Date: 12 th December 2013

Transcription

1 Mr Ross Taylor Parsons Brinckerhoff Amber Court William Armstrong Drive Newcastle Upon Tyne NE4 7YQ Our ref: EPR/FP3838EB/A001 Your ref: EPR/FP3838EB/RFI Date: 12 th December 2013 Dear Mr Taylor We need more information about your application Application reference: EPR/FP3838EB/A001 Operator: C.GEN Killingholme Limited Facility: C.GEN Killingholme Thank you for your application. Unfortunately I need to ask you for some more details before I can decide whether it is suitable for being duly made or not. The following is to confirm our conversation of 5 th and 12 th December Please provide a response to the following points: Point 1: H1 Assessment and Detailed Modelling When we consider your application for a permit, we must be sure that you are going to take the necessary measures to protect the environment and ensure that what you are doing will not pose an unacceptable risk. The submitted H1 assessment and detailed modelling, specifically for air, do not follow the Environment Agency s recommended H1 guidance or, what we believe to be a similar methodology. The supporting information provided has been prepared for a planning application and does not cover all of the required environmental considerations. Please review your H1 assessment and detailed modelling in line with our H1 Guidance and appropriate Annexes. Please ensure that you provide an assessment for ALL potential sources of emissions, both short and long term, and consider all relevant receptors and relevant environmental standards and critical loads; in line with our H1 Guidance. Point 2: Form EPB, Application for an environmental permit Part B3 New bespoke installation permit, Table 1a Types of activities Based on the information provided, we believe that the regulated facilities you are applying for will include additional activities to those you have stated in Table 1a of Form EPB, PartB3. With reference to Schedule 1 of the Environmental Permitting Regulations (amended 2013) please review your proposals and where necessary revise Table 1a of Application Form EPB, Part B3. We have provided a list of activities below, based on the information provided, that we believe apply to your installation; this is not an exhaustive list: S1.1A(1)(a) Burning any fuel in an appliance with a rated thermal input of 50 or

2 more megawatts; S1.2A(1)(d) - Gasification or liquefaction of coal or other fuels in installations with a total rated thermal input of 20 megawatts or more; S1.2A(1)(a) Refining gas where there is likely to involve the use of 1,000 or more tonnes of gas in any 12 month period; S5.4A(1)(a)(i) Disposal of non-hazardous waste with a capacity exceeding 50 tonnes per day (or a 100 tonnes per day if the only waste treatment activity is anaerobic digestion) involving one or more of the following activities, and excluding activities covered by Council Directive 91/271/EEC concerning urban waste water treatment - biological treatment; S5.4A(1)(a)(iv) Disposal of non-hazardous waste with a capacity exceeding 50 tonnes per day (or a 100 tonnes per day if the only waste treatment activity is anaerobic digestion) involving one or more of the following activities, and excluding activities covered by Council Directive 91/271/EEC concerning urban waste water treatment treatment of slags and ashes; S6.10A(1)(a) Capture of carbon dioxide streams from an installation for the purposes of geological storage pursuant to Directive 2009/31/EC of the European Parliament and of the Council on the geological storage of carbon dioxide. Point 3: Form EPB, Application for an environmental permit Part B2 general new bespoke permit, Section 3 You have claimed accreditation to ISO14001 for an environmental management system. The information supplied suggests that your EMS has not yet been designed or written. Therefore you cannot claim to be externally verified or have an accredited EMS unless you provide the relevant registration numbers and certificates. If you are able to supply these details then you may reflect this in your Opra profile, otherwise you cannot claim credit for this. Please amend Application Form Part B2 and your Opra profile to reflect this change (this may affect the application fee). Point 4: Form EPF, Application for an environmental permit Part F1 Opra, charges, declarations Following completion of Point 2 and Point 3 (as shown above) please revise your Opra profile and Application Form Part F1 as appropriate, this will include the re-calculation of the application fee and you must submit any extra fees required. Point 5: Form EPB, Application for an environmental permit Part B3 New bespoke installation permit, Appendix 1 Question 1 Please confirm whether you are applying for a maximum biomass combustion figure of 30%, or, as some sections of the application indicate, 100% combustion (e.g. Section , Application For a New Bespoke Environmental Permit, report reference: 64042C/1.1). If it is intended to operate the plant at 100% biomass then the impact of any emissions must be assessed using our H1 guidance or equivalent methodology. Point 6: Form EPB, Application for an environmental permit Part B3 New bespoke Installation permit, Table 2 The height and location of all emission points must be clear and fixed. The application (Section 3.3, Application for a New Bespoke Environmental Permit, report reference: 64042C/1.1) says that the data is indicative which is not acceptable for the determination of the permit. Provide exact details of all emission points including their height and location. Please note, any change to the location, height or dimensions of these sources would require you to re-assess the potential impacts of emissions on the environment and human health.

3 Point 7: Form EPB, Application for an environmental permit Part B3 New bespoke Please provide details of the design of the waste water treatment plant (referred to in Section , Application for a New Bespoke Environmental Permit, report reference: 64042C/1.1), including any treatment chemicals to be used and the impact of any emissions from this plant must be assessed using our H1 guidance or equivalent methodology. Point 8: Form EPB, Application for an environmental permit Part B3 New bespoke Provide details of the proposed design and operation of the carbon capture plant (referred to in Section Application for a New Bespoke Environmental Permit, report reference: 64042C/1.1) including details of any chemicals used within the plant and how they will be stored, volumes required, waste streams and emissions. The impact of any emissions from this plant must be assessed using our H1 guidance or equivalent methodology. Point 9: Form EPB, Application for an environmental permit Part B3 New bespoke Please provide design details of the auxiliary boilers including the number and size (referred to in Section , Application for a New Bespoke Environmental Permit, report reference: 64042C/1.1) and all associated emission points (including their location on the site plan). Assess the impact of emissions from these units using our H1 guidance or equivalent methodology. Point 10: Form EPB, Application for an environmental permit Part B3 New bespoke Provide details of the diesel generators (referred to in Section and Application for a New Bespoke Environmental Permit, report reference: 64042C/1.1) including the number and size; and provide details of all emission points (including their location on the site plan). Provide a BAT justification for using this type of equipment, rather than other generating plant. Assess the impact of emissions from these units using our H1 guidance or equivalent methodology. Point 11: Form EPB, Application for an environmental permit Part B3 New bespoke Installation permit, Question 4a Describe the measures you will use for monitoring of additional emissions identified for the above plant. Point 12: Form EPB, Application for an environmental permit Part B2 general new bespoke permit, Question 7 The assessment of the emissions to air for the various scenarios is inadequate for the determination of the permit. Resubmit the assessment taking into account the following: The assessment should use our H1 methodology or equivalent; The assessment does not cover all potential pollutants ( e.g. metals, HCL, HF etc); It does not assess against all required EQS s (e.g. the 15 min SO 2 EQS); It does not provide the maximum process contribution figures or the predicted environmental concentrations; For the assessment of impacts on habitats, acid deposition is not considered nor are impacts assessed against most of the critical levels given in H1, Annex F - Table B4: Critical Levels For The Protection Of Vegetation And Ecosystems ; and No assessment has been made for local wildlife sites using the critical loads mentioned in the point above or the critical levels available on the APIS website.

4 There is no assessment of the impacts from the sour gas flare stack or of the plant items mentioned earlier such as the carbon capture plant, auxiliary boilers, diesel engines etc. Point 13: Form EPB, Application for an environmental permit Part B2 general new bespoke permit, Question 7 Application form part B2, question 7 The noise assessment should consider the impacts of the noise emissions from the flare stacks, and in particular the impact on habitat sites. Point 14: Form EPB, Application for an environmental permit Part B3 New bespoke Installation permit, Appendix 1 Question 2 Provide composition data for all fuels to be used, including coal, petroleum coke and biomass. You should consider parameters such as metals and halides etc, as a maximum percentage weight for weight on a dry basis. Point 15: Air Dispersion Modelling Please provide all model input files for all air dispersion modelling undertaken in support permit application EPR/FP3838EB/A001 to enable us to audit your results and conclusions. Point 16: Air Quality Management Areas (AQMA) From the information submitted it appears you have not considered all relevant Air Quality Management Areas including Hull AQMA No1(A). Table does not include details of this designation and you have not considered or assessed the potential impact of emissions on this AQMA. Please ensure you have considered all AQMA s and provide the assessments that you have undertaken to review the potential impacts from emissions on site. Point 17: Detailed Noise Modelling Please provide model input files and data for the noise modelling undertaken to support permit application EPR/FP3838EB/A001 to enable us to audit your results and conclusions. Point 18: Best Available Techniques (BAT) Where there is a choice of alternative measures you should explain your choice on the basis of costs and benefits following our H1, Annex K guidance and methodology. Please complete a cost benefit analysis and further detailed BAT appraisal where alternative options are available and identified around your choice of plant. For example, within your application, (Section 4.2.9, Application For a New Bespoke Environmental Permit, report reference: 64042C/1.1) it is stated A small combustor unit may be installed at the exit of the Claus units for use during their start-up, as an alternative to sending this sour gas to the Flare Stack. For note, in order for us to complete our review and assessment we require you to confirm which plant will be installed for use and how you have come to this decision. Additionally, you must justify why you have chosen to combust solid fuel in an IGCC facility as opposed to other alternative options. Please reply within 10 working days from the date of this letter. If we don t hear from you we must return your application and fee. Please send all correspondence to myself and Simon Paterson, contact details have been given below. If you or write to us please quote the application reference EPR/FP3838EB/A001 on any correspondence and send it to the relevant address below. When we receive the missing items we will continue to check the details in your application. If there s enough for us to begin the process of deciding whether or not we can grant your application we say the application is duly made and we ll let you know this by letter. If you have any questions then please phone me on or Matt.Derbyshire@environment-agency.gov.uk. In the event that I am unavailable, please contact Simon Paterson on or Simon.Paterson@environmentagency.gov.uk.

5 Yours sincerely, Matt Derbyshire Senior Permitting Officer