Ztd TMS Environment Ltd 53 Broomhill Drive Tallaght Specialists in Laboratory analysis,

environmental consultancy

monitoring and Dublin 24

Phone: + 353 - 1 - 462 6710

Administration, Office of Licence and Guidance, Environmental Protection Agency PO Box 3000, Johnstown Castle, CO Wexford.

27th April 2005

Fax: + 353 - 1 - 462 6714 nfo@tmsenv ie

Receiwed 2 7 APR 2005

Re: Application to the Environmental Protection Agency by Lagan Cement Ltd for an Integrated Pollution, Prevention and Control Licence for the Lagan Cement Ltd plant at Killaskillen, Kinnegad, CO Meath.

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MAIN FILE .- Dear Sir / Madam

We act on behalf of Lagan Cement Ltd (IPC Licence Reg No submit an Application for an Integrated Pollution, Cement Works under Classes 10.1 ‘The Production of Cement’ W ~ k l . 1 ‘The recovery or q..(...) disposal of waste in a facility, within the meaning of the Act of 1996, which facility is connected or associated with another activity speciJied 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’ of the First Schedule of the Protection of the Environment Act, 2003.

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Lagan Cement Ltd propose to burn Meat and Bone Meal (MBM) as a renewable fuel source at their cement manufacturing facility in Kinnegad, CO Meath. MBM is classified as a non- hazardous waste in the European Waste Catalogue and Hazardous Waste List under Chapter 2 Wastes from Agriculture, Horticulture, Aquaculture, Forestry, Hunting and Fishing, Food Preparation and Processing as 02 02 02 animal-tissue waste. The burning of MBM in a cement plant as fuel is therefore classified as co-incineration of waste and the activity will therefore be regulated under the terms of the Waste Incineration Directive (2000/76/EC). It is planned to bum up to 50,000 tonnes of MBM annually in the plant and this will result in replacing up to 45% of coal currently being burned at the plant. The proposal to use MBM as a fuel source at the plant will not change the cement manufacturing process in any way.

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All MBM transported to the site will have been processed at 133OC for 20 minutes at 3 bars pressure in a Department of Agriculture, Food and Rural Development (Department of Agriculture) approved rendering plant as is required by Regulation EC No 1774/2002 laying down health rules concerning animal by-products not intended for human consumption.

The burning of MBM as a renewable fuel source at Lagan Cement will result in an increase in energy efficiency and a decrease in mass emissions of greenhouse gases, particularly CO2

Registration No. 217750 Directors: I Shanahan (Managing), P Wrobel, E Shanahan

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from the plant. Lagan Cement will in effect be replacing fossil fuels with a renewable, carbon-neutral fuel, MBM and will in turn be making a significant positive contribution to the National Climate Change Programme by reducing their CO2 emissions to atmosphere.

A formal letter of notification has been sent to Meath County Council in order to meet the notification requirements of section 87( l)(a) of the Environmental Protection Agency Act, 1992 (as amended). This letter detailed the documentation submitted as part of the Licence Application and included copies of the Newspaper Notice and Site Notice as required by the Regulations. An application for Planning Permission for the proposed development has been submitted to Meath County Council together with an Environmental Impact Statement.

The fees for the IPPC Licence Application have been calculated at €30,473. This figure has been obtained from the Schedule of IPPC Licencing fees as set out in the EPA (Licencing Fees) (Amendment) Regulations 1994 to 2004. Since Lagan Cement Ltd employ more than 50 people at their facility it is classed as a Large Activity as specified in the Regulations.

Class of Activity: 10. Cement €16,506 11. Waste €13,967

The fees for both activities are summed for the IPPC Application.

We request that the Agency should use their discretionary power under Article 13 of the Environmental Protection Agency (Licensing Fees) Regulations, 1994 to refund a portion of the fees due in respect of this Application. In particular it should be noted that there is no change to the Cement Manufacturing Activity (Class 10) and furthermore the existing IPC Licence was reviewed less than 18 months ago. This proposal deals with a change in fuel and there is very limited consideration required in respect of the manufacturing and operational activities at the site.

I enclose the following documentation as part of this application for an IPPC Licence:

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15 Copies of the EIS and Non-Technical Summary of the EIS for the proposed development; 1 original and 5 copies of the Planning Application for the proposed development; 1 original and 5 copies of the IPPC Licence Application; 1 electronic (CD ROM) copy of the submissions 6 copies of an information VideoDVD and consultation information circulated to the local community and interested parties; A cheque for €30,473 being the relevant fee for this application.

I trust that we have provided all of the information which you require and I look forward to an early response in respect of the Application.

*fth/ Tom Ryan TMS Enviro ent Ltd r”

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L-, 1 I_ -

Lagan Cement News e New Environmental Measures at Lagan

Lagan Cement Limited A Lagan Company

October 2005 .. . .

Lagan Cement and Lagan Asphalt are working together to introduce a number of new positive environmental

measures at their plants in Killaskillen, near Kinnegad. Both companies are collaborating on a new inclusive'Good

Neighbour Environmental Plan'.

In order to foster good relations with neighbours and promote goad environmental practice, both companies will seek to

improve on any aspeas of the buslness that might have potential to cause inconvenience or nuisance to our neighbours.

The plan will provide for;

- Implementation of new technologies which reduce environmental impact

8 Review of logistics and procedures to reduce envhnmentd impact

Improved communicotilon with neighbours - -

Lagan will also be inviting neighbours into the facility in the near future to update them on the plan and the first

of their new objectives.

New Technology New Reverse Warning Systems All vehicle reversing horns, including dumpers, loading shovels and transit vehlcles on both Lagan Cement and Lagan Asphalt sites are to be changed to a new type of reverse warning system, which ha5 a reduced tonal impact.

The new, environmentatlyfriendly units operate at a level of 105 decibels at a distance of 1 metre and go decibels at 7.5 metres but at 100 metres the output is negligible with no long distance carry. At night, the output is further

reduced when vehicle sidelights are turned on.

There should therefore be greatly reduced noise levels audible from neighbouring properties.

New Rock Breaking Machinery lagan has begun uslng a "Citybreaker". ThIs carries out the rock-breaking functlon Lagan requires, but with

significantly reduced noise output levels, as the machinery is fitted with integrated soundproofing. These are designed to operate in congested areas like cities, and cau5e minimal disturbance compared to the'normal'type.

Only these "Citybreakers" are to be used on the facility effective imrnedlately. Furthermore, no rock breaking actlvltles are to commence before 08:ooam, abo effective immediately.

We expect that neighbours will experience a significant reduction in noise levels from rock breakers.

New Water Pump

The water pump in the quarry has been changed to a 'low noise' pump.

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New Procedures Dust abatement A number of new procedures have been put in place to minimise dust disturbance;

I The procedurefor monitoring the dd// rig dust abatement uperation when it is in use, wlll Incorpwafe daily inspection and sign off &y lagan's Quarry Supervisor to ensure that if is in operation and workrng correctly.

Drillling services providers and rig operuton have been rleurly instructed that Lagan Cement will not talerate any drilling a d M y which results in dust levels whlch have potentid to impact on neighbours, and any breaches in this regard will result In the contractor being disciplined.

Noise abatement A number of new procedures have been put in place to minimise noise disturbance;

The lntemm system will not be used at lagan Asphalt before 0g:mrn effective Immediately. An ulternative method of communication with drivers is also to be established, with the intention to replace the Intercom system in the near future.

U All unusual or additional noise sources are to be reported as a matter of'high uqcncy'and given a priority response by the Mechunlcal department and the corrective maintenance carried out as U matter o f urgenq.

Wells and Water levels Lagan Cement continues to monitor local well levels and i5 aware that some wells do show a seasonal draw down, however low well/reservoirs/riwrs levels are being experienced throughout the country.

Slnce the first reports of dry wells by 'neighbours in summer 2004, new wells haw been bored for a number o f

residences.Thls has includeda number of new wells drilled for properties that were built after quarrying began and had inadequate wells originally provided.

These were drilled as a good neighbour gesture and Lagan Is happy to continue to discuss individual well levels

with midents on a one to one basis.

Corn m u n kat ion Lagan Cement and Lagan Asphalt are committed to a good neighbour policy. This not only mean5 meeting our

requirements in respect of the IPPC licence (in the case of Lagan Cement) but also going over and above this to

ensure that our impact on neighbours is minimised.

We will be endeavouring to keep neighbours up to date with the progress of our Good Neighbour Environmental

Plan as well as continuing to respond to specific complaints though the correct channels.

We will be inviting neighbours In to discuss the Plan and any matters they would like to raise. In the meantime,

if you have any queries, please do not hesitate to contact us.

Lagan Cement Killaskillen, Klnnegad, Co. Meath

Tel: 04479200 Fax: 04479201 Email: infobhgancement.wm Web: www.lagancement.cmn

Lagan Cement Limited A Lagan Company

www.laaonr ernent.com I

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