Environmental Impact Statement · This Environmental Impact Statement ... abatement unit is...

Industrial Emissions Licence Application

To

Environmental Protection Agency

Environmental Impact Statement

In respect of Installation of a Regenerative Thermal Oxidiser (RTO)

at Kingspan Insulation Ltd.

Castleblaney, Co. Monaghan

Prepared by AWN Consulting

June 2015

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NON-TECHNICAL SUMMARY Kingspan Insulation Limited

Kingspan EIS NTS, Page 1

NON-TECHNICAL SUMMARY 1.0 INTRODUCTION This Environmental Impact Statement (EIS) has been prepared by AWN Consulting Ltd (AWN) on behalf of Kingspan Insulation Limited (Kingspan), Castleblayney, County Monaghan. It relates to the planned introduction of a regenerative thermal oxidiser (RTO) at the facility. Whilst not required to support a planning application, this EIS has been prepared to support the Industrial Emission (IE) Licence Review Application for the facility (IE Licence no. P0057-02). As the Kingspan facility already exists with fully consented planning permission, the EIS considers current operations to comprise the baseline for assessment purposes, describing the current condition of the environment. Any future impacts, both positive and negative have been evaluated during construction and with the proposed thermal oxidiser in operation. The EIS has also considered a number of minor modifications proposed to the existing site in connection with the relocation of two other emission points not connected to the oxidiser unit and adjustments to future proposed Industrial Emission licence condition requests. Kingspan produces insulation board for use in all elements of the building industry and building types. The insulation is a vital component of modern buildings helping to reduce energy consumption by preventing the loss of heat (or in warm conditions, reducing its ingress). Kingspan is a leader in its field and exports products around the world with a significant contribution to both the local and national economy. Environmental, health and safety activities are managed through the site’s integrated management system which is certified to ISO 9000 (for quality), ISO 14001 (for environmental management) and OSHAS 18001 (for occupational health and safety). Requirement for an EIS A number of organic chemicals are used in the production process. These chemicals can lead to the generation of emissions, principally releases of volatile organic compounds or VOC that at predicted concentrations in the environment have no significant direct impact on human health. The principal emissions include chemical emissions from the process line and drying ovens and dust from trimming activities. A high efficiency dust abatement unit removes dust from extracted air before release to the environment. Like many domestic, commercial and industrial activities, however, the VOCs can contribute to the formation of ozone in the atmosphere and subsequently have the potential to affect air quality. The planned introduction of the oxidiser unit will lead to a significant reduction in emissions of VOC from the site. The removal of VOCs through the installation of a suitable VOC abatement unit is required in order to reduce emissions from the facility and ensure compliance with the current IE licence. Consultation and Scoping The EPA provided screening opinion on the requirement for an EIS and has requested an EIS is prepared to support the Industrial Emissions Licence Review Application that seeks to obtain permission to operate the oxidiser unit. The oxidiser unit does not require planning permission under permitted development already granted by the local planning authority, Monaghan County Council. The EPA, rather than the planning authority is hence the competent authority in determining the acceptability of the EIS, informed by the views of statutory and non-statutory consultees.

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Letters of consultation and a scoping document were issued to;

The Environmental Protection Agency (EPA);

The Planning Department at Monaghan County Council;

Irish Water (IW);

Inland Fisheries Ireland (IFI);

The Department of Arts, Heritage and the Gaeltacht including the National Parks and Wildlife Service (NPWS); and,

Health Service Executive Dublin North East (Cavan/Monaghan). 2.0 DESCRIPTION OF THE DEVELOPMENT The proposed regenerative thermal oxidiser (RTO) is to be located at the existing Kingspan facility in the town of Castleblayney, Co. Monaghan. The site is located approximately 1km south-west of the town centre and 26 km north-west of Dundalk. The facility is part of the Bree Industrial Estate located adjacent to the N2 National Primary Road which runs from Dublin to Derry. The facility typically operates from 8am-10pm Monday to Thursday, 8am-6pm Friday. There are currently no activities at site on Saturday or Sunday but production is run to meet market demand and can potentially operate 24 hours a day, 7 days a week. The site location is illustrated in Figure 2-1.

Figure 2-1 Site Location Map

The closest dwellings are located in the Bree townland to the north-east of the site and directly across the Coill Darach Road adjacent to the site boundary. Housing is also located approximately 200 m from the site to the north-west (The Willows). The site was previously accessed from the north-east via the Bree housing estate, however, recent road improvements and direct access to the N2 Castleblayney bypass adjacent to the facility

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have enabled traffic to the industrial estate to be rerouted away from the residential areas. The immediate site locality, site boundary and location of the regenerative thermal oxidiser is illustrated in Figure 2-2.

Figure 2-2 Site Boundary and Location of RTO

The Kingspan facility buildings are the main structures within the industrial estate. There are smaller warehouse and administration buildings owned by Shabra adjacent to the site to the west and there is an industrial manufacturing facility to the north. The site buildings comprise an administration building, a main manufacturing and link building, a gluing/bead manufacturing building and a storage/distribution warehouse. Description of the Manufacturing Process Two types of insulation board are made at the Kingspan facility both of which use a similar means of production but differ in their chemical composition. Two aluminium and paper foil facings provide the board surface which the plastic component chemicals when mixed, expand in between, to form the board, curing into a rigid cell structure. A gas blowing agent with no ozone depleting potential is formed from a liquid additive to create the closed cell structure of the insulation with the blowing agent encapsulated within the board structure. Blowing agents used include a hydrocarbon compound with a chlorine element. The board is then cut to size using saws (rebating and main cutting) and in the case of one type of board, phenolic board, cured in an oven.

Insulation beads, for pumping into existing cavity wall spaces, and integrated plasterboard/insulation products are also produced at the site in a separate building by using steam to expand plastic pellets.

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Description of the Regenerative Thermal Oxidiser (RTO)

It is proposed to install an RTO at the currently operational facility. The unit will be installed towards the north-west of the site in an area furthermost from housing in the Bree townland. The equipment footprint will be approximately 5 m wide, 18 m in length and less than 4 m in height except for the absorber unit and stack. The stack will extend to an overall height of 12 m and the absorber will extend to 10 m above ground level. All equipment other than the stack and absorber will be below the adjacent warehouse roofline. The equipment will be located on an existing concreted area and the adjacent buildings will shield it from public view on all sides. In addition to the RTO, some increases are proposed to the heights of the stack A2-5 and A2-12. The stacks are currently at a height of 9.5 m and are proposed to be increased to a maximum height of 14.8 m to enhance the dispersion of emission components once released into the atmosphere. The RTO will treat organic compounds generated in the manufacturing process and specifically from Stack A2-1 (comprising sampling points A2-1a and A2-1b). The compounds are broken down within a carefully controlled system in the presence of heat and air into combustion products including carbon dioxide and water. Oxides of nitrogen and carbon monoxide can also be produced from the combustion process. The combustion of one of the VOC’s will generate hydrogen chloride that will be removed by an absorber (acid gas scrubber) where the gas is contacted with a water based solution. Treated emissions will then be discharged to atmosphere from the stack. A new wastewater discharge will also occur from the introduction of the RTO and scrubber unit. The effluent will comprise a saline solution resulting from the absorber unit and a quench system used to prevent the formation of complex, chlorinated hydrocarbon products. The proposed RTO abatement system consists of the following components:

1. Inlet stream - Raw gas consisting of VOC to be treated. 2. Suction Fans to draw extracted air from the production plant into the treatment unit. 3. Combustion chamber with ceramic bed matrix that combusts the VOC and converts

them into combustion products, principally water and carbon dioxide. 4. A burner that provides heat into the combustion chamber (rating of less than 150

Kilowatts, using clean burning Liquid Petroleum Gas (LPG) fuel). 5. Cooling quench system (to cool gas prior to the acid gas scrubber system and

prevent complex chlorinated hydrocarbon compounds being generated). 6. Washing column dosed with a sodium hydroxide solution (an acid gas scrubber

system that removes acidic components including hydrogen chloride before being discharged to air)

7. Exhaust stack with appropriate monitoring platform, access and sampling points. For context, the heat input (and fuel demand) for the RTO is equivalent to around five domestic combi boilers (of 30 KW size). An illustration of the RTO unit is provided in Figure 2-3.

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Figure 2-3 Illustrative image of an example regenerative thermal oxidiser (note: illustration does not include an absorber unit)

VOC removal efficiency will be maximised by ensuring the design is optimised for time, temperature and turbulence. Additionally, the amount of oxygen affects the rate of oxidation. The design of the RTO ensures that turbulence inside the thermal oxidiser will promote good mixing of oxygen and VOCs at the specified temperature to deliver complete and clean combustion conditions. A removal efficiency of 99.9% or greater can be anticipated from the unit. This means the residual VOC load discharged to air will be up to a thousand times less than the load in the extracted air from the factory. This will have a significant beneficial impact on local air quality. An operating temperature of greater than 850oC and residence time of greater than 0.5 seconds will ensure clean combustion and removal of VOC components that achieve compliance with Best Available Technique (BAT) emission levels defined by the Environmental Protection Agency (EPA). Energy is recovered within the unit by recovering heat from the back end of the process and returning it to the start, thereby minimising fuel consumption and combustion related emissions including carbon dioxide with global warming potential. Energy consumption has been optimised using a high performing honeycomb matrix within the thermal recovery unit. The main fan, which is the laden air suction fan, will be housed in a soundproofing cabin to minimise noise from the RTO unit. Pre-commissioning, Commissioning, Start up and Training An acceptance test will be carried out to confirm the operation of the RTO unit meets design performance. Testing will include the evaluation of process parameters, such as operating temperature and residence time, and emission values for discharges to sewer and air.

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Technician training will be provided to Kingspan staff by the RTO provider in the period between pre-commissioning and RTO start-up and acceptance. Control Systems The operation of the RTO will be completely automated, connected to the factory and installed with a remote Ethernet link direct to the manufacturer. The Ethernet link will enable specialist support to be instantly available to monitor operating parameters and modify the RTO’s operation, if required. Controls include automated start-up and shut-down, as appropriate. Critical alarms will be programmed to directly shut-down the unit should it not operate with strictly defined performance parameters. In the event of a production interruption, emission control measures continue to operate. The abatement units onsite are started prior to and shut down after production begins. In the case of the RTO, an appropriate warm up period will apply (between 30 minutes and 1 hour) to ensure the unit is at operational temperature upon commencement of board production. A bypass on the RTO unit is present to reroute emissions around the abatement plant directly to stack A2-14 should the RTO require to be shut down. No production will continue to occur with the RTO unit offline. Construction and Installation Programme The current programme of works anticipated for the installation of the oxidiser unit is as follows:

June 2015: Contract award to preferred vendor.

August 2015: Commencement of civil engineering works comprising foundations and connections to onsite utility services including water, gas and sewer.

December 2015: Delivery and installation of thermal oxidizer unit.

December 2015: Commissioning and commencement of oxidiser operation. Construction work will be carried out during regular daytime hours and night-time activity is not anticipated. 3.0 ALTERNATIVES Alternative locations and techniques have been reviewed to identify the BAT for the treatment of VOC emissions at the Kingspan Facility. The abatement unit is required to achieve compliance with emission limits of VOCs from emission point A2-1 (comprising sampling points A2-1a and A2-1b). The initial method of VOC emission control is through the careful management of chemical mixing and injection rates in the process. This is achieved through a computer controlled process ensuring the correct product recipe is used in the board’s manufacture, helping to reduce the level of excess organic component and achieve the required product quality. Any residual VOC is then extracted and requires treatment prior to discharge to air. Alternative Locations The location for the RTO has been determined on the basis of:

Available footprint for the unit on a site that is fully utilised by buildings, access roadways and raw material storage;

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The proximity to the source of emission as ducting is required between the production line and the abatement unit;

Availability of a suitable tie-in point to the public sewer to receive the effluent generated by the RTO unit;

Proximity to liquefied petroleum gas (LPG) storage which provides a clean burning fuel for the RTO; and

Safe location with preference towards a location away from housing.

Alternative locations including the staff car-park, adjacent to the existing dust extraction unit and internally were considered but it was determined that the selected external location is sufficiently close to the production activity, provides adequate dispersion of LPG in the event of a gas leak, is close to utility tie-in points and does not interfere with the continued safe operation of the site including safe vehicle access. Technology Assessment BAT identifies the most appropriate emission reduction technique that provides the highest level of protection to the environment as a whole, taking into account technical and economic considerations. A summary of all the available abatement options for the control of VOC emissions is included in Appendix A to the EIS. The Appendix describes the relative merits and disadvantages of a number different techniques, including, but not limited to, membrane separation, condensation, adsorption, thermal oxidation and flaring. Following an initial screening assessment, only two abatement techniques were considered suitable for further evaluation based on the nature of VOC, their concentration and the volumetric flows currently emitted from Stack A2-1. They are adsorption and thermal oxidation.

Adsorption, in effect, is a concentration step to either reduce the footprint of another treatment system onsite or a means of capturing the VOC for subsequent offsite treatment. Offsite treatment may include thermal regeneration (and associated control of emissions through thermal oxidation) or landfilling of the adsorbent media. Onsite thermal oxidation is considered to represent the only practical option that gives rise to the greatest level of protection to the environment as a whole, when both direct emissions from site and indirect emissions offsite are considered. Selection of Thermal Oxidiser The types of thermal oxidiser available include:

Direct or straight thermal oxidation (with limited energy recovery);

Regenerative thermal oxidation (where energy is recovered from the ceramic chambers of the oxidiser to preheat the incoming gas stream); and

Recuperative thermal oxidation (where energy is recovered in a similar way to regenerative systems but using heat exchangers).

These systems will be able to achieve the required removal efficiencies and attain compliance with the stack emission limit values. The systems differ in the method and level of energy recovery achieved from the thermal oxidation process. Fuel consumption, running costs and emissions of the carbon dioxide are reduced the more energy is recovered. Regenerative thermal oxidation provides the highest level of energy recovery practical for the volume flows requiring treatment at the Kingspan facility. Heat recovery from the exhaust

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stack is considered unlikely as a quench system should be used to rapidly cool the exhaust gas and prevent the potential for reformation reactions to take place that can produce complex chlorinated organic compounds. The chosen RTO unit is small in scale without a concentration reduction step and it is considered further reductions in size will have limited benefit whilst potentially doubling the investment required. A regenerative thermal oxidiser (RTO) has been identified to represent BAT for the treatment of VOC at the Kingspan facility. A wet scrubber following thermal treatment is considered BAT to minimise emissions of acid gas by-products. A quench system will also be deployed to prevent complex, chlorinated hydrocarbon compounds being formed and to control the incoming gas temperature into the wet scrubber. 4.0 SCOPING PROCESS & ASPECTS EVALUATED A Scoping report and letter of invite to comment on the proposals was issued to the following consultees on the 7th April 2015:

The Environmental Protection Agency (EPA);

The Planning Department at Monaghan County Council;

Irish Water (IW);

Inland Fisheries Ireland (IFI);

The Department of Arts, Heritage and the Gaeltacht including the National Parks and Wildlife Service (NPWS); and

Health Service Executive Dublin North East (Cavan/Monaghan). The scoping document identified the aspects proposed, the methodology of assessment and aspects that were proposed not to be evaluated. At the time of issue of this EIS, only the IFI and HSE have formally replied to the invitation to comment on the proposed scope of the EIS. A consultation meeting has been held onsite with the Environmental Health Officer for the HSE Dublin / North-East, Cavan & Monaghan region. IFI noted that the site lies within the catchment area of the River Fane, which feeds Lough Muckno. Potential impacts cited include the treatment of wastewater associated with the RTO and surface water run off during the construction period. IFI recommended surface waters should be treated onsite in order to minimise the impact on water quality and habitat degradation. Aqueous effluent discharged to sewer will be treated via the wastewater treatment plant at Castleblayney and IFI noted it should be ensured that sufficient capacity is demonstrated at the wastewater treatment plant for such treatment. The HSE did not raise any concerns in relation to the proposed development. Aspects Included in the EIS The aspects covered in this EIS and summarised in the following sections of this Non-Technical Summary are:

Chapter 5: Population & Human Health

Chapter 6: Material Assets

Chapter 7: Landscape & Visual

Chapter 8: Biodiversity

Chapter 9: Soil, Geology & Hydrogeology

Chapter 10: Water & Hydrology

Chapter 11: Air Quality & Climate

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Chapter 12: Noise & Vibration

Chapter 13: Waste Management

Chapter 14: Accident Prevention Structure of the EIS Chapters For each aspect included in the EIS, the following information is provided:

Introduction

Study Methodology

Receiving Environment

Characteristics of the Proposed Development

Potential Impacts of the Proposed Development

Do-Nothing Scenario

Remedial and Mitigation Measures

Predicted Impact of the Proposed Development

Monitoring

Reinstatement

Interactions

Difficulties Encountered The potential impacts of each aspect are then described in the following context:

Quality – positive, neutral or negative

Significance – imperceptible, slight, moderate, significant or profound

Duration – short-term, medium-term, long-term, permanent and temporary Specialist Assessments Additional assessments highlighted within the EIS include a SEVESO review demonstrating that the site is and will remain below relevant assessment thresholds for the assessment of major accident hazards. A flood risk review, appropriate assessment (AA) screening study for biodiversity, air dispersion modelling and noise modelling have also been carried out. Aspects Not Included within the EIS Roads, traffic and transport have not been independently assessed in this EIS but has been considered in Chapter 6 Material Assets. It is considered that minimal traffic increase will be generated as a result of the proposed development either during the construction or operational phases. In addition, recent road improvement works and the opening of direct access from the industrial estate to the N2 will reduce the traffic volume through residential areas adjacent to the site. A SEVESO screening assessment has been carried out which identified that the volumes of chemicals stored on site both prior to and following the introduction of the oxidiser are below defined thresholds with the SEVESO regulations (both SEVESO II and the forthcoming SEVESO III requirements). Therefore, major accident hazards are not independently assessed but are discussed in Chapter 5 Population & Human Health and Chapter 14 Accident Prevention and Response. The introduction of the oxidiser unit will be within the site boundary located on an area of existing hardstanding. It does not represent new development and will not interact with aspects of known archaeology, cultural heritage or architectural heritage.

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5.0 POPULATION & HUMAN HEALTH The impacts, if any, of the proposed RTO on Population and Human Health as defined in the EPA Advice Notes on Current Practice (in the preparation of Environmental Impact Statements) (2003) have been evaluated. In accordance with the above guidance, this chapter has considered the 'existence, activities and well-being of people’ with respect to ‘topics which are manifested in the environment such as new land-uses, more buildings or greater emissions’. Issues examined include:

Demography

Population

Employment

Natural Resources

Landscape Amenity and Tourism

Social Infrastructure There are a number of other industrial units along the boundary of the site, these include; the Shabra Group, who specialise in integrated plastic recycling, repurposing, manufacturing and supply of recycled products and MC-Bauchemie, who specialise in construction chemicals and protection-technologies. Overall lands to the west of the area are mostly in agricultural use while land in the eastern direction has been developed for suburban housing and recreation on the lakeshore of Lough Muckno. Residential development is present immediately to the north of the site and to the north-west. There are no schools in the immediate environs of the site, however there are two secondary and five primary schools within the town of Castleblayney. These schools service the population of the surrounding areas. The nearest General Hospital to the facility is located at the Louth General Hospital, Dublin Road, Dundalk. This is a distance of roughly 35 km from the site by road. The site has good transport infrastructure due to its proximity to the N2 and N53. The M1 motorway, linking Dublin and Belfast is 25 km to the east, accessible via the N53. The current road linking the site and the main transport corridor to other major towns is the N2 which until recently was accessed through residential areas to the north-east. Direct access off the N2 is now open and all staff vehicles and HGVs can access the site via the N2, leading to a significant reduction in traffic through the housing estate and residential areas when leaving or entering the site. The assessment included in the EIS describes the employment statistics for County Monaghan. There has been a significant rise in unemployment in both the County Monaghan area and in the State as a whole between 2006 and 2011. Though the figures for the period between 2006 and 2011 recorded a significant increase in unemployment in Ireland, it is apparent from more recent data that employment is now growing again, though levels of unemployment remain high in Monaghan and are above the State average. In terms of landscape amenity, Kingspan recognise that the landscape, natural heritage and amenities of Castleblaney have an important role to play in contributing to a high quality of life for residents and a positive experience for visitors. Further discussion of impact on landscape amenity is presented in Chapter 7 Landscape and Visual. During construction works for the proposed installation, there may be an increased number of HGVs accessing the site, however due to the prefabricated nature of the project the increase in HGVs is predicted to be low. The RTO will run on LPG which will be supplied

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from the existing site storage tank and will require connection into the existing site water supply for the quench and scrubber system. Once installation and commissioning of the equipment is complete, the RTO is predicted to improve air quality emissions; this is detailed further in Chapter 11. Improved access, due to the opening of the connecting road from the N2 to the site, will ensure that both construction and operational vehicles no longer pass residential areas in Bree townland. The main potential impacts on local residences and businesses associated with the proposed introduction will be in relation to potential landscape and visual, air quality and noise and vibration impact. No significant impacts associated with the introduction of the RTO unit have been identified for these aspects. An evaluation of material assets including local capacity to supply water, electricity, fuel, sewer dishcarge and effluent treatment services for the proposed RTO has identified no restrictions in the availability of such services (see Chapter 6) that would otherwise take capacity away from other users. It’s unlikely that the proposed RTO will create demand for additional housing as the main facility is already in operation and the RTO unit will not change the production capacity of the facility. The RTO unit is a highly specialised item of equipment that will be manufactured overseas and imported. No jobs will be created during the construction of the unit. The introduction of the RTO will however provide some temporary local contracts to support civil construction works but these are predicted to be limited due to the size and nature of the development. Operation of the RTO will not provide any additional jobs to the local economy in addition to the 80 people currently employed directly by Kingspan (with additional economic value being derived through local supply contracts). The main impact of the RTO’s introduction is to secure the existing employment at the site and associated economic benefit by maintaining emissions from a particular emission point to air (Stack A2-1, comprising A2-1a and A2-1b) within legal requirements. As identified previously, unemployment rates in the County are above the national average. It is expected the proposed development will have a positive, moderate, long term impact on the immediate hinterland and Castleblaney through supporting continued employment and the associated economic and social benefits. Air quality will improve as the RTO unit is being introduced to specifically remove emissions of organic compounds used in the production process. Other potential impacts of the proposed introduction of the RTO on humans and related aspects such as noise and landscape/visual impact are considered to be negligible. The potential impact of these aspects and their associated mitigation measures are dealt with in the corresponding chapters of this EIS. Overall, the introduction of the RTO on Population and Human Health is considered to be neutral to positive, moderate and long term in nature. 6.0 MATERIAL ASSETS The EIS considered a number of aspects relating to Material Aspects of the proposed development, namely ownership and access, water supply, wastewater discharge, electrical supply and natural resources. There are no known areas of archaeological significance close to the site so the economical assets of the surrounding environment were considered. The existing facility and the site grounds are owned by Kingspan and are secured by means of CCTV and a 2 m high fence on the boundary. Access to the site is via the industrial estate

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access road which has now been upgraded to link directly to the N2. Security gates and barriers to limit access to the industrial estate are planned for installation in late 2015. The Kingspan facility is bounded by similar industrial type developments mainly comprising of warehouses to the north and the west. There are residential developments to the east, north-east and north-west. Electrical supply to the site is via a mains connection and it is anticipated that the proposed development will increase the electrical demand for the site by less than 5% annually when operational. This is anticipated to be well within the capacity of the site connection and local grid. It is estimated that there will be an additional 20 truck movements as a result of construction works, the RTO delivery and waste disposal. This represents 15% of the current weekly HGV traffic to the site so it is considered to be negligible. During operations, it is estimated that there will be 1-2 additional LPG fuel deliveries required annually and occasional (e.g. monthly) deliveries of sodium hydroxide for absorber water dosing. There will also be the potential requirement for irregular salt removal from scaling within the equipment which will need to be taken from the site. This will however by very irregular (e.g. every couple of years). The increased demand for mains water supply as a result of the proposed development is estimated to be double the 2014 consumption volume bringing the total site consumption to approximately 4,000 m3 per year. This is still considered to be small for an industrial activity and sufficient capacity exists within the network to meet this demand. There is currently no process wastewater discharge from the facility but the RTO will produce a saline effluent discharge at a rate of approximately 0.6 cubic metres per hour (m3/hr) which will be collected in the sewer network. It is considered that there is sufficient capacity in the Castleblaney Waste Water Treatment works to deal with this effluent and Irish Water, who operate the facility, have approved acceptance of the discharge rate and composition. There will be a small volume of waste generated as a result of the installation of the RTO. A waste generation model was prepared and it is estimated that approximately 200 tonnes of non-hazardous waste will be generated. There is sufficient capacity within the region to deal with this waste volume and existing waste management procedures will be followed to maximise segregation of waste types and to divert waste from landfill, where possible. The most significant impact on natural resources will be LPG consumption by the RTO. It is anticipated that the current site consumption will be increased by 33% to generate thermal energy for the combustion process. Building materials such as wood and metal will also be consumed in small quantities. The potential impact of the development on tourism is also considered but it is concluded that any significant tourism destinations in Castleblaney are at a sufficient distance from the facility and will not be impacted by the proposed development. Overall, it is considered that the potential impact can be classed as neutral, imperceptible and long-term with respect to material assets.

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7.0 LANDSCAPE & VISUAL Landscape has two separate but closely related aspects. The first is visual impact, i.e. the extent to which a new structure in the surrounding area can be seen. The second is landscape character impact, i.e. effects on the fabric or structure of the landscape. Landscape character is derived from the appearance of the land and takes account of natural and man-made features such as topography, landform, vegetation, land use and built environment and their interaction to create specific patterns that are distinctive to particular localities. This assessment describes the likely nature and scale of changes to individual landscape elements and characteristics, together with the significance of such changes. Visual impact is considered under ‘Visual Intrusion’ and ‘Visual Obstruction’ where:

Visual Intrusion is an impact on a view without blocking; and

Visual Obstruction is an impact on a view involving blocking thereof. The Kingspan facility buildings are the main structures within the industrial estate. There are smaller warehouse and administration buildings owned by Shabra adjacent to the site to the west and there is an industrial manufacturing facility to the north. The maximum roofline of the warehouse buildings at the Kingspan facility range between 6 m and 12.5 m above ground level with the maximum roofline of neighbouring warehouse buildings at 8 m above ground level. There are a number of existing air emission stacks at the Kingspan facility, extending from the main manufacturing warehouse with heights ranging from 7 m to 12.5 m above ground level. There are multiple dense residential developments adjacent to the eastern boundary of the Kingspan site at a minimum distance of 20 m from the boundary. There are also residential estates to the north and north-east of the facility at close proximity to the site. ‘The Willows’ residential estate is located approximately 200 m to the north-west of the site past M.C Chemicals manufacturing facility. The overall character of the surrounding area is dominated by moderate industrial manufacturing and storage adjacent to recent high density housing on one side and a regionally significant road network on the other. The Bree Industrial Estate and adjacent agricultural lands to the south-west have been zoned for industrial development with a key aspect being the proximity to the regionally important N2 National Primary Road. The existing facility and proposed development fall within this industrial development zone. In addition, Monaghan County Council, as the relevant planning authority, have confirmed to Kingspan in a letter dated 27th February 2015, that the erection of the proposed equipment is ‘exempted development’ falling within Schedule 2, Part 1, Class 21 of the Planning and Development Regulations 2001, as amended. AWN attended the site in respect of preparation of the EIS and took photos to illustrate the proposed location of the equipment and the potential visual impact. The illustrations presented as Figures 7-3 and 7-4 (Chapter 7) show that the main RTO equipment will be shielded from public view on all sides. The new emission stack, absorber and reconfigured emission stacks will, however, be visible above the line of the existing buildings. However, it is considered that the stacks will not create a visual obstruction and will be in keeping with the existing stacks and site development. Any visual impacts or impacts on the surrounding landscape are likely to be neutral, slight and long-term in nature.

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8.0 BIODIVERSITY The biodiversity chapter provides an assessment of the impacts of the proposed development in question on the ecological environment, i.e. flora and fauna. It has been compiled in compliance with the European Communities Legal requirements and follows Guidelines on the Information to be contained in Environmental Impact Statements (Environmental Protection Agency, 2002) and Advice Notes on Current Practice in the preparation of EIS (2003). This section was compiled by Ger O’Donohoe of Moore Group (Environmental Services). There are no internationally designated sites (Natura 2000 sites) within 15 km of the project site. The lands in which the proposed development is located have no formal designations. The nearest designated lands to the site is the Muckno Lough proposed National Heritage Area (Site Code: 001981) at 1.2 km to the north-east. There is no hydrological connectivity and limited biological connectivity between the subject site and nearby conservation sites. The predominant habitat in the project area is Buildings and Artificial Surfaces (BL3). A habitat map of the site has not been included as the proposed development will take place in the existing buildings and hard-stand areas. Given the existing artificial habitat on site and the fact that the site is an operation facility, there is no potential for mammals on site and there is limited habitat available for birds. It is considered that there would be no change to the existing flora and fauna of the surrounding environment should the existing operation continue or with the addition of the proposed RTO. The development is located in an area of low ecological value with no hydrological connectivity to conservation areas and as such is unlikely to have any significant impacts. The proposed development will not have any significant effects on designated sites within 15 km of the development site. The impact of the RTO on biodiversity is considered to be neutral, imperceptible and long term. 9.0 SOIL, GEOLOGY & HYDROGEOLOGY The soils, geology and hydrogeology chapter of this EIS assesses and evaluates the potential impacts on the soil, geological and hydrogeological aspects of the site and surrounding areas. In assessing likely potential and predicted impacts, account is taken of both the importance of the attributes and the predicted scale and duration of the likely impacts. Due consideration has been given to guidelines produced by the Institute of Geologists of Ireland (IGI) in the document entitled Guidelines for the Preparation of Soils, Geology and Hydrogeology Chapters of Environmental Impact Statements (2013). The existing Kingspan facility is located in an area of undulating landscape with associated drumlins. The Kingspan site itself is relatively flat and lies at approximately 128 m-129 m AOD (above Ordnance Datum - Malin Head). The site is underlain predominately by the Kehernaghkilly Formation which is commonly characterised by black shales and minor rhyolitic tuffs. A detailed site investigation carried out by AWN Consulting in February 2015 confirmed the presence of dark grey to black shales at a depth of approximately 0.50 m – 1.70 m below surface level at the Kingspan site. The depth to bedrock at the proposed RTO location is 0.80 m below ground level. The subsoil type underlying the site according to the Geological Survey of Ireland (GSI) (2015) is Made Ground to the north, Lower Palaeozoic Sandstone and Shale Fill (TLPSsS) and bedrock at the southern corner of the site. There are no mines on/near the subject site and

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the GSI website confirmed that there are presently no geo-hazards, such as landslides, within a radius of 10 km of the site. The bedrock aquifer beneath the Castleblaney area, according to the GSI (2014), is classed as PI, which is ‘Generally unproductive except for Local Zones’. From the AWN site investigation in February 2015, the subsoil thickness was confirmed to be between 0.3 - 1.5 m of generally low permeability till, which indicates an ‘Extreme’ local vulnerability. Groundwater level monitoring indicates that the local flow direction is towards the south-east with a relatively flat hydraulic gradient of approximately 0.01. The soil and groundwater baseline report issued by AWN following the site investigation, concluded that there is no significant evidence of any impact from current previous use of the site. The installation of the RTO will require the excavation of an area of approximately 100 m2 down to bedrock at 0.8 m below ground level for the equipment foundations. In addition, there will be some trenching required for utility connections. Clean fill will be imported for backfill once utility connections have been completed. It is anticipated that the excavated material will not be contaminated and be recovered for re-use offsite. No significant dewatering is expected to be required during construction works. The primary potential impacts to soil and groundwater assessed include accidental spills or leaks from construction machinery or concrete/cement run-off from foundation works. The excavation footprint area is small but the aquifer vulnerability is extreme due to the shallow depth to bedrock. Additionally, the surface water run-off from construction activities may have potential to impact on local soil and groundwater quality. However, the existing site surface water drainage network discharges to the public storm-water system via interceptors which should help to eliminate any potential issues. Once the RTO equipment is operational, it is not considered to have any potential impact on the regional soil and/or groundwater quality. Saline effluent generated by the equipment is discussed in Chapter 10 Water & Hydrology and sodium hydroxide required for the scrubber/neutralisation system will be stored in a 6 m3 storage tank inside a bunded area adjacent to the equipment. For the proposed development, the residual impact is considered to be neutral in terms of quality and of imperceptible, long term significance as a result of this proposed development on the surrounding soils, geology and hydrogeological environment. 10.0 WATER & HYDROLOGY The Water & Hydrology chapter of the EIS assesses the potential impact which the proposed development may have on the regional hydrology and water quality. An extensive document review was carried out. There are no significant watercourses immediately surrounding the site; however, there are a number of streams and rivers within a 2 km radius of the site. The development is located within the Fane River Catchment which forms part of the Neagh Bann International River Basin District (NB IRBD) (IE06_03) as defined under the EU Water Framework Directive (WFD) (2000/60EC). The Fane River is located approximately 2 km to the north of the site and flows eastwards into the Blayney Castle Lake (or Muckno Lough), which is located approximately 1.2 km to 1.5 km to the north-east of the site and is the main water feature in the area. There are no direct surface water drainage pathways from the site to off-site watercourses.

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The WFD requires ‘Good Water Status’ for all European waters by 2015, to be achieved through a system of river basin management planning and extensive monitoring. ‘Good Water Status’ means both good ecological status and good chemical status. For the Fane River WMU (Water Management Unit), the main pressure preventing achievement of ‘Good Water Status’ is diffuse agricultural pollution. The monitoring of surface water quality undertaken by the EPA indicates that the Fane River is of ‘Poor Status’ during sampling in 2006 and 2012 and the WFD status for Muckno Lough was classed as ‘Bad Status’ for periods between 2007-2009 and 2010-2012. The WFD risk score for the lake is ‘1b’ which means it is ‘at risk of not achieving good status’ by 2015. The Office of Public Works flood database website shows that no flood events been recorded at the proposed development and this was supported by a North Western – Neagh Bann Catchment-based Flood Risk Assessment and Management (CFRAM) Study (UoM 06) Inception Report, which highlighted that there were no flood occurrences at the proposed location of the Kingspan site. The Kingspan facility currently has a mains water supply for the canteen, toilets and domestic use only. There is currently no process water demand for the manufacturing operations. The proposed RTO will require approximately 0.5 m3/hr for the quench system and an additional 0.1 m3/hr for the scrubber water. There is capacity within the mains water supply for this additional demand. There is considerable overlap of the potential impacts of the proposed development on the regional hydrology & water quality with the potential impacts on soil & groundwater quality discussed in Chapter 9 Soil, Geology and Hydrogeology. During the construction phase, the potential release of contaminants from construction machinery or concrete/cement run-off has the potential to impact on local water quality but the extensive hard-standing areas at the site mean that spills will be captured by the site surface water drainage network via the interceptors. A suitable risk assessment for wet concreting will be completed prior to works being carried out which will include measures to prevent discharge of alkaline wastewaters or contaminated storm water to the underlying subsoil. No discharges to sewer of process effluent currently occur from the site. The introduction of the RTO will introduce a new, low volume effluent that will be saline in nature. The volumes are anticipated to be 0.6 m3/hr or less. This discharge will combine with contributions from other domestic, commercial and industrial properties leading to a very substantial dilution of the saline levels within the discharge prior to treatment. The effluent will undergo treatment at the Castleblayney wastewater treatment works operated by Irish Water prior to discharge to Lough Muckno. The Material Assets Chapter of the EIS (Chapter 6) identifies suitable treatment capacity in the public wastewater treatment works is available. Irish Water have evaluated an application and confirmed acceptance of the effluent, thereby confirming the effluent will not impact the treatment capability of the treatment process and that subsequent discharge from their facility will not impact Lough Muckno. No impact resulting from salinity levels within the effluent is anticipated to occur as a result of dilution in the public sewer system, subsequent treatment and additional dilution following discharge into the receiving water. Operation of the plant will be according to BAT principles and in compliance with the licence for the site to ensure that inputs to, and subsequent contamination of, water environments does not occur during normal and/or emergency conditions.

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The residual impact of the proposed development is considered to be neutral in terms of quality and of imperceptible, long term significance as a result of this proposed development on the surrounding hydrological environment. 11.0 AIR QUALITY & CLIMATE The EIS presents an assessment of the impacts in terms of air quality and climate of the proposed planned introduction of a regenerative thermal oxidiser (RTO) and discontinuation of a previously licensed emission point. Air dispersion modelling was carried out using the United States Environmental Protection Agency’s regulated model AERMOD. The air dispersion modelling input data consisted of information on the physical environment, design details for all emission points on-site and meteorological data. Using this input data, the model predicted ambient concentrations at various locations for each hour of the meteorological period used. This study adopted a worst-case approach which will lead to an over-estimation of the actual levels that will arise. Good air quality currently exists in the locality although current operations emit a blowing agent for which background levels are not measured. The proposed RTO will remove these emissions from a principal source onsite. Modelling of the existing operation at limits identified in the site’s current IE Licence (Licence no. P0057-02) are predicted to lead to an exceedance for a compound, formaldehyde, and a proposed reduction in this limit has been identified that should be applied whether or not the RTO is installed. Typical emissions of formaldehyde are well below both the current and proposed licence limits. The greatest potential impact on air quality during the construction phase of the proposed development is from construction dust emissions and the potential for nuisance dust. While construction dust tends to be deposited within 200 m of a construction site, the majority of the deposition occurs within the first 50 m. There is the potential for a number of greenhouse gas emissions to the atmosphere during the construction phase of the development. Construction vehicles, generators etc. may give rise to CO2 and NO2 emissions. When the dust minimisation measures detailed in the mitigation section of this chapter are implemented, fugitive emissions of dust from the site will be insignificant and pose no nuisance at nearby receptors. Due to the size and nature of the construction activities, CO2 and NO2 emissions during construction will have a negligible impact on climate. A bypass on the RTO unit is present to reroute emissions around the abatement plant directly to stack A2-14 should the RTO require to be shut down. No production will continue to occur with the RTO unit offline and hence no significant air quality impacts will occur. The impact of the proposed revision to license conditions for formaldehyde is predicted to result in a three-fold reduction in concentrations at sensitive locations beyond the site boundary compared to current licensed conditions. Typical emissions from the facility are well below both current and proposed limits. Volatile organic compound concentrations are found to improve due to the proposed RTO when compared against air quality standards and guidelines designed to protect human health and the environment. The contribution of the RTO to total greenhouse gas emissions in Ireland is considered insignificant (compared to 57.8 million tonnes of CO2 equivalent in 2013) and thus will be imperceptible in terms of Ireland’s obligations under the Kyoto Protocol. The overall impact of the RTO on air quality and climate is predicted to be positive, moderate and long term in nature.

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12.0 NOISE & VIBRATION This section of the EIS assesses the noise and vibration impacts associated with installation of the proposed RTO at the existing Kingspan facility. Relevant impacts during both the construction and operational phases of the proposed development are addressed with reference to the most appropriate guidance documents. Annual noise monitoring data undertaken at the nearest noise sensitive locations to the facility as part of the existing IE Licence (Licence no. P0057-02) were reviewed to determine the operational noise levels associated with current site operations. The reviewed data was used to determine compliance with the existing noise emission limits and the main sources contributing the surrounding noise environment. The relevant noise emissions limit values relating to operational activities were reviewed in line with the EPA’s NG4 guidance document relating to the control of noise emissions from scheduled activities. Predictive calculations were then performed to assess the potential impacts associated with the construction and operation of the proposed RTO development at the most sensitive locations surrounding the development site. The closest noise sensitive properties are those located approximately 50 m north-east of the site along the Coill Darach Road on which the facility is located. Additional properties are located approximately 200 m to the north-west of the facility (The Willows). Activities at Kingspan site are largely contained within the manufacturing buildings with the exception of external dust extract systems and extract units located along the southern building façade in addition to vehicle movements to and from the site. Schedule B4 of the IE Licence sets emission limit values of 55dB (LAeq 30min) and 45dB (LAeq

30min) with respect to operational noise from the facility at the nearest noise sensitive locations over day and night-time periods, respectively. Review of the measured LA90

parameter at the four specified noise sensitive locations indicates that noise levels over day and night-time periods are well within the relevant emission limit values of 55 dB(A) and 45 dB(A). The RTO will typically operate on an 18 hour day but depending on market demand may operate on a continual 24 hour basis. The RTO will operate for 30 minutes to 1 hour either side of the manufacturing process operating hours to allow for suitable warm up and shut down periods if not run on a continuous basis. The operation of this new unit has the potential to add to operational noise levels from the Kingspan facility at the nearest noise sensitive locations. The construction phase will be of short-term duration requiring the installation of foundations, connections to on-site utility services and installation and commissioning of the new plant. No night time construction activity is anticipated to be required. In terms of constriction noise limits, there is no statutory Irish guidance relating to the maximum permissible noise level that may be generated during the construction phase of a project. Local authorities typically control construction activities by imposing limits on the hours of operation. The results of the noise assessment indicate that construction noise levels at the nearest noise sensitive locations are all well below the recommended construction noise limits for daytime periods of 65 dB LAeqT. Construction activities will be carried out during regular daytime hours and night-time construction related activity is not anticipated. In order to assess the potential impact of operational plant and equipment on site, a noise model of the site and surrounding area was developed using a proprietary noise calculation

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package Brüel & Kjær Type Predictor. The calculated cumulative noise level associated with the existing and proposed fixed plant items are in the range of 25 to 35 dB LAeqT.

The operation of the RTO unit is calculated to increase noise levels by 0 to 3 dB(A) at properties to the north of the site to within 25 to 32 dB(A). To the north-west of the site, noise levels are calculated to increase by 5dB to a level of 35 dB(A). The calculated noise levels at all locations are well below the proposed operational emission limit values of 55 dB, 50 dB, and 45 dB LAr,T during day, evening and night-time periods, respectively. In the case of the Kingspan facility, considering a new IE Licence is being sought as part of the application, it is considered reasonable that the updated licence complies with the most up to date relevant guidance documents relating to noise (i.e. NG4, 2012). In this instance, considering noise levels from the facility have operated under the ‘typical limit values’ set for licenced sites to date, it is proposed to maintain these limit values as part of any revised IE Licence issued. It is proposed, however, to introduce a new evening criterion to comply with the new guidelines which set a limit value of 50 dB LAr,T for this period and to update the time periods over which day and night-time periods are defined. The existing IE Licence for the facility does not set any emission limits values relating to vibration. There are no sources of vibration associated with the existing facility which give rise to any appreciable levels of vibration to the surrounding environment. There are no vibration sources associated with the proposed RTO and, hence, no changes to the existing vibrations will occur. In light of the above, no vibration limits are deemed necessary for the existing or updated Kingspan facility. Overall, assuming noise levels associated with the proposed RTO are designed to operate within the relevant noise limits set out in this chapter, operational noise levels at all locations are within the relevant limit values. Noise levels are predicted to increase by a slight margin at the closest noise sensitive properties to the north-west and hence overall impacts are determined to be negative, slight and long-term. 13.0 WASTE MANAGEMENT The waste management chapter of the EIS considers the potential impact of additional waste generation during the construction and operational phases of the proposed development. The baseline conditions for the EIS, as noted previously, are the existing operations at the site and the facility has a number of waste management procedures for hazardous and non-hazardous waste which are managed through Kingspan’s Integrated Management System (IMS). An extensive document review was carried out to assist in identifying current and future requirements for waste management and included a number of National and Regional Waste Policies, Strategies and Reports. In terms of waste management, the receiving environment is defined by Monaghan County Council as the local authority responsible for administering waste management activities in the area. This is governed by requirements as set out in the North East Region Waste Management Plan 2005 – 2010, which is currently being evaluated in line with the requirements of the Waste Framework Directive (2008/98/EC). The new Regional Waste Management Plan for the Connacht-Ulster Region has been issued for public consultation which will cover the Monaghan area as well as Galway, Mayo, Sligo, Roscommon, Leitrim, Donegal and Cavan.

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The current plan set waste management targets for the North East Region of:

43% Recycling

39% Energy Recovery

18% Disposal The plan also identified a number of objectives for regional waste management and an evaluation report issued in 2012 noted the regions progress in achieving the objectives set. The external receiving environment can be characterised as one where there is increasing awareness and responsibility on the commercial and industrial (C&I) sector to provide accurate data on waste generation and to enforce source segregation and collection of all waste streams. Existing waste materials generated at the facility as part of current operations are collected by approved waste contractors and recovered offsite, where possible. A total of 400 tonnes of hazardous and non-hazardous waste was recorded in 2014, the majority of this relates to non-hazardous board. A waste generation model was used to estimate the likely volumes of waste expected to be generated during the construction phase of the proposed development. It is estimated that over 200 tonnes of soils, stones and concrete will be excavated for the foundations of the RTO along with trenches required for utility connections. Based on the results of site investigations carried out by AWN in February 2015 it is not expected that any contaminated material will be encountered during excavations, however in the event that contaminated material is encountered, it will need to be tested and classified prior to disposal or recovery. Additional waste materials expected to be generated during construction will be timber and metal. These materials will be segregated on site and are expected to weigh less than 1 tonne in total. There will not be any regular waste generated from the equipment once operational. However, there will be irregular disposal of waste salts required from maintenance and descaling of the equipment every couple of years. Existing waste management procedures and contractors will be used to deal with the additional material generated from the proposed development. Extra receptacles will be brought in, where required, to ensure maximum segregation of materials and written records of waste transfers will be maintained at all times. The long-term waste impact can be concluded to be neutral and imperceptible. 14.0 ACCIDENT PREVENTION & RESPONSE The impacts on the accident prevention and response systems and infrastructure in place at Kingspan with and without the RTO unit in place have been evaluated within the EIS. The accident prevention procedures at the facility detail the integrated management system (IMS) methods already in place to minimise risks of accidents and protect staff safety, members of the public, public infrastructure such as waste water treatment plant and the environment. Potential unplanned events include fire or explosion from flammable material or vapour accumulation and the spillage of chemicals including chemicals used in production or fuels to provide heat for production processes and buildings.

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Consequence modelling has been carried out to evaluate the effect of a scenario whereby excess concentrations of volatile organic compounds (VOC) rapidly ignite within the combustion chamber of the RTO and lead to overpressure. The organisational structure is appropriate to minimise the risk of an accident and to minimise the consequences should one occur. All employees are made aware of the potential for major accidents and are trained, where relevant, in procedures needed to ensure that policy objectives are met. In addition, all contractors' employees are made aware of the potential for accidents and their responsibilities in relation to them. A spillage of chemical onsite could present an offsite hazard either through the generation of vapour, by infiltrating the ground, reaching groundwater or by entering a public sewer system. If entering an effluent sewer system, a chemical could reach a sensitive receiving environment via the Castleblayney waste water treatment plant before reaching Lough Muckno. There are currently no discharges to effluent from the site (though the proposed RTO unit will introduce one). A chemical also has the potential to interfere with the waste water treatment plant’s effective operation. If discharged into the storm-water drains, a chemical could be discharged directly to a sensitive receiving environment such as Lough Muckno. In the event of fire, contaminated firewater could be generated which has the potential to be discharged offsite. Breaks in either the effluent or storm-water sewers could also provide a pathway to ground or groundwater. As a consequence of these potential risks, very stringent procedures are in place to manage chemicals and prevent spills from initially occurring. In addition, physical infrastructure exists to prevent the risk of chemicals reaching the environment or members of the public in the unlikely event of a spill. All materials are appropriately labelled, segregated and stored with appropriate containment. Delivery areas of bulk chemicals are served by spill aprons. Spill aprons are dedicated areas where a tanker can be parked to allow the delivery of chemicals and in the unlikely event of a spill mean chemicals drain to a common collection point. Containment is in place to capture spills within the apron should they occur, storing the full volume of a tanker delivery. Liquid chemicals are fully bunded with a volume of either 110% capacity of the largest tank or container or 25% of the total volume stored, whichever is the greater. Bunds are containment systems that surround tanks and collect any material in the event of a spill and can comprise concrete structures or plastic units depending on the size of the tanks. Bunds are checked for integrity as part of a three yearly programme. Bulk raw materials are transferred via pipe with no or limited levels of manual handling of chemicals involved which reduces the potential for spills arising from human error. In future, the integrity programme will incorporate the underground fuel transfer line present on site. Other, smaller volume chemicals are typically stored in protected containers and stored in bunded areas away from vehicle access to prevent the risk of damage from vehicle movements. Incompatible materials are stored in segregated areas. Bulk tanks are also fitted with fill alarms that automatically trip pumps to prevent continued filling of the tank and any spillage of material that could result from overfilling. Interceptors are in place for all surface water discharges offsite from process areas which will collect any hydrocarbon spills on areas of hardstanding in the unlikely event of their occurrence. No or extremely low volumes of chemicals are anticipated to be required during construction and risks from chemicals to the receiving environment during this phases are expected to be very low. Earthworks have the potential to increase releases of dusty material to surface waters via roadways and these are described further in Chapter 11 Air Quality.

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There are potential health and safety risks arising from the construction phase due to the use of large, mobile machinery and heavy equipment and materials. Access for vehicles, equipment and materials will be directly from the N2 road. Access through the neighbouring Bree housing estate is now prevented by security barriers ensuring safe separation of vehicle movements and members of the public. Work will also be carried out within the security perimeter of the Kingspan facility itself with no uninvited public access permitted. Existing accident prevention and response procedures and infrastructure will continue to be in place on site and extended to include construction and operation of the RTO unit. This includes appropriate containment of the caustic solution tank to prevent the potential for spills. The delivery and transfer of the chemical will continue to be carried out in accordance with the existing procedures for the transfer of chemicals. A lower explosive limit flammability monitor on the RTO will be installed, which will automatically shut down the unit if excess VOC concentrations on the inlet to the RTO are detected to prevent overpressure. The alarms and trips will be set well below the level that can present a risk of such an occurrence. Additional shut off valves will be installed onsite to enable suitable retention volume to be available onsite in the event of fire and to protect surface waters and public sewerage treatment systems. The current accident prevention and response procedures for Kingspan require only minor amendments for the proposed RTO. For this reason the impact can be considered very low in both the short and long term. The containment provided for a new tank containing caustic solution will prevent spills of caustic solution from entering the new sewer line being introduced. The RTO will not significantly increase the risk of a spill occurring and protective measures are in place in the unlikely event of a spill occurring. The potential for ‘out of spec’ material to be discharged to sewer exists if controls for the acid gas scrubber (absorber unit) do not operate correctly. The effluent will comprise principally of a saline solution. Potential fluctuations in chloride levels and acidity or alkalinity levels could occur due to the presence of acid gas being scrubbed and from the use of caustic solution. Protective measures to prevent this happening include alarms being fitted to critical control systems to alert the operator of out of specification conditions occurring and to respond accordingly including where necessary the shut-down of the system. The volume of effluent discharged will be low (<0.6 m3/hr) relative to the flows collected by the sewer system and treated at the Castleblayney wastewater treatment works. The principal component of the water is chloride (‘salt’) with the principal environmental effect being the potential to increase the brackishness of any receiving water. In the event of an ‘out of spec’ discharge occurring, the discharge will be diluted many fold, thereby reducing the concentration of the ‘out of spec’ component. Irish Water, who are responsible for the wastewater treatment works, will identify conditions as part of their acceptance of the effluent discharge to ensure no adverse impacts from either planned or unplanned discharges occur at the treatment works. Such discharges will not have any negative impact on the ultimate receiving water, Lough Muckno. Critical alarms will be programmed to directly shut down the unit as part of the controlled shut down of the unit. In the event of an external grid supply interruption for example, the existing 250 KVA emergency generator onsite will kick in and has sufficient capacity to meet the duty of the RTO to continue operating the fans and controls of the system, thereby minimising the potential for only partial treatment and build-up of VOC inside the unit as part of a controlled shut down. Whilst the unit is shutting down, extracted air from the process will be redirected around the RTO unit and scrubber and discharged direct to air via stack A2-14 without treatment (similar to current baseline). This is an important safety feature of the system. In the event of

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shut down of the RTO, production will also cease. Bypass events are therefore likely to be rare, of very short duration and discharge rates will be similar to the existing site operation. The impacts associated with any discharge whilst the unit is shutting down will be neutral, slight and short term. The release of air emissions outside design performance specification and, in turn, outside requirements that will be stipulated in any revised Industrial Emission Licence are expected to be unlikely to occur and if they do occur will only occur for very short periods of time as the RTO unit will be shut down if the unplanned event continues to occur. The impact on human health can be considered to be very low and very short term in nature. Emissions to air will be monitored in accordance with any revised IE Licence to demonstrate that emissions to air do not have any potential adverse impact on human health or the environment. The risk and consequences of overpressure in the RTO from excess concentrations of VOC within the combustion chamber of the RTO (above the lower explosive limit of the compounds being treated) has been assessed. Monitoring and automatic shut-down systems will be installed to prevent such an occurrence however. Explosion scenarios can result in potentially damaging overpressures, especially when flammable vapour/air mixtures are ignited in a congested area. Consequence modelling was completed using specialist consequence modelling and risk appraisal software to evaluate the potential effects in the unlikely event of such an occurrence. The assessment concluded that the level of individual risk is acceptable when compared to Health and Safety Authority land-use planning criteria (HSA, 2010). No significant impacts are expected at any residential dwellings in the area. Safety and environmental indicators will continue to be tracked to assess the effectiveness of the IMS procedures and environmental and safety protection systems in place. These include indicators to demonstrate how well preventative measures are considered and planned (leading indicators) and indicators to assess the frequency and significance of unplanned events in the unlikely event of them arising (lagging indicators). Overall the impact of the RTO unit in relation to the potential for accidents is considered to be negative, slight and short term. Mitigation measures identified in this EIS however will significantly reduce the potential for an accident to occur. 15.0 CONCLUSION Overall the introduction of the RTO is considered to have a positive, moderate, long-term effect on the environment by improving air quality and securing continued employment by achieving compliance with the IE Licence limits. A slight negative impact is identified for the potential additional noise and risks associated with potential accidents but are not considered to be significant with the proposed mitigation measures in place. Ambient noise levels will continue to be within acceptable noise levels specified in the IE Licence and by organisations such as the World Health Organisation (WHO). All other aspects are considered to be neutral in nature, with the RTO having no perceptible effect on current conditions.

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