attachment no. f.1.1 emissions to atmosphere · 2013. 7. 26. · the cpi oil will be discharged to...

ATTACHMENT No. F.1.1 Emissions to Atmosphere

Contents Attachment F.1.1.1 Pictorial of Location of WHRs Attachment F.1.1.2 Schematic of SCRs

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Pictorial of Location of WHRs

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Fuel

9 Gas Engine A

Air

Gas Engine B

Air

Exhaust ducting l j

Oxidation NOx and CO Catalyst measurement

.V-. "---V ......V.- ... ....-.......W-.-.. . ,..... . .......,,.W ,,....

Air rea day Exhaust ducting Jmk .- .. ...................................... ............. .. - I

l 1 SCR Mixing Oxidation device catalyst Catalyst measurement

Atmosphere

Air

Exhaust ducting - ....... --..-I "-I" "" ............... " -..,,*.---.-.--.-"---" "

Mixing SCR Oxidation device catalyst Catalyst measurement

.- . .... i

Road Tanker W'U Bulk Storage

Schematic of SCRs

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ATTACHMENT No. F.1.2

Treatment/Abatement of Produced Water

Attachment F.1.2.1 Overview of Produced Water Treatment System

Attachment F.1.2.2 Unit Operations of Produced Water Treatment System and

Sludge Handling Attachment F.1.2.3 Simplified Process Flow Diagram of Produced Water Treatment

System (PFD 9) Attachment F.1.2.4 Produced Water Treatment Unit Schematic (Dwg: IPPCL 028)

Waste Water Treatment Sludge Handling Schematic (Dwg: IPPCL 030)

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F.1.2.1 Overview of Produced Water Treatment System The Produced Water Treatment System has a design capacity of 6 m3/hr. The treatment system has been designed to reduce the maximum concentrations of metals, salts and other parameters likely to occur in the produced water to a level (prior to discharge to sea). The control system for the treatment system will include critical process alarm and plant status outputs to the Terminal control system. A number of the unit operations on site (refer to Section D of the IPPC Application Form for a description of each unit operation) will aid in the removal of contaminants from the produced water. Gross oil removal will occur in the slugcatcher, the methanol flash drum, the raw methanol storage tanks and the methanol coalescer. The methanol still can be considered the first stage in the treatment of the produced water. The methanol still will significantly reduce the methanol content, the oil and grease content, and possibly the dosing chemicals (e.g. corrosion inhibitor) in the produced water. The methanol concentration in the produced water will be reduced to less than 50 ppmwt methanol. Methanol MonitoringFeed streams to and from the WWTP can contain methanol and appropriate samples and analyses are carried out. Samples will be taken each day from the Methanol Still outlet and will support trending of performance over the medium to long term. This frequency is appropriate for detection and management of slow moving events caused by changes in reservoir fluids. The principal parameters for minimisation of methanol in produced water are the Methanol Still pressure/ temperature. The Corrib design pays close attention to the control of the Methanol Still (especially bottoms conditions) to minimise methanol losses to the produced water treatment plant feed. It has been identified that there is no reliable on-line measurement device for direct measurement of methanol in Corrib produced water. Instead, the presence of methanol is inferred from an on-line Total Organic Carbon (TOC) analyser on the treated outlet from the produced water treatment plant. “Buffer” capacity is provided in the produced water treatment process and its associated sumps to allow sufficient time for response to, and containment of, methanol excursions. The produced water exiting from the methanol still will be pumped to the Effluent Feed Sump (66 m3 capacity) and from there will be pumped to the Produced Water Treatment System. If the water in the Effluent Feed Sump is found to contain a high concentration of methanol (>150 mg/l) it will be pumped to the raw methanol storage tanks, otherwise it will be pumped to the Produced Water Treatment System. The Produced Water Treatment System will comprise the following treatment units: • Corrugated Plate Interceptor (CPI) • Ultrafiltration (UF) • Nano Filtration (NF) • Granular Activated Carbon (GAC) • Ion-Exchange • pH adjustment

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The Corrugated Plate Interceptor (CPI) will remove suspended solids and free oil. The Ultra filtration (UF) unit will remove emulsified oil and certain organics. The Nano filtration (NF) unit will remove the majority of heavy metals. The permeate (semi-treated water) from the NF unit will be passed through an activated carbon filter to remove soluble organics. Any residual heavy metals (mercury, nickel, lead, zinc) will then be absorbed onto a selective ion exchange resin. The treated water will be pH adjusted as required (NaOH/ HCl dosing) before discharging to the Treated Produced Water Sump. Further information is given in Section F1.2.3 The Treated Produced Water Sump will have a capacity of 144 m3. Continuous monitoring of flow, pH, and conductivity along with regular sampling and analyses of other parameters in the treated produced water stream will be provided. If the quality of treated effluent in the sump does not meet the required discharge standard it will be pumped to the raw methanol storage tanks for recycling through the Produced Water Treatment System. If the quality of the water in the sump meets the required discharge standard it will be pumped to the Produced Water Discharge Sump (105 m3 capacity). From here it will be pumped transferred to the Umbilical Cores for final discharge. Any surplus water will be disposed of off-site by road tanker.

The following measures will be incorporated into the new arrangements to ensure satisfactory operation:

• Biocide Addition: It will be necessary to incorporate Biocide dosing into the treated produced water discharge to prevent fouling and corrosion in the Umbilical cores. Further information on alternatives considered for biological growth control is given in F1.2.4.

• A new transfer line will be installed on site to transfer the treated produced water from the Treated Produced Water Sump (T-8302B) to the Onshore Terminal Termination Unit (OTTU) and Umbilical Cores. An additional pump will be installed to pump treated produced water to the OTTU.

• A 75mm flexible hose will be employed to transfer surplus treated produced water to the road tanker utilizing the current treated Produced Water Discharge Pump (P-8302B)

• Two additional pumps will be required at the OTTU to pump treated produced water through the Umbilical Cores for discharge at the manifold.

The Produced Water Treatment System will produce a number of waste streams, namely:

• oil and sludge from the Corrugated Plate Interceptor (CPI)

• concentrate and cleaning waste from the Ultrafiltration Package (cleaning using CIP chemicals)

• concentrate and cleaning waste from the Nanofiltration Package (cleaning using CIP chemicals, antiscalent and acid dosing)

• backwash from the activated carbon filtration unit

• discharge from ion exchange regeneration (regeneration using 30% Sodium Hydroxide and 30% HCl)

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The CPI oil will be discharged to the Oil Sump (5 m3 capacity) and from there pumped to the condensate stabilisation process. All of the other waste streams, together with the sludge from the Surface Water Treatment System CPI will be discharged to the Balance Water Sump (30m3 capacity) which will be fitted with an agitator. The waste stream will be pumped from the Balance Water Sump to the Reaction / Flocculation Tank where it will be subject to the following treatment stages:

• First stage precipitation by pH adjustment using lime slurry.

• Second stage precipitation by pH adjustment and TMT-15 dosing.

• Coagulation by Ferric Chloride dosing.

• Flocculation by polyelectrolyte dosing.

The resultant waste stream will then be pumped to a filter press for dewatering to produce a filter cake suitable for disposal. This cake will be discharged to a skip and treated / disposed off-site by a licensed waste contractor. The filtrate from the filter press will be pumped to the Effluent Feed Sump for recycling through the Produced Water Treatment System.

As part of the Produced Water Treatment System will be required to be kept frost-free, a suitably designed building will house the membrane units and the sludge treatment facilities to ensure satisfactory performance.

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F.1.2.2 Unit Operations of Produced Water Treatment System and Sludge Handling

The following additional information was provided as part of a Request for further information in support of the original IPPC application. This information provides more detail on the individual processes within the treatment processes. Refer to Produced Water Treatment Unit schematic L3882-020-110-0136. Produced Water Treatment Process Philosophy The produced water contains trace quantities of heavy metals and organic compounds, which must be reduced to very low levels before discharge. The produced water treatment plant uses a sequential 3 step process to remove free liquid hydrocarbons, to remove metal ions, and to remove soluble hydrocarbons. Load on the systems for removal of metal ions and soluble hydrocarbon is considerably reduced by the use of nano-filtration (NF). The NF membranes provide gross removal of heavy metals and organic molecules prior to the downstream processes. After the NF pretreatment stage absorption processes provide a permeate “polishing” stage to ensure the final water quality meets design intent. The nano-filtration membranes are susceptible to fouling from suspended solids, oil and scaling by precipitation. Acid dosing and anti-scalant addition have been included to limit scaling. Ultra-filtration membranes are provided upstream of NF to remove free oil and reduce suspended solids to below limits of detection. These ‘pre-treatments’ allow the nano-filtration plant to operate economically and without excessive fouling and cleaning, which would be detrimental to the membrane life. As with the surface water plant, a Tilted Plate Separator (TPS) is used up-stream of the ultra-filtration plant to remove the bulk of the suspended solids and free oil.

Produced Water Treatment: Process Description The Produced Water Plant is designed for a net capacity of approx 6 m3/h. Produced water and filtrate from the filter press is collected in the Effluent Feed Sump and pumped to the produced water TPS. Produced Water Treatment: Tilted Plate Separator Description The produced water feed flows downwards through the plates, and denser particulates settle to the bottom. The solids are allowed to accumulate before being periodically discharged. Sludge is discharged directly to the balance water sump. Oil coalesces on the plates and rises to the surface, where it continuously overflows a skimmer and flows under gravity to the oil collection tank before being pumped to the oil sump. The feed effluent, having passed through the plate pack, rises into the main body of the TPS and overflows a weir into the clarified produced water tank. Produced Water Treatment: Ultra-Filtration Description The ‘clarified’ produced water is pumped by the UF feed pumps through a cartridge filter to the produced water ultra-filtration plant. The produced water UF comprises two stages of two pressure vessels in series. The produced water UF operation is as per the surface water UF, but each stage utilises two pressure vessels instead of four due to the lower feed flow rate. The UF permeate from both stages is combined and passed through a NF pre-filter and into the UF Permeate Inter-stage Tank. The UF permeate is dosed with anti-scalant to help minimise the scaling potential of the

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dissolved salts in the process stream, before being pumped at up to 40 bar into the nanofiltration (NF) plant. Produced Water Treatment: Nano-Filtration Description The Nano-filtration (NF) membranes remove a high percentage of the heavy metals and organics from the produced water, but allow passage of the monovalent sodium and chloride ions. The NF plant comprises 3 stages (a 6:3:2 array) of pressure vessels in series, each containing multiple nano-filtration membranes. Produced water enters the first stage pressure vessels in parallel, permeate and concentrate exit from the tail end of the vessels. Permeate flows to the common permeate header, the concentrate from the six pressure vessels is recombined and fed forward to the feed of the second stage. This process is repeated for the second and third stages, the concentrate from the third stage is high in dissolved solids and is bled from the system and discharged to the balance sump. The NF permeate is collected in the NF Permeate Tank. The NF membranes are subject to fouling by the deposition and precipitation of components in the produced water. The NF plant is designed to be taken off line periodically for a ‘Clean In Place’ (CIP), to remove accumulated foulants from the membrane. Produced Water Treatment: Activated Carbon Adsorption Pumps transfer the NF permeate to an activated carbon filter. The permeate enters the top of the bed and passes down through the activated carbon. Higher molecular weight trace organics are absorbed. The activated carbon bed is backwashed at periodic intervals to ensure that it does not become compacted, however this does not serve as a regenerative process, and the carbon must be replaced (either disposed of or sent for regeneration) when saturated. The carbon is backwashed with service water from the service water storage tank using the carbon filter backwash/ ion exchange regeneration pumps. The activated carbon treated produced water feeds directly into the top of the ion exchange unit and passes through the resin bed. The resin absorbs heavy metals from the produced water and the treated water exits from the bottom of the column. Produced Water Treatment: Selective Ion Exchange The ion exchange absorption capacity decreases as the heavy metals are absorbed by the resin, and after a set volume of water has passed through the resin, the ion exchange is taken off line for regeneration. Service water is pumped upwards through the resin bed to lift the bed and remove any fines, followed by regeneration with hydrochloric acid solution and conditioning with sodium hydroxide. The heavy metal laden, regeneration waste water flows to the balance sump. The ion exchange treated water is pH corrected with sodium hydroxide before progressing to the treated produced water sump. MEMBRANE CLEAN IN PLACE (CIP) The membranes are flushed, cleaned and rinsed using the CIP package. Initially, the cleaning pump is used to pump hot water (40-50°C) from the hot water tank, via the CIP cleaning tank, through the selected membrane plant, and out of the respective permeate and concentrate drain lines to the balance sump. This purges the system of its contents and begins to heat the membranes and pipe-work. Hot water (40-50°C) or a solution of cleaning chemicals in hot water is then made up in the CIP cleaning tank, and the cleaning pump is used to recycle this cleaning solution through the selected membrane plant, and back into the CIP cleaning tank. In the case of the UF

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plants,the recirculation pumps are run simultaneously. After a set time, the cleaning solution is discharged to waste for off-site disposal, and the plant is rinsed using service water, through the CIP cleaning tank and the cleaning pump. SLUDGE TREATMENT PLANT (Refer to Waste Water Treatment Sludge Handling Unit Schematic L3882-020-110-0138) Apart from the multi media backwash water, all the waste streams from both the produced water and surface water treatment plants enter the balance water sump. The treatment of the multi media backwash water is described in the Surface Water Treatment Process Description. Waste is pumped from the balance water sump to a three stage flocculation tank by the flocculation tank feed pumps. When not feeding forward, these pumps re-circulate the contents of the balance water sump to help maintain solids in suspension. The first stage of the flocculation tank is dosed with lime slurry, to elevate the pH and precipitate heavy metals. TMT15 is dosed to assist the precipitation of mercury. Ferric chloride is then dosed to aid coagulation of the finer colloids and precipitants, followed by polyelectrolyte to help bind the agglomerates into flocs. The flocculation tank suspension is pumped to a filter. The suspended solids are retained in the filter press, whilst the liquid passes through the cloths and into the filtrate storage tank. The filtrate is pumped back to the effluent feed sump. The suspended solids are compacted between the filter plates as the feed pressure increases, and the feed flow subsequently decreases. Once full, the press plates are opened and the cake is disposed of off-site. PERFORMANCE CONTROLS As with any liquid processing system residence time in the Produced Water and Surface Water Treatment Facilities is limited. Treatment is progressive through each of the treatment steps, with each unit operation making a contribution to the objective of meeting the ELV’s/ equivalent EQS discharge limits. Some treatment units improve several parameters. Discharge limits are very stringent. It is likely that intermediate samples taken from within the treatment process will not be representative over time, and analysis against ELV’s will be unfeasible due to interference from competing species. In addition, certain performance parameters are not measurable online and require laboratory analysis, sometimes off-site at suitably equipped and qualified 3rd party facility. Consequently, the operational strategy emphasises continual measurement of parameters which are considered a reliable indicator of changes in performance relative to the treatment objectives. Conductivity and pH have been selected as the most reliable online indicators of treatment quality in respect of IPPC licence ELVs. Online measurement of turbidity and TOC will be used for process surveillance. In addition, laboratory measurements of COD will be used as an indicator of efficiency of hydrocarbon removal and will provide confidence between periodic measurements of suspended solids, dissolved solids and oil in water. Off-line test frequencies will be set to give confidence that sample results are representative of time averaged performance and will demonstrate that compliance criteria are satisfied. Additional samples will be triggered by online deviations in pH or conductivity or deviations in COD.

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WATER TREATMENT PERFORMANCE OBJECTIVES Tilted Plate Separator: Removal of free oil and suspended solids. Flow regulated at inlet to keep water treatment facilities throughput within design operating envelope. Automated pump out of oil and solids Filters: Removal of filterable solids to protect membranes Fouling indicated by rising pressure drop. Operator surveillance to trigger filter change when pressure drop threshold is reached. Ultra/Nano-Filtration: Oil, Solid, Heavy Metals and Hydrocarbon Removal Principal controls of performance include automatic pH control and operator surveillance to trigger CIP when cross membrane pressure drop increases. The unit will be set up during commissioning and will be periodically checked as part of the preventative maintenance regime. Granular Activated Carbon: Polishing step for organic molecules. Sample points will be engineered to ensure the onset of bed saturation is detected with sufficient warning to complete bed replacement prior to breakthrough at the outlet. Selective Ion Exchange: Removal of heavy metal ions Cycle time is influenced by flow and ion concentrations in the feed. The interval between regeneration will be set during commissioning and will be adjusted based on periodic laboratory samples as the ion exchange resin ages. Resin will be replaced on a time-based strategy with the initial change out frequency determined during commissioning in conjunction with the vendor. Precipitation, Flocculation & Sludge Treatment: Contaminant removal as filter cake Precipitation and Flocculation will be set up during commissioning. Surveillance of chemical dose rates (incl. Lime) will be a fundamental part of operational surveillance. Chemical dose will be optimised through periodic laboratory jar tests. The sludge process will be set up to maximise cake dryness. Periodic surveillance will be used to maintain system performance.

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PRODUCED WATER FROM METHANOL STILL

Effluent Feed Sump

Corrugated Plate Interceptor

Treated Produced Water Sump

Treated WaterSump (T8302B)

Oil Sump and Off-Spec Condensate Tank

Oil

BalanceWater Sump

Reaction/ Flocculation

Tank

Filter Press Package

Filter Cake

Surface Water Treatment

Sludge

PFD 9 - Produced Water Treatment System

UltrafiltrationPackage

NanofiltrationPackage

Ion-Exchange

Activated Carbon Filtration

Offspec Produced WaterRaw Methanol Storage Tanks

Sludge

Cleaning /Regeneration

Waste

LimeFerric ChlorideTMT 15Polyelectrolyte

Chemical Addition

To discharge at Well Head Manifold via Umbilical Cores – SW3

Filtrate

Filter Cake Skip and Waste Disposal

Filtrate

Raw Methanol StorageTanksOff-spec Treated

Produced Water

pH adjustment(NaOH / HCl)

BiocideAddition

Surplus exported off site by Tanker

Monitoring & Analysis

Monitoring & Analysis

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Treatment/Abatement of Surface Water

Surface Water Treatment Attachment F.1.3.1 Overview of Surface Water Treatment System Attachment F.1.3.2 Unit Operations of Surface Water Treatment System Attachment F.1.3.3 Simplified Process Flow Diagram of Surface Water

Treatment System (PFD 10) Attachment F.1.3.4 Surface Water Treatment Unit Schematic (Dwg: IPPCL-029)

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F.1.3.1 Overview of Surface Water Treatment System (Oily Water System)

Surface water runoff from paved process areas (referred to as “Oily Water”) will be routed to an open drain system and collected in the Open Drains Sump prior to treatment in the Surface Water Treatment System. The Surface Water Treatment System has a design capacity of 30 m3/hr. The treatment system has been designed to treat the surface water (oily water) to a level (prior to discharge to sea) such that there is zero harm to the receiving environment when the treated water is discharged. The control system for the treatment system will include critical process alarm and plant status outputs to the Terminal control system. The Open Drains Sump (1346m3 capacity) consists of two chambers, the first of which contains an Oil Skimmer which will remove floating oil and discharge it by gravity to the Oil Sump. The water then flows out of the first chamber under an oil control baffle into the second larger chamber. The water is then pumped at a controlled rate to the Surface Water Treatment System. The primary treatment stage comprises a Corrugated Plate Interceptor (CPI) to remove the bulk of separable oil and suspended solids from the water. The separated oil is discharged to the Oil Sump and from there pumped to the Offspec Condensate Storage Tank for reprocessing. The separated solids are collected in the Sludge Tank and then pumped to the Balance Water Sump where they are combined with the solids/sludge from the Produced Water Treatment Plant. The treated water drains by gravity to the Clarified Water Tank and from there is pumped to the secondary treatment stage. The secondary treatment stage is designed to reduce the concentration of trace hydrocarbons, suspended solids and oil/condensate and comprises a Multimedia Filter (media is a mixture of anthracite, sand, garnet and gravel) to remove particulate suspended solids followed by an Ultra Filtration (UF) unit to remove residual free and emulsified oil. The Multimedia Filter backwash is recycled to the Open Drains Sump and the UF backwash is recycled to the primary treatment stage. Continuous monitoring of flow, pH, and conductivity along with regular sampling and analyses of other parameters in the treated surface water stream will be provided. If the quality of treated water does not meet the required discharge standard it will be recirculated through the Surface Water Treatment System. If the quality of the water in the Surface Water Discharge Sump meets the required discharge standard it will be discharged to the sea outfall, SW1. The Open Drain Sump incorporates a duty and standby pump for the transfer of contaminated water and firewater to the Used Firewater Pond. Both pumps are independently plumbed and are capable of simultaneous operation. In the event of failure of power generation at the Terminal both pumps are capable of being driven from mains electricity. This is compliant with condition 3.12.5 of the IPPC Licence (P0738-01)

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F.1.3.2 Unit Operations of Surface Water Treatment System The following additional information was provided as part of a Request for further information in support of the original IPPC application. This information provides more detail on the individual processes within the treatment processes. Refer to Surface Water Treatment Unit schematic L3882-020-110-0137. SURFACE WATER TREATMENT SYSTEM The principal parameter driving the selection of treatment processes for the surface water is the discharge target concentration of oil in water, which is specified at 0.3 mg/l. To meet this limit an Ultra-filtration (UF) process utilising oleo-phobic membranes that were specially developed for oil-water separation has been included. The ultra-filtration membranes also provide an effective barrier to suspended solids. The filtered suspended solids and oil particles will accumulate during normal operation within the UF membranes, which will therefore require periodic cleaning. The frequency with which cleaning is required will be minimised by pre-treating the feed water in a Tilted Plate Separator (TPS), followed by a multi-media filtration unit. Surface Water Treatment Process Description Surface water run off and fire-water are collected in the open drain sump and pumped to the surface water Tilted Plate Separator (TPS). The feed flows downwards through the plates, and denser particulates settle to the bottom of the TPS. The solids accumulate before being periodically discharged as sludge. Sludge is collected in a buffer tank before being pumped to a balance sump. Oil coalesces on the plates and rises to the surface, where it continuously overflows a skimmer, and flows under gravity to the oil sump. The surface water, having passed through the plate pack, rises into the main body of the TPS and overflows a weir into the clarified water tank. The ‘clarified effluent’, is pumped to enter the top of a multi media filter, which is comprised of layers of anthracite, sand, garnet and graded. This removes the bulk of suspended solids and some of the residual free oil. The solids retained by the multi media filter are removed periodically by air scouring and backwashing the filter with UF permeate. The multi media backwash water is returned to the surface water sumps via the surface water drains. A percentage of the solids will settle in the open drain sumps and be removed in routine sump de-sludging. The remainder will be reprocessed through the waste water treatment plant. The multi media filtered effluent flows through a cartridge filter that is located immediately upstream of the surface water Ultra-Filtration (UF) unit. Ultra-Filtration (UF) Operation - Description The surface water is fed onto the membrane surface under pressure. The water passing through the membrane is removed as ‘permeate’, whilst the retained water, oil and suspended solids are removed as a ‘concentrate’. The feed pressure is typically in the range 3-5 bar. The UF comprises two stages of four pressure vessels in series, each stage with its own recirculation pump. The recirculation pumps create a high shear stress at the membrane surface to help limit surface fouling and provide the cross-membrane pressure drop .The first stage recirculation pump draws both UF feed water and ‘Stage 1 re-circulated concentrate’ from the common header and pumps it through the first stage pressure vessels in parallel. Each pressure vessel contains multiple membrane elements. Retained water, oil and solids (concentrate) exits from the tail end of the pressure vessel. The concentrate from the four pressure vessels combines and returns to the common header. Permeate from the membrane elements is adjusted via rate set valves to distribute the permeate flow between the membranes and to determine the overall split between permeate recycle and forward flow. The second stage recirculation pump draws a

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combination of ‘Stage 1’ re-circulated concentrate and ‘Stage 2’ re-circulated concentrate from the common header, and processes it in a similar fashion to Stage 1. From the UF, a bleed of concentrate containing suspended solids and coalesced oil is returned to the inlet of the surface water Tilted Plate Separator (TPS) The UF permeate from both stages is combined and fed forward to the treated water sumps. The UF membranes are subject to fouling from the oil and suspended solids in the produced water. The UF plant is designed therefore to be taken off line periodically for a ‘Clean In Place’ (CIP), to remove accumulated foulants from the membrane.

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SURFACE WATER RUNOFF FROM PROCESS AREAS

Corrugated Plate Interceptor

Ultrafiltration Package

PFD 10 - Surface Water Treatment System

BalanceWater Sump

Backwash

Oil

Clarified Surface Water Tank

Used / Contaminated Firewater(Emergency Situations only) Used

Firewater Pond

Open Drains Sump

Oil Sump and Off-Spec Condensate Tank

Oil

SludgeSludge Tank

Multimedia Filter

Package

Treated Water Sump

(T-8302A)

Treated Surface Water Discharge to Outfall SW1

Off-specTreated Water

Backwash

Recycled to surface water treatment system via open drains sump

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Treatment/Abatement of Uncontaminated Surface Water

Uncontaminated Surface Water Attachment F.1.4.1 Description of Uncontaminated Surface Water Treatment

System

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F.1.4.1 Description of Uncontaminated Surface Water Treatment System

Uncontaminated Surface Water (or “storm water”) is runoff from the Terminal’s non-process areas and roofs, but excludes bunded areas which drain to the potentially contaminated surface water system (oily water). This water is collected in the perimeter surface water drains and is routed via an Emergency Holding Tank (EHT) to the settlement ponds. Discharge from the settlement ponds is commingled through a discharge channel designed to permit flow proportional sampling, after which the runoff enters the local peat ditch system and ultimately the drainage ditch that runs alongside the R314 road to the southwest of the Terminal. Additional details of the operation of the uncontaminated surface water drains system and contingency arrangement for potential contamination has been provided in the Section ?? of the Application. Settlement Ponds The settlement ponds are as described in Section F.1.2.5 of the previous Application, with the following clarifications. The settlement ponds will retain the oil retention barrier (previously referred to as an oil skimmer) that were originally installed for the construction phase, as an additional precautionary measure. A rip-rap was proposed at the construction stage of the project, the purpose of the was to retard flows entering the local drainage network. The rip-rap was intended to feed water over the open peat ground and eventually discharged to the road drainage ditch. However this design was not considered appropriate for construction and an open ditch system was used in consultation with the Mayo County Council. Experience gained during the construction phase indicates that the rip-rap arrangement will also not be suitable for long term operation. It is therefore proposed to use the open ditch arrangement. As the size of catchments for the operation phase are considerably smaller than the construction phase, the flows through the open ditches to SW2 will also be reduced commensurately. No significant disturbance is therefore expected to the local watercourses with this arrangement.

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Assessment of Use of Biocide

Attachment F.1.5 Assessment of the Use of Biocide for Biological Growth

Control in Produced Water Discharge System

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F.1.5 Control of Biological Growth in the Produced Water Discharge System F.1.5.1 Evaluation of Potential Methods for Control of Biological Growth Hydraulic analysis of the treated produced water discharge system through the umbilical shows that a small change of core surface roughness, or reduction of internal diameter, due to biological growth will significantly reduce the discharge capacity of the system. In addition, biological growth could induce corrosion in the form of microbially induced corrosion (MIC), if biofilm becomes established. MIC normally takes the form of pitting corrosion that can rapidly penetrate pipe walls It is consequently imperative that the system is maintained in a clean condition and that biological growth cannot be allowed to become established. Various potential biological growth control methods were evaluated from many different industrial sectors and activities, including desalination, oil and gas processing, municipal water systems, power generation, and cooling water systems. This evaluation process indicated that the identification of an optimal biological growth control system would require site specific assessment of the Terminal’s operating requirements and the receiving environment for the treated discharge F.1.5.2 Industry Guidance and Regulations A review of guidance and regulations relating to control of biological growth revealed that the although there is no direct guidance that cover the Corrib scenario, the draft BREF note on the application of Best Available Techniques to Industrial Cooling Systems (ICS) (2001) suggests a selection philosophy and criteria that can be applied in the selection of biocides. Although some of the criteria used in the ICS BREF note are not applicable for the present situation, the selection philosophy has been adopted by SEPIL for identification of a suitable biological growth control method. SEPIL has therefore sought to balance technical feasisbility with environmental impact of potential biological contro methods, which is the primary selection consideration expressed in the ICS BREF Note. Guidance provided in the Biocidal Products Directive 98/8/EC has been considered in the method used for carrying out a site specific assessment of the impact of biocides discharged into receiving water, as has the potential applicability of Environmental Quality Standards (EQSs) in the Water Framework Directive (2000/60/EC). F.1.5.3 Technical Challenges to Biological Growth Control in the Corrib Produced Water Discharge system Surveillance options for direct or indirect indications of biological growth within the umbilical system is extremely limited. The overall length, small diameter, and very limited access to the cores means that it is not practical to sample their internal surfaces for sessile bacteria and biofilm growth or inspect them for microbially induced corrosion (MIC). The remote sub-surface location of the discharge point also makes it impractical to sample the discharged water for evidence of planktonic bacteria that is indicative of sessile bacteria.

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As a consequence of these limitations, the main surveillance option is to monitor the pump discharge pressures and treated produced water volumetric discharge rate relative to reference performance data, and infer from those observations the development of biological growth which could restrict flow through the umbilical cores. This surveillance process could be supplemented by laboratory assessment of water samples for biological growth potential, biocide efficacy, and biocide optimisation. F.1.5.4 Alternative Methods for Biological Control Considered. Many methods of controlling biological growth in the Corrib produced water discharge system were considered. Examples of methods that are used to control biological growth in water treatment systems, cooling water systems, and related operations include ozone, ultraviolet radiation, competitive microbiologically, hydrodynamic cavitation, flushing, surfactants, mechanical cleaning with rotating brushes or sponge balls (Langford, 1977), light intensity (Yang et al., 2000), or controlling pH (Yukselen et al., 2003) or temperature. Methods involving mechanical cleaning were considered impractical for the small diameter umbilical cores that would be used for produced water discharge e.g. scrapping, brushes, sponge balls, pigging, surfactants and flushing. Access is limited and there is a significant risk of blocking the system during these operations. Single point treatment at the inlet of the umbilical, for example based on ultraviolet treatment, or hydrodynamic cavitation, both of which need to be continuously applied, were considered but rejected due to the inability to treat an already contaminated system i.e. systems where sessile bacteria have become established. The sessile bacterial contamination may occur in the event that the treatment system is offline (upset conditions) whilst produced water is discharged, or due ingress at the discharge point of the system during system shutdown. Sterilisation by ozone or hypochlorite generation was considered to represent a significant integrity risk, and also would not effectively treat the whole system. Ozone and hypochlorite are oxidising agents that could induce localised (pitting) corrosion of the super duplex stainless steel cores. The relative advantages and disadvantages of alternatives considered are summarised in Table F.1.5.1 on the following page.

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Table F.1.5.1. Comparison of Potential Methods for the Control of Biological Growth in Umbilical Cores used for the Discharge of Treated Produced Water

Method Disadvantage Advantage

Mechanical cleaning e.g. brushes, sponges, etc

Discharge system has to be shutdown for cleaning

Risk of MIC due to inadequate removal of biofilm

Impractical for small bore tubes

Risk of blockage when biofilm is removed

Chemical handling not required.

No chemical discharge to the environment.

Flushing Impractical due to velocity limitations of discharge system (maximum possible velocities in the ¾" and 1" umbilical cores are 0.89 m/sec and 0.98 m/sec, respectively)

Risk of blockage when biofilm is removed



Inlet treatments e.g. UV, hydrodynamic cavitation, heating, etc

Only treats water entering discharge system

Cannot remediate or treat system downstream of treatment point. Cannot address biological contamination due to ingress into discharge system that may occur during Terminal shutdowns.



Oxidising agent generators e.g. ozone, chlorine, etc

Risk of corrosion of umbilical cores due to oxidizing agent

Formation of bio-persistent halogenated organics

Poor at penetrating and dispersing heavy anaerobic infestations

Biological control of whole discharge system.

No interruption to discharge operation

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Method Disadvantage Advantage

Biocide: Oxidising (e.g. hypochlorite, chlorine dioxide, etc)

Risk of corrosion due to oxidizing agent

Chemical discharge to the environment

Formation of bio-persistent halogenated organics. Chemical handling

Occupational health and safety considerations e.g. exposure to chlorine gas

Very short half life



Biocide: Non-oxidising (e.g. gluteraldehyde, THPS, Acrolein™, isothiazolines, etc

Chemical handling

Occupational health considerations

Slow biodegradation

Slow degradation by other mechanisms e.g. hydrolysis, photodegradation, etc

Very short half life e.g. gluteraldehyde

Limited efficacy e.g. quaternary ammonium compounds only function as bacteriostatics



Biocide: DBNPA – Optimal method

Chemical handling

Chemical discharge to the environment


Broad spectrum biocide that should allow for uncertainities in respect of types of biological growth


Rapid degradation (fast hydrolyzing) to benign degradation products

Photodegrable

Acts as a kill biocide, as opposed to being a bacteriostatic, which is consistent with the preventative operating strategy of the water discharge system

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F.1.5.5 Selected Biological Control Method The specific characteristics of the Corrib treated produced water discharge through the umbilicals, described in Section F.1.5.3, requires that the a control method is one that ensures the prevention of biological growth, rather than one that requires detailed surveillance and remediation of growth observed in the system. Considering the various methods in use for industrial biological growth control, summarised in Table F.1.5.1 and their individual advantages and disadvantages when assessed for the specific conditions in the Corrib treated produced water discharge system, SEPIL has determined a control method based on biocide application to be the most appropriate. The biocide that has been selected for this purpose is DOW Antimicrobial 7287 (DBNPA). Overall, DBNPA is considered to have an optimal combination of functional performance and degradation characteristics in respect of environmental impact. An assessment of potential alternative biocides has been carried out and the justification for the selection of DBNPA is given in in section F.1.5.10. Contextual background on the use of biocides in the marine environment is given in section F.1.5.11. F.1.5.6 Biocide application strategy Biocide will be injected on the suction side of the pumps used to discharge treated produced water via the umbilical. Plant operators will control application of the biocide in accordance with a chemical treatment programme guide (CTPG) and a task instruction. The CTPG will define the biocide dose, treatment duration and frequency. Biocide use will be monitored and recorded as part of site chemicals management and supplier contract management procedures. Biocide dose will be optimised using samples of produced water taken upstream of the biocide injection point. The biocide optimisation will be based on laboratory test methods. Figure F.1.5.1 on the following page shows a schematic of the biocide dosing process of the treated produced water discharge system.

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Figure F.1.5.1: Schematic of the Biocide Dosing of the Treated Produced Water Discharge System.

Treated produced water sump

Filtration

Biocide storage drum

Biocide injection pump

Subsea manifold

Water discharge

pump

Discharge to sea

93 km Umbilical



Filtration

Biocide storage drum

Biocide injection pump

Subsea manifold

Water discharge

pump

Discharge to sea

93 km Umbilical

The residence time in the umbilical cores used to discharge produced water will be approximately 1 day when operating at maximum capacity i.e. ~22 m3/d (¾" core) and ~43 m3/d (1" core). The calculation of residence times is presented in the Appendix to this section. The operating philosophy is to use the 1” core at maximum capacity at all times. The operating strategy will be intermittent/batch application of biocide. A daily 2 hour application concentration of 200 ppm v/v of DBNPA should be assumed to represent the maximum likely usage of the biocide. This represents an active DBPNA concentration of 40 ppm, which is within the recognised application range for non-oxidising biocides, as detailed in BREF document on Industrial Cooling (see V.4.4). Based on a daily discharge capacity of the system of 65 m3/day the total annual usage of the ‘as supplied’ product would be 0.395 m3 (Vb).

Vb = 65 x (2/24) x (200/1 x 106) x 365 The application strategy is based on process laboratory and field data from the manufacturer of DBNPA. The application strategy will be further refined once production commences and produced water is treated at the Terminal. The dominant degradation pathway of DBNPA at application conditions involves reaction with nucleophilic substances, for example sulphites, or organic material such as bacteria and algae. In addition, DBNPA will decompose via hydrolysis. The rate of decomposition via hydrolysis as a function of temperature and pH is illustrated in Figure F1.5.2 below (see “References” for source of data). The discharged produced water will be in the range pH 6-9. This is an IPPC licence requirement. DBNPA rate of degradation by hydrolysis increases with increasing pH. Based on DBNPA degradation characteristics and the residence time in the cores, and assuming a maximum temperature of 10°C at the discharge point, and maintenance of the

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discharged water at less then pH 7.0, over-application in the system with DBNPA to allow for degradation due to hydrolysis will not be necessary. An added benefit of operating at the lower end of the IPPC permitted pH range will be the avoidance of carbonate scale deposition in the discharge system. The system will be optimised in respect of maintaining the discharged water in the permitted range of pH 6-9, minimisation of biocide use and prevention of carbonate scale deposition. F.1.5.7 Justification for SW3-S Sample Point Location Relative to Biocide Injection Point It is proposed that sample point SW3-S be located upstream of the biocide injection point. Justifications for the location are as follows: 1. Biocide will be injected into the treated produced water to prevent biological growth in the produced water discharge system. Application of biocide will be on a batch/intermittent basis for a short duration e.g. 2 hours per day at a specific dose concentration. Sampling at SW3-S will be on a 24 hour flow proportional basis. As a consequence, a sample taken on a 24 hour flow proportional basis would be an average that is not representative of the produced water discharged at any time during the 24 hour period. 2. Several of the ELVs specified for SW1a (now SW3-S) will be influenced by the presence of biocide in the produced water i.e. COD, BOD, Total N and Toxicity. Interpretation and reconciliation of these data, where the sample is collected as described in 1, would be very complicated. 3. The proposed biocide (DBNPA) will degrade relatively quickly after application, therefore measured values of ELVs such as COD, BOD, Total N and Toxicity will be strongly dependent on the time between biocide application and ELV measurement. BOD and Toxicity measurement will be further complicated by the long duration of the measurement techniques and degradation of the biocide during the measurements. 4. The characteristics of the discharged treated produced water containing biocide at the application concentration can be easily simulated in a laboratory. A sample of treated produced water can be dosed with biocide at the application concentration and then subjected to all required tests. This approach would provide a simple method for assessment of the environmental impact of treated produced water containing biocide. F.1.5.8 Fate of DBNPA in the Marine Environment When released in the treated produced water discharge stream at the sub-sea manifold, DBNPA will immediately start to undergo degradation through the natural process of hydrolysis, and by the process of bio-degradation. The rate of hydrolysis is shown in Figure F.1.5.2 in terms of its half-life as a function of both pH and temperature. The 10deg C line represents the maximum temperature that is estimated for the seafloor at the Corrib field. The vertical line at approximately pH7 represents the intended value for the discharge stream, and that at approximately 8.2 represents the upper range of seawater pH.

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Figure F 1.5.2. Hydrolysis degradation of DBNPA as a function of temperature and pH

10 deg C estimated

This shows that the rate of hydrolysis of the discharged biocide would be expected to lie between a half life of 10 hours and 100 hours. Dow report that biodegradation, which is the breakdown of DBNPA through its metabolism by micro-organisms in the marine environment, procedes at a rate of 78% after 28 days (672 hours). In combination therefore hydrolysis and biodegradation are highly effective processes that will rapidly result in the complete degradation of DBNPA once discharged as part of the treated produced water stream at the subsea manifold. F.1.5.9 Environmental Impact of DBNPA in the treated Produced Water Discharge The environmental impact of the biocide discharge, as detailed above, has been evaluated using the Osborne Adams method. Details of the assessment are presented in “Technical Note: Corrib Subsea Risk Assessment Antimicrobial 7287, The Osborne Adams method was developed for discharges during pipeline commissioning. The method is considered appropriate for the unique Corrib discharge system, which is at a seabed location similar to a typical pipeline commissioning operation. In addition, the methodology is consistent with the Water Framework Directive, which uses the PEC/PNEC parameter, where PNEC is equivalent to EQS. The assessment concluded that there would not be a significant impact to the marine environment from the proposed discharge of biocide. It is recognised that the Osborne Adams method does not consider cumulative effects of the biocide discharge. However, based on the rapid degradation of DBNPA to non-persistent degradation products, and the water currents in the area, cumulative effects would not occur.

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In addition, the Osborne Adams methodology does not consider the degradation of DBNPA when discharged to sea, and is therefore conservative. F.1.5.10 Assessment of Alternative Biocides Biocides can be classified as either oxidising or non-oxidising, as determined by the mode of action. Oxidising biocides are more widely used in the electric power and refining industries because of their effectiveness, moderate cost, and ease of application. Numerous biocides were considered for the Corrib application, and relevant legislation such as REACH and the Biocidal Product Directive 98/8/EC were considered. Oxidising biocides such as hypochlorite, hypochlorite/NaBr, peroxides, chlorine dioxide, etc., were considered to represent too great a threat to the integrity of the umbilical cores due to the risk of localised (pitting) corrosion of the super duplex stainless steel cores. Several biocides such as formaldehyde, gluteraldehyde, Acrolein™, and chlorine dioxide were eliminated due to occupational health considerations. Others were eliminated due to their functional limitations, such as their ability to kill bacteria as opposed to acting as bacteriostatic. From an environmental perspective, a biocide that readily degrades to a degree consistent with the OECD guidelines (>70% degradation after 28 days) and OSPAR guidance in respect of chemicals released to the marine environment that specifies at least 20% biodegradation after 28 days, was adopted as a requirement. As a consequence, DBNPA (2,2-dibromo-3-nitrilopropionamide) was selected as the basis of design due to rapid degradation in comparison to other non-oxidising biocides (78% biodegration after 28 days) In addition, DBNPA is one of only a few biocides with environmental properties allowing registration with the US EPA for once-through cooling systems, which includes permission to discharge the treated effluent water into public water, if done in accordance with an NPDES (National Pollutant Discharge Elimination System) permit (see “References” for source of data). DBNPA does not have a substitution warning under the UK Harmonised Mandatory Control Scheme (HMCS), and is not on the OSPAR List of Chemicals for Priority Action. DBNPA has both gold and silver HQ band classification for the different applications that DBNPA is registered for under the UK HOCNF registration system. This means that is in the top 2 performance classes in terms of its environmental impact. However, it is recognised the HQ band classification is not directly applicable to the unique Corrib application. Table F1.5.2 HQ Band Classification

Min Value Max Value Category >0 <1 Gold >=1 <30 Silver >=30 <100 White >=100 <300 Blue >=300 <1000 Orange >=1000 Purple

Note: HQ is calculated as PEC/PNEC for the given application.

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F.1.5.11 Examples of Biocide Use and Discharge in the Marine Environment Use and discharge of biocide in marine operations is not uncommon. Examples of oil and gas operations that involve use and discharge of biocide include: Offshore sea water systems use continuous hypochlorite to prevent biofouling of water injection systems and heat exchanger (cooling) systems. A significant proportion of the treated sea water is discharged back to the sea. Offshore process systems, such as pipelines, separators, storage cells and hazardous drains, are periodically treated with non-oxidising biocides such as gluteraldehyde, quaternary amines or THPS at shock treatment concentrations e.g. 500 ppm. The biocide is discharged in produced water and is subject to the environmental controls of the respective country. Pipeline installation and commissioning operations often involve discharge of biocide, such as gluteraldehyde or quaternary amines, prior to being brought into operation. Well operations involve fluids that are treated with non-oxidising biocides prior to use, and which are eventually discharged to the environment. Other examples of marine operations where biocides are released to the environment include ships’ ballast water treatment which use both oxidising and non-oxidising biocides that are discharged to the environment after application. Onshore use of biocides usually requires some form of treatment before release of treated water to surface waters. Examples include power generation and refinery operations. Cooling water systems use both oxidising and non-oxidising biocides, as detailed in the ICS BREF Note. In open circuit systems, and in some closed circuit systems, biocides are released to the environment. However, DBNPA is used in sea water desalination operations to protect membranes with reject streams being discharged at near shore locations.

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Appendix 1 Calculation of umbilical volume, and produced water residence time, and produced water velocity in umbilical cores during discharge The umbilical volume (V) V = πr2L where r is the umbilical core internal radius L is the umbilical length The umbilical residence time (tR) tR = V/Q where Q is the produced water discharge rate The water velocity (v) v = Q/πr2 For the ¾" core V = π (9.53 (mm) / 1000)2.93000 (m) = 26.5 (m3) tR = 26.5 (m3) / 22 (m3/d) = 1.2 days v = 22 (m3/d) / (9.53 (mm) / 1000)2 = 0.89 m/sec For the 1" core V = π (12.7 (mm) / 1000)2.93000 (m) = 47.1 (m3) tR = 47.1 (m3) / 43 (m3/d) = 1.1 days v = 43 (m3/d) / (12.7 (mm) / 1000)2 = 0.98 m/sec

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F.1.5.12 References DOW Antimicrobial 7287 and DOW Antimicrobial 8536: The fast-acting, broad-spectrum biocides with low environmental impact, Form No. 253-01464-06/18/02 Langford T. (1977) Environmental management of coastal cooling discharges in Hong kong, Chemistry & Industry: 612-616. Yang L, Chang W-S & Lo Huang M-N. “Natural disinfection of wastewater in marine outfall fields, Water Research 34: 743-750, 2000. Yukselen MA, Calli B, Gokyay O & Saatci A. (2003) Inactivation of coliform bacteria in Black Sea waters due to solar radiation, Environment International 29: 45-50. European Commission document “Integrated Pollution Prevention and Control (IPPC), Reference Document on the Application of Best Available Techniques to Industrial Cooling Systems, December 2001”. Technical Note: Corrib Subsea Risk Assessment Antimicrobial 7287 Presentation: Risk Assessments of Chemical Discharges Arising From The Commissioning of Pipelines, Julia Osborne and Laura Adams, Fisheries Reserch Services (FRS) and The Centre for Environment, Fisheries and Aquaculture Services (CEFAS).

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ATTACHMENT No. F.2 Emissions Monitoring and Sampling Points

Contents Attachment F.2.1 Location of Main Air Emissions and Monitoring/Sampling

Points (Dwg: IPPCL-020) Attachment F.2.2 Monitoring/Sampling Points within Terminal for emissions

to surface waters and to ground (Dwg: IPPCL-021) Attachment F.2.3 Monitoring/Sampling Points for ambient air, ambient

surface water and discharge of uncontaminated surface water (Dwg: IPPCL-022)

Attachment F.2.4 Location of Ambient Noise Monitoring Points and Weather

Station (Dwg: IPPCL-023) Attachment F.2.5 Location of Ambient Groundwater Monitoring Points

(Dwg: IPPCL-024)

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attachment no. f.1.1 emissions to atmosphere · 2013. 7. 26. · the cpi oil will be discharged to...

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