Integrated Pollution Prevention and Control (IPPC) Licensing

Transcription

1 Integrated Pollution Prevention and Control (IPPC) Licensing Application Form EPA Reg. N o : (Office use only) Environmental Protection Agency P.O. Box 3000, Johnstown Castle Estate, Co. Wexford Lo Call: Telephone: Fax: Web: info@epa.ie EPA Export :00:59:05

2 IPPC Application Form V1/07 CONTENTS ABOUT THIS APPLICATION FORM...3 SECTION A: NON-TECHNICAL SUMMARY...4 SECTION B: GENERAL...5 SECTION C: MANAGEMENT OF THE INSTALLATION...10 SECTION D: INFRASTRUCTURE & OPERATION...12 SECTION E: EMISSIONS...12 SECTION F: CONTROL & MONITORING...15 SECTION G: RESOURCE USE AND ENERGY EFFICIENCY...16 SECTION H: MATERIALS HANDLING...17 SECTION I: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY18 SECTION J: ACCIDENT PREVENTION & EMERGENCY RESPONSE...21 SECTION K: REMEDIATION, DECOMMISSIONING, RESTORATION & AFTERCARE...22 SECTION L: STATUTORY REQUIREMENTS...22 SECTION M: DECLARATION... ERROR! BOOKMARK NOT DEFINED. ANNEX 1: CHECKLIST FOR ARTICLE 10 COMPLIANCE...26 Page 2 of 30 EPA Export :00:59:05

3 IPPC Application Form V1/07 ABOUT THIS APPLICATION FORM This form is for the purpose of making an application for an Integrated Pollution Prevention and Control (IPPC) Licence under the Environmental Protection Agency Acts, 1992 and There are separate application forms for licensees who wish to apply for a review of existing licences and for Pig & Poultry sector applicants. The Application Form must be completed in accordance with the instructions provided in the IPPC Licensing Application Guidance Note. The Guidance Note gives an overview of IPPC Licensing, outlines the licence application process (including number of copies required) and specifies the information to be submitted in the application. The Guidance Note and application forms are available to download from the IPPC Licensing pages of the EPA s website at A valid application for an IPPC licence must contain the information prescribed in the Environmental Protection Agency (Licensing) Regulations, 1994 to Article 10 of the Regulations sets out the statutory requirements for information to accompany a licence application. The application form is designed in such a way as to set out these questions in a structured manner and not necessarily in the order presented in Article 10. In order to ensure a legally valid application in respect of Article 10 requirements, please complete the Article 10 Checklist provided in Annex 2. This Application Form does not purport to be and should not be considered a legal interpretation of the provisions and requirements of the Environmental Protection Agency Acts, 1992 and 2003 and the Environmental Protection Agency (Licensing) Regulations 1994 to While every effort has been made to ensure the accuracy of the material contained in the Application Form, the EPA assumes no responsibility and gives no guarantees, undertakings and warranties concerning the accuracy, completeness or up-to-date nature of the information provided herein and does not accept any liability whatsoever arising from any errors or omissions. Should there be any contradiction between the information requirements set out in the Application Form and any clarifying explanation contained in the accompanying Guidance Note, then the requirements in this Application Form shall take precedence. Page 3 of 30 EPA Export :00:59:05

4 IPPC Application Form V1/07 SECTION A: NON-TECHNICAL SUMMARY A non-technical summary of the application is to be included here. The summary should identify all environmental impacts of significance associated with the carrying on of the activity/activities, and describe mitigation measures proposed or existing to address these impacts. This description should also indicate the normal operating hours and days per week of the activity. The following information must be included in the non-technical summary: A description of: the installation and its activities, the raw and auxiliary materials, other substances and the energy used in or generated by the installation, the sources of emissions from the installation, the environmental conditions of the site of the installation (e.g. soil and groundwater, air, noise, surface water), the nature and quantities of foreseeable emissions from the installation into each medium as well as identification of significant effects of the emissions on the environment, the proposed technology and other techniques for preventing or, where this is not possible, reducing emissions from the installation, where necessary, measures for the prevention and recovery of waste generated by the installation, further measures planned to comply with the general principles of the basic obligations of the operator i.e. (a) all the appropriate preventive measures are taken against pollution, in particular through application of the Best Available Techniques (BAT); (b) no significant pollution is caused; (c) waste production is avoided in accordance with Council Directive 75/442/EEC of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment; (d) energy and other resources are used efficiently; (e) the necessary measures are taken to prevent accidents and limit their consequences; (f) the necessary measures are taken upon definitive cessation of activities to avoid any pollution risk and return the site of operation to a satisfactory state. measures planned to monitor emissions into the environment. Supporting information should form Attachment N o A.1 See Attachment A.1 RESPONSE Page 4 of 30 EPA Export :00:59:05

5 IPPC Application Form V1/07 SECTION B: GENERAL B.1. Owner/Operator Name*: Address: Edenderry Power Limited Ballykilleen Edenderry Co. Offaly Tel: Fax: * This should be the name of the applicant which is current on the date this IPPC Licence Application is lodged with the Agency. It should be the name of the legal entity (which can be a limited company or a sole trader). A trading/business name is not acceptable. Name and Address for Correspondence Only application documentation submitted by the applicant and by the nominated person will be deemed to have come from the applicant. Name: Address: Tel: Fax: Same as above Address of registered or principal office of Body Corporate (if applicable) Address: Bord na Móna plc Main Street Newbridge Co. Kildare Tel: Fax: If the applicant is a body corporate, the following information must be attached as Attachment B1: a) a Certified Copy of the Certificate of Incorporation. b) the Company s Registration Number from the Companies Registry Office. c) Particulars of Registered Office of the Company. Page 5 of 30 EPA Export :00:59:05

6 IPPC Application Form V1/07 Name and address of the proprietor(s) of the Land on which the Activity is situated (if different from applicant named above): Proprietor s Name: Address: Same as above Same as above Tel: Fax: Name and address of the owner(s) of the building and ancillary plant in which the activity is situated ( if different from applicant named above): Name: Address: Same as above Same as above Tel: Fax: B.2. Location of Activity Name: Address*: Edenderry Power Limited Ballykilleen Edenderry Co. Offaly Tel: Fax: Contact Name: Mr. Tom Egan Position: Plant Manager tom.egan@edenderrypower.ie * Include any townland. National Grid Reference (12 digit 6E,6N) E, N Location maps ( A3), appropriately scaled, with legible grid references should be enclosed in Attachment B.2. The site boundary must be outlined on the map in colour. B2.1 Site Location RESPONSE A site location map (Drawing reference EdenP rev-01), site layout plan (Drawing reference EdenP rev-02) and an Environmental monitoring plan (EdenP rev-03) in Irish Grid projection are included in Attachment B.2. Geo-referenced digital drawing files (e.g. AutoCAD files) in Irish Grid projection of the site boundary and overall site plan, including labelled emission, monitoring and sampling Page 6 of 30 EPA Export :00:59:05

7 IPPC Application Form V1/07 points, are also required. This data should be provided to the Agency on a separate CD- Rom containing sections B.2, E.6 and F.3. Name of geo-referenced digital drawing files Name of CD-Rom with digital drawing files EdenP rev-01 EdenP rev-02 EdenP rev-03 P rev drwgs B.3. Class of Activity Identify the relevant activities in the First, Third or Fourth Schedule of the PoE Act 2004 to which the activity relates: Schedule Class Description Note 1 First Schedule 2.1 See Note Below Class 2.1: the operation of combustion installations with a rated thermal input equal to or greater than 50 MW, Note 1: In order to give a precise identification select only those words from the description of the class or classes that best describes the nature of the activity for which the licence is being applied for. B.4. Employees/ Capital Cost Give- (i) In the case of an established activity, the number of employees and other persons working or engaged in connection with the activity on the date after which a licence is required and during normal levels of operation, or (ii) In any other case, the gross capital cost of the activity to which the application relates. Number of Employees (existing facilities): 45 Gross Capital Cost (new proposals) Not applicable B.5. Relevant Planning Authority Give the name of the planning authority in whose functional area the activity is or will be carried out. Name: Address: Offaly County Council Aras an Chontae Charleville Road Tullamore Co. Offaly Tel: Fax: Page 7 of 30 EPA Export :00:59:05

8 IPPC Application Form V1/07 Planning Permission relating to this application: has been obtained is being processed is not yet applied for is not required Local Authority Planning File Reference N o : 07/1691 B5.1 Planning Permission Existing Planning Permission The following planning permissions are presented in Attachment B 5 Planning permission for the Twin peaking plants Planning permission for co-fuelling of peat/biomass/mbm Application for Planning permission A planning application was made to Offaly County Council on the 07/12/07 with respect to the installation and operation of Peaking Power plants at Ballykilleen, Edenderry, Co. Offaly. As well as a planning application form, an Environmental Impact Statement (EIS) was also submitted as a planning support document. The EIS, titled Edenderry Power Limited, Peaking Power Plant, Environmental Impact Statement outlined the potential environmental impact of the installation and operation of this type of facility in the context of the existing infrastructure at the site. There were objections to the proposed development and conditional planning permission was awarded on the 12/02/2008. The planning conditions and hardcopy of the EIS are included as part of Attachment B.5.The softcopy of the EIS is contained on a dedicated CD. Existing Integrated Pollution Prevention Control Licence The activities on-site are currently conducted in accordance with the conditions of Licence Register No. P which was awarded by the agency in January A copy of this licence is included in Attachment B 5. Attachment B.5 should contain all planning permissions, including a copy of all conditions, and the required copies of any EIS should also be enclosed. For existing activities, Attachment N o B.5 should also contain all licences and permits past and present in force at the time of submission. B.6. Relevant Sanitary Authority. In the case of a discharge of any trade effluent or other matter to a sewer of a sanitary authority, give the name of the sanitary authority in which the sewer is vested or by which it is controlled. Name: Address: Not Applicable Tel: Fax: Page 8 of 30 EPA Export :00:59:05

9 IPPC Application Form V1/07 In the case of a discharge of any trade effluent or other matter to a sewer not vested by a sanitary authority, the applicant must supply as Attachment N o B.6; (a) the name and address of the owner(s) of the sewer and the waste water treatment plant to which the sewer discharges and who are responsible for the quality of the treated effluent discharging to waters and (b) a copy of the effluent regulations and the agreement between the applicant and the aforementioned. Name: Address: Not Applicable Tel: Fax: B.7. Relevant Health Board Region The applicant should indicate the Health Board Region where the activity is or will be located. Name: Address: Midland Health Board Central Office Arden Road Tullamore Co. Offaly Tel: Fax: B.8 Site Notice, Newspaper Advertisement and Planning Authority Notice. Attachment N o B.8 should contain a copy of the text of the site notice, a map (no larger than A3) showing its location on site (in accordance with Article 7 of the Regulations) and a copy of the newspaper advertisement. A copy of the notice given to the Planning Authority should also be included. RESPONSE B8. Site Notice, Newspaper Advertisement and Planning Authority Notice B8.1 Site Notice A site Notice has been erected in accordance with articles 5 and 7 of the Environmental Protection Agency (Licensing) Regulations, 1994 (S.I. No. 85 of 1994). The exact location of the site notice is depicted in drawing reference EdenP rev-01. A copy of the site notice is included in attachment B.8 B8.2 Newspaper Advertisement A notice was published in the Irish Independent dated the 23/04/2008 in accordance with articles 5 and 6 of the Environmental Protection Agency (Licensing) Regulations, 1994 (S.I. No. 85 of 1994). A copy of this notice is presented in Attachment N o B.8. B8.3 Planning Authority Notice Page 9 of 30 EPA Export :00:59:05

10 IPPC Application Form V1/07 Notice has been given to the local Planning Authority (Offaly County Council) in accordance with Article 9 of the Environmental Protection Agency (Licensing) Regulations, 1994 (S.I. No. 85 of 1994). A copy of the letter is included in attachment B.8 B.9 Seveso II Regulations State whether the activity is an establishment to which the EC (Control of Major Accident Hazards involving Dangerous Substances) Regulations (S.I. No. 74 of 2006) apply. If yes, outline how the process comes under these regulations. Supporting information should be included in Attachment N o B.9. RESPONSE B.9 Seveso II Regulations Comparison of the total tonnage of gas oil (1,900tonnes (combination of proposed and existing)) that will be held at the facility with the threshold levels outlined in Schedule 1, Annex 1 Part 1 (Named Substances) of the EC (Control of Major Accident Hazards involving Dangerous Substances) Regulations (S.I. No. 74 of 2006) indicate that the threshold levels of 2500 tonnes will not be exceeded. Therefore the installation and operation of the proposed peaking plants will not come under the Seveso II regulations. B.10 IPPC Directive Specify whether the activity is a category of industrial activity referred to in Annex I of the IPPC Directive (96/61/EC) and if yes specify the category. Supporting information should be included in Attachment N o B.10. RESPONSE The proposed activity comes under a category of industrial activity referred to in Annex 1 the IPPC Directive (96/61/EC). The relevant category is 1.1 Combustion installations with a rated thermal input exceeding 50 MW SECTION C: MANAGEMENT OF THE INSTALLATION C.1 Site Management & Control Details should be provided on the management structures for the activity. Organisational charts and all relevant environmental management policy statements, including provisions for on-going assessment of environmental performance, are required. C.1.1 RESPONSE Page 10 of 30 EPA Export :00:59:05

11 IPPC Application Form V1/07 Management structures and relevant environmental management policy statements were previously supplied as part of the last IPPC review. The proposed operation of the peaking plants will not require any alteration to these items. C.2 Environmental Management System (EMS) Indicate whether an Environmental Management System has been developed for the installation. If yes, specify which standard and include a copy of the accreditation certificate. C.2.1 RESPONSE A formal Environmental Management System (EMS) is already in place at Edenderry Power Limited. This system is fully documented and meets the requirements of the international standard for Environmental Management Systems ISO Specification with guidance for use. The existing EMS will be revised and updated to include the installation and operation of the proposed peaking plants. A copy of the accreditation certificate is included in Attachment N o C. C.3 Hours of Operation Provide details of the hours of operation for the installation, including: (a) Proposed hours of operation. (b) Proposed hours of construction and development works and timeframes. (c) Any other relevant hours of operation expected. This information should form Attachment N o C. C.3.1 Proposed hours of operation RESPONSE Due to the unpredictable demand for peaking energy, it is not possible to outline definitive hours of operation of the peaking plant. It is proposed that the plant would operate between 0 and 1500 hours per year. These hours would be in response to peaks in national demand for electricity. The plant will operate in combination with the existing power station. Due to the restrictions on the amount of gas oil to be stored at the facility and the provision of de-mineralised water for the operation of the peaking plants, the maximum period of continuous operation will be 84hrs. Proposed hours of construction and development works and timeframes The construction of the peaking plants will require the preparation of the site prior to installation of the peaking plants. This will consist of installing a concrete pad as a foundation for the generation equipment, the construction of two liquid fuel storage tanks and the construction of two demineralised water storage tanks. Once this infrastructure is in place the peaking plants will be dismantled at their existing sites and shipped to the Edenderry facility where due to their modular nature will be reassembled. All construction activities will take place between 08:00hrs and 20:00hrs. The timeframe for the construction and installation process is 8 weeks. Any other relevant hours of operation expected Not Applicable Page 11 of 30 EPA Export :00:59:06

12 IPPC Application Form V1/07 SECTION D: INFRASTRUCTURE & OPERATION D.1. Operational Information Requirements Describe the plant, methods, processes, ancillary processes, abatement, recovery and treatment systems, and operating procedures for the activity, to include a copy of such plans, drawings or maps, (site plans and location maps, process flow diagrams), and such other particulars, reports and supporting documentation as are necessary to describe all aspects of the activity. Maps and drawings must be no larger than A3 size. A development and operational history of the site should be included here. Attachment N o D should contain a list of all unit operations (processes) to be carried out, including flow diagrams of each with any relevant additional information. See Attachment D.1 E.1. Emissions to Atmosphere RESPONSE SECTION E: EMISSIONS E.1.A. Details of all point emissions to atmosphere Details of all point emissions to atmosphere should be supplied. Complete Table E.1(i) for Boiler Emissions and Table E.1(ii) and E.1(iii) for all other main emission points. Complete Table E.1(iv) for minor emission points. A summary list of the emission points, together with maps and/or drawings (no larger than A3), and supporting documentation should be included as Attachment N o E. Plans of emission elevations, relevant roof heights, etc., should also be included, as should detailed descriptions and schematics of all abatement systems. RESPONSE See Attachment E.1 The applicant should address in particular any emission point where the substances listed in the Schedule of S.I. 394 of 2004 are emitted. For emissions outside the BAT guidance limit, a full evaluation of the existing abatement/treatment system must be provided. A planned programme of improvement towards meeting upgraded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within the limits as set out in the BAT guidance note(s). These notes can be found on the EPA website at E.1.B. Fugitive and Potential emissions Give summary details of fugitive and potential emissions in Table E.1(v). Page 12 of 30 EPA Export :00:59:06

13 IPPC Application Form V1/07 RESPONSE There is a very low potential for any significant fugitive emissions to arise from the operation of the proposed infrastructure. In relation to activities listed in the Schedule of Council Directive 1999/13/EC on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain activities and installations; specify the relevant category of activity in the Schedule specify how the requirements in relation to fugitive emissions will be met. Full details and any supporting information should form Attachment E.1.B RESPONSE Council directive 1999/13/EC does not apply in this case. E.2 Emissions to Surface Waters Tables E.2(i) and E.2(ii) should be completed. A summary list of the emission points, together with maps/drawings (no larger than A3) and supporting documentation should be included as Attachment N o E.2. The applicant should address in particular any emission point where the substances listed in the Schedule of S.I. No. 394 of 2004 are emitted. Details of all List I and List II substances listed in the Annex to EU Directive 76/464/EEC (as amended), contained in any emission must be presented. All surface water runoff and storm water drains discharging to surface water bodies must be included. A National Grid References (12 digit, 6E, 6N) must be given for all discharge points. The identity and type of receiving water (river, ditch, estuary, lake, etc.) must be stated. For emissions outside the BAT guidance limit, a full evaluation of the existing abatement/treatment system must be provided. A planned programme of improvement towards meeting upgraded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within the limits as set out in the BAT guidance note(s). See Attachment E.2 RESPONSE E.3 Emissions to Sewer Tables E.3(i) and E.3(ii) should be completed. A summary list of the emission points, together with maps and/or drawings (no larger than A3) and supporting documentation should be included as Attachment N o E.3. Details of all List I and List II substances listed in the Annex to EU Directive 76/464/EEC (as amended), contained in any emission must be presented. All relevant information on Page 13 of 30 EPA Export :00:59:06

14 IPPC Application Form V1/07 the receiving sewer, including any effluent treatment/abatement systems, not already described, with schematics as appropriate should also be included in Attachment N o E.3. For emissions outside BAT guidance limit (where given), a full evaluation of the existing abatement/treatment system must be provided. A planned programme of improvement towards meeting upgraded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within any limits set out in the BAT guidance note(s). RESPONSE Not Applicable E.4. Emissions to Ground Describe the existing or proposed arrangements necessary to give effect to Articles 3,4,5,6, and 7 of Council Directive 80/68/EEC of 17 December 1979 on the protection of groundwater against pollution by certain dangerous substances. The applicant should supply details of the nature and quality of the substance (agricultural and non-agricultural waste) to be landspread (slurry, effluent, sludges etc) as well as the proposed application rates, periods of application and mode of application (e.g., pipe discharge, tanker). For emissions outside the BAT guidance limit, a full evaluation of the existing abatement/treatment system must be provided. A planned programme of improvement towards meeting upgraded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within the limits as set out in the BAT guidance note(s). Not Applicable E.5 Noise Emissions RESPONSE Give particulars of the source, location, nature, level, and the period or periods during which the noise emissions are made or are to be made. Table E.5(i) should be completed, as relevant, for each source. Supporting information should form Attachment N o E.5 For emissions outside the EPA Guidance Note for Noise in elation to Scheduled Activities 2 nd Edition (2006), a full evaluation of the existing abatement/treatment system must be provided. A planned programme of improvement towards meeting upgraded standards is required. This should highlight specific goals and a time scale, together with options for modification, upgrading or replacement as required to bring the emissions within the limits as set out in the Guidance Note. RESPONSE See Attachment E.5 Page 14 of 30 EPA Export :00:59:06

15 IPPC Application Form V1/07 E.6 Tabular Data on Emission Points Applicants should submit the following information for each emission point: Point Code Provide label ID s assigned in section E Point Type Easting Northing Verified Emission A=Atmospheric SW=Surface Water SE = Sewer GW=Groundwater N = Noise SL=Soil/Ground WS=Waste 6E-digit GPS Irish National Grid Reference 6N-digit GPS Irish National Grid Reference Y = GPS used N = GPS not used e.g. SO 2, HCl, NH 3 An individual record (i.e. row) is required for each emission point. Acceptable file formats include Excel, Access or other upon agreement with the Agency. A standard Excel template can be downloaded from the EPA website at This data should be submitted to the Agency on a separate CD-Rom containing sections B.2, E.6 and F.3. SECTION F: CONTROL & MONITORING Describe the proposed technology and other techniques for preventing or, where this is not possible, reducing emissions from the installation/facility. F.1: Treatment, Abatement and Control Systems Details of treatment/abatement systems (air and effluent emissions) should be included, together with schematics as appropriate. For each Emission Point identified complete Table F.1(i) and include detailed descriptions and schematics of all abatement systems. Attachment N o F.1 should contain any supporting information. RESPONSE See Attachment F.1 F.2: Emissions Monitoring and Sampling Points Identify monitoring and sampling points and outline proposals for monitoring emissions. Table F.2(i) should be completed (where relevant) for air emissions, for emissions to surface waters, for emissions to sewers, for emissions to ground, and for waste emissions. Where ambient environment monitoring is carried out or proposed, Table F.2(ii) should be completed as relevant for each environmental medium. Include details of monitoring/sampling locations and methods. Attachment N o F.2 should contain any supporting information. See Attachment F.2 RESPONSE Page 15 of 30 EPA Export :00:59:06

16 IPPC Application Form V1/07 F.3: Tabular Data on Monitoring and Sampling Points Applicants should submit the following information for each monitoring and sampling point: Point Code Provide label ID s assigned in section F3 Point Type Easting Northing Verified Pollutant M=Monitoring S=Sampling 6E-digit GPS Irish National Grid Reference 6N-digit GPS Irish National Grid Reference Y = GPS used N = GPS not used e.g. SO 2, HCl, NH 3 An individual record (i.e. row) is required for each monitoring and sampling point. Acceptable file formats include Excel, Access or other upon agreement with the Agency. A standard Excel template can be downloaded from the EPA website at This data should be submitted to the Agency on a separate CD-Rom containing sections B.2, E.6 and F.3. Point source monitoring/sampling refers to monitoring from specific emission points (e.g. from a boiler stack or outlet from a wastewater treatment plant). Examples of ambient monitoring includes monitoring of ambient air quality (e.g. boundary or off-site) or monitoring of river quality upstream/downstream of an effluent discharge. SECTION G: RESOURCE USE AND ENERGY EFFICIENCY G.1 Give a list of the raw and ancillary materials, substances, preparations, fuels and energy which will be produced by or utilised in the activity. The list(s) given should be very comprehensive, all materials used, fuels, intermediates, laboratory chemicals and product should be included. Particular attention should be paid to materials and product consisting of, or containing, dangerous substances as described in the EU (Classification, Packaging, Labelling and Notification of Dangerous Substances) Regulations 1994 [SI 77/94]. The list must classify these materials in accordance with Article 2 of these Regulations, and must specify the designated Risk Phrases (R-Phrases) of each substance in accordance with Schedule 2 of the Regulations Tables G.1(i) and G.1(ii) must be completed. Copy as required. Supporting information should be given in Attachment N o G. G.2 Energy Efficiency A description of the energy used in or generated by the activity must be provided. Outline the measures taken to ensure that energy is used efficiently and where appropriate, an energy audit with reference to the EPA Guidance document on Energy Audits should be carried out. RESPONSE See Attachment G Page 16 of 30 EPA Export :00:59:06

17 IPPC Application Form V1/07 SECTION H: MATERIALS HANDLING H.1 Raw Materials, Intermediates and Product Handling All materials should be listed in Tables G.1(i) and G.(ii) of Section G. Details of the storage conditions, location within the site, segregation system used and transport systems within the site should be outlined here. In addition, information relating to the integrity, impermeability and recent testing of pipes, tanks and bund areas should be outlined. H.2 Describe the arrangements for the recovery or disposal of solid and liquid wastes accepted into or generated by the installation/facility. For each waste material, give full particulars of: (a) Name (b) Description & nature of waste (c) Source (d) Where stored and integrity/impermeability of storage areas (e) Amount (m 3 ) and tonnage (f) Period or Periods of generation (g) Analysis ( include test methods and Q.C. ) (h) European Waste Catalogue Code (i) Waste Category per EC Reg 1774/2002/EC where relevant Where any waste would be classified as Hazardous Waste as defined in the Waste Management Acts, 1996 to 2003, this should be made clear in the information provided. Summary Tables H.1(i) and H.1(ii) should also be completed, as appropriate, for each waste. The licence/permit register number of the waste collection agent or disposal/recovery operator should be supplied as well as the expiry date of the relevant permits. Supporting information should form Attachment N o H.2 RESPONSE See Attachment H H.3 Waste disposal by on-site landfilling For wastes to be disposed of by landfilling on-site, full details of the disposal site should be submitted (to include inter alia, site selection procedures, location maps, (no larger than A3) geology, hydrogeology, operational plan, containment, gas and leachate management, post-closure care). Page 17 of 30 EPA Export :00:59:06

18 IPPC Application Form V1/07 Supporting information should form Attachment N o H.3. Not applicable RESPONSE SECTION I: EXISTING ENVIRONMENT & IMPACT OF THE ACTIVITY Describe the conditions of the site of the installation. RESPONSE A full description of the existing environment is outlined in the accompanying Environmental Impact Statement (Edenderry Power Ltd. Peaking Power Plant, Environmental Impact Statement, November 2007 ESBI International). Provide an assessment of the effects of any emissions on the environment, including on an environmental medium other than that into which the emissions are made. RESPONSE An assessment of all of the potential environmental impacts is outlined in the EIS with specific investigations carried out with respect to potential air and noise impacts. A synopsis of these specific reports is included in Attachment I.1 and I.5. Describe, where appropriate, measures for minimising pollution over long distances or in the territory of other states. RESPONSE This request applies to the potential air emissions arising from the proposed operation of the peaking plants. The air dispersion modelling report that is attached to the EIS demonstrates that the potential air impact of the facility does not extend beyond the boundary of the facility therefore the proposed development does not have the potential to impact at long distances or in the territory of other states. I.1.Assessment of atmospheric emissions Describe the existing environment in terms of air quality with particular reference to ambient air quality standards. Provide a statement whether or not emissions of main polluting substances (as defined in the Schedule of S.I. 394 of 2004) to the atmosphere are likely to impair the environment. Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made. Attachment N o I.1 should also contain full details of any dispersion modelling of atmospheric emissions from the activity, where required. When carrying out dispersion modelling, regard should be had to the "Guidelines for the Preparation of Dispersion Modelling Assessments for Compliance with Regulatory Requirements an Update to Royal Meteorological Society Guidance" or similar guidelines from a recognised authority. Page 18 of 30 EPA Export :00:59:06

19 IPPC Application Form V1/07 RESPONSE See Attachment I.1 I.2. Assessment of Impact on Receiving Surface Water Describe the existing environment in terms of water quality with particular reference to environmental quality standards or other legislative standards. Table I.2(i) should be completed Provide a statement whether or not emissions of main polluting substances (as defined in the Schedule of S.I. 394 of 2004) to water are likely to impair the environment. Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made. Full details of the assessment and any other relevant information on the receiving environment should be submitted as Attachment N o I.2. See Attachment I.2 RESPONSE I.3. Assessment of Impact of Sewage Discharge. Give summary details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made. Full details of the assessment and any other supporting information should form Attachment N o I.3. RESPONSE Not Applicable I.4 Assessment of Impact of Ground/Groundwater Emissions Describe the existing groundwater quality. Tables I.4(i) should be completed. Give summary details and an assessment of the impacts of any existing or proposed emissions on the ground (aquifers, soils, sub-soils and rock environment), including any impact on environmental media other than those into which the emissions are to be made. This includes landspreading, land injection etc. Land on which material may be landspread shall be identified on a suitable scaled map (1:10,560 and 1:50,000) and submitted as no greater than A3 size. All vulnerable (as a result of ground emissions) surface water bodies must be identified on these maps. Additional information should be included in Attachment N o I.4. Landspreading of Agricultural/Non Agricultural Wastes Tables I.4(ii) and I.4.(iii) should be complete where applicable. Further information is available in the Application Guidance Document. Page 19 of 30 EPA Export :00:59:06

20 IPPC Application Form V1/07 RESPONSE Not Applicable I.5 Ground and/or Groundwater Contamination Summary details of known ground and/or groundwater contamination, historical or current, on or under the site must be given. Full details including all relevant investigative studies, assessments, or reports, monitoring results, location and design of monitoring installations, plans, drawings, documentation, including containment engineering, remedial works, and any other supporting information should be included in Attachment N o I.5. Not Applicable RESPONSE I.6 Assessment of the Environmental Impact of On-site Waste Recovery and/or Disposal. Describe the arrangements for the prevention and recovery of waste generated by the activity. Give details, and an assessment of the impact of any existing or proposed on-site waste recovery/disposal on the environment, including environmental media other than those into which the emissions are to be made. This information should form Attachment N o I.6. Not Applicable I.7 Noise Impact RESPONSE Give details and an assessment of the impacts of any existing or proposed emissions on the environment, including environmental media other than those into which the emissions are to be made. Ambient noise measurements Complete Table I.7(i) in relation to the information required below: (i) (ii) State the maximum Sound Pressure Levels which will be experienced at typical points on the boundary of the operation. (State sampling interval and duration) State the maximum Sound Pressure Levels which will be experienced at typical noise sensitive locations, outside the boundary of the operation. (iii) Give details of the background noise levels experienced at the site in the absence of noise from this operation. Prediction models, maps (no larger than A3), diagrams and supporting documents, including details of noise attenuation and noise proposed control measures to be employed, should form Attachment N o I.7. Page 20 of 30 EPA Export :00:59:06

21 IPPC Application Form V1/07 RESPONSE See Attachment I.7 I.8 Environmental Considerations and BAT Describe in outline the main alternatives, if any, to the proposals contained in the application. Describe any environmental considerations which have been made with respect to the use of cleaner technologies, waste minimisation and raw material substitution. Describe the measures proposed or in place to ensure that: (a) The best available techniques are or will be used to prevent or eliminate or, where that is not practicable, generally reduce an emission from the activity; (b) no significant pollution is caused; (c) waste production is avoided in accordance with Council Directive 75/442/EEC of 15 July 1975 on waste; where waste is produced, it is recovered or, where that is technically and economically impossible, it is disposed of while avoiding or reducing any impact on the environment; (d) energy and other resources are used efficiently; (e) the necessary measures are taken to prevent accidents and limit their consequences; (f) the necessary measures are taken upon definitive cessation of activities to avoid any pollution risk and return the site of operation to a satisfactory state. Supporting information should form Attachment N o I.8. See Attachment I.8 RESPONSE SECTION J: ACCIDENT PREVENTION & EMERGENCY RESPONSE Describe the existing or proposed measures, including emergency procedures, to minimise the impact on the environment of an accidental emission or spillage. Also outline what provisions have been made for response to emergency situations outside of normal working hours, i.e. during night-time, weekends and holiday periods. Describe the arrangements for abnormal operating conditions including start-up, leaks, malfunctions or momentary stoppages. Supporting information should form Attachment N o J. See Attachment J RESPONSE Page 21 of 30 EPA Export :00:59:06

22 IPPC Application Form V1/07 SECTION K: REMEDIATION, DECOMMISSIONING, RESTORATION & AFTERCARE Describe the existing or proposed measures to minimise the impact on the environment after the activity or part of the activity ceases operation, including provision for postclosure care of any potentially polluting residuals. Supporting information should be included as Attachment No. K. RESPONSE Decommissioning, restoration & Aftercare of the proposed peaking plants will be carried out in line with the existing IPPC licence requirements. The infrastructure associated with the proposed development will be incorporated into the pre-existing guidelines for this aspect of the facility operation. These include: Removal of all chemicals or wastes stored on site. Any oils, lubricants or fuels that are on site at the time of closure will be disposed of or recycled through appropriately registered contractors, Post final operation, plant equipment, machinery etc will be dismantled and stored under suitable conditions until sold to other power generators or disposed or recycled through appropriately licensed waste disposal contractors. Plant buildings will undergo a thorough house cleaning The site and buildings will be left in a secure manner and appropriate security maintained on site in the event of the site being left vacant for a period of time. SECTION L: STATUTORY REQUIREMENTS Indicate how the requirements of Section 83(5)(a)(i) to (v) and (vii) to (x) of the EPA Acts, 1992 and 2003 shall be met, having regard, where appropriate, to any relevant specification issued by the Agency under section 5 (3) of the Act and the reasons for the selection of the arrangements proposed. RESPONSE Section 83(5) (a) (i): The activity will not lead to a breach of Section 50 or Section 51 of the Air Pollution Act, 1987 (See section E.1 and I.1 of the application form and associated attachments) Section 83(5) (a) (ii): The activity will not lead to a breach of section 26 of the local government (Water Pollution) Act (See sections E.2 and I.2 of the application form and associated attachments) Section 83(5) (a) (iii): There are no relevant Regulations or standards requiring being addressed arising from the nature of the proposed activities and the receiving environment. Section 83(5) (a) (iv): The activity will not lead to a breach of Section 106 of the EPA Acts (See sections E.3 and I.5 of the application form and associated attachments) Section 83(5) (a) (v): The activity will not result in emissions that will cause significant environmental pollution (See section B.3 Environmental impact Statement) Section 83(5) (a) (vii): The activity will be managed to ensure that the production of waste is prevented or minimised and where waste is produced, it will be recovered and where it is not economically and technically possible to recover it, be disposed of in a manner which will prevent or minimise any impact on the environment. (See section H.2 and relevant attachment) Page 22 of 30 EPA Export :00:59:06

23 IPPC Application Form V1/07 Section 83(5) (a) (viii): The activity will be managed in order that energy is to be used efficiently in the carrying out of the licensed activity. (See section G.2 and relevant attachment) Section 83(5) (a) (ix): The activity will be operated so that necessary measures will be taken to prevent accidents in the carrying out of the activity. In addition, it is ensured that where an accident occurs, its consequences for the environment are limited, and where there are consequences for the environment, these consequences are remedied.(see Section J and relevant attachment) Section 83(5) (a) (x): The activity will ensure that necessary measures are taken upon the permanent cessation of the activity (including such a cessation resulting from the abandonment of the activity) to avoid any risk of environmental pollution and return the site of the activity to a satisfactory state. (See Section K) Indicate whether or not the activity is carried out, or may be carried out, or is located such that it is liable to have an adverse effect on - (a) a site placed on a list in accordance with Chapter 1 of SI 94 of 1997, or (b) a site where consultation has been initiated in accordance with Article 5 of the EU Habitats Directive (92/43/EEC), or The activity will not impact on such sites RESPONSE Indicate whether or not the activity is liable to have an adverse effect on water quality in light of S.I. No. 258 of 1998 (Local Government (Water Pollution) Act, 1977 (Water Quality Standards for Phosphorus) Regulations, 1998). RESPONSE The activity will not have an adverse effect on water quality in light of S.I. No. 258 of 1998 (Local Government (Water Pollution) Act, 1977 (Water Quality Standards for Phosphorus) Regulations, 1998). Indicate whether any of the substances specified in the Schedule of the EPA (Licensing) (Amendment) 2004, S.I. 394 of 2004, are discharged by the activity to the relevant medium. RESPONSE The following substances as specified in the Schedule of the EPA (Licensing) (Amendment) Regulations, 2004 (S.I. No. 394 of 2004) are discharged by the activity: Air: (1) Sulphur dioxide and other sulphur compounds (2) Oxides of nitrogen and other nitrogen compounds (6) Dust The emissions of these substances are predicted not to have a significant impact on the nearest sensitive receptors. (See Section I.1 and relevant attachment) Fit and Proper Person The PoE Act in Section 83(5)(xi) specifies that the Agency shall not grant a licence unless it is satisfied that the applicant or licensee or transferee as the case may be is a fit and Page 23 of 30 EPA Export :00:59:06

24 IPPC Application Form V1/07 proper person. Section 84(4) of the PoE Act specifies the information required to enable a determination to be made by the Agency. Indicate whether the applicant or other relevant person has been convicted under the PoE Act, the Waste Management Act 1996, the Local Government (Water pollution) Acts 1977 and 1990 or the Air Pollution Act No RESPONSE Provide details of the applicant s technical knowledge and/or qualifications, along with that of other relevant employees. RESPONSE Edenderry Power Limited has been operating the existing facility for almost 9 years and in that period has gained extensive experience in power generation Provide information to show that the person is likely to be in a position to meet any financial commitments or liabilities that may have been or will be entered into or incurred in carrying on the activity to which the application relates or in consequence of ceasing to carry out that activity. RESPONSE A copy of the Bord na Móna plc annual report (2006/07) containing a statement of accounts is available on the website Supporting information should be included as Attachment N o L with reference to where the information can be found in the application. Page 24 of 30 EPA Export :00:59:06

25 IPPC Application Form V1/07 Page 25 of 30 EPA Export :00:59:06

26 IPPC Application Form V1/07 ANNEX 1: CHECKLIST FOR ARTICLE 10 COMPLIANCE Article 10 of the Environmental Protection Agency (Licensing) Regulations, 1994 to 2004 sets out the statutory requirements for information to accompany a licence application. The Application Form is designed in such a way as to set out these questions in a structured manner and not necessarily in the order presented in Article 10. In order to ensure a legally valid application in respect of Article 10 requirements, all Applicants should complete the following checklist and submit it with the completed Application Form. Article 10(2) Section in Checked by Application Applicant (a) give the name, address and telephone number of the applicant and, if different, any address to which correspondence relating to the application should be sent and, if the applicant is a body corporate, the address B.1 of its registered or principal office, (b) give - (i) in the case of an established activity, the number of employees and other persons working or engaged in connection with the activity on the date after which a licence is required and during normal levels of operation, or (c) (d) (ii) in any other case, the gross capital cost of the activity to which the application relates, give the name of the planning authority in whose functional area the activity is or will be carried on, in the case of a discharge of any trade effluent or other matter (other than domestic sewage or storm water) to a sewer of a sanitary authority, give the name of the sanitary authority in which the sewer is vested or by which it is controlled, B.4 B.5 NA (e) (f) (g) give the location or postal address (including where appropriate, the name of the relevant townland or townlands) and the National Grid reference of the premises to which the activity relates, B.2 specify the relevant class or classes in the First Schedule to the Act to which the activity relates, B.3 specify the raw and ancillary materials, substances, preparations, fuels and energy which will be produced by or utilised in the activity, G (h) describe the plant, methods, processes, ancillary processes, abatement, recovery and treatment systems, and operating procedures for the activity, D Page 26 of 30 EPA Export :00:59:06

27 IPPC Application Form V1/07 Article 10(2) continued../ Section in Application (i) indicate how the requirements of section 83(5)(a)(i) to (v) and (vii) to (x) of the Act shall be met, having regard, where appropriate, to any relevant specification issued by the Agency under section L 5(3) of the Act and the reasons for the selection of the arrangements proposed, Checked by Applicant (j) give particulars of the source, nature, composition, temperature, volume, level, rate, method of treatment and location of emissions, and the period or periods during which the emissions are made or are to be made, E (k) (l) (m) (n) (o) (p) describe the arrangements for the prevention or minimisation of waste and, where waste is produced, the on and of site arrangements for the recovery or disposal of solid and liquid wastes, H specify, by reference to the relevant European Waste Catalogue codes as prescribed by Commission Decision 2000/532/EC of 03 May 2000, the quantity and nature of the waste or wastes produced or to be produced by the activity, provide: (i) details, and an assessment, of the impacts of any existing or proposed emissions on the environment, including on an environmental medium other than that or those into which the emissions are or are to be made, and (ii) details of the proposed measures to prevent or eliminate, or where that is not practicable, to limit, reduce or abate emissions, identify monitoring and sampling points and outline proposals for monitoring emissions and the environmental consequences of any such emissions, F.3 describe the condition of the site of the installation, describe in outline the main alternatives, if any, to the proposals contained in the application which were studied by the applicant, I.8 H I I (q) specify the measures to be taken to comply with an environmental quality standard where such a standard requires stricter conditions to be attached to a licence than would otherwise be determined by reference to best available techniques, NA Page 27 of 30 EPA Export :00:59:06

28 IPPC Application Form V1/07 Article 10(2) continued../ Section in Checked by Application Applicant (r) describe the measures to be taken for minimising pollution over long distances or in the territory of other states, A (s) describe the measures to be taken under abnormal operating conditions, including start-up, shutdown, leaks, malfunctions, breakdowns and momentary stoppages, J (t) (u) describe the measures to be taken on and following the permanent cessation of the activity or part of the activity to avoid any risk of environmental pollution and to return the site of the activity to a satisfactory state, describe, in the case of an activity which gives, or could give rise, to an emission containing a hazardous substance which is discharged to an aquifer and is specified in the Annex to Council Directive 80/68/EEC of 17 December 1979 on the protection of groundwater against pollution caused by certain dangerous substances, the arrangements necessary to comply with said Council Directive, (v) include any other information required under Article 6(1) of Council Directive 96/61/EC of 24 September 1996 concerning integrated pollution prevention and control, (w) (x) include a non-technical summary of information provided in relation to the matters specified in paragraphs (f) to (v) above, state whether the activity consists of, comprises, or is for the purposes an establishment to which the European Communities (Control of Major Accident Hazards involving Dangerous Substances) Regulations, 2000 apply, K NA NA A NA Page 28 of 30 EPA Export :00:59:06

29 IPPC Application Form V1/07 Article 10(3) Without prejudice to Article 12(1), an application for a licence shall be accompanied by - Section in Application Checked by Applicant (a) (b) a copy of the relevant page of the newspaper in which the notice in accordance with article 6 has been published, B.8 a copy of the text of the site notice erected or fixed on the land or structure in accordance with article 7, B.8 (c) (d) a copy of the notice given to the planning authority under section 85(1)(a) of the Act, a copy of such plans, including a site plan and location map (no larger than A3), and such other particulars, reports and supporting documentation as are necessary to identify and describe - (i) the activity (ii) the position of the site notice in accordance with article 7, (iii) the point or points from which emissions are made or are to be made, and (iv) monitoring and sampling points, and (e) a fee specified in accordance with section 94 of the Act. Fee Included B.8 B.2 B.2 B.2 B.2 Page 29 of 30 EPA Export :00:59:06

30 IPPC Application Form V1/07 Article 10(4) Checked by Applicant (b) A signed original and 2 hardcopies of the application and accompanying documents/particulars in hardcopy format plus 2 copies of all files in electronic searchable PDF format on CD-Rom shall be submitted to the headquarters of the Agency. In cases where an E.I.S. is required to be submitted to the Agency in support of the application, a signed original and 2 hardcopies of the EIS plus 16* copies of all files in electronic searchable PDF format on CD-Rom shall be submitted to the headquarters of the Agency. * Energy sector applicants = 18 copies Hardcopies submitted. CD version submitted. Page 30 of 30 EPA Export :00:59:06

31 Edenderry Power Ltd. IPPC Review Attachment A.1 Description Non Technical Summary Edenderry Power Ltd operate a peat fired power station in Ballykilleen, Edenderry, Co. Offaly on behalf of Bord na Mona plc. The construction of the plant commenced in January 1999 and the boiler structure was completed in August of that year. The main plant buildings were ready in December and turbine erection and connection to the national grid were completed in May Synchronisation of the plant to the grid took place in September with full commissioning in December The plant directly employs 45 people as well as c. 250 indirectly in supplies to and services provided to the plant. From December 2000, Edenderry power has been supplying 120MW electricity to the national grid meeting c. 3% of Ireland s requirements. The existing plant operates using a state of the art bubbling fluidised bed peat combustion and burns approximately 1.0 to 1.2 million tonnes of peat per annum. The energy created from burning peat is used to generate steam which in turn drives a generator which through a step-up transformer supplies the national grid. The exhaust steam from the turbine is condensed with cooling water from a system of cooling towers. Fly ash in the flue gas leaving the boiler is removed by an electrostatic precipitator by means of an electrical charge achieving a removal efficiency of greater than 99.8%. The flue gas leaving the electrostatic precipitator is then discharged through a 70 m high stack. The facility operates under IPPC licence register no P Under the provision of this licence the facility has obtained permission to replace up to a maximum of 20% of the fuel requirement with biomass (composed of a maximum of 10% meat and bone meal (MBM) and 10% wood chippings). The review of this IPPC licence is sought in relation to the operation of two Pratt and Whitney Twinpac gas turbine units at the site. The electrical output from each of the units will be approximately 52 megawatts, giving a total increase of the site s capacity of 104 megawatts. The twinpac units are comprised of two interlinked gas turbines (GTs) sharing a common generator. Each twinpac unit has two stacks giving a total of four stacks for the proposed infrastructure. The twinpac units require additional infrastructure such as a source of demineralised water (from existing on site sources), water storage tanks, gasoil storage tanks fuel conditioning plant and two bunded transformers. Drawing number EdenP rev-02 site layout drawing indicates the proposed location of the Twinpacs and the existing infrastructure. Air emission from the four gas turbines will be discharged through four dedicated 20m exhaust stacks. The units will be fuelled with low sulphur (max. 0.1%S) gas oil. Process The process involved is the combustion of gas oil in a gas turbine that drives a generator for electricity production. The turbine comprises an air compressor, a combustion chamber, a turbine and an electricity generator. The air compressor draws in large quantities of air and compresses it within the combustion chamber where it flows through the turbine. Following injection of fuel into the combustion chamber the combined gases within the chamber reach temperatures of greater than 1,000 C. This increase in temperature increases the velocity of the gases through the turbine providing sufficient power to operate the air compressor and produce the desired electrical power output. The waste gases from the process, following expansion and extraction of mechanical work are discharged to atmosphere via the dedicated discharge stacks. Operations The plant will be required to operate during peaking capacity. These do not normally occur at night-time and night-time operation is therefore not foreseen. It is predicted that, when called upon, the units will operate between 5 and 10 hours per day. The units will operate at maximum Bord na Móna Environmental Ltd Page 1 EPA Export :00:59:06

32 Edenderry Power Ltd. IPPC Review Attachment A.1 output or not at all. The number of units in operation at any one time will depend on the size of the peak load experienced. Irrespective of the number of units on-line, the Twinpacs will operate in combination with the existing power station. Plant operation is expected to for a maximum of 1,500 hours per year. The main consumables used during the operation of the plants will be gas oil and demineralised water. Based on the capacity of the gas oil storage tanks both plants will be able to run continuously for a maximum of 60 hours before refilling of the storage tanks is required. Over the entire year (based on 1,500 hours running), the total volume of gas oil used will be 38,700 tonnes with a corresponding 42,570 tonnes of demineralised water required. If one or both of the units run less than the 1,500 hours than fuel and water consumption will be proportionally less. The maximum amount of gas oil stored at the facility will be 1,900 tonnes( including existing storage). Therefore the facility does not fall within the remit of the European Communities (Control of Major Accident Hazards Involving Dangerous Substances) Regulation Air Emissions The pollutant parameters that may be present in the air emission from the operation of the proposed peaking plants are as follows: Nitrogen Oxides (NO x ) Sulphur Dioxide (SO 2 ) Carbon Monoxide (CO) Particulate Carbon Dioxide The parameters of most significance with respect to potential impact on ambient air quality of the surrounding environment are nitrogen oxides (NO x ) and sulphur dioxide (SO 2 ). As the proposed infrastructure is of the most advanced kind available the emission of particulate and carbon monoxide are very low. The carbon dioxide emission will not have an impact on ambient air quality. SO 2 and NO x emissions arise from the incomplete combustion of fossil fuels. NO x is a mixture of Nitric Oxide and Nitrogen Dioxide (majority in Nitric oxide form at the point of emission). It is produced from the oxidation of fuel or air nitrogen under high temperatures. SO 2 is produced by the oxidation of sulphur containing fuels with the amount of SO 2 produced directly related to the sulphur content of the fuel. The plant will use state of the art low NO x technology in the form of a water injection abatement system. Use of this system will ensure that the operation of the plant will achieve the emission limit values ( ELV s) determined by the EU Commission as representing Best Available Technology ( BAT) in the EU large Combustion Plant Directive ( 2001/80/EC) and also comply with the requirements of the large combustion Plants Regulations (SI 644 of 2003). The plant will also be fuelled using low sulphur content (<0.1%S) gas oil to further minimise emissions. To establish the potential impact on ambient air quality of the operation of the Twinpac units an air dispersion modelling assessment was carried of the two most significant parameters (NO x and SO 2 ) on the receiving environment. The modelling was carried out based on available emission data for this type of plant, taken from IPPC licence applications of similar infrastructure at other facilities. The emissions of the proposed twinpac units (operating simultaneously and continuously) were combined with the existing emissions from the single large power plant stack (A1-1). The input data used for the existing stack is based on the existing maximum IPPC licence limits and would be considered to be worst case. The modelling was carried out using site specific information that included, the existing emissions, the proposed emissions from the Twinpacs, the local topographical data, the existing site infrastructure and the additional required Bord na Móna Environmental Ltd Page 2 EPA Export :00:59:06

33 Edenderry Power Ltd. IPPC Review Attachment A.1 infrastructure. The predicted emissions were examined using three years of meteorological data to estimate the worst case predicted ground level impact. The predicted impacts were then compared to the appropriate Air Quality Standards (AQS). A group of seven nearest sensitive receptors were identified around the facility and potential impact on ambient air quality was determined at these locations. The predicted contributions to ground level concentrations of SO 2 and NO x due to the combined emissions of the EPL power station and proposed peaking plants are low. The dispersion modelling indicates that the simultaneous operation of both facilities will not have a significant adverse impact on air quality outside the boundary of the facility at these locations. These predicted concentrations are well below the relevant national air quality standards. The dispersion modelling indicates that due to the influence of existing on site buildings elevated concentrations are predicted in the immediate vicinity of the plant within the site boundary. Climate and Trans boundary Air Pollution The proposed infrastructure will utilise high efficiency state of the art technology and will participate in the EU emissions trading scheme. Based on 1,500 operational hours the twinpacs will emit a maximum of 120,000tonnes of CO 2. This represents a very small part of total national emissions of greenhouse gases. The long range transport of sulphur dioxide and nitrogen oxides contributes to regional pollution problems in Europe. This has resulted in international agreement on limiting emissions. Based on 1,500 operational hours the total sulphur dioxide and nitrogen oxides produced would be 79 tonnes and 169 tonnes respectively. To put this in context the existing facility is licensed to emit 2,549.2 tonnes per year of sulphur dioxide and 1,380.8 tonnes of nitrogen oxides per year. This is an approximate 3% increase in sulphur dioxide emissions and an 12% increase in nitrogen dioxide for the facility. In the context of the national emission allocations these are not significant increases. Noise Operations at the existing power station are subject to daytime and night-time noise limits applied at the nearest noise sensitive receptor. The facility is in compliance with these limit values, which will continue to apply following installation of the new plant. These types of power generating units are commonly located in urban environments and therefore incorporate a number of engineering controls to reduce the potential for significant nose impact. The controls that are implemented include installation of a silencer at the top of the outlet stack, provision of an inlet silencer to attenuate noise from the compressor, cladding of the enclosure and silencing of various fans and other pieces of equipment. Modelling of the combined impact of the existing facility and the proposed Gas Turbines was carried out and predicted impacts were determined at the nearest noise sensitive receptor. The results of the cumulative noise modelling show that the noise contribution from the proposed generators has a minimal effect on the current noise levels at the nearest sensitive receptor. Water Demineralised water from the existing power station will be used in the operation of the peaking plant for the abatement of air emissions. At maximum operational capacity the water usage will be 28.4m 3 /hour. Based on a storage capacity of 2,400m 3, the plant would be able to run for 84.5 hours continuously without requiring any additional water from the existing facility. The water supply requirement is within the capacity of the existing plant and existing limits on the wastewater streams. The existing wastewater treatment system is under complete automatic control. Bord na Móna Environmental Ltd Page 3 EPA Export :00:59:06

34 Edenderry Power Ltd. IPPC Review Attachment A.1 Any additional rainwater run-off that is generated by the increase of hard standing areas required for the installation of the proposed infrastructure will be directed into the existing surface water management system. The potential increase in volume of additional storm water is so low as to be of no consequence. Other emissions There will be no onsite disposal of waste. Any waste arising from the operation of the twinpac units such as sludge from the fuel conditioning unit, waste oils arising from maintenance activities, metal scrap and mixed packaging waste will be recycled or disposed of in accordance with the requirements of the packaging regulations and using approved waste disposal contractors. The proposed twinpacs units will not have any discharge to ground or groundwater arsing from the activity. Resources Required There are a number of resources required for the installation and operation of the proposed infrastructure. An area of the site on which the facility is located will have to be dedicated to the twinpac units as well as the auxiliary storage tanks. This area was previously used as a contractor car park area. Sections of this area will require concrete pads to be installed for the twinpac units, auxiliary tanks and bunded areas. The remaining area will remain as is and continue to allow free draining of rainwater to ground. The main resources used during the operation of the twinpac units will be gas oil and demineralised water. Gas oil is a light distillate similar to diesel and is required to have a low sulphur content (<0.1%S). Based on a maximum of 1,500hrs per year the total consumption will be 38,600 tonnes of gas oil. The gas oil will be stored in two 650m 3 (untreated) storage tanks and one 800m 3 (treated) storage tank adjacent to the facility. Water for the NO x abatement will be sourced from the existing on site demineralised water stocks. A reserve of 2400m 3 will be stored adjacent to the twinpac unit in two water storage tanks. This reserve will be dedicated to the operation of the twinpac units. Monitoring of emissions The two matrices that will require monitoring from the operation of the twinpac will be air emissions and water emissions. The emissions of NO x and SO 2 from the operation of the units will be measured using a continuous emission monitoring system (CEMS). The CEMS will provide monitoring to confirm ELV compliance and will be connected to the existing Scania recording system. The water emissions will be incorporated into the existing waste water treatment infrastructure and as such will be monitored under the requirements of the existing IPPC licence. Environmental management A formal Environmental management System (EMS) is already in place at Edenderry Power Limited. This system is fully documented and meets the requirements of the international standard for Environmental Management Systems ISO Specification with guidance for use. The existing EMS will be revised and updated to include the installation and operation of the proposed peaking plants. Decommissioning and Post Closure Bord na Móna Environmental Ltd Page 4 EPA Export :00:59:06

35 Edenderry Power Ltd. IPPC Review Attachment A.1 The existing facility has already completed a decommissioning and closure plan as required by the existing IPPC licence. This closure plan will be updated to include the decommissioning and removal of all infrastructure associated with the peaking plants. Aspects relating to the existing IPPC Licence Further to the installation and operation of the proposed peaking plants there are a number of issues with regard to the existing licence that are subject to change as part of this review. Briefly the following changes are proposed: Introduction of an increased hourly air Emission limit value ( twice the existing) to be applied only for spot-check 30minute measurements to bring in line with existing conditions for continuous emission monitoring (Condition 4.1.1) Removal of Table B.1.2 ( Schedule B) and implementation of Table B.1 Schedule B Emission to air only to reflect the reclassification of category 3 MBM Removal of requirement for annual monitoring of PM 10 and PM 2.5 from Table C.1.2 Schedule C: Control and Monitoring as this is not required under the Waste Incineration directive or the Large Combustion plant directive Temperature emission limit value to be applied at SW-1 instead of W-1 Approval for proposed boiler wash down process during scheduled shut down periods Alteration in application of noise emission limit values to apply at all times apart from 1 hour before and 1 hour after synchronisation of the existing plant with the national grid during start up and shut down. Bord na Móna Environmental Ltd Page 5 EPA Export :00:59:06

36 Edenderry Power Ltd. IPPC Review Attachment B.1 The Company registration number is The address of the Registered Office of the Company is Main Street, Newbridge, Co. Kildare Bord na Móna Environmental Ltd Page 1 EPA Export :00:59:06

37 Edenderry Power Ltd. IPPC Review Attachment B.1 Bord na Móna Environmental Ltd Page 2 EPA Export :00:59:06

38 ¹ <Double-click here to enter title> Edenderry Power Ltd Edenderry Power Ltd Peaking Plants Site Location Map SITE NOTICE!( Edenderry!( Clonbulloge Main Street, Newbridge, Co. Kildare. Phone Fax "Copyright and ownership of this drawing is vested in Bord na Mona Environmental Ltd. whose prior written consent is required for its use, reporduction or for publication to a third party. All rights reserved by the law of copyright and by international copyright conventions are reserved to Bord na Mona Environmental Ltd. and may be protected by court proceedings for damages and/or injunctions and costs" (C) Copyright Bord na Mona Environmental Ltd. Issue Details Drawn By: Approved By Scale SCr SC 1:10000 Date Drawing No. Rev No. 17/03/08 EdenP rev-01 EdenP rev-01 c Ordnance Survey of Ireland All rights reserved Permit Number EPA Export :00:59:06

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41 Headquarters P.O. Box 3000 Johnstown Castle Estate County Wexford Ireland INTEGRATED POLLUTION PREVENTION & CONTROL LICENCE Licence Register Number: 654 Licensee: Location of Installation: Edenderry Power Limited Ballykilleen Edenderry County Offaly EPA Export :00:59:07

42 Environmental Protection Agency Licence Reg. N o 654 INTRODUCTION This introduction is not part of the licence and does not purport to be a legal interpretation of the licence. Edenderry Power Limited (EPL) operate a peat fired base load power station under licence Reg. No. 482 which was granted on 22 July 1999 under Class 2.1 of the First Schedule to the Environmental Protection Agency Act This power station was built on a greenfield site in a rural area in Ballykilleen, Edenderry, County Offaly and, following a period of commissioning, commenced production in January The plant has an input of 299 MW th and a net output of 118 MW el and consumes approximately 1.0 million tonnes of peat per annum. The purpose of the new licence IPPC licence Reg. 654 is to allow Edenderry Power Limited to replace a maximum of 20% (by calorific value) of the fuel requirement with 10% biomass (wood material) and 10% non-specified risk material meat and bonemeal (MBM). The co-incineration of MBM requires Edenderry Power Limited to be licensed under Class 11.1 of the First Schedule to the Environmental Protection Agency Acts 1992 and The licence sets out in detail the conditions under which Edenderry Power Limited will operate and manage this Installation. Introduction EPA Export :00:59:07

43 Environmental Protection Agency Licence Reg. N o 654 Table of Contents Page No. Glossary of Terms 1 Decision & Reasons for the Decisions 5 Part I Schedule of Activities Licensed 5 Part II Schedule of Activities Refused 5 Part III Conditions 6 Condition 1. Scope 6 Condition 2. Management of the Installation 6 Condition 3. Infrastructure and Operation 8 Condition 4. Interpretation 10 Condition 5. Emissions 12 Condition 6. Control and Monitoring 12 Condition 7. Resource Use and Energy Efficiency 15 Condition 8. Materials Handling 16 Condition 9. Accident Prevention and Emergency Response 17 Condition 10. Decommissioning & Residuals Management 18 Condition 11. Notifications, Records and Reports 19 Condition 12. Financial Charges and Provisions 21 SCHEDULE A: Limitations 23 SCHEDULE B: Emission Limits 24 SCHEDULE C: Control & Monitoring 29 SCHEDULE D: Annual Environmental Report 34 Contents EPA Export :00:59:07

44 Environmental Protection Agency Licence Reg. N o 654 Glossary of Terms All terms in this licence should be interpreted in accordance with the definitions in the Environmental Protection Agency Acts 1992 and 2003 (the Acts), unless otherwise defined in this section. Adequate lighting AER Agreement Annually Attachment Application Appropriate facility BAT Bi-annually Biennially Biomass BOD CEN COD Co-incineration Construction and Demolition Waste Containment boom Daily Day Daytime DB(A) DO 20 lux measured at ground level. Annual Environmental Report. Agreement in writing. All or part of a period of twelve consecutive months. Any reference to Attachments in this licence refers to attachments submitted as part of this licence application. The application by the licensee for this licence. A waste management facility, duly authorised under relevant law and technically suitable. Best Available Techniques All or part of a period of six consecutive months. Once every two years. As defined in Article 2(11) of Directive 2001/80/EC on the limitation of certain pollutants into the air from large combustion plants. 5 day Biochemical Oxygen Demand. Comité Européen De Normalisation European Committee for Standardisation Chemical Oxygen Demand. As defined in Council Directive 2000/76/EC on the incineration of waste. Wastes that arise from construction, renovation and demolition activities: Chapter 17 of the EWC or as otherwise may be agreed. A boom which can contain spillages and prevent them from entering drains or watercourses or from further contaminating watercourses. During all days of plant operation, and in the case of emissions, when emissions are taking place; with at least one measurement on any one day. Any 24 hour period hrs to 2200 hrs Decibels (A weighted). Dissolved Oxygen. Page 1 of 34 EPA Export :00:59:07

45 Environmental Protection Agency Licence Reg. N o 654 Documentation Drawing EMP Emission Limits Environmental Damage EPA European Waste Catalogue (EWC) Facility Fortnightly GC/MS Green waste Heavy Metals HFO ICP Incident Any report, record, result, data, drawing, proposal, interpretation or other document in written or electronic form which is required by this licence. Any reference to a drawing or drawing number means a drawing or drawing number contained in the application, unless otherwise specified in this licence. Environmental Management Programme. Those limits, including concentration limits and deposition rates established in Schedule B of this licence. Has the meaning given it in Directive 2004/35/EC Environmental Protection Agency. A harmonised, non-exhaustive list of wastes drawn up by the European Commission and published as Commission Decision 2000/532/EC and any subsequent amendment published in the Official Journal of the European Community. Any site or premises used for the purposes of the recovery or disposal of waste. A minimum of 24 times per year, at approximately two week intervals. Gas Chromatography/Mass Spectroscopy Waste wood (excluding timber), plant matter such as grass cuttings, and other vegetation. This term is to be interpreted as set out in Parameters of Water Quality, Interpretation and Standards published by the Agency in ISBN Heavy Fuel Oil. Inductively Coupled Plasma Spectroscopy. The following shall constitute an incident for the purposes of this licence: a) an emergency; b) any emission which does not comply with the requirements of this licence; c) any exceedance of the daily duty capacity of the waste handling equipment; d) any trigger level specified in this licence which is attained or exceeded; and, e) any indication that environmental pollution has, or may have, taken place. Installation IPPC K A stationary technical unit or plant where the activity concerned referred to in the First Schedule of EPA Acts 1992 and 2003 is or will be carried on, and shall be deemed to include any directly associated activity, which has a technical connection with the activity and is carried out on the site of the activity. Integrated Pollution Prevention & Control. Kelvin. Page 2 of 34 EPA Export :00:59:07

46 Environmental Protection Agency Licence Reg. N o 654 kpa Leq Licensee List I List II Local Authority Maintain Mass Flow Limit Mass Flow Threshold Kilo Pascals. Equivalent continuous sound level. Edenderry Power Limited, Ballykilleen, Edenderry, County Offaly. As listed in the EC Directives 76/464/EEC and 80/68/EEC and amendments. As listed in the EC Directives 76/464/EEC and 80/68/EEC and amendments. Offaly County Council Keep in a fit state, including such regular inspection, servicing, calibration and repair as may be necessary to adequately perform its function. An Emission Limit Value which is expressed as the maximum mass of a substance which can be emitted per unit time. A mass flow rate, above which, a concentration limit applies. MBM Monthly Night-time Noise Sensitive Location (NSL) Meat and Bone Meal A minimum of 12 times per year, at approximately monthly intervals hrs to 0800 hrs. Any dwelling house, hotel or hostel, health building, educational establishment, place of worship or entertainment, or any other Installation or area of high amenity which for its proper enjoyment requires the absence of noise at nuisance levels. Oil Separator Device installed according to the International Standard I.S. EN 858-2:2003 (Separator systems for light liquids (e.g. oil and petrol)-part 2: Selection of nominal size, installation, operation and maintenance. PER Pollution Emission Register. Quarterly Rate of Desulphurisation Regional Fisheries Board Sanitary Effluent Sample(s) SOP All or part of a period of three consecutive months beginning on the first day of January, April, July or October. The ratio of the quantity of sulphur which is not emitted into the air at the combustion plant site over a given period to the quantity of sulphur contained in the fuel which is introduced into the combustion plant facilities and which is used in the same period. Southern Regional Fisheries Board. Waste water from facility/installation toilet, washroom and canteen facilities Unless the context of this licence indicates to the contrary, samples shall include measurements by electronic instruments. Standard Operating Procedure. Page 3 of 34 EPA Export :00:59:07

47 Environmental Protection Agency Licence Reg. N o 654 Standard Method Storm Water The Agency TA Luft TOC A National, European or internationally recognised procedure (eg, I.S. EN, ISO, CEN, BS or equivalent), as in-house documented procedure based on the above references, a procedure as detailed in the current edition of Standard Methods for the Examination of Water and Wastewater, (prepared and published jointly by A.P.H.A., A.W.W.A & W.E.F), American Public Health Association, 1015 Fifteenth Street, N.W., Washington DC 20005, USA; or, an alternative method as may be agreed by the Agency. Rain water run-off from roof and non-process areas. Environmental Protection Agency. Technical Instructions on Air Quality Control - TA Luft in accordance with art. 48 of the Federal Immission Control Law (BImSchG) dated 15 March 1974 (BGBI. I p.721). Federal Ministry for Environment, Bonn 1986, including the amendment for Classification of Organic Substances according to section TA.Luft, published in July Total Organic Carbon. Trade Effluent Trade Effluent has the meaning given in the water pollution Acts 1977 and 1990 Trigger Level Weekly WWTP A parameter value, the achievement or exceedance of which requires certain actions to be taken by the licensee. During all weeks of plant operation, and in the case of emissions, when emissions are taking place; with at least one measurement in any one week. Waste Water Treatment Plant. Page 4 of 34 EPA Export :00:59:07

48 Environmental Protection Agency Licence Reg. N o 654 Decision & Reasons for the Decisions Reasons for the Decision The Agency is satisfied, on the basis of the information available, that subject to compliance with the conditions of this licence, any emissions from the activity will comply with and will not contravene any of the requirements of Section 83(5) of the Environmental Protection Agency Acts, 1992 and In reaching this decision the Environmental Protection Agency has considered the application and supporting documentation received from the applicant, all submissions and objections received from other parties and the report of its inspectors. Part I Schedule of Activities Licensed In pursuance of the powers conferred on it by the Environmental Protection Agency Acts, 1992 and 2003, the Agency hereby grants a licence to: Edenderry Power Limited, Ballykilleen, Edenderry, County Offaly under Section 83(1) of the said Acts to carry on the following activities Class 2.1: the operation of combustion installations with a rated thermal input equal to or greater than 50 MW, and Class 11.1: the recovery or disposal of waste in a facility, within the meaning of the Act of 1996, which facility is connected or associated with another activity specified in this Schedule in respect of which a licence or revised licence under Part IV is in force or in respect of which a licence under the said Part is or will be required, at Ballykilleen, Edenderry, County Offaly, subject to the following twelve Conditions, with the reasons therefor and associated schedules attached thereto. Part II Schedule of Activities Refused None of the proposed activities as set out in the licence application have been refused. Page 5 of 34 EPA Export :00:59:07

49 Environmental Protection Agency Licence Reg. N o 654 Part III Conditions Condition 1. Scope 1.1 Activities at this installation shall be limited as set out in Schedule A: Limitations. 1.2 The installation shall be controlled, operated, and maintained and emissions shall take place as set out in this licence. All programmes required to be carried out under the terms of this licence, become part of this licence. 1.3 For the purposes of this licence, the installation, is the area of land outlined in orange on Site Plan Drawing No. T687/2B, Rev. A, in response to the request for information under Article 11(2)(b)(ii) received by the Agency on 31 March Any reference in this licence to installation shall mean the area thus outlined in orange. The licensed activities shall be the carried on only within the area outlined. 1.4 No alteration to, or reconstruction in respect of, the activity or any part thereof which would, or is likely to, result in (a) a material change or increase in: The nature or quantity of any emission, The abatement/treatment or recovery systems, The range of processes to be carried out, The fuels, raw materials, intermediates, products or wastes generated, or (b) any changes in: Site management infrastructure or control with adverse environmental significance, shall be carried out or commenced without prior notice to, and without the agreement of the Agency. 1.5 This licence is for the purposes of IPPC licensing under the EPA Acts, 1992 and 2003 only and nothing in this licence shall be construed as negating the licensee s statutory obligations or requirements under any other enactments or regulations. 1.6 This licence has been granted in substitution for the licence granted to the licensee on 22 July 1999 and bearing Register No.: 482. The previous licence (Reg. No. 482) is replaced by this revised licence. Reason: To clarify the scope of this licence. Condition 2. Management of the Installation 2.1 Installation Management The licensee shall employ a suitably qualified and experienced installation manager who shall be designated as the person in charge. The installation manager or a nominated, suitably qualified and experienced deputy shall be present on the installation at all times during its operation or as otherwise required by the Agency. The management of the co-incineration plant shall be in the hands of a person who is competent to manage the plant. Page 6 of 34 EPA Export :00:59:07

50 Environmental Protection Agency Licence Reg. N o The licensee shall ensure that personnel performing specifically assigned tasks shall be qualified on the basis of appropriate education, training and experience, as required and shall be aware of the requirements of this licence. 2.2 Environmental Management System (EMS) The licensee shall maintain an Environmental Management System (EMS). The EMS shall be updated on an annual basis The EMS shall include as a minimum the following elements: Management and Reporting Structure Schedule of Environmental Objectives and Targets. The licensee shall prepare a Schedule of Environmental Objectives and Targets. The Schedule shall as a minimum provide for a review of all operations and processes, including an evaluation of practicable options, for energy and resource efficiency, the use of cleaner technology, cleaner production, and the prevention, reduction and minimisation of waste, and shall include waste reduction targets. The Schedule shall include time frames for the achievement of set targets and shall address a five year period as a minimum. The Schedule shall be reviewed annually and amendments thereto notified to the Agency for agreement as part of the Annual Environmental Report (AER) Environmental Management Programme (EMP) The licensee shall maintain an EMP, including a time schedule, for achieving the Environmental Objectives and Targets prepared under Condition It shall include: (a) (b) (c) designation of responsibility for targets; the means by which they may be achieved; the time within which they may be achieved. The EMP shall be reviewed annually and amendments thereto notified to the Agency for agreement as part of the Annual Environmental Report (AER) (Condition 11.10). A report on the programme, including the success in meeting agreed targets, shall be prepared and submitted to the Agency as part of the AER. Such reports shall be retained on-site for a period of not less than seven years and shall be available for inspection by authorised persons of the Agency Documentation (i) (ii) Corrective Action The licensee shall maintain an environmental management documentation system which shall be to the satisfaction of the Agency. The licensee shall issue a copy of this licence to all relevant personnel whose duties relate to any condition of this licence. The licensee shall maintain procedures to ensure that corrective action is taken should the specified requirements of this licence not be fulfilled. The responsibility and authority for initiating further investigation and corrective action in the event of a reported nonconformity with this licence shall be defined. Page 7 of 34 EPA Export :00:59:07

51 Environmental Protection Agency Licence Reg. N o Awareness and Training The licensee shall maintain procedures for identifying training needs, and for providing appropriate training, for all personnel whose work can have a significant effect upon the environment. Appropriate records of training shall be maintained Communications Programme The licensee shall establish and maintain a Public Awareness and Communications Programme to ensure that members of the public are informed, and can obtain information at the installation, at all reasonable times, concerning the environmental performance of the installation. In addition the programme shall include provision for regular meetings with local residents and representatives together with the circulation of a newsletter at a frequency to be agreed with the residents, which shall provide information of activities on-site, and compliance with this licence. Reason: To make provision for management of the activity on a planned basis having regard to the desirability of ongoing assessment, recording and reporting of matters affecting the environment. Condition 3. Infrastructure and Operation 3.1 The licensee shall establish all infrastructure referred to in this licence prior to the commencement of the licensed activities or as required by the conditions of this licence. 3.2 Installation Notice Board The licensee shall provide and maintain an Installation Notice Board on the installation so that it is legible to persons outside the main entrance to the installation. The minimum dimensions of the board shall be 1200 mm by 750 mm The board shall clearly show:- a) the name and telephone number of the installation; b) the normal hours of opening; c) the name of the licence holder; d) an emergency out of hours contact telephone number; e) the licence reference number; and f) where environmental information relating to the installation can be obtained. 3.3 The licensee shall install on all emission points such sampling points or equipment, including any data-logging or other electronic communication equipment, as may be required by the Agency. All such equipment shall be consistent with the safe operation of all sampling and monitoring systems. 3.4 Sampling equipment shall be operated and maintained such that sufficient sample is collected to meet both internal monitoring requirements and those of the Agency. A separate composite sample or homogeneous sub-sample (of sufficient volume as advised) should be refrigerated immediately after collection and retained as required for EPA use. Page 8 of 34 EPA Export :00:59:07

52 Environmental Protection Agency Licence Reg. N o The licensee shall clearly label and provide safe and permanent access to all on-site sampling and monitoring points and to off-site points as required by the Agency. 3.6 Tank and Drum Storage Areas All tank and drum storage areas shall be rendered impervious to the materials stored therein All tank and drum storage areas shall, as a minimum, be bunded, either locally or remotely, to a volume not less than the greater of the following:- (i) 110% of the capacity of the largest tank or drum within the bunded area; or (ii) 25% of the total volume of substance which could be stored within the bunded area All drainage from bunded areas shall be diverted for collection and safe disposal All inlets, outlets, vent pipes, valves and gauges must be within the bunded area The integrity and water tightness of all the bunding structures and their resistance to penetration by water or other materials stored therein shall be tested and demonstrated by the licensee at least once every three years. This testing shall be carried out in accordance with any guidance published by the Agency. 3.7 The licensee shall have in storage an adequate supply of containment booms and/or suitable absorbent material to contain and absorb any spillage at the installation. Once used the absorbent material shall be disposed of at an appropriate facility. 3.8 All pump sumps, storage tanks or other treatment plant chambers from which spillage of environmentally significant materials might occur in such quantities as are likely to breach local or remote containment or separator, shall be fitted with high liquid level alarms (or oil detectors as appropriate). 3.9 The provision of a catchment system to collect any leaks from flanges and valves of all over ground pipes used to transport material other than water shall be examined. This shall be incorporated into a schedule of objectives and targets set out in Condition of this licence for the reduction in fugitive emissions The licensee shall maintain, in a prominent location on the site, a wind sock or other wind direction indicator, which shall be visible from the public roadway outside the site. REASON: To provide for appropriate operation of the installation to ensure protection of the environment. Page 9 of 34 EPA Export :00:59:07

53 Environmental Protection Agency Licence Reg. N o 654 Condition 4. Interpretation 4.1 Emission limit values for emissions to atmosphere shall be interpreted in the following way: For Continuous Monitoring of emissions to atmosphere from peat or peat and biomass combustion: The emission limit values for emissions to air shall be regarded, for operating hours within a calendar year (excluding periods of start-up and shutdown), as complied with if: None of the mean calendar monthly mean values exceeds the emission limit values; and In the case of: Sulphur dioxide and dust: 97% of all the 48 hourly mean values do not exceed 110% of the emission limit values. Nitrogen oxides: 95% of all the 48 hourly mean values do not exceed 100% of the emission limit value The value of the 95% confidence intervals of a single measured result shall not exceed the following percentages of the emission limit values: Sulphur dioxide 20% Nitrogen dioxide 20% Dust 30% The validated hourly and daily average values shall be determined from the measured valid hourly average value after having subtracted the value of the confidence interval specified above Any day in which more than three hourly average values are invalid due to malfunction or maintenance of the continuous monitoring system shall be invalidated. If more than ten days a year are invalidated the licensee shall take action as appropriate to improve the reliability of the continuous monitoring system For Continuous Monitoring of emissions to atmosphere from coincineration: No valid daily average value shall exceed the emission limit value Half-hourly average values shall be determined within the effective operating time (excluding the start-up and shutdown periods if no waste is being incinerated) from the measured values after having subtracted the value of the confidence interval below. The daily average values shall be determined from those validated average values To obtain a valid daily average value no more than five half-hourly average values in any day shall be discarded due to malfunction or maintenance of the continuous measurement system. No more than ten daily average values per year shall be discarded due to malfunction or maintenance of the continuous measurement system. Page 10 of 34 EPA Export :00:59:07

54 Environmental Protection Agency Licence Reg. N o At the daily emission limit value level, the values of the 95% confidence intervals of a single measured result shall not exceed the following percentages of the emission limit values: Sulphur dioxide 20% Nitrogen dioxide 20% Dust 30% For Non-Continuous Monitoring (i) (ii) (iii) For any parameter where, due to sampling/analytical limitations, a 30 minute sample is inappropriate, a suitable sampling period should be employed and the value obtained therein shall not exceed the emission limit value. For flow, no hourly or daily mean value, calculated on the basis of appropriate spot readings, shall exceed the relevant limit value. For all other parameters, no 30 minute mean value shall exceed the emission limit value The concentration and volume flow limits for emissions to atmosphere specified in this licence shall be achieved without the introduction of dilution air and shall be based on gas volumes under standard conditions of:- (i) (ii) In the case of combustion gases: Temperature 273K, Pressure 101.3kPa, dry gas; 3% oxygen for liquid and gas fuels; 6% for solid fuels. In the case of co-incineration: Temperature 273K, Pressure 101.3kPa, dry gas, 6% oxygen. 4.2 Emission limit values for emissions to waters in this licence shall be interpreted in the following way: Continuous monitoring: (i) (ii) (iii) Composite Sampling: (i) (ii) Discrete Sampling (i) No flow value shall exceed the specified limit. No ph value shall deviate from the specified range. No temperature value shall exceed the limit value. No ph value shall deviate from the specified range. For parameters other than ph and flow, eight out of ten consecutive composite results, based on flow proportional composite sampling, shall not exceed the emission limit value. No individual result similarly calculated shall exceed 1.2 times the emission limit value. For parameters other than ph and temperature, no grab sample value shall exceed 1.2 times the emission limit value Where the ability to measure a parameter is affected by mixing before emission, then, with agreement from the Agency, the parameter may be assessed before mixing takes place. Page 11 of 34 EPA Export :00:59:07

55 Environmental Protection Agency Licence Reg. N o Noise Noise from the activity shall not give rise to sound pressure levels (Leq,30 mins) measured at specified noise sensitive locations which exceed the limit value(s). Reason: To clarify the interpretation of limit values fixed under the licence. Condition 5. Emissions Reason: 5.1 No specified emission from the installation shall exceed the emission limit values set out in Schedule B: Emission Limits of this licence, subject to Condition 4. There shall be no other emissions of environmental significance. 5.2 The licensee shall ensure that the activities shall be carried out in a manner such that emissions including odours do not result in significant impairment of, and/or significant interference with amenities or the environment beyond the installation boundary. 5.3 No substance shall be discharged in a manner, or at a concentration which, following initial dilution, causes tainting of fish or shellfish. 5.4 The licensee shall ensure that vermin, birds, flies, mud, dust, litter and odours do not give rise to nuisance at the installation or in the immediate area of the installation. Any method used by the licensee to control any such nuisance shall not cause environmental pollution. To provide for the protection of the environment by way of control and limitation of emissions. Condition 6. Control and Monitoring 6.1 The licensee shall carry out such sampling, analyses, measurements, examinations, maintenance and calibrations as set out below and as in accordance with Schedule C: Control & Monitoring of this licence: Analysis shall be undertaken by competent staff in accordance with documented operating procedures Such procedures shall be assessed for their suitability for the test matrix and performance characteristics determined Such procedures shall be subject to a programme of Analytical Quality Control using control standards with evaluation of test responses Where analysis is sub-contracted it shall be to a competent laboratory. 6.2 All automatic monitors and samplers shall be functioning at all times (except during maintenance and calibration) when the activity is being carried on unless alternative sampling or monitoring has been agreed in writing by the Agency for a limited period. In the event of the malfunction of any continuous monitor, the licensee shall contact the Agency as soon as practicable, and alternative sampling and monitoring facilities shall be put in place. Agreement for the use of alternative equipment, other than in emergency situations, shall be obtained from the Agency. Page 12 of 34 EPA Export :00:59:07

56 Environmental Protection Agency Licence Reg. N o Monitoring and analysis equipment shall be operated and maintained as necessary so that monitoring accurately reflects the emission or discharge. 6.4 All treatment/abatement and emission control equipment shall be calibrated and maintained, in accordance with the instructions issued by the manufacturer/supplier or installer. 6.5 The frequency, methods and scope of monitoring, sampling and analyses, as set out in this licence, may be amended with the agreement of the Agency following evaluation of test results. 6.6 The licensee shall prepare and maintain a programme, to the satisfaction of the Agency, for the identification and reduction of fugitive emissions. This programme shall be included in the Environmental Management Programme. 6.7 The integrity and water tightness of all underground pipes and tanks and their resistance to penetration by water or other materials carried or stored therein shall be tested and demonstrated by the licensee. This testing shall be carried out by the licensee at least once every three years and reported to the Agency on each occasion. A written record of all integrity tests and any maintenance or remedial work arising from them shall be maintained by the licensee. 6.8 All flanges and valves on over-ground pipes used to transport materials other than uncontaminated water, where no permanent provision for containment of leaks is provided, shall be subject to weekly visual inspection or otherwise monitored for leaks to the satisfaction of the Agency. All such inspections shall be recorded in a log which shall be available for inspection by Agency. 6.9 Emission to atmosphere In the case of peat or peat and biomass combustion only: Within three months of the date of grant of this licence, the licensee shall establish procedures relating to the malfunction or breakdown of abatement equipment. In the event of breakdown, operations shall be reduced or closed down if a return to normal operation is not achieved within 24 hours. In no circumstances shall the cumulative duration of unabated operation in any twelve-month period exceed 120 hours Sampling and analysis of all pollutants, including dioxins and furans, as well as reference measurement methods to calibrate automated measurement systems shall be carried out in accordance with CEN standards. If CEN standards are not available, ISO, national or international standards which will ensure the provision of data of an equivalent scientific value shall apply The appropriate installation and functioning of the automated monitoring equipment for emissions to air shall be subject to an annual surveillance test. Calibration shall be carried out by means of parallel measurements with reference methods at least once every three years Process Effluent The drainage system and bunds shall be inspected weekly, desludged as necessary and properly maintained at all times. All sludge and drainage from these operations shall be collected for safe disposal Compliance toxicity monitoring on the two most sensitive species agreed or specified by the Agency shall be repeated as required by Agency. The licensee shall submit a report to the Agency within six weeks of completion of the testing The licensee shall characterise the Total Dissolved Solids content of the effluent discharge within six months of the date of grant of licence. This characterisation shall be repeated at intervals thereafter as required by the Agency. Page 13 of 34 EPA Export :00:59:07

57 Environmental Protection Agency Licence Reg. N o Storm water A visual examination of the storm water discharge shall be carried out daily. A log of such inspections shall be maintained The drainage system and bunds shall be inspected weekly, desludged as necessary and properly maintained at all times. All sludge and drainage from these operations shall be collected for safe disposal In the event that any analyses or observations made on the quality or appearance of surface water run-off should indicate that contamination has taken place, the licensee shall: (i) (ii) (iii) 6.12 Ground Water 6.13 Noise Carry out an immediate investigation to identify and isolate the source of the contamination; Put in place measures to prevent further contamination and to minimise the effects of any contamination on the environment; and Notify the Agency as soon as is practicable The licensee shall maintain groundwater monitoring wells at locations GW1 and GW2 as outlined in the licence application All groundwater monitoring points and the Puraflo biological system shall be included in the site s maintenance programme No effluent other than sanitary shall be permitted to discharge to the Puraflo system The licensee shall carry out a noise survey of the site operations annually. The survey programme shall be undertaken in accordance with the methodology specified in the Environmental Noise Survey Guidance Document as published by the Agency Deliveries of MBM by road shall take place only during daytime hours unless otherwise agreed with the Agency Pollution Emission Register (PER) The licensee shall prepare and maintain a PER for the site. The substances to be included in the PER shall be agreed by the Agency each year by reference to the list specified in the Agency s AER Guidance Note. The PER shall be prepared in accordance with any relevant guidelines issued by the Agency and shall be submitted as part of the AER Co-incineration Test Programme The licensee shall prepare, to the satisfaction of the Agency, a test programme for the co-incineration of waste. This programme shall be submitted to the Agency, prior to implementation This test programme, following agreement with the Agency, shall be implemented and a report on its implementation shall be submitted to the Agency on completion The criteria for the operation of the abatement equipment as determined by the test programme shall be incorporated into the standard operating procedures Co-incineration of waste shall not be permitted (outside of the agreed test programme) until the Agency has indicated in writing its satisfactory acceptance of the results of the test programme. Page 14 of 34 EPA Export :00:59:07

58 Environmental Protection Agency Licence Reg. N o 654 Reason: 6.16 The co-incineration test programme shall as a minimum: Verify the residence time, minimum temperature and oxygen content of the exhaust gas which will be achieved during normal operation and under the most unfavourable operating conditions anticipated Establish all criteria for operation, control and management of the abatement equipment to ensure compliance with the emission limit values specified in this licence Establish criteria for the control of waste input including the maximum mass flow and the maximum calorific value Assess the performance of any monitors on the abatement system and establish a maintenance and calibration programme for each monitor Confirm that all measurement equipment or devices (including thermocouples) used for the purpose of establishing compliance with this licence has been subjected, in situ, to its normal operating temperature to prove its operation under such conditions The plant shall have and operate an automatic system to prevent waste feed: At start-up, until the temperature of 850 o C has been reached; Whenever the temperature of 850 o C is not maintained; Whenever the continuous measurements required show that any emission limit value is exceeded due to disturbances or failures of the purification devices; and Whenever stoppages, disturbances, or failure of the purification devices or the measurement devices may result in the exceedance of the emission limit values. To provide for the protection of the environment by way of treatment and monitoring of emissions. Condition 7. Resource Use and Energy Efficiency 7.1 The licensee shall carry out an audit of the energy efficiency of the site within one year of the date of grant of this licence. The audit shall be carried out in accordance with the guidance published by the Agency; Guidance Note on Energy Efficiency Auditing. The energy efficiency audit shall be repeated at intervals as required by the Agency. 7.2 The audit shall identify all opportunities for energy use reduction and efficiency and the recommendations of the audit will be incorporated into the Schedule of Environmental Objectives and Targets under Condition above. 7.3 The licensee shall identify opportunities for reduction in the quantity of water used on site including recycling and reuse initiatives, wherever possible. Reductions in water usage shall be incorporated into Schedule of Environmental Objectives and Targets. 7.4 The licensee shall undertake an assessment of the efficiency of use of raw materials in all processes, having particular regard to the reduction in waste generated. The assessment should take account of best international practice for this type of activity. Where improvements are identified, these shall be incorporated into the Schedule of Environmental Objectives and Targets. Reason: To provide for the efficient use of resources and energy in all site operations. Page 15 of 34 EPA Export :00:59:07

59 Environmental Protection Agency Licence Reg. N o 654 Condition 8. Materials Handling 8.1 Disposal or recovery of waste shall only take place in accordance with the conditions of this licence and in accordance with the appropriate National and European legislation and protocols. 8.2 Waste sent off-site for recovery or disposal shall be transported only by an authorised waste contractor. The waste shall be transported only from the site of the activity to the site of recovery/disposal in a manner which will not adversely affect the environment and in accordance with the appropriate National and European legislation and protocols. 8.3 No waste classified as green list waste in accordance with the EU Transfrontier Shipment of Waste Regulations (Council Regulation EEC No.259/1993, as amended) shall be consigned for recovery without the agreement of the Agency. 8.4 Waste for disposal/recovery off-site shall be analysed in accordance with Schedule C: Control & Monitoring of this licence. 8.5 Unless approved in writing by the Agency the licensee is prohibited from mixing a hazardous waste of one category with a hazardous waste of another category or with any other non-hazardous waste. 8.6 Waste Acceptance/Removal and Characterisation Procedures Wastes shall be accepted at/removed from the facility only from/by an authorised or exempted carrier under National or European legislation or protocols. Copies of the waste collection permits shall be maintained at the facility The quantity of waste to be accepted at the facility on a daily basis shall not exceed the appropriate storage capacity available for such waste Waste shall only be accepted at the installation from known suppliers or new suppliers subject to initial waste profiling, and analysis and characterisation off-site Prior to commencement of waste acceptance at the facility, the licensee shall establish and maintain detailed written procedures for the acceptance and handling of wastes. These procedures shall include the following: (i) (ii) (iii) (iv) (v) Waste inspection and sampling at the point of entry to the facility. Waste characterisation and waste profiling from known customers or new customers accepted at the facility. Methods for the characterisation of waste. Waste quantification, documentation and reception. The manner in which the waste will be handled. This shall include silo management procedures (e.g. periodic emptying and cleaning). 8.7 The licensee shall submit proposals for the approval of the Agency for suitable containment at the waste reception area. These proposals shall be implemented prior to the acceptance of waste for co-incineration. Page 16 of 34 EPA Export :00:59:07

60 Environmental Protection Agency Licence Reg. N o Any waste deemed unsuitable for processing at the facility or in contravention of this licence shall be immediately separated and removed from the facility at the earliest possible time. Temporary storage of such wastes shall be in a designated Waste Quarantine Area. Waste shall be stored under appropriate conditions in the quarantine area to avoid putrefaction, odour generation, the attraction of vermin and any other nuisance or objectionable condition. 8.9 Wastes disposed of by on-site co-incineration: Only waste which complies with Schedule A.1 Waste Acceptance of this licence shall be co-incinerated on site These wastes shall only be introduced to the boiler when the appropriate operating conditions, which as a minimum shall meet those set out in Schedule B: Emissions Limits, have been achieved No Category 1 MBM shall be accepted at the installation The licensee shall ensure that waste from the plant, prior to being sent for disposal or recovery off-site, is: (i) Segregated, classified, packaged and labelled in accordance with National, European and any other standards which are in force in relation to such labelling; (ii) (iii) Stored in designated areas, protected as may be appropriate, against spillage and leachate run-off; Stockpiled in such a manner as to minimise dust generation Prior to the commencement of co-incineration the licensee shall submit details of the classification and ultimate disposal/recovery destination facility for the ash and its appropriateness to accept the ash, to include permit details and issuing authority. Coincineration of waste shall not be permitted until the Agency has indicated in writing its acceptance of the proposed facility for the disposal of ash Dry residues in the form of dust and dry residues from the treatment of combustion gases, shall be stored in closed containers and transported in such a way as to prevent dispersal in the environment Upon commencement of co-incineration, fly ash and bottom ash shall be stored separately, unless otherwise agreed with the Agency The licensee shall submit a proposal to the Agency for alternative recovery options for settlement pond sludge within six months of the date of grant of this licence. Reason: To provide for the appropriate handling of materials and the protection of the environment. Condition 9. Accident Prevention and Emergency Response 9.1 The licensee shall, within six months of date of grant of this licence, ensure that a documented Accident Prevention Policy is in place which will address the hazards on-site, particularly in relation to the prevention of accidents with a possible impact on the environment. This procedure shall be reviewed annually and updated as necessary. Page 17 of 34 EPA Export :00:59:07

61 Environmental Protection Agency Licence Reg. N o The licensee shall, within six months of date of grant of this licence, ensure that a documented Emergency Response Procedure is in place, which shall address any emergency situation which may originate on-site. This Procedure shall include provision for minimising the effects of any emergency on the environment. This procedure shall be reviewed annually and updated as necessary. 9.3 In the event of an incident the licensee shall immediately:- (i) (ii) (iii) (iv) (v) (vi) isolate the source of any such emission; carry out an immediate investigation to identify the nature, source and cause of the incident and any emission arising therefrom; evaluate the environmental pollution, if any, caused by the incident; identify and execute measures to minimise the emissions/malfunction and the effects thereof; identify the date, time and place of the incident: provide a proposal to the Agency for its agreement within one month of the incident occurring or as otherwise agreed with the Agency to:- identify and put in place measures to avoid reoccurrence of the incident; and identify and put in place any other appropriate remedial action. Reason: To provide for the protection of the environment. Condition 10. Decommissioning & Residuals Management 10.1 Following termination, or planned cessation for a period greater than six months, of use or involvement of all or part of the site in the licensed activity, the licensee shall, to the satisfaction of the Agency, decommission, render safe or remove for disposal/recovery, any soil, subsoils, buildings, plant or equipment, or any waste, materials or substances or other matter contained therein or thereon, that may result in environmental pollution Residuals Management Plan: The licensee shall prepare, to the satisfaction of the Agency, a fully detailed and costed plan for the decommissioning or closure of the site or part thereof. This plan shall be submitted to the Agency for agreement within six months of the date of grant of this licence The plan shall be reviewed annually and proposed amendments thereto notified to the Agency for agreement as part of the AER. No amendments may be implemented without the agreement of the Agency The Residuals Management Plan shall include as a minimum, the following: A scope statement for the plan The criteria which define the successful decommissioning of the activity or part thereof, which ensures minimum impact on the environment A programme to achieve the stated criteria Where relevant, a test programme to demonstrate the successful implementation of the decommissioning plan Details of costings for the plan and a statement as to how these costs will be underwritten. Page 18 of 34 EPA Export :00:59:07

62 Environmental Protection Agency Licence Reg. N o A final validation report to include a certificate of completion for the residuals management plan, for all or part of the site as necessary, shall be submitted to the Agency within three months of execution of the plan. The licensee shall carry out such tests, investigations or submit certification, as requested by the Agency, to confirm that there is no continuing risk to the environment. Reason: To make provision for the proper closure of the activity ensuring protection of the environment. Condition 11. Notifications, Records and Reports 11.1 Notwithstanding the requirements of Condition , the licensee shall notify the Agency, in writing, one month prior to the commencement of co-incineration, of the intended date of commencement of the activity The licensee shall notify the Agency by both telephone and either facsimile or electronic mail, if available, to the Agency s Office of Environmental Enforcement, South East Region, PO Box 3000, Johnstown Castle Estate, County Wexford, or to such other Agency office as may be specified by the Agency, as soon as practicable after the occurrence of any of the following: Any release of environmental significance to atmosphere from any potential emission point including bypasses Any emission which does not comply with the requirements of this licence Any malfunction or breakdown of key control equipment or monitoring equipment set out in Schedule C: Control & Monitoring which is likely to lead to loss of control of the abatement system Any incident with the potential for environmental contamination of surface water or groundwater, or posing an environmental threat to air or land, or requiring an emergency response by the Local Authority. The licensee shall include as part of the notification, date and time of the incident, summary details of the occurrence, and where available, the steps taken to minimise any emissions In the case of any incident which relates to discharges to water, the licensee shall notify the Local Authority and the Southern Regional Fisheries Board as soon as practicable after such an incident The licensee shall make a record of any incident. This record shall include details of the nature, extent, and impact of, and circumstances giving rise to, the incident. The record shall include all corrective actions taken to; manage the incident, minimise wastes generated and the effect on the environment, and avoid recurrence. The licensee shall as soon as practicable following incident notification, submit to the Agency the incident record The licensee shall record all complaints of an environmental nature related to the operation of the activity. Each such record shall give details of the date and time of the complaint, the name of the complainant and give details of the nature of the complaint. A record shall also be kept of the response made in the case of each complaint The licensee shall maintain a log, which shall be open to inspection by authorised persons of the Agency at all times, of all scheduled and unscheduled start-ups and shutdowns. Page 19 of 34 EPA Export :00:59:07

63 Environmental Protection Agency Licence Reg. N o The licensee shall record all sampling, analyses, measurements, examinations, calibrations and maintenance carried out in accordance with the requirements of this licence and all other such monitoring which relates to the environmental performance of the installation All measurement results shall be recorded, processed and presented in an appropriate fashion in order to enable the Agency to verify compliance with the permitted operating conditions and emission limit values The licensee shall as a minimum keep the following documents at the site:- (i) (ii) (iii) (iv) (v) the licences relating to the installation; the current EMS for the installation; the previous year s AER for the installation; records of all sampling, analyses, measurements, examinations, calibrations and maintenance carried out in accordance with the requirements of this licence and all other such monitoring which relates to the environmental performance of the installation; an up-to-date site drawing/plan showing the locations of key process and environmental infrastructure, including monitoring locations and emission points; (vi) relevant correspondence with the Agency; and (vii) up to date site drawings/plans showing the location of key process and environmental infrastructure, including monitoring locations and emission points; and this documentation shall be available to the Agency for inspection at all reasonable times The licensee shall submit to the Agency, by the 31 st March of each year, an AER covering the previous calendar year. This report, which shall be to the satisfaction of the Agency, shall include as a minimum the information specified in Schedule D: Annual Environmental Report and shall be prepared in accordance with any relevant guidelines issued by the Agency A full record, which shall be open to inspection by authorised persons of the Agency at all times, shall be kept by the licensee on matters relating to the waste management operations and practices at this site. This record shall be maintained on a monthly basis and shall as a minimum contain details of the following: (i) (ii) (iii) (iv) (v) (vi) The tonnages and EWC Code for the waste materials sent off-site for disposal/recovery. The names of the agent and carrier of the waste, and their waste collection permit details, if required (to include issuing authority and vehicle registration number). Details of the ultimate disposal/recovery destination facility for the waste and its appropriateness to accept the consigned waste stream, to include its permit/licence details and issuing authority, if required. Written confirmation of the acceptance and disposal/recovery of any hazardous waste consignments sent off-site. Details of all wastes consigned abroad for Recovery and classified as Green in accordance with the EU Transfrontier Shipment of Waste Regulations (Council Regulation EEC No. 259/1993, as amended). The rationale for the classification must form part of the record. Details of any rejected consignments. (vii) Details of any approved waste mixing. Page 20 of 34 EPA Export :00:59:07

64 Environmental Protection Agency Licence Reg. N o 654 Reason: (viii) The results of any waste analyses required under Schedule C: Control & Monitoring. (ix) The tonnages and EWC Code for the waste materials recovered/disposed onsite A full record, which shall be open to inspection by authorised persons of the Agency at all times, shall be kept by the licensee on matters relating to the receipt of waste for co-incineration and to co-incineration operations and practices on site. This record shall be maintained on a monthly basis and shall as a minimum contain details of the following: (i) (ii) (iii) (iv) (v) (vi) The date of receipt of each consignment of waste; The description of the waste for each consignment, with reference to the EWC codes, including the category of animal by-product where relevant; The tonnage of the waste for each consignment; The name and address of the carrier; The results of any analyses required under Schedule A.1 Waste Acceptance; The quantity incinerated. This record shall be retained for a period of at least two years The written records of off-site waste profiling and characterisation shall be retained by the licensee for all active suppliers and for a two-year period following termination of licensee/supplier agreements. To provide for the collection and reporting of adequate information on the activity. Condition 12. Financial Charges and Provisions 12.1 Agency Charges The licensee shall pay to the Agency an annual contribution of 19,228, or such sum as the Agency from time to time determines, having regard to variations in the extent of reporting, auditing, inspection, sampling and analysis or other functions carried out by the Agency, towards the cost of monitoring the activity as the Agency considers necessary for the performance of its functions under the Environmental Protection Agency Acts, 1992 and The first payment shall be a pro-rata amount for the period from the date of this licence to the 31st day of December, and shall be paid to the Agency within one month from the date of the licence. In subsequent years the licensee shall pay to the Agency such revised annual contribution as the Agency shall from time to time consider necessary to enable performance by the Agency of its relevant functions under the Environmental Protection Agency Acts, 1992 and 2003, and all such payments shall be made within one month of the date upon which demanded by the Agency In the event that the frequency or extent of monitoring or other functions carried out by the Agency needs to be increased the licensee shall contribute such sums as determined by the Agency to defraying its costs in regard to items not covered by the said annual contribution. Page 21 of 34 EPA Export :00:59:08

65 Environmental Protection Agency Licence Reg. N o Environmental Liabilities The licensee shall as part of the AER provide an annual statement as to the measures taken or adopted at the site in relation to the prevention of environmental damage and the measures in place in relation to the underwriting of costs for remedial actions following anticipated events (including closure) or accidents/incidents, as may be associated with the carrying on of the activity. Reason: To provide for adequate financing for monitoring and financial provisions for measures to protect the environment. Page 22 of 34 EPA Export :00:59:08

66 Environmental Protection Agency Licence Reg. N o 654 SCHEDULE A: Limitations A.1 Waste Acceptance Table A.1.1 Waste for disposal by on-site co-incineration EWC Code Waste Description Quantity Category 3 Meat and Bone Meal Max value shall not exceed 10% of total fuel input based on calorific value (Maximum 100,000 tonnes) Table A.1.2 Waste acceptance criteria Waste Description EWC Code Parameter Range MBM Moisture content Calorific value Oil content Particle size 2-8% MJ/kg 10-16% 2-20 mm Page 23 of 34 EPA Export :00:59:08

67 Environmental Protection Agency Licence Reg. N o 654 SCHEDULE B: Emission Limits B.1 Emissions to Air Table B.1.1 Emission Limit Values for combustion of peat or peat and biomass Emission Point Reference No.: A1-1 Location: Boiler House Volume to be emitted: Maximum in any one day: 11,640,000 m 3 Maximum rate per hour: 485,000 m 3 Minimum discharge height: 70 m above ground Parameter Emission Limit Value Oxides of sulphur 600 mg/m 3 Nitrogen oxides (as NO 2 ) 325 mg/m 3 Dust 50 mg/m 3 Page 24 of 34 EPA Export :00:59:08

68 Environmental Protection Agency Licence Reg. N o 654 Table B.1.2 Emission Limit Values for co-incineration Emission Point Reference No.: A1-1 Location: Boiler house Volume to be emitted: Maximum in any one day: 11,640,000 m 3 Maximum rate per hour: 485,000 m 3 Minimum Discharge Height: Operating Temperature: Residence Time: Maximum Co-incineration Capacity: Maximum Thermal Input: 70 m 850 o C minimum 2 seconds minimum 15 tonnes/hr max at any one time 300 MW Parameter Emission Limit Value 24 hour mean (mg/m 3 ) Oxides of sulphur (as SO 2 ) 191 Nitrogen oxides (as NO 2 ) 300 Dust 29 Parameter Dioxins (TEQ - See Toxic Equivalents at end of Schedule B.1) The sum of cadmium (as Cd) and thallium (as Tl) and their compounds. Emission Limit Value (6-8 hour samples) 0.1 ng/ m hour samples 0.05 mg/m 3 Mercury (as Hg) and its compounds hour samples 0.05 mg/m 3 The sum of antimony (as Sb), arsenic (as As), lead (as Pb), chromium (as Cr), cobalt (as Co), copper (as Cu), manganese (as Mn), nickel (as Ni), vanadium (as V) and tin (as Sn) and their compounds hour samples 0.5 mg/m 3 Page 25 of 34 EPA Export :00:59:08

69 Environmental Protection Agency Licence Reg. N o 654 Dioxin Toxic Equivalents For the determination of the TEQ value stated as an emission limit the mass concentrations of the following dioxins and furans have to be multiplied with their equivalence factors before summing. 2,3,7,8-Tetrachlorodibenzodioxin (TCDD) 1 1,2,3,7,8-Pentachlorodibenzodioxin 0.5 1,2,3,4,7,8-Hexachlorodibenzodioxin (HxCDD) 0.1 1,2,3,7,8,9-Hexachlorodibenzodioxin (HxCDD) 0.1 1,2,3,6,7,8-Hexachlorodibenzodioxin (HxCDD) 0.1 1,2,3,4,6,7,8-Heptachlorodibenzodioxin (HpCDD) 0.01 Octachlorodibenzodioxin (OCDD) ,3,7,8-Tetrachlorodibenzofuran (TCDF) 0.1 2,3,4,7,8-Pentachlorodibenzofuran (PeCDF) 0.5 1,2,3,7,8-Pentachlorodibenzofuran (PeCDF) ,2,3,4,7,8-Hexachlorodibenzofuran (HxCDF) 0.1 1,2,3,7,8,9-Hexachlorodibenzofuran (HxCDF) 0.1 1,2,3,6,7,8-Hexachlorodibenzofuran (HxCDF) 0.1 2,3,4,6,7,8-Hexachlorodibenzofuran (HxCDF) 0.1 1,2,3,4,6,7,8-Heptachlorodibenzofuran (HpCDF) ,2,3,4,7,8,9-Heptachlorodibenzofuran (HpCDF) 0.01 Octachlorodibenzofuran (OCDF) Equivalence Factor Page 26 of 34 EPA Export :00:59:08

70 Environmental Protection Agency Licence Reg. N o 654 B.2 Emissions to Water Emission Point Reference No.: W-1 Name of Receiving Waters: Location: River Figile via Settlement Pond Before Settlement Pond Volume to be emitted: Maximum in any one day: 1,500 m 3 Maximum rate per hour: 65 m 3 Parameter Temperature Emission Limit Value 25 C (max.) ph 6-9 Toxicity mg/l 10 TU BOD kg/day Suspended Solids Total Dissolved Solids Ammonia (as N) 5 4 Total Phosphorus (as P) Oils, Fats & Greases Mineral Oils Residual Chlorine B.3 Emission to Sewer There are no process effluent emissions to sewer. B.4. Noise Emissions Daytime db(a) L Aeq (30 minutes) Night-time db(a) L Aeq (30 minutes) Note 1: 55 Note 1 45 Note 1 There shall be no clearly audible tonal component or impulsive component in the noise emission from the activity at any noise sensitive location. Page 27 of 34 EPA Export :00:59:08

71 Environmental Protection Agency Licence Reg. N o 654 B.5 Emissions to Ground Puraflo System Emission Point Reference No.: GE-1 Parameter Emission Limit Value (mg/l) BOD 25 Suspended Solids 25 Page 28 of 34 EPA Export :00:59:08

72 Environmental Protection Agency Licence Reg. N o 654 SCHEDULE C: Control & Monitoring C.1.1 Control of Emissions to Air Emission Point Reference No.: A1-1 Description of Treatment: Boiler exhaust emissions abatement Control Parameter Monitoring Key Equipment Note 1 Combustion chamber temperature Oxygen concentration of exhaust gas Continuous Continuous Temperature probe Oxygen analyser Pressure of exhaust gas Continuous Pressure transmitter Temperature of exhaust gas Continuous Temperature probe Water vapour content of Continuous Moisture analyser exhaust gas Note 2 Flow Continuous Flow meter Nitrogen oxides Continuous Selective non-catalytic reduction Note 3 Sulphur dioxide Continuous Limestone injection system Limestone injection system with activation reactor Note 3 Dust Continuous Electrostatic precipitator Note 1: The licensee shall maintain appropriate access to standby and/or spares to ensure the operation of the abatement Note 2: system. Not required if sampled exhaust gas is dried before the emissions are analysed. Note 3: To be installed prior to commencement of co-incineration subject to Conditions 6.15 and C.1.2 Monitoring of Emissions to Air Emission Point Reference No.: A1-1 Parameter Monitoring Frequency Analysis Method/Technique Sulphur dioxide Continuous Flue gas analyser Nitrogen oxides Continuous Flue gas analyser Dust Continuous Isokinetic/gravimetric Dioxins and furans Note 1 Heavy metals Note 1 Quarterly for first twelve months of co-incineration, biannual thereafter Quarterly for first twelve months of co-incineration, biannual thereafter CEN method (EN 1948, Parts 1,2,3) To be agreed with the Agency PM and PM Annually Standard methods Note 1: Following commencement of co-incineration. Page 29 of 34 EPA Export :00:59:08

73 Environmental Protection Agency Licence Reg. N o 654 C.2.1 Control of Emissions to Water Emission Point Reference No.: W-1 Description of Treatment: Waste water treatment Control Parameter Monitoring Key Equipment Note 1 Effluent (ph) Neutralisation Neutralisation tank ph Dosing Pump Note 1: The licensee shall maintain appropriate access to standby and/or spares to ensure the operation of the abatement system. C.2.2 Monitoring of Emissions to Water Emission Point Reference No.: W-1 Parameter Monitoring Frequency Analysis Method/Technique Flow Continuous On-line flow meter with recorder Temperature Continuous On-line temperature probe with recorder ph Continuous ph electrode/meter and recorder Biochemical Oxygen Demand Weekly Note 1 Standard Method Suspended Solids Weekly Note 1 Standard Method Total Dissolved Solids Weekly Note 1 Standard Method Ammonia (as N) Weekly Note 1 Standard Method Total Phosphorus (as P) Weekly Note 1 Standard Method Ortho-phosphate (as P) Weekly Note 1 Standard Method Residual Chlorine Weekly Standard Method Mineral Oils Monthly GC-MS Petroleum Range Organics Monthly GC-MS Diesel Range Organics Monthly GC-MS Oils, fats & greases Monthly Standard Method Toxicity Note 2 As may be required To be agreed by the Agency Note 1: Note 2: Samples shall be collected on a 24 hour flow proportional composite sampling basis. The number of toxic units (Tu) = 100/x hour EC/LC 50 in percentage vol/vol so that higher Tu values reflect greater levels of toxicity. For test regimes where species death is not easily detected, immobilisation is considered equivalent to death. Page 30 of 34 EPA Export :00:59:08

74 Environmental Protection Agency Licence Reg. N o 654 C.2.3 Monitoring of Storm Water Emission Emission Point Reference No.: SW-1 Parameter Monitoring Frequency Analysis Method/Technique ph Continuous ph electrode/meter Flow Continuous Flow meter Conductivity Continuous Standard Method Biochemical Oxygen Demand Monthly Note 1 Standard Method Suspended Solids Monthly Note 1 Standard Method Total Dissolved Solids Monthly Note 1 Standard Method Ammonia Monthly Note 1 Standard Method Ortho-phosphate (as P) Monthly Note 1 Standard Method Mineral Oils Monthly GC-MS Petroleum Range Organics Monthly GC-MS Diesel Range Organics Monthly GC-MS Oils, fats and greases Monthly Standard Method Visual Inspection Weekly Sample and examine for colour and odour Note 1: C.3.1 Samples shall be collected on a 24 hour flow proportional composite sampling basis. Control of Emissions to Sewer There are no process effluent emissions to sewer. C.3.2 Monitoring of Emissions to Sewer There are no process effluent emissions to sewer. Page 31 of 34 EPA Export :00:59:09

75 Environmental Protection Agency Licence Reg. N o 654 C.4 Waste Monitoring Waste Class Frequency Parameter Method Ash Biannual TOC, metals (Ba, Cd, Mo, Sb, Se, Zn, Tl, Hg, Pb, Cr, Cu, Mn, Ni, As, Co, V, Sn) and their compounds, chloride, fluoride, sulphate, dioxins/furans and dioxin-like PCBs. MBM Annual sample from each supplier Moisture content Oil content Particle size Calorific value To be agreed with the Agency To be agreed with the Agency C.5 Noise Monitoring There is no additional noise monitoring required in this schedule. C.6 Ambient Monitoring C.6.1 River Monitoring Location: River Figile upstream and downstream of site discharge Parameter Monitoring Frequency Analysis Method/Technique ph Biannual Standard Method Temperature Biannual Standard Method Conductivity Biannual Standard Method Dissolved Oxygen Biannual Standard Method BOD Biannual Standard Method Suspended Solids Biannual Standard Method Total Dissolved Solids Biannual Standard Method Total Oxidised Nitrogen (as N) Biannual Standard Method Ammonia (as N) Biannual Standard Method Ortho-phosphate (as P) Biannual Standard Method Page 32 of 34 EPA Export :00:59:09

76 Environmental Protection Agency Licence Reg. N o 654 C.6.2 Groundwater Monitoring Location: GW1 and GW2 Parameter Monitoring Frequency Analysis Method/Technique ph Biannually ph electrode/meter Hardness Biannually Standard Method Organohalogens Note 1 Biannually GC-MS Note 1: Screening for priority pollutant list substances (such as US EPA volatile and/or semi-volatile compounds). C.7 Puraflo System Monitoring Location: GE1 Parameter Monitoring Frequency Analysis Method/Technique BOD Biannually Standard Method Suspended Solids Biannually Standard Method Ammonia Biannually Standard Method Page 33 of 34 EPA Export :00:59:09

77 Environmental Protection Agency Licence Reg. N o 654 SCHEDULE D: Annual Environmental Report Annual Environmental Report Content Note 1 Emissions from the installation. Waste management record. Resource consumption summary. Complaints summary. Schedule of Environmental Objectives and Targets. Environmental management programme report for previous year. Environmental management programme proposal for current year. Pollution emission register report for previous year. Pollution emission register proposal for current year. Noise monitoring report summary. Ambient monitoring summary. Account of co-incineration process, including energy input (NCV) breakdown per fuel type. Tank and pipeline testing and inspection report. Bund Integrity report. Effluent Total Dissolved Solids Characterisation report. Reported incidents summary. Energy efficiency audit report summary. Report on the assessment of the efficiency of use of raw materials in processes and the reduction in waste generated. Report on progress made and proposals being developed to minimise water demand. Reports on financial provision made under this licence, management and staffing structure of the installation, and a programme for public information. Statement of measures in relation to prevention of environmental damage and remedial actions (Environmental Liabilities) Any other items specified by the Agency. Note 1: Content may be revised subject to the agreement of the Agency. th Sealed by the seal of the Agency on this the 20 day of January PRESENT when the seal of the Agency was affixed hereto: Padraic Larkin Director/Authorised Person Page 34 of 34 EPA Export :00:59:09

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87 SITE NOTICE APPLICATION TO THE ENVIRONMENTAL PROTECTION AGENCY FOR A REVIEW OF INTEGRATED POLLUTION PREVENTION AND CONTROL LICENCE Bord na Móna plc, Main Street, Newbridge, Co. Kildare intends to apply to the Environmental Protection Agency for a review of an Integrated Pollution Prevention and Control Licence in respect of peaking electricity generation plants at Edenderry Power Ltd., Ballykilleen, Edenderry, Co. Offaly. The activity, which is an activity under Class 2.1 of the First Schedule of the Environmental Protection Agency Act, 1992 as amended, will consist of mobile Electricity Generating Plant having an approximate electrical rating up to 104 MW. A copy of the application for a review of an Integrated Pollution Prevention and Control licence may be inspected at or obtained from the headquarters of the Agency at P.O. Box 3000, Johnstown Castle Estate, Co. Wexford as soon as is practicable after the receipt by the Agency of the application for the licence. Signed Tom Egan Plant Manager Date 23/04/08 EPA Export :00:59:09

88 Our Ref: EdenIPPCrevCC-01 Planning & Development Section Offaly County Council, Árus an Chontae Charleville Road, Tullamore Co. Offaly 21 st April 2008 Bord na Móna plc Application for a Review of the Integrated Pollution Prevention and Control Licence for Peaking Power Plant at Edenderry Power Ltd., Ballykilleen, Edenderry, Co. Offaly Dear Sirs, Environmental Consultancy Services (Bord na Móna Environmental Ltd.) on behalf of Bord na Móna plc, Main street, Newbridge, Co. Kildare wishes to notify you of its intention to apply to the Environmental Protection Agency (EPA) for a review of the Integrated Pollution Prevention and Control Licence in respect of the peaking plant to be located within the Edenderry Power Ltd, lands at Ballykilleen, Edenderry, Co. Offaly located at National Grid Reference E, N. The activity, which is an activity under Class 2.1 of the First Schedule of the Environmental Protection Agency Act, 1992 as amended, will consist of peaking plant with a total electricity capacity output of approximately 104MW. The proposed infrastructure received planning permission (with conditions) on the 12/02/2008 (planning reference: 07/1691). A copy of the application for a review of an Integrated Pollution Prevention and Control licence may be inspected at or obtained from the headquarters of the Agency at P.O. Box 3000, Johnstown Castle Estate, Co. Wexford as soon as is practicable after the receipt by the Agency of the application for the licence. Yours faithfully, Sean Creedon Senior Environmental Consultant Environmental Consultancy Services Bord na Móna Environmental Ltd. MAIN STREET, NEWBRIDGE, CO KILDARE, IRELAND TELEPHONE: , FAX: REGISTERED OFFICE: MAIN ST., NEWBRIDGE, CO KILDARE; REGISTERED NO: EPA Export :00:59:09

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91 Edenderry Power Ltd. IPPC Review Attachment D.1 Development history of the site Bord na Móna plc owns and runs a electricity generating facility at Ballykilleen, Clonbullogue, Co. Offaly. The facility is located adjacent to Kilcumber Bridge on the R401, 3km north of Clonbolluge and 8km south of Edenderry. The location of the facility is outlined in Drawing No. EdenP rev-01. The Edenderry Power Limited (EPL) plant was built on a green field site in 1999 and therefore it was possible to incorporate environmental considerations and the mitigation of environmental impacts into the design of the plant. The plant directly employs 45 people as well as approximately 250 indirectly in supplies and services provided to the plant. The wages, supplies and services plough approximately 30 million euro back into the local economy annually. The plant utilises state of the art bubbling fluidised bed peat combustion. It consists of a highly efficient (91%) plant that has an electrical output of 118MW and burns approximately 1.0 to 1.2 million tonnes of peat per annum. The energy created from burning the peat is used to generate steam which in turn drives a generator which through a step up transformer supplies the national grid. The planning history of the facility is as follows: Permission was granted by An Bord Pleanala in December 1998 for a peat fired electricity generating station subject to conditions ( An Bord Pleanala Ref. PL Planning Authority Ref. 02/437) Permission was granted by Offaly County Council in September 1998 for a pump house for water abstraction from the Figile River at Clonbullogue ( Palnning Authority Ref. 98/493 Decision by An Bord Pleanala that the proposed use of biomass and meat and bone meal as auxiliary fuels in the power station was development and not exempted development ( An Bord Pleanala Ref. RL2032) Permission was granted by An Bord Pleanala in May 2005 for material change of use as a power station of electricity generation by combustion of peat to use as a power station and a waste recovery facility for the electricity generation by combustion of a mix of fuels including biomass and recovered (treated) meat and bone meals subject to conditions ( An Bord Pleanala Ref. PL , Planning Authority Ref. 04/210) As part of the operation of the facility it is required to maintain an IPPC licence. The following outlines the licensing history of the facility: Following application in 1999, the EPA granted IPC Licence Register No. 482 in July 1999 for the following activity Class 2.1: The production of energy in combustion plant the rated thermal input of which is equal to or greater than 50MW An application was made to the EPA in 2002 for a revised licence to facilitate the combustion of meat and Bone meal and Biomass as well as Peat (up to a Bord na Móna Environmental Ltd Page 1 EPA Export :00:59:09

92 Edenderry Power Ltd. IPPC Review Attachment D.1 maximum of 10 % MBM per annum in the fuel mix). In January 2006, EPL was issued with IPPC Licence Register no P for the following activities: Class 2.1: The operation of combustion installations with a rated thermal input equal to or greater than 50MW Class 11.1: The recovery or disposal of waste in a facility, within the meaning of the Act of 1996, which facility is connected or associated with another activity specified in this Schedule in respect of which a license or revised licence under Part IV is in force or in respect of which a licence under the said Part is or will be required, The facility has also been granted a Greenhouse gas emission Permit Register Number (IE-GHG007-02) by the EPA which authorises the facility to emit specified greenhouse gases from listed emission points. Operational History The proposed installation of the peaking plants is to occur in a previously undeveloped section of land within the boundary of the facility. The proposed location is west of the existing Intermediate peat storage building at the northern end of the facility (see Drawing reference EdenP rev-02). This area has been previously used as a temporary car park area for on-site contractors. Almost all of the area in question has an existing hardcore finish. Plant description The proposed infrastructure is classed as peaking plants and are designed to operate during short periods of peak energy demand. As a result of this requirement the plants are required to have short start up times and reach capacity energy production as rapidly as possible. The proposed plants will be Pratt and Whitney Twin Pac peaking plants. The combined power output of both plants is 104MW. The plant will incorporate four exhaust stacks, one for each turbine. The activity will be fuelled by low sulphur content gas oil (0.1% sulphur content). Each plant consists of two gas turbines driving a common generator and will incorporate four exhaust stacks, one for each turbine. The power units are compact in design and each unit occupies an area of 37m x 17m approximately. The units are low profile with only the air intakes and exhaust stacks exceeding 5m in height. The adjacent peat storage building is approximately 20m in height. As well as the gas turbines and generator the units also include inlet air filters, ducting, exhaust ducting and auxiliary systems. Each Twinpac is of modular design for ease of transport and assembly. Methods The gas turbines require the use of both gas oil and demineralised water for generation of electricity. The gas oil is to be stored in two large storage tanks adjacent to the twinpac plants. The gas oil is conditioned prior to use by a fuel conditioning plant and is then ready Bord na Móna Environmental Ltd Page 2 EPA Export :00:59:09

93 Edenderry Power Ltd. IPPC Review Attachment D.1 for use. The demineralised water is already generated at the existing facility and therefore does not require any pre treatment prior to use. The demineralised water is to be stored in two storage tanks (750m 3 ) adjacent to the twinpac units. Processes The gas turbine process is based on the Brayton cycle which was proposed by a Boston engineer, George Brayton around The cycle consists of four stages or processes. Fresh air at ambient conditions is drawn into the compressor, where its temperature and pressure are raised. The high-pressure air proceeds into the combustion chamber, where fuel is burnt at constant pressure. The resulting high-temperature gases then enter the turbine, where they expand to the atmospheric pressure through a row of nozzle vanes. This expansion causes the turbine blade to spin, which then turns a shaft inside a magnetic coil. When the shaft is rotating inside the magnetic coil, electrical current is produced. The exhaust gases leaving the turbine are then emitted through the exhaust stacks. Figure D1 below outlines the process. Ancillary processes Figure D1. Outline of Brayton Cycle Gas turbine process The two main ancillary processes are the gas oil delivery, treatment and storage and the use of demineralised water for NOx suppression and turbine compressor washing. Bord na Móna Environmental Ltd Page 3 EPA Export :00:59:09

94 Edenderry Power Ltd. IPPC Review Attachment D.1 Gas oil will be delivered to the facility by road tanker and dispensed into two untreated gas oil storage tanks (750m 3 ) from a dedicated gas oil unloading area. The gas oil will then be treated prior to use and stored in a treated gas oil tank (800m 3 ). Pre-treatment will be carried out by a fuel conditioning tank and any sludge produced during this process will be collected in a small tank and removed off site for treatment by a licensed waste contractor. The tanks and fuel conditioning plant will be located within a bund in accordance with best practice. Abatement The proposed twinpac units use a water injection system for the control of NO x emissions. This involves the injection of water into the combustion chamber. This injection reduces the combustion temperature and so reduces the formation of thermally produced NO x. Recovery and treatment systems The operation of the proposed twinpac units will generate very small volumes of waste. The fuel conditioning unit that treats the gas oil prior to use will produce small volumes of sludge. This sludge will be collected and removed off site for disposal. The increased production in demineralised water that is used for the abatement system will result in a slight increase in the overall Total Dissolved Solids (TDS). The additional TDS stream will be incorporated into the existing treatment system and be subject to the existing effluent discharge conditions in the IPPC licence. The washings from the off line combustion Turbine compressor washing will be collected in a sump and the waste material will be removed off site for disposal using a registered waste disposal contractor. Operational procedures The peaking plants will operate as required to meet sudden peaks in the national demand for electricity. These peaks do not normally occur at night time but may arise at this time due to the unavailability of other capacity within the national grid system. It is envisaged the when called upon that the units will operate for between 5 and 10 hours per peaking incident, however if required the plant can operate continuously for as long as 60 hours. It is foreseen that the maximum number of operational hours per year will be The units will operate on a full on or off mode and the number of units operating at once will depend on the peaking load demand at that time. The percentage efficiency of the plant is approximated at 35 36%. Bord na Móna Environmental Ltd Page 4 EPA Export :00:59:09

95 Edenderry Power Ltd. IPPC Review Attachment E.1 ATTACHMENT NO. E1. The existing IPPC licence has one controlled emission point (A1-1, main boiler stack). The installation of the proposed Twinpac units will increase the number of air emission pints at the facility by four. Table E1 a below describes these emissions points and Drawing ref EdenP rev-02 highlights the locations of these additional emission points. REF SOURCE STACK HEIGHTS A2-1 Gas turbine emission 20m from concrete base A2-2 Gas turbine emission 20m from concrete base A2-3 Gas turbine emission 20m from concrete base A2-4 Gas turbine emission 20m from concrete base Following the completion of the required tables for the proposed development, there are a number of additional issues in the existing licence with respect to the exiting activity. Bord na Móna Environmental Ltd Page 1 EPA Export :00:59:09

96 Edenderry Power Ltd. IPPC Review Attachment E.1 TABLE E.1(ii) MAIN EMISSIONS TO ATMOSPHERE (Emission point 1 of 4) Emission Point Ref. N o : A2-1 Source of Emission: Exhaust Gases from Gas turbine No. 1 Location: Stack No. 1 Grid Ref. (12 digit, 6E,6N): Vent Details Diameter: 3.07 x 2.27 Height above Ground(m): Date of commencement: Characteristics of Emission: (i) Volume to be emitted: 20m To be confirmed ( TBC) Average/day 5,643,323Nm 3 /d Maximum/day 5,643,323Nm 3 /d Maximum rate/hour 235,138Nm 3 /h Min efflux velocity 26.3m.sec -1 (ii) Other factors Temperature 350 o C(max) 350 o C(min) 350 o C(avg) For Combustion Sources: Volume terms expressed as : wet. X dry. 15_%O 2 (iii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) Note: Maximum of 1500 operating hours per annum anticipated 60 min/hr 24 hr/day 365 day/yr Bord na Móna Environmental Ltd Page 2 EPA Export :00:59:09

97 Edenderry Power Ltd. IPPC Review Attachment E.1 TABLE E.1(ii) MAIN EMISSIONS TO ATMOSPHERE (Emission point 2 of 4) Emission Point Ref. N o : A2-2 Source of Emission: Exhaust Gases from Gas turbine No. 1 Location: Stack No. 2 Grid Ref. (12 digit, 6E,6N): Vent Details Diameter: 3.07 x 2.27 Height above Ground(m): Date of commencement: Characteristics of Emission: (i) Volume to be emitted: 20m To be confirmed ( TBC) Average/day 5,643,323Nm 3 /d Maximum/day 5,643,323Nm 3 /d Maximum rate/hour 235,138Nm 3 /h Min efflux velocity 26.3m.sec -1 (ii) Other factors Temperature 350 o C(max) 350 o C(min) 350 o C(avg) For Combustion Sources: Volume terms expressed as : wet. X dry. 15_%O 2 (iii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) Note: Maximum of 1500 operating hours per annum anticipated 60 min/hr 24 hr/day 365 day/yr Bord na Móna Environmental Ltd Page 3 EPA Export :00:59:09

98 Edenderry Power Ltd. IPPC Review Attachment E.1 TABLE E.1(ii) MAIN EMISSIONS TO ATMOSPHERE (Emission point 3 of 4) Emission Point Ref. N o : A2-3 Source of Emission: Exhaust Gases from Gas turbine No. 2 Location: Stack No. 1 Grid Ref. (12 digit, 6E,6N): Vent Details Diameter: 3.07 x 2.27 Height above Ground(m): Date of commencement: Characteristics of Emission: (i) Volume to be emitted: 20m To be confirmed ( TBC) Average/day 5,643,323Nm 3 /d Maximum/day 5,643,323Nm 3 /d Maximum rate/hour 235,138Nm 3 /h Min efflux velocity 26.3m.sec -1 (ii) Other factors Temperature 350 o C(max) 350 o C(min) 350 o C(avg) For Combustion Sources: Volume terms expressed as : wet. X dry. 15_%O 2 (iii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) Note: Maximum of 1500 operating hours per annum anticipated 60 min/hr 24 hr/day 365 day/yr Bord na Móna Environmental Ltd Page 4 EPA Export :00:59:09

99 Edenderry Power Ltd. IPPC Review Attachment E.1 TABLE E.1(ii) MAIN EMISSIONS TO ATMOSPHERE (Emission point 4 of 4) Emission Point Ref. N o : A2-4 Source of Emission: Exhaust Gases from Gas turbine No. 2 Location: Stack No. 2 Grid Ref. (12 digit, 6E,6N): Vent Details Diameter: 3.07 x 2.27 Height above Ground(m): Date of commencement: Characteristics of Emission: (i) Volume to be emitted: 20m To be confirmed ( TBC) Average/day 5,643,323Nm 3 /d Maximum/day 5,643,323Nm 3 /d Maximum rate/hour 235,138Nm 3 /h Min efflux velocity 26.3m.sec -1 (ii) Other factors Temperature 350 o C(max) 350 o C(min) 350 o C(avg) For Combustion Sources: Volume terms expressed as : wet. X dry. 15_%O 2 (iii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) Note: Maximum of 1500 operating hours per annum anticipated 60 min/hr 24 hr/day 365 day/yr Bord na Móna Environmental Ltd Page 5 EPA Export :00:59:09

100 Edenderry Power Ltd. IPPC Review Attachment E.1 TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical characteristics of the emission (Emission point 1 of 4) Emission Point Reference Number: A2-1 Parameter Prior to treatment (1) Brief As discharged (1) mg/nm 3 kg/h description mg/nm 3 kg/h. kg/year Avg Max Avg Max of treatment Avg Max Avg Max Avg Max SO None NO x Water Injection Particulate None Concentrations should be based on Normal conditions of temperature and pressure, (i.e. 0 o C,101.3kPa). Wet/dry should be the same as given in Table E.1(ii) unless clearly stated otherwise. Bord na Móna Environmental Ltd Page 6 EPA Export :00:59:09

101 Edenderry Power Ltd. IPPC Review Attachment E.1 TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical characteristics of the emission (Emission point 2 of 4) Emission Point Reference Number: A2-2 Parameter Prior to treatment (1) Brief As discharged (1) mg/nm 3 kg/h description mg/nm 3 kg/h. kg/year Avg Max Avg Max of treatment Avg Max Avg Max Avg Max SO None NO x Water Injection Particulate None Concentrations should be based on Normal conditions of temperature and pressure, (i.e. 0 o C,101.3kPa). Wet/dry should be the same as given in Table E.1(ii) unless clearly stated otherwise. Bord na Móna Environmental Ltd Page 7 EPA Export :00:59:09

102 Edenderry Power Ltd. IPPC Review Attachment E.1 TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical characteristics of the emission (Emission point 3 of 4) Emission Point Reference Number: A2-3 Parameter Prior to treatment (1) Brief As discharged (1) mg/nm 3 kg/h description mg/nm 3 kg/h. kg/year Avg Max Avg Max of treatment Avg Max Avg Max Avg Max SO None NO x Water Injection Particulate None Concentrations should be based on Normal conditions of temperature and pressure, (i.e. 0 o C,101.3kPa). Wet/dry should be the same as given in Table E.1(ii) unless clearly stated otherwise. Bord na Móna Environmental Ltd Page 8 EPA Export :00:59:09

103 Edenderry Power Ltd. IPPC Review Attachment E.1 TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical characteristics of the emission (Emission point 4 of 4) Emission Point Reference Number: A2-4 Parameter Prior to treatment (1) Brief As discharged (1) mg/nm 3 kg/h description mg/nm 3 kg/h. kg/year Avg Max Avg Max of treatment Avg Max Avg Max Avg Max SO None NO x Water Injection Particulate None Concentrations should be based on Normal conditions of temperature and pressure, (i.e. 0 o C,101.3kPa). Wet/dry should be the same as given in Table E.1(ii) unless clearly stated otherwise. Bord na Móna Environmental Ltd Page 9 EPA Export :00:59:09

104 Edenderry Power Ltd. IPPC Review Attachment E.1 Issue relating to the existing activity within the existing Licence There are a number of issues relating to the existing activity within the licence that require revision. These issues and the reasons for revision are outlined below. 1. Declassification of Category 3 Meat and Bonemeal ( MBM) EPL received from the EPA a letter dated November in which MBM Category 3 has been de-classified as a waste. The Department of Environment, Heritage and Local Government (DEHLG) have recently informed the Agency that Category 3 MBM when used as a fuel should be classed as a product and not a waste. In such circumstances it is not subject to nor does it come within the scope of the Waste Incineration Directive. Based on the above information the emissions from the existing stack (A1-1) do not come under the Waste Incineration Directive when MBM is combusted. It is therefore contended that the requirements of Table B.1.2 in Schedule B (B.1) of the existing licence be removed and that the emissions from the existing stack should be limited by the emission limit values outlined in Table B.1.1 only (Emission Limit Values for combustion of peat or peat and biomass). The emission limit values outlined in Table B.1.1 should apply when combusting Peat, Biomass and MBM. 2. Continuous Emissions Monitoring Incompatibility between sections and of the Licence. Edenderry Power Limited operates a Continuous Emissions Monitoring system to monitor the air emission requirements of the licence. Based on previous monitoring reports supplied by the EPA contracted monitoring company it is apparent that the measured emission levels were compared to the licence limits under condition which states: (i) (ii) (iii) For any parameter where, due to sampling/analytical limitations, a 30 minute sample is inappropriate, a suitable sampling period should be employed and the value obtained therein shall not exceed the emission limit value For flow, no hourly or daily mean value, calculated on the basis of appropriate spot readings shall exceed the relevant limit value. For all other parameters, no 30 minute mean value shall exceed the emission limit value As previously outlined to the license inspector during the site visit of 29/3/2007, sections and are not compatible, neither operationally or mathematically, and both cannot be applied simultaneously. For example, under of the current licence the emission limit values for Sulphur Dioxide are considered as complied with, if 48 Hourly Mean Values do not exceed 110% of the emission limit values i.e. 660 mg/m 3, however section of the Licence implies that every half hour must not exceed 600 mg/m 3. The 48 hour mean values are calculated in 24 hour blocks. Namely day 1 plus day 2 generates the first 48hour mean, day 2 plus day 3 generates the 2 nd 48 hour mean etc. It is worth noting that under the previous licence (IPPC Register No P )., an hourly limit of twice the Daily E.L.V. was permitted in recognition of normal operating conditions, such as sootblowing, minor fuel variation etc. Bord na Móna Environmental Ltd Page 10 EPA Export :00:59:09

105 Edenderry Power Ltd. IPPC Review Attachment E.1 In the absence of an alternative, it is submitted that in order to resolve this apparent contradiction it is proposed that the old Hourly Limit of twice the standard E.L.V. from P be reinstated for Spot Check Monitoring ( 30 minute). Determination of compliance of emission would depend on this measurement and also compliance with Condition as presently described in the existing license. This increase in the emission limit values (for 30 minute spot checking only) to twice the existing limit values has already been demonstrated not to result in exceedences of the appropriate ambient air quality limit values. This was demonstrated as part of the previous IPPC review application and is outlined in the Inspectors report dated 16/09/2005 from the Office of Licensing and Guidance (Table 2) on the previous review application. 3. Removal of PM 10 and PM 2.5 monitoring requirement from Schedule C, C.1.2 It is contended that this requirement be removed for the following reasons. 1. Monitoring of either of these parameters is not required under the Waste Incineration Directive (2000/76/EC) or under the Large Combustion Plant Directive (2001/80/EC). 2. These parameters were not included in the Proposed Determination (PD) of the existing license. These parameters were included in the Final Determination (FD) of the existing licence. The monitoring or lack of monitoring of these parameters was not raised as an objection by a third party or EPL during the required period between the PD and the FD or flagged in either the inspectors report or the technical committee s review of objections. Bord na Móna Environmental Ltd Page 11 EPA Export :00:59:10

106 Edenderry Power Ltd. IPPC Review Attachment E.2 Attachment E.2 The existing facility has one monitored process water point and a single discharge point into the River Figile. The process monitored point (W-1) is the discharge into the settlement pond. The surface water discharge point (SW-1) is the discharge point from the settlement pond directly into the River Figile. The proposed development will require additional quantities of demineralised water to be produced at the facility. This demineralised water will be injected into the combustion chamber to reduction NOx formation and will be lost to atmosphere as water vapour. The increase in production of demineralised water will result in an increase in the total amount of Total Dissolved Solids (TDS) discharged to the settlement pond (and hence the River Figile) over a year s operation (main plant operation combined with 1500 hours of peaking plant operation). The proposed development will not result in a significant increase in volumes of water discharged to the settlement pond and therefore discharged to the River Figile. Therefore there is no proposed alteration to the existing emission limit values as applied to W-1 under the existing licence. Based on the existing licence there are two proposed changes to the present conditions. These are outlined in tables E2 (i) and tables E2 (ii). 1. Removal of the Temperature emission limit value at W-1 and application of the same emission limit value at SW-1. The above change is based on information provided in three letters addressed to the EPA dated the 06/11/2006, 25/05/2007 and 21/12/2007. As outlined in the previous submissions regarding this issue, the existing licence has resulted in unavoidable temperature exceedences at the W-1 monitoring point. Condition 6.9 of the previous IPC licence 482 (now P ) stated that No effluent shall be discharged which results in a temperature increase at the edge of the mixing zone of greater than C in the receiving system. during the period of P there were no exceedences of the allowed limits. The conditions of the existing IPPC licence - P , makes no reference to the previous temperature monitoring requirements in the River and at SW-1, however it places a new absolute maximum temperature limit at W-1 of 25 0 C. The process effluent daily average temperature, monitored at W-1 sampling chamber, can reach temperatures above 25 0 C, particularly in the warmer summer and autumn months, and during start-up periods. Routinely temperatures of greater than 25 0 C are seen. Figure E.2.1 shows daily average data collected between August - November 2007 (where temperatures at W-1 exceed 25 0 C,) and corresponding post abatement temperature data for SW-1, where evidence of temperature dissipation can be seen. From the collected data it can be seen that the 25 0 C limit was exceeded 7 times, mainly due to one start up and high ambient temperatures during August. Note that during the period the plant ran continuously, this is in fact an operational record and typically one or two more start ups would have occurred (possibly resulting in additional exceedences). Bord na Móna Environmental Ltd Page 1 EPA Export :00:59:10

107 Edenderry Power Ltd. IPPC Review Attachment E.2 Effluent Temperature Monitoring Temperature W1 Avg W1 Max SW /08/ /08/ /08/ /08/ /08/ /09/ /09/2007 Date 19/09/ /09/ /10/ /10/ /10/ /10/ /10/ /11/ /11/2007 Figure E.2.1 Effluent Temperature Monitoring 21/11/ /11/2007 From the above Figure it can be seen that although the daily average temperature reduces as the year progresses the maximum temperatures at W-1 remain very close to the 25 o C limit. This is because the W-1 maximum temperatures are intermittent and related to normal periodic process activities such as Soot Blowing and Boiler purge. The temperature dissipation capabilities of the Settlement Pond are clearly evident. Currently the abatement or temperature reduction method used is the Settlement Pond, which is located after the W-1 process effluent monitoring point. The primary function of the settlement pond is to allow sufficient dissipation of the process effluent temperature prior to being discharged to the river through SW-1. This pond has a capacity of > 3000 m 3 and typically provides a residence time of approximately 3 days. The final effluent temperature is monitored at SW-1 sampling chamber before discharging. In light of this abatement system, it is contended that the existing absolute temperature maximum limit of 25 0 C at W-1 is not appropriate. Meeting this limit would involve the use of a significant increase in cooling water purging to reduce process effluent temperature at W-1, which in turn will require increased volumes of river water intake. This action would have the effect of reversing measures taken over the previous number of years to reduce water intake into the plant. Retaining the limit at W-1 provides no additional environmental benefit as the effluent is cooled prior to discharge in the Settlement Pond and therefore it is proposed that the 25 o C limit at W-1 be applied at the SW-1 Monitoring point. Bord na Móna Environmental Ltd Page 2 EPA Export :00:59:10

108 Edenderry Power Ltd. IPPC Review Attachment E.2 2. Revision of the kg/day emission limit values in Schedule B, B.2 Emission to Water The maximum volumetric discharge allowable at W-1 under the existing licence is 1,500m 3 per day. Applying this limit value to the existing emission limit value concentrations of each parameter results in an increase in the daily kg/day emission limit value for all parameters apart from Total dissolved solids ( no change ). Bord na Móna Environmental Ltd Page 3 EPA Export :00:59:10

109 Edenderry Power Ltd. IPPC Review Attachment E.2 TABLE E.2(i): EMISSIONS TO SURFACE WATERS (One page for each emission) Emission Point: Emission Point Ref. N o : Source of Emission: Location : SW-1 Cooling tower blowdown, water treatment plant neutrailsation basin discharges, boiler blowdown, cooling water to cool the boiler blowdown and surface water run-off East of settlement pond Grid Ref. (12 digit, 6E,6N): Name of receiving waters: E, N River Figile Flow rate in receiving waters: 0.03 m 3.sec -1 Dry Weather Flow Available waste assimilative capacity: Emission Details: (i) Volume to be emitted 0.10 m 3.sec -1 95%ile flow 127.2kg/day Normal/day 1,080m 3 Maximum/day 2,080m 3 Maximum rate/hour 200m 3 (ii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) 60 min/hr 24 hr/day 365 day/yr Bord na Móna Environmental Ltd Page 4 EPA Export :00:59:10

110 Edenderry Power Ltd. IPPC Review Attachment E.2 TABLE E.2(ii): EMISSIONS TO SURFACE WATERS - Characteristics of the emission (1 table per emission point) Emission point reference number : SW-1 Parameter Prior to treatment As discharged % Efficiency Max. hourly average (mg/l) Max. daily average (mg/l) kg/day kg/year Max. hourly average (mg/l) ph 6-9 Temperature 25 Toxicity Max. daily average (mg/l) 10 TU BOD Suspended Solids Total Dissolved Solids Ammonia (as N) Total Phosphorous(as P) Oils, Fats and Greases Mineral oils Residual Chlorine 0.02 kg/day kg/year Bord na Móna Environmental Ltd Page 5 EPA Export :00:59:10

111 Edenderry Power Ltd. IPPC Review Attachment E.2 TABLE E.2(i): EMISSIONS TO SURFACE WATERS (One page for each emission) Emission Point: Emission Point Ref. N o : W-1 Source of Emission: Location : Cooling tower blowdown, water treatment plant neutralisation basin discharges, boiler blowdown and cooling water to cool the boiler blowdown East of settlement pond Grid Ref. (12 digit, 6E,6N): Name of receiving waters: E, N Settlement pond (and ultimately River Figile) Flow rate in receiving waters: 0.03 m 3.sec -1 Dry Weather Flow Available waste assimilative capacity: Emission Details: (i) Volume to be emitted 0.10 m 3.sec -1 95%ile flow 127.2kg/day Normal/day 1,500m 3 Maximum/day 1,500m 3 Maximum rate/hour 65m 3 (ii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) 60 min/hr 24 hr/day 365 day/yr Bord na Móna Environmental Ltd Page 6 EPA Export :00:59:10

112 Edenderry Power Ltd. IPPC Review Attachment E.2 TABLE E.2(ii): EMISSIONS TO SURFACE WATERS - Characteristics of the emission (1 table per emission point) Emission point reference number : W-1 Parameter Prior to treatment As discharged % Efficiency Max. hourly average (mg/l) Max. daily average (mg/l) kg/day kg/year Max. hourly average (mg/l) ph 6-9 Toxicity Max. daily average (mg/l) 10 TU BOD Suspended Solids Total Dissolved Solids Ammonia (as N) Total Phosphorous(as P) Oils, Fats and Greases Mineral oils Residual Chlorine 0.02 kg/day kg/year Bord na Móna Environmental Ltd Page 7 EPA Export :00:59:10

113 Edenderry Power Ltd. IPPC Review Attachment E.5 Attachment E.5 As part of the Environmental Impact Statement carried out for the planning application a noise impact modelling assessment report was carried out ( Peaking Power Plant Environmental Impact Statement Nov 2007 Appendix B Noise Modelling Report Appendix A). The sound pressure levels outlined in this report are inputted into Table E.5 (i) below.. The potentially significant noise sources from the operation of the plant that were identified during the assessment were noise radiated from the top of the stack and the air inlet. The period of operation will be a maximum of 1500 hrs per year. It is expected that the plants will be operated for 5 to 10hour periods, however the plants are capable of operating up to a maximum of 84hours continuously. The plants are designed for operation in an urban environment and as such have a low noise impact. Bord na Móna Environmental Ltd Page 1 EPA Export :00:59:10

114 Edenderry Power Ltd. IPPC Review Attachment E.5 Table E.5(i): NOISE EMISSIONS - Noise sources summary sheet Source Twin peaking Generator Twin peaking Generator Pac Pac Emission point Ref. No Equipment Ref. No Sound Pressure 1 dba at reference distance Octave bands (Hz) Sound Pressure 1 Levels db(unweighted) per band K 2K 4K 8K m No m No Impulsive or tonal qualities Periods of Emission 1. For items of plant sound power levels may be used. Bord na Móna Environmental Ltd Page 2 EPA Export :00:59:10

115 Edenderry Power Ltd. IPPC Review Attachment F.1 TABLE F.1(i): ABATEMENT / TREATMENT CONTROL Emission point reference number : A2-1 Control 1 parameter Equipment 2 Equipment maintenance Equipment calibration Equipment back-up NO x Water Injection The operation of the equipment will be reviewed to ensure that the required abatement levels are achieved. Any reduction in the required levels will result in appropriate maintenance work being instigated. N/A Spare parts, local storage of treated water Control 1 parameter Monitoring to be carried out 3 Monitoring equipment Monitoring equipment calibration NO x Continuous Monitoring NO x Continuous emission monitoring systems ( CEMS) To be agreed with the Environmental protection agency 1 List the operating parameters of the treatment / abatement system which control its function. 2 List the equipment necessary for the proper function of the abatement / treatment system. 3 List the monitoring of the control parameter to be carried out. Bord na Móna Environmental Ltd Page 1 EPA Export :00:59:10

116 Edenderry Power Ltd. IPPC Review Attachment F.1 TABLE F.1(i): ABATEMENT / TREATMENT CONTROL Emission point reference number : A2-2 Control 1 parameter Equipment 2 Equipment maintenance Equipment calibration Equipment back-up NO x Water Injection The operation of the equipment will be reviewed to ensure that the required abatement levels are achieved. Any reduction in the required levels will result in appropriate maintenance work being instigated. N/A Spare parts, local storage of treated water Control 1 parameter Monitoring to be carried out 3 Monitoring equipment Monitoring equipment calibration NO x Continuous Monitoring NO x Continuous emission monitoring systems ( CEMS) To be agreed with the Environmental protection agency 1 List the operating parameters of the treatment / abatement system which control its function. 2 List the equipment necessary for the proper function of the abatement / treatment system. 3 List the monitoring of the control parameter to be carried out. Bord na Móna Environmental Ltd Page 2 EPA Export :00:59:10

117 Edenderry Power Ltd. IPPC Review Attachment F.1 TABLE F.1(i): ABATEMENT / TREATMENT CONTROL Emission point reference number : A2-3 Control 1 parameter Equipment 2 Equipment maintenance Equipment calibration Equipment back-up NO x Water Injection The operation of the equipment will be reviewed to ensure that the required abatement levels are achieved. Any reduction in the required levels will result in appropriate maintenance work being instigated. N/A Spare parts, local storage of treated water Control 1 parameter Monitoring to be carried out 3 Monitoring equipment Monitoring equipment calibration NO x Continuous Monitoring NO x Continuous emission monitoring systems ( CEMS) To be agreed with the Environmental protection agency 1 List the operating parameters of the treatment / abatement system which control its function. 2 List the equipment necessary for the proper function of the abatement / treatment system. 3 List the monitoring of the control parameter to be carried out. Bord na Móna Environmental Ltd Page 3 EPA Export :00:59:10

118 Edenderry Power Ltd. IPPC Review Attachment F.1 TABLE F.1(i): ABATEMENT / TREATMENT CONTROL Emission point reference number : A2-4 Control 1 parameter Equipment 2 Equipment maintenance Equipment calibration Equipment back-up NO x Water Injection The operation of the equipment will be reviewed to ensure that the required abatement levels are achieved. Any reduction in the required levels will result in appropriate maintenance work being instigated. N/A Spare parts, local storage of treated water Control 1 parameter Monitoring to be carried out 3 Monitoring equipment Monitoring equipment calibration NO x Continuous Monitoring NO x Continuous emission monitoring systems ( CEMS) To be agreed with the Environmental protection agency 1 List the operating parameters of the treatment / abatement system which control its function. 2 List the equipment necessary for the proper function of the abatement / treatment system. 3 List the monitoring of the control parameter to be carried out. Bord na Móna Environmental Ltd Page 4 EPA Export :00:59:10

119 Edenderry Power Ltd. IPPC Review Attachment F.1 The twinpac plants will be fuelled using 0.1% Sulphur content gas oil. The MSDS sheet for this gas oil is included as part of this attachment. Use of this gas oil will ensure that the formation of Sulphur Dioxide is minimised. Bord na Móna Environmental Ltd Page 5 EPA Export :00:59:10

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130 Edenderry Power Ltd. IPPC Review Attachment F.2 ATTACHMENT F.2 The existing IPPC licence has one controlled emission point (A1-1, main boiler stack). The installation of the proposed Twinpac units will increase the number of air emission points at the facility by four. Bord na Móna Environmental Ltd Page 1 EPA Export :00:59:10

131 Edenderry Power Ltd. IPPC Review Attachment F.2 TABLE F.2(i) : EMISSIONS MONITORING AND SAMPLING POINTS ( 1 table per monitoring point) Emission Point Reference No. : A2-1 Parameter Monitoring frequency Note 1 Accessibility of Sampling method Analysis method/ Sampling Points technique Nitrogen Oxides Continuous To be confirmed Proprietary NOx CEMS Flue gas Analyser Sulphur Dioxide Annually To be confirmed To be confirmed Note 2 Flue gas Analyser Temperature Continuous To be confirmed Proprietary CEMS Temperature Probe Oxygen Continuous To be confirmed Proprietary CEMS Oxygen Analyser Note 1: During Plant operation Note 2: A feasibility assessment of an in stack CEMS system will be carried. If the results of this assessment are unfavourable then an extractive technique will be applied. Bord na Móna Environmental Ltd Page 2 EPA Export :00:59:10

132 Edenderry Power Ltd. IPPC Review Attachment F.2 TABLE F.2(i) : EMISSIONS MONITORING AND SAMPLING POINTS ( 1 table per monitoring point) Emission Point Reference No. : A2-2 Parameter Monitoring frequency Note 1 Accessibility of Sampling method Analysis method/ Sampling Points technique Nitrogen Oxides Continuous To be confirmed Proprietary NOx CEMS Flue gas Analyser Sulphur Dioxide Annually To be confirmed To be confirmed Note 2 Flue gas Analyser Temperature Continuous To be confirmed Proprietary CEMS Temperature Probe Oxygen Continuous To be confirmed Proprietary CEMS Oxygen Analyser Note 1: During Plant operation Note 2: A feasibility assessment of an in stack CEMS system will be carried. If the results of this assessment are unfavourable then an extractive technique will be applied. Bord na Móna Environmental Ltd Page 3 EPA Export :00:59:10

133 Edenderry Power Ltd. IPPC Review Attachment F.2 TABLE F.2(i) : EMISSIONS MONITORING AND SAMPLING POINTS ( 1 table per monitoring point) Emission Point Reference No. : A2-3 Parameter Monitoring frequency Note 1 Accessibility of Sampling method Analysis method/ Sampling Points technique Nitrogen Oxides Continuous To be confirmed Proprietary NOx CEMS Flue gas Analyser Sulphur Dioxide Annually To be confirmed To be confirmed Note 2 Flue gas Analyser Temperature Continuous To be confirmed Proprietary CEMS Temperature Probe Oxygen Continuous To be confirmed Proprietary CEMS Oxygen Analyser Note 1: During Plant operation Note 2: A feasibility assessment of an in stack CEMS system will be carried. If the results of this assessment are unfavourable then an extractive technique will be applied. Bord na Móna Environmental Ltd Page 4 EPA Export :00:59:10

134 Edenderry Power Ltd. IPPC Review Attachment F.2 TABLE F.2(i) : EMISSIONS MONITORING AND SAMPLING POINTS ( 1 table per monitoring point) Emission Point Reference No. : A2-4 Parameter Monitoring frequency Note 1 Accessibility of Sampling method Analysis method/ Sampling Points technique Nitrogen Oxides Continuous To be confirmed Proprietary NOx CEMS Flue gas Analyser Sulphur Dioxide Annually To be confirmed To be confirmed Note 2 Flue gas Analyser Temperature Continuous To be confirmed Proprietary CEMS Temperature Probe Oxygen Continuous To be confirmed Proprietary CEMS Oxygen Analyser Note 1: During Plant operation Note 2: A feasibility assessment of an in stack CEMS system will be carried. If the results of this assessment are unfavourable then an extractive technique will be applied. Bord na Móna Environmental Ltd Page 5 EPA Export :00:59:10

135 Edenderry Power Ltd. IPPC Review Attachment I.1 ATTACHMENT I.1 The significant existing air emission point at the facility is the A1-1 boiler stack. The proposed infrastructure will result in the installation of an additional four air emission points. In order to determine the potential impact on ambient air quality of the proposed peaking plants both the proposed emissions and the existing emissions from the entire facility have to be examined. Therefore an ambient air impact assessment was carried out ( A Dispersion modelling assessment of Air Emissions from the Proposed Peaking Plants at the Edenderry Power facility as part of an Environmental Impact Statement. Bord na Móna Environmental Ltd. ECS2763- November 2007). The impact assessment was carried out as part of the Environmental Impact Assessment (Edenderry Power Limited, Peaking Power Plant, Environmental Impact Statement November 2007) submitted with the planning application. The assessment is included in full in Appendix A (Air emissions modelling report) of the EIS. Both Nitrogen Dioxide and Sulphur Dioxide were identified as the significant emission parameters as part of the assessment. These parameters result from the incomplete combustion of fossil fuels. The peaking plants also have the potential to emit Carbon monoxide, Dust and Carbon dioxide. As the peaking plants are to be of the most advanced specification both Carbon monoxide and Dust are emitted at insignificant levels and are not considered in the assessment. Carbon dioxide will be emitted during the operation of the plants but this parameter does not have an impact on local ambient air quality. This parameter will however have to be considered under the green house gas permit for the existing facility (IE-GHG007-02). The impact assessment was carried out to establish what the potential impact of the combined operation of the peaking plants and the main boiler is predicted to have on the ambient air levels of Nitrogen Dioxide and Sulphur Dioxide. Each of the peaking plants will have two emission stacks 20m high. The emission characteristics of these stacks were taken from a previous assessment carried out in Emission characteristics of the existing main boiler stack are based on the present IPPC licence emission limit values combined with the maximum volumetric discharge. This information combined with the topography, building characteristics and location of the nearest sensitive receptors were all inputted in a dispersion model. The dispersion model used in this case is the AERMOD model (AERMOD version released 18 th September 2007). The air dispersion modelling demonstrated that based on the combined emissions of the main boiler stack and the peaking plant stacks the Air Quality Standards (AQS) were exceeded at the boundary of the facility. The AQS for the 1hr and annual averages for nitrogen dioxide are predicted to be 156.7% and 169.5% of the respective limit values. The AQS for the 1hr, daily and annual averages for sulphur dioxide are predicted to be 114.6%, 244.5% and 226.4% of the respective limit values. Predicted ground levels impacts were also determined at the seven nearest sensitive receptors located to the north and south of the facility. The worst case impact (predicted ground level impact plus background levels) at these receptors is predicted to be 38.9% and 28.8% of the 1hr and annual nitrogen dioxide limit values respectively and 54.9%, 49.6% and 35.5% of the 1hr, daily and annual average sulphur dioxide limit values respectively. A number of conservative assumptions were made as part of the modelling assessment. The most significant of these is that the main boiler was operating at maximum volumetric discharge and maximum emission levels and that the peaking plants were operating 24 hours a day, 7 days week. Bord na Móna Environmental Ltd Page 1 EPA Export :00:59:10

136 Edenderry Power Ltd. IPPC Review Attachment I.1 The dispersion modelling assessment indicates that the combined emissions have the potential to result in a significant impact on ambient air quality at the boundary of the facility. This impact is predicted to occur at the north eastern boundary of the facility. The assessment also indicates that the combined emissions will not have a significant impact at the nearest sensitive receptors. Bord na Móna Environmental Ltd Page 2 EPA Export :00:59:10

137 Edenderry Power Ltd. IPPC Review Attachment I.2 ATTACHMENT I.2 The existing facility has one monitored process water point and a single discharge point into the River Figile. The process monitored point (W-1) is the discharge into the settlement pond. The surface water discharge point (SW-1) is the discharge point from the settlement pond directly into the River Figile. The proposed development will require additional quantities of demineralised water to be produced at the facility. The increase in production of demineralised water will result in an increase in the total amount of Total Dissolved Solids (TDS) discharged to the settlement pond (and hence the River Figile) over a year s operation. Demineralised Water production and TDS Based on Peaking Plant Manufacturers data the maximum de-mineralised water demand is expected to be 28.4m 3 /hr. If we assume three scenarios one with the new plant running for 100 hours the second with the plant running for 500 hours per annum and the third with the plant running 1500 hours per annum, this would result in the following Annual Hrs De Min Required m 3 Estimated Additional TDS produced Estimated % Increase in TDS v 2006 EPL TDS Total 100 2,840 6,191 Kg 1.01 % ,200 30,956 Kg 5.07 % ,600 92,868 Kg 15.21% The current maximum De-Min output with two streams on line is 4.5 l/s or 16.2 cubic meters per hour. This is sustainable for only 11 hours at which time both streams would go off line. A more typical sustainable production level would be an average 10 cubic meters per hour. Based on the Fuel Storage of 2100m 3 the estimated maximum sustained run-time for the units is 60 hours. Although this is an unlikely scenario, the proposed 1200 m 3 reserve water tanks ( two in total), along with an estimated continuous 7m 3 /h contribution from the existing water treatment plant will still comfortably provide NOx abatement for 84 Hours. The total TDS discharged in 2006 was 610,480kg. The maximum allowable TDS discharge under the terms of the existing licence is 6,000kg /day. This equates to a maximum of 2,190,000kg per year. In 2006 the facility, discharged 27.9% of its allowable discharge. If the peaking plants were running for 1500 hours in 2006 the TDS discharge would have been 32.1%. This is only a potential increase of 4.1% of the maximum allowable discharge which is not significant. Bord na Móna Environmental Ltd Page 1 EPA Export :00:59:10

138 Edenderry Power Ltd. IPPC Review Attachment I.2 Proposed Boiler Wash down process Further to the potential impact of the operation of the peaking plants a boiler wash down process is proposed for approval by the EPA as part of this review. This wash down process will be carried out on the main boiler during scheduled shutdown periods. The maintenance of the boiler in this fashion is necessary in order to maintain and/or improve energy efficiency of the boiler operation. As such this process will have a very positive environmental impact in line with the requirements of the existing IPPC licence. The wash down process involves removal of ash within the boiler tubes and subsequent prevention of the loss of heat transfer in the boiler operation. Figure I.3.1 overleaf outlines the proposed process. The process itself can be summarised as follows. Water will be applied to the boiler pipes using a high pressure delivery system. Boiler washings from the cleaning process will then be collected beneath the boiler in a holding carriage. From here the material shall be pumped to a flocculation tank where the washings will be mixed with appropriate amounts of flocculant. (Betzdearborn AE1128- MSDS sheet is included as part of this attachment).the flocculant will be stored adjacent to the mixing tank in a separate vessel and dosed into the mixing tank from that point. During this mixing process the solid material will be clumped together to form the floc, which will then settle to the bottom of the mixing tank. The solid material which consists solely of ash will be pumped from the bottom of the mixing tank to the ash wagons. These rail wagons will then remove the ash from the site and transport to the existing licensed landfill facility. The clear water on top of the mixing vessel is then moved along to a large pond for further settlement. This water is then available to be recycled for reuse in the cleaning process. If necessary it can be pumped to the Water treatment plant for further treatment before it is reused. It is estimated that the total process shall require a maximum of 6,000 cubic meters of water, with no more than 25 cubic meters to be used per hour. The total process is expected to extend over a period of 10 days. The flocculent to be used is a Polyacrylamide Emulsion which is extensively used in the treatment of waste waters. Water for the wash down process will be sourced from the River Figile and the on site borehole. As the required volumes are significantly below the maximum allowable operational water volumes and as the plant will not be in operation at the time of the wash down process then this process will not result in a significant increase in the volumes of water abstracted from the River Figile or pumped from the on-site bore hole. The proposed process is a closed loop, however it may be required to discharge some of the washings following interaction with the flocculant and having passed through the wastewater treatment to the main lagoon ( and hence to the River Figile). It is proposed that testing of the washings be carried out prior to this discharge. A testing programme can be draw up with the agreement of the Agency prior to discharge. Bord na Móna Environmental Ltd Page 2 EPA Export :00:59:10

139 Edenderry Power Ltd. IPPC Review Attachment I.2 Boiler Flocculent Holding carriage Flocculation tank Rail Wagon Settlement Pond Water Treatment Plant Figure I.3.1 Flow diagram of proposed boiler wash down process Bord na Móna Environmental Ltd Page 3 EPA Export :00:59:11

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143 Edenderry Power Ltd. IPPC Review Attachment I.2 Bord na Móna Environmental Ltd Page 7 EPA Export :00:59:11

144 Edenderry Power Ltd. IPPC Review Attachment I.2 Bord na Móna Environmental Ltd Page 8 EPA Export :00:59:11

145 Edenderry Power Ltd. IPPC Review Attachment I.2 ATTACHMENT I.2 The existing facility has one monitored process water point and a single discharge point into the River Figile. The process monitored point (W-1) is the discharge into the settlement pond. The surface water discharge point (SW-1) is the discharge point from the settlement pond directly into the River Figile. The proposed development will require additional quantities of demineralised water to be produced at the facility. The increase in production of demineralised water will result in an increase in the total amount of Total Dissolved Solids (TDS) discharged to the settlement pond (and hence the River Figile) over a year s operation. Demineralised Water production and TDS Based on Peaking Plant Manufacturers data the maximum de-mineralised water demand is expected to be 28.4m 3 /hr. If we assume three scenarios one with the new plant running for 100 hours the second with the plant running for 500 hours per annum and the third with the plant running 1500 hours per annum, this would result in the following Annual Hrs De Min Required m 3 Estimated Additional TDS produced Estimated % Increase in TDS v 2006 EPL TDS Total 100 2,840 6,191 Kg 1.01 % ,200 30,956 Kg 5.07 % ,600 92,868 Kg 15.21% The current maximum De-Min output with two streams on line is 4.5 l/s or 16.2 cubic meters per hour. This is sustainable for only 11 hours at which time both streams would go off line. A more typical sustainable production level would be an average 10 cubic meters per hour. Based on the Fuel Storage of 2100m 3 the estimated maximum sustained run-time for the units is 60 hours. Although this is an unlikely scenario, the proposed 1200 m 3 reserve water tanks ( two in total), along with an estimated continuous 7m 3 /h contribution from the existing water treatment plant will still comfortably provide NOx abatement for 84 Hours. The total TDS discharged in 2006 was 610,480kg. The maximum allowable TDS discharge under the terms of the existing licence is 6,000kg /day. This equates to a maximum of 2,190,000kg per year. In 2006 the facility, discharged 27.9% of its allowable discharge. If the peaking plants were running for 1500 hours in 2006 the TDS discharge would have been 32.1%. This is only a potential increase of 4.1% of the maximum allowable discharge which is not significant. Bord na Móna Environmental Ltd Page 1 EPA Export :00:59:11

146 Edenderry Power Ltd. IPPC Review Attachment I.2 Proposed Boiler Wash down process Further to the potential impact of the operation of the peaking plants a boiler wash down process is proposed for approval by the EPA as part of this review. This wash down process will be carried out on the main boiler during scheduled shutdown periods. The maintenance of the boiler in this fashion is necessary in order to maintain and/or improve energy efficiency of the boiler operation. As such this process will have a very positive environmental impact in line with the requirements of the existing IPPC licence. The wash down process involves removal of ash within the boiler tubes and subsequent prevention of the loss of heat transfer in the boiler operation. Figure I.3.1 overleaf outlines the proposed process. The process itself can be summarised as follows. Water will be applied to the boiler pipes using a high pressure delivery system. Boiler washings from the cleaning process will then be collected beneath the boiler in a holding carriage. From here the material shall be pumped to a flocculation tank where the washings will be mixed with appropriate amounts of flocculant. (Betzdearborn AE1128- MSDS sheet is included as part of this attachment).the flocculant will be stored adjacent to the mixing tank in a separate vessel and dosed into the mixing tank from that point. During this mixing process the solid material will be clumped together to form the floc, which will then settle to the bottom of the mixing tank. The solid material which consists solely of ash will be pumped from the bottom of the mixing tank to the ash wagons. These rail wagons will then remove the ash from the site and transport to the existing licensed landfill facility. The clear water on top of the mixing vessel is then moved along to a large pond for further settlement. This water is then available to be recycled for reuse in the cleaning process. If necessary it can be pumped to the Water treatment plant for further treatment before it is reused. It is estimated that the total process shall require a maximum of 6,000 cubic meters of water, with no more than 25 cubic meters to be used per hour. The total process is expected to extend over a period of 10 days. The flocculent to be used is a Polyacrylamide Emulsion which is extensively used in the treatment of waste waters. Water for the wash down process will be sourced from the River Figile and the on site borehole. As the required volumes are significantly below the maximum allowable operational water volumes and as the plant will not be in operation at the time of the wash down process then this process will not result in a significant increase in the volumes of water abstracted from the River Figile or pumped from the on-site bore hole. The proposed process is a closed loop, however it may be required to discharge some of the washings following interaction with the flocculant and having passed through the wastewater treatment to the main lagoon ( and hence to the River Figile). It is proposed that testing of the washings be carried out prior to this discharge. A testing programme can be draw up with the agreement of the Agency prior to discharge. Bord na Móna Environmental Ltd Page 2 EPA Export :00:59:11

147 Edenderry Power Ltd. IPPC Review Attachment I.2 Boiler Flocculent Holding carriage Flocculation tank Rail Wagon Settlement Pond Water Treatment Plant Figure I.3.1 Flow diagram of proposed boiler wash down process Bord na Móna Environmental Ltd Page 3 EPA Export :00:59:11

148 Edenderry Power Ltd. IPPC Review Attachment I.2 Bord na Móna Environmental Ltd Page 4 EPA Export :00:59:11

149 Edenderry Power Ltd. IPPC Review Attachment I.2 Bord na Móna Environmental Ltd Page 5 EPA Export :00:59:11

150 Edenderry Power Ltd. IPPC Review Attachment I.2 Bord na Móna Environmental Ltd Page 6 EPA Export :00:59:11

151 Edenderry Power Ltd. IPPC Review Attachment I.2 Bord na Móna Environmental Ltd Page 7 EPA Export :00:59:11

152 Edenderry Power Ltd. IPPC Review Attachment I.2 Bord na Móna Environmental Ltd Page 8 EPA Export :00:59:11