Decommissioning Management Plan

For

Lagan Cement Limited

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Document Control Details Control Item Details Document Owner/ Curator

Brian Reynolds

Security Classification Confidential Supersedes Revision Level C File Location W Drive/Environmental Master Folder/ISO 14001/Env

Management Manuals Document Number DMP 001

Revision History Revision Level Date Revision description Originator A 27-6-02 First Revision Brian Reynolds B 12-04-07 Second Revision – new

licence No. inserted Brian Reynolds

C 16-06-08 Third Revision – Residuals Mgt Plan restructured against EPA guidelines.

Brian Reynolds

D 04-03-09 Fourth Revision – new license No. and fuel type inserted.

Brian Reynolds

Approvals Approver Function Location Tom McManus Technical Manager Kinnegad Brian Reynolds Environmental Officer Kinnegad

Notification List Function Site Environmental Department: Tom McManus

Lagan Cement

Distribution List Function Site Environmental Department: Tom McManus

Lagan Cement

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Table of Contents

Section 1: Introduction

• Facility and Licence Details • Facility Closure Scenarios Covered in Plan

Section 2: Site Evaluation

• Facility Description & History • Facility Compliance Status • Facility Processes and Activities • Inventory of the Site Buildings, Plant, Raw Materials and Wastes.

Section 3: Closure Considerations

• Clean or Non Clean Closure Considerations • Plant or Equipment Decontamination Requirements • Plant Disposal or Recovery • Soil or Spoil removal

Section 4: Criteria for successful closure

• Addressing of Site Environmental Liabilities at Closure. Section 5: Closure Plan Costing

• Decontamination Costs • Plant & Waste Disposal Costs • On going Monitoring • Facility Security & Staffing

Section 6: Closure Plan Update & Review

• Proposed Frequency of Review • Proposed Scope of Review

Section 7: Closure Plan Implementation

• EPA Notification. • Local or other Statutory Authority notifications • Test Programme • Full or Partial Closure considerations

Section 8: Closure Plan Validation

• Closure Validation Audit • Closure Validation Audit Report • Closure Validation Certificate.

Section9: Preparation of Restoration and Aftercare Management Plan.

• Restoration Plan • Costing of Restoration Plan

Appendix 1 – Site Layout

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Section1 Introduction

Facility and Licence Details: Operator Name: Lagan Cement Ltd Installation Name: Lagan Cement Ltd Location of Site: Killaskillen

Kinnegad Co Meath

Telephone No. 044 9379200 Facsimile No. 044 9379201 IPPC Licence No. P0487-05 Facility Closure Scenarios Covered in Plan:

The closure scenario outlined in this report is a ‘Clean Closure’ – therefore upon

cessation of cement production and decommissioning of the facility, there will be no

remaining environmental liabilities. The plan will outline the decommissioning and

restoration of the production site and associated quarries.

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Section 2

Site Evaluation

Facility Description & History: Lagan Cement Ltd operates a cement works and associated limestone and shale

quarries at Killaskillen, Kinnegad, County Meath. The limestone and shale quarries

supply raw materials for the cement manufacturing process The plant is located in the

south western corner of County Meath adjacent to the County Westmeath border. The

plant is approximately 2.5 km southwest of Kinnegad, 1.2km north of Ballinabrackey,

60 Km by road from Dublin and Athlone and approximately 17km south east of

Mullingar.

The company applied for an IPPC licence to carry out the activity of ‘production of

cement’ at the site and was issued with licence reg. No. P0487-01 on 21 May 2001. In

2003, Lagan Cement applied for a licence review in order to increase production of

cement from 450,000 to 600,000 tons per annum. This revised licence was issued on

6th November 2003. On 27th April 2005, the company submitted an application for the

co-incineration of meat and bone meal as a fuel source. Licence registration No. 487-

03 was issued on 8th May.

The licence, 487-04 was issued on 13th May 2008. This licence facilitated the

introduction of additional waste products as raw materials and fuel sources into the

production process. It allowed an increase in the cement production rate from 600,000

tons to 700,000 tons per annum.

The current license, 487-05 was granted on the 26th January 2009 and allows for the

introduction of SRF and TDF as additional fuel sources.

Facility Compliance Status:

The overall environmental compliance at the Lagan Cement is of a high standard. The

management and monitoring systems ensure compliance with legal and regulatory

requirements and best practice. The aims of the management system are to comply

with all requirements of the IPPC licence, prevent any environmental incident which

could give rise to significant releases to the environment and the on-going continuous

improvement of environmental performance.

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An operational risk assessment was carried out to determine the environmental risk

category of the process. In conjunction with compliance, this assessment also took

into account the complexity and environmental sensitivity of the operation. The

classification was undertaken for the site using the scoring system outlined in the EPA

ELRA Guidance Document 2006. The complexity examined the potential hazards due

to the operation of the site. The environmental sensitivity of the surrounding

environment took into account the key receptors which include Human Beings;

Groundwater; Surface Water; Air Quality; Protected Ecological Sites and Sensitive

Agricultural Receptors. The matrix used attributed a score of 8, which indicates that

the Environmental Sensitivity Classification for the site and surrounds is 2.

Facility Processes and Activities:

Lagan Cement Ltd manufactures grey Portland Cement. Cement is produced in a kiln

at very high temperatures from a mixture of raw materials. Limestone is the primary

raw material required for the production of cement. Shale is an important additive for

the manufacture of cement. All of the limestone required onsite is excavated from the

onsite limestone quarry. The shale quarry provides a certain quantity of the shale

requirements for the plant with a certain amount also imported to the site from

elsewhere. Other raw materials such as iron ore, bauxite and gypsum are currently

imported to the site. Coal, meat & bone meal, SRF and diesel oil are also used as fuels

within the kiln.

There are eight stages in the cement manufacturing process:

1. Raw material preparation;

Limestone from the on-site quarry is passed through a primary and then through a

secondary crusher where the shale produced in the onsite quarry is also crushed. The

imported shale, sand and bauxite are also added in at the secondary crusher stage. The

raw materials have now been crushed to sub a 100mm mix.

Crushed material is then transported via a covered conveyor to the blending shed. The

conveyor is fitted with neutron type analysers for continuous measurement of

calcium, silica, iron and alumina in the raw feed.

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2. Blending;

The raw material mix which has been transported from the secondary crushers are

blended in the blending shed reducing fluctuations by laying a large number of layers

on a stockpile within the shed. This is now referred to as the blended raw mix.

Material is reclaimed off the pile and fed to the raw mill at an average rate of about

37tonnes per hour.

3. Raw meal milling and mixing;

A belt conveyor feeds the blended raw mix reclaimed from the blending shed to the

raw mix feed bin. From the feed bin the material is fed to a raw mill for grinding and

drying to a fine dust called raw meal.

4. Raw meal kilning;

The installation consists of three major sections, the preheater, the kiln and the clinker

cooler – the latter operation is discussed below. A variety of equipment serves this

unit at start-up, shut down and during normal operation.

The raw meal is drawn from the raw meal feed silos through discharge hoppers to a

weighing bin and is introduced close to the top of the column in the kiln pre-heater.

As it is guided down through the cyclones in the system, it picks up heat from the hot

gases produced in the kiln.

At the bottom of the pre-heater the hot material is introduced into the kiln where its

temperature is gradually brought up to 1420°C utilizing flame temperatures of up to

2000oC. As the kiln rotates the material inside tumbles following a spiral path on the

inside of the kiln shell, finally reaching the outlet where it drops into the clinker

cooler. Here the intermediate product, clinker, is abruptly cooled to 600°C and then

down to 100°C at a slower pace. The heat of the material is recovered, heating the air

needed for combustion.

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5. Clinker cooling and handling:

From the end of the kiln, clinker drops out into the clinker cooler. This is a cross flow

heat exchanger: ambient air is blown through a moving grate and through the clinker

to cool it at a forced high rate from 1350 OC down to 600 OC and then on to lower

temperatures at a slower pace.

The clinker is crushed by a roller-breaker to remove large lumps and is transported

with special heat resistant conveyors to clinker silos for storage. From the clinker

silos, clinker is fed to the cement mill for grinding to cement as and when required.

6. Clinker grinding:

Cement is produced by grinding the intermediate product, clinker, with gypsum in the

correct proportions. Cem II clinker content can range from 80-94%, with limestone

comprising 6-20%. Cem I clinker contents range from 95% - 100%, with limestone

comprising up to 5%. In addition both Cem I and Cem II also contain approximately

4% gypsum, which is added at the clinker grinding stage to control the setting

characteristics of the final cement. Cement grinding is done in a ball mill, a metal tube

lined with special cast steel liner plates designed to help lift the grinding media (steel

balls) in the mill as it is turned. The mill is internally divided into two chambers with

a diaphragm separating the unequally sized compartments. The first compartment pre-

grinds the coarse material while the second compartment completes the grinding

process. To improve efficiency, air flowing through the mill cools the material being

ground and moves material faster through the system. With the help of an air

separator the fine ground material is removed as finished product while coarse

material is returned to the mill at the feed end. Material continues circulating in a

closed circuit until it reaches the required fineness. The finished product from the

clinker grinding is transferred to the cement silos.

7. Storage and Handling of Cement:

From the cement silos, cement is drawn pneumatically and conveyed by air slides into

bucket elevators for bagging and pallet loading in the packing plant or for direct

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loading in to container trucks. The packing machine fills bags of 25kg at a rate of up

to 2,400 bags per hour which are conveyed to a palletising machine. Pallets are either

loaded immediately for sale or stocked.

8. Coal Preparation

Coal from the coal storage area is conveyed as needed to a feed bin, which in turn

feeds the coal to the coal mill. Coal needs to be ground to a fine powder to facilitate

combustion in the kiln. The high temperatures required in a cement kiln and the way

heat needs to be transferred to the material in the kiln requires a flame with a high

temperature. This is achieved via coal dust blown in through a burner pipe. The flame

reaches temperatures of about 2,000oC. The coal mill operation is similar to the raw

meal mill, only significantly smaller in capacity and specially designed to grind coal

safely. The milled coal from the coal mill is stored in one of two fine coal silos.

The coal dosing system from the fine coal silos to the burners is controlled

gravimetrically. In the kiln, coal is burned only when temperatures are high enough

for safe combustion. To start-up the installation fuel oil is used to preheat the areas

where coal combustion takes place. This is a matter of safety. For this purpose special

arrangements are made for the fuel supply.

Inventory of the Site Buildings, Plant, Raw Materials and Wastes.

The Lagan Cement facility comprises of the following buildings/plant:

• Primary crusher Cement mill • Secondary Crusher Electricity sub station • Blending Shed Cement silos • Raw mill Clinker Silo • Raw meal homogenising silo Packing and Bulk Loading • Raw meal silo Stores building • Preheater tower Workshop • Kiln Facilities Building • Oil tanks Weighbridge • Coal store building Administartion Building • Coal Mill Vehicles Washes • Clinker Cooler Control Room & laboratory • Gypsum store Mobile Plant

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The buildings on site are a new design, consisting of concrete, steel work and

cladding. No asbestos cement sheeting was used, as in older plants and therefore the

buildings pose no environmental concern in the event of decommissioning/closure.

Site layout details are contained in Appendix I.

The raw material utilised and stored on site comprise of the following:

• limestone • shale • sand • overburden, • iron ore, • bauxite • Gypsum

The fuel utilised and stocked on site currently consist of:

• Coal • Meat & Bone Meal • Oil • SRF

In the event of decommissioning/closure, all stocks/fuels would be utilised prior to

closure. As this would be apart of normal operation, no extra costs would be involved.

To prevent any spillage to ground all oil tanks are bunded. Lagan Cement complete a

bund integrity assessment once every 3 years in accordance with section 6.6 of the

IPPC guidance note on ‘Storage and Transfer of Materials for Scheduled Activities’.

In addition all underground pipes are also tested for integrity as per licence conditions

Wastes onsite consist of non hazardous and hazardous and are as follows:

• Oil • Filters • Grease • Timber • Cardboard • Mixed Commercial • Metal • Batteries • Gas Discharge Lamps

All wastes are removed from site by waste collection permit holders and are

transported to licensed waste premises. All waste records are retained on site.

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Section 3

Closure Considerations Clean or Non Clean Closure Declaration:

On the decommissioning/closure of Lagan Cement, the closure is expected to be a

‘Clean Closure’. Once plant is decommissioned and removed there will be no

remaining environmental liabilities.

Plant or Equipment Decontamination Requirements:

Due to the nature of the cement production industry and materials used there will be

no decontamination requirements.

Plant Disposal or Recovery:

Decommissioning and plant removal will involve all structures above and below

ground. The individual stages of decommissioning are set out in a logical sequence.

However timeframes of decommissioning stages may overlap. The stages of

decommissioning are as follows:

Stage 1 Production decommissioning

Stage 2 Removal of excess residuals from site

Stage 3 Decommissioning/removal of plant

Stage 1: Production Decommissioning

The objective would be to shut the plant down in a structured format, starting with the

quarry area and progressing through to the final stages of cement milling and export

of final product from site.

Step 1

The first step would be to cease all activity with the limestone and quarry areas

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Step 2

Utilise all raw material already stockpiled in vicinity of secondary crusher. (correct

proportions would be left as advanced notice of closure is assumed.) Both primary

and secondary crushers could then be decommissioned.

Step 3

Utilise all material in the blending shed for the production of raw meal. Once all

material in blending shed has been utilised, the blending shed(stacker/reclaimer) and

raw mill can be decommissioned.

Step 4

Utilise all stocks of raw meal within raw meal silo for the production of clinker. Once

all stocks are utilised, the raw meal silo, preheater tower, kiln, clinker cooler, coal

mill, coal shed, coal feed silos and kiln fuel oil tanks can be decommissioned.

Step 5

Utilise all clinker stocks in the clinker silos, yard clinker and gypsum stocks for the

production of cement. (correct proportions of clinker/gypsum are assumed due to

advanced notice). Once all clinker is utilised, the clinker silo and cement mill can be

decommissioned.

Step 6

Remove all cement from cement silos via bulk tanker and bagging. Decommission

cement silo’s, cement lorry despatch and bagging/palletising machines.

Waste Disposal or Recovery:

All raw materials will be utilised in the making of cement during the

decommissioning of the plant. Remaining residuals such as waste oil and greases will

be disposed of through licensed companies. As disposal/recycling is an on-going

event, it is estimated that approximately six months of waste will have to be disposed

of. Any stocks items remaining in stores will be returned to manufacturers.

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Soil or Spoil Removal:

Due to the nature of the cement production industry and materials used there will be

no requirement for soil or spoil removal.

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Section 4

Criteria for Successful Closure

Addressing of Site Environmental Liabilities at Closure:

A successful clean closure at Lagan Cement will be achieved if the following criteria

have been met. The criteria include:

• Full decommissioning of all process equipment.

• Use of all raw materials and removal of all finished product from site.

• Removal of all plant and equipment from site.

• All wastes removed from site and disposed/recovered in accordance with the

appropriate National and European legislation protocols.

• Maintenance of environmental system including all procedures/records until

end of closure period.

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Section 5

Closure Plan Costing Contained within this section are the estimated costs of plant decommissioning, plant

removal and waste removal.

Decontamination Costs:

No costs are estimated against decontamination of plant. Plant & Waste Disposal Costs: Plant Decommissioning:

It is considered that there will be no additional cost for decommissioning supervision

as this can be achieved under normal working conditions.

Plant Removal:

It is estimated that the scrap value of all machinery would cover the cost of

dismantling/removal. For concrete buildings /structures, the removal costs are based

on a percentage of the cost of buildings. It is estimated that approximately cost would

be €2.3 million. This will be set aside over the lifetime of the plant operation.

Raw Material Removal:

All raw materials will be utilised in the making of cement during the

decommissioning stage. Therefore no costs will be incurred.

Waste Removal:

Remaining residuals such as waste oil and greases will be disposed of through a

licensed company. Disposal/recycling is on-going. Any stocks items remaining in

stores will be returned to manufacturers. On previous costings, disposal of the above

would be estimated at €5000

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On Going Monitoring:

There will be no additional costs for on going monitoring as the site closure will be a

‘Clean Closure’ and therefore no remaining environmental liabilities once

decommissioned.

Facility Security & Staffing:

Staffing levels will be gradually reduced as the plant is closed. Therefore no extra

costs will be incurred.

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Section 6

Closure Plan Update & Review

Proposed Frequency of Review:

The closure plan is reviewed on an annual basis. Proposed Scope of Review:

The review examines all the elements as outlined in the contents section.

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Section 7

Closure Plan Implementation

EPA Notification:

The EPA will be notified in writing following the termination or cessation for a period

greater than six months of use or involvement of all or part of the site as per licenced

activities. A two week notice period will be provided to the Agency under planned

cessation conditions. Under unplanned cessation conditions, the Agency will be

notified as soon as practicable.

Local or other Statutory Authority notifications:

Both Meath County Council and the Eastern Regional Fisheries Board will be notified

upon cessation of activity.

Test Programme:

The site closure at Lagan Cement will be a clean closure and as such no test

programme will be required.

Full or Partial Closure considerations:

Due to the nature of the plant a full closure would be expected. The full closure will

be carried out under three stages as outlined in the Section 3 ‘Closure Considerations’.

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Section 8

Closure Plan Validation

Closure Validation Audit:

In the event of a plant closure, Lagan Cement propose to utilise the services of URS

Ireland Ltd to carry out the validation audit. URS Ireland are an independent

professional body and are suitably qualified to carry out the work. URS conducted the

Environmental Liabilities Risk Assessment on behalf of Lagan Cement.

Closure Validation Audit Report:

An independent validation audit would encompass the physical closure of the facility.

This would involve validating all the criteria as set out in section ‘Criteria for

Successful Closure’. The criteria are:

• Full decommissioning of all process equipment.

• Use of all raw materials and removal of all finished product from site.

• Removal of all plant and equipment from site.

• All wastes removed from site and disposed/recovered in accordance with the

appropriate National and European legislation protocols.

• Maintenance of environmental system including all procedures/records until

end of closure period.

On completion, a full report and closure certificate will be issued by URS to Lagan

Cement.

Closure Validation Certificate:

The final closure report and certificate will be submitted to the Agency within 3

months of execution of the plan.

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Section 9

Preparation of Restoration and Aftercare Management Plan

The Lagan Cement site will not require a full restoration and aftercare management

plan. Once decommissioned, there will be no remaining environmental liabilities. The

restoration will be minimal with reshaping of quarry edges and general top soiling and

tree planting required. No after care management plan will be required.

Restoration Plan

The restoration plan examines how the quarries will be restored and how Lagan

Cement site will be returned to agricultural use. The individual stages of restoration

are set out, however timeframes of restoration stages may overlap. The stages of

restoration are as follows:

Stage 1 Restoration of Limestone Quarry

Stage 2 Restoration of Shale Quarry

Stage 3 Reshaping of Settlement Ponds

Stage 4 Top soiling and planting of trees.

Stage 1: Restoration of Limestone Quarry:

On cessation of the plant and with pumping from the quarry stopped, groundwater

levels are expected to rebound, filling the limestone quarry. A lake will form within

the quarry. Final restoration proposal would include the soiling of some sections of

the quarry bench to encourage colonisation and some re-grading and planting of

overburden slopes around the margin.

Were possible, margins would be re-graded to provide shallow bank gradients, with

soiling, grassing, marginal and aquatic planting carried out. The quarry overburden

slopes would be graded back to 1:4 maximum grading. The upper part of the top

quarry face will remain above the level of the water to a maximum of 6 metres.

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Stage 2: Restoration of Shale Quarry:

In the shale quarry, once pumping has ceased, groundwater levels will rebound to

form a new lake. The rock slope will be covered with 2 metres of overburden, soiled

and grassed.

Stage 3: Reshaping of Settlement Lagoons:

The final settlement ponds have been constructed with sloping sides to accommodate

wildlife. The more steep sided attenuation pond will be reshaped to form shallow

areas for wildlife.

Stage 4: Top Soiling and Tree Planting of Works site:

The works site and quarry handling area will be re-graded to original levels, soiled

and returned to agricultural use. The material storage area will be re-graded, soiled

and planted as woodland. The screen bunds will be graded out, soiled and grassed or

planted. Within the landscaping scheme for restoration, approximately 17 ha of new

woodland will be planted.

Costing of Restoration Plan

An estimate cost for re-grading the limestone quarry overburden slopes would be

approximately €5,000. Similar works for the shale quarry re-grading would cost

€3000. The general landscaping required combined with tree planting would be at a

cost of €20,000.

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Appendix I

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EPA Export 26-07-2013:19:22:06

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EPA Export 26-07-2013:19:22:06