Rhode Peaking Power Plant. Annual Environmental Report 2008

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1 Rhode Peaking Power Plant Annual Environmental Report 2008 Table of Contents Subject Page Introduction 1 Summary Information Plant Operation Data 1 Emissions to Air 1 Emissions to Water 2 Waste 2 Energy and Water Consumption 2 Environmental Incidents and Complaints 2 Non-compliances 3 Management of the Activity Environmental Management Programme 2008 Environmental Management Programme Proposal 2009 Pollution Emission Register Environmental Audit Licence-Specific Reports Emissions to Atmosphere Emissions to Water Waste Management Resources Consumption Summary Complaints Noise Monitoring Groundwater Monitoring Tank and Pipeline Testing and Inspection Reported Incidents Review of Residuals Management Plan Review of Environmental Liabilities Insurance Cover Energy Efficiency Audit Annual Emissions of SO 2 and NO x Annual Energy Input Annual Carbon Dioxide Surface Water Monitoring Appendix 1 Environmental Site Assessment

2 Introduction This is the Annual Environmental Report of Rhode Peaking Power Plant for the year ending December 2008, in compliance with requirements of Integrated Pollution Control Licence Register No. P The Rhode peaking power plant was commissioned in 2004 and has been operated commercially since. It operates on quick response to National Grid requests for load and has a nominal maximum capacity of 104 MW electric (MWe), delivered from two generators each driven by two combustion turbines. The plant has been purchased by Endesa Ltd. from E.S.B., the take over date was 8 th January Their Irish address is: Regus House, Harcourt Centre, Harcourt Road, Dublin 2. The environmental procedures for Rhode are contained in a folder held in the Operation Office and also in electronic format. Environmental management at Rhode is under the control of Utility Operation and Maintenance Services (UOMS). The UOMS staff appointed at the Rhode site are: John Hensey, Mick Nolan and Carey Thornhill. Phone calls to are transferred to the mobile phone of the person on duty. Summary Information Plant Operation Data MWH Generated Gas Oil Consumed (tonnes) Demineralised Water (tonnes) * Number of Starts * Demineralised water is supplied with the fuel to the engines to reduce combustion temperatures and thus NOx levels. Emissions to Air The average values for NOx emission are significantly reduced following gas turbine engine tuning carried out during 200. Average NOx (mg/normalm 3 ) Unit 1 2 Stack A1 A2 A3 A4 Station Average Average Average Average

3 The total quantity of CO 2 emitted was 45 tonnes. The estimated quantity of NOx emitted was 5 tonnes. The estimated quantity of SO 2 emitted was 3 tonnes. Emissions to Water The discharge points S2 and S3 were inspected daily and the results were recorded in the station checklist. Monthly samples from S2 and S3 were analysed for BOD, ph, conductivity and Total Petroleum Hydrocarbons (TPH), as required by the IPCL. The average yearly values are shown in the Licence-Specific Report. Values for ph have been high since the station was commissioned. Investigation indicated that leaching from fresh concrete was a contributing factor. The S2 sampling point has reduced to a ph average of 8.1. The S3 ph remains high but the average value has reduced to the limit value of 9.0. Boreholes BH1 & BH2 were sampled during October. The results for DRO and other analyses were within the required limits. An Environmental Site Assessment was carried out by consultants URS in connection with the sales process. Extracts relating to groundwater are shown in Appendix 1. Effluent from the Water Treatment Plant Neutralising Tank was discharged within a ph range of to 9, as specified by the IPCL. The total quantity for the year was 18 cubic metres at.3 average ph. Waste Waste leaving the site is recorded in the Waste Register, held in the Operations Office. A summary of the quantities and disposal information is shown in the Licence-Specific Report, below. No waste was disposed of on site. Energy and Water Consumption Item Quantity Comment Gas Oil 140 tonnes Fuel for the gas turbine engines Demineralised Water 1324 tonnes For NOx reduction. Supplied from a bore hole on the neighbouring site. Electricity The imported electrical energy is small in relation to the amounts of electricity generated. When the plant is shut down this is mainly heating and lighting. Domestic Water The town water supply is used for mess rooms and toilets. The number on site varies from one after normal hours to three or occasionally five during normal operation. An energy efficiency audit was carried out during Energy control is by way of adjusting heater thermostats and lighting. Actions on these are included in the work scheduler. Environmental Incidents and Complaints The EPA were notified by on 9/5/2008 that no NOx data was recorded on Unit_1. The fault was repaired before further operation of the plant. On Wednesday 12 th November the NOx reading for Unit 1 was lost for a period of 35 minutes. This 3

4 was reported to the EPA and the fault was corrected before any further running of the generating unit. There were no complaints from the public during Non-Compliances Following a visit to site on th February 2008 by the EPA Inspector, three noncompliances were identified. 1. Fuel Farm Bund Integrity Testing. The bund was subsequently inspected by an external consultant, a report was submitted and the results were found to be satisfactory. 2. Underground Tank and Pipeline Testing. The drain lines were inspected by an external contractor, using cctv cameras and were found not to require repair at this time. The underground tank was inspected and tested by an external consultant, it was found to be in good condition. 3. Emissions to Atmosphere. The engines were re-tuned during 200 and NOx levels are now satisfactory. There were six observations to be addressed. Items 1 and 2 are included in the 2009 Environmental Plans and the others have been attended to. Management of the Activity Environmental Management Programme for 2008 Daily and weekly checks are recorded in paper format, held in the Operations Office. A computer based work scheduling system is used and records of recurring checks and other environmental work is held in the database. Environmental Management Programme Proposal for 2009 Issues raised in the Inspectors visit on 19 th February 2009 are as follows: 1. In relation to testing the integrity of the chemical and emergency diesel bunds, these have already been tested by filling with water and all were found to be satisfactory. The tests have been recorded in the work scheduling system and a new job has been generated for In relation to water sampling point S3, we will arrange for an investigation and a report by a consultant chemist. 3. In relation to CEMS calibration and servicing, we are arranging an annual service contract for the equipment. 4. In relation to reviewing environmental risks and financial provisions, this has been addressed by the new owners, Endesa Ltd. 5. The result of the bore hole samples taken for the Site Assessment Audit are included in this report, as requested by the EPA. The computerised work scheduler will be used to control the environmental work programme required by the IPCL. 4

5 Pollution Emission Register Summary for 2008 Item Tonnes Derivation CO tonnes gas oil * 3.3 (Emission Factor tco 2 /TJ) * (NCV TJ/tonne) * 1.0 (Oxidation Factor) NO x value * 140/814*102/120 SO tonnes gas oil * 0.11/100 sulphur * (S to SO 2 ) Environmental Audit An environmental site assessment was carried out by URS Ireland Ltd., as part of the sale process between ESB and the new owners Endesa. Extracts from this report and the report conclusions and recommendations are shown in Appendix 1. 5

6 Licence-Specific Reports (IPCL Schedule ) Emissions to Atmosphere Average NOx (mg/normalm 3 ) Unit 1 2 Stack A1 A2 A3 A4 January February March April May June July August September October November December Emissions to Water Averages for monthly water sample analyses BOD Mg/l Conductivity MuS/cm ph TPH MuG/l Sampling Point S2 S3 S2 S3 S2 S3 S2 S < < Waste Management Report

7 European Waste Code Description Quantity (tonnes) Disposal Carrier Location Name & Permit General Waste 5.99 AES Tullamore County Waste Disposal Recycling bins.8 AES Tullamore Oily water 2.00 ENVA Portlaoise ENVA Oil contaminated 0.8 ENVA Portlaoise ENVA waste Sewage Sludge 1.5 Accelerated Drains Ltd. Edenderry Total Total Total Total Edenderry Treatment Plant Permits Company Title Carrier Permit Disposal Permit AES Advanced Environmental Services, Athlone 053(2)/OY/351/0 W ENVA ENVA, Clonamin Industrial Estate, 033(2)/OY/281/05 County Waste Accelerated. Drains Portlaoise Disposal Accelerated Drains Ltd. 158(2)/OY/433/0 Edenderry Treatment Plant Resources Consumption Summary See Plant Operation Data in Summary Information. Complaints There were no complaints from the public during Noise Monitoring Noise tests were carried out during commissioning in 2004 and in September The results were in conformance with the required levels, 55 db daytime and 45 db at night time. As there had been no change to the plant or the operating regime the EPA were requested to allow suspension of yearly tests and this was agreed. Groundwater Monitoring See Summary Information. Tank and Pipeline Testing and Inspection A visual inspection of all tanks was carried out locally per ESB GDS 1.3. Pipelines are inspected weekly and recorded in the checklist. Underground piping was inspected, as required by the IPCL, using cctv. The underground holding tank was also inspected and tested. Reported Incidents

8 See Summary Information. Review of Residuals Management Plan This is included under the heading Environmental Liability Risk Assessment. Review of Environmental Liabilities Insurance Cover The ELRA was carried out during 200. EPA Amendment A to the Rhode IPCL was issued this year and the new owners Endesa Limited will address this. Energy Efficiency Audit This was carried out during the year and associated tasks were entered to the work scheduler. Annual Emissions of SO 2 and NOx Data on NOx is contained above in Summary Information. In relation to control of SO 2 emissions, the fuel was analysed and found to have a sulphur content of % in the Main Tank and % in the Service Tank. Subsequently extra low sulphur fuel was added to bring the value below 0.1% The tanks were sampled again during October and the total sulphur content of fuel on site was 0.08% Annual Energy Input The main energy input was 140 tonnes of gas oil. Electricity imports were relatively small for heating, lighting and gas turbine engine auxiliary supplies. Annual Carbon Dioxide The total quantity of CO 2 emitted was 45 tonnes. Surface Water Monitoring See Emissions to Water above and also comments in Summary Information. Carey Thornhill, Environmental Coordinator Rhode Peaking Power Plant Date: 18 th March

9 Appendix 1 Environmental Site Assessment by URS Ireland Ltd. Ground Water Sampling Extracts and Comments Groundwater Analytical Results The groundwater analytical results are presented in Tables to 11. Laboratory reports are presented in Appendix B. A summary of the results is presented below: TPH, BTEX, MTBE and PAH compounds were not detected in the groundwater samples analysed and hence all concentrations were below the IGVs (where present). All metal concentrations with the exception of barium were below their respective IGVs (where present). There were some IGV exceedances reported for calcium, chloride, iron, potassium, manganese, total hardness, ammonia, nitrite, phosphate and total phenols. Total coliform counts of 400cfu/100ml and 00cfu/100ml was recorded in sample BH3 and its duplicate sample. Coliforms were not detected in any of the other samples. The relative percentage differences (RPDs) between results for sample BH3 and its duplicate sample are shown in Table 12. The RPD was acceptable for all groundwater analytes except aluminium, barium, potassium, manganese and alkalinity. Extract from Discussion (Section ) Given that there was no field evidence of hydrocarbon contamination observed in soil during the investigation and that no hydrocarbon compounds were detected in groundwater, it is considered that the reported low level TPH concentrations in soil are not a cause for concern.. CONCLUSIONS AND RECOMMENDATIONS Based on the results and observations of the Phase 1 and 2 ESA, URS has drawn the following conclusions: 9

10 From the perspective of human health and potential environmental risks posed by soil and groundwater, the site is considered suitable for the continued industrial use. In general, the analytical results for most analytes were comparable to Dutch screening values. The only exceedances of the DSVs were observed for total aliphatics (mineral oil), PAHs and the metals cadmium and nickel. There were no exceedances of the Dutch intervention values. A conservative assessment of the soil analytical data collected during the ESA identified potential risks to controlled waters (i.e. groundwater and surface water) from a number of metals as well as hydrocarbon indicator compounds, polycyclic aromatic hydrocarbons (PAH), fluoride and sulphate. However, URS has concluded that these potential risks are not a cause for concern. Elevated coliform levels in groundwater represent a potential risk to future site users should they come into direct contact with groundwater. Safe work practices should put in place to prevent workers coming into contact with extracted groundwater used on site. Based on the information obtained during the Phase 1 and 2 ESA, the presence of asbestos containing materials (ACM) in the subsurface is considered unlikely. In summary, no remedial action is currently considered necessary at the site under a continued industrial land use scenario, from the perspective of environmental soil and groundwater quality. 10