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VIRIDIAN POWER LIMITED HUNTSTOWN POWER STATION PHASE II IPPC LICENCE APPLICATION SUPPORT DECEMBER 2005 For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 25-07-2013:17:58:17

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Page 1: VIRIDIAN POWER LIMITED

VIRIDIAN POWER LIMITED HUNTSTOWN POWER STATION PHASE II IPPC LICENCE APPLICATION SUPPORT DECEMBER 2005

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Page 2: VIRIDIAN POWER LIMITED

PB Power List of Revisions

LIST OF REVISIONS

Current Rev.

Date Page affected

Prepared by

Checked by (technical)

Checked by (quality

assurance)

Approved by

original Dec 05 C Reed

N Mant

P Philip

W E Hatfield

REVISION HISTORY

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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Page 3: VIRIDIAN POWER LIMITED

PB Power Page i of iii

CONTENTS

Page No.

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

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

2. SECTION B – GENERAL .................................................................................................4

2.1 Attachment B1 – Company Registration Documents ................................................4

2.2 Attachment B2 – Site Maps .......................................................................................6

2.3 Attachment B5 – Planning Approval and Licences....................................................6

2.4 Attachment B8 – Site Notice....................................................................................13

2.5 Attachment B10 – IPPC Directive............................................................................14

3. SECTION C – MANAGEMENT OF THE INSTALLATION..............................................15

3.1 Attachment C – Site Management and Control .......................................................15

3.2 Interfaces with Phase I ............................................................................................17

4. SECTION D – INFRASTRUCTURE AND OPERATION ................................................21

4.1 Attachment D – Operational Information .................................................................21

4.1.1 Combined Cycle Generating Plant ...................................................................21

4.1.2 Design Features ...............................................................................................21

4.1.3 Plant Layout .....................................................................................................24

4.1.4 Operating Regimes ..........................................................................................24

5. SECTION E – EMISSIONS ............................................................................................27

5.1 Attachment E1A – Emissions to Air.........................................................................27

5.1.1 Major Emissions ...............................................................................................27

5.1.2 Minor Emissions ...............................................................................................28

5.2 Attachment E1B – Fugitive and Potential Emissions to Air .....................................29

5.3 Attachment E2 – Emissions to Water ......................................................................30

5.3.1 Abstraction .......................................................................................................30

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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5.3.2 Discharges .......................................................................................................30

5.3.3 Mitigation ..........................................................................................................32

5.4 Attachment E4 – Emissions to Ground....................................................................37

5.5 Attachment E5 – Noise Emissions ..........................................................................37

6. SECTION F – CONTROL AND MONITORING..............................................................38

6.1 Attachment F1 – Treatment and Abatement ...........................................................38

6.2 Attachment F2 – Monitoring and Sampling .............................................................38

6.2.1 Monitoring at Source of Emission.....................................................................38

6.2.2 Ambient Monitoring ..........................................................................................39

7. SECTION G – RESOURCE USE AND ENERGY EFFICIENCY ....................................40

7.1 Attachment G – Raw Materials and Energy ............................................................40

7.1.1 Raw Materials...................................................................................................40

7.1.2 Energy Efficiency..............................................................................................41

8. SECTION H – MATERIALS HANDLING ........................................................................42

8.1 Attachment H1 – Materials and Wastes ..................................................................42

9. SECTION I – EXISTING ENVIRONMENT AND IMPACT OF THE ACTIVITY...............43

9.1 Site Condition ..........................................................................................................43

9.2 Impacts ....................................................................................................................43

9.2.1 Attachment I1 – Atmospheric Emissions..........................................................43

9.2.2 Attachment I2 – Surface Water Emissions.......................................................44

9.2.3 Attachment I4 – Groundwater Emissions .........................................................44

9.2.4 Attachment I5 – Groundwater Contamination ..................................................45

9.2.5 Attachment I6 – Waste Recovery and Disposal ...............................................45

9.2.6 Attachment I7 – Noise Impact ..........................................................................45

9.3 Attachment I8 – BAT Arguments and Mitigation Measures.....................................47

9.3.1 Selection of Process.........................................................................................47

9.3.2 Selection of Fuel...............................................................................................47

9.3.3 Use and Discharge of Water ............................................................................47

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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PB Power Page iii of iii

9.3.4 Other Raw Materials.........................................................................................48

9.3.5 Emissions to Air................................................................................................48

9.3.6 Waste ...............................................................................................................48

9.3.7 Energy Efficiency..............................................................................................48

9.3.8 Monitoring of Emissions ...................................................................................49

9.3.9 Noise and Vibration ..........................................................................................49

10. SECTION J – ACCIDENT PREVENTION AND EMERGENCY RESPONSE.............50

10.1 Attachment J – Accident Prevention and Emergency Response.........................50

11. SECTION K – REMEDIATION, DECOMMISSIONING, RESTORATION AND AFTERCARE .........................................................................................................................53

11.1 Attachment K – Remediation, Decommissioning, Restoration and Aftercare ......53

11.1.1 Decommissioning Management .......................................................................53

11.1.2 Criteria for Decommissioning Plan ...................................................................53

11.1.3 Residuals Management Plan ...........................................................................53

11.1.4 Main Plant Elements ........................................................................................53

11.1.5 Hazardous Waste.............................................................................................54

11.1.6 Non-hazardous Waste......................................................................................55

11.1.7 Buildings Security.............................................................................................55

11.1.8 Decommissioning Completion Report ..............................................................55

12. SECTION L – STATUTORY REQUIREMENTS .........................................................57

12.1 Attachment L – Statutory Requirements ..............................................................57

12.1.1 Section 83 of the EPA Acts ..............................................................................57

12.1.2 Habitats Directive .............................................................................................57

12.1.3 Water Quality Standards for Phosphorus.........................................................58 APPENDIX A. SITE MAPS APPENDIX B. WATER BALANCE APPENDIX C. NOISE PLOTS APPENDIX D. AIR DISPERSION MODELLING STUDY

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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PB Power Page 1 of 58 Pages

LIST OF ABBREVIATIONS

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

oxides of nitrogen NOxO2 oxygen SCOLF sulphur content of certain liquid fuels (Directive) SO2 sulphur dioxide SSS self shifting synchronising (clutch) TDS total dissolved solids te tonne TU toxicity units V volts VOCs volatile organic compounds VPL Viridian Power Limited %v percent by volume

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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1. SECTION A – NON-TECHNICAL SUMMARY

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

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

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

Viridian Power Limited is a project company wholly owned by Viridian Group plc. The Huntstown Phase II combined cycle gas turbine (CCGT) project involves the construction and operation of a 401.1 MWe gas fired combined cycle gas turbine power plant located to the west of the Dublin Airport in Ireland.

Phase II of the power station is located on the same site as the Phase I 342.7 MWe unit, which entered commercial operation in 2002. Both plants are to be operated by a subsidiary of Viridian Group, GenSys Power Limited, as the Operations and Maintenance Company formed for this project, who manage the day to day operations and maintenance of the Plant including the reporting obligations and dispatching notifications.

The site was selected owing to being located near a main transmission line of its main fuel source of gas as well as the dominant electricity demand centre of Dublin. Natural gas, dominated by St. Fergus analysis, is piped approximately 2 km to the site from a connection to the Irish National Transmission System. Electricity from Phase II will be exported via a 220kV cable to an ESB National Grid (ESBNG) air insulated switchyard within the site boundary and then by cable to the 220kV Corduff Substation some 4 km from the site.

The project is being constructed under a Turnkey engineer, procure and construct (EPC) contract by Mitsubishi Corporation with completion in Autumn 2007.

The Huntstown Phase II Project comprises a single-shaft Mitsubishi 701F gas turbine driving a generator. The gas turbine exhausts into a horizontal gas path heat recovery steam generator (HRSG). The HRSG delivers steam at three pressures to a steam turbine which drives the same generator via a clutch. The turbine is of a tandem compound design coupled to an electric generator.

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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PB Power Page 3

The layout of the plant is on a single axis, with the gas turbine at one end of the turbine building, and the steam turbine at the other, under a single crane. The HRSG has an integral exhaust stack.

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

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

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

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

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

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

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

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

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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2. SECTION B – GENERAL

2.1 Attachment B1 – Company Registration Documents The following pages contain copies of the Certificates of Incorporation for the creation of Davjohn Limited, dated 15 March 2000 and for its name change to Viridian Power Limited dated 23 January 2003, with reference number 323213.

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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2.2 Attachment B2 – Site Maps Figure A1 in Appendix A shows the site plan for Phase I and the proposed plant for Phase II, including release points E1 to air and D1 to surface waters. E1 is the HRSG stack. The plant has no bypass stack at present although space provisions are included in case it is required in the future. D1 is the existing waste water discharge basin which receives surface and process drains from Phase I and Phase II. The process flows are monitored separately before reaching the discharge.

Figure A2 in Appendix A shows the location of the site.

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

The development is also governed by the conditions of the previous permissions on this site, F98A/1313, PL06F 110954, F00A/0957, F01A/1046, and F03A/0272, insofar as they pertain to this site.

The current Planning Permission F05A/0490 was granted on 4 July 2005 and reflects the Mitsubishi design for the site, and a combined output of 740MWe.

A copy of the Notification of planning permission is given below. This is followed by a copy of the text of the letter to be sent to the Local Authority advising them of this IPPC Licence application.

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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2.4 Attachment B8 – Site Notice The advertisement to be placed in the Irish Independent and Fingal Independent newspapers will contain the following text:

APPLICATION TO THE ENVIRONMENTAL PROTECTION AGENCY FOR A LICENCE

Name of applicant: Viridian Power Limited.

Address of applicant: 3rd Floor, Mill House, Ashtowngate, Navan Road, Dublin 15.

Proposed activity: Huntstown Power Station Phase II.

Proposed location of the activity: The proposed location is adjacent to Phase I of Huntstown Power Station, which is adjacent to Huntstown Quarry, in the townlands of Huntstown and Johnstown, in the functional area of Fingal County Council.

National Grid Reference of proposed development: E 311385 N 241450.

Class and nature of proposed activity in accordance with the First Schedule of the Protection of the Environment Act 2003: Class: 2.1. Nature: The operation of combustion installations with a rated thermal input equal to or greater than 50 MW.

An Environmental Impact Statement, as required for this type of development by the European Communities (Environmental Impact Assessment) Regulation, 1989, S.I. 349 of 1989, was submitted to the Environment Agency and to Fingal County Council in connection with the original application for an IPC Licence for Phases I and II of the Power Station. This Licence was issued and Local Authority Planning Approval was granted for Phases I and II on the basis of this Statement.

A copy of the application may be inspected at or obtained from the Headquarters of the Agency, at Johnstown Castle Estate, County Wexford as soon as possible after receipt of the application by the Agency.

The same text will be displayed at the conspicuous public location shown in Figure A3 in Appendix A.

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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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.

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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3. SECTION C – MANAGEMENT OF THE INSTALLATION

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

• to improve environmental performance by:

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

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

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

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

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

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

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

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

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

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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Key Outputs:

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

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

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

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

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

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

Key Outputs:

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

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

• development of Environmental Management Procedures to reduce environmental impacts;

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

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

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

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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Key Outputs:

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

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

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

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

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

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

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

An Ancillary Services Agreement between the Phase I and Phase II companies covers the sharing of surplus facilities and services between Phase 1 and Phase II, and also the sale of products from Phase I to Phase II. Reciprocal sharing of Phase II services is allowed. The agreement also sets out the responsibilities of each party to comply with the IPPC Licences which cover the activities of both Phase I and Phase II.

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

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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

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

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

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

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

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

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

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

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

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

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

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

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A. SHARED FACILITIES

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

1

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

2

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

3

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

4

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

5

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

6

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

7

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

8

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

9

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

10

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

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

12

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

13

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

14

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

15

Table 1. Shared Facilities

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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B. SERVICES

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

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

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

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

Table 2. Shared Services

C. SUPPLIES

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

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

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

2

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

3

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

4

Table 3. Shared Supplies.

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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4. SECTION D – INFRASTRUCTURE AND OPERATION

4.1 Attachment D – Operational Information

4.1.1 Combined Cycle Generating Plant In common with Huntstown Phase I, it has been decided that a Combined Cycle Gas Turbine (CCGT) plant operating on natural gas (with distillate as backup fuel) is the most appropriate option for the site at Phase II. The advantages of CCGT over conventional fossil fuel fired alternatives include:

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

The natural gas used in the plant will be supplied by the Bord Gais Eireann high pressure transmission network with a mixture of sources including imports via the Scotland to North Dublin interconnector pipelines. In comparison with solid and liquid fuels, the sulphur content of gaseous fuel means that emissions of SO2 can be considered negligible for the purposes of emissions calculations. The maximum sulphur content of the standby distillate to be used in the project will be limited to 0.15% by weight, in accordance with EPA guidelines and will be reduced to a maximum of 0.1% by the end of 2007 in accordance with the Sulphur Content of Liquid Fuels (SCOLF) EU Directive. Thermal power plants, by their nature, emit carbon dioxide. However, owing to the higher thermal efficiency of gas turbines in combined-cycle mode and to the relatively low proportion of carbon in natural gas fuel, mass emissions of CO2 per kWh are relatively low when compared with traditional open-cycle technology (approximately one third lower).

4.1.2 Design Features A plant layout has been developed based on a single shaft combined cycle arrangement. This includes provision for conversion to allow the option of open cycle gas turbine operation is this were required in the future; a clutch drive between the steam turbine and the generator allows isolation of the steam turbine and space is allowed for the erection of a bypass stack. A typical single shaft arrangement is illustrated in Figure 1 and a simplified process flow diagram in Figure 2.

Other features of the plant include an air cooled condenser and a 34.5 metre tall exhaust stack. The relatively low stack height takes account of civil aviation constraints imposed by

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the proximity of Dublin Airport, but is still sufficient to ensure adequate atmospheric dispersion of exhaust gases.

Air Cooled Condenser

HRSG

Steam Turbine

Gas Turbine

Air Inlet

Figure 1. Typical Single Shaft Combined Cycle Gas Turbine Plant Layout (building not shown)

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PB Project No 61825B.

Figure 2. CCGT Process Diagram.

File : Application support Huntstown Phase II text.doc

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4.1.3 Plant Layout The plant is based on a nominal 270 MWe Mitsubishi 701F gas turbine. The exhaust heat from this turbine will generate steam, through a three pressure Nooter Eriksen heat recovery steam generator (HRSG) that will operate a nominal 130 MW Mitsubishi steam turbine. With the gas turbine generator and steam turbine working in tandem (i.e. in combined cycle mode), the output from the unit will be approximately 400 MW from the single hydrogen cooled Mitsubishi Electric generator. This system allows an efficiency in excess of 50%, as compared to about 37% for a typical conventional boiler plant. The plant layout is shown in Figure A1 in Appendix A.

The hot exhaust gases from the gas turbine will be used to raise steam in the boiler which is expanded through the steam turbine to generate electricity. This arrangement, designed around BAT principles, ensures the optimum use of fuel and minimises emissions.

An air cooled condenser has been selected to condense the steam from the steam turbine. The alternative to the air cooled condenser was rejected since it would require large quantities of cooling water, which are not readily available in the area. Wet type cooling towers were also rejected on grounds of visual impact.

A stack will be installed for the exhaustion of emissions into the atmosphere from the HRSG, of sufficient height to ensure adequate dispersal of the emissions, but not impinging on the air navigation requirements of Dublin Airport. The main stack will be of height 34.5 m, which is 112 m above Ordnance Datum (Malin Head).

The Phase II plant includes a new turbine building, housing the gas and steam turbines, a new gas turbine water injection storage tank and a number of new areas and extensions to existing facilities within Phase I. These include a new distillate oil storage tank with its own bunded area to the north of the Phase I area. The existing workshop and consumable stores buildings within Phase I and the switchyard area to the east of the site will be extended to accommodate the needs of Phase II. The existing fuel oil unloading station, firefighting and raw water storage tanks, water treatment plant and administration building will serve both Phases I and II.

4.1.4 Operating Regimes The plant is envisaged as a cycling or base load plant and hence could operate for 24 hours per day and 365 days per annum depending on maintenance and despatch requirements. Distillate oil facilities are provided as a standby provision in accordance with the Consent to Construct or Reconstruct a Generating Station, in the event that natural gas is unavailable. The gas is provided as an interruptible supply and operation on standby fuel is not expected to exceed 10 days per year. Provision is made for operation on oil for up to 5 days in one session, in the form of storage of distillate oil and water for injection into the gas turbine to control NOx emissions.

The gas turbine will be started using its generator by a Static Frequency Converter startup system. Air at atmospheric conditions will be drawn from an inlet air system to the

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compressor section and compressed. After reaching firing speed, fuel will be injected into the combustors and mixed with the compressed air and ignited.

The gas turbine will be accelerated to a self-sustaining speed of approximately 70% rated speed. At this point, additional fuel will be injected to accelerate the gas turbine 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 synchronisation. Synchronisation will be accomplished by an automatic synchroniser.

Once the gas turbine is synchronised to the grid, the load is increased to a hold point while steam is raised in the HRSG. Initial steam is bypassed directly to the air cooled condenser until steam conditions are suitable for admission to the steam turbine. The gas turbine load can be increased to give higher steam conditions to match the pre-existing temperature of the steam turbine.

The steam turbine is then accelerated by admitting steam until it reaches synchronous speed, at which point the self shifting synchronising (SSS) clutch will engage and transmit power to the common generator. The load can then be ramped to the required despatch load.

The Mitsubishi 701F gas turbine uses a dry low NOx combustor. When firing natural gas, no water is injected and combustion is dry. For distillate oil firing, demineralised water is injected to control NOx emissions.

The combustion system consists of 20 combustors. Each combustor has a pilot burner located in the centre position producing a small diffusion flame to stabilise the premix flame. This is surrounded by eight main burners producing a pre-mixed flame.

Each of the 20 transition pieces has a bypass valve which directs a portion of the compressor delivery air directly into the transition piece to enhance flame stability during starting and to maintain desired fuel/air ratio during loading.

For shutdown, the module load is reduced and the steam turbine is unloaded by closing the steam valves. As the steam turbine load reaches zero, the SSS clutch will disengage and the steam turbine is tripped to run down to turning gear speed.

The remaining load on the gas turbine can then be reduced and the unit disconnected from the grid by a reverse power relay. The unit is then run down to turning gear speed by reducing the fuel input.

The CCGT can be held in readiness for restart with condenser vacuum maintained, and gland steam supplied by the small auxiliary boiler.

During startup, NOx and CO emission concentrations will not fall to guaranteed levels until a minimum gas turbine load is reached, which is 50% firing gas and 65% firing distillate oil. Any increase in concentration is offset by a reduced exhaust flowrate while at low load.

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Similarly during shutdown, concentrations may increase briefly. The durations of cold, warm and hot starts are 275, 155 and 95 minutes respectively.

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5. SECTION E – EMISSIONS

5.1 Attachment E1A – Emissions to Air

5.1.1 Major Emissions The plant includes one source of major emissions to air, which is the HRSG stack. These emissions comprise gas turbine exhaust gases which have passed through the HRSG, where heat has been extracted making steam to drive the steam turbine, reducing the temperature of the gases. 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. Of these only NOx and CO are considered significant when firing natural gas. SO2 becomes significant only when firing the standby fuel distillate oil.

The emission concentrations of these pollutants are judged for their compliance with BAT requirements by comparison with the Large Combustion Plant BREF issued by the IPPC Bureau and the UK Environment Agency’s consultation draft “IPPC Sector Guidance Note, Combustion Activities” issued in March 2005. Ireland’s EPA has not yet issued its own combustion sector guidance note, but it is anticipated that their interpretation of the BREF will be similar to that of the UK and so the comparison to this document is considered valid. Table 4 below compares the proposed emission concentrations, as consented in the existing IPC Licence 483 and illustrates their consistency with both the BREF and the UK draft Guidance Note. The reduced UK Draft Guidance Note SO2 level on firing gas from 2008 reflects the reduction of maximum sulphur in distillate oil from 2008 in accordance with the SCOLF Directive; actual concentrations from the proposed plant will comply with this as demonstrated in the dispersion study discussed in Section 9.2.1 (Attachment I1) and reproduced in full in Appendix D.

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

Pollutant Fuel

Proposed plant BREF UK draft Guidance Note

natural gas 50 20 – 50

PB Project No 61825B.

50 NOx (as NO2) distillate oil 120 – 125 natural gas 100 5 – 100 100 CO distillate oil 100 – 100 natural gas 12 – 10 SO2

distillate oil 120 – 112 (66 from 2008)

natural gas 2 – 5 Dust distillate oil 10 – –

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

5.1.2 Minor Emissions 5.1.2.1 General

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

5.1.2.2 Auxiliary Boiler

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

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

5.1.2.3 Emergency Diesel Generator

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

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gear for the turbine rotors, battery chargers, control power, communications and fire protection systems. The emergency generator will be a multi-cylinder diesel engine with a 400V generator. Low sulphur diesel will be supplied from a bunded diesel tank local to the generator. 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 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.

5.1.2.4 Firefighting System

The station will have a full fire detection and protection capability, integrated with the existing Phase I system. Water for firefighting will be stored in the existing fire water tank and a new fire water tank with electric and diesel engine fire pump will be provided to serve the Phase II fuel tank cooling spray system. The diesel fired pump 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 firefighting skid roof. Pumps will be run only for emergency duty or for weekly testing purposes. Emissions to atmosphere from the firewater pump engine will not be significant.

5.1.2.5 Fuel Systems

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

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

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

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5.3 Attachment E2 – Emissions to Water

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

Raw water sourced from on-site wells will be used for service water supply and for the fire protection system. Demineralised water will be used for make up water for the HRSG, injection into the gas turbine for NOx emission control when firing distillate oil standby fuel and for the initial fill and occasional top-up for closed cooling systems.

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

The expected normal requirement for Phase II is approximately 4 m³ potable water per day for domestic use and 4 m³/hour demineralised water as make-up water for the boiler. The domestic demand is sized on an allowance of 200 litres per person per day for use by 20 site staff. The boiler water make-up is sized as 1% of the boiler flow of 381 m³/hour. When firing on distillate oil, demineralised water is injected into the gas turbine at approximately 65 m³/hour to control NOx emissions to compliant levels from a storage tank of 8000 m³ capacity.

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

5.3.2 Discharges 5.3.2.1 General

Surface drains from Phase II will flow into the existing Phase I network which releases water at discharge point D1. Because the discharges from both Phases are combined, the apportionment of responsibility for the contributions to the combined drain from the two

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Phases is managed via an arrangement between the operators of the two Phases as described above in Section 3.2. Existing flow proportional sampling of the Phase I surface water flows will be retained.

The operation of the CCGT power station will generate aqueous effluent streams, consisting mainly of boiler blowdown. Most of this will normally be recycled when the quality is suitable but the remainder will receive appropriate treatment before release via discharge point D1. The typical water balance shown in Appendix B reflects the preferred scenario with water discharge recycled where possible, reducing the net discharge from Phase II. However the plant is designed to discharge the maximum flow in the event that recycling is not possible or appropriate. Table 5 shows the preferred and maximum flowrates of process drains.

Source Preferred discharge from site, tonnes/day

Maximum discharge from site, tonnes/day

miscellaneous drains 3.0 5.0 sampling drain 24.0 150.0 boiler blowdown 0.0 301.5 contingency 9.0 143.5 TOTAL 36.0 600.0

Table 5. Process Flows from Phase II.

5.3.2.2 Surface Drains

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

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

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

5.3.2.3 Sanitary Drains

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

The sewage holding tank adjacent to the maintenance contractor’s compound is only used intermittently during maintenance outage work and will be emptied as required for off-site disposal.

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5.3.2.4 Chemical Drains

In order to maintain the required quality of steam in the boiler, it is necessary to discard a portion of boiler water at a controlled rate. About 1% of the steam flow in the boiler will be blown down each hour. This is exposed to atmospheric pressure so that some is flashed off as water vapour while the remainder is cooled in a regenerative heat exchanger to recover heat, boosting the efficiency of the CCGT process, the reduction in temperature also easing its handling.

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

The boiler blowdown and sampling drains which are not recycled are routed to a new waste water treatment plant, together with sump drains from the gas turbine water injection storage tank, air cooled condenser and areas containing dosing chemicals. The plant treats the drains with sodium hypochlorite to remove ammonia. Treated drains are dosed with sodium hydroxide and/or hydrochloric acid to adjust the pH value and with sodium bisulphite to remove excess chlorine, with a facility to be recirculated back to the treatment pit. Treated water quality is monitored and the water is only released provided its quality is acceptable.

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

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

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

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

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

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

separators, neutralisation facility); and

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• discharge quality targets based on recognised benchmarks. The expected discharge quality is described in Table E2(ii) of the Application Form and is consistent with the “achievable releases” defined in the draft UK Sector Guidance Note, as shown in Table 6 below. The achievable releases are intended by the Guidance Note to provide a basis for emission limits.

Parameter Unit Table E2(ii) (D1, treated process drains)

UK Guidance Note “achievable release”

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

Table 6. Aqueous Discharge Quality Limits.

The site of the power stations will be drained into the existing land drainage system serving the Huntstown quarry. A copy of the waste permit WPW/1/87 for the quarry referred to in Table E2(i) of the Application Form follows as Figure 3.

The significant pollutants as listed in the Schedule of the Environmental Protection Agency (Licensing) Regulations (Amended) 2004 are carcinogens and biocides. These are controlled to minimal levels in the final discharge. The only recognised potential carcinogen on site is hydrazine, which is used in small quantities as a boiler feedwater oxygen scavenger. Any traces reaching process drains are removed by the sodium hypochlorite. Sodium hypochlorite, which as a source of chlorine has biocide properties, is used in the waste water plant to remove ammonia and surplus is reduced by sodium bisulphite dosing to low residual levels.

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

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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Figure 3 (part 2 of 3). Waste Permit WPW/1/87 for the Roadstone Quarry.

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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5.4 Attachment E4 – Emissions to Ground The only emission to ground is the treated sewage from the percolation pit within Phase I power station. This handles sanitary drains from both Phase I and Phase II and will be declared in detail as an emission from Phase I station within the review of its IPC Licence. The emission from Phase II is limited to the untreated sewage from the Gatehouse building.

5.5 Attachment E5 – Noise Emissions A comprehensive provisional list of noise sources within Phase II is given in the completed Table E.5(i) of the Application Form. The principal sources are:

• air cooled condenser; • deaerator; • gas turbine; • gas turbine air inlet; • HRSG; • main transformer; • unit transformer; and • stack.

Figure C1 in Appendix C shows the plot, highlighting these sources. The plant layout is arranged to minimise, as far as is practicable, the impact of noise on the nearest sensitive receptor to the east of the site – with, for example, the air cooled condenser at the west end of the site and the gas turbine injection water tank located to provide some shielding. A combination of low noise equipment, acoustic lagging and shielding will be used to mitigate the noise contribution.

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6. SECTION F – CONTROL AND MONITORING

6.1 Attachment F1 – Treatment and Abatement The significant pollutants at the point of emission to air E1 are oxides of nitrogen and carbon monoxide. These are controlled by the dry low emission gas turbine burners, which maintain concentrations within the limits of IPC Licence 483 from 50% load upward firing gas and 65% load upward firing distillate oil. No further treatment or abatement on natural gas firing is necessary. On firing the standby fuel distillate oil, NOx emissions are controlled by injection of demineralised water into the combustors. Sufficient water is stored to match the 5 day storage of distillate oil fuel.

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

The process drains from Phase II plant are treated with sodium hypochlorite to remove ammonia and with sodium hydroxide/hydrochloric acid to adjust the pH to within an acceptable range. After the ammonia removal stage, sodium bisulphite is added to remove excess chlorine (arising from sodium hypochlorite) and redox potential is monitored to control the chlorine/bisulphite balance. The discharge from the process is monitored and either recycled or discharged according to its composition. The flowrate of drains requiring this process is minimised by recirculating as much as possible of the drains.

6.2 Attachment F2 – Monitoring and Sampling

6.2.1 Monitoring at Source of Emission HRSG exhaust gases discharged at point E1 are continuously monitored for oxides of nitrogen, carbon monoxide and oxygen. Concentrations of oxides of nitrogen and carbon monoxide are corrected to the appropriate reference conditions of 15% by volume oxygen dry at 0ºC, 101.3 kPa. Values are recorded in the power station distributed control system. Exceedences of maximum limits will be alarmed. Four ports at right angles in the same plane are provided for independent monitoring of particulates and velocities, in accordance with EPA Guidance Note 5.2. The sample probes and ports are situated at elevation 29.425 metres and safely accessed from a platform. The sampling plane is situated more than 0.5 duct diameters upstream of the stack outlet in accordance with recognised 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 recognised guidance notes, but this is not critical when only gaseous species are being measured.

The dedicated Phase II streams are the process drains from the waste water treatment plant and pumped drains from the new fuel oil storage tank bund. Surface drains from the main

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

6.2.2 Ambient Monitoring Ambient monitoring of NO2 in air at St Margaret’s National School is undertaken in agreement with the programme agreed with the EPA in accordance with Condition 10.9 of IPC Licence 483. This programme will be continued for one year before and one year after Phase II commercial operation date to provide comparative data.

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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 Phase II plant may be divided into fuels, water and operation chemicals.

The fuels used are natural gas and distillate oil. Of these only distillate oil is stored on site. Specified and typical gas compositions and a typical distillate oil composition are shown in Tables 7 and 8 respectively below.

Parameter Unit Permitted range Typical value, week 46, 2002

carbon dioxide %vol. ≤4 2.400 nitrogen %vol. ≤6 0.769 methane %vol. 87.366 ethane %vol. 6.464 propane %vol. 2.368 n-butane %vol. 0.332 iso-butane %vol. 0.180 n-pentane %vol. 0.055 iso-pentane %vol. 0.051 neo-pentane %vol. 0.001 hexane + %vol. 0.014 gross calorific value MJ/Nm³ @ 15ºC,

101.325 kPa 36.5 – 47.2 40.35

net calorific value MJ/Nm³ @ 15ºC, 101.325 kPa

36.45

Wobbe index MJ/Nm³ @ 15ºC, 101.325 kPa

45.7 – 54.7 50.21

relative density @ 15ºC, 101.325 kPa

0.55 – 0.7 0.6458

density mg/Nm³ @ 15ºC, 101.325 kPa

0.7914

mean molecular mass 18.663 water dewpoint ºC at 15 MPa a -13 hydrogen sulphide 3.7 0.42 odour intensity ≥1.7 1.9 water content mg/m³ 112

Table 7. Fuel Gas Composition.

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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Parameter Unit Typical content Carbon % mass 87.2 Hydrogen % mass 12.7 Nitrogen % mass <0.01 Total Sulphur % mass 0.15 Net calorific value MJ/kg 42.6 Density @15C kg/m³ 865.5 Kinematic Viscosity @40ºC cSt 3.577 Kinematic Viscosity @20ºC cSt 5.920 Flash Point PMCC ºC 75.5 Cloud Point ºC -2 Pour Point ºC -33 Water Content % mass 0.01 Carbon Residue, micro method % (m/m) <0.1 Ash % mass 0.002 Mercaptan Sulphur % mass <0.0003

Table 8. Distillate Oil Composition.

7.1.2 Energy Efficiency The plant has been 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 was one of the key parameters in optimising the overall design as well as selecting the individual components of the plant. Incentives for efficiency were provided by the open competitive process which resulted in the selection of the successful contractor.

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

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

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

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

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 both Phases I and II. This represents an update of the similar study done for the IPC Licence 483, with more project-specific data and a newer version of the ISC-3 model. The full report of the study is given in Appendix A.

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

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

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

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

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

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

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

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

The main results are summarised in Table 9 below. All are within the Air Quality Objectives. The maxima occur within 1 km of the site, to the east or north-east.

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

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

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

Irish Air Quality Objective

NO2 19th hourly average

73.5 73.5 104.7 200

annual average

2 1.7 – 40

SO2 25th hourly average

– – 129.6 350

4th 24 hour average

– – 47.6 125

Table 9. Predicted Air Quality Impacts, µg/m³.

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

9.2.2 Attachment I2 – Surface Water Emissions All discharged water is routed to the adjacent land drains. The quantity of discharge is minimised by recycling a large proportion of process drains. The volume of discharge is small compared to the quarry dewatering flows, so that the impact of the power station is insignificant.

9.2.3 Attachment I4 – Groundwater Emissions Geotechnical surveys have shown that the permeability of the soil is low. Infiltration of water to groundwater will therefore be low. The impact both from construction and operation of the plant will therefore be insignificant.

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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, lubricating oil, turbine jacking oil and ammonia. Measures are in place to prevent these substances reaching groundwater. The distillate fuel oil is stored in a dedicated blind 110% capacity bund. Lubricating and jacking oils are contained within closed, bunded systems. Ammonia is stored in either a bunded area or double skinned tanks and excess ammonia in process drains is removed within the waste water treatment plant before release. The risk of contamination of groundwater is therefore insignificant.

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 The existing IPC Licence 483 includes sound pressure levels at noise sensitive receptors for the combined effects of both Phases I and II. The limits, as L90 (30 minutes) are 45 dB(A) by night and 55 dB(A) by day. In addition there shall be no clearly audible tonal or impulsive noise at these receptors. Completed Table I.7(i) of the Application Form defines four receptors at which noise will be monitored. Table 10 identifies these receptors and lists the noise contributions from Phases I and II, as described below.

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No. Location Measured sound pressure level at receptors during Phase I operation, L90 dB(A)

Contribution from Phase I extrapolated from site boundary measurements, L90 dB(A)

Calculated allowed contribution from Phase II, L90 dB(A)

1 Residence at Kilshane Road, ~1200m magnetic WNW of acoustic centre

36.5 36 44

2 Residence at Ashbourne Road, ~520m magnetic ESE of acoustic centre

42.5 37 44

3 Residence Woodlands, ~1200m magnetic NNW of acoustic centre

39.5 35 44

4 Occupied Bungalow at Ashbourne Road, ~ 390m magnetic E of acoustic centre

43.0 40 43

Table 10. Noise Impacts at Nearby Residences

In order to assess the contribution of Phase II to the noise at these receptors, it is necessary to determine the contribution from the existing Phase I plant. Witnessed acceptance tests by the main contractor for Phase I in November 2002 demonstrated compliance with the limits during base load operation on natural gas firing, with night time L90 values at the four locations identified in Table I.7(i) of the application form of 36.5, 42.5, 39.5 and 43.0 dB(A) respectively. The contribution to these measurements from Phase I plant – excluding other sources of noise – was determined by extrapolation from site boundary measurements, as L90 values of 36, 37, 35 and 40 dB(A) respectively.

The main contractor for Phase II has undertaken a noise modelling study to determine the allowed contribution from Phase II to the overall night time noise limits at the receptors. Using the existing contributions from Phase I, they determined that the allowed contributions from Phase II at locations 1 to 4 would be 44, 44, 44 and 43 dB(A) respectively. A preliminary noise map showing the predicted distribution of noise from both Phases, in an area including the two closest receptors nos. 2 and 4, is shown as Figure C2 in Appendix C.

Plant is being designed to ensure that the sound pressure level contributions at the receptors do not exceed these allocations. Low noise equipment and acoustic insulation have been selected to minimise the contribution of Phase II. Foundations are being laid at strategic locations to enable the erection of acoustic shields, should these be necessary.

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9.3 Attachment I8 – BAT Arguments and Mitigation Measures

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

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

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

Discharge of process water waste is mitigated by recycling, where possible, and by treating the final effluent before release. When possible, boiler blowdown is recycled to the raw water tank and a portion of sampling drains returned to the steam/water cycle. Effluent pH is adjusted by acid or caustic dosing to within an acceptable range. Sodium hypochlorite is added to remove most of the ammonia and sodium bisulphite is dosed to remove excess residual chlorine.

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

The gas turbine uses dry low emission burners so that no demineralised water is required to ensure compliant emissions of NOx. Demineralised water injection is required for firing on distillate oil but these occasions will be very infrequent.

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9.3.4 Other Raw Materials The conditioning chemicals used for boiler water and feedwater are supplied in, and dispensed from, IBCs. This minimises the risk of contact with operating personnel and release to the environment. The preferred compounds are generally of low toxicity. 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 50 mg/Nm³ (at reference conditions of 15%v oxygen, dry, 0ºC, 1013 mbar a) on natural gas firing to comply with the “achievable release” defined in the UK Environment Agency draft IPPC Sector Guidance Note, Combustion Activities. The burner design adopted for this project is supplied with a commercial guarantee to meet this limit at loads above 50%. Similarly, NOx concentration is guaranteed not to exceed 120 mg/Nm³ on distillate oil firing (with water injection) above 65% load, which is consistent with the UK Environment Agency draft IPPC Sector Guidance Note achievable release of 125 mg/Nm³.

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

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

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

9.3.7 Energy Efficiency

PB Project No 61825B.

The management of energy will be an integral part of the Environmental Management System with energy policies integrated into the overall environmental policy. Staff training aimed at minimising energy use and developing good housekeeping techniques will be a

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fundamental part of the staff’s initial training programme and subsequent refresher courses. One of the key environmental aspects will be the assessment of energy use and its minimisation through well targeted improvement plans. Such an improvement plan will be managed through procedures and will identify the areas where energy is utilised, identify potential energy efficiency measures and ensure that their financial viability is appraised. This process will be initiated once the 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 Emissions to air will be monitored in the exhaust flue for the significant pollutants (NOx and CO) continuously, in accordance with the LCPD amendment. Additional sampling arrangements comprising four ports at right angles in the same plane are provided, as well as provision for another port for independent gas monitoring. These arrangements are in accordance with UK Environment Agency Technical Guidance Document M1, which is consistent with BS EN 13284-1 (2002). Oxygen is monitored on-line in the HRSG flue. There are no other continuous emissions to air.

The discharge from the process drains waste water treatment plant is continuously monitored for pH, temperature, flow, ammonia content and conductivity. The pH, ammonia and conductivity measurements are linked to the valving to direct discharge either to release (if compliant) or recycled to the treatment plant (if not). 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 have been identified to ensure that far field noise limits will be complied with, should they be necessary.

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

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

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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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 existing Emergency Incident Response Plan managed by the operator GenSys. This Plan includes responsibility for both Phases I and II. The Plan, currently as version 6 dated September 2002, is continually reviewed and updated.

Components of the Plan include:

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

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

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

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

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

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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

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

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

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

Table 12. Suite of Safety Procedures.

PB Project No 61825B.

File : Application support Huntstown Phase II text.doc

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

6.3

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

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

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

6.7 Insurance Reporting Fire and Evacuation 6.8

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

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

Table 13. Contents of Emergency Incident Response Plan

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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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, VPL 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, VPL 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 14.

Equipment Resources Timescale months

Net Cost, €

Comments

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

Heat Recovery Steam

10 3 1 million Includes high value alloy materials for re-use.

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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PB Project No 61825B.

Equipment Resources Timescale months

Net Cost, €

Comments

Generator Dismantled on site Units removed from site

Steam Turbine 10 2 Nil Units removed from site Generator 10 1 Nil Units removed from site Air Cooled Condenser

10 3 100,000 Dismantled on site

Auxiliary Boiler 5 1 30,000 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 Closed Cooling Water Cooler

5 1 50,000 Units removed from 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 tank 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

Table 14. Main Decommissioning Plant Elements.

11.1.5 Hazardous Waste Hazardous waste including waste solvents, waste oils, solid waste, fluorescent tubes and other hazardous waste requiring disposal/recovery will be sent to an agreed waste disposal/recovery site as per the IPPC Licence conditions.

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 as per the IPPC Licence.

11.1.7 Buildings Security Prior to decommissioning, all buildings will be secured to prevent unauthorised 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 and waste water

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

In accordance with the terms of the IPPC Licence, 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 VPL. 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 2 years from the date of last production. This will be determined by the nature of the obsolescence of the plant, and the

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success of 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.

PB Project No 61825B. File : Application support Huntstown Phase II text.doc

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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 15 below indicates where each condition is addressed.

Sub-clause 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”

Attachment I2 in Section 9.2.2

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”

Attachment I7 in Section 9.2.6

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 minimised or, … disposed of in a manner which will prevent or minimise any impact on the environment”

Attachment I6 in Section 9.2.5

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

Table 15. References to Section 83 of the EPA Acts

12.1.2 Habitats Directive The EIS submitted with the planning application confirms that the site not listed as an Area of Scientific Interest (ASI), nor is it proposed as a National Heritage Area (NHA) or Special Area of Conservation (SAC). It is not a known site for any legally protected plant species or

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habitat type. It is understood that no site within 10 km of the power station falls within any of the categories of:

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

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. Irrespective of the classification of the water ultimately receiving any aqueous discharge from the proposed Phase II plant, it is considered that no significant impact will arise because under normal circumstances no phosphate will be used by the plant and discharged within its effluent. Phosphate on site is restricted to a supply of trisodium phosphate for dosing into boiler water at times of transient water quality. Since the plant is air cooled, the risk of ingress of acid forming impurity prompting the use of phosphate to counter such acid formation is very low.

The estimated quantity of trisodium phosphate stored on the site is 1 tonne. The expected maximum quantity of trisodium phosphate to be discharged over a year, as declared in Table G1(i) of the Application Form is 0.2 tonne (of which phosphate ion PO4

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

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