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ESB Marina Generating Station AER 2011 - IPC License P0578-02

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ESB Marina Generating Station

Annual Environmental Report 2011

Required under IPPC License P0587-02

for the period 1st Jan. 2011 to 31st Dec. 2011

ESB Marina Generating Station AER 2011 – IPC License P0578-02

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Contents1. Introduction

License Number

Licensee

Location of Activity

Licensed Activity

Environmental Policy

Environmental Management Organisation Chart and Personnel (Table 1)

2. Summary Information

Self-Monitoring Data

Emissions to Waters / Sewers

Surface Water Monitoring

Emissions to Atmosphere

Wastes Arising

Agency Monitoring and Enforcement

Energy and Water Consumption

Energy Sources and Consumption

Water Sources and Consumption

Environmental Incidents and Complaints

Energy Efficiency Audit Summary

3. Management of the Activity

Schedule of Objectives and Targets for 2011.


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Environmental Management Programme Report 2011

Process Improvement to minimise air emissions

- Emissions to air

- Efficiency

- Ambient air quality

Reduce risk of soil/groundwater pollution

Reduce noise levels generated within the site

IPL License Compliance

Waste Management

License Review

Schedule of Objectives and Targets for 2012

Environmental Management Programme 2009-2013

Pollution Emission Register Proposal

Pollution emission Register Report

License-Specific Reports


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Appendices

1. Appendix 1 Summary of Emissions 2011

2. Appendix 2 Ambient Air Quality Report 2011

3. Appendix 3 Annual Noise Survey Report 2011

4. Appendix 4 Ground Water Sampling Report 2011

5. Appendix 5 Bunds Testing / Status Report 20011

6. Appendix 6 Environmental Management Programme 2009-2013

6a Additional ongoing projects for 2012

7. Appendix 7 Residuals Management Plan Annual Review

8. Appendix 8 Site Map

9. Appendix 9 Confirmation of Financial Capability


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1. Introduction

License Register No. P0578-02

Licensee Electricity Supply Board.

Location of the Activity Marina Generating Station, Centre Park Road, Cork.

Licensed ActivityThe production of energy in combustion plant the rated thermal input of which is greater than 50 MW

This Annual Environmental Report

This Annual Environmental Report (AER 2011) is the sixth AER prepared in accordance with the conditions of IPPC License P0578-02. This

Annual Environmental Report covers the period calendar year 2011 and has been prepared in accordance with the EPA’s Guidance Note for the

preparation of an Annual Environmental Report.

The Plant

The combustion plant operated by ESB at Marina Generating Station consists of one open cycle gas turbine (OCGT). The heat recovery element

has now been decommissioned. Maximum output is now 94 MW.

Plant Operations

For Marina in 2011 typical running is at it’s minimum load of 20MW when it is called upon in order to provide emergency voltage and MW

response if required. Of the total number of hours available in 2011 Marina CT ran for 15% of the time with an annual load factor of only 4%. The

average running load for 2011 was 24.6 MW highlighting the low load running typical of a peaking unit (Marina is available from 20 MW to 94

MW). The unit was only started 39 times in the year. During 2011 ESB Marina took over the adjacent oil farm which was previously operated

by the National Oil Reserve Agency (NORA) as our grid code states that we must retain 3 days supply of a back-up fuel. This is equivalent to


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approximately 1,600t of gasoil. In February 2011 ESB Marina applied to the EPA for a Technical Amendment to our licence in relation to this

change. This was granted in August 2011(Technical Amendment P0578-02/A)

Environmental Improvements

During 2011 we purchased new colour coded waste bins for our kitchen/office area and erected new information/signage to increase

awareness of correct recycling to try and achieve our recycling target of 70% of our waste.

During 2011 the light switches on corridors in the office building were replaced with push button units on timers which turn off these lights

automatically. Various outside flood lights were also replaced with energy efficient units.

In December 2011 21,000 litres of oil was removed from a number of redundant transformers and sent for recovery. See Appendix 5.

The level of risk associated with the storage of oil was further reduced by draining down the main lube oil tank of the now redundant 30 MW

steam turbine which was part of the old combined cycle operation in Marina. This reduced the oil stored on site by 9,800 litres. This operation

took place on 08/10/2009.

A new bunded barrel store was installed for the temporary storage of solid oily waste in drums, empty/near empty drums and disused oil filters

while awaiting collection for disposal .- The operation of the new bunded barrel store is working well and is the only storage area for this

waste. It also improves the safe handling and removal of this waste.

Dry Cell Battery collection boxes were placed in workshops and canteen to provide for segregation of this waste stream. – The canteen and all

workshops bar one are now closed, the collection boxes are now in other prominent work areas such as the thermal control room and

administration office .

In November 2009 the process of removing all bulk chemicals off site began with the decommissioning of the Water treatment plant. This

process is now complete.

On December 10th 2010 a new Data Logger was fitted to our main water meter. Data from this is collected and archived on a half hourly basis.

This helps to track water consumption, highlights any leaks in the system and is a sustainability improvement.


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Environmental Policy and Management Structure

Below are Marina Generating Station’s Environmental Policy and Organisation Chart for Environmental Management. The Station’s Environmental

Policy was revised in early 2006 in preparation for Marina’s re-certification to international standard ISO14001:2004 and again in March 2008 as

part of an annual review of the system for environmental management. It was reviewed and amended in May 2010 and again in May 2011 to take

account of the new operating structure in the station and as part of the annual review of our EMS.


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Environmental Policy

Environmental Policy.

We, the management and staff at Marina, commit to:

Defining, documenting, implementing and maintaining an environmental policy appropriate to the nature, scale and environmental impacts of our activities, products and services as a part of an Environmental Management System certified to ISO 14001,

Preventing pollution and to continually improving our system for managing the impacts of our business on the environment,

Complying with applicable legal requirements and other requirements to which we, as an organisation, subscribe and which relate to the environmental aspects of our business, with regard to noise reduction ,control of air emissions and continuous monitoring of surface water. Total removal of all water treatment bulk chemicals and minimising oil storage requirements.

Striving to continually reduce our waste sent to landfill and increase the volumes sent for recycling, targeting at least recycling 50% of all waste, and to improve our sustainability performance.

Complying with all legal requirements of our IPPC Licence.

Setting and reviewing environmental objectives and targets at regular intervals,


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Actively promoting environmental awareness through communications and training and making environmental considerations an integral element in all decision making,

Communicating this policy to all employees and to other persons working on our behalf,

Making this policy available to the public.


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1.1 Environmental Management Organisation Chart

Figure 1.1 Company Organisation Chart for Power Generation/Marina Generating Station

GeneralManager

GroupManager

StationManager

Group Chemist

FinancialOfficer

ExecutiveDirector

GroupManager

PlantManager

Group Chemist

FinancialOfficer

Civil Engineer

PaRC x 3Including:Env. Co-ordSafety Co-ord

OCTM x 6

Shared Resources


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Table 1 : Personnel in the above positions and new positions in Marina in November 2009 (post OCGT conversion) are:

Executive Director Donal Crean

Group Production Manager Paul Smith

Plant Manager Gerard Stapleton

Production ManagerPlant Manager

Administration Officer (part time) Eileen O’Donoghue

Group Chemist, (part-time) Liz Stack

Financial Officer, (part time) Paul Prendergast

Civil Engineer (part-time) Tom Hayes

Planning and regulatory Compliance ( PaRC)

Team member & Nominated Safety EngineerDermot Brophy


Team member John N OSullivan


Team member & Environmental Coordinator Gerard Slyne

Open Cycle Team Members ( OCTM) Paul Murray

Pat Kelly

Tony Conroy

Alan Corbett

William Morrison

Donal Coakley


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2. Summary Information

2.1 Self-Monitoring Data

Emissions to Waters/Sewers

There are 2 licensed emission points to waters at Marina Generating Station. These

points are listed in Schedule B of license IPPCL P0578-02. These points, listed below,

are subject to emission limit values and are monitored and reported on in accordance with

the terms of the license.

SW 4 & 7 are subject to emission limit values set out in license Schedule B.2

SW4 Surface Water / Station Drainage

SW7 Surface Water/Station Drainage

o Re SW4 – treated sewage effluent discharge ceased at beginning of 2006.

Summary Mass Emission Data for these 2 emission points are given in Table 1 and Table 2

Refer to Table for the parameters measured, the limit values and the frequency of measurement for each of these emission points.

Table 1: SW4 Emission Point - Surface Water

Emission

PointParameter Units

Q1 Q2 Q3 Q4

SW4

Suspended Solids Mg/l

<5 14 29 41

Mineral Oils Ug/l 16.8 ug/l150 22

247

Sewage effluent via SW4 ceased in Jan 06.

# Storm water emissions only after conversion to OCGT.

Table 2: SW7 Emission Point - Surface Water

Emission Point Parameter Units Q1 Q2 Q3 Q4

SW7

Suspended Solids Mg/l <5 13 <3 25

Mineral Oils Ug/l 23.7 270 11 557


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Table 3: Emissions to Water - Licensed Emission Points, parameters, and frequency of measurements

Emission Point Description

Emission Point NoPer

Schedule B Emission Limits.

Mineral Oil

Suspended

SolidsFlow

Monitoring

Frequency

Visual Measured

Interceptor 2 (surface water, town water) plus, until 16th Jan 2006, sewage effluent.

SW4 X Xmax 12m3/hr

Weekly Quarterly

Interceptor 3 (surface water)

SW7 X Xmax

12m3/hr

Weekly Quarterly

Emission Limit Values ->

100mg/l.

Re SW4: For domestic effluent, the original ELV for BOD was 20 mg/l, for suspended solids 30 mg/l. Domestic sewage effluent discharge to the river ceased on 16th Jan 2006


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Surface Water Monitoring

There are 3 licensed Storm Water emission points at Marina Generating Station. These

points, SW 2, 8, and 9 are listed in Schedule C of the IPC license P0578-02 and are

subject to monitoring as set out in schedule C.2.3.

SW2 Storm Water / Station Drainage.

SW8 Storm Water/ Station Drainage

SW9 Storm Water / Station Drainage

Emission Point No. & Description

YearSampled

Q1 Q2 Q3 Q4 Monitoring Frequency

Visual Measured

SW2 [per ref:P0578-02/AP03JD]Interceptor 1 (town water,river water, surface water)

2011Mineral Oil

50.9 324 2304 541 WeeklyQuarterly

2010Mineral Oil 436

ug/l77 ug/l

<10 ug/l

27930 ug/l

Weekly Quarterly

2009 7.5 2 0 <2 Weekly

2008 7.9 3 0 12 Weekly

SW8 [per ref:P0578-02/AP03JD]Interceptor 4 (surface water)

2011Mineral Oil

42995102,8

302304 2694 Weekly

Quarterly

2011Suspended

Solids 274 197 48 18 Weekly Quarterly

2010Mineral Oil

1394 NST NST 24133

Weekly Quarterly

2010Suspended

Solids <5 mg/l NST NST 32 Weekly Quarterly

2009 No flow No flow N/A N/A

2008 7.0 2 N/A 12

SW9 [per ref:P0578-02/AP03JD]Access Road (surface water)

2011Visual Check

Weekly

2010Visual Check

Weekly




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Emissions to Atmosphere in Kilogram - 2011

Fuel Natural Gas Distillate (Gas Oil)

Substance, Kg CO2NOx

as NO2CO2

NOX

as NO2

SOx

as SO2Particulates

2011 35823 51335 710 0.192 ~0 Not measured

2010 141,926,000 121,992 5,710 1.54 0.00064 Not measured

2009 158,386,000 500,627 26,000 40 0.016603 Not measured

2008 258,733,000 883,826 0 0 0 Not measured

2007 213,976,000 734,418 47,000 See ++ 56 Not measured

Particulates and SOx are not applicable to natural gas.

No distillate fuel was burned in 2008.

The licensed annual mass emission limits are based on the allowable concentrations in mg/Nm3 for each emission for each fuel, and the maximum flue gas flow rate of 22,100,000 Nm3 per day.

NOX : 275 mg/Nm3 x max daily flue gas flow rate of 22,100,000 Nm3/day x 365 days on gas

NOX : 400 mg/Nm3 x max daily flue gas flow rate of 22,100,000 Nm3/day x 365 days on distillate

SOX : 110 mg/Nm3 x max daily flue gas flow rate of 22,100,000 Nm3/day x 365 days on distillate

Particulates : 15 mg/Nm3 x max daily flue gas flow rate of 22,100,000 Nm3/day x 365 days on distillate

CO2 figures have been verified under GHG Regulations; Ref GHG Permit 069-02.


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Wastes Arising - Information on each waste stream for 2011

Waste Type Hazardous Non-hazardous

Recyclable 31.51 tonne 6.61 tonne

Non-recyclable 1.93 tonne 7.99 tonne

Total 33.44 tonne 14.60 tonne

Recyclable as % of Total 94% 45 %

Total recyclable as % of total waste 79%


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Non- Hazardous Waste Disposed of in 2011

Collection/Transport Treatment/Disposal

EWC Type of WasteWeight tonnes

Carrier Licence

Storage Area

Disposal/ Recovery

Code

Waste Contractor

Contractors Licence

Final Disposal LocationCert of Export

Cert of Treatment (exported

loads)

20 03 01Mixed Municipal Waste

7.43Greenstar W173-01

D5Greenstar Cork

W0173-01Kinsale Rd, CorkW0012-02

15 01 06 Dry Mixed Recyclables- plastic & paper

1.3Greenstar WO173-01

R3 Recovery

Greenstar Cork

W0173-01 Thornton’s Recycling, DublinW044-02

17 02 01 Timber 6.22Veolia, Cork

WO173-01R1 -Energy

Greenstar Cork

W0173-01WRS FermoyW107-1

16 06 05 Assorted Batteries 0.08Enva

WCP-DC-08-1116-01

R6EnvaWCP-DC-08-1116-01

WCP-DC-08-1116-01

KMK Metal recycling,Tullamore,Co.Offaly113-02

Hazardous Waste Disposed of in 2011

Collection/Transport Treatment/Disposal

EWC Type of WasteWeight tonnes

Carrier Licence

Storage AreaDisposal/ Recovery

CodeWaste Contractor

Contractors Licence

Final Disposal Location

Cert of Export

Cert of Treatment (exported

loads)

13 05 07

Oily water from culverts

7.32

Enva Ireland Ltd

W 0041-1

Enva Ireland Ltd., Portlaoise,Co. Laois

R1Enva Ireland Ltd WCP-DC-08-

1116-01



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13 03 07

PCB free transformer oil

21.0

Enva Ireland Ltd

W 0041-1



1116-01


15 02 02

Solid oily waste 1.05

Enva Ireland Ltd

W 0041-1



1116-01Lindenschmidt Germany

20 01 21

Fluorescent tubes 1.3

Enva Ireland Ltd

CK WMC 16/01


R5 Enva Ireland LtdW 0041-1W 0184-104 714 98089

Irish Lamp Recycling, Kildare

17 06 05

Construction materials containing asbestos

0.39Rilta

CW WMS 346/06

Greenougue Business Park,Rathcoole, Co.Dublin

D1Rilta Environmental CW WMS

346/06Lindenschmidt Germany

16 05 06

Mixture of laboratory chemicals

2.44

Enva Ireland Ltd

CK WMC 16/01

Shannon Environmental,Co.Clare

R1 Shannon Environmental,Co.Clare

W1-11Lindenschmidt Germany

17 06 05

Construction materials containing asbestos

10.19 RiltaCW WMS

346/06

Greenougue Business Park,Rathcoole, Co.Dublin

D1Rilta Environmental CW WMS

346/06Weirshop, Germany


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2.2 Agency Monitoring and Enforcement

In 2010 the Environmental Protection Agency carried out sampling of emissions to water

emitted from licensed emission points on Marina GS site. Samples were collected on:-

11/01/2011 ( SW4) and (SW7)

23/08/2011 (SW4 and SW7)

There was a site visit on 14/12/2011 by our inspector. He did a site walk about and had

discussions with the plant manager.

Energy and Water Consumption

2.2.1 Energy - Sources & Consumption MWH

2.2.2 Water - Sources & Consumption

Water SourceOn-site Ground Water

On-site Surface Water

Municipal Supply

Year

Quantity m3

0 0 12,232 2011

0 0 5,564 2010

0 0 31,092 2009

0 0 30,703 2008

0 0 32,970 2007

The municipal figure for water delivered is from Marina Operations records of meter readings. On 10/12/2010 a new data logger was fitted to our main water meter. From this, data is collected and archived on half hourly intervals. There was a large reduction in the volume of water used in 2010 due to a marked decrease in process and domestic water usage. There was a large increase in water volume used in 2011 due to various leaks on site which took time to locate and repair.

Energy SourceHeavy

Fuel OilLight

Fuel OilNatural

GasElectricity Coal Year

MWHNCV

N/A 2.71 173,661 820 N/A 2011

N/A 16 691,3881480

#N/A 2010

N/A 97*

776,894**

5230***

N/A 2009

N/A0

*1,276,524 **

7,350***

N/A 2008

N/A 176*

1,056,187**

6,487***

N/A 2007


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2.3 Environmental Incidents and Complaints

Incidents (0)

Environmental Complaints (0)

2.4 Energy Efficiency Audit for OCGT

Parameter 2007 2008 2009 2010 2011

Thermal Efficiency Generated 38.81% 38.75% 30.72% 21.9% 20.18%

GWH Generated 409.979 492.772 246.05 146.05 35.39

House Load GWH 6.487 7.35 5.23 1.48 0.82

Total Starts 248 195 237 119 39

Gas Consumption TJ 3,820.09 4,614.78 2785 2482.7 625

Distillate Consumption litres 17,610 0 9330 1640 0

The efficiency in 2010 was down due to the permanent conversion from combined cycle

to open cycle in November 2009. 21% efficient is as expected for this type and age of

unit.


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3. Management of the Activity

Environmental management was formalised at Marina Generating Station (GS) with the

establishment of a formal documented Environmental Management System (EMS) in 1999.

This system and its operation were audited and certified to ISO 14001:1996 Standard in 2000

and re-certified in 2003. Re-certification to revised standard ISO14001:2004 took place during

2006.

Since 1999 environmental management has been carried out in accordance with the written

terms and procedures of Marina EMS and its operation has been subject to regular

surveillance audits as part of the independent certification process in addition to internal

audits.

3.1 Schedule of Objectives and Targets for 2012

Objective Target

1. To prevent pollution and to continually improve our system for managing the impacts of our activities on the environment

Complete a range of projects to reduce risk to the environment

2. To operate our installation in compliance with IPPCL P0578-02 and other permits and legal requirements.

Zero non-compliances

3. To promote environmental awareness among all staff and demonstrate our awareness to the public.

Provide training for

Internal auditing

Emergency preparedness

Fire extinguisher usage

Communication to staff

Email correspondence

Issuing policy statement to each employee.

Periodic Briefing

Communication to Public

Display Environmental Policy on Installation’s Notice Board at main entrance

4. To maintain and operate Marina’s EMS in conformance with ISO14001

Zero major non-conformances


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3.2 Environmental Management Programme Report 2011

ESB operated its Marina installation under IPPC License P0578-02 of 4th Jan 2006.

The environmental policy was reviewed and amended during 2011

Environmental Management System Manual EMS 3 Legislation was updated in Jan. 2011

Progress in implementing the 2011 Environmental Management Programme was as follows:

3.2.1 Process improvement to minimise air emissions

Emissions to Air

The station’s Continuous Emissions Monitoring System (CEMS) was

decommissioned in October 2009 and replaced with a PEMS system. Performance

testing of the PEMS has been carried out by ESB staff and a full QAL2 test was

completed in June/July 2010. The Annual Surveillance Test was not performed in

2011 due to long periods of non running of the machine. This has been discussed

with our inspector.

Efficiency

Air inlet pre-filters and fine filters were changed out during October 2009 to improve

performance of the gas turbine. Average 21% efficient. They were replaced again in

September 2011.

In-house electricity consumption was monitored throughout the year. To minimise

house load the smaller rated UT1 transformer was used as far as practicable in

preference to the larger station transformer.

Ambient Air Quality

The station’s Ambient Air Quality Monitoring System was first installed in Nov 2003

and has continued in operation since then to ascertain the impact of the station’s

emissions to air on ambient air quality. During 2011 this analyser performed

satisfactorily. The resulting air quality and metrological data file has been sent to ESB

PG Environmental Services for analysis. Refer to Appendix 2.

The windsock erected on the station roof as per IPCL P0578-02 was replaced as

necessary.

3.2.2 Reduce risk of soil/groundwater pollution

Bunding of transformers

All transformers on site are bunded with the exception of ESB Networks’ transformers

T105 and T106 which will be bunded as part of a major Transmission Compound

Development Project being undertaken by EirGrid plc and ESB Networks. Piling work


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for this project was completed in 2008 and construction work commenced early Q2,

2009.This work is ongoing.

Under Marina’s environmental work programme for 2011 repairs were carried out to a

number of bunds. Subsequent testing has revealed that some further repairs are

required. A number of bunded transformers were drained of oil in December 2011

which resulted in 21,000 litres of oil being removed off site for recycling. Please refer

to Appendix 5.

Groundwater sampling

Sampling of groundwater boreholes was carried out bi-annually in accordance with

the terms of IPPCL P0578-02 by an accredited laboratory. The reports are contained

in Appendix 4.

Risk Reduction

Operations Staff carry out a weekly environmental check for leaks on all unbunded

over-ground pipes and any unbunded vessels containing other than clean water, in

accordance with an Environmental Check List. The completed list is retained on file.

3.2.3 Reduce noise levels generated within the site.

The annual noise survey for 2011 was not carried out due to prolonged periods of

non operation of the Marina OCGT plant. This has been discussed with our inspector.

Please refer to Appendix 3.

3.2.4 IPPC License compliance

In 2011, there was no environmental incident. Weekly visual checks are completed on

our interceptors and quarterly monitoring is done by a contractor.

3.2.5 Waste Management

Solid waste is segregated into defined hazardous and non-hazardous waste steams

and disposed of or recycled using licensed Waste Contractors. Section 2.1.4 above

sets out the waste streams disposed of during 2011.

With the exception of waste metal and asbestos, all other waste streams are

managed by a single licensed waste contractor employed by Marina station to

manage all waste removal/disposal operations.

3.2.6 Promote environmental awareness among all staff and demonstrate our awareness to the public.

3.2.6.1 Training

As part of the transition from CCGT to OCGT 8 of the 10 new staff members were

trained on environmental awareness and a copy of our licence given to all staff in


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October/November 2009. The two remaining staff members are former shift

managers who would have done this training previously. We also had oil spill

response training in April 20011 for four staff members. The remaining six staff

are scheduled for this training in April 2012. We no longer have bulk chemicals on

site.

3.2.6.2 Communications to Staff

Environmental issues are circulated to all staff and quarterly Environmental

Management Group meetings are held on site.

3.2.6.3 Communication to Public

The revised environmental policy was maintained on the Installation’s Public notice board.

3.3 Environmental Management Programme 2009-2013

This programme is set out in Gantt chart format in Appendix 6.

Appendix 6a shows additional projects proposed for 2012.

3.4 Pollution Emission Register Proposal

The information used to produce this report is obtained from sampling of SW 7 emission point and plant operation logs.

3.5 Pollution Emission Register Report

As we no longer have any process water emissions, the monitoring schedule has changed where we do a weekly visual check and do quarterly sampling for mineral oil and suspended solids as per Agency ref: P0578-02/AP03JD (03/09/2009).

3.6 License-Specific Reports

The following recurring reports required under the terms of IPPC License P0578-02 were submitted to the Environmental Protection agency during 2011 by the dates specified in the license.

Reports submitted during 2011 Submission Date

Annual Environmental Report 2010 30th March 2011.


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Appendices

Appendix 1 Summary of Emissions 2011

Appendix 2 Ambient Air Quality Report 2011

Appendix 3 Annual Noise Survey Report 2011

Appendix 4 Ground Water Sampling Report 2011

Appendix 5 Bunds Testing / Status Report 2011

Appendix 6 Environmental Management Programme 2009-2013

Appendix 6a Additional projects for 2012

Appendix 7 Residuals Management Plan for 2011

Appendix 8 Site Map showing groundwater testing boreholes.

Appendix 9 Statement of Financial Capability


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Appendix 1

Summary of Emissions 2011


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AER Returns Workbook

Version 1.1.13

REFERENCE YEAR 2011

1. FACILITY IDENTIFICATIONParent Company Name Electricity Supply Board (Marina)

Facility Name Electricity Supply Board (Marina)PRTR Identification Number P0578

Licence Number P0578-02

Waste or IPPC Classes of ActivityNo. class_name

2.1The operation of combustion installations with a rated thermal input equal to or greater than 50MW

Address 1 Marina Generating StationAddress 2 Centre Park RoadAddress 3 CorkAddress 4

CorkCountry Ireland

Coordinates of Location -8.44550 51.8999River Basin District IESW

NACE Code 3511Main Economic Activity Production of electricity

AER Returns Contact Name Gerard SlyneAER Returns Contact Email Address [email protected]

AER Returns Contact Position Environmental coordinatorAER Returns Contact Telephone Number 0214917539

AER Returns Contact Mobile Phone Number 0879851750

AER Returns Contact Fax Number 0214917513Production Volume 35.39

Production Volume Units GWhrNumber of Installations 1

Number of Operating Hours in Year 1325Number of Employees 10

User Feedback/CommentsWeb Address

2. PRTR CLASS ACTIVITIESActivity Number Activity Name

1(c)Thermal power stations and other combustion installations


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Appendix 2

Ambient Air Quality Report 2011

This report is pending data analysis

by ESB Power Generation Environmental Services

and will be submitted as soon as it is available.


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Appendix 3

Annual Noise Survey Report 2011

Please see letter sent to the EPA below which explains the reasons as to why this survey did

not take place during 2011 and also the plans to carry out this survey in mid 2012.


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Office of Environmental Enforcement,South/South West Region,Environmental Protection Agency,Regional Inspectorate,Inniscarra,Co.Cork

28 February 2012

Licensee: ESB, Marina Power Station, Centre Park Rd., Cork

License: IPPCL P0578-02

Subject: PEM’s and Noise Monitoring – 2011

Attn: Mr. John Doheny, Inspector

Dear Sir,

Following a site visit by you on December 14th last and your subsequent discussions with Ger Stapleton, the Plant manager, please find his explanations below as to why PEMS and noise monitoring did not occur in ESB Marina in 2011.You will also find details of the programme to address these issues in 2012.We hope this information is to your satisfaction. If you have any further queries or need any clarification on any of the information given below please contact me or the Plant manager (Ger Stapleton).

Yours Sincerely,

____________________

Gerard SlyneEnvironmental Coordinator


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Testing PEMS equipment and noise monitoring requires having specialist persons on site to perform the tests to the required standard. During the year 2011 Marina CT (Combustion Turbine) started a total of 35 times. As a peaking unit the notice time prior to being called to run is 15 – 30 minutes notice. Under normal circumstances Marina runs at it’s minimum load of 20MW when it is called upon in order to provide emergency voltage and MW response if required. Of the total number of hours available in 2011 Marina CT ran for 15% of the time with an annual load factor of only 4%. The average running load for 2011 was 24.6 MW highlighting the low load running typical of a peaking unit (Marina is available from 20 MW to 94 MW). Given this low running profile and the extremely short notice it has proved almost impossible to get specialists to site while the unit is running.

For Marina to request a test on the system for any purpose there is a large financial penalty. This is built into the grid code and is justified as Marina would be displacing a cheaper unit from the system who would still be entitled to be paid. In order to achieve even a 4 hour test this would cost Marina in the order of €31,000 in gas purchase and penalties. For a lean peaking station this does not make economic sense.

Additionally, if Marina were to request a test it would mean running an inefficient peaking unit for 4 hours thus producing unnecessary amounts of CO2 and NOx etc. From an environmental point of view this would not make sense.

In March / April of 2012 Eirgrid will require Marina to complete a set of maximisation tests on both gas and distillate. This is a planned test and is required by Eirgrid so it removes the fiscal obstacle to performing a test – Eirgrid will be paying for this. This planned test also removes the obstacle of not having any notice to organise testing services for both PEMS and noise. With the notice we will have we will have no problem getting specialists to site. Given this information I would expect to have a suitable PEMS check and noise check carried out prior to June of 2012.


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Appendix 4

Ground Water Sampling Points 2011


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Summary of Groundwater Analysis Units2009 2010 2011

29-02-08 23-09-08 05-03-09 09-09-09 19-04-11 27-10-11

AGW1 (Driveway

)

Appearance DRY DRY DRY DRY DRY DRYChemical Oxygen Demand (Settled) mg/l DRY DRY DRY DRY DRY DRYTotal Colifirms cfu/100ml DRY DRY DRY DRY DRY DRYE. Coli cfu/100ml DRY DRY DRY DRY DRY DRYElectrical Conductivity (EC) - Site uS/cm DRY DRY DRY DRY DRY DRYTotal 16 EPA PAHs ng/l DRY DRY DRY DRY DRY DRYChloride mg/l DRY DRY DRY DRY DRY DRYNitrate mg/l DRY DRY DRY DRY DRY DRYAmmonical Nitrogen mg/l DRY DRY DRY DRY DRY DRYpH - Site pH Units DRY DRY DRY DRY DRY DRYTemperature DegC DRY DRY DRY DRY DRY DRYTotal Nitrogen mg/l DRY DRY DRY DRY DRY DRY

AGW2 (SE of

GT)

Appearance Clear Clear clear clearSlightly cloudy clear

Chemical Oxygen Demand (Settled) mg/l 19 <15 <15 11 14.2 7.82Total Colifirms cfu/100ml 3 18 7 9 <1 12E. Coli cfu/100ml <1 1 <1 <1 <1 <1Electrical Conductivity (EC) - Site uS/cm 829 330 432 310 1310 500

Total 16 EPA PAHs ng/l <10 <10 0.39 <0.1 <0.17<0.009-

0.027Chloride mg/l 98 29 105 19. 2 223 49Nitrate mg/l 1.9 4.5 2.0 5.9 0.7 3.26Ammonical Nitrogen mg/l 0.3 c 0.2 0.8 0.222 <0.2pH - Site pH Units 7.43 6.81 7.45 7.75 7.9 7.82Temperature DegC 10.1 17.0 9.3 15.0 11.4 10.9Total Nitrogen mg/l 3 3 10 <0.1 1.0 3.6


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Summary of Groundwater Analysis Units 2009 2010 201105-03-09 09-09-09 19-04-10 14-10-10 19-04-11 27-10-11

AGW3 (Rear of Boiler

House)

AppearanceCloudy /

silty Clear Clear Clear ClearVery

cloudyChemical Oxygen Demand (Settled) mg/l <15 20.6 53 79.5 80.9 126Total Colifirms cfu/100ml 1 <1 <1 <1 <1 1E. Coli cfu/100ml <1 <1 <1 <1 <1 <1Electrical Conductivity (EC) - Site uS/cm 4350 2011 4185 3999 2040 10210Total 16 EPA PAHs ng/l 0.07 0.107 0.326 <0.1 <0.17 1.06Chloride mg/l 1266 1170 1460 3340 229 3250Nitrate mg/l 3.1 <0.3 <0.01 <0.3 <0.5 <0.0677Ammonical Nitrogen mg/l 1.1 0.8 1.26 4.6 1.63 3.22pH - Site pH Units 7.54 7.42 7.00 7.35 8.32 8.5Temperature DegC 10.0 15.4 10.1 15.0 11.0 10.1Total Nitrogen mg/l 4 <0.1 <1 <1 1.5 6.4

AGW4 (Wharf)

Appearance

Dark Grey &

Silty Clear

Dark Grey &

Silty Clear ClearSlightly cloudy

Slightly cloudy

Chemical Oxygen Demand (Settled) <15 <15 <15 171 195 47.7 65.3Total Colifirms 14 14,670 14 10,140 866 120 411E. Coli 5 15 5 <1 37 <1 3Electrical Conductivity (EC) - Site 393 811 393 353 520 570 690Total 16 EPA PAHs <10 0.02 <10 1.06 1.48 1.73 2.63Chloride 64 38 64 11.8 10.3 10 8Nitrate 0.4 6.3 0.4 0.0303 <0.3 <0.5 0.12Ammonical Nitrogen 1.3 <0.2 1.3 <0.2 0.413 0.492 <0.2pH - Site 6.51 7.9 6.51 8.08 7.64 7.9 7.88Temperature 17.1 6.8 17.1 10.7 13.8 11.8 10.4Total Nitrogen 3 13 3 <1 <1 <1.0 1.1


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Appendix 5

Bunds Testing / Status Report 2011


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Marina GS Transformer Bunds

Bund #

Type Plant ItemLiquid

VolumeLast tested Result

Next

Test

Date

Comment

1-03 Concrete T107 25 m3 August 08Slight leak at high level

Repairs required

Repairs completed during outage in Sept./Oct. 2011. More repairs needed.

1-01 Concrete T101 23.7 m3 April 07 Passed 2010, April

Repairs will be tendered for during outage in Nov 2011

1-02 Concrete T102 23.7 m3 2008 FailedRepairs required

Repairs completed during outage in Sept./Oct. 2011. Drained of oil in Dec. 2011

1-04

Butyl rubber liner over concrete/concrete lock

UT1 4.27 June 2008 Passed Mid 2011Will be tested in 2012

1-05 S 11 4.27 June 2008 Passed Mid 2011Will be tested in 2012

1-09 UT2 4.27 June 2008 Passed Mid 2011Drained of oil in Dec. 2011

1-12 ST12 4.27 June 2008 Passed Mid 2011Will be tested in 2012

1-13 UT4 4.27 June 2008 Passed Mid 2011Will be tested in 2012

1-06

Spray Sealed over concrete / concrete block

HOT1 0.87 m2

Tested in 2010

Failed. Re-work required

Repairs required

Contractor engaged to carry out repairs in Q1 2011. (Beton Construction)HoT 5 drained of oil in Dec.2011

1-07 HOT5 0.87 m2

1-11 HOT4 1.10 m2

Tested in 2010

Still Leaking. Repairs required

Contractor engaged to carry out repairs in Q1 2011. (Beton Construction HoT 4 drained of oil in Dec.2011

1-10 HOT9 0.87 m2

1-14 HOT6 0.87 m2Re-sealed & Tested 2008

Passed Mid 2011

Repairs will be tendered for during outage in Nov 2011


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Marina GS Transformer Bunds

Bund #

Type Plant ItemLiquid


Next

Test

Date

Comment

1-15 HOT8 0.87 m2Re-sealed & Tested 2008

Failed. Re-work required

Mid 2011

Repairs completed during outage in Sept./Oct. 2011

HOT2 & HOT7

0.87 m2 Redundant Drained 2008Not applicable

Marina GS - Chemical & Oil Tank Bunds

Bund # Type Plant ItemLiquid


Next

Test

Date

Comment

3-01Steel on concrete base

Hydrazine Tank

900 litre Nov 04 Passed Decommissioned 2009

3-02 Concrete HCl Tank 20 t Nov 04 Passed Decommissioned 2009

3-03 ConcreteCaustic Tank

20 t Nov 04 Passed Decommissioned 2009

3-04 PlasticHCl ChemStore

1 t (IBC)Installed Q1 2008

Certified Decommissioned 2009

3-05 PlasticSodium Hypochlorite Tank

8.5 t Q1, 2007 Passed Decommissioned 2009

3-06 PlasticSodium Bromide

1 t Nov 04 Passed Decommissioned 2009

2-01 PlasticGT Waste Oil Tank

2,000 litres Q2 2010 Passed.Scheduled to be tested in Q22013

2-02 PlasticWaste Oil Store

Max 350 litres and 1200 litres

Installed Q3 2008

2011New double skin plastic tanks installed 2008.

2-03 Stainless steelG1 lub oil filtration unit

Oil throughput

Decommissioned 2009

3-07 Steel unit with grated floor.

Empty oil drums & solid oily waste.

Installed Q3 2008.

2011Passed

Q3 2014

2-04 Steel unit with grated floor with 2 levels.

Main lub oil store & antifreeze

Q 3 2010. Passed Q3 2013


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Appendix 6

Environmental Management Programme 2009-2013

Gantt Chart


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ID Task Name

1 Prevent Pollution/Target Continuous Improvements inEMS and Environmental Performance

2 Rationalise / Reduce oil stocks in stores by 30%

3 Target a Recycling Rate of at least 50%

4 Replace Interceptor No. 4 with new.

5 Promote energy sustainaiblity

6 AIR7 NOx - Measure Continuously

8 Carry out CEMS Annual Surveillance Test

9 Calibrate temperature and pressure annually

10 Change CEMS lamp Q2,2010

11 Calibrate CEMS' O2 Analyser Monthly

24 Install PEMS to replace CEMS

25 Maintain/improve energy efficiency

26 Monitor delta-p ; Install new air inlet filters on GTas required

43 Clean steam condenser CW side

44 Ambient NO2 - Measure Continuously

45 Service NO2 Analyser

56 Calibrate NO2 Analyser

117 Maintain register of NO2 High Alarms

118 Report NO2 Annual Data

124 SOx - Minimise

125 Purchase gas oil <0.1% sulphur only

130 Other Emissions to Air

131 Establish a programme to reduce fugitive emissions[IPPCL719/C6.6]

132 Terminate bulk hydrazine use/dispose of residual

133 Terminate bulk sodium hypochlorite use / dispose of residual

134 Terminate bulk sodium bromide use / dispose of residual

135

136 Other Issues

137 Replace windsock

143 Refurbish gas line cathodic protection

144 WATER145 Oil Store

146 Remove & dispose of all unlableled / out of date materials in oil store

147 Install oil over water detectors into (4 off) interceptors[IPPCL714 C3.8]

150

151 SOIL/GROUNDWATER152 Test integrity of bunds every 3 years [ IPPCL719 C3.6.5]

153 Bund 1-04 (UT1) 3 yearly re-test

154 Bund 1-05 (ST11) 3 yearly re-test


156 Bund 1-12 (ST12) 3 yearly re-test


158 Bund 1-06/1-07 (HOT1/5) Re-seal & Re-test

159 Bund 1-10/1-11 (HOTs 4/9) Re-seal & Re-test

160 Bund 1-15 (HOT 8) Repair seal

161 Bund 1-14 (HOT 6)

162 Bund 1-01 (T101)

163 Bund 1-02 (T012) Repair

164 GIS Project

165 Construction incl Bunds T105 & T106

166 Bund Transformers T105 and T106

167 Inspect T105 & T106 WEEKLY

259 Test Groundwater (AWG1,2,3,4) bi-annually

270 Complete overground distillate pipeline (replacesunderground line).

271 Install pipe and commission

272 WATER CONSERVATION273 Lab to Report on water consumption

326

327 NOISE328 Sustain altered startup procedure to avoid excessive noise

329 Carry out annual noise survey at noise sensitive locations

335 Submit Annual Noise Survey Results to EPA as part of AER

341 Inspect noise abatement equipment

347 WASTE348 Acquire/Publish ENVA Quarterly Waste Rpt & % Recycled

368 Remove remnant hazardous waste ex site

369 Miscellaneous seals/gaskets

370 Boiler 4 cladding and spray insulation

371 U4 chimney seals

372 Promote Environmental Awareness amongStaff/Demonstrate to Public

373 Training of Internal Auditors

374 Training of staff in Emergency Response Mgt

375 Emergency Preparedness - Training

376 Provide hands-on training in the use of fire extinguishers

377 Communicate to staff

378 Issue Environmental Bulletin

389 Issue environmental policy to any new member of staff

390 Communicate to public

391 Renew Notices on Installation's Public Notice board

01-01

Shift Mgr

Civil Contractor

Civil Contractor,ESBI

01-01

02-04

02-04

02-04

02-04

External Trainer

Donal L

Jim D

Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q12009 2010 2011 2012 2013 2014 2015


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Appendix 6 a

Environmental Management Programme 2012

In addition to the Gantt Chart covering the period 2009-2013 we have a number of issues we

would like to continue / progress in 2012.


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Marina 2010/ 2011/ 2012 EMP

Environmental Management Programme 2010/2011/2012

EMP Task DescriptionObjective /

TargetPerson

Responsible CompletionDate 2011 2012 Completion Date

P1/2010/11/12

Bunding Testing Programme 2010/2011/2012: Water tightness tests required on bunds; T107,T101,T102,HOT1,HOT5,HOT4,HOT9,HOT8,waste oil transfer tank @ G.T, oil barrel storage area bund. All mobile bunds to be labelled and begin a testing schedule on them in 2012.

To prove integrity of all bunds to help prevent any leakage of oil to the soil or ground water.

Plant Manager: Mr G. Stapleton.

Q 2 2010

More repairs due in 2011.We await return of contractors.-Tendering & repairs completed on T102,T107 & HOT8 in Sept. by Ring Bros. T107 failed test in Dec. so further repairs needed.

T102, UT2,HOT4,HOT5 were drained of oil in Dec. 2011with a total of 21,000 litres of oil removed for recycling.Empty transformers to be labelled so and possibility of emptying more trafos to be investigated. Portable bunds labelled on 23/2/12. Register also created.

P2/2010/11/12 Old Boat House: Inspect the old boat house near the CW outfall with a view to removal of all its contents off site. (Pat Coleman, senior chemist is due on site shortly to do inspection)

To ensure removal of all hazardous substances from the area.

Q 2 2010 P. Coleman on site on 08/04/2010 for inspection. Report to follow.

Q 2 2010 All haz material removed for proper disposal by licenced contractor.

Q 2 2010 All haz material removed for proper disposal by licenced contractor.Possibility of fencing off this structure to be considered by the plant manager.


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P3/2010/11/12 Chemicals: Do a further search of the site for redundant chemicals that may still be on site. All decommissioned chemical tanks to be labelled so.

To continue to locate and remove from site all redundant chemicals.

Plant Manager: Mr. G. Stapleton

Q 2 2010 Check completed July 2010

Q 4 2011 More chemicals in quarintine awaiting removal by licenced contractor. Feb 23rd -date for removal by licenced contractor.-Complete.

Q 2 2012 Quantity of oil dispersant located & awaiting an SDS from manufacurer to allow removal & disposal by waste contractor.This issue has been addressed & we await arrival of contractor for removal. - 7 barrels (1400 L) of chemicals removed from site by Enva on 24/2/2012.

P4/2010/11/12 EMS: Begin a full review of our EMS - to be completed on a phased basis over the course of the year.

To comply with licence requirements and to amend the EMS where required.

Environmental Co-ordinator : G. Slyne

Q 4 2010 Ongoing.

Q 4 2011 Ongoing.

Q 4 2012 Ongoing.

P5/2010/11/12 Bulk CO2 Tank: Remove R22 refrigerant from the CO2 tank in August 2010. Source alternative to R22 and associated compressor.

To replace R22 refrigerant with a more environmentally friendly substance when current compressor fails.


Q 3 2010 Work took place on tank during outage in Sept.Status Of refrigerant removal to be confirmed.

Q 4 2010 Refrigerant removal not now an option due to mechinal constraints.

Q 2 2011 New compressor ordered. Now in main stores as a spare part.

P6/2010/11/12 Waste Target: Reduce waste to landfill and increase recycling rates. To meet Enva target rate of 70% recycled and surpass if possible. Clear plastic bags now being used for all waste, for better identification of waste streams and origin.

To decrease levels of waste going to landfill and increase recycling rates by staffbriefings, increase awareness of rise in landfill levy and

All Staff. Q 4 2010 Completed Dec. 2010

Q 4 2011 Ongoing.

Q 4 2012 Ongoing but vigilance required to maintain & increase recycling levels. New waste bins purchased & in service in kitchen area to promote this. Information posters in kitchen also to help increase awareness.


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improve local segregation. Target rate of 70% recycled.

P7/2010/11/12 Energy Efficiency: Commision energy efficiency audit for the refurbished TCR and offices / toilets. CMMS jobs completed in 2011 included push button switches on timers in office block corridors & stairwells. Timer put on basement lighting. Broken external lighting replaced with energy efficient models.

To determine if the new work areas are usingenergy efficiently and to highlight areas for improvement. Implement changes if possible and identify other areas where improvements could be made.

Sustainability champion : Dermot Brophy. All Staff

Q 3 2010 Awaiting news from HO on survey date

Q 4 2010Complete -Report out on 10.02.2011

Q4 2011 Plant manager to review findings and issue recommendations.Some jobs to be entered in CMMS & EMP

P8/2010/11/12

Policy: Review and update our Environmental Policy Statement if required.

To include any changes or improvements to the station environmental performance.

Environmental Co-ordinator : G.Slyne

Q 1 2010 Completed on 12/5/2010

Review completed May 2011

Q2 2012.Review to be completed in May 2012

P9/2010/11/12

Fire fighting foam: Remove all redundant fire fighting foam from site.

To continue to remove any unwanted substances from the site.


Q 3 2010 -Completed 0n 21/9/2010

P10/2010/11/12 Public Roadway: Inspect boundary fence to public roadway and remove and dispose of any visible litter.

To satisfy a request from CCC that all businesses keep their public


Q 3 2010 Completed on 20/7/2010

Q3 2011Will be done Summer 2011.

Q4 2012 Will be done twice in 2012.


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boundary litter free.

completed

P11/2010/11/12

Training: Complete Environmental awareness training with staff.

To ensure staff are aware of their environmental obligations and are able to respond correctly in the event of an environmental incident.


Q 3 2010 Enva training on 21/05/10 for 4 staff & Jim Reynolds training for 8 staff on 27/05/10

4 of the 6 OCTM's received oil spill response training in April 2011

Q 2 2012 Oil spill response training scheduled for April 2012 for remaining staff. One staff member to do Asbestos work coordinators course in Feb.2012.- Completed

P12/2010/11/12 Re-certification to ISO14001: Ensure station licence is continued.

Continued licence certification.

Environmental Co-ordinator: G. Slyne

Complete: Oct. 2010

Q4 2011 Complete: Aug. 2011

Q4 2012

P13/2010/11/12 Compliance with IPPCL and relevant legislation: Monitor compliance with IPPCL, ensure compliance with licence conditions. Track compliance with Environmental legislation through EMS 3 review, legislation updates from HO and through the internal auditing system. Currently in Licence review process re Surface Water regulations 2009.

To keep abreast of any new legislation and ensure station compliance.

Environmental Co-ordinator: G. Slyne

Complete: Dec 2010

Q4 2011 Currently engaged in Licence Review process. Submission sent to agency on Feb. 10th 2012.

Q 4 2012 Ongoing.

P14/2010/11/12 Interceptor Monitoring: Engage a contractor to undertake quarterly inspections for mineral oil and suspended solids on all four interceptors. 2 additional Interceptors located in the oil farm across the road. All 6 Interceptors to be monitored quarterly in 2011.The 2 in the oil farm will be added to the monitoring list when fuel is placed in the storage tank.

To ensure the interceptors are operating correctly in capturing any leakage of contaminants and monitor levels of these.


Q 2 2010 Contract in place 8/04/2010. Inspections to begin shortly.-16/04/2010. 2nd completed on

Q 4 2011 Ongoing. Contract in place for 2011. 1st samples taken on 22/2/2011. Sampling suspended in the oil

Q 4 2012 Ongoing. Contract in place for 2012. Sampling resumed in the oil farm in Dec.2011.


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15/07/2010 farm until oil is stored in the tank.

P15/2010/11/12 Legionella Monitoring: Engage a contractor to undertake monthly inspections on all water outlets. On 14/02/2011 a new WRAS approved water tank was fitted to feed toilets/showers and sinks and pipework was disinfected & lagged.The old metal tanks on the roof were isolated and decommissioned. A local weekly flushing of showers is now in operation to prevent contamination.

To reduce the risk of legionella in water outlets.

Environmental Co-ordinator; G. Slyne

Complete: Dec 2011

Q 4 2011 Ongoing. Contract in place for 2011.

Q 4 2012 Ongoing. Contract in place for 2012.

P16/2010/11/12 Water Usage: - Fit a data logger to main water meter at front gate to track water usage. On December 10th 2010 a new Data Logger was fitted to our main water meter. Data from this is collected and archived on a half hourly basis. This helps to track water consumption, highlights any leaks in the system and is a sustainability improvement.

To monitor and manage station water usage and reduce if possible. Target use is less than 10/cm per day as we no longer have any process water. Usage is tracked on the water.ie website and monitored on a monthly basis.( more often at present due to ongoing leaks)

Sustainability champion : Dermot Brophy.

Q4 2010 Complete: Dec 2010

Some leaks detected & repaired in 2011. More to be rectified in 2012.

Ongoing. Repairs to ongoing leak at main entrance gate completed in Dec.2011.Water usage still above normal so more repairs required. New water meter to be fitted at main entrance to replace broken one in Feb/ March 2012 by CCC.- These repairs done on 23/2/12 and consumption now down to 18cm from 23cm per day.


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P17/2010/11/12 Oil Farm: The Environmental Aspects need to be reviewed and ensure the oil farm is included in the environmental weekly checklist. Risk assessments are also to be completed for the oil farm. Safe Operating Procedures (SOP's) also to be put in place.The Emergency preparedness and response procedures need to be reviewed and updated to include the oil farm - currently in draft form

To ensure all environmental risks are considered and that controls are adequate and to ensure weekly oil farm monitoring is robust. To ensure compliance with licence conditions and that all risks are covered in the event of an emergency.

Plant Manager, Ger Stapleton. NSE: Dermot Brophy. Environmental Co-ordinator; G. Slyne

Q1 2012 Risk assessments completed & uploaded to IDM in Feb.2012. SOP's also in place. Environmental Aspects reviewed in Feb. 2012. Weekly environmental checklist updated to include the oil farm in Jan.2012. Emergency preparedness & response procedures currently being finalised.( 17/2/12)

Appendix 7

Residuals Management Plan Annual Review 2011

TMS Ref. no. 10073 Rev. 0

“ESB Marina Generating Station

Residuals Management Plan”

This was completed on 25th August 2010.

There were no amendments to the above RMP for 2011.

ENVIRONMENTAL LIABILITIES

RISK ASSESSMENT & RESIDUALS

MANAGEMENT PLAN

Title of Report: Environmental Liabilities Risk Assessment & Residuals

Management Plan

Client: ESB Marina Power Generation Station

Attention: Elizabeth Stack

Date: 25th August 2010

TMS Ref. No: 10073 Rev. 0

Written by: Approved by:

Douglas McMillan Nick Smyth

TABLE OF CONTENTS PAGE

1.0 Introduction 6

1.1 Scope of Work

1.2 Key Assumptions

1.3 Disclaimer

2.0 Site Activities 12

2.1 Site Description

2.2 Plant Operation

2.2.1 Introduction

2.2.2 Instrumentation and Control Room

2.2.3 Fuel Delivery

2.2.4 Power Generation

2.2.5 Water Treatment

2.2.6 Laboratory

2.2.7 Chemical Storage

2.2.8 Oil Storage

2.2.9 Waste Disposal

2.2.10 Management of Change

2.2.11 Emergency Planning

2.3 Emissions

2.3.1 Introduction

2.3.2 Air Emissions

2.3.3 Water Emissions

2.3.4 Noise Emissions

2.4 Ecological Description

2.4.1 River Lee

2.4.3 Groundwater / Soil

2.5 Inventory of Site Plant and Equipment

2.6 Historical Record

3.0 Step 1: Initial Screening and Operational Risk 27

Assessment

3.1.1 Complexity

3.1.2 Environmental Sensitivity

3.1.3 Pollution Record

3.1.4 Classification of Risk

4.0 Step 2: Closure, Restoration, Aftercare Management 32

Plan (CRAMP) – Known Liabilities

4.1 Site Evaluation

4.1.1 Site Description

4.1.2 Plant and Materials

4.1.3 Waste materials

4.1.4 Asbestos

4.1.5 Environmental Incidents

4.1.6 Long-term Liabilities

4.2 Closure Considerations

4.2.1 Introduction

4.2.2 Closure Exclusions

4.2.3 Criteria for Successful Decommissioning

4.3 Implementation of RMP

4.3.1 Strategy

4.3.2 RMP General Activities

4.3.3 Decommissioning

4.3.3.1 Decontamination Works

4.3.3.2 Residual Liquid Fuel, Tankage and Pipelines

4.3.3.3 Residual Chemicals and Tankage

4.3.3.4 Drainage Line Cleaning

4.3.3.5 Tanks & Sumps

4.3.3.6 Plant Disposal

4.4 Building Demolition

4.4.1 Introduction

4.4.2 Removal of Infrastructure and Services

4.4.3 Material and Residues

4.4.4 Demolition Nuisance Mitigation

4.5 Costing & Financing

4.6 Closure Plan Update & Review

4.7 Closure Plan Implementation

4.7.1 Notification of Regulatory Authorities

4.7.2 Test Programme

4.8 Closure Plan Validation

4.9 Restoration and Aftercare Management Plan

5.0 Step 3: Environmental Liability Risk Assessment 51

ELRA) - Unknown Liabilities

5.1 Risk Identification

5.1.1 Identification of Processes

5.1.2 Identification of Risks

5.1.2.1 Fire/Explosion resulting in Emissions to Air

5.1.2.2 Fire/Explosion resulting in Emissions to Water

5.1.2.3 Distillate Leak from Pipeline

5.1.2.4 Natural Gas Leak

5.1.2.5 Hydrogen Leak

5.1.2.6 Mechanical Failure

5.1.2.7 Leak from Drains

5.1.2.8 Oil Leak from Transformers

5.2 Risk Assessment

5.3 Risk Register

5.4 Risk Matrix

5.5 Risk Management Programme

6.0 Quantification of Unknown Environmental 72

Liabilities

6.1 Financial Model

7.0 Environmental Liability Review 74

8.0 Costing & Financing 75

APPENDIX 1. Chemical & Bottled Gas Quantities at Marina

APPENDIX 2. Oil Quantities at Marina.

APPENDIX 3. Large Plant Components & Equipment List

1.0 INTRODUCTION

TMS Consultancy was commissioned by ESB Marina Power Station, County Cork, to

prepare a Residuals Management Plan and to undertake a comprehensive

Environmental Liabilities Risk Assessment (ELRA) in accordance with conditions

10.3 and 12.2 respectively of its Integrated Pollution Prevention and Control (IPPC)

N° 719.

Clause 10.2 requires the licensee to maintain a fully detailed and costed plan for the

decommissioning or closure of the site or part thereof which must be reviewed

annually with proposed amendments notified to the Agency for written agreement as

part of the AER. Clause 12.2 requires the facility to undertake a risk assessment of the

whole site in order to make suitable provisions to cover situations where

environmental liabilities may be incurred. As recommended by the 2009 independent

review of the 2005 RMP and 2006 ELRA this report has been prepared to address

these two licence requirements. This combined report has been prepared to address

these two licence requirements.

1.1 Scope of Work

Environmental liabilities can be subdivided into two main types, known and unknown

liabilities. The quantification and costing of these liabilities is conducted as separate

exercises and different financial instruments are appropriate for each type of liability.

Clause 14 of IPPC Licence Reg. N° 719 requires the preparation and submission to

the Agency of a Residuals Management Plan (RMP) to cover restoration of the site

... 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.

Clause 10.2 requires the licensee shall maintain “a fully detailed and costed plan for

the decommissioning or closure of the site or part thereof” which must be reviewed

annually with proposed amendments notified to the Agency for written agreement as

part of the AER. This must include as a minimum: i) a scope statement for the plan;

ii) the criteria which define the successful decommissioning of the activity or part

thereof, which ensures minimum impact to the environment; iii) a programme to

achieve the stated criteria; iv) where relevant, a test programme to demonstrate the

successful implementation of the decommissioning plan; and v) details of costings for

the plan and a statement as to how these costs will be underwritten.

Directive 96/61/EC of 24 September 1996 concerning integrated pollution prevention

and control contains references to the necessary measures “to prevent accidents and

limit their consequences” with the scope of the work to be carried out for the ELRA

defined by Condition 12.2 of Marina’s IPPC Licence:

The Licensee shall arrange for the completion, by an independent and

appropriately qualified consultant, of a comprehensive and fully costed

Environmental Liabilities Risk Assessment for the operation, which will address

liabilities from past and present activities.

The EPA requires an independent professional assessment and costing of potentially

significant environmental liabilities that could arise under plant failure or emergency

conditions, or environmentally significant situations that do not fall under the control

and management regime of the IPPC licence. The purpose of costing such liabilities is

to ensure that the facility can make adequate provisions, via a financial instrument or

other appropriate means, for remediating the potential environmental impairment

which could result.

The EPA Guidance on Environmental Liability Risk Assessment, Residuals

Management Plans and Financial Provision (EPA 2006) was used as the reference

document for preparation of this report. The required approach comprises the

following principal steps:

Step 1: Initial Screening and Operational Risk Assessment

Step 2: Closure, Restoration, Aftercare Management Plan (CRAMP) - Known

Liabilities

Step 3: Environmental Liability Risk Assessment (ELRA) - Unknown Liabilities

Step 4: Financial Provision.

The RMP concerns identification and costing of known liabilities or steps 1, 2 and 4

while the ELRA addresses unknown liabilities or steps 1, 3 and 4 related to the site

covered by IPPC licence n° 719 and adjacent environmental media which could be

impacted by a poorly managed closure and/or emergency scenarios. The procedure for

the work carried out included a desktop study which reviewed the following

documentation:

IPPC Licence N° 719,

ISO 14001-certified Environmental Management System and associated

documentation i.e.:

o EMS1 Policy Manual,

o EMS2 Register of Aspects and Impacts,

o EMS3 Register of Environmental Legislation,

o EMS4 Environmental Programme Manual,

o EMS6 Reference Data Manual and other EMS documentation,

o EMS Procedures

o EMS 9.1 Operational Procedures Manual

o EMS 9.2 Environmental Waste procedures

o EMS10 Environmental Emergency Procedures Manual

o EMS 10.2 Reference Data Manual

o EMS11 Environmental Monitoring procedures

Previous Environmental Risk Assessment & Residuals Management Plan,

Annual Environmental Reports 2005-2010,

Groundwater Monitoring, Bund, Noise and Waste reports,

Air Modelling & Environmental Incident reports,

Firewater Retention Study,

EMG & Management Review meeting minutes,

Audit & EPA site inspection reports,

Site Chemical MSDS.

A site walkover and audit:

Discussions with key ESB Marina personnel,

On-site inspection of additional documentation and records,

Walk-through physical inspection of the power generation plant and site.

Based on this approach, the following information was compiled:

Site location and general context;

Site environmental sensitivity evaluation;

Site history and operational history including full details of site processes;

Site investigations and information available regarding the environmental

performance of the site;

Details of the layout and contents/construction of all site buildings;

Site assets register and details of the type and value of process equipment and

tanks;

Stock inventory, raw materials information and details of all hazardous

materials;

Details of storage arrangements and that bunds and underground services have

been tested as required;

Identification of all items of plant and other materials that may be

decommissioned, rendered safe or removed from the site for disposal or

recovery in the event of closure;

Identification of locations where cleaning, decontamination or remediation

works may be required in the event of decommissioning to prevent

environmental pollution;

Details of waste shipments and waste contractors;

Drawings of the facility (at appropriate scales).

Some of this information was used to prepare a description of site activities in section

2.0.

An initial screening and operational risk assessment was then carried out to determine

the facility’s risk category as described in Section 3.0.

This step was followed for the CRAMP by a description of relevant closure

considerations, criteria for successful closure, closure plan costing, recommendations

for closure plan update and review and description of the requirements for closure

plan implementation and validation. This information is provided in section 4.0.

The ELRA described in section 5.0 required hazard identification, risk assessment,

identification and assessment of risk mitigation measures and development of risk

management programme, and an assessment of the unknown environmental liabilities.

Based on this work, a thorough assessment was made of potential environmental

liabilities requiring remediation to which costs could be assigned. The appropriate

remedial actions are described for these and remediation or corrective costs are

identified.

Finally, section 6.0 assesses and establishes the relevant financial provisions to ensure

that adequate finances are available to cover:

Known environmental liabilities that will arise at the time of facility closure;

Known environmental liabilities that are associated with the aftercare and

maintenance of the facility until such time as the facility is considered to no

longer pose a risk to the environment;

Unknown environmental liabilities that may occur during the operating life of

the facility.

1.2 Key Assumptions

A certain degree of subjectivity and uncertainty is involved in the execution of

ELRAs. Assumptions underpinning this report are as follows:

ESB maintains site conditions in accordance with their IPPC Licence and

their ISO 14001-accredited Environmental Management System (EMS)

(operational since 2000). No provision has been made for costs associated

with any criminal proceedings that could arise, as firstly, it is understood

that there is good will and a strong desire by the ESB to remain compliant

with relevant legislation and EPA requirements, and secondly, such costs

are uninsurable and therefore cannot be underwritten by any third party or

insurance organisation;

The ELRA has been based upon historic and current operational activities.

It does not consider the potential environmental liabilities associated with

significant changes in use of the site, such as redevelopment for other

commercial or industrial purposes by ESB or any other party, as these

would require a separate risk assessment exercise should they arise.

Furthermore, the ELRA does not include a costing of the final clean up of

the site after closure as this is set out in the Residuals Management Plan,

specifically catered for under Condition 10 of the IPPC licence.

1.3 Disclaimer

This report is based on information supplied by ESB Marina Generating Station to

TMS Consultancy.

2.0 SITE ACTIVITIES

2.1 Site Description

Marina Generating Station is a major landmark building located at Centre Park Road,

approximately 2 km from the centre of Cork city. Historically, the station’s original

configuration was a 120 MW capacity conventional thermal plant, developed in two

stages. The ‘A’ Station comprised two 30 MW units dating from 1954 and the ‘B’

Station comprised a single 60 MW unit dating from 1964. The station was fuelled

initially by coal and was converted in 1958 to fuelling by heavy fuel oil (HFO).

The station’s dual fuel (natural gas and distillate oil) combined cycle gas turbine

(CCGT) plant was commissioned in 1979 by the addition of an 85 MW (ISO

conditions) open cycle gas turbine (OCGT) and a heat recovery boiler which fed

steam to a 30 MW legacy steam turbine to provide total electricity generating capacity

of 115 megawatts (MW). The heat recovery boiler feeds either one of two steam

turbines (Units 1 & 2) that were part of the original ‘A’ Station, although the Unit 2

steam turbine has been out of service for some time. ‘A’ Station boilers were removed

in 1995. The ‘B’ Station, comprising the 60 MW boiler and steam turbine (Unit 4),

remains in place but is disused.

The CCGT was converted to open cycle in 2009 and is fired on natural gas supplied

from the national gas network. The CT can also burn gasoil as a standby fuel and that

is supplied from the National Oil Reserve Agency (NORA) storage site adjacent to the

station via a dedicated underground pipeline. The heat recovery boiler was

decommissioned in November 2009 so the maximum output is now 94 MW. Marina’s

role has moved, as new gas-fired plant has been commissioned (Aghada, Aughinish,

Tynagh Power) to being that of a 2-shifting mid-merit plant at times of high system

demand or a support role in times of system emergency. Load factor at the plant and

hours of operation has dropped significantly as a result of which the plant has

switched to operation as open cycle peaking plant. Projected future annual load

factors are in the order of 5 to 10% and annual operating hours 500 to 1000.

The site occupies approximately 18,500m2 or 4.5 acres (standard) located in an

industrial area within Cork city. There are no residential areas in the immediate

vicinity of the site’s boundaries. The site is bounded to the north by the River Lee

and to the south by a disused coal yard (where a transformer compound is currently

being constructed) and the Centre Park Road.

A site further to the south, comprising a tank farm, also formed part of the original

ESB site and has been on long term lease to the National Oil Residues Agency

(NORA). An underground distillate pipeline runs from the tank farm site to the ESB

Marina site. Distillate is used very infrequently, approximately once per year for

proof purposes and/or as standby. An ash disposal area located to the east of the ESB

Marina site also formed a part of the original ESB site. This was sold in 1971. The

area to the south of ESB Marina was operated as a coal storage area in former times

but is now on lease to the Department of Social Welfare.

2.2 Plant Operation

2.2.1 IntroductionThe plant was started 237 times in 2009 at times of high system demand, most

typically in a 2 shift running pattern for 5 to 6 days per week, interspersed with some

24 hour running for some 3,337 operating hours. The plant is run by approximately 10

employees. The Environmental Management System (EMS) which has been running

since 1996 has been ISO 14001 accredited since 2000 and environmental management

is fully integrated into all aspects of site management and operations.

The site operates to a comprehensive set of proactive management controls including

a comprehensive maintenance programme (run through its Computerised

Maintenance Management System or CMMS), operational control procedures,

environmental monitoring, audits and inspections, calibration, emergency plans and

improvement programmes. Full integration of environmental management into the

day-to-day running of the site is achieved by delegation of actions to the station

management team and the Environmental Management Group which holds regular

meetings to identify, discuss and action all relevant issues. Environmental bulletins

are also provided to all staff. As part of 14001 certification and IPPC licence

condition 2.2, an Environmental Management Programme details objectives and

targets to be achieved for the year based on the most pressing environmental issues

identified by the EMS.

2.2.2 Instrumentation & Control Room

Operation of the turbines and other plant is monitored and controlled automatically

from a central control room. The process is tracked by a performance emission

monitoring system (PEMS) on the GT exhaust which monitors NOx (as NO2)

emissions. The main operational control is achieved through good combustion by

keeping oxygen (O2) concentrations as low as possible and burning at the correct

temperatures to minimise NOx generation. Preventive maintenance (PM) is a key

element of plant activities and where possible predictive condition monitoring is

performed to detect onset of plant deterioration. Otherwise plant and equipment is

maintained on a planned cyclical basis in a preventative way before performance

deteriorates or breaks down.

This maintenance system is computerised and managed through the Computerised

Maintenance Management System (CMMS) with unit performance or energy

consumption being measured against a target level whilst operating. Plant reliability

and optimised performance is achieved by undertaking corrective and preventive

work, either during short-term plant shutdowns or longer plant overhauls, usually on

an annual basis. Apart from the routine monitoring of performance, annual energy

efficiency audits of the generating units are carried out and opportunities for energy

efficiency improvement or recovery identified and implemented. Energy efficiency in

2009 was down to periods of open cycle operation during the summer of 2009 and

then the permanent conversion to open cycle operation from September 2009.

Air inlet pre-filters and fine filters were changed out during October 2009 to improve

performance of the gas turbine. In-house electricity consumption was monitored

throughout the year. To minimise house load the smaller rated UT1 transformer was

used as far as practicable in preference to the larger station transformer.

From a safety perspective, turbine runaway of the combustion turbines is prevented by

its protection with a sophisticated set of internationally recognised standards and

manufacturer’s recommendations including alarmed temperature and pressure

controls, continuous vibration monitoring and so on.

2.2.3 Fuel Delivery, Handling and Storage

Natural gas is supplied from the national gas network. The CT can also burn gasoil as

a standby fuel and that is supplied from the National Oil Reserve Agency (NORA)

storage site adjacent to the station via a dedicated underground pipeline.

2.2.4 Power Generation

The OCGT operates by drawing in air for combustion from the atmosphere which is

compressed this to a high pressure by a compressor driven directly by the gas turbine.

The air is mixed with the fuel in the burners and ignited in the combustion chamber to

produce hot gas. The hot gas enters the gas turbine where it causes the blades of the

turbine to turn. As a result the turbine drives its air compressor and generates

electricity for supply to the national grid.

2.2.5 Water Treatment and Cleaning Processes

Wastewaters are produced as a result of infrequent combustion turbine washings.

2.2.5.1 Sewage Treatment Plant EffluentAll Marina site sewage has been discharged into a municipal sewer on Centre Park

road since 2006.

2.2.5.2 Boiler Water BlowdownsBoiler blowdowns have ceased since decommissioning of the last remaining boiler in

September 2009.

2.2.5.3 Combustion Turbine Washings

The station has an off-line compressor water washing system to be used if required

due to performance degradation attributable to dirt on compressor blades. The system

operates by introducing a detergent solution into the compressor for approximately 3

to 5 minutes which is allowed soak for 20 minutes, followed by rinsing with clean

water for a further 15 to 20 minutes. Flowrates are about 0.33 m3 / minute with the

resulting effluent stored in a tank for approved disposal off-site using a licensed waste

contractor.

2.2.6 Laboratory

Laboratory facilities on-site were closed in September 2009 and all chemicals

removed from site.

2.2.7 Chemical Storage

In November 2009 the process of removing all bulk chemicals off site began with the

decommissioning of the Water treatment plant. This process is now complete. Smaller

quantities stored on site are listed in Appendix 1.

2.2.8 Storage of OilsQuantities of oil stored on site are listed in Appendix 2. Any tank and drum storage

areas remaining are stored in impervious bunds and all drainage from bunded areas is

diverted for collection and safe disposal in accordance with condition 3.6 of Marina’s

IPPC licence and are integrity tested at least once every three years. All transformers

on site are bunded (with the exception of T105 and T106) and some repairs were

carried out on bunds in 2009.

Waste oil is stored in one of 2 double-skinned plastic tanks located in a secure storage

shed at the southern end of the main station building. The level of risk associated with

oil storage was further reduced in 2009 by the draining down of the main lube oil tank

of the now redundant 30 MW steam turbine which was part of the old combined cycle

operation in Marina. This operation reduced the quantity of oil stored on site by 9,800

litres.

Operations Staff carried out a weekly environmental check for leaks on all unbunded

over-ground pipes and any unbunded vessels containing other than clean water, in

accordance with an Environmental Check List.

An underground distillate pipeline connects the storage tank directly from the NORA

tankfarm to the combustion turbine where it is used for emergency back-up operation.

All drainage from bunded areas is diverted for collection and safe disposal. Drainage

water from the site passes through the four oil interceptors before discharge off-site.

2.2.9 Waste Disposal

ESB Marina’s waste management system is required under the terms of its IPPC

Licence (Condition 8) and its ISO 14001 accreditation and is focused on waste

segregation and its management. Waste is clearly labelled and appropriately

segregated, stored in designated areas, protected against spillage and leachate run-off

and only handled by authorised waste contractors. Consequently, 382.33 tonnes of

waste was generated in 2009, of which 83.3% of the waste was reused or recycled i.e.

43.9% of hazardous waste and 95.26% of non-hazardous waste.

Non-hazardous waste generated in 2008/2009 included aluminium cans, glass, dry

mixed recyclables (plastic & paper), timber, rockwool insulation, cardboard, green

waste, scrap ferrous metal and mixed commercial waste. The list of hazardous

materials generated in 2008/2009 included contaminated packaging, waste oil, oil-

contaminated material, asbestos waste, oil / water mix, oil filters, lead-acid batteries,

fire-fighting foam, empty oil barrels, fluorescent tubes and adhesive.

A new bunded barrel store was installed in 2009 for the temporary storage of solid

oily waste in drums, empty/near empty drums and disused oil filters while awaiting

collection for disposal. Dry cell battery collection boxes were placed in workshops

and canteen to provide for segregation of this waste stream.

There is one general Waste Management procedure (EMS 9.2-01) and each type of

waste is subject to its own specific procedure (EMS 9.2-02 to EMS 9.2-30). All waste

is disposed of using licensed contractors agreed by the EPA. Depending on the

contract, contractors are either responsible for their own waste removal and disposal

or may use the Station’s own waste disposal facilities.

2.2.10 Management of Change

The means of identifying potential hazards, including environmental impacts,

associated with a modification or change to existing operations is detailed in the

procedures PGTS 15/22 Safety in Plant Modifications and EMS 9.1-06 Consideration

of Environmental Aspects of Plant Modifications. These employ a Plant Modification

Checklist with the aim of ensuring that all associated risks and resultant hazards

which could potentially give rise to an accident are identified and evaluated prior to

implementation of any change.

2.2.11 Emergency Planning

Emergency procedures detail:

Roles and responsibilities,

Procedures for evacuation,

Procedures for reporting emergencies,

Procedures for making plant safe,

Procedures for handover to fire brigade,

Maintenance of fire water systems and water and foam supplies,

Training,

Drills.

Emergency procedures are reviewed regularly and following major plant

modifications. The Plant Manager co-ordinates quarterly drills. Marina maintains an

on-going monitoring programme which consists of the following controls:

Weekly checks are carried out for the presence of liquids in bunds and

sumps, bund drain valves, spills, seepage from traffos and bottled gas

compounds and the contents of the site’s three spill kits;

An Accident/Incident Investigation Standard (PGTS 38/22) is in place to

identify root causes with a view to preventing similar occurrences in the

future;

An OHSAS 18001-certified safety management system is operated on site;

Internal, external and environmental audits

The station's fire fighting system consists of an electric and a diesel powered pump

both of which are rated at 1.6 m3 / minute.

2.3 Emissions

2.3.1 Introduction

There is a comprehensive system of Preventive Maintenance (PM) carried out for

most plant and equipment items including all of those that play a part in

environmental protection. Dedicated PM tasks (CMMS Standard Work Order Cards

or SWOCs) for plant and equipment purely provided for the purposes of

environmental protection and minimizing environmental impact are tagged with the

‘ENVIR’ label and are given priority codes to reflect their relative importance i.e. A,

B or C. A system of corrective or breakdown maintenance runs in tandem with the

PM policy for situations where plant or equipment is subject to deterioration,

imminent failure or breakdown.

Maintenance staff also keep a lookout for potential environmental problems or plant

deterioration such as abnormalities in environmental control equipment, drips from oil

pipe joints, liquid in bunds, evidence of oil staining under a transformer etc. (see EMS

9.1-03 Maintenance of Power Plant to Minimise Environmental Impact).

2.3.2 Air Emissions

There is one licensed emission to atmosphere point at Marina (A1-1 GT Exhaust

Stack) which is monitored in accordance with Schedule B of the station’s IPPC

Licence. The main atmospheric emissions are the greenhouse gas carbon dioxide

(CO2), water (H2O), nitrogen oxides (NOx) and carbon monoxide (CO) when firing on

natural gas and the same plus some small emissions of particulates and SO2 when

firing on gas oil. Gas oil combustion is controlled by national legislation limiting

sulphur content, so gas oil used at Marina is purchased to a legal product specification

limiting S content to less than 0.1%.

The important greenhouse gases from the combustion of fossil fuels are carbon

dioxide (CO2) and nitrous oxide (N2O) with large combustion plants worldwide

responsible for about one-third of all CO2 emissions. CO2 emission is directly related

to the carbon content of the fuels so that gaseous fuels have significantly lower

emissions than other fossil fuels. Thermal efficiency was 30.72% in 2009 down from

38.75% in 2008. The efficiency in 2009 was down to periods of open cycle operation

during the summer of 2009 and also the permanent conversion to open cycle operation

from September 2009. Air inlet pre-filters and fine filters were changed out during

October 2009 to improve performance of the gas turbine.

During 2009, the GT started 237 times, most typically in a 2 shift running pattern for

5 to 6 days per week, interspersed with some 24 hour running for 3,337 operating

hours. 99% of the electrical energy produced in 2009 was from natural gas only as

only a tiny amount of gas oil was used i.e. 776,894 MWH of natural gas and 97 MWH

of gas oil. Total CO2 produced was 158,412 tonnes while total NOx amounted to 500

tonnes.

The station’s Continuous Emissions Monitoring System (CEMS) was

decommissioned in October 2009 and replaced with a PEMS system. Performance

testing of the PEMS was carried out by ESB staff and a full QAL2 test has been

carried out to ensure that measurement accuracy is within required limits.

In open cycle operation dispersion is greatly increased due to the increased

temperature and discharge velocity of the combustion gases and modelling of this

increased dispersion predicted a reduction of impact of approximately 50% with

regard to hourly 99.8%ile NOx values. A NO2 ambient air quality monitor has been in

place at Montenotte since 2003. Data from this is used in combination with Met

Eireann wind speed and direction and plant operation data to identify any adverse

impacts. This monitoring has identified that Marina does not have a significant

detrimental effect on the air quality within the Cork city area with average and peak

NO2 values significantly below relevant air quality standards.

2.3.3 Water Consumption and Emissions

Water consumption stood at 30,703 m3 in 2008 and 31,092 m3 in 2009. This is

expected to decrease significantly for 2010 with the decommissioning of the heat

recovery element. A reserve tank of 675 m3 of town water is situated next to the Gas

Turbine. Water for domestic use and for auxiliary plant cooling requirements is also

stored in roof tanks on A Station boiler house roof (1 x 13 m3 & 1 x 5m3 respectively).

There are no emissions to municipal sewers from the ESB Marina site but there are

four licensed water emission points at Marina Generating Station (SW3 -

Neutralisation Tank effluent), SW4 (Interceptor 2 - surface water, process water, town

water), SW6 (Cooling Water Outfall - river water)) and SW7 (Interceptor 3 - surface

water, process water and boiler blowdown effluent). Interceptors are monitored

visually each week. Interceptor 1, 2, 3, 4 have quarterly mineral oil tests carried out

while Interceptors 2, 3, 4 also have quarterly suspended solids analysis done. SW3

and SW6 are no longer operational with the removal of the heat recovery element.

Reference to these is to be removed from the licence conditions.

There are also three licensed stormwater emission form the site i.e. SW2 receiving

waters through Interceptor 1 (process water, town water, river water, surface water)),

SW8 from Interceptor 4 (surface water) and SW9 (Access Road (surface water))

monitored weekly visually for colour and odour.

Four groundwater monitoring stations - AGW1 (driveway), AGW2 (SE of GT),

AGW3 (rear of boiler house) and AGW4 (wharf) - are tested twice yearly for pH,

COD, nitrate, total ammonia, total nitrogen, conductivity, chloride, cyanide, PAH and

total chloriforms.

Hazardous materials especially all bulk chemicals and wastes are stored in designated

locations protected against spillage. Chemical drum storage is on dedicated storage

racks that incorporate bunds. The drainage system, bunds, silt traps and oil

interceptors are inspected weekly in accordance with an Environmental Checklist.

Any sludge such as sewage sludge or sludge at the bottom of interceptors is removed

or de-sludged as necessary.

2.3.4 Noise EmissionsNoise and vibration are common issues arising from the operation of large

combustion plants especially gas turbines which have the potential for high noise

emissions. Environmental noise surveys carried out at the boundaries of the site in

November 2008 and December 2009 confirmed the station was within its licence

limits of 55 dB(A) during daytime hours and 45 dB(A) at night with no tonal

components present.

2.4 Ecological Description

2.4.1 River Lee

The Marina site is situated beside the River Lee runs into the Cork harbour area with

1,436 hectare of intertidal habitat designated as a Special Protection Area (SPA). The

River Lee is also important for salmon fishing although the waters directly outside the

generating station are not designated as salmonid waters. ESB commissioned Irish

Hydrodata Ltd to complete a thermal plume study which showed that even under

worst-case conditions (neap tide and dump condenser in operation), that the plume

was minimal and has negligible impact on fish movements, which was corroborated

by fisheries census work.

With the decommissioning of the boiler and heat recovery unit discharges are

confined to surface water runoff. Phosphate and ammonia releases ceased in

September 2009.

2.4.2 Groundwater/Soil

An ESBI Groundwater Monitoring Study was carried out for the period 2003 to 2004.

This found groundwater samples were generally cloudy as the result of fines

mobilisation arising from groundwater recharge. Elevated conductivities and chlorides

associated with borehole AGW-3 were considered to result from the influence of the

brackish waters of the Lee. Groundwater was also found to be contaminated with

ammoniacal nitrogen and coliforms which are unrelated to the site’s activities.

Consequently, these were considered to reflect background urban levels associated

with foulwater losses or fertilizers lost from a storage site nearby. The station and its

activities were not considered to be having an adverse impact on soil or groundwater

quality.

2.5 Inventory of site plant and equipment

The current main operational features of the station include the following (a more

complete list of large plant components and equipment is provided in Appendix 6):

One GE/Alstom 85 MW Frame 9B combustion turbine and Alstom

generator

One (decommissioned) CMI exhaust gas heat recovery steam generator

(HRSG)

A refurbished (but decommissioned) Siemens 30 MW steam

turbine/generator

2 decommissioned steam turbines, one 30MW and one 60MW

Two stacks

Water treatment plant (WTP) including bulk chemical storage tanks for

processing of towns water prior to its use in the boiler (decommissioned)

A (decommissioned) neutralisation plant for treating water treatment

effluents

Generator, unit and house transformers

Electrical compound and associated overhead line and cables

A decommissioned, cooling water system comprising pumphouse, inlet and

outlet culverts, and discharge weir, for condenser cooling

Dump condenser and associated plant (decommissioned)

Supporting facilities including the following:

Administrative offices and canteen (canteen now closed)

Chemical laboratory

Water storage tank

Fire protection pumphouse

One workshop and stores

2.6 Historical Record

ESB Marina Generating Station was established in 1954. The station’s original

configuration was a 120 MW capacity coal/oil-fired thermal plant, developed in two

stages. Station A comprised two 30MW coal fired units commissioned in 1954.

Station B comprised a single 60MW unit commissioned in 1964 and subsequently

decommissioned but not dismantled. In 1979 the current 85 MW combined cycle gas

turbine (CCGT) was commissioned. The station converted to oil in 1958 and then to

natural gas in 1979. The three A station boilers were dismantled in 1995.

It was replaced in the early ‘80s to produce a total electricity generating capacity of

115 megawatts (MW) comprised of an 85MW combustion turbine and a waste

recovery boiler which feeds steam to a 30MW steam turbines which formed part of

the original A station. The heat recovery element has now been decommissioned and

maximum output is now 94 MW.

The CT is fired on natural gas supplied from the national gas network. The CT can

also burn gasoil as a standby fuel and that is supplied from the National Oil Reserve

Agency (NORA) storage site adjacent to the station via a dedicated underground

pipeline. Marina’s role has moved to being that of a 2-shifting mid-merit plant at

times of high system demand or a support role in times of system emergency and

operates as open cycle peaking plant, with a lower annual load factor of 5 to 10% and

reduced operating hours. A number of incidents have occurred in the past. These are

discussed in detail in section 4.1.5

3.0 Step 1: Initial Screening and Operational Risk Assessment

3.1 Introduction

A closure plan or Closure, Restoration and Aftercare Management Plan (CRAMP)

provides costings that deal with site decommissioning and known liabilities for the

facility at closure while an Environmental Liability Risk Assessment (ELRA)

considers the risk of unplanned events occurring during the operation of a facility that

could result in unknown liabilities materialising. An initial risk assessment was

carried out in order to categorise Aghada Generating Station as being of risk Category

1, 2 or 3 to identify the suitable CRAMP/ELRA approach for the facility.

A relatively simple risk assessment decision matrix is employed that relies on the use

of the three key aspects of Complexity, Environmental Sensitivity and Pollution

Record.

3.1.1 Complexity

A complexity banding indicates the extent and magnitude of potential hazards

according to the class of activity. This ranges from G1 (least complex) to G5 (most

complex). Marina is classed in section 2 Energy:

2.1 The production of energy in combustion plant the rated thermal input

of which is equal to or greater than 50 MW.

As a generating station producing approximately 1000 megawatts a year it is rated G4

making it automatically a Category 3 risk (see Table 3.1 below) thereby invalidating

the need to complete an initial screening.

Table 3.1. Risk Category.

Risk Category Total Score

Category 1 <5

Category 2 5-23

Category 3 >23

A CRAMP for a Category 3 facility such as Marina, may require, either due to the

nature of the operation (e.g. mining and landfill) or due to the presence of significant

land contamination, a process of extensive restoration and aftercare. This period

would typically include on-going restoration/remediation works, contaminated land

remediation/management and long term monitoring. However, where category 3

facilities (excluding mining and landfill) have demonstrated by way of previous

investigations that long term liabilities are not present, the requirements for RAMP

will be reduced.

The ELRA for a Category 3-risk facility requires a detailed site-specific approach, the

objectives of which are generally:

To identify and quantify environmental liabilities at the facility focusing on

unplanned but possible and plausible events occurring during the operational

phase;

To calculate the value of financial provisions required to cover unknown

liabilities;

To identify suitable financial instruments to cover each of the financial

provisions; and

To provide a mechanism to encourage continuous environmental improvement

through the management of potential environmental risks.

3.1.2 Environmental Sensitivity

The sensitivity of the receiving environment in the vicinity of the facility is evaluated

using an environmental sensitivity sub-matrix which assesses six key environmental

receptors: Human Beings, Groundwater, Surface Water, Air Quality, Protected

Ecological Sites, and Sensitive Agricultural Receptors (see Table 3.2). A score is

applied to each receptor (more sensitive locations receiving a higher score) and these

scores are added to obtain an environmental attribute score. The score is then

classified as Low, Medium or High by checking against a pre-defined Environmental

Sensitivity Classification Table (see Table 3.2).

Although this step, and the steps described in 3.1.3 Pollution Record and 3.1.4

Classification of Risk are not required, due to the fact that Aghada is automatically

classed as a Category 3 facility because of its G4 rating, these sections and the

completed Table 3.2 are useful for completion of the risk assessment process

described in sections 3.2 and 3.3.

Table 3.2. Environmental Sensitivity Sub-Matrix.

Environmental Attribute Environmental Attribute Score

Human Occupation

<50m

50-250m

250-1000m

>1km

Scoring System

5

3

1

0

Plant Score

3

Groundwater Protection

Regionally important aquifer

Locally important aquifer

Poor Aquifer

Vulnerability Rating-Extreme

Vulnerability Rating-High

Vulnerability Rating-Moderate

Vulnerability Rating-Low

2

1

0

3

2

1

0

0

0

Sensitivity of Receiving Waters

Class A

Class B

Class C

Class D

Designated Coastal & Estuarine Waters:

Potentially Eutrophic Coastal & Estuarine Waters:

3

2

1

0

2

1

1*

0

Air Quality and Topography

Complex Terrain

Intermediate Terrain

Simple Terrain

2

1

0

1

Protected Ecological Sites

Within or directly bordering protected site 2

<1km to protected site

>1km to protected site

1

0

0

Sensitive Agricultural Receptors

Fruit, vegetable or dairy farming <50m from site

boundary

Fruit, vegetable or dairy farming 50-150m from site

boundary

Fruit, vegetable or dairy farming >150m from site

boundary

2

1

0

0

Total Environmental Attribute Score: 5

* The EPA have classified Cork Harbour water quality as “intermediate”.

** Intermediate terrain where the elevations of receptors lie between the stack tip elevation and the plume rise elevation,

US EPA (2000) Meteorological Monitoring Guidance for Regulatory Modelling Applications.

Table 3.2. Environmental Sensitivity Classification.

Total Environmental Attribute Score Environmental Sensitivity Classification

Low <7 1

Moderate 7-12 2

High >12 3

The result is 5 or Low (<7) for the station giving it an Environmental Sensitivity

Classification of 2.

3.1.3 Pollution RecordThis is based on the facility’s compliance record and whether significant ground

contamination is present below the facility. Marina Generating Station has had no

complaints and one non-compliance in the past 12 month period - a category 3

incident where an oil leak occurred in the gas turbine steel engine compartment on

09/12/2009. Prompt action by staff ensures that no pollution occurred. A more

significant oil spill occurred in 2003 after which an immediate containment and clean

up operation was carried out, despite which 1000 to 1500 litres of oil was

unaccounted for and may have been released to soil/groundwater. Consequently, the

facility is classed as being minor non-compliant and has a compliance record score of

3 (i.e. Licensed facilities with minor emission non-compliances (< 5 non-compliances

in a 12 month period) are classified as being Minor Non-Compliant and have a score

of 3. Facilities with minor soil and groundwater contamination (i.e. those with

concentrations above background but not posing risk to the environment) are also

considered in the class).

3.1.4 Classification of RiskScores for each of the three aspects – Complexity, Environmental Sensitivity and

Pollution Record - are then multiplied together to give the total score which is read

against the score banding in Risk Category Table (see Table 3.1) to classify the

facility as being low, medium or high risk. The score for the site is:

4 x 1 x 3 = 12

This would classify the site as a Category 2 risk although it is automatically classified

as Category 3 due to its energy generation capacity.

4.0 Step 2: Closure, Restoration, Aftercare Management

Plan (CRAMP) – Known Liabilities

4.1 Site Evaluation

4.1.1 Site Description

A description of the station and its features is given in section 2.1 and an image of the

site layout is given in Figure 1.

4.1.2 Plant and Materials

The site stores a variety of coded items and materials that are used in operations and

maintenance activities, most of which are of little or no environmental significance. A

full list of maximum quantities of chemicals on site is given in Appendix 1 while a

description of the storage and locations of oils is found in section 2.2.9 and a full

description in Appendix 2. Actual quantities remaining at shut-down would likely be

much less due to scaling down of activities prior to closure, allowing a staged

reduction in inventory. Plant and equipment remaining on site at the time of

decommissioning will be sold on to suitable customers. Where this is not feasible they

will be disposed of through the company’s list of registered waste disposal

contractors.

4.1.3 Waste materials

A summary of waste materials and waste generation over the last three years is

presented in section 2.2.9 and a rough inventory of site plant and equipment is given

in section 2.5 with a list of larger equipment given in Appendix 3. The amount of

wastes generated will increase significantly during implementation of the RMP with

the following being of particular note:

Batteries,

Waste lubricating oils,

Waste transformer oils,

Waste chemicals,

WEEE.

Soft stripping of buildings prior to demolition will also generate some of the

following types of items which may be recycled or reused:

Fittings,

Fixtures,

Furniture,

Blinds,

Heaters,

Dryers,

Light switches and sockets,

Piping.

Additional hazardous wastes that may arise during decommissioning would be as

follows:

Smoke detectors,

Chemical paints and additives,

Coolants (spent machine),

Refractory brick from the station chimney,

Silica gel.

Wastes arising during decommissioning will be managed in accordance with

Condition 8 of IPPC Licence Reg. N° 719.

4.1.4 Asbestos

Asbestos was used extensively in the original development at Marina, but all lagging

containing asbestos was removed where known and accessible during an Asbestos

Removal Programme carried out in 2002 to remove all asbestos from A and B station

boilers. There are residual areas where encapsulated asbestos has not yet been

removed, most notably the external cladding to the ‘B’ Station boiler. Asbestos was

not used extensively in the redevelopment of Marina as a CCGT power plant and all

insulating materials that were used are non-asbestos fibres. However, minor amounts

of asbestos may also still be incorporated in certain small items such as gaskets and

gland packing. Consequently, large-scale removal of asbestos insulation and lagging

from the plant will not arise during decommissioning.

4.1.5 Environmental Incidents

In 1981 an incident involving the unloading of two drums of liquid chlorine occurred

when a leak was detected in one of the drums. This was satisfactorily controlled. A

release of weak acid to drain also occurred in 1992 during an acid wash of boiler

tubes and headers. Lime was used to neutralise the leakage before eventual discharge

to the river.

An environmental assessment carried out by ESBI in 1998 detected levels of Poly-

aromatic Hydrocarbon (PAH) contamination at borehole number 2. This was thought

to have arisen from historical storage of coals outside of the licensed area. However,

coals have not been stored there since 1979. The report indicated that PAH would be

expected to disintegrate over time and that levels would approach near background

levels. This assessment also identified potassium cyanide contamination at borehole

number 1 (AGW-1). This contamination was thought to have originated from sources

off-site and since then levels have since declined to <0.05 mg/l. Other exceedences

which may occur in the boreholes e.g. coliforms, chlorides, nitrates etc. are also

believed to originate off-site as there are no sources of these materials on-site.

In 2003 a spill resulted in the release to soils of approximately 1,000 to 1,500 litres of

lubrication oil. This oil is less dense than water, highly viscous, non-volatile and

biodegradable. A study was carried out to determine the consequences of this spill

(ESBI “Combustion Turbine Oil Spill Desk Study”) which concluded that the oil was

unlikely to reach the surface water drainage system and is more likely to have been

taken up by soils under the spill site. It considered that the retention capacity of the

soils along the route from the oil spill to the River Lee might be as high as 5,700 litres

which exceeded the volume of oil spilt.

There were two category three incidents in 2006 and one incident in 2008 and 2009

respectively. All of these were light to moderate oil spills which were successfully

dealt with by site staff to prevent any pollution.

Consequently, any contamination that has arisen as a result of the above incidents has

been dealt with satisfactorily and there is no ongoing impact on station lands.

4.1.6 Long-term Liabilities

The screening process identifies the site as a Category 3 facility making a Restoration

and Aftercare Management Plan including on-going restoration/remediation works,

contaminated land remediation/management and long term monitoring, in addition to

the compulsory Closure Plan. However, as the site has demonstrated by way of

previous investigations that long-term liabilities are not present, these RAMP

requirements should be reduced. Furthermore, the environmental monitoring

programme conducted at Marina is carried out in accordance with the requirements of

Condition 6.1 of its licence. Monitoring in accordance with Schedules B and C is

designed to identify any impacts associated with operation of the station so as to allow

effective remedial action or minimise environmental pollution.

Current knowledge concerning the long-term environmental liability associated with

the site and full compliance with IPPC Licence Reg. N° 719 is expected to ensure that

any additional liabilities will be avoided. Consequently, a significant soil and

groundwater programme at station decommissioning is not anticipated beyond that

which is already carried out as per Schedule C of the licence.

4.2 Closure Considerations

4.2.1 Introduction

The energy market is currently very volatile and the anticipated reduced usage

patterns of the site have not yet materialised so that there are currently no plans or

dates for closure. It is also considered that given its historical landmark status it is

unlikely that the site would be demolished, however, this RMP considers restoration

of the site to an anticipated industrial end use which includes demolition of the

existing building structure. Should no major incidents occur between now and any

future closure date, a clean closure is envisaged for the site. With the inactivation of

the HRSG, steam turbine, water treatment plant and cooling water facility, from an

environmental risk perspective, much of the more significant decommissioning work,

has already been completed.

4.2.2 Closure Exclusions

The structural form of station buildings is conventional structural steel supported on

reinforced concrete foundations. Gantries and walkways for access to plant and

equipment are constructed of stainless/galvanised steel open grating type flooring.

These are supported on steel beams and columns. External walls predominantly

comprise brickwork with some profiled metal cladding and asbestos sheeting (‘B’

Station boiler house). Roofs are constructed of profiled metal decking on purlins

spanning between rafters. The materials used do not pose any environmental threat in

the event of station closure, whether they are demolished or remain in place.

Certain station areas will continue to operate or remain operational. These include

facilities such as the 300 litre diesel tank supplying the diesel engine-powered fire

pump in the fire protection pumphouse. Services that are performed by contractors on

an ongoing basis include the following: hygiene services, general building work,

waste disposal service, rodent control, laundry, lagging, tool hire and specialist

welding. These activities have no implication for the RMP.

All equipment and plant at Marina is the property of the station, other than the

following:

Cylinders in which bottled gas is delivered are the property of the supplier,

who will be responsible for their removal;

The 110 kV compound, including network transformers and associated

cabling, are the property of ESB Networks.

4.2.3 Criteria for Successful Decommissioning

ESB has already successfully decommissioned a number of power stations on the

above basis in the past at Miltown Malbay, Screeb, Gweedore, Allenwood,

Portarlington, Ringsend and Ferbane as well as the HRSG, steam turbine, WTP and

cooling water facility in 2009. Since commissioning of its first unit in the 1950s, the

presence of Marina Generating Station has not resulted in significant environmental

impacts and the station will continue to be operated in a responsible manner. Issues

that are likely to arise upon closure at Marina have all been dealt with successfully in

the past at other ESB sites.

Successful clean closure will be achieved when it can be demonstrated that there are

no remaining environmental liabilities at the site. In practice, this will require

demonstration that the following criteria have been met:

The appropriate decontamination of all plant and equipment using standard

procedures and authorised contractors;

Documented reports of all raw materials dispatched from the site;

All wastes handled, packaged, temporarily stored and disposed or recovered in

a manner which complies with regulatory requirements;

All relevant records relating to waste and materials movement and transfer or

disposal are managed and retained throughout the closure process;

Clearance and documentation indicating final disposal for any asbestos found

to be present in the station.

Documented post-closure soil and groundwater programmes if this need

arises;

The Environmental Management System remains in place and is actively

implemented during the closure period;

Secure archiving of all documentation.

Furthermore, the areas occupied by all/relevant facilities and ancillary areas will be

decommissioned and rehabilitated to a condition where are no constraints on future

land use due to residual contamination or structures. Materials will be treated in such

a manner that:

Equipment and uncontaminated materials will be resold or reused;

Uncontaminated materials that cannot be reused will be recycled;

Contaminated or unrecyclable materials will be disposed of using authorised

waste contractors.

The overall objective is for clean closure of the site with no residual liabilities or

constraints.

4.3 Implementation of RMP

4.3.1 Strategy

ESB intends to manage and execute the RMP using internal resources, supplemented

as necessary and appropriate with external resources. All external resources used for

cleaning, waste disposal, etc. will be fully approved and licensed as appropriate.

A Residuals Management Team will be created to manage and execute the entire

project and key activities will be supervised by personnel with appropriate experience

and expertise. Only suitably qualified personnel will carry out decontamination

works.

Options that will be available with regard to various residuals are broadly as follows:

Reuse - removal for reuse at other ESB power station(s) or return to supplier

Recovery / recycling - sale to third-party

Disposal - final disposal as waste

Waste sent off-site for recovery / recycling or disposal will only be conveyed to

licensed waste contractors and carriers.

4.3.2 RMP General Activities

The activities within the scope of the RMP are as follows:

Cessation of all energy production;

Cancellation of all incoming deliveries of materials to the station;

Termination of all contracts other than those that are concerned with the

RMP or related to safety of personnel or the environment;

Return of materials to suppliers where possible, for resale or reuse;

Isolation and purging of transfer lines from bulk storage to direct pipe

contents back to bulk storage;

Shutting and blanking of supply lines from bulk storage for chemicals to

intermediate storage;

Cleaning and decontamination of all plant and equipment;

Cleaning, decontamination and inspection of bunds, sumps and underground

drains;

Removal of old and obsolete equipment and destocking of the workshops and

stores;

Isolation and disconnection of all electrical supplies to pumps and motors;

Draining of oil from obsolete transformers that cannot be reused elsewhere;

Decommissioning of redundant oil-filled cables and draining of header tanks

and sealing ends;

Cleaning of residues from the boiler and cleaning and blanking off of fuel

lines;

Draining and cleaning of lube oil systems;

Draining of water systems such as raw feedwater tanks, condensate storage

tanks and supplementary cooling systems (carried out in 2009);

Transfer of ion exchange resins to drum storage (carried out in 2009);

Maintenance of parts of the water supply system to provide wash-down and

cleaning facilities during decommissioning and to meet the ongoing needs

for fire protection and sanitary services;

Maintenance of site drainage system and oil interceptors during

decommissioning activities;

Ultimate removal and appropriate disposal of biological filters for foul

effluent;

Secure archiving of all relevant documentation including drawings,

instrumentation diagrams, validation documentation, vendor manuals and

data, project files, maintenance records, inspection records, waste disposal

records and other appropriate documentation;

Maintenance of defined site access procedures and security requirements for

ongoing monitoring of the site from safety, fire protection and environmental

perspectives.

It is anticipated that any necessary decontamination of plant and equipment will be

carried out on site. It will primarily involve cleaning in situ and power washing of

internal and external surfaces. ESB will seek approval from the Agency for any

decontamination procedures and monitoring requirements to be employed. An

appropriate disposal route for all wash waters generated during decommissioning will

be agreed with the Agency prior to disposal.

4.3.3 Decommissioning

4.3.3.1 Decontamination Works

Tanks, pipes, drains and sumps are all regularly tested in accordance with internal

EMS procedures so they will be in good condition (EMS 9.1-04 Maintenance of

Drains, Sewers and Effluent Pipe Lines). An assessment of the level of contamination

will be made for residues or materials including fuels, oils, greases and process

reagents/chemicals. All contaminants will be removed, drained or flushed from

all/relevant plant, tanks and pipelines and residues containing fuels, oils and other

contaminants will be removed off-site for recovery or disposal. All/relevant buildings,

structures, plant and surfaces will be hosed down or flushed out with high pressure

water and treated in the effluent treatment plant if necessary. Any areas of

soil/groundwater with visual contamination will be excavated directly for off-site

treatment and risk assessments will be conducted to establish the most suitable

method of remediation.

4.3.3.2 Residual Liquid Fuel, Tankage and Pipelines

The station's own storage of diesel is limited to small capacity tanks serving diesel

powered items of equipment such as the fire protection pumphouse. Plastic tanks of

small capacity are in use for waste oils. The maximum quantity of liquid fuel will be

used prior to the cessation of power generation so that the minimum quantity remains

on site. Where possible, all pipelines and tanks will be drained using on-site pumps to

“loss of suction” to minimise the remaining residues within tanks and pipework.

Drains in the areas where these facilities are located will be isolated before

commencement of decommissioning activity.

Tankage: The most effective method for cleaning of tanks will be to absorb residues

by scrubbing / flushing. The dissolved liquid will then be pumped to a tanker for

treatment and re-separation and the tank will be jet washed with water / detergent to

remove remaining residues. The tanks will then be suitable for removal for clean

scrapping.

Pipelines: Where necessary, pipework will be cleaned by a variety of methods

including an in-situ pneumatic pipe cleaner / scourer machine (a ‘pig’), retro-jetting

with water, flushing with water or kerosene, or high-pressure air flushing. At this

stage of cleaning the pipework will be in an acceptable state for either retention on

site or removal for clean scrapping.

4.3.3.3 Residual Chemicals and Chemical Storage Tank Cleaning

The main bulk chemicals used at the station and associated tanks have been

decommissioned and removed from site. The use of wet chemistry in the station

laboratory was eliminated with the closure of the lab in September 2009..

4.3.3.4 Drainage Line Cleaning

The discharges of concern are:

• SW2 - Surface Water/Station Drainage





The above are protected by oil interceptors as appropriate and there is no potential for

impact upon the receiving environment if the drainage system is left in place after

decommissioning. However, cleaning of station drains will be required to mitigate the

potential for oil residues to be present within pipelines. This will involve cleaning

down the drainage system using water jetting, utilising the existing oil interceptor

system and vacuum tankers. Oil interceptors will be cleaned down and all waste and

effluent will be removed for appropriate disposal. No areas of heavy or free product

oil residues that would require steam cleaning are expected. On completion of

decommissioning the site drainage will be in a suitable condition for removal or more

likely to be left in place to continue to provide surface water drainage for the site. The

station will continue to properly operate and maintain the site drainage system prior to

and during implementation of the RMP.

4.3.3.5 Tanks & Sumps

The only remaining notable tank and sump within the station is the turbine lubrication

oil tank associated with the combustion turbine. All waste will be removed from the

above for appropriate disposal and tanks, sumps and associated pipework cleaned

down and decommissioned.

4.3.3.6 Plant Disposal

Mobile plant items include one forklift, several pallet trucks and one van for

movement of materials around site. Fixed plant items and material containers are

listed in Appendix 3. Plant services including pipes and cabling with the majority of

pipelines and transfer lines above ground and welded where reasonably practicable.

All the above will be drained of oils/chemicals and/or decontaminated where

necessary and reused or sold for scrap.

4.4 Building Demolition

4.4.1 Introduction

There will be a logical sequence of demolition works. Due to the unforeseeable nature

of any future demolition work a demolition programme cannot be drawn up.

However, best practice guidelines will be used to draw up a waste management plans

for the Construction and Demolition work which will be carried out under the control

of a C&D Waste Manager. This will address the following aspects of any demolition

project:

Analysis of the waste arisings / material surpluses (pre-

demolition/reclamation audit);

Specific waste management objectives for the project (material recovery

targets);

Methods proposed for the prevention, reuse and recycling of wastes (soft

stripping of reusable items, recycling of non-reusable items, disposal of non-

recyclables);

Material handling processes (degree of segregation, use of crushers and

screeners for aggregate preparation etc.); and

Proposals for education of workforce and plan dissemination programme.

Such a plan will maximise waste prevention and minimisation and ensure demolition

debris is segregated into steelwork, masonry and other materials to maximise the

possibilities for reuse, ideally on site or less preferably, recycling. Disposal will only

be considered as a last resort.

A coherent Demolition Plan will also constitute an integral part of the project C&D

Waste Management Plan to ensure that the sequence of operations to be followed is

predetermined and documented to ensure that an appropriately selected

dismantling/demolition methodology is employed. This will also pay special attention

to the sorting/segregation arrangements to be followed.

4.4.2 Removal of Infrastructure and Services

All drainage and associated services will be carefully removed along with all roads,

hardstand areas and other infrastructure. Decontamination will be carried out as

previously outlined if necessary. As for demolition works, the specific requirements

for infrastructure removal are impossible to foresee so a detailed sequential

programme of removal cannot be produced.

4.4.3 Material and Residues

Provision will be made for the appropriate and authorised disposal of the following:

Process chemicals, reagents and food substances;

Laboratory reagents;

Fuels and oils;

Operational equipment wastes;

Wastewater treatment sludges;

Soil or spoil.

4.4.4 Demolition Nuisance Mitigation

Any demolition works that are carried out in connection with or associated with the

RMP have the potential to lead to elevated noise levels and to creation of dust.

Additional traffic movements will also arise. The following mitigation measures are

proposed:

Noise: All works will be carried out during daylight hours and noise levels

will monitored to ensure compliance with the requirements set out in condition

8 of IPPC Licence Reg. N° 734. Noise minimisation measures will be

employed. These will include such measures as using saw-cutting machinery

instead of rock breaking equipment;

Dust: Surfaces that have the potential to generate dust during their demolition

will be wetted prior to the work commencing. Demolition on windy days will

be avoided as far as possible;

Traffic: While traffic will arise in the removal from site of residuals, this will

coincide with the elimination of current sources of traffic associated with

station operations. It is considered that the demolition related traffic will not

pose undue difficulties.


ESB has a very significant working capital and any decommissioning or closure of

Marina would be a well resourced activity. The company has adequate resources of

finance and manpower to implement the RMP through to completion. More

significantly, ESB makes specific financial provision for closure of its power stations

and this is outlined in the company’s annual accounts. This figure represents the

present value of the current estimate of the costs for closure of generating stations

including Marina at the end of their useful economic life. These costs are recognised

in full at the outset of the asset life, but are discounted to present values using a risk

free rate.

Since the costs are capitalised and initially provided on a discounted basis, the

provision is increased each year by a financing change. This is calculated based on the

provision balance and is included in ESB’s profit and loss account. In this way the

provision equals the estimated closure costs.

Further to the above, Marina covers a significant area in a central location and being

an industrial site it has considerable potential for redevelopment and would be

expected to constitute a considerable asset following decommissioning. Furthermore,

much of the plant and equipment will have significant residual value. The value of the

site and its plant and equipment alone provides a fund that greatly exceeds the

potential costs of decommissioning.

Specific costings have not been developed for the RMP at Marina. However, it is

evident from the limited number of issues that required inclusion in the scope of the

RMP that the company’s financial provisions and the value of the assets at Marina are

orders of magnitude greater than the costs that may be incurred. Estimates of

projected costs associated with site closure are outlined in Table 4.1 below.

In the event of demolition works, a detailed Project C&D Waste Management Plan

will be drawn up as outlined in Section 4.4. Costs in this case will be contingent on a

number of factors including space and time constraints, local authority conditions

attached to the work, material recovery targets imposed by future legislation and

available markets for reuse and recycling.

In the event of demolition works, a detailed Project C&D Waste Management Plan

will be drawn up as outlined in Section 4.4. Costs in this case will be contingent on a

number of factors including space and time constraints, local authority conditions

attached to the work, material recovery targets imposed by future legislation and

available markets for reuse and recycling.

Table 4. RMP Costings.Item Removal CostBuilding demolition 1,000,000Asbestos removal & disposal 15,000Surfaces removal e.g. hardstandings, roads etc. 60,000Pipework (water and sewers) 190,000Electrical services 200,000Security enclosures Already in placeMobile plant 20,000Decommissioning plant 110,000Landscaping and re-contouring 150,000Off-site waste disposal e.g. pipework, oils, equipment etc.

80,000

Power consumption during decommissioning 5,000Engineering construction management during decommissioning

50,000

Facility security & staffing 30,000Test Programme 5,000Environmental Monitoring 5,000Reporting to EPA 3,000Verification Audit/Certification 1,500Hydrogeological site investigation 30,000Subtotal 1,954,500Contingency (25%) 488,625Total (excl. VAT) 2,443,125

Cost components for demolition waste management can be broken down into:

Purchase cost of waste materials;

Handling costs;

Storage and transportation costs;

Revenue generated from sales of reusable/recyclable materials;

Disposal costs including landfill tax.

This will enable proper estimation of total waste concrete, soil and masonry

management costs.

4.7 Closure Plan Update & Review

The RMP is reviewed annually as part of the AER. This review aims to address any

developments at Marina and evaluate the scope of the RMP in the context of any

environmental incidents at the station to update the RMP as necessary. The updated

and reviewed Plan will take account of any relevant changes in site processes,

technology and/or costs.

4.8 Closure Plan Implementation

4.8.1 Notification of Regulatory Authorities

The EPA and local authorities will be given 6 months notice of site closure. The form

of notice will be in accordance with prevailing guidance and on the foot of proper

consultations with the authorities as part of the process.

4.8.2 Test Programme

The monitoring and reporting requirements set out in IPPC Licence Reg. N° 719 will

be complied with in full until the licence is surrendered to the Agency. The

monitoring will identify if any contamination of air, surface water, groundwater or

soils has occurred during the lifetime of the IPPC Licence.

In the event that a future environmental incident causes contamination of these media,

which has not been quantified at the time of the closure of the facility, a specifically-

designed test programme will be established as part of the RMP to identify the nature

and scale of any associated environmental pollution. For example, such test

programmes have already been carried out in relation to the 1998 environmental

assessment and the 2003 oil leak.

Tests will be carried out on wash waters generated during the decontamination works

to confirm that they are suitable for discharge. While testing has already confirmed

that there is no reason to believe that such contamination may be present, oils will be

sampled and tested for PCB contamination.

The main monitoring requirements will relate to groundwater sampling and analysis

as per condition condition 6 of IPPC Licence. The duration of this monitoring before

the site can be considered free of contamination will be agreed with the EPA.

4.9 Closure Plan Validation

Following successful implementation of the RMP after physical closure of the

relevant sections of the site, a validation audit of all aspects relating to the affected

area(s) will be carried out by an independent auditor and a report produced to

demonstrate its successful implementation. It will confirm that there is no continuing

risk of pollution to the environment from the site. The report will address:

Disposal of materials;

Decontamination of items of plant and equipment;

Decommissioning of plant and equipment;

Results of monitoring and testing;

The need, if any, for ongoing monitoring and investigations.

The report will be submitted to the Agency within three months of completion of the

RMP.

In addition to the above validation, in line with ESB’s policy in relation to closure of

its power stations, a full environmental summary report will be prepared. This will

outline the following:

The full history of the power station site from its initial development through

to closure;

The various investigations undertaken and reports prepared during the

operation of the plant;

The actions taken in the course of the RMP.

The Environmental Summary Report will be made available to future users of the site,

whether this is ESB or a third party.

It is expected that the EPA will conduct a post closure audit of the site to satisfy itself

that the facility is fully compliant with its licence conditions at the time of closure in

order to facilitate the formal partial surrender, surrender or transfer of the licence.

4.10 Restoration and Aftercare Management Plan

Site restoration and aftercare management plans are required in the case of landfill

and mining facilities and where there is evidence of soil and groundwater

contamination or there have been spills in the past. In this instance, facilities will be

required to undertake some level of soil and groundwater investigation and risk

assessment and when contamination is detected, there will be site remediation

requirements. The purpose of remediation is to restore the soil and groundwater to a

state that does not pose a risk to the environment. This process will include a suitable

contaminated land risk assessment, which will provide recommendations and a

programme of measures. The general process for the development of a site restoration

and/or remediation proposal typically involves the following steps:

Audit of the site to identify potential sources of contamination and likelihood

of occurrence;

Soil and groundwater investigation;

Qualitative contaminated land risk assessment and conceptual site model;

Quantitative contaminated land risk assessment;

Proposals for the restoration of the site through remediation;

Agreement of the proposal with the EPA.

This scenario is not currently anticipated, however, should the need arise as a result

of some future contamination event the RMP will be revised accordingly as part of its

annual update for the AER.

5.0 Step 3: Environmental Liability Risk Assessment (ELRA) -

Unknown Liabilities

5.1 Risk Identification

The ELRA covers environmental risks leading to a potential or anticipated liability.

Environmental risks cover all risks to surface water, groundwater, atmosphere, land

and human health. There are three main areas that need to be looked at for risk

identification. These include the following:

The identification of potential environmental receptors;

The identification of processes that may be potential hazards to the

environmental receptors and the likely pathways from the source of the

hazard to the environmental receptor;

The identification of the risks related to these processes.

5.1.1 Scope of ELRA

The ELRA should cover environmental risks leading to a potential or anticipated

liability. Environmental risks are deemed to cover all risks to: surface water,

groundwater, atmosphere, land and human health.

5.1.2 Environmental Receptor Identification

Environmental receptors are those environmental media around the site that may be

affected by the ongoing processes at the facility or the failure thereof. The following

receptors were identified:

Human Beings – The site is situated 2 kilometres from the centre of Cork

city with 275,000 inhabitants. The nearest residence is just over 50 metres

from the station boundary;

Soil & Groundwater – there is no direct discharge to groundwater or soil and

activities are principally carried out on hardstand areas. The groundwater

quality is not of sufficient quality to provide an abstractable resource for

consumption;

Surface water – all surface water runoff and effluent ultimately discharges

into the River Lee and from there to Whitegate Bay and Cork Harbour;

Air Quality – air quality monitoring at Montenotte has identified no

significant degradation of air quality as a result of the station’s activities;

Flora and Fauna – principally fisheries in the River Lee and Cork Harbour

with its wader and waterfowl populations.

5.1.3 Identification of Processes

A number of processes are carried out during the operation of the plant, which may

affect the environment. These have been identified and listed below:

Instrumentation and Control Room;

Water Treatment and Cleaning Processes;

Power Generation;

Laboratory;

Chemical and Oil Delivery and Storage;

Waste Storage and Disposal.

All these processes are outlined in detail in section 2.2.

5.1.4 Identification of Risks

Where relevant, hazards are identified in relation to each of the processes outlined in

section 3.2.3 and all possible causes of failure of the process are identified and the

subsequent effects on each environmental receptor considered.

In relation to the risk of fire and explosion the site is designed and operated in

accordance with site-specific Alstom Fire Protection Concepts (GT and Overall Plant

Doc. Codes AGH/00/G/MB15-55321/DO/001 & AGH/00/M/09-004/DO/001) and

Explosion Protection Concepts (GT & CCGT Doc. Codes. AGH/00/G/MB15-

55321/DO/002 & AGH/00/M/09-004/DO/002). Fire protection measures are designed

to fulfil the following requirements:

Inhibiting the outbreak and spread of fire,

Protection of operating personnel,

Early fire detection, warning, and suppression and/or extinguishment, and

Minimising damage resulting from a fire.

Fire risk potential on site has been classified into three areas: category 1 (high),

category 2 (medium) and category 3 (low).

Explosion protection concepts are similar to those for fire protection aiming to:

Inhibit the possibility of an explosion or fire due to gas leakage;

Protect operating personnel;

Detect gas leakage to mitigate the hazard; and

Initiate procedures for a safe plant shut down.

There is no feasible technical method of containment or remediation of releases to the

atmosphere once a fire is burning out of control but many measures can be used to

prevent a fire starting and to prevent a fire from getting out of control. To this end,

comprehensive fire prevention systems are in place at Marina based on the local

applicable codes and standards and Alstom standard plant design, procedures and

safety instructions to prevent and control the occurrence of fires at any location on the

site (see Section 3.2.4). These include both passive and active fire control measures.

Passive measures incorporate fire zoning, segregation and optimal equipment layout

including:

Strategic plant and optimum equipment layout;

Fire zoning segregation and passive fire barriers;

Selection of suitable non-combustible and fire-resistant materials;

Adequate travel distances and fire escape ways;

Emergency escape way lighting;

Bunding of fuel and chemical storage tanks;

Protection of ignition sources;

Containment of fire water run-off.

Where passive measures alone are insufficient, active fire control measures are

provided which incorporate adequate warning and fire-fighting systems including:

Fire and smoke detection systems;

Continuous gas monitoring systems;

Automatic combustible gas warning & alarm system;

Venting of air/gas accumulations;

Automatic/manually operated deluge systems for high risk areas;

Water spray and sprinkler systems;

Ring main hydrant system (with backup electric and diesel pumps);

Fire-fighting pump station;

In-house procedures specific to potential hazards;

Routine self-audits;

Provision of fire-fighting equipment, PPE and staff training;

Fire fighting procedures specific to identified fire emergency scenarios

(updated in 2010).

A comprehensive firewater retention study and risk assessment was carried out for the

station. This assessed the likelihood of uncontrolled fire at each of the six different

locations around the site where oil volumes of 10m3 or more are stored. Each of these

are bunded (except the turbine oil tank due to physical constraints). For each of the oil

and flammable chemical storage areas, an uncontrolled fire was considered (an

uncontrolled fire is defined as a fire which is not extinguished at an early stage, and in

effect destroys its object and generates large volumes of firewater because of its

duration).

For each uncontrolled fire, its likely duration was estimated. This duration, coupled

with the fire-fighting system capacity available, was used to derive a likely volume of

firewater generated. The probability of an uncontrolled fire event was calculated using

a decision tree analysis method. The decision trees for each fire event considered the

following probabilities:

• Electrical fault occurring (transformers);

• Electrical protection system failure (transformers);

• Initial fire occurring;

• 24-hour staff being unable to extinguish fire immediately;

• Fixed deluge system (Water or CO2) failing to detect and extinguish

(Turbines);

• Fire brigade fails to extinguish fire quickly.

Probabilities were estimated using the following:

• Industry experience to date with fire incidents ;

• Staff awareness of fire prevention, control and environmental impact is high

and is constantly improving through the operation of the ISO 14001 certified

EMS;

• The station is equipped with automatic fire detection systems and is manned

24 hourly with staff trained in fire fighting skills;

• Response time of fire brigade is 3 minutes;

• The station is equipped with effective fixed deluge systems for high risk

areas, a hydrant system covering the entire site and ample mobile fire

fighting equipment.

The study concluded that nine significant fire risks were present with a potential, once

every 410 years, to generate up to 3200 m3 of firewater containing up to 6m3 of oil

(since the study was first carried out three of these fire risks have been removed from

the site leaving six in total). The firewater would also be contaminated with foam

concentrate, which is a Nicerol protein foam which is biodegradable and free of

detergents and glycol ether.

Most of the firewater would overflow bunds and make its way to the drainage system

with some oil removal in the interceptors. By closing the interceptor discharge

isolating valve, a significant amount would be likely to back up through the drainage

system and overflow onto the site and from there percolate into the soil and

groundwater. For the worst case scenario, only a relatively small amount of 6 m3 of oil

would be likely to escape to the marine or soil and groundwater environment. With an

oil spill of this size effective remediation measures are possible in the case of soil and

groundwater and effective activation of emergency oil spill response plans would

further minimise the spread and impact of oil in the marine environment. In addition,

the groundwater has no value as drinking water as it is contaminated by nitrogen

compounds and in some places by saline compounds, hydrocarbons and other

compounds originating from sources beyond the site.

Given the low risk of an uncontrolled fire, the likely amounts of oil released to the

environment and the remediation and limitation measures possible in the environment

during and after the event, it was concluded that a Fire Water Retention facility was

not required for the station.

5.1.4.1 Fire/Explosion Resulting in Emissions to Air

Accidental emissions to air could arise in the event of fires or explosions occurring at

the plant. The principal environmental hazard associated with a fire or explosion is the

potential for gaseous releases of toxic or pollutant matter to atmosphere with such

releases temporarily reducing local air quality and impacting on the atmosphere.

Some materials may emit hazardous decomposition products during a fire in addition

to the dangers of smoke raising additional questions of health and safety but in the

case of the station, as there are no significant volumes of flammable chemicals on site

a toxic plume is not considered likely.

5.1.4.2 Fire/Explosion Resulting in Emissions to Water

As described in section 5.1.4 a fire risk assessment was carried out which identified a

one in 410 year risk of 6 m3 of oil reaching the soil or groundwater making the

provision of a firewater retention facility unnecessary and the likelihood of any

serious environmental impact remote.

5.1.4.3 Distillate Leak from Pipeline

Oil is piped to the combustion from the NORA storage site which has the potential to

leak to ground and then to groundwater. Detection is more difficult with underground

pipes. This must be inspected at least every three years for leaks and boreholes are

monitored (Schedule C of IPC Licence).

5.1.4.4 Natural Gas Leak

Should gas escape from a tank, pipeline, cylinder, etc. a flammable vapour cloud will

form, ignition of which could result in a flash fire or a vapour cloud explosion (VCE)

depending on the amount of vapour in the flammable region and the turbulence within

the cloud. Where flammable gas/liquid is released under pressure, a jet flame may

occur in the event of immediate ignition. Delayed ignition of a gas release may also

burn back to the release point causing a jet flame. Consequently, the principal risks

linked to natural gas arise either where:

It is accidentally released and allowed to accumulate within its explosive

limits in a confined space, building or inverted space;

Air is allowed to enter and mix with the gas in spaces that normally contain natural gas.

Potentially hazardous incidents which could occur include:

Leaks from/ruptures of pipelines inside/outside buildings;

Leaks within the gas compressor system;

Leaks within the combustion chambers;

Rupture of natural gas lines;

Failure of the combustion flame on start-up causing gas build-up;

Failure of valves to isolate gas from air-filled spaces through direct failure or

failure of control systems;

Failure of inerting system whereby an inerting gas is used to purge the system

of gas before replacement with air or vice versa;

Failure of gas detection systems and/or emergency ventilation systems or

procedures.

The risk minimization/prevention and safety measures in place include:

Combustion of natural gas (and distillate) is carefully managed, employing a

sophisticated automated control system that ensures the fuel is burned

efficiently, safely and in controlled conditions (according to procedures GDS

9/6 and GDG 22/22 Safe Firing and Safe Handling of Natural Gas);

Routing the natural gas line underground as much as possible;

All underground gas pipes are long term technically sealed, i.e. fully

welded with full hydraulic testing;

Where gas pipes emerge from underground they are in trenches;

There is impact protection for the gas pipeline at all locations;

The gas supply is filtered to remove dust and debris to avoid damage to

pipework and associated control and safety equipment;

Provision of continuous gas monitoring systems;

Proprietary slam shut type valves are in place operating automatically in

response to pressure loss;

Venting of gas/air accumulations;

Nitrogen purging of gas lines and testing with detection equipment for pipeline

maintenance;

Protection of ignition sources from physical damage;

Designation and demarcation of zones with potentially explosive atmospheres;

Manual push-button on fire alarm panel at security can shut-off supply;

All excavation on site is controlled by the permit-to-work system;

Forbidding welding in the area of gas pipework;

Inspection and maintenance program in place.

5.1.4.5 Hydrogen Leak

Hydrogen-derived hazards include:

Escape of hydrogen resulting in accumulation of explosive air/gas mixture;

Escape of hydrogen that has ignited.

Measures taken to eliminate fire risk involves ensuring generator housing remains

filled with pure hydrogen. To this end the building is equipped with suitable vents to

permit the escape of any vented gases while a sophisticated fail safe control system

ensures the hydrogen purity is maintained in a safe range. When maintenance is

carried out the hydrogen is purged with carbon dioxide and vented safely to the

atmosphere. Hydrogen losses are determined by means of regular hydrogen leakage

wipe tests. Continuous monitoring equipment has been provided to enable rapid

detection of leaks and suitable fire fighting equipment is provided.

GDG 18/2 Safe Use of Hydrogen controls operational aspects while other control

measures include the following:

The hydrogen cylinders are kept in protective MCP frames at all times when

on site;

The hydrogen cylinders and hoses are replaced on a regular basis and undergo

regular inspection and maintenance;

Operators are trained in the handling of hydrogen;

The hydrogen storage areas are caged;

SOPs covering the handling of hydrogen are in place;

The hydrogen storage areas are zoned appropriately;

The hoses and pipe work are regularly inspected.

5.1.4.6 Mechanical Failure

The major risk of mechanical failure is of turbine runaway and disintegration.

Internationally approved standards on the monitoring and testing of the overspeed

protection system are rigorously applied. Mechanical failure may also occur as a

result of fatigue, excessive vibration and external interference that can cause

mechanical damage or oil leaks resulting in fire. The plant element most at risk is the

turbine unit. A regular programme of preventive maintenance and in-service

inspection along with continuous vibration monitoring of the turbines is in place. This

ensures the early detection of any mechanical faults and so limits the risk of any such

event occurring.

5.1.4.7 Transformer/Oil Spill

Two House Transformers (HOT 2 and HOT 7) identified as surplus to requirements

were drained of oil in 2008 as was the main lube oil tank of the steam turbine in 2009

(16 m3) as risk reduction opportunities to lower the amount of oil stored on site. After

testing to prove the absence of PCBs in the oil, the oil was drained from these

transformers and recycled. Spills of oils and chemicals constitute the most frequent

environmental incidents at Marina over the past few years i.e. oil leak from a cooler in

2008 and a leak from a the gas turbine steel engine compartment in 2009. However,

none of these or indeed any previous incidents events have yet caused any significant

environmental damage.

The largest quantity of oil which could leak from the main transformer is 25.0 m3. The

worst-case scenario is the whole amount being released to its bund and bund failure

occurring. In such an event, the oil would go straight to the relevant bund or contained

area making the principal risk that of bund failure or runoff out of a building. All

transformers and other oil storage locations are bunded and bunds integrity tested

every three years and regularly inspected (some bund repairs were carried out in 2009

on the foot of test findings). Also the transformer oil filled cables are alarmed to

detect any loss of oil pressure that is indicative of an oil leak and this alarm is checked

monthly. Bunds are checked weekly according to EPA IPC Guidance Note on

“Storage and Transfer of Materials for Scheduled Activities”. The sources of potential

spillage are:

Lube/control/seal oil system for the combustion turbine;

Insulating oil systems for large transformers (traffos) and their associated

bunds T101, T102, T107;

Smaller main unit, house and network transformers and oil-filled cables.

For associated quantities of oil see Appendix 1. Other protection measures include the

provision of alarmed three-compartment oil traps on the surface water drainage

system serving impermeable bunds, provision of locked isolation valves to the fuel

tanks and the provision of a locked distillate oil farm and a locked discharge valve.

Fuel oil tanks and associated pipework are inspected at regular intervals as part of the

PM schedule and fire protection measures are provided.

Oil spill response training is also provided to staff and there are three Emergency Oil

Spill Bins, one adjacent to Gas Turbine Fuel Skids, one adjacent to the waste store

and one in ‘A’ Station Basement between G1 and G2. Also services provided by

Marina’s Waste Contractor include oil clean-up, retrieval, recycling and disposal

employing plant such as vacuum tankers, absorbent materials, and high-pressure

jetting equipment.

For lubricating oils, best international practice has been used to design and select the

most relevant storage and usage areas and protection and fire containment systems.

High-pressure fire fighting systems have been provided and the lubricating oil is

stored in highly ventilated areas.

Waste oils are stored in a plastic bunded oil tank located in a secure storage shed at

the southern end of the main station building. Some other oils are also stored at this

location.

5.1.4.8 Leak from Drains

A leak in the drainage system could result in a variety of substances going to ground

and/or groundwater including sewage effluent, oils, gas oil, chemicals and untreated

effluent. Controls in place include EMS 9.1-04 (Procedure for the Maintenance of

Drains, Sewers and Aqueous Effluent Pipelines) and biannual borehole monitoring to

detect contamination.

5.3 Risk Assessment

The hazards associated with the various processes are tabulated below in a Risk

Assessment Form. Risk classification tables were used to determine risk ratings based

on the chance of occurrence and the severity of each risk. These ratings were

multiplied together to obtain risk scores. A risk register and risk matrix was then

devised to list the critical risks to be assessed during the study. These are dealt with

in sections 3.4 and 3.5.

Table 3.2 Risk Classification Table – Occurrence.

Rating

Occurrence

Category Description Likelihood of

Occurrence (%)

1 Very

Low

Very low chance (0-5%) of hazard occurring in

30yr period

0-5

2 Low Low chance (5-10%) of hazard occurring in 30 yr

period

5-10

3 Medium Medium chance (10-20%) of hazard occurring in

30 yr period

10-20

4 High High chance (20-50%) of hazard occurring in 30

yr period

20-50

5 Very

High

Very high chance (>50%) of hazard occurring in

30 yr period

>50

Table 3.3. Risk Classification Table – Severity.

Rating

Severity

Category Description Cost of

Remediation (€)

1 Trivial No damage or negligible change to environment <€100

2 Minor Minor impact/localised or nuisance €100-€1,000

3 Moderate Moderate damage to environment €1,000-€10,000

4 Major Severe damage to local environment €10,000-€100,000

5 Massive Massive damage to a large area, irreversible in

medium term

€100,000-

€1Million

Table 3.4. Risk Assessment Form.

Risk

ID

Process Potential Hazards Environmental

Effect

Occurrence

Rating

Basis of Occurrence Severity

Rating

Basis of Severity Risk

Score

1 All processes

covered by 6

critical fire risks

Fire/explosion

resulting from

significant fire risks

Emissions to air 1 Failure of all passive

and active fire control

measures. Once every

410 year event.

5 No method of containing

emissions to air so no

costs involved in clean

up. Mitigated by

atmospheric dilution.

5

2 All processes

covered by 6

critical fire risks

Fire/explosion

resulting from

significant fire risks

Firewater emissions to

soil, groundwater and

River Lee

1 Failure of all passive


measures. Once every

410 year event.

5 Contaminated firewater

& oil entering river

ecosystem (containing 6

m3). Cost of cleaning

soil & river bed.

5

3 Fuel Delivery &

Storage

Distillate leak from

pipeline

Emissions to soil and

groundwater

2 Failure of pipeline

inspections

4 Cost of soil/groundwater

remediation

8

4 Power

Generation

Natural gas leak

resulting in

fire/explosion



measures




up. Mitigated by


5

Risk

ID

Process Potential Hazards Environmental

Effect

Occurrence

Rating

Basis of Occurrence Severity

Rating

Basis of Severity Risk

Score

5 Power

Generation

Leak from hydrogen

in generator housing

resulting in

fire/explosion



measures




up. Mitigated by


5

6 Power

Generation

Mechanical failure

(turbine units, fans)

Emissions to

atmosphere and waters

1 Failure of

sophisticated control

mechanisms and PM

4 Remediation of

contaminated soil,

groundwater, riverbed.

4

7 Oil Storage Leak from

transformers/ oil

storage locations due

to bund failure

Emissions to

soil/groundwater

2 Failure of bund

checks, integrity

testing, oil

interceptors and Oil

Spill Response Plan.

4 Quantity of oil in largest

transformer 25 m3. Cost

of soil excavation and/or

GW remediation

8

8 Oil Delivery &

Storage

Leak from drains Emission to

soil/groundwater

2 Failure of pipe

inspection procedures

but difficult to detect

4 Possible undetected leak

of sewage effluent, oil or

chemicals & cost of

8

soil/groundwater

remediation

3.4 Risk Register

Table 3.5. Risk Register.

8 Leak from drainage system resulting in emission to soil/groundwater 2 4 8

1 Fire/explosion resulting in emission to air 1 5 5

2 Fire/explosion resulting in firewater release to River Lee 1 5 5

4 Gas leak resulting in fire/explosion and emissions to air 1 5 5

5 Hydrogen leak resulting in fire/explosion and emissions to air 1 5 5

Risk ID Description Occurrence Rating Severity Rating Risk Score

3 Distillate leak from pipeline to soil and groundwater 2 4 8

6 Mechanical failure of turbine equipment resulting in emissions to soil, groundwater

and surface waters

1 4 4

7 Transformer / oil spill to soil and groundwater due to bund failure 1 4 4

3.5 Risk Matrix

A risk matrix has been developed to display the risks visually with colour coding to

give an indication of the critical nature of each risk (Table 3.6).

Table 3.6. Risk Matrix.

OC

CU

RR

EN

CE

O

V High 5

High 4

Medium 3

Low 2Risk I.D.

3, 8

V. Low 1Risk I.D.

6, 7Risk I.D. 1, 2, 4, 5

Trivial Minor Moderate Major Massive

1 2 3 4 5

SEVERITY

None of the risks fall into the red zone, which would require priority attention, or the

amber zone, which requires mitigation or management action. The green zones in

which the risks are located (two in dark green and seven in light green) are the lowest

level risks and indicate a need for continuing awareness and monitoring on a regular

basis. Whilst they are currently low or minor risks, some (i.e. those in the dark green

zone) have the potential to increase to medium or even high-level risks and so must be

regularly monitored. In these cases, where cost-effective mitigation measures can be

carried out to reduce the risk even further this course of action should be pursued.

3.6 Risk Management Programme

Risk mitigation measures that were identified in the course of the risk assessment are

noted in the following Risk Mitigation Form. Risk scores are also revised and re-

ranked using this Form (see Table 3.9).

Table 3.7. Risk Mitigation Form.

Risk

ID

Process Potential Hazards Risk Score

Before

Mitigation

Possible Mitigation

Measures

Risk

Manager

Timeframes Revised

Occurrence

Rating

Revised

Severity

Rating

Risk

Score

1 All processes

covered by 6

critical fire

risks

Fire/explosion resulting

in emissions to air

5 Ensure continued

implementation of EHS

management system,

adherence to IPPC

licence conditions,

CMMS, checks,

monitoring etc.

(summarised in 5.1.4)

Station

Manager

N/A N/A N/A 5

2 All processes

covered by 6

critical fire

risks

Fire/explosion resulting

from significant fire

risks

5 As per above Station

Manager

N/A 1 4 5

3 Fuel Delivery

& Storage

Distillate leak from

pipeline


Manager

On-going N/A N/A 8

4 Power

Generation

Natural gas leak

resulting in

fire/explosion


Manager

On-going N/A N/A 5

Risk

ID

Process Potential Hazards Risk Score

Before

Mitigation

Possible Mitigation

Measures

Risk

Manager

Timeframes Revised

Occurrence

Rating

Revised

Severity

Rating

Risk

Score

5 Power

Generation

Leak from hydrogen in

generator housing

resulting in

fire/explosion


Manager

On-going N/A N/A 5

6 Power

Generation

Mechanical failure

(turbine units, fans)


Manager

On-going N/A N/A 4

7 Oil Storage Leak from transformers

etc. due to bund failure


Manager

On-going N/A N/A 4

8 Chemical/Oil

Delivery &

Storage

Leak from drains 8 As per above Station

Manager

On-going N/A N/A 8

This form can be used as a Risk Management Programme, which provides a mechanism for continuous and ongoing environmental risk

management and mitigation in order to reduce the unknown environmental risk at the plant.

6.0 QUANTIFICATION OF UNKNOWN ENVIRONMENTAL

LIABILITIES

6.1 Financial Model

A financial model is required to estimate the environmental liability associated with

the risks identified. Known risks and the associated costs are calculated in the

Residuals Management Plan. The model is defined in terms of the worst, most likely

or best case scenarios. In this case the most likely scenario is taken which selects the

median value of each range used. The median probability and severity are then

multiplied together to determine the most likely cost. Table 6.1 illustrates this.

Table 4.1. Most Likely Scenario Financial Model (EPA, 2006).

Risk Occurrence

Rating

Likelihood of

Occurrence Range

Severity

Rating

Cost

Range (€)

Median

Probability

Median

Severity (€)

Most Likely

Scenario Cost (€)

1 1 0-5% 5 100,000-1M 2.5% 550,000 13,7500

2 1 0-5% 5 100,000-1M 2.5% 550,000 13,7500

3 2 5-10% 4 10,000-100,000 7.5% 55,000 4,125

4 1 0-5% 5 100,000-1M 2.5% 550,000 13,7500

5 1 0-5% 5 100,000-1M 2.5% 550,000 13,7500

6 1 0-5% 4 10,000-100,000 2.5% 55,500 1,375

7 1 0-5% 4 10,000-100,000 2.5% 55,500 1,375

8 2 5-10% 4 10,000-100,000 7.5% 55,000 4,125

Total €66,000

7.0 ENVIRONMENTAL LIABILITY REVIEW

It is recommended that a review of the Environmental Liability Risk Assessment should be carried out

on an annual or biennial basis to capture any changes that occur on-site which may result in

environmental impacts. In particular, the ELRA should be revised should any parts of the site be

decommissioned and/or new plant added. The following steps should be followed as part of this

review:

Update the risk register by adding new risks or omitting redundant risks;

Verify the implementation of the Risk Management Programme;

Ensure that the financial provision continues to satisfactorily cover the facility’s environmental

liabilities;

Verify that the financial instruments continue to provide the required financial provision.


The figure of €2,443,125 calculated in Table 4.1 in Section 4.0 above represents the present value of

the current estimate of the costs for part-closure of Marina at the end of its useful economic life. These

address the known financial liabilities associated with the site.

The figure of €66,000 given in Table 6.1 of Section 6.0 represents the present estimated value of the

unknown financial liabilities associated with the site.

ESB has adequate resources of finance and manpower to implement the RMP through to completion

and will make specific financial provision for closure of the site.

APPENDIX 1. CHEMICAL & BOTTLED GAS QUANTITIES AT MARINA

Chemical Quantity Use

Silica gel 75 kg Transformer oil moisture removal

Carbon dioxide 24 bottles Hydrogen system purge gas

Carbon dioxide 6 t Gas turbine fire fighting system

Lubrication oils 2.5 t Lubrication

Foam concentrate 3.4 t Fire fighting

Antifreeze 4 x 205 litres

Coolant

Hydrogen gas 75 bottles Generator cooling

Nitrogen gas 45 bottles Purging of natural gas lines

Sulphur hexa-fluoride

(SF6)

23 kg Circuit breaker insulation

APPENDIX 2. OIL QUANTITIES IN MARINA

Lube Oil Tanks & Main Transformers (10.5kV/220kV)

CT Lube Oil Tank

17 m3

T101 (bunded)

23.7 m3

T102 (bunded)

23.7 m3

T107 (bunded)

25.0 m3

Main Unit Transformers 10kV/3.5kV/380V

UT1 (bunded)

4.27 m3

UT2 (bunded)

4.27 m3

UT4 (bunded)

4.27 m3

House Transformers 3.3kV/380V

HOT1 (bunded)

0.87 m3

HOT4 (bunded)

1.1 m3

HOT5 (bunded)

0.87 m3

HOT6 (bunded)

0.87 m3

HOT8 (bunded)

0.87 m3

HOT9 (bunded)

0.75 m3

Network Transformers 110kV/38kV

T105 (bunded)

21.1 m3

T106 (bunded)

21.1 m3

ST11 (bunded)

4.27 m3

ST12 (bunded)

4.27 m3

Oil Filled Cables (110kV)

Reference Capacity

Cable Tank Sealing Ends

Trabeg 1, length 150 m located on-site

393 l 600 l 54 l

Trabeg 2, length 150 m located on-site

650 l 180 l 105 l

Kilbarry 1, length 221 m 500 l 150 l 90 l

Kilbarry 2, length 215 m 486 l 150 l 90 l

T107, length 40 m 90 l 150 l 90 l

Lube Oils

1. Perfecto T32:

` 8 x 208 litres

2. Perfecto HT5

2 x 20 litres

3. Alpha SP 460

1 x 25 litres

4. CT Castrol 778

8 x 208 litres

5. Shell traffo oil

1 x 208 litres

6. Fyre wash F2

3 x 208 litres

7. Deusol 140

2 x 208 litres

8. Gilo Therm 140 (CO2)

1 x 208 litres

APPENDIX 3. LARGE PLANT COMPONENTS & EQUIPMENT LIST

Large Plant Components

CT:

Air Intake System

Compressor

Combustion System

Turbine

Couplings and Bolts

Exhaust

Bearings

Auxilaries (inc. pumps & valves)

Fuel System

Electrical and C&I

Generator

MV Equipment

LV Equipment

Transformers

Batteries/Chargers

Hydrogen System

Miscelaneous

Control & Instrumentation

Balance of Plant

Heating & Ventilation

Fire Protections System

Comperssed Air System

Emissions Monitoring System

A Station:

Boiler BOP

Deaerators (4)

HP Module

IP Module

IP Casings and Diaphragms

IP Rotor and Moving Blades

IP casing Studs

Crossover Pipes

LP Module

Bearings

Couplings and Coupling Bolts

Barring Gear

Lube and Safety Oil System

Jacking Oil System

Seal Oil System

Bleed Valves

Feedwater Heaters

Condenser (6) – all decommissioned

Gland Steam System

Air Ejectors

Generator (3) - all decommissioned

Electrical

MV Equiment

LV Equiment

Transformers

Batteries/Chargers

C&I System

Balance of Plant

CW Systems

Auxiliaries

Fuel System

Chemical Treatment

Large Equipment

Boiler 4 (decommissioned)

Sewage holding tank

WTP - pumps, sand filter vessel (empty), instrumentation , valves, PLC control, neutralisation sump

and associated instrumentation

Safety showers & eye baths- 10 approx

HCL bund and bunded acid tank (empty)

4 interceptors

Boiler feed pumps (3)

Raw water storage tank (3)

Cooling water pipeline- inlet and outlet

Lube oil tanks G1 (empty)

Lube oil tank CTs

Auxiliary Cooling Water System

Bulk chemicals tanks (empty)

Gas bottle storage

Transformers and cables as per EMS 10.2

3 Waste laydown areas

PEMS CT

1 air compressor

Appendix 8: Site Map

Appendix 9: Confirmation of Financial Capability.

esb - environmental protection · pdf fileesb marina generating station aer 2011 – ipc...

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