Mr Mark Butler Environmental Engineer Irish Cement Limited Platin Drogheda County Louth

1 S” October 201 8

Headquarters, PO Box 3000 Johnstown Castle Estate CO Wexford, Y35 w821, Ireland

CeannchethrS, Bosca Poist 3000 E a s t i t Chaisledn Bhaile Sheiin Contae loch Gharrnan, ~ 3 5 ~ 8 2 1 , tire

5: t.353 53 916 0600 F: c353 53 916 0633 E: infc@enaa;ie w www.ePa.ie LoCall: 1890 33 55 99

Reg No: POO30-06

Dear Mr Butler

I refer to your application for a licence review.

I am to advise in accordance with Regulation 10(2)(b)(ii) of the EPA (Industrial Emissions) (Licensing) Regulations 2013, that the following information is required in support of the application under Regulation 9 of the Regulations:

Waste Acceptance Capacity 1 . In light of the An Bord Pleangla (ABP) consent to allow for the increased waste

incineration capacity up to a maximum of 465,000 tonnes per annum of alternative fuels (Board Order 17.DPA0050) and associated detail, provide an update to the Agency on the implications of this restriction on the licence review application lodged.

Raw Materials, Intermediates, Products, etc., used or generated on the site 2. The applicant is requested to update Tables G.l(i) and (ii) to include all of the proposed

alternative fuels and use of alternative raw materials to be considered under this application.

3. The applicant is requested to update Tables G. 1 (i) and (ii) to include all raw materials, intermediates and products employed in the quarrying operation.

Best Available Technology (BAT) 4. The applicant is requested to provide an assessment of the applicability of the

individual BAT contained in the following documents relevant to the current application:

Integrated Pollution Prevention and Control Reference Document on the Best Available Techniques for Waste Incineration (August 2006) Commission Implementing Decision (EU) 2018/1147 of 10 August 2018 establishing best available techniques (BAT) conclusions for waste treatment, under Directive 2010/75/EU of the European Parliament and of the Council.

Emissions to Atmosphere The analysis presented in the application in relation to the assessment of the impact of emissions to atmosphere is incomplete and the applicant is requested to update the analysis and inchde the following: Note: Any telephone mnyuiries in relation to the above should be directed to Deirdre French

at the number above. All written communications and replies should be directed to Aiding F Kehoe, Office of Environmental Sustainability, EPA, PO Box 3000, Johnstown Castle Estate, County Wexford.

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Clarify the current status of the abatement at Cement Mill 1 (A2-04) in terms of the current abatement measures in place at this discharge point, the measures levels of emissions and confirm compliance with BAT 18 for the production of cement, lime and magnesium oxide. Clarification is required on the number of calm hours in the meteorologicaI data set employed and how these calm hours have been accounted for in the model presented. Provide a full set of baseline data for all parameters addressed in the model. In each case provide the sources of the baseline data (site specific, EPA, UK or other databases) and a justification for same. Update the model presented (including the 75% flow sensitivity analysis) for the proposed application noting the following discrepancies identified between Table 8.5 of the 201 7 EIAR and Table El (ii) of the application:

EP A2-01- The max temp. (1 18OC) is employed in Table 8.5 whereas all other stacks employ the average temp (87OC). EP A2-05 - The efflux velocity in Table 8.5 (I 5.4 1 d s ) differs from that in Table El (ii) (8.8mls). EP A2-08 - The easting in Table 8.5 (306603E) differs from that in Table El(ii) (306602E). EP A2-0 1 - Carbon Monoxide is listed in Table 8.5 at an ELV of 1 ,500mg/m3 but is not included in Table E.l(iii) for A2-01. EP A2-01 -Ammonia is not listed in Table 8.5 for A2-01 but is included in Table E. 1 (iii) at an ELV of 50mg/m3 for A2-0 1. EP A2-01 , A2-02 and A2-08 -TOC is not listed in TabIe 8.5 but is included in Table E.l(iii) at an ELV of 10rng/rn3. Include TOC in the modelling assessment. EP A2-04 dust emissions modelled (Table 8.5) and ELV sought (Table E.I(iii) for 10mg/Nm3 while other similar sources are modelled at ELV of 20mg/Nm3. Please confirm.

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Advise what, if any, terrain details have been incorporated into the model and justify same in relation to the requirements of AG4.

10. Abnormal operations (start up, malfunction, by-pass, etc.) have not been presented and AG4 notes that these should be included where realistic. Please provide an analysis of the implications of abnormal operations at the installation.

11, When updating the model the applicant is required to include the main emission sources of the Carranstown Waste to Energy licenced faciIity (Reg. No. WO1 67-03) in the air dispersion modelling assessment to ensure a robust analysis of cumulative impacts may be undertaken.

12. Provide graphical results for all pollutants addressed in the model and for each relevant averaging period relevant to that pollutant for comparison with the AQS or guidelines applied.

13. On completion of the above updates to the model, the applicant is requested to provide a detailed analysis of the findings for each pollutant. This will include an analysis of the changes in mass emissions associated with the increased volumetric flows coupled with a commentary on the resultant changes in ground level concentrations.

Hydrology and Hydrogeology 14. Update Table E.2 (ii) to incIude all monitoring parameters for SW4 covered in

Schedule C.2.3 of the current licence, i.e. flow, temperature, pH, suspended solids, mineral oil, visual inspection, BOD, COD, toxicity, lead, copper, zinc and screening

Note: Any telephone enquiries in relation to the above should be directed to Deirdre French at the number above. All written conrmunicatiuns and replies should be directed to Aiding F Kehoe, Office of Environmental Sustainability, EPA, PO Box 3000, Johnstown Castle Estate, County Wexford.

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for organic compounds and heavy metals. The applicant is also requested to confirm the proposed monitoring frequency for each parameter and any variation to the existing regimes should be justified.

15. Provide a site drainage map that illustrates the location and orientation of all new firewater retention tanks and bunded facilities for the storage of wastes across the installation. A description of each new element of the infrastructure is required.

16. Provide a mass balance analysis of the combined surface water discharge from the site to confirm that the discharge at the current volumes and ELVs will achieve compliance with the relevant EQS as listed in the European Communities Environmental Objectives (Surface Waters) Regulations 2009 at the River Nanny. Specify any additional measures (including mitigation, site abatement and ELVs) that will be required to achieve compliance with the EQS.

17. In relation to the proposed changes at the installation, provide a technical assessment of the likely impact on groundwater quality and receptors having regard to the European Communities Environmental Objectives (Groundwater) Regulations 201 0. The EPA “Guidance on the Authorisation of Discharges to Groundwater” (201 1) should be employed in carrying out this assessment. Specify any additional measures (including mitigation, site abatement and ELVs) that will be required to achieve compliance with the EQS.

Appropriate Assessment 18. The applicant is required to provide an updated Natura Impact Statement @TIS)

prepared in accordance with EU guidance documents on the requirements of Appropriate Assessment and the Appropriate Assessment of Plans and Projects in Ireland - Guidance for Planning Authorities. In particular the revised NIS should account for the following:

This updated assessment should accurately reflect the current legislative regime, current best practice and guidance and the latest case law. The NIS should also consider the most up to date ecological status of the receiving environment. Identify the latest Conservation Objectives (COS) for all Natura 2000 sites within the zone of influence. C o n f m where water is drawn fi-om for the purposes of dust minimisation and consider if such abstraction has any implications for the NIS. Based on the issues raised in this Regulation 10(2)(b)(ii) in terms of impact to atmosphere, surface water and groundwater, the revised analysis of these impacts need to be considered in the NIS. In combination effects with other plans or projects in the area should be considered in greater detail. Page 20 of the NIS received by the Agency on 17/09/2018 states “It is noted that there are no habitats within the Zone of Infrtience of the proposed development, that is, habitats that may be impacted by the proposed development, regardless of distance from the site, such as active raised bog habitats in SACS, which may be sensitive to nitrogen deposition”. This statement fails to recognise the sensitivity of the wetlands which are a Qualifying Interest for the River Nanny Estuary and Shore SPA. The updated NIS should consider all qualifying interests withm the relevant European Sites. The NIS should clearly detail the mitigation measures required for each likely significant effect, which should include at minimum the following: o a description of each measure, o who is responsible for implementation of each measure, o timescale for implementation,

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Note: Any telephone enquiries in relation to the above should be directed to Deirdre French at the number above. AI1 written comnzunications and replies should be directed to Aiding F Kehoe, Office of Enviromenta1 Sustainability, EPA, PO Box 3000, Johnstown Castle Estate, County Wexford.

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o how the measure will address the likely significant effect, o and evidence of the degree of confidence in the likely success of the measure.

Baseline Report 19. The applicant is required to provide a Baseline Report that complies in full with the

European Commission Guidance concerning baseline reports under Article 22(2) of Directive 201 0/75/EU. All proposed alternative materials and alternative fuels should be considered in the application of this guidance.

Installation Boundary Map 20. Provide an updated installation boundary map which clearly shows the proposed

licensed installation boundary marked by a continuous red line.

In addition to the above please also provide an updated non-technical summary to reflect the information provided in your reply.

The requested information should be submitted to the Agency within 4 weeks of the date of this notice, in order to allow the Agency to process and determine your application.

In the circumstances, you should make arrangements to have the required documents (1 signed original and 1 copv in hardcopy format, and 2 copies of all files in electronic searchable PDF format on CD-ROM) submitted to the Agency. Your response to this request should be directed to Aisling F Kehoe, Administration Officer, Office Environmental Sustainability.

It should be noted that the eight-week period within which the Agency is to decide the proposed determination will commence on the day on which this notice has been complied with. If you have any further queries pIease contact Ms Deirdre French at the number above.

Yours sincerely

Environmental Licensing Programme Office of Environmental Sustainability

Note: Any telephone enquiries in relation to the above should be directed to Deirdre French at the number above. All wri#en conimunications and replies should be directed to Aisling F Kehoe, Office of Environmental Sustainability, EPA, PO Box 3000, Johnstown Castle Estate, County Wexford.