POWER & ENERGY HOLDINGS (ROI) LTD · 2013. 7. 26. · N nitrogen NGR National Grid Reference NO...

POWER & ENERGY HOLDINGS (ROI) LTD AVOCA SCGT IPPC LICENCE APPLICATION SUPPORTING INFORMATION JULY 2008

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PB Power Contents Page i of iii

Document No. 63110/PBP/000004 Rev A 0618R000.DOC/S3/3/RT

CONTENTS

Page

LIST OF ABBREVIATIONS

1. SECTION A – NON-TECHNICAL SUMMARY 1.1

1.1 Attachment A1 – Non-technical Summary 1.1

2. SECTION B – GENERAL 2.1

2.1 Attachment B1 – Company Registration Documents 2.1 2.2 Attachment B2 – Site Maps 2.4 2.3 Attachment B5 – Planning Approval and Licences 2.4 2.4 Attachment B8 – Site Notice, Newspaper Advertisement 2.4 2.5 Attachment B10 – IPPC Directive 2.5

3. SECTION C – MANAGEMENT OF THE INSTALLATION 3.1

3.1 Attachment C 3.1 3.1.1 Site management and control 3.1 3.1.2 Environmental Management System 3.1 3.1.3 Hours of operation 3.3

4. SECTION D – INFRASTRUCTURE AND OPERATION 4.1

4.1 Attachment D – Operational information 4.1 4.1.1 Simple cycle generating plant 4.1 4.1.2 Design features 4.1 4.1.3 Plant layout 4.3 4.1.4 Operating regimes 4.4

5. SECTION E – EMISSIONS 5.1

5.1 Attachment E1A – Emissions to air 5.1 5.1.1 Major emissions 5.1 5.1.2 Minor emissions 5.1

5.2 Attachment E1B – Fugitive and potential emissions to air 5.2 5.3 Attachment E2 – Emissions to surface waters 5.3

5.3.1 Abstraction 5.3 5.3.2 Discharges 5.4 5.3.3 Mitigation 5.7

5.4 Attachment E4 – Emissions to ground 5.7 5.5 Attachment E5 – Noise emissions 5.7

6. SECTION F – CONTROL AND MONITORING 6.1

6.1 Attachment F1 – Treatment and Abatement 6.1 6.2 Attachment F2 – Monitoring and sampling 6.1

6.2.1 Monitoring at source of emission 6.1 6.2.2 Remote monitoring 6.3

7. SECTION G – RESOURCE USE AND ENERGY EFFICIENCY 7.1

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7.1 Attachment G – Raw materials and energy 7.1 7.1.1 Raw materials 7.1 7.1.2 Energy efficiency 7.2

8. SECTION H – MATERIALS HANDLING 8.1

8.1 Attachment H1 – Materials and wastes 8.1

9. SECTION I – EXISTING ENVIRONMENT AND IMPACT OF THE ACTIVITY 9.1

9.1 Site condition 9.1 9.2 Impacts 9.1

9.2.1 Attachment I1 – Atmospheric emissions 9.1 9.2.2 Attachment I2 – Surface water emissions 9.3 9.2.3 Attachment I4 – Groundwater emissions 9.3 9.2.4 Attachment I5 – Groundwater contamination 9.3 9.2.5 Attachment I6 – Waste recovery and disposal 9.4 9.2.6 Attachment I7 – Noise impact 9.4

9.3 Attachment I8 – BAT arguments and mitigation measures 9.5 9.3.1 Selection of process 9.5 9.3.2 Selection of fuel 9.6 9.3.3 Use and discharge of water 9.6 9.3.4 Other raw materials 9.7 9.3.5 Emissions to air 9.7 9.3.6 Waste 9.7 9.3.7 Energy efficiency 9.7 9.3.8 Monitoring of emissions 9.8 9.3.9 Noise and vibration 9.8

10. SECTION J – ACCIDENT PREVENTION AND EMERGENCY RESPONSE 10.1

10.1 Attachment J – Accident prevention and emergency response 10.1

11. SECTION K – REMEDIATION, DECOMMISSIONING, RESTORATION AND AFTERCARE 11.1

11.1 Attachment K – Remediation, decommissioning, restoration and aftercare 11.1 11.1.1 Decommissioning management 11.1 11.1.2 Criteria for decommissioning plan 11.1 11.1.3 Residuals management plan 11.1 11.1.4 Main plant elements 11.1 11.1.5 Hazardous waste 11.2 11.1.6 Non-hazardous waste 11.3 11.1.7 Buildings security 11.3 11.1.8 Decommissioning completion report 11.3

12. SECTION L – STATUTORY REQUIREMENTS 12.1

12.1 Attachment L – Statutory Requirements 12.1 12.1.1 Section 83 of the EPA Acts 12.1 12.1.2 Habitats Directive 12.2 12.1.3 Water quality standards for phosphorus 12.3

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A. SITE MAPS A1

B. WATER BALANCE AND PROCESS FLOW B1

C. NOISE FIGURES C1

D. AIR DISPERSION MODELLING STUDY D1

D.1 Summary D1 D.2 Existing environment D2

D.2.1 Ambient air quality D4 D.3 Environmental impact D5

Air quality during construction D5 D.3.1 Air quality during operation D6 D.3.2 Control of oxides of nitrogen during combustion D7 D.3.3 Conversion of nitric oxide to nitrogen dioxide D7

D.4 Atmospheric dispersion modelling D9 The dispersion model and inputs D10 D.4.1 Modelling Scenario D11 D.4.2 Modelling results D13 D.4.3 Analysis of results D20

D.5 Mitigation measures and monitoring programmes D23 Construction D23 D.5.1 Operation D24

D.6 Conclusion D25

E. ENVIRONMENTAL IMPACT ASSESSMENT (CD) E1

F. PROPOSED AMENDMENT TO EXISTING LICENCE F1

G. PLANNING AUTHORITY NOTIFICATION G1

H. REPORTS AND ACCOUNTS H1

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PB Power List of Abbreviations Page 1 of 2


LIST OF ABBREVIATIONS

AOD above ground installation BAT best available techniques BOD biochemical oxygen demand BREF BAT reference document °C degrees Celsius CCGT combined cycle gas turbine CER Commission for Energy Regulation CO carbon monoxide CO2 carbon dioxide COD chemical oxygen demand COSHH Control of Substances Hazardous to Health cSt centistoke dB decibels dB(A) decibels A-weighted DFO Distillate Fuel Oil EC European Community EPA Environmental Protection Agency EU European Union g gram h hour IFI Irish Fertilizer Industries Ltd IPPC Integrated Pollution Prevention and Control ISO International Organization for Standardization kg/m3 kilogram per cubic metre kg/s kilogram per second km kilometre km2 square kilometre kPa kilopascal kV kilovolt LCPD Large Combustion Plant Directive LHV Lower Heat (Calorific) Value m metre m2 square metre m³ metre cubed mg/l milligrams per litre mg/m³ milligrams per metre cubed mg/Nm³ milligrams per normal metre cubed MJ/kg Megajoules per kilogram MW megawatt MWe megawatt electric MWth megawatt thermal N nitrogen NGR National Grid Reference NO nitrogen oxide NO2 nitrogen dioxide NOx oxides of nitrogen NPWS National Parks and Wildlife Service O2 oxygen OH&S Occupational Health and Safety PEH Power & Energy Holdings (ROI) Ltd PM10 particulate matter pNHA Proposed Natural Heritage Area ppm parts per million SCGT simple cycle gas turbine SO2 sulphur dioxide TDS total dissolved solids

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PB Power List of Abbreviations Page 2


μg/m3 micrograms per metre cubed V volts VOCs volatile organic compounds %v per cent by volume

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PB Power Section 1 Page 1.1 of 1.2

63110/PBP/000004 Rev A 0618R000.doc/S5/2/RT

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 an IPPC Permit for the proposed Avoca SCGT near Arklow in County Wicklow. The new plant will be constructed on a site previously owned by Irish Fertilizer Industries Ltd and will provide up to 280 MW of generation capacity at site ambient conditions.

The Avoca project is proposed by Power and Energy Holdings (ROI) Limited (PEH), part of the Viridian Group.

The plant will operate as a peaking power plant designed to operate in a more flexible manner than conventional thermal power stations to meet relatively short periods of peak electricity demand. With the rapid growth in the demand for electricity in Ireland and the ever increasing proportion of renewable sourced energy, the existing installed generation capacity must be supplemented by highly flexible plant in order to fully satisfy the highest demand, at all times. The rapid, controllable, response provided by peaking facilities is also ideally suited to use as reserve generation in the event of unexpected conventional power station outage.

The electricity generated by the Project will be delivered to the Irish National Grid. PEH propose to develop this as a peaking plant in order to assist EirGrid in meeting additional, temporary, demands of the grid and, as such, is expected to operate for approximately 300-500 hours per year. The facility will help maintain the electrical stability of the supply in terms of generation capacity, voltage control and frequency regulation.

The configuration of the development is currently being investigated, however the plant will comprise one or more gas turbine generators, fuelled solely by ultra low sulphur distillate fuel oil (DFO). The DFO will have a sulphur content of less than 0.1 per cent in accordance with European Community (EC) Directive 1999/32/EC.

The thermal input of the proposed plant will be up to approximately 800 MWth with the efficiency of the plant being of the order of 35 per cent based on the lower calorific value (LHV) of the DFO fuel.

The gas turbine is an engine in which air is compressed by an axial compressor and delivered to combustion chambers where fuel is injected and burned. Demineralized water is also added to reduce the flame temperature and the resulting nitrogen oxide emissions. The hot gases created by the combustion are passed through the turbine, where they expand and drive the turbine. The work done by the gases in the turbine drives both the generator, to generate electricity, and the axial flow air compressor. The used gases are then discharged to a dedicated stack system and released to atmosphere. The height of each stack will be 22 m.

The gas turbines chosen for the proposed plant will be equipped with proven pollution control technology which will limit the production of NOx to a maximum of 120 mg/Nm3 during oil firing. The emissions of NOx will therefore be in accordance with the limits set in the Large Combustion Plant Directive (LCPD). In order to maintain these emission levels, water injection techniques will be

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63110/PBP/000004 Rev A 0618R000.DOC/S5/2/RT

employed. This method represents the Best Available Technique (BAT) for limiting emissions of NOx to atmosphere from liquid fuel fired gas turbines operating in simple cycle.

Dispersion modelling was performed for NOx, sulphur dioxide (SO2) and particulate matter. The plant is not expected to cause any exceedances of any of the limits prescribed in the Air Quality Standards Regulations 2002.

The use of DFO 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.

Water consumption and discharge are minimal due to the proposed operating regime of the SCGT plant. The majority of water required by the plant will be taken from the Avoca River. The return to the river of the effluent will result in an average increase in dissolved solid concentration of around 0.45 per cent, and is not considered significant.

Noise attenuation measures will be applied at source and provisions will be made for acoustic barriers where necessary to ensure that appropriate noise limits will be met.

The site is currently covered in road stone and is not the subject of any ecological designation, nor will the project lead to significant pollution to any designated ecological sites in the vicinity of the plant.

The plant will act as an operating reserve for the National Grid and, as such, will not be in continuous operation. The plant will be controlled remotely from Huntstown Power Station, in Dublin, and will require only a small on-site staff for periodic maintenance and receiving road tanker deliveries of the fuel.

The peaking plant will be designed with an expected operational life of 30 years. Decommissioning of the plant will be undertaken with full consultation with the local authorities and the Environmental Protection Agency.

The plant will be operated under health, safety and environmental procedures developed for the Huntstown Power Station (Phases 1 and 2), which include essential features such as staff training and awareness and an Emergency Incident Response Plan. PEH will also develop an Environmental Management System for the project and is committed to working towards accreditation to ISO 14001.

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2. SECTION B – GENERAL

2.1 Attachment B1 – Company Registration Documents

Copies of the Certificate of Incorporation are attached overleaf.

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2.2 Attachment B2 – Site Maps

Figure A.1 (see Appendix A) show the general location of the site whilst Figure A.2 shows the site location in more detail. The Project is to be located approximately 2 km north-west of Arklow, County Wicklow around 72 km south of Dublin. The Irish Grid Reference for the site is 322916, 175023. The site is a plot of 10.5 acres adjacent to the site access road for the Avoca River Park industrial zone.

Figure A.3 shows the site plan/layout for the proposed Avoca plant including release points E1 to E10 to air.

2.3 Attachment B5 – Planning Approval and Licences

Planning permission for the plant has only recently been submitted to Wicklow Council. For information, copies of the planning application documents, including the Environmental Impact Statement and supporting planning drawings, are provided on the CD included in Appendix E.

Holfeld Plastics Ltd, the current site owner, has agreed to amend the site boundary of the existing IPPC Licence number P0031-02 to remove the area for the proposed development as part of the land sale agreement. Written confirmation of this from Holfeld Plastics has been incorporated in to this document as Appendix F and includes a drawing of the proposed amended boundary.

2.4 Attachment B8 – Site Notice, Newspaper Advertisement

Question – do we need to re-advertise due to technology change? Can we check with the EPA?

A copy of the site notices that were displayed in conspicuous locations around the site is shown in Figure A.4. The notices were erected on 14 March 2008.

The newspaper advertisement was placed in the Irish Independent on 13 March 2008 and contained the following text:

Wicklow County Council

Power & Energy Holdings (ROI) Ltd. seek permission for the development of a Simple Cycle Gas Turbine peaking power station on a site of approximately 4.25 hectares at the former Irish Fertilizers Industries Ltd. site at the Avoca River Park, in the townland of Shelton, Arklow, Co. Wicklow.

The development will consist of 1 no. gatehouse at entrance (72 m2), I no. tanker unloading facility including canopy (120 m2), I no. water treatment plant building (552 m2), 1 no. black start diesel generator building (123 m2), 1 no. store building (557 m2), 1 no. switchyard relay building (240 m2), 2 no. cylindrical distillate oil tanks (567 m2 excluding bund, maximum height 17 metres), 2 no. cylindrical water injection tanks (509 m2 maximum height 17 metres, 1 no. raw/fire water tank (113 m2, maximum height 14 metres), 2 no. cylindrical regeneration chemical tanks (57 m2, maximum height 4 metres), 2 no. gas turbine plant enclosures and ancillary equipment (2,692 m2), 1 no. emergency diesel generator (282 m2), 1 No 220 kV overhead line of length 200 m

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including the construction of two pylon towers. The development will also provide for a graveled switchyard compound of 7,251 m2, site roads of approximately 5,292 m2 and associated site works.

This application relates to an activity for which an Integrated Pollution Prevention Control License under the Environmental Protection Agency Acts 1992 and 2003 is required. An Environmental Impact Statement will be submitted to the planning authority with the application.

The planning application and accompanying Environmental Impact Statement may be inspected or purchased at a fee not exceeding the reasonable cost of making a copy at the offices of Wicklow County Council, County Buildings, Wicklow during its public opening hours and a submission or observation in relation to the application may be made to the authority in writing on payment of the prescribed fee within the period of 5 weeks beginning on the date of receipt by the authority of the application.

Wicklow County Council was notified of the submission of the application for an IPPC Permit in a letter dated 8 April 2008. A copy of this letter is included as Appendix G.

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

3.1.1 Site management and control

The Avoca SCGT plant will be operated on behalf of the applicant by GenSys Power Limited (GenSys), part of the Viridian Group. GenSys recognizes that its activities may have an effect on the environment and local community and an Environmental Policy Statement will be developed to communicate its environmental aims.

3.1.2 Environmental Management System

A comprehensive Environmental Management System that will be prepared for the project and is expected to be similar to that for the existing EMS in place for the Huntstown power station and will be designed to achieve the following objectives:

• to improve environmental performance by:

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

- complying with the Power and Energy Holdings (ROI) environmental policy;

- minimizing environmental risks and preventing pollution; and

- maintaining effective and efficient Environmental Management Systems;

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

- educate and train staff to conduct their activities in an environmentally responsible manner;

- inform suppliers and contractors of their high environmental standards; and

- encourage all stakeholders to use energy resources efficiently.

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

GenSys has established a 3-phase approach to the development and implementation of environmental management strategies that will be in accordance with the ISO 14001:2004 requirements. The integration of additional quality and safety systems will further increase the efficiency of the EMS.

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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 ISO 14001:2004.

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. Emergency procedures will be incorporated 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;

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• Development of an audit programme to demonstrate compliance with the Environmental Policy; and

• Annual EMS review meetings to identify opportunities for continual improvement.

Phase 3

A tailored environmental training programme to 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.

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.

3.1.3 Hours of operation

Figure A.5 shows the proposed construction timetable. The construction process will take approximately 20 months, including commissioning.

Construction work will only take place during daylight hours and will be limited to:

Monday to Friday 07:00 – 19:00 hours

Saturday 07:00 – 13:00 hours.

Work will not take place on Sundays or Public Holidays unless such work is associated with an emergency or does not exceed the ambient noise levels. If it becomes necessary to perform construction work outside of the times indicated, due to technical constraints or similar, written approval of the local authorities will be requested, in advance.

The commissioning process will take of the order of eight weeks and will be progressive from the final erection checks, pre-commissioning and testing of individual component parts through to the testing of the overall plant to prove the technical acceptance. Prior to the commercial operation of the plant, it

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will be demonstrated that the facility is fit for purpose. Performance testing will be undertaken to ensure compliance will all applicable guarantees and the reliability of the plant will be assessed by operating under commercial conditions for an agreed period of time, without the need for major repair to any item of plant or equipment.

Operation of the power station is expected to be for the order of 300-500 hours per year. In accordance with a ruling from the Commission for Energy Regulation, the fuel oil storage at the plant will be sufficient to enable continuous operation at full load for 72 hours.

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4. SECTION D – INFRASTRUCTURE AND OPERATION

4.1 Attachment D – Operational information

4.1.1 Simple cycle generating plant

The “Fixed Cost of a New Entry Peaking Plant for the Capacity Payment Mechanism” Final Decision Paper produced by the CER and NIAUR concludes that new entry peaking plant should be based on a large simple cycle gas turbine (SCGT) configuration.

Conventional thermal plant, including combined cycle gas turbines (CCGT), require a significant time to achieve full load, primarily, due to the time taken to heat the boiler surfaces and generate steam. Steam turbines associated with these types of plant also require a slow increase in their load to avoid detrimental thermal stress.

CCGT plant start up is much quicker than that of coal fired plant. The issues regarding the steam-side generation are still present, although it is possible to maintain the boiler temperature until needed. The complexity of the start up process, however, presents a high risk of unit tripping, during either a cold or hot start, and it is not considered that a CCGT plant would provide the required reliability to operate under the proposed generation regime. For CCGT plant to provide the appropriate level and quality of grid support it must be held in spinning reserve.

Gas turbines can achieve full load within approximately 15 minutes, when operating in simple cycle. There is, therefore, no requirement for such plant to be held as spinning reserve.

Further advantages of simple cycle plant are:

• low capital and operating costs;

• shorter construction period; and

• well-proven technology for the plant rating and operating regime proposed.

The Decision Paper also concludes that new entry peaking plant should operate on distillate fuel oil (DFO) and that there is no requirement for a secondary fuel source. The maximum sulphur content of the DFO to be used in the project will be limited to 0.1 per cent by weight, in accordance with EPA guidelines and EU Directive 1999/32/EC relating to the reduction in the sulphur content of certain liquid fuels.

4.1.2 Design features

The station will consist of five generating units. Each unit will comprise two gas turbine engines and power turbines and ancillary equipment, an air cooled generator, air intakes, instrumentation and a dedicated exhaust stack for each gas turbine (two per unit). The total electrical output of the Avoca power station will be up to 280 MWe at site ambient conditions.

The plant will operate in simple cycle mode with an overall generation efficiency of approximately 35 per cent. The turbines burn the fuel, with compressed air, in a combustion chamber. The hot

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gases then expand over the turbine blades, turning the turbine and driving an electrical generator. These gases are then discharged to atmosphere.

The gas turbines will be equipped with the proven pollution control technology. Water injection into the combustion chamber of the turbine represents the Best Available Technique (BAT) for limiting emissions of NOx to atmosphere from liquid fuel fired gas turbines. State of the art firing controls will also be used to enable the combustion to be optimized for all operating conditions.

The flue gases from each gas turbine will be discharged to atmosphere by a dedicated stack system. The total stack height will be 22 m to ensure adequate atmospheric dispersion of the turbine exhaust gases.

The final layout of the plant will be determined following the completion of the tender process however a typical arrangement for the layout of each gas turbine island is shown in Figure A.3 and a simplified process flow diagram is shown in Figure B.2.

One engine, and then the whole station, can be black started using the station emergency shutdown diesel generator.

Demineralized water is required for the injection into the turbines, periodic compressor washing and for the closed circuit cooling system. There are two ways of generating the water required and as such the plant will either employ an ion exchange or reverse osmosis process. In addition to employing one of these processes the water treatment plant will consist of the following: a raw water break tank, treated water storage tanks and all interconnecting pipe work.

Transformers will be provided for plant electrical supplies. All outdoor transformers will be oil filled and situated within an individual containment bund in case of spillage. In this event, the spillage will be transferred into a road tanker for off-site disposal at a licensed facility.

The remainder of the plant will consist of air compressing equipment, electrical switchgear and control equipment. The compressed air system will be provided to compress and deliver air of a quantity and quality suitable for all general, instrument and control purposes at all appropriate points in the plant.

Fire fighting services will be provided. Fire water will be stored in a dedicated volume in the lower part of the raw water tank. All applicable storage will be designed to comply with the relevant fire regulations and will be installed with fire pumps, hose reels, fire hydrants, foam systems and portable extinguishers.

The plant will be designed to allow for on site operation as well as remote operation from Huntstown Power Station, Dublin and will require a minimum of manual intervention. Full facilities for the interfacing of information, control and alarm systems will be installed so that plant can be controlled and monitored via a distributed control system. In the event of unsafe fault conditions the plant will shut down.

The design of buildings, enclosures and plant equipment will also minimize regular and long term maintenance. Materials and finishes will be selected to meet this objective and to ensure that the appearance of the plant does not deteriorate with time.

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4.1.3 Plant layout

The proposed plant layout has been designed with regard to the following factors:

• Compliance with regulatory requirements

• Provisions to minimize noise and visual impact

• Technical requirements and access for maintenance

• Connection to the transmission network

• Plant and personnel safety

• Road access.

The plant equipment will be arranged so that the site will have logical boundaries between the three distinct process elements: processing and storage of fuel and water; power generation; and the export of electricity to the Irish National Grid. The orientation of the stages is based upon the existing landscape in terms of site access and the transmission system connection points. The site entrance will remain in its current position and an emergency egress will be established towards the south east corner of the site perimeter.

The main generation units will be located to the south centre of the site with the turbines enclosed individually in steel framed acoustic enclosures. The stacks will be 22 m high. A purpose built switchyard, for the export of electricity, will be toward the north-east of the site to enable a simple process of connection to the 220 kV transmission line, east of the site.

Connection to the transmission system may require the construction of two new suspension towers. The first tower, around 190 m south east of the site, will be a three arm angle tower. This will be a double circuit terminal tower that will allow the line to loop into the plant. The second will be a terminal tower located around 25 m from the east boundary of the site and will provide an appropriate approach angle for the connection of the re-routed transmission line to the switchyard.

Alternatively, connection to the transmission system may be by underground cable to the existing Arklow substation.

New on-site roads and paved areas will be provided as required. No off-site road work will be necessary as the existing dedicated access road, parallel to the site boundary, is sufficient for the requirements of the proposed development. The layout has been arranged to allow future reticulation roads around the site as identified in the masterplan scheme for the overall IFI site.

A steel wire mesh fence will be constructed around the site for security and the plant will have closed circuit television installed.

Car parking spaces will be provided towards the north-west corner of the site.

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4.1.4 Operating regimes

The power station will be used to generate electricity at peak demand times and also during periods of instability of the Irish National Grid. It is expected that the plant will operate intermittently for a total of approximately 300-500 hours throughout the year. Sufficient DFO will be stored on-site to allow for up to 72 hours of continuous operation at full load.

The gas turbine will be accelerated to a self-sustaining speed of approximately 70 per cent rated speed. At this point, additional fuel will be injected to accelerate the gas turbine and the generator to the rated speed, while automatically disengaging the starting device.

After a short period of operation at rated speed, the unit will be ready for synchronization which will be accomplished by an automatic synchronizer.

For shutdown, the load on the gas turbines can be reduced and the unit disconnected from the grid by a reverse power relay. The unit is then run down by reducing the fuel input.

During start-up, NOx and CO emission concentrations will not fall to guaranteed levels until a minimum gas turbine load is reached. Any increase in concentration is offset by a reduced exhaust flow rate while at low load. Similarly during shutdown, concentrations may increase briefly. The time required for the turbines to reach full load will normally be of the order of 10 minutes.

The plant will be designed and constructed to a target average annual availability of at least 97 per cent and an expected operational life of 30 years.

In addition to the above operational modes the plant can be used as a black start plant to re-establish the electrical grid after a total loss. Grid failure is extremely rare, therefore the actual requested hours of operation for the black start function are expected to be very low. In the event of an actual black start event the unit may be required to start up one main generating unit at Avoca. Once this unit is synchronized and supplying electric power to the station auxiliaries, the black start generator can be shut down. The black start generator will also serve as an emergency diesel generator to provide emergency back-up and enable the plant to be shut down in a safe manner, if the station is subject to a loss of electricity. To ensure that the black start generator will respond when called upon, the unit will be started and run for a few hours at regular intervals. It is expected that this engine will only ever operate for test purposes with a total operational time, per year, of the order of 50 hours.

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5. SECTION E – EMISSIONS

5.1 Attachment E1A – Emissions to air

5.1.1 Major emissions

The major emissions from the plant will be the gas turbine exhaust gases released via the dedicated turbine stacks. Details of exhaust gas constituents are given in Tables E1(ii) and E1(iii) of the application form.

The significant pollutants as listed in the Schedule of the Environmental Protection Agency (Licensing) Regulations (Amended) 2004 are SO2, NOx, CO, VOCs and dust.

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 Environmental Protection Agency Draft BAT Guidance Note on Best Available Techniques for the Energy Sector (Large Combustion Plant Sector). The plant will operate in full compliance as shown in Table 5.1 and demonstrated in the air dispersion modelling study discussed in Section 9.2.1 and reproduced in full in Appendix D.

TABLE 5.1 PROPOSED EMISSION CONCENTRATIONS OF POLLUTANTS

AND BAT CRITERIA

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

Pollutant Fuel

Proposed plant BREF EPA Sector Guidance Note

NOx (as NO2) distillate oil 120 – 120

CO distillate oil 100 – 100

SO2 distillate oil 56 – 120

Dust distillate oil 15 – –

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 black start and emergency diesel generator, and fuel systems. These are described in more details below.

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5.1.2.2 Black start/emergency generator

One engine, and then the whole station, can be black started using the black start/emergency diesel generator. Once the start up process has been completed the black start unit will shut down and the larger units would then assist in the restoration of the grid.

The start up power required by the black start facility will be supplied by the black start/ emergency diesel engine. Low sulphur diesel will be supplied to the generator from the main DFO storage tanks. The diesel generator is expected only to operate for weekly testing purposes to confirm that the unit is available for emergency duty.

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

5.1.2.3 Fire fighting system

The station will have a full fire detection and protection capability. Water for fire fighting will be stored in lower part of the raw water tank. All applicable storage will be designed to comply with the relevant fire regulations and will be installed with electric motor driven and diesel engine driven fire pumps, hose reels, fire hydrants, foam systems and portable extinguishers. The diesel engine driven fire pump will have a rating less than 0.1 MWe and will be fired on low sulphur diesel supplied from a bunded diesel tank local to the pump. The pump engine will discharge to atmosphere through a silencer and stack located above the fire fighting skid roof. Pumps will be run only for emergency duty or for weekly testing purposes. Emissions to atmosphere from the fire fighting system will not be significant.

5.1.2.4 Fuel systems

The “Fixed Cost of a New Entry Peaking Plant for the Capacity Payment Mechanism” Final Decision Paper produced by the CER and NIAUR concludes that new entry peaking plant should operate on DFO and that there is no requirement for a secondary fuel source.

Approximately 7000 m3 of DFO will be stored in a bunded tank on-site. This quantity is sufficient to operate the plant at maximum output for approximately three days. The fuel will be delivered to site by road tankers.

There will be some minor fugitive emissions to atmosphere such as breathing losses from the fuel storage tanks but these are not considered significant.

5.2 Attachment E1B – Fugitive and potential emissions to air

Table E1(v) lists sources within the distillate fuel oil and turbine lubricating systems from which occasional emissions may arise owing to operation of plant protective devices.

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5.3 Attachment E2 – Emissions to surface waters

5.3.1 Abstraction

The majority of water required by the plant will be taken from the Avoca River. Water will, primarily, be required for injection into the gas turbines in order to control emissions of oxides of nitrogen (NOx). Water will also be required for the fire fighting system and on-site facilities. Drinking water will be provided via a tie in to local towns water supply that supplies the Holfeld Plastics site.

The turbine injection water must be of high purity and will be treated in an on-site water treatment plant. The total volume of treated water stored on-site will be approximately 6500 m3. Together with the miscellaneous minor process requirement of 1 m3/day, the total quantity of river water required by the power station will be of the order of 400 m3/day. This level of abstraction is based on the plant operating at full load for four hours and completely refilling the demineralized water tanks over the following 20 hours ready for the next peak.

As discussed in Section 4.1.4, the proposed plant is expected to operate for of the order of 500 hours per year and the above level of abstraction will not be required every day. For every hour of full load operation the plant will require approximately 100 m3 of water from the Avoca River. The annual daily mean water abstraction rate is therefore approximately 137 m3/day.

If ever the station was to operate continuously for 72 hours the water requirement for the plant would rise to around 490 m3/day in order to refill the demineralized water storage tanks, assuming filling over a period of 15 days. This would also be necessary during the commissioning of the plant.

There are two parameters to consider when assessing the impact of the anticipated level of water abstraction on rivers, the dry weather flow and the 95th percentile flow. Dry weather flow (DWF) is defined as the “annual minimum daily mean flow rate with a return period of 50 years”. 95th percentile flow is the flow that is equalled, or exceeded, at least 95 per cent of the time. Normal river flow is, therefore, only lower than this figure for a maximum of 18 days per year.

The anticipated raw water requirement from the river will be around 20.4 m3/h. As a worst case scenario, the Avoca River has a DWF of 2340 m3/h. If abstraction were to take place during times of DWF, the plant requirement would represent approximately 0.87 per cent of the flow during this period and, as such, is not expected to have any significant impact on the river. The 95th percentile flow is quoted as 6300 m3/h. Whilst remaining conservative, this is a more likely operating scenario with the abstraction requirement being around 0.32 per cent of the river flow.

Raw river water will be stored on site in a dedicated storage tank. The lower portion of this tank will be dedicated to fire water storage and will supply the fire fighting system. The upper part of the tank will be used to supply the water treatment plant, in the event of river water being unavailable, and to supply water for plant cleaning purposes.

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5.3.2 Discharges

5.3.2.1 General

The operation of the SCGT power station will generate small amounts of aqueous effluent streams, consisting mainly of effluent from the water treatment plant.

Subject to detailed design of the proposed plant, the drainage systems will comprise collector drains from all hard surfaces areas leading to a retention pond with a controlled discharge to the existing land drainage system bordering the site. Drains for all areas used for operations and vehicle parking will pass through oil interceptors. All oil storage facilities will be blind bunded to 110 per cent of the largest vessel plus allowance for rain and fire water. It is proposed that details are agreed with the EPA at a later date as a pre-operational condition of the licence.

The quantity of effluent produced per day from the water treatment plant will vary depending upon the hours of operation of the plant with a maximum of around 74 m3/day, when completely filling the demin water tanks. For normal operation, where demin water is only used to replace water injected into the turbines, it is anticipated that the effluent will be around 61 m3/day based upon the operating regime discussed in Section 5.3.1.

The water treatment plant effluent will be a concentrated solution of the salts removed from the river water plus any regenerants used in the treatment process. The flow rate will be of the order of 3 m3/h, and be around 6.5 times more concentrated than the river. Taking the 95th percentile flow of 6300 m3/h, the return of the effluent to the river will result in an average increase in concentration, for each salt, of around 0.45 per cent, and is not considered significant.

The effluent will also contain some additional sodium sulphate or chloride produced by the neutralization of the spent regenerants. The caustic soda solution and the acid used for regeneration may contain minute traces of mercury and cadmium. Every reasonable effort will be made to obtain supplies free of these metals however, based on current data, it is expected that less than 12 g per annum of cadmium and less than 3 g per annum of mercury would be discharged.

The quality of the effluent from the SCGT plant will be monitored for flow, pH, suspended solids and oils and grease.

The typical water balance shown in Appendix B as Figure B.2. Table 5.2 shows the preferred and maximum flow rates of process drains.

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TABLE 5.2 PROCESS FLOWS FROM THE PLANT

Source Preferred discharge from site, tonnes/day

Maximum discharge from site, tonnes/day

Miscellaneous Drains 1.0 2.0

Water treatment plant effluent 61 74

Minor process effluents 0.5 0.5

TOTAL 62.5 76.5

‘Miscellaneous drains’ comprises the water from the cleaning of the gas turbine air compressors. These are removed from site and disposed of by a suitably licensed contractor. This is discussed further in Section 5.3.2.4.

The minor process effluents refer to miscellaneous losses from plant and storage equipment such as leaks or dripping taps. This has been included as a ‘factor of safety’ as the nature of these losses make them difficult to quantify.

Where oil contamination is a possibility the effluents will be passed through oil interceptors/traps before entering the drainage systems.

Due to the volume and nature of these effluents, the impact on the Avoca River is considered to be insignificant.

5.3.2.2 Surface drains

The surface water drainage system will drain areas of the site unlikely to be contaminated with oil and discharge the water to the drainage ditches that border the site. The majority of the surface water drainage will be uncontaminated and typical of the surface water run off from the existing hardstanding at the site.

An oily waste water drainage system will drain all areas where oil spillages could occur. The design will incorporate oil interceptors and traps. These will discharge, with the other surface water, into the site drainage ditches. The discharge from each oil interceptor will contain no visible oil or grease.

Adequate facilities for the inspection and maintenance of oil interceptors will be provided and the interceptors will be regularly emptied and desludged to ensure efficient operation. A qualified contractor will dispose of the sludge off-site.

All oil and chemical storage tanks and areas where drums are stored will be surrounded by impermeable bunds. Single tanks will be within bunds sized to contain 110 per cent of capacity and multiple tanks or drums will be within bunds sized to contain 110 per cent of the capacity of the largest tank. Permanently fixed taps, filler pipes, pumping equipment, vents and sight glasses will also be located within the bunded area. Taps and valves will be designed to discharge downwards and will

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be shut and locked in that position. Manually started electrically operated pumps will remove surface water collected within the bund and its composition will be verified prior to disposal.

5.3.2.3 Sanitary drains

Sewage will drain to a dedicated storage tank that will be emptied and exported from site by a licensed waste disposal contractor.

5.3.2.4 Chemical drains

The contaminated water drainage system will collect the water treatment plant effluent and pump this directly back into the main channel of the Avoca River.

The expected discharge quality is described in Table E2(ii) of the Application Form and is compared with the latest available data for the Avoca River from the EPA in Table 5.3 below.

TABLE 5.3 AQUEOUS DISCHARGE QUALITY

Parameter Unit Table E2(ii) water treatment

plant effluent

Avoca River

ammoniacal nitrogen mg/l N 0.8 0.12

Cadmium * µg/l 0.6 -

Mercury * µg/l 0.2 -

pH 6 - 9 6 - 7

BOD mg/l 23 3.5

Total phosphorus mg/l P 0.6 0.09

TDS mg/l 522 78

The concentrations of cadmium and mercury shown in Table 5.3 represent additions to current levels as data for the current concentrations in the Avoca River are unavailable. The effluent will be well within the standards prescribed by the European Communities (Drinking Water) Regulations 2000 of:

• Cadmium 5 μg/l

• Mercury 1 μg/l

In addition, these effluent concentrations are very much a worst case scenario for the plant and every reasonable effort will be made to obtain supplies of acid and caustic soda (required for water treatment regeneration) that are free of cadmium and mercury.

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From time to time it will be necessary to wash the blades of the air compressor section of the gas turbines to remove debris that has penetrated the inlet air filters and become lodged on the compressor blades. This will be done at times when the performance of the gas turbines has degraded and will depend upon the air quality in the vicinity of the plant. Washing will be performed off-line with the compressor blades rotating slowly through a detergent solution. Approximately 15 m3 of waste water containing detergent per unit will be removed from site by road tankers for disposal by a licensed contractor.

During the detailed engineering stage, consideration will be given to the storage, recovery and re-use of these effluents.

5.3.3 Mitigation

All aqueous process effluent discharged to the Avoca River will be in accordance with EPA limits. The use of de-icing substances will be minimized during the winter.

The control of water use and discharge will be consistent with the BAT requirements described in the large combustion plant BREF.

All elements of the treatment systems will be regularly monitored to ensure optimum performance and maintenance. The water treatment plant effluent will be monitored for pH value. If the pH is outside the range of 6 to 9, or as permitted by the EPA, the discharge will automatically stop until the failure is corrected.

No pollutants as listed in the Schedule of the Environmental Protection Agency (Licensing) Regulations (Amended) 2004 will be used on site.

No prescribed substances as described in the Water Quality (Dangerous Substances) Regulations 2001 are generated or used on the site.

5.4 Attachment E4 – Emissions to ground

The proposed plant will produce no emissions to ground.

5.5 Attachment E5 – Noise emissions

A comprehensive provisional list of noise sources is given in the completed Table E.5(i) of the Application Form. The principal sources are:

• Gas turbines;

• Air intakes;

• Stacks;

• Fin fan cooler bank;

• Air compressors;

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• Water injection module; and

• Generator transformers.

Figure C1 in Appendix C shows the plot, highlighting these sources. The plant layout is arranged 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. Strategic locations of noise barriers will be identified to ensure that far field noise limits will be complied with, should they be necessary.

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6. SECTION F – CONTROL AND MONITORING

6.1 Attachment F1 – Treatment and Abatement

The gas turbines chosen for the proposed plant will be equipped with proven pollution control technology which will limit the production of NOx to a maximum of 120 mg/Nm3 during oil firing. The emissions of NOx will therefore be in accordance with the limits set in the Large Combustion Plant Directive (LCPD). In order to maintain these emission levels, water injection techniques will be employed. This method represents the Best Available Technique (BAT) for limiting emissions of NOx to atmosphere from liquid fuel fired gas turbines operating in simple cycle.

The maximum sulphur content of the DFO to be used in the project will be limited to 0.1 per cent by weight, in accordance with EPA guidelines and EU Directive 1999/32/EC relating to the reduction in the sulphur content of certain liquid fuels.

Dispersion modelling was performed for NOx, carbon monoxide, sulphur dioxide (SO2) and particulate matter. The plant is not expected to cause any exceedances of any of the limits prescribed in the Air Quality Standards Regulations 2002.

All aqueous process effluent discharged to the Avoca River will be in accordance with EPA limits. The use of de-icing substances will be minimized during the winter.

The control of water use and discharge will be consistent with the BAT requirements described in the large combustion plant BREF.

All elements of the treatment systems will be regularly monitored to ensure optimum performance and maintenance. The water treatment plant effluent will be monitored for pH value. If the pH is outside the range of 6 to 9, or as permitted by the EPA, the discharge will automatically stop until the failure is corrected.

No pollutants as listed in the Schedule of the Environmental Protection Agency (Licensing) Regulations (Amended) 2004 are to be used on site.

No prescribed substances as described in the Water Quality (Dangerous Substances) Regulations 2001 are generated or used on the site.

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

6.2 Attachment F2 – Monitoring and sampling

6.2.1 Monitoring at source of emission

Gas turbine operating parameters (e.g. fuel flow, power output, inlet temperature), O2 and flue exit temperature will be monitored continuously during operation. Owing to difficulties in measuring large volumes of air flow through the gas turbine, the flow rate will be calculated from manufacturers’ data and the fuel flow and power parameters. Control of the gas turbine combustion temperature and the

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fuel/demineralized water ratio, and monitoring of the NOx emissions will be used to control exhaust NOx concentration. All alarms will be monitored by the distributed control system in the central control room.

Concentrations of NOx, O2 and CO will be continuously monitored in each flue. The emissions monitoring instruments will be calibrated on a regular basis. The NOx signal will be corrected for O2 and moisture and the signals recorded by the Emissions Monitoring System. Post commissioning tests will monitor the levels of NO, NO2, CO and O2. This automated monitoring systems (AMS) will be MCertS approved and will be operated and maintained in compliance with BS EN 14181. Provision will be included to allow for parallel monitoring of the flue gases.

Discontinuous monitoring of SO2 and particulate matter will be made at least bi-annually in accordance with the requirements of the Large Combustion Plant Directive.

Logs will be kept by the operators and on the computer system, including the following:

• electricity generated and fuel burn/consumption;

• the maximum hourly mean value of NOx in mg/m3;

• the daily mean value of the hourly means of NOx in mg/m3;

• the mass of fuel burned;

• the mass of NOx released; and

• the mass release of carbon dioxide calculated from the carbon content of the DFO in accordance with the EU Emissions Trading Scheme.

The above records will be retained for 10 years.

Records will be kept of all environmental audits performed, emissions testing results and instrumentation calibration/testing documentation.

Exceedences of maximum limits will be alarmed. Four ports at right angles in the same plane will be provided for independent monitoring of particulates and velocities, in accordance with EPA Guidance Note 5.2. The sampling plane will be situated more than 0.5 duct diameters upstream of the stack outlet in accordance with recognized guidelines. Height constraints prevent the distance from the monitoring plane to the nearest upstream flow disturbing geometrical feature complying with the minimum of 5 diameters recommended in recognized guidance notes, but this is not critical when only gaseous species are being measured.

All elements of the water treatment system will be regularly monitored for flow, temperature, conductivity and ammonia content and high parameter levels will be alarmed to ensure optimum performance and maintenance. The water treatment plant effluent will be monitored for pH value. If the pH is outside the range of 6 to 9, or as permitted by the EPA, the discharge will automatically stop until the failure is corrected.

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Adequate facilities for the inspection and maintenance of oil interceptors will be provided all bunded areas where water is likely to be contaminated with oil will be monitored.

6.2.2 Remote monitoring

The operation and monitoring of the gas turbines and associated auxiliary plant equipment, including the water treatment and fuel systems, will be managed from Huntstown Power Station or locally via control outstations during maintenance. The plant operational status will be monitored locally and from the central control room.

The central control room will be fitted with the necessary equipment to allow full interfacing with the systems installed at the site. All data generated by the on-site systems will be available to the central control room via a distributed control system. The facilities for plant control and observation will range from dedicated push-button and auto-manual fascias, for the control of individual motors and valves, to VDUs for the operational co-ordination of all plant systems.

Fully detailed alarm signalling and time-tagging will be achieved via the data acquisition system utilizing the screens and printers of the control facilities. Sufficient equipment will be provided to enable performance and efficiency monitoring, including the full cycle from fuel input to electrical output and the auxiliary electrical system. Various plant parameters will be monitored, trended and archived on a continuous basis, both for immediate operational needs and for continuous assessment of the plant maintenance requirements.

All necessary instrumentation and control equipment will be provided to permit continuous monitoring and control of emissions in order to meet planning consents and achieve the EPA requirements as specified in the plant IPPC Licence.

The control and instrumentation systems will adopt redundant measurement and control techniques. These will include redundant CPUs and communications and redundant sensors connected to separate I/O interfaces. A redundant secure leased line data connection will be provided between the site and Huntstown Power Station.

Consequently, as well as being fail-safe all systems will be sufficiently robust to survive an internal failure without disturbing power generation. However, control outstations will be able to continue to control the plant in the event of a complete loss of communication to the supervisory computers. In this event operational staff will be dispatched to the site until communication links are restored.

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7. SECTION G – RESOURCE USE AND ENERGY EFFICIENCY

7.1 Attachment G – Raw materials and energy

7.1.1 Raw materials

The raw materials used by the Avoca plant may be divided into fuels, water and operation chemicals.

The fuel for the plant will be distillate fuel oil which will be stored on site in a dedicated storage tank within a bund sized for 110 percent of the volume of the tank. The plant will require approximately 40 000 tonnes per year of DFO based on 500 hours operation. A typical distillate oil composition is provided in Table 7.1.

TABLE 7.1 DISTILLATE OIL COMPOSITION

Parameter Unit Typical content

Carbon % mass 86.3

Hydrogen % mass 13.6

Nitrogen % mass <0.01

Total Sulphur % mass <0.1

Net calorific value MJ/kg 43.2

Density @15ºC kg/m³ 836.2

Kinematic Viscosity @40ºC cSt 2.616

Flash Point PMCC ºC 64.0

Cloud Point ºC -7

Pour Point ºC -24

Water Content % mass <0.01

Carbon Residue, micro method % mass 0.05

Ash % mass 0.001

Mercaptan Sulphur % mass <0.0003

Water will be primarily used for water injection into the gas turbines during DFO firing. Per annum, the total water requirement will be approximately 50 000 tonnes.

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7.1.2 Energy efficiency

The station will consist of five or more generating units. Each unit will be comprised of two gas turbines and ancillary equipment, an air cooled generator, air intake, instrumentation and a dedicated exhaust stack for each turbine. The total electrical output of the Avoca power station will be up to 280 MWe at site ambient conditions. The plant will operate in simple cycle mode with an overall generation efficiency of approximately 35 per cent and therefore will have a thermal input of approximately 800 MWth.

The plant will be designed to provide the most cost-effective solution to a set of commercial, energy supply and environmental objectives. As a result, the potential energy consumption on site is one of the key parameters in optimizing the overall design.

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8. SECTION H – MATERIALS HANDLING

8.1 Attachment H1 – Materials and wastes

The following waste arisings are anticipated at this site:

• oil;

• paper filters;

• oil filters;

• batteries;

• fluorescent light fittings;

• domestic waste;

• scrap metal;

• empty drums; and

• wooden pallets.

Hazardous wastes are included in Table H1(i) of the application form whilst the other waste materials are included in Table H1(ii).

All hazardous waste, as identified in the tables, will be removed by a licensed contractor.

All general waste will be stored on site in suitable facilities and taken off the site by a proven, licensed responsible contractor. The developer will ensure that these wastes are disposed of in an acceptable manner by undertaking spot checks. All waste loads will be accompanied with consignment notes.

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

9.1 Site condition

The proposed site is approximately 2 km north west of Arklow, County Wicklow.

The site is located on land previously owned by Irish Fertilizer Industries Limited (IFI), who closed their operations at the site in 2002. In the 1960s a state owned fertilizer factory was built and the surrounding area operated as a landfill site for the waste from the production processes. The plant has since been decommissioned.

The previous use as a fertilizer production facility has led to significant contamination of the ground beneath the area surrounding the site. The primary pollutants are ammonia and nitrates. The natural ground water flow tends, north-west to south-east, towards the Avoca River and facilitates the slow removal of these chemicals. Significant work has been undertaken by the current owner to regenerate the land. The proposed site is now completely covered by hardstanding and is currently used for the storage of various types of road vehicle.

The absence of semi-natural habitats on the former IFI landholding limits the species diversity, with most of the species recorded being typical of the surrounding region. The proposed power plant will be constructed on land currently covered with hardstanding. There is negligible ecological interest associated with the site itself.

Road Traffic Noise from the N11 was the dominant noise source in the area of the proposed Peaking Power Plant. Road traffic on local roads also contributed to the noise levels within the area.

9.2 Impacts

9.2.1 Attachment I1 – Atmospheric emissions

The impact of emissions to air has been assessed by an air dispersion modelling study of the plant. All dispersion modelling was undertaken using AERMOD 4.0.13 which is a second generation modelling program developed in the US.

The AERMOD model calculates time averaged ground level concentrations over any set of distances from the source. To predict the ground level concentrations associated with the peaking station, the study used a 20 km by 20 km Cartesian grid, with 1000 m spacing. For higher definition closer to the site, a 2 km by 2 km grid, with 100 m spacing, was also used. scenarios identified. Both grids were centred on NGR T 22834 75113.

The full report of the study is given in Appendix D.

The modelled pollutants were NO2, CO, SO2 and PM10. The DFO sulphur content was assumed to be a typical 0.1 per cent. Impacts were compared with the Air Quality Standards Regulations 2002 derived from EU Directives.

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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;

• assuming continuous base load operation all year; and

• assuming the maximum emissions coincide with the worst case meteorological conditions.

The main results are summarized in Table 9.1.

TABLE 9.1 INCREMENTS AND BACKGROUND CONCENTRATIONS

OF KEY POLLUTANTS

Pollutant Averaging Period

Increment to ground level concentrations

Concentration in ambient air Guideline

19th highest hourly average 172.6 81.7 200

NO2 1 year 1.4 5.67 40


SO2 4th highest daily

average 48.0 8.00 125

CO 8 hour running average 314.8 1500 10 000

8th highest daily average 9.2 58.8 50

Particulates 1 year 1.7 17.6 20

The existing background levels of NO2, CO and SO2 are well within the limits set by the Air Quality Standards Regulations 2002. Background concentration of particulate matter, however, is high with respect to the guidelines likely as a result of traffic in the vicinity of the monitors. The daily average itself already exceeds of the limit value of 50 μg/m3.

The predicted maximum short term increases in concentrations of NO2 and SO2 occur at a point approximately 6.1 km west of the proposed site south-east of Ballycoog, at the base of Croghan Mountain.

The location of maximum annual increments is significantly influenced by the local terrain and indicative of the prevailing meteorological conditions, ie predominantly south-westerly winds. In practice, the predicted small increments to annual average levels due to the proposed power plant would be virtually undetectable using diffusion tubes or other monitoring equipment in use today.

Increases to the short term concentrations are highest on the sides of the hills within the study area.

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The impact of the atmospheric emissions from the proposed SCGT power station in isolation will be well within the Air Quality Standards Regulations 2002. As such, the impact of the new plant is considered to be insignificant.

9.2.2 Attachment I2 – Surface water emissions

The quantity of effluent produced per day from the water treatment plant will vary depending upon the hours of operation of the plant with a maximum of around 74 m3/day, when completely filling the demin water tanks. For normal operation, where demin water is only used to replace water injected into the turbines, it is anticipated that the effluent will be around 61 m3/day. The effluent will be a concentrated solution of the salts removed from the river water plus any regenerants used in the treatment process. The flow rate will be of the order of 3 m3/h, and be around 6.5 times more concentrated than the river. Taking the 95th percentile flow of 6300 m3/h, the return of the effluent to the river will result in an average increase in concentration, for each salt, of around 0.45 per cent, and is not considered significant.

The effluent will also contain some additional sodium sulphate or chloride produced by the neutralization of the spent regenerants. The caustic soda solution and the acid used for regeneration may contain minute traces of mercury and cadmium. Every reasonable effort will be made to obtain supplies free of these metals however, based on current data, it is expected that less than 12 g per annum of cadmium and less than 3 g per annum of mercury would be discharged.

The quality of the effluent from the plant will be monitored for flow, pH, suspended solids and oils and grease. The surface water from any areas of the site that are likely to be contaminated with oil will drain to oil interceptor(s) to limit the oil in water content to a level regulated by the IPPC Permit, normally with a limit of “no visible oil” quoted (below 10 ppm), before discharge to the surface water drainage system.

9.2.3 Attachment I4 – Groundwater emissions

The previous land use as a fertilizer production facility has led to significant contamination of the ground beneath the area surrounding the site. The primary pollutants are ammonia and nitrates. The natural ground water flow tends, north-west to south-east, towards the Avoca River and facilitates the slow removal of these chemicals.

The surface water drainage system will drain areas of the site unlikely to be contaminated with oil and discharge the water to the drainage ditches bordering the site. The majority of the surface water drainage will be uncontaminated and typical of the surface water run off from the existing hardstanding. The proposed plant will not lead to significant additional surface water run off.

9.2.4 Attachment I5 – Groundwater contamination

The risk of infiltration to groundwater is low. The only List I or List II substances used on site are distillate fuel oil and lubricating oil. Measures are in place to prevent these substances reaching groundwater. The distillate fuel oil storage tanks will be contained within a common blind bund sized for 110 per cent of the capacity of the largest tank. Lubricating oil is contained within a closed bunded system. The risk of contamination of groundwater is therefore insignificant.

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9.2.5 Attachment I6 – Waste recovery and disposal

As an inherent characteristic of the process, only small quantities of waste are generated. Such wastes as are produced are retained on site for collection and disposal by licensed contractors. The impact of this waste outside the site boundary in terms of odour, dust and water resources is insignificant and no disposal by landfill is carried out on site. It is therefore concluded that no specific assessment of waste impact on the environment is necessary.

9.2.6 Attachment I7 – Noise impact

A noise impact assessment has been undertaken and focused on five NSR locations that surround the power station, as shown in Figure C.2. Existing baseline conditions at each location have been determined by an attended noise survey.

Predictions of the impact of the plant were based on information regarding the noise output of the specific items of plant. The noise and vibration impacts during operation, as detailed in Table 9.2 have been predicted using a noise propagation model using the typical values for the proposed plant items, and considering directional and screening effects.

TABLE 9.2 NOISE IMPACTS AT NEARBY RESIDENCES

NSR Location Specific noise level due to

peaking plant (rating level)

LAeq (dB)

Acoustic feature

correction

Lowest recorded night

time background

level LA90 (dB)

Level of rating above background

NSR Location 1 – Residential near site entrance 40 5 33 8

NSR Location 2 – Residential near Church (Easton boundary) 36 5 31 10

NSR Location 3 – Prison Road 36 5 27 14

NSR Location 4 – Glenart Castle 37 5 31 11

NSR Location 5 – Caravan Site R747 38 5 36 7

The noise contour map generated by the model is shown in Figure C.3.

The specific noise levels detailed in Table 9.2 assume that there are no tonal or impulsive elements during the actual operation of the plant. The acoustic feature correction has been applied to reflect that the plant will not always be in operation.

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Low noise equipment and acoustic insulation have been selected to minimize any potential impacts. Foundations may be laid at strategic locations to enable the erection of acoustic shields, should these be necessary.

The impact of construction noise and vibration is not predicted to be significant due to the distances between the proposed construction site and the noise sensitive receptors, and due to the temporary and changing nature of the noise source.

The impact of predicted operational noise has been assessed for the proposed plant against background noise levels obtained during the attended noise survey. The results of the BS 4142 assessment have predicted that potential complaints are possible from residents due to operational noise of the Peaking Power Station at NSR locations 1 to 5. However, the level of noise control that will be provided on this project is extensive and will be based on achieving the WHO night time noise limit of 45 dB(A) at the nearest residential sensitive receptor. The noise model has shown that operational noise levels from the proposed Peaking Power Station should not exceed this 45 dB(A) limit at any residential receptor.

9.3 Attachment I8 – BAT arguments and mitigation measures

9.3.1 Selection of process

The plant will be used to respond to requests from EirGrid, as the transmission system operator in Ireland, to assist in meeting the temporary peak generating demands of the grid and help maintain the electrical stability of the supply in terms of voltage control and frequency regulation. The plant will play a key role in complementing intermittent renewable generation and provide strategic support to the grid.

Conventional thermal plant, including combined cycle gas turbines (CCGT), require a significant time to achieve full load, primarily, due to the time taken to heat the boiler surfaces and generate steam. Steam turbines associated with these types of plant also require a slow increase in their load to avoid detrimental thermal stress.

CCGT plant start up is much quicker than that of coal fired plant. The issues regarding the steam-side generation are still present, although it is possible to maintain the boiler temperature until needed. The complexity of the start up process, however, presents a high risk of unit tripping, during either a cold or hot start, and it is not considered that a CCGT plant would provide the required reliability to operate under the proposed generation regime. For CCGT plant to provide the appropriate level and quality of grid support it must be held in spinning reserve, producing all the atmospheric emissions of normal operation but without generating any electricity.

The gas turbines proposed for the Avoca site can achieve full load within approximately 4 minutes, when operating in simple cycle, (although normal start-up time is in the order of 5 minutes). There is, therefore, no requirement for such plant to be held as spinning reserve.

Renewable energy processes cannot be considered for peaking operation as they inherently lack the required control to satisfy the demand responsive duty requirements of this operating regime.

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The proposed simple cycle gas turbine is ideally suited to operate as standing reserve plant due to its short start up time, reliability and flexibility.

9.3.2 Selection of fuel

Distillate fuel oil (DFO) will be used as the fuel type for the gas turbines, and the optional black start facility. The “Fixed Cost of a New Entry Peaking Plant for the Capacity Payment Mechanism” Final Decision Paper, produced by the Commission for Energy Regulation and the Northern Ireland Authority for Utility Regulation, concludes that new entry peaking plant should operate on DFO and that there is no requirement for a secondary fuel source.

It is proposed to use DFO with a sulphur content of less than 0.1 per cent in line with current EC legislation. In practice, most suppliers provide DFO with a sulphur content of around 0.05 per cent, An analysis of the DFO used, by PEH, at the Huntstown power station states that the sulphur content is approximately 0.002 per cent.

9.3.3 Use and discharge of water

The majority of water required by the plant will be taken from the Avoca River. Water will, primarily, be required for injection into the gas turbines in order to control emissions of oxides of nitrogen (NOx). Per annum, the total water requirement will be approximately 50 000 tonnes.

Water will also be required for the fire fighting system and on-site facilities. Drinking water will be provided via a tie in to local towns water supply that supplies the Holfeld Plastics site.

Raw river water will be stored on site in a dedicated storage tank. The lower portion of this tank will be dedicated to fire water storage and will supply the fire fighting system. The upper part of the tank will be used to supply the water treatment plant, in the event of river water being unavailable, and to supply water for plant cleaning purposes. On-site facilities will be used on an irregular basis due to the remote operation of the plant. It is proposed that any sewage generated will be stored in an underground tank for periodic removal and disposal by a licensed contractor.

On a day-to-day basis, the only effluent produced by the plant will comprise the effluent from the water treatment plant. The water treatment plant effluent will be a concentrated solution of the salts removed from the river water plus any regenerants used in the treatment process and this will discharge directly to the Avoca River. The return of the effluent to the river will result in an average increase in dissolved solid concentration of around 0.45 per cent, and is not considered significant.

The effluent will also contain some additional sodium sulphate or chloride produced by the neutralization of the spent regenerants. The quality of the effluent from the plant will be monitored for flow, pH, suspended solids and oils and grease.

The surface water from any areas of the site that are likely to be contaminated with oil will drain to oil interceptor(s) to limit the oil in water content to a level regulated by the IPPC Permit, normally with a limit of “no visible oil” quoted (below 10 ppm), before discharge to the surface water drainage system.

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9.3.4 Other raw materials

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.

9.3.5 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 120 mg/Nm³ (at reference conditions of 15%v oxygen, dry, 0ºC, 1013 mbar a) on DFO firing with water injection to comply with the limit defined in the Environmental Protection Agency Final Draft Guidance Note on BAT for the Energy Sector (Large Combustion Plant Sector).

The emission of sulphur dioxide is minimized by using natural gas fuel with negligible sulphur content. The sulphur content of distillate fuel oil is limited to 0.1 per cent by weight with SO2 emission less than half of the EPA Guidance Note value of 120 mg/Nm³.

Carbon monoxide will also be emitted from the plant and this will be limited to 100 mg/Nm³ as per the EPA Guidance Note. There are no prescribed limits for the emission of particulate matter within the Guidance Note however these will be less than 15 mg/Nm³.

The stack height of 22 m 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.

9.3.6 Waste

The installation uses an intrinsically low waste producing process. There are no waste products associated with the liquid fuel. The other materials consumed in significant quantities are the chemicals used within the water treatment plant. These will be delivered to fixed storage tanks. 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.

9.3.7 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 minimizing 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 minimization through well targeted improvement plans. Such an improvement plan will be managed through procedures and will identify the areas where energy is utilized, identify potential energy efficiency measures and ensure that their financial viability is appraised. This process will be initiated once the

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plant has been handed over from the construction contractor and assessments may be made of each of the principal areas of energy use such as heat recovery, electrical drives, lighting and ventilation.

9.3.8 Monitoring of emissions

Concentrations of NOx, O2 and CO will be continuously monitored in each flue. The emissions monitoring instruments will be calibrated on a regular basis. The NOx signal will be corrected for O2 and moisture and the signals recorded by the Emissions Monitoring System. Post commissioning tests will monitor the levels of NO, NO2, CO and O2. This automated monitoring systems (AMS) will be MCertS approved and will be operated and maintained in compliance with BS EN 14181. Provision will be included to allow for parallel monitoring of the flue gases.

Discontinuous monitoring of SO2 and particulate matter will be made at least bi-annually in accordance with the requirements of the Large Combustion Plant Directive.

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).

The discharge from the water treatment plant will be continuously monitored for pH, temperature, flow and conductivity. The pH and conductivity measurements are linked to the valving to direct discharge either to release or recycled to the treatment plant. Additional measurements are made on regular manual samples. These arrangements are designed to ensure that only discharge of acceptable quality is released.

9.3.9 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. Strategic locations of noise barriers will be identified to ensure that far field noise limits will be complied with, should they be necessary.

The vibration BAT objective has been achieved by avoiding all sources of reciprocating machinery with the exception of the emergency diesel generator or black start diesel drive which will only operate occasionally.

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10. SECTION J – ACCIDENT PREVENTION AND EMERGENCY RESPONSE

10.1 Attachment J – Accident prevention and emergency response

Accidents with the potential to affect the environment are handled within the Emergency Incident Response Plan managed by the operator GenSys. The plan will be based on the procedures in place for Huntstown power station, also operated by GenSys.

Components of the Huntstown 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 plant, and will provide the same services for the Avoca power station when commissioned. All maintenance activities on-site are conducted using a permit to work system, which is based on a suite of safety rules. These are listed in Table 10.1. There is also a suite of safety procedures which must be adhered to as shown in Table 10.2.

A detailed Emergency Incident Response Plan which aims to address the hazards on site will also been developed and be located in the plant control room which is manned on a 24 hour basis. This emergency incident response plan will be designed to address any emergency situations which may occur on site. The Emergency Incident Response Plan contents are listed in Table 10.3.

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.

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 will engage an external contractor to assist in this implementation program and an initial status review of both the Environmental and Health and Safety

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systems on-site will be undertaken. Once complete, work schedules and target accreditation dates will be defined.

In the event of an unplanned emission on-site, 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.

TABLE 10.1 DOCUMENTS MAKING UP THE PERMIT TO WORK SYSTEM.

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 Authorizations Procedure

SP - Safety Rules H Completion of Safety Documents

SP - Safety Rules I Defined Persons - Safety Rules

SP - Safety Rules J Confined Spaces

TABLE 10.2

SUITE OF SAFETY PROCEDURES.

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

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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 10.3

CONTENTS OF EMERGENCY INCIDENT RESPONSE PLAN

1 Emergency Contact Details

2 Incident Support Team Contact Details

3 Oil Chemical and Product Inventory

3.1 Maximum quantities onsite at peak times

4 Emergency Response Training Philosophy

5 References connected to Emergency Response Plan

6 Emergency Procedures

6.1 Roles and Responsibilities

6.2 Initial response to any incident

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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

6.4 All Clear

6.5 Return to Operational Status

6.6 Incident Report

6.7 Insurance Reporting

6.8 Fire and Evacuation

6.9 Gas Leak

6.10 Fuel Oil Spill

6.11 Electrical fire in CO2 protected area

6.12 Sodium Hydroxide (Caustic) Spill

6.13 Hydrochloric Acid Spill

6.16 Other Chemical Spill

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

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11. SECTION K – REMEDIATION, DECOMMISSIONING, RESTORATION AND AFTERCARE

11.1 Attachment K – Remediation, decommissioning, restoration and aftercare

11.1.1 Decommissioning management

Following permanent cessation of the licensed activities on the site, PEH will arrange for the 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.

11.1.2 Criteria for decommissioning plan

The criteria used to determine the successful implementation of the decommissioning plan will include:

• adequate planning and resources to ensure safe cessation of activities;

• adequate manpower and financial resources to execute the decommissioning management programme; and

• adequate management of the site to preserve its potential for reuse.

11.1.3 Residuals management plan

Following cessation of licensed activities on the site, PEH will use reasonable endeavours to make the site suitable for redevelopment. The site and facilities will be made safe including measures to ensure that the site the site presents no continuing risk to the environment.

The equipment will be made available for sale, for reuse or recycling. Owing to the inherent nature of the materials, the decommissioning may be substantially funded by the value of the redundant materials.

11.1.4 Main plant elements

The plant equipment and buildings will be decommissioned and the material removed from the site for reuse of parts or material recycling, all in accordance with good engineering, safety and environmental practices. The main plant elements are listed in Table 11.1.

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TABLE 11.1 MAIN DECOMMISSIONING PLANT ELEMENTS

Equipment Resources Timescale months

Net Cost, €

Comments

Gas Turbine 20 2 Nil Includes high value alloy materials for re-use. Units removed from site

Diesel Generator

5 1 Nil Units removed from site

Air Compressors

2 1 Nil Units removed from site

Pumps 2 1 Nil Units removed from site

Air Inlet Filter 5 1 50,000 Dismantled on site

Transformers 5 1 Nil Units removed from site

Switchgear 10 2 50,000 Units removed from site

Tanks 10 3 100,000 The diesel oil tanks will be rendered environmentally safe by a specialist contractor and residual hazardous material will be disposed of appropriately. The decommissioned tank will be sold for scrap metal recycling.

Piping 10 4 200,000 Dismantled on site

Cranes 5 1 Nil Units removed from site

Buildings Fabric and Steel

10 3 Nil Dismantled on site

Cabling 10 3 Nil Dismantled on site

Ducting 10 4 200,000 Dismantled on site

Foundations 10 5 500,000 Broken out and crushed, or retained for redevelopment

11.1.5 Hazardous waste

Hazardous waste including waste solvents, waste oils, solid waste, fluorescent tubes and other waste requiring disposal/recovery will be sent to an agreed waste disposal/recovery site.

All waste transported off site will be transported in accordance with good environmental practice and appropriate national and European legislation.

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11.1.6 Non-hazardous waste

Non hazardous waste including process solid waste, insulation and other waste requiring disposal/recovery shall be sent to an agreed waste disposal/recovery site.

11.1.7 Buildings security

Prior to decommissioning, all buildings will be secured to prevent unauthorized entry. A maintenance program will be put in place to ensure that the buildings do not decay or present an unacceptable nuisance in the area.

11.1.8 Decommissioning completion report

11.1.8.1 Test programme

During the execution of the Residuals Management Plan, an assessment will be conducted by an independent qualified Environmental Consultant to monitor and report the compliance status and environmental risk factors of the plan. The following points will be specifically covered:

• regular contact with EPA;

• verification/certification that underground sumps and all storage tanks and lines are not leaking;

• verification to ensure that there is no risk to surface water, groundwater or any soil contamination; and

• physical examination of the facility to ensure removal of any or all contaminants.

A summary report on the final outcome of the execution of the residuals management programme to include surveys, results, assessments, studies, proposals performed as part of the execution the plan.

Any ongoing monitoring programme will be identified, if required and a contract set up with an appropriately qualified consultant to monitor and report as required.

11.1.8.2 Final report

A final validation report will be issued by the company to include a certificate of completion of the Residuals Management Plan. This will be done within three months of end of the execution of the plan.

11.1.8.3 Financial provisions

The total cost of implementing this residuals management plan will be determined in due course and will be met by PEH. The financial costs associated with the Residuals Management Plan will be reviewed on an annual basis to ensure they accurately reflect market costs.

The time to decommission the plant completely is likely to be 1 to 2 years from the date of last production. This will be determined by the nature of the obsolescence of the plant, and the success of

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commercial or technical revival measures which may be under investigation prior to decision to decommission, based on technical or commercial obsolescence.

Any other financial provisions in the event of closure of the facility or part thereof as may be identified in the Environmental Liabilities Risk Assessment, required under the IPPC Licence, will be addressed as part of that assessment.

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12. SECTION L – STATUTORY REQUIREMENTS

12.1 Attachment L – Statutory Requirements

12.1.1 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 12.1 below indicates where each condition is addressed.

TABLE 12.1 REFERENCES TO SECTION 83 OF THE EPA ACTS

Subclause Extract from Clause Reference in application documents

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

Attachment I1 in Section 9.2.1

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”


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

Attachment I8 in Section 9.3

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


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

Attachment I8 in Section 9.3

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


83(3)(5)(a)(viii) “…energy will be used efficiently” Attachment G in Section 7.1.2

83(3)(5)(a)(ix) “… necessary measures will be taken to prevent accidents”

Attachment J in Section 10.1

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

Attachment K in Section 11.1

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Fit and Proper Person

Section 83(5)(xi) of the PoE Act specifies that the EPA shall not grant a licence unless it is satisfied that the applicant is a fit and proper person.

As per Section 84(4) of the PoE Act:

The Applicant has no previous convictions under the PoE Act, the Waste Management Act 1996, the Local Government (Water Pollution) Acts 1977 and 1990 or the Air Pollution Act 1987.

The Applicant is a highly experienced operator of thermal power plants for the purposes of electricity generation. The Applicant currently operates power stations in Ireland with a total generating capacity of approximately 744 MW under IPPC Licence Numbers P0483-03 and P0777-01.

The Applicant is in a position to meet any financial commitments or liabilities that will be entered into or incurred in carrying on the activity to which the application relates or in consequence of ceasing to carry out that activity. The Applicant has already financed two major thermal power plant projects in Ireland to a total value of approximately €500 million and has now entered the wind power development field, having recently bought Eco Wind Power. The following annual reports are included as Appendix H:

• Viridian Group Annual Report and Accounts 2006-2007

• Viridian Power & Energy Limited Report and Accounts 31 March 2007

12.1.2 Habitats Directive

The proposed site is not listed as being within any designated conservation area on the NPWS database. The closest designated areas, as detailed in Table 12.2, are the Arklow Town Marsh proposed Natural Heritage Areas (pNHA), approximately 0.7 km south east and the Avoca River Valley pNHA, approximately 0.8 km north west. The Arklow Sand Dunes pNHA lies approximately 3.5 km east of the site while Arklow Rock lies approximately 4 km to the south east.

TABLE 12.2 DESIGNATED CONSERVATION AREAS WITHIN 5 KM

Site name Site No Designation status

Distance from site (km)

Arklow Town Marsh 1931 pNHA 0.7

Avoca River Valley 1748 pNHA 0.8

Arklow Sand Dunes 1746 pNHA 3.5

Arklow Rock - Askintinny 1745 pNHA 4.0

Buckroney – Brittas Dunes and Fen 0729 cSAC / pNHA 5.0

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The nearest candidate Special Area of Conservation (cSAC) is the Buckroney-Brittas Dunes and Fen, approximately 5 km north east of the site. This cSAC is an extensive sand dune/fen system that contains several coastal habitats, including two priority habitats, listed in the EU Habitats Directive.

Records of rare and protected plants on the NPWS database show 11 records of five Flora Protection Order listed species occurring within the 10 km square. These are listed in Table 12.3.

TABLE 12.3 PROTECTED PLANT SPECIES WITHIN THE 10 KM SQUARE (T27) OF THE

PROPOSED SITE

Species Common Name Primary habitat

Asparagus officinalis prostratus Wild asparagus Sandhills

Asplenium obovatum lanceolatum Lanceolate spleenwort Banks and walls.

Cephalanthera longifolia Narrow-leaved helleborine Damp woods and scrub

Papaver hybridum Round prickly-headed poppy Sandy fields

Saxifraga granulata Meadow saxifrage Sand hills and pastures near coast

The habitats in the vicinity of the proposed development are unsuited to any of these species with the exception of narrow-leaved helleborine. However, this species has not been recorded since 1928 and a specific site for plant within the 10 km square is not provided. The limited amount and apparent recent origin of the damp scrub habitat in the vicinity of the site would make it very unlikely to support the plant.

12.1.3 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. The proposed peaking station will cause no adverse effects on water quality with respect to these regulations.

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PB Power Appendix A

63110/PBP/000004 Rev A 0618R000.DOC/S17/1/RT

APPENDIX A SITE MAPS (6 pages)

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PB Power Appendix A Page A1 of A6

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A. SITE MAPS

Figure A1. Site Location

Figure A2. Detailed site Location

Figure A3. Plot Plan showing Release Points

Figure A4. Location of Public Notices

Figure A5. Construction timetable

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PB Power Appendix B

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APPENDIX B WATER BALANCE AND PROCESS FLOW

(2 pages)

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PB Power Appendix B Page B1 of B2

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B. WATER BALANCE AND PROCESS FLOW

Water TreatmentPlant Effluent

Demin WaterStorageRiver Water Water Treatment

Plant 4.8 kg/s

0.9 kg/s

5.7 kg/s

FIGURE B.1 WATER BALANCE

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PB Power Appendix B Page B2

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FIGURE B.2 PROCESS FLOW MASS BALANCE

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PB Power Appendix C

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APPENDIX C NOISE FIGURES

(4 pages)

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C. NOISE FIGURES

Figure C1. Site Plan showing Principal Noise Sources

Figure C2. Noise monitoring locations

Figure C3. Noise contour diagram

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PB Power Appendix D

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APPENDIX D AIR DISPERSION MODELLING STUDY

(25 pages)

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D. AIR DISPERSION MODELLING STUDY

D.1 Summary

The main gaseous pollutant emitted from the proposed SCGT plant will be NOx of which some 95 per cent is nitric oxide (NO) and 5 per cent nitrogen dioxide (NO2). NO oxidizes to NO2 in the presence of ozone. The SCGT plant will therefore contribute to background concentrations of NO2. To assess the size of this contribution, dispersion modelling was conducted over an area, centred on the site, of 20 km by 20 km. Detailed information is provided, within this section, on turbine plant emissions and control, the analysis of NO oxidation rates and the dispersion modelling process.

The proposed plant will operate on distillate fuel oil (DFO). The combustion of DFO gives rise to atmospheric emissions of SO2 and very low levels of particulate matter, in addition to oxides of nitrogen (NOx). The emissions of SO2 and particulate matter have also been assessed using dispersion modelling.

The topography in the study area is characterized by hills and mountains to the north and west. South and east of the proposed site, the land slopes gradually down to 0 m AOD, at the coast. For the entire study area, the terrain ranges from 0 m to approximately 550 m AOD. The proposed site is situated at the base of a valley, approximately 1.5 m AOD. As such, within 1 km the land rises sharply, to around 60 m AOD to the north and 30 m AOD to the south. Terrain effects generally occur when ground levels, within 1 km of the stack, vary by more than a third of the stack height therefore elevation data have been included in all modelling exercises.

The proposed power station will be used to respond to requests from EirGrid, as the transmission system operator in Ireland, to assist in meeting the temporary peak generating demands of the grid and help maintain the electrical stability of the supply in terms of voltage control and frequency regulation, expected to amount to 300-500 hours per year operation. The atmospheric dispersion modelling, however, was performed assuming full load operation for 8760 hours per year in order to consider all possible operating and atmospheric conditions.

The result of using this conservative approach is to ensure that the maximum predicted impact within the potential operating regime of the proposed plant is considered. This ensures that there is a “factor of safety” built into all of the air quality assessment, giving a high degree of confidence that the actual impacts will be less than those presented in this assessment. The results of the modelling, together with the existing pollutant concentrations in the ambient air, have been compared to the Air Quality Standards Regulations 2002.

Key findings from the analysis are:

• the predicted maximum increase in long term NO2 concentration, due to the proposed SCGT plant, is 1.4 μg/m3;

• the predicted maximum increase in short term NO2 concentrations, at any receptor, is 172.6 μg/m3;

• the predicted maximum increase in long term SO2 concentration is 6.5 μg/m3;

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• the predicted maximum increase in short term SO2 concentrations, at any receptor, is 122.2 μg/m3;

In conclusion, the impact of the atmospheric emissions from the proposed power station in isolation will cause no exceedances of the limits as prescribed by the Air Quality Standards Regulations 2002..

D.2 Existing environment

The Air Quality Standards Regulations 2002 specifies a series of standards and objectives for air quality in Ireland:

Nitrogen dioxide: - an hourly maximum of 200 μg/m3 by 1 January 2010 not to be exceeded more than 18 times a year (equivalent to the 99.79th percentile).

- an annual average of 40 μg/m3 by 1 January 2010.

- an annual average objective, for the protection of vegetation, of 30 μg/m3.

Sulphur dioxide: - a 1 hour mean of 350 μg/m3 by 1 January 2005 not to be exceeded more than 24 times a year (equivalent to the 99.73rd percentile).

- a 24 hour mean of 125 μg/m3 not to be exceeded more than 3 times a year (equivalent to the 99.18th percentile).

- an annual and winter objective, for the protection of ecosystems, of 20 μg/m3.

Particulates (PM10): - a 24 hour mean of 50 µg/m3 by 1 January 2010 not to be exceeded more than 7 times a year (equivalent to the 99.99th percentile).

an annual average of 20 µg/m3 by 1 January 2010.

Carbon monoxide: - a maximum daily 8 hour mean of 10 000 µg/m3, calculated by examining running 8 hour averages and assigning them to the day in which each period ends.

The Regulations are in accordance with the European Community ambient air quality guidelines for nitrogen dioxide, sulphur dioxide and particulates (Directive 99/30/EC) that were adopted 22 April 1999. A summary of the limit values of the Directive is set out in Table D.1 and Table D.2.

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TABLE D.1 EC AIR QUALITY STANDARDS

FOR THE PROTECTION OF HUMAN HEALTH

Parameter Reference period

Compliance date

Statutory ground level

concentration limit values

(μg/m3)

Number of permitted

exceedences

Equivalent percentile

Hourly 2010 200 18 99.79 Nitrogen dioxide Annual 2010 40 - -

Hourly 2005 350 24 99.73 Sulphur dioxide 24 hourly 2005 125 3 99.18

24 hours (daily mean values)

2005 50 8 97.81 Particulates (Stage 1)

Annual limit 2005 40 - -

24 hours (daily mean values)

2010 50 7 98.08 Particulates (Stage 2)

Annual limit 2010 20 - -

TABLE D.2

EC AIR QUALITY STANDARDS FOR THE PROTECTION OF VEGETATION/ECOSYSTEMS

Parameter Reference period Statutory ground level concentration limit values

Nitrogen dioxide Annual 30 μg/m3

Sulphur dioxide Annual 20μg/m3

It is important to define the areas in which the limit values in Table D.2 are to be achieved. The Directive states that sampling points should be:

• at least 5 km from major emission sources; or

• 20 km from an agglomeration, which is defined as an area with a population of more than 250 000; and

• representative of areas of at least 1000 km2.

The Air Quality Standards Regulations 2002 intend that these objectives will apply in those parts of Ireland that are:

• more than 20 km from an agglomeration; or

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• more than 5 km from other built up areas, industrial installations or motorways; and

• be representative of areas of at least 1000 km2.

As the proposed SCGT Power Station will be classed as an industrial installation, it is considered that the standards for the protection of vegetation and ecosystems are not applicable to the zone of influence of the proposed plant, ie areas within 5 km of the site. The limits are however applicable outside this area and have therefore been considered.

The Buckroney Brittas Dunes are a candidate Special Area of Conservation (cSAC) and, as such, is the only European designated ecosystem in the vicinity of the proposed site. The Dunes are also designated as a proposed Natural Heritage Area (pNHA) under the Wicklow County Development Plan 2004. Additional pNHAs, within the study area and more than 5 km from the site, are Arklow Rock Askintinny and the north-west corner of the Avoca River Valley. Arklow Town Marsh is also a pNHA but is located around 0.7 km south-east of the site.

D.2.1 Ambient air quality

The EU Directive 96/62/EC (Air Framework Directive) is implemented in Irish law by the Air Quality Standards Regulations 2002. The Regulations discuss the country in terms of zones and agglomerations and have divided Ireland into four, Zone A to D. Zones A to C are large cities and towns that are specifically mentioned as part of Schedule 10 of the above regulations. Arklow is within Zone D, Rural Ireland, being the remainder of the state.

The framework for the monitoring of ambient air quality in Ireland is prescribed in the National Air Quality Monitoring Programme. Monitoring stations throughout the country are operated by the Environmental Protection Agency (EPA) and other local authorities. Each station measures and records a selection of various pollutants, significantly: nitrogen oxides and dioxides; sulphur dioxide; particulate matter; carbon monoxide; and ozone.

The EPA produce annual reports regarding the air quality of Ireland as a whole. The latest available, “Air Quality in Ireland 2006”, was published in 2007 and was based upon information recorded by the 24 monitoring stations operating in 2006. Appendix C of this report lists summary data for the year, by Zone and for each pollutant. Table D.3 is based upon the information within the appendix, and represents the average for the relevant monitoring stations for Zone D.

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TABLE D.3 BACKGROUND POLLUTANT LEVELS, ZONE D

(μg/m3)

Measurement

Maximum hourly Maximum 24 hourly Annual average

NO2 81.67 - 5.67

NOx - - 8.33

SO2 31.00 8.00 2.67

Particulates - 58.80 17.60

Comparison of the above data with the limits set by the Air Quality Standards Regulations, as described in Section D.2, shows that exceedences are only ever generated by particulates. All other pollutants are well within the prescribed thresholds.

Five air monitoring stations contributed to the particulate measurements for Zone D in 2006. Of these, exceedences were only recorded at Carnsore Point, nine instances and maximum daily concentration of 93 μg/m3, and Castlebar, two instances with a maximum of 62 μg/m3. The average of the remaining three stations is 46.3 μg/m3.

D.3 Environmental impact

Air quality during construction

Dust could be emitted during several activities associated with the construction works should preventive measures not be taken. Dust could arise from: earth moving operations for site levelling, back filling and foundations; removal of spoil, site stripping, blow-off and spillage from vehicles; concreting operations, site reinstatement and road construction and during wind blow over bare dry construction areas.

Only with high wind speeds would long distance transport of dust and the potential for soiling of buildings occur. In these conditions more dust would also be created at source. The extent of any such emissions of dust is very dependent on wind speed, ground conditions, the prevalence of hot, dry conditions and the use of preventive measures.

The dust particles that may be emitted during construction would be of large diameter and would therefore tend to resettle on the ground within 100 to 500 m of the site. Approximately 70 per cent of the dust would generally settle out of the atmosphere within 200 m of the source, and less than 10 per cent could be expected to remain at a distance of 400 m. With the nearest housing being at a distance of around 450 m and with roads lying between, soiling of residential buildings is unlikely to occur.

Dust emissions from the site will not be more onerous than those normally encountered on construction sites. Construction operations will be conducted so as to minimize the generation and

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spread of dust. PEH will require its contractors to implement a comprehensive mitigation and monitoring programme. This will prevent construction work generating levels of atmospheric dust which would constitute a health hazard or nuisance to people working on the site or living nearby.

The use of wheel and chassis washing units will also help to prevent the transport of mud and dust onto off-site routes.

The commissioning of each unit of the SCGT plant will take approximately 8 weeks. The purpose of commissioning is to adjust the performance of the newly installed plant to achieve all required operational and environmental performance criteria. Firing of the gas turbines will be intermittent during this period. It is possible that during commissioning the emissions of oxides of nitrogen will be temporarily higher than those during normal operation. However, operational periods during commissioning are often short and operation is, frequently, at low load. Thus the total mass emissions of oxides of nitrogen during commissioning will be low.

D.3.1 Air quality during operation

The primary fuel to be used in the new plant will be distillate fuel oil (DFO). DFO is also a low sulphur fuel. It is proposed to use DFO with a sulphur content of less than 0.1 per cent in line with current EC legislation. In practice, most suppliers provide DFO with a sulphur content of around 0.05 per cent, An analysis of the DFO used, by PEH, at the Huntstown power station states that the sulphur content is approximately 0.002 per cent.

The combustion of DFO results in the emission of flue gases containing carbon dioxide, water vapour, oxygen, nitrogen, carbon monoxide (CO), oxides of nitrogen (NOx), sulphur dioxide (SO2) and particulate matter.

The emissions of NOx from all gas turbines will be below 120 mg/Nm3, at reference conditions, in accordance with the requirements of the Large Combustion Plant Directive standard for gas turbines. PEH will require the manufacturer to guarantee these NOx emissions levels.

The emissions of NOx will be balanced to keep those of CO less than 100 mg/Nm3.

Combustion in gas turbines is conducted at high excess air rates, typically 200-300 per cent. There are, therefore, very low levels of unburned carbon (ie particulate matter) or unburned hydrocarbons present in the products of combustion. The emission of particulate matter will be less than 15 mg/Nm3.

The components of significance in the flue gas are NOx, SO2, CO and particulate matter. The contribution to ground level concentrations of these pollutants due to the new plant have been quantitatively assessed using dispersion modelling techniques and have been compared with the background air quality in the area, and with EC legislation and Irish regulations.

During normal operation and under normal meteorological conditions all gaseous discharges from the chimney will be colourless and odourless. At start-up, under certain weather conditions, it may be possible for a faint brown haze to be seen for a few minutes only.

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All environmental controls at the plant and all emissions will comply with the conditions and limits set by the Environmental Protection Agency in the IPPC Permit to operate the plant.

D.3.2 Control of oxides of nitrogen during combustion

The formation of oxides of nitrogen in the combustion of fossil fuels is unavoidable. NO is the principal oxide of nitrogen produced, with a small proportion of NO2. The ratio of NO2 to NO is approximately 1:19.

When NOx was first identified as a harmful pollutant, the exhausts of gas turbines typically contained from 280 to 470 mg/Nm3 NOx. The problem having been identified the manufacturers of gas turbines were able to reduce the levels to about 235 mg/Nm3 by fairly simple changes to air and fuel distribution in the combustors.

Since the NOx formation from atmospheric nitrogen is strongly dependent on the maximum flame temperature and also the time the hot gases remain at this temperature, the thermal NOx component can be reduced by cooling the flames within the combustion zones of the turbines. It is proposed that the flame temperature, and therefore the emissions of NOx, will be controlled by the use of water injection into the turbines.

The concentrations of oxides of nitrogen in the exhaust gases will, therefore, not exceed 120 mg/Nm3 (58.5 ppm).

D.3.3 Conversion of nitric oxide to nitrogen dioxide

NOx emissions from the proposed plant will consist of the gases NO and NO2. It is only NO2 that is of concern in terms of direct health and environmental effects. However NO is a source of NO2 in the atmosphere. The gases are in equilibrium in the air, with NO predominating at the stack exit. As the plume cools, the equilibrium changes, resulting in a predominance of NO2.

NO is oxidized to NO2 mainly by reaction with ozone. Within 5 km of the source less than 20 per cent of the NO will have converted to NO2 under stable conditions. Under unstable conditions with more atmospheric mixing up to 50 per cent of the nitric oxide may have converted to NO2. The rate of conversion of nitric oxide to NO2 increases with rising ozone concentration, wind speed and solar radiation.

For assessing the impacts on air quality of emissions to atmosphere from large combustion sources, such as power stations, it is important that realistic estimates are made of how much nitric oxide would be oxidized to nitrogen dioxide at all receptors considered.

The rate of oxidation of nitric oxide to nitrogen dioxide depends on both the chemical reaction rates and the dispersion of the plume in the atmosphere. The oxidation rate is dependent on a number of factors that include the prevailing concentration of ozone, the wind speed and the atmospheric stability.

Between 1975 and 1985 about 60 sets of measurements were made of the concentrations of nitric oxide and nitrogen dioxide in various power station plumes. These measurements were carried out

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under widely varying weather conditions at altitudes between 200 m and 700 m. From the data collected, an empirical relationship for the percentage oxidation in a power station plume based on downwind distance, season of the year, wind speed and ambient ozone concentration may be described by the following equation (which is sometime referred to as Janssen’s equation):

( )( )x

xANO

NO α−−= exp12

where x is the distance downwind (km) of the emission point and α and A are constants dependent on time of year and derived from the measurements of wind speed and ozone concentrations.

The empirical relationship has been used to estimate the percentage oxidation for each hour during 2005 for downwind distances from the proposed plant. These estimates have been made using hourly average meteorological data from Rosslare and hourly average ozone concentrations from Johnstown Castle, the nearest monitoring site which measures ozone. Table D.4 shows the minimum, maximum and annual average estimates of NO2 in the plume for selected distances downwind of the plume, the figure takes into account the ratio of NO to NO2 in the plume on exit from the stack.

TABLE D.4 ESTIMATES OF THE PERCENTAGE OF NITROGEN DIOXIDE (NO2) IN OXIDES

OF NITROGEN (NOx) 2005

Percentage nitrogen dioxide (NO2) Downwind distance

(km) Lowest one hour average

Highest one hour average Annual average

1 2.4 16.0 7.7

2 4.7 29.0 14.6

3 6.8 39.7 20.8

5 10.8 55.6 31.4

10 19.3 76.1 50.1

Based on the principles outlined above, the average proportion of nitrogen dioxide within 2 km of the stack will be 14.6 per cent. The highest percentage oxidation for any hour during 2005 for impacts that occur within 2 km of the stacks is 29.0 per cent. Conversion rates have been calculated for ground level receptors across the study area and applied to the results of the NOx emissions dispersion modelling data.

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D.4 Atmospheric dispersion modelling

When flue gases are discharged from a chimney they have two sources of momentum. One is related to the velocity of discharge. This is usually designed to be in excess of 15 metres per second as this value has been found to be sufficient to avoid immediate downwash of the plume.

The momentum from the velocity of discharge is soon dissipated.

The second source of momentum is much more significant and is related to the discharge temperature of the flue gases. The flue gases being warmer than the surrounding atmosphere into which they are discharged, have a buoyancy and thus rise. This process continues until the flue gases have cooled to the same temperature as the surrounding air.

Mathematical models calculate the effects of these two sources of momentum and determine the height to which the flue gases will rise. This height plus the height of the chimney gives an effective chimney height.

The mathematical model then determines the dispersion of the flue gases from this effective chimney height. Note that the effective chimney height can be many times greater than the actual chimney height due to the large amount of heat present in the flue gases.

Dispersion occurs as a result of turbulence, and turbulence can result from both buoyancy effects and wind shear (also called mechanical) effects.

As an example of buoyancy effects, on a sunny day, solar heating creates turbulence by heating the ground and the air near the ground. The buoyancy of the heated bubbles of air causes it to rise, creating turbulence. These are the thermals experienced by small plane and glider pilots on sunny days. These can also rapidly disperse a plume in the surrounding air. At night, during stable conditions, the buoyancy effect is to suppress rather than cause or enhance turbulence.

Wind shear as a cause of turbulence is well known to pilots as well. Wind shear effects, important to air pollution modelling, result from high (several meters per second) wind speeds near the ground. Since the wind speed at the ground is zero, any high wind speeds result in substantial wind shear. Wind shear dominates over buoyancy effects not only under high wind conditions, but also near the ground under any conditions.

As a result of this, two parameters are used to define the “stability” of the atmosphere. The first is the friction velocity. This is a measure of wind shear. Shear stress per unit mass has the units of velocity squared. The square root of this is the friction velocity.

The second parameter is a stability term called the Monin-Obukhov length. As mentioned above, shear stress always dominates near the ground. The height above the ground, where buoyancy effects begin to dominate (generating turbulence in convective conditions or suppressing turbulence in stable conditions) is called the Monin-Obukhov length. This can be thought of as a depth of the neutral (i.e. shear-dominated) flow. The Monin-Obukhov length is positive for stable conditions, and negative for convective. Near-neutral conditions are characterized by very large negative, or very large, positive Monin-Obukhov lengths. Very stable conditions have Monin-Obukhov length of a few

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metres to a few tens of metres, while very unstable conditions have negative lengths of about the same size.

The dispersion model and inputs

All dispersion modelling was undertaken using AERMOD 4.0.13 which is a second generation modelling program developed in the US.

The AERMOD model calculates time averaged ground level concentrations over any set of distances from the source. To predict the ground level concentrations associated with the peaking station, the study used a 20 km by 20 km Cartesian grid, with 1000 m spacing. For higher definition closer to the site, a 2 km by 2 km grid, with 100 m spacing, was also used. scenarios identified. Both grids were centred on NGR T 22834 75113).

The meteorological data used for this modelling exercise was that from the station at Rosslare (station number 03957). The data periods considered were the years 2002-2006 inclusive. This meteorological data was chosen as the most recent available data in the vicinity of the proposed site. For each year the predominant wind direction was from the south west. The wind rose for 2005 can be seen in Figure D.1.

FIGURE D.1 WIND ROSE, ROSSLARE 2005

Terrain effects generally occur when ground levels within 1 km of the stack vary by more than a third of the stack height. The proposed site is situated at the base of a valley, approximately 1.5 m AOD. As such, within 1 km the land rises sharply, to around 60 m AOD to the north and 30 m AOD to the south. For the entire 20 km by 20 km study area, the terrain ranges from 0 m to approximately 550 m AOD. The modelling, therefore, included local terrain data.

Building downwash is a wake effect that local structures can impose on the plume. The effect is generally to pull the plume down to the ground closer to the stack and not allow the plume to disperse

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as effectively, thus increasing ground level concentrations. Potential downwash structures are those which are located within 5L of the stack where L is the height or the maximum projected width of the building, whichever is lower. If a stack is higher than the height of the building plus 1.5L then the building is not a downwash structure.

Table D.5 gives the data on buildings inputted into the model.

TABLE D.5 DISPERSION MODELLING DATA

BUILDINGS SURROUNDING

Height Diameter

DFO Tank 16.5 23

Demineralized Water Tank 16 23

Raw Water Tank 7.6 15

Turbine Exhaust Stack (10) 22 2.4

D.4.1 Modelling Scenario

The proposed power station will be used to respond to requests from EirGrid plc to assist in meeting the, temporary, peak generating demands of the grid and help maintain the electrical stability of the supply in terms of voltage control and frequency regulation. The normal operation of the proposed power station will therefore include of the order of 300-500 hours operation per year. The atmospheric dispersion modelling, however, was performed assuming full load operation for 8760 hours per year in order to consider all possible operating and atmospheric conditions. This method ensures that the modelling results represent an exceptionally worst case scenario.

The fuel for the power station will be low sulphur DFO. The DFO has a sulphur content of less than 0.1 per cent in accordance with the European Community (EC) Directive 1999/32/EC and ensures that emission levels of sulphur dioxide (SO2) are insignificant.

In addition, the turbines will be fitted with proven pollution control technology that limits the production of nitrous oxides (NOx) to a maximum of 120 mg/Nm3. Water injection into the turbines represents the Best Available Technique (BAT) for limiting emissions of NOx to atmosphere from oil-fired gas turbines. The emissions of NOx will, therefore, be within the limits set out in the EC Large Combustion Plant Directive (LCPD).

The dispersion modelling inputs, per gas turbine, are as shown in Table D.6.

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TABLE D.6 DISPERSION MODEL INPUTS PER STACK

Parameter Units DFO Firing

Fuel input kg/s 1.87

NOx emission level mg/Nm3 120

NOx flow rate g/s 8.5

SO2 emission level mg/Nm3 56

SO2 emission rate g/s 4.0

Particulate emission level mg/Nm3 15

Particulate emission rate g/s 1.1

Flue gas temperature K 706

Actual flue gas volume m3/s 197.0

Normal flue gas flow rate Nm3/s 71.1

Oxygen content % 14.0

Moisture content % 6.7

Flue gas velocity m/s 42.8

Equivalent stack diameter m 2.4

Stack height m 22 The location of the stacks are, at this stage, provisional. For modelling purposes they are assumed to be at the following Irish National Grid References (NGR):

• T 22843 75075

• T 22835 75059

• T 22866 75064

• T 22859 75048

• T 22890 75053

• T 22882 75037

• T 22913 75041

• T 22905 75025

• T 22936 75030

• T 22929 75014.

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The centre of the study area is located at NGR T 22834 75113.

In order to assess ground level concentrations of the various pollutant gases emitted by the plant, the AERMOD model was used to calculate the following:

• NO2 - 19th Highest Hourly concentration

• NO2 - Annual Average concentration

• NOx - Annual Average concentration

• SO2 - 25th Highest Hourly concentration

• SO2 - 4th Highest Daily concentration

• SO2 - Annual Average concentration

• Particulates - 8th Highest Daily concentration

• Particulates - Annual Average concentration

• Carbon Monoxide (CO) Maximum Daily 8 Hour Average concentration.

D.4.2 Modelling results

A conservative view of the operation of the plant has been adopted in the modelling so that a “worst case” is presented. The purpose of using this approach is to ensure that the absolute maximum predicted impact within the potential operating regime of the plant is considered. This ensures that there is a “factor of safety” built into all of the air quality assessment, giving a high degree of confidence that the actual impacts will be less than those presented in this assessment.

Table D.7 and Table D.8 presents the worst case ground level concentrations predicted by the dispersion modelling for the pollutants considered for the new power station. The tables also shows the relevant Air Quality Standards Regulations 2002 objectives and reports the location and direction of the maximum predicted. The table indicates the meteorological data year for which the maximum was observed.

TABLE D.7 ANNUAL AVERAGE GROUND LEVEL CONCENTRATIONS

(μg/m3)

Pollutant Increment to ground level concentrations Guideline Distance

(km) Direction (degrees) Year

NO2 1.4 40 4.2 45 2006

NOx 13.8 30 0.4 56 2002

SO2 6.5 20 0.4 56 2002

Particulates 1.7 20 0.4 56 2002

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TABLE D.8 SHORT TERM GROUND LEVEL CONCENTRATIONS

(μg/m3)


Increment to ground level concentrations Guideline Distance

(km) Direction

(º) Year

NO2 19th highest

hourly average 172.6 200 6.1 279 2005

25th highest hourly average 122.2 350 6.1 279 2005


average 48.0 125 0.4 34 2006

Particulates 8th highest daily average 9.2 50 0.4 45 2002

The maximum 8 hour average increment to carbon monoxide concentrations is 314.8 µg/m3, and occurs in 2005.

Five isopleths, Figures D.2 through D.6, have been prepared to illustrate, across the study area, the following sets of results relating to the objective of the protection of human health:

• increments to annual average NO2 concentrations;

• 19th highest hourly increments to NO2 concentrations; and

• 25th highest hourly increments to SO2 concentrations.

• 4th highest daily increments to SO2 concentrations.

• 8th highest daily increments to particulates concentrations.

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The predicted short term increases in concentrations of NO2 and SO2 occur at a point approximately 6.1 km west of the proposed site south east of Ballycoog, at the base of Croghan Mountain.

The location of maximum annual increments is significantly influenced by the local terrain and indicative of the prevailing meteorological conditions, ie predominantly south-westerly winds. In practice, the predicted small increments to annual average levels due to the proposed power plant would be virtually undetectable using diffusion tubes or other monitoring equipment in use today.

Increases to the short term concentrations are highest on the sides of the hills within the study area

D.4.3 Analysis of results

The results of the modelling have been compared to appropriate objectives. Key findings from the analysis are:

• the predicted maximum increase in long term NO2 concentration, due to the proposed SCGT plant, is 1.4 μg/m3;

• the predicted maximum increase in short term NO2 concentrations, at any receptor, is 172.6 μg/m3;

• the predicted maximum increase in long term SO2 concentration is 6.5 μg/m3;

• the predicted maximum increase in short term SO2 concentrations, at any receptor, is 122.2 μg/m3;

• the emissions of the plant in isolation will cause no exceedances of the limits prescribed by the Air Quality Standards Regulations 2002.

The Air Quality Standards Regulations 2002 outline acceptable concentration limits for a range of pollutants. The increments, due to the emissions from the proposed power station, have been compared with the background concentrations, as per figures published by the EPA.

The key pollutants produced by the new plant will be NO2 and SO2. The concentrations of these gases and the ambient air concentrations, are shown in Table D.9 for comparison with the regulatory limits.

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TABLE D.9 KEY POLLUTANT BACKGROUND CONCENTRATIONS

(μg/m3)





NO2 1 year 1.4 5.67 40



average 48.0 8.00 125

The increments quoted represent the predicted maximum emission levels of the proposed power station, and represent a very much worst case scenario as the average 19th highest hourly concentration of NO2 is approximately 13.7 μg/m3 for 2005. The average for SO2 is 18.1 μg/m3.

The plant will also give rise to emissions of carbon monoxide (CO) and particulate matter.

TABLE D.10 ADDITIONAL POLLUTANT BACKGROUND CONCENTRATIONS

(μg/m3)




CO 8 hour running average 314.8 1500 10 000

8th highest daily average 9.2 58.8 50

Particulates 1 year 1.7 17.6 20

As shown in Table D.10, the CO addition to the ambient concentrations will be extremely low in comparison with the limit stated in the guidelines, causing no breach of the regulations.

Background concentration of particulate matter, however, is high with respect to the guidelines likely as a result of traffic in the vicinity of the monitors. The daily average itself is already in exceedance of the limit value of 50 μg/m3. The maximum increase expected due to the power station is only around 0.5 per cent of the existing environment and is, therefore, not considered a significant increase.

The annual figures for particulate emissions are within the regulatory limit.

Protection of vegetation and ecosystems

The predicted maximum values for NOx and SO2 do not cause any exceedence of the limit values for the protection of vegetation and ecosystems, as shown in Table D.11.

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TABLE D.11 KEY POLLUTANT BACKGROUND CONCENTRATIONS

(μg/m3)

Pollutant Averaging period



NOx 1 year 13.8 8.33 30

SO2 1 year 6.5 2.67 20

Worst case scenario

The atmospheric dispersion modelling was performed assuming full load operation for 8760 hours per year in order to consider all possible operating and atmospheric conditions. In reality the limited, peaking, operation of the plant (typically 300 – 500 hours per year) would result in an impact lower than presented above. The further assumption of the analysis is that SCGT operation coincides directly with the meteorological conditions giving rise to the maximum predicted impact.

It should be noted that the ground level concentrations of pollutants from the proposed plant should not, necessarily, be simply added to those for the existing sources in the area since, in many instances, the location and prevailing weather conditions of the two maxima will be different.

For short term averaging periods it is unlikely that there will be such a coincidence of contributions from several sources. This is due to the weather conditions associated with the maximum from each type of source. Plumes from point sources, such as power station plumes, generally provide a maximum increment to ground level concentrations when the weather conditions are warm and/or windy. Conversely, the maxima associated with line sources, such as roads, occur when it is calm, cold and there is a low level inversion. During these times the thermally buoyant plume from a point source will burst through the inversion layer and disperse over a larger area. The inversion layer will severely limit the ability of the plume to ground, the maximum short term concentrations from each source type will not coincide and there will not be a summation of the effects.

Therefore it is not reasonable, and represents a very worst case, to sum the maximum contribution to ground level concentrations due to the proposed plant in isolation with the existing monitored background level for short term concentrations. In spite of this, the results of the modelling indicate that the predicted emissions will only cause an exceedance of the Air Quality Standards Regulations 2002 in relation to short term NO2 emissions.

The modelling of NOx emissions from the proposed plant has also applied further worst case conditions as the analysis considered the plant operating at the 120 mg/Nm3 limit as set out in the LCPD. Normal operation of the plant would result in emissions of NOx being significantly less that this limit and in turn reduce the increments to ground level concentrations of NO2.

With regard to the occurrence of long term maxima from the various types of sources the likelihood of them coinciding is high. This is due to the long averaging periods and the variation in meteorological conditions over the averaging period.

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D.5 Mitigation measures and monitoring programmes

Construction

Good site management practices during the construction works will help to prevent the generation of airborne dust. PEH will require its construction contractors to take sufficient precautionary measures to limit dust generation.

To ensure that atmospheric dust, contaminants or dust deposits generated by the construction do not exceed levels which could constitute a health hazard or nuisance to those persons working on the site, or living nearby, a dust monitoring programme will be carried out throughout the construction period. It is proposed that environmental monitoring of dust be carried out at areas of excavation, the stockpiles, various additional locations across the site and at locations on the site boundary. A trained and competent person will carry out the monitoring, on a weekly basis. If dry windy weather prevails then the rate of monitoring will be increased. An aerosol monitoring system will be used. The results will be checked against Table D.12.

TABLE D.12 MAXIMUM ALLOWABLE EXPOSURE LEVELS

Dust Monitoring location Level Action

Aerosol monitoring system (directional, with instantaneous read-out)

Excavation areasStockpiles

>1 and <5 mg/m3 Review PPE* level if >1 mg/m3

Environmental Dust Sampler (gravimetric over fixed time period)

>5 mg/m3 continuously

Stop work in breathing zone Identify cause and carry out remedial work Review PPE level, go to level 2 respiratory protection Monitor every 30 minutes

Site perimeter 0.2 mg/m3 Stop work Identify cause and carry out remedial work

Visual and odour checks

Site wide Excessive dust or odour

Further monitoring or control measures as appropriate. All such instances to be logged

*PPE - Personal protection equipment.

If the above values are exceeded then the rate of monitoring will be increased to four times a day or to a level consistent with the results that have been logged and additional remedial action as described below will be taken.

If a potential for dust emissions exists, for example on dry windy days, then the following procedure will be followed:

• materials will be tested for moisture content;

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• if material is dry then water will be sprayed on to the working area to suppress dust;

• excavation faces not being worked will, if required, be either sheeted or treated with a chemical dust suppressant;

• in addition all operatives working in areas of potential dust emission will be provided with paper type face masks.

Materials deposited on stockpiles on site will be closely monitored for any possible emission of dust and if required they will be damped down, covered or treated with a dust suppressant.

If finely ground materials are delivered, these should be in bag form or stockpiled in specified locations where the material can be suitably covered.

All vehicles carrying bulk materials into or out of the site will be covered to prevent dust emission. Minimum drop heights will be used during material transfer.

Dust emission from moving construction plant and site transport will be mitigated by the use of water bowsers, which will dampen all movement areas being utilized by traffic.

If necessary, a wheel washing facility will be provided adjacent to the site exit and will be used by all heavy commercial vehicles leaving the site, preventing the transmission of soil from the site to the public highway.

Also a road sweeping vehicle will be employed when required during the construction period to remove dust and dirt from all the public roads.

The above measures may only be necessary should the activities leading to the greatest dust generation occur during a dry period.

If care is taken dust emissions will not impact on local air quality.

D.5.1 Operation

The following mitigating measures have been included in the design of the proposed plant:

• the use of water injection, which ensures NOx levels to be in accordance with LCPD requirements;

• the use of a fuel inherently low in sulphur;

• the flue gases will be of sufficient temperature and velocity to ensure good dispersion.

These measures, in combination, result in acceptable increases in background concentrations of oxides of nitrogen, limited emissions of sulphur dioxide and negligible emissions of particulates, such that no further measures are deemed necessary.

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Emissions will be controlled during operation in accordance with the gas turbine manufacturer’s recommendations and the limits and conditions specified in the IPPC permit for the process, taking account of the technical guidance available for this type of plant.

PEH will require a manufacturer’s guarantee in place to guarantee the performance of the NOx abatement system. If NOx values are outside the guarantee value, the operation and calibration of the instrument will be checked and, if proved to be accurate, the plant will be examined and the fault corrected.

The stack will be fitted with a continuous NOx and CO monitor. The measured value will be recorded and displayed locally and in the central control room at Huntstown power station. Routine calibration checks will be carried out as recommended by the manufacturer and as agreed with the EPA. PEH will also perform any other ad-hoc calibration checks required by the EPA. An oxygen monitor will also be supplied and results from this will be used to correct the NOx measured value to the format required by the EPA. Either a moisture meter will be provided or a mathematical correction factor based on combustion of DFO will be used to convert to the dry condition. The results from this stack monitoring will be available to the public via the EPA.

Sampling points and safe access adjacent to the continuous monitoring points will be installed, if required.

D.6 Conclusion

The construction impacts would potentially comprise emissions of dust and emissions during commissioning. Due to the distance from the proposed site to the nearest house dust impacts will not be noticeable. Emissions during commissioning will be of short duration and low mass; the impact will therefore not be significant.

The maximum long term concentration of NO2, due to the emissions from the new plant, is 3.5 per cent of the long term objective of 40 μg/m3. All other regulated pollutants are, similarly, well within the prescribed long term objectives. No exceedence of these standards will be caused by the operation of the plant.

The impact of the atmospheric emissions from the proposed SCGT power station will be well within the Air Quality Standards Regulations 2002, either in isolation or when considered in conjunction with the background concentrations. As such, the impact of the new plant is considered to be insignificant.

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PB Power Appendix E

63110/PBP/000004 Rev A 0618R000.doc/S25/2/RT

APPENDIX E ENVIRONMENTAL IMPACT ASSESSMENT

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PB Power Appendix F

63110/PBP/000004 Rev A 0618R000.doc/S25/1/RT

APPENDIX F PROPOSED AMENDMENT TO EXISTING LICENCE

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PB Power Appendix G

63110/PBP/000004 Rev A 0618R000.doc/S25/1/RT

APPENDIX G PLANNING AUTHORITY NOTIFICATION

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PB Power Appendix H

63110/PBP/000004 Rev A 0618R000.doc/S25/1/RT

APPENDIX H REPORTS AND ACCOUNTS

(112 pages)

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POWER & ENERGY HOLDINGS (ROI) LTD · 2013. 7. 26. · N nitrogen NGR National Grid Reference NO...

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