HUNTSTOWN POWER COMPANY LIMITED from Phase I is exported via a 220 kV cable to an ESB National Grid...

HUNTSTOWN POWER COMPANY LIMITED HUNTSTOWN POWER STATION PHASE I IPC LICENCE REVIEW APPLICATION SUPPORT MARCH 2006

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PB Power List of Revisions

LIST OF REVISIONS

Current Rev.

Date Page affected

Prepared by

Checked by (technical)

Checked by (quality

assurance)

Approved by

original Mar 06 C Reed

N Mant

P Philip

W E Hatfield

REVISION HISTORY

PB Project No 61825B. File : Application Support Huntstown Phase I Review

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PB Power Page i of iii

CONTENTS ...................................................................................................................................................

1. SECTION A – NON-TECHNICAL SUMMARY .................................................................2

1.1 Attachment A1 – Non-technical Summary.................................................................2

2. SECTION B – GENERAL .................................................................................................5

2.1 Attachment B1 – Company Registration Documents ................................................5

2.2 Attachment B2 – Site Map.........................................................................................7

2.3 Attachment B5 – Planning Approval and Licences....................................................7

2.4 Attachment B8 – Site Notice....................................................................................12

2.5 Attachment B10 – IPPC Directive............................................................................12

3. SECTION C – MANAGEMENT OF THE INSTALLATION..............................................13

3.1 Attachment C – Site Management and Control .......................................................13

3.2 Interfaces with Phase II ...........................................................................................15

4. ATTACHMENT D – OPERATIONAL INFORMATION....................................................19

5. SECTION E – EMISSIONS ............................................................................................20

5.1 Attachment E1A – Emissions to Air.........................................................................20

5.1.1 Major Emissions ...............................................................................................20

5.1.2 Minor Emissions ...............................................................................................21

5.2 Attachment E1B – Fugitive and Potential Emissions to Air .....................................23

5.3 Attachment E2 – Emissions to Water ......................................................................23

5.3.1 Abstraction .......................................................................................................23

5.3.2 Discharges .......................................................................................................24

5.3.3 Mitigation ..........................................................................................................26

5.4 Attachment E4 – Emissions to Ground....................................................................31

6. SECTION F – CONTROL AND MONITORING..............................................................32

6.1 Attachment F1 – Treatment and Abatement ...........................................................32


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6.2 Attachment F2 – Monitoring and Sampling .............................................................32

6.2.1 Monitoring at Source of Emission.....................................................................32

6.2.2 Ambient Monitoring ..........................................................................................32

7. SECTION I – EXISTING ENVIRONMENT AND IMPACT OF THE ACTIVITY...............34

7.1 Site Condition ..........................................................................................................34

7.2 Assessment of Impacts ...........................................................................................34

7.2.1 Attachment I1 – Atmospheric Emissions..........................................................34

7.2.2 Attachment I2 – Water Discharges...................................................................35

7.3 Attachment I8 – BAT Arguments and Mitigation Measures.....................................37

7.3.1 Selection of Process.........................................................................................37

7.3.2 Selection of Fuel...............................................................................................37

7.3.3 Use and Discharge of Water ............................................................................37

7.3.4 Other Raw Materials.........................................................................................37

7.3.5 Emissions to Air................................................................................................38

7.3.6 Waste ...............................................................................................................38

7.3.7 Energy Efficiency..............................................................................................38

7.3.8 Monitoring of Emissions ...................................................................................39

7.3.9 Noise and Vibration ..........................................................................................39

8. SECTION J – ACCIDENT PREVENTION AND EMERGENCY RESPONSE ................40

8.1 Attachment J – Accident Prevention and Emergency Response ............................40

9. SECTION L – STATUTORY REQUIREMENTS.............................................................43

9.1 Attachment L – Statutory Requirements..................................................................43

9.1.1 Section 83 of the EPA Acts ..............................................................................43

9.1.2 Habitats Directive .............................................................................................43

9.1.3 Water Quality Standards for Phosphorus.........................................................44

9.1.4 Government Acts..............................................................................................44

9.1.5 Technical Knowledge and Qualifications..........................................................44 APPENDIX A. SITE MAPS


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APPENDIX B. WATER BALANCE DIAGRAMS APPENDIX C. AIR DISPERSION MODELLING STUDY APPENDIX D. ORGANISATION CHART FOR GENSYS POWER LIMITED APPENDIX E. FIT AND PROPER PERSON DECLARATION APPENDIX F. CURRICULUM VITAES OF SENIOR OPERATING STAFF


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PB Power Page 1 of 44 Pages

LIST OF ABBREVIATIONS

AGI above ground installation AIS air insulated switchyard barg bar gauge pressure BAT best available techniques BGE Bord Gais Eireann BOD biochemical oxygen demand BREF BAT reference document CCGT combined cycle gas turbine CER Commission for Energy Regulation CO carbon monoxide CO2 carbon dioxide COD chemical oxygen demand dB(A) decibels A-weighted EMS environmental management system EPA Environmental Protection Agency EPC engineer, procure and construct ESB Electricity Supply Board ESBNG ESB National Grid EU European Union HCl hydrochloric acid or hydrogen chloride vapour HRSG heat recovery steam generator IPC Integrated Pollution Control IPPC Integrated Pollution Prevention and Control kPa kilopascal kV kilovolt m³ metre cubed mg/l milligrams per litre mg/Nm³ milligrams per normal metre cubed MSDS material safety data sheet MW megawatt MWe megawatt electric MWth megawatt thermal N nitrogen NO2 nitrogen dioxide NOx oxides of nitrogen

oxygen O2 Reg. register RO reverse osmosis SCOLF sulphur content of certain liquid fuels (Directive) SO2 sulphur dioxide TDS total dissolved solids te tonne V volts VOCs volatile organic compounds VPL Viridian Power Limited %v percent by volume µg/l microgram per litre


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1. SECTION A – NON-TECHNICAL SUMMARY

1.1 Attachment A1 – Non-technical Summary This document provides supporting material for an application to the Environmental Protection Agency for review of the IPC Licence 483 for Phase I of Huntstown Power Station, at Huntstown, Finglas, near Dublin. The plant is already authorised for operation under IPC Licence number 483, which covers both Phases I and II. The two Phases also already have full planning permission. This new application is for a review of the IPC Licence related to issue of a separate Licence for Phase II, including full compliance with the EU Integrated Pollution Prevention and Control (IPPC) Directive and incorporating updated project-specific information. This application for Phase I recognises areas common to both Phases, including:

• combined impacts of both Phases on noise; • combined impacts of both Phases on air quality; • surface water drains from Phase II into existing Phase I drain systems and

discharge; and • common environmental management and accident response procedures.

Huntstown Power Company Limited is a project company wholly owned by Viridian Group plc. The Huntstown Phase I combined cycle gas turbine (CCGT) project involves the construction and operation of a 342.7 MWe gas fired combined cycle gas turbine power plant located to the west of the Dublin Airport in Ireland. This plant has been in operation since November 2002.

Phase I of the power station is located on the same site as the Phase II 401.1 MWe unit, which is under construction and scheduled to enter commercial operation in Autumn 2007. Both plants are to be operated by a subsidiary of Viridian Group, GenSys Power Limited, as the Operations and Maintenance Company formed for this project, who manage the day to day operations and maintenance of the Plant including the reporting obligations and dispatching notifications.

The site was selected owing to being located near a main transmission line of its main fuel source of gas as well as the dominant electricity demand centre of Dublin. Natural gas, dominated by St. Fergus analysis, is piped approximately 2 km to the site from a connection to the Irish National Transmission System. Electricity from Phase I is exported via a 220 kV cable to an ESB National Grid (ESBNG) air insulated switchyard within the site boundary and then by cable to the 220 kV Finglas Substation some 2 km from the site.

The project was constructed under a Turnkey engineer, procure and construct (EPC) contract by Siemens AG with completion in November 2002.

The Huntstown Phase I Project comprises a Siemens V94.3A gas turbine driving a generator. The gas turbine exhausts into a horizontal gas path heat recovery steam generator (HRSG). The HRSG delivers steam at three pressures to a separate steam


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turbine generator. The turbine is of a tandem compound design coupled to an electric generator.

The layout of the plant is in a single building, with the gas turbine at one end of the turbine building, and the steam turbine at the other, under a single crane. There is an exhaust bypass stack for operation without the steam turbine. The HRSG has an integral exhaust stack.

The gas turbine and steam turbine generators are connected at 15 and 20 kV respectively to a three winding step up transformer via isolated phase busducts. Each generator has its own generator circuit breaker. Unit auxiliary transformers connected to the generator busbars supply a unitised 6.6 kV switchboard. An on-site air insulated switchyard (AIS), owned by ESBNG, was built as part of the Phase I project and will be equipped with a second set of 220kV circuit breaker and export cable terminations to serve Phase II. The interface to ESB is at the cable interface to the generator transformer HV terminals.

The gas is supplied by Bord Gais by equipment in the existing on-site gas metering station.

The project uses an air cooled steam condenser which is a closed system with no plume. This enables the plant to consume minimal quantities of water giving an environmental benefit.

An auxiliary boiler is provided for gland steam supply during shutdown.

The natural gas fired CCGT design is selected as the Best Available Techniques (BAT) solution to meet the demand for electrical power in the Dublin region. It is designed to impose the least overall environmental impact in terms of land use, air quality, noise impact, water resources and waste management. The advantages of CCGT over conventional fossil fuel fired alternatives include:

• minimal environmental impact; • higher generating efficiencies; • compatibility with the proposed site, currently used for quarrying; • higher plant reliability and ease of operation; • low operating costs; • shorter construction period; and • well-proven technology for the plant rating proposed.

The location is fallow former agricultural land with no designated ecological status. Water consumption and discharge are minimised by use of air cooling for the rejection of unavoidable surplus heat and by the recirculation, whenever possible, of process drains. The most significant pollutant emitted to air, oxides of nitrogen (NOx), is minimised at source by low emission burner design and computer modelling demonstrates that exhaust gases are dispersed adequately to ensure that impacts on air quality are well within standard objectives. Noise attenuation measures are applied at source with acoustic barriers to ensure that existing planning permission and IPC Licence noise limits are met.


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The use of natural gas as principal fuel ensures that the process inherently incurs little waste. No landfilling is carried out on site and no waste requiring landspreading is generated.

Environmental monitoring of air quality at a local site at St. Margaret’s National School is undertaken as part of the Planning Approval conditions.

The plant is operated under existing health, safety and environmental procedures, which include essential features such as staff training and awareness and an Emergency Incident Response Plan. The operator is developing its Environmental Management System and is committed to working towards accreditation to ISO 14001.

Following permanent cessation of the licensed activities on the site, Huntstown Power Company is committed to decommissioning and making safe of the site. The site owner will prepare and submit a report covering tests and investigations to confirm that the site presents no continuing risk to the environment.


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2. SECTION B – GENERAL

2.1 Attachment B1 – Company Registration Documents The following page contains a copy of the Certificate of Incorporation for the creation of Huntstown Power Company Limited, dated 28 September 2000.


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2.2 Attachment B2 – Site Map Figure A1 in Appendix A shows the site plan for Phase I and the proposed plant for Phase II. The borders of Phase I are identified in red outline. Essentially the outer perimeter of the entire site is the outer border of Phase I with the exclusion of areas designated as Phase II.

2.3 Attachment B5 – Planning Approval and Licences Planning permission for the gas fired combined cycle gas turbine electricity generating station with an output of up to 600 MW to be developed in 2 phases was granted on 25 March 1999 by Fingal County Council decision order No. 0816 Register Reference F98A/1313. The planning permission had nine conditions.

The development is also governed by the conditions of the previous permissions on this site, PL06F 110954, F00A/0957, and F01A/1046, insofar as they pertain to this site.

The current Planning Permission for both Phases F05A/0490 was granted on 14 July 2005 and reflects the combined design for the Phase I and Phase II site, with a combined rated output of 740 MWe, although on cold days the plant output is nearer 780 MWe.

A copy of the Notification of the latest planning permission for Phase I, Final Grant Order Number P/3661/01 dated 4 December 2001, is given below. This is followed by a copy of the text of the letter which was sent to the Local Authority in December 2005 advising them of the intention to apply for a review of the current IPC Licence.


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PB Project No 61825B.

Fingal County Council P O Box 174 County Hall Swords Fingal County Dublin Dear Sirs Huntstown Power Station – IPC Licence We write on behalf of the current owners of Phase I of Huntstown Power Station (Huntstown Power Company) and of Phase II (Viridian Power Limited). We refer to the current IPC Licence for the entire power station, No. 483, issued by the Environmental Protection Agency (EPA) in 1999 and amended in 2005 to take account of the EU IPPC Directive 96/61/EC. This letter is to inform you of the Action being taken as requested by the EPA in order to take account of the different sponsorship of the two Phases. For Phase I, the owners (or PB Power on their behalf) will request EPA to undertake a review of the current Licence, under Article 15 of the Environmental Protection Agency Regulations. For Phase II, the owners (or PB Power on their behalf) will formally submit an Application for a new IPPC Licence covering Phase II only (plus facilities common to both Phases where appropriate). We understand that you will be involved as a statutory consultee for both processes and trust that this is sufficient notification for your purposes at this stage. Yours faithfully PB POWER

File : Application Support Huntstown Phase I Review

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2.4 Attachment B8 – Site Notice The advertisement placed in the Fingal Independent newspaper on 22 March 2006 contained the following text:

Application to the Environmental Protection Agency for the Review of an IPC Licence

Notice is hereby given in accordance with Section 87(1) of the Environmental Protection Agency Acts 1992 and 2003, that Huntstown Power Company, Huntstown Quarry, Finglas, Dublin 11, Reg. no. 483, will submit information to support the determination of an IPC Licence review for Class 2.1 – The operation of combustion installations with a rated thermal input equal to or greater than 50 MW. This review is being undertaken to (i) amend the site boundary and accommodate changes arising from a separate IPPC Licence application (Reg. no. 777) for a portion of the site, (ii) take account of proposed changes in discharges to water and (iii) incorporate the requirements of the Protection of the Environment Act 2003, as appropriate. The reference number of this review in the Register of Licences is Reg. no. 779. A copy of the application for the review of the IPC licence and such further information relating to the application as may be furnished to the Agency in the course of the Agency’s consideration of the application will, as soon as practicable after receipt by the Agency, be available for inspection or purchase at the headquarters of the Agency (tel: Locall 1809 33 55 99 or 053 – 9160600). The same text will be displayed at the conspicuous public location shown in Figure A2 in Appendix A.

2.5 Attachment B10 – IPPC Directive The proposed plant accords with Category 1, Energy Industries, Section 1.1, Combustion installations with a rated thermal input exceeding 50 MW of the IPPC Directive 96/61/EC.

In addition, the proposed plant accords with Directive 2001/80/EC on the limitation of emissions of certain pollutants into the air from large combustion plants. Article 4 paragraph 2 states that for new plant not subject to an application for a full licence before 27 November 2002, emission limits defined in Part B of Annexes III to VI of that Directive are obligatory for applicable plant, which includes gas turbines.


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3. SECTION C – MANAGEMENT OF THE INSTALLATION

3.1 Attachment C – Site Management and Control The Phase I power plant is operated on behalf of the applicant by GenSys Power Limited (GenSys), a wholly owned subsidiary of Viridian Group. GenSys operates the plant in accordance with their Environment Management System. This system is designed to achieve the following objectives:

• to improve environmental performance by:

o complying with legislation and where possible exceeding minimum legal requirements;

o complying with the Huntstown Power Company Limited environmental policy; o minimising environmental risks and preventing pollution; and o maintaining effective and efficient Environmental Management Systems;

• to recognise that stakeholders have a role to play and aim to:

o educate and train staff to conduct their activities in an environmentally

responsible manner; o inform suppliers and contractors of their high environmental standards; and o encourage all stakeholders to use energy resources efficiently.

To achieve these aims, objectives and targets will be set and progress reported annually.

GenSys recognises that its activities may have an effect on the environment and local community. An Environmental Policy Statement has been developed to communicate environmental aims and an initial Environmental Management System (EMS) framework has been established to help reduce and control impacts.

GenSys has established a 3-phase approach to develop and implement an EMS appropriate with BS EN ISO14001:2004 requirements. The system will be integrated with the existing Quality and Safety systems to increase system efficiency. Phase 1 An initial environmental review will be conducted to identify all environmental impacts associated with both current and future activities and to assess compliance with all current and forthcoming legislation and codes of practice. Current environmental performance will be benchmarked and performance indicators will be developed to aid with measuring future environmental improvements.

A Gap analysis will be conducted against the requirements of BS EN ISO14001:2004 to help establish an appropriate and effective EMS and a framework to implement it.


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Key Outputs:

• a detailed report demonstrating current environmental performance, highlighting any areas of concern;

• development of Key Performance Indicators; and • development of a framework to implement an effective EMS.

Phase 2 The Environmental Manager will be responsible for developing and implementing the EMS. A register of all current and forthcoming environmental legislation will be completed demonstrating compliance status. All activities will be assessed against set criteria including emergency conditions, to identify significant environmental impacts. Registers will be recorded of significant impacts.

Environmental Management Procedures will be developed to reduce significant impacts and to meet Environmental Policy obligations. They will be developed from existing emergency procedures to anticipate and manage accident and emergency conditions.

A monitoring programme will be implemented to demonstrate effectiveness of improvements procedures. An audit programme will be established to demonstrate progress to meeting set targets and internal compliance with environmental responsibilities.

Senior management will review the EMS performance annually and measures to meet continual improvements will be made.

Key Outputs:

• development of an environmental legislation and codes of practice register, demonstrating compliance status;

• assessment of environmental aspects and register of significant environmental impacts;

• development of Environmental Management Procedures to reduce environmental impacts;

• implementation of a monitoring programme to measure against defined Key Performance Indicators;

• development of an Audit programme to demonstrate compliance with the Environmental Policy; and

• annual EMS review meeting to identify opportunities for continual improvement. Phase 3 A tailored environmental training programme will be delivered to all staff to provide the appropriate level of skills and knowledge in order for them to meet the requirements of the EMS. General awareness sessions will be conducted for non-operational staff, contractors and visitors. This will form part of the induction programme. Training records will be held to demonstrate competence.


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Key Outputs:

• development of tailored environmental training programme; • staff, contractors and visitors trained to an appropriate level according to their

environmental responsibilities; • induction training module; and • environmental training records.

The implementation of the Environmental Strategy will help GenSys meet its environmental aspirations and demonstrate best practice within the power generation industry. Effective environmental management provides the controls to reduce environmental risks and identify and meet all legal requirements. Through effective training and robust systems to monitor performance it is expected that operational efficiencies will increase, providing demonstrable continual improvements.

An organisation chart for GenSys is included as Appendix D.

3.2 Interfaces with Phase II Huntstown Plant was originally planned and designed as the first phase of an integrated electricity generation development comprising two CCGT power plant modules on the Huntstown Quarry Site.

Planning permission for a CCGT power station of 600 MWe in two phases was sought and granted by Fingal County Council on 25 March 1999. Subsequent planning permissions were granted for Phase I of 343 MWe and Phase II of 400 MWe.

Huntstown Phase I was designed and constructed with a number of plant items, services interconnections and facilities with sufficient capacity to meet the operational requirements of two CCGT power plants. Operating experience to date with the Phase I Plant has demonstrated that these plant items, services and facilities are more than sufficient to meet Phase I requirements and continue to be available as originally designed.

In particular, the Administration/Control Building will be shared by both units. There is sufficient space allocated in the Control Room for the Phase II Plant Control and associated electrical equipment so that installation can occur without disrupting Phase I operations. The two Control Systems, however, will be separate and specific to their respective units.

An Ancillary Services Agreement between the Phase I and Phase II companies covers the sharing of surplus facilities and services between Phase I and Phase II, and also the sale of products from Phase I to Phase II. Reciprocal sharing of Phase II services is allowed. The agreement also sets out the responsibilities of each party to comply with the IPPC Licences which cover the activities of both Phase I and Phase II.


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The Phase I operator is currently GenSys, who will also operate Phase II. The Environmental Policy and Environmental Management System and Emergency Response Procedures for Phase I are being amended to reflect the Phase II plant and activities.

Once construction is complete, the Phase II surface water drains will be connected to the Phase I surface water system, via oil separators, with grab sample monitoring points to check for compliance with the IPPC Licence.

Process water from Phase II will be discharged at the common IPC Licence discharge D1, after separate treatment and monitoring to ensure compliance with the Licence limits.

Phase I will have the right to the use of Phase II new fire water tank and pumps (which belongs to Phase II) to protect the Phase I fuel oil storage tank with water spray. This is a new requirement arising from the building of an adjacent Phase II fuel tank, so that each tank is cooled by a water curtain on the side facing the neighbouring tank.

The Phase I Fuel Oil Storage Tank is expected to remain dedicated to Phase I. A new Fuel Oil Storage Tank is to be constructed, dedicated to Phase II supply. However, to increase flexibility for both units, the two tanks will be cross connected to allow for transfer of fuel from one to another by agreement between the parties.

As a Shared Facility, the use of Phase I Plant air foam system to protect Phase II fuel oil tank is also planned.

The shared use (by interconnection) of fire alarm panel and systems is also planned.

The new security Gatehouse/Induction visitor centre and contractors’ compound will be a Shared Facility built by Phase II but on Phase I Adjoining Property. This building and compound will be handed over to Phase I. The use of this building is included in shared services.

Only one connection to the sewage system is envisaged for Phase II. This is from the Gatehouse/Induction Centre. This pipe is planned to run to the lift pump chamber east of the 220kV AIS gate (serving the AIS washroom). From there this will join the existing flow to Phase I treatment plant and discharge to percolation bed.

Potable water for Phase II will be metered and charged separately, via a new connection to the existing incoming water supply.

A new gas pipe will be installed from the Bord Gais owned above ground installation to the Phase II plant.

New fuel pipelines and a fuel skid will connect Phase II to the fuel oil storage tanks and fuel oil unloading station and pumps currently installed on the Phase I area.

The interconnections between Phase I and Phase II can be categorised as “Shared Facilities”, “Services” and “Supplies”, as listed in Tables 1 to 3 below.


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A. SHARED FACILITIES

Connection to and shared use of resources of the Phase I Plant fire main and hydrant system (including the addition by Viridian Power Limited (VPL) of an extra fuel oil tank foam/spray water system for both the Phase I Plant and Phase II Plant main fuel oil tanks), the Phase I Plant fire fighting pumping system and associated ancillary equipment, as well as fire fighting water reserves.

1

Shared use of the Administration Control Building (UCA) reception, kitchen, toilets and general staff welfare services including heating, air conditioning and lighting.

2

Connection of the relevant Phase II Plant earthing to the station wide Earthing Grid and lightning protection grid.

3

Connection to and shared use of the Phase I Site tannoy (site evacuation siren and personnel paging) system operated from the Administration Control Building.

4

Connection to and shared use of the Phase I Plant boiler drain down storage underground tank. (Note that Phase II Plant discharge piping shall provide for the appropriate isolation and monitoring upstream of the drain down tank).

5

Connection to and the shared plant use of the Phase I Plant raw water tank as storage for blow down process water from Phase II Plant and connection to and shared use of raw water from the Phase I Plant raw water storage tank for general service water applications.

6

Connection to and shared use of the Phase I Plant auxiliary boiler system and associated ancillary equipment to provide surplus auxiliary steam for VPL use.

7

Shared use of the Phase I Plant main and contractor car parking facilities along with shared use of the site contractor temporary housing and associated facilities.

8

Shared use for maintenance work of secure equipment and plant laydown areas designed for this purpose on the site.

9

Shared use of existing workshops and workshop equipment on the Phase I Site along with the storing and use of additional similar Phase II Plant workshop equipment in this area.

10

Shared use of Phase I Plant mobile crane, forklift and lifting gear. 11

Connection to and shared use of the Phase I Plant compressed air system and associated ancillary equipment of dryers, filters etc.

12

Shared use of the existing computer local area backbone network to permit communication between Phase I Plant and Phase II Plant gateway and PI (process information) servers for the electronic exchange, display, interrogation and management of data.

13

Shared use of the Phase I Plant dedicated consumables storage area (for storing greases, paints, lubricants and other such consumables).

14

Connection to and shared use of the existing internal and external telecommunications system infrastructure to allow VPL to connect additional telecommunication devices and to install VPL direct billing services for its external telecommunication circuits use.

15

Table 1. Shared Facilities


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B. SERVICES

1 Connection to and shared use of the perimeter fence and security systems including:

CCTV security surveillance system, intruder detection and access to related personnel muster information recordings and real time camera views and alarms;

site entrance security gatehouse and associated offices and facilities; and other Phase I Site wide manned security services.

2 Connection to and shared use of the site wide street, site access areas and general site perimeter lighting system.

Table 2. Shared Services

C. SUPPLIES

1 Surplus demineralised water from the Phase I Plant to the Phase II Plant from the existing Phase I water treatment plant on the Phase I Site.

(Note that the purpose built water treatment plant is capable of servicing the operational requirements of two CCGT power plants and contains two redundant process streams for producing demineralised water. The Phase II Plant will have its own separate demineralised water storage facilities).

Interconnection and shared use of low voltage electricity connection from the Phase I Plant emergency distribution supply.

2

Shared use of copies of data streams from the Phase I Site external off site ambient air monitoring station and output data from the dust, over pressure and seismic monitoring facilities.

3

Shared use of and electronic access to Phase I Site weather station data and information streams including the site weather forecast service.

4

Table 3. Shared Supplies.


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4. ATTACHMENT D – OPERATIONAL INFORMATION

The operation of the plant is generally as described in the original application for the IPC Licence No. 483. The plant is envisaged as a cycling or base load plant and hence could operate for 24 hours per day and 365 days per annum depending on maintenance and despatch requirements. Distillate oil facilities are provided as a standby provision in accordance with the Consent to Construct or Reconstruct a Generating Station, in the event that natural gas is unavailable. The gas is provided as an interruptible supply and operation on standby fuel is not expected to exceed 10 days per year. Provision is made for operation on oil for up to 5 days in one session, in the form of storage of distillate oil and water for injection into the gas turbine to control NOx emissions.

During startup, NOx emission concentrations will not fall to guaranteed levels until a minimum gas turbine of 60% load is reached. Any increase in concentration is offset by a reduced exhaust flowrate while at low load. Similarly during shutdown, concentrations may increase briefly. The durations of cold, warm and hot starts are approximately 170, 100 and 50 minutes respectively.


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5. SECTION E – EMISSIONS

5.1 Attachment E1A – Emissions to Air

5.1.1 Major Emissions The Phase I plant includes two sources of major emissions to air, of which only one can be operated at any one time. The principal source is the HRSG stack. These emissions comprise gas turbine exhaust gases which have passed through the HRSG, where heat has been extracted making steam to drive the steam turbine, reducing the temperature of the gases. The alternative release point is the bypass stack, where the same exhaust gases are released upstream of the HRSG when it is not available and at a higher temperature. Tables E.1(ii) to E.1(v) and E.2(i) to E.2(ii) of the application form are completed with updated information on exhaust gas constituents.

The significant pollutants as listed in the Schedule of the Environmental Protection Agency (Licensing) Regulations (Amended) 2004 are SO2, NOx, CO, VOCs and dust. Of these only NOx and CO are considered significant when firing natural gas. SO2 becomes significant only when firing the standby fuel distillate oil.

The emission concentrations of these pollutants are judged for their compliance with BAT requirements by comparison with the Large Combustion Plant BREF issued by the IPPC Bureau and the UK Environment Agency’s “IPPC Sector Guidance Note, Combustion Activities” issued in July 2005. Ireland’s EPA has not yet issued its own combustion sector guidance note, but it is anticipated that their interpretation of the BREF will be similar to that of the UK and so the comparison to this document is considered valid. Table 4 below compares the proposed emission concentrations, as consented in the existing IPC Licence 483 and illustrates their consistency with both the BREF and the UK draft Guidance Note. The reduced UK Guidance Note SO2 level on firing gas from 2008 reflects the reduction of maximum sulphur in distillate oil from 2008 in accordance with the SCOLF Directive; actual concentrations from the proposed plant will comply with this as demonstrated in the dispersion study discussed in Section 7.2.1 (Attachment I1) and reproduced in full in Appendix C.


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Concentration, mg/Nm³ at reference conditions 15%v O2 dry 0ºC 101.3 kPa

Pollutant Fuel

Proposed plant BREF UK Guidance Note

natural gas 50 20 – 50


50 NOx (as NO2) distillate oil 125 – 125 natural gas 100 5 – 100 100 CO distillate oil 100 – 100 natural gas 12 – 10 SO2

distillate oil 120 – 112 (66 from 2008)

natural gas 2 – 5 Dust distillate oil 10 – –

Table 4. Proposed Emission Concentrations of Pollutants and BAT Criteria.

5.1.2 Minor Emissions 5.1.2.1 General

Table E1(iv) lists the sources of minor atmospheric emissions, which are identified as the auxiliary boiler, emergency diesel generator, firefighting system, hydrochloric acid storage tank vent and fuel systems. These are described in more detail below.

5.1.2.2 Auxiliary Boiler

A small auxiliary boiler is installed to supply the start-up and shut down auxiliary steam for the plant (gland steam sealing to seal the vacuum in air cooled condenser, and heating of the deaerator to maintain low oxygen in the feed water). The auxiliary boiler is in service when steam from the HRSG low pressure steam system is unavailable, i.e. during startup and shutdown and until suitable steam conditions can be established in the HRSG. The auxiliary boiler allows vacuum to be maintained during short shutdowns, thus improving the start times. The auxiliary boiler has a fuel input rating of approximately 2 MWth and is rated at 10 te/hour of steam at 11 barg pressure. The auxiliary boiler is normally fired on natural gas but has dual fuel capability using diesel fuel oil if the main gas supply is interrupted. The diesel is stored in a separate, dedicated, bunded tank. The auxiliary boiler operates occasionally for 2-3 hours during start up of the station, until the HRSG is capable of supplying sufficient steam. The boiler does not normally operate when the main plant is on load.

Emissions to atmosphere from the auxiliary boiler are only occasional but comprise combustion by-products (NOX, CO from firing on natural gas and also SO2 and particulates if firing on low sulphur diesel oil). The auxiliary boiler stack is located adjacent to the main HRSG stack.

5.1.2.3 Emergency Diesel Generator

An emergency diesel generator with a rating/duty of ca. 1.2 MWe is used to provide safe run down and emergency power to essential systems in the event of interruption of the normal power supply. The essential users include emergency lubricating oil and turning gear for the


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turbine rotors, battery chargers, control power, communications and fire protection systems. The emergency generator is a multi-cylinder diesel engine with a 400V generator. Low sulphur diesel is supplied from a bunded diesel tank local to the generator. The diesel generator operates for weekly testing purposes to confirm that the unit is available for emergency duty.

Emissions to atmosphere from the generator only occur during emergency situations or during testing. Emissions comprise combustion products (NOX, CO, SO2, particulates) discharged through a silencer and exhaust mounted on the diesel generator skid.

5.1.2.4 Firefighting System

The station has a full fire detection and protection capability, which will be integrated with the new Phase II system. Water for firefighting is stored in the existing fire water tank and a new fire water tank with electric and diesel engine fire pump will be provided to serve the Phase II fuel tank cooling spray system. The diesel fired pump has a rating less than 0.1 MWe and is fired on low sulphur diesel supplied from a bunded diesel tank local to the pump. The pump engine discharges to atmosphere through a silencer and stack located above the firefighting skid roof. Pumps are run only for emergency duty or for weekly testing purposes. Emissions to atmosphere from the firewater pump engine are not be significant.

5.1.2.5 Hydrochloric Acid Storage Tank Scrubber Vent

A new hydrochloric acid (HCl) Storage Tank was installed and commissioned, 15/07/2004, as part of a programme to reduce the manual handling of chemicals on site. The tank has a capacity of 10.35 m3. The HCl tank is filled 3 times per annum. A scrubber unit was also installed to abate breathing losses. Water contaminated with HCl is removed for disposal off-site by a certified waste disposal company, SITA. Emissions from the vent during the performance test were measured at between 1 and 9 ppm HCl by volume.

While the HCl tank is not being filled a pump operates for 1 minute every 15 minutes. This ensures the packing in the scrubber contains 10% weight of water which is sufficient to absorb up to 3 kg of HCl fumes. The supplier has advised that during periods of non-filling of the main tank, and with the scrubber pumps set to operate 4 times per hour, there is negligible flow into the scrubber and therefore the emission concentration is trace.

5.1.2.6 Fuel Systems

The plant is normally fired on natural gas. Gas is piped to the site in an existing high pressure pipeline (78 barg) operated by Bord Gais Eireann (BGE). The existing AGI is being extended to serve Phase II. The Consent to Construct or Reconstruct a Generating Station granted by the Commission for Energy Regulation (CER) requires the plant to have the capability to use an alternative fuel supply for strategic fuel diversity. Distillate oil is stored on the site to ensure that short term electrical output can be maintained in the event of a loss of gas supply. Up to approximately 10,000 m3 of low sulphur (0.15%) distillate oil can be stored in a bunded tank on Phase I site. This quantity is sufficient to operate the plant at maximum output for approximately five days in the event of an interruption in gas supply. The distillate oil is delivered to site by road tankers.


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There are some minor fugitive emissions to atmosphere (e.g. breathing losses from distillate oil tank) but these are not considered significant. The safety creep relief valve installed in the AGI gas compound for local over-pressure control releases small quantities of natural gas to atmosphere if activated but operates rarely.

5.2 Attachment E1B – Fugitive and Potential Emissions to Air Table E1(v) lists sources within the natural gas and turbine lubricating systems from which occasional emissions may arise owing to operation of plant protective devices.

5.3 Attachment E2 – Emissions to Water

5.3.1 Abstraction Although this application refers to Phase I of the Huntstown power generation site, the new supply and drainage arrangements for Phase II and for the adjacent Roadstone property at Huntstown are also described in the following text. Abstraction requirements, process effluents, proposed treatments, measures for dealing with storm water runoff and treatment of domestic sewage are all considered.

Raw water sourced from on-site wells is used for service water supply and for the fire protection system. Demineralised water is used for make up water for the HRSG, and for the initial fill and occasional top-up for closed cooling systems.

Raw water is abstracted from two wells within the Phase I site. Here it is used to supply the firefighting system and feed the demineralisation plant. The firefighting system will be extended to include a new storage tank and pumping station serving the shell cooling spray on both fuel storage tanks. Demineralised water from the Phase I demineralisation plant is used to supply the needs of both Phases. Phase II therefore has no demineralisation plant and therefore none of the associated storage of chemicals or neutralisation and discharge of effluent; the additional demand, however, will increase the consumption of raw water and chemicals and the discharge of reject water associated with the water treatment plant of Phase I, which is included within the review of the existing IPC Licence. Phase II obtains its potable water supply from the same mains source as Phase I and is metered independently. Figures B1 and B2 in Appendix B show respectively basic arrangements of the process and surface drain arrangements. Figure B3 shows a water balance showing expected flowrates during normal natural gas fired operation and illustrates the relationship between Phases I and II as well as the recycling flows designed to minimise water and chemical consumption and discharge rates.

The normal requirement for Phase I is approximately 4 m³ potable water per day for domestic use and 4 m³/hour demineralised water as make-up water for the boiler. The domestic demand is sized on an allowance of 200 litres per person per day for use by 20 site staff. The boiler water make-up is sized as 1% of the boiler flow of nominally 331 m³/hour. Phase I gas turbine is equipped with dry low emissions pre-mix burners for firing on distillate oil.


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It should be noted that minimal cooling water is required on the site because of the use of an air cooled condenser. This dramatically reduces the water requirement of the station, compared with alternative technologies.

5.3.2 Discharges 5.3.2.1 General

Surface drains from the existing Phase I plant and the proposed Phase II plant will flow into the existing Phase I network which releases water at discharge point D1, which is located in the north west corner of the site and not on the southern boundary as proposed in the original IPC Licence application. Because the discharges from both Phases are combined, the apportionment of responsibility for the contributions to the combined drain from the two Phases is managed via an arrangement between the operators of the two Phases as described above in Section 3.2. Existing flow proportional sampling of the Phase I surface water flows will be retained.

The operation of the CCGT power station generates aqueous effluent streams, consisting mainly of boiler blowdown. Most of this is normally recycled when the quality is suitable but the remainder is released via discharge point D1 with the reject flows from the demineralisation plant. The typical water balance shown in Figure B3 reflects the preferred scenario with water discharge recycled where possible, reducing the net discharge from Phase I. However the plant is designed to discharge the maximum flow in the event that recycling is not possible or appropriate. Table 5 shows the preferred and maximum flowrates of process drains from both Phases.

Source Preferred discharge from site, tonnes/day

Maximum discharge from site, tonnes/day

Phase I – CCGT process 18.6 50.0 Phase I – demineralisation plant reject

114.7 150.0

Phase I - total 133.3 200.0 Phase II 36.0 600.0 TOTAL 169.3 800.0

Table 5. Process Flows from Phases I and II.

5.3.2.2 Surface Drains

Surface water runoff consists of rainwater, spillages and wash water. Since this may become contaminated with oily substances, oil interceptors are included in the drains on the development. Once oils have been removed, surface runoff is discharged.

The distillate oil storage tank is housed in a bund with a capacity of 110% of the tank plus allowance for fire and rainwater. The bund has no drain. Rainwater which gathers in the bund is discharged by pumping over the bund after examination to ensure that there is no unacceptable oil content.


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Pumps are installed to convey the drainage water into the existing surface drains which serve the quarry dewatering. Compared to the existing volumes of surface water being pumped out of the quarry, the volumes arising from the power station are not significant.

5.3.2.3 Sanitary Drains

Sanitary drains from the administration and workshop buildings are treated in the existing foul water treatment plant within Phase I. Treated sanitary drains are discharged to a percolation area within the Phase I site. The expected sewage flow is about 150 litres per person per day. This amounts to a normal maximum daily flow of about 1500 litres per day, with a biochemical oxygen demand (BOD) of about 30 g after treatment. On occasions, with up to 20 people on site for training or induction, etc., this could rise to 3000 litres and 60 g BOD.

5.3.2.4 Chemical Drains

The existing demineralisation plant comprises principally carbon filter pretreatment, reverse osmosis (RO) trains and electrostatic ion exchange polishing. The RO train reject and the carbon filter backwash flows are directed to the collecting chamber at release point D1. There will be a small increase in the throughput of this plant and hence the reject flows to accommodate the demands of Phase II for demineralised water. These increased flows are taken into account in Table 5 above and Tables E.2(i) of the Application Form.

In order to maintain the required quality of steam in the boiler, it is necessary to discard a portion of boiler water at a controlled rate. About 1% of the steam flow in the boiler is blown down each hour. This is exposed to atmospheric pressure so that some is flashed off as water vapour while the remainder is cooled in a heat exchanger easing its handling and through a cartridge filter and anion exchanger to improve its purity. There is also an option for cooled blowdown water to be recycled to the raw water tank.

Samples of steam and water are taken from strategic locations of the steam/water cycle to monitor the water chemistry and ensure that it stays within targets designed to ensure plant integrity and efficiency.

The boiler blowdown and sampling drains which are not recycled are routed to a waste water holding pond, together with sump drains from the air cooled condenser and areas containing dosing chemicals. The water quality is monitored and the water is only released provided its quality is acceptable.

The gas turbine compressors are washed with water occasionally, either during operation or off-line. On line washings are dispersed with the HRSG exhausts, while off-line washings are segregated into a dedicated tank for disposal off site by a licensed contractor.

In addition, during cleaning of the boiler prior to outage re-commissioning, quantities of chemical waste may be generated which will be disposed of off-site by specialised contractors.


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5.3.3 Mitigation A significant proportion of the chemical drains described above are normally recycled, resulting in considerable reductions in water consumption and discharge rates. Normally the whole of the boiler blowdown and the majority of the sample drains, being generally of the same quality as boiler feedwater is cooled and returned to the Phase I condensate collection tank or raw water tank. Its quality is purer than well water and its temperature low enough to avoid damage to the demineralisation plant. These streams are thus retained within the steam/water inventory.

The control of water use and discharge is consistent with the BAT requirements described in the large combustion plant BREF and the draft UK guidance note based on it. The rationale followed is:

• avoid water use (air cooled condenser eliminates cooling water); • avoid contamination at source (no solid fuel, 110% capacity blind impervious bunds

or double skinned tanks for oils and chemical stores); • recycle water to reduce consumption (as described above); • treat before release (separate surface, process and sanitary streams, oil/water

separators, neutralisation facility); and • discharge quality targets based on recognised benchmarks.

The expected worst case discharge quality from the combined flows described in Tables E.2(ii) of the Application Form is shown in Table 6 below and is consistent with the “achievable releases” defined in the UK Sector Guidance Note. The actual concentrations in the combined discharge are expected to be somewhat lower. The achievable releases are intended by the Guidance Note to provide a basis for emission limits.


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Parameter Unit Table E2(ii) (D1, combined drains)

UK Guidance Note “achievable release”

suspended solids mg/l 30 1 – 10 ammoniacal nitrogen mg/l N 5 5 cadmium µg/l 10 mercury µg/l 5 heavy metals % removal >95 pH 6 – 9 5 – 9 COD mg/l 50 low BOD mg/l 20 total phosphorus mg/l P 0.1 TDS mg/l 2000 mineral oil mg/l 20 free residual chlorine mg/l 0.2

Table 6. Aqueous Discharge Quality.

The site of the power stations will be drained into the existing land drainage system serving the Huntstown quarry. A copy of the waste permit WPW/1/87 for the quarry follows as Figure 3.

The significant pollutants as listed in the Schedule of the Environmental Protection Agency (Licensing) Regulations (Amended) 2004 are carcinogens and biocides. These are controlled to minimal levels in the final discharge. The only recognised potential carcinogen on site is hydrazine, which is used in small quantities as a boiler feedwater oxygen scavenger.


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Figure 3 (part 1 of 3). Waste Permit WPW/1/87 for the Roadstone Quarry.


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5.4 Attachment E4 – Emissions to Ground The only emission to ground is the treated sewage from the percolation pit within Phase I power station. This handles sanitary drains from both Phase I and Phase II.


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6. SECTION F – CONTROL AND MONITORING

6.1 Attachment F1 – Treatment and Abatement The significant pollutants at the point of emission to air E1 are oxides of nitrogen and carbon monoxide. These are controlled by the dry low emission gas turbine burners, which maintain concentrations within the limits of IPC Licence 483 from 60% load upward firing gas or distillate oil. No further treatment or abatement on natural gas firing is necessary. On firing the standby fuel distillate oil, NOx emissions are controlled by use of dry low NOx premix burners.

Surface drains from the potentially oil contaminated areas of the transformers and the maintenance parking area pass through oil/water separators before release. Other surface drains join the existing Phase I drains system which has its own oil/water separators. The existing fuel oil unloading area also serves the new Phase II storage tank and drains via the existing oil/water separators.

The process drains from Phase I plant are monitored and either recycled or discharged according to its composition. The flowrate of drains requiring this process is minimised by recirculating as much as possible of the drains.

6.2 Attachment F2 – Monitoring and Sampling

6.2.1 Monitoring at Source of Emission Surface drains from the main Phase II area join the existing Phase I drains to form a common stream to the D1 discharge point. The discharge from the waste water treatment plant is continuously monitored for flow, temperature, conductivity, ammonia content and pH value. Flows from the oil/water separators in the transformer and maintenance parking areas are monitored for oil content, as is any water in the fuel oil bund. High levels of these continuously monitored parameters are alarmed.

6.2.2 Ambient Monitoring Ambient monitoring of NO2 and NOx in air at St Margaret’s National School is undertaken in agreement with the programme agreed with the EPA in accordance with Condition 10.9 of IPC Licence 483. This programme was implemented for one year before and one year after Phase I commercial operation date to provide comparative data and measurements continue for a similar period before and after Phase II commissioning. Table 7 summarises the latest quarterly report findings. These continue to show no exceedences of the Air Quality objective (200 μg/m3 hourly average not to be exceeded more than 18 times a year). In general it is observed that values do not fall significantly when the Phase I plant is not in operation, indicating that other sources such as road traffic are the principal local source of airborne NOx in the area.


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Quarter NO2 NOx

maximum hourly concentration, µg/m³

129 342

period mean hourly concentration, µg/m³

July to September 2005

25 38

maximum hourly concentration, µg/m³

111 496

period mean hourly concentration, µg/m³

October to December 2005

20 37

Table 7. Air Quality Monitoring at St. Margaret’s National School


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7. SECTION I – EXISTING ENVIRONMENT AND IMPACT OF THE ACTIVITY

7.1 Site Condition The site is adjacent to a working quarry. Prior to the development of Phase I power station, the site consisted of fallow agricultural land. There is therefore no identified history of significant pollution events or risk on the site. Soil and vegetation were typical of the area with no particular ecological interest. There are no nature conservation areas or designated views or prospects.

Geotechnical studies of the area suggest that the water table is 1-2 metres down, but no significant groundwater resources have been identified. Dewatering and draining activities are managed at the quarry. There are no foul sewers in the area.

Noise is dominated by traffic on the nearby N2 trunk road and M50 motorway, airport activity and the quarry, but noise levels fall for at least part of the night to typical urban residential levels.

Air quality is dominated by local road and air traffic, but air quality standards are complied with.

7.2 Assessment of Impacts

7.2.1 Attachment I1 – Atmospheric Emissions The impact of emissions to air has been assessed by an air dispersion modelling study of both Phases I and II. This represents an update of the similar study done for the IPC Licence 483, with more project-specific data and a newer version of the ISC-3 model. The full report of the study is given in Appendix C.

The modelled pollutants were NO2 (firing natural gas or distillate fuel oil) and SO2 (firing distillate only). Distillate sulphur content was assumed to be a typical 0.14% by weight. Three scenarios were modelled: 1 – operation as CCGTs firing natural gas, 2 – both Phases firing gas but with Phase I operating in OCGT mode exhausting through the bypass stack and 3 – both Phases as CCGTs firing distillate. Only scenario 1 represents normal operation.

Impacts were compared with Irish Air Quality Objectives derived from EU Directives. Annual average predictions were made for NO2 based on scenarios 1 and 2. It was not considered appropriate to base annual average values on distillate firing as this is a rare event.

There are several factors making the assessment conservative, so that the predictions are “worst case”. These include:

• assuming NOx concentration is at the maximum consented; • ignoring the reduction of maximum sulphur content in distillate to 0.1% by 2007; • assuming continuous base load operation all year;


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• assuming the maximum emission from infrequent conditions (scenarios 2 and 3) coincides with the worst case meteorological condition;

• modelling the contribution of Phase I when it is already contributing to the existing background levels; and

• conservative assumptions for conversion of NOx to NO2 of 50% for short term and 100% for long term values respectively.

The existing background levels of NO2 and SO2 are well within Air Quality Objective values. Some increase in NO2 has been observed since 2001, which may be attributed to either Phase I operation or increased local road traffic. However NOx values recorded at St. Margaret’s National School do not decrease when Phase I station is shut down, confirming that the major source in the area is traffic.

The main results are summarised in Table 8 below. All are within the Air Quality Objectives. The maxima occur within 1 km of the site, to the east or north-east.

Scenario 1 (normal CCGT operation, both Phases, firing gas)

2 (OCGT operation on Phase I, CCGT on Phase II, firing gas)

3 (CCGT operation, both Phases, firing distillate oil)

Irish Air Quality Objective

NO2 19th hourly average

73.5 73.5 104.7 200

annual average

2 1.7 – 40

SO2 25th hourly average

– – 129.6 350

4th 24 hour average

– – 47.6 125

Table 8. Predicted Air Quality Impacts, µg/m³.

From these results it is concluded that the predicted impacts are well within Air Quality Objective values and no further abatement of emissions is required.

7.2.2 Attachment I2 – Water Discharges The discharges from the plant enter the dewatering flow from the adjoining quarry, which is estimated to be a minimum of 234 m³/hour, amounting to 5616 m³/day. This is the value as declared in 1999 and is expected to be higher now as quarry operations go deeper. The maximum discharge from the Huntstown power plants at 800 m³/day is significantly less than this and the normal flow of around 170 m³/day is even lower. In terms of water flow therefore the impact of discharge is not considered to be significant.

It is understood that the quarry dewatering stream into which the discharges from Huntstown Power Plant is released drains into the Ward River, within the Eastern River Basin. This river is not listed as a designated salmonid river and is classified as “moderately polluted”.


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The average runoff within the Eastern River Basin is 122.8 m³/s (442,080 m³/h) according to the EPA’s Report “Water Quality in Ireland 2001 – 2003”. The quality of the Ward River is shown in Table 9, as published in the Environmental Statement for the N2 Finglas to Ashbourne Road scheme.

Parameter Ward River water quality at Coolatrath Bridge, mg/l

ammoniacal N 0.748

phosphate as P 0.855

BOD 3.6

Table 9. Ward River Water Quality

The assimilative capacity of a receiving water is a measure of its ability to absorb waste water discharges while complying with relevant legislation and water quality objectives. For rivers it may be calculated using river flow rate, maximum concentrations of key parameters, target water quality and current water quality. Table 10 compares the contribution by the quarry and Huntstown Power plant expected and maximum discharges of key parameters to the Ward River, based on observed quarry discharge concentrations and expected releases from Huntstown Power plant.

Quarry discharge, maximum observed at 5616 m³/day

Huntstown Power total discharge, expected, at 170 m³/day

Huntstown Power total discharge, maximum, at 800 m³/day

Parameter

mg/l kg/day mg/l kg/day mg/l kg/day

ammoniacal N

0.87 4.9 0.5 0.085 5 4

phosphate as P

0.4 2.2 0.1 0.017 0.1 0.08

BOD 11 61.8 5 0.85 20 16

suspended solids

122 685.2 10 1.7 30 24

Table 10. Discharges from Quarry and Huntstown Power Plant to Ward River


The values in the final two columns represent a worst case scenario of which the probability of occurrence is considered remote. It is assumed that the contents of the key parameters are at their maximum allowed values at the same time. It is also assumed that the recycling facilities at both Phases of the power plant are simultaneously unavailable and that this persists for 24 hours. However even under these extremely pessimistic circumstances the contribution of key parameters by the Power Plant drains is significantly less than that provided by the existing quarry dewatering flow and under normal circumstances is substantially lower. It is therefore concluded that the impact of the power plant drains is trivial and that the assimilative capacity of the river system at Ward River level is likely to be sufficient to accept the drains without significant change to its quality.


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7.3 Attachment I8 – BAT Arguments and Mitigation Measures

7.3.1 Selection of Process The combined cycle gas turbine process is widely recognised as a modern, efficient means of providing electrical power on the scale of the requirement for Huntstown. Its efficiency is significantly better than conventional plant and the fuels have a lower carbon content, both of which result in a lower emission rate of carbon dioxide per unit of useful energy provided. While renewable energy processes are recognised as avoiding the net generation of carbon dioxide, they are not feasible on the scale of power demand at Huntstown.

7.3.2 Selection of Fuel Natural gas provides a fuel with low carbon content and negligible sulphur content, these factors resulting in reduced emissions of carbon dioxide and SO2 respectively. Gas usage also avoids the generation of ash storage and disposal associated with solid fuels and requires no storage on site. The standby fuel, distillate oil, is only utilised on rare occasions that natural gas is unavailable; during the operation of Phase I, no distillate oil firing has yet been required. The emissions of carbon dioxide, NOx and SO2 arising from distillate oil firing are only moderately greater than those associated with natural gas firing.

7.3.3 Use and Discharge of Water The use of the air cooled condenser for the Phase I plant avoids the abstraction and discharge of large quantities of water associated with once-through cooling or evaporative cooling tower circuits at other, conventional power plants. The Huntstown area does not have the water supply resources to support water based cooling. The air cooled condenser represents a proven alternative of acceptable efficiency and with adequate control of other environmental impact such as noise.

Discharge of process water waste is mitigated by recycling, where possible. When possible, boiler blowdown is recycled and a portion of sampling drains returned to the steam/water cycle. Effluent pH is adjusted by acid or caustic dosing to within an acceptable range.

Demineralised water is provided to Phase II from Phase I plant. There is therefore no demineralisation plant within Phase II and therefore none of the effluent or ion exchange resin regenerants handling associated with such plant. All additional discharge associated with demineralised water consumption by Phase II is covered within the review of the existing IPC Licence.

The gas turbine uses dry low emission burners so that no demineralised water is required to ensure compliant emissions of NOx. Dry low NOx premix burners are also used for fuel oil operation.

7.3.4 Other Raw Materials The conditioning chemicals used for boiler water and feedwater are supplied in, and dispensed from, IBCs. This minimises the risk of contact with operating personnel and release to the environment. The preferred compounds are generally of low toxicity.


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The quantity of lubricating oils used is small enough to be contained wholly within the pump skids and associated equipment and there is no requirement for bulk storage of lubricants.

7.3.5 Emissions to Air The pollutants of most concern within the emissions to air are NOx and SO2. The proposed plant meets the BAT requirement with respect to both emission concentration at source and impact on air quality at ground level.

The emission concentration of NOx would be required not to exceed a value of 50 mg/Nm³ (at reference conditions of 15%v oxygen, dry, 0ºC, 1013 mbar a) on natural gas firing to comply with the “achievable release” defined in the UK Environment Agency draft IPPC Sector Guidance Note, Combustion Activities. The burner design adopted for this project is supplied with a commercial guarantee to meet this limit at loads above 50%. Similarly, NOx concentration is guaranteed not to exceed 125 mg/Nm³ on distillate oil firing above 65% load, which is consistent with the UK Environment Agency draft IPPC Sector Guidance Note achievable release of 125 mg/Nm³.

The emission of sulphur dioxide is minimised by using natural gas fuel with negligible sulphur content. The sulphur content of distillate oil standby fuel is limited to 0.15% by weight, which will be reduced to 0.1% by 2008.

The stack height of 34.5 metres has been shown by the air dispersion modelling study to provide sufficient dispersion of exhaust gases to ensure that the impact on air quality is acceptable. Moreover, this dispersion ensures that there is no discernable odour impact at ground level due to exhaust gases. The stack height complies with restrictions imposed by air traffic regulations.

7.3.6 Waste The installation uses an intrinsically low waste producing process. There are no waste products associated with the natural gas or liquid fuel. The other materials consumed in significant quantities – boiler water conditioning chemicals – are delivered to fixed storage tanks or in exchangeable IBCs so that there is no accumulation of empty containers within the installation. Few solid wastes are stored on site. The potential for recovery and reuse of plant wastes, however small, will be regularly assessed through the Environmental Management System.

7.3.7 Energy Efficiency The management of energy will be an integral part of the Environmental Management System with energy policies integrated into the overall environmental policy. Staff training aimed at minimising energy use and developing good housekeeping techniques will be a fundamental part of the staff’s initial training programme and subsequent refresher courses. One of the key environmental aspects will be the assessment of energy use and its minimisation through well targeted improvement plans. Such an improvement plan will be


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managed through procedures and will identify the areas where energy is utilised, identify potential energy efficiency measures and ensure that their financial viability is appraised.

7.3.8 Monitoring of Emissions Emissions to air are monitored in the exhaust flue for the significant pollutants (NOx and CO) continuously, in accordance with the LCPD amendment. Additional sampling arrangements comprising four ports at right angles in the same plane are provided, as well as provision for another port for independent gas monitoring. These arrangements are in accordance with UK Environment Agency Technical Guidance Document M1, which is consistent with BS EN 13284-1 (2002). Oxygen is monitored on-line in the HRSG flue. There are no other continuous emissions to air.

Process waste water is continuously monitored for pH, temperature and conductivity. The pH and conductivity measurements are linked to the valving to direct discharge either to release (if compliant) or recycle (if not). Additional measurements are made on regular manual samples. These arrangements are designed to ensure that only discharge of acceptable quality is released.

7.3.9 Noise and Vibration The BAT objective with regard to continuous noise sources has been addressed by the incorporation of appropriate noise attenuation measures. These include site layout to provide shielding from noise sources, gas turbine acoustic enclosure, attenuation on ventilation inlets and discharges and insulation of pipes and other measures to maintain operating area noise below 85 dB(A) at 1 metre.

The principal source of intermittent noise is the operation and testing of safety valves. This is an infrequent occurrence. Testing on these valves is during normal working hours. Silencers are installed as necessary to minimise this source of noise.

The vibration BAT objective has been achieved by avoiding all sources of reciprocating machinery.


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8. SECTION J – ACCIDENT PREVENTION AND EMERGENCY RESPONSE

8.1 Attachment J – Accident Prevention and Emergency Response Accidents with the potential to affect the environment are handled within the existing Emergency Incident Response Plan managed by the operator GenSys. This Plan includes responsibility for both Phases I and II. The Plan, currently as version 6 dated September 2002, is continually reviewed and updated.

Components of the Plan include:

• contact details; • oil, product and chemical inventories; • competency matrix; • schedule of roles and responsibilities; • emergency procedures including response to spills of chemicals; • equipment lists; • facility maps and plans; and • material safety data sheets (MSDSs) for chemicals and products on site.

GenSys is responsible for the continuous operation and maintenance of the Huntstown Phase I plant, and will provide the same services for the phase II plant when commissioned. All maintenance activities onsite are conducted using a permit to work system, which is based on a suite of safety rules. These are listed in Table 11. There is also a suite of safety procedures which must be adhered to. These are listed in Table 12.

A detailed Emergency Incident Response Plan which aims to address the hazards on site has also been developed and is located in the plant control room which is manned on a 24 hour basis. This emergency incident response plan is designed to address any emergency situations which may occur on site. The Emergency Incident Response Plan contents are listed in Table 13.

As part of its accident prevention and emergency response strategy, GenSys provides all operations staff with accredited First Aid, Fire Fighting, Chemical Spill and Confined space rescue training. Refresher training is carried out as required and all records are maintained in the site training database.

In conjunction with the Phase II project, this suite of procedures will be reviewed to reflect the changing site infrastructure. GenSys aims ultimately to implement an integrated occupational health and safety (OH&S) and environmental management system in line with OHSAS 18001 and ISO 14001, the final step of which will be successful external accreditation. GenSys has engaged an external contractor to assist in this implementation program and an initial status review of both the Environmental and Health and Safety systems onsite is being undertaken. Once complete, work schedules and target accreditation dates will be defined.


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Incident reports are currently undertaken for any unplanned event. In the event of an unplanned emission onsite, GenSys is committed to conducting a root cause analysis of the incident. Any measures which may be identified to avoid a recurrence of the incident will be examined and implemented and documented.

SP - Safety Rules A Procedure for applying the safety rules SP - Safety Rules B Work on Low Voltage Apparatus SP - Safety Rules C High Voltage Switching SP - Safety Rules D Earthing High Voltage Apparatus SP - Safety Rules E Work on Automatically or Remotely Controlled Plant and Apparatus SP - Safety Rules F Computer Based Safety Document Production System - PRISM SP - Safety Rules G Authorisations Procedure SP - Safety Rules H Completion of Safety Documents SP - Safety Rules I Defined Persons - Safety Rules SP - Safety Rules J Confined Spaces

Table 11. Documents Making up the Permit to Work System.

SP 001 Safety Statement SP 002 Accidents and First Aid SP 003 Display Screen Equipment SP 004 Control of Visitors SP 005 Risk Assessment SP 006 Fire Prevention SP 007 Use of Fork Lift SP 008 Clean Area for Plant Maintenance SP 009 Safe Working Methods SP 010 Environmental Management Programme SP 011 Fire Procedure - Specific Areas SP 012 Fire and Evacuation Procedure SP 013 Personal Protective Equipment SP 014 Safety Committee SP 015 Contractor Safety Procedures SP 016 Safety in Plant Modifications SP 017 Control of Substances Hazardous to Health (COSHH) SP 018 Oil Spillage Procedures - Specific Areas SP 019 Chemical Spillage Procedures SP 020 Major Gas Leak SP 021 On-Site Explosion SP 022 Hot Work - Guidelines SP 023 Plant Outage Works – Safety Audit/Inspections SP 024 Safe use of lifting equipment SP 025 Safe use of scaffolding

Table 12. Suite of Safety Procedures.



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Emergency Contact Details 1 Incident Support Team Contact Details 2 Oil Chemical and Product Inventory 3 Maximum quantities onsite at peak times 3.1 Emergency Response Training Philosophy 4 References connected to Emergency Response Plan 5 Emergency Procedures 6 Roles and Responsibilities 6.1 Initial response to any incident 6.2

6.3

Levels of Emergency Level 1 Emergency, restricted to one operating area

Level 2 Emergency, Restricted to Huntstown site, two or more operating areas

Level 3 Emergency, Potential off site impact All Clear 6.4 Return to Operational Status 6.5 Incident Report 6.6

6.7 Insurance Reporting Fire and Evacuation 6.8

6.9 Gas Leak Fuel Oil Spill 6.10 Electrical fire in CO2 protected area 6.11 Sodium Hydroxide (Caustic) Spill 6.12 Hydrochloric Acid Spill 6.13 Ammonia Spill 6.14 Hydrazine Hydrate Spill 6.15 Other Chemical Spill 6.16

Appendix A Incident Command Centre (ICC) Equipment List. Appendix B Emergency Alarm Signals Appendix C Facility Maps, Plans Appendix D On-Site Emergency Equipment List And Location Appendix E Incident Support Team Call Out List Appendix F Checklists For Incident Support Team Members

Table 13. Contents of Emergency Incident Response Plan


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9. SECTION L – STATUTORY REQUIREMENTS

9.1 Attachment L – Statutory Requirements

9.1.1 Section 83 of the EPA Acts Clauses 83(3)(5) (a) (i) to (v) and (vii) to (x) of the EPA Acts 1992 and 2003 make reference to specific conditions for the granting of a Licence. Compliance with all these conditions is covered within this supporting document. Table 14 below indicates where each condition is addressed.

Sub-clause Extract from Clause Reference in Application Documents or original Licence 483

83(3)(5)(a)(i) “… section 50 of the Air Pollution Act 1987 … section 51 of the Air Pollution Act 1987”

Attachment I.1 in Section 7.2.1

83(3)(5)(a)(ii) “… any relevant quality standard for waters, trade effluents and sewage effluents and standards … section 26 of the Local Government (Water Pollution) Act 1977”

Attachment I.2 in Section 7.2.2

83(3)(5)(a)(iii) “… any standard for an environmental medium prescribed under regulations made under the European Communities Act 1972”

Attachment I.8 in Section 7.3

83(3)(5)(a)(iv) “…noise … any regulations under section 106”

Licence 483

83(3)(5)(a)(v) “… will not cause significant environmental pollution”

Attachment I.8 in Section 7.3

83(3)(5)(a)(vii) “ … having regard to Part III of the Act of 1996, production of waste… will be prevented or minimised or, … disposed of in a manner which will prevent or minimise any impact on the environment”

Licence 483

83(3)(5)(a)(viii) “…energy will be used efficiently” Licence 483 83(3)(5)(a)(ix) “… necessary measures will be taken to

prevent accidents” Attachment J in Section 8.1

83(3)(5)(a)(x) “… necessary measures will be taken upon the permanent cessation of the activity”

Licence 483

Table 14. References to Section 83 of the EPA Acts

9.1.2 Habitats Directive The EIS submitted with the planning application confirms that the site not listed as an Area of Scientific Interest (ASI), nor is it proposed as a National Heritage Area (NHA) or Special


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Area of Conservation (SAC). It is not a known site for any legally protected plant species or habitat type. It is understood that no site within 10 km of the power station falls within any of the categories of:

a) a site placed on a list in accordance with Chapter 1 of SI 94 of 1997; b) a site where consultation has been initiated in accordance the EU Habitats Directive 92/43/EEC); or c) a European site as defined in Article 2 of SI 94 of 1997.

9.1.3 Water Quality Standards for Phosphorus The Local Government (Water Pollution) Act, 1977 (Water Quality Standards for Phosphorus) Regulations, 1998 define maximum allowed phosphate concentrations in lakes and rivers, in accordance with their degree of pollution or tolerance of inhabiting invertebrate species to pollutants. Irrespective of the classification of the water ultimately receiving any aqueous discharge from the Phase I plant, it is considered that no significant impact arises because under normal circumstances no phosphate will be used by the plant and discharged within its effluent. Phosphate on site is restricted to a supply of trisodium phosphate for dosing into boiler water at times of transient water quality. Since the plant is air cooled, the risk of ingress of acid forming impurity prompting the use of phosphate to counter such acid formation is very low.

The estimated quantity of trisodium phosphate stored on the site is 1 tonne. The expected maximum quantity of trisodium phosphate to be discharged over a year is 0.2 tonne (of which phosphate ion PO4

- - - would constitute 0.12 tonne) and is determined under a combination of pessimistic assumptions. It was assumed for this purpose that the whole boiler blowdown was discharged – whereas normally it would be recycled – and that this would contain 5 mg/kg of phosphate, and that these two conditions would coincide for a total of three months within the year.

9.1.4 Government Acts To comply with the Statutory Requirement that the operator of the installation is a “fit and proper person” as outlined under Section 84(4) of the Protection of the Environment Act 2003, Appendix E includes a copy of a signed declaration by the Plant Manager and other senior staff to confirm that they have not been convicted under this Act or other applicable legislation.

9.1.5 Technical Knowledge and Qualifications To demonstrate the appropriate technical knowledge and qualifications of the operators of the installation, Appendix F presents the CVs of the Plant Manager and other senior staff identified as signatories to the declaration copied in Appendix E.


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HUNTSTOWN POWER COMPANY LIMITED from Phase I is exported via a 220 kV cable to an ESB National Grid...

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Transcript of HUNTSTOWN POWER COMPANY LIMITED from Phase I is exported via a 220 kV cable to an ESB National Grid...