for inspection purposes only. consent of copyright owner ... · the unit has a condensate polisher...

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Give details of the source of high levels of ammonia (>10mg/l) on occasion at PE15 but not detected at these levels at PE24, a similar process effluent. For emissions outside the BAT guidance limit, provide a planned programme of improvement or justify the level having regard to the BAT guidance note. In relation to PE15 (water treatment neutralisation sump for Unit 1 (AD1))- ESB Aghada operates AVTO (all volatile treatment) for the maintenance & integrity of the boiler- Unit 1. The unit has a condensate polisher operating as a result of the boiler conditioning process. Ammonia is used as the conditioning agent. Ammonia is absorbed onto the polisher resin in-line & during the regenerating process of the resin the ammonia is stripped from the resin. This results in the station managing the ammonia discharge to an ELV limit of 300mg/l per discharge as per licence requirements. PE24 -water treatment neutralisation sump for AD2 does not operate with a condensate polisher and therefore ammonia will not be detected in the sump, as no polisher regenerations take place there. 1. Please note that Ammonia is a component of Dissolved Inorganic Nitrogen

(DIN) and therefore an impact assessment of the discharges in relation to ammonia and the DIN standards for costal waster is appropriate and should be provided as requested previously.

ESB Aghada is not required by licence to test for DIN. However in December 2011 & January 2012, ESB Aghada did test for ammonia in the receiving waters close to PE4 & PE19. However we would point out that no ammonia limits for coastal waters have been provided in the European Communities Environmental Objectives (Surface Waters) Regulations 2009: S.I. No. 272 2009. In terms of DIN under our current IPPC Licence ESB Aghada is not required to carry out testing for DIN. However as part of this licence review ESB has carried out a once off test of inlet and outlet of our main CW emission points (PE4 & PE19) and DIN can be derived from the results. It is important to note that this was a once off test and so would not constitute a fully representative analysis. The results of the 2011/2012 tests are as follows:

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Please see table below: European Communities Environmental Objectives (Surface Waters) Regulations 2009: S.I. No. 272 2009 pg 40: Nutrient Conditions:

Ammonia: No regulations are given regarding ammonia levels in coastal waters. As can be noted from the EPA 2007-2009 data ESB would point out that the concentration of DIN in the Cork harbour is extremely high (presumably due to Nitrates run off from lands). Therefore it is impossible for ESB to comply with the requirements of the Surface water regulations as the background concentration in our intake water already exceeds the limits in the regulations. However below are details of the once off test impacts and also the assimilative capacity calculations Dissolved Inorganic Nitrogen (DIN) = Sum of nitrate (NO3), nitrite (NO2) and ammonia (NH3). From the results above AD1: Cooling water intake AD1: DIN = 94 +2679 +16 =2789 μg/l Cooling water outfall AD1: PE4 discharge DIN = 93 +2821 + 16 = 2930μg/l DIN difference between intake and outfall = 0.141μg/l From the results above AD2: Cooling water intake AD2: DIN = 54 + 2391 +16 = 2461 μg/l Cooling water outfall AD2: PE19 discharge DIN = 80 + 2383 + 16 = 2479μg/l DIN difference between intake and outfall = 0.018μg/l

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PE4 Discharge - assimilative calculation

PE 4 Assimilative capacity Analysis DIN Once off measurement

In Out 2.461 2.93

Cb Ce-Cb 1+D C

2.461 0.469 5.819409375 2.541592371

EQS 2.6

D Availiable Dillution Water b Average Depth of receiving Water (m) 17.27

F Max Flow rate of Discharge allowed under licence (m3) 32,000 PE19 Discharge - assimilative calculation

PE19 Assimilative Capacity Analysis DIN Once off measurement

In Out 2.461 2.479

Cb Ce-Cb 1+D C

2.461 0.018 5.673366667 2.464172719

EQS 2.6

D Availiable Dillution Water b Average Depth of receiving Water (m) 17.27

F Max Flow rate of Discharge allowed under licence (m3) 33,000

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2. Provide a copy of the notification from the Agency that agreed the intertidal habitat assessment proposal required under Condition 6.8 of your licence.

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3. Confirm if high level liquid alarms have been installed on pumps, sumps and other treatment plant chambers as per condition 9.3.3 of your current IPPCL licence

The following sumps/pumps have level alarms: Unit Pumps, sumps and other treatment plant

chambers alarm description AD1 (A1-1) Condensate Extraction pumps extraction pit Condensate Pit sump CW pump house sump CW busmain pit CTS (A1-2, A1-3, A1-4) False Start drains tanks *3 AD2 (A2-1) Effluent Pit Electrochlorination pit Rain water/Surface water pit Indoor pit ( hotwell/CEP) Blowdown pit Tansfer pit ( Traffo pump pit) Fuel gas sump pit Fuel oil sump pit (centrifuge) Main Fuel oil pit Water Treatment Plant neutralisation sump False Start drains Fuel gas condensate tank 4. Confirm if the requirements of Condition 13.3 of your current licence have been

addressed Yes, a procedure is in place - entitled EMS 10.1-04 Procedure to Address Environmental Compliance of Aghada Generating Station In the event of National Electricity System Emergencies. This procedure was reviewed as recently as January 2012 in preparation for an ISO 14001 recertification audit. 5. Clarify if a written undertaking, not to operate the plant (A1-1) for more than

20,000 hours between January 1, 2008 and December 31 2015 with closure therafter, has been submitted to the Agency.

This statement was removed from our licence as part of Technical Amendment B which was issued by the EPA on 16th May 2008. See attached appendix 1.

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6. Clarify if a written undertaking, not to operate each plant (A1-2, A1-3 and A1-4)

for more than 10,000 hours with closure thereafter, has been submitted to the Agency.

This clause is from the Large Combustion Plant Directive and provided the possibility of derogation from the requirements for Continuous Monitoring of air emissions. ESB Aghada did not apply for this derogation as we provided Continuous monitoring. This has subsequently been modified to Predictive Emissions Monitoring (PEMs) following agreement with the Mr. John Doheny EPA after a trail period of use in November /December 2007. 7. Give details of monitoring equipment agreed with the Agency in relation to

Emission to Atmosphere and Emission to Water as required by you existing licence ( see Schedules).

In relation to Air Emissions the station monitors by means of continuous emission monitoring on AD1 & AD2 and Predictive Emission Monitoring on the CTs. AD1 and AD2 is infrared. The AD2 in-situ RM230 dust measuring device functions according to the scattered light measuring principle. It is installed in the flue gas duct and carries out direct, non-contact emission measurements. After a one-off gravimetric comparison measurement, the RM230 outputs the measured value for the scattered light intensity, which is converted by means of regression, as the dust concentration (mg/m3). Emissions Point Reference No: A1-1 Parameter Monitoring Frequency Analysis

Method/Technique Nox Continous Extractive optical absorption

spectroscopy SOx 1* Extractive optical absorption

spectroscopy Dust 1* Gravimetric

1*see correspondence to the Agency dated 20th Sept 2007, returned correspondence from the Agency on the 1st October 2007 and following up correspondence with the Agency on the 12th June 2009. Appendix 2

Emissions Point Reference No: A1-2, A1-3, A1-4 Parameter Monitoring Frequency Analysis


spectroscopy SOx 2* Extractive optical absorption

spectroscopy Dust 2* Gravimetric 2* PEMS is approved by the Agency in a letter from the Agency dated 15th February 2008. See attached Appendix 3.

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Emissions Point Reference No: A2-1 Parameter Monitoring Frequency Analysis


spectroscopy SOx Continous Extractive optical absorption

spectroscopy Dust Continous Gravimetric Oxygen Continous Extractive optical absorption

spectroscopy Temperature Continous Extractive optical absorption

spectroscopy Pressure Continous Extractive optical absorption

spectroscopy Water vapour Continous Gravimetric In relation to emission to water, we have continuous monitoring on the following:

Schedule of Water Sampling Points Licence Conditions. Emissions to Water.

Station discharge points are sampled and analysed on a weekly, monthly or quarterly basis as per Discharge Licence/ IPPCL No. PO561-04

Emissions Point Reference No: PE19 Condenser Cooling Water

Parameter Monitoring frequency

Analysis Method/Technique

pH Continuous Inline pH meter Temperature Continuous Inline thermocouple

temp monitoring Chlorine 0.3mg/l Grab sample

Emissions Point Reference No: PE4 Condenser Cooling Water

Emissions Point Reference No: PE24



pH Continuous Inline pH meter Flow Continuous Inline flow meter

Ammonia Weekly Nessler’s Reagent List 1 & 2 Annually External Laboratory

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pH Weekly Inline pH meter Ammonia Monthly External Laboratory Phosphate

(as P) Monthly External Laboratory

Emissions Point Reference No: SW27



Mineral Oil Monthly Standard Method Visual Inspection Weekly N/A

Emissions Point Reference No: SW22



pH Quarterly pH electrode/meter BOD Quarterly Standard Method

Residual Chlorine (SW22 only)

Weekly Standard Method

Visual Inspection Weekly N/A


Parameter Monitoring Frequency


BOD Quarterly Standard Method Suspended solids Quarterly Standard Method Visual inspection Weekly N/A

Emission to Water. SW 3 Sewage Plant Discharge Parameter Monitoring

Frequency Analysis Method

BOD1 Quarterly Standard Method

Visual Weekly Not Applicable

Suspended Solid Quarterly Standard Method

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Emissions to Water. PE4 Cooling water Outfall Parameter Monitoring

Frequency Analysis Method

Flow Continuous Record pump rating

Temperature Delta T (in & out)

Continuous Thermocouple

Thermal Load Continuous OIS Res. Chlorine Weekly grab

sample Standard Method

8. Confirm if the ELRA and residuals management plan as required by the existing

licence have been submitted to the Agency On the 7th of December 2011, the station submitted the revised Environmental Liabilities Risk Assessment & Residuals Management Plan - as per Conditions 15.2.1 & Condition 14.2.1 of the IPPCL P0561-01. In compiling the AER each year the reports are reviewed annually. 9. Confirm if a continuous chlorine monitor installed in PE4 as required by the

existing licence Chlorine is dosed into the main cooling water to prevent the mussel growth in the sea water pipework. It is only dosed when the sea temperature exceeds 9°C, which is usually March/April to December/ January. In 2006, a chlorine monitor was installed on Unit 1, however this never worked correctly due to condition of the environment it was to work in. Instead it was agreed with Mr. John Doheny EPA inspector that a grab sample would we taken weekly to verify the chlorine on discharge. In relation to the chlorine meter on PE19, similarly the meter has to date not worked correctly and so grab samples are taken weekly as agreed with the Agency in July 2010.

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Appendix 1

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- - . . - - - - - - - - -. . - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

I -,

This report has been cleared for submission to the Board by the

mental Protection Aqency

II I cc: Mr. P Nolan

FROM: Sehn 0 Donoghue

Technical Aimendments to the following licence holder:

Electricity Supply Board (Aghada) REG. N O . PO561-04

Background The licensee wrote to the Agency on 23rd April 2008, requesting an amendment to its licence under Section 96 of the EPA Acts 1992 to 2007. The licensee requests that the requirements of the National Emissions Reduction Plan (NERP) be incorporated into the licence. The NEW is a mechanism provided for in ithe Large Combustion Plant Directive (200 1/80/EC), which allows “existing plant”, as defined in the Directive, to achieve the environmental objectives of the Directive in a cost effective manner through the installation of abatement at a selection of qualifying plant. The Directive requires that the total emissions reductions achieved in the NEW are at least as great as the total reductions that would be achieved by the imposition of the post 2007 Emission Limit Values (ELV)s at all qualifying plant.

The NERP has been agreed between participating licensees (The ESB and Aughinish Alumina Ltd.) and the Department of the Environment, Heritage and Local Government and annual emission allowances in tonnes for SOZ, NOx and Dust have been agreed for each participating plant. The applicant proposes, in accordance with the relevant provisions of the Large Combustion Plant Directive (LCPD), that these allowances or ceilings replace the post 2007 ELVs in the licence.

The applicant also requested the removal of references in the licence to mobile peaking plant used for emergency power generation (EGC plant), as this plant has been removed off site.

Assessment It should be noted that the requirement to protect local air quality remains irrespective of the reductions achieved through the NERP, and that the ELVs that applied in the licence up until January 1’‘ 2008 now continue to apply indefinitely for the purposes of protecting air quality.

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' As explained above, the NEW is provided for in the LCPD, and the current licence also makes provision for the non-application of the post 2007 ELVs in the event of participation in the NEW. It is therefore considered that the requested replacement of the post 2007 ELVs with annual emissions ceilings can be accommodated under Section 96( l)(b) of the EPA Acts 1992 to 2007.

The applicant has also indicated that reductions greater than those required by the NEW can be achieved, and the licence requires these greater reductions, and the measures that will be taken to achieve them to be set out in the Environmental Management Plan, and reviewed as appropriate.

The removal of references to the EGC plant in the licence is appropriate as this mobile plant has been removed from the site, and the requirements to record operational details, monitor emissions and other requirements are now void.

Recommendation

I recommend that the requested licence amendments be approved as set out in the attached Recommended Technical Amendment. The OEE has been consulted in relation to this application, and agrees with the recommendation.

Signed:

OCLR.

I

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I Environmental Protection Agency An Ghniornhaireacht um Choornhnti Comhshooil

Location of Installatioira:

Headquarters P.O. Box 3000

Johnstown Castle Estate County Wexford

Ireland

Aghada. Generating Station, Whitegate, Midleton, Co. Cork

TECHNICAL AMENDMENT B To

CONTROL LICENCE INTEGRATED POLLUTION PIREVENTION &

1 Licence Register Number: I PO56 1-104

1 Licensee: 1 Electricity Supply Board

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Reasons for the Decision

The Environmental Protection Agency is satisfied, on the basis of the information available, that subject to compliance with the conditions of the Integrated Pollution and Prevention Control (IPPC) licence Reg. No. PO561-04 granted on the 13'h December 2004 and amended on 1'' August 2006, as well as any amendments noted herein, any emissions from the activity will comply with and not contravene any of the requirements of Section 83(5) of the Environmental Protection Agency Acts, 1992 and 2003.

Technical Amen dm ent In pursuance of the powers conferred on it by Section 96( 1) (b) of the Environmental Protection Agency Acts, 1992 and 2003, the Agency amends the licence, granted to Electricity Supply Board, Aghada Generating Station, Whitegate, Midleton, Co. Cork.

Henceforth, the licence shall be read in conjunction with Amendment A, and the amendments set out below. This amendment shall be cited as Amendment B to the licence.

This amendment is limited to the following :-

Technical Amendment PO561 -04/B Page I of 4

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Amendments X I ~

P *,

1

Conditions

3.2 In the case of participation of the plant in a National Emission Reduction Plan (NEW), as defined by Directive 200I/80/EC, the plant’s annual average emission level shall be calculated in accordance with the NEW plan.

I Amend Condition 3 of the existing licence by deletion of condition 3.2 above.

5.1 No specified enlission to the atmosphere shall exceed the emission limit value set out in Schedule l(i) Emissions to Atmosphere, subject to Conditions 3 and 5.2 of this licence. With the exception of DGlO (for emergency use less than 50 hours per annum), there shall be no other emission to the atmosphere of environmental significance.

above. ng li

5.2 The aggregated annual emissions ceilings for each of the parameters specified in Schedule l(i) Emissions to Atmosphere, of this licence, shall not be exceeded. The annual emissions ceilings may be revised in accordance with the implementation, management and operation provisions of the NEW as submitted in association with the technical amendment request dated 231d April 2008.

Amend Condition 5.2 of the existing I b o v e . 1

5.6.1 Record of operation of Unit 1, CTl1, CT12, CT14, and the CCGT stipulating whether on gas or oil.

5.10 The licensee shall include in the Environmental Management Plan (See Condition 2.3) the site specific measures to be taken to deliver the targets contained within the implementation agreement. The Agency shall be notified of any variation to the plan as part of the AEF: and such notification shall detail the reasons for any deviation between emissions and the targets set out in the

Technical Amendment P0561-04/B Page 2 of 7

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agreement, along with any remedial measures to deliver the targets. The Environmental Management Plan shall be reviewed by the licensee where required by the Agency.

Technical Amendment PO561 -04/B Page 3 of 7

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Schedules to Licence

1 1

Schedule 1 (i) Emissions to Atmosphere

Emission Point Reference No.: Al-1

Location: Unit 1 - 675MW Thermal Input

Volume to be emitted: Maximum in any one day:

Maximum rate per hour:

19,200,000 m3

800,000 m3

Minimum discharge height: 152 m above ground

!) 1 3yo ~ ;.5 ~

. Note 1: Annual emissions from AI-1 ;hall be calculated in accordarce with the NEW.

Technical Amendment PO561 -04/B Page 4 of 7

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Schedule l(i) Emissions to Atmosphere Emission Point Reference No’s.:

Location:

Al(EGC), A2(EGC)

Stack No. 1 , Stack No. 2

Maximum in any one day:

Maximum rate per hour:

Volume to be emitted:

Nitrogen oxides (as NOz) 1 Dust

7,690,000 m3

320,400 m3

87 25.1

20 1 4.6

Minimum discharge height: 20 m above ground

Schedule 1 (ii) Emissions to Atmosphere: AbatemenVTreatment Control

Emission Point Reference No’s.:

Description of Treatment:

Al(EGC), A2(EGC)

Water injection for NO, supression

Monitoring:


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Equipment:

Nitrogen Oxides Water Injection Appropriate spare parts and local storage of treated water

ting licence by removal of the table above referring to emission I

Schedule 1 (iii) Monitoring of Emissions to Atmosphere

Emission Point Reference No's.: Al(EGC) and A2 (EGC:)

I Not applicable

Note 1 :

Note 2

Dunng plant operations.

The emission curves shall be validated on a yearly basis.

Plant log and commissioning test curves I Note2

Based on fuel consumption and fuel sulphur content

To be agreed with the Agency





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Sealed by the Seal of the Agency on this the XX day of MMMM, YYYY

PRESENT when the seal of the Agency was affixed hereto

Ms Laura Burke, Director

4


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Appendix 2

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Appendix 3

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Ms Orla Newman Chemist/Environmental Co-ordinator Electricity Supply Board Aghada Generating Station Whitegate Midleton Co Cork 15 February 2008 Our Ref: P0561-04/ap08JD Dear Ms Newman,

Our meeting at this office on 01 February 2008, and your correspondence dated 05 February 2008, received by the Agency on 07 February 2008 in relation to Predictive Emissions Monitoring Systems (PEMS) refers.

The Agency has assessed your proposal for PEMS on CT11, CT12, & CT14 as outlined at the meeting and in the aforementioned correspondence and found that it is generally to the satisfaction of the Agency.

As provided for under Condition 11.5 of the licence the Agency approves the use of PEMS on CT11, CT12, & CT14 at ESB Aghada Generating Station.

You are reminded that all reports submitted to the Agency must be certified accurate and representative by the Plant Manager or other senior officer designated by the Plant Manager (Condition 12.7).

Please quote the above reference in future correspondence in relation to this matter.

Yours sincerely …………………………… John Doheny Inspector Office of Environmental Enforcement

\\OWL\OEE\05. Licence Enforcement\IPC Licence Enforcement\IPC DB Documents\P561-570\P0561-04\ap08JD.doc

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