kmk metals recycling ltd

hl ETAL S. R E C Y C L I N G

KMK Metals Recycling Ltd. Precious and Non-Ferrous Metals Electronic Scrap and Metallic Residues Hazardous Metal Waste

Electronic Cops

Environmental Licensing Programme

Office of Environmental Sustainability

05/07/19

Re: Further Information Request (Reg. No.: PI 076-01)

Cappincur Ind. Est. Daingean Road Tullamore Co. Offaly Ireland

Telephone 057-934 1634

Telefax 057-932 0056

E-Mail [email protected] k. ie

Website www. km k. ie

EPA Waste Licence WO1 13-04

Dear Sir or Madam,

Further to issuing of "I-App-RFI Reg.I0(2)(b)(ii) or ArtI4(2)(b)(ii) " dated

05/06/2019 on EDEN as part of IED Licence Application Reg. No. P1076-01; KM[K Metals Recycling

Ltd. submit the following response:

1) The Baseline Noise Report submitted as an appendix to the EIAR refers to traffic noise at the noise

sensitive locations but does not identijj the potential sources of noise from the installation activities.

Clarijj the potential sources of noise at the installation.

The potential sources of noise at the installation are clarified in Appendix I .

2) In relation to site operation hours please clarifj the following:

(a) The licence application states that the site will operate Monday to Friday dam-2pm and 2pm-

10pm. Clarijj that these hours are correct.

This is correct. The site will be operational from 6am - lOpm Monday to Friday; 6am - 2pm as

part of shift one and 2pm - lOpm as part of shift two. Operations are also intended for one shift

on Saturdays fi-om 6am - 2pm. No operations will take place on Sundays or Bank Holidays.

@) What are the hours of waste acceptance for the installation?

The hours of waste acceptance for the installation are the same as the operational hours listed

above in response to section 2(a).

3) Provide an assessment of the existing and proposed waste activities against the Commission

Implementing Decision (EU) 2018/1147 of 10 August 2018 establishing best available techniques

(BAT) conclusions for waste treatment, under Directive 201 0/75/EU of the European Parliament

and of the Council (notified under document C(2018) 5070).

This assessment has been prepared and is provided in Appendix 2.

Registered Office: Cappincur Industrial Estate, Daingean Road, Tullamore, Co.0ffaly Reg. No. 67176 VAT No. IE 4534857E

Directors K. Kyck M. Kyck

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 06-07-2019:03:57:19

K A K KMK Metals Recycling Ltd. Precious and Non-Ferrous Metals Electronic Scrap and Metallic Residues Hazardous Metal Waste

4) In relation to discharges to surface water please address the following:

(a) Clarifi the number of discharges to storm water. Section 7.7 of the licence

application form states that there is one discharge point (SWl), but Section 2.

Water of the report “Land & soils and water chapters for EL4R”refers to a second

discharge point (S W2).

There is one discharge point from the KMK site - SW1. Monitoring location SW 1

is the location of the last manhole before the surface water drainage line exits the

site, as shown in Figure I below.

From location SWl, the drainage line continues off-site behind the adjacent



Telefax 057-932 0056

E-Mail infobkmk.ie

Website www. kmk.ie


facilities. Monitoring location SW2 is at the discharge point to the field drain. The stormwater at

this point includes discharges from KMK as well as discharges from the adjacent facilities that

connect into this drainage line.

Q

Figure I : Surface Water Monitoring Locations

65) Provide further information on the nature of the stormwater discharged through these two

points.

The stom-water discharged from the site comes from the drainage infrastmcture nn-site, which is

presented in Drawing 1 in the report presented in Appendix 3.

Registered Office: Cappincur Industrial Estate, Daingean Road, Tullamore, Co.offaly Reg. No. 67176 VAT No. IE 4534857E

Directors K. K y c k M. Kyck

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 06-07-2019:03:57:19

IWd\K kl ETA LS * R E C Y C L I N G

KMK Metals Recycling Precious and Non-Ferrous Metals Electronic Scrap and Metallic Residues Hazardous Metal Waste

Ltd,

On KMK’s site all yard and roof water drains to an attenuation tank at the northwest

corner of the site, which has a capacity of 233.7m3 to attenuate excess stormwater

during extreme rainfall events. Overflow from the attenuation tank will discharges

along drainage lines at the back of the site to a silt trap and interceptor at the north

eastern corner, before discharge off-site to the adjoining premises. This in turn

discharges to a field drain.

Monitoring at discharge point SWl was undertaken in March 2019, and the report

is presented in Appendix 3. The following parameters were scheduled: m Total suspended solids, COD, conductivity, pH

Cappincur Ind. Est. Daingean Road Tullarnore Co. Offaly Ireland


Te I efax 057-932 0056

E-Mail [email protected]

Website www. krnk.ie


m Hydrocarbons - mineral oil Metals - chromium, lead, mercury, nickel, arsenic, copper, zinc, iron, aluminium

In summary, the reported results were below the facility permit emission limits and low levels of

metals were reported.

(c) Provide details of any abatement on the SW2 dischargepoint, e.g. oil interceptor, silt trap, etc.

A class 1 interceptor and silt traps have been installed within drainage network as per the enclosed

drainage maps (see Drawing 1, Appendix 3).

(d) What is the distance between the stormwater discharge point($ to the land drain and

confluence with the River Brosna?

The distance between the SW 1 discharge point and the River Brosna is 490m at the closest point.

The distance between the SW2 discharge point to the land drain and the River Brosna is 400m at

the closest point.

5) Please provide an updated Environmental Impact Assessment Report in accordance with the

requirements of Directive 2014/52/EU on the assessment of the effects of certain public and

private projects on the environment and the European Union (Planning and Development)

(Environmental Impact Assessment) Regulations (S.I. 296 of 201 8). The updated EIAR should

include robust assessments of the interactions between impacts on different factors and also of

the cumulative impacts of the discharges from the installations.

This updated report is provided as part of Appendix 4 (Part I & 2).

4) Clarijj which of the emission points to air (A-1, A-2, A-3) are existing and which are proposed.

The emission points to air, whether existing or proposed, are clarified in Appendix 5.



For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 06-07-2019:03:57:19

K A K KMK Metals Recycling Ltd. Precious and Non-Ferrous Metals Electronic Scrap and Metallic Residues Hazardous Metal Waste


Telephone 057-934 1634 7) Provide further information on the type of dust filters that are present or intended

to be installed on the channelled emission points to air. Do these dustfilters comply

with the requirements of BATfor the mechanical treatment of waste, including the

mechanical treatment of WEEE containing mercury in the case of the emission

point from the shredder?

Telefax 057-932 0056

E-Mail infodkm k. ie

Website www.kmk.ie

The type of dust filters that are present or intended to be installed are clarified in

Appendix 6. EPA Waste Licence WO1 13-04

8) What is the timeframe for installing the dustfilters on the emission point from the shredder (A-

2)?

On receival of the IED licence, preparations for installation will begin.

9) Provide an updated ‘Table 4 Stack Emission Details for the Proposed Dust and Mercuy

extraction points at KMK Metals Recycling Facility, Kilbeggan ’’ of the report Air Dispersion

Modelling Assessment for Proposed emission points at KMK Metals Reqcling Facility,

Kilbeggan, so that the coordinates for the three emission points are expressed as six digit easting

and northing GPS Irish National Grid references,

This table has been updated in the report listed as Appendix 7.

10) A screening for Appropriate Assessment was undertaken on 16th May 2019 and the Agency

determined that an Appropriate Assessment of the proposed activity is required. You are thereby

required to submit a Natura Impact Statement, as defined in Regulation 2(1) of the European

Communities (Birds and Natural Habitats) Regulations 2011 as amended. You are furthermore

advised to refer to the document ‘Appropriate Assessment of Plans and Projects in Ireland -

Guidance for Planning Authorities’, issued in 2009 by the Department of the Environment,

Heritage and Local Government, and revised in 2010. This document is available on the

National Parks & Wildlife Survive website at:

http://www.npws.ie/sites/defaultjfiles/publications/pdf~PWS 2009 AA Guidancemdf

A Natura Impact Statement has been prepared and is provided in Appendix 8.



For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 06-07-2019:03:57:19

METALS. R ECY CL I I'YG

KMK Metals Recycling Ltd. Precious and Non-Ferrous Metals Electronic Scrap and Metallic Residues Hazardous Metal Waste


Telephone 057-934 1634 In addition to the above, please also provide an updated non-technical summary

(Application Form, and EIS where applicable) to reflect the information provided in your

reply, insofar as that information impinges on the non-technical summary.

Non-technical summaries have been updated to reflect the information provided. The updated

non-technical summary of the IE Application Form is provided in Appendix 9. The updated

non-technical summary of the EIAR is provided in Appendix 4 .

Telefax 057-932 0056

E-Mail infodkm k. ie

Website www. km k. ie


1 hope the above is to your satisfaction. Please do not hesitate to contact me if you require any further

information.

Yours Sincerely,

W Olivia Brennan

Compliance Manager

Registered Office: Cappincur Industrial Estate, Daingean Road, Tullarnore, Co.Offaly Reg. No. 67476 VAT No. IE 4534857E


For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 06-07-2019:03:57:19

For

insp

ectio

n pur

pose

s only

.

Conse

nt of

copy

right

owne

r req

uired

for a

ny ot

her u

se.

EPA Export 06-07-2019:03:57:19

kmk metals recycling ltd

Documents