The licensee shall take the actions specified to close out the non-compliances and observations raised in this Site Visit Report.

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1 Site Visit Report The site visit process is a sample on a particular day of an installation's compliance with some of its licence conditions. Where non-compliance against a particular condition has not been reported, this should not be construed to mean that there is full compliance with that condition of the licence. Instructions and actions arising from the visit shall be addressed, or where applicable noted, by the licensee in order to ensure compliance, to improve the environmental performance of the installation and to provide clarification on certain issues. The licensee shall take the actions specified to close out the non-compliances and observations raised in this Site Visit Report. Licensee Name of Installation Licensee Shell E&P Ireland Limited Shell E&P Ireland Limited Licence Register No. P CRO Site Address Site Visit Reference No. Bellanaboy Bridge Gas Terminal, Bellanaboy Bridge, Bellagelly South, Mayo SV08805 Report Detail Issue Date 09/03/2016 Prepared By Ian Marnane Site Visit Detail Date Of Inspection 24/02/2016 Announced No Time In 09:35 Time Out 13:15 Agency Personnel On Site Licensee Personnel and Role Ian Marnane Annette Jordan Michelle McKim Bob Blachford - Corrib Manager Catriona King - Environmental Advisor Bambi Barnes - Production co-ordinator John Needham - Maintenance co-ordinator Neil Bourke - Instrumentation (Metering) Engineer Des Walsh - Instrumentation (Maintenance) Ray Mehigan - Control Room Operative Martin Berry - SAP (Work Prep Scheduling Lead) Edwin Brandsma DCS (PACO Engineer) Jarlath Trench - HSE Manager Photo Taken No Samples Taken No Video Taken No Site Visit Report - SV Shell E&P Ireland Limited Page 1 of 5

2 Scope The scope of this site inspection was to review information in relation to the licensed emission points, including the gas turbines and generators as well as other potential sources of emissions to atmosphere. Media Air Site Areas Inspected The main areas of the site inspected during the visit were the turbines/compressors, generators and control room. Documents Inspected The following documents were reviewed: February 2016 Turbine/compressor CEMS calibration records; Calculation spreadsheet for calculation of turbine flue gas flow; Q periodic monitoring reports for the generators; SAP maintenance records and planned maintenance for the CEMS; Data processing applied to the raw CEMS data; CEMS weekly zero and span check control charts. Site Visit Report - SV Shell E&P Ireland Limited Page 2 of 5

3 1. Site Specific Issues 1.1 Are the monitoring provisions for the turbines appropriate and adequately maintained? Yes No Yes The equipment used is appropriate and the weekly checking of the span and zero point were satisfactory. The data handling and compliance assessment procedures were also found to be satisfactory. The following comments should be addressed by the licensee: 1. The analyser measures only NO and applies a standard additional factor of 5 % to account for NO2 in the combustion gas. The licensee should complete monitoring of the flue gases for both NO and NO2 in order to verify that this 5 % factor is an appropriate and conservative assumption to account for the NO2 fraction of the gas. 2. Flue gas velocity is calculated rather than measured in the stack. The ISO standard (Annex E) specifies the method to be used for calculation of flue gas flow from energy consumption. The licensee is requested to assess their method against the requirements of ISO and make any relevant adjustments. The licensee should verify that the input parameters (e.g. fuel flow rate) as specified in Table E.5 of ISO comply with the necessary performance criteria, and that the overall uncertainty in the calculated value is satisfactory. 3. The applied correction for oxygen was reviewed during the site visit. In addition please verify whether any additional corrections are applied for other parameters (temperature, pressure, moisture) requires that all automatic monitors must be operational when the activity is being carried out unless alternative sampling or monitoring has been agreed in writing in advance for a limited period. The licensee indicated that a call-out service is in place with a monitoring contractor, however any such arrangements for alternative monitoring in the event that neither of the CEMS are available must be agreed by the Agency in order for operation of the turbines to continue. In the absence of any agreement under 6.3 the relevant activity should cease where the CEMS are not operational. 5. The NO calibration gas concentration for the CEMS is 61 ppm, which is equivalent to approximately 125 mg/nm3 NOX (as NO2). This is relatively high compared to the licence limit of 50 mg/nm3 NOX (as NO2). When these gas cylinders are being replaced a more appropriate calibration gas concentration should be specified, in the region of % of the ELV. A response to the above queries should be submitted to the Agency as a licensee return, within 6 weeks of receipt of this report. The measurement of NO and NO2 from the gas turbines can be completed at the next scheduled monitoring visit and reported separately if necessary. 1.2 Are appropriate measures in place to monitor fugitive and diffuse emissions? No 6.8 and 3.10 No Yes Site Visit Report - SV Shell E&P Ireland Limited Page 3 of 5

4 3.10 requires the establishment of a leak detection and repair programme, while 6.8 specifies the requirements for a programme for identification and reduction of diffuse VOC emissions using a variety of different techniques. The licensee is requested to address the following points: 1. Provide the details of the programme put in place to meet the requirements of 3.10, including details of assessments completed to date; 2. The licensee indicated that a contract was in place to carry out the assessment as required under 6.8. The licensee should note that this condition requires all of the listed techniques to be employed for the purposes of identifying and reducing diffuse emissions. The findings of this assessment should be submitted to the EPA upon completion. The response to point 1 should be included as part of the licensee return requested under Site Specific Issue 1.1 above. 1.3 Are air emissions from the generators adequately monitored? Yes 6.1 No Yes The periodic emissions monitoring reports from Q were reviewed by the Agency and were generally found to be satisfactory. The licensee should note the following comment: 1. The Agency requests that measurement uncertainty is also determined for volumetric flow as well as the other monitored parameters. At present no measurement uncertainty is presented for flow. This should be addressed for future monitoring visits. Site Visit Report - SV Shell E&P Ireland Limited Page 4 of 5

5 Summary This visit focussed specifically on emissions to atmosphere, mainly from the turbines/compressors and generators. The performance of the site was generally found to be satisfactory, however a number of comments and/or requests for clarification are included within this report and should be addressed by the licensee as required in each case. FOLLOW-UP ACTIONS You are required to complete the instructions and actions, as outlined in this report, within the specified timeframe. Where required, you shall respond to actions specified in Investigations within the required timeframe. The licensee shall maintain documentary evidence, for review by the EPA, that the prescribed corrective actions were completed within the required timeframe. You are not required to respond directly to items contained in this EPA site visit report; where an issue requires a direct response, the EPA will generate a Investigation through the EDEN system. You will receive notification when a Investigation instruction or action is generated. Please note that this Site Visit Report will be made available for public viewing via the EPA s Licence Enforcement Access Portal within one day of the issue date and will be published on the Licence Details Page of the EPA s website, that relates to your licence 60 calendar days after the issue date. You may if you choose submit, within 45 calendar days of the issue date of this Site Visit Report, a Licensee Public Response that will be published alongside the Site Visit Report. This Response, should you wish to avail of it, provides you with an opportunity to inform the public about how you are implementing the actions set out in the report, activities underway, timescales and target completion dates. Please be aware that the content of your Licensee Public Response must be factual and should not breach the EPAs stated online publication standards. If you wish to submit a Licensee Public Response to an EPA Site Visit Report, you should do this by clicking on the Make a Response link on the Site Visits page in EDEN. A.pdf document containing your response can be attached and submitted from here. Please note that you are required to comply with the conditions of your licence at all times, and where noncompliance occurs you must restore compliance within the shortest possible time. These actions will be verified during subsequent EPA visits. Please quote the above Inspection Reference in any future correspondence in relation to this Report. Site Visit Report - SV Shell E&P Ireland Limited Page 5 of 5