ESB Lough Ree Power IPPCL Review - Clarifications

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2 ESB Lough Ree Power IPPCL Review - Clarifications For the purposes of EC Environmental Objectives (Landfill Directive) Regulations 1999/31/EC

3 CONTENTS 1.ADDRESS MAPS TABLE B1(II).3 4.AL-SW1-ADF TABLE C1(I) AL-SW1- EMISSION POINT TABLE C2(I) EIS COMPLIANCE WITH LANDFILL DIRECTIVE-CELLS COMPLIANCE WITH LANDFILL DIRECTIVE-ADF LEACHATE & WASTE GROUND WATER ASSESSMENT -ADF SURFACE WATER ASSESSMENT -ADF...15 SECTION C: ATTACHMENTS Attachment:1:Lough Ree Power Sampling & Emission Points 2:Lough Ree Power Site Boundary 3:Lough Ree Power ADF Emission Points 4:Lough Ree Power ADF Cells 1

4 QUERY No 1 Clarify the licensee address, name and address for correspondence and address of registered/principal office of Body Corporate 1 Licensee Name & Address Name*: ESB Electricity Supply Board Address: Lough Ree Power Lanesborough Co Longford Tel: Fax: : RESPONSE Name and Address for Correspondence Name: Address: ESB Lough Ree Power Lanesborough Co Longford Tel: / Fax: Eimear.Dennehy@esb.ie Address of registered or principal office of Body Corporate Address: ESB Head Office 27 Lower Fitzwilliam Street Dublin 4 Company Register N/A No. Tel: Fax: Duncan.Clarke@esb.ie 2

5 QUERY No 2 Resubmit a site plan in a readable font. Include the site boundary in red. Also, provide a separate drawing clearly showing surface water emission points,(including emission point ADF-SW1), Surface water monitoring locations and groundwater monitoring boreholes. RESPONSE See Attachment 1: Lough Ree Power Site Drawing which illustrates the stations sampling and emission points See Attachment 2: Lough Ree Power Site boundary See Attachment 3: Lough Ree ADF Emission Points drawing which illustrates AL-SW1 QUERY No 3 Resubmit Table B.1(II) for emission point PS-SW4. Include all "Notes" referred to in this table RESPONSE Please note, the inclusion of Note 3- in the original application form was an error on our behalf. See attached resubmitted Table for B1(ii) for PS-SW4. Please Note the inclusion of Note 2 Note 2: Relates to an ESB submission from 2nd of February 2007 regarding Ammonia discharge limits from PS-SW5 which was agreed by the Agency and agreed by OEE inspector Kealan Reynolds. The agreement stipulates the following conditions; a) The concentration of ammonia in the Neutralised Water Treatment effluent PS-SW4 for LRP is set at 1.5mg/L for routine operation and excluding Condensate Polisher Operation. b) The regeneration of the condensate polisher is limited to 5 every two years and the concentration of ammonia discharged during these occasions will be set to 50mg/l. Subsequent Toxicity tests were submitted in communication to the Agency dated 12th of May 2009 and results were agreed with OEE Inspector Kealan Reynolds 3

6 TABLE B.1 (ii): EMISSIONS TO SURFACE WATERS - Characteristics of the emission Emission Point Reference Number: PS-SW4 Neutralised Water Treatment 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) Max. daily average (mg/l) kg/day kg/year Temperature 25C ph 6-9 Toxicity 10TU* See Note1 Suspended Solids 25 Not Applicable Not Applicable BOD 50 Total Dissolved Solids 20,000 Ammonia (as N) 1.5 See Note 2 Note: 1 Toxicity testing is on a Request only basis as agreed with the Agency- approx every three years it is conducted at the request of the Agency. Note: 2 ESB submissions on Ammonia Discharge dated 2nd of Feb Agreed with Inspector Kealan Reynolds 4

7 QUERY No 4, 5 Clarify the purpose of emission point AL- ADF referred to in Section B.2 attachment No B.2 of the licence application. Submit Table C1(i). for emission point ADF-SW1 RESPONSE Please note, in the licence review submission two typing errors occurred - where AL-ADF and AL-SW1 were stipulated in the tables, these were referencing only one emission point that of ADF-SW1. AL-SW1 was the original naming of the emission point in the IPC applicationit was changed to ADF-SW1 in the IPPCL see Schedule 2(I) Emission to Water in licence Please also reference attachment 3- Lough Ree Power- ADF Emission Points for positioning of ADF-SW1. See attached the resubmitted tables of Section B.2 attachment No B.2 of the licence application and Section C Attachment No C.3 of the licence application where this typing error has now been removed and the correct reference to AL-SW1 has been put in place. Query 4: Section B.2 Attachment No B2 Point Code Easting Northing Verified Emission ADF-SW1 202, ,500 No Visual ph Conductivity COD Ammoniacal Nitrogen TSS Heavy Metals Ortho phosphate Toxicity 5

8 Query 5 Section C 1(i) Emission Point Reference Number: ADF-SW1 Ash Disposal Facility Control 1 parameter Equipment 2 Equipment maintenance Equipment calibration Equipment back-up Monitoring to be carried out 3 Monitoring equipment Monitoring equipment calibration Visual Inspection Not applicable Not applicable Not applicable Not applicable Weekly Not applicable Not applicable Leachate Level (leachate only) Grab Sample see Note 2 & 3 Fault rectification Not applicable Spare held on site Weekly Ko meter As per EMS procedures Electrical Conductivity Grab Sample see Note 2 & 3 Fault rectification Not applicable Spare held on site Weekly Ko meter As per EMS procedures ph Grab Sample see Note 2 & 3 Fault rectification Not applicable Spares to be held on site Weekly ph meter As per EMS procedures Ammoniacal Nitrogen Grab Sample see Note 2 & 3 Fault rectification Not applicable Not applicable Quarterly Laboratory Test As per standard procedure COD Grab Sample see Note 2 & 3 Fault rectification Not applicable Not applicable Quarterly Laboratory Test As per standard procedure Total Suspended Solids Grab Sample see Note 2 & 3 Fault rectification Not applicable Not applicable Quarterly Laboratory Test As per standard procedure Heavy Metals Grab Sample see Note 2 & 3 Fault rectification Not applicable Not applicable Quarterly Laboratory Test As per standard procedure Total Phosphorous Grab Sample see Note 2 & 3 Fault rectification Not applicable Not applicable Quarterly Laboratory Test As per standard procedure Toxicity Grab Sample see Note 2 & 3 Fault rectification Not applicable Not applicable Quarterly Laboratory Test As per standard procedure Note 2: No sample is recovered from ADF-SW1; all discharges are recycled into the conditioning of the Ash cells. Note 3: No leachate is recovered from the Ash Disposal Facility. 6

9 QUERY No 6 Clarify the purpose and location of the emission point referred to as AL-SW1. RESPONSE Please note, in the licence review submission two typing errors occurred - where AL-ADF and AL-SW1 were stipulated in the tables, these were referencing only one emission point that of ADF-SW1. ADF-SW1 - was originally referred to as AL-SW1 in the IPC application. ADF-SW1 Ash Disposal Facility ADF-SW1 is located at the Lough Ree Power Ash Disposal Facility. It is the outfall drain from the lagoon at the ash disposal facility. The drainage network collect run-off from the cells in the ash disposal facility and discharges to the holding lagoon. The ash disposal facility does not give rise to any leachate as this is recycled into the system as it is used to condition the ash. Water from the lagoon is used to wet the ash to prevent dust nuisance. 7

10 QUERY No 7 Submit Table C2(I) for Emission Point PS-SW2 RESPONSE Emission Point Reference Number PS-SW2 Screen Wash Water outfall Parameter Monitoring frequency Accessibility of Sampling Points Sampling method Analysis method/ technique Flow Continuous Accessible Flow Meter Online Flow meter with recorder probe Temperature Continuous Accessible Online Temperature probe with recorder Total Residual Chlorine Daily* To be agreed with the agency To be agreed with the agency To be agreed with the agency Please Note*- No sodium Hypochlorite is used in the station therefore the testing of chlorine is not required. Please contact OEE inspector Kealan Reynolds for confirmation of this requirement. 8

11 QUERY No 8 Provide details on the Environmental Impact Statement (EIS), referred to in Section D Attachment D.1.1.of the licence application. State the date of the EIS. RESPONSE Lanesborough New Peat Power Station Project, EIS, February 2001, Report No P04B003-R1-04 which is available on request. QUERY No 9 Provide a drawing showing all existing and future cells of the installations landfill. Use different colours for cells where the operation has ceased, currently active cells and cells that are planned in to be construction in future. Include their labels in a readable font. RESPONSE See Attachment 4, Lough Ree Power ADF Cells to clarify the different phases of the cells. QUERY No 10 Justify Departures from the requirements of the Council Directive 1999/31/ec on the landfill of waste (Landfill Directive) in respect of liners, water control and leachate management, cover and capping, prevention and Stability. RESPONSE There are no departures from the landfill directive stipulated above. Please refer to the submission in the 3rd of October for compliance with the directive. Please note some minor alterations to the initial proposal were requested by OEE inspector Kealan Reynolds and these were conducted at his request. 9

12 QUERY No 11 Provide a summary of any leachate and waste testing results in accordance with Decision 2003/33/EC confirming classification of the landfill as non-hazardous RESPONSE Leachate As stipulated in the 3 rd of October submission, Section B.2.1(a) Surface water - there is no surface water runoff from the cell, any leachate is re-used in the ash cell to condition the ash therefore there are no results available as the leachate is recycled back into the cell. Borehole analysis for 2010 & can be seen in Query No 12 Response section. Ash See Table below for analysis of fly ash peat as stipulated in Schedule 3(iii) of IPPCL for 2010 and The bottom ash is recycled and used for Bord Na Mona works. Please see Environmental Impact Statement February 2001 report No P04B003-R1-04, Section where it is stipulated that peat fly ash is not classified as hazardous waste under the European Waste Catalogue and Hazardous Waste List -Catalogue Index

13 Table Peat Ash-2010 &2011 Quarterly Analysis Date ph Aluminium mg/kg Arsenic mg/kg Cadmium mg/kg Calcium mg/kg Copper mg/kg Iron mg/kg Nickel mg/kg Zinc mg/kg Qtr Qtr Qtr Qtr Qtr Qtr Qtr Qtr

14 QUERY No 12 Provide a thorough groundwater assessment that quantifies the impacts of the landfill on groundwater and identifies appropriate remediation measures where necessary. Include the relevant monitoring data and its interpretation in support of your response. RESPONSE As previously stated quarterly and annual analysis of groundwater is required by the Agency in Schedule 5(I) of the IPPCL. I attach a table below which details the 2011 and 2010 quarterly and annual analytical results for boreholes- GW2-GW6 present in the ADF. Heavy Metals are required only on an annual basis. 12

15 Table ADF- Borehole Analysis 2010 & 2011 Date Sample Point TPH NH4 (mg/l N) Cl mg/l Groundwater Threshold n/a n/a n/a value NT Qtr ADF-GW < Qtr ADF-GW4 NT <0.85 <0.1 < Qtr ADF-GW5 NT <0.85 < Qtr ADF-GW6 NT <0.85 < Qtr ADF-GW3 < Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW4 < Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW3 < Qtr ADF-GW4 < Qtr ADF-GW Qtr ADF-GW6 < Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW5 < Qtr ADF-GW Zn Fe Ni Cu Cd Al As

16 TPH NH4 (mg/l N) Cl mg/l Zn Date Sample Point Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW Qtr ADF-GW Fe Ni Cu Cd Al As NT= not tested- a mix up of sampling requirements with the laboratory resulted in No TPH values for Quarter monitoring only* N/A- there is No established threshold for this parameter Groundwater Threshold values based on Schedule 5 of the European Communities Environmental Objectives (Groundwater) Regulations 2010 (S.I. No. 9 of 2010). Please note that monthly data for conductivity and Ph is available on request for all boreholes- they can also be seen in the quarterly environmental reports submitted to the OEE inspector. Where there is a designated Threshold value- all parameters are within the limits. 14

17 QUERY No 13 Provide a thorough surface assessment that quantifies the impacts of the landfill on surface water and identifies appropriate remediation measures where necessary. Include the relevant monitoring data and its interpretation in support of your response. RESPONSE There are no surface water emissions, leachate is recycled into the cell to condition the ash therefore this query is not applicable to Lough Ree Power. 15

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22 AIR EMISSIONS EMISSION PS-A1 PS-A2 PS-A3 PS-A4 SURFACE WATER EMISSIONS EMISSION PS-SW1 PS-SW2 PS-SW3 PS-SW4 PS-SW5 PS-SW6 NOTE: DESCRIPTION MAIN STACK DESCRIPTION SAMPLING POINTS PS-SW1 PS-SW2 PS-SW3 PS-SW4 PS-SW5 PS-SW6 EMISSION POINT SAMPLING POINT AUX. BOILER STACK DIESEL GEN. STACK DIESEL FIRE PUMP CONDENSER COOLING WATER SCREEN WASH WATER BOILER BLOWDOWN WATER TREATMENT EFFLUENT SURFACE WATER DRAINAGE (1) SURFACE WATER DRAINAGE (2) EMISSION DESCRIPTION CONDENSER COOLING WATER SCREEN WASH WATER BOILER BLOWDOWN WATER TREATMENT EFFLUENT SURFACE WATER DRAINAGE (1) SURFACE WATER DRAINAGE (2) ALL COORDINATES TO IRISH NATIONAL GRID EASTING 201, , , , EASTING 200, , , , , , , , , NORTHING 269, , , , NORTHING 269, , , EASTING NORTHING 200, , GW-1 GROUNDWATER BOREHOLE 201, GW-2 GROUNDWATER BOREHOLE 269, , , , , , , , , , , , , ISSUED SB JL JL S.Bolton J.Lyons J.Lyons :2000 (A3) ELECTRICITY SUPPLY BOARD LOUGH REE POWER EMISSION & SAMPLING POINTS ESBI ENGINEERING LTD. ESB INTERNATIONAL FIG

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25 Capped Cell Operations Ceased Cell Commissioned and in Operation Cell under construction Proposed future cell LEACHATE LAGOON BORD NA MONA ENERGY LIMITED