clogrennane lime ltd toonagh lime workstoonagh lime works follows acceptable principles of waste...
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Toonagh Lime Works
Clogrennane Lime Ltd
Toonagh Lime Works
AER 2010
Licence # P0 771-01
Toonagh Lime Works
2
Section 1 – Overview ………………………………………………………………. 3
1.0 Introduction
1.1 Description of Activities
1.2 Responsibility for Environmental Management
1.3 Environmental Policy
Section 2 – Emissions …………………………………………………………….. 4
2.1 Emissions to Atmosphere
2.2 Noise Emissions & Tonal Noise
2.3 Dust Deposition & Annual PM 10 / 2.5
Section 3 – Waste Management ………………………………………………. 7
3.1 Waste Management Overview
3.2 Repak
3.3 Waste Register
Section 4 – Resource Consumption
Section 5 – Bund Integrity ………………………………………………………. 9
Section 6 – Complaints / Incidents
Section 7 – Environmental Management Programme ………………… 10
7.1 Review of 2010 Objectives and Targets (2nd
Schedule)
7.2 2011 Objectives and Targets (3rd
Schedule)
Section 8 – Reports ……………………………………………………………….. 12
8.1 Review of ELRA and CRAMP
8.2 Energy Efficiency Audit – Summary
8.3 Bat Survey
8.4 WYG Report
Section 9 – Inspections ………………………………………………………….. 13
Appendix A – Diesel Loss Overview
Appendix B – AER Contents as per Schedule D of Licence # P0 771-01
Appendix C – PRTR 2010/2009
3
Section 1 – Overview
1.0 Introduction
IPPC Licence Register Number: P0771-01
Licensee Name: Clogrennane Lime Ltd
Site Name: Toonagh Lime Works
Location: Toonagh Quarry, Ennis, County Clare
1.1 Description of Activities
Production of lime in a kiln (POE 13.3).
The activity at the plant consists of the calcining of limestone in a kiln to produce quicklime. The
plant consists of a kiln, storage silos, a petcoke plant, workshop and office building. A weighbridge is
in operation at the site.
Stone is purchased from an adjacent quarry, stockpiled and fed into the kiln as required. Once inside
the kiln, it is heated to ~10000C. The final product is either sold as lump or crushed lime.
The fuel source for the kiln is petcoke, which is dried and milled before combustion.
Emissions from the site consist of emissions to atmosphere from the stack, fugitive dust emissions
and noise emissions. There are no emissions to water or sewer.
The site is also part of the GHG Scheme (IE-GHG 145-02).
The plant operates 24 hours a day, 365 days a year. It is primarily controlled via radio link from the
control room in the Carlow plant, although Toonagh personnel can take control of the plant if
necessary.
1.2 Responsibility for Environmental Management
The responsibility for the Environmental Management of Toonagh Lime Works is as follows:
(i) Location Manager, Mr. Bill Keogh
(ii) Technical Manager, Mr. Joe Connolly
(iii) Quality Technician, Mr. Mark Kennedy
(iv) Managing Director, Mr. Larry Byrne
1.3 Environmental Policy
Toonagh Lime Works operates an Environmental Management System to achieve its short and long
term goals of Continuous Environmental Improvement. This Management System is in the form of
an IPPC licence, which is supported by procedures from the Environmental Manual.
Se
cti
on
2 –
Em
issi
on
s
2.1
E
mis
sio
ns
to
Atm
os
ph
er
e
Em
issi
on
So
urc
e R
efe
ren
ce –
A1
.1 (
Kiln
).
All e
mis
sio
ns
to a
tmo
sph
ere
are
wit
hin
th
e E
LV’s
as
set
ou
t in
Sch
ed
ule
B.1
of
lice
nce
nu
mb
er
P0
77
1-0
1.
Pa
ram
ete
r
1st
Ha
lf 2
01
0
(mg
/ N
m3)
2n
d H
alf
20
10
(mg
/ N
m3)
An
nu
al
Av
era
ge
(mg
/ N
m3)
ELV
’s
(mg
/Nm
3)
Ma
ss E
mis
sio
ns
(20
10
)
(to
nn
es
pe
r a
nn
um
)
Ma
ss E
mis
sio
ns
(20
09
)
(to
nn
es
pe
r a
nn
um
)
Co
mp
lia
nce
(%)
Pa
rtic
ula
tes
4.7
5
.2
4.9
5
< 5
0
0.4
2
0.3
8
10
0
PM
10
2.0
5
3.1
2
.58
--
--
0.2
1
0.0
8
10
0
PM
2.5
0.8
5
2.7
1
.78
--
--
0.1
3
0.0
6
10
0
Nit
rog
en
Ox
ide
s
(as
NO
2)
39
1.5
2
96
3
43
.75
4
00
2
8.2
9
19
.27
1
00
Ox
ide
s o
f S
ulp
hu
r
(as
SO
2)
< 5
<
5
< 5
6
65
0
.43
0
.98
1
00
4
5
2.2
N
ois
e E
mis
sio
ns
& T
on
al
No
ise
All n
ois
e m
ea
sure
me
nts
are
co
mp
lia
nt
wit
h t
he
lim
its
as
set
ou
t in
lice
nce
nu
mb
er
P0
77
1-0
1 (
Co
nd
itio
n 4
.5 &
Sch
ed
ule
C.5
).
As
pe
r C
on
dit
ion
6.1
, a
to
na
l no
ise
su
rve
y w
as
carr
ied
ou
t in
20
10
. N
o t
on
al n
ois
e w
as
evid
en
t.
All m
ea
sure
me
nts
are
30
min
ute
LA
eq d
B(A
).
Da
y
Loca
tio
n
Q1
Q
2
Q3
Q
4
ELV
C
om
pli
an
ce (
%)
NS
L 1
48
5
3
38
.3
37
.9
55
1
00
NS
L 2
51
5
4
50
5
2.6
5
5
10
0
Nig
ht
Loca
tio
n
Q1
Q
2
Q3
Q
4
ELV
C
om
pli
an
ce (
%)
NS
L 1
44
4
2
37
.3
38
.6
45
1
00
NS
L 2
42
4
1
42
.2
40
.6
45
1
00
6
2.3
D
us
t D
ep
os
itio
n &
An
nu
al
PM
10
/ 2
.5
As
pe
r S
che
du
le B
1.2
, d
ust
de
po
siti
on
is m
ea
sure
d o
nce
pe
r q
ua
rte
r o
n a
30
da
y c
om
po
site
sa
mp
le.
An
nu
al m
ea
sure
me
nt
of
am
bie
nt
PM
10
& 2
.5 w
as
carr
ied
ou
t. A
lth
ou
gh
no
lim
its
are
se
t fo
r th
ese
pa
ram
ete
rs in
th
e li
cen
ce,
the
re
sult
s w
ere
sti
ll b
elo
w
na
tio
na
l lim
its.
A c
op
y o
f th
is r
ep
ort
is
ava
ila
ble
on
sit
e f
or
insp
ect
ion
.
All d
ust
de
po
siti
on
re
sult
s a
re w
ith
in t
he
lim
its
set
ou
t in
th
e lic
en
ce,
as
sho
wn
in
th
e t
ab
le b
elo
w;
Loca
tio
n
Q1
Q
2
Q3
Q
4
ELV
C
om
pli
an
ce (
%)
AM
1
19
9
27
6
32
1
33
2
35
0
10
0
AM
2
17
7
15
4
14
0
28
5
35
0
10
0
AM
3
13
8
19
8
10
9
30
1
35
0
10
0
AM
4
11
2
19
2
12
7
33
5
35
0
10
0
*A
M 5
12
3
79
3
46
3
06
--
--
----
No
te 1
:
All r
esu
lts
in m
g /
m2/
da
y *N
ote
2:
AM
5 i
s n
ot
spe
cifi
ed
in t
he
lice
nce
bu
t is
do
ne
in
ad
dit
ion
to
AM
1-4
, h
en
ce n
o lim
its
are
se
t fo
r th
is lo
cati
on
Section 3 – Waste Management
3.1 Waste Management Overview
Toonagh Lime works follows acceptable principles of waste management and control. These
principles are as follows:
Prevention
Toonagh Lime Works strives to prevent waste wherever possible. This principle is
efficient operation of the plant and process. Since all raw materials are used during the pro
there is no process waste
Minimisation
The efficient control of the plant and equipment ensures that the generation of material
specification is kept to an absolute minimum
Re-use
All process materials are used within the proces
Recycling
Waste materials generated will be recycled where possible
Energy Recovery
Energy recovery from waste material does not
Disposal
The production of waste is minimised through the efficient operating of all areas of production. With
the reduction of waste through the implementation of the above principles the disposal of waste
kept to a minimum
3.2 Repak
We are members of the Repak scheme and post returns biannually
Energy Recovery
Management
Waste Management Overview
Toonagh Lime works follows acceptable principles of waste management and control. These
Toonagh Lime Works strives to prevent waste wherever possible. This principle is intrinsic to the
efficient operation of the plant and process. Since all raw materials are used during the pro
The efficient control of the plant and equipment ensures that the generation of material
is kept to an absolute minimum
All process materials are used within the process to produce the final products
ill be recycled where possible
Energy recovery from waste material does not apply to the operations at Toonagh Lime Works
The production of waste is minimised through the efficient operating of all areas of production. With
the reduction of waste through the implementation of the above principles the disposal of waste
We are members of the Repak scheme and post returns biannually
Prevent
Reduce
Re-Use
Recycle
Energy Recovery
Disposal
7
Toonagh Lime works follows acceptable principles of waste management and control. These
intrinsic to the
efficient operation of the plant and process. Since all raw materials are used during the process,
The efficient control of the plant and equipment ensures that the generation of material outside
apply to the operations at Toonagh Lime Works
The production of waste is minimised through the efficient operating of all areas of production. With
the reduction of waste through the implementation of the above principles the disposal of waste is
8
3.3
W
ast
e R
eg
iste
r
Th
e f
ull P
oll
uta
nt
Re
lea
se a
nd
Tra
nsf
er
Re
gis
ter
can
be
fo
un
d in
Ap
pe
nd
ix C
Th
e t
ab
le b
elo
w g
ive
s a
su
mm
ary
of
ph
ysic
al
wa
ste
s le
av
ing
th
e s
ite
Ha
zard
ou
s w
ast
e c
on
sist
ed
of
con
tam
ina
ted
so
il f
rom
th
e d
iese
l lo
ss in
cid
en
t a
s d
esc
rib
ed
in
Ap
pe
nd
ix A
Fu
ll C
1 r
eco
rds
are
ava
ila
ble
on
sit
e
Wa
ste
De
scri
pti
on
H
aza
rdo
us
(Ye
s /
No
) E
WC
D
isp
osa
l/
Re
cov
ery
Co
de
Dis
po
sal
Co
mp
an
y
Wa
ste
Tra
nsp
ort
er
Fin
al
De
stin
ati
on
Qu
an
tity
of
Wa
ste
Pro
du
ced
Ge
ne
ral
Wa
ste
G
en
era
l wa
ste
fro
m s
ite
an
d
wo
rksh
op
No
2
0 0
3 0
1
D1
Cla
re W
ast
e
Ltd
Gre
yho
un
d
Re
cycl
ing
Cla
re W
ast
e
Ltd
Cle
an
Ire
lan
d
Re
cycl
ing
Ltd
Ba
llin
ag
un
Lan
dfi
ll,
Cre
e,
Co
. C
lare
Ina
gh
La
nd
fill
,
Co
. C
lare
4.0
2 t
Wa
ste
Wo
od
Pa
lle
ts e
tc
No
2
0 0
1 3
8
R3
G
reyh
ou
nd
Re
cycl
ing
Cle
an
Ire
lan
d
Re
cycl
ing
Ltd
Fin
sa L
td,
Sca
riff
, C
o.
Cla
re
2.2
2 t
Mix
ed
Re
cycl
ab
les
Dry
off
ice
an
d
pa
cka
gin
g
wa
ste
No
2
0 0
1 0
1
R3
G
reyh
ou
nd
Re
cycl
ing
Cle
an
Ire
lan
d
Re
cycl
ing
Ltd
Cle
an
Ire
lan
d
Re
cycl
ing
,
Cre
e,
Co
.
Cla
re
0.1
2 t
Co
nta
min
ate
d
So
il
Fro
m d
iese
l
loss
inci
de
nt
Ye
s 1
7 0
5 0
3*
R5
E
NV
A L
td
EN
VA
Ltd
E
NV
A
Po
rtla
ois
e
66
.76
t
9
Section 4 – Resource Consumption
The table below outlines the resource consumption at Toonagh Lime Works in 2010;
Resource 2010 2009 Units
Petcoke 6375 5351 tonnes
Electricity 2.271 2.01 GWh
On-site ground water abstraction 45 50 m3
On-site surface abstraction 0 0 m3
Municipal supply 0 0 m3
The sole raw material for the process is limestone. 100% of raw material brought on site is
consumed with no process waste generated.
Section 5 – Bund Integrity
Toonagh Lime Works maintains two bunded areas on site;
Bund 1 – Oil storage bund
Bund 2 – Petcoke diesel bund
Both bunds were tested for soundness in 2010 and were found to be impermeable to water loss
Both bunds are due again for testing in 2013.
Section 6 – Complaints / Incidents
There were no complaints in Toonagh Lime Works in 2010, or in any previous year of operation.
There was one incident on site, as detailed in Appendix A.
A non- compliance against Condition 5.1 of the licence was issued in inspection report reference #
((P0771-01)sm03vt)).
10
Se
cti
on
7 –
En
vir
on
me
nta
l M
an
ag
em
en
t P
rog
ram
me
7.1
R
ev
iew
of
20
10
Ob
ject
ive
s a
nd
Ta
rge
ts (
2n
d S
che
du
le)
Are
a
Ob
ject
ive
T
arg
et
Tim
efr
am
e
Re
spo
nsi
bil
ity
P
rog
ress
En
vir
on
me
nta
l M
an
ua
l
To
est
ab
lish
an
En
viro
nm
en
tal M
an
ua
l
an
d im
pro
ve t
he
EM
S
To
ha
ve
a f
ull
y d
igit
al,
com
pa
ny-
wid
e
En
vir
on
me
nta
l M
an
ua
l
by
20
12
Sta
ge
1 –
Ju
ly
20
10
Mr.
Jo
e C
on
no
lly
Mr.
Bre
nd
an
Wa
lsh
Sta
ge
1 c
om
ple
ted
En
viro
nm
en
tal M
an
ua
l e
sta
blish
ed
En
erg
y U
sag
e
To
id
en
tify
are
as
wh
ere
a
red
uct
ion
in e
ne
rgy
con
sum
pti
on
is
po
ssib
le
To
re
ma
in b
elo
w t
he
up
pe
r le
ve
ls o
f e
ne
rgy
con
sum
pti
on
as
fou
nd
in t
he
BR
EF
fo
r th
e li
me
ind
ust
ry
En
d 2
01
0
Mr.
Ala
n R
ya
n
Mr.
Bil
l Ke
og
h
Co
mp
lete
d
Sit
e id
en
tifi
ed
as
be
ing
hig
hly
en
erg
y
eff
icie
nt
Fu
ll r
ep
ort
av
ail
ab
le o
n s
ite
fo
r
insp
ect
ion
Du
st
To
co
ntr
ol fu
git
ive
em
issi
on
s
To
re
ma
in b
elo
w t
he
lim
its
for
du
st
de
po
siti
on
as
set
ou
t in
the
lice
nce
On
go
ing
M
r. J
oe
Co
nn
oll
y
Mr.
Bil
l Ke
og
h
Du
st a
wa
ren
ess
pro
gra
m i
nit
iate
d
No
du
st c
om
pla
ints
in
20
10
or
an
y
pre
vio
us
ye
ar
Tra
inin
g
To
ke
ep
all
sta
ff u
p t
o
da
te w
ith
ne
w a
nd
exi
stin
g le
gis
lati
on
an
d
be
st p
ract
ice
me
tho
ds
To
en
sure
th
at
ke
y
ma
na
ge
me
nt
are
fu
lly
aw
are
, a
t a
min
imu
m,
of
ke
y le
gis
lati
ve
issu
es
On
go
ing
M
r. J
oe
Co
nn
oll
y
Inte
rna
l tra
inin
g w
as
carr
ied
ou
t in
20
10
Ext
ern
al tr
ain
ing
(E
PA
se
min
ar)
att
en
de
d
11
7.2
2
01
1 O
bje
ctiv
es
an
d T
arg
ets
(3
rd S
che
du
le)
Are
a
Ob
ject
ive
T
arg
et
Tim
efr
am
e
Re
spo
nsi
bil
ity
O
pe
rati
on
al
Me
an
s /
Me
cha
nis
m f
or
Ach
iev
em
en
t
En
vir
on
me
nta
l M
an
ua
l
Sta
ge
2 –
to
exp
an
d t
he
exi
stin
g M
an
ua
l, f
ocu
sin
g
on
em
erg
en
cy
pre
pa
red
ne
ss
To
ha
ve
a f
ull
y d
igit
al,
com
pa
ny-
wid
e
En
vir
on
me
nta
l M
an
ua
l
by
20
12
Sta
ge
2 –
En
d
20
11
Mr.
Jo
e C
on
no
lly
Mr.
Bre
nd
an
Wa
lsh
Mr.
Ma
rk K
en
ne
dy
Mr.
Bil
l Ke
og
h
Ma
nu
al w
ill
be
exp
an
de
d a
nd
tie
d i
n
wit
h t
he
OH
SA
S 1
80
01
sy
ste
m f
or
em
erg
en
cy r
esp
on
se.
Ge
ne
ral p
roce
du
res
will
be
exp
an
de
d
an
d u
pd
ate
d.
En
erg
y U
sag
e
To
in
corp
ora
te t
he
fin
din
gs
of
the
en
erg
y
usa
ge
su
rve
y c
arr
ied
ou
t
in 2
01
0 in
to a
fu
ll e
ne
rgy
eff
icie
ncy
au
dit
To
re
ma
in b
elo
w t
he
up
pe
r le
ve
ls o
f e
ne
rgy
con
sum
pti
on
as
fou
nd
in t
he
BR
EF
fo
r th
e li
me
ind
ust
ry
En
d 2
01
1
Mr.
Ala
n R
ya
n
Mr.
Jo
e C
on
no
lly
A f
ull
en
erg
y e
ffic
ien
cy a
ud
it w
as
last
carr
ied
ou
t in
20
08
.
Th
is d
esk
ba
sed
au
dit
will
be
re
vis
ed
usi
ng
th
e in
form
ati
on
fro
m t
he
en
erg
y
usa
ge
su
rve
y c
arr
ied
ou
t in
20
10
.
Die
sel
Loss
To
fu
lly
co
mp
ly w
ith
th
e
reco
mm
en
da
tio
ns
of
WY
G in
re
lati
on
to
th
e
die
sel l
oss
inci
de
nt
in
20
10
To
ha
ve
co
mp
lete
d o
ff
site
mo
nit
ori
ng
an
d
red
uce
d o
n s
ite
mo
nit
ori
ng
by
en
d o
f
20
11
En
d 2
01
1
Mr.
Jo
e C
on
no
lly
Mr.
Ma
rk K
en
ne
dy
Mr
Bil
l Ke
og
h
Fu
ll c
on
sid
era
tio
n w
ill b
e g
ive
n t
o t
he
fin
al W
YG
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12
Section 8 – Reports
8.1 Review of ELRA and CRAMP
The original ELRA and CRAMP was completed and submitted to the Agency in 2007.
The Financial Provisions in the original document are considered sufficient for the site at present.
A new ELRA, incorporating Financial Provisions (2011) is currently being drafted and will be
submitted to the Agency for approval in Q2 of this year.
8.2 Energy Efficiency Audit – Summary
An energy efficiency audit was carried out in 2008. This report was submitted to the Agency. The
report found that no major savings could be made in the area of energy efficiency, although some
minor modifications to the plant were recommended. Toonagh Lime Works operates a highly
efficient dual shaft regenerative kiln, and the audit found that it is operating at levels considered to
be those of an efficiently operated kiln, as found in the BREF for the lime industry (2001 version).
An energy monitoring survey was carried out in 2010. Using the results from this survey it is planned
to repeat the original energy use survey in 2011. Results from this will be compared to the typical
results as found in the latest BREF (2010 version) for the lime industry.
8.3 Bat Survey
As agreed in letter to the Agency dated 30th
June 2010, the bat survey is now required every second
year instead of annually. Therefore no survey was carried out in 2010. A survey is planned for 2011.
8.4 WYG Incident Report
A report on the diesel loss incident was submitted to the Agency on the 26th
November 2010. This
report contained an overview of the incident, the initial response and the proposed medium to long
term plan. A second WYG report is expected in Q2 2011.
13
Section 9 – Inspections
Two site inspection reports were issued in 2010;
Inspection Reports
SM02aJD SM03vt
Date of Inspection
4/11/2009 3/11/2010
Date of report
12/11/2010 22/11/2010
Non-compliances
None One
Audit observation 1
Storage of waste on site SO2 test programme
Audit observation 2
Records not available for
inspection Oil and lubricant store
Audit observation 3
SO2 test programme Financial provision
Audit observation 4
General housekeeping -----
Audit observation 5
Diesel tank hose -----
All points in both reports have been addressed and a response sent to the Agency
14
Appendix A – Diesel Loss Incident
Overview
On the 28/29th
October 2010, an incident occurred on site at Toonagh Lime Works. An operator
error resulted in the loss of approximately 2800 litres of diesel from a bunded storage tank on site
As soon as the loss of diesel became apparent, an emergency response plan was initiated. The EPA,
local County Council and the Inland Fisheries board were contacted
WYG Environmental Consultants were brought in to project manage the incident response
Response to incident
The immediate response to the incident involved the collection of residual diesel on site and the
monitoring of wells and springs both on and off site. Clogrennane Lime Ltd worked closely with the
Agency and local County Council, with several meetings being held between the relevant parties
In the medium to long term, monitoring wells were drilled on site with a view to establishing a pump
and treat system for any diesel encountered. Inspection of off-site wells and springs continued on a
routine basis
Current standing
No diesel was encountered at any monitoring location on or off site. The monitoring wells have not
encountered any diesel contamination and there has been no evidence of diesel contamination in
the groundwater
The site itself sits on a massive limestone formation. The foundations of the kiln were built on this
formation and surrounded by granular infill material. It is suspected that the diesel lost is held in the
porous material at the foundations of the kiln
Monitoring of the wells both on and off site will continue for a period as agreed with the Agency
Correspondence with the Agency
A joint Clogrennane Lime Ltd / WYG Incident Report was submitted to the Agency on the 26th
November 2010. This report contained an overview of the incident and the medium to long term
incident response plan
Site inspection report SM03vt was received from the Agency on the 22/11/2010, dealing mainly with
the incident. A non-compliance was issued against Condition 5.1 of the licence
15
Appendix B – AER Contents as per Schedule D
Topic Comments
Emissions from installation
Included
Waste management record
Included
Resource consumption summary
Included
Schedule of environmental objectives
Included
Environmental management programme – previous year
Included
Environmental management programme – current year
Included
Pollution emission register – previous year
Included
(PRTR)
Pollution emission register – current year
Included
(PRTR)
Noise monitoring summary
Included
Ambient monitoring summary
Included
Tank and pipeline testing and inspection report
Included
(Section 5)
Reported incidents summary
Included
(Appendix A)
Energy efficiency audit report summary
Included
Report on the assessment of the efficiency of use of raw materials in process and
the reduction in waste generated
Included
Report on Progress Made and Proposals being developed to minimize Water
Demand the Volume of Trade Effluent Discharged
N/A
Review of residuals management plan
Included
Review of Environmental Liabilities including Financial Provision
Included
Appendix C – Pollutant Release & Transfer Register – 2010 & 2009
