Appendix to FIR Point 15 - Environmental Protection Agency · Danafloat_068 (Pb Aux Collector) - Safety and emergency procedures are prepared, risk assessments are carried out. -

IEL PO516-03 Review Application

Response to Further Information Request 09/03/2017

Appendix to FIR Point 15

Assessment Report prepared in accordance with Article 22(2) of

Industrial Emissions Directive 2010/75/EU

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Assessment Report In accordance with

Article 22(2) of Industrial Emissions Directive (2010/75/EU)

Table of Contents

1 Introduction ............................................................................................................................ 2

2 Scope of Report/ Assessment ............................................................................................... 2

3 Stage 1: Site Activities and Identification of Hazardous Substances ............................ 2

3.1 Current Use ........................................................................................................................ 2

3.2 Past Use .............................................................................................................................. 3

3.3 Identification of Hazardous Substances Used, Produced or Released at the

Installation ................................................................................................................................... 3

4 Stage 2: Identification of Relevant Hazardous Substances ............................................. 3

4.1 Relevant Hazardous Substances ...................................................................................... 3

5 Stage 3: Assessment of the site-specific pollution possibility ........................................ 5

5.1 Storage, Usage, containment measures and potential risks to the environment ......... 5

5.2 Soil and Groundwater Containment hazards. ................................................................. 9

6 Conclusion .............................................................................................................................. 10

Appendix A - Identification of Hazardous Substances ........................................................... 11

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1 Introduction

To meet the requirements of Article 22(2) of Industrial Emission Directive

(2010/75/EU) and determine whether or not a baseline report is required for the

facility an assessment of chemicals and substances used, produced or released onsite

and considered relevant hazardous substances in the context of Regulations 9(2)(n) has

been carried out.

2 Scope of Report/ Assessment

The assessment follows the stages set out in the European Commission Guidance

concerning baseline reports under Article 22(2) of Directive 2010/75/EU on industrial

emissions:

Stage 1 - Site Activities and Identification of Hazardous Substances

Stage 2 – Identification of ‘relevant hazardous Substances’

Stage 3 – Assessment of the site-specific

The on-site historic landfill is not included within the scope of this assessment. With the

IE Directive, licence activities were amended to include Class 11.5 to account for the

historic landfill which has a total capacity exceeding 25,000 tonnes and has not been

closed in accordance with Article 13 of the Landfill Directive. As part of review

application the licensee is requesting to add activity Class 11.1 to facilitate the

remediation and closure of the landfill. To this end a baseline report has been carried

out for the landfill area of the site. Refer to reports presented in Attachment D of review

application and to Appendix to FIR Point 11.

3 Stage 1: Site Activities and Identification of Hazardous Substances

3.1 Current Use

In operation since 1977, the relevant activities in the First Schedule of the EPA Act

1992, as amended, to which the activity relates are as follows:

1.3 (a) The extraction and processing (including size reduction, grading and

heating) of minerals within the meaning of the Minerals Development Acts

1940 to 1999, where the facility involves a metalliferous operation.

1.3 (b) The extraction and processing (including size reduction, grading and

heating) of minerals within the meaning of the Minerals Development Acts

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1940 to 1999, where the facility involves any other operation where either

the level of extracted or processed minerals is greater than 200,000 tonnes

per annum or the total operational yield is greater than 1,000,000 tonnes,

and storage of related mineral waste.

The licence was subsequently amended on 6th January 2014 under Section 82A(11) of

the Environmental Protection Act 1992 to Industrial Emissions Licence (IEL) status. The

‘Schedule of Activities Licensed’ was amended to include:

11.5 Landfills, within the meaning of section 5 (amended by Regulation 11(1) of

the Waste Management (Certification of Historic Unlicenced Waste Disposal

and Recovery Activity) Regulations 2008 (S.I. No. 524 of 2008)) of the Act of

1996, receiving more than 10 tonnes of waste per day or with a total

capacity exceeding 25,000 tonnes, other than landfills of inert waste.

3.2 Past Use

In the past the Knockumber site was in use for agricultural purposes. There is no

evidence of previous industrial activities.

3.3 Identification of Hazardous Substances Used, Produced or Released at the

Installation

It is necessary to determine whether or not hazardous substances are used, produced or

released in view of deciding on the need to prepare a baseline report. A listing of all

substances used in the day to day operations of the activities is presented in Table G.1

(i) of review application form.

A listing of hazardous substances including volumes stored and how and where they are

stored are presented in Appendix A below. Material safety Data Sheets are readily

available for each of the substances.

4 Stage 2: Identification of Relevant Hazardous Substances

4.1 Relevant Hazardous Substances

Regulation (EC) No 1272/2008 on the classification, labelling and packaging of

substances and mixtures (CLP Regulation) which, as a result of their hazardousness,

mobility, persistence and biodegradability (as well as other characteristics), are capable

of contaminating soil or groundwater and are used, produced and/or released by the

installation.

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A review of Article 3 of Regulation) EC) No 1272/2008 was undertaken and the

following substances have been brought forward from Stage 1 having been identified as

relevant hazardous substances:

Sodium Cyanide

Sodium Ethyl Xanthate

Zinc Sulphate

Danofloat-068

Potassium Isoamyl Xanthate

Copper Sulphate

Chloros (Sodium hypochlorite)

Ultra Low Sulphur Diesel

Kerosene

The substances listed as relevant hazardous substances used at the installation have the

potential to have an effect on soil or groundwater pollution if released into the

environment either in small quantities over time or in large quantities.

The likelihood of the release of these substances into the environment taking into

account the volume of each substance, storage and containment measures in place is

presented in Table below.

Laboratory chemicals and other substances used in workshops identified as being

hazardous in Attachment A have been discounted from the ‘relevant hazardous

substance’ list on account of the small volumes stored and used on site and storage

conditions.

Although hydraulic oil (SAE 20 Plus) and engine oil (Ultra SHPD) as products are not

classified as hazardous in accordance with CLP as per manufacture MSDS these

substances have been included in the assessment of site-specific pollution possibilities

on account of the large volumes stored and used on site.

Lubricants and greases used on site have also been discounted from the ‘relevant

hazardous substance’ list on account of the small volumes stored and used on site and

storage conditions.

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5 Stage 3: Assessment of the site-specific pollution possibility

5.1 Storage, Usage, containment measures and potential risks to the environment

All chemical substances used at the facility are stored in suitable closed, labelled storage

tanks / container, under cover and within secondary containment as shown in table

below.

Substance/Material

Storage / Containment

Sodium Cyanide - Safety and emergency procedures are prepared, risk

assessments are carried out.

- Tanks Internal to building

- All chemical tanks stored in a contained area.

- Daily operator inspections.

- Routine maintenance of pumping systems coordinated

through the maintenance management system (Maximo)

- Regular scheduled inspection of hazardous chemical lines.

- All tanks are covered with a vent open to atmosphere.

- All tanks at atmospheric pressure

- Training and Standard Operating Procedures (SOP’s) in place.

- Detailed risk assessment and material compatibility of the

bunds and tanks are performed at selection and installation.

Integrity testing is performed as set by the licence and

maintenance is carried out as per manufactures instructions.

- Level measurement and high level switches on all chemical

tanks with alarms in the control room.

- Appropriate filling interlocks to prevent overfilling.

- Hot works procedure in place.


- Safety and emergency procedures are prepared, risk















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Substance/Material






Zinc Sulphate




















Danafloat_068 (Pb Aux Collector)




















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Substance/Material






















Copper Sulphate - Safety and emergency procedures are prepared, risk



















Chloros (Sodium

hypochlorite)



- Drums stored with secondary containment on hardstanding.


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Substance/Material


Bulk Storage Ultra Low Sulphur Diesel

- Outer bund of the totally enclosed bunded tank containing a

minimum of 110% of the volume on the inner tank

- High level alarm which will activate a 90dB sounder and

flashing beacon

- Bund is monitored 24/7 with float switches to detect

presence of any liquid

- Flame arrester vent cap on exterior of tank

- Fill points are located in cabinet complete with drip tray

- When filling ullage on tank is checked on TM300 electronic

tank gauge & confirmed prior to filling

- Tank at atmospheric pressure

- Tank sitting on concrete hardstanding

- Hazard labels display on tank

- A weekly inspection is carried out as per IEL Condition 6.10

- Relevant personnel trained in safety and emergency

procedures including handling and of hazardous materials

- Routine maintenance as per manufactures instructions

Bulk Storage Kerosene / Engine Oil / Hydraulic Oil /

- Outer bund of the totally enclosed bunded tank containing a

minimum of 110% of the volume on the inner tank

- High level alarm which will activate a 90dB sounder and

flashing beacon

- Bund is monitored 24/7 with float switches to detect

presence of any liquid

- Flame arrester vent cap on exterior of tank

- Fill points are located in cabinet complete with drip tray

- When filling ullage on tank is checked on TM300 electronic

tank gauge & confirmed prior to filling

- Tank at atmospheric pressure

- Tank sitting on concrete hardstanding

- Hazard labels display on tank

- A weekly inspection is carried out as per IEL Condition 6.10

- Relevant personnel trained in safety and emergency

procedures including handling and of hazardous materials

- Routine maintenance as per manufactures instructions

The main hazards for contamination of soil and groundwater comprise:

Spills resulting in the containment of surface water or soil

Loss of containment from storage tanks

Contaminated runoff on the event of a fire

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The company has implemented measures to prevent and minimise accidental emissions

to the environment including:

Containment measures (bunded facilities)

Fire water Retention Facilities

Fully trained Emergency Response Team (ERT)

Extensive emergency equipment resources

Accident/incident investigation procedures

Procedures for dealing with accidental emissions

Emergency Response co-ordination with local fire services

Extensive fire detection systems (sprinkler & gaseous systems)

The company is certified to OHSAS:2007 and ISO 14001:2004 working towards ISO

14001:2015.

Emergency response procedures prepared in accordance with IEL Condition 9.2 for

potential emergencies which may arise is in operation is presented in Appendix J – 1

A fire water risk assessment (FWRA) conducted in accordance with IEL Condition 3.9.1

is presented in Appendix J – 2.

The responsibilities of management and employees for accident prevention are set out

in written procedures. All employees have access to all the relevant EHS information

including Emergency Response Procedures, Task Specific Risk Assessments, SOPs, work

instructions and SDS’s.

The necessary resources are made available for training of management and employees

in the prevention of accidents through task specific training.

Detailed risk assessment and material compatibility of bunded structures and storage

tanks are performed at selection and installation.

Integrity testing of all bunded structures is performed as set by the licence and


Spill kits for the containment of diesel and oil spills and chemical spills is maintained

onsite.

Refer to Table I.8 (i) BREF on Emission form Storage presented in Appendix to FIR Point

13.

5.2 Soil and Groundwater Containment hazards.

There has been no pollution causing incident at the facility which has resulted in the

release of the relevant hazardous substances to soil and groundwater.

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All surface runoff is directed to the site drainage system which is part of the on-site

closed-loop water management system.

Concrete hard standing in chemical unloading and transfer areas prevents any potential

spills from reaching soil or groundwater.

Due to the containment measures in place and good site management practices it is

considered a very low risk of discharge of substances listed to the environment and in

particular to soil or groundwater exists during normal and routine operations.

Abnormal operating conditions which may give rise to pollution of soil or groundwater

is also considered. Taking into account design, risk assessment and HAZOP’s carried out

prior to purchasing and installation of chemical storage tanks, leak detection systems,

filling interlocks to, preventative maintenance schedules and measures the Company

has implemented to prevent and minimise accidental emissions to the environment will

ensure that the risk of release of any hazardous substance to soil or groundwater in

minimised or eliminated.

In the event of cessation of site activities, the site will be closed in accordance with

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

presented within Attachment K. An Environmental Liabilities Risk Assessment has also

been carried out in accordance with IEL Condition 12 and is presented in Attachment K.

Both the CRAMP and ELRA is updated annually or as required throughout the

operational life of the installation. These measures will ensure that potentially polluting

substances, if any, are removed from the site in a manner that does not pose significant

risk of pollution to soil or groundwater.

6 Conclusion

There is no indication of pollution of soil or groundwater consistent with current and

historic land use.

The existing facility is designed to ensure the protection of soil and groundwater. All

materials handling is undertaken indoors with secondary containment. Mitigation

measures are in place to prevent spillages / overfilling and therefore a relatively low

risk of soil or groundwater pollution arising during normal operations.

The design of bulk chemical / substance storage facilities combined with good

environmental practices onsite as well as emergency response procedures will ensure

the risk of any unplanned events will be minimised.

It is clear that due to containment and control measures in place to ensure that

contamination of soil and groundwater does not occur, the likelihood of or potential for

contamination of soil or groundwater is extremely low. It is therefore concluded that a

baseline report is not required.

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Appendix A - Identification of Hazardous Substances

Substance/Material CAS number

Amount Stored (tonnes)

Storage Location / Use

Hazard Statement

Sodium Cyanide 143-33-9 15.0 Process Chemical stored in contained area

H290 / H300 / H310 / H331 / H 370 / H372 / H410


140-90-9 20.0 Process Chemical stored in contained area

H228 / H302 / H311 / H317 / H314 /H400 / H410

Zinc Sulphate (Sulphuric Acid, Zinc Salt)

7446-19-7 10.0 Process Chemical stored in contained area

H302 / H318 / H410

Danafloat_068 (Pb Aux Collector)

61792-48-1 53378-51-1

141-98-0 1310-73-2

10.0 Process Chemical stored in contained area

H302 / H314 / H411


928-70-1 2720-73-2

71769-53-4


H228 / H302 / H311 / H317 / H314 / H411

Copper Sulphate

7758-95-7 7786-81-4


H302 / H315 / H318 / H317 / H332 / H334 / H341 / H350i / H360D / H372 / H373 / H400 / H410

Chloros (Sodium hypochlorite)

7681-52-9 200L Process Chemical stored in contained area

H290 / H314 / H318 / H335 / H400

Ammonia solution GPR 1336-21-6 20 L Laboratory Chemical stored in segregated bunded area

H314/ H335/ H400

Arsenic AAS Standard Solution Hydrogen chloride Diarsenic trioxide

7647-01-0 1327-53-3

100 mls Laboratory Chemical stored in segregated bunded area

H350/ H300 /H314 H410/ H331

Chromium AAS Standard Solution

7697-37-2


H272 /H314/ H350i H317 /H400 /H410

Cyanide ISE Calibrating Solution

151-50-8 100 mls Laboratory Chemical stored in segregated bunded area

H302/ H312/ H332 H412

Lead acetate-3-hydrate 6080-56-4 1 kg Laboratory Chemical stored in segregated bunded area

H351 H360- Df H373 ** H400/ H410

Mercury AAS Standard Solution

7697-37-2 10045-94-0


H272/ H314 /H331 H373 ** H400/ H410

Potassium permanganate extra pure

7722-64-7 500 g Laboratory Chemical stored in segregated bunded

H272/ H302 /H400 H410

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Substance/Material CAS number

Amount Stored (tonnes)

Storage Location / Use

Hazard Statement

area Silver AAS Standard Solution

7697-37-2 7761-88-8


H272/ H314 /H314 H400 /H410

Tetraethylenepentamine, Tech

112-57-2 500 ml Laboratory Chemical stored in segregated bunded area

H312/ H302/ H314 H317/ H411

Zinc AAS Standard Solution

7697-37-2


H272 /H314/ H400 H410

Ultra Low Sulphur Diesel Diesel Oil Naphthalene

68334-30-5 91-20-3

Capacity for up to 70,000

litres

Mobile Fleet – bulk bunded storage

H304 / H315 / H332 / H351 / H373 / H411

Kerosene 64742-81-0 Capacity for up to 10,000L

Heating Oil Fleet – bulk bunded storage

H226 / H304 / H315 / H336 / H411

Ultra SHPD 15W-40 phosphorodithioc acid

68649-42-3


litres

Engine Lubricant Fleet – bulk bunded storage

H315 / H411

SAE 20 Plus phosphorodithioc acid


litres

Hydraulic Oil Fleet – bulk bunded storage

H315 / H318 / H411

Castrol Alphasyn T 220 Tricresyl phosphate

133075-5

880 litres Stores Compound / Workshops in contained area

H312/ H302 /H411

Castrol EPX 80W-90 n/a 510 litres Stores Compound / Workshops in contained area

H412 /H302/ H311 /H330 H314 /318 /H317 /H373 H304

Castrol Tection T15W-40 phosphorodithioc acid

68649-42-3

20,000 litres Stores Compound / Workshops in contained area

H304 H315 H318 H411

740 Heavy Duty Rust Guard Stoddard Solvent Heptane Petroleum gases

8052-41-3 142-82-5

68476-86-8

1700 g Stores Compound / Workshops in contained area

H312/ H315/ H350 / H400/ H410

752 Cold Galvanizing Compound Methyl ethyl ketone, Xylene, Ethylbenzene Zinc, Stoddard Solvent Actone, Petroleum gases

78-93-3 1330-20-7 100-41-4

7440-66-6 8052-41-3

67-64-1 68476-86-8

9 Kg Stores Compound / Workshops in contained area

H312/ H315/ H350 / H400/ H410

MOBIL SHC GEAR 46m LONG-CHAIN ALKYL AMINE

n/a 80 litres Stores Compound / Workshops in contained area

H330 / H311 / H302 / H317 / H400 / H410 / H373 / H314

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Documents

Appendix to FIR Point 15 - Environmental Protection Agency · Danafloat_068 (Pb Aux Collector) - Safety and emergency procedures are prepared, risk assessments are carried out. -