integrated pollution prevention and control (ippc)/waste ...the site boundary must be outlined on...

Galmoy Mines Ltd.

Integrated Pollution

Prevention and Control

(IPPC)/Waste Licensing

Review Form and Guidance

Note

for the purposes of

EC Environmental Objectives (Surface Waters) Regulations

2009

Environmental Protection Agency

P.O. Box 3000, Johnstown Castle Estate, Co. Wexford

Lo Call: 1890 335599 Telephone: 053-9160600 Fax: 053-9160699

Web: www.epa.ie Email: [email protected]

EPA Reg. No: (Office use only)

Introduction

INTRODUCTION

This Form is for the purposes of a review of an IPPC/Waste Licence in order to

ensure that all authorisations under the EPA Act 1992 to 2007 and the Waste

Management Acts 1996 to 2010 having discharges liable to cause water pollution

are in compliance with the EC Environmental Objectives (Surface Waters)

Regulations 2009.

While every effort has been made to ensure the accuracy of the material

contained in the Review Form, the EPA assumes no responsibility and gives no

guarantees; undertakings and warranties concerning the accuracy, completeness

or up-to-date nature of the information provided herein and does not accept any

liability whatsoever arising from any errors or omissions.

The Review Form and all supporting information shall be submitted to the

Headquarters of the Agency in a format of a signed original, one hardcopy and

two copies on CD-Rom. In cases where an Environmental Impact Statement

(EIS) is required in support of the Review Form, a signed original, one hardcopy

plus 16 copies (or 18 copies if the activity is within Energy sector) on CD-Rom

shall be submitted.

All pages, including maps/drawings/plans, shall be no larger than A3 size. All

files on CD-Rom shall be submitted in searchable PDF format and be no larger

than 10MB each in size. All CD-Roms shall be labelled with the Licensee’s name,

Licence Register Number, address of the activity and name of the file (i.e.

Review Form).

Introduction

CONTENTS

SECTION A: GENERAL ....................................................................................... 1

SECTION B: EMISSIONS ................................................................................... 3

SECTION C: CONTROL & MONITORING .............................................................. 8

SECTION D: EXISTING ENVIRONMENT & IMPACT OF THE

ACTIVITY ....................................................... ............................ ..15

SECTION E: STATUTORY REQUIREMENTS ........................................................ 38

SECTION F: APPROVED ADJUSTMENTS & CONDITIONS .................................... 44

SECTION G: DECLARATION ............................................................................. 46

ANNEX 1: TABLES/ATTACHMENTS ................................................................... 47

Galmoy Mines Ltd.

1

SECTION A: GENERAL

A.1 Licensee

Name*: Galmoy Mines Ltd

Address: Galmoy via Thurles

Galmoy

Co Kilkenny

IPPC Licence P0517-01

Tel: 056 8837100

Fax: 056 8837105

e-mail: [email protected]

* This should be the name of the Licensee which is current on the date this IPPC/Waste

Licence Review Form is lodged with the Agency. It should be the name of the legal entity

(which can be a limited company or a sole trader). A trading/business name is not

acceptable.

Name and Address for Correspondence

Only documentation submitted by the Licensee and by the nominated person will be deemed to

have come from the Licensee.

Name: Galmoy Mines Ltd

Address: Galmoy via Thurles

Galmoy

Co Kilkenny

Tel: 056 8837122

Fax: 056 8837105


Address of registered or principal office of Body Corporate (if applicable)

Address: Lundin Mining Corporation

Company Registered Number: 131188

Corporate Head Office

150 King Street West,

Suite 1500, PO Box 38

Toronto, ON M5H 1J9

Company

Register No.

Lundin Mining Corporation

131188

Tel: 00 1 416 342 5560

Fax: 00 1 416 348 0303


Galmoy Mines Ltd.

2

A.2 Location of Activity

Name: Galmoy Mines ltd

Address*:

Castletown, Whiteswall, Rathreargh,

Garrylaun and Rathpatrick

Galmoy

Co Kilkenny

Tel: 056 8837100

Fax: 056 8837105

Contact Name: Peter Small

Position: Mine Manager


* Include any townland.

National Grid Reference

(12 digit 6E,6N)

E 227 329 N 173 226

Location maps (no larger than A3), appropriately scaled, with legible grid references should

be enclosed in Attachment No A.2. The site boundary must be outlined on the map in red

colour.

Geo-referenced digital drawing files (e.g. AutoCAD files) in Irish Grid projection of the site

boundary and overall site plan, including labelled emission points to surface water and

their monitoring and sampling locations, are also required.

Galmoy Mines Ltd.

3

SECTION B: EMISSIONS

B.1 Emissions to Surface Waters &/or Ground

Historically Galmoy Mines Ltd extracted and processed minerals (lead and zinc) from four

Orebodies (G, K, R and CW). The ore was processed in the mill to produce separate lead

and zinc concentrates. This was achieved by crushing, grinding, flotation and dewatering.

Separation of the zinc and lead minerals from the host rock took place in a flotation

process with lead being removed first using aeration and reagents. A similar process was

repeated for the removal of zinc. The resulting products were dewatered and stored

ready for shipment to smelters abroad. The tailings produced in this process were either

pumped to the tailings impoundment dam or mixed with cement and pumped

underground as a backfill paste.

In May 2009, due to economic circumstances, Galmoy Mines Ltd ceased production. The

Mine Closure Plan was implemented in early June 2009 and the mill processing plant and

surface ancillaries were dismantled and removed from the mine plant site.

Mining has since ceased in October 2012 with the underground pumps switched off in a

phased manner, with the final pumps in the G orebody turned off in March 2013.

Groundwater levels are currently recovering to natural levels and should conservatively

be fully recovered by 2015 based on modelling predictions by K.T. Cullen (1992).

Progressive restoration of the Tailings Management Facility (TMF) is ongoing. Phase 1

was completed in 2011 and Phase 2 will be completed in 2013. An integrated constructed

wetland is proposed for the Phase 3 of the TMF in 2013.

Photo 1 –Rehabilitation works showing capped TMF prior to spreading of topsoil on the

glacial till cap.

Galmoy Mines Ltd.

4

Photo 2 –Phase 1 of the Rehabilitated TMF

Photo 3 – Weir from Phase 2 to Phase 3 with TMF rehabilitation in background and

HDPE lined phase 3 in the foreground

Galmoy Mines Ltd.

5

Photo 4 – Mowing grass for silage on Phase 1 of the Rehabilitated TMF – 2012 and

cattle grazing in the background.

Historically Clean Water (GW1) was segregated and pumped to the surface for

treatment, re-use or disposal. Groundwater entering the mine through fissures was

collected and pumped to a conditioning pond on the surface. This water was intercepted

before entering the mine workings to ensure that it was not contaminated. After

conditioning, this water was used for augmenting the flow in local streams including the

Glasha and mixed with treated mine water as final Discharge effluent (SW1).

In April 2010 the stream augmentation to the Coady’s Castle stream which feeds into the

Glasha River (Referred to as the Rathdowney River in the WFD) ceased on instruction

from the EPA, as clean water could no longer be collected and segregated from

underground sources. The proposed discharge to the Glasha will in part replace the SW1

discharge to the River Goul along with restoration of groundwater baseflow to the river

following recovery of groundwater levels.

Previously, Treated Mine Water (PS3) and Treated Process Water (PS5) were discharged

to the River Goul (SW1). As the mine is no longer mining and processing ore and is not

abstracting groundwater, the volume and flow is greatly reduced. It is proposed to retain

the discharge point to the River Goul pending the development of an alternative

enterprise on the industrial site, however the volume and effluent loading is <10% of the

Licenced discharge and will be subject to the approval of the Local Authority and the

EPA.

As part of the rehabilitation plan, surface water runoff generated from the rehabilitated

TMF will discharge to the River Glasha at SW2. Extensive measures are in place to

Galmoy Mines Ltd.

6

minimise any potential impact of the discharge from the TMF. Phase 1 and Phase 2 of the

TMF will be capped for the purpose of grazing cattle and any runoff from the capped

rehabilitated area will be treated by a constructed wetland system in Phase 3 of the TMF.

The wetland system will further reduce metal and organic concentrations from Phases 1

and 2. Previous information submitted as part of the TMF rehabilitation studies have

indicated the low leachability of the tailings and the absence of acid mine drainage1.

The installation of the wetland in Phase 3 is designed treat the surface water from phase

1 and phase 2. The location of the wetland within phase 3 will reduce the footprint of the

tailings runoff area and cap Phase 3 at the same time. However, the treated runoff to be

generated by the site contains primarily agricultural runoff with some shorter term runoff

of water from the interface of the cap which contains compost (Phase1) and the tailings

surface.

Based on the assimilative capacity study, the discharge at SW2 will meet the criteria as

set out in S.I. 272 of 2009 in the River Glasha for most parameters. An Appropriate

Assessment of the potential impact on the River Nore SAC is included as part of this

report. In conclusion there is a negligible impact on the River Nore SAC. It is considered

that no significant adverse effects will arise from the proposed surface water discharge

from the TMF at Galmoy Mines to the stream and that this development can be screened

out from further Appropriate Assessment or EIS.

A summary list of the emission points, together with maps/drawings (no larger than A3)

and supporting documentation should be included as Attachment No B.1.

1 Golders, 2011 – TMF Rehabilitation and Closure Plan

Galmoy Mines Ltd.

7

B.2 Tabular Data on Emission Points to surface water

Licensees should submit the following information for each emission point to surface

water:

Point Code Easting Northing Verified Emission

SW1

Surface

Emission

Point

E227329 N173226 Y Suspended solids,

Lead, Zinc,

Cadmium, Arsenic,

Ammonia (as

N), Nitrate (as N),

Nitrite (as N),

Biochemical oxygen

demand,

Copper,

Sulphate,

Orthophosphate (as

P)

SW 2 226439 170638 Y Suspended solids,

Lead, Zinc,

Cadmium, Arsenic,

Ammonia (as N),

Nitrate

(as N), Nitrite (as N),

Biochemical oxygen

demand, Copper,

Sulphate,

Orthophosphate (as

P), Total Alkalinity

* SW = Surface Water

An individual record (i.e. row) is required for each emission point. Acceptable file formats

include Excel, Access or other upon agreement with the Agency.

Galmoy Mines Ltd.

Page 8

SECTION C: CONTROL & MONITORING

Describe the proposed technology and other techniques for preventing or,

where this is not possible, reducing emissions from the installation/facility.

C.1 Treatment, Abatement and Control Systems

An overview/summary of treatment/abatement systems for effluent emissions should be

included together with schematics as appropriate.

For each Surface Water Emission Point identified complete Table C.1(i).

Supporting information should form Attachment No C.1.

Normal operation and variations for start-up and shutdown should be described.

Anticipated malfunctions and known problems associated with the treatment should be

highlighted.

Proposed monitoring to be undertaken for influent(s) to treatment plant, and in-

treatment monitoring required for the management of the treatment plant should be

detailed.

C.1 Treatment, Abatement and Control Systems

Wetlands

It is proposed to treat runoff from the Phase 1 and 2 of the rehabilitated TMF by means of

a constructed wetland system (located in Phase 3) and a surface water attenuation

lagoon. Constructed wetland treatment systems are engineered systems designed and

constructed to utilize the natural processes involving wetland vegetation, soils, and their

associated microbial assemblages to assist in treating wastewater. They are designed to

take advantage of many of the same processes that occur in natural wetlands, but do so

within a more controlled environment. Constructed wetlands consist of former terrestrial

environment that have been modified to create poorly drained soils and wetlands flora

and fauna for the primary purpose of contaminant or pollution removal from wastewater.

Constructed wetlands are essentially wastewater treatment systems and are designed

and operated as such, though many systems do support other functional values.

A major part of the treatment process for degradation of organics is attributed to the

microorganisms living on and around the plant root systems. Once microorganisms are

established on aquatic plant roots, they form a symbiotic relationship in most cases with

the higher plants. This relationship normally produces a synergistic effect resulting in

increased degradation rates and removal of organic compounds from the wastewater

surrounding the plant root systems. Also, microorganisms can use some or all

metabolites released through plant roots as a food source. By each using the others

waste products, this allows a reaction to be sustained in favor of rapid removal of

organics from wastewater.

Galmoy Mines Ltd.

9

Wetland trial data by VESI Environmental Ltd. (included in Attachment C.1.) and

reference material indicates that high removal rates of organics and metals are

achievable. Controls systems will be incorporated to ensure optimum removal of lead and

zinc, and suspended solids from the surface water. Suspended Solids are removed from

solution by the physical act of settling via large hydraulic resident times in the lagoons.

The lagoons within the wetland are laid out in a series to increase the retention of

suspended soils and allow for an even well distributed water flow. Following treatment of

surface water in the constructed wetlands, water will flow towards the surface water pond

to the north. Further settlement and treatment will occur in the settlement pond. The

treated water will be discharged via an outfall pipe to the Glasha River.

Once the water is discharged from the wetland at PS 9, the water will be discharged to

the Glasha Stream provided the water meets the allowable discharge quality.

As an interim measure while the wetland is being established and in the unlikely event

that water quality does not meet the discharge standards, water from PS 9 will be

recycled back to the Galmoy water treatment plant for further treatment.

Attenuation Pond (Surface Water Lagoon)

The attenuation pond will be located downstream from the wetlands on the North West

corner of Phase 2 and will be used for final polishing prior to discharge into the Glasha

Stream. It is expected that water quality of the influent into the attenuation pond will

meet EPA guidelines.

The surface area of the attenuation pond is approximately 2.4Ha. All the material from

the excavation works was used to construct the dome of Phase 2. The depth of the pond

will be variable due to the undulating nature of the limestone bedrock below the glacial

till. Based on current activities, the average depth of the attenuation pond will be

approximately 2 metres2. The attenuation pond capacity is 50,000m3.

2 Golders 2011 - TMF Rehabilitation and Closure Plan

Galmoy Mines Ltd.

10

No

PS 9 -Water quality meets standards?

Yes

Phase 2- Rehabilitated TMF

River Glasha Sampling of Glasha @ ASW3

Attenuation Pond

Phase 3 – Constructed Wetland

Phase 1- Rehabilitated

TMF

PS 9

Water

Treatment

Plant

SW 1

Galmoy Mines Ltd.

11

C.2 Monitoring and Sampling Points

Identify monitoring and sampling points and outline proposals for monitoring emissions to

surface water bodies.

Table C.2(i) should be completed (where relevant) for emissions to surface water.

Where ambient environment monitoring is carried out or proposed, Table C.2(ii) should

be completed as relevant for each environmental medium and at least 12 samples should

be taken at regular intervals.

Include details of monitoring/sampling locations and methods.

Supporting information should form Attachment No C.2.

C.2 Monitoring and Sampling Points

Currently there are ten monitoring and sampling points outlined in IPPC Licence P0517-

01, Technical Amendment B and EPA correspondence P0517-01/ap23pos{GW1}.docx for

monitoring. These include Mine Water (PS1), Reclaim Water (PS4), Treated Mine Water

(PS3), Lamella, Treated Process Water (PS5), Effluent Pond Discharge (PS8) and

Discharge Effluent (SW1). Effluent Pond Discharge is a combination of Treated Mine

Water, Lamella and Treated Process Water. The locations of the monitoring points are

outlined in Drawing B-1. Ambient monitoring points are located at ASW1 (upstream) and

ASW2 (downstream) and are outlined in Drawing C-2. Many of these monitoring points

will become redundant and will be retired as part of the Mine Closure Plan (MCP). PS1,

PS4, PS3 and PS5 monitoring points will no longer apply as all processing of materials

and pumping and treatment of mine water will cease very soon.

As the proposal outline will deal with discharge of the treated surface water from the

surface of the TMF to the Glasha River, an additional 3 monitoring locations will be

required. PS9 treated water from the wetland, SW2 (discharge from attenuation pond)

and ASW3 (downstream monitoring on the Glasha River) as outlined in the monitoring

programme and aftercare management plan.

During each working week visual checks are carried out by the Environmental

Department on a daily basis to ensure that the Water Treatment Systems are functioning

correctly. These checks are recorded on the Daily Environmental Site Sheet. This

monitoring process is supported by daily checks carried out and recorded by the on duty

Environmental Staff to ensure compliance with IPPC licence. This monitoring process is

supported by daily checks carried out and recorded by the on duty Water Treatment

Operator (WTO) every day of the week. Two hourly checks are carried out by the WTO on

parameters in the Lamella, Mine Water and Reclaim Water Treatment Plants which

include pH, ferric sulphate, flocculant, water clarity and underflows and two checks (at

10am and 10pm) for pH are carried out at Discharge Effluent and Effluent Pond Discharge

to ensure compliance with IPPC licence.

Galmoy Mines Ltd.

12

C.3 Tabular Data on Monitoring and Sampling Points

Licensees should submit the following information for each monitoring and sampling

point:

Point Code Point Type Easting Northing Verified Pollutant

Provide label

ID’s

M=Monitori

ng

S=Sampling

6E-digit

GPS Irish

National

Grid

Reference

6N-digit

GPS Irish

National

Grid

Reference

Y = GPS

used

N = GPS

not used

e.g.

Ammonia

(as N),

Biochemical

oxygen

demand

An individual record (i.e. row) is required for each monitoring and sampling point.

Acceptable file formats include Excel, Access or other upon agreement with the Agency.

Point source monitoring/sampling refers to monitoring from specific emission points (e.g.

from a wastewater treatment plant). Ambient monitoring includes monitoring of river

quality upstream/downstream of an effluent discharge.

Galmoy Mines Ltd.

13

C.3 Tabular Data on Monitoring and Sampling Points

Point

Code

Point Type Easting Northing Verifie

d

Pollutant

SW1

Surface

Emission

Point

E227329 N173226 Y Suspended solids, Lead, Zinc,

Cadmium, Arsenic, Ammonia

(as N), Nitrate (as N), Nitrite

(as N), Biochemical oxygen

demand, Copper, Chemical

oxygen demand, Sulphate,

PS1 Emission

Point


Nitrate (as N), Nitrite (as

N),Ammonia (as N), Chemical

Oxygen Demand, Sulphate,

Mercury, Arsenic, Cadmium,

Aluminium, Iron, Copper,

Magnesium and Chromium

PS4 Emission

Point


Nitrate (as N), Nitrite (as

N),Ammonia (as N), Chemical

Oxygen Demand, Sulphate,

Mercury, Arsenic, Cadmium,

Aluminium, Iron, Copper,

Magnesium and Chromium

ASW1 Ambient

Monitoring




(as N), Iron, Copper, Sulphate,

Orthophosphate (as P), Total

Alkalinity

ASW2

Ambient

Monitoring






Alkalinity

PS 9 Ambient

Monitoring






Alkalinity

SW2 Emission

Point




(as N),Iron, Copper, Sulphate,

Galmoy Mines Ltd.

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Point

Code

Point Type Easting Northing Verifie

d

Pollutant


Alkalinity

ASW3 Ambient

Monitoring






Alkalinity

PS1 & PS4 will no longer be water sources at Galmoy Mines

Galmoy Mines Ltd.

15

SECTION D: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY

D.1 Assessment of Impact

Describe the existing environment in terms of water quality with particular reference to

environmental quality objectives and standards as specified in the EC Environmental

Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009. Table D.1(i) should

be completed as appropriate.

Indicate whether or not the activity complies with the requirements of the EC

Environmental Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009 and

the EC Environmental Objectives (Groundwater) Regulations 2010 S.I. No. 9 of 2010.

The Licensee should conduct an assessment of impact of discharge(s) from the

installation/facility on receiving surface water and/or groundwater. In undertaking this

assessment the Licensee shall have particular regard to substances used in the

manufacturing processes likely to result in discharges. The licensee shall have regard for

the environmental quality objectives and standards specified for protected areas and/or

the standards specified in the Schedules of the EC Environmental Objectives (Surface

Waters) Regulations 2009 S.I. No. 272 of 2009. When completing any assimilative

capacity calculations have regard to the Water Services Training Group ‘Guidance to

Applicant – Discharge to Surface Waters’ available at

http://www.wsntg.ie/publications/index.asp and other standard guidance.

If the process discharges are to coastal, transitional waters or lakes, the assessment may

require a modelling study. The modelling study shall include estimates on what the

resultant concentrations of the permitted substances in the receiving water body will be

upon discharge at the current licence limits.

Regardless of the receiving water body type, determine the maximum allowable

discharge concentrations to achieve compliance with the 95%ile good status limits. N.B.

If the discharge is to a water body that is already achieving high status, or if the

discharge is to waters draining to the surface water bodies identified under the First

Schedule of the EC Environmental Objectives (Freshwater Pearl Mussel) Regulations

2009, compliance must be with 95%ile high status limits.

State distance from the process discharges to a nearest downstream water dependent

Protected Area. Include the name and code of this Protected Area.

Full details of the assessment, including a copy of an Environmental Impact Statement if

it was required for the purposes of obtaining planning permission(s), should be submitted

as Attachment No D.1.1.

Where necessary, the Licensee should supply detailed information on the proposals to

comply with the requirements of the EC Environmental Objectives (Surface Waters)

Regulations 2009 S.I. No. 272 of 2009 including a detailed timeframe for any proposed

works in Attachment No D.1.2.

Galmoy Mines Ltd.

16

D.1 Assessment of Impact

An extensive monitoring programme has been ongoing since 1996 to assess the impact

of mining activity on receiving surface water and to examine relevant aspects of the

surface water environment in the vicinity of the Galmoy Mines Ltd. The work programme

involves individual ongoing surveys of streams and rivers and documents their water

quality, biotic status, flow regimes and beneficial uses in order to define the basic

characteristics of the local freshwater environments.

The Galmoy Mines mining project is located within the townsland of Castletown,

Whiteswall, Rathreargh, Garrylaun and Rathpatrick close to the village of Galmoy in

North County Kilkenny (Drawing A-2).The area lies in the watershed of the Erkina River a

tributary of the River Nore. The River Glasha to the north and River Goul to the east are

both tributaries of the River Erkina.

The water body is located within the Special Area of Conservation 20 of the Nore River

Basin District (SAC 002162). The Erkina system consists of a network of tributaries

draining an area of approximately 387 km2 at Durrow. The Goul rises in the Slieve

Ardagh Hills and flows for 38km through Urlingford to Ballyboodin (near Durrow). The

Glasha River rises close to Galmoy and flows to the north towards Rathdowney and the

confluence with the River Erkina.

The treated water from the mining operations is discharged to the River Goul. Following

the cessation of mining and the turning off the groundwater pumps and following the

construction of the wetland the discharge to the River Goul will reduce by over 90%. The

current discharge point is approximately 350m west of Fertagh Bridge (Drawing C-2).

Consequently, the Goul system has been studied in greater detail.

The north and west of the site drain to tributaries of the Glasha Stream, which drains to

the north, into the River Erkina, which then flows eastwards towards the River Nore. In

accordance with the Mine Closure Plan schedule the discharge to the River Goul will cease

in 2013. The proposed discharge point from the TMF, as outlined in earlier application, is

the adjacent Glasha Stream via the wetland treatment system and the attenuation pond.

The catchment area for the Glasha Stream, the Glasha Stream in the vicinity of the TMF

and the TMF are given below:

• Total catchment area of the Glasha Stream is approximately 1,300 Hectares;

• Catchment area of the Glasha Stream at the discharge point is 335 Hectares; and

• Surface catchment area of the TMF excluding the downstream and wetland walls is

23.4 Hectares.

Surface Area of top embankment of TMF is 33.64 Ha. Phase 1: 9.36 Ha. Phase 2: 14.02

Ha. Phase 3: 8.285 Ha. Total Footprint of TMF is 33.745 Ha. Areas are calculated based

on the EPA Hydrotool for the total catchment and the discharge location while the TMF

area is based on the surveyed data from Galmoy (Q4, 2012).

An appropriate assessment was undertaken on the River Glasha and the potential impact

on the River Nore SAC located. The Glasha flows into the Erkina River and eventually

Galmoy Mines Ltd.

17

flows into the River Barrow and Nore SAC/SPA. The approximate distance of the

discharge point to the River Barrow and Nore SAC is 13km. The approximate distance to

the River Nore SPA is 16km. The potential impact of the surface water discharge is

negligible and will not affect the WFD target of reaching good status by 2021.

Water Flow

Historical hydrometrics data in this region is moderate. There are no active hydrometric

stations within the Glasha Catchment with one inactive staff gauge at Glasha Cross

Roads. The nearest EPA monitoring station is at Glasha Cross Roads on the River

Rathdowney, approximately 4km downstream from the site boundary.

A baseline survey and a hydrometric monitoring program were undertaken as part of the

EIS for the development in 1992. The hydrometric stations were installed at Coadys

Castle, Glasha Cross Roads and on the River Goul to the south. Data is also available for

mean runoff from Phase 1 of the TMF in 2012.

Equations to estimate low flows based on catchment areas (Martin and Cunnane (1977),

MacCarthaigh, 2002) are available and are calculated as part of the project. However,

these equations are largely guided by the values plotted for the larger catchments, that

the percentage scatter among values for small catchment is very large and that these

equations cannot be used reliably for low flow on small catchment areas (Brogan and

Cunnane, 2005).

Hydrometric Data

A search of the Register of Hydrometric Stations in Ireland found the nearest flow

gauging stations on the River Glasha, downstream of Galmoy. The EPA, operates both

stations and details are provided in Table 1 below and shown in Figure 1-1 (Attachment

B.1.).

TABLE 1 LOW FLOW CHARACTERISTIC FROM RELEVANT GAUGING STATIONS

Station

Number

Waterbo

dy Location

DTM

Area

[Km2]

DWF

(m³/

s)

95

%ile

(m³/s)

Mean

Station Type

15005 Erkina Durrow 387 0.4 0.75 5.7124 Data logger 1954-

present

15043 Erkina Coolkerry 136.8 0.05 0.1 Staff Gauge 1990-

1997

15056 Erkina Coneyburrow

Bridge 132 NA NA NA

Staff Gauge 2002-

present

15042 Glasha Glasha Cross

Roads 10.4 NA NA NA

Staff gauge only

1990-1998

18

Data from the Coolkeery and Coneyburrow gauging stations on the River Erkina are

for limited flow periods and does not cover the low flow periods of 1975-1976. Long

term data, DWF and 95%ile data from the River Glasha is not available from the

EPA/OPW for Glasha cross roads. Previous monitoring was undertaken prior to the

start of mining at Galmoy. Data is available from Galmoy mines between July 1992

and October 1992. The data corresponds to the low flow period for 1992.

TABLE 2 GLASHA STREAM FLOW MEASUREMENT JUL-OCT 19923

Waterbody Location

DTM

Area

[Km2]

Average

l/s

Maximum

Flow

l/s

Minimum

Flow

l/s

Glasha Glasha Cross

Roads 10.4 75.79 244.01 4.01

Glasha Coadys Castle 2.3 4.21 39.74 0.22

The monitoring station at Coady’s Castle is located <1km downstream of the mine.

The monitoring station at Glasha Cross Roads is 2 km downstream of the Mine

consists of a staff gauge. Summary data from the station at Coady’s Castle and

Glasha cross roads corresponded to Dry Weather period in 1992 based on the

information from Durrow see Figure in Attachment B.1.

FIGURE 1 FLOW MONITORING AT DURROW GAUGING STATION 1992 - M3/SEC

3 Based on KT Cullen 1992

Corresponding 1992

Monitoring period at

Coady’s Castle and Glasha

cross roads

Galmoy Mines Ltd.

19

While the data for 1992 corresponds to low flow in 1992, data from Durrow and

rainfall data for 1992 suggests that the 95%ile and DWF will be lower for both

Coady’s castle and Glasha cross roads. Additionally applying the methodology as

outlined in Mundal and Cunnane (2009) the SAAR and MF calculations are included

in Table 3 below.

TABLE 3 MEAN AND 95%ILE FLOW ESTIMATES

Location Data source

DTM

Area

[Km2]

DWF

(litre/s)

95 %ile

(litre/s)

Mean

(litre/s)

Tailings Area

Phase 1 and 2

Area

0.234

SAAR4 NA 0.595

MF 5 NA 0.305

Pro-rata – Durrow

gauging station6 0.242 0.429 3.454

Pro rata- Hydrotool7 NA 0.534

Low limits of confidence -

Hydrotool NA 0.36

Upper limits – Hydrotool NA 0.79

Discharge Point-

Glasha

Area

3.35

SAAR 7.28

MF 4.37

Pro-rata – Durrow

gauging station 3.46 6.14 49.44

Pro rata- Hydrotool 7.64

Low limits of confidence -

Hydrotool 5.09

Upper limits – Hydrotool 11.28

A flow recording device will be installed at the discharge location SW2 by Galmoy

mines Ltd. In conjunction flow monitoring data for the River Glasha will be

recorded at Duggan’s Bridge. Flow monitoring at Phase 1 and Phase 2 has been

undertaken since 2011. A total of 76 flow measurements were taken from the thin

crested V shaped weir at Phase 1 in 2012. Data for Phase 1 in 2012 indicates that

the average flow rate is 1.23 l/s in comparison to a predicted mean flow of 1.38 l/s

based on longer term data from Durrow gauging station. Variances in mean flow

are accounted for by different flow monitoring periods and lower soil moisture

deficits in the summer of 2012.

4 As per empirical formulas, Mundal and Cunnane, 2009

5 As per empirical formulas, Mundal and Cunnane, 2009

6 Based on prorata flows at Durrow gauging station

7 Area = 9.2 km2

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For the purposes of the assimilatory capacity calculations it is proposed to use the

pro-rata mean data based on the Long term data from Durrow gauging station.

Calculation based on the 95 %ile assimilative capacity are also included but are less

crucial in this case as the 95%ile flows from the tailings will decrease in proportion

to decreasing rainfall unlike a discharge from a typical Wastewater treatment plant.

Again the 95%ile is calculated based on a prorata basis.

It is likely that the pro-rata approach will be highly conservative for the 95%ile

data. River flow can be divided into two main components:

• Surface runoff from rainfall, and

• Baseflow recession from groundwater storage.

Surface runoff results from rainfall, resulting in an increase in river flow with rainfall

and a reduction when rainfall ceases. The baseflow recession is that part of the

river flow which comes from groundwater storage. In general there is a gradual

decrease in groundwater discharge during dry periods. The groundwater storage of

the moderately permeable subsoils (10-5 to 10-6 m/sec) and aquifer contributing to

Coady’s Castle is higher than the low permeability tailings and cap material (10-9

m/sec). As a consequence run off from the tailings cap will be primarily surface

water runoff with a minor component of baseflow. To illustrate this point a

calculation of groundwater infiltration was completed for Galmoy. The main

parameters involved in the estimation of recharge/groundwater infiltration are:

annual rainfall; annual evapotranspiration; and a recharge coefficient. The recharge

coefficient is estimated using Guidance Document GW5, Groundwater Working

Group 2005. The recharge over the extreme and high vulnerability areas and

moderately permeable till, peat and rock close to or at surface is in the order of

70% with 30% surface water runoff. Recharge/groundwater infiltration over the

tailings is lower at an estimated 25% with 75% runoff.

The recharge calculations are summarised as follows:

TABLE 4 RECHARGE CALCULATIONS FOR TAILINGS AND GALMOY AREA RECHARGE

CALCULATIONS FOR TAILINGS AND GALMOY AREA

Coady’s Castle area Tailings Phase 1 & 2

Average annual rainfall

(R)

826 mm 826 mm

Estimated A.E. (95% of

P.E.)

322 mm 322 mm

Effective rainfall

potential recharge

404 mm 404 mm

Recharge coefficient 70% 25%

Baseflow during low flow periods will be controlled and adjusted to mimic the

overall catchment by the storage in the constructed wetland and attenuation pond.

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RUNOFF WATER QUALITY

Available qualitative and quantitative data for the River Glasha, in conjunction with

chemical monitoring results of the rehabilitated TMFs from Galmoy, form the basis

for the assimilative capacity calculations. Quality Data from Tailings Area 1 for 2012

are included below in Figure 1-6.

The water chemistry at the TMF taken from 2012 and 2013 show the following:

• pH concentrations are stable and between 7 and 8.5 pH units.

• Ammonia concentrations are significantly elevated above normal

background levels ranging from <0.05 mg/l as N to 86mg/l as NH4. This

is attributed to high ammonium content in the organic material used to

improve the growing medium on the capping layer. Low concentrations

of Nitrate in the runoff indicate reducing conditions in the organic

material.

• Dissolved oxygen concentrations are increasing since January 2012

possibly as a result of stabilisation of organic material in the TMF capping

layer. Dissolved Oxygen saturation levels are ~100%.

• Phosphate levels are consistently low with all runoff containing <0.02

mg/l.

• Concentrations of trace metals and in particular lead are low and

decreasing in the runoff from the TMF. Lead concentrations have

consistently decreased and are currently <10 µg/l. However some

isolated spikes are noted. Concentrations of arsenic were 55 µg/l on

average. Elevated concentrations appear to correlate to low flows.

• Sulphate concentrations were elevated at various periods which are

caused by oxidation of sulphite. Concentrations decreased to <500 mg/l

outside of the capping works. Elevated concentrations of Sulphate

appear to be correlated to lower flows (0.52).

• BOD and COD concentrations are decreasing and generally less than 5

mg/l since May 2012.

• Variations in runoff water quality appear to reflect rainfall patterns based

on the available data. Elevated concentrations of Ammonium appear to

be correlated to lower flows (0.37). Elevated Metals also appear to be

associated with lower flows while dissolved oxygen levels appear to be

correlated with higher flow rates.

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FIGURE 2 NITRATE (NO3) AND AMMONIUM CONCENTRATIONS (NH4) AT TMF

Ammonium concentrations are highly variable in early 2012. A noticeable decrease

occurred since May 2012 however a spike in concentrations occurred in

August/September 2012. Concentrations in January - February 2013 (average 4.07

mg/l) were greatly reduced to the same period in 2012 (average of 61.85 mg/l).

FIGURE 3 ZINC AND IRON CONCENTRATIONS AT TMF

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FIGURE 4 CONDUCTIVITY AND SULPHATE CONCENTRATIONS

Figure 5 COD and BOD concentrations at TMF

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FIGURE 6 LEAD CONCENTRATIONS AT TMF

FIGURE 7 DISSOLVED OXYGEN (MG/L) AND PH CONCENTRATIONS AT TMF

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FIGURE 8 SUSPENDED SOLIDS CONCENTRATIONS AT TMF

Data presented above corresponds to the data from 2012. Elevated concentrations

were noted in early 2012 however a noticeable decrease was noted since April

2012. It is anticipated that concentrations of sulphate, ammonium and organic

materials will decrease over the following years as the cap becomes established.

Based on the above the following averages were determined for runoff from the

TMF.

Concentrations of metals, ammonium and sulphate have decreased substantially

since October 2012(see recent data).

TABLE 5 PRE-TREATMENT WATER QUALITY FROM TAILINGS

Analyte units Average

Oct 2012

– Feb

2013

Average

Data

May 2012 –

Feb 2013

Conductivity uS/cm 793 1340

Sulphate mg/l 184 546

C.O.D. mg/l 60.35 109

T Ammonia mg/l 5.41 18.9

BOD mg/l 3.5 4.79

Zinc µg/l 248 284

Iron µg/l 320 478

Manganese µg/l 121 339

Potassium mg/l 14.5 29.5

Cadmium µg/l <1 <1

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Analyte units Average

Oct 2012

– Feb

2013

Average

Data

May 2012 –

Feb 2013

Arsenic µg/l 36 62

Lead µg/l 9.3 17.5

pH pH units 7.61 7.64

D.O. mg/l 11.3 10.75

S.S. mg/l 19.5 108.8

Nitrate mg/l 4.5 7.74

Receiving water quality

Water quality data for the River Glasha available at Duggan’s Bridge (0.8 km

downstream) and Glasha Cross Roads (3.8 km downstream of Galmoy) were

assessed to characterise the background chemical and biological status of River

Glasha. Additional data is also provided in the extensive monitoring data of Galmoy

Mines in 1992. Monitoring data available pre and post mining is comparable in the

Glasha River. Chemical data is available for the mining period however while the

data is similar to pre/post mining concentrations; the surface water samples

includes augmentation flows and therefore not reflective of the natural surface

water quality. Biological, biotic and sediment data along with Q data of the Glasha

were undertaken on an annual basis during the operation of the mine (Aquens 1996

-2011).

TABLE 6 BACKGROUND SURFACE WATER QUALITY

units

Coady’s

Castle-

Average

pre mining

Glasha

Cross

Roads

Current

data

Conductivity uS/cm 727 729.64

Sulphate mg/l 28 141.91

C.O.D. mg/l 19 NA

T Ammonia mg/l 0.09 <0.05

BOD mg/l 2 NA8

Zinc µg/l 41 13.55

Ortho phosphate mg/l NA <0.02

Cadmium µg/l NA <1

Arsenic µg/l NA 4.00

Lead µg/l 7 2.33

pH pH units 7.8 7.56

D.O. mg/l NA 10.84

S.S. mg/l NA 8.44

8 Data from U/S of Rathdowney WWTP 2009 suggests BOD is approx 1.3 mg/l

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Nitrate mg/l 15 14.82

Potassium mg/l NA 6.64

Iron µg/l NA 133

Surface water samples from 1992 and 2012/2013 show the following:

• Ammonia concentrations are elevated above normal background levels

ranging in 1992 and are greatly reduced during the current monitoring

period (<0.05 mg/l as NH4). The slightly elevated ammonium is

attributed to organic peat material present in 1992. However a sizeable

proportion of this material has been removed during the construction of

the TMF. Concentrations of Nitrate in the Glasha are comparable to pre

mining levels;

• Phosphate levels are consistently low with all runoff containing <0.02

mg/l;

• Concentrations of trace metals in the surface water reflect the presence

of a lead and zinc in the natural soils and geology of the area.

• pH concentrations are stable and between 7 and 8.5 pH units.

• Dissolved oxygen consistently high.

• Phosphate levels are consistently low at <0.02 mg/l.

• BOD and COD concentrations are generally below detection limits <2

mg/l.

Assimilative Capacity

The impact on the receiving water can be assessed by calculating the assimilative

capacity. Based on the discharge quality form the TMF runoff, a calculation of the

assimilative capacity was undertaken on the direct discharge to the Glasha River.

Most parameters as set out in the S.I. 272 of 2009 would be met in the discharge

with the exception of ammonium. The treatment provided in the wetlands and

attenuation pond will reduce the ammonium levels so that the assimilative capacity

for Good Status is achieved at the discharge point.

The Assimilative Capacity is calculated as follows:

Q(rev)C(rev) + Q(dis)C(dis) = C total (mg/l) Q(rev) + Q(dis)

Where: Q is the volume of flow/discharge

C is the concentration of indicator chemical parameters

(rev) is the receiving watercourse

(dis) is the discharge liquid)

(tot) is the mixed total.

The assimilative capacity of the receiving waters has been calculated using

available water quality data from the following sources:

• Estimation of the mean flow for the catchment area to point of

discharge;

• Water quality data from Duggan’s Bridge and Glasha Cross Roads;

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• Nutrient parameters have been taken from runoff supplied by Galmoy.

These values do not take into account any further treatment in the

settlement lagoon.

• Treated effluent values have been taken from the treated runoff trial

where available, and guidelines values otherwise;

Available water quality data for the Glasha were used in the calculations. As

ammonium concentrations are below detection limits (<0.05) background

concentrations are assumed to be at nominally clean concentrations of 0.008 mg/l.

The results of the assimilative capacity calculations are included below for pre-

treatment and post treatment of the run-off water in the proposed wetland in the

Table 7 and 8 on the following page.

TABLE 7 PRE TREATMENT 95%ILE ASSIMILATIVE CAPACITY

Parameter

Units

Background Quality

Discharge Quality

Estimated Mean stream flow

l/s

Discharge m

ean Volume l/s Assimilative

Capacity

Relevant

standard

C total C Total

mg/l

SI 272 of

20099

Conductivity mS/c

m 727 1340 49.440 3.454 40571 767.03

Sulphate mg/l 141 546 49.440 3.454 8856.9 167.45

C.O.D. mg/l 19 109 49.440 3.454 1315.8 24.88

Total

Ammonical

Nitrogen

mg/l 0.00810 18.9 49.440 3.454 65.7 1.242 <0.065

BOD mg/l 1.311 4.79 49.440 3.454 80.8 1.53 <1.5

Zinc µg/l 43.6 284 49.440 3.454 3136.5 59.30 10012

Ortho

phosphate mg/l 0.02 0.02 49.440 3.454 1.1 0.02 <0.075

Cadmium µg/l 1 1 49.440 3.454 52.9 1.00

Arsenic µg/l 1.57 62 49.440 3.454 291.8 5.52 25

Lead µg/l 1.07 17.5 49.440 3.454 113.3 2.14 7.2

pH pH

units 7.64 7.64 49.440 3.454 404.1 7.64

9 Mean concentrations used as mean flow is the crucial parameter

10 Notionally clean river. Data from Rathdowney WWTP indicates upgradient BOD = 1.3mg/l

11 Notionally clean river

12 High Alkalinity in the surface water runoff <150 mg/l

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Parameter

Units

Background Quality

Discharge Quality

Estimated Mean stream flow

l/s

Discharge m

ean Volume l/s Assimilative

Capacity

Relevant

standard

C total C Total

mg/l

SI 272 of

20099

D.O. mg/l 10 10.75 49.440 3.454 531.5 10.05

S.S. mg/l 20.77 108 49.440 3.454 1399.9 26.47

Nitrate mg/l 17.8 7.74 49.440 3.454 906.8 17.14

The elevated ammonium concentrations are a function of the type of organic material

used in the TMF cap. Ammonium concentrations in Phase 1 and 2 will reduce over the

following 1-2 years and fall below 5 mg/l on average based on recent data. To further

reduce the ammonium concentrations on the TMF cap, it is proposed to non-intensively

farm the rehabilitated TMF area. Nitrogen inputs will be below 170kg/hectare to help

achieve the objective of the Nitrates Directive (91/676/EEC) to curtail nitrate/ammonium

losses from agriculture to surface and ground waters. Concentrations of BOD are also

slightly elevated above the mean limits as set out in SI272 of 2009. Concentrations of

BOD in the runoff are likely to decrease over the following years once the tailings cap is

established.

Removal rates are of 98% removal efficiency for ammonium and 80% BOD are

anticipated in the wetland area and a removal rate of 50% for metals and sulphate based

on trial data (VESI Environmental Ltd.) and previous studies. Given the low loading rates

in the proposed wetland system the above removal rates can easily be achieved. Similar

and higher rates have been achieved in wetland systems in Ireland at Glaslough13 and in

wetlands treating tailings facilities and metals in motorway runoff14. The suitability of

Typha and Phragmites for treating metals is well known15. A range of emergent and

floating aquatic plants is recommended to enhance the biodiversity.

13

Glaslough ICW

http://www.dublincity.ie/WaterWasteEnvironment/WasteWater/Documents/Glaslough_ICW__Dan_Doo

dy_et_al_-_Feb_09__.pdf 14

Kadlec, R.H. and Knight, R.L (1996). Treatment Wetlands 15 EA UK (2003) Guidance Manual for Constructed Wetlands

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TABLE 8 REMOVAL RATES BASED ON TRIAL DATA AND PREVIOUS STUDS

Parameter Removal rates

% Removal

Lead 50%

Zinc 50%

Sulphate 50%

Total ammonia 98%

Arsenic 50%

BOD 80%

COD 50%

The proposed Hydraulic Retention times in the wetland area are very high at 4

litre/m2/day, therefore the removal rates can easily be achieved.

TABLE 9 POST TREATMENT 95%ILE ASSIMILATIVE CAPACITY

Parameter Units

Background Quality

Discharge Quality

Estimated Q95 stream flow

l/s

Treated Discharge Volume16

l/s

Assimilative

Capacity

Relevant

standard

C total

C Total

mg/l

SI 272 of

2009

Conductivity mS/c

m 727 1000 49.440 3.454 39396 744.83

Sulphate mg/l 141 273 49.440 3.454 7914.0 149.62

C.O.D. mg/l 19 54.5 49.440 3.454 1127.6 21.32

T Ammonia mg/l 0.008 0.6 49.440 3.454 2.5 0.047 <0.065

BOD mg/l 1.3 0.96 49.440 3.454 67.6 1.28 <1.5

Zinc µg/l 43.6 142 49.440 3.454 2646.1 50.03 10017

16

Figure conservatively does not take into account dilution via rainfall on the wetland or attenuation area 17 High Alkalinity in the surface water runoff <150 mg/l

Galmoy Mines Ltd.

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Parameter Units Background Quality

Discharge Quality

Estimated Q95 stream flow

l/s

Treated Discharge Volume16

l/s

Assimilative

Capacity

Relevant

standard

C total

C Total

mg/l

SI 272 of

2009

Ortho

phosphate mg/l 0.02 0.01 49.440 3.454 1.0 0.02 <0.035

Cadmium µg/l 1 1 49.440 3.454 52.9 1.00

Arsenic µg/l 1.57 31 49.440 3.454 184.7 3.49 25

Lead µg/l 1.07 8.75 49.440 3.454 83.1 1.57 7.2

pH pH

units 7.64 7.64 49.440 3.454 404.1 7.64

D.O. mg/l 10 10.75 49.440 3.454 531.5 10.05

S.S. mg/l 20.77 21.6 49.440 3.454 1101.5 20.82

Nitrate mg/l 17.8 7.74 49.440 3.454 906.8 17.14

For a notionally clean river and an emission limit value of 0.6 mg/l of ammonia, Table 9

indicates the primary discharge would not cause deterioration in the environmental status

of the river. Approximately 72% of the hypothetically available assimilative capacity of

the River Glasha will be consumed at this ELV. Therefore the proposed emission limit

value of 0.6 mg/l of ammonia and a tighter limit of 0.5 mg/l to be achieved by 1st

January 2021.

For a notionally clean river and an emission limit value of 2.4 mg/l of BOD, Table 9

indicates the primary discharge would not cause deterioration in the environmental status

of the river. Approximately 80% of the hypothetically available assimilative capacity of

the River Glasha will be consumed at this ELV. Therefore the proposed emission limits

value of 2 mg/l of BOD and a tighter limit of 1.5 mg/l to be achieved by 1st January 2021.

While ortho-phosphate has not been an issue at Galmoy Mine, the TMF or in the Glasha

River it is proposed to monitor as part licence.

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TABLE 10 PROPOSED MAXIMUM EFFLUENT STANDARDS FOR DISCHARGE

Parameter Units Discharge ELV

Total Ammonical N mg/l N 0.6

BOD mg/l 2

Zinc mg/l 0.5

Ortho phosphate mg/l 0.05

Arsenic µg/l 0.1

Lead mg/l 0.01

pH pH units >6

<9

S.S. mg/l 25

Nitrate mg/l 25

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Ecological assessment

The site nearest aquatic based Designated Conservation Area hydrologically linked to the

river is the River Barrow and River Nore SAC and River Nore SPA, the boundary of which

is over 13 km and 16km downstream respectively. In addition to the assimilative capacity

findings these distances further rule out any significant alone and in-combination impacts

based on the fact that any material from the tailings ponds will be completely diluted and

likely undetectable before it reaches the SAC/ SPA. No toxic and or other effects are likely

even immediately downstream of the discharge.

It is considered that no significant adverse effects will arise from the proposed TMF

discharge from Galmoy Mines and that this development can be screened out from

further Appropriate Assessment.

In informing this it is an assumption that ongoing monitoring and careful design

approaches to minimise risks to local surface and groundwater quality will be

implemented.

Protected Species

Two species of aquatic vertebrates of national and international importance occur in the

Nore system, these are the white clawed crayfish: Austropotamobius pallipes and the

freshwater pearl mussel: Margaritifera margaritifera durrovensis. Both species are

protected under SI 112 of 1990 of the Wildlife Act (1976) species. The salmonid

populations were assessed in previous surveys and the white-clawed crayfish

Austropotamobius pallipes Lereboullet, following the population depletion in the

catchment as a result of a disease (Baars and Kelly-Quinn, 2008), has not been surveyed

at the monitoring sites in the past two years.

Pearl Mussel

The Nore Freshwater Pearl Mussel, Margaritifera durrovensis, has been studied by

Galmoy mine’s consultants, Ecoserve, over the period 1995 to 2000. The results of the

investigations show that not only is the population critically low but no recruitment has

been detected for over 20 years. An average of 72.5% of the mussel population inhabits

an area downstream of the confluence of the River Erkina and Nore at Durrow. Ecoserve

state that there is no suggestion of any change in the pearl mussel population which

could be attributed to the activities of the mine at Galmoy.

34

D.2 Environmental Considerations and Best Available Techniques (BAT)

Describe, in outline, the main alternatives, if any, to the proposals contained in the

Review Form.

Describe any environmental considerations which were made with respect to the use of

cleaner technologies, waste minimisation and raw material substitution.

Describe the measures proposed or in place to ensure that:

(a) the best available techniques are or will be used to prevent or eliminate or, where

that is not practicable, generally reduce an emission from the activity;

(b) no significant pollution is caused;

(c) waste production is avoided in accordance with Council Directive 75/442/EEC of

15 July 1975 on waste; where waste is produced, it is recovered or, where that is

technically and economically impossible, it is disposed of while avoiding or

reducing any impact on the environment;

(d) energy and other resources are used efficiently;

(e) the necessary measures are taken to prevent accidents and limit their

consequences; and,

(f) the necessary measures are taken upon definitive cessation of activities to avoid

any pollution risk and return the site of operation to a satisfactory state.

This section should present a statement on energy efficiency at the site to include,

where appropriate, an energy audit with reference to the EPA Guidance document on

Energy Audits. Licensees should have regard to Section 5 of the EPA Acts 1992 and

2003 in selecting BAT and in particular the following:

• The use of low-waste technology;

• The use of less hazardous substances;

• The furthering of recovery and recycling of substances generated and used in

the process and of waste where appropriate;

• Comparable processes, facilities or methods of operation, which have been

tried with success on an industrial scale;

• Technological advances and changes in scientific knowledge and

understanding;

• The nature, effects and volume of the emissions concerned;

• The commissioning dates for new or existing facilities;

• The length of time needed to introduce the BAT;

• The consumption and nature of raw materials, including water, used in the

process and their energy efficiency;

• The need to prevent or reduce to a minimum the overall impact of the

emissions on the environment and the risks to it;

• The need to prevent accidents and to minimize the consequences for the

Environment; and,

Galmoy Mines Ltd.

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• The information published by the Agency in the form of sectoral BAT

Guidance documents and the relevant BREF documents published by the EC

(available for download at http://eippcb.jrc.es/ and at www.epa.ie).

Compliance with legislation and BAT

The EU Directive on the management of waste from the extractive industries,

(Directive 2006/21/EC of the European Parliament and of the Council of 15 March

2006) hereafter referred to as The Mine Waste Directive (Regulations) 2009,

applies to waste resulting from the extraction, treatment and storage of mineral

resources and sets minimum requirements on how waste from an extractive

industry is managed by specifically addressing environmental and human health

risks that may arise from its treatment and disposal. Mine waste facilities must be

subjected to the new provisions by 2012.

The current EU level framework for the safe management of waste from the

extractive industry comprises:

• The Mine Waste Directive as described above, together with;

• A best available techniques reference (BREF) document for the

Management of

• Tailings and Waste-Rock (MT–WR) in mining; and

• An amendment to the scope of the Seveso II Directive to include mineral

ore processing, and particularly, tailings dams or facilities used in

connection with such processing.

To operate, a company must obtain a permit issued by the competent authorities;

and in the event of modification to an existing waste facility this authority must

be satisfied that (amongst other conditions) arrangements have been made for

the closure of the facility, rehabilitation of the land and Post-Closure

maintenance/monitoring needs are catered for. A facility will only be regarded as

finally closed when the competent authority has carried out a final inspection,

assessed the reports produced by the operator and confirmed that

restoration/rehabilitation has been completed as planned.

The operator will be required to maintain and monitor the site for a period

determined by the competent authority. The cost of this aftercare must be met by

the operator. The closure plan and aftercare procedures should be included as

part of the required waste management plan (reviewed every five years) with

specific reference to the:

• Evaluation of leachate generation and quality;

• Prevention of leachate generation;

• Prevention of contamination of surface and groundwater; and

• Treatment of any contaminated waters prior to discharge.

• The general requirement for the safe management of extractive waste is

established by

• Article 4 of the Mine Waste Directive. Measures to be taken are to be

based on Best

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• Available Techniques (BAT) as defined in Directive 96/61/EC (The

Integrated Pollution

• Prevention and Control Directive). In tandem with the development of the

Mine Waste

• Directive, the EU IPPC Bureau in Seville developed the BREF document for

Management of Tailings and Waste Rock in Mining Activities (MT – WR),

which was published in July 2004 and intended to be used as a reference

when trying to determine BAT for the management of mine waste.

The determination of appropriate BAT involves taking local and site specific

factors into account. Typically a risk assessment is applied in order to assess the

techniques used and to ensure they are most appropriate to the specific

circumstances in terms of environmental, safety, technical and engineering

aspects. Chapter 4 of the BREF document describes techniques that are

considered relevant in determining BAT and BAT-based measures. Section 4.2.4

of the BREF document deals specifically with the closure and aftercare phase.

A risk assessment for the failure of the Galmoy TMF has been carried out as

previously stated which includes the risk at closure. The probability of failure of

the Galmoy facility and release of either tailings water or tailings solids to the

environment as indicated by the risk assessment is less than that predicted for

the Active phase because of the reduction and near absence of water on top of

the dam at closure. The final cap profile for both Phases 1 and 2 will be shaped as

a dome and as such runoff migrates to the external walls and into a perimeter

interceptor drainage system. The drainage system and spillways have been

designed to cater for a 1 in 150 year storm event.

The cap for Phase 3 will be shaped with a gentle slope falling towards a low point

on the embankment wall where a spillway will be installed to transfer surface

water runoff from all phases to the attenuation pond. Therefore, the possibility of

the tailings being mobilised in the absent of any pond water on top of the facility

is negligible. Therefore, no financial provision will be required to address such an

event because of the negligible probability of occurrence.

Wetlands are specified as an appropriate BAT treatment for mining operation

under BREF guidance (pg 356).

In wetland technology the seepage waste are collected into a wetland area

constructed on an old pond or an swamp areas close to the operation. Using

neutralising construction materials (carbonate rocks) and natural specific

vegetation, the metals in seepage waters are precipitated and clean waters can

be lead towards local rivers/lakes.

The aim of the reclamation and closure plan for the Galmoy Mines tailings facility

is to reintegrate land that has been disturbed by construction, operational and

decommissioning activities into the surrounding landscape. It is intended that the

post reclamation quality of surface run-off water and capability of the disturbed

areas will, where possible resemble conditions prior to disturbance or allow an

alternative land use.

Galmoy Mines Ltd.

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Galmoy Mines is currently in the process of taking necessary measures upon

definitive cessation of activities to avoid any pollution risk and return the mine

site to a satisfactory state as outlined in the Closure Restoration and Aftercare

Management Plan (CRAMP). Legislation requires that a Mine Closure Plan (MCP)

be prepared to facilitate a controlled exit from any redundant mine in order to

minimise the long term environmental impacts. Adequate financial provision has

been made for closure and the plan has incorporated physical rehabilitation,

pollution prevention and socio-economic considerations.

The Mine Closure Plan of December 2010 has been approved by the Authorities

and is now being implemented in agreement with the Mine Closure Plan Schedule.

A mine closure programme has been developed to implement the Mine Closure

Plan. In addition to the Closure Rehabilitation Aftercare and Management Plan

(CRAMP), a monitoring programme has been devised and the costs associated

with monitoring calculated.

The overall objective is to rehabilitate the mine site, TMF and underground and to

minimise the long term impacts on the environment. This is achieved by setting

objectives and implementing the Mine Closure Programme which consists of

decontamination, demolition, retention and rendering safe. Financial provision is

provided for the completion of this task.

Discharge of treated mine water to the River Goul will cease in 2013. A proposed

discharge point to the River Glasha (SW2) is included in this application for the

rehabilitated tailings management facility. The main objectives for the

rehabilitation of Phase 1 & 2 of the TMF are to achieve a sustainable, and

stabilizing vegetative cover, install an engineered, self draining cap and drainage

system, establish agricultural grassland and biodiversity habitat, long term

beneficial agricultural use and establish a physically, chemically and biologically

stable and sustainable structure. The main objectives for the rehabilitation of

Phase 3 are to achieve a sustainable and stabilizing vegetation cover, to establish

an integrated constructed wetland to treat Phase 1 and Phase 2 runoff and

provide a biodiversity habitat.

The integrated constructed wetland is a low waste sustainable treatment

technology which can adapt to conditions and deliver a high quality output. The

integrated constructed wetland can treat and reduce nitrate, ammonium,

phosphate, BOD and metals thereby substantially reducing the overall chemical

loading on the River Erkina. Wetland trails in 2009 indicated the high success rate

of the wetlands area. Wetlands recovery and recycle nutrients that would

otherwise be discharge to the surface water network.

Phase 3 (and, by extension, from Phases 1 and 2 which drain into Phase 3) will

remain, if required, during this period. Assuming normal rainfall and

evapotranspiration rates for grassland, surface water runoff from Phase 1 & 2 into

Phase 3 will be a relatively small volume. Surface water falling on Phase 3 will be

free of contamination. As a precautionary/interim measure the surface water post

treatment in the wetland r can be retained, if necessary, subject to approval by

Galmoy Mines Ltd.

38

EPA, and pumped back to the water treatment plant on site t until the discharge

meetings the standards as set out in this document. Water in the existing holding

ponds can be discharge to the River Goul to achieve full compliance at the final

discharge to the River Goul. This will be an interim measure while the integrated

constructed wetland is being established.

SECTION E: STATUTORY REQUIREMENTS

E.1 Best Environmental Practices – Compliance with Legislation

Demonstrate if the best environmental practices are in place for control of diffuse

emissions from the installation/facility as set out in the following legislation:

(a) a specification prepared by the Agency in accordance with Section 5 of the

Environmental Protection Agency Act 1992 as amended by Section 7 of

the Protection of the Environment Act 2003;

(b) the Urban Waste Water Treatment Regulations 2001 (S.I. No. 254 of

2001) as amended by the Urban Waste Water Treatment (Amendment)

Regulations 2004 (S.I. No. 440 of 2004) or any future amendment

thereof;

(c) the European Communities (Good Agricultural Practice for Protection of

Waters) Regulations 2009 (S.I. No. 101 of 2009) or any future

amendment thereof;

(d) the Local Government (Water Pollution) Act, 1977 (Control of Cadmium

Discharges) Regulations 1985 (S.I. No. 294 of 1985);

(e) the Local Government (Water Pollution) Act, 1977 (Control of

Hexachlorocyclohexane and Mercury Discharges) Regulations 1986 (S.I.

No. 55 of 1986);

(f) the Local Government (Water Pollution) Acts, 1977 and 1990 (Control of

Carbon Tetrachloride, DDT and Pentachlorophenol Discharges) Regulations

1994 (S.I. No. 43 of 1994); and,

(g) measures or controls identified in a pollution reduction plan for the river

basin district prepared in accordance with Part V of the EC Environmental

Objectives (Surface Waters) Regulations 2009 S.I. No. 272 of 2009 for the

reduction of pollution by priority substances or the ceasing or phasing out

of emissions, discharges and losses of priority hazardous substances.

Galmoy Mines Ltd.

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E.1 Best Environmental Practices – Compliance with Legislation

This review is based on the requirement to comply with EC Environmental Objectives

(Surface Waters) Regulations 2009 S.I. No. 272 of 2009 and EC Environmental

Objectives (Freshwater Pearl Mussel) Regulations 2009. These regulations apply to the

habitats that are within the boundaries of sites designated as a Special Area of

Conservation, under the European Communities (Natural Habitats) Regulations, 1997

(S.I. No 94 of 1997).

Although compliance with Second Schedule of the Urban Waste Water Treatment

Regulations 2001 (S.I. No. 254 of 2001) as amended by the Urban Waste Water

Treatment (Amendment) Regulations 2004 (S.I. No. 440 of 2004) is required, the

limits for Total Nitrogen in particular have now been superseded by the Environmental

Objectives (Freshwater Pearl Mussel) Regulations 2009.

Based on the runoff water quality from the capped TMF and the results of the trial

wetlands, the final discharge will achieve the standards as set out under S.I. 272 of

2009. Proposed effluent discharge limits as set out in section D above can be easily

achieved following completion of capping works and establishment of the wetlands

area.

Section 5 of the Environmental Protection Agency Act 1992 as amended by Section 7 of

the Protection of the Environment Act 2003; states that the Best Available techniques

shall be construed as a reference to the most effective and advanced stage of

development of an activity and its methods of operation, which indicate the practical

suitability of particular techniques for providing, in principle, the basis for emission

limit values designed to prevent or eliminate, or where that is not practicable,

generally to reduce an emission and its impact on the environment as a whole. Mining

activities ceased onsite in October 2012. Results from initial cessation of mining since

June 2009 demonstrate the reduction in emission of Pb, Zn NH3 etc to surface water.

The mine has achieved 100 % compliance for ammonium and Pb and 99.2% Zn in

2012 at SW1. Extensive monitoring of the tailings and surface water has been

undertaken and is submitted as part of this application.

Water quality from the cap containing compost will improve with time as indicated from

the initial monitoring results. All surface water from the rehabilitated TMF will be

directed into the wetland, where any remaining elevated values will be removed.

Discharge from the wetland will flow towards an attenuation pond. If water quality

leaving the wetland is unsatisfactory, all waters will be pumped to the treatment plant

until satisfactory for discharge.

The success of the rehabilitation and closure works will be measured by its

performance during the 5 year active, 5 year passive and the 20 year stable phase.

In the introduction, reference is made to BREF- MTWR criteria and the work

undertaken by Galmoy is considered to comply with the BREF- MTWR guidelines.

Based on the BREF - MTWR criteria for success, the criteria for closure needs to include

Galmoy Mines Ltd.

40

physical, chemical and biological stability. The hydrological environment, geographical

influences, and local sensitivities also need to be considered together with future land

use. A financial mechanism has been agreed with the EPA and associated authorities.

Awareness of the socio-economic issues needs to be highlighted. These issues have

been discussed in this report and are briefly summarised below. BAT guidelines

outlined in BREF – MWTR 2005 will be used to assess that the criteria for closure are

being met (Table E-1.1).

41

Criteria for the Closure of Tailings Facilities (BREF MTWR Chapter 4, Table 4.2.4.1)

Table E-1.1: Criteria for Closure

Issue Closure Objectives TMF rehabilitation achievements/goals for Galmoy

Physical Stability All remaining anthropogenic structures are

physically stable

The TMF is designed to exceed the safety criteria given by

the ICOLD standard.

TMF audited by Golder for the past 10 years with

extensive data submitted to support the physical stability

of the TMF.

The formation of the dome for Phases 1 and 2 and the

completion of Phase 3 will minimise the risk of dam

failure.

Chemical Stability Physical structures remaining after closure are

chemically stable

Monitoring of herbage, the compost cap, tailings, and

water quality to continue in the Active Care period.

Monitoring data to support water quality emanating from

the TMF recorded and monitored over 10 years in TMF

annual Audit as per IPPC license.

Cap to include a minimum of 0.3m of glacial till/soil in

Phase 1, an average thickness of 0.8m in Phase 2 and

1.0m in Phase 3.

Reduced monitoring to occur in the Passive Care period

and further reductions in the Stable Phase.

Biological Stability The biological environment is restored to a

natural, balanced ecosystem typical of the area, or

is left in such a state so as to encourage and

enable the natural rehabilitation and/or

reintroduction of a biologically diverse, stable

environment

The rehabilitation programme will return the surface of

the TMF to a combination of agronomic and ecologically

sustainable land uses.

Monitoring to date substantiates the validity of these end

points.

Galmoy Mines Ltd.

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Issue Closure Objectives TMF rehabilitation achievements/goals for Galmoy

Hydrological and

hydrogeological

environment

Closure aims at preventing physical and chemical

pollutants from entering and subsequently

degrading the downstream environment -

including surface and ground waters

Monitoring of groundwater and surface water to continue

in the Active and Passive Care periods. Water Treatment

Plant to remain operational as required. A land drainage

system may be incorporated into surface of TMF if

required. Construction of a wetlands and attenuation pond

for surface water prior to discharge to Glasha stream.

Geographical and

climatic influences

Closure is appropriate to the demands and

specifications of the location, in terms of climatic

(e.g., rainfall, storm events, seasonal extremes)

and geographic factors (e.g., proximity to human

habitations, topography, accessibility of the mine)

Rainfall and evapotranspiration rates have been taken

into consideration for drainage design as the impact of

extreme events.

Local sensitivities and

opportunities

Closure optimizes the opportunities for restoring

the land and the upgrade of land use is considered

whenever appropriate and/or economically

feasible.

Regionally sourced compost has been used to cap the

tailings on Phases 1 and 2 and glacial till soil used to form

the dome shapes, cap the tailings of Phase 3 and

installation of a wetland.

Land use Rehabilitation is such that the ultimate land-use is

optimized and is compatible with the surrounding

area.

Surface of the TMF will be returned to a mixed growing

economy; grazing and wetland biodiversity.

Socio-economic

considerations

Consideration must be taken of opportunities for

local communities whose livelihoods may depend

on the employment and economic fallout of the

mining activities. Adequate measures are made to

ensure that potential socio-economic advantages

associated with closure are maximized.

This issue is mainly related to the industrial area of the

mine site and will be dealt with separately as it does not

focus on the TMF.

43

The Closure Rehabilitation and Management Plan (CRAMP) was developed to reduce

the overall impact of emissions and risk to the environment during

decommissioning. It provides a detailed ordered approach to the closure process.

The CRAMP database is a detailed database used to keep track of the costs involved

in mine closure and record the progress of decommissioning, decontamination,

dismantling and rehabilitation of each specific area. This includes planning,

identification of success criteria, monitoring of progress, selling of equipment,

contractor management, and cost management. The CRAMP database allows

Galmoy Mines to manage costs and an Independent Third Party to audit costs and

review the progress of work achieved from the previous audits and provide a

statement of quality of the work undertaken in the intervening period.

Certification that works have been completed and are of the required standard will

be issued by Galmoy Mines personnel or by a Third Party as and when each mine

Closure Plan task Area has been completed. A transparent report prepared by the

Third Party on expenditure and costs is provided to the Authorities on a quarterly

basis and forms the basis for the request for drawdown of funds. Finally, within the

CRAMP database there is an outline of the monitoring proposals and a statement as

to the certification requirements. Final verification of rehabilitation will be

undertaken once all areas have been rehabilitated.

44

SECTION F: APPROVED ADJUSTMENTS & CONDITIONS

Where the Office of Environmental Enforcement (OEE) of the Agency has agreed any

variations or adjustments to the conditions of the existing licence, the licensee must

supply a schedule detailing these agreed variations and adjustments to the existing

licence conditions. An updated, scaled drawing of the site layout (no larger than A3)

providing visual information on such adjustments or variations where appropriate should

be included.

In the case of once-off assessments/ reports required under conditions of the existing

licence the licensee must supply a schedule detailing those assessments/ reports that

have been completed and agreed with the Office of Environmental Enforcement (OEE) or

as otherwise agreed.

Attachment No F1 shall include the schedule of variations and/or adjustments together

with the updated drawing.

Condition

No.

Existing

Condition

Proposed Wording

(where

appropriate)

OEE

Agreement

Reference

Description

45

Attachment No F1