unit 15 t: 021 434 5366 melbourne business parkthis identified there was limited measured...

1 of 7 C:14\196\02_Galway Metal Company IE Application September 2015

Ms Liz Leacy,

Office of Climate Licensing and Resource,

Environmental Inspection Agency,

PO Box 3000,

Johnstown Castle Estate,

County Wexford.

31st August 2015

Re: Application for Licence (Reg. No: P1006-01) Galway Metal Company Limited, Oranmore,

Dear Ms..Leacy,

I refer to the Agency’s letter dated the 18th August 2015 in accordance with Regulation

10(2)(b)(ii) of the EPA (Industrial Emissions)(Licensing) Regulations 2013. The requested

information is set out herein.

Emissions to Air - Fragmentiser

1. Provide information on the likely nature, characteristics and volume of the air emissions

from the fragmentiser.

The nature, characteristics and volume of the air emissions from a fragmentiser depends on the

type and configuration of the system. Typically a fragmentiser comprises an input conveyor

that feeds pre-shredded metals to a hammer mill. The output from the mill, includes metal and

non-metal materials that pass through a downline separation process which removes the non-

metal residue. The metal fraction is then segregated into ferrous and non-ferrous streams. There

are two discrete air emission sources from a fragmentiser, the hammer mill and the downline

output separation process.

There are two types of hammer mills used in the fragmentisers-'damp' and 'dry' In Ireland and

the UK the 'damp' mill is the dominant methodology, whereas a 'dry' mill is the most commonly

used system in the EU.

In the ‘damp’ system water is injected into the mill chamber under regulated conditions to

ensure it turns to vapour, producing a damp atmosphere. This objective is to control the mill

temperature, suppress dusts and vapours and minimise the risk of generating potentially

flammable conditions within the chamber.

The output from the mill is damp, not wet, which maintains the density differential between

metals and non-metals, enabling the use of air suction separation to draw off the light

fragmentiser residue fraction.

Unit 15

Melbourne Business Park

Model Farm Road

Cork

T: 021 434 5366

E: [email protected]

www.ocallaghanmoran.com

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In the ‘dry’ system water is not injected into the mill. In the absence of this dust suppression

an extraction fan is required to control dusts and vapours generated in the mill chamber.

Cyclone filters and wet scrubbers are used either on their own, or in combination to treat the

extracted air. The system allows for the efficient removal of the lighter non-metals from the

output using suction techniques.

The lack of air extraction on the ‘damp’ hammer mill means that there are no point emission

sources and that the emissions are diffuse. The air extraction on the ‘dry’ mill means that there

is a point emission source. Both the ‘damp’ and ‘dry’ systems include air extraction on the

downline separation process, which results in point emission sources.

Advantages/Disadvantages

The ‘damp’ system reduces the likelihood and severity of fires within the mill compared to the

‘dry’ system. It also produces less dust and fewer diffuse air emissions than the ‘dry’ system.

However, the addition of too much water can result in steamy conditions within the mill that

reduces visibility and increases the moisture content in the non-metals, thereby affecting the

separation efficiency of the output and increasing disposal costs.

The ‘dry’ system presents a higher risk of fire, but allows more efficient downline separation

of the metals and non-metals and the low moisture content in the non-metals means the disposal

costs can be lower than those from the ‘damp’ system.

GMC Fragmentiser

The fragmentiser at the Limerick facility has a ‘damp’ mill, which uses water injection to

suppress air emissions. The downline separation process is fitted with an air extraction system

and cyclone dust filter. It is only proposed to move the ‘damp’ hammer mill to the GMC site.

The output from the mill will not be processed at GMC, but will be returned to the Limerick

facility where it will be treated in the multi-stage separation process.

Nature & Characteristics of the Air Emissions

GMC does not have any data on the emissions from the hammer mill, as monitoring of any

such emissions is not a requirement of the Waste Permit. In the absence of plant specific data

GMC conducted a literature review to identify the likely composition and volumes of the

emissions to air from the mill. The data sources included:

Treatment in Shredders of Non Hazardous Metal Wastes prepared by FEAD

(European federation representing the waste management industry) (2014);

Guidelines on Best Available Techniques (BAT) and Provisional Guidance on Best

Environmental Practices relevant to Article 5 and Annex C of the Stockholm

Convention on Persistent Organic Pollutants: Shredder Plants for End of Life Vehicles

(Secretariat of the Stockholm Convention on Persistent Organic Pollutants October

2008);

Report on the Technical Working Group (TWG) Kick Off Meeting for the Review of

the Reference Document on Best Available Techniques for Waste Treatment (March

2014);

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BREF Style Report Metal Fragmentising Operations Industrial Emissions Directive

prepared on behalf of the British Metal Recycling Association (BMRA) (January

2013);

Interim Report ‘Study on Waste Related Issues of Newly Listed POPs and Candidate

POPs (ESWI 2010), commissioned by the European Commission.

JRC Reference Report on Monitoring of Emissions from IED Installations (Draft

Report (JRC IPPC Bureau 2013), commissioned by the European Commission.

The FEAD document states that the emissions to air from a shredder plant are likely to be dust,

Volatile Organic Compound (VOC), water vapour and occasionally smoke in the event of a

fire. The Guidelines of BAT and Provisional Guidance on Best Environmental Practices states

that shredder plants for treatment of end-of-life (ELV) vehicles have the potential to form and

release unintentional persistent organic pollutants that include polychlorinated dibenzo-p-

dioxins (PCDD) and dibenzofurans (PCDF) or polychlorinated biphenyls (PCB).

The TWG Report on the Kick Off Meeting states that a discussion took place on the pollutants

from installations shredding ELV (i.e. dust, total VOC, mercury, lead, dioxins and furans,

odour/mercaptans) and waste electrical and electronic equipment (WEEE) (same as for ELV

plus ammonia) and that the determination of these key pollutants would be further discussed

and fine-tuned during the next steps of the BREF review.

The Guidelines of BAT and Provisional Guidance on Best Environmental Practices contains

the results of a European dioxin inventory. This identified there was limited measured dibenzo-

p-dioxins and dibenzofurans data; however the results were generally, very low with

concentrations <0.01 ng I-TEQ/m³ in a plant in Germany.

A study in Belgium looked at potential sources of unintentionally released PCB and

PCDD/PCDF from three shredders processing ELV and WEEE. With the exception of one

monitoring event all of PCDD/PCDF concentrations, were <0.1 ng TEQ/Nm³.

The Guidelines conclude that at present there is insufficient evidence that the shredding of ELV

and WEEE causes the formation of new PCDD / PCDF or PCB. The data indicates that the

PCDD/PCDF and PCB released from shredder plants are associated with oils, dielectric fluids

and other materials contained in the ELV and WEEE, which are simply set free through this

mechanical process.

The FEAD document comments that the historically the primary sources of the VOC in the

shredder emissions were associated with the ELV fuels and fluids and refrigerant gases. The

implementation of the Priority Waste Stream Directives for ELV and WEEE, which require

specific depollution measures to extract fuels and oils from vehicles and refrigerant gases,

means that VOC are less likely to be emitted.

Volume of Emissions

The hammer mill that will be installed at GMC is a ‘damp’ system that does not have any air

extraction on the mill chamber. Effective dust suppression is achieved by water mist injection.

As there is neither an extraction fan, nor a flue stack on the mill the only emissions are diffuse

and the volume and emission rate is not known.

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The JRC Draft BREF on Monitoring of Emissions states that the quantification of diffuse

emissions is not easy and is, in general, labour and cost intensive. Measurement techniques are

available, but the measurement uncertainty can be relatively high and therefore the level of

confidence in the results can be low. . However, there are ongoing activities, in particular by

the Technical Committee CEN/TC 264, to define standardised methods for the measurement

of diffuse emissions.

2. Confirm the impact of these emissions to air on the environment including the emissions

from the CAT engine. It may be necessary in this regard to include the fragmentiser emission

in the air dispersion model. Take emissions of VOC and POPs including PCB into

consideration in your impact analysis.

The air dispersion model used to assess the impacts on air requires input parameters for the

concentrations of the individual pollutants, an efflux rate (m/s) and a mass emission

(Nm3/hour). As referred to above, this data is not available and therefore it is not possible to

include the diffuse emission from the hammer mill in the dispersion model.

However, while the quantitative assessment of diffuse emissions is difficult, the JRC Draft

BREF on Monitoring of Emissions states that a qualitative monitoring of diffuse emissions

may be performed by the analyses of wet and dry depositions downwind of the plant, which

then allows an estimation of the evolution of diffuse emissions over time (monthly or yearly

basis).

Dust deposition monitoring is carried out at the Clearcircle Limerick facility where the hammer

mill is currently located. The results of the monitoring carried out between 2010 and 2014 are

presented in Table 1, which also includes the dust depositional limit (350mg/m2/day) set in the

Waste Permit. Monitoring point D2 is the closest to the hammer mill. The results confirm that

the facility activities, including the operation of the hammer mill, are not a cause of any

significant dust emissions.

Table 1 Dust Deposition Data Limerick Facility

Period D1

(mg/m2/day)

D2

(mg/m2/day)

Limit

(mg/m2/day

2010 Q1 28.5 23.4 350

2010 Q2 106.2 84.8 350

2010 Q3 66.7 71.1 350

2011 Q1 65.4 31.4 350

2011 Q2 78.6 62.6 350

2011 Q3 81.1 17.5 350

2011 Q4 68.7 10.3 350

2012 Q1 112.9 1.9 350

2012 Q2 105.9 13.5 350

2012 Q3 88.4 227.9 350

2013 Q1 53.5 63.1 350

2013 Q2 48.7 11.6 350

2013 Q3 50.8 85.1 350

2014 Q1 56.8 93.4 350

2014 Q2 65.9 120.1 350

2014 Q3 63.8 107.3 350

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The available data on the concentrations of POPs, including PCB1 generated at ELV and WEEE

shredding plants indicates that these, along with VOC are not a significant issue.

3. Confirm if it proposed to collect air emissions from the fragmentiser.

As the hammer mill is a ‘damp’ system where the injection of water is the primary emission

control measure, it is not necessary to collect air emissions from the mill chamber.

a) If air emissions are collected confirm how it is proposed to treat the emissions and

why this method of treatment was chosen taking into consideration the waste stream intake

and the likely nature and characteristics of the air emissions.

Not applicable.

b) If air emissions are not collected confirm how it is proposed to mitigate against

these emissions having a negative impact on the environment.

Systems for dust suppression or dust collection are normally installed on fragmentisers for the

treatment of ELV and help to reduce potential emission of POPs1. The controls are applied in

both the mill and the downline separation process. In the mill, the controls include either water

injection, or air extraction and treatment (e.g. cyclones, venture scrubbers or bag filters). In the

separation process, the controls include air extraction and treatment (cyclones or bag filters).

The mill that will be installed at GMC is a ‘damp’ system where water spray is injected into

the chamber to supress dust. Downline separation will not be carried out at GMC, but will

remain at the Limerick facility.

The primary control measures to mitigate against the emissions from the mill from having a

negative impact on the environment are;

The injection of water mist into the mill that supresses dust generation.

The ELV de-pollution unit complies with the requirements of the Waste Management

(End-of Life) Regulations 2006 in relation to the removal and storage of all fuel, oils

and fluids. All liquids are removed from the vehicles and stored in integral sealed units

pending consignment from the site. The de-pollution measures are documented in

EHSP020 Procedure for the De-Pollution of End of Life Vehicles

WEE that could contain oils and dielectric fluids, for example transformers and

condensers, are only accepted from producers that have measures in place to ensure all

of the fluids are removed before delivery to the facility.

1 • Guidelines on Best Available Techniques (BAT) and Provisional Guidance on Best Environmental

Practices relevant to Article 5 and Annex C of the Stockholm Convention on Persistent Organic Pollutants:

Shredder Plants for End of Life Vehicles (Secretariat of the Stockholm Convention on Persistent Organic

Pollutants October 2008);

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As referred to in the response to Further Information Request No 2, the dust deposition

monitoring carried out at the Clearcircle Limerick facility, where the mill is currently located,

demonstrates the operation of the hammer mill is not a cause of significant dust emissions.

4. State how the new installation of a fragmentiser at Galway Metals Ltd will comply with

all relevant aspects of the Stockholm Convention and the National Implementation Plan for the

Stockholm Convention on Persistent Organic Pollutants.

The mill that that will be installed at GMC is currently in operation at the Clearcircle Limerick

facility. It is not proposed to install a replacement mill at the Limerick facility and the relocation

will not change the total number of fragmentiser mills (3 No.) currently operating in the

country.

It is a condition of the Waste Permit for the Limerick facility to complete an investigation to

ensure any diffuse emissions of POPs to atmosphere are adequately controlled and minimised.

The investigation must have regard to inter alia the Provisional Guidance on Best

Environmental Practices relevant to Article 5 and Annex C of the Stockholm Convention on

Persistent Organic Pollutants.

In 2011 Clearcircle Limerick conducted the investigation and the report, which describes how

the facility complied with the requirements of the Stockholm Convention, is in Attachment 1.

Compliance was achieved through a combination of the fragmentiser design, the Permit

conditions and the facility’s documented operational practices. There will be no change to

either the operation of the hammer mill, or the types of materials processed. The operational

procedures at GMC, which have been developed at a corporate level, will be amended to reflect

the relocation of the mill. In this context, the report findings apply equally to the GMC facility.

5. Confirm the proposed emission limit values for emissions to air from the fragmentiser.

As monitoring of the diffuse emissions from the hammer mill has not been carried out and the

data on emissions from similar plants is relatively limited, it is not possible to determine

emission limit values. The current BREF for Waste Treatment stipulates it is BAT to achieve

the following emission levels VOC 7-20mg/Nm3and PM to 2-20mg/Nm3. The FEAD

submission to the TWG states that a particulate emission level of < 40 mg/Nm3 can be achieved

in the majority of EU Member States; however the emission limit values that will be set in the

new BREF for Waste Treatment are not known.

GMC assumes that, pending the adoption of the revised BREF on Waste Treatment which will

include mandatory emission limit values, the Agency will set the same emission limit values

for all of the hammer mills currently operating in the country. These will be in accordance with

Article 15 (3) of the IED, taking into consideration Recital 15 of the Preamble, which states it

is important to provide sufficient flexibility to competent authorities to set emission limit

values, which ensure that under normal operating conditions the emissions do not exceed the

emission levels associated with the best available techniques.

In this context GMC will ensure that any additional mitigation measures to achieve the

emission limit values set in the Licence will be implemented by the date specified by the

Agency.

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6. Confirm how it is proposed to maintain the emissions to air from the fragmentiser below

the proposed emission limit values taking into consideration the age of the associated plant

The hammer mill is a ‘damp’ system where water is injected into the mill to supress dust. In

this context the effectiveness of the control measures is not related to the age of the plant, but

to the efficiency of the water injection system. The mill is subject to a regular preventative

inspection and maintenance programme, which includes an assessment of the water injection

system.

In addition to the above please also provide an updated non-technical summary to reflect the

information provided in your reply.

An updated Non-Technical Summary is in Attachment 2.

Yours Sincerely,

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ATTACHMENT 1

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C:\09\048_Greenstar\ECRL\0482701.Doc February 2010 (MW/MG)

PERSISTENT ORGANIC POLLUTANTS

ASSESSMENT

HEGARTY METAL PROCESSORS (INTERNATIONAL) Ltd

BALLYSIMON ROAD

LIMERICK

WFP-LKC-11-001-01

Prepared For: -

Hegarty Metals Processors (International) Ltd

Ballysimon Road,

Limerick

Prepared By: -

O’ Callaghan Moran & Associates,

Granary House,

Rutland Street,

Cork

December 2011

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11\196_One51\17_POPse Emission Ballysimon Road\1961701.Doc December 2011 (JOC/MS) i

TABLE OF CONTENTS

PAGE

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

1.1 REGULATORY BACKGROUND ...................................................................................... 1

2. POP EMISSIONS AND CONTROLS: BEST PRACTICE ......................................... 3

2.1 POTENTIAL SOURCES OF POPS ................................................................................... 3

2.2 BEST PRACTICE ........................................................................................................... 3

3. HEGARTY METALS OPERATIONS .......................................................................... 5

3.1 POTENTIAL SOURCES OF POP EMISSIONS TO ATMOSPHERE ........................................ 5

3.2 EXISTING CONTROL MEASURES .................................................................................. 5

4. CONCLUSIONS............................................................................................................... 7

Appendix 1 Annex IV of EC Regulation 850/2004

Appendix 2 Draft Guidance on Best Environmental Practice

Appendix 3 Hegarty Metals ELV De-pollution Procedure

Appendix 4 WEEE Decontamination Procedures

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11\196_One51\17_POPse Emission Ballysimon Road\1961701.Doc December 2011 (JOC/MS) 1 of 7

1. INTRODUCTION

The Hegarty Metal Processors (International) Limited (Hegarty Metals) Ballysimon Road

facility operates under a Waste Permit (WFP-LKC-11-001-01) granted by Limerick County

Council.

Condition 7.6 of the Permit requires an investigation to ensure any potential fugitive

emissions of persistent organic pollutants to atmosphere are adequately controlled and

minimised. The investigation shall have regard to S.I. No. 235 of 2010 and the Revised Draft

Guidelines on Best Available Techniques (BAT) and Provisional Guidance on Best

Environmental Practices relevant to Article 5 and Annex C of the Stockholm Convention on

Persistent Organic Pollutants.

1.1 Regulatory Background

S.I. No. 253 gives statutory effect to EC Regulation No. 850/2004, as amended, on persistent

organic pollutants (POPs). POPs are chemical substances that persist in the environment, bio

accumulate through the food chain, and pose a risk of causing adverse effects to human health

and the environment. They include pesticides (such as DDT), industrial chemicals (such as

polychlorinated biphenyls and bromodiphenyls) and unintentional by-products of industrial

processes (such as dioxins and furans).

EC Regulation 850/2004 prohibits the production, placing on the market and use of particular

POPs, and restricts the production, placing on the market and use of other POPs. The aim of

the Regulation is to ensure the coherent and effective implementation of the 2001 Stockholm

Convention on POPs.

S.I. No 253 designates the Environmental Protection Agency (Agency) as the competent

authority for the purposes of EC Regulation 850/2004. The Agency is obliged to draw up and

maintain POPs release inventories and prepare national action and implementation plans to

achieve the objectives of the Stockholm Convention.

Article 5 of the EC Regulation imposes conditions on the holders of any stockpiles of the

POPs listed in Annex IV of the Regulation. The holder must manage the stockpile as waste

and, in accordance with Article 7, put in place measures to avoid cross contamination and

ensure that the substances are recovered /disposed of without undue delay.

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The POPs listed in Annex IV of Regulation, a copy of which is in Appendix 1, include

pesticides, polychlorinated biphenyls (PCB); Polychlorinated dibenzo-p-dioxins and

dibenzofurans (PCDD/PCDF), and Bromodiphenyl ethers (BDE).

Annex C of the Stockholm Convention identifies the shredding of end-of-life vehicles (ELV)

and certain types of waste electrical and electronic equipment as an activity with the potential

to form and release unintentional POPs.

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2. POP EMISSIONS AND CONTROLS: BEST PRACTICE

2.1 Potential Sources of POPS

Section VI K of the Draft Guidelines on Best Available Techniques and Provisional Guidance

on Best Environmental Practices relevant to Article 5 and Annex C of the Stockholm

Convention on POPs (Draft BAT Guidance) discusses POP emissions from the shredding of

ELVs and electrical equipment. A copy of Section VI K is in Appendix 2.

The Draft BAT Guidance states that, at present, there is insufficient evidence to conclude that

the shredding of ELVs, household electrical equipment and other electrical equipment

produces new PCDD/PCDF and PCBs. However, shredding has the potential to release

unintentional POPS, comprising PCDD/PDCF and PCBs contained in oils, dielectric fluids

and other materials in the vehicles or consumer goods, which are simply set free through the

mechanical process.

In 2009, the European Commission conducted a studya of a range of POPs, including

polymers of BDE to provide guidance on the best options for their elimination or restriction.

The study identified that two BDE polymers (C-PentaBDE and C-Octa BDE) were likely to

be present in shredder residue.

C-PentaBDE is used in the manufacture of flexible polyurethane (PUR) foams, which are

mainly used for the production of automotive and upholstery applications (e.g. automotive

seating, head rests, sofas, mattresses etc). C-OctaBDE is used in the manufacture of

acrylonitrilebutadiene-styrene (ABS) polymers, which were mainly used for housings/casings

of electrical and electronic equipment, typically office equipment and business machines.

2.2 Best Practice

The Draft BAT Guidance (Appendix 2) recommends that it is best environmental practice to

strengthen the responsibility of the operators of shredders to ensure that hazardous

components and fluids in the incoming wastes, especially electrical devices, such as

transformers and condensers, are identified and removed before the wastes are shredded.

The minimum technical requirement for treatment facilities that operate shredders is that they

must be constructed to prevent the contamination of soil, water and air. This requires the

provision of appropriate storage facilities, including impermeable surfaces with spillage

a Interim Report: Study on Waste Related Issues of newly Listed POPs and candidate POPs; August 2010

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collection for dismantled spare parts, including for oil-contaminated spare parts, appropriate

containers for the storage of batteries, filters and PCB/PCT-containing condensers and

appropriate storage tanks for other fluids.

The primary control measure to minimise the risk of POP emissions is the removal of fluids,

like brake fluid, petrol, steering fluid, motor oil, coolants and transmission fluid from the ELV

or other devices before shredding. This is especially applicable in the case of fluids

containing PCBs, which should be identified and removed from any device to be shredded,

with particular attention given to transformers and condensers.

The control measures should include:

The removal of batteries and liquefied gas tanks;

The removal or neutralization of potential explosive components, (e.g., air bags);

The removal and separate collection and storage of fuel, motor oil and oil from other

components;

The removal of catalysts;

The removal of tyres and large plastic components (such as bumpers, dashboards,

fluid containers, etc.), if these materials are not segregated in the shredding process in

such a way that they can be effectively recycled as materials.

Although not referred to in the Draft BAT Guidance recommendations, it is considered best

practice to minimise the risk of accidental fire in stockpiled shredded residues, which could

result in the formation and release of POPs to atmosphere.

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3. HEGARTY METALS OPERATIONS

3.1 Potential Sources of POP Emissions to Atmosphere

The facility accepts and processes metals ELVs and de-polluted transformers and switch gear

under contracts with the ESB and others. The processing involves the initial manual

separation of the metals into different types and the de-pollution of vehicles, followed by

shredding, segregating and sizing. The shredder produces a ferrous metal stream consisting

of small pieces of steel, a non ferrous metal stream comprising 95% aluminium 3% copper

and 2% non metallic residuals and a shredder residue waste stream that contains non metallic

materials (plastic, rubber, fabric, foam and wood).

The shredding process is similar to that described in the Draft BAT Guidance. Therefore,

while the facility is not a source of new POPs (PCDD/PCDF and PCB), there is the potential

for the release of unintentional POPS to atmosphere during the processing of the ELVs and

electrical equipment.

The residue can include fragments of plastics containing BDE. However, the residue

stockpiles are not a source of emissions of these substances to atmosphere. The Agency, in its

role of preparing an inventory of POPs in the country, has included the Hegarty Metals

facility in a nationwide study of BDE levels in shredder residues. The study involved the

Agency collecting and analysing representative samples of the residue. It is expected that the

results will be included in the final report to be published by the Agency.

3.2 Existing Control Measures

The Waste Permit specifies the manner in which the facility should be constructed and

operated to prevent the contamination of soil, water and air. The Permit requires the

provision of appropriate storage arrangement, including impermeable surfaces with drainage

directed to oil interceptors, bunds and storage receptacles for all the materials and wastes

accepted and handled at the facility.

The ELV de-pollution unit complies with the requirements of the Waste Management (End-of

Life) Regulations 2006 in relation to the removal and storage of all fuel, oils and fluids. All

liquids are removed from the vehicles and stored in integral sealed units pending consignment

from the site. The de-pollution measures are documented in EHSP020 Procedure for the De-

Pollution of End of Life Vehicles, which is in Appendix 3.

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Electrical waste that could contain oils and dielectric fluids, for example transformers and

condensers, are only accepted from producers that have measures in place to ensure all of the

fluids are removed before delivery to the Hegarty Metals facility. A copy of the procedure

that documents the cleaning of the electrical equipment is in Appendix 4.

Hegarty Metals has put in place measures to minimise the risk of accidental fires and to

ensure a rapid and effective response if a fire does occur. These measures are described in the

report on the Firewater Retention Risk Assessment, prepared and submitted to Limerick City

Council in September 2010.

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4. CONCLUSIONS

Shredding of the ELV and certain types of WEEE is a potential source of the release to

atmosphere of unintentional of POPS (PCDD/PCDF and PCB). The shredded residue may

contain other POPs (BDE) but the stockpiled residue is not a source of emissions to the

atmosphere.

The conditions in the Waste Permit regarding the site design and operation, which are

intended to ensure that wastes are handled and stored in a way that minimises the risk to soil

water and air, comply with the technical requirements of the Draft BAT Guidance.

The existing control measures for the removal of fluids that have the potential to contain

POPs from the ELVs and WEEE before these are shredded, complies with the primary control

measures’ specified in the Draft BAT Guidance.

Hegarty Metals have put in place measures to minimise the risk of accidental fires at the

facility, including the shredder residue stockpiles, and ensure a rapid and effective response to

limit the duration of any fire.

OCM considers that the control measures already employed by Hegarty Metals comply with

the best practice recommendations set out in the Draft BAT Guidance to control and minimise

the emission of POPs to the atmosphere.

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11\196_One51\17_POPse Emission Ballysimon Road\1961701.Doc December 2011 (JOC/MS)

APPENDIX 1

Annex IV of EC Regulation 850/2004

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REGULATIONS

COMMISSION REGULATION (EU) No 756/2010

of 24 August 2010

amending Regulation (EC) No 850/2004 of the European Parliament and of the Council on persistent organic pollutants as regards Annexes IV and V

(Text with EEA relevance)

THE EUROPEAN COMMISSION,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Regulation (EC) No 850/2004 of the European Parliament and of the Council of 29 April 2004 on persistent organic pollutants and amending Directive 79/117/EEC ( 1 ), and in particular Article 7(4)(a), Article 7(5) and Article 14 thereof,

Whereas:

(1) Regulation (EC) No 850/2004 implements in the law of the Union the commitments set out in the Stockholm Convention on Persistent Organic Pollutants (hereinafter ‘the Convention’) approved by Council Decision 2006/507/EC of 14 October 2004 concerning the conclusion, on behalf of the European Community, of the Stockholm Convention on Persistent Organic Pollutants ( 2 ) and in the Protocol to the 1979 Convention on Long-range Transboundary Air Pollution on Persistent Organic Pollutants (hereinafter ‘the Protocol’) approved by Council Decision 2004/259/EC of 19 February 2004 concerning the conclusion, on behalf of the European Community, of the Protocol to the 1979 Convention on Long-range Transboundary Air Pollution on Persistent Organic Pollutants ( 3 ).

(2) Following nominations of substances received from the European Union and its Member States, Norway and Mexico, the Persistent Organic Pollutants Review Committee established under the Convention has concluded its work on the nine proposed substances, which have been found to meet the criteria of the Convention. At the fourth meeting of the Conference of the Parties to the Convention from 4 to 8 May

2009 (hereinafter ‘COP4’) it was agreed to add all nine substances to the Annexes to the Convention.

(3) Annexes IV and V to Regulation (EC) No 850/2004 should be amended in order to take into account the new substances that have been listed during the COP4.

(4) The COP4 decided to list chlordecone, hexabromobiphenyl and hexachlorocyclohexanes, including lindane, in Annex A (elimination) to the Convention. Those substances are included in Annexes IV and V to Regulation (EC) No 850/2004 since they were listed by the Protocol.

(5) The COP4 decided to list pentachlorobenzene in Annex A (elimination) to the Convention. Therefore, pentachlorobenzene should be listed in Annexes IV and V to Regulation (EC) No 850/2004, indicating the corresponding maximum concentration limits, which have been set applying the methodology used for establishing the limit values for persistent organic pollutants (hereinafter ‘POPs’) in Council Regulation (EC) No 1195/2006 of 18 July 2006 amending Annex IV to Regulation (EC) No 850/2004 of the European Parliament and of the Council on persistent organic pollutants ( 4 ) and in Council Regulation (EC) No 172/2007 of 16 February 2007 amending Annex V to Regulation (EC) No 850/2004 of the European Parliament and of the Council on persistent organic pollutants ( 5 ). Those provisional maximum concentration limits should be reviewed in view of the results of a study on the implementation of the waste-related provisions of Regulation (EC) No 850/2004, to be conducted on behalf of the Commission.

(6) The COP4 decided to list Perfluorooctane sulfonic acid and its derivatives (hereinafter ‘PFOS’) in Annex B (restriction) to the Convention, with some exemptions for specific applications. The use of PFOS is currently allowed for some specific applications. Because of the lifespan of articles containing PFOS, these

EN L 223/20 Official Journal of the European Union 25.8.2010

( 1 ) OJ L 158, 30.4.2004, p. 7. ( 2 ) OJ L 209, 31.7.2006, p. 1. ( 3 ) OJ L 81, 19.3.2004, p. 35.

( 4 ) OJ L 217, 8.8.2006, p. 1. ( 5 ) OJ L 55, 23.2.2007, p. 1.

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articles will continue to enter the waste stream for some years, although in decreasing volumes. There may be practical difficulties of identifying certain materials containing PFOS within a given waste stream. Data on quantities and concentrations of PFOS in articles and wastes is currently still not sufficient. Extending the obligation in Regulation (EC) No 850/2004 to destroy or irreversibly transform the POP content to PFOS for waste exceeding the concentration limits of Annex IV could have impacts on existing recycling schemes, which may challenge another environmental priority of ensuring the sustainable use of resources. In view of this, PFOS is listed in Annexes IV and V without an indication of the concentration limits.

(7) The COP4 decided to list tetrabromodiphenyl ether, pentabromodiphenyl ether, hexabromodiphenyl ether and heptabromodiphenyl ether, hereinafter ‘polybrominated diphenyl ethers’, in Annex A (elimination) to the Convention. Placing on the market and use of pentabromodiphenyl ether and octabromodiphenyl ether have been restricted in the Union by virtue of Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency ( 1 ), with a maximum concentration limit of 0,1 % by weight. Pentabromodiphenyl ether, hexabromodiphenyl ether, heptabromodiphenyl ether and tetrabromodiphenyl ether are not currently being placed on the market in the Union as they are restricted by Commission Regulation (EC) No 552/2009 of 22 June 2009 amending Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards Annex XVII ( 2 ) and Directive 2002/95/EC of the European Parliament and of the Council of 27 January 2003 on the restriction of the use of certain hazardous substances in electrical and electronic equipment ( 3 ). However, because of the lifespan of products containing those polybrominated diphenyl ethers, end-of-life products containing these substances will continue to enter the waste stream for some years. Taking into account the practical difficulties of identifying materials containing polybrominated diphenyl ethers within a mixed waste fraction and the current lack of comprehensive scientific data on quantities and concentrations of polybrominated diphenyl ethers in articles and wastes, extending the obligation to destroy or irreversibly transform the POP content to these new substances for waste exceeding the concentration limits of Annex IV could endanger existing recycling schemes and thus hinder the sustainable use of resources. This problem was acknowledged by the COP4 and special exemptions were agreed for continued recycling of wastes that contain listed polybrominated diphenyl ethers even if

this may lead to recycling of the POPs. Therefore, those exceptions should be reflected in Regulation (EC) No 850/2004.

(8) Uniform maximum concentration limits are required in the Union in order to avoid a distortion of the internal market. Provisional maximum concentration limits have been set for pentachlorobenzene in Annexes IV and V to Regulation (EC) No 850/2004 based on available data and under application of the precautionary principle.

(9) In view of the lack of comprehensive scientific information on quantities and concentrations in articles and wastes, as well as exposure scenarios, at this stage, no maximum concentration limits can be established for PFOS and polybrominated diphenyl ethers in Annexes IV and V to Regulation (EC) No 850/2004. Subject to further information becoming available and a review by the Commission, maximum concentration limits for the nine POPs will be proposed, taking into account the objectives of the POP Regulation.

(10) In accordance with Article 22 of the Convention, the amendments to Annexes A, B and C thereto enter into force one year from the date of communication by the depositary of an amendment, which will fall on 26 August 2010. Consequently and for reasons of coherence, this Regulation should apply from the same date.

(11) The measures provided for in this Regulation are in accordance with the opinion of the Committee established by Council Directive 75/442/EEC ( 4 ). This Regulation should enter into force as a matter of urgency,

HAS ADOPTED THIS REGULATION:

Article 1

1. Annex IV to Regulation (EC) No 850/2004 is replaced by Annex I to this Regulation.

2. Annex V to Regulation (EC) No 850/2004 is amended in accordance with Annex II to this Regulation.

EN 25.8.2010 Official Journal of the European Union L 223/21

( 1 ) OJ L 396, 30.12.2006, p. 1. ( 2 ) OJ L 164, 26.6.2009, p. 7. ( 3 ) OJ L 37, 13.2.2003, p. 19. ( 4 ) OJ L 194, 25.7.1975, p. 39.

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Article 2

This Regulation shall enter into force on the day of its publication in the Official Journal of the European Union.

It shall apply from 26 August 2010.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels, 24 August 2010.

For the Commission The President

José Manuel BARROSO


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ANNEX I

‘ANNEX IV

List of substances subject to waste management provisions set out in Article 7

Substance CAS No EC No Concentration limit referred to in Article 7(4)(a)

Tetrabromodiphenyl ether C 12 H 6 Br 4 O

Pentabromodiphenyl ether C 12 H 5 Br 5 O

Hexabromodiphenyl ether C 12 H 4 Br 6 O

Heptabromodiphenyl ether C 12 H 3 Br 7 O

Perfluorooctane sulfonic acid and its derivatives (PFOS) C 8 F 17 SO 2 X (X = OH, Metal salt (O-M + ), halide, amide, and other derivatives including polymers)

Polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/PCDF)

15 g/kg ( 1 )

DDT (1,1,1-trichloro-2,2-bis (4-chlorophenyl)ethane)

50-29-3 200-024-3 50 mg/kg

Chlordane 57-74-9 200-349-0 50 mg/kg

Hexachlorocyclohexanes, including lindane

58-89-9 210-168-9 50 mg/kg

319-84-6 200-401-2

319-85-7 206-270-8

608-73-1 206-271-3

Dieldrin 60-57-1 200-484-5 50 mg/kg

Endrin 72-20-8 200-775-7 50 mg/kg

Heptachlor 76-44-8 200-962-3 50 mg/kg

Hexachlorobenzene 118-74-1 200-273-9 50 mg/kg

Chlordecone 143-50-0 205-601-3 50 mg/kg

Aldrin 309-00-2 206-215-8 50 mg/kg

Pentachlorobenzene 608-93-5 210-172-5 50 mg/kg

Polychlorinated Biphenyls (PCB) 1336-36-3 and others 215-648-1 50 mg/kg ( 2 )

Mirex 2385-85-5 219-196-6 50 mg/kg

Toxaphene 8001-35-2 232-283-3 50 mg/kg


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Substance CAS No EC No Concentration limit referred to in Article 7(4)(a)

Hexabromobiphenyl 36355-01-8 252-994-2 50 mg/kg

( 1 ) The limit is calculated as PCDD and PCDF according to the following toxic equivalency factors (TEFs):

PCDD TEF

2,3,7,8-TeCDD 1

1,2,3,7,8-PeCDD 1

1,2,3,4,7,8-HxCDD 0,1

1,2,3,6,7,8-HxCDD 0,1

1,2,3,7,8,9-HxCDD 0,1

1,2,3,4,6,7,8-HpCDD 0,01

OCDD 0,0003

PCDF TEF

2,3,7,8-TeCDF 0,1

1,2,3,7,8-PeCDF 0,03

2,3,4,7,8-PeCDF 0,3

1,2,3,4,7,8-HxCDF 0,1

PCDD TEF

1,2,3,6,7,8-HxCDF 0,1

1,2,3,7,8,9-HxCDF 0,1

2,3,4,6,7,8-HxCDF 0,1

1,2,3,4,6,7,8-HpCDF 0,01

1,2,3,4,7,8,9-HpCDF 0,01

OCDF 0,0003

( 2 ) Where applicable, the calculation method laid down in European standards EN 12766-1 and EN 12766-2 shall be applied.’


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ANNEX II

In Annex V, Part 2, to Regulation (EC) No 850/2004 the table is replaced by the following:

‘ Wastes as classified in Commission Decision 2000/532/EC

Maximum concentration limits of substances listed in Annex IV ( 1 ) Operation

10 WASTES FROM THERMAL PROCESSES

Aldrin: 5 000 mg/kg;

Chlordane: 5 000 mg/kg;

Chlordecone:

5 000 mg/kg;

DDT (1,1,1-trichloro-2,2-bis (4-chlorophenyl) ethane): 5 000 mg/kg;

Dieldrin: 5 000 mg/kg;

Endrin: 5 000 mg/kg;

Heptabromodiphenyl ether (C 12 H 3 Br 7 O);

Heptachlor: 5 000 mg/kg;

Hexabromobiphenyl: 5 000 mg/kg;

Hexabromodiphenyl ether (C 12 H 4 Br 6 O);

Hexachlorobenzene: 5 000 mg/kg;

Hexachlorocyclohexanes, including lindane:

5 000 mg/kg;

Mirex: 5 000 mg/kg;

Pentabromodiphenyl ether (C 12 H 5 Br 5 O);

Pentachlorobenzene: 5 000 mg/kg;

Perfluorooctane sulfonic acid and its derivatives (PFOS)

(C 8 F 17 SO 2 X)

(X = OH, Metal salt (O-M + ), halide, amide, and other derivatives including polymers);

Polychlorinated Biphenyls (PCB) ( 5 ): 50 mg/kg;

Polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/PCDF) ( 6 ): 5 mg/kg;

Tetrabromodiphenyl ether (C 12 H 6 Br 4 O);

Toxaphene: 5 000 mg/kg;

Permanent storage shall be allowed only when all the following conditions are met:

1. the storage takes place in one of the following locations:

— safe, deep, underground, hard rock formations,

— salt mines,

— a landfill site for hazardous waste, provided that the waste is solidified or partly stabilised where technically feasible as required for classification of the waste in Subchapter 1903 of Decision 2000/532/EC;

2. the provisions of Council Directive 1999/31/EC ( 3 ) and Council Decision 2003/33/EC ( 4 ) were respected;

3. it has been demonstrated that the selected operation is environmentally preferable.

10 01 Wastes from power stations and other combustion plants (except 19)

10 01 14 * ( 2 ) Bottom ash, slag and boiler dust from co- incineration containing dangerous substances

10 01 16 * Fly ash from co- incineration containing dangerous substances

10 02 Wastes from the iron and steel industry

10 02 07 * Solid wastes from gas treatment containing dangerous substances

10 03 Wastes from aluminium thermal metallurgy

10 03 04 * Primary production slag

10 03 08 * Salt slag from secondary production

10 03 09 * Black dross from secondary production

10 03 19 * Flue-gas dust containing dangerous substances

10 03 21 * Other particulates and dust (including ball mill dust) containing dangerous substances

10 03 29 * Wastes from treatment of salt slag and black dross containing dangerous substances

10 04 Wastes from lead thermal metallurgy

10 04 01 * Slag from primary and secondary production


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Wastes as classified in Commission Decision 2000/532/EC


10 04 02 * Dross and skimming from primary and secondary production

10 04 04 * Flue-gas dust

10 04 05 * Other particulates and dust

10 04 06 * Solid wastes from gas treatment

10 05 Wastes from zinc thermal metallurgy


10 05 05 * Solid waste from gas treatment

10 06 Wastes from copper thermal metallurgy



10 08 Wastes from other non- ferrous thermal metallurgy

10 08 08 * Salt slag from primary and secondary production


10 09 Wastes from casting of ferrous pieces


16 WASTES NOT OTHERWISE SPECIFIED IN THE LIST

16 11 Waste linings and refractories

16 11 01 * Carbon-based linings and refractories from metallurgical processes containing dangerous substances

16 11 03 * Other linings and refractories from metallurgical processes containing dangerous substances


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17 CONSTRUCTION AND DEMOLITION WASTES (INCLUDING EXCAVATED SOIL FROM CONTAMINATED SITES)

17 01 Concrete, bricks, tiles and ceramics

17 01 06 * Mixtures of, or separate fractions of concrete, bricks, tiles and ceramics containing dangerous substances

17 05 Soil including excavated soil from contaminated sites, stones and dredging spoil

17 05 03 * Inorganic fraction of soil and stones containing dangerous substances

17 09 Other construction and demolition wastes

17 09 02 * Construction and demolition wastes containing PCB, excluding PCB containing equipment

17 09 03 * Other construction and demolition wastes containing dangerous substances

19 WASTES FROM WASTE MANAGEMENT FACILITIES, OFF-SITE WASTE WATER TREATMENT PLANTS AND THE PREPARATION OF WATER INTENDED FOR HUMAN CONSUMPTION AND WATER FROM INDUSTRIAL USE

19 01 Wastes from incineration or pyrolysis of waste


19 01 11 * Bottom ash and slag containing dangerous substances

19 01 13 * Fly ash containing dangerous substances

19 01 15 * Boiler dust containing dangerous substances


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19 04 Vitrified waste and waste from vitrification

19 04 02 * Fly ash and other flue-gas treatment wastes

19 04 03 * Non-vitrified solid phase

( 1 ) These limits apply exclusively to a landfill site for hazardous waste and do not apply to permanent underground storage facilities for hazardous wastes, including salt mines.

( 2 ) Any waste marked with an asterisk * is considered as hazardous waste pursuant to Directive 91/689/EEC and subject to the provisions of that Directive.

( 3 ) OJ L 182, 16.7.1999, p. 1. ( 4 ) OJ L 11, 16.1.2003, p. 27. ( 5 ) The calculation method laid down in European standards EN 12766-1 and EN 12766-2 shall apply. ( 6 ) The limit is calculated as PCDD and PCDF according to the following toxic equivalency factors (TEFs):

PCDD TEF

2,3,7,8-TeCDD 1

1,2,3,7,8-PeCDD 1

1,2,3,4,7,8-HxCDD 0,1

1,2,3,6,7,8-HxCDD 0,1

1,2,3,7,8,9-HxCDD 0,1

1,2,3,4,6,7,8-HpCDD 0,01

OCDD 0,0003

PCDF TEF

2,3,7,8-TeCDF 0,1

1,2,3,7,8-PeCDF 0,03

2,3,4,7,8-PeCDF 0,3

1,2,3,4,7,8-HxCDF 0,1

1,2,3,6,7,8-HxCDF 0,1

1,2,3,7,8,9-HxCDF 0,1

PCDD TEF

2,3,4,6,7,8-HxCDF 0,1

1,2,3,4,6,7,8-HpCDF 0,01

1,2,3,4,7,8,9-HpCDF 0,01

OCDF 0,0003’


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APPENDIX 2

Draft Guidance on Best Environmental Practice

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Section VI

Guidance/guidelines by source category:

Source categories in Part III of Annex C

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Part III Source category (k):

Shredder plants for the treatment of end-of-life

vehicles

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Section VI.K. Shredder plants for the treatment of end-of-life vehicles

Guidelines on BAT and Guidance on BEP i December 2006

Table of contents

List of tables .............................................................................................................................. .......... i

List of illustrations .............................................................................................................................. . i

VI.K Shredder plants for the treatment of end-of-life vehicles ........................................................ 1

Preamble .............................................................................................................................. .... 1

1. Process description .......................................................................................................... 1

3. Composition of shredder waste ....................................................................................... 3

4. Emission concentrations from shredder plants .............................................................. 4

5. Recommended measures ................................................................................................. 5

6. Minimum technical requirements for treatment .............................................................. 5

7. Primary measures ............................................................................................................ 5

8. Secondary Measures ....................................................................................................... 5

References............................................................................................................................... . 7

Other Sources ........................................................................................................................... 7

List of tables

Table 1 Organics in shredder residues defined in the original reference as “fuel fractions” and

“disposal fractions ........................................................................................................... ................ 3

Table 2 Dibenzo-p-dioxins and dibenzofurans emissions in German shredder plants ....................... 4

Table 3 Measured data for emission concentrations from shredder plants ......................................... 4

List of illustrations

Figure 1 Overview of the shredder process ..................................................................................... ....... 2

Figure 2 Composition of shredder waste ........................................................................................ ........ 2

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Guidelines on BAT and Guidance on BEP 1 December 2006

VI.K Shredder plants for the treatment of end-of-life vehicles

Summary

Shredder plants for treatment of end-of-life vehicles are lbisted in Annex C of the Stockholm

Convention as a source that has the potential to form and release chemicals listed in Annex C.

Shredders are large-scale machines equipped inside with one or more anvils or breaker bars and

lined with alloy steel wear plates. An electric motor drives the rotor with the free-swinging alloy

steel hammers. Beneath the shredder is a vibratory pan, which receives the shredded material

discharged through the grates. Typically a ferrous metal stream is produced, which is relatively

clean and consists of small (50 mm) pieces of steel and a “fluff” stream, which contains the

fragments of non-ferrous metals and other materials that entered the shredder (also known as

fragmentizer).

Very few data of stack emission measurements at shredder plants are available. However, the

results of some studies have shown levels of dioxin compounds greater than 0.1 ng I-TEQ/m3. At

present there is not sufficient evidence that in the (mechanical) shredding of vehicles, household

electrical equipment or other electrical appliances new formation occurs of polychlorinated

dibenzo-p-dioxins (PCDD), polychlorinated dibenzofurans (PCDF) or polychlorinated biphenyls

(PCB). The data available indicate that the PCDD/PCDF and PCB released from shredder plants

are from industrial, intentional production and have been introduced with oils, dielectric fluids, and

other materials contained in these vehicles or consumer goods and which are simply set free

through this mechanical process.

In any case, measures to prevent accidental fires (w hich could result in the formation of chemicals

listed in Annex C) should be in place at shredder pl ants. Shredder light fluff consists of flammable

plastic films and fibrous dust, which forces a careful plant operation for the prevention of

accidental fire. Systems for dust suppression (e.g. wet shredding) or dust collection (e.g. cyclones,

venture scrubbers or baghouse) are normally insta lled on shredder plants for the treatment of end-

of-life vehicles. Dust suppression or collection systems would help to reduce potential emission of

persistent organic pollutants. To improve emission control of the dust, fine dry residues should be

stored in such a way that dispersion is minimized. Other sources of dioxin precursors that may

result in the formation of PCDD/PCDF when burnt include PCB-containing condensers, PCB- or

chlorobenzene-contaminated waste oils or tex tiles, and polymers containing brominated flame

retardants (formation of polybrominated dibenzo -p-dioxins (PBDD) and polybrominated

dibenzofurans (PBDF) as contaminants).

Preamble

Shredder plants for the treatment of end-of-life vehicles are listed in Annex C of the Convention as a

source that has the potential to form and release unintentional persistent organic pollutants. At

present, however, there is insufficient evidence that, in this mechanical process, dibenzo-p-dioxins

and dibenzofurans or polychlorinated biphenyls are newly formed. The data available indicate that

the dibenzo-p-dioxins and dibenzofurans and polychlorinated biphenyls released from shredder plants

are from industrial/intentional polychlorinated bipheny l production and have been introduced with the

oils and dielectric fluids, etc., contained in the vehicles or more probably in consumer goods. The

shredders simply free these contaminants.

1. Process description

End-of-life-vehicles are processed through shredders. The practice is to shred them along with other

end-of-life metal products (such as bicycles, offi ce furniture, vending machines and so-called white

goods, such as household devices). In the plant, a high-performance-hammer mill produces sized

pieces of ferrous scrap of a high physical and chemical purity. The ferrous scrap is sought after by

steel makers and other secondary metal producers. An overview of the process is shown in figure 1.

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SECTION VI. Guidance/guidelines by source category: Part III of Annex C


Figure 1 Overview of the shredder process

Shredder plant for the treatment of ELV

ELV

Other electronic equipment

-Vending machine-White goods-Household

device etc. (PCDD/PCDF, PCB, BFR)

Small size ferrous metal

Small size non-ferrous metal

Lead and other recycablematerials

Shredder waste(PCDD/PCDF,PCB, BFR)

Dismantle

Shredding in Hammer mill

Dust-collection

Magnetic and/or Size separation

Shredding process

Recycle (sec.Metal smelters)

Disposal- landfill- incineration

Final disposal and/or Recycle

Emission(PCDD/PCDF,

PCB, BFR)

Effluent(PCDD/PCDF,

PCB, BFR)

Input Output

Shredder plant

Many components of vehicles and other electrical de vices are made of non-ferrous materials, such as

copper, aluminum and zinc. In the shredding process, magnetic separation is used to remove the

magnetic ferrous fraction from other materials. The non-ferrous metals, such as copper and aluminum,

are normally sorted out at a later stage. The remainder is the so-called shredder waste and is estimated

at between 25% and 35% of the weight of end-of- life vehicles (Environment Australia, Department of

the Environment and Heritage, 2002). Shredder waste consists of glass, fibre, rubber, automobile

liquids, plastics and dirt. Figure 2 illustrates the composition of shredder waste.

Figure 2 Composition of shredder waste

Source: Environment Australia, Department of the Environment and Heritage (2002)

End of life vehicles

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3. Composition of shredder waste

The composition of shredder fluff will vary consider ably from batch to batch and shredder to shredder

– due to the different mixes of raw materials being processed and the differing levels of pre-

processing and inspection by shredder operators. It shoul d be noted that shredder fluff is likely to vary

significantly between shredders due to varying requirements under state and territory licensing

conditions and the changes in those conditions over time.

An investigation from Sweden (Börjeson, L.; Löfvenius, G.; Hjelt, M.; Johansson, S.; Marklund, S.,

2000) shows that levels of PCDD/PCDF per gram in dry samples of shredder fluff are low in all the

fractions (table 1). This conforms to expectations th at levels of dioxins and furans should generally be

very low, because dibenzo-p-dioxins and dibenzofurans is neither used nor deliberately produced for

any technical product or substance.

Unlike the dibenzo-p-dioxins and dibenzofurans levels, however, the levels of polychlorinated

biphenyls were high, especially in fractions originating from industrial waste or waste white goods.

The presence of polychlorinated biphenyls in whit e goods contributes most heavily to polychlorinated

biphenyls in the shredder process, but is not a result of unintentional formation during the shredder

process. Therefore, it is desirable to know and identify before the shredder process which components

of an electrical device may include these compounds a nd to try to dismantle them before shredding.

Table 1 Organics in shredder residues defined in the original reference as “fuel

fractions” and “disposal fractions

Organics

PCDD/PCDF

I-TEQ ng g-1

Fuel fr

PCDD/PCDF

I-TEQ ng g-1

Disposal fr

PCB

ug g-1

Fuel fr

PCB

ug g-1

Disposal fr

PCBz

ug g-1

Fuel fr

PCBz

ug g-1

Disposal fr

P1 half dism. < 0.6 - 6.7 - 2.2 -

P1 full dism. < 0.20 - 6.1 - 0.4 -

P1 mixed cars < 0.03 0.04 1.1 41 0.7 0.4

P1 mixed waste < 0.2 0.03 12 77 0.8 0.3

P1 white goods < 0.15 0.04 34 114 0.9 0.4

P1 industrial waste < 0.3 0.04 24 62 0.3 0.2

P2 half dism. < 0.2 - 2.1 - 1.9 -

P2 half dism. < 0.11 - 0.5 - 1.5 -

P2 full dism. < 0.6 - 0.6 - 0.4 -

P2 mixed cars < 0.3 0.06 1.5 14 1.5 0.3

P2 mixed waste < 0.2 0.15 39 217 1.9 0.4

P2 white goods < 0.16 0.11 102 254 0.7 0.5

P2 industrial waste < 0.12 0.14 25 295 0.4 0.15

Source. Börjeson, L; Löfvenius, G; Hjelt, M.; Johansson, S.; Marklund, S. 2000

Studies have confirmed that automotive shredder residues derived from end-of-life vehicles contain

PCB in the ppm-range (=mg/kg) (Urano et al. 1999, Sakai et al. 1998, 2000). dibenzo-p-dioxins and

dibenzofurans contamination in engine oil from end-of-life vehicles could not be detected. Taking

congener profiles into account, it can be considered that the major reason for this is that

polychlorinated biphenyls -containing materials manufactured in the past were mixed in the recycling

and waste processes. While emissions of persistent organic pollutants from shredding plants were not

examined in these studies, given the levels of PCB in the ppm-range (=mg/kg) in automotive shredder

residues, potential emissions of persistent organi c pollutants through flue gas should be considered.

This polychlorinated biphenyl release originates from the commercial polychlorinated biphenyl

mixture that is used in automobiles. These PCBs are not unintentionally generated persistent organic

pollutants and thus, in a strict sense, not subject to the polychlorinated biphenyl release inventory

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under the provisions of Article 5 of the Stockholm Convention. Since there is no way, however, to

differentiate between intentional and unintentional polychlorinated biphenyls in shredder wastes and

emissions, best available techniques and best envi ronmental practices should be applied to minimize

or eliminate release of any polychlorinated biphenyls from the shredder process.

Copper and chlorine in significant amounts are cons tituents of shredder waste and promote in case of

burning the formation of dibenzo-p-dioxins and dibenzofurans and other unintentionally released

persistent organic pollutants.

4. Emission concentrations from shredder plants

A report on a European dioxin inventory stated that measured dibenzo -p-dioxins and dibenzofurans

data exist for a few shredder installations. Generally, very low concentrations (< 0.01 ng I-TEQ/m³)

were found in a plant investigated in Sachsen-Anhalt (Germany). The available data are summarized

in table 2 below, showing emissions and emission factors to air.

Table 2 Dibenzo-p-dioxins and dibenzofurans emissions in German shredder plants

Minimum Maximum Geometric mean Arithmetric mean

Emission concentration

(ng I-TEQ/m³) 0.002 0.430 0.056 0.140

Emission factor

( g I-TEQ/t) 0.059 0.667 0.236 0.303

Source: LUA 1997.

A further investigation from Belgium (François, F., Blondeel, M., Bernaert, P., Baert, R., 2004)

considered potential specific sources of uninten tionally released PCB and PCDD/PCDF from a

shredder plant turning end-of-life vehicles and wast e from electronic and electrical equipment into

various reusable fractions. An overview of a number of stack emission measurements of dibenzo -p-

dioxins and dibenzofurans and unintentionally released polychlorinated biphenyls is given in table 3.

The shredders are equipped with at least a cyclone f ilter system for de-dusting the flue gases. Flue gas

flow rates are typically about 75,000 Nm³/h. All dibenzo-p-dioxins and dibenzofurans concentrations,

except one, were below 0.1 ng TEQ/Nm³.

Table 3 Measured data for emission concentrations from shredder plants

Emission measurements PCDD/PCDF

ng TEQ/Nm3

dioxin-like PCB (sum of 12)

ng TEQ/Nm3

shredder 1 0.0098

0.012

0.0048

0.0004

0.048

0.41

0.073

0.025

shredder 2 0.077

0.043

0.022

0.74

1.06

0.30

shredder 3 0.0088

0.37

0.025

0.171

0.34

0.73

Source: François, F., Blondeel, M., Bernaert, P., Baert, R. 2004

Dioxin precursors which may result in the formation of polychlorinated dibenzo -p-dioxins and

dibenzofurans (PCDD/PCDF) when burnt include polychlorinated biphenyls -containing condensers,

polychlorinated biphenyls or chlorobenzene contaminated waste oils or textiles, and polymers

containing brominated flame retardants (formation of polybrominated dibenzo-p-dioxins (PBDD) and

polybrominated dibenzofurans (PBDF) as contaminants).

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5. Recommended measures

An important best environmental practice is to strengthen the responsibility of the operators of

shredders. An analysis should be undertaken to identify hazardous components and fluids with

incoming material and to provide facilities to remove them before the shredder process.

It is crucial to control treated scrap, especially electric devices, transformers and condensers, which

must be identified, dismantled and eliminated separately to avoid the introduction of polychlorinated

biphenyls into the plant. This is also a measure to reduce the contamination of shredder residues by

polychlorinated biphenyls.

Nevertheless, shredder residues are always contaminated and must only be disposed of in an

incineration dedicated plant.

By dismantling and recycling big plastic parts, for instance bumpers, a considerable reduction of the

remaining plastic fraction in the end-of-life vehicles and in the resulting shredder waste can be

achieved.

By further treatment of shredder wastes, for instance by eddy current separation, a considerable

proportion of the metals contained in the waste, such as copper and aluminium, can be recovered.

In order to achieve a higher proportion of recyclable fractions, the use of recyclable material and

simple disassemblies should be encouraged in the stage of product design. This is not only valid for

end-of-life vehicles.

6. Minimum technical requirements for treatment

Sites have to be constructed to prevent the contamination of soil, water and air. For this reason,

appropriate storage facilities, including impermeable surfaces with spillage collection facilities;

decanters and cleanser-degreasers should be provided, as well as equipment for the treatment of

appropriate storage tanks for water, including ra inwater. In addition, appropriate storage for

dismantled spare parts, including impermeable storage for oil-contaminated spare parts, appropriate

containers for the storage of batteries (with electrolyte neutralization on site or elsewhere), filters and

PCB/PCT-containing condensers and appropriate storage tanks for fluids are necessary.

7. Primary measures

Fluids, like brake fluid, petrol, steering fluid, motor oil, coolants and transmission fluid should

generally be removed from the end-of-life vehicle or other devices before shredding. This is

especially applicable in the case of PCBs, which should be identified and removed from any device to

be shredded. Specific attention should be given to transformers and condensers. Measures should

include:

The removal of batteries and liquified gas tanks;

The removal or neutralization of potential explosive components, (e.g. , air bags);

The removal and separate collection and storage of fuel, motor oil and oil from other

components;

The removal of catalysts;

The removal of tyres and large plastic components (such as bumpers, dashboards, fluid

containers, etc.), if these materials are not segregated in the shredding process in such a way

that they can be effectively recycled as materials.

8. Secondary Measures

Measures to prevent releases of persistent or ganic pollutants at shredder plants include:

The advanced treatment of flue gas (with bag f ilters and activated carbon filters to remove both

gaseous and particle emissions);

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The proper disposal of residuals and liquid shredder wastes containing a mixture of organic

materials, heavy metals such as copper and, in many cases, polychlorinated biphenyls and

other chlorinated substances. Treating this waste in an inappropriate manner will lead to

emissions of unintentionally released persistent organic pollutants. This is especially the case

in open burning. Shredder wastes should be never burned in an open fire or in inappropriate

facilities;

The appropriate treatment of shredder waste is incineration in a facility meeting the

requirements for best available techniques and best environmental practices. If such a facility

is not available, disposal in a sanitary landfill may be preferred to other forms of disposal.

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References

Basel Convention Secretariat. 2002. Technical Guidelines on the Environmentally Sound

Management of the Full and Partial Dismantling of Ships . Basel Convention on the Control of

Transboundary Movements of Hazardous Wastes a nd Their Disposal, United Nations Environment

Programme. Geneva.

Börjeson, L.; Löfvenius, G.; Hjelt, M.; Johansson, S.; Marklund, S. 2000. “Characterization of

automotive shredder residues from two shredding facilities with different refining processes in

Sweden”, Waste Manage Res. (2000) 18 p.358±366

European Commission. 2000. Directive 2000/53/EC of the European Parliament and of the Council

of 18 September 2000 on end-of life vehicles. Offi cial Journal of the European Communities,

L 269/34-269/42 EN, 21.10.2000

Environment Australia, Department of the Environment and Heritage .2002. “Environmental Impact

of End-of-Life Vehicles: An Information Paper”

François F., M. Blondeel, P. Bernaert, and R. Baert .2004. Diffuse Emissions of PCDD/F and Dioxin-

like PCB from Industrial Sources in the Flemish Region. Organohalogen Compd. 66, 906-912

Fahrni, H.-P., 2005. Präsentation - Seminar der Abteilung Abfall “Situation RESH” 2005, BUWAL,

Switzerland,

Fiedler, H.; Sakai, S. 2004. Shredder Plants for Treatment of end-of-life-vehicles. Information

document prepared for the third Session of the Expert Group on BAT/BEP. www.pops.int

LUA .1997. Identification of Relevant Industria l Sources of Dioxins und furans in Europe.

Materialien No. 43. Landesumweltamt Nordrhein-Westfalen, Essen, Germany

Sakai S., S. Urano, and H. Takatsuki .2000. Leaching behavior of PCB and PCDDs/DFs from some

waste materials. Waste Management 20, 241-247

Sakai S., S. Urano, and H. Takatsuki .1998. Leaching Behavior of Persistent Organic Pollutants

(POPs) in Shredder Residues. Chemosphere 37, 2047-2054

Towa Kagaku Co. 2001. Research report on current status of recycling plaza

Urano S., S. Sakai, and H. Takatsuki .1999. PCB in Automobile Shredder Residue and its origin. 8th

Symposium on Environmental Chemistry Program and Abstracts, pp 50-51 (in Japanese)

Other Sources

Nourreddine, M. 2006. “Recycling of auto shredder residue” Journal of Hazardous Materials-5423.

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APPENDIX 3

Hegarty Metals ELV De-pollution Procedure

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Clearcircle Environmental – Metals Division

Stage Procedure Timeline Notes1 ELV's inspected by IMI at weighbridge and waste

acceptance details recorded, i.e. Vehicle make, model, registration, owner details incl name, address and ATF details if applicable

At time of acceptance

Vehicle registration certificate supplied in case where Certificate of Destruction Required.

2 Initial inspection of ELV interior, boot and engine area of vehicle for rubbish, pressurised vessels and other unacceptable waste

At time of acceptance

Pressurised vessels and /or rubbish to be taken back off site by owner or vehicle rejected. In event that vehicle is inspected after owner has left all rubbish should be placed in appropriate bins. Any pressurised vessels must be removed to appropriate storage.

3 Accepted ELV's directed to stockpiling areas for de-pollution if required or storage area for transfer to Frag plant or Hammond Lane if already de-polluted by supplier, i.e. ATF facility

All ELV's depolluted within 1 working week of acceptance

All ELV's stored in concrete hard stand areas where any potential leakage is directed to surface water management system.

Stage Procedure Timeline Notes1 De-pollution book is completed for all ELV's processed

through De-Pollution plant.De-pollution book completed at time of de-pollution

Details of ELV make, model and registration are recorded and later transferred to electronic register.

2 Complete Certificate of Destruction (COD) Within 2 weeks of de-pollution

Green copy to the last owner, yellow & White to Group EHS Mgr or Delegate, white to be forward to Department of Environment to de-register the vehicle.

3 Maintain COD electronic register Updated on a monthly basis

Stage Procedure Timeline Notes

EHSP020 Procedure for the Acceptance and De-Pollution of End-of-Life-Vehicles

De-Pollution

ELV Acceptance

Administration

EHSP020 Rev E Page 1 of 3

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1 Detailed inspection of ELV interior, boot and engine area of vehicle for rubbish, pressurised vessels and other unacceptable waste. This is particularly important for Hegarty Metals to prevent APD's.

Approx time to de-pollute one ELV is 30 minutes

Each vehicle is split into 3 compartments for inspection - interior or main cabin, boot and engine area. A large yellow X must be painted onto each compartment to verify inspection has being completed. The vehicle roof should be marked for interior or main cabin inspection. The yellow X mark verifies that compartment has being inspected and is free from pressurised vessels and other unacceptable wastes. If a particular compartment cannot be accessed then a yellow circle mark should be placed in that area. Further inspections of this compartment will be completed by material handler operator prior to shredding as part of waste acceptance procedures.

2 Inspect vehicle for all major components Engine, gearbox, running gear and all major parts must be there3 Remove Battery Place in designated bin supplied by Rilta Environmental 4 Remove Fuel Filler Cap If detachable type, place in scrap metal bin5 Remove Oil Filler Cap Place in scrap metal bin6 Set Heater Control in car to maximum heat To allow all liquid to flow out at stage 157 Lift Vehicle off ground with fork-lift Approx. 150mm is sufficient height8 Remove 4 wheels and spare wheel Set aside for removal of lead weights and tyre disposal9 Remove any parts known to contain mercury Place in designated bin supplied by Rilta Environmental

10 Place Vehicle on De-Pollution Rig Ensure vehicle is secure and move access ladder into place11 De-gas Air conditioning unit (If Fitted) Specialist tool in place for degassing12 Drain Engine Oil from sump Leave tray in place for remainder of process13 Remove Oil Filter Place in designated bin 14 Drain Transmission Oil Transferred to storage tank for removal by Rilta Environmental 15 Drain Rear Differential Oil (if applicable) Transferred to storage tank for removal by Rilta Environmental 16 Drain Coolant Transferred to storage tank for removal by Rilta Environmental 17 Drain Brake Fluid Transferred to storage tank for removal by Rilta Environmental 18 Remove Catalytic Converter (if Fitted) Place in designated bin for export19 Drain Window Washer Bottle Transferred to storage tank for removal by Rilta Environmental 20 Drain Brake Reservoir Transferred to storage tank21 Drain Clutch Reservoir (if applicable) Transferred to storage tank22 Drain Power Steering Reservoir (if fitted) Transferred to storage tank for removal by Rilta Environmental 23 Drain Fuel Tank Examine fuel in inspection glass and divert to correct storage tank24 Drain Shock Absorbers or remove Suspension Fluid Specialist tool in place for draining the fluid25 Remove Vehicle from De-pollution Unit Using forklift27 Remove or deploy Air-Bags in situ (if fitted) Specialist tool in use 28 Remove Vehicle to Shredding Area (Hegarty Metals) or

stockpiling area for transfer to Hammond LaneUsing forklift

Rev H 13/10/2011

out at the start of the process to allow the oil to gravity drain. The sequence of events can be altered for reasons of operation efficiency, but stage 13 (draining engine oil) must be carried

EHSP020 Rev E Page 2 of 3

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FORM REVISION HISTORYDOCUMENT TITLE ELV Acceptance and De-Pollution Procedure

DOCUMENT NUMBER EHSP020

REV DATE DESCRIPTION OF CHANGE AMENDED BY APPROVED BYA 21/02/2006 Amd 030 New Document K FAHY K FAHYB 12/02/2007 Amd 083 ATF I MURPHY K FAHYC 22/11/2007 Amd 120 Incl HMPIL K FAHY K FAHYD 02/10/2008 Amd 186 incl One51 & Rilta K FAHY K FAHY

E 16/03/2009Amd 197 incl tool for degassing air bags and draining shock absorber fluid K FAHY K FAHY

F 31/03/2011 General Review MOK M BERGING 04/08/2011 Review for inspections for pressurised vessels M Bergin K ByrneH 13/10/2011 Review for new Limerick, Galway and Cork facility

permit requirments.MOK M BERGIN

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APPENDIX 4

WEEE Decontamination Procedures

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RILTA Environmental Ltd.

EMS PROCEDURE MANUAL TITLE Management of waste Oil Filled

Equipment

REF

ISSUED BY Colin Lennon APPROVED BY

DATE 28/03/2011 PAGE 1 of 5

This document is issued and controlled by the Environmental Manager. This is a controlleddocument subject to change at any time, and therefore should not be copied. Only signed,authorised copies may be used as working documents.

Revision Description By Approved Date000 C. Lennon 28/03/2011

1.0 PurposeTo document the procedures for the acceptance, testing and disposal of obsolete &waste oil filled electrical equipment (OFE) including known and suspect PCB(Polychlorinated Biphenyls) holdings.

2.0 ScopeThe procedure outlined in this document conforms to the guidelines laid out in theManagement Plan for Polychlorinated Biphenyls (PCBs) in Ireland published by theEPA in August 2008.

3.0 ResponsibilityOperations Director & Environmental Manager

4.0 ProcedureObsolete and waste transformers will be transported under C1 hazardous wasteconsignment note and delivered by appropriately licensed and permitted carriers tothe Cedar Site covered by EPA waste licence no. W0185 01.Upon arrival of the load at the Cedar site

Complete the C1s by completing the following fields:The net weight of the loadEnsure the delivery vehicle driver has properly completed Part B ofthe C1Complete sections 16, 17 & 20

Count the number of units to ensure that the number of units on the ESB C1annex match the actual number of units deliveredIf the number of units match enter the Rilta Serial number using permanentmarker on a prominent position on each unit.If the numbers of units do not match make a note on the annex of thedifference.

Write the first 5 digits of the RILTA s/n on the top of each page of the ESB Annex(acts as a quick reference)

Make a copy of the ESB annex to be used when de polluting the units.

OFE will be offloaded and stored in a quarantine area pending testing ordecommissioning.

OFE manufactured during or prior to 1989 will be assumed to contain PCBs. OFEwith no identifiable date of manufacture will also be assumed to contain PCBs.

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Equipment

REF


DATE 28/03/2011 PAGE 2 of 5

These items of OFE will be quarantined pending testing as per Rilta EnvironmentalEMS procedure on the Testing of PCB wastes.Subject to analysis results the following actions will be taken.Pre 1989 and unidentifiable OFE will not be decommissioned until laboratory testinghas been completed.During de commissioning of OFE gaskets and seals may be encountered that aremanufactured from asbestos, if confirmed or suspect asbestos gaskets/seals areencountered the operator will put on P3 respiratory protection mask, gently removethe gasket/seal to ensure that no damage occurs during removal. The suspect itemwill be placed into red asbestos bags pending confirmation on the nature of theitem. The bags will be labelled with the asbestos a warning label as per REACHguidelines.If the gasket is determined to be manufactured from asbestos it will be placed intoUN approved packaging and exported for disposal under TFS to facilities in Germany.

PCB concentration <50 mg/lTransformer oil will be drained from the transformerWhen de polluting each item find the ESB s/n on the ESB annex and fill in the RILTAs/n and the date de polluted in the columns provided

The following data for each piece of OFE decommissioned will be recordedTransformer Decommissioning Log.

o Dateo Rilta s/no Manufacturero KVao Year of Manufacture

The copies of the ESB annexes are to be kept on one clipboard

The transformer decommissioning log is to be kept on another clipboard

Recovered oil will be treated via the Rilta Environmental Oil treatment facility(W0192 03)

Waste metals will be sent for recycling and recovery via the facilities listed in annex4

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Equipment

REF


DATE 28/03/2011 PAGE 3 of 5

PCB concentration >50 mg/lThe unit(s) will be safely moved using any necessary spill control measures such asdrip trays or bunded containers to the designated storage area without removingthe PCB oil contentThe client will be notified of the test resultsEach unit will be inspected to ensure its suitability for transport by sea. Particularattention will be paid to possible leaks and rusty/unsafe hinges and joints andoverall integrity of the unit.If suitable for transport, the relevant TFS paperwork will be prepared and allauthorities notified.The unit will be transported whole in a suitably bunded tray as per ADR & IMDGregulations and EPA guidelines.If the unit is deemed unsuitable for transport the following procedure will apply:The unit(s) will be safely moved to the designated storage area without removingthe PCB oil content.It will be secured in place to ensure no spills take placeTransformer oil will be drained from the unitThe oil will be transferred into UN approved drums and stored pending export fortreatment and disposal via the facilities listed in annex 4The empty unit(s) will be packaged and labelled as per ADR and IMDG and exportedfor treatment and disposal via the facilities listed in annex 4

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Equipment

REF


DATE 28/03/2011 PAGE 4 of 5

>50 mg/l PCBs

Testing

Drained transformersexported fortreatment and

disposal (see annex 4for list of facilities)

Wastetransformer oildrained from

unit

Waste Metalrecycled (seeannex 4 for listof facilities)

Oil Removed from OFEand treated in the Rilta

Environmental Oiltreatment facility (W0192

03)

Assessment ofsuitability for

transport by sea

No Yes

Whole units labelled& packaged as perADR & IMDG andexported fortreatment and

disposal

Notify Client

Waste Oil packagedinto UN Containersand exported fortreatment and

disposal (see annex 4for list of facilities)

<50 mg/l PCBs

OFE

Table 1.0 PCB management flow chart

OFE will be stored and all processing will be carried out in a remotely bunded area (seeannex 1).

To avoid cross contamination of equipment two separate sets of pumping equipment andpiping will be provided, one for PCB concentrations <50mg/l and the other for PCBconcentrations >50mg/l.

Two separate decanting areas will be set up for the decanting of the transformer oil.Decanting will be carried out on steel fabricated drip trays with rear and side splash guardssimilar in design to that photographed on page 32 of the EPA management plan for PCBs.

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Equipment

REF


DATE 28/03/2011 PAGE 5 of 5

All processing will be carried out by appropriately trained personnel equipped with thefollow PPE:

Class 5 Cut Resistant Gloves which complies to standard EN388 and EN407Safety footwear with antislip soles, sole protection and toe guardsOverallsSafety Glasses

If PCB concentration is greater than 50ppm the following will also be worn:Nitrile or butyl rubber gloves – do not use Latex glovesEye protectionCoveralls impervious to PCBs such as Tychem FRespiratory protective devices with a full face mask fitted with a class P3cartridge/canister suitable for use with PCBs is required when handling PCB liquids attemperatures >55°C, where there is a significant amount of PCB liquid exposed tothe air, or where adequate ventilation is not possible.

Emergency Procedures will be put in place to deal with the followingFirst Aid treatment following exposure to PCB containing oilsFire involving PCB containing oilsLeak / Spill of PCB containing oils

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ATTACHMENT 2

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Industrial Emissions, Application Form, V.2.0, March 2014

Page 1 of 12

NON-TECHNICAL SUMMARY

Galway Metal Company Limited (GMC) is applying to the Environmental Protection Agency

(EPA) for a Licence for its existing metals recovery installation at Oranmore, Galway. It is

intended to move part of the fragmentiser (metal shredding unit), which is currently at

GMC’s sister company’s metal recycling plant in Limerick, to Oranmore.

The fragmentiser has the capacity to shred more than 75 tonnes of metal/day and

therefore will require an Industrial Emissions Licence to operate. The classes and nature

of the industrial emissions directive activities, in accordance with the First Schedule to the

Act of 1992 as amended, are:

11.1 The recovery or disposal of waste in a facility, within the meaning of the Act of 1996,

which facility is connected or associated with another activity specified in this Schedule in

respect of which a licence or revised licence under Part IV is in force or in respect of which

a licence under the said Part is or will be required.

11.4.(b) Recovery, or a mix of recovery and disposal, of non-hazardous waste with a

capacity exceeding 75 tonnes per day involving one or more of the following activities,

(other than activities to which the Urban Waste Water Treatment Regulations 2001 (S.I.

No. 254 of 2001) apply):

(iv) Treatment in shredders of metal waste, including waste electrical and electronic

equipment and end-of-life vehicles and their components.

GMC applied to Galway County Council for planning permission to install and operate the

shredder and associated ancillary works. An Environmental Impact Statement (EIS) was

submitted with the planning application and a copy of the EIS is included in this application.

The Council granted permission on 9th March 2015.

The design and method of operation at both the existing facility and proposed development

are based on the requirements of the Best Available Techniques for the Waste Treatment

Industries 2006 (BREF), which specifies the Best Available Techniques (BAT) for Waste

Management Facilities, the BREF for Energy Management and the BREF for Storage.

The emission limit values were determined by those set in the existing Waste Permit,

which comply with BAT, and an assessment of the impacts of the new emission sources,

which include air emissions and noise.

The EC (Control of Major Accident Hazards involving Dangerous Substances) Regulations

2006 do not apply.

The Installation

The installation is located in Oranmore, approximately 8km to the east of Galway City. It

encompasses approximately 1.45 hectares (ha) and is occupied by a weighbridge at the

site entrance, external paved storage and processing areas and one main building, which

is divided into discrete units, an office, workshop, maintenance building and car park.

The central section of the main building contains designated processing areas for recycling

of non-ferrous, aluminium and new and reusable steel and end of life vehicles. The eastern

section is occupied by a vehicle and plant maintenance garage, with offices in the western

section.

The remainder of the installation is occupied by external materials storage, handling and

processing areas. The main processing area (7,993m2) includes separate storage bays for

cast aluminium, aluminium turnings, stainless steel turnings, cable and stainless steel

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Page 2 of 12

storage. To the east of the main building is an oil storage bund, which is used to store

waste oil removed from the end of life vehicles (ELV) and fuel for the on-site plant and

collection fleet.

Current Operations

The installation accepts and processes scrap metal and ELV. The processing involves

manual separation of the metals into different types: vehicle de-pollution; shredding,

segregating and sizing of metals. The majority of the processing and storage activities are

carried out in the open yard in the centre of the site and inside the main building.

Diesel is stored in a tank located in a bund in the north-east corner of the site. Lubricating

and hydraulic drums are stored on spill trays in the garage and workshop, which are inside

the main building. Waste oils generated during plant maintenance and the de-pollution

processes are stored in the bund in the north east corner of the site. Oil spill containment

and clean-up equipment are maintained at strategic locations around the installation.

Metal and metal compounds are delivered by vehicles operated by Galway Metal and third

party waste contractors. Each load is inspected by an Incoming Materials Inspector (IMI),

who rejects loads that are not suitable and quarantines any materials that not listed in the

Permit.

Depending on the types of materials, the load is directed to either the main processing

building, or the external yard areas for storage or processing. Following processing the

materials are sent to overseas foundries (Spain, Portugal, France and the UK) where they

are smelted for re-use.

The main activity is the manual separation of the various types of metals, which are then

stored pending consignment. Some of the materials are sheared using a fixed plant

Leimbach shears to reduce the size to a level suitable for shipment. The shears is powered

by a number of electric motors, with the electricity supplied by an on-site diesel powered

generator. This generator will be replaced by mains supply.

Copper is baled in a small electrically powered baler in the western section of the main

building. Other metals are baled using an electrically powered Taurus Baler, the motors of

which are located in a lean-to building at the southern boundary of the site. It is proposed

to decommission and remove this baler. Vehicle wheels are crushed in an electrically

powered crusher located inside the main processing building adjacent to the copper store.

All ELVs are de-polluted inside the main building, using a dedicated De-Pollution Unit. The

de-pollution process is mainly mechanical, using gravity and compressed air operated

vacuum system to drain fluids from the vehicles. The fluids are stored in a series of bunded

tanks adjacent the de-pollution unit.

The separation, stockpiling and loading of the materials is carried out using five (5 No.)

diesel powered mechanical grabs and five (5 No.) diesel powered forklifts

Drinking water is obtained from the mains supply. Wastewater from the toilets and canteen

and rainwater run-off from the operational yards is collected and discharged to the Irish

Water foul sewer. Clean rainwater from the building roofs and the car park discharges to

a drain that runs along the southern boundary.

Proposed Development

The proposed development includes the provision of a pre-shredder and hammer mill and

associated ancillary works, which will include the demolition of an existing shed;

replacement of existing power generator with mains electrical supply including enclosed

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Page 3 of 12

electrical transformers; moveable separation wall; acoustic screen barrier; a new diesel

tank and bunding; modifications to the alignment of existing storm and foul water services

and modifications to south and east boundaries.

The pre-shredder and hammer mill will process end of life vehicles and other metals for

recycling. The output from the mill not be processed at GMC, but will be sent to the

Clearcirlce Limerick facility for further treatment. The process is complementary to the

existing operation and means it will no longer be necessary to transfer scrap metals from

the Oranmore to other sites for processing.

The pre-shredder and hammer mill and associated direct drive Caterpillar engine and

engine room, exhaust stack and cooling fans will be located in the east of the site. A pit

will be provided beneath a conveyor feed line. It will operate six hours per day, five days

per week. An acoustic barrier will be provided around the hammer mill.

Raw & Auxiliary Materials and Energy Usage

Facility operations involve the consumption of electricity, water, oils, coolants and

electricity. The estimated quantities used in 2013 are presented in Table 1

Table 1: Resource Consumption

Resource Units Consumption

Electricity kWhr 231,660

Water m3 1,272

Auto Diesel Litres 328,068

Tractor Diesel / Gas Oil Litres 233,699

Hydraulic Oil Litres 10,000

Engine Oil Litres 1,000

Antifreeze / Coolant Litres 400

There will be a significant increase in diesel and electricity consumption when the pre-

shredder and hammer mill being operation. These will be recorded on an annual basis as

part of an energy and raw materials management plan.

Sources of Emissions

The actual and potential emissions from the installation are:

Noise from plant and equipment used to process the wastes and the delivery/collection

vehicles.

Dust from waste processing and vehicle movements on yards during dry weather.

Rainwater run-off from the yards and building roofs.

Exhaust gas emissions from hammer mill direct drive Caterpillar engine.

Vehicle exhaust gases from the delivery and collection vehicles.

Environmental Conditions

The surrounding area is predominantly rural in nature however there are a number of

industrial and commercial parks within a 1km radius of the GMC site, including Oranmore

Business Park (southwest), Deerpark Industrial Estate (west northwest), Westlink

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Commercial Park (south), Glenascaul Manufacturing and Technology (northwest) and

Glenascaul Business Park (northwest). There are three residential dwellings and a hotel

within 500m of the site.

The climate in the area is mild and wet, with the prevailing wind direction from the south

west. The site is covered in made ground, underlain by a limestone till that is

approximately 2m thick. The underlying bedrock is limestone and is a Regionally Important

Aquifer. The ground level at the site is some 1.5m higher than the lands to the east.

The site is in the catchment of the Frenchfort River (Coastal), which is a Surface Water

(River catchment) Waterbody of the IE_WE_ClarinKilcolgan Water Management Unit

designated in the Western River Basin District Management Plan. The Frenchfort River

Water Body Status Report states that the overall status is ‘Good’ but it is considered at

risk of not maintaining this this status by 2015.

Sanitary wastewater discharges to the Irish Water foul sewer. Rainwater run-off from the

paved operational yards also discharges to the foul sewer via a Class 1 Oil Interceptor and

a 400m3 capacity flow attenuation tank. The discharge is regulated by a Trade Effluent

Discharge Licence issue by Galway County Council and monitoring has confirmed

compliance with the emission limit values set in the licence.

Rainwater run-off from the building roof and car park discharges to drain along the

southern boundary of the Business Park that joins the Carrowmonesh Stream

approximately 150m east of the GMC site. The Carrowmonesh enters the sea at Oranmore

village, approximately 1.2km southwest of the GMC site. The site is not in a flood plain

and there is no record of any flooding either at, or in the vicinity of the site.

Runoff from the external operational and storage area is collected and directed to an above

ground attenuation tank, which has a capacity of 400m3 and provides temporary storage

of surface water before it is discharged to the foul sewer at a maximum rate of 4

litres/second (l/s). There is a shut-off valve at the outlet from the tank that can be closed

in the event of an incident to contain any contaminated water within the site boundary.

The size of the tank was based on a 1:100 year return storm event (102.8mm over 24

hour period), an impermeable area of 1.07ha and a maximum discharge rate to the foul

sewer of 4l/s. The maximum storage capacity required is 754 m³. This is accommodated

by a combination of the attenuation tank (400m3) and additional retention (390m3) within

the southern area of the site, which gives a total temporary storage capacity of 790m3.

The conveyor pit will provide an additional 96m3 storage capacity.

The ambient air quality is good and the routine dust monitoring carried out in accordance

with the Waste Permit conditions confirms dust emissions from the site are not an issue.

The noise levels in the area are typical of an area zoned for Business and Technology Use.

The annual noise monitoring carried out in accordance with the Waste Permit conditions

confirms the site is not a source of noise nuisance.

A site investigation carried out in 2009 found that groundwater in the south east of the

site was contaminated with oil and some metals. The primary contaminant source was

damage to the underground surface water drains. In response GMC carried out remedial

works, the scope of which was approved in advance by Galway County Council and the

EPA. The damaged pipework was repaired, as was damage to the concrete yards. Two

groundwater interceptor trenches were installed, contaminated soils excavated and

removed and in-situ chemical treatment completed.

The remedial works were completed by May 2013 and a review of the effectiveness of the

actions carried out in September 2013, which was based on the results of groundwater

monitoring in five on-site wells, concluded that groundwater quality had improved

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Page 5 of 12

significantly. Galway County Council has confirmed that the remedial works were carried

out satisfactorily.

In 2011, an assessment of the sediments in the drain along the southern boundary of the

Business Park and in the Carrowmoneash Stream, both up and down stream of the

confluence with the drain, identified oil contamination and that GMC was partly responsible

for this contamination.

Remediation works, which were agreed in advance with Galway County Council and the

EPA were completed in November 2011. Some 720 tonnes of contaminated soils were

removed. Due to the proximity of the railway line it was not possible to remove all of the

contaminated sediments, but testing indicated the residual contamination did not present

an environmental risk to water quality

The water quality in the Carrowmoneash Stream and the discharge from the site (rainwater

run-off from the building roofs and the car park) continues to be monitored and the

discharge is compliant with the emission limit values set in the Permit.

A revised Baseline Soil and Groundwater Quality Report was prepared in March 2015 and

submitted to the Agency.

Nature of the Emissions and Assessment of Impact

Soils and Geology

The fragmentiser will require substantial foundations, which are likely to be piled through

the existing concrete slab into bedrock. They conveyor will be located in an underground

pit. This pit will be approximately 11m long by 2.5m wide and is likely to be 3.5m deep.

As the top of the bedrock is expected to be 2m below ground level, approximately 137m3

of soil and 53m3 of rock may have to be excavated.

The concrete slab and bedrock will be excavated using rock breakers and cutting saws and

blasting will not be required. The concrete rubble and rock fragments will, if possible be

used on site as backfill, with any surplus sent for off-site recycling/recovery. It is possible

that some or all of the excavated soils may be contaminated with oil and in this is the

case, they will be segregated from the rubble and rock fragments and sent to a suitably

authorised waste management facility.

The stockpiles of excavated materials will, pending removal from the installation, be

covered to prevent windblown dust, the contamination of rainwater run-off by sediment

and increase in the moisture content of the soils.

In the construction phase, all machinery and plant will be refuelled in designated areas

away from the open excavations to prevent any accidental spills from entering

excavations. In the operational phase oil will be stored in tanks that are provided with

appropriately sized and constructed spill containment bunds. Oil spill containment and

clean-up kits will be provided and staff trained in their use.

There are no existing direct or indirect emissions to ground and the proposed fragmentiser

will not result in any new emission to ground. The plant will be located on a concrete slab.

Rainwater run-off will drain to the surface water drainage system, which includes silt traps

and an oil interceptor that will remove any oil entrained in the run-off. The proposed

development will not have any discernible impact on the soils and geology.

Water

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The construction phase will involve piling for the foundations for the fragmentiser and the

provision of the concrete conveyor pit. As the pit will be 3.5m deep and the groundwater

table is at approximately 2.2m, it will be necessary to lower the water table to at least

3.7m below ground level to allow the concrete base and side walls to be formed. There is

the potential of oil spills or leaks from the plant and equipment used in the construction

stage.

There are no existing direct or indirect emissions to groundwater and the proposed

inclusion of the fragmentiser will not result in any new emission to groundwater. The plant

will be located on a concrete slab and any potential contaminants, such as oils or fuels,

lost from either the machinery or associated storage tanks will be collected in the surface

water drainage system and directed via silt traps to the interceptor before discharge to

the public foul sewer.

The volume of firewater associated with a fire at the site is estimated to be in the region

of 720m3. This figure includes for a period of heavy rainfall (50mm) occurring at the same

time as the fire. The flood prevention measures already in place provide a storage capacity

of 790m3, which exceeds the volumes generated by a fire. At present there is the potential

for firewater run-off to enter the drain at the southern site boundary, but measures

including the provision of a shut off valve will be put in place to prevent this. The

development will not result in any significant changes to the paved area and therefore

there will be no increase in the volume of firewater run-off in the event of a fire.

Although there is no evidence that groundwater beneath the site is significantly

contaminated with oil, it is prudent to assume there may be residual low level

contamination in the water pumped from the excavation and this will be directed to the

silt trap and oil interceptor before discharge to the foul sewer. Once the pit has been

constructed, the water table will be allowed to re-establish itself to its natural level.

In the construction phase, all machinery and plant will be refuelled in designated areas

away from the open excavations to prevent any accidental spills from entering

excavations. In the operational phase oil will be stored in tanks that are provided with

appropriately sized and constructed spill containment bunds. Oil spill containment and

clean-up kits will be provided and staff trained in their use.

There are no existing direct or indirect emissions to groundwater and in the operational

stage, the fragmentiser will not result in any new emission to surface water or

groundwater. The plant will be located on a concrete slab. Rainwater run-off will drain to

the surface water drainage system, which includes silt traps and an oil interceptor that will

remove any oil entrained in the run-off.

Oil is stored in tanks that are provided with appropriately sized and constructed spill

containment bunds. During the construction phase, oil spill containment and clean-up kits

will be provided and staff trained in their use.

Facility staff carry out routine inspections of the surface water drains, silt traps and oil

interceptors and arrange for them to be cleaned. The oil storage tanks and bunds are

routinely tested to ensure they are fit for purpose. Surface water and groundwater quality

monitoring will continue to be carried out in accordance with the Waste Permit conditions.

The pit beneath the conveyor belt will provide an additional 93m3 of firewater run-off

storage capacity. Two shut off valves will be installed on the storm water drainage system

to prevent the escape of firewater run-off the drain on the southern boundary and the foul

sewer.

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Page 7 of 12

The proposed development will not result in any discernible change to either the volume

or quality of the rainwater run-off from the site. During construction, the local water table

will be temporarily lowered by approximately 1.5m to allow the installation of the conveyor

pit. This will be a localised event and should not impact on any known groundwater

abstraction wells, the nearest of which 1.7km west of the site.

Ecology

There are no habitats of any ecological importance within the site boundary and the habitat

values of the surrounding lands are low. The site is not inside the boundary of any

designated protection area (Natura 2000 Sites) and the development will not result either

in direct loss of any habitats, or damage to a Natura 2000 Site

A Natura Impact Screening Report was prepared and submitted with the planning

permission application and a copy of this report is included in Part C of the EIS document.

There are 11 No. Natura 2000 Sites located within a 15 km radius of the site, with Inner

Galway Bay (Site Code 004031) located 1.4km southwest of the site – the closest Natura

2000 site. A complete list of sites is provided in Table 1 of Section 3.2 of the Screening

Report.

The screening report concluded that with appropriate mitigation in place, it is unlikely that

there will be any significant impact on the qualifying habitats or species of the Natura 2000

network either as a result of the project or in combination with other projects and

consequently the project will not have any significant impact on the designated site or the

habitats or species for which it has been designated.

The majority of the site is paved and is essentially without vegetation except occasionally

on the margins or on piles of spoil. The only unpaved part is the parking area west of the

main entrance and the through route to the premises by the railway.

The plants concerned are generally thought of as weed species, those that follow tillage

or other disturbance and die out when a vegetation cover is established. There is no fauna

resident on site except for those insects which feed on or from the few plants in the parking

area. Larger species would visit from time to time.

The site has no heritage value and it resembles many urban or otherwise disturbed

habitats. As such it supports characteristic plants, several of them introduced and still

spreading through the country. None of the changes proposed will alter the present impact

of the operation on flora and fauna which is primarily one of habitat replacement by hard

standing and buildings.

Air Quality & Climate

The primary source of air emissions will be CAT diesel engine. Air Dispersion Modelling

(ADM) was carried out in order to assess the impact of engine air emissions on the

receiving air environment. The model used was the U.S. Environmental Protection

Agencies AERMOD v8.5.1. THE ADM considers the following.

Background air quality data (EPA, 2012)

Site data; location, plan area, elevations and orientation of buildings and

structures.

Engine characteristics and emissions data

Terrain data, and

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Meteorological data

The background levels of the emissions from the engine (oxides of nitrogen, oxides of

sulphur, carbon monoxide, ammonia and particulates (dusts) were combined with those

in the exhaust gases from the engine to predict the impacts on air quality. The predicted

levels of all of the parameters are below ambient air quality limits specified in EU Directives

2008/50/EC and 1999/30/EC.

In the construction phase dust may arise due to the movement of vehicles. However, this

will have a negligible impact on the receiving environment as the site is in a rural location

and there are no sensitive receptors nearby.

In the operational phase dust may be caused by vehicular traffic on-site and off-site or

the handling, movement and processing of metal material. Dust monitoring carried out at

GMC’s sister site in Limerick, where operations are similar to those that will occur at GMC,

shows the dust deposition levels are significantly below accepted limit values. Dust

deposition levels at GMC are expected to be similar to those at the Limerick site.

The proposed development will have a negligible impact on air quality both during the

construction phase and during normal operations, as such no remedial or mitigation

measures are required.

All new developments that give rise to extra greenhouse gases (GHG) emissions are

considered to have a negative effect on climate. While the addition of the fragmentiser will

result in indirect additional GHG emissions from increased electricity usage, this will be

off-set somewhat by the reduction in the GHG emissions from the vehicles that no longer

have to drive from Galway to Limerick

Noise & Vibration

The fragmentiser will be a new source of noise emissions at the installation. A baseline

noise assessment and noise prediction modelling were carried out to assess the noise

impacts of the proposed development on the receiving environment.

Baseline noise monitoring measured at-source noise and background noise. A BS

5228:2009 based noise prediction model was used to determine noise levels at Noise

Sensitive Locations (NSLs) during the construction and operational phases. The NSLs

included three private residences and one hotel, all within 500m of the site boundaries

The local area surrounding the site is predominantly rural in nature however a number of

significant of off-site noise sources were identified, which included:

Traffic noise arising on the N18 (and to a lesser extent, the M6)

Stationary source noise from commercial/industrial facilities surrounding the site,

and

Trains passing on the nearby Dublin to Galway railway line

Background off-site noise levels were determined to be significant, the primary sources

being existing heavy traffic on the N18 and existing commercial/industrial facility noise

and were the major contributor to noise at NSLs. The modelling determined there would

be a negligible increase in noise levels at NSL’s as a result of the proposed development.

.

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Based on results of monitoring at GMC’s sister site in Limerick where operations are closely

similar to proposed operations at GMC tonal or impulsive noise is not anticipated. Therefore

the development will have a negligible impact on local area noise characteristics.

On the basis of vibration and air overpressure monitoring which has taken place at GMC’s

sister site at Limerick, where the fragmentiser is currently located and where sensitive

receptors are much closer to the site, vibration and air overpressure will have a negligible

impact on sensitive receptors at the GMC site

As noise and vibration impacts are negligible no mitigation measures are necessary;

however in accordance with best practice noise barriers will be provided around the

fragmentiser hammer mill.

Proposed technology and other techniques to prevent or eliminate, or where this

is not practicable, limit, reduce or abate emissions from the installation

GMC has assessed the proposed development against the BAT Conclusions and

recommendations on best practice in the following guidance documents:

Reference Document on Best Available Techniques for the Waste Treatments

Industries August 2006;

Reference Document on Best Available Techniques for Energy Efficiency February

2009.

Reference Document on Best Available Techniques on Emissions from Storage, July

2006).

Submission prepared by FEAD (European federation representing the waste

management industry) on best practice for the operation of metal shredders.

Revised Draft Guidelines on Best Available Techniques (BAT) and Provisional

Guidance on Best Environmental Practices relevant to Article 5 and Annex C of the

Stockholm Convention on Persistent Organic Pollutants.

The BREF on Waste Management is currently under review by a Working Group. FEAD

have made a submission to the Group is specific to the treatment in shredders of non-

hazardous metal waste, including waste electrical and electronic equipment and end-of-

life vehicles and their components. It is expected that the Working group will take these

into consideration and will recommend their application in the mechanical treatment of

metal wastes.

The hammer mill is a ‘damp’ system where water is injected into the mill chamber. The

objective is to control the mill temperature, supress dust emissions and minimise the risk

of fires.

The Waste Permit at the GMC sister Limerick facility required an assessment of potential

fugitive emissions of persistent organic pollutants (POPs) to atmosphere are adequately

controlled and minimised. The assessment, which was completed in 2011, had regard the

Revised Draft Guidelines on BAT and Provisional Guidance on Best Environmental Practices

relevant to Article 5 and Annex C of the Stockholm Convention on POPs ,which applies to

the shredding of end-of-life vehicles (ELV) and certain types of waste electrical and

electronic equipment (WEEE).

The GMC current Waste Permit specifies the manner in which the facility must operate so

as to ensure that pollution and or nuisance to neighbours and the general public is

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prevented. The Permit conditions require the site management team to have the

appropriate training and qualifications; identify the types of wastes and processes that can

be carried out; specify how wastes and raw materials that have the potential to cause

pollution are handled and stored; the control measures that must be applied to prevent

nuisance, and require appropriate emergency response procedures to be in place.

Summary of the Quantity and Nature of the Waste

The overall amount of waste accepted will be 60,000 tonnes, comprising different types of

scrap metals, end of life vehicles and electrical and electronic equipment.

Measures to Comply with Waste Management Hierarchy

The existing facility is designed and operated to maximise the recovery of metal wastes.

The proposed changes are consistent with the Waste Hierarchy as all of the waste accepted

at the installation, with the exception very small amounts of non-recyclables inadvertently

delivered by customers, will be recycled.

BAT

Condition 2 of the current Waste Permit requires GMC to develop and implement an

Environmental Management System (EMS) for the facility. The installation is accredited to

ISO 14001 EMS which is consistent with the requirements of e BREF. It requires GMC to

prepare site specific operational control procedures for all waste activities and ensure that

facility staff are provided with the appropriate skills and training to perform their assigned

functions.

The Permit conditions require the implementation of the control measures specified in the

BREF in so far as they apply to metal recycling and the prevention of soil contamination.

The proposed changes take into consideration the requirements of the Waste Management

and Energy Management BREFs

Abnormal Operating Conditions

GMC has documented procedures on the handling and storage of oils/fluids which detail

the responses that will be implemented in the event of a spill/release. GMC also has

documented waste acceptance and operational procedures that detail the actions taken to

minimise the acceptance of non-suitable waste, for example gas canisters, that could

cause an incident if processed in the fragmentiser.

GMC has prepared and adopted an Accident Prevention Policy (APP) and Emergency

Response Procedures (ERP). The APP addresses all potential hazards, with particular

reference to the prevention of accidents that may cause damage to the environment. The

ERP identifies all potential hazards at the site that may cause damage to the environment

and also specifies roles, responsibilities and actions required to deal quickly and efficiently

with all foreseeable major incidents and to minimise environmental impacts.

In the event of an incident that results in environmental pollution GMC will carry out the

relevant response actions described in the Environmental Liability Risk Assessment Report

that has been submitted to the Agency.

Avoidance of the Risk of Environmental Pollution due to Closure of the Facility

The installation does not have a defined lifetime. In the unlikely event that the installation

must close, GMC will ensure the closure and decommissioning is carried out in accordance

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Page 11 of 12

with a Decommissioning Management Plan that has been submitted to the Agency as part

of the application.

Environmental Monitoring:

GMC currently conducts surface water, groundwater, noise and dust monitoring and this

will continue pending the decision on the licence application.

Measures to Comply with an Environmental Quality Standard

The emission limit values proposed in the application and those that will be set by the EPA

in the new licence are and will be based on achieving compliance with the relevant EQS.

Measures to comply with Council Directive 80/68/EEC and 2006/118/EC in

relation to the protection of groundwater.

There will be no discharge to ground. The site is designed to prevent accidental emissions

to ground.

The Main Alternatives to the Proposed Technology, Techniques and Measures

Alternative Sites

The GMC installation is the preferred location within the Clearcircle Metals Ireland Ltd

group of four waste metal recycling facilities to locate a fragmentiser plant. The three

alternative sites considered include the Cork Metal Company, A1 Metal Recycling in

Mountmellick and Clearcircle Metals Limerick.

Munster is already well serviced with a fragmentiser located at Hammond Lane Cork and

therefore in terms of national distribution, locating an additional fragmentiser in Cork

would not serve the needs of the industry. The Mountmellick facility is small and, given its

location at the edge of the town and surrounded by residential development, the site was

considered unsuitable.

Due to the implementation of EU Industrial Emissions Directive 2010 the fragmentiser

currently located at Clearcircle Metals Limerick will cease operation in July 2015. The

relocation of the fragmentiser to GMC will improve transport efficiencies and reduce

associated environmental pollution, as the existing 10,000 tonnes per annum of

fragmentiser feed material transported by road from GMC to Limerick will no longer be

necessary, as the processed materials will be exported from Galway City Docks.

Furthermore, a substantial portion of the fragmentiser feed material collected from

Authorised Treatment Facilities (ATF) in County Clare can be transported directly to

Galway, a much shorter distance.

Alternative Site Layout & Processes

The proposed location of the fragmentiser takes into consideration operational,

environmental and planning aspects, including noise and visual mitigation, vehicle turning

movements within the site and existing site operations. The restrictive factors were taken

into consideration included:

The proposed location is open space and can accommodate the fragmentiser, the feed

stock, the shredded stockpiles and vehicular access to and from these stockpiles.

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Shredder plants of the type proposed for the GMC installation produce first-grade

processed materials, generating revenue for exporting countries and, as recycled materials

are naturally less expensive than primary materials, offering a cost advantage to the

industries that consume them. In this context there currently is no viable alternative

process to the shredder.

Initially it was proposed to operate the pre-shredder and hammer mill in the same manner

as at the Limerick facility. This would involve the installation of a pre-shredder powered

by a generator and hammer mill with direct drive CAT engine. These combined with the

existing Leimbach shears generator, would increase the number of point source emissions

to atmosphere at GMC from one to three.

Air dispersion modelling of the proposed three point emission sources indicated a potential

adverse impact on atmosphere at the GMC facility. In response, an assessment of the

implications of changing from the use of generator to mains electricity supply for the

Leimbach shears, re-shredder and hammer mill, was carried out.

This found that the Leimbach shears generator and pre-shredder generator could be

replaced by an up-grade of mains electricity supply involving the installation of three

transformers. Consequently, the design of the existing process was revised, with the

Leimbach shears and pre-shredder now being powered by the mains electricity, with the

hammer mill being powered by a single CAT engine thus reducing emission points to one,

as is currently the case.

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