NORTH KILLINGHOLME POWER PROJECT APPLICATION FOR A NEW BESPOKE ENVIRONMENTAL PERMIT

Transcription

1 NORTH KILLINGHOLME POWER PROJECT APPLICATION FOR A NEW BESPOKE ENVIRONMENTAL PERMIT C.GEN Killingholme Ltd 64042C/1.1 Finl

2 North Killingholme Power Project 64042C/1.1 Prepred for C.GEN Killingholme Ltd Clough Lne Killingholme North Lincolnshire DN40 3JP Prepred y Prsons Brinckerhoff Willim Armstrong Drive Amer Court Newcstle upon Tyne NE4 7YQ +44 (0)

3 CONTENTS Pge LIST OF ABBREVIATIONS 3 INTRODUCTION 7 1 Introduction North Killingholme Power Project Purpose of this Document 9 APPLICATION FORMS 13 2 Appliction Forms [to e inserted in finl pdf] Prt A Aout You Prt B2 Generl New Bespoke Permit Prt B3 New Bespoke Instlltion Permit Prt F1 OPRA, Chrges nd Declrtions 15 INFORMATION IN SUPPORT OF FORM B Informtion in Support of Form B Discussions efore the Appliction Aout the Site Supporting Informtion Plnning Sttus Aility s n Opertor Environmentl Risk Assessment 30 INFORMATION IN SUPPORT OF FORM B Informtion in Support of Form B Wht Activities Are Applied For? Emissions to Air, Lnd nd Wter Operting Techniques Generl Requirements Types nd Amounts of Rw Mterils Comustion Sector Monitoring Environmentl Impct Assessment Resource Efficiency nd Climte Chnge 86 PROPOSED IMPROVEMENT PLAN 97 5 Proposed Improvement Pln Introduction Improvement Pln Pre-Opertion Conditions

4 LIST OF ABBREVIATIONS µg/l µg/m 3 µs/cm AEL AGR AQMAU ASU r g BAT BREF CCGT CCS CHP-R CO CO2 CPK DAA d(a) DCO DCS DLN EA EAE EMS EP EQS ES EU ETS g/s H2S H2S HRSG ID IED IGCC ISO microgrms per litre microgrms per cuic metre microsiemens per centimetre Associted Emissions Level cid gs removl Air Qulity Modelling nd Assessment Unit ir seprtion unit guge pressure est ville techniques Reference Document on Best Aville Techniques comined cycle gs turine cron cpture nd storge comined het nd power-redy cron monoxide cron dioxide C.RO Ports Killingholme Ltd Directly Associted Activity deciel (A-weighted) Development Consent Order distriuted control system dry low-nox Environment Agency environmentl spects evlution Environmentl Mngement System Environmentl Qulity Stndrd Environmentl Sttement EU Emissions Trding Scheme grms per second hydrogen sulphide hydrogen sulphide het recovery stem genertor initil dilution Industril Emissions Directive integrted gsifiction comined cycle Interntionl Stndrds Orgnistion -3 -

5 kg kilogrm kg/s kilogrms per second LCP lrge comustion plnt LHV lower ehting vlue LNB low-nox urners LoW List of Wstes m metre m/s metres per second m3 cuic metre m3/dy cuic metres per dy m3/s cuic metres per second mg/l milligrms per litre mg/nm3 milligrms per Norml cuic metre MJ/m3 megjoules per cuic metre MSL Minimum Stle Lod MWe megwtt electricl MWe megwtt electricl MWth megwtt therml N2 nitrogen NETS Ntionl Electricl Trnsmission System NOx oxides of nitrogen NSIP Ntionlly Significnt Infrstructure Project oc degrees Celsius OPRA Opertionl Risk Apprisl OS Ordnnce Survey PA 2008 Plnning Act 2008 PCB Polychlorinted iphenyl PINS Plnning Inspectorte PM10 prticulte mtter of less thn 10 microns dimeter ppm prts per million rwfd Revised Wste Frmework Directive SAC Specil Are of Conservtion SCR Selective Ctlytic Reduction SO2 sulphur dioxide SPA Specil Protection Are SRU Sulphur Recovery Unit STU Sttionry Technicl Unit TGTU Til Gs Tretment Unit _1.docx Error! Unknown document property nme Prepred y Error! Unknown document property nme. for Error! Unknown document property nme.

6 TSS WWTP totl suspended solids Wste Wter Tretment Plnt -5 -

7 SECTION 1 INTRODUCTION -7 -

8 1 INTRODUCTION 1.1 North Killingholme Power Project C.GEN Killingholme Limited ("C.GEN") is seeking to develop new 470 megwtt electricl ("MWe") therml generting sttion ("Generting Sttion") nd ssocited development ("North Killingholme Power Project "/ the "Project") on lnd djcent to the C.RO Ports Killingholme Ltd ("CPK") Terminl t North Killingholme, North Lincolnshire The Generting Sttion is intended to operte either s Comined Cycle Gs Turine ("CCGT") plnt or s n Integrted Gsifiction Comined Cycle ("IGCC") plnt. The Generting Sttion will e designed to provide totl genertion cpcity of up to 470 MWe under norml operting conditions When operting s CCGT plnt, the Generting Sttion would e fired on nturl gs which would e otined from existing high pressure gs supply networks in the re. When operting s n IGCC plnt the Generting Sttion would e fuelled y col (principlly), possily lended with petroleum coke ("petcoke") or iomss from which syngs will e produced to fuel the generting sttion. It my lso operte on iomss lone in certin circumstnces. The use of gsifiction technology will provide gret del of flexiility with respect to the choice of fuels. To llow the Generting Sttion to operte s n IGCC plnt, gsifiction equipment would e constructed in ddition to the items of plnt comprised in the CCGT plnt The Generting Sttion will e Ntionlly Significnt Infrstructure Project ("NSIP") s defined y the Plnning Act 2008 (s mended y the Loclism Act 2011) ("PA 2008"). On 25 Mrch 2013, C.GEN sumitted n ppliction for development consent order ("DCO") to the Secretry of Stte for Energy nd Climte Chnge 1 to uthorise the construction nd opertion of the Project. Tht ppliction ws ccepted y PINS on 19 April 2013 nd Exmintion of the ppliction commenced on 12 Septemer Purpose of this Document The Project will comprise two instlltions s defined in Prgrph 1, Prt 1, Schedule 1 of the ting (Englnd nd Wles) Regultions 2010 (s mended) ("EP Regultions") s: sttionry technicl unit where one or more ctivities re crried on. The instlltions will e Power Islnd, comprising gs turine operting in comined cycle, nd Gsifiction Plnt C.GEN will e the only owner / opertor of the Project. As the instlltions will e crried out y the sme opertor on the sme site, opertion of the Project will therefore require single issued y the Environment Agency ("EA") (s the regultor, of oth instlltions) under Section 13(1) of the EP Regultions There will e no interctions etween the Project / C.GEN nd other holders of s. 1 Though the Secretry of Stte ers legl responsiility for the ppliction, the Government hs mde the decision to delegte responsiility for ccepting nd exmining pplictions to the Plnning Inspectorte ("PINS"). Decisions on pplictions for development consent in respect of energy projects will e tken y the Secretry of Stte for Energy nd Climte Chnge. -9 -

9 1.2.3 As the proposed opertor, this document is sumitted y C.GEN to present the forml ppliction for new espoke for the North Killingholme Power Project (s per the requirements of Section 2(1), Prt 1, Schedule 5 of the EP Regultions). Document Structure In order to provide ll the relevnt informtion with which the EA cn determine this ppliction, this document provides the following: Appliction Forms: i Form A; ii Form B2; iii Form B3; nd iv Form F1; c Supporting Informtion; nd Proposed Improvement Pln (including suggested improvement conditions tht C.GEN considers should e included in the finl ) The Opertionl Risk Apprisl ("OPRA") spredsheet for the clcultion of the complexity of the Project (s the instlltion ) is included s Appendix A to this document. Terminology The Appliction Site for the purposes of the ppliction for the (s shown in Figure 1), refers to lnd within the oundry of the DCO ppliction nd is the equivlent of the Principl Project Are. It does not contin the Electricl Grid Connection Lnd; nd Gs Connection Lnd s referred to in the DCO ppliction The Electricl Grid Connection nd Gs Connection for the Project will not e suject to control under the EP Regultions nd re therefore not included in this ppliction The Principl Project Are includes: Opertions Are (Figure 2) This is the lnd proposed for the Generting Sttion itself (the NSIP); Fuel Hndling Ares (Figure 3) These comprise the loctions for the fcilities needed to supply nd store solid fuel for the Project vi ril or se nd conveyors; nd -10 -

10 c Cooling Wter Connection (Figure 4) This will comprise n intke nd outfll from the River Humer, round the existing CPK jetties The proposed oundry for the will e within the Principl Project Are. Development Scenrios IGCC opertion of the Project, with cron cpture nd storge, would tke plce when solution for trnsporting nd storing the cptured cron dioxide ("CO 2 ") from the Project is in plce, except in certin circumstnces which re governed y the requirements proposed to e ttched to the DCO. Currently, vile trnsport nd storge system is not ville. It is nticipted tht, in due course, CO 2 trnsport infrstructure will ecome ville through which cptured CO 2 could e trnsported for storge in empty gs / oil fields or deep sline formtions under the North Se ed Where other IGCC power plnt operting scenrios would pply (such s opertion with no CO 2 cpture, or iomss-only production of syngs), the shift rector would e ypssed (per Prgrph elow), enhncing power plnt efficiency. Becuse of the higher power plnt efficiency when the IGCC is operting without CCS, opertion of the IGCC with CO2 cpture represents the worst cse scenrio in terms of emissions to ir nd wter nd hs formed the sis for ssessments in the Environmentl Sttement nd this EP Appliction Bsed on the ove, there re numer of different development scenrios for the Project. The scenrio(s) tht will ultimtely e implemented will reflect the nture of the electricity mrket nd other fctors t the time of construction, nd tht re not necessrily identifile t this stge. As result, rnge of construction / opertion scenrios hve een considered within the DCO ppliction For the purposes of the DCO ppliction the following terminology, s it reltes to n ppliction for n (which considers opertionl impcts only), ws used: Scenrio B Opertion of Generting Sttion s CCGT plnt Scenrio D Opertion of Generting Sttion s CCGT plnt with susequent construction of the Gsifiction Plnt Scenrio E Opertion of Generting Sttion s n IGCC plnt For the purposes of this ppliction for new espoke, the operting scenrios will, herefter, e referred to s: -11 -

11 Opertion s CCGT plnt (Scenrios B nd D); nd Opertion s n IGCC plnt (Scenrio E) In ddition to the ove scenrios, the ES identifies further suset of scenrios reflecting different fuels to e used when the Generting Sttion is operting s n IGCC power plnt. The selected operting mode could e comintion of two of the scenrios mentioned elow. These re: Scenrio E1 Pulverised solid fuel supplied to the gsifier will comprise 100 per cent col; Scenrio E2 Pulverised solid fuel supplied to the gsifier will comprise mixture of 70 per cent col nd 30 per cent petcoke; Scenrio E3 Pulverised solid fuel supplied to the gsifier will comprise mixture of 70 per cent col nd 30 per cent iomss (in the form of torrefied iomss); nd Scenrio E4 Nturl gs to e comusted within the gs turine(s) in the event of the Gsifiction Plnt eing unville It is noted tht for opertion s n IGCC plnt (Scenrio E), the worst cse environmentl performnce of the Project is opertion with CCS (Scenrios E1 to E3), therefore ll susequent emissions dt nd ssessments relte to this cse

12 SECTION 2 APPLICATION FORMS -13 -

13 2 APPLICATION FORMS 2.1 Prt A Aout You 2.2 Prt B2 Generl New Bespoke Permit 2.3 Prt B3 New Bespoke Instlltion Permit 2.4 Prt F1 OPRA, Chrges nd Declrtions -15 -

14 SECTION 3 INFORMATION IN SUPPORT OF FORM B2-17 -

15 3 INFORMATION IN SUPPORT OF FORM B2 3.1 Discussions efore the Appliction The EA is sttutory consultee in respect of pplictions for DCO to uthorise construction nd opertion of n onshore therml generting sttion with cpcity of more thn 50 megwtts ("MW") Under the Infrstructure Plnning (Environmentl Impct Assessment) Regultions 2009 ("EIA Regultions"), production of n Environmentl Sttement ("ES") is mndtory for NSIPs comprising therml generting sttion with het output of 300 MW or more. As the cpcity of the Generting Sttion will exceed this threshold, the Generting Sttion is n NSIP for which n EIA is required to e undertken C.GEN hs met with officers of the EA on severl occsions s prt of the preppliction consulttion process for the DCO ppliction in order to discuss the proposls for the Project nd consulttion is on-going in reltion to tht ppliction Specific meetings relting to ting for the Project were held on: 28 August 2013 Kick-off meeting for the Appliction; nd 9 Octoer 2013 Pre-ppliction meeting to discuss drft ppliction documents At these meetings, the EA ws represented y Principl Permitting Officer from the Ntionl Permitting Service nd the Regultory Officer responsile for the re where the Project will e locted. 3.2 Aout the Site Site Loction The Principl Project Are is pproximtely 5 km north west of Imminghm Docks, s shown in Figure 1, on lnd djcent to CPK The ddress of the lnd comprising the Opertions Are is: C.GEN Killingholme Ltd Clough Lne Killingholme North Lincolnshire DN40 3JP The Ordnnce Survey ("OS") Ntionl Grid Reference for the centre of the Opertions Are is pproximtely TA Figure 5 shows the proposed oundry for the

16 Type of Regulted Fcility / Activity The Project, eing comintion of ctivities listed in Schedule 1 of the EP Regultions, will represent two instlltions for the purposes of regultion under the. The two instlltions will e the Power Islnd, comprising gs turine operting in comined cycle, nd Gsifiction Plnt The detils of the ctivities re presented nd descried in Section 4.1 of this document. 3.3 Supporting Informtion Site Plns The proposed lyout for the Project is such tht there is logicl rrngement of the key elements such tht: c d Fuel storge fcilities (s pplicle) re to e provided s close s possile to the potentil delivery mens; The gs nd stem turines in the Power Islnd re locted to the south nd west of the Opertions Are in order to fcilitte the export of electricity to the Ntionl Grid Electricity Trnsmission System ("NETS"); The hyrid cooling towers re locted with regrd to the previling south westerly winds to mximise the operting efficiency; nd The elements of the Gsifiction Plnt re rrnged such tht ech stge of the process, from solid fuel preprtion to the supply of gseous fuel to the gs turine(s), is djcent to the next, s fr s prcticle The proposed lyouts of the Project re shown in Figure 6 (Scenrio B) nd Figure 7 (Scenrio E), which lso show the conceptul oundry of ech of the sttionry technicl units ("STU"), s pproprite. Further detil of ech of the nticipted STUs (the Power Islnd nd the Gsifiction Plnt) is provided in Section 4.1 of this document The nticipted emissions points, in line with the definition of the STUs nd the DAAs presented in Section 4.1, re included on the ove figures. A description of the principl nd fugitive relese points is presented in Tle

17 Tle 1: Summry of Relese Points nd Storge Loctions Ctegory Description / Identifiction Identity on Site / Lyout Plns Air Mjor Releses Min Stck A1 Flre Stck A2, A3 Minor Releses Acid tnk (wter tretment) vent scruer M1 Fuel milling / drying / preprtion M2 Comustion units (relted to sulphur recovery strt-up) M3, M4, M5 CSU fuel unloding M6 On-Site Covered Fuel Storge S1 Other Fuel Storge S2 Slg Storge S3 Filter Cke Storge S4 Wter Mjor Releses Cooling Wter / Comined Effluent Dischrge W The emissions points presented in Figure 6 nd Figure 7 re indictive given tht the Project hs not yet een the suject of detiled design process. The finl loctions will e confirmed to the Environment Agency, y C.GEN, s prt of proposed Improvement Condition (see Section 5.3). Site Condition / Bseline Report A Site Condition Report hs een prepred in ccordnce with EA Guidnce Note H5 Site Condition Report Guidnce nd Templtes April The Report is presented s Appendix B to this document. Non-Technicl Summry of the Project The Project is intended to operte either s CCGT power plnt or s n IGCC power plnt

18 3.3.5 When operting s CCGT power plnt, the Project will e fired on nturl gs which will e otined from the existing high pressure gs supply networks in the re When operting s n IGCC power plnt, vriety of fuels my e used to llow the Project to e fired on syngs. The vriety of fuel mixtures include col, either s sole fuel or co-fired with petcoke or iomss, which is sujected to pre-comustion tretment producing the syngs IGCC opertion of the Project, with cron cpture nd storge, would tke plce when solution for trnsporting nd storing the cptured CO 2 from the Project is in plce. Currently, vile trnsport nd storge system is not ville. It is nticipted tht, in due course, CO 2 trnsport infrstructure will ecome ville through which cptured CO 2 could e trnsported for storge in empty gs / oil fields or deep sline formtions under the North Se ed There re certin limited circumstnces in which IGCC opertion of the Project could tke plce without cron cpture nd storge. These circumstnces could pply where: The Government relxes the requirement for cron cpture nd storge, for exmple in response to shortfll in supply of electricity under the terms of the Energy Bill; or The IGCC opertion of the Project tkes plce using iomss s fuel, which does not require cron cpture nd storge In such cses the cron cpture pprtus would e ypssed. Operting Regime The Project is nticipted to operte s se lod plnt (i.e. it will not e suject to regulr significnt fluctutions in the electricl output). Whilst trditionl CCGT plnts re considered flexile, nd cn dopt numer of different operting regimes (such s two-shifting nd lod following), the Gsifiction Plnt is not s flexile nd thus limits the potentil operting regimes for the Project when operting s n IGCC plnt The proposed operting regime will result in pproximtely strt-ups nd shutdowns per nnum. Description of CCGT Power Plnt A CCGT power plnt usully comprises gs turine nd Het Recovery Stem Genertor ("HRSG"), which serves the stem turine equipment During opertion of CCGT power plnt, nturl gs is urnt in the comustion chmer of ech gs turine producing hot, high-pressure gses. These gses expnd through the gs turine to generte electricity. The hot, expnded gses re then used in the HRSG to generte stem, which is in turn used in the stem turine equipment to generte dditionl electricity. The spent stem leving the stem turine equipment will pss to condenser, which is cooled y wter coming from the hyrid cooling towers. The resultnt condenste will e returned to the HRSG for reuse

19 The flue gses will e dischrged into the tmosphere through the Min Stck. The height of the Min Stck will e 80 m. Description of n IGCC Power Plnt To llow the Project to operte s n IGCC power plnt, Gsifiction Plnt is required in ddition to the Power Islnd descried ove. One dvntge of n IGCC power plnt is tht the Gsifiction Plnt could remove CO 2 nd other cron-sed components from the syngs used s fuel in the CCGT, so tht the CO 2 content in the flue gs is minimised. The cptured CO 2 could then e trnsferred to CO 2 trnsport nd storge system. The infrstructure required for CO 2 compression, trnsport nd storge system does not form prt of the Project During opertion of n IGCC power plnt (with removl nd cpture of CO 2 ), solid fuel is prtilly comusted. This produces flmmle syngs mixture which (t this stge) primrily consists of cron monoxide ("CO") nd hydrogen ("H 2 "). The flmmle syngs mixture is scrued to remove ny solids nd wter-solule gses, nd then (to enle removl nd cpture of CO 2 ) is pssed through CO shift rector where wter ("H 2 O") comines with the CO to produce CO 2 nd dditionl H Following the CO 2 shift rector, the flmmle syngs mixture is pssed to n cid gs nd CO 2 removl unit, where the cid gses nd CO 2 re removed. The resulting syngs strem is then mixed with nitrogen ("N 2" ) nd pssed into the comustion chmer of the gs turine There re certin circumstnces where IGCC opertion might tke plce without CO 2 cpture, trnsport nd storge. In such cse, the syngs, fter eing scrued with wter to remove remining solids nd wter-solule gses, will ypss the shift rector. As consequence, the syngs keeps its originl composition consisting minly of H2 nd CO. The ctivted cron filter will remove trces of mercury nd other undesirle sustnces. The AGR equipment is dequte to remove the sulphur compounds produced in the gsifier in this different operting scenrio, soring these cid gses into solvent within the cid gs removl ("AGR") sorer unit. The syngs exiting the sorer could e mixed with nitrogen (from the Air Seprtion Unit ("ASU")) nd / or stem The process for generting electricity then follows tht descried for CCGT power plnt During opertion of n IGCC power plnt, numer of solid wstes will e produced in ddition to those during opertion of CCGT power plnt. These include slg, filter cke (from the gsifier) nd sulphur (from the AGR). The slg is n inert nd vitrified mteril contining minly feedstock sh. The filter cke contins the ulk of the sh seprted from the syngs in the scruer of the gsifiction process. Both slg nd filter cke will e either sold for use in the construction industry or trnsported to n pproprite lndfill site y suitly licensed contrctor. Filter cke cn e lso prtilly recycled to the feedstock yrd. The sulphur will e sold s rw mteril for use in the chemicl industry The Project will incorporte two flre systems constructed within one tower (i.e the support structure, the ldders nd pltters re common to oth flres) to e utilised during emergencies, strt-up nd shut-down of the plnt (i.e. not ordinrily s prt of continuous IGCC opertion): -23 -

20 Flre 1 (min flre), dedicted to the syngs dischrge from the scruer, just efore nd fter the AGR, nd the feed strem efore it reches the gs turine; nd Flre 2 (cid flre), dedicted to the sour gs from the AGR nd Clus units. A smll comustor unit should e instlled t the exit of the Clus units for use during their strt-up, s n lterntive to sending this sour gs to the Flre Stck The flres will llow vrious items of equipment to chieve the correct chemicl composition, pressure nd temperture conditions during strt-up nd prior to norml opertion. The flres will e minly used during emergencies s sfety mesure nd lso used during shut down of the units The height of the Flre Stck will e out 135 m. 3.4 Plnning Sttus As discussed in Section 1.1, the Generting Sttion will e n NSIP s defined y the PA On 25 Mrch 2013, C.GEN sumitted n ppliction for DCO to the Secretry of Stte for Energy nd Climte Chnge ("Secretry of Stte") to uthorise the construction nd opertion the Project The ppliction for the DCO ws formlly ccepted on 19 April 2013 nd the exmintion period commenced on 12 Septemer The sttutory timescles, s prescried y the PA 2008 re s follows: End of Exmintion Period (Mrch 2014); Recommendtion, y PINS, to the Secretry of Stte (June 2014); nd c Decision y Secretry of Stte (Septemer 2014) The Plnning Inspectorte reference numer for the DCO ppliction is EN Aility s n Opertor Mngement Systems The Project will incorporte n Environmentl Mngement System ("EMS") which will e n integrl prt of its overll mngement system. The EMS is defined s the policies, mngement principles, orgnistionl structure, responsiilities, stndrds / procedures, process controls nd resources which re in plce to mnge environmentl protection cross ll spects of the usiness. The EMS will comprise procedures tht will ensure tht the Project opertes s intended nd tht fults nd incidents re detected nd corrected The Project will e operted nd mintined using set of written procedures nd guidnce developed, where pproprite, from the mnufcturer s operting nd mintennce mnuls. A system will e in plce to mintin nd updte these procedures where necessry in order to ensure control on content nd to clerly define the responsiilities of ech individul on the site The EMS will plce prticulr importnce on: -24 -

21 c d e Reducing risks to the environment to level tht is s low s resonly prcticle using est ville techniques; Integrting EMS responsiilities within line mngement; A commitment to personnel environmentl wreness nd competence; The on-going monitoring nd review of environmentl performnce; nd A commitment to working to chieve continuous improvement in environmentl performnce The overll im of the Interntionl Stndrd ISO (which ws formlly issued in Septemer 1996 nd updted in 2004) is to support environmentl protection nd prevention of pollution, in lnce with socio-economic needs, through the development of n EMS. It is the intention to certify the EMS to the ISO stndrd s soon s prcticle fter commissioning nd hnd over of the Project from the construction contrctor to C.GEN Hence, the detiled specifiction of ech component of the EMS will e s descried in this stndrd. However, it is worth riefly outlining the key fetures of the EMS s they ffect the (nd this ppliction for such Permit). Environmentl Mngement System Policy It is the policy of C.GEN tht ll of its operting sites will hve n EMS ccredited to the ISO nd such system will e estlished for the Project Arrngements will e in plce to ensure tht ll employees will e wre of the policy nd its contents, nd to hve copies ville on request. Copies of the policy will e ville to other interested prties, including contrctors. The policy will e reviewed t intervls in line with the EMS mngement review system. Environmentl Aspects Evlution The ISO interntionl stndrd requires tht the environmentl significnce of the Project ctivities is determined y mens of Environmentl Aspects Evlution ("EAE"). It will e the responsiility of C.GEN to develop n pproprite EAE methodology to identify the direct nd indirect effects from its ctivities nd to highlight which sustnces, ctivities or incidents relted to the direct spects of running the Project re likely to hve hrmful effect on the environment. Here environment includes: ir; wter; lnd; flor; fun; humns; nd their interreltion. Any sustnce, ctivity or incident tht hrms, or under the worst cse scenrio hs high-risk potentil to hrm, the environment will e identified s eing "Significnt Aspects" The EAE will ddress (inter li): -25 -

22 c d e f g h i j Legl oligtions; Significnt environmentl emissions nd dischrges; Indirect environmentl effects; Humn helth issues; Issues of pulic concern; Implictions of modifying plnt; Implictions of the use of new sustnces; Implictions of Contrcts; Opertionl risks; nd Norml opertion, emergency, mintennce nd modifiction regimes Aspects which re identified s Significnt Aspects will e ssocited with procedures/tsks which monitor, mesure, control, mitigte or otherwise mnge the issue. These will cover (inter li): c d e f g h i Energy use; Monitoring; Emission control; Fugitive emissions; Noise nd virtion; Wste minimistion; Rw mteril nd wter minimistion; Odour; nd Responsiilities nd procedures Ech Significnt Aspect will e controlled through procedures tht identify the relevnt responsiilities of mngers nd stff C.GEN (nd its stff) will e responsile for estlishing nd mintining tsk control nd recording systems in order to fulfil their llocted environmentl tsks. All stff will e responsile for working in ccordnce with procedures imed t environmentl complince

23 Monitoring, Control nd Chnge Mngement The primry mechnism tht ensures Opertionl Control is the Significnt Aspects List, which is generted from Risk Assessments nd Aspects Evlution. Procedures will ddress ech of these significnt issues nd generte the informtion nd dt necessry to monitor dequtely the Project s environmentl performnce, ensure chievement of trgets nd develop understnding of the performnce of the Project so s to identify fults, identify further improvements nd to optimize mintennce routines. Inventories of emissions, wter use, wstes nd rw mterils will e developed for internl mngement nd externl reporting purposes Environmentl issues relting to routine nd preventtive mintennce will e ssessed under the Environmentl Aspects Evlution. Brekdown nd non-routine requests my require risk ssessment The Mngement Progrmme will e criticl to the controlled implementtion of chnges which my hve environmentl implictions. Ech component of the Mngement Progrmme will comprise description of the issue, the ojective, the responsiility for resolution nd timescle. The issues will originte from considertion of (inter li): c d e f g h i New legl oligtions; Results of routine monitoring ctivities; Commercil undertkings; Improvement trgets set y C.GEN; Review of the Environmentl Aspects Evlution; Complints or suggestions from the pulic; Stff suggestions; Plnt chnges; nd Non-complinces. Trining Environmentl trining will relte to oth generl wreness nd e jo-specific Mngement nd stff will hve ckground pproprite to their discipline nd will hve een trined in the opertion of the Project y prcticl nd clssroom techniques. Experienced stff will e seconded for use in trining opertionl stff, where possile, nd equipment mnufcturers nd suppliers will e utilised where pproprite to supply trining, s will specilised consultnts Stff trining requirements will e regulrly pprised with courses for updting skills nd fmiliristion with new techniques. All stff will e trined on procedures to minimise emissions nd to mnge non-norml opertion of the Project or environmentl emergency situtions

24 For ech individul role, competence nd trining profile will e produced sed on the jo requirements. This will del with Sttutory, Environment nd Technicl Issues s well s Personl Skills nd Qulities. Considertion will e given to the need for the provision of pproprite supervision. Where ssessed s necessry, the pproprite level of supervision will e provided All stff will e required to hve sic wreness of the EMS, C.GEN s policies, significnt environmentl spects nd implictions of their re of opertion s well s their roles nd responsiilities in complying with EMS requirements Ech individul s knowledge nd skills will e ssessed nd mtched ginst the needs of the jo position. This will identify ny further experience or trining needs for the individul to llow him to crry out the ssigned jo position. These will then e prioritised nd plnned Trining records will e mintined nd trining needs regulrly reviewed All contrctors nd su-contrctors will e given pproprite trining prior to the commencement of ny works or services. Review nd Audit C.GEN recognises tht continuous improvement requires the on-going repprisl of Environmentl Systems nd Policy in order to ensure tht they remin effective (in line with developing est prctice) nd relevnt to the usiness s whole. An nnul review will exmine ll mngement systems (including the EMS) implemented for the Project to identify ny res where opportunities nd / or potentil exist for improvements. Mngement focus on environmentl performnce will e mintined y review of key indictors t regulr mngement meetings An udit system ensures tht the procedures remin current nd re followed. In order to chieve nd mintin certifiction to ISO 14001, the EMS will hve to e certified y externl ccredited uditors. Their tsk is to ensure tht the EMS meets ll the stndrds required y ISO nd tht the procedures re properly followed Activities nd the EMS of the Project will e udited to n greed progrmme. Activities will e suject to regulr smple uditing nd monitored internlly for complince ginst the EMS, including legl requirements nd C.GEN stndrds. Internl udit will normlly e crried out y site stff with suitle experience nd / or trining with the overll process, nd the internl udit procedure will lso e suject to udit y externl ssessors Audits will lso e crried out on the mngement systems of contrctors nd service providers, y greement nd with their co-opertion Where corrective ction is identified s eing required, through udit (or otherwise), which involves chnges to the EMS or modifictions to the plnt nd equipment of the Project, the implementtion of such chnges will e mnged vi the EMS Mngement Progrmme

25 Ojectives nd Trgets Ojectives nd Trgets will e identified nnully s prt of the usiness plnning cycle nd used to drive overll continuous improvement. In ddition other environmentl improvements my e implemented t ny time through other ctivities on the sttion (for exmple, mintennce ctivities, new improvement conditions nd new developments). Progress towrds Ojectives nd Trgets nd the introduction of chnge is mnged nd monitored using the EMS Mngement Progrmme. Risk Assessment Environmentl risk ssessment of the existing process will e crried out s prt of implementing the EMS. These risk ssessments, together with the Aspects Evlution, llow routine EMS Procedures to e produced, to mnge risks under norml circumstnces, nd Emergency Plns to e drwn up to mitigte impcts under norml circumstnces. Such ssessments will cover the implictions of mteril storge, wter or oil trnsfer, dringe nd site security Forml Environmentl Risk Assessment will e crried out: c d e f g h i j k Under norml operting regimes; Under potentil norml/emergency regimes; For existing equipment; For existing mteril storge; Before new sustnce is introduced to site; Before the instlltion of new plnt on site; Before ny significnt Contrct is let; Before existing plnt is modified; All significnt risks will e referenced in the Significnt Aspects List nd chnges introduced through the Mngement Progrmme; Specific environmentl requirements ssocited with contrct will e identified y risk ssessment nd mnged s pproprite; nd Non-complinces nd system improvement C.GEN will require / encourge full nd open reporting of ll environmentl incidents, including ner misses. Stff will e encourged to report environmentl incidents nd prolems which my result from (inter li) the following fctors: -29 -

26 c d e f g h Pollution incidents; Potentil incidents; Breches of legisltion; Supplier non-complinces; Contrctor non-complinces; Non-complinces discovered during udits; Environmentl mngement system non-complinces; nd Results of externl ssessments All non-complince reports will e investigted to identify the root cuse. Ech incident will e individully recorded, the responsiility for ction llocted nd progress/further investigtions recorded nd monitored. Where the corrective ction required involves chnges to the EMS or plnt modifictions, the implementtion of such chnges will e mnged vi the Mngement Progrmme Contrctor personnel will e informed of the need to report incidents. Reporting C.GEN will report nnully to ll its stkeholders on its environmentl progress nd ccomplishments, tking into ccount locl nd ntionl reporting stndrds nd est prctices C.GEN will report CO 2 emissions in ccordnce with the requirements of EU Greenhouse Gs Emission Allownce Trding Directive 2003/87/EC nd the EU Emissions Trding Scheme ("EU ETS"). 3.6 Environmentl Risk Assessment An Environmentl Risk Assessment hs een undertken in ccordnce with the EA Guidnce Note H1 Environmentl risk ssessment for permits (Decemer 2011). The risk ssessment hs used the H1 Softwre Tool to identify initil environmentl risks from the Project. The results of the Tool re presented s Appendix C to this document The Project hs een suject to comprehensive Environmentl Impct Assessment, s discussed in Section

27 SECTION 4 INFORMATION IN SUPPORT OF FORM B3-31 -

28 4 INFORMATION IN SUPPORT OF FORM B3 4.1 Wht Activities Are Applied For? The Project is intended to operte either s CCGT plnt or s n IGCC plnt. The Project will e designed to provide its totl genertion cpcity of up to 470 MW under norml operting conditions. Schedule 1 Activities The instlltion will consist of two seprte sttionry technicl units ("STU") sed on the following regulted ctivities s listed in Prt 2, Schedule 1 of the EP Regultions: Power Islnd STU Ctegory: 1.1 A(1)() Burning ny fuel in n pplince with rted therml input of 50 or more megwtts Type: Fuels: Purpose: Gs turine (operting in comined cycle) Nturl gs, syngs Electricl power genertion Gsifiction Plnt STU Ctegory: 1.2 A(1)(d) Gsifiction or liquefction of col or other fuels in instlltions with totl rted therml input of 20 megwtts or more Purpose: Production of syngs for comustion in gs turine During opertion s n IGCC plnt, it is possile tht the Power Islnd STU will operte in isoltion, either s result of the unvilility of the Gsifiction Plnt STU (e.g. for unforeseen mintennce), or s the result of commercil decision y C.GEN to use nturl gs s fuel for the Project. Sttionry Technicl Units The definition of STU is not included in the EP Regultions. However, the EA RGN 2 Understnding the mening of regulted fcility (April 2013) sttes: The essence of technicl unit is tht it cn crry out the Activity, or Activities, on its own. This mens tht the technicl unit must include enough plnt nd mchinery to llow the Activity to tke plce in controlled mnner for sufficient period of time for the opertion to rech its designed or intended output Therefore, the STUs comprised in the Project cn e defined s: -33 -

29 Power Islnd STU incorporting i ii iii Gs reception fcility; Gs Turine; nd One (or two) electricity genertor(s) nd trnsformer(s); nd Gsifiction Plnt STU incorporting i ii iii iv v Fuel milling / drying / preprtion equipment; Gsifier; Syngs tretment nd conditioning equipment; Acid gs removl equipment; nd Sulphur recovery nd til gs tretment. Directly Associted Activities As Prt 1 Regultion 2(1) of the EP Regultions provides tht, directly ssocited ctivity ("DAA") is n opertion tht, in reltion to ny other ctivity: c Hs technicl connection with the ctivity; Is crried out on the sme site s the ctivity; nd Could hve n effect on pollution The gsifiction of col (or other solid fuel, s descried in Section 1.2) is not considered to e techniclly linked with the Power Islnd STU s gsifiction is not pre-requisite for opertion of the comustion process (i.e. the Project will e cple of firing on nturl gs only, under ll scenrios). As such, gsifiction of col is descried s seprte STU Therefore, the DAAs for ech STU my e considered to e: Power Islnd STU i ii iii iv v vi Rw wter tretment; Hyrid cooling towers; Wter tretment (deminerlistion) plnt; Het recovery stem genertor nd ssocited stem turine; Wste wter tretment plnt; nd Auxiliry oilers / Emergency diesel genertors

30 Gsifiction Plnt STU i ii iii iv v vi vii viii Rw wter tretment; Hyrid cooling towers; Wter tretment (deminerlistion) plnt; Wste wter tretment plnt; Auxiliry oilers / Emergency diesel genertors; Flring; Solid fuel unloding, hndling nd storge; nd Solid wste removl equipment nd storge. 4.2 Emissions to Air, Lnd nd Wter Point Source Emissions to Air The principl point sources for emissions to ir re s shown in Tle 1: Emissions from the Min Stck, which is comprised in the Power Islnd STU; nd Emissions from the Flre Stck, which is comprised in the Gsifiction Plnt STU The prescried sustnces within these emissions will include: oxides of nitrogen (NO x ); sulphur dioxide (SO 2 ); c prticulte mtter (PM 10 ); nd d oxides of cron (CO nd CO 2 ). Min Stck The Min Stck serves the gs turine nd HRSG within the Power Islnd STU nd will dischrge to tmosphere the emission from comustion within the gs turine The gs turine will normlly operte etween 80 nd 100 per cent lod, ut will e cple of operting t rnge of prt lod conditions down to the Minimum Stle Lod ("MSL") which will e dependent upon the gs turine selected for the Project. The emissions prmeters for the Project will vry sed on the fuel used. However, the emissions concentrtions will e controlled to the ssocited emissions levels ("AEL") of the relevnt est ville techniques ("BAT") for the comustion of gseous fuels within gs turine s shown in Tle 2, nd discussed in Section

31 Tle 2: Emissions from the Min Stck (Power Islnd STU) Vlue Prmeter Units Nturl Gs (B) Col (E1) Col/ Petcoke (E2) Col/ Biomss (E3) Oxides of nitrogen (s NO 2) mg/nm Cron monoxide mg/nm Sulphur dioxide (SO 2) mg/nm 3 negligile Prticultes (PM 10) mg/nm 3 negligile NOTE: Figures quoted re t stndrd reference conditions 15 per cent oxygen, dry, 0ºC, r Typicl flue gs nlyses of emissions from the Min Stck, under ech of the ove representtive fuel comintions re presented in Tle 3. Tle 3: Flue Gs Anlysis for Ech Fuel Scenrio Prmeter Units Vlue Nturl Gs Col Col/ Petcoke Col/ Biomss Norml flue gs flow rte Nm 3 /s NO x emission level mg/nm NO x flow rte g/s CO emission level mg/nm CO emission rte g/s SO 2 emission level mg/nm 3 negligile SO 2 flow rte g/s negligile PM emission level mg/nm 3 negligile PM emission rte g/s negligile Temperture C Actul flue gs volume m 3 /s Oxygen content % volume Flue gs velocity m/s Stck dimeter m

32 4.2.6 The nnul emissions ssocited with the Project, for ech fuel scenrio, re given in Tle 4 elow. The nnul emissions hve een clculted ssuming worst cse sis of the mximum potentil operting cse, i.e. the min units operting continuously 100 per cent se lod, nd, for ech fuel scenrio, ssuming 100 per cent use of ech fuel type / lend. Tle 4: Potentil Annul Mss Emissions Prmeter Mss (tonnes) Nturl Gs Col Col/ Petcoke Col/ Biomss Oxides of nitrogen (s NO 2) Cron monoxide Sulphur dioxide (SO 2) negligile Prticultes (PM 10) negligile The impct of the emissions from the Project hs een ssessed vi full ir dispersion modelling study nd compred to the sttutory ojectives for the relevnt pollutnts. The results re summrised elow (Air Qulity Assessments) nd discussed in more detil in Section 6 of the ES tht is presented s Appendix D to this document. Flre Stck The opertion of the Flre Stck comprised in the Gsifiction Pln STU will llow vrious items of equipment to chieve the correct chemicl composition, pressure nd temperture conditions during strt-up nd prior to norml opertion. The flres will lso e used during shut down of the units, nd s sfety mesure The Project will incorporte two flres constructed within the Flre Stck to e utilised during plnt strt-up, shut-down nd emergency (i.e. not ordinrily s prt of continuous IGCC opertion): Flre 1 ( min flre ) will flre gs from the scruer, which is from n offt-tke just efore nd fter the AGR, nd the feed strem efore it reches the gs turine; nd Flre 2 ( sour flre ) will flre sour gs from the AGR nd Clus units, which is prt of the desulphuristion process. A smll comustor unit my e instlled t the exit of the Clus units for use during their strt-up, s n lterntive to sending this sour gs to the Flre Stck The emissions prmeters for ech flre re presented in Tle

33 Tle 5: Emissions from the Flre Stck Following Comustion Vlue Prmeter Units Min Flre Sour Flre NO x emission kg Equivlent NO x flow rte g/s SO 2 emission kg Equivlent SO 2 flow rte g/s Temperture (for modelling purposes) Actul flue gs volume (for modelling purposes) C 1275 m 3 /s Flue gs velocity m/s Effective Flre Dimeter (for modelling purposes) m Air Qulity Assessments Directive 2008/50/EC of 21 My 2008 on mient ir qulity nd clener ir for Europe (the "Amient Air Qulity Directive") identifies desired mximum ground level concentrtions nd the dte y which the ojectives should e met nd introduces new ojectives for fine prticles The Air Qulity Stndrds Regultions 2010 (the "AQS Regultions") give effect, in Englnd, to the Amient Air Qulity Directive. The AQS Regultions specify series of stndrds nd ojectives for ir qulity in the UK. The ojectives re summrised in Tle

34 Tle 6: UK AQS Regultions Ojectives for Amient Air Qulity Pollutnt Averging Period Ojective (Ground Level Concentrtion) (µg/m 3 ) Numer of permitted Exceednces Nitrogen Dioxide (NO 2) Sulphur Dioxide (SO 2) Prticles (PM 10) Cron Monoxide 1 Hour Annul 40-1 Hour Hour Hour Annul 40-8-hour rolling The AQS Regultions hve lso een implemented through the Air Qulity Strtegy for Englnd, Wles, Scotlnd nd Northern Irelnd (2007). The Air Qulity Strtegy lso incorportes n dditionl ojective for SO2:15-minute men ojective of 266 µg/m 3 (not to e exceeded more thn 35 times yer) Dispersion modelling hs een crried out on the emissions from the Min Stck nd from the Flre Stck nd the results compred to the ove thresholds. This ws used to determine the significnce of the process contriution of the Project to ground level concentrtions of ech of the relevnt pollutnts The full dispersion modelling report cn e found in Section 6 of the ES, which is included s Appendix D of this document The results from the nlysis, on the sis of worst cse scenrio of operting with lod fctor of 100 per cent (i.e. full lod opertion for the entire study period), of the emissions from the Min Stck re presented in Tle

35 Tle 7: Min Stck Mximum Process Contriution to Ground Level Concentrtions Pollutnt Averging Period Ojective (µg/m 3 ) Opertion s CCGT plnt (µg/m 3 ) Opertion s n IGCC plnt (µg/m 3 ) Nitrogen Dioxide (NO 2) 1 Hour Annul Minute Sulphur Dioxide (SO 2) 1 Hour Hour Prticles (PM 10) Cron Monoxide 24 Hour Annul hour rolling Tle 8 indictes the potentil short-term process contriutions from the Flre Stck. Tle 8: Flre Stck Mximum Process Contriution to Ground Level Concentrtions Pollutnt Averging Period Ojective (µg/m 3 ) Min Flre (µg/m 3 ) Sour Flre (µg/m 3 ) Nitrogen Dioxide (NO 2) Sulphur Dioxide (SO 2) 1 Hour (4) 15 Minute Hour As shown, the mximum process contriution from the Flre Stck to 15-minute men ground level concentrtions of SO 2 is predicted to e greter thn the dditionl Air Qulity Strtegy Ojective of 266 µg/m 3. In order to estimte the mximum process contriution, the dispersion of the emissions from the Flre Stck hs een modelled for ech hour of the five yer ( ) study period. From such nlysis, n nnul verge totl of 260 exceednces of this Ojective is nticipted t the loction of the mximum predicted impct from opertion of the Sour Flre. However, s set out in Section of the ADMS 5 User Guide (Cmridge Environmentl Reserch Consultnts Ltd, Novemer 2012), the numer of exceednces hs een clculted over full yer, on pro-rt sis

36 As discussed ove, the opertion of the Flre Stck is only nticipted during strtup nd prior to norml opertion. The flres will lso e used during shut down of the units, nd s sfety mesure. As such, the Flre Stck will not operte continuously. The numer of exceednces predicted y the dispersion modelling softwre is considered to e mteril over-estimtion nd not fully representtive of the nticipted operting regime for the Project (which is discussed in Section 3.5) The mximum process contriution, of the Sour Flre, to hourly verge ground level concentrtions is within the AQS Ojective. However, it is noted tht this mximum process contriution is not well elow 2 the AQS Ojective. Agin, the clcultion of the process contriution is, s ove, sed on the ssumption of continuous opertion. The intermittent nture of the Flre Stck will reduce the potentil for / risk of its emissions eing relesed during time where prticulr comintions of meteorologicl conditions (wind speed, direction, etc.) my result in higher process contriutions. As such, gin this is considered to represent n over-estimtion. Point Source Emissions to Wter Cooling Wter Dischrge In order to mintin the correct chemicl control of the hyrid cooling tower system, it will e necessry to purge the cooling wter cycle of the dissolved solids. The mount of cooling tower purge is dependent upon the totl dissolved solid content in the rw wter, which determines mximum concentrtion fctor for stisfctory opertion of the cooling towers Using the sline wter of the River Humer, it is nticipted tht the hyrid cooling towers would require purge of pproximtely 0.2 m 3 /s for opertion s CCGT plnt nd pproximtely 0.3 m 3 /s for opertion s n IGCC plnt (in order to provide for the dditionl cooling duty) The purge will e concentrted solution of the dissolved solids lredy present in the rw river wter ecuse the purge is derived from the river wter itself. It will lso contin some smll mounts of chemicls dded for the conditioning of the cooling wter (such s the continuous or intermittent (shock) dosing with iocide (such s chlorine dioxide or sodium hypochlorite), which is used to prevent io-fouling within the intke pipework nd to prevent legionell) A typicl nlysis of the nticipted cooling tower dischrge to the River Humer is detiled in Tle 9. 2 =<75 per cent of the relevnt AQS Ojective, tken from Development Control: Plnning for Air Qulity (Environmentl Protection UK, 2010) -41 -

37 Tle 9: Cooling Tower Dischrge Anlysis Prmeter Concentrtion (µg/l) Priority Sustnces Cdmium 0.15 Mercury 0.02 Led 0.15 Nickel 4.07 Specific Pollutnts Cynide, (s CN-) Chlorine - * Arsenic 4.05 Chromium 0.8 Copper 4.8 Zinc Iron 150 Physico-Chemicl Stndrds Ammoni (s NH4-) 60 N-Totl (µmol/l) EA Non-Sttutory EQS Hydrogen Sulphide - * Fluoride - * * Note: No ville dt -42 -

38 Boiler Blowdown The stem / wter circuits will require high purity wter to void internl corrosion nd ensure optiml efficiency. Although of extremely high purity, this wter will still contin some dissolved solids. The wter qulity within the oiler wter / stem circuit will e controlled y continuously purging smll quntities from the system (lowdown) to prevent the excessive concentrtion of dissolved solids in the wter. As the feed wter will e of high purity, the totl mount of lowdown from the oilers will e smll, of the order of 185 m 3 /dy The lowdown will e dischrged to dedicted lowdown vessels nd sent to the deminerlistion plnt to e re-used or dischrged to the River Humer fter tretment in the wste wter tretment plnt. These vessels re open to tmosphere nd, s such, some of the lowdown immeditely flshes off to tmosphere. Therefore the totl lowdown will e: On dischrge After flshing-off to tmosphere 185 m 3 /dy 145 m 3 /dy The remining lowdown will feed to the wste wter tretment plnt for susequent dischrge either to the hyrid cooling tower sins or mixed directly with the cooling tower dischrge to the River Humer A typicl nlysis of this lowdown is shown in Tle 10. Tle 10: Typicl Boiler Blowdown Anlysis Prmeter Unit Vlue Conductivity µs/cm 50 ph - 10 Ammoni s NH3 mg/l 1 Phosphte s PO4 mg/l The oiler lowdown is sed on the mss flow through the stem cycle of the Power Islnd STU, which is function of the electricl lod of the Project. As such, opertion s n IGCC plnt will not lter the oiler lowdown requirements when compred to opertion s CCGT plnt. Rw Wter Tretment Plnt A seprte, dedicted on-site deminerlistion tretment plnt will tret fresh mins wter provided y Anglin Wter to qulity suitle for use in the HRSG. Two tretment methods (or comintion of oth) re under considertion for the Project: Ion Exchnge The tretment process to e used involves filtrtion, followed y the exchnging of ctions in the supply (clcium, mgnesium, sodium, etc) for hydrogen ions y -43 -

39 using ction exchnge resins nd then exchnging the nions in the dectionised wter (sulphte, chloride, cronte, silicte, etc) for hydroxyl ions y using nion exchnge resins. When the resins re exhusted the resin eds re ckwshed, regenerted with dilute cid (for the ction resin) nd with dilute custic sod (for the nion resin), rinsed to remove ny excess regenernt nd returned to service. The deminerlistion plnt will consist of: fresh wter rek tnk, deminerlised wter storge tnks, n cid storge tnk, custic storge tnk, n utomtic effluent neutrlising system, control pnel nd ll interconnecting pipe work. The treted wter storge tnk will hve the cpcity to hold treted wter sufficient for full lod opertion of the Project for round dy. Reverse Osmosis Rw wter is pssed through semi-permele memrne under pressure. The memrne is designed so tht wter is llowed to pss through while retining the dissolved solids for dischrge with the reject wter. Reverse Osmosis plnts my consist of multiple stges depending upon ny concentrtion nd flow requirements of the effluents The deminerlistion plnt effluent will e concentrted solution of ll the dissolved solids present in the rw mins wter, with possily some dditionl sodium sulphte or sodium chloride produced s result of ny effluent neutrlistion requirements The effluent produced will e pproximtely 0.4 kg/s, on verge. An nlysis of the effluent, sed on current rw wter qulity dt sourced from Anglin Wter 3 is presented in Tle

40 Tle 11: Deminerlistion Tretment Plnt Effluent Anlysis Prmeter Concentrtion (µg/l) Priority Sustnces Cdmium 0.05 Mercury 0.19 Led 3.82 Nickel 7.20 Specific Pollutnts Cynide, (s CN-) 6.67 Chlorine 2600 Arsenic 2.53 Chromium 10 Copper 1470 Zinc n/ * Iron 40 Physico-Chemicl Stndrds Ammoni (s NH4-) 60 N-Totl n/ * EA Non-Sttutory EQS Hydrogen Sulphide n/ * Fluoride 2933 *Dt not ville from Anglin Wter; no such chemicls will e dded During norml opertion the wter tretment plnt is nticipted to produce n effluent of pproximtely 35 m 3 /dy for opertion s CCGT Plnt, incresing to pproximtely 315 m 3 /dy for opertion s n IGCC plnt

41 Comined Effluent The effluents from the HRSG nd the deminerlistion plnt will e mixed with the cooling tower purge prior to dischrge to the River Humer. Tle 12 presents the nticipted nlysis of the comined effluent sed on the respective mss flows nd compositions of ech of the three min effluent strems during opertion s CCGT plnt, prior to tretment in the Wste Wter Tretment Plnt As shown in Tle 12 (y comprison with Tle 9), the comined effluent is dominted y the flow rte of the cooling tower purge given the comprtive volumes of the effluent strems

42 Tle 12: Comined Effluent Anlysis (µg/l) Prmeter Opertion s CCGT plnt Priority Sustnces Cdmium 0.15 Mercury 0.02 Led 0.16 Nickel 4.04 Specific Pollutnts Cynide, (s CN-) 0.02 Chlorine - Arsenic 4.01 Chromium 0.76 Copper 7.83 Zinc Iron Physico-Chemicl Stndrds Ammoni (s NH4-) N-Totl (µmol/l) EA Non-Sttutory EQS Hydrogen Sulphide - Fluoride 6.16 Gsifiction Plnt Creful chemicl control is required in order to prevent corrosion nd ensure nd mintin efficient opertion of the gsifier of the quench nd scruer wter circuit of the Gsifiction Plnt nd will need to e continuously purged. This purge flow is dependent upon the level of chlorine nd other sustnces (such s mmoni) present in the quench wter circuit. These levels will e directly relted to the chlorine nd nitrogen content in the solid fuel

43 The norml flow rte for the effluent from the Gsifiction Plnt will e pproximtely 2300 m 3 /dy. However, higher chlorine content of the fuel would require n incresed effluent of up to pproximtely 6500 m 3 /dy The nticipted rnge of compositions of the effluent from the Gsifiction Plnt is shown in Tle

44 Tle 13: Gsifiction Plnt Effluent Anlysis Prmeter Norml Chlorine Fuel Concentrtion (µg/l)* High Chlorine Fuel Concentrtion (µg/l)** Priority Sustnces Cdmium 8 5 Mercury Led 10 5 Nickel Specific Pollutnts Cynide, (s CN-) Chlorine - - Arsenic 15 5 Chromium Copper Zinc Iron Physico-Chemicl Stndrds Ammoni (s NH4-) N-Totl (µmol/l) EA Non-Sttutory EQS Hydrogen Sulphide Fluoride *95t/h of gsifiction islnd effluent entering the WWTP ** 270 t/h of gsifiction islnd effluent entering the WWTP There will e n dditionl requirement of pproximtely 1.9 kg/s for lowdown from the syngs cooling system during opertion s n IGCC plnt

45 Comined Effluent The effluents from the Gsifiction Plnt, the deminerlistion plnt nd the oiler lowdown will e collected y the Wste Wter Tretment Plnt prior to mixing with the cooling tower purge, for dischrge to the River Humer. Tle 14 presents the nlysis of the comined effluent entering the Wste Wter Tretment Plnt. Tle 14: Comined Effluent / Wste Wter Tretment Plnt Feed Anlysis Prmeter Norml Opertion (µg/l) High Chlorine Fuel (µg/l) Priority Sustnces Cdmium Mercury Led Nickel Specific Pollutnts Cynide, (s CN-) Chlorine - - Arsenic Chromium Copper Zinc Iron Physico-Chemicl Stndrds Ammoni (s NH4-) N-Totl (µmol/l) EA Non-Sttutory EQS Hydrogen Sulphide Fluoride

46 Wter Qulity Assessment Bsed on the methodology presented in the EA Horizontl Guidnce Note H1 Annex (d): Surfce Wter Dischrges (sic), estimtes of river flow speeds were used in conjunction with the EA Initil Dilution Spredsheet in order to llow for the clcultion of process contriutions to the concentrtions of the vrious EQS pollutnts. The initil dilution ("ID") is function of mient current velocity, wter depth nd effluent dischrge, s such, rnge of fctors for the ID of the comined effluent dischrge re expected over the tidl cycle The worst (lowest) initil dilution will e experienced during low tide (slck wter) whilst the est (highest) initil dilution will e t the point etween high tide nd low tide when the river current is t its gretest For opertion s CCGT plnt, ll process contriutions will e <4 per cent of the relevnt EQS nd re, therefore, considered not to e significnt sed on the screening criteri from the ove H1 Guidnce Note For opertion s n IGCC plnt, in order to determine the tretment requirements for the Wste Wter Tretment Plnt, the methodology presented in the EA H1 Guidnce Note for the initil ssessment of sic effluents to surfce wters hs een reversed. This hs llowed the determintion of the required compositions of the Wste Wter Tretment Plnt effluent tht will result in comined effluent dischrge tht would hve no significnt impct on the River Humer. Site Dringe There will e four dringe systems comprised in the Project: the surfce wter dringe system; the oily wter dringe system; the wste wter tretment plnt system; nd the sewerge system The min plnt dischrge will e vi the hyrid cooling tower return infrstructure tht will dischrge the cooling wter purge to the River Humer. The suspended solids from the rw wter tretment plnt will e mixed with the cooling purge prior to its ultimte dischrge representing only minor increse in the suspended solid concentrtion of such solids tht were originlly tken from the River Humer thus representing no ddition of mteril to the River It my e tht the surfce wter dringe system, the oily wter dringe system nd the wste wter tretment system will e mixed with the cooling wter return prior to dischrge, following suitle tretment. The dischrges from ll dringe systems will e monitored seprtely nd, where the qulity of effluent cnnot e controlled to within cceptle limits to ensure the overll dischrge from the Generting Sttion is of suitle qulity, it will e retined for further tretment or removed nd disposed of y suitly licensed contrctor The surfce wter dringe system will drin res of the Opertions Are unlikely to e contminted with oil nd my dischrge the wter to dedicted storge tnk. This tnk would form prt of wter reclmtion system tht would recycle the collected surfce wter to the deminerlistion tretment plnt or to the hyrid cooling tower sins. The mjority of the surfce wter dringe will e uncontminted nd typicl of surfce wter run-off from res of hrdstnding nd rods. The collected surfce wter could lso e re-used within the hyrid cooling towers to reduce the mount of wter to e strcted from the River Humer

47 The Project will not led to significnt increse in the quntity of surfce wter runoff, given tht much of the Opertions Are is lredy covered with vriety of hrdstndings. The Flood Risk Assessment undertken to support the DCO ppliction for the Project hs considered s worst cse (mximum) chnge of lnd covering of 6.6 h (to e developed principlly for the Power Islnd STU). The sitewide dringe systems will limit the surfce wter run-off rte from the Opertions Are to the existing run-off rte from C.GEN lnd (seeking to provide some etterment where possile) The surfce wter dringe system for ny res with the potentil for oil contmintion of ny surfce wter will feed to sumps nd will pss through oil interceptor/filters prior to dischrge to dedicted surfce wter holding tnk An oily wter dringe system will drin ll res where oil spillges could occur. The res lile to oil spillge re: c d The oil unloding re djcent to the luricting oil storge tnks; The electricl trnsformers (which my contin insulting oil; if so this will e PCB free); The res surrounding the unded oil storge tnks (the unds themselves will not hve ny dringe connections); nd Any cr prking res The design of the oily wter dringe system will incorporte suitly sized oil interceptors nd trps. Adequte fcilities for the inspection nd mintennce of the interceptors will e provided nd the interceptors will e regulrly emptied nd desludged to ensure efficient opertion. A qulified contrctor will dispose of the sludge off-site The qulity of the effluent from the oily wter system will e controlled to limit the oil in wter content to level regulted y the, normlly with limit of no visile oil quoted (<10 ppm) nd to reduce the suspended solids to 15 mg/l. The dischrge from ech oil interceptor will pss to the surfce wter dringe system for recovery nd re-use, or dischrge to the River Humer vi the cooling wter return infrstructure The on-site sewerge dringe system will pipe ll domestic / snitry effluent to n on-site sewge tretment plnt. The treted sewge will e removed from site for disposl y suitly licensed contrctor All elements of the tretment systems will e regulrly monitored to ensure optimum performnce nd mintennce There will e specific site dringe systems in the gsifier y-products (slg nd filter cke) storge re nd the fuel storge re. These dringe systems will include seprtors nd trps. Wter collected vi these systems will e suject to seprtion of solids nd suitle tretment in order to control ll dischrges to within the permitted operting limits A site dringe pln will e produced s prt of the power sttion construction contrct. A copy will e supplied to nd discussed with the Environment Agency. This pln will lso show the ultimte loction of ll unded res

48 A full fire wter risk ssessment will e undertken s prt of the detiled design process to determine the retention nd dischrge rrngements for fire fighting wter. Miscellneous Effluents Occsionlly it will e necessry to wsh the ldes of the ir compressor section of the gs turines to remove deris tht hs penetrted the inlet ir filters nd ecome lodged on the compressor ldes. This will e done t times when the performnce of the gs turines hs degrded nd will depend upon the ir qulity in the vicinity of the proposed site Wshing cn e done in two wys, either y: On-line wshing, where fine spry of deminerlised wter is llowed to pss through the gs turine (nd is susequently emitted y the Min Stck); or Off-line wshing, where the compressor ldes re rotted slowly through detergent solution In the cse of off-line wshing, pproximtely 15 m 3 of wste wter contining detergent will e retined on-site in storge tnk nd susequently tnkered off-site y licensed contrctor for disposl t n ppropritely licensed disposl fcility Flue gs side wshing is not nticipted. However, during commissioning nd t infrequent intervls during the life of the Project it will e necessry to clen the wter side of the HRSG tues chemiclly. All resulting effluents will e tnkered off site y licensed contrctor for tretment nd disposl t n ppropritely licensed disposl fcility As ll miscellneous wsh wter will e tnkered off site, there will not e ny impcts of this dischrge on the surrounding environment Domestic/snitry wter requirements will e pproximtely 200 litres per person per dy (c. 30 m 3 /dy) nd will dischrge to n on-site sewge tretment plnt prior to removl from site for disposl y suitly licensed contrctor In ddition, to llow for non-norml operting conditions, elow ground sewerge wter holding tnk my e instlled for the controlled relese of sewerge effluent from the Project. Point Source Emissions to Sewers, Effluent Tretment Plnts or Other Trnsfers Off-Site There will e no dischrge to ny sewerge system s ll effluents will e treted onsite for susequent disposl. Disposl in this context refers to dischrge to the River Humer s prt of the comined effluent dischrge (i.e. mixed with the hyrid cooling tower purge) or removl from site y suitly licensed contrctor. Point Source Emissions to Lnd The Project will operte in full ccordnce with the Wste Frmework Directive nd the Wste (Englnd nd Wles) Regultions C.GEN, t ll phses of the Project, will seek to pply the wste hierrchy s prt of their wste prevention nd mngement policy

49 The wste hierrchy consists of the following, in order of preference: c d e Prevention; Re-use; Recycling; Other recovery (e.g. energy recovery); nd Disposl A feture of the gs turine (CCGT) technology to e incorported in the Power Islnd for the comustion of gseous fuels is tht wste generted should e miniml nd will e restricted to the following: c d e Generl office wstes; Used gs turine ir intke filters; Used ion exchnge resins or used Reverse Osmosis memrnes (typiclly replced every 5 to 10 yers); Seprted oil / sludge from oil / wter seprtors; nd Used oil, chemicls or chemicl continers The significnt solid wstes nticipted from the opertion of the Gsifiction Plnt re: c Ash in the form of inert slg nd fly sh filter cke; nd Filter cke/sludge from the Wste Wter Tretment Plnt; nd Sulphur extrcted in elementry form It is nticipted tht the slg nd Wste Wter Tretment Plnt filter cke, will e sold for use in the construction industry or trnsported to n pproprite lndfill site y suitly licensed contrctor The elementl sulphur will likely e used s rw mteril in the chemicl industry Prior to disposl, the slg, fly sh nd filter ckes will e ssessed nd clssified in ccordnce with the Wste Frmework Directive definition for hzrdous wste nd the EA Technicl Guidnce WM2 -Interprettion of the definition nd clssifiction of hzrdous wste (2013) (nd ny successor document) nd proposls for its mngement included, ccordingly, in the Site Wste Mngement Pln. 4.3 Operting Techniques Technicl Stndrds The Project will consist of two STUs, s descried in Section 4.1, for comustion nd gsifiction

50 4.3.2 The new plnt will e designed nd operted in ccordnce with the relevnt sections of the documents: c EPR 1.00 Getting the Bsics Right; EPR 1.01 Sector Guidnce Note for Comustion Activities; EPR 1.02 Gsifiction, Liquefction nd Refining i Guidnce for the Gsifiction, Liquefction nd Refining Sector (IPPC S1.02); d e CHP Redy Guidnce for Comustion nd Energy from Wste Power Plnts ( CHP-R Guidnce ); BAT Reference Document for the Lrge Comustion Plnts ( Drft LCP BREF, June 2013); f UK Technicl Working Group LCP BREF Review ( Wish List, My 2011); g h EU Reference Document on BAT for Lrge Comustion Plnts ( LCP BREF, July 2006); BAT Reference Document for the Refining of Minerl Oil nd Gs ( Drft Refining BREF, July 2013); i BAT Reference Document for Common Wste Wter nd Wste Gs Tretment/Mngement Systems in the Chemicl Sector ( Drft Wste Wter BREF, July 2011); j k l EU Reference Document on Best Aville Techniques in Common Wste Wter nd Wste Gs Tretment / Mngement Systems in the Chemicl Sector ( Wste Wter BREF, Ferury 2003); EU Reference Document on BAT on Emissions from Storge ( Storge BREF, July 2006); nd EU Reference Document on the ppliction of Best Aville Techniques to Industril Cooling Systems ( Cooling BREF, Decemer 2001). Best Aville Techniques Activities Comustion BAT Conclusion 44 (for the comustion of gseous fuels) of the Drft LCP BREF sttes: -55 -

51 In order to increse the energy efficiency of nturl gs comustion, BAT is to use one or comintion of... the techniques given elow: c CHP rediness Regenertive feedwter heting Comined cycle (CCGT) The ove BAT conclusion is reinforced y the position stted in the Wish List (t ) tht, BAT for new-uild plnt is CHP, or CHP-redy where there re no immedite opportunities for CHP t the time of uild. The Project complies with this As set out in Section (of this document), the Project is nticipted to operte s se lod plnt (i.e. it will not e suject to regulr significnt fluctutions in the electricl output). The Wish List sttes tht, it is not BAT to operte [open cycle gs turines] se lod without het recovery. The Project will comprise gs turine nd ssocited stem turine plnt nd is, therefore, sed on CCGT technology The Project will e designed to e CHP-redy ("CHP-R"). The ssessment of existing nd future CHP opportunities for the Project nd the nlysis of CHP-R re presented in the Comined Het nd Power Assessment (Prsons Brinckerhoff, Mrch 2013) sumitted with the DCO ppliction for the Project During the detiled design stge of the Project, the implementtion of regenertive feedwter heting will e exmined. The finl decision nd rrngements for such mesure will e determined through n nlysis of the chievle improvements on the efficiency of the stem cycle (within the Power Islnd) lnced with the potentil impct to the overll energy efficiency of the Project given tht feedwter heting cn tke energy wy from other prts of the process Tle of the Drft LCP BREF provides the BAT-ssocited energy efficiency for new CCGT plnt (electricity generting only) should e etween 48.5 nd >58 per cent (net). The position stted within the Wish List is tht this should e 55 to 59 per cent (LHV, t full lod). When operting s CCGT plnt (t full lod) the design efficiency of the Project will e greter thn 55 per cent (LHV) The Project will, therefore, comprise ll comustion-specific BAT for energy efficiency where pproprite, noting the overll BAT principle for the optimistion of the Project s whole. Gsifiction BAT Conclusion 82 (for gsifiction nd IGCC plnts) of the Drft LCP BREF sttes: In order to increse the energy efficiency of the IGCC nd gsifiction plnts, BAT is to use one or comintion of... the techniques given elow: -56 -

52 c d e Het recovery from the gsifiction process Integrtion of gsifiction nd comustion locks Dry feedstock feeding system High temperture nd pressure gsifiction Design improvements All on-site electricl requirements will, during opertion, e provided y the electricity generted within the Power Islnd through dedicted low- nd medium-voltge systems For the Project operting s n IGCC plnt, the wter / stem systems cross the Project (i.e. the Power Islnd, Gsifiction Plnt nd Common Fcilities) will e fully integrted. This mens tht het from the gsifiction process will e recovered y the rising of stem tht will e supplied to the stem pipes nd equipment within the Project, nd which could e fed to the HRSG to supply the stem turine. Similrly, feed wter to the Gsifiction Plnt could e tken from outlet strem from the condenser which will condense the spent stem leving the stem turine In ddition, the ASU for the Project will supply oxygen to the gsifier whilst nitrogen will e pssed to the Power Islnd where it will e mixed with the resultnt syngs prior to comustion within the gs turine The col (nd other solid fuel hndling) will incorporte milling, drying nd pressurising of the fuel prior to introduction (y lock hopper or similr) to the gsifier (s DAA thereof) The gsifiction process (descried in detil lter in this section) will tke plce t high temperture nd pressure t typicl conditions of etween C t pressure of greter thn 40 r g Design improvements referred to in (e) of BAT Conclusion 82 re considered pplicle to existing plnts. However, the optimistion of the process in respect of energy usge nd efficiency will e undertken during the detiled design of the Project The BAT-ssocited energy efficiency (net) for existing IGCC plnt is stted etween 34 nd 46 per cent (LHV). The lrge rnge for efficiency is considered to llow for the efficiency penlties of CCS such tht the rnge covers opertion s n IGCC plnt with nd without CCS The Project, during opertion s n IGCC plnt with CCS (ie Scenrios E1, E2, E3 of the ES), the plnt would hve net electricl efficiency of round 36 per cent (LHV, with CCS). Where other IGCC opertion scenrios pply (such s opertion without CCS, or iomss-only production of syngs) the plnt s shift rector would e ypssed, enhncing power plnt net electricl efficiency to round 41 per cent (LHV). This is within the stted rnge, which will reflect developments in IGCC technology following the development of the existing plnts. Fuel utilistion is lso discussed in the Drft LCP BREF which sttes tht the BAT-ssocited performnce level is for n utilistion of >91 per cent. This level will form prt of the minimum functionl specifiction for the Project nd the ultimte design level will e determined during the tendering / contrct wrd process

53 The Project will, therefore, incorporte ll gsifiction-specific BAT for energy efficiency (s pproprite). Common Fcilities Cooling The Cooling BREF sttes tht, it is cknowledged tht the finl BAT solution will e site-specific solution A numer of cooling technologies were exmined for implementtion t the Project, nmely: c Once-through cooling systems; Closed circuit evportive cooling (hyrid cooling towers); nd Direct ir cooled condensers Once-through, or direct, cooling systems, pump wter directly through the condenser nd return it, t n elevted temperture, to the source. This involves the trnsfer of ll of the rejected het to lrge mss of cooling wter. In order to extrct the required mount of het with the given flows nd temperture rise, the condenser nd het exchngers within the power plnt must e designed for this duty. Once-through cooling requires lrge cooling infrstructure to del with the mount of wter required Once-through cooling would hve typicl wter requirement of the order of 15 m 3 /s (1.3 million m 3 /dy). If once-through cooling were to e dopted there would need to e sumerged culvert or tunnel into the River Humer tht could either terminte t shore pumping sttion or extend to the Opertions Are y wy of culvert or tunnel. The first lterntive is difficult to chieve since the vilility of lnd close to the river nk is restricted due to the opertions of djcent port fcilities, the need for protection of the integrity of the flood defences nd the river nk pulic footpth. The second lterntive would involve longer nd more complex expensive tunnels ut would minimise the disruption. However, the strction of this volume of wter could lso potentilly hve higher ecologicl impct on qutic life in the River Humer due to entrinment / impingement s well s the effect of loclised wter temperture increses With ll het rejected to the river wter, there would need to e seprtion distnce etween the intke nd the outfll. The dissiption of the het would need to e modelled to ensure tht the therml plume ws oth of miniml risk to recircultion nd lso hd n cceptle miniml environmentl effect on the river ecosystem. The River Humer nd mny of its triutries re slmonid rivers for which there is temperture limit of 1.5 C ove the river temperture, t the edge of the mixing zone, for dischrged cooling wter. This criterion my not e chievle during high river wter temperture events in the summer time, which my ffect either ecology or plnt vilility In light of the ove, once-through cooling will not e implemented s prt of the Project

54 Cooling towers utilise the high ltent het of evportion for wter to dissipte the het lod. The totl strction requirements for the Generting Sttion s n IGCC with CCS (which hs the highest cooling demnd) would e less thn 1 m 3 /s (up to m 3 /dy) nd significntly less thn with once-through cooling In the cse of hyrid cooling towers, the wter evportion rte mounts to pproximtely 0.9 per cent to 1.1 per cent of the circultion rte. The evportion tking plce in cooling tower is dependent upon the ility of the ir pssing through the tower to hold moisture nd hence the humidity of the mient ir entering the tower. The humidity is represented y the wet ul temperture of the ir nd cooling towers re designed on the sis of wet ul pproch since cooling the wter to the wet ul temperture is the theoreticl minimum temperture tht cn e chieved y evportive cooling. Achieving close to the wet ul requires lrge, expensive cooling towers nd most cooling towers re designed to n pproch of 8 to 10 C The wter evported from the cooling tower wter circuit must e replced y fresh mke-up wter. The continued ddition of new wter nd evportion of wter vpour leds to n increse in the dissolved slts in the circulting wter. In order to void scling of condensers nd het exchngers, the concentrtion of the slts must e regulted y purging some of the circulting wter from the system The volumes of cooling wter pssing through the condensing systems remin more or less the sme s for once-through cooling. However, insted of eing returned to its source, the cooling wter is pssed to the cooling tower for cooling prior to recircultion to the condenser nd het exchngers Hyrid cooling towers re composed of wet section nd dry section. Hot wter leving the condenser is pssed to the top of the towers nd flows through n ir cooled het exchnger tht performs pproximtely 20 per cent of the cooling duty of the towers, depending upon mient conditions. The wter leves the het exchngers nd is spryed down the wet section of the towers where the remining het is lost through evportion. A significnt environmentl dvntge of this hyrid system is tht the ir leving the cooling towers is under-sturted with wter, mening tht for the mjority of the time no vpour plume is visile Air cn e used s the het trnsfer medium for sites where cooling wter is scrce, or the cost nd / or prcticility of pumping the lrge quntities of wter required is considerle An ir cooled condenser rejects the het relesed from the condensing stem to tmosphere vi series of rows of finned tue cooling elements. The elements re mounted in A frmes on rised pltform supported y steel work. A series of low speed xil flow fns re mounted eneth the frmes to force the mient ir up through the cooling elements nd the ir is heted s the exhust stem condenses inside. The condenste is collected nd pumped to the feed wter return Using ir s the cooling medium elimintes the need for the construction of wter intke / outlet infrstructure. This represents the most simple infrstructure nd environmentl option. However, this solution is very expensive, hs the lrgest footprint, nd hs n importnt negtive influence on the overll plnt efficiency

55 There re plnt efficiency impcts ssocited with the incresed relince on mient ir to provide prt (or ll) of the cooling duty. As such, once-through cooling represents the most efficient cooling medium, followed y the use of hyrid cooling towers, with ir-cooled condensers representing the lest energy efficient option for the Generting Sttion, which would reduce the net electricl output y round 2 per cent of the mximum continuous rting However, the chievle efficiency increses need to e lnced with the potentil for significnt environmentl impcts. Given the potentil sensitivity of the Humer Estury SAC / SPA to wter strction of the volumes required for once-through cooling, it is not considered fesile to utilise once-through cooling t the loction. The opertion of such cooling system would lso hve n extremely high potentil for interfering with the cooling wter rrngements for the existing Centric nd E.ON Killingholme Power Sttions Therefore, it is considered tht the utilistion of hyrid cooling towers represents the idel lnce etween operting efficiency penlties, the potentil environmentl impcts nd the opertion of neighouring fcilities in the re nd re thus BAT for the Project. Emissions to Air The mximum emissions concentrtions for relevnt pollutnts for ll potentil operting scenrios re shown in Tle 2. Oxides of Nitrogen The Wish List sttes tht BAT for the control of NO x emissions from CCGT technology re dry low-no x ("DLN") premix urners The Drft LCP BREF, t BAT Conclusion 47, lso sttes: In order to reduce NO X emissions to ir from the comustion of nturl gs in gs turines..., BAT is to use one or comintion of the techniques given elow: c d e f Dry low-nox urners Selective Ctlytic Reduction ("SCR") Wter or stem injection Advnced computerised process control Low-lod design concepts Low-NOx urners ("LNB") As explined in Section 3.5 of this document, the Project is intended to operte under se lod regime nd, s such, low-lod design concepts re not considered pplicle when determining BAT for the Project

56 Should the Project e constructed initilly for opertion s CCGT plnt only (Scenrio B), the gs turine will incorporte DLN urners for the comustion of nturl gs. The DLN urners reduce the pek flme temperture, which is proven method for primry pollution control tht does not require dditionl secondry control mesures, such s SCR. Therefore, the use of DLN urners is sufficient to control the emissions of NO x to 50 mg/nm 3 which is the BAT AEL for the comustion of nturl gs for gs turines, s per of the Wish List. There will, therefore, e no requirement for the implementtion of LNB For opertion s n IGCC plnt, BAT Conclusion 83 of the Drft LCP BREF sttes: In order to prevent or reduce NOX emissions while limiting CO emissions to ir from IGCC plnts, BAT is to use one or comintion of the techniques given elow: c d Dry low-nox urners for the comined cycle gs turine; Syngs dilution with wste nitrogen from the ASU; Stem injection in the gs turine comustion chmer; nd/or SCR As the Drft LCP BREF provides, DLN urners my not e suitle for the comustion of syngs with ir in the comustion chmers of the gs turine where the hydrogen content of the syngs is >25 per cent, nd their pplicility is to e determined on cse-y-cse sis. Should this prove to e the cse, the gs turine will e fitted with diffusion-type urners prior to the commencement of opertion of the Gsifiction Plnt STU. This would tke plce either upon the commencement of opertion of the Power Islnd (Scenrio E) using syngs or t lter dte, which would require the replcement of the DLN urners Following the modifiction required for the Project to operte s n IGCC plnt, the dilution of the syngs feed to the gs turine with excess nitrogen from the ASU, nd possily with stem, would ct s the primry mesure to limit the formtion of NO x y controlling the flme temperture. Should the gs turine e required to operte on nturl gs, wter or stem my e injected into the gs turine s primry NO x control mesure for tht operting scenrio Secondry NOx control my lso e required. The HRSG my e fitted with SCR which could either e instlled from the outset (Scenrio C) or t the time of conversion should the Project e constructed, initilly, s CCGT plnt (Scenrio D). The Wish List sttes tht SCR is not BAT for gs turines. However this is considered to reflect the UK position of BAT for the comustion of nturl gs only (i.e. it does not consider the comustion of syngs). SCR is considered s BAT for IGCC opertion y the Drft LCP BREF The Drft Refining BREF sttes, t BAT Conclusion 34, tht the BAT AEL for NOx from gs turines (including CCGT) nd IGCC is mg/nm As per Tle 2, the emissions control systems will e designed in order to chieve mximum NO x emission level of 50 mg/nm 3 under ll operting / fuel scenrios which is the BAT AEL for comustion of gseous fuels in gs turines ( )

57 The Project will, therefore, e cple of incorporting ll BAT for the control of NO x emissions (s pproprite, to e determined in the detiled design of the Project). Where devition from BAT my e required (i.e. the inclusion of SCR whilst firing on nturl gs within the IGCC plnt) these systems will still deliver the BAT AEL. Cron Monoxide For CCGT, BAT Conclusion 49 of the Drft LCP BREF sttes: In order to reduce CO emissions to ir from the comustion of nturl gs, BAT is to use one or comintion of the techniques given elow: Complete comustion i ii iii Good furnce / comustion chmer design Use of high performnce monitoring Mintennce of the comustion system c d Well optimised system to reduce emissions of NO x Advnced utomted process control Appliction of oxidtion ctlysts Cron monoxide is formed y the incomplete comustion of cron present in the fuel. Gs turine technology hs developed, nd continues to develop, etter, more efficient nd more complete comustion, typiclly operting with excess ir flows of etween per cent. Gs turine performnce monitoring, optimistion nd control systems similrly continue to develop s mnufcturers, working with opertors, seek to deliver etter performnce nd higher output from their generting equipment The Wish List (t ) sttes tht BAT AEL for CO emissions from CCGT technology is etween mg/nm The Project will, therefore, comprise ll BAT for the control of CO emissions. CO emissions will e controlled to mximum of 90 mg/nm 3, in ccordnce with the BAT AEL. Sulphur Dioxide Opertion of the Project s CCGT plnt (or comustion of nturl gs within the IGCC plnt) will result in negligile emissions of SO 2 due to the insignificnt mount of sulphur in the fuel BAT Conclusion 54 of the Drft Refining BREF sttes: In order to reduce sulphur emissions from off-gses contining hydrogen sulphide (H 2 S), BAT is to use ll of the techniques given elow: -62 -

58 c Acid gs removl e.g. y mine treting Sulphur recovery units (SRU) e.g. y Clus process Til gs tretment unit (TGTU) The Drft LCP BREF notes, t BAT Conclusion 84, tht: In order to prevent nd / or reduce SOx emissions to ir from IGCC plnts, BAT is to use the technique given elow: Acid gs removl (AGR) The BAT AEL is given, y the Drft LCP BREF, s 3 16 mg/nm The Project will, therefore, comprise ll BAT for the control of SOx emissions (nd H 2 S) y the ppliction of techniques over nd ove those prescried in the Drft LCP BREF, in full ccordnce with the Drft Refining BREF s per the STU definitions in Section SO2 emissions will, s per Tle 2, e up to pproximtely 6 mg/nm 3 nd thus in ccordnce with the BAT AEL. Prticulte Mtter As for cron monoxide, emissions of prticulte mtter (PM 10 ) re formed y the incomplete comustion of cron present in the fuel. Gs turine technology hs developed, nd continues to develop, etter, more efficient nd more complete comustion, typiclly operting with excess ir flows of etween per cent. Opertion of the Project s CCGT plnt (or comustion of nturl gs within the IGCC plnt) will result in negligile emissions of PM BAT Conclusion 85 of the Drft LCP BREF sttes: In order to reduce dust, metl mmoni nd hlogen emissions to ir from IGCC plnts, BAT is to use one or comintion of the techniques given elow: c Syngs filtrtion Syngs trs nd sh recircultion to the gsifier Syngs wshing As necessry, filtrtion methods, such s g filters will e used to remove ny entrined dust / solids within the rw syngs The reminder of the sh is then removed in the syngs scruer prior to tretment in the AGR, SRU nd til-gs tretment units. This genertes slurry tht will e pssed to the wste wter tretment plnt. The resultnt filter cke will e recirculted, s fr s is resonly prcticle recycled to the solid fuel preprtion units nd, ultimtely, the gsifier

59 The Project will, therefore, comprise ll BAT for the control of the emissions of prticulte mtter when operting s n IGCC plnt. Tle of the Drft LCP BREF sttes tht the BAT AEL for dust from IGCC plnts is etween mg/nm 3 ; emissions from the Project will e controlled to mximum of 1.5 mg/nm 3, in ccordnce with the BAT AEL. Methne Methne is chemiclly ctive gs nd is the mjor component of nturl gs. The min potentil for releses of methne from the Project is likely to e potentil lekges from gs pipelines, which re the responsiility of the gs supplier A numer of intermittent opertions in support of norml power sttion opertion will e crried out on site nd result in minor emissions of methne. These include gs venting of lines during strt-up nd shutdown to void dngerous ir / gs mixtures eing present t criticl opertion stges. These releses will e minimised through the implementtion of dvnced process monitoring nd control systems All these releses will e intermittent nd function of the operting regime of the Project operting s CCGT plnt (or firing on nturl gs during opertion s n IGCC plnt). Min Stck Height A stck height sensitivity study ws undertken, s prt of the EIA for the Project in order to exmine the dispersion of the flue gses from the Min Stck (s per Tle 3 of this document) over rnge of stck heights, in 10 m intervls from 40 m to 100 m (inclusive). The stck height sensitivity considered long term nd short term contriutions to ground level concentrtions of NO The stck height modelling results were compred ginst the UK AQS ojectives. The modelling results were considered to e significnt if the ground level concentrtions exceed 10 per cent of the short term ojectives (up to 24 hour verges) nd 1 per cent of the long term ojectives (monthly/nnul results etc) It ws ssumed tht the Project would e operting t full lod for 8760 hours per nnum, nd therefore worst cse scenrio hs een considered The stck height study predicted the 19th highest hourly nd nnul NO 2 ground level concentrtions s result of the opertion of the Project. The 19th highest hourly vlue is otined with regrd to the complince requirements of EU nd UK legisltion nd llows numer of exceednces of the relevnt mient ir qulity limits to cter for norml wether conditions, which my only occur for one hour during the yer, to e disregrded s these wether conditions cnnot e mitigted for in ny significnt wy For the purposes of the stck height sensitivity nlysis, the ir dispersion modelling pplied conversion fctors recommended for screening / worst cse pproch y the EA Air Qulity Modelling nd Assessment Unit ("AQMAU") nd the EA Horizontl Guidnce Note H1 Annex (f). The guidnce sttes tht n initil ir qulity ssessment should e undertken sed on 50 per cent conversion of the short-term verge NO x concentrtions nd 100 per cent conversion of the long-term verges It ws considered tht stck height of 80 m will provide dequte dispersion of the flue gses from the Project (irrespective of the fuel type)

60 Flre Stck The Drft LCP BREF nd the LCP BREF do not consider the emissions from or opertion of flres. The Drft Refining BREF, t BAT Conclusion 55, sttes tht, in order to prevent emissions to ir from flres, BAT is to use flring only for sfety resons or non-routine opertionl conditions (e.g. strt-ups, shutdown) BAT Conclusion 56 continues: In order to reduce emissions to ir from flres when flring is unvoidle, BAT is to use the techniques given elow: c d Correct plnt design Plnt mngement Correct flring devices design Monitoring nd reporting As set out in Section 3.5, the Project will incorporte two flres to e utilised during plnt strt-up (i.e. not ordinrily s prt of continuous IGCC opertion). The flres will llow vrious items of equipment to chieve the correct chemicl composition, pressure nd temperture conditions during strt-up nd prior to norml opertion. The flres will lso e used during shut down of the units, nd s sfety mesure The flres will not e used during norml opertion of the Project. High integrity relief vlves will e utilised throughout the Project in order to minimise the risk of requiring the use of the flres (i.e. the vlves will e used s sfety mesures on individul items of plnt nd equipment such tht risk of n overll plnt filure will e voided) Process prmeters will e continuously recorded to ensure correct nd efficient opertion of the Project through the distriuted control system ("DCS"). Any significnt devitions will e lrmed nd corrections crried out on occurrence. Records will e mintined of performnce nd devition The flres will e designed to ensure efficient comustion of gses sent to them. The flres will include the use of stem to help mintin flme stility. The implementtion of flre gs recovery techniques (s prt of correct plnt design ) is relted to continuously operting flres nd, s such, is not considered pproprite for the Project sed on the nticipted opertion of the flres The design of the flre stem system will interfce with the monitoring equipment, s prt of the DCS, in order to e ville t the flre tips s soon s conditions tht could led to flring event re recorded Continuous monitoring equipment will e instlled within the flres in order to determine the exct composition of ny / ll gses sent to the flre (in respect of relevnt pollutnts) nd the prmeters ssocited with the comustion of the flre gses (e.g. het content of the mixture, rtio of ssistnce, velocity) The nture of ll flring events will e included s prt of the periodic reporting requirements of the

61 The Project will, therefore, comprise ll pplicle BAT for the operting regime of the Flre Stck nd the minimistion of emissions from necessry flring events. Emissions to Wter The principl effluents nticipted for the Project, s per Section 4.2, re: c d e Cooling wter purge / dischrge; HRSG (oiler) nd syngs cooling system lowdown; Rw wter tretment (deminerlistion) plnt effluent; Gsifiction Plnt effluent ; nd Wste Wter Tretment Plnt effluent. Cooling Wter Some chemicls will e dded for the conditioning of the cooling wter, such s the continuous or intermittent (shock) dosing with iocide (e.g. chlorine dioxide or sodium hypochlorite) to prevent io-fouling within the intke pipework nd prevent legionell EPR 1.01 sttes tht indictive BAT for emissions from cooling tower purge is to: Optimise the dosing regime for iocides in evportive cooling towers to minimise their use Chemiclly treting the min cooling wter circuit my llow the reduced use of iocides. Do not relese ccidentl overdoses of iocides into the environment The Cooling BREF suggests tht there re two pproches tht should e tken for the control of emissions from industril cooling systems: Prevention y design nd mintennce; nd Control y optimised cooling wter tretment For prevention, the Cooling BREF sttes tht, for ll wet cooling systems, the choice nd ppliction of mterils sed on their corrosion-sensitivity should e undertken through nlysis of the cooling wter in order to select the correct mterils. The Cooling BREF lso sttes tht the design of the cooling tower system should void stgnnt zones in order to reduce fouling nd corrosion within the system The detiled design of the Project will consider ll mient nd process prmeters (which will include the wter qulity nd its likely vrition over the lifetime of the Project) nd will lso e designed with regrd to mintining high operting efficiencies For the control of emissions, the Cooling BREF sttes tht this should e chieved through reduced (optimised) dditive ppliction of dosing chemicls nd the selection of chemicls tht represent the lest risk possile to the environment (e.g. chromium nd mercury compounds re not BAT)

62 The cooling tower effluent will e continuously monitored for flow, temperture, ph nd other wter chemistry prmeters in order to ensure the efficiency of the cooling tower tretment systems. These prmeters will e used to optimise the dosing regime to ensure tht the mounts of these chemicls re kept to n solute minimum. Blowdown Within the Project, stem will e generted from high purity wter (i.e. within the HRSG or the het exchngers of the syngs cooling system). This wter is used to protect ginst internl corrosion nd reductions in opertionl efficiency s result of fouling / scling of the equipment tht will form the stem cycle for the Project. Although of extremely high purity, this wter will still contin some dissolved solids. Wter qulity within the wter / stem circuit will e controlled y continuously purging smll quntities from the system (lowdown) to prevent the excessive concentrtion of dissolved solids within the HRSG (nd tretment chemicls, noted in EPR 1.01 s e.g. phosphtes, smll mounts of lklis, hydrzine, mmoni, etc.) This wter will e treted (in the wste wter tretment plnt) nd re-used within the Project or dischrged either vi the hyrid cooling towers or directly into the cooling wter dischrge system. Deminerlistion Effluent EPR 1.01 sttes tht indictive BAT, for de-ionistion effluent is to, neutrlise wter de-ionistion plnt regenertion effluent efore dischrge The wste wter tretment plnt will collect ll process effluents, including the deminerlistion plnt effluent, nd will include mesures to control the ph s descried elow. Gsifiction Plnt Effluent The Drft LCP BREF does not present BAT conclusions for the prevention nd control of wter pollution from the gsifiction process. However, Section of the BREF sttes, under Techniques to consider in the determintion of BAT, Wste wter is recirculted fter internl tretment for IGCC plnts nd gsifiction plnts using syngs wet clening techniques Wter from the syngs scruer will e sent to the Wste Wter Tretment Plnt prior to re-use, where prcticle, within the Project. Wste Wter Tretment Plnt Effluent The Drft Wste Wter BREF sttes, t BAT Conclusion 26: BAT is to remove the pollutnts from wste wters generted t chemicl sites efore their dischrge to receiving wter ody y pplying one of the following techniques: -67 -

63 Collection of wste wters nd their tretment t centrl wste wter tretment plnt on the chemicl site, with or without n on-site centrl pre-tretment of the triutry strems. Collection of wste wters nd their tretment t wste wter tretment plnt outside the chemicl site, provided tht n equivlent level of protection of the environment s whole is gurnteed nd provided this does not led to higher levels of pollution in the environment compred with the ppliction of BAT 26(I). Wste wters generted t the chemicl site might e suject to n on-site centrl pre-tretment prior to their dischrge to n off-site wste wter tretment plnt The wste wter tretment plnt will collect ll process effluents from within the Project (with the exception of the cooling tower purge) nd will thus e BAT in respect of the ppliction of centrl Wste Wter Tretment Plnt. The Wste Wter Tretment Plnt is descried in detil lter in this section ( Process Descriptions ) Prgrph () ove is not considered to pply in the cse of the Project BAT Conclusions 39 nd 40 provide discussions of uffer tnks efore nd fter the Wste Wter Tretment Plnt, respectively: BAT is to prevent fluctutions in the effluent wste wter qulity nd to lower effluent emissions y lncing of flows nd pollution lods/concentrtions t the inlet to the centrl wste wter tretment plnt y using n equlistion tnk. BAT is to reduce the emission of pollutnts to the receiving environment due to opertionl filures, equipment lekges nd ny ccidentl spills y hving uffer storge cpcity ville in order to store wste wters for their further recovery, tretment nd/or disposl The Wste Wter Tretment Plnt will incorporte sufficient flow-lncing nd uffer rrngements in order to ensure efficient opertion of the Wste Wter Tretment Plnt nd provide suitle environmentl protection. These will e complimented y monitoring of oth the inlet nd outlet of the tretment plnt BAT Conclusion 41 sttes: BAT is to reduce the emission of totl suspended solids (TSS) from centrl wste wter tretment plnts y pplying I nd II elow: -68 -

64 prior to downstrem iologicl tretment in order to ensure the proper functioning of the tretment system y pplying one or more of the following techniques: i ii iii iv grit seprtion cogultion nd floccultion sedimenttion flottion fter downstrem iologicl tretment nd efore the finl effluent dischrge y pplying one or more of the following techniques: i ii iii iv sedimenttion filtrtion microfiltrtion ultrfiltrtion The effluents from the wter / stem cycle lowdown (including the syngs cooling system) nd the deminerlistion plnt will e such tht pre-tretment will not e required The effluent from the Gsifiction Plnt will e pre-treted using the following methods: c Degssing Floccultion Clrifiction The finl stge of the wste wter tretment plnt could incorporte dul medi filter, which will use snd nd nthrcite s filter medi, nd ctivted cron filters BAT Conclusion 43 sttes tht, BAT is to reduce the emission of totl nitrogen from centrl wste wter tretment plnts y pplying iologicl nitrifiction / denitrifiction The Project will therefore incorporte ll specific BAT for the control of emissions to wter from centrl wste wter tretment plnt. Process Descriptions The Project will e designed to provide totl genertion cpcity of up to 470 MWe under norml operting conditions. The Generting Sttion will operte either s CCGT or n IGCC plnt

65 When operting s CCGT plnt the Generting Sttion would e fired on nturl gs which would e otined vi n existing high pressure gs supply network in the re. When operting s n IGCC plnt the Generting Sttion would e fuelled y col (principlly), possily lended with petroleum coke (petcoke) or iomss from which syngs will e produced to fuel the generting sttion. It my lso operte on iomss lone in certin circumstnces Electricl genertion within n IGCC power sttion is sed round the estlished concept nd technology of CCGT plnt utilising n rrngement of gs turines nd stem turines, such s tht operting t the Centric nd E.ON Killingholme Power Sttions tht re close to the Principl Project Are. However, when operting s n IGCC syngs is urned in the gs turine in plce of nturl gs. Figure 8 presents schemtic representtion of the CCGT principle IGCC opertion of the Generting Sttion, with cron cpture nd storge, would tke plce when solution for trnsporting nd storing the cptured CO 2 from the Generting Sttion is in plce. Currently, vile trnsport nd storge system is not ville. It is nticipted tht, in due course, CO 2 trnsport infrstructure will ecome ville through which cptured CO 2 could e trnsported for storge in empty gs / oil fields or deep sline formtions under the North Se ed. A smll proportion of the cptured CO 2 could possily e supplied to industry or other users, ut the mjority of the cptured CO 2 would require trnsport nd storge. The infrstructure required for CO 2 trnsport nd storge does not form prt of the Project nd is therefore not included in this ppliction There re certin circumstnces when IGCC opertion might tke plce without CO 2 cpture, trnsport nd storge (s descried in Section 3.5) Figure 9 shows schemtic representtion of the IGCC principle. Gs Turine The Power Islnd will comprise n industril type gs turine tht will consist of n inlet ir filter; n ir compressor; comustion chmers; power turine; nd exhust silencer. Air will e compressed in the compressor of the gs turine nd gseous fuel injected into the comustion chmers where the fuel will urn producing hot, high-pressure gses. These gses will expnd cross the rotor ldes of the gs turine, which will drive oth the compressor nd the electricl genertor(s). Het Recovery Stem Genertors The low-pressure exhust gses from the gs turine will still contin useful nd recoverle het energy; the exhust gses will pss through HRSG where this het will e extrcted from the exhust gses to rise stem. The HRSG is likely to comprise seprte high, medium nd low pressure stem circuits. Stem Turine The resultnt stem will e provided to condensing stem turine t rnge of elevted pressure levels nd will expnd cross the stem turine ldes. This expnsion will, s within the gs turine, rotte the turine nd drive the sme or n dditionl electricl genertor to increse the electricl output of the Project. The residul het within the spent stem will e rejected vi condenser system nd the resultnt condenste will e returned to the HRSG for re-use

66 Condensing System The finl exhust stem will e conveyed from the stem turine plnt to condenser system. The het rejected y the condensing stem is pssed to, nd thus hets, the cold cooling wter. The wter forming in the condenser will then e returned vi mechnicl de-ertor to the HRSG for conversion ck into stem. Gsifiction Plnt The gsifiction of solid fuel involves its prtil comustion, in gsifier, with pure oxygen nd t high temperture nd pressure. This produces flmmle syngs, primrily consisting of cron monoxide (CO) nd hydrogen (H 2 ). Pure oxygen for the comustion will e provided y the ASU The fuel preprtion will include roller-type mills, similr to those used in trditionl col-fired power sttion nd n internl hot gs genertor to generte hot inert gs strem. The mills will rek down the solid fuel to size rnge suitle for efficient pneumtic trnsport nd gsifiction. As the fuel is ground it will, lso, e dried y the heted inert gs strem so tht the wrm gs evportes the wter in the col. Pulverised col will e removed from the gs strem y g filters or similr Pulverised nd dried col will e trnsported to the col pressuristion nd feeding system. This system will consist of: lock hoppers where the col strem is pressurised with nitrogen; nd feed hoppers tht receive the pressurised mixture nd feed the fuel to the gsifier lso using strem of nitrogen The gsifier will consist of pressurised vessel contining the gsifiction chmer nd solid fuel injectors. The gsifiction process produces syngs which, t tht stge, is gseous mixture of predominntly CO nd H 2 ; ny inert compounds within the fuel form molten slg tht flows towrds the ottom of the gsifier The gsifiction process tkes plce t etween 1400 nd 1700 C. The molten slg will fll into wter th t the se of the gsifier. The slg then solidifies on contct with this wter for removl y sluicing system For CO 2 cpture to tke plce, the syngs psses through shift rector, converting the CO nd wter into H 2 nd CO 2 fter eing scrued with wter to remove remining solids nd wter-solule gses like hydrochloric cid ("HCl") nd mmoni ("NH 3 "). In susequent het exchngers the syngs will e cooled to pproximtely 40 C y producing stem t severl pressure levels. An ctivted cron filter will remove trces of mercury nd other undesirle sustnces. The cid gs removl ("AGR") equipment will remove CO 2 from the gses exiting the shift rector nd gs cooling system, together with ny sulphur compounds produced in the gsifier, soring these cid gses into solvent 4 within the AGR sorer unit. The syngs exiting the sorer is mixed with nitrogen (from the ASU 5 ) nd / or stem. This is to control the fuel gs composition to within the tolernces for optimum firing efficiency nd NO x reduction for the gs turine. 4 The Acid Gs Removl technology uses solvent tht is mixture of dimethyl ethers of polyethylene glycol. The solvent will hve no dverse impct on the environment lthough direct dischrges to surfce wter will e voided. 5 The ASU will consist of severl compressors nd frctionting columns tht will produce pure oxygen nd nitrogen through the cryogenic distilltion of the mient ir

67 There re certin circumstnces where IGCC opertion might tke plce without CO 2 cpture, trnsport nd storge. In such cse, the syngs, fter eing scrued with wter to remove remining solids nd wter-solule gses, will ypss the shift rector. As consequence, the syngs keeps its originl composition consisting minly of H 2 nd CO. The ctivted cron filter will remove trces of mercury nd other undesirle sustnces. The AGR equipment is dequte to remove the sulphur compounds produced in the gsifier in this different operting scenrio, soring these cid gses into solvent within the AGR sorer unit. The syngs exiting the sorer could e mixed with nitrogen (from the ASU) nd / or stem The resulting solvent, enriched with sour compounds, from the AGR sorer will then e pssed through selective regenertion process where the cid gses will e removed s seprte strems nd the len solvent is returned to the AGR Cptured sulphur compounds, principlly hydrogen sulphide, will e converted to elementl sulphur tht will e sold s commercil y-product of the Project. The sulphur recovery unit will consist of urners utilising low pressure oxygen from the ASU s n oxidnt. This oxidnt will convert hydrogen sulphide ("H 2 S") into SO 2 nd wter vpour. The sulphur recovery unit will lso consist of numer of so-clled Clus rectors tht will convert SO 2, into elementl liquid sulphur, in ctlytic mnner. The sulphur will then e collected into sulphur pit prior to trnsporttion to the end user y truck The gses exiting the Clus units still contin some H 2 S, SO 2 nd sulphur trioxide ("SO 3 "). After comustion, these components re re-converted into H 2 S in the hydrogention unit. After cooling in quench tower nd compression nd fter hving pssed through the quench tower, the H 2 S is re-injected into the min syngs strem just efore the ctive cron filter. This ssures tht, under norml opertion, no sulphur compounds (other thn some trces of SO 2 exiting the Min Stck) re emitted into the tmosphere. Hyrid Cooling Towers Hyrid cooling towers re composed of wet section nd dry section. Hot wter leving the condenser nd the users in the Gsifiction Plnt units is pssed to the top of the towers nd flows through n ir cooled het exchnger tht performs pproximtely 20 per cent of the cooling duty of the towers, depending upon mient conditions. The wter leves the het exchngers nd is spryed down the wet section of the towers where the remining het is lost through evportion. A significnt environmentl dvntge of this hyrid system is tht most of the time the ir leving the cooling tower is under-sturted with wter, nd so no vpour plume will e visile This evportion nd continuous recircultion results in concentrting of the dissolved solids present in the cooling wter tht could impct on the operting efficiency of the condenser nd cooling systems through fouling / scling of the het trnsfer interfces. In order to mintin the correct chemicl control of the system, it is necessry to purge continuously the cooling wter nd replce this wter, nd tht lost y evportion, with mke-up tken from rw wter source, which will e the River Humer

68 Rw Wter Tretment A seprte, dedicted on-site deminerlistion tretment plnt will tret fresh mins wter provided y Anglin Wter to qulity suitle for use in the HRSG. Two tretment methods (or comintion of oth) re under considertion for the Project: Ion Exchnge The tretment process to e used involves filtrtion, followed y the exchnging of ctions in the supply (clcium, mgnesium, sodium, etc) for hydrogen ions y using ction exchnge resins nd then exchnging the nions in the dectionised wter (sulphte, chloride, cronte, silicte, etc) for hydroxyl ions y using nion exchnge resins. When the resins re exhusted the resin eds re ckwshed, regenerted with dilute cid (for the ction resin) nd with dilute custic sod (for the nion resin), rinsed to remove ny excess regenernt nd returned to service. The deminerlistion plnt will consist of: fresh wter rek tnk, deminerlised wter storge tnks, n cid storge tnk, custic storge tnk, n utomtic effluent neutrlising system, control pnel nd ll interconnecting pipe work. The treted wter storge tnk will hve the cpcity to hold treted wter sufficient for full lod opertion of the Project for round dy; nd Reverse Osmosis Rw wter is pssed through semi-permele memrne under pressure. The memrne is designed so tht wter is llowed to pss through while retining the dissolved solids for dischrge with the reject wter. Reverse Osmosis plnts my consist of multiple stges depending upon ny concentrtion nd flow requirements of the effluents The deminerlistion plnt effluent will e concentrted solution of ll the dissolved solids present in the rw mins wter, with possily some dditionl sodium sulphte or sodium chloride produced s result of ny effluent neutrlistion requirements. Genertor(s) The genertors will e of the cylindricl rotor type nd will e cooled y ir or hydrogen in closed circuit cooling rrngement. Auxiliry Boilers One (or more) smll uxiliry oiler(s) of the order of 30 megwtts therml ("MWth") my e instlled to provide stem for the strt-up of the Project nd will operte intermittently for limited numer of hours per yer. The oiler will provide stem, normlly provided y the het recovery stem genertor, for deertion of the feedwter / condenste efore its introduction into the min oiler; to wrm the stem piping nd stem turine glnd system. An electric vcuum pump or stem injector will e used to estlish the condenser vcuum during strt-up of the min power sttion The oiler(s) my e complemented with one or more emergency diesel-genertors necessry to provide electricity to vitl uxiliries under lck-out conditions

69 Fuel Supply, Mterils Hndling, Utilities nd Infrstructure During opertion s CCGT plnt, nturl gs will e supplied to the Generting Sttion y dedicted supply pipeline to the high-pressure gs network nd will not e stored on-site. Nturl gs will e delivered y pipeline to n on-site conditioning plnt, where its pressure nd temperture will e mtched to the requirements of the gs turine When operting s n IGCC plnt, in ddition to the ove requirement for highpressure nturl gs connection to del with strt-ups nd to enhnce the plnt's vilility, it is nticipted tht solid fuel would e delivered, y se, to existing deep wter port fcilities t the River Humer (with susequent trnsfer to the existing erth within the whrfge re t CPK), or y ril The options for solid fuel delivery to the Project re: Trnsfer y rge to the existing whrfge re of CPK. The solid fuel would then e unloded from the rge nd closed pipe conveyor system would deliver the fuel to the Opertions Are. It is estimted tht up to three rge convoys (ech of up to four rges) per week would e required in order to meet the mximum nticipted fuel consumption of the Project; nd Trnsfer y trin directly to the Fuel Hndling Are which will e included s prt of the Gsifiction Plnt. A worst cse ssessment of delivery y hlf-trins hs noted tht n verge of 5 hlf-trin deliveries would e required ech dy. The existing rilwy line tht serves CPK would need to e modified to provide new siding in order to ccommodte the fuel delivery trins. A ril hed, locomotive run-round fcilities nd n unloding fcility would e provided within the Opertions Are A screw-type CSU is the preferred option for unloding fuel from rges. This type of unloder incorportes totlly enclosed conveying system which prevents the emission of dust except t the inlet screw / col interfce on ord the rge, nd the point of trnsfer from the CSU to the pipe conveyor The inlet feeder is designed to trnsfer mteril from elow the surfce of the ulk solid fuel nd in conjunction with the greter rech nd mnoeuvrility, when compred to other unloding methods, llows for lmost dust free unloding s crgo vlnches cn e minimised It remins possile tht nturl gs my lso e used s fuel during opertion s n IGCC plnt. The modifiction of the gs turine for IGCC opertion will not prohiit the Power Islnd from firing on nturl gs t times where the Gsifiction Plnt is not ville (e.g. during unforeseen mintennce). On-Site Storge For oth of the ove options, the on-site storge cpcity is proposed to e sufficient for t lest two weeks' continuous opertion of the Generting Sttion in order to protect opertion of the Project from ny interruption or disruption to the supply of solid fuel

70 Col, the principl solid fuel for the Project operting s n IGCC plnt, will e stored within dedicted covered fuel storge uilding. Prticulte nd dust emissions rising from the storge, hndling, conveying nd pre-processing of solid fuels will e limited vi vriety of dust mitigtion mesures, including stndrd est prctice nd pproprite filters. Strt-Up nd Shutdown For strt-up of the Power Islnd (i.e. the gs turine nd the stem turine), the strt sequence comprises two distinct opertions: synchronistion nd rmp-up to the instructed output level. The whole opertion will tke up to 180 minutes to full lod for cold strt. Opertion t strt-up nd low lod uses diffusion flme urners. Hence during strt-up of the gs turine NO x emissions will e higher thn the full lod vlue, the NO x emissions will e met t no greter thn 70 per cent gs turine unit lod fctor in ccordnce with the requirements of the IED Once generting unit is synchronised it cn e rmped up to the instructed lod. The rte of loding of the gs turine depends upon the metl tempertures of the stem turine nd HRSG, nd the rte t which stem cn e introduced. Once gs turine lod is reched, comustion is switched to pre-mix urners nd the NO x emissions will ttin the full lod levels For the Gsifiction Plnt, strt-up of the gsifier nd ssocited equipment is expected to e pproximtely 120 minutes (cold strt). The principl ctivities during this period will e the initil ignition of the strt-up urners (possily firing on nturl gs) nd the wrming / preprtion of the process nd, following ignition of the min solid fuel urners, the pressuristion of the gsifier unit Shutdown of the Gsifiction Plnt is expected to tke round 15 minutes for the lod on the gsifier to e reduced nd stopped. Additionl time my e required in order to sfely shutdown (i.e. cool nd / or depressurise) the reminder of the ssocited equipment. Control nd Operting Philosophy The Project is nticipted to operte s se lod plnt (i.e. it will not e suject to regulr significnt fluctutions in the electricl output). Whilst trditionl CCGT plnts re considered flexile, nd cn dopt numer of different operting regimes (such s two-shifting nd lod following), the Gsifiction Plnt is not s flexile nd thus limits the potentil operting regimes for the Project when operting s n IGCC plnt The proposed operting regime will result in pproximtely strt-ups nd shutdowns per nnum Dt from the continuous monitoring of emissions to ir nd dischrges to wter will e integrted into the power sttion DCS with relevnt signls operting control-room lrms. Opertionl stff will hve ccess to environmentl informtion nd will e trined to ensure complince with regultory limits. Historicl records of up to ten yers will e stored within the DCS nd e retrievle on demnd. Older records will e downloded to off line storge

71 Mjor plnt mintennce shut downs will e plnned on long-term sis with such outges likely to e infrequent (of the order of every four yers) nd of short durtion only (up to six weeks). Mintennce progrmmes will e developed to e in ccordnce with the recommendtions of the equipment mnufcturers recommendtions nd operting instructions There my occsionlly e forced outges which will e infrequent in nture nd typiclly of very short durtion. 4.4 Generl Requirements Control of Fugitive Emissions to Air Unit protection systems will e designed to ensure sfe plnt strt-up, to prevent the initition of events leding to hzrdous operting conditions nd to execute emergency shutdown of plnt in the event of mjor fults in the equipment One (or more) smll uxiliry oiler(s) my e instlled for the Project, possily complemented y one or more emergency diesel-genertors. The opertion of this equipment will e restricted to strt-up or emergency shutdown events. Routine testing of the units will e undertken, which will typiclly e for 30 minutes t weekly intervls The risk of fugitive emissions to ir is minimised y scheduled mintennce of nturl gs continment / pre-tretment to minimise the relese of unurned gs In respect of emissions from fuel hndling, the fuel hndling process (including the continuous screw unloder, the conveyor elts, the col stcker nd storge), will produce emissions of less thn 10 kg/dy of dust (sed on emissions fctors from TNO-Mulder (1987) 6 nd TAUW (2010) 7 ) which could e redily controlled y dustsuppression mesures such s spry-dmpening. Spry dmpening hs the potentil to minimise up to 98 per cent of dust emissions 8 such tht the overll emissions of dust will e limited to c.0.2 kg/dy. As such there will e no significnt relese of dust to ir A pipe conveyor hs een selected for the Project tht will operte such tht, following loding, the conveyor elt is folded over itself creting seled trnsfer pipe until the point of dischrge. Thus, the potentil for ny dust emission or ccidentl fuel spillge long the length of the conveyor is eliminted. The return prt of the conveyor will lso e folded, thus eliminting ll dust emission from the conveyor return The unloding of rilwy wgons will tke plce within uilding tht will e open on two sides to llow for the pssge of the trin through the uilding. The minor dust emissions tht will e generted during unloding will e contined within the uilding y the utilistion of stndrd dust suppression techniques tht could include spry dmpening of the internl re nd the use of temporry screens t either end of the uilding to crete n enclosed environment s the wgons re unloded. 6 TNO (Ntionl Institute On Applied Reserch), Dust Emission Fctors for Hndling of Bulk Mterils, W. Mulder, TAUW (Engineering nd Consultncy Agency), Emission Reduction Mesures for Fine Dust, commissioned y Dutch Ministry of Environment, Octoer EU IPPC Reference Document on Best Aville Techniques on Emissions from Storge (July 2006) -76 -

72 4.4.4 Other potentil fugitive emissions to ir comprise releses of cron dioxide from the deluge fire fighting system. This will e restricted to emergency fire-fighting events nd routine testing or mintennce. Control of Fugitive Emissions to Wter The sources, direction nd destintion of ll drins will e estlished nd recorded. The sources, direction nd destintion of ll susurfce pipe-work will e estlished nd recorded. Any susurfce sumps nd storge tnks will e identified. Lekge from pipes etc. will e minimised. All susurfce pipe-work will e enclosed within lined trenches Bunds will e provided round tnks nd sized to hold not less thn the greter of 110 per cent of the lrgest tnk contents or 25 per cent of the totl tnk contents within the und, plus n llownce if pplicle for the volume of fluid from ny ssocited fire protection system or rinwter. The following equipment will e locted in unded res: c d e f g Emergency diesel genertor(s); diesel fire pump fuel oil tnk; chemicl storge re; gs turine luricting oil module; stem turine luricting oil module; stem turine fire resistnt fluid ("FRF") module; nd oil filled trnsformer compounds These unds will e impermele nd resistnt; will contin no outlet,;will drin to lind collection point; will contin no penetrtion of contined surfces; will e designed to ctch leks from fittings; nd will hve fill points inside the und Any rinwter collected in the und sumps long with ny minor spillges will e pumped vi portle pump to suitly locted oily wter seprtor. The pumps will e of low sher design to prevent emulsifiction. Mjor spillges of oil or oil/wter emulsions cused y high velocity sprys of the fire protection system will e trnsferred to suitle continers for off-site disposl Ares where there is dnger from oil-contminted wste wter will drin under grvity or e pumped to suitly locted tilted plte seprtors. A licensed contrctor will dispose of the seprted oil off site. Recovered wter will e trnsferred to the storm wter drins sump (from surfce drins) or the wstewter tretment sump (from process drins) prior to dischrge All oils will e stored in unded res. Any spillge will e collected nd removed from site. All rinwter will e pumped to Clss 1 oil/wter interceptor. Therefore, ny spillges will e prevented from entering the ground wter Ammoni, List II sustnce, will e stored on site. Up to 2 m 3 of mmoni solution my e stored on site in unded re. Any spillges in the unded re will e -77 -

73 collected nd removed from site. All rinwter in the unded re will e smpled efore pumping to the dringe system. No mmoni cn enter the ground wter In ddition, trce quntities of cdmium nd mercury my e present in ny cid nd custic sod required for neutrlistion of effluents or regenertion of the processes within the wter tretment plnts. Wherever possile, cid nd custic free from these sustnces will e sourced. In either cse, storge tnks for oth hydrochloric cid nd custic sod will e unded, nd, s such, direct or indirect dischrges of List I or II sustnces to ground wter cnnot occur All unds will, through the EMS, e suject to n pproprite progrmme of inspection, testing nd mintennce. EMS procedures will lso ensure continment of spills from unded res. For exmple, unds exposed to rinwter will e inspected regulrly nd ny contents tested nd disposed of ppropritely Ares where rod tnkers prk to unlod oils or chemicls will e unded or kered. Control of Odour The design nd mngement of the Project, when operting s CCGT plnt, will e such tht there will e little susceptiility to detectle odour, lthough odour minimistion will e mnged within the EMS The relese of unurned nturl gs will e minimised y scheduled mintennce. The sence of odornt from nturl gs further reduces the odour impct of such releses During opertion s n IGCC plnt, sources of odour will e: c Wste wter tretment plnt; Solid fuel preprtion; nd Flre Stck Odour emissions from the Flre Stck will e controlled y ensuring efficient comustion of gses sent to the Flre Stck (e.g. including stem ssistnce to mintin the flme stility) nd the destruction of odorous compounds (i.e H 2 S). Such emissions will e minimised y the use of the Flre Stck s strt-up, shutdown nd emergency mesure only in ccordnce with BAT for flring events The fuel preprtion will include roller-type mills, similr to those used in trditionl col-fired power sttion, nd n internl hot gs genertor to generte hot inert gs strem. The mills will rek down the solid fuel to size rnge suitle for efficient pneumtic trnsport nd gsifiction. As the fuel is ground it will, lso, e dried y the heted inert gs strem so tht the wrm gs evportes the wter in the col. Pulverised col will e removed from the gs strem y g filters or similr All chemicls nd dosing systems will e shielded from the tmosphere. Air dischrged from the mmoni nd other process dosing chemicls will pss through device such s common wter sel nd n ctive cron filter, where pproprite, in order to void the uncontrolled relese of these chemicls to the tmosphere

74 The EMS for the Project will incorporte full odour mngement pln tht will descrie mesures for the conducting odour monitoring nd, where necessry, responding to identified events. The Pln will e suject to regulr review nd chnge mngement, s required, s per the EMS s whole. Control of Noise nd Virtion The principl noise-emitting items of plnt contined in the Project re considered to e: c d e f g Gs turine; Stem turine; HRSG; Compressors; Hyrid cooling towers; Pressure vlves; nd Ventiltion pertures It is nticipted tht the overll noise produced y the Generting Sttion will e of constnt nd stedy nture, with the inclusion of some tonl content due to the opertion of trnsformers nd fns. The principl sources of intermittent noise will e the opertion nd testing of sfety vlves. The testing of these vlves will e infrequent nd during dylight hours The Project is to incorporte significnt numer of mitigtion mesures to reduce the noise emitted into the locl environment. These BAT mesures include: -79 -

75 c d e The gs turine, stem turine nd mjor compressors will e housed in individul coustic enclosures, of hevy construction, specified t 85 db(a) Sound Pressure Level t 1 m. In turn, these re housed within the Turine Hll or Compressor Hll; Turine filter nd ventiltion pertures re to e fitted with high performnce silencers, nd designed such tht ll sensitive receptors enefit from screening nd/or directivity corrections; Internl surfces within the turine hll will e treted to control internl reverernt noise levels. An pproprite tretment would consist of dense minerl wool pnel ehind perforted sheet steel, or spry-on cellulose fire tretment; High performnce silencers will e instlled in the outlet duct(s) etween the gs turine nd the HRSG. Due to the imprcticlity of screening stck noise, dischrge noise will e controlled using these silencers tht will e tuned to ttenute low frequencies from the gs turine exhusts; nd Unit trnsformers nd genertor trnsformers will e housed in n pproprite enclosure or three sided pen, to provide full screening to noise sensitive receptors The principl dditionl noise emitting items of plnt during opertion s n IGCC plnt will e: Gsifier; nd Fuel milling, drying nd pressurising A full ssessment of the potentil impcts of Noise nd Virtion from the Project ws undertken s prt of the EIA for the Project nd is presented in the ES tht ws sumitted s prt of the DCO ppliction. The full report is included with this ppliction in Section 10 of the ES tht is included s Appendix D of this document. 4.5 Types nd Amounts of Rw Mterils Generl Rw Mterils With regrd to new developments, in prticulr those which my reduce the environmentl impct of the proposed CCGT power sttion, regulr reviews of methods of reducing emissions of oxides of nitrogen, investigtions into identifying potentil users of stem nd methods of chemicl control of feed wter, oiler wter nd process wter will e conducted in ccordnce with the requirements of the The rw mterils used in the process re: -80 -

76 c luricting oil: luricting oil will e used in the gs turines, stem turine nd other mechnicl equipment. Occsionl top up or replcement will e required; trnsformer oil: trnsformer oil (free of pc) will e used in oil cooled trnsformers. Occsionl top up or replcement will e required; nd dosing chemicls: vrious chemicls will e used for feed wter nd oiler wter dosing. Typicl chemicls re mmoni or other neutrlizing mine, crohydrzide, or other oxygen scvenger, nd trisodium phosphte An inventory of rw mterils is shown in Tle 15. Tle 15: Inventory of Rw Mterils Mteril Purpose Quntity Stored On-Site Fte Luricting oil Used for luriction nd hydrulic control 20 tonnes Returned to mnufcturer Trnsformer oil Used for cooling 20 tonnes Returned to mnufcturer Dosing Chemicls Crohydrzide Ammoni Trisodium Phosphte Used for HRSG/feedwter chemicl control 2 tonne 2 tonne 2 tonne Dischrged in oiler lowdown either for reuse or to sewer Supplies of the luriction oil nd trnsformer oil nd other mterils in smll quntity will e delivered to the site y rod. All vlves, pipework nd couplings ssocited with the filling/emptying of oil storge tnks will e contined within the und surrounding the tnk All chemicls used on site will e stored within unded re sized to ccommodte the greter of 110 per cent of the contents of the lrgest tnk within the und or 25 per cent of the totl tnk contents. All spillges will e retined within the unded res nd treted s necessry prior to disposl off-site in mnner tht ensures no dverse environmentl impct The BAT ojective is chieved y the low consumption rtes of rw mterils inherent in power sttion design, y the selection of lest hzrdous mterils nd y pproprite storge. The EMS will provide mechnism for minimising the risk of spillges nd mnging down the consequences of ny such incident. It lso provides mechnism for identifying those mterils on site tht possess significnt impcts or risks nd for identifying lterntives where economiclly vile

77 Fuels Nturl Gs When operting s CCGT plnt (t full lod) the design efficiency of the Project will e greter thn 55 per cent (LHV). The Project will require pproximtely 840 MWth (255 million therms per nnum) of nturl gs No nturl gs will e stored on-site nd will e supplied on n uninterruptle sis. Col It is expected tht col will e the principl solid fuel used in the gsifier. The Project, during opertion s n IGCC plnt with CCS, will e designed with net electricl efficiency of round 36 per cent ( LHV). If the Project is fired solely y col, pproximtely 200 tonnes per hour will pss through the gsifier The on-site storge cpcity is proposed to e sufficient for t lest two weeks' continuous opertion of the Project in order to protect its opertion from ny interruption or disruption to the supply of solid fuel. Therefore, the minimum on-site fuel storge requirements will e pproximtely tonnes Allowing for fuel utilistion of 91 per cent (in ccordnce with the minimum BAT requirements), the minimum on-site storge would e pproximtely tonnes. Other Fuels During opertion s n IGCC plnt, the Project my use solid fuel tht consists of mixture of col nd torrefied iomss nd / or petcoke Typicl usge of iomss could e pproximtely 17.1 kg/s, with on-site storge of round tonnes Typicl usge of petcoke could e pproximtely 13.0 kg/s, with on-site storge of round tonnes. Wter The use of wter will e monitored nd the EMS will provide mechnism for reducing its use where commercilly vile Wter will e used in the Project primrily for mke-up to the hyrid cooling towers of evportive losses. Wter will lso e required s mke-up to the stem / wter cycle of the oiler / stem turine nd syngs cooling system Deminerlised wter will e supplied, vi the dedicted on-site wter tretment (deminerlistion) plnt, with rw wter supplied from the Anglin Wter min supply It is proposed to recover nd reuse lowdown in the rw wter tretment plnt. Boiler lowdown is high purity wter contining smll mounts of mmoni nd phosphte. Other losses from the stem / wter cycle of the Project will e minimised y good mintennce

78 A dedicted storge of fire fighting wter will e retined in the rw wter tnk. A wter deluge system will e provided for the trnsformers. Cron dioxide deluge fire fighting systems will e employed in the gs turine re Minor quntities of wter will e used for domestic / snitry purposes (drinking, wshing, etc). 4.6 Comustion Sector Fuel Usge Nturl Gs The nturl gs will e trnsported to the site vi n underground pipeline with no onsite storge or tretment fcilities eyond djustment of temperture, pressure nd filtrtion nd knockout pots to remove ny condensed liquids The gs turines will operte on nturl gs, with typicl specifiction shown in Tle 16. Tle 16: Nturl Gs Specifiction Compound Typicl Mole (per cent) Nitrogen 0.84 Cron dioxide 1.08 Methne Ethne 5.15 Propne 1.61 Butne 0.5 Pentne 0.12 Totl sulphur <0.001 Gross clorific vlue 41.7 MJ/m The Project will include emergency diesel genertors to provide emergency ck-up nd enle the plnt to e shut down in sfe mnner in the event of loss of electricity. It is expected tht this genertor will only ever e operted for routine testing procedures of round 30 minutes t weekly intervls The diesel (distillte fuel oil) will hve sulphur content of less thn 0.1 per cent. The fuel supply contrcts will specify the nlysis of the fuel; C.GEN will require n nlysis from the supplier to ccompny ech delivery s condition of cceptnce. The sulphur content of the distillte fuel oil would e typiclly 0.05 per cent

79 Syngs The Gsifiction Plnt will supply syngs to the gs turine for comustion following the gsifiction of solids fuels descried ove. The composition of solid fuels tht re fed to the gsifier hs little effect on the overll composition of syngs produced A typicl syngs composition is provided in Tle 17. Tle 17: Syngs Specifiction (prior to Gs Turine) Compound Hydrogen 65.6 Oxygen 0.2 Nitrogen 13.6 Cron monoxide 2.4 Cron dioxide 2.5 Wter (vpour) 15.8 Gross clorific vlue 19.9 MJ/m 3 Typicl Mole (per cent) 4.7 Monitoring Environmentl Monitoring The will impose emissions limits on the Project tht will e ssocited with the ppliction of BAT nd these emissions levels hve een ssessed s prt of the comprehensive EIA undertken for the Project (s presented in the ES, included s Appendix D of this document) The conclusion of the ES is tht the residul impcts, for ir, wter nd noise, re ll Not Significnt nd, s such, no off-site monitoring is proposed for the Project Monitoring Stndrds All monitoring within the Project will e undertken in full ccordnce with the EA Technicl Guidnce Notes M1 nd M2 nd the Europen IPPC Bureu s Reference Document on the Generl Principles of Monitoring. C.GEN will lso pply the British Stndrd EN Sttionry Source Emissions Qulity ssurnce of utomted mesuring systems, s pproprite Where possile, ll monitoring equipment will e certified to the EA MCertS scheme. If no suitle equipment with MCertS is ville, instruments certified to other ntionl stndrds will e used. Where this is not possile instruments with proven reliility will e selected

80 4.7.4 The monitoring system will e designed to produce reports in the formt required y the EA nd include dt storge fcilities to enle exmintion of records should environmentl incidents occur in the re. Anlyticl methods used will e in ccordnce with methods recommended y the EA or where no such recommendtion exists, to relevnt interntionl or ntionl stndrds. Point Source Emissions to Air Gs turine operting prmeters (e.g. fuel flow, power output, inlet temperture), O 2 nd flue exit temperture will e monitored continuously during opertion. Owing to difficulties in mesuring lrge volumes of ir flow through the gs turine, the flow rte will e clculted from mnufcturers dt nd the fuel flow nd power prmeters. Control of the gs turine comustion temperture nd the fuel rtio nd monitoring of the NO x emissions will e used to control exhust NO x concentrtion. All lrms will e monitored y the distriuted control system in the centrl control room Concentrtions of NO x, O 2 nd CO will e continuously monitored in the Min Stck. During opertion s n IGCC plnt, the continuous monitoring will e extended to include SO 2 nd PM 10. The emissions monitoring instruments will e clirted on regulr sis. The NO x signl will e corrected for O 2 nd moisture nd the signls recorded y the Emissions Monitoring System. Post commissioning tests will monitor the levels of NO, NO 2, CO nd O 2. This utomted monitoring systems will e MCertS pproved nd will e operted nd mintined in complince with BS EN Provision will e included to llow for prllel monitoring of the flue gses Logs will e kept y the opertors nd on the computer system, including the following: electricity generted nd fuel urn / consumption; the mximum hourly men vlue of ll relevnt pollutnts, in mg/nm 3 ; c the dily men vlue of the hourly mens of ll relevnt pollutnts in mg/nm 3 ; d e f g the type nd mss of fuel gs urned; the mss of NO x nd SO 2 relesed; the mss relese of cron dioxide clculted from the cron content of the fuels consumed in ccordnce with the EU Emissions Trding Scheme; nd dt on the wter dischrges to the foul sewer The ove records will e retined for ten yers Records will e kept of ll environmentl udits performed, emissions testing results nd instrumenttion clirtion / testing documenttion The surfce wter dringe nd sewer system will incorporte on-site mnhole ccess for smpling purposes. Systems nd procedures will e implemented to ensure tht monitoring of the effluent is monitored nd recorded Monitoring of releses will form prt of the overll Qulity Assurnce pln for the power sttion nd will e controlled s prt of the EMS. Short term records of -85 -

81 operting prmeters will e kept for control purposes. Regulrly smpled records of importnt process prmeters nd mximum levels of emissions will e dt logged nd kept ville for inspection All solid wste will e disposed of in ccordnce with Duty of Cre nd Hzrdous Wste regultions nd the composition of the wste, its hzrd chrcteristics nd ny relevnt precutions clerly stted on the relevnt forms. Monitoring of Process Vriles Ntionl Grid will provide nlyses of the nturl gs supplied to the Project. The relevnt suppliers will provide nlyses of ll process / tretment chemicls. Anlysis of towns wter will e crried out t regulr intervls to ensure optiml opertion of the rw wter tretment plnt The nture of the proposed instlltion is such tht there re no mjor process vriles requiring monitoring in ddition to those descried ove. Controls will e introduced through the EMS for monitoring the flows of rw mterils on to site nd wstes off site to ensure complince with the relevnt regultions nd to identify reduction opportunities. 4.8 Environmentl Impct Assessment In Mrch 2013, C.GEN sumitted n ppliction for DCO to the Secretry of Stte for Energy nd Climte Chnge to uthorise the construction nd opertion the Project. As prt of the ppliction procedure n Environmentl Sttement ws prepred tht discussed in detil the environmentl impcts ssocited with the Project An electronic copy of the full ES cn e found on the CD included s Appendix D of this document. 4.9 Resource Efficiency nd Climte Chnge Energy Mngement Policy The mngement of energy is n integrl prt of the EMS with energy policies integrted into the overll environmentl policy. Stff trining imed t minimizing energy use nd developing good housekeeping techniques will e fundmentl prt of stff s initil trining progrmme nd susequent refresher courses. One of the key environmentl spects mnged through the EMS is the ssessment of energy use nd its minimistion through well trgeted improvement plns. Such n improvement pln will e mnged through the EMS nd will identify the res where energy is utilised, identify potentil energy efficiency mesures nd ensure tht their finncil viility is pprised. This process will e initited from the design phse nd ssessments my e mde of ech of the principl res of energy use such s het recovery, electricl drives, lighting nd ventiltion. Mesures for the Improvement of Energy Efficiency The Project will e designed for the highest prcticl energy efficiency. The Project, when operting s CCGT plnt is expected to chieve net efficiency, t full lod, in excess of 55 per cent (LHV). The efficiency is dependent upon the prticulr requirements for electricl power. This efficiency is significntly higher thn tht -86 -

82 currently chievle y lterntive generting technologies using the sme fuel source When operting s n IGCC plnt with CCS, the net electricl efficiency will e pproximtely 36 per cent (LHV) The energy efficiency requirements will e met through: Detiled design of the Project, incorporting ll energy efficiency-specific BAT mesures, s discussed in Section 4.3; energy mngement policy; nd opertionl energy efficiency mesures nd identifiction opportunities for increses wherever prcticle The Project will e designed to provide the most cost-effective solution to set of commercil, energy supply nd environmentl ojectives. As result, the potentil energy consumption on site is one of the key prmeters in optimising the overll design s well s selecting the individul components of the power sttion. The open competitive process resulting in the selection of the successful contrctor will provide incentives for efficiency increses, where such opportunities exist. Energy Usge The Project will comprise n industril type gs turine, with n ssocited HRSG. Stem from the HRSG will provide stem to condensing stem turine plnt. Air will e compressed in the compressor of ech gs turine nd fuel injected into the comustion chmers where it urns to produce hot, high-pressure gses. These gses will e expnded through power turine, which drives oth the compressor nd n electricity genertor ssocited with ech gs turine The typicl therml input for the Project operting t full lod will e pproximtely 860 MWth, when firing on nturl gs, nd 1310 MWth when operting s n IGCC plnt, under norml opertions The low-pressure gs turine exhust gses will pss through the HRSG, where het will e extrcted from the gses to rise stem. The stem will e t very high pressure nd will expnd through stem turine equipment turning series of ldes s it does so. These ldes re connected to shft which in turn is connected to the plnt genertors. At full output the ldes turn t some 3000 revolutions per minute. By the time the stem exits the stem turine it hs lost most of its useful energy The finl exhust stem will e conveyed from the stem turine plnt to wet-cooled condenser system. The wter forming in the condenser will then e returned vi mechnicl de-ertor to the het recovery stem genertor for conversion ck into stem When operting s n IGCC with CCS, the genertor(s) will produce pproximtely 520 MW of electricity, under norml operting conditions. For n IGCC with CCS, the mximum energy consumption on site will e pproximtely 100 MW. All on-site electricl requirements will, during opertion, e provided y the electricity generted within the Power Islnd through dedicted low- nd medium-voltge systems The net efficiency of power sttion cn e descried s energy out divided y energy in. Since the purpose of the Project will e the genertion of power, it is -87 -

83 inpproprite to consider energy efficiency or environmentl spect of the delivered energy. Similrly, it is inpproprite to detil in this section the environmentl impct resulting from on-site energy use Hyrid cooling towers will e used to provide the cooling duty for the Project. The het rejection from the towers will e up to pproximtely 305 MWth for opertion s CCGT plnt nd 495 MWth for opertion s n IGCC plnt There will lso e dditionl energy losses, such s through het contined within the flue gses nd het trnsfer from the plnt pipe work. The totl of these losses will e up to pproximtely 60 / 155 MW (CCGT / IGCC opertion respectively) The overll efficiency of the Project could e further improved if it proves techniclly nd economiclly fesile to provide het to surrounding fcilities or potentil customers nd operte in CHP mode. Throughout the lifetime of the Project, ongoing consulttions will e undertken with locl compnies nd other stkeholders identified y DECC / North Lincolnshire Council regrding the potentil or otherwise for the provision of het or power to nery developments, where such provision is oth techniclly nd economiclly fesile A report on progress of the implementtion of CHP will e sumitted to the EA every two yers (or other greed reporting frequency) in ccordnce with the provisions of the CHP-R Guidnce. Wste There re numer of steps required in order to determine if wste is hzrdous or non-hzrdous, s descried in the EA Technicl Guidnce WM2 -Interprettion of the definition nd clssifiction of hzrdous wste (2013) The revised Wste Frmework Directive ("rwfd") (2008/98/EC) provides Europewide definition of hzrdous wste s, wste possessing one or more of the 15 hzrdous properties set out in Annex III of the rwfd, nd requires the correct mngement nd regultion of such wste. Wste clssifiction is sed on the Europen List of Wste (Commission Decision 2000/532/EC) (formerly the Europen Wste Ctlogue) nd the hzrdous properties provided in Annex III of the rwfd There re three ctegories of entries in the List of Wste ("LoW"): c Asolute entries re utomticlly considered hzrdous; Mirror entries re linked entries tht re considered hzrdous (or nonhzrdous) if they contin dngerous sustnces nd the wste possesses properties specified in Regultion (EC) 1272/2008 on the clssifiction, lelling nd pckging of sustnces nd mixtures; nd Non-Hzrdous entries re neither solute or mirror entries. Wste Recovery nd Disposl Generl Wste A feture of the gs turine technology to e incorported in the Project for the comustion of gseous fuels is tht wste generted should e miniml nd will e restricted to the following: -88 -

84 Generl office wstes; Used gs turine ir intke filters ; c d e Used ion exchnge resins or used Reverse Osmosis memrnes (typiclly replced every 5 to 10 yers); Seprted oil / sludge from oil / wter seprtors; nd Used oil, chemicls or chemicl continers For the wstes identified ove, the relevnt entries of the LoW re presented in Tle

85 Tle 18: Europen List of Wstes Entries Generl Project Wste LoW Wste Code Wste Descriptor Type of Entry Generl Office Wste Mixed municipl wste Non-Hzrdous Deminerlistion Medi * Sturted or spent ion exchnge resins Asolute Hzrdous * Memrne system wste contining hevy metls Mirror Hzrdous * Sludges from oil/wter seprtors Asolute Hzrdous Oily Wter * Interceptor sludges Asolute Hzrdous * Oil from oil/wter seprtors Asolute Hzrdous * Oily wter from oil/wter seprtors Asolute Hzrdous Wste Minerl Oil * Minerl-sed mchining oils contining hlogens (except emulsions nd solutions) * Minerl-sed mchining oils free of hlogens (except emulsions nd solutions) Asolute Hzrdous Asolute Hzrdous Compressor Wsh Fluid * Detergents contining dngerous sustnces Mirror Hzrdous Detergents other thn those mentioned in Mirror Non- Hzrdous * Antifreeze fluids contining dngerous sustnces Mirror Hzrdous Used Antifreeze Antifreeze fluids other thn those mentioned in Mirror Non- Hzrdous Lortory Wste * Lortory chemicls, consisting of or contining dngerous sustnces, including mixtures of lortory chemicls Mirror Hzrdous * Discrded inorgnic chemicls consisting of or contining dngerous sustnces Mirror Hzrdous Discrded Chemicls * Discrded orgnic chemicls consisting of or contining dngerous sustnces Mirror Hzrdous Discrded chemicls other thn those mentioned in , or Mirror Non- Hzrdous Scrp Metl Wste metl Non-Hzrdous -90 -

86 Air filters re predominntly mde of steel (frmes) nd plstic / fric filter mterils tht re considered non-hzrdous. However, power sttions in the UK tret these s specil wstes (i.e. not hzrdous ), tht re removed from site y suitly licensed contrctors tht hve the cpcity to process such items. Additionl Solid Wstes The significnt solid wstes nticipted from the opertion of the Gsifiction Plnt re: c Ash in the form of inert slg nd fly sh filter cke; Filter cke/sludge from the Wste Wter Tretment Plnt; nd Sulphur extrcted in elementry form It is nticipted tht the slg, nd possily the fly sh nd Wste Wter Tretment Plnt filter cke, will e sold for use in the construction industry or trnsported to n pproprite lndfill site y suitly licensed contrctor The elementl sulphur will likely e used s rw mteril in the chemicl industry Prior to disposl, the slg, fly sh nd filter ckes will e ssessed nd clssified in ccordnce with the Wste Frmework Directive definition for hzrdous wste nd the EA Technicl Guidnce WM2 -Interprettion of the definition nd clssifiction of hzrdous wste (2013) (nd ny successor document) nd proposls for its mngement included, ccordingly, in the Site Wste Mngement Pln In the LoW, Chpter 10 Wstes from Therml Processes (susection wstes from power sttions nd other comustion plnts ) hs een exmined in respect of the solid process wste tht my result from the Project operting s n IGCC plnt Fly sh nd slg re specificlly included within the LoW, s shown in Tle

87 Tle 19: Europen List of Wstes Entries Gsifiction Plnt LoW Wste Code Wste Descriptor Type of Entry Bottom sh, slg nd oiler dust (excluding oiler dust mentioned in ) Non-Hzrdous Col fly sh Non-Hzrdous * Sludges from on-site effluent tretment contining dngerous sustnces Mirror Hzrdous Sludges from on-site effluent tretment other thn those mentioned in Non-Hzrdous The gsifiction process will tke plce t high temperture nd pressure t typicl conditions of etween C t pressure of greter thn 40 r g. Under these conditions, the inorgnic frction of the col will e fully melted The melt dripping down from the memrne wlls of the gsifier will e cooled nd solidified y quenching in wter sump, giving rise to vitreous slg which will e collected t the ottom of the gsifier nd evcuted y lock hopper system. As per the fly sh, the slg will e stored prior to removl from site for sle to the construction industry nd will not e suject to ny dditionl tretment The fly sh will e generted from smll drops of melt nd voltile compounds which re crried down y the gses descending within the gsifier. The mixture of gses nd prticultes is cooled down in the quench section of the gsifier. The fly sh will solidify there, t tempertures of round 250 C. This solidified fly sh will e crried wy y wter strem towrds clrifier to seprte the prticles from the wter. The slurry t the ottom of the clrifier will e sent to vcuum elt filter, removing pproximtely 60 per cent of the remining wter, creting the filter cke, which will consist of fly sh nd remining wter The typicl compositions of the slg nd filter cke re presented in Tle

88 Tle 20: Typicl Anlysis of Solid Wstes Sustnce / Prmeter Units Slg Filter Cke Cron % w/w <0.5 <5 Moisture % w/w Silic SiO 2 % w/w (dry sis) Aluminum Al 2O 3 % w/w (dry sis) Titnium TiO 2 % w/w (dry sis) 1 1 Iron Fe 2O 3 % w/w (dry sis) Clcium CO Mgnesium MgO Potssium K 2O Sodium N 2O % w/w (dry sis) % w/w (dry sis) % w/w (dry sis) % w/w (dry sis) Sulphur SO 3 % w/w (dry sis) Phosphorus P 2O 5 % w/w (dry sis) Brium BO % w/w (dry sis)

89 Tle 21: Solid Wste Anlysis (Typicl Trce Elements) Sustnce / Prmeter Units Slg Filter Cke Arsenic (As) Cdmium (Cd) Colt (Co) Chromium (Cr) Copper (Cu) Mercury (Hg) Mngnese (Mn) Nickel (Ni) Led (P) Antimony (S) Thllium (Tl) Vndium (V) Zinc (Zn) ppm (dry sis) ppm (dry sis) ppm (dry sis) ppm (dry sis) ppm (dry sis) ppm (dry sis) ppm (dry sis) ppm (dry sis) ppm (dry sis) ppm (dry sis) ppm (dry sis) ppm (dry sis) ppm (dry sis) Trce elements will ll e present in quntities tht re less thn 0.1 per cent (w/w, dry) of the prticulr solid wstes nd, therefore, oth the slg nd the filter cke re considered to e non-hzrdous wstes sed on the limiting concentrtions for ech potentil hzrd presented in Appendix C of WM The finl compositions of the sludge(s) from the Wste Wter Tretment Plnt will e determined following the wrd of contrct for the design nd construction of the Gsifiction Plnt (nd will e ffected y the composition of the solid fuel used). Detils of the types nd mounts of ech solid strem will e included in the periodic reporting s required y the. Wste Storge nd Disposl The filter cke will e stored in dedicted enclosed wste continers tht will e suitle for loding directly on to the ck of hevy hulge vehicles The slg will e conveyed to the slg storge re vi elt conveyor or similr. An overhed crne is nticipted to distriute the slg evenly nd to lod tipper trucks or open-topped continers for ultimte disposl vi rge from the CPK whrfge re, or vi rilwy

90 The resins or memrnes (s pproprite to the selection of technology) from the wter tretment plnt will e the suject of mintennce / replcement contrct for the lifetime of the Project. Spent resins or memrnes will e replced nd removed from site for recycling / disposl y the medi supplier In ddition, during decommissioning, uilding wste will e produced. In order to fcilitte the implementtion of the Wste Frmework Directive during decommissioning, much of the structures nd equipment for the Project will e mde of mterils suitle for recycling s fr s is prcticle. For exmple, lrge proportion of the uildings will e constructed of pre-fricted steel nd will therefore e of interest to scrp metl merchnts Only smll quntities of potentilly hzrdous wste will e stored on-site t ny time, nd ny such sustnces will e held in secured continers to prevent contminnt migrtion. Closed storge fcilities or suitle dmpening techniques will e utilised within the Project where emissions of dust etc. from wste re possile. All mitigtion mesures will e in full ccordnce with industry est prctices All wste will e delt with in mnner tht complies with the Regultions nd (upon leving the site) wste will e treted nd disposed of y suitly licensed contrctors The design of the Project will incorporte ll the fetures needed to comply with relevnt sfety regultions. The HSE will lso e consulted with regrd to sfety issues ssocited with the Project

91 SECTION 5 PROPOSED IMPROVEMENT PLAN -97 -

92 5 PROPOSED IMPROVEMENT PLAN 5.1 Introduction The detiled design stge of the Project hs not yet een completed nd, s such, it is pproprite to suggest some pre-opertionl conditions in ddition to the improvement pln. Also included is the dte y which the conditions will e met in rckets. 5.2 Improvement Pln C.GEN Killingholme Ltd ( the Opertor ) shll notify the Environment Agency, in writing, of the dte when commissioning of the instlltion is complete. (As notified) The Opertor shll provide commissioning report, to the Environment Agency, detiling: i ii The results of the commissioning progrmme; nd Any significnt chnges to the informtion provided in the originl permit ppliction. (Within one month of completion of the instlltion commissioning process). c The Opertor shll chieve certifiction of its Environmentl Mngement System to ISO A site closure pln will e sumitted to the Environment Agency in order to outline the proposls for the decommissioning of the Project nd the reinsttement of the Opertions Are. (Within twelve months of completion of the instlltion commissioning process). 5.3 Pre-Opertion Conditions The Opertor shll sumit written report to the Environment Agency providing detiled design for the instlltion, including ll dringe systems. (Twelve months prior to the instlltion commissioning dte); The Opertor shll undertke review of the ppliction ginst the finl plns for the instlltion, prior to construction, to: i ii ensure tht the finl proposls will meet the requirements for BAT; nd tht the ppliction still ccurtely reflects the finl design nd operting proposls. c The Opertor shll sumit written report to the Environment Agency detiling the findings of this review. (Twelve months prior to the instlltion commissioning dte); d The Opertor shll instll suitle utomted monitoring systems ("AMS") for mesurement of relevnt pollutnts nd O 2 tht will hve MCertS certifiction. A -99 -

93 report shll e sumitted to the Environment Agency detiling how the instlltion nd opertion of the AMS y the Opertor shll meet with BS EN (Twelve months prior to the instlltion commissioning dte); e The Opertor shll undertke review of the Site Condition Report, post construction, to determine if it dequtely: i ii iii ddresses the requirements of H5 guidnce nd the Groundwter Regultions 1998; proposed dequte preventtive mesures to protect groundwter nd lnd eneth the instlltion; nd reflects the condition of the site prior to opertion of the instlltion. f The Opertor shll sumit written report to the Environment Agency detiling the findings of this review. (Three months prior to the instlltion commissioning dte); g The Opertor shll inform the Environment Agency prior to fuel eing urned for the first time. (Two weeks prior to the instlltion commissioning dte)