Directors Eoghan Lynch (Chairman) Jerry Mehigan Joe Burns Gerald Bythell Sean Clarke Tim Corcoran Gary Cotter Paul Coughlan Denis Crowley Matt Cunningham Phelim Devine Philip Dilley (British) Paul Dunne Mike Evans Peter Flynn Liam Luddy Ria Lyden Sean Mason Donal McDaid Declan Monaghan Fergus Monaghan Seamus Mulherin John O’Mahony Niamh O’Sullivan Associate Directors Peter Adams Tom Blake Paul Brady Ger Breen John Burgess Senan Clandillon Michael Daly James Duggan Alan J Duggan John Flaherty Ken Freeman Hugh Gray Hugh Griffin Clem Hussey Conor Lavery Tony Lynch Eileen McCarthy Robert McGrath John Mundy Andrew Nixon Joanna O’Brien Gavin O’Donnell Hugh O’Dwyer John O’Sullivan David O’Keeffe John Reale Barry Ryan Joe Ryan Grainne Wolfe Company Secretary Ken Freeman

\\DUBNTS03\DUBLIN_JOBS\217000\217893-00\1. CLIENT\1-02 CORRESPONDENCE\L0001_217893-00_REVIEW

BY EPA OF IPPC LICENCE REGISTER NO P0376-01 PREMIER PERICLASE Ltd..docx

Ove Arup & Partners Ireland trading as Arup | Company Reg No: 37037 Reg Office: 50 Ringsend Road Dublin 4

Cork | 15 Oliver Plunkett St Tel +353 (0)21 427 7670 Dublin | 50 Ringsend Rd Tel +353 (0)1 233 4455

Galway | 21 Middle St Tel +353 (0)91 894 700 Limerick | Hartstonge House Upr Hartstonge St Tel +353 (0)61 212 100

Our ref 217893-00/DM/SB

File ref A. L0001

50 Ringsend Road Dublin 4

Ireland

t +353 1 233 4455 f +353 1 668 3169

don.menzies@arup.com arup.ie

Environmental Protection Agency

PO Box 3000

Johnstown Castle Estate

Wexford

For the Attention of:

Ana Bolger - Programme Officer

Environmental Licensing Programme

Office of Climate, Licensing & Resource Use

1 September 2011

Dear Sirs

217893-00 Register No P0376-02 Review by EPA of IPPC Licence Register No P0376-01 Premier Periclase Ltd.

On behalf of Premier Periclase Ltd. we enclose an application for review of IPPC Licence

Register No P0376-01.

As requested in your letter of 30 June 2001, the following are enclosed:

One original, signed

One Paper copy

2 No CDs containing:

o Application (searchable pdf)

o Excel spreadsheets with emission and monitoring/sampling points

o Geo-referenced AutoCAD drawing with site boundary and emission point

to surface water, etc.

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EPA Export 13-09-2011:03:41:09

217893-00/DM/SB

1 September 2011 Page 2 of 2

\\DUBNTS03\DUBLIN_JOBS\217000\217893-00\1. CLIENT\1-02 CORRESPONDENCE\L0001_217893-00_REVIEW BY

EPA OF IPPC LICENCE REGISTER NO P0376-01 PREMIER PERICLASE LTD..DOCX

Please let us know if you require any further information.

Yours sincerely

for

Arup

Don Menzies

Enc

cc Mr Declan Duffy

Premier Periclase Limited

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EPA Export 13-09-2011:03:41:09

Integrated Pollution Prevention and Control

(IPPC)/Waste Licensing

Review Form and Guidance

Note

for the purposes of

EC Environmental Objectives (Surface Waters) Regulations

2009

Environmental Protection Agency

P.O. Box 3000, Johnstown Castle Estate, Co. Wexford

Lo Call: 1890 335599 Telephone: 053-9160600 Fax: 053-9160699

Web: www.epa.ie Email: info@epa.ie

EPA Reg. No: (Office use only)

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Introduction

INTRODUCTION

This Form is for the purposes of a review of an IPPC/Waste Licence in order to ensure that all authorisations under the EPA Act 1992 to 2007 and the Waste

Management Acts 1996 to 2010 having discharges liable to cause water pollution are in compliance with the EC Environmental Objectives (Surface Waters) Regulations 2009.

While every effort has been made to ensure the accuracy of the material

contained in the Review Form, the EPA assumes no responsibility and gives no guarantees, undertakings and warranties concerning the accuracy, completeness or up-to-date nature of the information provided herein and does not accept any

liability whatsoever arising from any errors or omissions.

The Review Form and all supporting information shall be submitted to the Headquarters of the Agency in a format of a signed original, one hardcopy and two copies on CD-Rom. In cases where an Environmental Impact Statement

(EIS) is required in support of the Review Form, a signed original, one hardcopy plus 16 copies (or 18 copies if the activity is within Energy sector) on CD-Rom

shall be submitted. All pages, including maps/drawings/plans, shall be no larger than A3 size. All

files on CD-Rom shall be submitted in searchable PDF format and be no larger than 10MB each in size. All CD-Roms shall be labelled with the Licensee’s name,

Licence Register Number, address of the activity and name of the file (i.e. Review Form).

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EPA Export 13-09-2011:03:41:09

Contents

CONTENTS

INTRODUCTION ................................................................... 1

SECTION A: GENERAL .......................................................................................... 1

SECTION B: EMISSIONS ........................................................................................ 3

SECTION C: CONTROL & MONITORING ......................................................... 4

SECTION D: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY 6

SECTION E: STATUTORY REQUIREMENTS ................................................... 8

SECTION F: APPROVED ADJUSTMENTS & CONDITIONS .......................... 9

SECTION G: DECLARATION .............................................................................. 10

ANNEX 1: TABLES/ATTACHMENTS ..................................... 11

ATTACHMENT NO A2: LOCATION OF ACTIVITY ...................................... 21

ATTACHMENT NO B1: EMISSIONS .................................................................. 23

ATTACHMENT NO C1: CONTROL & MONITORING ................................... 28

ATTACHMENT NO C2: CONTROL & MONITORING ................................... 37

ATTACHMENT NO D.1.1 ASSESSMENT OF IMPACT ON RECEIVING

SURFACE WATERS ............................................................................................... 40

ATTACHMENT NO D.1.2 COMPLIANCE WITH EC ENVIRONMENTAL

OBJECTIVES (SURFACE WATER) REGULATIONS, 2009 ............................ 59

ATTACHMENT NO D2: ENVIRONMENTAL CONSIDERATIONS .............. 60

ATTACHMENT NO E: STATUTORY REQUIREMENTS ............................... 66

ATTACHMENT NO F: APPROVED ADJUSTMENTS & CONDITIONS ...... 68

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Page 1

SECTION A: GENERAL

A.1 Licensee

Name*: Premier Periclase Limited

Address: Boyne Road,

Drogheda

Co. Louth.

Tel: 041 987 0700

Fax: 041 987 0706

e-mail: ppl@eircom.net

* This should be the name of the Licensee which is current on the date this IPPC/Waste

Licence Review Form is lodged with the Agency. It should be the name of the legal entity

(which can be a limited company or a sole trader). A trading/business name is not

acceptable.

Name and Address for Correspondence

Only documentation submitted by the Licensee and by the nominated person will be deemed to

have come from the Licensee.

Name: Premier Periclase Limited

Address: Boyne Road,

Drogheda

Co. Louth.

Tel: 041 987 0700

Fax: 041 987 0706

e-mail: ppl@eircom.net

Address of registered or principal office of Body Corporate (if applicable)

Address: Boyne Road,

Drogheda

Co. Louth.

Company

Register

No.

59188

Tel: 041 987 0700

Fax: 041 987 0706

e-mail: ppl@eircom.net

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Page 2

A.2 Location of Activity

Name: Premier Periclase Limited

Address*: Boyne Road,

Drogheda

Co. Louth.

Tel: 041 987 0700

Fax: 041 987 0706

Contact Name:

Position: Safety & Environmental Officer

e-mail: dduffy@premierpericlase.ie

* Include any townland.

National Grid Reference

(12 digit 6E,6N)

311250, 276100

Location maps (no larger than A3), appropriately scaled, with legible grid references should be enclosed in Attachment No A.2. The site boundary must be outlined on the map in red colour.

Geo-referenced digital drawing files (e.g. AutoCAD files) in Irish Grid projection of the site

boundary and overall site plan, including labelled emission points to surface water and

their monitoring and sampling locations, are also required.

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Page 3

SECTION B: EMISSIONS

B.1 Emissions to Surface Waters

Describe the nature of emissions from the activity to receiving surface waters. Specify

which of these emissions are process discharges and storm/surface water discharges.

Tables B.1(i) and B.1(ii) should be completed.

Please note that monitoring of the discharge(s) for the purposes of Table B.1(ii) shall be

undertaken for the list of compulsory parameters listed in Table D.1(i). Where other

relevant substances have been identified, during the Assessment of Impact on Receiving

Surface Water requested under Section D.1 of this Review Form, monitoring of the

discharge upstream and downstream for the relevant parameters shall also be included.

A summary list of the emission points, together with maps/drawings (no larger than A3)

and supporting documentation should be included as Attachment No B.1.

Attachment No B1 includes the required information and tables.

B.2 Tabular Data on Emission Points to surface water

Licensees should submit the following information for each emission point to surface

water:

Point Code Easting Northing Verified Emission

Provide label

ID’s (e.g.

SW1, SW2*)

6E-digit GPS

Irish National

Grid Reference

6N-digit GPS

Irish National

Grid Reference

Y = GPS used

N = GPS not

used

e.g. Ammonia

(as N),

Biochemical

oxygen

demand

* SW = Surface Water

An individual record (i.e. row) is required for each emission point. Acceptable file formats

include Excel, Access or other upon agreement with the Agency.

The required information is included on a spreadsheet in the CDs.

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Page 4

SECTION C: CONTROL & MONITORING

Describe the proposed technology and other techniques for preventing or,

where this is not possible, reducing emissions from the installation/facility.

C.1 Treatment, Abatement and Control Systems

An overview/summary of treatment/abatement systems for effluent emissions should be

included together with schematics as appropriate.

For each Surface Water Emission Point identified complete Table C.1(i).

Supporting information should form Attachment No C.1.

Normal operation and variations for start-up and shutdown should be described.

Anticipated malfunctions and known problems associated with the treatment should be

highlighted.

Proposed monitoring to be undertaken for influent(s) to treatment plant, and in-

treatment monitoring required for the management of the treatment plant should be

detailed.

Attachment No C1 includes the required information and tables.

C.2 Monitoring and Sampling Points

Identify monitoring and sampling points and outline proposals for monitoring emissions to

surface water bodies.

Table C.2(i) should be completed (where relevant) for emissions to surface water.

Where ambient environment monitoring is carried out or proposed, Table C.2(ii) should

be completed as relevant for each environmental medium and at least 12 samples should

be taken at regular intervals.

Include details of monitoring/sampling locations and methods.

Supporting information should form Attachment No C.2.

Attachment No C2 includes the required information and tables.

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Page 5

C.3 Tabular Data on Monitoring and Sampling Points

Licensees should submit the following information for each monitoring and sampling

point:

Point Code Point Type Easting Northing Verified Pollutant

Provide label

ID’s

M=Monitori

ng

S=Sampling

6E-digit

GPS Irish

National

Grid

Reference

6N-digit

GPS Irish

National

Grid

Reference

Y = GPS

used

N = GPS

not used

e.g.

Ammonia

(as N),

Biochemical

oxygen

demand

An individual record (i.e. row) is required for each monitoring and sampling point.

Acceptable file formats include Excel, Access or other upon agreement with the Agency.

Point source monitoring/sampling refers to monitoring from specific emission points (e.g.

from a wastewater treatment plant). Ambient monitoring includes monitoring of river

quality upstream/downstream of an effluent discharge.

The required information is included on a spreadsheet in the CDs.

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Page 6

SECTION D: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY

D.1 Assessment of Impact on Receiving Surface Water

Describe the existing environment in terms of water quality with particular reference to

environmental quality standards as specified within the EC Environmental Objectives

(Surface Waters) Regulations 2009 S.I. No. 272 of 2009. Table D.1(i) should be completed

as directed.

Indicate whether or not the activity complies with the requirements of the EC

Environmental Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009.

The Licensee should conduct an assessment of impact of discharge(s) from the

installation/facility on receiving surface water. In undertaking this assessment the

Licensee shall have particular regard to substances used in the manufacturing processes

likely to result in discharges of those substances listed in the EC Environmental

Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009. When completing

any assimilative capacity calculations have regard to the Water Services Training Group

‘Guidance to Applicant – Discharge to Surface Waters’ available at

http://www.wsntg.ie/publications/index.asp and other standard guidance.

If the process discharges are to coastal, transitional waters or lakes, the assessment may

require a modelling study. The modelling study shall include estimates on what the

resultant concentrations of the permitted substances in the receiving water body will be

upon discharge at the current licence limits.

Regardless of the receiving water body type, determine the maximum allowable

discharge concentrations to achieve compliance with the 95%ile good status limits. N.B.

If the discharge is to a water body that is already achieving high status, or if the

discharge is to waters draining to the surface water bodies identified under the First

Schedule of the EC Environmental Objectives (Freshwater Pearl Mussel) Regulations

2009, compliance must be with 95%ile high status limits.

State distance from the process discharges to a nearest downstream water dependent

Protected Area. Include the name and code of this Protected Area.

Full details of the assessment, including a copy of an Environmental Impact Statement if

it was required for the purposes of obtaining planning permission(s), should be submitted

as Attachment No D.1.1.

Attachment No D.1.1 includes the required information.

Where necessary, the Licensee should supply detailed information on the proposals to

comply with the requirements of the EC Environmental Objectives (Surface Waters)

Regulations 2009 S.I. No. 272 of 2009 including a detailed timeframe for any proposed

works in Attachment No D.1.2.

Attachment No D.1.2 states that no further measures are needed to comply with EC

Environmental Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009.

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Page 7

D.2 Environmental Considerations and Best Available Techniques (BAT)

Describe, in outline, the main alternatives, if any, to the proposals contained in the

Review Form.

Describe any environmental considerations which were made with respect to the use of

cleaner technologies, waste minimisation and raw material substitution.

Describe the measures proposed or in place to ensure that:

(a) the best available techniques are or will be used to prevent or eliminate or, where

that is not practicable, generally reduce an emission from the activity;

(b) no significant pollution is caused;

(c) waste production is avoided in accordance with Council Directive 75/442/EEC of 15

July 1975 on waste; where waste is produced, it is recovered or, where that is

technically and economically impossible, it is disposed of while avoiding or reducing

any impact on the environment;

(d) energy and other resources are used efficiently;

(e) the necessary measures are taken to prevent accidents and limit their

consequences; and,

(f) the necessary measures are taken upon definitive cessation of activities to avoid

any pollution risk and return the site of operation to a satisfactory state.

This section should present a statement on energy efficiency at the site to include, where

appropriate, an energy audit with reference to the EPA Guidance document on Energy

Audits. Licensees should have regard to Section 5 of the EPA Acts 1992 and 2003 in

selecting BAT and in particular the following:

• The use of low-waste technology;

• The use of less hazardous substances;

• The furthering of recovery and recycling of substances generated and used in

the process and of waste where appropriate;

• Comparable processes, facilities or methods of operation, which have been

tried with success on an industrial scale;

• Technological advances and changes in scientific knowledge and

understanding;

• The nature, effects and volume of the emissions concerned;

• The commissioning dates for new or existing facilities;

• The length of time needed to introduce the BAT;

• The consumption and nature of raw materials, including water, used in the

process and their energy efficiency;

• The need to prevent or reduce to a minimum the overall impact of the

emissions on the environment and the risks to it;

• The need to prevent accidents and to minimize the consequences for the

Environment; and,

• The information published by the Agency in the form of sectoral BAT

Guidance documents and the relevant BREF documents published by the EC

(available for download at http://eippcb.jrc.es/ and at www.epa.ie).

Attachment No D.2 includes the required information.

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EPA Export 13-09-2011:03:41:10

Page 8

SECTION E: STATUTORY REQUIREMENTS

E.1 Best Environmental Practices – Compliance with Legislation

Demonstrate if the best environmental practices are in place for control of diffuse

emissions from the installation/facility as set out in the following legislation:

(a) a specification prepared by the Agency in accordance with Section 5 of the

Environmental Protection Agency Act 1992 as amended by Section 7 of the

Protection of the Environment Act 2003;

(b) the Urban Waste Water Treatment Regulations 2001 (S.I. No. 254 of 2001)

as amended by the Urban Waste Water Treatment (Amendment)

Regulations 2004 (S.I. No. 440 of 2004) or any future amendment thereof;

(c) the European Communities (Good Agricultural Practice for Protection of

Waters) Regulations 2009 (S.I. No. 101 of 2009) or any future amendment

thereof;

(d) the Local Government (Water Pollution) Act, 1977 (Control of Cadmium

Discharges) Regulations 1985 (S.I. No. 294 of 1985);

(e) the Local Government (Water Pollution) Act, 1977 (Control of

Hexachlorocyclohexane and Mercury Discharges) Regulations 1986 (S.I. No.

55 of 1986);

(f) the Local Government (Water Pollution) Acts, 1977 and 1990 (Control of

Carbon Tetrachloride, DDT and Pentachlorophenol Discharges) Regulations

1994 (S.I. No. 43 of 1994); and,

(g) measures or controls identified in a pollution reduction plan for the river

basin district prepared in accordance with Part V of the EC Environmental

Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009 for the

reduction of pollution by priority substances or the ceasing or phasing out of

emissions, discharges and losses of priority hazardous substances.

Attachment No E includes the required information.

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Page 9

SECTION F: APPROVED ADJUSTMENTS & CONDITIONS

Where the Office of Environmental Enforcement (OEE) of the Agency has agreed any

variations or adjustments to the conditions of the existing licence, the licensee must

supply a schedule detailing these agreed variations and adjustments to the existing

licence conditions. An updated, scaled drawing of the site layout (no larger than A3)

providing visual information on such adjustments or variations where appropriate should

be included.

In the case of once-off assessments/ reports required under conditions of the existing

licence the licensee must supply a schedule detailing those assessments/ reports that

have been completed and agreed with the Office of Environmental Enforcement (OEE) or

as otherwise agreed.

Attachment No F1 shall include the schedule of variations and/or adjustments together

with the updated drawing.

Condition

No.

Existing

Condition

Proposed Wording

(where

appropriate)

OEE

Agreement

Reference

Description

Attachment No F includes the required information.

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EPA Export 13-09-2011:03:41:10

Signed by: (on behalf rganis

Company stamp or seal:

PREMIER PERICLASE LTD. BOYNE RD.

ROGHEDA, CO. LOUTH 041-9870700

SECTION G: DECLARATION

Declaration

I certify that the information given in this Review Form is truthful, accurate and complete.

I give consent to the EPA to copy this Review Form 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 via the EPA's website. This consent relates to this Review Form itself and to any further information, submission, objection, or submission to an objection whether provided by me as Licensee, any person acting on the Licensee's behalf, or any other person.

3ti0)1 Date:

LifeRI Ziptz,...R__

014.4-toz

A-urs clot (

Print signature name:

Position in organisation:

Page 10

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Page 11

ANNEX 1: TABLES/ATTACHMENTS

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Page 12

Summary List of the Emission Points to Surface Waters

There is only one emission point to Surface Waters:

SW-1 Discharge of Effluent to Irish Sea

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Page 13

TABLE B.1(i): EMISSIONS TO SURFACE WATERS (One page for each emission)

Emission Point:

Emission Point Ref. No.: SW-1

Source of Emission: Diffuser Pipe

Location : Irish Sea

Grid Ref. (12 digit, 6E,6N): E 316884 N 277175

Name of receiving waters: Irish Sea

Flow rate in receiving waters: Not Applicable m3.sec-1 Dry Weather Flow

Not Applicable m3.sec-1 95%ile flow

Emission Details:

(i) Volume to be emitted

Normal/day 180,000 m3 Maximum/day 190,000 m3

Maximum rate/hour 8.010 m3

(ii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown

to be included):

Periods of Emission (avg) 60 min/hr 24 hr/day 365 day/yr

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Page 14

TABLE B.1(ii): EMISSIONS TO SURFACE WATERS - Characteristics of the emission (One table per emission point)

Emission Point Reference Number: SW1

Parameter Prior to treatment As discharged % Efficiency

Max. hourly

average

(mg/l)

Max. daily

average

(mg/l)

kg/day kg/year Max. hourly

average

(mg/l)

Max. daily

average

(mg/l)

kg/day kg/year

ppm MgO 300 300 570,000 20,810,000 100 100 19,000 6,935,000 Not applicable

pH 12.5 12.5 Not

applicable

Not

applicable

11 11 Not

applicable

Not

applicable

Not applicable

Mineral Oil No

information

No

information

No

information

No

information

20 20 3,800 1,387,000 Not applicable

Chromium (as Cr) No

information

No

information

No

information

No

information

0.5 0.5 95 34,675 Not applicable

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Page 15

TABLE C.1(i): ABATEMENT/TREATMENT CONTROL

Emission Point Reference Number: SW1

Control 1

parameter

Equipment 2 Equipment

maintenance

Equipment

calibration

Equipment

back-up

Monitoring to

be carried out 3

Monitoring

equipment

Monitoring

equipment

calibration

Flow Valve Major Overhaul Not Applicable Spare Parts Hourly pH probe & meter Daily

Rake speed Effluent Clarifier,

Rake, Motor Major Overhaul Not Applicable Spare Parts Continuous Open / Closed

circuit Not Applicable

1 List the operating parameters of the treatment/abatement system which control its function. 2 List the equipment necessary for the proper function of the abatement/treatment system. 3 List the monitoring of the control parameter to be carried out.

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Page 16

TABLE C.2(i): EMISSIONS MONITORING AND SAMPLING POINTS (One table per monitoring point)

Emission Point Reference Number: SW1

Parameter Monitoring frequency Accessibility of Sampling

Points

Sampling method Analysis method/

technique

pH Continuous/Daily Accessible Daily PPL Method At.17

Flow Continuous/Daily See Below See Below See Below

Ppm MgO Daily Accessible Daily PPL Method AT.11

Salinity Monthly Accessible Monthly External Analysis

Calcium Monthly Accessible Monthly External Analysis

Chromium Monthly Accessible Monthly External Analysis

Zinc Monthly Accessible Monthly External Analysis

Nickel Monthly Accessible Monthly External Analysis

Flow Measurement:

Due to tidal influences continuous flow measurement is extremely difficult and inaccurate. Daily reporting is therefore calculated using accurate input measurements.

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Page 17

TABLE C.2(ii): AMBIENT ENVIRONMENT MONITORING AND SAMPLING POINTS (One table per monitoring point)

Monitoring Point Reference Number: ASW1 _________

Parameter Monitoring frequency Accessibility of

Sampling point

Sampling method Analysis method/

technique

Assessment of Sea-water outfall

area including:

(i) Biological survey and

analysis of sediments

(ii) Chemical survey of Sea-

water

Three-yearly By Sub-aqua divers only Spot sampling at distances

100m, 200 and 300 m north and

south of diffuser location, on

flood and ebb tides

The samples were sieved

through a 2mm mesh and the

retained fauna preserved in

alcohol until examined by a

marine biologist.

All parameters except

Carbonate and Bicarbonate

were analysed by the

Environment Agency

laboratory, Leeds, U.K. The EA

is UKAS accredited for

these tests.

Analytical procedures for

carbonate and bicarbonate are

described in Grasshalf, Ehrhardt

and Kreuiling (Eds.), (1983),

"Method of Seawater Analysis",

Verlag - Chemie GmbH,

Weinheim.

pH

∑Nitrogen μg. N/l

∑Phosphorus μg P/l

Sulphate mg SO4/l

Carbonate mmoles

Bicarb. mmoles

Zinc μg Zn/l

Nickel μg Ni/l

Chromium μg Cr/I

Calcium mg Ca/l

Magnesium mg Mg/l

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EPA Export 13-09-2011:03:41:11

Page 18

Table D.1(i) RECEIVING WATER SURFACE WATER QUALITY

Monitoring Point/Grid Reference: ______ASW1____

(Average of results for 200 m north and south and 100 m north and south of diffuser – excludes results for samples taken at outfall)

Parameter Results 1

(mg/l and µg/l)

Sampling method

(grab, drift etc.)

Normal Analytical

Range

Analysis method/

technique

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2004 2007 2010

pH 8.3 7.9 8.1 8.2 8.1 7.8 8.0 8.1 7.8 7.9 8.0 7.9 8.0 Grab

Temperature2 No information Grab

Electrical Conductivity2 No information Grab

Ammonia (as N) 2

No information Grab

Chemical Oxygen demand

2

No Information Grab

Biochemical Oxygen demand

2

No information Grab

Dissolved Oxygen DO2 No information Grab

Total Nitrogen (µg/l N) 0.074 0.259 0.100 0.280 0.029 0.243 0.649 0.197 0.328 0.246 0.171 0.230 0.430

Grab

Nitrite (as N) 2

No information Grab

Nitrate (as N) 2

No information Grab

Total Phosphorous (µg/l P) 0.043 0.022 0.041 0.056 0.028 0.037 0.049 0.043 0.040 0.068 0.023 0.026 0.050

Grab

OrthoPhosphate (as P) 2

No information Grab

Sulphate mg SO4/l 2,625 2,581 2,938 3,056 2,963 2,554 2,794 2,740 2,724 2,709 2,755 2,554 2,382 Grab

Carbonate mmoles 0.21 0.13 0.11 0.11 0.12 0.10 0.08 0.10 0.11 0.12 0.14 0.12 0.13 Grab

Bicarb. mmoles 2.40 1.78 1.82 1.81 1.84 1.79 1.82 1.80 1.82 1.76 1.70 1.72 1.64 Grab

Magnesium mg Mg/l 1,225 1,328 829 1,129 1,772 1,163 1,267 1,257 1,327 1,217 1,263 1,237 1,097 Grab

Calcium mg Ca/l 385 424 427 391 406 390 423 418 459 436 427 428 391 Grab

Zinc µg Zn/l <5 <10 2.2 4.5 4.2 22.8 3.8 2.1 1.4 1.7 1.2 1.4 4.6 Grab

Nickel µg Ni/l <5 <10 0.78 0.39 0.36 0.22 0.51 0.44 0.36 0.26 0.50 0.36 0.94 Grab

Chromium µg Cr/I <10 <10 0.67 1.04 0.90 0.11 0.14 0.21 0.32 0.31 0.82 0.82 1.11 Grab

1 At least 12 samples should be taken at regular intervals.

2See notes below on these parameters

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Page 19

Notes on Parameters not monitored

Parameters for which no information has been provided in the above table have not been monitored because the IPPC licence Register No 0376-

01 does not require them to be monitored.

Condition 6.10 states:

Chemical and biological surveys (conducted since 1980) in the vicinity of the effluent discharge pipe shall be carried out annually and a

summary report submitted as part of the AER.

These parameters were not included in monitoring prior to the application for or grant of licence Register No 0376-01 and hence have not been

monitored since then.

As Premier Periclase does not discharge organic material or nutrients COD, BOD, DO, nitrogen compounds and orthophosphates are not

relevant to the impact of the discharge.

The temperature of seawater and hence the electrical conductivity are seasonal. The discharge by Premier Periclase would not be

expected to have any discernible impact on these parameters would not be expected to have any discernible impact on these parameters.

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Page 20

Summary of the monitoring results

Monitoring Point/Grid Reference: ______ASW1____

(Average of results for 200 m north and south and 100 m north and south of diffuser – excludes results for samples taken at outfall)

Parameter Results 1

(mg/l and µg/l)

Sampling method

(grab, drift etc.)

Normal Analytical Range

Analysis method/

technique

Average 1992-2010 Average 2001-10

pH 8.0 7.9 Grab

Total Nitrogen (µg/l N) 0.249 0.269

Grab

Total Phosphorous (µg/l P) 0.040 0.042

Grab

Sulphate mg SO4/l 2,721 2,600 Grab

Carbonate mmoles 0.12 0.13 Grab

Bicarb. mmoles 1.82 1.70 Grab

Magnesium mg Mg/l 1,239 1,203 Grab

Calcium mg Ca/l 416 420 Grab

Zinc µg Zn/l 4.54 2.24 Grab

Nickel µg Ni/l 0.46 0.52 Grab

Chromium µg Cr/I 0.59 0.76 Grab

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EPA Export 13-09-2011:03:41:11

Page 21

ATTACHMENT No A2: LOCATION OF ACTIVITY

Figure A.2.1 shows the location of the Premier Periclase Ltd facility.

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EPA Export 13-09-2011:03:41:11

E311250

N276100

31

20

00

E

31

00

00

E

274000N

276000N

278000N 278000N

276000N

274000N

31

20

00

E

31

00

00

E

Job No

Drawing Status

Discipline

Scale at A4

Drawing No Issue

© Arup

A4

Drawing Title

Job Title

Do not scale

N0001 P1217893-00

1:30,000

Report

Environmental

Figure: A.2.1

Site Location

Premier Periclase Ltd Review of

IPPC Licence Reg. No. P0376-01

\\D

ubnts03\dublin_jobs\217000\217893-00\4. Internal P

roject D

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Arup, 50 Ringsend Road

Dublin 4

Tel +353(0)1 233 4455 Fax +353(0)1 668 3169

www.arup.ie

N

Ordnance Survey Ireland Licence No. EN0002811 © Government of Ireland

Date

August 2011

Drogheda

Created using CADplot http://www.oasys-software.com/cadplot/

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EPA Export 13-09-2011:03:41:11

Page 23

ATTACHMENT No B1: EMISSIONS

Figure B1.1 shows the emission point and ambient monitoring point.

The emissions to surface waters comprise the treated effluent from the periclase (magnesite)

manufacturing process. No surface water, e.g. site drains, is discharged to the River Boyne.

All surface water goes through the treatment plant and/or into the pipe and discharged with

the treated effluent through the submarine pipeline at Baltray.

1. Introduction

The two main raw materials for the process are sea-water and limestone. The attached

schematic flow chart outlines the process.

Sea-water is taken from the Boyne estuary for approximately eight hours per day, around

high tides, and stored in a large reservoir. About 150,000m3 of sea-water are used each day

and are pumped through a large underground pipeline to the magnesia plant, four miles

upstream. Up to seven million litres of fresh water per day are also required for the process.

Sulphuric acid is used in the purification (i.e., carbonate removal) of both sea-water and

fresh water.

2. Surface Water Management and Protection

Any rainwater falling on the site is generally either absorbed by the dry limekiln (ESP) dust

or collected in the sludge settlement lagoons. There is no surface water run-off out of the

existing landfill over surrounding soils or watercourses. Any ponding within the landfill

generally either evaporates or is absorbed into the underlying waste. Rainwater falling on

lime fines is incorporated into the lime by hydration.

3. Wet - End System

3.1 Sea-water Supply

Sea-water is extracted from the Boyne estuary at Baltray over two four hour periods at each

high tide and pumped to a 300,000m3 Sea-water Reservoir. From here the water is pumped

on a continuous basis some 3.5 km through a 1.5m diameter underground pipeline to the

factory.

There the sea-water passes through a softener consisting of Sulphuric Acid Injection

combined with a Degassing tower which removes CO2 from the water. The sea-water then

passes to a 56m diameter Sea-water Clarifier where sand or other suspended solids are

settled out and removed.

3.2 Wet-end Reaction

Sea-water from the clarifier enters the reactor where it is mixed with slaked lime to produce

magnesium hydroxide. To assist the reaction, some previously produced magnesium

hydroxide slurry is recycled to the reactor to act as seed. The reactor is 30m in diameter and

6.5m deep. Internal agitation keeps settling to a minimum and the liquid overflow is passed

to two settling (or thickening) tanks where magnesium hydroxide separates from the sea-

water and thickens with the aid of a flocculant. From here the magnesium hydroxide slurry

is sent to two Secondary Thickeners for further settling.

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Page 24

The overflow from the primary and secondary thickeners, or spent sea-water, returns to sea,

via the Effluent Clarifier. In the clarifier, fresh sea-water is used to neutralise excess lime in

the overflow and a floating bed of precipitate is used as a final filter. These processes reduce

pH and suspended solids in the spent sea-water in which calcium chloride has replaced

magnesium chloride. Quality assurance testing monitors overall control of the wet end

system including (inter alia) seawater degassing and suspended solids quality, degree of

reaction, chemical analysis and settling characteristics of precipitated product, and effluent

pH and solids concentration. Full details and test descriptions are contained in the laboratory

manual QD.2, maintained by the company but not included with this application.

3.3 Filtration

Thickened magnesium hydroxide solids are separated from sea-water by filtration, using

three large rotary vacuum Drum Filters and two Belt Press Filters. The final "cake" from

the filtration stage now contains about 70% solids (30% water). Quality assurance testing

monitors filter feed density, % solids and washing efficiency by chloride testing. Full details

and test descriptions are contained in the laboratory manual QD.2, maintained by the

company but not included with this application.

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EPA Export 13-09-2011:03:41:11

Page 25

Summary of Effluent Monitoring Results 1992-2010

Basis: Samples provided by Premier Periclase Ltd to Forbairt when sampling water and sediment at ASW-1.

Parameter Year

1992 1993 1994 1995 1996 1997 1998

pH 10.8 8 10.8 10.4 10.1 10.7 10.3

∑Nitrogen μg N/l 60 380 100 340 30 427 <0.04

∑Phosphorus μg P/l <5 15 18 <5 15 20 0.02

Sulphate μg SO4/l 2600 2500 2900 3000 3000 2580 2700

Zinc μg Zn/l <5 <10 2.1 <2 3.8 5.16 3.74

Nickel μg Ni/l <5 <10 0.85 0.78 0.195 0.175 0.198

Chromium μg Cr/l <10 20 20.1 21 16.4 18.7 15.9

Calcium mg Ca/l 2500 2400 3123 1998 2480 2310 2305

Magnesium mg Mg/l 5 30 83 40.8 5.4 54 87

Iron as μg Fe/l 38 40 12 31

Parameter Year

1999 2000 2001 2004 2007 2010

pH 10.4 10.7 10.4 10.1 9.8 9.1

∑Nitrogen μg N/l 134 576 805 184 280 213

∑Phosphorus μg P/l 39 16 25 <20 <20 <20

Sulphate μg SO4/l 2640 2670 2740 2820 2610 2460

Zinc μg Zn/l 17.2 3.87 2.95 2.1 0.43 <0.4

Nickel μg Ni/l 0.588 <0.058 0.62 3.86 0.34 0.54

Chromium μg Cr/l 20.3 13.3 29.8 11 27.9 26.6

Calcium mg Ca/l 2270 2480 2360 2390 2270 2280

Magnesium mg Mg/l 60 34.2 40.6 80 34.5 73.4

Iron as μg Fe/l 26 19.6 43.5 22.8 <100 106

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EPA Export 13-09-2011:03:41:11

Page 26

Tabular Data on Emission Points to surface water

Point Code Easting Northing Verified Emission

SW1 311575 276020 N – GPS not

used

The following effluent

parameters are monitored:

Total Nitrogen

Total Phosphorus

Sulphate

Zinc

Nickel

Chromium

Calcium

Magnesium

Iron

This table is included on the CD.

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EPA Export 13-09-2011:03:41:11

AN5 ASW1

ASW1

E316914

N277150

SW1

SW1

E311883

N276124

277500N

275000N

31

50

00

E

31

25

00

E

31

00

00

E

277500N

275000N

31

50

00

E

31

25

00

E

31

00

00

E

A3 A

1

B C D E F G H

Job No

Drawing Status

Discipline

Scale at A3

Drawing No Issue

Drawing Title

Issue Date By Chkd Appd

Job TitleClient

2

3

4

5

Do not scale © Arup

N0002 P1217893-00

1:20,000

Report

Environmental

Figure: B.1.1

Surface Water Emission Point

and Monitoring Points

Premier Periclase Ltd

Review of IPPC Licence

Reg. No. P0376-01

Premier Periclase

Boyne Road, Drogheda,

Co. Louth

Arup, 50 Ringsend Road

Dublin 4

Tel +353(0)1 233 4455 Fax +353(0)1 668 3169

www.arup.ie

\\D

ubnts03\dublin_jobs\217000\217893-00\4. Internal P

roject D

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1.dw

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/ /P1 30 08 11 GMcT DM DM

N

Ordnance Survey Ireland Licence No. EN0002811 © Government of Ireland

1.0 Km

0.50.3

0.4

Scale 1:20,000

0.1

0 0.2

ASW1

Ambient Surface

Water Monitoring

Discharge Pipe

Legend:

SW1

Surface Water

Sampling Point

Created using CADplot http://www.oasys-software.com/cadplot/

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EPA Export 13-09-2011:03:41:11

Page 28

ATTACHMENT No C1: CONTROL & MONITORING

1. Introduction

The two main raw materials for the process are sea-water and limestone. The attached

schematic flow chart outlines the process.

Sea-water is taken from the Boyne estuary for approximately eight hours per day,

around high tides, and stored in a large reservoir. About 150,000m3 of sea-water are

used each day and are pumped through a large underground pipeline to the magnesia

plant, four miles upstream. Up to seven million litres of fresh water per day are also

required for the process. Sulphuric acid is used in the purification (i.e., carbonate

removal) of both sea-water and fresh water.

2. Wet - End System

2.1 Sea-water Supply

Sea-water is extracted from the Boyne estuary at Baltray over two four hour periods at

each high tide and pumped to a 300,000m3 Sea-water Reservoir. From here the water

is pumped on a continuous basis some 3.5 km through a 1.5m diameter underground

pipeline to the factory.

There the sea-water passes through a softener consisting of Sulphuric Acid Injection

combined with a Degassing tower which removes CO2 from the water. The sea-water

than passes to a 56m diameter Sea-water Clarifier where sand or other suspended

solids are settled out and removed.

2.2 Wet-end Reaction

Sea-water from the clarifier enters the reactor where it is mixed with slaked lime to

produce magnesium hydroxide. To assist the reaction, some previously produced

magnesium hydroxide slurry is recycled to the reactor to act as seed. The reactor is

30m in diameter and 6.5m deep. Internal agitation keeps settling to a minimum and the

liquid overflow is passed to two settling (or thickening) tanks where magnesium

hydroxide separates from the sea-water and thickens with the aid of a flocculant. From

here the magnesium hydroxide slurry is sent to two Secondary Thickeners for further

settling.

The overflow from the primary and secondary thickeners, or spent sea-water, returns

to sea, via the Effluent Clarifier. In the clarifier, fresh sea-water is used to neutralise

excess lime in the overflow and a floating bed of precipitate is used as a final filter.

These processes reduce pH and suspended solids in the spent sea-water in which

calcium chloride has replaced magnesium chloride. Quality assurance testing monitors

overall control of the wet end system including (inter alia) seawater degassing and

suspended solids quality, degree of reaction, chemical analysis and settling

characteristics of precipitated product, and effluent pH and solids concentration. Full

details and test descriptions are contained in the laboratory manual QD.2, maintained

by the company but not included with this application.

Table C1.1 summarises material inputs and outputs and also outlines any relevant

environmental details.

Treated effluent is sampled every hour and a 24 hour composite sample is produced

for analysis.

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Page 29

The operation of the treatment plant does not vary from normal during start-up and

shutdown of the plant. The only anticipated malfunction or known problem is high

suspended solids caused by adverse weather conditions in which case the wet process

is shut down.

Monitoring of influent is part of normal production and on-treatment monitoring is not

required for the management of the treatment plant.

Full details (where applicable) of environmental emissions are given under section C,

question 12 and/or question 13 and monitoring details under section, C question 18.

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EPA Export 13-09-2011:03:41:11

Page 30

Table C1.1 Wet - End Process Summary

Plant

/Equipment

Material Inputs Material Outputs Environmental/Waste Emissions

Type Typical

Input

Type Typical

Output

Type Abatement

Equipment

Emission

Point

Ref. Point

1 x Seawater

Degasser

(i) Seawater 6,750 m3/hr Degassed

Seawater

6,750 m3/hr None Not

Applicable

Not

Applicable

Not

Applicable.

(ii) Sulphuric

Acid

0.9 t/hr

(iii) Antifoam 2.1 kg/hr

1 x Seawater

Clarifier

(i) Degassed

Seawater

6,750 m3/hr Clarified

Seawater

6,750 m3/hr Settled

Magnesium

Hydroxide

Solids

Settling Pond Waste to

Tip-head

Not

Applicable

(ii) Magnesium

Hydroxide

Underflow

100 m3/hr

(iii) Flocculant 0.8 kg/hr

Slaker (i) Process

Water

180 m3/hr Lime Slurry 200 m

3/hr Slaker Grits None Waste to

Tip-head

Not

Applicable

(ii) Lime 22 t/hr

1 x Reactor (i) Clarified

Seawater

6,250 m3/hr Magnesium

Hydroxide Slurry

7,700 m3/hr Reactor Grits Settling Pond Waste to

Tip-head

Not

Applicable

(ii) Lime Slurry 200 m3/hr

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EPA Export 13-09-2011:03:41:11

Page 31

Plant

/Equipment

Material Inputs Material Outputs Environmental/Waste Emissions

Type Typical

Input

Type Typical

Output

Type Abatement

Equipment

Emission

Point

Ref. Point

(iii) Seed 1,250 m3/hr

2 x Primary

Thickeners

(i) Magnesium

Hydroxide

Slurry

7,750 m3/hr (i) Thickened

Magnesium

Hydroxide

70 m3/hr None Not

Applicable

Not

Applicable

Not

Applicable

(ii) Filtrate

Returns

95 m3/hr (ii) Seawater

Overflow

6,530 m3/hr

(iii) Sec. Thick.

Overflow

5 m3/hr (iii) Seed 1,250 m

3/hr

(iv) Flocculant 2.7 kg/hr

1 x Effluent

Clarifier

(i) Seawater

Overflow

6,530 m3/hr (i) Spent

Seawater

6,930 m3/hr Spent

Seawater: pH

Suspended

Solids

Settling Pond

and floating

filter bed

Seawater

outfall

ASW- 1

(ii) Clarified

Seawater

500 m3/hr (ii) Magnesium

Hydroxide

Underflow

100 m3/hr

(iii) Flocculant 0.5 kg/hr

2 x

Secondary

Thickeners

(i) Thickened

Magnesium

Hydroxide

Slurry

70 m3/hr (i) Thickened

Magnesium

Hydroxide Slurry

65 m3/hr None Not

Applicable

Not

Applicable

Not

Applicable

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EPA Export 13-09-2011:03:41:11

Page 32

Plant

/Equipment

Material Inputs Material Outputs Environmental/Waste Emissions

Type Typical

Input

Type Typical

Output

Type Abatement

Equipment

Emission

Point

Ref. Point

(ii) Flocculant 0.5 kg/hr (ii) Seawater

Overflow

5 m3/hr

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EPA Export 13-09-2011:03:41:11

Page 33

2.3 Filtration

Thickened magnesium hydroxide solids are separated from sea-water by filtration,

using three large rotary vacuum Drum Filters and two Belt Press Filters. The final

"cake" from the filtration stage now contains about 70% solids (30% water). Quality

assurance testing monitors filter feed density, % solids and washing efficiency by

chloride testing. Full details and test descriptions are contained in the laboratory

manual QD.2, maintained by the company but not included with this application.

Table 9.4.3 summarises material inputs and outputs and also outlines any relevant

environmental details.

Full details (where applicable) of environmental emissions are given under section C,

question 12 and/or question 13 and monitoring details under section, C question 18.

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EPA Export 13-09-2011:03:41:12

Page 34

Table C1.2 Filtration Process Summary

Plant

/Equipment

Material Inputs Material Outputs Environmental/Waste Emissions

Type Typical

Input

Type Typical Output Type Abatement

Equipment

Emission

Point

Ref. Point

2 x

Degassing

Towers and

Basin

(i) Fresh Water 300 m3/hr Degassed Process

Water

300 m3/hr None Not

Applicable

Not

Applicable

Not

Applicable

(ii) Sulphuric Acid 0.1 t/hr

(iii) Caustic Soda

Liquor

4 l/hr

3 x Rotary

Drum Filters

(i) Thickened

Magnesium

Hydroxide Slurry

65 m3/hr (i) Filtered

Magnesium

Hydroxide (50-

55% solids)

60 tph None Not

Applicable

Not

Applicable

Not

Applicable

(ii) Process Wash

water

55 m3/hr (ii) Filtrate Returns 90 m

3/hr

2 x Belt

Presses

Filtered

Magnesium

Hydroxide (50-

55% solids)

60 t/hr (i) Filtered

Magnesium

Hydroxide (65-

70% solids)

50 t/hr None Not

applicable

Not

Applicable

Not

Applicable

(ii) Filtrate Returns 5 m3/hr

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Page 35

3. Process Control

All processes are controlled by fully automated PLC, computerised microprocessing

and automated processing control systems (SCADA system). Inputs to controls are

monitored in control rooms 24 hrs per day by dedicated operators. The control

systems include both hardwired and softwired failsafe shut down systems for

protection in the event of power failure.

Details of the process control systems are contained in the operating manuals

maintained by the company as part of its ISO 9002 Quality System and other

documentation, not included with this application but available from the company.

Details of environmental monitoring equipment are given under section C, question

12 and/or question 13 and monitoring details under section, C question 18.

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Thickener /

Settling

Thickener /

Settling

Effluent

Clarifier

Seawater

Clarifier

Reactor

Seawater

Reservoir

Settling Pond

Weir

To Sea

Seawater

Degasser

Job No

Drawing Status

Discipline

Scale at A4

Drawing No Issue

© Arup

A4

Drawing Title

Job Title

Do not scale

N0003 P1217893-00

NTS

Report

Environmental

Figure: C.1.1

Effluent Clarifier Schematic

Premier Periclase Ltd Review of

IPPC Licence Reg. No. P0376-01

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Arup, 50 Ringsend Road

Dublin 4

Tel +353(0)1 233 4455 Fax +353(0)1 668 3169

www.arup.ie

Ordnance Survey Ireland Licence No. EN0002811 © Government of Ireland

Date

August 2011

Created using CADplot http://www.oasys-software.com/cadplot/

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Page 37

ATTACHMENT No C2: CONTROL & MONITORING

1. Introduction

Enterprise Ireland has been monitoring the chemical and biological characteristics of

an area off Baltray, Co. Louth, since 1980. The area receives the effluent discharge

from the Premier Periclase magnesite production plant at Drogheda.

Previous monitoring has measured chemical characteristics of sea water in the vicinity

of the effluent plume and the results have shown that, based on the parameters

measured, there was little or no measurable impact on water quality resulting from the

discharge.

2. Method

2.1 Biological Samples

Samples of bottom sediment are collected from the sites indicated in Table 4.

The samples are sieved through a 2mm mesh and the retained fauna preserved in

alcohol until examined by a marine.

2.2 Water Samples

Water samples are collected from the following sites lm below the surface and lm

above the sea bed:

200 m North of outfall

100 m North of outfall

100 m South of outfall

200 m South of outfall

The samples are collected using a metal-free water sampler on ebb and flood tides.

One sample of final effluent is provided by the company on each sampling occasion.

The samples are analysed for the following parameters:

pH

Total Nitrogen

Total Phosphorus

Sulphate

Carbonate

Bicarbonate

Zinc

Nickel

Chromium

Calcium

Magnesium

All parameters except Carbonate and Bicarbonate are analysed by the Environment

Agency laboratory, Leeds, U.K. The EA is UKAS accredited for these tests.

Analytical procedures for carbonate and bicarbonate are described in Grasshalf,

Ehrhardt and Kreuiling (Eds.), (1983), "Method of Seawater Analysis", Verlag-

Chemie GmbH, Weinheim.

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Page 38

2.3 Sediment Samples

Samples of sediment are collected for chemical analysis from five locations using a

stainless steel van Veen grab. The sediments are analysed for nickel, zinc, chromium,

calcium and magnesium by the EA. These samples are collected from the following

locations:

200 m North of outfall

100 m North of outfall

100 m South of outfall

200 m South of outfall

2 km East of outfall

3. Comments on Results

3.1 Sea Water chemistry

There were slight increases in pH and in the concentration of chromium in the vicinity

of the outfall. The increases are not environmentally significant.

3.2 Biological results

Biological data shows that diversity similar on each sampling occasion. The number

and diversity of animals in the sediment at the outfall site is broadly similar to the

sample sites at 100m, 200m and the outfall.

3.3 Sediment analysis

Analysis of sediments from the vicinity of the outfall for metals content shows that the

levels of nickel, zinc and chromium are comparable to the metal levels found in

sediment at a control site 2km east of the outfall. Enterprise Ireland maintains a

database of metal levels found Irish ports and harbours. The metal levels at all sites

sampled were at the lower end of the range found in Irish ports and harbours.

3.4 Conclusions

The results of the seawater quality survey show that the effluent had no effect on sea

water quality outside the immediate discharge area.

Biological data showed that diversity is similar on each sampling occasion. The

number and diversity of animals in the sediment at the outfall site is broadly similar to

sites some distance from the outfall.

Analysis of sediments from the vicinity of the outfall for metals content shows that the

levels of nickel, zinc and chromium were comparable to the metal levels found in

sediment at a control site 2km east of the outfall. The metal levels at all sites sampled

were at the lower end of the range found in Irish ports and harbours.

Based on water and sediment quality and on biological data, the opinion of Enterprise

Ireland is that the effluent discharge has no significant impact on environmental

quality.

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ASW1

Sediment

N

Ordnance Survey Ireland Licence No. EN0002811 © Government of Ireland

Job No

Drawing Status

Discipline

Scale at A4

Drawing No Issue

© Arup

A4

Drawing Title

Job Title

Do not scale

N0004 P1217893-00

1:50,000

Report

Environmental

Figure: C.2.1

Sampling Sites for Water and

Biological Samples

Premier Periclase Ltd Review of

IPPC Licence Reg. No. P0376-01

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Arup, 50 Ringsend Road

Dublin 4

Tel +353(0)1 233 4455 Fax +353(0)1 668 3169

www.arup.ie

Date

August 2011

1.5 Km10.4

0.5

Scale 1:25,000

0.20

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ASW1

Ambient Surface

Water Monitoring

Discharge Pipe

Legend:

Sampling Sites

Created using CADplot http://www.oasys-software.com/cadplot/

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Page 40

ATTACHMENT No D.1.1 ASSESSMENT OF IMPACT ON RECEIVING SURFACE

WATERS

Description of the existing environment in terms of water quality with

particular reference to environmental quality standards as specified within

the EC Environmental Objectives (Surface Waters) Regulations 2009 S.I.

No. 272 of 2009. Table D.1(i) should be completed as directed.

The surface waters into which the treated effluent is discharge are the Irish Sea. The

discharge pipe is laid in/on the sea bed for a distance of 1.6 km from the coast. The

discharge pipe terminates in a diffuser. The depth of water at this location is

approximately 3.5 m.

The EPA Report on Water Quality in Ireland 2007-2009 (Chapter 5, Appendix 1)

gives information on the Boyne Estuary Plume Zone, which is reproduced in Table

D1.1.1. Figure D.1.1.1 shows the plume zone.

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EPA Export 13-09-2011:03:41:12

N

Ordnance Survey Ireland Licence No. EN0002811 © Government of Ireland

Job No

Drawing Status

Discipline

Scale at A4

Drawing No Issue

© Arup

A4

Drawing Title

Job Title

Do not scale

N0005 P1217893-00

1:50,000

Report

Environmental

Figure: D.1.1.1

Boyne Estuary Plume Zone

Premier Periclase Ltd Review of

IPPC Licence Reg. No. P0376-01

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Arup, 50 Ringsend Road

Dublin 4

Tel +353(0)1 233 4455 Fax +353(0)1 668 3169

www.arup.ie

Date

August 2011

2.5 Km21.51

Scale 1:50,000

0 0.5

Boyne Estuary

Plume Zone

Boyne Estuary

Discharge Pipe

Legend:

Created using CADplot http://www.oasys-software.com/cadplot/

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EPA Export 13-09-2011:03:41:12

Page 42

Table D1.1.2 – Chapter 5 Appendix 1: Summary statistics for individual water bodies assessed between 2007-2009.

Boyne Estuary Plume Zone

Summary

Stats Salinity

Temp

(°C) pH

Secchi

(m)

DO sat.

(%)

DO

(mg/l)

BOD

(mg/l)

TON

(mg/l)

NH3

(mg/l)

DIN

(mg/l)

MRP

(µg/l)

Chl. a

(µg/l)

Winter MINIMUM 32.95 0.13 0.130 16

MEDIAN 33.53 0.15 0.156 20

MAXIMUM 33.99 0.16 0.163 27

No. of

samples 8 8 8 8

Summer MINIMUM 22.80 11.92 8.0 1.8 90.4 7.6 < 1.5 0.00 < 0.01 0.015 < 10 < 2

MEDIAN 33.64 14.37 8.1 2.9 96.5 8.2 < 1.5 0.01 0.01 0.035 10 4.0

MAXIMUM 34.25 15.51 8.3 4.3 106.1 9.0 1.9 0.30 0.08 0.310 80 7

No. of

samples 48 48 48 18 48 48 20 48 48 48 48 48

TSAS criteria Threshold Value Unpolluted

Winter DIN 0.378 0.156 Pass

Winter MRP 42 20 Pass

DIN- 0.378 0.035 Pass

MRP- 42 10 Pass

Chloro. Median 10.6 4.0 Pass

Chloro 90 percentile 21.1 7.0 Pass

Opportunistic algae 0.6

DO%sat 5 percentile 79 91.9 Pass

DO%sat 95 percentile 121 104.8 Pass

BOD 4 1.9 Pass

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Page 43

Enterprise Ireland (formerly Forbairt, Eolas and IIRS) has been monitoring the

chemical and biological characteristics of an area off Baltray, Co. Louth, since 1980.

The following parameters have been sampled. Initially the samples were taken at

yearly intervals. With the agreement of the Agency, since the year 2001 sampling has

been at at three yearly intervals.

pH

Total Nitrogen

Total Phosphorus

Sulphate

Carbonate

Bicarbonate

Zinc

Nickel

Chromium

Calcium

Magnesium

In addition, bottom sediment has been sampled and analysed for occurrence of species

of fauna.

The Enterprise Ireland reports have consistently summarised the receiving

environment by stating that based on water and sediment quality and on biological

data, it is apparent that the effluent discharge has no significant impact on

environmental quality.

Table D1.1.2 summarises the impact on the quality of the receiving waters.

The only parameter that is common to the IPPC licence (ELVs) and the environmental

quality standards as specified within the EC Environmental Objectives (Surface

Waters) Regulations 2009 S.I. No. 272 of 2009 is chromium. However, no EQS has

been set for coastal waters for Chromium-III, the type of chromium that is used by

Premier Periclase. Premier Periclase does not use Chromium-VI.

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Page 44

Table D1.1.2 – SI No 272 of 2009

COASTAL WATERS

A - Ecological Status

Physico-chemical conditions supporting the biological elements

(i) Thermal Conditions

Requirement EPA Data Data Comment

Not greater than a 1.5°C rise in

ambient temperature outside the

mixing zone

Median summer temperature in

Boyne Estuary Plume Zone is

14.37°C.

No data available on temperature of

effluent.

No conclusion can be drawn.

(ii) BOD

Requirement EPA Data Data Comment

No EQS set for coastal waters. Median summer BOD in Boyne

Estuary Plume Zone is <1.9 mg

O2/l.

No data available on BOD of

effluent. The IPPC licence does

not require monitoring of the BOD.

No conclusion can be drawn.

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Page 45

(iii ) Oxygenation Conditions

Requirement EPA Data Data Comment

Dissolved oxygen lower limit: (35

psu) 95%ile >80% Saturation.

Dissolved oxygen upper limit: (35

psu) 95%ile <120% saturation

Median summer DO in Boyne

Estuary Plume Zone is 8.2 mg/l,

96.5% saturation. 5-95%

percentile range is 79-121.

No data available on dissolved

oxygen (DO) of the effluent. The

IPPC licence does not require

monitoring of the DO.

EPA Data shows waters are

classified as unpolluted.

(iv) pH (Acidification Status)

Requirement EPA Data Data Comment

None Median summer pH in Boyne

Estuary Plume Zone is 8.1.

The pH of the effluent is

approximately 10.5, which is

within the licence limit of 11.0

The pH of the receiving waters is

7.8-8.0.

No conclusion can be drawn.

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Page 46

(v) Nutrient Conditions – Ammonia

Dissolved Inorganic Nitrogen (mg N/l)

Requirement (Coastal Waters) EPA Data Data Comment

Good status (0 psu

1)l ≤2.6 mg N/l In Boyne Estuary Plume

Zone winter and summer

DIN medians are 0.156

and 0.035 mg/l

respectively.

2010 Survey:

0.4 mg/l Flood tide, 0.6 mg/l Ebb

tide

EPA Data shows waters are

classified as unpolluted. (34.5 psu) ≤0.25 mg N/l

High status (34.5 psu) ≤0.17 mg/N/l

(vi) Nutrient Conditions – Phosphorus

Molybdate Reactive Phosphorus (MRP)

Requirement EPA Data Data Comment

No EQS

has been set

for coastal

waters

In Boyne Estuary Plume

Zone winter and summer

DIN medians are 20 and

10 mg/l respectively.

2010 survey: The concentration of

phosphorous in the effluent is

below the limit of detection (0.013

mg/l).

The concentration in the receiving

waters is 25-30 mg/l.

No conclusion can be drawn.

1 Linear interpolation to be used to establish the limit value for water bodies between these salinity levels based on the median salinity of the

water body being assessed.

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Page 47

(vii) Specific Pollutants

Arsenic

Requirement EPA Data Data Comment

Environmental Quality Standard

(EQS) – Annual Average (AA): 20

µg/l

The average concentration of

arsenic in effluent in 2008-2010

was 1.77 µg/l. The concentration is

not measured in the receiving

waters.

No conclusion can be drawn.

Chromium

Requirement EPA Data Data Comment

For non-inland waters No EQS has

been set for chromium other than

Chromium VI.

The average concentration of total

chromium in effluent in 2008-2010

was 15.5 µg/l.

The concentration in the receiving

waters is 1-1.5 µg/l.

No conclusion can be drawn.

EQS – Annual Average (AA):

Chromium VI: 0.6 µg/l; Maximum

Allowable Concentration (MAC):

32 µg/l

PPL do not use Chromium VI. The

chromium salts used are Chromium

III. See attached Material Safety

Data Sheet.

No conclusion can be drawn.

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Page 48

Copper

Requirement EPA Data Data Comment

Environmental Quality Standard

(EQS) – Annual Average (AA): 10

µg/l

The average concentration of

copper in effluent in 2008-2010

was 3.92 µg/l. The concentration is

not measured in the receiving

waters.

No conclusion can be drawn.

Zinc

Requirement EPA Data Data Comment

Environmental Quality Standard

(EQS) – Annual Average (AA): 40

µg/l

The maximum concentration of

zinc in effluent in 2008-2010 was

3.73 µg/l. The concentration in the

receiving waters was 1-3 µ/l.

Complies.

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Page 49

B - Chemical Status

Priority Substances

(a) Lead

Requirement EPA Data Data Comment

Environmental Quality Standard

(EQS) – Annual Average (AA):

7.2 µg/l

The maximum concentration of

lead in effluent in 2008-2010 was

0.194 µg/l. The concentration in

the receiving waters was 1-3 µ/l

Complies.

(b) Nickel

Requirement EPA Data Data Comment

Environmental Quality Standard

(EQS) – Annual Average (AA): 20

µg/l

The average concentration of nickel

in effluent in 2008-2010 was 2.04

µg/l. The concentration in the

receiving waters was 1 µg/l.

Complies.

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Page 50

Priority Hazardous Substances

(c) Cadmium

Requirement EPA Data Data Comment

Environmental Quality Standard

(EQS) – Annual Average (AA):

0.2 µg/l; Maximum Allowable

Concentration (MAC): 1.5 µg/l.

The average concentration of

cadmium in effluent in 2008-2010

was below the limit of detection,

0.09 µg/l.. The concentration of

cadmium is not measured in the

receiving waters.

No conclusion can be drawn.

(d) Mercury

Requirement EPA Data Data Comment

Environmental Quality Standard

(EQS) – Annual Average (AA):

0.05 µg/l; Maximum Allowable

Concentration (MAC): 0.07 µg/l.

The average concentration of

mercury in effluent in 2008-2010

was about the limit of detection, 0.2

µg/l. The concentration is not

measured in the receiving waters.

No conclusion can be drawn.

C - Summary

The quality of the receiving waters complies with the requirements of the Regulations, SI No 272 of 2009.

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Page 51

Requirements of the EC Environmental Objectives (Surface Waters)

The activity complies with the requirements of the EC Environmental Objectives

(Surface Waters) Regulations 2009 S.I. No. 272 of 2009.

Assimilative Capacity

The only substances listed in the EC Environmental Objectives (Surface Waters)

Regulations 2009 S.I. No. 272 of 2009 that are discharged by Premier Periclase are

listed in Table D1.1.1. Based on analysis of the receiving waters over 30 years, the

impact of the discharge is insignificant.

The effluent and receiving waters have been sampled and analysed for total chromium.

The EQS is for Chromium VI. No EQS has been set for total chromium in waters that

are not inlet waters. PPL do not use Chromium VI. The chromium salts used are

Chromium III. See attached Material Safety Data Sheet.

Modelling Study

A modelling study is not required because of the insignificant impact on the quality of

the receiving waters.

Maximum Allowable Discharge Concentrations

DIN

The average background concentration of Dissolved Inorganic Nitrogen (DIN) over

the last 10 years is 0.212 mg/l. No EQS has been set for transitional waters. The EQS

for coastal waters is 0.35 mg/l for Good Status and 0.17 mg./l for High status. Hence

even if no DIN is discharged, High Status cannot be attained. The maximum

allowable discharge concentration (MADC) of DIN in the effluent to sustain Good

Status is 0.4 mg/l.

The average concentration over the last 10 years is 0.37 mg/l, which is less than the

calculated MADC.

MRP

The average background concentration of total phosphorous over the last 10 years is

0.035 mg/l. The concentration of Molybdenum Reactive Phosphate (MRP) has not

been determined. The EQS for transitional waters is 0.4 mg/l for unspecified status.

The maximum allowable discharge concentration (MADC) of MRP in the effluent is

0.59 mg/l.

The average concentration over the last 10 years is <0.02 mg/l, which is less than the

calculated MADC.

Zinc

The average background concentration of zinc over the last 10 years is 2.24 µg/l. The

EQS (Annual Average) for transitional waters is 40 µg/l for unspecified status. The

maximum allowable discharge concentration (MADC) of zinc in the effluent is 187

µg/l.

The average concentration over the last 10 years is 1.8 µg/l, which is less than the

calculated MADC.

Nickel

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Page 52

The average background concentration of nickel over the last 10 years is 0.52 µg/l.

The EQS (Annual Average) for transitional waters is 20 µg/l for unspecified status.

The maximum allowable discharge concentration (MADC) of nickel in the effluent is

96 µg/l.

The average concentration over the last 10 years is 1.3 µg/l, which is less than the

calculated MADC.

Chromium

Chromium VI is not used by PPL. All chromium salts used re Chromium III. See

attached Material Safety Data Sheet.

The average background concentration of chromium over the last 10 years is 0.76 µg/l.

The EQSs for Chromium VI for non-inland waters is 0.6 µg/l (annual average) and 32

µg/l (maximum allowable concentration), for unspecified status. Chromium VI is not

used by PPL. All chromium salts used re Chromium III. See attached Material Safety

Data Sheet.

As PPL do not use Chromium VI there is no risk of Cr-VI contamination.

EC Environmental Objectives (Freshwater Pearl Mussel) Regulations 2009

The discharge is not to waters draining the surface water bodies identified under the

First Schedule of the EC Environmental Objectives (Freshwater Pearl Mussel)

Regulations 2009.

Nearest Downstream Water Dependent Protected Area

Figure D.1.1.2 shows relevant protected areas.

These include:

A Special Protected Area (SPA) that extends within the Boyne and its estuary from

Drogheda to approximately xx m from the high water line and

A Special Area of Conservation (SAC) that extends within the Boyne and its estuary

from Drogheda to approximately xx m from the high water line and north and south of

the mouth of the Boyne for several kilometres.

A proposed Natural Heritage Area (pNHA) of similar extent to the SAC, but extending

to coastal terrain.

The discharge location is within the Boyne Estuary Plume Zone but approximately

500 m to the east of the protected areas listed above.

The Boyne Estuary Plume Zone covers an area of approximately 4.6km2. It was

assessed by the Eastern River Basin District (ERBD) as being “At Risk” based on the

port tonnage (morphology test CM4A). Overall, the zone is classified as being High

Quality Status. (ERBD)

An Environmental Impact Statement was not required for the purposes of any

application for planning permission in respect of the Premier Periclase Ltd facility.

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EPA Export 13-09-2011:03:41:12

277500N

275000N

31

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277500N

275000N

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B C D E F G H

Job No

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Issue Date By Chkd Appd

Job TitleClient

2

3

4

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Do not scale © Arup

N0006 P1217893-00

1:20,000

Report

Environmental

Figure: D1.1.2

Protected Areas

Premier Periclase Ltd

Review of IPPC Licence

Reg. No. P0376-01

Premier Periclase

Boyne Road, Drogheda,

Co. Louth

Arup, 50 Ringsend Road

Dublin 4

Tel +353(0)1 233 4455 Fax +353(0)1 668 3169

www.arup.ie

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nvironm

ental\N

0006_217893-00_P

1.dw

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ep 2011 11:50:28

/ /P1 30 08 11 GMcT DM DM

N

Ordnance Survey Ireland Licence No. EN0002811 © Government of Ireland

1.0 Km

0.50.3

0.4

Scale 1:20,000

0.1

0 0.2

Legend:

Special Protection Areas (SPA)

Proposed Natural Heritage Areas (pNHA)

Special Area of Conservation (SAC)

Created using CADplot http://www.oasys-software.com/cadplot/

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SAFETY DATA SHEET FOR CHROMIUM (III) OXIDE GREEN

Issue 1: Date 04/08/2010

1 Identification

1.1 Identification of substance: Chromium(III) Oxide Green

Chemical formula: Cr2O3 Product code: HG/T2775-1996

1.2 Recommended use and restrictions on use:

no

1.3 Company identification: Gansu Qiyuan Chromate-Chemical Production Co.,Limited. West Suburb,Jiayuguan City,Gansu 735100,China Tel:+86 937 6265614 Fax:+86 937 5974305/5968928 Website:www.qiyuanchem.com

1.4 Emergency Telephone Number: +86 937 6265614

2 Hazard Identification

This product is not considered hazardous under EU Regulatory guidelines. This product is not classifiable under GHS guidelines; no labelling elements required.

3 Composition / Information on Ingredients

Ingredients Synonyms EINECS

Number

CAS Number

Concentration

Chromium (III) Oxide

Chrome Oxide;

GreenChrome

Oxide;Chromium(III)

Oxide,99%,Amouphous

Powder

215-160-9 1308-38-9 99%

4 First-aid Measures

4.1 Inhalation Symptoms: Inhalation of dust may cause mechanical respiratory irritation Remove exposed person to fresh air. Keep warm and at rest. If any discomfort continues, seek medical attention.

4.2 Skin Contact

Symptoms: Prolonged contact may cause skin irritation. Remove contaminated clothes, wash affected skin thoroughly with soap and water; consult physician if any discomfort continues. Wash clothing before re-use.

4.3 Eye Contact Symptoms: May cause mechanical eye irritation. Eyes may be itchy and red. Flush thoroughly with water for at least 15 minutes. Check for and remove contact lenses. Seek medical attention if any discomfort continues.

4.4 Ingestion Symptoms: Chromium (III) oxide has low oral toxicity because it is insoluble in water and poorly absorbed. Move exposed person to fresh air and keep person warm and at rest. Wash out mouth with water and remove dentures if any. Seek medical attention. If vomiting occurs keep the head as low as possible to prevent vomit entering lungs. If unconscious, place in recovery position and get medical attention immediately. Maintain an open airway. Loosen tight clothing such as a collar, tie, belt or waistband.

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5 Fire-fighting Measures

5.1 Suitable Extinguishing Media This product in non-combustible. Use fire-extinguishing media appropriate for surrounding materials

5.2 Unsuitable Extinguishing Media

None

5.3 Specific Exposure Hazards Thermal decomposition may produce chromic oxide or other oxides of chromium.

5.4 Special Protective Equipment for Fire-fighters

Wear self-contained breathing apparatus if this product is involved in a fire.

6 Accidental Release Measures

6.1 Precautions For non-emergency personnel: Keep unnecessary people away; Ensure area well ventilated and/or use appropriate respiratory protection. Prevent skin and eye contact. For emergency responders: Protective clothing must be worn. The selection of clothing should take account to the magnitude of the release and the likely level of exposure

6.2 Environmental Precautions

Prevent material from entering sewers, water sources or low lying areas.

6.3 Clean-up Prevent material coming into contact with waterways, drains or sewers. Use vacuum cleaner fitted with HEPA filter to remove spilt material into suitable sealable containers. If no vacuum cleaner available, moisten split material before sweeping and avoid creating airborne dust. Do not hose away any spillage. Dispose of absorbed residues at an appropriately licensed waste disposal facility.

7 Handling and Storage

7.1 Precautions for safe handling

Prevent contact with eyes and skin. Wear suitable protective gloves and coveralls and use safety spectacles. Avoid handling that leads to the formation of dust. If the creation of airborne dust is likely use suitable respiratory protection (P3 filter). Do not handle along with incompatible materials. Ensure adequate ventilation of the working area. Good industrial hygiene practices required. Eating, drinking and smoking in work areas is prohibited. Wash hands after use. Remove contaminated clothing and protective equipment before entering eating areas.

7.2 Conditions for safe storage

Store in tightly closed original container in a dry, cool and well-ventilated place. Keep containers closed when not in use. Do not store in open or unlabelled containers. Keep separate from food, feedstuffs, fertilisers and other sensitive material. Keep in original container.

8 Exposure Controls / Personal Protection

8.1 Occupational Exposure Limits:

TLV: (as Cr metal, Cr(III) compounds) 0.5 mg/m³ as 8 hour TWA; A4; (ACGIH 2008).

UK WEL (as Cr metal, Cr(III) compounds): 0.5 mgm

-3 (8 hour TWA);

TLV: Threshold Limit Value; WEL: Workplace exposure limit; TWA: Time weighted average

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8.2 Exposure Controls

Engineering Controls Maintain air concentrations below occupational exposure standards. Processes likely to generate dust or fume should be contained within a closed system.

Personal Protection Eye/face If eye contact is likely, safety glasses should be worn. Ensure that eye wash stations are close to the working area.

Skin/hands Suitable protective clothing should be worn if repeated or prolonged skin contact is likely. If hand contact is likely, chemically resistant impervious gloves complying with an approved standard. The selection of clothing should take account to the task being performed and the likely level of exposure. Contaminated clothing should be removed with care to prevent skin contact during undressing and contaminated clothing should be washed before re-use. Ensure safety showers are close to the workstation location.

Respiratory If dusts or mists are generated during use of this product, use adequate ventilation, local exhaust or enclosures to control below exposure limits. If ventilation is not adequate, wear a suitable half mask respirator with filter P3 (EN 143).

Thermal hazards Not applicable

9 Physical and Chemical Properties

9.1

Appearance: Green powder

Odour: Odourless

Odour threshold: Not applicable

pH Value 7.5@ 0.5% solution

Melting/freezing point: 2435oC

Boiling point: 4000oC

Flash point: Not applicable

Evaporation rate: Not applicable

Flammability: Not flammable

Upper/lower flammability limits: Not applicable

Vapour pressure: Not applicable

Vapour density: Not applicable

Relative density: 5.21 gcm-3

at 20oC

Solubility: Insoluble in water

Partition coefficient: octanol-water Not applicable

Auto-ignition temperature Not applicable

Decomposition temperature Not available

Viscosity Not applicable

10 Stability and Reactivity

10.1 Reactivity: Product does not decompose at ambient temperatures. A small amount (<0.1% as Cr) of reversion to hexavalent chromium may occur if the dry chromium (III) oxide powder is exposed to elevated temperatures. Thermal decomposition may produce chromic oxide or other oxides of chromium.

10.2 Chemical stability: Stable under ambient conditions.

10.3 Possibility of hazardous reactions: Does not react vigorously with other chemical agents under ambient conditions; Dry Chromium (III) oxide powder can react with molten alkali at very high temperatures under oxidising conditions. May react with chlorine trifluoride, lithium, nitroalkanes, dirubidiumacetylide, oxygen difluoride and other strong oxidisers.

10.4 Conditions to avoid: None.

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10.2 Incompatible materials: Molten alkali, chlorine trifluoride, lithium, nitroalkanes, dirubidiumacetylide, oxygen difluoride and other strong oxidisers.

10.3 Hazardous Decomposition Products: Substance decomposes on heating to chromic oxide

11 Toxicological Information

11.1

Acute toxicity Rat Oral LD50 1: >5000 mg/kg

Skin corrosion/irritation

No indication of skin irritation or corrosion was found in rabbits exposed to chromium (III) oxide (500 mg moistened with water) under an adhesive patch for 4 h

Serious eye damage/irritation

May cause mechanical eye irritation.

Sensitisation There are reports of allergic dermatitis in workers exposed to chromium (III) but chromium (III) compounds are less potent sensitisers than chromium (VI) compounds. Immunological response is believed to be related to chromium rather than chromate.

Germ cell mutagenicity

Although trivalent chromium has the capacity to damage DNA, it is not thought to be an effective mutagen due to its poor cellular uptake; Positive results have been reported in some cellular assays of genotoxicity.

Carcinogenicity Chromium(III) compounds are not classifiable by IARC as to their carcinogenicity to humans (Group 3)

Reproductive toxicity

Chromium (III) oxide administered to rats at a concentration of 2 or 5% of the diet had no effect on reproductive capacity. There is inadequate evidence to indicate that chromium (III) compounds are reproductive toxicants.

Systemic target organ toxicity single exposure

No information is available

Systemic target organ toxicity repeated exposure

No clear systemic effects have been reported in animals exposed to oral doses of chromium (III) compounds of up to 1368 mg/kg/day (rats). Rats exposed to concentrations of chrome (III) oxide of 15 mgm-3 for 6 hours/day for 13 weeks are reported to have showed evidence of damage to the respiratory system and changes in thyroid weight; Exposure of rats to 150 mgm-3 for 45 days caused severe respiratory damage (emphysema) and liver and kidney toxicity. Continuous exposure of an unspecified mammal species to 4.2 mgm-3 for 24 hours/day for 17 weeks caused acute pulmonary oedema and other adverse respiratory effects.

Aspiration hazard Chromium (III) oxide does not present an aspiration hazard

11.3 Likely routes of exposure, symptoms, delayed and immediate effects

Inhalation: May cause mechanical respiratory irritation. Ingestion: Chromium (III) oxide has low oral toxicity because it is insoluble in water and poorly absorbed. In rats dosed with 5 g kg-

1 of chromium (III) oxide no

deaths or pathological changes were noted after 14 days (LD50 > 5 g kg-1

) Skin and eye exposure: May cause eye irritation, symptoms may include itchy eyes and redness.

11.4 Chronic effects, from short or long-term exposure

Repeated or prolonged exposures to inhaled dust may cause delayed effects of the respiratory system e.g. chronic bronchitis or pneumoconiosis. Prolonged/repeated skin contact may cause allergic dermatitis. No adverse effects were seen in rats fed chromium (III) oxide at up to 1368 mg kg

-1 day

-1 chromium (III) for 90 days

11.5 Interactive effects No information is available

11.6 Other information None Notes: 1. Dose lethal to 50% of experimental animals 2. Concentration lethal to 50% of experimental animals

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12 Ecological Information

12.1 Ecotoxicity NOEC1 >6840 mg/L – Zebra fish

Brachydanio rerio, 96 hours NOEC >684 mg/L – Leuciscus idus

(ide), 48 hours NOEC >6840 mg/L – Pseudomonas fluorescens, 24 hours

(All as Cr/L)

This product is practically insoluble and would not be expected to give rise to adverse effects to aquatic organisms. Chromium(III) occurs naturally in the environment and is an essential nutrient.

12.2 Persistence and Biodegradability

Chromium(III) compounds are generally stable in the environment.

12.3 Bioaccumulative Potential This material is not expected to significantly bioaccumulate.

12.4 Mobility in soil Chromium(III) oxide is expected to have low mobility

Chromium (III) compounds are expected to be rapidly and strongly adsorbed onto soil, particularly by iron and manganese oxides, clay minerals and sand.

12.5 Other adverse effects None. Notes: 1. median lethal concentration; 2. chromium, not specifically Cr(III) hydroxide

13 Disposal Considerations

Ensure local and national regulatory requirements are met. Recover and reclaim or recycle, if practical. Do not incinerate as some Cr(III) may convert to Cr(VI). Dispose of at an appropriately licensed waste disposal facility. All containers should be disposed of in an environmentally safe manner and in accordance with governmental regulations.

14 Transport Information

Product is not considered as dangerous as defined by the European Union Dangerous substances/preparations Directives; therefore no special transport requirements are needed.

15 Regulatory Information

Product is not considered as dangerous as defined by the European Union Dangerous substances/preparations Directives; EU Labelling not required.

16 Other Information

It is strongly recommended that users ensure that the information contained in the safety data sheet is brought to the attention of the employees and others handling this product. Distributors of this product are advised to forward this document to their customers. Date of preparation: August 2010

Data sheet prepared by IOM Consulting Limited (Contract 611-00450)

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ATTACHMENT No D.1.2 COMPLIANCE WITH EC ENVIRONMENTAL OBJECTIVES

(SURFACE WATER) REGULATIONS, 2009

No measures are required to achieve compliance with the requirement of the EC

Environmental Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009.

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ATTACHMENT No D2: ENVIRONMENTAL CONSIDERATIONS

D2.1 Environmental Considerations and BAT

The following documents were considered in the assessment of environmental

considerations and BAT at the Premier Periclase Limited (PPL) facility:

Article 3 of Directive 2008/1/EC of the European Parliament and of the

Council of 15 January 2008 concerning integrated pollution prevention and

control.

European Commission IPPC reference document on Best Available

Techniques (BREF) in the Cement, Lime and Magnesium Oxide

Manufacturing Industries (May 2010)

Section 5 of the Environmental Protection Agency Act 1992 as substituted by

of the Section 7 of the Protection of the Environment Act 2003

D2.2 Energy Efficiency

The PPL Environmental Policy requires all its facilities to optimise the use of energy

and material resources. PPL operates under IPPC Licence Reg. No. P0376-01. The

primary aim of IPPC licensing is to prevent or reduce emissions to air, water and land,

to reduce waste and to use energy efficiently. PPL achieves this by using the most

advanced, energy-efficient methods to create a range of high quality product as well

as operating under an established Environmental Management System (EMS).

PPL continually invests in BAT based technologies. Recent examples include:

Table D2.1 - Premier Periclase Investment in Energy Efficient Technologies

Year Technology (IR£)

1987

Ongoing

Installation of over 50 variable speed drives with installed

capacity of 5,000kw

0.5m

1988 Conversion to Gas Firing/Dual Burners 1.6m

1990 Installation of Energy Efficient Shaft Kilns 10.5m

1994 Installation of Pressure Filtration (Belt Presses) 1.0m

1996 Installation of Lime Kiln Preheater 3.5m

*Note: Not included in the above list is the installation of 7.5kW ACS800 Inverters]

that PPL purchase as a standard drive for all drives up to 7.5kW. Currently 22 of these

have been installed on-site

In addition significant power savings were made on all pumps, fans and blowers

where inverters were installed. These were installed over a period from 1995 onwards.

As a direct result of this investment the company has achieved very significant

improvements in specific fuel consumption. In addition, this energy efficiency

reduces the emissions of fuel produced carbon dioxide by over 50% of the original

start-up levels. The company has already achieved the targets set for the next century

in the reduction of emissions of greenhouse gases set at the recent 1997 Kyoto

Conference on global warming.

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Energy usage has been decreased by 21% in the last five years and energy

consumption is now approximately 55% of the consumption in 1990. (Source:

Annual Environmental Report 2010)

Premier Periclase has also identified a program for further energy savings on a plant

wide basis. These are currently being implemented and include the ongoing reduction

of air consumption and leaks.

An Energy Audit of the PPL facility was carried out in 2008 by EURO environmental

services. A copy of the report was sent to the EPA.

Premier Periclase have made a number of significant changes in their production

processes. Major energy efficiency projects were completed in the 1990s:

Area Improvement Estimated Energy

Saving

Shaft Kiln

Installation

In 1991 the company installed a shaft

kiln system replacing the previous rotary

kiln process. This is vertical kiln system,

which utilises heat energy much more

efficiently. The company estimate this

made significant savings in energy usage

of up to 70% on this process.

Close to 70% saving on

periclase sintering

process

Belt Presses The belt press process was installed in

1994. This increased the dry matter

content of the cake going to the MHF

process from 50% range to 70% range.

This generated energy savings of 18%.

18% energy reduction in

MHF process

Lime Kiln

Preheater

In 1996 the company installed a

preheater to the lime kiln and reduced

the length of the lime kiln. The preheater

utilises heat energy from the lime kiln

process to preheat crushed limestone to

700 deg C. As a result of this investment,

the lime kiln energy usage reduced by

approximately 20%.

20% reduction in energy

requirement

Other

Projects

The company is continuously reviewing

improvements that can be made to

further improve energy efficiency.

Variable speed drives were installed on a

number of processes throughout the

1990s. A variable speed drive is due to

be installed on 1 of the multi hearth

furnaces, on a Combustion Air Fan,

resulting in a reduced power

requirement.

Not determined – positive

long term energy

efficiency

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Premier Periclase will continue to seek ways of further gaining energy efficiency but

the scope for improvements is obviously limited as most of the major changes have

already been introduced.

D2.3 Waste Minimisation

Approximately 8,000 m3 per annum of grits from the wet end process are disposed on

in the landfill. Markets are being pursued for other by-products which have amounted

to 12,000 tonnes per annum.

D2.4 Council Directive 2008-1-EC – General Obligations

Article 3 of Council Directive 2008-1-EC lists the general obligations on the operator

to ensure that appropriate pollution prevention and control measures are put in place.

Each of these obligations and the measures taken at the PPL facility to address them

are listed below:

a. all the appropriate preventive measures are taken against pollution, in

particular through application of the best available techniques;

An Environmental Management Plan (EMP) is agreed annually and provided to the

Agency in the AER. The EMP sets targets and objectives for the year ahead and aims

to achieve continuous improvement of the Environmental Management System, an

example was the following:

The dust transfer points at the jetty were fitted with extraction points and scrapers

to reduce dust falling and becoming airborne. Levels were non-detectable at

boundary during ship loading in September. However the company continues to

explore the possibility to reduce the dust at the inlet to the ship hold.

b. no significant pollution is caused;

PPL currently operates within the limits imposed by its IPPC Licence Reg. No.

P0376-01. IPPC limits are set by the Agency in order to protect air quality standards.

Any exceedance of these limits is immediately investigated by PPL and reported to

the Agency. The results of all on-site monitoring and any exceedances of the limits

are also reported in the Annual Environmental Report.

An assessment of the impact on surface water discharges is provided in Attachment

D1.1.

c. waste production is avoided in accordance with Directive 2006/12/EC of the

European Parliament and of the Council of 5 April 2006 on waste; where

waste is produced, it is recovered or, where that is technically and

economically impossible, it is disposed of while avoiding or reducing any

impact on the environment;

Premier Periclase Ltd has identified all waste streams associated with our onsite

activities and follows strict waste management guidelines as set out by the Agency

and in accordance with Directive 2006/12/EC. PPL has had a comprehensive

approach to waste management incorporating the principles of prevention,

minimisation re-use and recycling. All employees are kept aware of the requirement

to reduce or recycle our waste. See section D2.3 above.

d. energy is used efficiently;

See section D2.2 above.

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e. the necessary measures are taken to prevent accidents and limit their

consequences;

PPL has prepared an Emergency Response Procedure which outlines the accident

prevention and emergency response procedures in place at PPL in the event of a fire, a

spill of flammable or environmentally harmful material, or any other major industrial

accident. Emergency response training in the following procedures is also provided to

all PPL employees:

Evacuation routes

Alarm systems

Reporting to supervisors

Personal protective equipment

A Fire-water Risk Assessment Report has been prepared to take account of the

proposed introduction of alternative fuels on-site.

f. the necessary measures are taken upon definitive cessation of activities to

avoid any pollution risk and return the site of operation to a satisfactory state.

PPL intends to operate its facility for the foreseeable future. However, in the event of

definitive cessation of activities at the site, PPL will ensure that appropriate measures

are taken to avoid any pollution risk and return the site to a satisfactory state. A

Closure, Restoration and Aftercare Management Plan (CRAMP) has been prepared for

the facility. The CRAMP and costs associated with its implementation will be

reviewed annually. The document will be amended if necessary.

D7 Environmental Protection Agency Act 1992 – Determination of BAT

Section 5 of the Environmental Protection Agency Act 1992, inserted by Section 7 of

the Protection of the Environment Act 2003, lists the considerations to be taken into

account when determining BAT. Each of these considerations is discussed below.

(i) the use of low-waste technology,

Premier Periclase Ltd has had a comprehensive approach to waste management

incorporating the principles of prevention, minimisation re-use and recycling. All

employees are kept aware of the requirement to reduce or recycle our waste.

Premier periclase has identified all waste streams associated with our onsite activities.

The Safety & Environmental officer acts as the coordinator for all waste going off

site. Records of all materials are maintained and reviewed for any unusual increase in

any particular waste stream.

(ii) the use of less hazardous substances,

The raw materials used in the periclase manufacturing process at Premier Perilcase

are not hazardous. The hazardous materials at PPL are predominantly those used in

the laboratories or in the maintenance workshop. These materials are used in

relatively small quantities and are stored in secured areas only. Liquid fuels are stored

in specific bunded areas.

(iii) the furthering of recovery and recycling of substances generated

and used in the process and of waste, where appropriate,

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Waste segregated on site for recycling includes pallets, paper, cardboard, timber,

glass, oils & greases, aluminium, WEEE ,C&D, steel and other metals and off site

recycling is carried out by permitted specialist contractors.

Employees have been informed of the waste streams and the appropriate location for

wastes to be stored for offsite recycling or recovery.

(iv) comparable processes, facilities or methods of operation, which

have been tried with success on an industrial scale,

Whilst there is no directly comparable industry in Western Europe PPL uses best

practice from similar heavy industries.

(iv) technological advances and changes in scientific knowledge and

understanding,

PPL uses Best Available Techniques.

(v) the nature, effects and volume of the emissions concerned,

The main emissions from the periclase manufacturing process are emissions to

atmosphere from combustion gases and emissions to water. The volumes of these

emissions are currently regulated according to the existing IPPC Licence so that the

potential to impact human health and the environment are minimised.

(vi) the commissioning dates for new or existing activities,

PPL was commissioned in 1979.

(vii) the length of time needed to introduce the best available

techniques,

A number of best available techniques are already employed at PPL (refer to Table

D2.3 above).

(ix) the consumption and nature of raw materials (including water) used in

the process and their energy efficiency,

The principal raw material used in the periclase making process is limestone. This is

extracted directly from PPL’s quarry

Seawater is pumped from the Irish Sea and after replacement of magnesium cations

by calcium cations it is returned to the Irish Sea.

Energy efficiency at PPL is described in section D2.6 below.

(x) the need to prevent or reduce to a minimum the overall impact of the

emissions on the environment and the risks to it,

The risk to the environment posed by the facility is assessed in the Environmental

Liability Risk Assessment. This document has been provided to the EPA. The impact

of the emissions on the environment and the risk to the environment is low given the

low quantity of hazardous substances used and generated and the environmental

properties of these substances. The main emissions will be to air from combustion

gases and have no significant impact on the environment. PPL operates its facility in

compliance with IPPC licence P0376-01.

(xi) the need to prevent accidents and to minimise the consequences for the

environment, and

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All operations and activities are carried out in accordance with the relevant PPL

procedures, which are designed to minimise accidents. The main accident scenarios

that could occur at the site are fires, explosions and spills of harmful material. PPL

has developed the Emergency Response Procedure which sets out the responses to

such events.

(xii) the information published by the Commission of the European

Communities pursuant to any exchange of information between

Member States and the industries concerned on best available

techniques, associated monitoring, and developments in them, or by

international organisations

The activities carried out at PPL are discussed above with reference to the European

Commission BREF document for cement, lime and magnesium oxide referenced

above.

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ATTACHMENT No E: STATUTORY REQUIREMENTS

Specification prepared by the Agency in accordance with Section 5 of the

Environmental Protection Agency Act 1992 as amended by Section 7 of

the Protection of the Environment Act 2003

The Agency has published BAT Guidance Note on Best Available Techniques for the

Production of Cement and for the Production of Lime in a Kiln (1st Edition, 2008). A

BAT Guidance note has not been published specifically in relation to the manufacture

of periclase (magnesite).

In accordance with the provisions of the above Guidance Note in relation to surface

waters, contamination of wastewater has been minimised through appropriate site

layout and design of surface water collection systems, keeping uncontaminated water

separate from contaminated water, and good housekeeping measures to minimise the

likelihood of contamination by particulates.

Treatment of seawater that has been used in the process involves:

- pH correction/neutralisation

- coagulation/flocculation/precipitation

- sedimentation/filtration/flotation

Any rainwater falling on the site is generally either absorbed by the dry limekiln (ESP)

dust or collected in the sludge settlement lagoons. There is no surface water run-off

out of the existing landfill over surrounding soils or watercourses. Any ponding

within the landfill generally either evaporates or is absorbed into the underlying waste.

Rainwater falling on lime fines is incorporated into the lime by hydration.

Urban Waste Water Treatment Regulations 2001 (S.I. No. 254 of 2001)

as amended by the Urban Waste Water Treatment (Amendment)

Regulations 2004 (S.I. No. 440 of 2004) or any future amendment

thereof

These Regulations prescribe requirements in relation to the provision of collecting

systems and treatment standards and other requirements for urban waste water

treatment plants, generally and in sensitive areas provide for monitoring procedures in

relation to treatment plants and make provision for pre-treatment requirements in

relation to industrial waste water entering collecting systems and urban waste water

treatment plants.

Sewage arising on the PPL site is discharged to the local authority sewer in Boyne

Road.

Accordingly the regulations do not apply to the PPL facility.

European Communities (Good Agricultural Practice for Protection of

Waters) Regulations 2009 (S.I. No. 101 of 2009) or any future

amendment thereof

These Regulations provide statutory support for good agricultural practice to protect

waters against pollution from agricultural sources. The PPL facility does not engage

in agricultural activities and therefore the regulations do not apply to the facility.

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Local Government (Water Pollution) Act, 1977 (Control of Cadmium

Discharges) Regulations 1985 (S.I. No. 294 of 1985)

The manufacture of periclase (magnesite) does not come within any of the industrial

sectors for which emission limit values are specified in SI No 294 of 1985.

The concentration of cadmium in the effluent from the plant is below the limit of

detection (0.09 µg/l) as shown in the Annual Environmental Reports for 2008, 2009

and 2010. This is below the ELVs for various industrial sectors in SI No 294 of 1985.

Local Government (Water Pollution) Act, 1977 (Control of

Hexachlorocyclohexane and Mercury Discharges) Regulations 1986 (S.I.

No. 55 of 1986)

The PPL plant does not use or discharge mercury or hexahlorocyclohexane.

The manufacture of periclase (magnesite) does not come within any of the industrial

sectors for which emission limit values are specified for mercury in SI No 294 of

1985.

The concentration of mercury in the effluent from the plant is at or below the limit of

detection (0.2 µg/l) as shown in the Annual Environmental Reports for 2008, 2009

and 2010.

Local Government (Water Pollution) Acts, 1977 and 1990 (Control of

Carbon Tetrachloride, DDT and Pentachlorophenol Discharges)

Regulations 1994 (S.I. No. 43 of 1994)

The PPL plant does not use or discharge carbon tetrachloride, DDT or

pentachlorophenol.

Measures or controls identified in a pollution reduction plan for the river

basin district prepared in accordance with Part V of the EC Environmental

Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009 for

the reduction of pollution by priority substances or the ceasing or

phasing out of emissions, discharges and losses of priority hazardous

substances.

No measures are listed in the Programme of Measures (POM) for the Boyne Estuary

Plume Zone under any of the listed pressure sources headings:

Dangerous Substances (Physio-Chemical)

Forestry (Physio-Chemical)

Landfills, etc. (Physio-Chemical)

Wastewater /Industrial Discharges (Physio-Chemical)

Wastewater/Unsewered (Physio-Chemical)

Physical Modifications (Morphological)

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ATTACHMENT No F: APPROVED ADJUSTMENTS & CONDITIONS

1. Amendment A to the licence P0376-01 was issued on 5 July 2007. This

Amendment introduces the following:

Definitions of “BAT” and “Incident”

Condition 2.10 “Resource Use and Energy Efficiency”

Condition 7.8 “Decommissioning & Residuals Management”

Condition 12.2 requiring preparation of an Accident Prevention Procedure

Condition 12.3 requiring annual revision of the Accident Prevention Procedure

and the Emergency Response Procedure and updating if necessary

Condition 12.4 specifying action by licensee in the event of an incident.

2. The frequency of chemical and biological surveys in the vicinity of the effluent

discharge pipe (required by Condition 6.10) of the licence has been reduced

from annual to triennial.

No changes are required to the site layout as a consequence of either of the above.

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Once-off Reports

Condition

No

Report Report Submission Date Agreed

*

5.2 and 5.3 Test Programme for

abatement Equipment

Within one month of completion of the

test programme.

Y

2.9.1 Programme for Public

Information

Within six months of the date of grant

of licence.

Y

9 Fire-water Retention

Study

Within six months of the date of grant

of licence.

Y

7.6 Landfill Operational

Plan

Within six months of the date of grant

of licence.

Y

6.5 Toxicity Testing

Scoping Proposal

Within three months of the date of

grant of licence.

Y

6.6 Toxicity Report Within six weeks of completion of test. Y

6.8 Effluent Dispersion

Report

Within twelve of date of grant of this

licence.

Y

9.5 Bund Integrity

Assessment.

Within three months of the date of

grant of licence. Y

2.4 Pollution Emission

Register Proposal

Within six months of the date of grant

of licence.

Y

2.2 Schedule of

Environmental

Objectives and Targets

Within four months of the date of grant

of licence.

Y

2.3 Environmental

Management

Programme Proposal

Six months from the date of grant of

licence.

Y

5.10 PM10

and PM 2.5

Evaluation report

Within twelve months of the date of

grant of licence.

Y

6.7 Continuous Flow

Monitoring Proposal

Within three months of the date of

grant of licence.

Y

5.13 Proposal for monitor

location, type, warning

and action levels

Within three months of the date of

grant of licence.

Y

* Completed and agreed with the Office of Environmental Enforcement (OEE) (Yes/No) or as

otherwise agreed.

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