Tel Fax

Mr. Brian Meaney, Office of Licence and Guidance, Environmental Protection Agency, PO Box 3000, Johnstown Castle Estate, Co. Wexford.

QlJlNN Cernenl Ltd. Scotchtown BallyconneII. County Cavan Ireland

e353 ro) 4 9 9525200 t353 (0) 49 9525201

infd$quinn-cernent.com www.qurnn-group.com

1

Date: 2l"JuIy 2014 Company: Quinn Cement Registration No.: PO37842

RE: Clerlcal Error in licence PO37842

Dear Brhn,

PO378-02 licence variation was granted on the 4'h of July 2012 to allow the Quinn Cement manufacturing facility to co-fuel production of cement by displacing a certain amount of coal fossil fuel with SRF (Solid Recovered Fuel).

It has recently become apparent that a clerical error was made in the licence review application which was submitted to the Agency on the 261h October 2009. The licence review application was compiled and submitted by WYG (White Young Green) on behalf of Quinn Cement Ltd, Since application submission WYG's Irish operations have become liquidated; the specialists who worked on the Project are no longer with the Company and so they are unable to comment on the application made.

The clerical error made on this application reIates to licence Section Schedule B (Emission Limits), Bl (Emissions .to Air) and the permitted volume to be emitted. The figures outlined in the Licence emanate from the Licence Application Form Annex 1 : tables/Attachments specifically Table E.l(ii) Emission Point Reference A2-0l.Please find inserted below:

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. . ..

tt was outlined in the WYG licence review application that the expected maximum volume per day to be emitted from emission point A2.-01 was 11,240,000 Nm3/d and maximum volume rate per hour

emitted was 472,500 Nm3/h. These values were subsequently incorporated into schedule B: Emission Limits of our current licence PO378-02.

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FLSmidth are a leading supplier of equipment and services to the global cement and minerals industries and supplied the original plant at Ballyconnell and all additional equipment for co-fuelling of SRF.

Attached is supporting documentation from FLSmidth produced 3/2/2009 (Annex 25), titled "Emissions to air IPPC application for alternative fuels projects, Ballyconnell Cement Plmt, Sean Quinn". This annex is part of the original contract between Quinn Cement Ltd and FLSmidth.

In Annex 25 it states that the daily maximum volume is estimated a t 14,750,000 Nm3/d and the hourly maximum as 615,000 Nrn3/hr. These figures should have been used by WYG in the original application. Quinn Cement Ltd. seek a technical amendment to licence PO378-02 Schedule B: licence Limits B.1 Emissions to Air Emission Reference No: A2:Ol and specifically the volume to be emitted to reflect the maximum rates recommended by FLSmidth.

Please note that in precedent Scotchtown licence 378 the maximum rate per hour outlined for A 2 4 1 was 600,000 Nm3/hr, there has been no change in production which would effeddecrease stack volume rate.

I hope this information will allow the Agency to make a speedy determination, if you have any queries or if any further information is required, please do not hesitate to contact me.

Kind Regards,

Michelle Cass Environmental Advisor Quinn Cement Tel (D): 049-9525212 Jviichelie.Cassla uinn-nroua.com

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FLSmldth A I S Vigers!ev Aiik 7 7 . DK-2SOO Valby . Copftnfrar;en . Denmark 'feel +4$ 36 18 10 0 0 . rex +45 36 30 L8 20 iiifo@fismidtl>.com www.flsnridth.com .CVR.No. DK 15 02 88 82

Customer Sewlees Alternative fuels

Qutr

TO

03 February 2009

Steve Tonry. Qdlnn Group.

Copies to

frorn Thoinas Schmidt

Filing

LaSJ, NAC, SZM, JeKN

Emissions to Air, IPPC Appllcatioli for Alternative Fuets ProJect, Baiiyconiiell Cement Plant,

Sean Quinn.

Emissions lo A $ r - IPPC Application Subject

Aalon:

This memo is intended to provide Sean Quinn Cement's Baliyconnell cement plant with appropriate technical information on emissions to air needed for writing an Integrated Pollution Prevention and Control (IPPC) licensing application t o obtain a licence for producing 4200 tpd clinker while substituting up to 100%0 of the calciner fossil fuel with Solid Refuse derived fuel (SRF).

The vafues suggested - and the technology proposed - are based on the Best Available Technology without entailing excessive costs {BAT) appropriate to corn- ply with the EU Waste Incineration Directive (WID) "Directive 2001/76/EC". In events where there rnay be special considerations which rnay give rise to arnbigu- ity, a note has been made of this.

First the requirements of the Waste Incineration Directive are summarised in tabu- lar form. An overvlew of the matn emission points is given together with the over- all data for each of the main ernissian paints (i.e. location, Source, vent details, volumetric flow and temperature). Each of the emissions components for which there are requirements set by the W1D are subsequently considered in detail. For each is briefly described:

0 Source of emission component Output routes and potential for accumulation within the system

e Abatement installations and/or methods

Suggestion for applicable limit inciuding brief outline of reasoning

How compliance will be ensured (monitoring and procedures)

The data and information contained in this memo represent calculated and F ~ C -

ommended vahes for the application - and which are expected to be relevant af- ter implementation of t h e proposed project They do not necessarily represent val- ues to be guaranteed by FLSrnidth in connection with the proposed project. The reasons for this are that preconditions need t o be defined and that it is only some aspect5 of kiln operation that can be guaranteed at a production capacjty of 4200 tpd due to tlic nominal capacity of the kiln being 3800 tpd.

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1. Legislation fram EU waste incineration directive [Directive 2007/76/EC 3

I EU waste Inclnera- tion directive limit

NOX rny/Nrn3 @ 30% O2 (dry) 500 * I I -_.-_

Cd + TI rng/Nm3 @I 10% O2 (dry) 0.05 ..__̂ I-

mg/Nm3 @ 1OU/n O2 ( d r y ) 0.05

0.5 5b .I- A5 + Pb c Cr + rng/Nrn'@ 10% O2 (dry)

ng/Nm'@ 10% O2 (dry) 0.1

___....___..I ~ -___- - - .ll.._l

rng/Nrn3 @ 10% O2 (dry) 50** F I I by authorities 1

*: 800 for existing plants +* Exemptions may be authorised by local authorities

2. Main emission paints

Below is a short dexr ipt ion of the emission points far the upgraded plant. This de- scription will onfy cover the modifkd areas of the plant, i.e. the cement mill and coal mill will not be included.

2,l, Main stack Source o f emission: toca tio n : Vent Details Diameter: 3500 rnm

Height: 116200 rnm Volume to be emitted: dry

Average/d: Max/d: Max/h :

ESP exhaust from raw mill, cement kiln and bypass Next to preheater

12 300 000 Nm3/d @ 10% Uz dry 14 750 000 Nm3/d @ 10% Qdry 615 000 Nm'lh 0 10% O2 dry

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Min vetocity Temperature ma x/m i n/a vg : 200/ L20/ 150 C

2.2.Caaler excess air Source of emission: Location: Next to preheater Vent Details Diameter: 3000 mm

Height: 37000 m m Volume to be emitted:

Average/d: Max/d: Max/h: Min velocity

Tern peratu re ma x/ m i n/a vg :

ESP fitter exhaust from clinker cooler

4 675 000 Nm3/d @ 10% 0 2 dry 5 610 000 Nm3/d @ 10% 0 2 dry 230 I100 Nm3/h @ 10% 02 dry

3 OW2 O W 2 60 OC

3. Specific emission components

Source of emission cornmnent:

Dust From solid produds being processed to produce cement clinker in kitn sys- tem. The solids are derived from raw mineral constituents and fuel ash.

O u t ~ u t routes and ootential for accumulation within the system: - From kiln ESP

- - From clinker cooler ESP

From bag filter on bypass

Abatement installations and/ormethods:

Bag filter for bypass gas and ESP filter for main kiln gas

Emissions from a bag filter are constantly low. Emissions can O C C U ~ ' in case of bag failure. The most common bag failure is due to mechanical ware. Process parameters of interest are the gas temperature as high temperature may burn the bags.

Emissions from an ESP filter can be changed by the temperature of the gas (velocity), partial pressure of water in the gas (increased resistivity) and by the current in the ESP.

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Suwestion for amlicable limit includinq brief outline of reasoninq :

Emission limit for dust shall be a5 the waste incineration directive 30mg/Nm3

Expected emissions:

plain stack

Average mg/ Nm’ Max mg/ Nmj

Average kg/h

Max kg/h

Coaler excess

Average mg/ Nm’

Max mg/ ~ 1 1 7 ~

Average kg/h

Max kg/h

Before treatment

7500

750fl

3510

4000

Before treatment

25200

21400

4400

~ Q O O

After treatment

< 3#

< 30

34

17

After treatment

c 30

< 30

5.8

7.0

How CO r n U I i a !~e~-a&!ie.,-g! wed f monitor in a and D roced U res 1 Emissions are rnonitored by an on-line stack anaiyzer [existing]

Calibration vatidation shall be done by government approved specialist once per year.

3.2.HCI /HF

I--_-______ Source of emission comjonent: A large Fraction of the chlorine and fluorine within high-temperature zones of the kiln system is present in the form of HCI and HF.

O u t w t routes and potentiaf for accuniufation within the system:

HCI and HF emissions are the result of slip of a rninor fractian of t h e substan- tially higher- concentrations of these components within the kiln system through dust filters with the preheater and bypass gas.

Chlorine accurnutates in the kiln system; particularty within the rotary kiln and calciner. Chloride will evaporate from the charge as it i s heated in the kiln.

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When the gasses are cooled in the preheater the chloride settles on the basic dust and returns to the kiln. The bypass extracts klln gas containing gaseous chlorine. By quench cooling the gas chlorine condenses as dust or is absorbed by du5t in the gas. The dust is sent to the cement mill. Some chlorine wilf a150 leave the kiln contained in the clinker.

Fluorine in kiln systems behaves similarly to chforine, but is present in sub- stantially lower concentrations.

____l__l_l Abatement installations and/or methods: HCI and HF are naturally abated by being brought into contact with the basic dust in the kin system within an appropriate temperature interval. The HCI and HF emissions may be controlled by adjusting the filter temperatures in the exit gasses from the bypass and preheater.

Sumestion for apdicable firnit includinq brief outline of reasonina:

Emission limit for shall be as the waste incineration directive HCl 10 mg/ Nm3 @ 10% 0 2 a n d HF 1 mg/ Nm3@ 10% Oz

Expected emissions HC1 / HF:

Average mg/ Nm'

Max mg/ Nm3

Average kg/h Max kq/h

Before treatment After treatment

- / - - / - < l o / 1 < 1 0 / 3

* / " - / - <6.1 / 0.61 <6.1 / 0.61

j j - J rr l i a nce w i J I be ens u 1:gd-j m on itorj ng 8 nd P roced u res) Emissions are monitored by an on-line stack analyzer.

Calibration shall be done once yearly by fL5rnidt.h or AB6 specialist.

3.3 NO,

Source of emission component:.

NO, is formed during combustion in the rotary kiln and calciner. I t may be formed from nitroyen and oxygen in air or in fuels.

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Putput routes and potential for accumutation within the svstem:

N O , formed in the rotary kifn escapes both directly through the bypass and af- ter being partialiy reduced in the calciner through t h e preheater. NO, formed in the catcher escapes through the preheater. No acctimulations.

Abatement installations and/or methods:

NO, is abated by a combination of a calciner designed to minimise emissions and a Selective Non Catalytic Reduction (SNCR) system installed in the caalciner to remove the NOx. Ammonia (NH3) will be used as reduction agent for SNCR.

lnvestigativns have shown that it is more efficient to remove NOx in the cal- ciner than in the bypass. A5 a result the SNCR will remove adequate NOx from the calciner to compensate for the slip in the bypass gas.

Suclclestion far awljcable limit includina brief outline of reasoning:

Emission limit for shall be as the waste incineration directive. For new kilns ap- plies a NOx limit of 500 mg/ Nm3 @ 10% 0 2 , whereas existing kiln must com- ply with a NOx limit of 800 mg/ Nm3 @J 10% 02, A tower limit wIll require a greater use of NH3 as reduction agent.

Expected emissions Before treatment

Average mg/ tvm3 moa Max rng/Nm3 1000

Average k m 412

Max kg/h 61 5

HQ.UW I ia rl ce wi n ~ ~ ~ ~ _ ~ ~ L ! . ~ ~ ~ ~ . . . ~ . ~ o ~ ~ d ~

Emissions are monitored by an on-line stack analyzer.

Calibration shall be done once yearly by FLSmidth or ABB specialist.

3.4.Cd+TI

Source of emission camuonent:

Impurities in t h e raw materials and fuel tha t only may escape in solid form a5 impurities in dust emissions.

Output routes and potential For. accurnd$tion within the system:.

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Cd will circulate in the kiln and preheater. Cd is removed primarify in the by- pass dust.

TI wlll circulate in the preheater exit and settle on the main ESP filter dust. Tl input shall be limited in the raw materials.

Abatement installations and/or methods:

Cd emissions are effectively abated by the bypass bag filter. The Cd inputs are continuously removed by sending the bypass dust tu the cement mills thereby maintaining a low concentration in the dust.

TI emissions are effectively abated by the main stack ESP. TI levels in the ESP dust must be monitored periodically to confirm that excessively high concen- trations do not gradually build up In the du5t. TI concentrations in fuels must be maintained extremely iow. I f excessively high Concentrations develop in the dust TI can be removed by bleeding filter dust t o the cement mill (not required if TI input in fuels and raw materials can be maintained sufficiently low).

The main potenttai concern retated to building up excessively high concentra- tions of TI in t h e dust is that in the w e n t of an ESP malfunction a high TI ernis- sion would result.

Suqqation for apdicable limit includina brief outline of reaso nine Emission limit for shall be as the waste incineration directive Cd+TI 0.05 mg/ Nm3 @ 10% 0 2

Expected e in is s i on s

Average mg /Nm3 -

Max mg/ Nm3 c; 0.05 c 0.05

Average k g l h Max kg/h < o m ~ 0 . 0 3

Before treatment After treatment

How compliance will be ensured (monitorins and Drocedures)

Regular sampling and measurements by government approved specialists (e .g . half yearly).

A regular periodical analysis of t h e thallium content in t h e preheater dust will give an indication of levels of thallium build-up in the system.

I n case of rapidly rising concentrations in dust the input shall be lowered in the raw materials and fuel - and bleeding of filter dust should be considered.

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Source of emission component:

Impurities in the raw materials and fuel.

Output routes and potential for accumulation within the svstem:

Hg is highly fugitive and will leave the system by the preheater exit gas. Hg will t o some extent settle on the main filter dust thereby accumulating in a cy- cle over the raw meal silo. Emission levels can be expected to be substantially higher when the raw mill is off than when the raw mill is on.

Abatement installations and/or methods:

No abatement system will be installed. In the event that daily average emis- sion tevels are close to the emission limit care must be taken not to operate the kiln for substantially longer periods of time without the raw mitt is in opera- tion than is normally the case.

Hg can to some extent be removed b y bleeding preheater filter dust to the ce- ment mil{. (not consldered necessaiy if inputs are maintained sufficiently low)

In the event of excessively high emission levels, compliance with emission lim- its can only be ensured by l imiting the input to the system (i.e. lowering the Hg in t h e raw materials and/or the fuel) or by installing a Hg scrubber (e,g. acti- vated carbon filter).

_S_ugg_~$~j~~~.fQ,T.appticab~e limit includins brief outline of reasoninq: Emission Iirnit for shall be as the waste incineration directive Hg 0.05 mg/ Nm' @I 100/0 0 2

Expected emissions Before treatment

Average mg/Nrn3 -

Max mg/ Nrn3 ~ 0 . 0 5

Average kg/h

Max kg/h <0.03

After treatment

tiow com&nce will be ensured [_m_onitorinq.gd procedures)

Regular sampling and measurements by government approved specialists. FLSn-tidth can supply an approved on-line Hg analyser if required by authori- ties. However, on-line analysis i s generally not required by authorities - partly

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due to the analysis technologies being relatively new and there still being un- certainty related to standards that wili apply in future (substantial discrepancy exists between measurement results from different approved analysis appara- tus types). Casts for on-line Fig analysis are presently substantially higher than for other components determined on-line. Therefore, instaIIation of on-line analysis instrumentation is not recommended.

A regular periodical analysis of the Hg in the preheater dust will give an indica- tion of raising or falling levels of Hg in the system.

Limit the input to the system i.e. Hg in the raw materials and fuel.

3.6.5b 4- As +- Pb + Cr + CO 4- Cu + Mn f Ni +V

SoLrce of emission cornrmnent:

Components in the raw materials and fuef.

I OytD_Eoutes and Dotentiai for accurnutgtion within the system:

The heavy metals wiIl prirnarity leave the system via the clinker.

Pb will circulate between the kiln and the calciner and be removed In the by- pass dust. Only traces wili leave in the clinker.

Abatement installations and/or methods:

Emissions are effectively abated by the instailed dust filters.

3cic)estion for applicabte l imit inciudinq brief outline of reasmino:

Emission limit for shall be as the waste incineration directive heavy metals 0.5 mg/ Nrn3 @ 10% O2

Expected emissions Before treatment After treatment

Average rng/Nm3 I

Max m g / Nm3 .;O.OS <0.05

Average kg/h

Max k g h ~ 0 . 3 co.3

now co rn r> l i an~w i l l be ensyred (ma w r i n g and D r m r

Regular sampling arid measurements by government approved specialists.

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Ensure that dust emissions comply with dust limits.

3.7.Diaxins and furans

Source of emission component;

Chemical reaction between organic carbon components and chloride in pres- ence of catalytic material - of by any possible dioxin and/or furan inputs es- caping. The main risk of formation in cement kiln systems is related formation in dust filters operated a t a high temperature (above 200°C).

Output routes and potential for accumulation within the svstem:

Dioxins and furans leave the system via the ESP preheater exit gas f i l ter or via t h e bypass bag filter.

Abatement installations and/or methods:

The rapid cooling of the exit gas before entering the dust filters will generally ensure negligible dioxin and Furan formation. Certain alternative raw materials may give an enhanced potential far formation of dioxins and/or furans.

Carbon filters can be installed, but due to the negligible dioxin and furan emis- sions from essentially all modern cement plants installation is not considered neccsa ry .

Susnestion for a B ! ~ b I e limit includin9 brief outline of r e a s o n i m

Emission limit for shall be as the waste incineration directive heavy metals 0.1 ng/ Nm3 @ 10% O7

Expected ernjssions Before treatment

Max ng/ Nm3 < O . l

Average ng/ Nm3 ~

Average kg/h

Max S h ~ 0 . 0 6

After treatment

<O. 1

<0.06

Haw comoliance will be ensured (monitgrin.4 and mocedures)

Regular sampling and measurements by government approved specialists.

;In case of high emissions filter remperatures may be adjusted and/or problem- atic constituents in raw niaterials should be removed. /'&//,,

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3.8.502

Source of emission cornDonent:

The main emissions results from pyrite in the raw materials. However, all sui- phur inputs t o the kiln system in fuel and raw materials may be a Source of SOz slip in combustion gas escaping through the bypass installation

Output routes and po ten t iaur accumulation within the system:

The main SOz emission from the kiln system will be formed from pyrlte in the upper preheater stages, where a fraction of it also may be reabsorbed.

Sulphur circulates between the kiln and the preheater and leaves the system in both clinker and bypass dust. There may be high 50, concentrations within high-temperature zones of the kiln system. The concentrations of SO2 within the kitn system depend on several operating parameters for the kiln system. SO2 from high-temperature zones may leave the system via the bypass where part - or all - of it is absorbed,

A substantial fraction of the SO2 in the preheater gas passing through the raw mill will be absorbed in the raw meal when t h e hot gas is being used in the raw mill. A minor fraction of SOr in the gasses passing through the fllrers is gener- ally absorbed.

Abatemenl.,~.~stallations andlor methods:

No abatement system will be installed.

SO;! emission levels are mainly controlled by controlling the pyrite content in the raw materials [sefective quarrying). In the event that daily average emis- sion levels are close to the emission limit care must be taken not to operate the kiln for substantially longer periods of t ime without the raw mill is in opera- tion than is normally the case.

In addition to the main SOz emission from the preheater, SO2 emissions via the bypass must be maintained low. I n order to maintain the bypass SO2 emission low, the following operational parameters must be adjusted appropriately: air exces5 in kiln and preheater, excess S in kiln (S/alkali ratio), degree of fuel burnout in calciner, kiln burner flame shape and intensity, temperature in by- pass instaltatlon.

In the event that SOz emission levels must be lowered (by up to 50%) Ca(0t-f) may be injected into the preheater and/or bypass (not considered appropri-

ate, but could be required by some authorities).

S u w e s t i on Coj--app I ica b le .li m.iL-!xt,udb 9 brief uu t I i n e..ofrea son in q :

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Emission limit for .SO2 exceeds the basis limit in the waste incineration direi-tive (50) due tu pyrite in the raw materials. I t is suggested the at limit of 450 in the current approval is used as a baseline representing 50% corning from pyrite In the raw miaterials and increased by the 50 specified as a basis in the waste incineration directive to a total of 500 mg/ ~ r n ~ @ 10% o2

Expected emissions Before treatment ARer treatment

Average mg/Nrn3 450 450

Max m g / Nm3 <500 < 500

Average kglh 230 230

Max kg/h <307 ~ 3 0 7

How c o w n c e will be ensured (monitorins and procedures)

Emissions are monitored by an on-line stack analyzer. Calibration shall be done by government approved specialist.

In case of high ernjssjons the pyrite input shall be lowered in the raw materials.

3.9. TOC

Source of emission component:

Mainly From organic materials in the in the raw materials. Some TOC may originate from incompletely combusted Fuet.

Outout routes and potential for accumulation within the system:

TOC evaporates from the organic carbon in the raw materials in top of the pre- heater before the temperatures becotnes high enough for full combustion to take place. TOC from incompletely burned calciner fuel may yield a minor con- tribution to preheater TOC emissions. The bypass gas may also yield a minor contribution to TOC emissions in the event of incompletely burned kiln burner and calciner fuel. TOC from the preheater and bypass will pass through the fil- ter and exit the system (cornponetits condensing below the filter temperature may be recirculated - and accumulated - within the kiln system).

Most of the organic material in the raw materials and essentially al l of t h e or- ganic material in the fuels is oxidised a t the high temperatures in the kiln sys- tem to form COz.

Abatement installations and/or methods:

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No abatement system will be installed. However, the calciner, fuel feed sys- tarns and process control systems have been designed to ensure effective burnout and thereby low fuel combustion induced TOC emissions.

TOC emission lev& are rnainly controlled by controlling the organic carbon content In the raw materials (selective quarrying). In addition the kiln system will continuously be operated with air excess.

In the event of having to further reduce TOC ernlsslons the installation of an active carbon filter is possible (not considered appropriate).

Suaclestion for applicable timit inchdincl brief outline of reasonim: Expected emission levels for TOC exceed the basis limit in the waste incinera- tion directive (10) due to relatively high organic carbon content in the raw ma- terials. I t is suggested to measure the TOC emission at current operating con- ditions and use this as a baseline in conjunction with statistical data for the or- ganic carbon content in the raw materials available for use in the coming 10-30 years. The TOC emission level in future when utilising alternative fuels will be appraximately the same (possibly marginally higher). The basis limit (10) could be added to the present baseline to obtain the suggested applicable limit.

There are two methods of estimating the TOC emissions from a given sample of raw meal. Either using “a rule of thumb in combination with a determination of the organic carbon content” or “an Off Gas Test” to estimate TUC release. The Off Gas Test result generally gives the best prediction of the most probable emission level, whereas the “rule of thumb in combination with a determination of the organic carbon content’’ gives an indication of the typical range of vari- ability.

The raw meal sample received on 14 January 2009 has an organic carbon con- tent of 0.28% and is a composite sample for a period of approx. a month. An Off Gas test analysis OF the sample reveals tha t the most probable raw material induced TQC emission is < 15 mg/Nrn3 @ 10% 0: (dry). The “rule of thumb” predicts that the expected raw material induced TOC emission is 20 to 40 mg/Nm3 @ 10% 0: (dry). I t is suggested to take into account that organic carbon contents in raw meal may be higher in the future and to add the basis fimit (10) to these levels in order to obtain a suggested applicable I h i t .

Based on the above an applicable limit value of 50 mg/Nrn3 02 10% O2 is pro- posed.

Expected emissions Before treatment After treatment

Average mg/Nm’ 20 20

Average kg/h 10 10

Max mg/Nrn3 450 < 50

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How compliance will be ensured [monitorina and procedures1

Emissions are monitored by an an-fine stack analyzer.

Calibration shall be done using certified standard test gasses by locai mainte- nance staff.

In case of high emissions the input of organic carbon shall be lowered in the raw materials. The completeness of combustion of fuels in the kiln system shall also be evaluated and addressed if appropriate.

3.10. CO

Source of emission comDonent:

Uncompleted combustion in the calciner (and rotary kiln).

f’artly oxidized organic carbon from the raw materials forming CO in the pre. heater cyclone stages,

Qutp.uJ+ro.gtes and Dotential far accumulation wirhin the svstem;

CO leaves the system via the exit gasses from the bypass and kiln (preheater).

- Abatement installations and/w methods: No abatement system will be installed. However, the calciner, fuel feed sys- tems and process control systems have been designed to ensure effective burnout and thereby low fuel combustion induced CO emissions. CO emission levels are controtled by controlling the organic carbon content in the raw materials (selective quarrying), by appropriate handling of fuels arid by appropriate control of kiln system operation to maximise fuel burnout.

Susqestion for aaolicabte limit including brief outline of i-easo n ina :

The Waste Incineration Directive does not specify a CO limit. The CO emission limit is set by “competent authority”. The appficable emission limit for CO for the Sean Quinn plant must take the relativefy high content of organic carbon in the raw materials into account. Further, it must allow for‘ some CO emission from fuel combustion.

It is suggested to set t h e l imit to a value of 6000 mg/Nm3 B 10% 02. ‘Phe range 0-0.5% r-cpi-esents the range of variation of CO ernissioris from German

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burnlng alternative fuels in an environmentally sustainable manner for many years.

Expected emissions Before treatment

Average mg/ Nm3 3000

Max mg/ Nm3 GOO0 Average kg/h 15’40

Max kg/h 3690

After treatment

3000

6000

1540

3690

How compliance will be ensured [rnonitorinq and Droceduresl

Emissions are monitored by an on-line stack analyzer.

Calibration shall be done by government approved specialist.

I n case of high emissions the input of organic carbon shall be lowered in the raw materials. The cornpfeteness of combustion of fuels in the kiln system shall also be evaluated and addressed if approprlate.

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