Joint Statement No 3 by the Environmental Protection Agency (EPA), Limerick City & County Council and Health Service Executive

Date released: Oct 09 2017

Joint Statement by the Environmental Protection Agency (EPA), Limerick City & County Council and Health Service Executive Mid-West

 1         Notification of dust deposition problem in residential areas of west Limerick City

Since the end of March 2017, the EPA has received a significant number of complaints about dust deposition from residents of the Mungret and Raheen areas of Limerick City.

 

Month

Number of Complaints

April ¹

78

May

24

June

25 ²

July

0

August

1

September

0

¹ Including late March

² Related to a natural event 20-21 June

 

Complaints were also received by Limerick City & County Council and the Health Service Executive (HSE) Mid-West. The complaints described thick dust deposited on cars, roofs and windows, solar panels and garden furniture. Complainantsstated their belief that the source of the dust was likely to be the nearby Irish Cement plant, which operates under an EPA Licence, P0029-03.  

2         Investigation of the dust issue

  • When the first complaints were received, EPA personnel began an investigation and convened an Inter-Agency group involving Limerick City and County Council and the Health Service Executive (HSE) to ensure integrated oversight of the investigation.

  • Samples of dust from cars belonging to a number of complainants were analysed and compared to samples of materials from the Irish Cement facility. Initial sample analysis results indicated that material in the dust deposits matched material sampled from the Irish Cement facility. Further samples also matched material from the Irish Cement facility.

  • Irish Cement committed to respond to each complaint of dust they received and to seek to visit complainants where possible.  Since that date, Irish Cement personnel have visited a number of complainants and have taken samples of dust for analysis.

  • The EPA and Limerick City & County Council have assessed the extent to which other potential discrete sources of dust may exist in the area. No such discrete source, other than the Irish Cement facility, has been identified as being a likely contributor to the issue.

  • The EPA initiated a formal Compliance Investigation into the management and control of dust at the Irish Cement facility on 25 April 2017. As part of their response to this investigation, Irish Cement conducted a detailed “Root and Branch” review of the material and product handling infrastructure and processes over the entire site. Any identified defects or failures were to be rectified immediately on discovery. 

  • The company also commenced a series of engineering and procedural measures to improve control over potential sources of fugitive dust emissions, including material stockpiles, conveyor belts, yard areas and roadways.

  • The EPA carried out a site inspection at the Irish Cement facility on Monday 22 May 2017 to assess progress in complying with the corrective actions imposed under the Compliance Investigation. The inspection team observed good progress in relation to each corrective action.

  • A final report on the “Root and Branch” analysis of activities on-site was submitted by Irish Cement on 12 June 2017.  Preventative maintenance and mitigation measures identified in the report are being tracked via individual corrective actions within the Compliance Investigation. Mitigation measures that have been completed to date include:

    • roadway around Cement Mill 5 building resurfaced,

    • store yard area (4.5 acres) covered in topsoil and seed with grass,

    • Roadway adjacent to the area around the Ascon shed resurfaced with tar,

    • additional sheeting in the limestone transfer building,

    • additional sheeting and doors associated with the clinker reject system,

    • sheeting installed to enclose limestone conveyors at Cement Mill 6 and Cement Mill 7,

    • sheeting installed to enclose the area around the limestone intake feeder,

    • Doors installed to enclose the entrance to the Blendomat building,

    • Water bowser in operation on quarry roads,

    • Netting installed at the kiln coolers, off-spec clinker chute and clinker transport system from the clinker silo to the cement mills.

      All of the mitigation measures identified in the “Root and Branch” report are scheduled for completion by June 2018. The EPA will continue to supervise progress in closing out the Compliance Investigation as part of its ongoing enforcement activity.

  • A second Compliance Investigation was initiated on 27 April 2017, into complaints of excessive noise from the Irish Cement facility. In response to this investigation, the Agency required the licensee to engage independent consultants to assess the site, to determine potential noise sources and identify any possible mitigation.  This work identified kiln shell cooling fans as a noise contributor onsite.  These kiln shell cooling fans are currently being replaced with fans that have a reduced sound pressure level. The replacement of fans is due for completion by 31 October 2017. The EPA will continue to supervise progress in closing out this Compliance Investigation as part of its ongoing enforcement activity. 

  • A large number of complaints (25) were received by the EPA from residents of the Mungret and Raheen areas about dust deposition on 20 and 21 June 2017.  There were no indications of any release of cement dust from the Irish Cement facility at that time, but these complaints corresponded with similar reports of unusual dust deposition elsewhere, suggesting a diffuse ambient origin.

3         Public health

Health advice based on sampling results to date and surveillance of healthcare usage confirms that exposure to cement dust may cause respiratory, eye and skin irritation but does not pose a serious health risk in the short term. In relation to possible short-term health implications, HSE Mid-West has continued to liaise with general practitioners and the local hospital emergency department. As before, no unusual patterns of ill health have been identified.

Because of local residents’ queries in relation to possible longer term health effects of releases of cement dust, HSE MidWest has collated detailed information on cancer rates and deaths from respiratory causes: -

  • Cancer Registration rates across the MidWest from 1994 to 2014 were examined by the National Cancer Registry (NCRI). This analysis shows that the rates in Ballycummin Electoral Division (ED#21051, which covers the Mungret /Raheen/Dooradoyle area) were 2% lower than expected when the MidWest was used as a comparison and 9% less than expected when the Ireland rates were used as a comparison.
  • A historic analysis of deaths from respiratory causes in the Midwest between 1991 and 1996, which was undertaken as part of a previous study by the Small Area Health Research Unit (SAHRU) of Trinity College Dublin on behalf of the former MidWestern Health Board, was reanalysed. The new study examined differences between Electoral Divisions in the MidWest in standardised mortality rates (SMRs) for respiratory conditions for all ages, and then separately for under 65s and 65+ years, concluding that “Ballycummin Electoral Division (21051) has a statistically significant low SMR for respiratory conditions for all ages and for over 65s.” As more recent information is not routinely available from current national information systems, the Central Statistics Office (CSO) have agreed in principle to provide mortality records for deaths from respiratory causes for the Midwest area to HSE MidWest Public Health Department on a once off basis for the years 2010-2014 to facilitate geocoding and updated analysis of local mortality rates.

Herds in the Mungret area of Limerick were included in the EPA National Dioxin Monitoring Programme for the first time in 2017. The samples were analysed by the State Laboratory on behalf of the EPA, and the results confirmed that milk from the Mungret area contained very low dioxin levels, which were well below permitted limits. Reports in this series are available on the EPA website at http://www.epa.ie/pubs/reports/other/dioxinresults/.

4         Ambient dust monitoring network

On 26 April 2017, the EPA installed a dust monitoring unit in the Mungret / Raheen area to provide continuous information on dust levels for assessment against air quality standards and to support ongoing health risk assessment by the HSE.

On 10 May 2017, Limerick City & County Council established a network of dust monitoring units in three locations in Limerick City, O’Connell Street, Castletroy and in Mungret / Raheen, close to the EPA location.

Dust monitoring results obtained since the installation of the monitoring network up to end July 2017 have been fully compliant with the statutory PM10 and PM2.5 limit values set for the protection of human health (See Particulate Monitoring in Limerick: Data Summary – 26 April to 31 July 2017). The results indicated that, over the period:

  • dust levels were generally somewhat higher in O’Connell Street, with lower and broadly similar results from the Castletroy and Mungret areas;

  • dust levels associated with winds from the Northwest were very similar to levels observed at other times.

    The EPA monitoring unit was removed on 15 June 2017 in favour of the Limerick City & County Council network which remains in operation in O’Connell Street, Castletroy and Mungret.  Data from the air quality monitors is hosted by and can be accessed through the following website: http://www.airqweb.co.uk.

5         Conclusion

The investigation by the EPA, in coordination with HSE Mid-West and Limerick City & County Council, into the dust issue in the Mungret and Raheen areas of Limerick City has demonstrated that

  • a dust deposition event, or events, occurred in the period 31 March – 30 April 2017 that led to a significant number of complaints from residents of the Mungret and Raheen areas;

  • the deposited dust contained cement material that is likely to have originated from the Irish Cement facility;

  • though the deposits of dust resulted in understandable public concern about possible health impacts, no such effects have been observed or reported;

  • ambient air quality monitoring, which commenced shortly after the first complaints and is ongoing, shows that dust levels in Limerick have consistently complied with statutory air quality standards.

  • additional dust control and containment measures have been, and continue to be, implemented by Irish Cement in line with their “Root & Branch” review.

The results of the investigations conducted by the three agencies confirm that the matter has been brought back within normal regulatory control. Accordingly this Inter-Agency Joint Statement concludes the work of the Inter Agency Group.

The EPA will continue to enforce the requirements of the Licence, and will continue to scrutinise the delivery by Irish Cement of their dust and noise control programmes under the ongoing Compliance Investigations. Further enforcement action will be considered by the EPA in line with its enforcement policy.

The EPA will continue to maintain access to the Information Page in relation to Irish Cement Mungret at http://www.epa.ie/enforcement/licenseeinfo/irishcementlimited/ for the present, and will update its contents with any new information of direct relevance to the dust issue, at least until the conclusion of the associated Compliance Investigation.

The HSE will continue health surveillance and will make publicly available any new information which becomes available on relevant variations in local health status measures.

Limerick City & County Council will continue to maintain the Air Quality Monitoring Network in Limerick City. Further information on the network is available on www.limerick.ie at the link https://www.limerick.ie/council/newsroom/news/air-monitors-will-give-accurate-picture-limericks-air-quality and real time data from the monitors at http://www.airqweb.co.uk.