from energy target is examined and attributed to each root cause. This information is used to improve energy forecasting and also to justify energy improvement projects. The energy performance for the month is formally reviewed and minuted.

Fuel switching from HFO to natural gas as addressed in this review will permit a minor improvement in energy efficiency due to the replacement of the old HFO boilers and burners by more modern and efficient gas fired boilers and burners.

SECTION H: MATERIALS HANDLING

H . l Raw. Materials, Intermediates and Product Handling

The main impact of switching to natural gas is that the HFO handling and storage volumes will reduce. This is beneficial in that the principal environmental risk at Aughinish is the possibility of a HFO spill during HFO ship unloading. This risk is greatly reduced by the proposed development.

H.2 accepted into or generated by the installation/facility

Arrangements for the recovery or disposal of solid and liquid wastes

Existing arrangements for waste recovery and/or disposal are unaffected by the proposed development.

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H.3 Waste disposal by on-site landfilling

On site landfilling will not be impacted by the proposed development.

SECTION I: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY

I. 1 .Assessment of atmosDheric emissions

The existing ambient air environment has been characterised by the ,Agency as high quality and typical of rural environment in Ireland.

I n 2005, Aughinish Alumina combusted almost 340,000 tonnes of HFO. The introduction of CHP in 2006 reduced HFO consumption to 240,000 tonnes per annum. Conversion of the calciners to natural gas further reduced HFO consumption to 100,000 tonnes per annum. The proposed gas boiler development will reduce HFO combustion on site from approximately 100,000 tonnes per annum in 2011 to almost zero. This will eliminate fuel based SOX and particulate emissions and will reduce site NOx emissions by 38%. This represents a major reduction of emissions to air and is to be welcomed.

Attachment NQ 1.1 contains details of the air emissions dispersion modelling conducted by AWN Consulting. The modelling was carried out to assess the impact of both of the gas boilers, i.e. the licensed gas boiler A4-A and the proposed gas boiler A4-B, on the ambient environment for the proposed scenario (2 Gas Boilers, 0 HFO Boilers, 2 CHP, 3 Calciners) relative to the following current baseline scenarios:

Base Case (2 HFO Boilers, 2 CHP, 3 Calciners) Alternative Base Case 8% of t ime (3 HFO Boilers, 1 CHP, 3 Calciners)

The modelling was carried out to assess the impact of nitrogen dioxide (NO2), sulphur dioxide (SO2) and carbon monoxide (CO) on ambient air quality and the overall purpose of the modelling was to assess whether the 32m stack height proposed for the 2 gas boilers was appropriate to ensure compliance with the ambient air quality standards.

The NO2 air dispersion modelling results were compared with the ambient air quality standards for NO2 for each of the three scenarios. The proposed scenario will lead to ambient NO2 concentrations (including background) which reach at most 35% of the l -hour limit value (measured as a 99.8th0/oile) and 32% of the annual limit value at the worst-case off-site ambient receptor. Compared to both the current base scenario and the alternative base scenario, the proposed scenario will increase ambient NO2 levels by between 2- 8% of the ambient limit value. (Despite the mass emission of NOx reducing by 38% the localised ambient NOx will peak slightly due to use of 32m stacks on the gas boilers compared to a 107m stack for the HFO boilers).

The SO2 air dispersion modelling results were compared with the ambient air quality standards for SO2 for the three scenarios. Both current base scenarios currently lead to ambient SO2 concentrations (including background) which reach at most 33% of the l -hour and 24-limit value (measured as a 99.8th%ile) at the worst-case off-site ambient receptor. Compared to both the base scenario and the alternative base scenario, the proposed scenario will decrease ambient SO2 levels by between 24 - 26% of the ambient limit value. Indeed, the proposed scenario 2 will reduce process SO2 emissions to zero and in doing so the SO2 level will revert to background levels in the region.

CO levels are extremely low for all three scenarios.

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1.2. Assessment of Impact on Receivina Surface Water

The proposed development will not impact on surface water quality.

1.3. Assessment of Impact on Sewaae Discharae

Aughinish operates an on-site biological treatment plant for the treatment and discharge of sanitary effluent. There will be no additional sanitary effluent generated by the proposed development.

1.4 Assessment of Impact of Ground/Groundwater Emissions

The proposed development will not impact on emissions to ground/groundwater.

1.5 Ground and/or Groundwater Contamination

A network of groundwater monitoring wells is in place to monitor groundwater quality in accordance with Condition 6.15 and Schedule C.8 of the current IPPCL POO35-05. No changes are proposed as part of this application.

Condition 6.15.4 requires that risk screening and, if necessary, a technical assessment of groundwater quality is carried out by the end of April 2014 and any actions are implemented in order to demonstrate compliance with the requirements of the 2010 G rou nd wa te r Reg u la tions .

1.6 Assessment of the Environmental Impact of On-site Waste Recoverv and/or Disposal

The proposed development will not impact on waste recovery or disposal.

1.7 Noise ImPact

The Aughinish facility is currently compliant with the 55 dB(A) and 45 dB(A) noise limits during day-time and night-time periods, respectively and compliance with the new guideline value of 50 dB(A) for evening periods (19:00-23:00hrs) was confirmed in 2012.

The new gas boilers are of lower capacity than the HFO boilers and the noise levels associated with the forced draft fans, stack exhausts and relief valves will be similar and no higher than with the existing equipment.

1.8 Environmental Considerations and BAT

The three main alternatives available to Aughinish Alumina to supply top-up steam for the production process are as follows:

1) Retain the existing HFO boilers and upgrade them for compliance with the Industrial Emissions Directive in advance of 2016. This option was rejected because:

a) It would leave the plant reliant on HFO which is likely to be more expensive and display more price volatility than natural gas in the coming years.

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b) The opportunity to convert from HFO to natural gas cost-effectively is too good an opportunity to miss given the low emissions and lower COz associated with natural gas. I ,

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2) Retain the existing HFO boilers and convert them to dual fuel HFO/natural gas. This option was rejected because:

a) The existing HFO boilers are 30 years.old so the maintenance cost is becoming more. sig n ifica n t. b) It would be technically difficult to re-configure the existing boilers for compliance with the stringent IED ELVs under natural gas or HFO firing.

3) Expand the CHP plant and provide the extra steam via co-generation. This option was rejected because:

a) Large CHP facilities are despatchable by the National Grid whereas the alumina refinery requires a guaranteed steady steam supply. When the Aughinish CHP plant is constrained to minimum output by the Grid manager the steam rate reduces to from 300 to 200 tonnes per hour. I n this mode (mainly during summer nights) i t is necessary to increase the top-up steam supply from 150 to 250 tonnes per hour. I t is not feasible to produce the full steam requirement for the refinery from CHP as the CHP steam supply cannot be guaranteed due to this constraint.

b) The existing CHP plant is exporting 120 MW onto the National Grid and the connection from Aughinish to the Grid is at its maximum capacity. An increase in steam production rates would entail an increase in power for export which would require a major upgrade (step up from 110 to 220 kV export and deep re- enforcement) of the National Grid.

For the above reasons we have concluded that the optimum solution is to install two new gas-fired boilers and retain the existing three HFO boilers as strategic back-up.

SECTION 3: ACCIDENT PREVENTION & EMERGENCY RESPONSE

Aughinish Alumina has an Accident Prevention Policy and maintains an Emergency Response capability that can address any emergency that is likely to arise on-site. Documented procedures detail the planned response for a range of potential emergency scenarios including for example a fire, a process chemical blowout or a containment failure of the Bauxite Residue Disposal Area. 0 The proposed gas boiler development will not introduce any risk scenarios or impact on the plant's state of emergency preparedness. Safety procedures related to use of natural gas in the CHP plant and Calcination area will also apply in the Boiler-house area once the new gas boilers are installed.

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SECTION K: REMEDIATION, DECOMMISSIONING, RESTORATION & AFTERCARE

The proposed development will not impact significantly on the plant's Closure Restoration and Aftercare Management plan (CRAMP), which has been submitted to the EPA under Condition 10 of the existing IPPC Licence. As the plant will use relatively little HFO in the future, the requirement under National Oil Reserves Agency (NORA) to retain a strategic stock of 55 days of HFO consumption will equate to a relatively small tonnage of HFO in storage. This will permit the plant to reduce to one operating HFO storage tank in service and will facilitate de-commissioning of the second HFO storage tank.

The requirements to prepare a baseline report and implement a formal closure plan following permanent cessation of activity under Article 13 of the European Union (Industrial Emissions) Regulations 2013 (S.I. No. 138 of 2013) amending Section 868 of the 1992 EPA Act are discussed in Section L Statutory Requirements.

SECTION L: STATUTORY REOUIREMENTS

L. 1 Statutory Requirements

Aughinish Alumina has been licenced as an IPC/IPPC facility since 1998. In this period Aughinish Alumina has demonstrated a high level of compliance with the requirements of the IPPC licence and other relevant environmental protection legislation. The plant has also undertaken many significant developments as part of a continuous improvement programme. The proposed development to replace the last remaining HFO usage application with natural gas for steam generation represents a further improvement in the environmental footprint of the plant.

As part of the Aughinish Environmental Management System (EMS) which is accredited to I S 0 14001, a register of legislation applicable to the facility is maintained and compliance is routinely evaluated.

The requirements of Section 83(5)(a)(i) to (v), and (vii) to (x) of the EPA Act 1992, as amended, shall be met. Details are given in Sections E, F, G, H and I of this application. Details of Accident Prevention and Emergency Response Measures and the Site Closure Plan have been submitted to the OEE under Conditions 9 and 10 of the current IPPC Licence .

The proposed development will not have an adverse effect on any designated sites. The Aughinish Alumina plant is located close to two Natura 2000 sites (River Shannon and River Fergus Estuaries SPA8 and the Lower River Shannon cSAC9), therefore an Appropriate Assessment Screening Report for the proposed development, is enclosed in Attachment 8.5.5. The Report concludes that: "It is not considered that the construction or operation of the proposed gas fired boiler and exhaust stack could result in any negative impact on the Conservation Objectives of either the Lower River Shannon cSAC or the River Shannon and River Fergus Estuaries SPA. As no impacts, either significant or non-significant, have been identified, significant cumulative impact with other plans and projects will not occur. Stage 2 Appropriate Assessment of the proposed project is therefore not required".

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Under Schedule 5 of the Planning and Development Regulations 2001-2012, an Environmental Impact Assessment was not considered necessary due to the sub- threshold status of the proposed gas boiler. The proposed boiler will result in a reduction rather than an increase in emissions to air.

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The proposed development will not have an adverse effect on water quality in light of the European Communities Environmental Objectives (Surface Water) Regulations 2009 (S.I. No. 272 of 2009).

The proposed development will not have an adverse effect on water quality in light of the European Communities Environmental Objectives (Ground Water) Regulations 2010 (S.I. No. 9 of 2010).

No substances specified in the Schedule of the EPA (Licensing)(Amendment) 2004, S.I. No. 394 of 2004, will be discharged by the activity.

Fit and ProDer Person

The applicant is a fit and proper person under Section 84(4) of the Protection of the Environment Act and meets the requirements set out in Section 84(4) of the Act.

L. 2 Industrial Emissions Directive (EC 2010/75/EU)

The following is a brief assessment of how the proposed development will contribute to compliance with the IED and enabling legislation enacted in Ireland.

L.2.1 Chapter I I of I E D

Article 22 Site Closure This article appears to be transposed in Article 13 of the European Union (Industrial Emissions) Regulations 2013 (S.I. No. 138 of 2013) Baseline Report & Permanent Cessation of Activity.

Aughinish has previously submitted to the Agency detailed reports regarding the decommissioning and eventual closure of the site under Condition 10 of the current IPPCL (and preceding licences). I t is concluded that even if a baseline report is required, Aughinish's obligations under Condition 10 are more onerous than the baseline requirement of the IED. The strict requirements will ensure that in accordance with article 13, sub-article 8, Aughinish will 'take all necessary actions to remove, control, contain and reduce relevant hazardous substances, so that the site .... ceases to pose any significant risk to human health and the environment. .....'

L.2.2 Chapter III of I E D

The following section contains an assessment of the applicability of Chapter I11 of the IED:

Article 28 Scope Article 28 states that Chapter I11 of the IED relates to combustion plant rated in excess of 50 MW. However it excludes plants in which the products of combustion are used for the direct heating, drying, or any other treatment of objects or materials. Thus the existing HFO boilers and existing CHP units and proposed gas boiler are covered by the requirements of Chapter I11 of the IED whereas the three calciners are not.

Article 29 Aggregation rules Under this Article the three stand-alone 150 MW HFO boilers are considered as a single combustion unit of 450 MW. I n a similar manner the two stand-alone gas fired boilers of 120 MW each are considered a single combustion unit of 240 MW. The appropriate ELVs to apply are based on this 'total capacity'.

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Article 30 Emissions Limit Values This Article details the appropriate ELVs to be applied to the new gas boilers. We have specified in our tender documents that the new gas boilers must comply with the ELVs referred to in Part 2 of Annex 5 of the IED specifically 35mg/Nm3 SOX, 100 mg/Nm3 NOx and 5 mgjNm3 dust. The new gas boiler will be will be compliant with the future ELV‘s to be introduced in 2016 under the Industrial Emissions Directive. The ELV for NOx will be 100 mg/Nm3 compared with 750 mg/nm3 for the existing HFO boilers.

Article 3 1 Desulphurisation rate This Article is not relevant to gas fired boilers or to our HFO fired boilers.

Article 32 This Article details the rules for eligibility in a TNP and how the annual mass emission allowances are to be calculated. Aughinish Alumina’s oil fired boilers are eligible to participate in a TNP and Aughinish has included them in the proposed Irish TNP along with a number of other Power generation companies ‘existing plant’ including the ESB, Scottish & Southern and Edenderry Power. The new gas boiler will be IED-compliant and will not impact on the TNP.

Transitional National Plan (TNP)

Article 33 This Article provides the option of opting boilers out of the IED and retaining the 2015 ELVs in 2016 and afterwards provided that the plant is shut-down after 17,500 hours operation or at the end of 2023, whichever occurs first. Aughinish Alumina is planning to exit from the above mentioned TNP and to declare formally before the end of 2013 that i t wishes avail of this LLTD option for. the HFO boilers.

Limited life time derogation (LLTD)

Article 34 Small isolated systems This Article has no relevance in the Aughinish context.

Article 35 District heating plants This Article has no relevance in the Aughinish context.

Article 36 Geological storage of COz This Article is not relevant to the current Aughinish context.

Article 37 This Article imposes obligations on LCP operators to ensure high up-time on emissions abatement equipment. Aughinish will comply with these requirements.

Malfunction or break-down of the abatement equipment

Article 38 This Article imposes specific requirements on monitoring requirements for LCP operators depending on plant size and type of fuel combusted. Aughinish will comply with these requirements.

Monitoring of emissions to air

Article 39 This Article refers to Part 4 of Annex 5 which defines compliance against a specific ELV. It also addresses how start-up and shutdown conditions are to be treated. Aughinish will apply these guidelines in determining its compliance performance.

Compliance with Emissions Limit Values

Article 40 Aughinish Alumina will raise steam principally from the CHP plant and f rom-the gas fired boilers. The HFO boilers will be operated for short periods if required. Only the CHP plant is equipped with multi-fuel capability (natural gas and distillate). Only one fuel is combusted at any one time. I n this scenario the ELVs for NG will apply during combustion of NG and those for distillate will apply during combustion of distillate.

Multi-fuel firing combustion plants

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Article 4 1 Implementing rules This Article states that guidelines will be developed for the definition of start-up and shut-down and for development of a Transitional National Plan. Aughinish will pay due attention to and comply with these guidelines.

L.3 Greenhouse Gas Permit & EU ETS

Aughinish currently holds a Greenhouse Gas (GHG) Permit from the EPA which authorises Aughinish to undertake specified activities resulting in emissions of CO2 from specified emission points. I t contains requirements that must be met in respect of such emissions, including monitoring and reporting requirements. Allowances for emissions of CO2 are allocated through Ireland's National Allocation Plan under the EU Emissions Trading Scheme. Aughinish has participated in the EU ETS since 2005. The ETS is currently in the third trading period (2013-2020). Under the ETS, Aughinish prepares an Annual Installation Emission Report which gives validated fuel consumption and related CO2 emission data for 12-month reporting periods.

During the coming months and before the new gas boilers are operational, the site will apply to the EPA through ETSWAP for an updated Greenhouse Gas (GHG) Permit. I

L.4 Aughinish and the application of BAT

The BREF documents of direct applicability to Aughinish Alumina are:

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Extractive Waste BREF - updated in 2009 Non Ferrous Metals BREF - to be updated in 2013 Large Combustion Plant BREF - to be updated in 2014

Extractive Waste BREF

Aughinish Alumina contributed to the development of this BREF through submissions made via the EPA. There are 17 separate references to Aughinish Alumina design and operational practices in the BREF. BAT for the Alumina sector entails guidelines on design, operations, maintenance, closure and aftercare of extractive waste storage facilities. These requirements are reflected through the IPPC licence Conditions for the BRDA at Aughinish:

- - - -

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- Water Management Plan - Comprehensive monitoring programme of stability and of environmental

Classification of the Facility under the Extractive Waste Directive Peer review and EPA approval of all design aspects Quality control and supporting documentation of all new constructions Extractive Waste Management Plan to address classification of wastes, their minimisation and their behaviour once disposed Operating and Safety Management Plan to ensure proper management of the facility

impacts (groundwater and air quality)

I n the BAT section Aughinish Alumina is referenced as a good example with respect to dust control (via sprinkler network) and Closure & Aftercare. Emerging technologies lists re-use of red mud for amelioration of Acid Mine Drainage and metals pollution in industrial site run-off. Aughinish Alumina maintains an interest in supporting whatever research is being conducted into re-use of red mud. Every year we are consulted by Universities and private Research laboratories in Ireland and across the EU looking for

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information on red mud and for samples of it. We anticipate that some of these ideas will eventually find traction.

Non Ferrous Metals BREF

This BREF concludes that BAT for alumina production entails:

- Use of high quality bauxite to minimise energy costs - Use of plate heat exchangers to reduce energy use - Use of fluid flash calciners to minimise energy required in calcination - Use of Electrostatic Precipitators or Bag Filters to minimise particulate

emissions from calciners - Use of dry disposal and residue neutralisation to minimise environmental

foot- prin t of residue storage

Aughinish Alumina employs all of these techniques already. The most recent addition is the use of Amphirols to maximise rate and extent of residue consolidation and partial neutralisation of the residual caustic through enhanced carbonation. In this manner bauxite residue pH is reduced below pH 11.5 and in-situ density is 75% solids or greater

Large Combustion Plant BREF

The revision of this BREF is due to be completed in 2014. It will define new ELVs for various types of large combustion plant. I n the case of Aughinish Alumina our main steam raising plant (Gas turbines commissioned in 2006 and Gas boilers to be commissioned in 2014) will come under the revised LCP BREF. While our three back- up HFO boilers will also come under the LCP BREF, the impact of abatement changes on these boilers will be marginal as they will be licensed to operate only for a maximum of 17,500 hours in the 8 year period from the start of 2016 to the end of 2023. As the Aughinish plant will be fuelled almost exclusively on natural gas there will be no combustion related SOX or particulate emissions and the only emission of note will be NOx. Bearing in mind the recent vintage of the gas fired plant these NOx emissions are already very low (<SO mg/Nm3 and <lo0 mg/Nm3) for the Gas turbines and Gas Boilers respectively.

The low NOx emission from the new gas boilers will be achieved employing:

- Staged air - Staged fuel - Flue gas recirculation

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I n the event that a new technology emerges before the end of 2023 for low-low NOx emissions from gas fired boilers we will be able to retro-fit it as we will be able to take outages on the gas boilers by operating the standby HFO boilers.

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SECTION M: ADDITIONAL MISCELLANEOUS REQUESTS

M . l Amendment of Condition 3.18

In the revised IPPC licence (POO35-OS), a new Condition 3.18 was added to our operation ...‘t he Licensee shall operate no more than 2 HFO boilers at any one time’. This new Condition represents a significant constraint on our operations under a number of scenarios:

Normal plant operation entails steam generation via 2 combined heat and power (CHP) units and 2 heavy fuel oil (HFO) boilers ie 4 steam generating units. This represents 90-95% of the operating time. When a CHP unit is shutdown for routine maintenance (5-10% of time) i t is standard practice to operate 3 HFO boilers. The logic here is that:

a. Provision of the high pressure process steam requirement via 4 units guarantees steady operation even if one of the 4 units trips. An uninterrupted steam supply to the process is a pre-requisite for steady efficient plant operation.

b. While operating with 1 CHP unit and 3 HFO boilers there is always the possibility of the CHP unit being despatched to minimum load by the National Grid Operator. Under such a condition operation of the third HFO boiler is a necessity to guarantee full steam supply.

(3) I n the event of a problem with the natural gas supply to Aughinish operation of all 3 HFO boilers would be required to provide the required steam.

We have conducted air dispersion modelling to demonstrate that operation of 3 HFO boilers does not breach air quality guidelines. Details of the modelling are included in Attachment 1.1.

In light of the above, we propose that Condition 3.18 be deleted.

M.2 Clarification and Amendment of Condition 8.4.26

Condition 8.4.26 of IPPCL POO35-05 states: The licensee shall within 3 months of the date of grant of this licence submit for agreement by the Agency a proposed scope for the biennial independent audit. At a frequency agreed by the Agency, the annual independent audit shall be equivalent to a ’Safety Evaluation of Existing Dams’ (SEED) audit.

The first sentence in the above condition indicates that the frequency of the independent audit is biennial, i.e. every two years. Schedule C7 of the licence also confirms and indicates that the frequency of the independent audit is every two years. Therefore for clarity and to avoid confusion the word “annual” in the second sentence of the above condition should be replaced with the word “biennial”.

We therefore request that the Condition 8.4.26 is amended as follows: The licensee shall within 3 months of the date of grant of this licence submit for agreement by the Agency a proposed scope for the biennial independent audit. At a frequency agreed by the Agency, the biennial independent audit shall be equivalent to a ’Safety Evaluation of Existing Dams’ (SEED) audit.

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M.3 Deliverables Required under IPPCL POO35-05 which have been met

Y

Y

Submission I

Complete

Com plete

Condition No.

Y

N

Y

Complete

Complete

Complete

N

N

N

Complete

Com plete

Com plete

Condition Requirement Deadline

Draw up an Extractive Waste Management Plan (EWMP) within 6 months

8.3.1 24/04/ 2 0 1 3 I I

Develop & maintain a Safety Manual for operations at the BRDA within 6 months

24/04/20 13 Complete Y 8.4.12

Progress report on Golders report re climate change protection (Breakout Study) within 6 months

2 4/ 04/ 2 0 1 3 Y 8.4.16 Com p lete

Progress report on implementation of recommendations of Residues Solutions Report within 6 months

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24/04/20 13 8.4.17

8.4.19 Develop standard operating procedures for mud farming within 6 months

24/04/2013

Submit a proposal on the scope and frequency of testing methods to be used to confirm partial neutralisation by mud farming within 6 months

8.4.20 24/04/20 13

Assess the water balance at the BRDA and develop a Water Management Plan for the BRDA, a copy of which should be available for inspection at all times, within 6 months

8.4.23 24/04/20 13

Submit for agreement a proposed scope for the biennial independent audit within 3 months

8.4.26 24/0 1/ 20 1 3

Develop a Major Accident Prevention Policy for the management of extractive waste within 3 months

Appoint a Safety Manager responsible for implementation and periodic supervision of the Major Accident Prevention Policy within 3 months

24/01/2013 9.4.1

,9.4.2 24/01/2013

Develop a Safety Management System to implement the Major Accident Prevention Policy within 3 months

Develop an Internal Emergency Plan specifying the measures to be taken in the event of an accident at the BRDA within 3 months

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9.4.3 24/0 1/20 13

9.4.4 24/0 1/ 20 1 3 N Com p lete

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SECTION N: DECLARATION

Declaration

I hereby make application for a licence / revised licence, pursuant to the provisions of the Environmental Protection Agency Act, 1992, as amended, and Regulations made thereu nde r.

I certify that the information given in this application is truthful, accurate and com plete.

I give consent to the EPA to copy this application for its own use and to make it available for inspection and copying by the public, both in the form of paper files available for inspection at EPA and local authority offices, and via the EPA's website. This consent relates to this application itself and to any further information, submission, objection, or submission to an objection whether provided by me as Applicant or any person acting on the Applicant's behalf.

3 l Signed by: Date: wLL 20 13

(on behalf of the organisation) 1

I print signature name: LIA M FL&.M I N G

Company stamp or seal: m Au hlnleh Alumina Limited I

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