attachment no. k remediation, … the quarry and treated domestic effluent to form the ......

Irish Cement Ltd Platin Works IPPC Licence Review Attachment No. K

K - 1 of 2

October 2009

ATTACHMENT No. K

REMEDIATION, DECOMMISSIONING, RESTORATION AND AFTERCARE

TABLE OF CONTENTS

K.1. Closure, Restoration and Aftercare Management Plan (CRAMP) ............... 2

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Irish Cement Ltd Platin Works IPPC Licence Review Attachment No. K

K - 2 of 2

October 2009

K.1. Closure, Restoration and Aftercare Management Plan (CRAMP)

A Closure, Restoration and Aftercare Management Plan (CRAMP) has been prepared for the facility. This document is included in this Attachment.

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Closure, Restoration and Aftercare Management Plan

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Irish Cement Ltd

Platin Works


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Irish Cement Ltd

Platin Works


September 2007

This report has been prepared for Irish

Cement Ltd for submission to the Environmental Protection Agency in connection with the review of IPC Licence Reg. No. P0030-02. Other than this intended use it should not be relied upon by any third party and no responsibility is undertaken to any third party. Arup Consulting Engineers

10 Wellington Road, Dublin 4 Ireland Tel +353 1 614 4200 Fax +353 1 668 3169 www.arup.ie

Job number D 5374/11

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Irish Cement Ltd Platin WorksClosure, Restoration and Aftercare Management Plan

CONTENTS

Page

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

2. SITE ASSESSMENT ................................................................................................................. 1 2.1 Site Location .............................................................................................................................. 1 2.2 Site Planning Context ................................................................................................................ 2 2.3 Environmental Sensitivity Evaluation ......................................................................................... 2 2.4 Site History ................................................................................................................................. 4 2.5 Site Layout and Assets .............................................................................................................. 5 2.6 Site Processes ........................................................................................................................... 5 2.7 Waste ......................................................................................................................................... 7 2.8 Site Classification ..................................................................................................................... 11

3. CLOSURE CONSIDERATIONS .............................................................................................. 16 3.1 Temporary Cessation of Cement Manufacturing ..................................................................... 16 3.2 Permanent Closure of the Cement Works ............................................................................... 18 3.3 Criteria for Successful Closure in the Case of Both Temporary and Permanent Closure ....... 20 3.4 Costs ........................................................................................................................................ 20 3.5 Closure Plan Update and Review ............................................................................................ 22 3.6 Closure Plan Validation ............................................................................................................ 22

4. AFTERCARE MANAGEMENT PLAN ..................................................................................... 22

5. FINANCIAL PROVISION ......................................................................................................... 22

6. REFERENCES ......................................................................................................................... 23

Figures Figure 1 Site Location Figure 2 Existing Site Layout Figure 3 Environmentally Sensitive Sites within 5km of Site Figure 4 Quarry Reinstatement Plan

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J:\D5300-D5399\D5374\5) DESIGN\41\IPPC REVIEW\ATTACHMENT K\ADDENDA\SS\CRAMP_D5374-11_ISSUE_2.DOC

Page 1 Arup Consulting EngineersIssue 2 18 August 2009

1. INTRODUCTION Irish Cement Limited (ICL) has been producing cement at its site at Platin, Co. Meath, since 1972 (refer to Figure 1). The following activities, classified in the First Schedule of the Protection of the Environment Act, 2003, are carried out at the site:

• Class 10.1. The production of cement

• Class 11.1 The recovery or disposal of waste in a facility

The Environmental Protection Agency (hereafter referred to as ‘the Agency’) granted a licence for the production of cement at the plant in 1996, Licence Reg. No. P0030-01. This was superseded in 1997 by Licence Reg. No. P0030-02.

This Closure, Restoration and Aftercare Management plan (CRAMP) stipulates the arrangements in place and the actions to be taken in the event of decommissioning of all or part of the operation so as to minimise any potential effects on the environment after shut-down.

This document has been prepared in accordance with the Agency publication ‘Guidance on Environmental Liability Risk Assessment, Residual Management Plans and Financial Provision’ [1].

Two closure options for the facility are assessed in this report:

1. Temporary cessation of cement manufacturing whereby ICL would retain ownership of the site with a view to reopening it at a later date, or

2. Permanent closure of the facility.

2. SITE ASSESSMENT This section establishes the environmental context of the facility. It identifies those areas and aspects of the natural environment which could be impacted upon by the facility.

2.1 Site Location The site of the Platin Works lies approximately 3 km southwest of Drogheda (refer to Figure 1). The factory was constructed in 1972 and included a nominal 400,000 tonne capacity single kiln unit (Kiln 1). Subsequently, capacity was increased to nominal 1.6 million tonnes of clinker annually by installing a second, much larger, kiln (Kiln 2). To the west of the factory site, which is triangular in plan, is the limestone quarry, which provides the primary raw material for the cement making process. The site is bounded on the southeast by the R152, on the northeast by county road CR319 and on the west by the limestone quarry. The lands surrounding the site are agricultural. The site layout is shown in Figure 2.

ICL Platin installed a new kiln (Kiln 3) and associated plant in December 2008.

The Kiln 3 development required the demolition of existing factory offices, stores and maintenance workshops. Replacement office and stores / workshop buildings were located elsewhere on-site. Demolition of a redundant boiler house and oil storage tank was carried out to facilitate construction of the new workshop and stores.

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2.2 Site Planning Context The development strategy adopted by Meath County Council is described in the County Development Plan 2007-2013. This document superseded the 2001 Plan. It became effective on 29 March 2007. The ICL Platin site and surrounding lands are unzoned in the Development Plan. There have been no changes to the zonings in the 2001-2007 Development Plan. Each zoning map will be amended over the next several months, and will be displayed as Variations to the County Development Plan 2007-2013.

A policy of the Council with regard to the extractive industry is ‘To facilitate the exploitation of the county’s natural resources and to exercise control over the types of development taking place in areas containing proven or potential deposits, whilst also ensuring that such industries are carried out in a manner which would not unduly impinge on the visual amenity or environment quality in the area.’[2]

Volume two of the Plan recognises the economic importance of the cement Works: ‘A substantial proportion of the population of Duleek is employed in manufacturing Industry such as the nearby Cement Works. In 1997 it was estimated that some 406 persons in the village were employed in manufacturing industry’ [3].

2.3 Environmental Sensitivity Evaluation 2.3.1 Surface Water

The River Boyne, to the north of the site, drains a catchment area of 2,300 km2 [4]. It rises in counties Offaly and Kildare and drains most of County Meath before flowing through Drogheda to discharge into the Irish Sea at Mornington in County Meath. Groundwater pumped from the Limestone Quarry is drawn from the Boyne catchment. According to the most recent survey published by the Agency a total of 18% of the river channel of the River Nanny was rated as being Class C or Moderately Polluted at that time, with 3% of the channel rated as being Class D - Seriously Polluted. None of the channel length was rated a being Class A [5]. A recent study by Ecofact Environmental Consultants revealed that there is no evidence that suggests the discharge from the ICL Platin facility is having any significant impact on the biological water quality of the downstream areas surveyed. The River Nanny, to the south of the site, drains 239 km2 and rises in the east of County Meath before flowing to Duleek to discharge into the Irish Sea at Laytown.

Sources of Emissions

ICL Platin’s treated water effluent is discharged into the River Nanny. The water treatment systems at ICL Platin are discussed below.

Management of process and surface water run-off on site consists of a water collection system which delivers process and surface water into a storm balancing tank followed by a sedimentation tank, both of which are used to reduce the levels of suspended solids. Deep well water from the quarry is managed through continuous pumping of groundwater from the deep well in the quarry floor. It does not require any treatment. Domestic effluent is treated in a purpose built package waste water treatment plant on site. Treated Process and Surface water run-off discharges from the sedimentation tank and confluences with deep well water from the quarry and treated domestic effluent to form the final treated effluent which discharges to the outfall point into the River Nanny via a designated pipeline. The treated final effluent is discharged through 2,637 m of 610 mm pipeline which runs underground from the cement manufacturing factory to the outfall point into the receiving waters of the River Nanny. The outfall pipe runs under roads and agricultural land and outfalls into the River Nanny south of the factory, just off the R150 regional road.

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Treated final effluent is monitored monthly in accordance with IPC Licence Reg No. P0030-02.

2.3.2 Soil and Groundwater Conditions

Geologically, Platin Quarry is located in a narrow band of Carboniferous aged limestones that are bounded to the north and south by older Lower Palaeozoic sandstones and shales [4]. The Platin limestones connect westwards with the limestone plains of Meath and extended eastwards to outcrop along the Irish Sea between Termonfeckin in the north and Laytown in the south. The Platin limestones constitute a regionally important aquifer while the enclosing Lower Palaeozoic strata have little regional groundwater potential. Groundwater within the limestone aquifer flows towards the east coast and either discharges directly into the Irish Sea or into the River Boyne and River Nanny systems as base flow. The pumping of groundwater from beneath the quarry to maintain dry working conditions has altered the natural groundwater flow regime around the quarry. Some of the groundwater that would previously have discharged into the two rivers as base flow has been intercepted beneath the quarry and this groundwater is now discharged to the River Nanny at the licensed outfall. This groundwater is of potable quality and as such is of better quality than the River Nanny water. Groundwater quality is monitored bi-annually in accordance with IPC Licence Reg. No. P0030-02.

2.3.3 Proximity to SPAs/SACs/NHAs

The three main types of nature conservation-sites in Ireland are Special Areas of Conservation (SACs), Special Protection Areas (SPAs) and Natural Heritage Areas (NHAs).

SACs are prime wildlife conservation areas in the country, considered to be important on a European as well as an Irish level. Most SACs are in the countryside, although a few sites reach into town or city landscapes, such as Dublin Bay and Cork Harbour.

The EU Birds Directive (79/409/EEC) came into force in 1979. It requires each member state to designate "Special Protection Areas" for birds.

The basic designation for wildlife is the Natural Heritage Area. Many NHAs have overlapping designations of SAC and/or SPA. There are currently 802 proposed NHAs which are not SAC/SPA. They cover a total area of about 113,000 hectares.

Four proposed NHAs and one SAC lie within 5 km of the centre of the Irish Cement site (refer to Figure 3) [6]:

pNHA site code 001861 Dowth Wetland

pNHA site code 001862 Boyne River Islands

pNHA site code 001578 Duleek Commons

pNHA site code 001593 Thomastown Bog

SAC site code 002299 River Boyne and River Blackwater

2.3.4 Sites and Monuments Record

The Sites and Monuments Record (SMR) of the Department of the Environment, Heritage and Local Government records known upstanding archaeological monuments, their original location (in case of destroyed monuments) and the position of possible sites identified as cropmarks on vertical aerial photographs. The SMR for County Meath is referenced in the draft County Development Plan for 2007-2013. It shows that there are recorded features of archaeological interest within the boundary of the ICL Platin site.

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2.4 Site History Cement Limited (subsequently named Irish Cement Ltd.) was founded as a public company in 1936 [4]. The construction of the cement plants, one at Boyne Road, Drogheda, Co. Louth and the other at Castlemungret, Co. Limerick, was undertaken in the following two years. At that time, the Drogheda factory had an annual production capacity of 150,000 tonnes while Limerick’s output was 75,000 tonnes. Demands for cement rose quickly and plans were soon made to develop the Drogheda Works by adding a second kiln. This went into operation in 1940, and by 1954 a third kiln was added at Drogheda and a second kiln at Limerick, which together boosted total production capacity to about 700,000 tonnes per year.

By the mid-sixties three further kilns had been added in Limerick, increasing combined yearly output of both Works to 1.3 million tonnes. The need for production capacity increased, and in 1967 Irish Cement Limited. decided to build a completely new plant at Platin, Co. Meath, some 3 km southwest of Drogheda.

The Platin Cement Works has reached its present state of development in two main stages. The decision taken in the late 1960s to build a completely new factory resulted in the provision of a nominal 400,000 tonnes capacity single kiln unit in 1972. Subsequently output was increased to nominal 1.6 million tonnes annually by installing a second much larger kiln which was completed in 1977. This allowed the original 40-year old works at Boyne Road, Drogheda – which by this time had become too costly to operate – to be gradually phased out.

The local availability of large deposits of the limestone and shale which the process demands, easy access to rail transport and the proximity of the site to the major Dublin market all make Platin an ideal location for cement manufacture.

The very significant improvements in production methods and control measures to minimise environmental impact which had evolved abroad during the previous decades were first introduced to this country in the development of the Platin Works. In particular the use of the modern dry process at Platin provided the highest level of fuel efficiency, automation and process control.

Today, in addition to supplying the market in the northern and eastern parts of the country, Platin also serves Northern Ireland and export markets.

In 1995, Meath County Council granted planning permission, for an extension of 5.8 hectares to the limestone quarry, and retention of the existing overburden mound to the north of the Works. In 1998 ICL Platin was granted planning permission to further extend the quarry by lowering the quarry floor to a finished floor level of 20m below OD over a period of 20 years. In 1999 the County Council granted permission for construction of 2 new silos at the cement Works. In 2000 permission was granted for the construction of new office premises at the cement Works. In 2001 permission was granted for a westward extension of the quarry, together with associated landscaping works, extending to 45 ha with a finished floor level of 20m below OD. In 2006 permission was granted for development of the new Kiln 3 line and associated works.

2.4.1 Liquids Handling

The main liquids used and stored at the facility are:

• process water

• diesel / gas oil (production fuel, central heating fuel, untaxed on-site vehicle fuel, taxed off-site vehicle fuel)

• lubricating oils, greases

• grinding aid

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• ammonia water

• quarry explosives

• cleaning chemicals

• laboratory chemicals.

Process water is pumped to various parts of the factory through metal pipes. Waste process water and surface water flows to the water treatment system through box drains and pipelines.

Diesel oil is transported within the site in metal pipes. Underground metal diesel pipes are protected from corrosion by placing inside plastic piping and are tested every 3 years for their integrity.

Lubricating oils and greases are stored in portable containers on locally bunded trays.

Small volumes of solvents are stored in the Research and Development (R&D) and Chemical Laboratories e.g. acetone, methanol, ethanol, paraffin, industrial methylated spirits (IMS). In the R&D Laboratory solvents are stored in unbreakable glass containers in a bunded cabinet. Solvents are dispensed from the Winchester bottles in the fume cupboard on an as needed basis. In the Chemical Laboratory chemical bottles are stored in sealed stainless steel containers. Bulk laboratory chemical containers are kept outdoors in a naturally ventilated self-bunded dedicated drum storage cabinet.

The schedule of bunded tanks on-site is shown in Table 1. All bunds are integrity tested in accordance with the requirements of the IPPC Licence for the facility.

The liquid explosive for quarry blasting is brought on-site in a road tanker. Blast holes are loaded with explosive from the tanker with a hose.

Ammonia water is transported on-site in a road tanker. It is pumped from the tanker into sealed, bunded stainless steel ammonia water tanks and transferred as required via stainless steel sealed pipes to the kiln process.

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Table 1 Schedule of Bunded Tanks

Ref. Substance Maximum Tank Capacity (L) Tank Location Tank Material Containment

1 Taxed diesel 113,500 Opposite garage Steel Concrete bund Untaxed Diesel

2 Quarry untaxed diesel 113,500 Top of quarry Steel Concrete bund 3 Production untaxed diesel 114,300 North of Raw Mill 1

building Steel Concrete bund

Untaxed Diesel and Grinding Aid 4 Diesel tanks 59,010 Under old Kiln 2 platform Steel Concrete bund 5 CEM I Grinding aid tanks 2 x 30,000 (60,000) Above old Kiln 2 platform Orthophthalic GRP Concrete bund 6 CEM II Grinding aid tanks 2x 30,000 (60,000) Adjacent to grate cooler

DB room Orthophthalic GRP Concrete bund

7 Central heating oil 2 x 6,500 (13,000) New Engineering Building

Steel Double skinned tank

8 Central heating oil 3,000 Garage Plastic Double skinned tank 9 Furnace diesel oil 4,550 Raw Mill Building Steel Single skinned tank on

bunded pallet 10 Emergency generator diesel oil 1,500 Kiln 2 Steel Single skinned tank on

bunded pallet 11 Central heating oil 3,500 Production Building Steel Double skinned tank 12 Ammonia water (<25%) 2 x 120,000 (240,000) North of Raw Mill 1

building Stainless steel Concrete bund

13 Production untaxed diesel 2,300 Packing Plant Steel Double skinned 14 Crusher diesel oil 3,000 Right of Crusher Plastic Double skinned 15 Emergency generator diesel oil 4,000 Kiln 3 Steel Double skinned 16 Kiln burner diesel tank 20,000 Kiln 3 Steel Concrete bund 17 Performax 3400 (polyacrylic acid

and sulphuric acid) 300 Beside Blue Tank Plastic Single skinned tank in

plastic bund

Biosperse 3001 (hypochlorite solution)

300 Beside Blue Tank Plastic Single skinned tank on bunded pallet

18 Performax 3400 (polyacrylic acid and sulphuric acid)

500 Next to CM4 cooling tower

Plastic Single skinned tank on bunded pallet

Biosperse 3001 (hypochlorite solution)

2 x 300 (600) Next to CM4 cooling tower

Plastic Single skinned tank on bunded pallet

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2.4.2 Solid Material Handling

Quarrying

Limestone

The cement Works is adjacent to adequate reserves of limestone suitable for cement manufacture. The reserves are overlain by glacial till. This material is removed on a planned basis. The limestone is drilled and blasted prior to loading for transport to the process. Typically, 18 metre high faces are developed.

Diesel fuelled wheel loaders load off-highway dump trucks, of up to 65 tonne capacity for transport of the blasted limestone to the crushing plant, which has a capacity of 1,000 tonnes of crushed limestone per hour.

During normal operation the crushed limestone is transported to a homogenising limestone store via conveyor belts. The existing limestone store, of capacity 36,000 tonnes, affords a blending effect that allows stone from different faces to be mixed into a reasonably homogenous material. An on-line analyser is installed to provide representative composite samples of crushed stone. A facility to feed an off-line emergency stockpile is available. Stone can be retrieved from the outside pile via a mechanical infeeder. A new limestone store was installed as part of the Kiln 3 project.

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Shale and Overburden

Shale is hauled by road from quarries near Donore and Denhamstown. Overburden is hauled from the Limestone Quarry. A two stage crushing system is operated for shale and overburden with a capacity of 500 tonnes per hour. The crushed shale and overburden is stored in a homogenising store of capacity 12,000 tonnes.

Bauxite and Iron Oxide

Bauxite is supplied from overseas and hauled from the relevant port to ICL Platin. Bauxite is transported to a bauxite storage hopper by conveyors.

Iron oxide is supplied from overseas and hauled from the relevant port to ICL Platin. Iron oxide is transported to the iron oxide storage hopper by conveyors.

Rawmilling

Limestone and shale/overburden are extracted from the homogenising stores by specially designed reclaimers and conveyed to separate mill feed hoppers. Limestone, shale/overburden, bauxite and iron oxide are extracted from their respective storage hoppers and conveyed together to the raw mills.

The objective of the rawmilling unit operation is to produce a meal of finely ground, dry and homogenised raw materials. The raw meal produced in the mills is conveyed to homogenising silos by a combination of pneumatic and mechanical equipment. There are four raw meal silos. Homogenising takes place in the upper chamber, which has a capacity of 2,000 tonnes. The raw meal then drops by gravity into the lower storage chamber that has a capacity of 5,000 tonnes per silo. A new raw mill was installed as part of the Kiln 3 project.

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Clinker Making

Homogenised Raw Meal or Kiln Feed is extracted from storage silos and mechanically transported to a feed hopper. The Kiln Feed flow is weighed and controlled on extraction from the feed hopper and conveyed into the kiln system.

The Kiln Feed falls into the kilns from the preheaters. As the material travels down the rotary kiln, the calcination process is completed and the transformation into clinker minerals occurs at a material temperature of 1,450ºC. To protect the kiln shell at these high operating temperatures, a lining of refractory material is installed. This lining gradually wears away by abrasion and thermal shocks. Renewal is required at approximately yearly intervals.

Excess air is drawn off and passed through a filter before discharge to atmosphere. Cooled clinker is transported from the kilns by mechanical conveyor to clinker silos. There are seven clinker storage silos in Platin at present. A new clinker store was constructed as part of the Kiln 3 project.

Combustion gases are drawn through the kiln and cyclone preheater by a fan. After the preheater, the gases are cooled by water injection in a conditioning tower. The existing kilns’ cooled gases are then dedusted in electrostatic precipitators. Kiln 3 gases are dedusted in a bag filter. The exhaust gases are also used for drying in the rawmills. The dust collected in the gas cleaning devices is returned to the kiln feed. The primary fuel for kiln firing at Platin is petroleum coke (pet coke). Coal may also be used.

Pet coke or coal is used as fuel for the kiln. It is stored in stockpiles. The material is pulverised in an airswept ball mill before metering and pneumatic conveying into the kiln’s burners. Exhaust gases from the kiln are used to ventilate the coal mill. These gases are cleaned in the coal mill filters before venting to atmosphere. The new Coal Mill 3 will be equipped with a bag filter.

While the kilns are currently fired by pet coke, and have in the past used coal and oil, small quantities of gas (LPG) and oil are used to light and preheat the kiln at startup.

Cement Milling

Clinker is extracted mechanically from storage and transported by a series of mechanical conveyors to the feed hoppers of the cement mills. Gyspum is added at the cement mill to control the setting time of the final cement. A gypsum store is available for strategic stocks. Limestone and raw meal are stored in storage hoppers and are added at the milling stage in accordance with standard requirements.

The finished product is conveyed by a combination of mechanical and pneumatic means to one of the cement silos.

Cement Storage and Dispatch

There are ten cement storage silos at the site. Two of the silos are used for the storage and direct dispatch of bulk cement by road. Each of these silos has two truck loading bays. Six of the silos are used for buffer storage, to supply the four bulk truck loading bays, supply of cement to the packing plant, transfer of cement to the rail silo and for storage of special cements. The rail silo is dedicated to the storage and dispatch of bulk cement by rail, with a dedicated weighbridge. The final silo is allocated for the storage of slag binder, with a dedicated weighbridge.

Finished products are transported onsite by air-slides, screw conveyors, conveyor belts or enclosed air transport pipes to storage silos where they are pumped to bulk dispatch areas or to the packaging plant and mechanically bagged and packed by an automatic bagger and packer. These packed products are transported by forklift and dispatched on trucks.

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Packing Plant

The cement is transported from the storage silos to the Packing Plant by a combination of air slides, screw conveyers and elevators. There are two rotary packers which fill 25 kg bags. The bagged cement is palletised on two palletisers. The completed pallets are loaded onto trucks by overhead crane or forklift for dispatch.

2.4.3 Historical Environmental Incidents

There have been no environmental incidents at the site in 35 years of operations that have adversely affected the environment or human health or that could have a residual environmental impact.

There have been no significant environmental incidents at the site relating to air, water, noise emissions or waste management. The Agency granted a licence for the production of cement at the plant in 1996, Licence Reg. No. 30. This was replaced in 1997 by Licence Reg. No. P0030-02. The facility achieved ISO 14001 accreditation for its Environmental Management System in 2006.

Where minor IPC Licence non-compliances do occur, they are reported to the Agency after the incident, again in monthly reports to the Agency and again in the Annual Environmental Report (AER). The kiln electrostatic precipitators (ESPs) can occasionally trip due to a safety interlock. All trips are recorded and investigated and action taken to reduce the likelihood of their reoccurrence. Trips are necessary for safety reasons, and all trips are recorded. The number of ESP trips has been decreasing steadily in recent years due to ongoing management attention and upgrading of the plant’s electronic control system (refer to graph).

Electrostatic Precipitator Trips

0

50

100

150

200

250

1996 1998 2000 2002 2004 2006 2008

Year

No. E

lect

rost

atic

Pre

cipi

tato

r Tri

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Kiln 1Kiln 2Trendline Kiln 1Trendline Kiln 2

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Process materials e.g. overburden and other solid materials unsuitable for recycling are deposited on the dedicated overburden mound. The main component of the landfill is overburden. This is essentially being repositioned and is consistent with the soils at the disposal site. Small quantities of other non-hazardous factory process materials such as waste rock, limestone, shale, raw meal and clinker are also deposited in the mound in accordance with the IPC Licence.

Most of the buildings on-site, which were constructed in the 1970s, were clad with fibre-cement sheet cladding containing asbestos. From time to time cladding materials are removed as part of plant maintenance. Fibre cement cladding containing asbestos has in recent years been landfilled in a specific location in the overburden mound. ICL Platin intends to remove this material for disposal off site in a licensed waste facility. At the request of the Agency, a Conditioning Plan for the overburden mound was submitted by ICL Platin in 2002 in order to ensure compliance with the European Council Directive on the Landfill of Waste (1999/31/EC).

The facility was originally designed for heavy fuel oil firing of the kilns but has since converted to the use of petroleum coke or coal. There are known to have been some spillages of heavy fuel oil during filling operations. The heavy fuel oil tank and boiler house were demolished in 2006-07. Mouchel Parkman was appointed by ICL Platin in October 2006 to design and implement a ground works remediation strategy for the site at Platin Works known as ‘Donnelly’s Hollow’[7]. The remedial activities at Donnelly’s Hollow were coordinated using an on-site petrochemical assay to target contamination and direct the excavation of materials requiring treatment and disposal. The results of the on-site Total Petroleum Hydrocarbons (TPH) screening of soil material complied with the Remediation Target Value (RTV) level. The Mouchel Parkman validation report concluded that the site is suitable for its proposed end use.

2.5 Site Layout and Assets The site layout is provided in Figure 2.

2.6 Site Processes Generally, the cement manufacturing operation is a series of material size reduction and mixing processes leading to the thermal process in the kiln where the synthetic clinker minerals are formed. A final material size reduction process reduces the clinker produced in the kiln to cement. There are specific inputs and outputs to each process on-site.

The principal processes on-site and their associated inputs and outputs are given in Table 3 below.

Table 3 On-site Processes, Raw Materials and Outputs

Process Raw Materials Process Output

Quarrying Limestone/overburden Crushed rock/overburden

Rawmilling Limestone, shale, bauxite, iron oxide Raw meal

Clinker production Homogenised raw meal or kiln feed Clinker

Cement milling Clinker, gypsum, limestone, raw meal, Ground Granulated Blast Furnace Slag

Cement

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(GGBS), Cr6 reducing agents

Packing/dispatch Cement, paper sacks, timber pallets and plastic, Cr6 reducing agents

Cement

The cement making process involves mixing raw materials and feeding them with fuel, for example coal, oil or, as currently, petroleum coke, to a horizontal, inclined, rotating kiln. The heat provided by the fuel drives the chemical reactions in the kiln necessary to produce cement clinker. Fuel is added at both ends of the kilns. The clinker is ground in cement mills, and gypsum and limestone/raw meal are added. Grinding aids are sometimes employed. The product is stored in silos and from there packed in bags or loaded into tankers for despatch by road or rail. Ancillary facilities to the process are: • 110 kV electricity sub-station

• Underground cable tunnels, electricity sub-station and switch rooms

• Workshops and stores

• Control building

• Administration offices

• Personnel facilities

• Roads and paved areas

• Process water supply reservoir

• Potable water supply from the public mains

• Sewage treatment plant

• Surface water settlement tanks

Planning Permission for the Kiln 3 development was received in 2006. The main elements of the development include the following:

• Limestone Store

• Raw Mill

• Preheater Tower

• Kiln

• Kiln Bag Filter

• Grate Cooler

• Grate Cooler Electrostatic Precipitator Filter

• Office Building

• Coal Mill and Bag Filter

• Clinker Storage Silo

• Cement Mil/Separator and Bag Filter

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• Workshop

• Associated conveyors

• Site works and internal roads

• Miscellaneous buildings structures and services.

2.7 Waste 2.7.1 Identification of Waste Streams

Waste generated at the ICL Platin can be categorised into:

• Non-hazardous waste which includes municipal waste, non-hazardous industrial waste and other wastes

• Hazardous waste as defined in the EC Directive 91/689/EEC.

Permitted non-hazardous wastes are disposed of on-site in the IPC licensed overburden mound/on-site landfill. The most significant component is overburden which is essentially being repositioned and is consistent with the soils of the disposition site. The disposal impacts the topography of the immediate area of the factory. The visual impact is reduced by the landscaping programme. Small volumes of other non-hazardous wastes licensed for disposal in the overburden mound/on-site landfill include limestone, shale, process materials (that cannot be recycled in the process) and filter bags.

Hazardous and non-hazardous wastes not disposed of on-site are disposed of off-site by appropriately licensed/permitted contractors.

All wastes are disposed of and analysed in accordance with the requirements of IPPC Licence Reg. No. P0030-02. The quantities of hazardous and non-hazardous wastes disposed of, the recovery/disposal location and the name of the waste contractor are reported to the Agency in the AER for the facility.

It is established practice at ICL Platin to recycle any waste streams which are economically recyclable. Wastes that are recycled include timber, metal, plastic, paper, cardboard, oils and tyres which are all recycled externally by licensed waste contractors. Waste process materials are recycled internally in the production processes. By maximisation of waste recycling, the environmental impact of wastes is reduced.

Wastes that cannot be recycled are disposed of off-cite and can be categorised as either hazardous or non-hazardous. Non-hazardous waste disposed of include household kitchen waste and sewage sludge.

The impact of on-site disposal of waste is very low.

The following wastes are generated at ICL Platin:

Non-hazardous Waste (On-site Disposal)

Limestone/Shale/Overburden/Process Material that cannot be recycled

Filter Bags

Non-hazardous Waste (Off-site Disposal/Recovery)

Canteen waste

Dry Mixed Recyclables

Wood

Construction and Demolition Waste

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Scrap Metal

Used Tyres

Dewatered Wastewater Treatment Sludge

Hazardous Waste (Off-site Disposal/Recovery)

Waste Oil Filters

Waste Oil

Waste Oil/Grease

Monitors

Other Electronic Waste

Fluorescent Tubes

Laboratory Chemicals

Lead/Acid Batteries

Fibrous Asbestos

Construction Material Containing Asbestos (Fibre Cement Cladding)

2.7.2 Waste Segregation System

Where practicable, segregation of waste occurs at ICL Platin and resultant waste streams are either recovered or disposed of internally or externally, following strict waste management guidelines set out by the Agency.

Internal Waste Disposal: ICL Platin has an on-site landfill that is licensed under IPPC License P0030-02. Inert wastes such as waste overburden, waste gypsum, waste filter bags and some other authorised inert wastes are deposited in this on-site landfill. Internal Waste Recovery: Dust and stone materials are gathered on-site directly by mobile plant or in red skips located around the site. The skips are transported by forklift to a designated collection point on the west side of Raw Mill 2 where the material is emptied and stored until it is loaded mechanically by a loading shovel and transported to the quarry for re-use in the process. External Waste Recovery: All other wastes that are not permitted for on-site landfill are recovered or disposed of off site, using licensed waste hauliers and licensed waste management contractors. A full paper trail of waste from the Platin site to end destination is kept on file at Platin Works, as per IPC license P0030-02.

Non-hazardous wastes segregated for recovery includes timber, metal, cardboard, paper, clear plastic and rubber. It is planned to introduce dry mixed recyclable segregation in Q3 2007. The segregation of these non-hazardous wastes for recovery is described below:

Timber: Timber packaging related to the supply of paper sacks is returned to the supplier for reuse. Clients return pallets for reuse to the site. Damaged pallets are returned to the supplier for repair. Waste timber and non-repairable pallets are transported by forklift to the Site’s Skip Area. These are stored in a timber skip and removed from site by a licensed waste haulier to a licensed waste contractor.

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Metal: Metal waste material on-site is gathered at various segregation sites around the factory in small blue bins. These are transported to the central waste metal skip area by forklift where they are mechanically loaded into low-sided skips. These are removed from site for recycling by a licensed waste haulier to a licensed waste contractor.

Cardboard: Cardboard is gathered and baled in a designated area in the stores. The bales are stored on-site and removed from site by a licensed waste haulier to a licensed waste contractor. Paper: Paper is collected in recycling bins in all offices and baled in a designated area in the stores. The bales are stored on-site and removed from site by a licensed waste haulier to a licensed waste contractor.

Plastic (clear): Plastic is collected in a designated area of the Stores and the Packing Plant. The plastic is removed from site by a licensed waste haulier to a licensed waste contractor.

Rubber / Tyres: Used tyres are stored in the tyre storage area at the Garage and removed from site for recycling by a licensed waste haulier to a licensed waste contractor.

Dry Mixed Recyclables:

A system for collection of Dry Mixed Recyclables is in operation on the site. Dry Mixed Recyclables include paper, cardboard, clear plastic, tin cans, tetra packs and plastic bottles and so will replace some of the segregation described above. Dry mixed recyclables are collected in colour-coded bins at various segregation centres. These are then transported by forklift to a static recycling compactor where they are mechanically emptied. The compactor is serviced when full and removed from site for recycling by a licensed waste haulier to a licensed waste contractor.

Hazardous wastes segregated for recovery include waste fuel oil, batteries, electronics, fluorescent tubes and others occasionally.

Fuel Oils: Waste fuel oils are collected and stored in UN double skinned approved tanks/drums in the oil collection point in the Waste Oil storage area. These are removed from site for recycling by a licensed haulier and are refined and recovered by a licensed waste contractor.

Batteries: Waste vehicle batteries are stored in a designated bunded container in the Garage area. Small batteries are collected and stored in an allocated bunded battery bin in the Stores area. These are removed from site for recycling by a licensed haulier and are recovered by a licensed waste contractor.

Waste Electrical and Electronic Equipment (WEEE): Electronic equipment is collected and stored in allocated cages in the Stores area. These items are removed from site for recycling by a licensed haulier. A licensed waste contractor carries out partial recovery of this waste.

Fluorescent tubes/lamps:

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Waste fluorescent tubes and lamps are collected and stored in allocated storage bins in the Stores area. These are removed from site for recycling by a licensed haulier. A licensed waste contractor carries out partial recovery of this waste.

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External Waste Disposal / Destruction:

Non-hazardous wastes for disposal, includes general and canteen waste.

General and Canteen Waste: General and canteen waste is gathered from the offices and canteens around the site in skips identified by their yellow colour. The office general bins are emptied into these yellow bins, which are then transported by forklift to the portable general waste compacter where they are mechanically emptied. The compactor is serviced when full and removed from site for recycling by a licensed waste haulier to a licensed waste contractor.

Hazardous wastes for disposal/destruction include greases, chemicals and others occasionally.

Grease is collected in barrels and stored on bunded pallets. Chemicals are stored in a suitable bunded container. These are removed from the site by a licensed waste haulier to a licensed waste facility.

Most of the buildings on-site, which were constructed in the 1970s, were clad with fibre-cement sheet cladding containing asbestos. From time to time cladding materials are removed as part of plant maintenance. Fibre cement cladding containing asbestos has in recent years been landfilled in a specific location in the overburden mound. ICL Platin intends to remove this material for disposal off site in a licensed waste facility.

2.8 Site Classification In order to determine the Risk Category of the facility a risk assessment was carried in accordance with the methodology given in the Agency publication ‘Guidance on Environmental Liability Risk Assessment, Residuals Management plans and Financial Provision’.

Tables 4- 6 show how the environmental sensitivity, risk category and hazard potential for the site were determined. The facility is Risk Category 3. On this basis a site specific Environmental Liabilities Risk Assessment is required for the Platin Works.

Table 4 Environmental Sensitivity

TOTAL Environmental Attribute Score Environmental Sensitivity Classification

Low <7 1

Moderate 7-12 2

High >12 3

Table 5 Risk Category

Risk Category Overall Risk Score

Category 1 <5

Category 2 5-23

Category 3 >23

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Table 6 Operational Risk Assessment

Complexity Score

Licensed Activity Class

10.1 The production of cement G3 3

Environmental Sensitivity

Sub Matrix Score

Score

Human Occupation

250m-1km

1

Groundwater Protection [8]

Regionally important aquifer 2

Vulnerability rating – extreme 3

Sensitivity of Receiving Waters

Class B [5] 2

Designated coastal and estuarine waters [9] 0

Potentially eutrophic coastal and estuarine waters [10] 0

Protected Ecological Sites

>1km from protected site 0

Air Quality & Topography

Intermediate terrain 1

Sensitive Agricultural receptors

Dairy farming < 50m from site boundary 2

Total Environmental Sensitivity 11 2 (moderate)

Compliance Record

Licensed facilities with minor emission non-compliances

3

OVERALL RISK SCORE

(Complexity x Environmental Sensitivity) x Pollution Record

(3 x 2) x 3 18

RISK CATEGORY Category 2

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3. CLOSURE CONSIDERATIONS ICL Platin currently has no plans to cease the operation of the cement manufacturing plant. Kiln 1 was decommissioned in October 2008 prior to commissioning of the modern and more energy efficient Kiln 3 in December 2008. The Kiln 3 line facilitates the production of CEM II cements. The limestone deposits on-site are sufficient to ensure continued operation for many years.

However, if it is decided to close, it is proposed that the Agency be informed at the earliest possible opportunity of decommissioning plans. The notice period is likely to be six months. The notification shall be provided in accordance with prevailing guidance and it is expected that there will also be discussions with the Agency as part of the process.

Alternative plans are proposed by ICL Platin for the following closure options:

1. Temporary cessation of cement manufacturing whereby ICL Platin would retain ownership of the site with a view to reopening it at a later date, or

2. Permanent closure of the facility and sale of the site.

3.1 Temporary Cessation of Cement Manufacturing The scope of this plan addresses the key issues, which would occur in an orderly shutdown of all or part the site activities i.e. well planned and well financed. It envisages that a complete shutdown would take place on a phased basis over an estimated time period of 6-9 months.

The scope of the plan includes the following major activities:

• Setting up a management structure to oversee the CRAMP

• Cessation of all production activities

• Removal of all remaining raw materials, intermediates and final products from the site

• Shutting down of all utility systems

• Completion of a report on all aspects of the site within 60 days of completion of the plan activities

• Maintaining an ongoing site security and monitoring service.

The basis of the plan is to ensure that, upon its implementation, the facility would be in such a condition as to not pose a risk to public health and safety or a risk of environmental contamination.

3.1.1 Implementation of the Closure Plan

Particular actions are listed below for specific areas of the facility as part of the Closure Plan. In general, care and attention will be given during the implementation of the plan to ensure that the potential risks associated with the plan are avoided. In the event of a spillage, leak or fire during decommissioning, the Platin Works Emergency Response Procedure would be implemented in order to minimise the risk to health and the environment.

Monitoring of groundwater will be carried out during the decommissioning phase of the development. If contamination is recorded, site remediation works will be carried out in accordance with a methodology agreed with the Agency. Due to the nature of the activities outlined above, contamination is unlikely.

3.1.1.1 Quarry

1. Cessation of all blasting

2. Continuation of dewatering of the quarry void.

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3.1.1.2 Raw Materials Storage Areas

1. Disposal of raw materials, intermediates, products and consumables by (depending on prevailing market conditions):

• removal for use at other cement plant(s), or

• sale, or

• disposal by licensed contractors. 3.1.1.3 Alternative Fuels Storage

1. Disposal of alternative fuels by (depending on prevailing market conditions):

• removal for use at other cement plant(s)

• sale, or

• disposal by licensed contractors.

3.1.1.4 Cement Plant (including Raw Mills, Kilns and Cement Mills)

1. Completion of work in progress and cessation of all further production 2. Transfer of product to a sister CRH plc facility or to customers. 3.1.1.5 Coal Plant

1. Completion of work in progress and cessation of all further operations

2. Cleaning of area around coal mills with a vehicle mounted mobile industrial vacuum cleaner.

3.1.1.6 Laboratories

1. Completion of all necessary analytical work on production in progress and all final products before removal from site

2. Return to vendor, transfer to sister CRH plc facility or sell on all unopened and in-date laboratory chemicals

3. Removal of all opened chemical containers and out of date chemicals for recycling, transfer to a sister CRH plc facility or send for disposal by a licensed contractor

4. Cleaning and decontamination of laboratory instruments

5. Cleaning and decontamination of all glassware, storage areas and any other equipment

6. Shutting down of all computer systems other than any deemed necessary for ongoing monitoring.

3.1.1.7 Maintenance Buildings (including Garage)

1. Secure archiving of all engineering documentation including drawings, process and instrumentation diagrams, validation documentation, vendor manuals and data, project files, maintenance records, inspection records and all other appropriate documentation

2. Disconnection of all maintenance equipment to leave it in a secure state.

3. Removal of all oils, waste oils and waste oil filters by a licensed contractor. 3.1.1.8 Administration Buildings and Canteen

1. The maintenance of a security presence on-site on a 24-hour basis for ongoing monitoring of the site from a safety, fire prevention and environmental perspective

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3.1.1.9 Overburden Mound

1. The overburden mound will remain intact on closure of the facility.

3.2 Permanent Closure of the Cement Works The scope of this plan addresses the key issues, which would occur in an orderly shutdown of all the site activities i.e. well planned and well financed. It envisages that a complete shutdown would take place on a phased basis over an estimated time period of 9-18 months.

The scope of the plan includes the following major activities:

• Setting up a management structure to oversee the CRAMP

• Cessation of all production activities

• Removal of all remaining raw materials, intermediates, fuels and final products from the site

• Decommissioning and removal from site of all equipment

• Decommissioning and removal from site of all buildings

• Shutting down of all utility systems

• Completion of a report on all aspects of the site within 60 days of completion of the plan activities.

In the event of permanent closure of the facility, two options arise:

1. Restoration and landscaping of the site

2. Possible sale of the land for development subject to Agency approval and appropriate zoning and planning consent.

ICL Platin intends to utilise existing internal resources to manage and execute the Closure Plan, supplemented where appropriate by outside resources. This Closure Plan team would be responsible for managing and executing the complete plan. Outside contractors required for cleaning, waste disposal or recycling activities would be fully approved and licensed.

It is estimated that the duration of decommissioning would be 9 to 18 months. Environmental monitoring would continue while the plan is in operation and up to 3 years following the completion of the plan. The Agency and the Local Authority would be informed of the results of the monitoring programme and of the status of the plan.

Monitoring of groundwater will be carried out during the decommissioning phase of the development. If contamination is recorded, site remediation works will be carried out in accordance with a methodology agreed with the Agency. Due to the nature of the activities outlined above, contamination is unlikely.

3.2.1 Implementation of the Closure Plan

Particular actions are listed below for specific areas of the facility as part of the Closure Plan. In general, care and attention will be given during the implementation of the plan to ensure that the potential risks associated with the plan are avoided. In the event of a spillage, leak or fire during decommissioning, the Platin Works Emergency Response Procedure would be implemented in order to minimise the risk to health and the environment.

Regardless of whether the site is landscaped and restored or sold for development, the measures described below will be carried out.

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3.2.1.1 Quarry

1. Closure will take place in accordance with the proposals described in the Quarry Closure Plan submitted to Meath County Council in August 2003 as part of the Planning Application for extension of the quarry (refer to Figure 4).

3.2.1.2 Raw Materials Storage Areas

1. Disposal of raw materials, intermediates, products and consumables by:

• removal for re-use at other cement plant(s), or

• sale, or

• disposal by licensed contractors, depending on prevailing market conditions. 3.2.1.3 Alternative Fuels Storage

1. Disposal of alternative fuels by (depending on prevailing market conditions):

• removal for use at other cement plant(s)

• sale, or

• disposal by licensed contractors.

3.2.1.4 Cement Plant

1. Completion of work in progress and cessation of all further production

2. Transfer of product to a sister CRH plc facility or to customers

3. Transfer of equipment to a sister CRH plc or other cement manufacturing facility.

3.2.1.5 Coal Plant

1. Completion of work in progress and cessation of all further operations

2. Cleaning of area around coal mills with a truck mounted mobile industrial vacuum cleaner

3. Transfer of equipment to a sister CRH plc or other cement manufacturing facility. 3.2.1.6 Laboratories

1. Completion of all necessary analytical work on production in progress and all final products before removal from site

2. Return to vendor, transfer to sister CRH plc facility or sell on all unopened and in-date laboratory chemicals

3. Removal of all opened chemical containers and out of date chemicals for recycling, transfer to a sister CRH plc facility or send for disposal by a licensed contractor

4. Cleaning and decontamination of laboratory instruments

5. Cleaning and decontamination of all glassware, storage areas and any other equipment

6. Shutting down of all computer systems other than any deemed necessary for ongoing monitoring

7. Transfer of specialised equipment to a sister CRH plc facility. Recycling obsolete equipment, if possible, otherwise disposal by licensed contractor.

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3.2.1.7 Maintenance Buildings (including Garage)

1. Secure archiving of all engineering documentation including drawings, process and instrumentation diagrams, validation documentation, vendor manuals and data, project files, maintenance records, inspection records and all other appropriate documentation

2. Distribution of equipment to a sister CRH plc facility or sale to an interested party, where possible

3. Removal of all old and obsolete equipment and maintenance of workshop areas and stores for recycling or for disposal by a licensed contractor

4. Removal of all oils, waste oils and waste oil filters by a licensed contractor. 3.2.1.8 Administration Buildings and Canteen

1. Removal of administration and reception equipment for distribution to a sister CRH plc facility or sale to an interested party, where possible, otherwise disposal by a licensed contractor

2. Removal of canteen equipment for distribution to a sister CRH plc facility or sale to an interested party, where possible, otherwise disposal by a licensed contractor.

3.2.1.9 Overburden Mound

1. The overburden mound will remain intact on closure of the facility. Reinstatement of the mound is ongoing through hydro-seeding and tree planting in accordance with the principles described in the 1994 Environmental Impact Statement for the extension of the mound and the quarry [11]. On closure of the facility, the mound will be fully reinstated through spreading of topsoil, fertilisation, seeding, planting and regrading as necessary in accordance with a methodology to be agreed with the Agency.

3.3 Criteria for Successful Closure in the Case of Both Temporary and Permanent Closure The implementation of the Closure Plan will be considered successful should no environmental liabilities remain at the site. The success of the closure will be assessed based on the following criteria:

• The above measures will be completed using standard procedures and authorised contractors

• All waste generated during decommissioning will be handled and disposed of in compliance with the relevant legislation and all records retained

• No contamination will remain on-site

• The Environmental Management System will continue to be applied during decommissioning.

3.4 Costs It is estimated that the resources detailed in Tables 7 and 8 would be required for a period of approximately 6-9 (temporary closure) or 9 to 18 months (permanent closure) to successfully implement the Closure Plan. The estimated cost associated with the internal ICL Platin resources is €400,000 (temporary closure) and €800,000 (permanent closure).

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Table 7 Closure Plan ICL Platin Staff Resource Estimate

Role Staff numbers

Management 1

Administration 1

Operations 2

Maintenance 3

Laboratory 1

Others 2

In addition, external resources will be required to implement the plan. The external contract support estimated to be required is outlined in Table 8. Some variation in cost between the closure options described in sections 3.1 and 3.2 would be expected. However, it is not considered necessary at this time to estimate specific costs for the different closure options as the total projected cost is expected to cover both options.

Table 8 Closure Plan External Resource Estimate

Role Costs €

Civil works 100,000

Electrical, mechanical and IT works 100,000

Logistics and transport 100,000

Contract cleaning 100,000

Waste disposal / recovery 100,000

Soil and groundwater testing 10,000

Report to Agency 10,000

Other relevant items specific to the site/ Contingency

100,000

Total €620,000

Therefore, the estimated cost to execute the Closure Plan at 2007 values is in the region of €1.02 million (temporary closure) and €1.42 million (permanent closure). In addition, maintaining an ongoing security, safety and environmental monitoring presence (in the event of temporary closure only) at the site would cost approximately €150,000 per annum.

The cost of demolition of buildings and landscaping is estimated to be €3,000,000.

Although current Agency requirements are that post-operational monitoring of groundwater is maintained typically for 3 years, the duration may be reduced, or the monitoring might be completely eliminated, if no evidence is found of any events or evidence of general degradation in groundwater quality.

No factors have been identified that would indicate an unusual liability for the site in comparison with other process industry sites.

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3.5 Closure Plan Update and Review This Closure Plan will be reviewed annually as part of ICL Platin’s Annual Environmental Report. The Plan will be updated or amended as required. The updated and reviewed Plan will take account of any site or process changes, technology changes and costing variations.

3.6 Closure Plan Validation Following the announcement of the closure of the site, an independent audit of the site will be carried out. The audit will devise an accurate inventory of all plant, equipment and wastes on-site. This inventory will be used as a benchmark against which successful decommissioning will be assessed.

All environmental monitoring will continue over the course of the decommissioning phase.

A final validation report including a certificate of completion for the CRAMP, for all or part of the site as necessary, shall be submitted to the Agency within three months of implementation of the Plan.

Such tests or investigations shall be carried out or such certification submitted as requested by the Agency to confirm that there is no continuing risk to the environment after closure.

4. AFTERCARE MANAGEMENT PLAN Following the closure of the Works, it is proposed to continue to carry out monitoring on-site. As previously stated, environmental monitoring would continue while the closure plan is in operation and up to 3 years following the completion of the plan. The Agency and the local authority would be informed of the results of the monitoring programme.

5. FINANCIAL PROVISION The total estimated costs required to implement the Closure, Restoration and Aftercare Management Plan (CRAMP) is in the region of €1.02 million (temporary closure) and €1.42 million (permanent closure) (2007 values). In addition, to maintain an ongoing security, safety and environmental monitoring presence at the site would cost approximately €150,000 per annum. The cost of building demolition and landscaping is estimated to be €3,000,000.

Cost of implementation of the CRAMP will be underwritten by CRH plc. Irish Cement Limited is a subsidiary of CRH plc, one of the world’s top international building materials groups. It has operations in 24 countries, with annual sales of over €18 billion and employs over 80,000 people at more than 2,000 locations. Finance will be drawn down if and when liabilities fall due.

The Annual Environmental Report (AER) for the Works shall contain a statement as to the financial provisions in place to meet these costs.

The CRAMP and cost estimate will be reviewed yearly and revised if required. The financial provision will be updated accordingly to reflect the current level of known environmental liabilities. Any revision to the above costs shall be calculated in accordance with the following methodology:

RPA Cost = (EPA Cost x WPI) + CiCC

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Where:- RPA Cost = Revised perpetual aftercare cost EPA Cost = Existing perpetual aftercare cost WPI = Appropriate Wholesale Price Index [Capital Goods, Building & Construction (i.e. Materials & Wages) Index], as published by the Central Statistics Office, for the year since last closure calculation/revision. CiCC = Change in compliance costs as a result of change in site conditions, changes in law, regulations, regulatory authority charges, or other significant changes.

6. REFERENCES

1. EPA (2006) Guidance on Environmental Liability Risk Assessment, Residuals Management Plans and Financial Provision.

2. Meath County Council County Development Plan 2001 Volume One Objectives for the County at Large

3. Meath County Council County Development Plan 2001 Volume Two Written Statements and Detail Objectives for Towns and Villages

4. Brady Shipman Martin (2001) Environmental Impact Statement for Platin Quarry Extension

5. Ecofact Environmental Consultants (2007) An Ecological and Sediment Study of the River Nanny Near Duleek Co. Meath

6. http://www.npws.ie/ on 1 March 2007 7. Mouchel Parkman (2007) Donnelly’s Hollow Remediation Validation Report 8. http://193.178.1.182/website/new_gwps/viewer.htm on 27 April 2007 9. S.I. No. 254 of 2001 Urban Waste Water Treatment Regulations, 2001 10. EPA Estuarine and Coastal Water Quality Map 2001 - 2005 11. Brady Shipman Martin (1994) Environmental Impact Statement for Proposal for the

Extension of Existing Overburden Mound & Quarry

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FIGURES

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Arup Consulting EngineersIssue 2 18 August 2009

Figure 1 Site Location

Figure 2 Existing Site Layout

Figure 3 Environmentally Sensitive Sites within 5km of Site

Figure 4 Quarry Reinstatement Plan

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Grid Reference306490E 271801N

Site Location

Irish Cement Ltd Platin CRAMP

D5374.11 August 2009 Figure 1

Ordnance Survey Ireland Licence NumberEN 0002809 c Government of Ireland

0 kilometres 2

Scale 1:50,000

Permitted Quarry Area

ICL Platin SiteBoundary

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Kiln 1

Limestone Store Packing Plant

HeadOffice

Kiln 2

Gypsum Store

CementMills

Pet Coke Storage Area

ShaleStore

Raw Mills

Coal Mills

Admin. Officesand

Workshop

Raw Meal Silos

CentralControlRoom

Clinker Silos

Cement Silos

Existing Site Layout



0 metres 400

Scale 1:10,000

Not To Scale

0 kilometres 8

Scale 1:200,000

0 metres 100

Scale 1:2,500


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002299

002290

Legend

pNHA

SAC

Permitted Quarry Area

ICL Platin SiteBoundary

001593

001578

001861

001862

Grid Reference306490E 271801N

5km Radius From centre of Site

Environmentally Sensitive Sites within 5km of Site




0 kilometres 2

Scale 1:60,000

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Quarry Reinstatement Plan



0 metres 400

Scale 1:10,000

Not To Scale

0 kilometres 8

Scale 1:200,000

0 metres 100

Scale 1:2,500


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attachment no. k remediation, … the quarry and treated domestic effluent to form the ......

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