PROPOSED STACK CONFIGURATION FOR THE GAS ENGINE PROJECT … · 2017-12-01 · Report Reference: 2016/RPSSCH5-1 2 PROPOSED STACK CONFIGURATION FOR THE GAS ENGINE PROJECT – A BAT

1

PROPOSED STACK CONFIGURATION FOR THE GAS

ENGINE PROJECT – A BAT JUSTIFICATION FOR

ROOSECOTE POWER STATION

Oct 2016

Report Reference: 2016/RPSSCH5-1

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2

PROPOSED STACK CONFIGURATION FOR THE GAS ENGINE PROJECT – A BAT JUSTIFICATION FOR

ROOSECOTE POWER STATION

1. Introduction This document reports on the outcomes of a BAT justification completed to demonstrate that the stack configuration chosen for the project and described in the substantial variation application is considered to represent the best available techniques for this site. The review was completed in response to a Schedule 5 Notice from the Environment Agency. Details of the notice are shown below:

“A BAT justification should be provided for the chosen stack configuration in order to show it is the best available techniques for this site. Please demonstrate why the proposed single emission stack per engine configuration is considered the Best Available Technique in comparison to combining multiple engine stacks into a common windshield. Your response must take into account:

• Different windshield configurations using differing numbers of engine emission stacks;

• How each stack configuration impacts on the dispersion of point source

emissions and surrounding air quality; and

• The cost and viability of each stack configuration.”

2. Proposed stack configuration The exhaust gas system for each gas engine as originally proposed, will comprise a silencer and ducting to convey the hot gases from the engines to a dedicated exhaust stack for each engine. Hence a five stack configuration is proposed. Each of the five exhaust stacks will be 30 m in height. The locations of these emissions points are illustrated on Figure 3 in the variation application. The stacks are designated release points A7, A8, A9, A10 and A11. Details of the stacks are shown in Table 1 below.

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Table 1 Stack characteristics

The stacks will be roof mounted on the top of the engine house as shown in Figures 1 & 2 below. This design has been selected to optimise costs of construction and installation. The proposed five stack configuration has been granted planning permission by Barrow-in-Furness Borough Council. The Local Authority, which has responsibility for local air quality, has been satisfied by the dispersion modelling studies which show that the predicted ground level NO2 concentrations will be at acceptable levels and that there is no significant impact on air quality associated with the proposed development. 3. Alternative stack configurations considered A single stack combining the exhaust gasses form the five individual gas engines has been considered – both in the form of a windshield configuration containing the individual ducts and a combined stack where all the exhaust gases are fully mixed. A stack design featuring aggregation of stacks would necessitate ground mounted stacks to the north of the engine house. This would require significantly greater lengths of exhaust ducting leading to a much increased stack diameter, with increased civil engineering and structural steel costs. The stack location would adversely impact on the access route requirements for maintenance purposes. Alternative designs with aggregation of two individual stacks or three individual stacks were also considered. However it was anticipated that any potential benefits on air quality would be maximised by increasing the extent of aggregation.

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4. Dispersion modelling The substantial variation application for the gas engine development included a dispersion model study to identify the optimum stack height and to examine the predicted effects on air quality. The stack height determination was undertaken to establish the height at which there is minimal additional environmental benefit associated with the cost of further increasing the stack. The approach used by the specialist consultants employed for this study was in line the EA guidance and sought to identify “an option that gives acceptable environmental performance but balances costs and benefits of implementing it”. Hence the approach gives a stack height which represents BAT for the proposed stack configuration – in effect the optimum height at which there is minimal additional environmental benefit that would result from the additional cost of further increasing the stack. The stack height modelling results were assessed in two stages:

• Stage 1 - The maximum predicted annual-mean and 99.79th percentile of hourly-mean NO2 process contributions were plotted against height to determine if there is a height at which no benefit is gained from increases in stack heights.

• Stage 2 - The lowest height at which the maximum long and short-term NO2 impacts across the entire grid are not considered to be ‘not significant’.

This process was followed to determine the proposed stack height as described in the substantial variation application. A similar process has been followed to determine the stack height for an aggregated stack as part of this study. The results of this analysis, comparing the predictions for the original design and the aggregated stack option are shown in in Appendix 1. The conclusions from this study are similar for a fully mixed combined stack as well as a windshield configuration. It should be noted that the study shown in Appendix 1 relates to the proposed development at the Glanford Brigg Generating Station. This is one of three projects that have had similar substantial variation applications submitted at the same time and in each case the proposed new development is identical. Hence the conclusions drawn from the modelling of different stack configurations at Brigg can also be applied to the proposed development at Roosecote Power Station. 5. Discussion The stack height determination in Appendix 1 has concluded that the potential aggregation of stacks would have minimal effect on both the predicted short term and long term air quality impacts associated with the development compared with the predicted impacts associated with the original design. Hence there are no advantages in seeking to aggregate stacks from the air quality perspective.

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The purpose of the development is to generate electricity during peak periods of demand, thereby reducing grid instability. The five stack design provides optimum flexibility for the plant as it permits maintenance to be completed on one engine without impacting on the operation of the remaining units. Hence should this occur during periods of grid instability, the plant would still be able to make a contribution to reducing grid instability – this would not be feasible for a fully combined stack. Similarly, there are safety advantages in providing separate stacks which would mean that operation of the remaining units would not be impacted by safety isolations imposed for the protection of maintenance workers which could otherwise be required should aggregation of stacks be used. Hence there are operational and safety advantages in providing separate stacks. However, it is acknowledged that some of these safety and maintenance concerns are reduced if a windshield approach is used as opposed to a fully mixed, combined stack. It should be noted that a fully mixed combined stack will increase back pressure within the exhaust ducting to individual engines. It is expected that this may have a minor adverse impact on efficiency and output, but the extent has not been quantified at this time. The design and layout of the engine house has to take into account the construction programme, but also future maintenance needs of the gas engines and associated electrical generators. As indicated in Figure 1, access to the north of the engine house ( the top of the drawing) has to be maintained to enable removal of each individual engine/ generator for maintenance reasons should the need arise for a major offsite overhaul. This is not possible from the southern end of the engine house due to the location of other plant items within the engine house. An alternative stack design featuring aggregation of stacks would necessitate ground mounted stacks to the north of the engine house which would adversely impact on the access route requirements. In addition the footprint of the plant and the position with respect to the site boundary have also influenced the design. It is considered that an alternative design with aggregated stacks would require significantly greater lengths of exhaust ducting leading to a much increased diameter stack – this would to lead to a larger footprint for the plant that cannot be accommodated within the site boundary taking into account the planned future of the site. The five stack configuration is considered to be the most cost effective option for the proposed development. Aggregation of stacks is a more expensive option due to the combination of increased civil engineering costs, structural steel and exhaust gas ducting that would be required. It is anticipated that a combined stack would add an estimated £400k to the overall cost of the development. Planning permission has been granted for the five stack configuration. Hence the local authority is satisfied that the proposed configuration does not have an adverse impact on local air quality.

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The points illustrated above show that the BAT process which would determine the stack height for an aggregated stack would not result in improved air quality, but the changed stack configuration would be potentially adverse to the operation of the plant and the footprint of the plant is such that there is insufficient space to accommodate a combined stack structure in one location.

6. Conclusions and Recommendations This analysis has examined the potential impacts of different stack configurations for the project. As indicated above, the five stack configuration is deemed to be the BAT option for the project. Alternative stack configurations are expected to be more costly to install, to present operational and safety challenges for maintenance periods and to restrict access to the engine house for major maintenance activities which would require individual engines/ generators to be removed. In addition, the footprint required for an aggregated stack configuration would require additional space which cannot be accommodated within the site boundary taking into account the planned future of the site. In addition, the dispersion modelling for the five stack configuration predicts that ground level NO2 concentrations will be within acceptable levels and therefore the impact on air quality will not be significant. This is resultant from following the methodology for determining the BAT stack height in line with the EA requirements. A similar process was followed to determine the stack height for an aggregated stack with the same insignificance criteria being used. The analysis shows that the predicted effect on air quality resulting from a changed stack configuration would be minimal. It should be noted that the Local Authority has already granted planning permission for the five stack configuration.

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Figure 1 Plan view of the proposed engine house showing engine and stack arrangement

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Figure 2 Side elevation of proposed engine house showing engine and stack arrangement

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9

APPENDIX 1

Air Quality Assessment for Substantial Permit Variation Application – Schedule 5

Response

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Air Quality Assessment for Substantial Permit Variation Application – Schedule 5 Response

Proposed Gas-Fired Electricity Generating Facility

Land at Glanford Brigg Generating Station, Scawby Road, Brigg, DN20 9LT

For Centrica Brigg Ltd

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DISCLAIMER

RPS has used reasonable skill and care in completing this work and preparing this report, within the terms of its brief and contract

and taking account of the resources devoted to it by agreement with the client. We disclaim any responsibility to the client and

others in respect of any matters outside the stated scope. This report is confidential to the client and we accept no responsibility to

third parties to whom this report, or any part thereof, is made known. The opinions and interpretations presented in this report

represent our reasonable technical interpretation of the data made available to us. RPS accepts no responsibility for data provided

by other bodies and no legal liability arising from the use by other persons of data or opinions contained in this report.

Except for the provision of professional services on a fee basis, RPS does not have a commercial arrangement with any other

person or company involved in the interests that are the subject of this report.

COPYRIGHT © RPS

The material presented in this report is confidential. This report has been prepared for the exclusive use of the client and shall not

be distributed or made available to any other company or person without the knowledge and written consent of the client or RPS.

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Contents

1 Introduction ............................................................................................................. 1

2 Methodology ........................................................................................................... 2

Approach .............................................................................................................................................. 2

3 Stack Height Determination ................................................................................... 4

Results of Stack Emissions Modelling ............................................................................................. 4

4 Comparison with Original Results ........................................................................ 7

Results of Stack Emissions Modelling ............................................................................................. 7

Glossary

References

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Tables, Figures and Appendices

Tables Table 2.1: Stack Characteristics ................................................................................................................... 2 Table 2.2: Mass Emissions of Released Pollutants ..................................................................................... 3 Table 3.1: Maximum Impacts Across the Modelled Grid – Long-term NO2 ................................................. 5 Table 3.2: Maximum Impacts Across the Modelled Grid – Short-term NO2 ................................................. 6 Table 4.1: Highest Predicted Short-term Process Contribution (μg.m-3) for NO2 – Original Assessment ... 7 Table 4.2: Highest Predicted Short-term Process Contribution (μg.m-3) for NO2 – Schedule 5 Response . 7 Table 4.5: Highest Long-term Predicted Environmental Concentrations – Original Assessment ................ 8 Table 4.6: Highest Long-term Predicted Environmental Concentrations – Schedule 5 Response.............. 8

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1 Introduction

1.1 The air quality assessment undertaken to accompany the substantial permit variation application

for the proposed gas-fired electricity generating facility on land at Glanford Brigg Generating

Station assumed that electricity would be generated by five 10 MWe spark-ignition gas

reciprocating engines. The assessment report acknowledged that other configurations are

possible (for example, four 12 MWe engines); however, the assessment considered the impacts

from five engines as this is the worst case.

1.2 The facility would generate electricity during peak periods of demand, thereby reducing grid

instability. All electricity will be fed directly into the local Distributed Network Operator network.

The gas engines would replace the permitted Open Cycle Gas Turbines that are yet to be

constructed.

1.3 In a Schedule 5 notice, the Environment Agency has requested that consideration is given to a

scenario in which the stacks are aggregated. This report provides the results of a stack height

determination assuming that the flues serving the five engines are routed through a single stack

enclosure. The impacts from the stack at the height so determined, have been compared with the

impacts predicted in the original assessment report.

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2 Methodology

Approach

2.1 As in the original assessment, the determination of the appropriate stack height for a single stack

was performed by identifying the height required to meet relevant air quality assessment levels

(AQALs) and overcome the wake effects of nearby buildings. A series of atmospheric dispersion

modelling simulations have been used to predict the ground-level concentrations for a single

stack at a range of heights: starting at 19 metres and extending up in 1 metre increments, until a

height of 32 metres is reached.

Model Inputs

Stack Parameters and Emissions Rates used in the Model

2.2 The stack characteristics modelled in the original assessment and the stack characteristics

modelled for this schedule 5 response are provided in Table 2.1.

Table 2.1: Stack Characteristics

Parameter Unit Value Used in

Original Assessment

Value Used in Schedule 5 Response

Location of stack 1 (x, y) - 498963, 405973 -


Location of stack 3 (x, y) - 498981, 405977 498981, 405977



Internal diameter m 1.0 2.24

Efflux velocity m.s-1 37.2 37.2

Efflux temperature o C 364 364

Actual volumetric flow Am3.s-1 29.2 146

O2 (wet) % 10.3 10.3

Water % 10.1 10.1

Normalised volumetric flow (dry, 00C, 15% O2)

Nm3.s-1 20.06 100.30

MCPD NOx Emission Concentration Limit (dry, 00C, 15% O2)

mg.Nm-3 95 95

2.3 The mass emission rate for NOx has been derived from the concentration limit value in the

Medium Combustion Plant Directive (MCPD). The mass emission rate for the original

assessment and this schedule 5 response are provided in Table 2.2.

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Table 2.2: Mass Emissions of Released Pollutants

Pollutants Emission Rate Used in Original Assessment (g.s-1)

Emission Rate Used in Schedule 5 Response (g.s-1)

NOx 1.91 (per stack) 9.5 (single combined stack)

Model Inputs

2.4 All other model inputs are the same as in the original modelling for the permit application variation

to allow a comparison of the results. In particular:

� Modelling has been undertaken for a worst case scenario assuming that the gas engines

operate for 1,500 hours per year.

� A complex terrain file has been used within the model.

� A surface roughness length of 0.5 m has been used within the model to represent the

average surface characteristics across the study area.

� The engine hall has been included within the model as the dominant structure (i.e. with the

greatest dimensions likely to promote turbulence).

Model Outputs

2.5 Pollutant concentrations have been predicted over a domain of 3 km by 3 km centred on the

Proposed Development and with a grid spacing of 30 m. Results have been reported for the

location where the highest concentration is predicted. This is considered a robust and

conservative approach.

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3 Stack Height Determination

Results of Stack Emissions Modelling

3.1 The stack height modelling results have been analysed in two stages:

� Stage 1 - The maximum predicted annual-mean and 99.79th percentile of hourly-mean

NO2 process contributions have been plotted against height to determine if there is a height

at which no benefit is gained from increases in stack heights.

� Stage 2 - The lowest height at which the maximum long and short-term NO2 impacts across

the entire grid are not considered to be ‘not significant’.

Stage 1

3.2 Graph 1 compares the maximum predicted annual-mean process contribution with the stack

heights modelled and Graph 2 compares the maximum predicted 99.79th percentile of hourly-

mean process contributions with the stack heights modelled.

Graph 1 – Maximum Predicted Annual-mean Process Contribution (μg.m-3) Compared vs Stack Height (m)

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

19 20 21 22 23 24 25 26 27 28 29 30 31 32

NO

2 Con

cent

ratio

n (μ

g.m

-3)

Stack Height (m)

Annual Mean NO2 Concentrations

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Graph 2 – Predicted 99.79th Percentile of Hourly-mean Process Contributions (μg.m-3) Compared vs Stack Height (m)

3.3 Neither of the graphs shows the ground-level Process Contribution levelling-off completely within

the range of heights considered.

Stage 2

3.4 The maximum long and short-term impacts across the modelled grid for each height are set out in

Table 3.1 and Table 3.2 respectively.

Table 3.1: Maximum Impacts Across the Modelled Grid – Long-term NO2

Height (m) Annual Mean PC (μg.m-3) Annual- mean PC as % of AQAL

19 2.99 7

20 2.64 7

21 2.29 6

22 1.97 5

23 1.72 4

24 1.50 4

25 1.30 3

26 1.09 3

27 0.91 2

28 0.77 2

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

19 20 21 22 23 24 25 26 27 28 29 30 31 32

NO

2 Con

cent

ratio

n (μ

g.m

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Stack Height (m)

99.79th Percentile of Hourly-mean NO2 Concentrations vs Height

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Height (m) Annual Mean PC (μg.m-3) Annual- mean PC as % of AQAL

29 0.65 2

30 0.56 1

31 0.48 1

32 0.43 1 AQAL for annual-mean NO2 is 40 μg.m-3; shaded cells show the heights at which the annual-mean PC exceeds 5% of the AQAL

Table 3.2: Maximum Impacts Across the Modelled Grid – Short-term NO2

Height (m) 99.79th Percentile of Hourly-mean PCs (μg.m-3)

99.79th Percentile of Hourly-mean PC as % of AQAL

19 57.72 29

20 52.99 26

21 49.21 25

22 45.87 23

23 42.25 21

24 38.81 19

25 35.54 18

26 32.25 16

27 29.29 15

28 26.00 13

29 22.72 11

30 20.84 10

31 18.67 9

32 16.81 8 AQAL for 99.79th hourly-mean NO2 is 200 μg.m-3; shaded cells show the heights at which the 99.79th Percentile PC exceeds 20% of

the AQAL

3.5 The EA risk assessment guidance does not provide specific criteria for determining an

appropriate stack height. For consistency with the planning application (which preceded the

substantial permit variation application), consideration has been to the height at which the long-

term PC is 5% of the AQAL or lower and the short-term PC is 20% of the AQAL or lower.

3.6 Taking the values as insignificance levels, the maximum long-term impacts, the impacts across

the grid are insignificant at all of the heights considered. For the short-term impacts, the

maximum impacts across the grid are insignificant with stack heights above 23 m.

3.7 Based on the results of the detailed stack height modelling and using professional judgement, the

optimum stack height for the single-stack scenario is considered to be 24 m.

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4 Comparison with Original Results

Results of Stack Emissions Modelling

Short-term NO2 Impacts

4.1 Table 4.1 summarises the highest predicted short-term Process Contribution (PC) for NO2

anywhere across the modelled grid for five 30 m stacks as presented in the original assessment

report.

Table 4.1: Highest Predicted Short-term Process Contribution (μg.m-3) for NO2 – Original Assessment

Averaging period (Pollutant)

AQAL (μg.m-3)

Max PC (μg.m-3)

Max PC as % of AQAL

Potentially Significant?

(Yes/No)

AC (µg.m-3)

Max PEC (µg.m-3)

Significant? (Yes/No)

1 hour 99.79th percentile (NO2)

200 35.9 18 Yes 28 63.9 No

4.2 Table 4.2 summarises the highest predicted short-term Process Contribution (PC) for NO2

anywhere across the modelled grid for emission from the five units combined and released via a

single 24 m stack.

Table 4.2: Highest Predicted Short-term Process Contribution (μg.m-3) for NO2 – Schedule 5 Response

Averaging period (Pollutant)

AQAL (μg.m-3)

Max PC (μg.m-3)

Max PC as % of AQAL


(Yes/No)

AC (µg.m-3)

Max PEC (µg.m-3)


1 hour 99.79th percentile (NO2)

200 38.8 19 Yes 28 66.8 No

4.3 The maximum PC for the single-stack at 24 m is slightly higher than the maximum PC for the five

30 m stacks. In both cases, the results show that the maximum short-term PC anywhere across

the modelling grid is above 10% of the relevant AQAL; however, when the PC is added to the AC,

the maximum short-term Predicted Environmental Concentration (PEC) is below the AQAL.

(Note: the PEC is the PC added to the background Ambient Concentration (AC)). As such, the

short-term NO2 impacts are considered to be ‘not significant’.

4.4 Comparison of Tables 4.1 and 4.2 shows that there is a marginal increase in the maximum PEC

for the aggregated stack option compared with the original submission. There are no resultant

beneficial effects on predicted local air quality from the aggregation of stacks. It should be noted

that the original assessment (with individual stacks) demonstrated that the highest PC as a

percentage of the AQAL at any discrete receptor was less than 10% and the short-term impacts

were screened-out as insignificant [1].

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Long-term NO2 Impacts

4.5 Table 4.3 summarises the highest long-term PEC anywhere across the modelled grid for five 30

m stacks as presented in the original assessment report.

Table 4.3: Highest Long-term Predicted Environmental Concentrations – Original Assessment

Averaging period

(Pollutant) AQAL

(μg.m-3) Max PC (μg.m-3)

Max PC as % of AQAL


(Yes/No) AC

(µg.m-3) Max PEC (µg.m-3)


Annual mean (NO2)

40 2.0 5 Yes 14 16.0 No

4.6 Table 4.4 summarises the highest long-term PEC anywhere across the modelled grid for a single

24 m stack.

Table 4.4: Highest Long-term Predicted Environmental Concentrations – Schedule 5 Response

Averaging period

(Pollutant) AQAL

(μg.m-3) Max PC (μg.m-3)

Max PC as % of AQAL


(Yes/No) AC

(µg.m-3) Max PEC (µg.m-3)


Annual mean (NO2)

40 1.5 4 Yes 14 15.5 No

4.7 The maximum PC for the single-stack at 24 m is slightly lower than the maximum PC for the five

30 m stacks. In both cases, the results show that the maximum long-term PC anywhere across

the modelling grid is above 1% of the relevant AQAL; however, when the PC is added to the AC,

the maximum long-term PEC is below the AQAL. As such, the long-term NO2 impacts are

considered to be ‘not significant’.

4.8 Comparison of Tables 4.5 and 4.6 shows that there is a marginal decrease in the maximum PEC

for the aggregated stack option compared with the original submission. However, the predicted

long term impacts were already not significant for the original proposal with individual stacks and

the effect of stack aggregation on long-term impacts was also not significant.

Summary

4.9 In conclusion, this analysis has shown that the potential aggregation of stacks (compared with the

original proposal) will have minimal effect on both the predicted short term and long term air

quality impacts associated with this development.

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Glossary

ADMS Atmospheric Dispersion Modelling System

AQMA Air Quality Management Area

AQS Air Quality Strategy

Effect The consequences of an impact, experienced by a receptor

IAQM Institute of Air Quality Management

Impact The change in atmospheric pollutant concentration and/or dust deposition. A

scheme can have an ‘impact’ on atmospheric pollutant concentration but no

effect, for instance if there are no receptors to experience the impact.

MCPD Medium Combustion Plant Directive

NLC North Lincolnshire Council

R&A Review and Assessment

Receptor A person, their land or property and ecologically sensitive sites that may be

affected by air quality.

Risk The likelihood of an adverse event occurring

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rpsgroup.com/uk

References

1 https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit

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7893

-66

rpsgroup.com

Contact

Fiona Prismall Technical Director RPS Planning & Development 6-7 Lovers Walk Brighton East Sussex BN1 6AH

T: +44 (0) 1273 546 800 [email protected]

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EPR/BM4406IU/V006 Issued Page 1 of 21

Environment Agency permitting decisions

Bespoke Variation

We have decided to issue the variation for Roosecote Power Station operated by Centrica Distributed generation Limited.

The variation number is EPR/BM4406IU/V006

We consider in reaching that decision we have taken into account all relevant considerations and legal requirements and that the permit will ensure that the appropriate level of environmental protection is provided.

Purpose of this document This decision document:

explains how the application has been determined

provides a record of the decision-making process

shows how all relevant factors have been taken into account

justifies the specific conditions in the permit other than those in our generic permit template.

Unless the decision document specifies otherwise we have accepted the applicant’s proposals. Structure of this document

Description of the changes introduced by the variation

Key issues

Annex 1 the decision checklist

Annex 2 the consultation responses

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Description of the changes introduced by the Variation This is a Substantial Variation.

The installation was previously permitted to operate one Large Combustion Plant (LCP); LCP No. 57, a single 456 MWth combined cycle gas turbine with a heat recovery steam generator and steam turbine. This had a maximum electrical output of 224 MW from operation of the CCGT. The former power station and supporting ancillary plant have since been demolished and therefore there is no existing unit present on site.

This variation removes the original combined cycle gas turbine, which has since been decommissioned and demolished, as well as removal of the demolished heat recovery steam generator, steam turbine and ancillary plant. This variation adds a peaking plant operating comprising up to five reciprocating spark-ignition gas engines. The new plant will have a total thermal input of circa 105 MW and will produce up to 49.9 MW of electricity gross. The proposed facility will operate to provide additional energy security during periods of peak electricity consumption within the UK. This electricity will be exported to the grid. Operation of the peaking plant is limited to 1,500 hours per annum per engine.

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Key issues of the decision

The Installation’s environmental impact Regulated activities can present different types of risk to the environment, these include odour, noise and vibration; accidents, fugitive emissions to air and water; as well as point source releases to air, discharges to ground or groundwater, global warming potential and generation of waste and other environmental impacts. Consideration may also have to be given to the effect of emissions being subsequently deposited onto land (where there are ecological receptors). All these factors are discussed in this and other sections of this document. For an installation of this kind, the principal emissions are those to air. The following sections of this document explain how we have approached the critical issue of assessing the likely impact of the emissions to air from the Installation on human health and the environment. Assessment Methodology Application of Environment Agency Web Guide for Air Emissions Risk

Assessment A methodology for risk assessment of point source emissions to air, which we use to assess the risk of applications we receive for permits, is set out in our Web Guide and has the following steps:

Describe emissions and receptors Calculate process contributions Screen out insignificant emissions that do not warrant further

investigation Decide if detailed air modelling is needed Assess emissions against relevant standards Summarise the effects of emissions

The methodology uses a concept of “process contribution (PC)”, which is the estimated concentration of emitted substances after dispersion into the receiving environmental media at the point where the magnitude of the concentration is greatest. The guidance provides a simple method of calculating PC primarily for screening purposes and for estimating process contributions where environmental consequences are relatively low. It is based on using dispersion factors. These factors assume worst case dispersion conditions with no allowance made for thermal or momentum plume rise and so the process contributions calculated are likely to be an overestimate of the actual maximum concentrations. More accurate calculation of process contributions can be achieved by mathematical dispersion models, which take into account relevant parameters of the release and surrounding conditions, including local

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meteorology – these techniques are expensive but normally lead to a lower prediction of PC. Use of Air Dispersion Modelling For this type of application, we normally require the Applicant to submit a full air dispersion model as part of their application, for the key pollutants. Air dispersion modelling enables the process contribution to be predicted at any environmental receptor that might be impacted by the plant. Once short-term and long-term PCs have been calculated in this way, they are compared with Environmental Quality Standards (EQS). Where an EU EQS exists, the relevant standard is the EU EQS. Where an EU EQS does not exist, our guidance sets out a National EQS (also referred to as Environmental Assessment Level - EAL) which has been derived to provide a similar level of protection to Human Health and the Environment as the EU EQS levels. In a very small number of cases, e.g. for emissions of Lead, the National EQS is more stringent that the EU EQS. In such cases, we use the National EQS standard for our assessment. National EQSs do not have the same legal status as EU EQSs, and there is no explicit requirement to impose stricter conditions than BAT in order to comply with a national EQS. However, national EQSs are a standard for harm and any significant contribution to a breach is likely to be unacceptable. PCs are considered Insignificant if:

the long-term process contribution is less than 1% of the relevant EQS; and

the short-term process contribution is less than 10% of the relevant EQS.

The long term 1% process contribution insignificance threshold is based on the judgements that:

It is unlikely that an emission at this level will make a significant contribution to air quality;

The threshold provides a substantial safety margin to protect health and the environment.

The short term 10% process contribution insignificance threshold is based on the judgements that:

spatial and temporal conditions mean that short term process contributions are transient and limited in comparison with long term process contributions;

the threshold provides a substantial safety margin to protect health and the environment.

Where an emission is screened out in this way, we would normally consider that the Applicant’s proposals for the prevention and control of the emission to

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be BAT. That is because if the impact of the emission is already insignificant, it follows that any further reduction in this emission will also be insignificant. However, where an emission cannot be screened out as insignificant, it does not mean it will necessarily be significant. For those pollutants which do not screen out as insignificant, we determine whether exceedances of the relevant EQS are likely. This is done through detailed audit and review of the Applicant’s air dispersion modelling taking background concentrations and modelling uncertainties into account. Where an exceedance of an EU EQS is identified, we may require the Applicant to go beyond what would normally be considered BAT for the Installation or we may refuse the application if the applicant is unable to provide suitable proposals. Whether or not exceedances are considered likely, the application is subject to the requirement to operate in accordance with BAT. This is not the end of the risk assessment, because we also take into account local factors (for example, particularly sensitive receptors nearby such as a SSSIs, SACs or SPAs). These additional factors may also lead us to include more stringent conditions than BAT. If, as a result of reviewing of the risk assessment and taking account of any additional techniques that could be applied to limit emissions, we consider that emissions would cause significant pollution, we would refuse the Application. Assessment of Impact on Air Quality The Applicant’s assessment of the impact of air quality is set out in the following document submitted with the Application: ‘Air Quality Assessment for Substantial Permit Variation Application’, revision2, dated 09/06/16. The assessment comprises:

Dispersion modelling of emissions to air from the operation of the installation.

A study of the impact of emissions on nearby sensitive habitat / conservation sites.

This section of the decision document deals primarily with the dispersion modelling of emissions to air from the installation and its impact on local air quality. The impact on conservation sites is considered below. The Applicant has assessed the Installation’s potential emissions to air against the relevant air quality standards, and the potential impact upon local conservation and habitat sites and human health. These assessments predict the potential effects on local air quality from the Installation’s stack emissions using the ADMS 5 dispersion model, which is a commonly used computer model for regulatory dispersion modelling. The model used 5 years of meteorological data collected from the weather station at Walney Island Airfield between 2010 and 2014. This weather station was selected as it is the closest

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to the installation. The impact of the terrain surrounding the site upon plume dispersion was considered in the dispersion modelling. The air impact assessments, and the dispersion modelling upon which they were based, employed the following assumptions. First, they assumed that the NO2 emission limit values (ELVs) in the Permit

would be based on the Medium Combustion Plant Directive emission limit of 95 mg/m3.

Second, they assumed that the Installation operates for a maximum of 1500 hours at the relevant long-term or short-term emission limit value.

We are in agreement with this approach. The assumptions underpinning the model have been checked and are reasonably precautionary. The Applicant has used a background from the DEFRA background maps. We agree with the Applicant that this selection of background value is appropriate. As well as calculating the peak ground level concentration, the Applicant has modelled the concentration of key pollutants at a number of specified locations within the surrounding area. The way in which the Applicant used dispersion models, its selection of input data, use of background data and the assumptions it made have been reviewed by the Environment Agency’s modelling specialists to establish the robustness of the Applicant’s air impact assessment. The output from the model has then been used to inform further assessment of health impacts and impact on habitats and conservation sites. Our review of the Applicant’s assessment leads us to agree with the Applicant’s conclusions. The Applicant’s modelling predictions are summarised in the following sections. Assessment of Air Dispersion Modelling Outputs The Applicant’s modelling predictions are summarised in the tables below. The Applicant’s modelling predicted pollutant concentrations at discreet receptors. The tables below show the ground level concentrations at the most impacted receptor.

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Pollutant EQS / EAL Back-ground

Process Contribution (PC)

Predicted Environmental Concentration (PEC)Note 1

µg/m3 µg/m3 µg/m3 % of EAL µg/m3 % of EAL

NO2 40 9 0.3 0.75 - -

200 18 11.6 6 - -

Note 1: Where an emission is insignificant we do not consider the PEC. (i) Screening out emissions which are insignificant The table above shows that emissions of both long term and short term NO2

are considered insignificant in that the process contribution is <1% of the long term EQS/EAL and <10% of the short term EAQ/EAL. For these emissions, we have also assessed the Applicant’s proposals to ensure that they are applying the Best Available Techniques to prevent and minimise emissions of these substances. This is reported below. Consideration of key pollutants

(i) Nitrogen dioxide (NO2) The impact on air quality from NO2 emissions has been assessed against the EU EQS of 40 g/m3 as a long term annual average and a short term hourly average of 200 g/m3. The model assumes a 70% NOx to NO2 conversion for the long term and 35% for the short term assessment in line with Environment Agency guidance on the use of air dispersion modelling. The above tables show that the long term PC at discrete receptors is less than 1% of the long term EU EQS and less than 10% of the short term EU EQS and therefore is screened out as insignificant. (ii) Dust Natural gas is an ash-free fuel and high efficiency combustion in the gas engines does not generate additional particulate matter. The fuel gas is always filtered. Thus for natural gas fired engines dust emissions are not an issue. (iii) Sulphur Dioxide Natural gas, that meets the standard for acceptance into the National transmission System, is considered to be sulphur free fuel. Hence, sulphur dioxide emissions from burning natural gas, were not considered to be significant and so were not modelled by the Applicant. We agree with this approach.

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(iv) Carbon Monoxide Efficient combustion within the proposed plant will ensure that levels of carbon monoxide (CO) are minimised. Control and management of combustion conditions within the proposed gas engines, including performance monitoring, process control techniques and suitable maintenance regimes, will be in place to minimise CO emissions. Impact on Habitats sites, SSSIs, non-statutory conservation sites etc. Sites Considered The following Habitats (i.e. Special Areas of Conservation, Special Protection Areas and Ramsar) sites are located within 10km of the Installation:

Morecambe Bay SAC

Duddon Estuary Ramsar/SPA The following Site of Special Scientific Interest is located within 2 km of the Installation:

South Walney and Piel Channel Flats SSSI

The following non-statutory local wildlife and conservation sites are located within 2 km of the Installation:

Salhouse Pool Country Wildlife Site Country Wildlife Site (CWS)

Stank and Roosecote Moss CWS

Stone Dyke CWS

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Habitats Assessment The following table shows the maximum process contributions at Morecombe Bay SAC.

Pollutant EQS / EAL (µg/m³)

Back-ground (µg/m³)

Process Contribution(PC) (µg/m³)

PC as % of EQS / EAL

Predicted Environmental Concentration (PEC) (µg/m³) Note 1

PEC as % EQS / EAL

Direct Impacts2

NOx Annual 30 7.7 0.7 2.5 8.5 23.8 NOx

Daily Mean 75 15.4 16.3 21.7 31.8 53.8

Deposition Impacts2

N Deposition (kg N/ha/yr)

8-10 13.1 0.0744 0.9 - -

Acid Deposition (Keq/ha/yr)

0.643 0.93 0.0053 0.83 - -

Note 1: Where an emission is insignificant we do not consider the PEC. Note 2: Direct impact units are µg/m³ and deposition impact units are kg N/ha/yr or Keq/ha/yr

(i) Screening out emissions which are insignificant The PC for both N deposition and acid deposition are <1% of the Critical Loads and therefore screen out as insignificant and it is possible to conclude no likely significant effect. (ii) Emissions unlikely to give rise to significant pollution The tables above show that the PCs for direct impacts from NOx are not considered insignificant as they are >1% of the long term Critical Level and >10% of the short term Critical Level. However, when taking the background into account, there is adequate headroom to indicate that an exceedence of the Critical Level is unlikely and it is possible to conclude no likely significant effect. The following table shows the maximum process contributions at Duddon Estuary Ramsar/SPA.

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PEC as % EQS / EAL

Direct Impacts2

NOx Annual 30 6 0.05 0.2 - - NOx

Daily Mean 75 12 2.5 3.3 14.5 14.6

Deposition Impacts2


8-10 13.3 0.0048 0.1 - -

Acid Deposition (Keq/ha/yr)

0.769 0.95 0.0003 0.05 - -

Note 1: Where an emission is insignificant we do not consider the PEC.Note 2: Direct impact units are µg/m³ and deposition impact units are kg N/ha/yr or Keq/ha/yr

(i) Screening out emissions which are insignificant The tables above show that the PC for direct impact from both long term and short NOx is considered insignificant as it is <1% of the long term Critical Level and <10% of the short term critical level and therefore we can conclude no likely significant effect. The PC for both N deposition and acid deposition are <1% of the Critical Loads and are therefore considered insignificant and it is possible to conclude no likely significant effect. The Applicant’s assessment of Habitats was reviewed by the Environment Agency’s technical specialists for modelling, air quality, conservation and ecology technical services, who agreed with the assessment’s conclusions, that it is possible to conclude no likely significant effect. We are satisfied that the Installation will not cause significant pollution at the sites. The Applicant is required to prevent, minimise and control emissions using BAT, considered elsewhere in this document.

SSSI Assessment The table below shows the maximum impact at South Walney and Piel Channel Flats SSSI






PEC as % EQS / EAL

Direct Impacts2

NOx Annual 30 6.9 0.7 2.5 7.7 25.6

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PEC as % EQS / EAL

NOx

Daily Mean 75 13.8 16.3 21.7 30.2 52.7

Deposition Impacts2


10 13.1 0.0744 0.74 - -

Acid deposition (Keq/ha/yr)

0.643 0.89 0.0053 0.83 - -


(i) Screening out emissions which are insignificant The table above shows that emissions of both nitrogen deposition and acid deposition are considered insignificant in that the process contribution is <1% of the relevant Critical Loads. It can be concluded that the emissions are not likely to damage the SSSI. (ii) Emissions unlikely to give rise to significant pollution The PC for direct impact from long term NOx is not <1% of the Critical Level and the direct impact from short term NOx is not <10% of the Critical Level and are therefore not considered insignificant. However, when taking the background into account, there is adequate headroom to indicate that an exceedence of the Critical Levels is unlikely and it is possible to conclude the emissions are not likely to damage the SSSI.

The Applicant’s assessment of the SSSI was reviewed by the Environment Agency’s technical specialists for modelling, air quality, conservation and ecology technical services, who agreed with the assessment’s conclusions, that the proposal is not likely to damage the special features of the SSSI.

Assessment of other conservation sites Conservation sites are protected in law by legislation. The Habitats Directive provides the highest level of protection for SACs and SPAs, domestic legislation provides a lower but important level of protection for SSSIs. Finally the Environment Act provides more generalised protection for flora and fauna rather than for specifically named conservation designations. It is under the Environment Act that we assess other sites (such as local wildlife sites) which prevents us from permitting something that will result in significant pollution; and which offers levels of protection proportionate with other European and national legislation. However, it should not be assumed that because levels of protection are less stringent for these other sites that they are not of considerable importance. Local sites link and support EU and national nature

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conservation sites together and hence help to maintain the UK’s biodiversity resilience. For SACs SPAs, Ramsars and SSSIs we consider the contribution PC and the background levels in making an assessment of impact. In assessing these other sites under the Environment Act we look at the impact from the Installation alone in order to determine whether it would cause significant pollution. This is a proportionate approach, in line with the levels of protection offered by the conservation legislation to protect these other sites (which are generally more numerous than Natura 2000 or SSSIs) whilst ensuring that we do not restrict development. Critical levels and loads are set to protect the most vulnerable habitat types. Thresholds change in accordance with the levels of protection afforded by the legislation. Therefore the thresholds for SAC SPA and SSSI features are more stringent than those for other nature conservation sites. Therefore we would generally conclude that the Installation is not causing significant pollution at these other sites if the PC is less than the relevant critical level or critical load, provided that the Applicant is using BAT to control emissions. The following table shows the maximum impact at the Salhouse Pool County Wildlife Site CWS. This was the most impacted local conservation site.






PEC as % EQS / EAL

Direct Impacts2

NOx Annual 30 11.4 0.6 1.9 12 39.9 NOx

Daily Mean 75 11.4 15.5 20.7 38.3 51.1

Deposition Impacts2


10 - 20 12.9 0.0564 0.6 - -

Acid deposition (Keq/ha/yr)

4.7 1.1 0.0040 0.09 - -


(i) Screening out emissions which are insignificant The tables show that the PCs for N deposition and acid deposition are <1% and we can conclude that impacts are insignificant. (ii) Emissions unlikely to give rise to significant pollution The PC for direct impact from long term NOx is not <1% of the Critical Level and the direct impact from short term NOx is not <10% of the Critical Level and

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are therefore not considered insignificant. However, the tables above show that the PCs (and also the PEC’s) are below the critical levels or loads. We are satisfied that the Installation will not cause significant pollution at the sites. The Applicant’s assessment of impacts on local conservation sites was reviewed by the Environment Agency’s technical specialists for modelling, air quality, conservation and ecology technical services, who agreed with the assessment’s conclusions, that there would be no likely impact on the sites. Stack configuration Aggregation of the 30 metre tall gas engine emission stacks into a single windshield would normally give better dispersion than individual stacks. The operator has provided a BAT assessment report for their proposed individual stack configuration. As outlined above, the dispersion modelling for the five stack configuration predicts that ground level NO2 concentrations will be within acceptable levels and therefore the impact on air quality will not be significant. The Applicant’s analysis shows that the predicted effect on air quality resulting from a changed stack configuration would be minimal. In addition there are issues with maintenance access, plant footprint and additional cost for combined flues. In view of the above, the Environment Agency’s technical specialists, agree with the assessment’s conclusions, that there would be no likely benefit from stack aggregation. Cooling systems As highlighted within the EU BREF for industrial cooling , there is a balance of environmental considerations when considering the cooling option to be employed and that any of the methods below may be considered BAT depending on circumstance. • Once-through river water; • Evaporative cooling tower; • Hybrid cooling tower; and • Fin-fan coolers. Each potential system has its particular advantages and disadvantages. Watercooling methods would have issues surrounding the irregular nature of the peaking plant generation. Due to the intermittent nature of operation of the peaking plant, settlement and siltation within the cooling system is a key problem, which could lead to blockages in the condenser/heat exchanger. This would result in increased maintenance costs and reduced cooling efficiency and could potentially affect reliability of the system. Hence the intermittent requirements for cooling, may cause additional costs and energy penalties. There are potential issues with, biological control and use of dosing chemicals.

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Fin-fan coolers have no significant water consumption requirement and hence will not result in additional effluent discharges. Whilst fin fan coolers can give rise to greater noise impacts, the noise assessment carried out has concluded that the noise effects from the peaking plant will not result in significant noise impacts. It is recognised that the fin-fan cooler option has a higher energy demand than other cooling options, however the extra energy consumption by the fin-fan coolers, which could be as high as 0.5MWe (1% of output), will not have a large impact on the overall energy efficiency for the project. On the basis of the above arguments, fin-fan coolers within a closed circuit cooling water system are considered BAT for this limited hours operation peaking plant. Energy Efficiency Directive Article 14 of the Energy Efficiency Directive require certain types of combustion installations to carry out a cost benefit analysis for cogeneration (also known as combined heat and power) or supplying a district heating or cooling network when substantially changing an existing installation. Certain installations are exempt from the requirements for cost benefit analysis as described below. Table 2 – CBA exempt installations Type of thermal electricity generating installation

(a) those peak load and back-up electricity generating installations which are planned to operate under 1 500 operating hours per year as a rolling average over a period of five years, based on a verification procedure established by the Member States ensuring that this exemption criterion is met.

Hence as a combustion plant limited to 1500 hours per year a CHP review is not required for this installation.

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Annex 1: decision checklist This document should be read in conjunction with the application, supporting information and permit/notice. Aspect considered

Justification / Detail Criteria met Yes

Receipt of submission

Confidential information

A claim for commercial or industrial confidentiality has not been made.

Identifying confidential information

We have not identified information provided as part of the application that we consider to be confidential. The decision was taken in accordance with our guidance on commercial confidentiality.

Consultation

Scope of consultation

The consultation requirements were identified and implemented. The decision was taken in accordance with our Public Participation Statement and our Working Together Agreements.

For this application we consulted the following bodies:

Barrow Borough Council Cumbria County Council Public Health England Health & Safety Executive National Grid

Responses to consultation, web publicising

The web publicising, responses (Annex 2) were taken into account in the decision.

The decision was taken in accordance with our guidance.

European Directives

Applicable directives

All applicable European directives have been considered in the determination of the application.

The site

Extent of the site of the facility

Plans are included in the permit and the operator is required to carry on the permitted activities within the site boundary.

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Aspect considered


Biodiversity, Heritage, Landscape and Nature Conservation

The application is within the relevant distance criteria of a site of heritage, landscape or nature conservation, and/or protected species or habitat .

A full assessment of the application and its potential to affect the sites has been carried out as part of the permitting process. We consider that the application will not affect the features of the site/habitat.

We have not formally consulted on the application. The decision was taken in accordance with our guidance.

See Key issues section for detailed assessment.

Environmental Risk Assessment and operating techniques

Environmental risk

We have reviewed the operator's assessment of the environmental risk from the facility.

The operator’s risk assessment is satisfactory.

Point source emissions to air. As discussed in the key issues section, for all human health and ecological receptors the impacts from the proposed variation, no significant pollution is predicted.

Point source emissions to water. There will be no process water discharges to sewer or surface water. Discharges to water will be restricted to surface water run-off from the roof, hardstanding and paved areas etc. and water will flow through the existing surface water drainage system before release into Salthouse Pool. There will be no point source emissions to land or groundwater.

Noise. The noise effects from the new peaking plant have been modelled. The effects at noise sensitive receptors have been determined to be negligible and with mitigation no adverse impacts are anticipated.

Waste generation from the peaking plant is anticipated to be low, and will result primarily from maintenance activities.

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Aspect considered


Operating techniques

We have reviewed the techniques used by the operator and compared these with the relevant guidance notes.

Emissions of Nitrogen Dioxide(NO2) cannot be screened out as insignificant. The Environment Agency has therefore assessed whether the proposed techniques are BAT. The impact of NOx emissions from the Installation is

Addressed in the Key issues section of this document.

Relevant guidance on BAT includes the Department of Energy and Climate Change “Developing Best Available Techniques for combustion plants operating in the balancing market” report by Amec Foster Wheeler and the Environment Agency draft guidance “Regulatory guidance for regulating >50MWth gas and oil fired plants operating in the balancing market under the Industrial Emissions Directive”

The Regulatory guidance gives a hierarchy of plant types, emission limits and operating hours for the balancing market. For a maximum of 1500 hours per annum operation, high efficiency gas engines are considered BAT with medium combustion plant directive emission limits.

Combustion temperatures within the piston of spark ignition engines are low, meaning gas engines inherently produce low NOx. Lean burn technology is to be applied which suppresses NOx formation. The gas engines achieve 95mg/m³ NOx which is the directive limit and the limit for gas engines in the Amec Foster Wheeler report.

Selective Catalytic Reduction(SCR) is not considered feasible for gas engines operating in the balancing market as it is not active for the first 30 minutes of plant operation.

Therefore the proposed techniques are considered to represent appropriate techniques for the facility.

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Aspect considered


The permit conditions

Updating permit conditions during consolidation.

We have updated previous permit conditions to those in the new generic permit template as part of permit consolidation. The new conditions have the same meaning as those in the previous permits.

The operator has agreed that the new conditions are acceptable.

Use of conditions other than those from the template

Based on the information in the application, we consider that we do not need to impose conditions other than those in our permit template, which was developed in consultation with industry having regard to the relevant legislation.

Pre-operational conditions

Based on the information in the application, we consider that we need to impose pre-operational conditions.

We have imposed conditions to ensure that:

A report be provided with final designs for the gas engines together with a review that the final design meets the requirements of BAT and that the environmental impact assessment still reflects the predicted impacts from the installation. This is to confirm the proposed engines represent the application and number of engines and blackstart options are confirmed.

Improvement conditions

Based on the information on the application, we consider that we need to impose improvement conditions.

We have imposed improvement conditions to ensure that:

Definition of the start-up and shut down definitions are provided for the gas engines. This will enable reporting of operating hours.

Notification is given to the Agency of completion of commissioning of the gas engines.

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Aspect considered


A commissioning report is provided to the Agency providing results of the commissioning programme and detailing any significant changes made.

A report be provided on the assessment of the potential release and impacts of formaldehyde from the gas engines.

A report be provided on the environmental impact of methane slip from the gas engines.

The improvement conditions for reports on formaldehyde and methane slip are standard for all gas engine installations. This is to establish what the generic impacts may be from this technology and how it compares with other technologies like CCGT’s. It should also allow the operator to demonstrate that there will be no harm to human health from Formaldehyde emissions.

Incorporating the application

We have specified that the applicant must operate the permit in accordance with descriptions in the application, including all additional information received as part of the determination process.

These descriptions are specified in the Operating Techniques table in the permit.

Emission limits We have decided that emission limits should be set for the parameters listed in the permit.

The following substances have been identified as being emitted in significant quantities and ELVs have been set for those substances.

A Nitrogen Dioxide limit of 95mg/m³ has been set. This limit is the relevant limit for new gas engines from the Medium Combustion Plant Directive.

It is considered that the ELVs equivalent parameters or technical measures described above will ensure that significant pollution of the environment is prevented and a high level of protection for the environment secured.

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Aspect considered


Monitoring We have decided that monitoring should be carried out for the parameters listed in the permit, using the methods detailed and to the frequencies specified.

These monitoring requirements have been imposed in order to satisfy the requirements of the Medium Combustion Plant Directive.

Based on the information in the application we are satisfied that the operator’s techniques, personnel and equipment have either MCERTS certification or MCERTS accreditation as appropriate.

Condition 3.1.4 relating to protection of soil, groundwater and groundwater monitoring, has been added in compliance with IED requirements.

Reporting We have specified reporting in the permit.

The reporting requirements have been imposed in order to satisfy the requirements of the Medium Combustion Plant Directive and Electricity Supply Industry reporting protocols.

Operator Competence

Environment management system

There is no known reason to consider that the operator will not have the management systems to enable it to comply with the permit conditions. The decision was taken in accordance with our guidance on what a competent operator is.

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Annex 2: External Consultation & web publicising advertising responses Summary of responses to consultation and web publication and the way in which we have taken these into account in the determination process. Response received from Public Health England Brief summary of issues raised No significant concerns raised Summary of actions taken or show how this has been covered

Response received from Barrow Borough Council Brief summary of issues raised Notified that planning consent contains noise conditions Summary of actions taken or show how this has been covered

Standard noise conditions used. AQMAU review of modelling data screened noise assessment out as low risk not requiring full audit.

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Roosecote Power Station Variation and consolidation number EPR/BM4406IU/V006 1

Notice of variation and consolidation with introductory note The Environmental Permitting (England & Wales) Regulations 2010

Centrica Distributed Generation Limited

Roosecote Power Station Rampside Road Barrow in Furness Cumbria LA13 0PQ

Variation application number

EPR/BM4406IU/V006

Permit number

EPR/BM4406IU

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Site Name Permit number EPR/BM4406IU

Introductory note

This introductory note does not form a part of the notice.

Under the Environmental Permitting (England & Wales) Regulations 2010 (schedule 5, part 1, paragraph 19) a variation may comprise a consolidated permit reflecting the variations and a notice specifying the variations included in that consolidated permit.

Schedule 1 of the notice specifies that all the conditions of the permit have been varied and schedule 2 comprises a consolidated permit which reflects the variations being made and contains all conditions relevant to this permit.

The consolidated variation notice takes into account and brings together in a single document all previous variations that relate to the original permit issued. It also modernises all conditions to reflect the conditions contained in our current generic permit template.

The requirements of the Industrial Emissions Directive (IED) 2010/75/EU are given force in England through the Environmental Permitting (England and Wales) Regulations 2010 (the EPR) (as amended).

The installation was previously permitted to operate one Large Combustion Plant (LCP); LCP No. 57, a single 456 MWth combined cycle gas turbine with a heat recovery steam generator and steam turbine. This had a maximum electrical output of 224 MW from operation of the CCGT. The former power station and supporting ancillary plant have since been demolished and therefore there is no existing unit present on site.

This variation removes, from the permit, the original combined cycle gas turbine, which has since been decommissioned and demolished, as well as removal of the demolished heat recovery steam generator, steam turbine and ancillary plant. This variation adds a peaking plant operating comprising up to five reciprocating spark-ignition gas engines to the permit. The new plant will have a total thermal input of circa 105 MW and will produce up to 49.9 MW of electricity gross. The proposed facility will operate to provide additional energy security during periods of peak electricity consumption within the UK. This electricity will be exported to the grid. Operation of the peaking plant is limited to 1,500 hours per engine per annum. Natural gas will be delivered to the new peaking plant via a dedicated gas supply. The electrical output from the plant will be exported to the 132kV Distribution Network via a step up transformer. Cooling for the gas engines will be provided by new fin-fan coolers which will operate in a closed circuit cooling water system. Emissions to air will result from the combustion of natural gas within the gas engines, which will be released into the atmosphere via 5 dedicated exhaust stacks 30m high. It is expected that there will be no significant sources of odour resulting from the operation of the peaking plant. The main pollutants from the facility will be gaseous combustion products (oxides of nitrogen and carbon monoxide). Assessment by the Environment Agency shows that the nitrogen dioxide (NO2) impact from the proposed activity is likely to be insignificant at sensitive human receptors. There are no process emissions released to sewer from the site and only uncontaminated surface waters are discharged to Roosecote Sands. The land surrounding the installation to the south is a gas terminal; whilst to the north-west are a sewage works and small industrial area. To the north-east of the site and to the east beyond Rampside Road are fields and agricultural land. Adjacent to the site to the south-west is an area of sand flats and wetland areas draining into Morecambe Bay. The closest residential properties are located approximately 650m to the north of the peaking plant’s location at Dowie Close.

The majority of the site forms part of the Morecambe Bay Special Protection Area (SPA), Special Area of Conservation (SAC), Site of Special Scientific Interest (SSSI) and wetland of international importance under the RAMSAR convention. South Walney and Piel Channel Flats, designated SSSI and SPA, is within 100 metres from the Installation ,and the Duddon Estuary, designated SPA and RAMSAR lies approximately 3KM from the Installation. Both Elliscales Quarry and Sea Wood are designated SSSI sites and located

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within 10Km of the Installation. Assessment by the Environment Agency shows that emissions from activities undertaken by the Installation are unlikely to have a significant impact on the habitat sites.

There are no changes to the installation boundary as a result of this variation.

The status log of a permit sets out the permitting history, including any changes to the permit reference number.

Status log of the permit

Description Date Comments

Application BM4406IU Duly made 29/03/2006

Additional information received 29/11/2006

Permit determined

19/12/2006

Variation application Duly made 05/10/2009

Additional information received Requested 07/10/2009

Received 16/10/2009

Variation determined EPR/BM4406IU/V003

11/03/2013 Environment Agency Initiated Variation to incorporate Eel Regulations improvement condition

Variation determined EPR/BM4406IU/V004

(PAS Billing ref PP3232RP)

14/12/2015 Agency Initiated variation to include condition 2.1.2 requiring the operator to provide evidence that the facility will operate in accordance with Chapter III of the Industrial Emissions Directive.

Varied Permit Issued.

Variation Application to Change Company name

04/03/2016

Variation issued EPR/BM4406IU/V005

07/03/2016 Name changed to Centrica Distributed Generation Limited

Variation application EPR/BM4406IU/V006

Duly made 01/07/16

Variation to replace combined cycle gas turbines with 5 gas spark engines

Additional Information received 13/10/16 Response to Schedule 5 Notice issued 21/9/16

Variation determined EPR/BM4406IU

01/12/2016 Varied and consolidated permit issued in modern condition format.

End of introductory note

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Notice of variation and consolidation

The Environmental Permitting (England and Wales) Regulations 2010

The Environment Agency in exercise of its powers under regulation 20 of the Environmental Permitting (England and Wales) Regulations 2010 varies and consolidates

Permit number

EPR/BM4406IU

Issued to

Centrica Distributed Generation Limited (“the operator”)

whose registered office is

Millstream Maidenhead Road Windsor Berkshire SL4 5GD

company registration number 04713745

to operate a regulated facility at


to the extent set out in the schedules.

The notice shall take effect from 01/12/2016

Name Date

J Linton 01/12/2016

Authorised on behalf of the Environment Agency

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Schedule 1

All conditions have been varied by the consolidated permit as a result of an Environment Agency initiated variation.

Schedule 2 – consolidated permit

Consolidated permit issued as a separate document.

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Permit number EPR/BM4406IU 6

Permit

The Environmental Permitting (England and Wales) Regulations 2010

Permit number

EPR/BM4406IU/V006

This is the consolidated permit referred to in the variation and consolidation notice for application EPR/BM4406IU/V006 authorising,

Centrica Distributed Generation Limited (“the operator”),

whose registered office is.

Millstream Maidenhead Road Windsor Berkshire SL4 5GD

company registration number 04713745

to operate an installation at


to the extent authorised by and subject to the conditions of this permit.

Name Date

J Linton 01/12/2016

Authorised on behalf of the Environment Agency

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Conditions

1 Management

1.1 General management

1.1.1 The operator shall manage and operate the activities:

(a) in accordance with a written management system that identifies and minimises risks of pollution, including those arising from operations, maintenance, accidents, incidents, non-conformances, closure and those drawn to the attention of the operator as a result of complaints; and

(b) using sufficient competent persons and resources.

1.1.2 Records demonstrating compliance with condition 1.1.1 shall be maintained.

1.1.3 Any person having duties that are or may be affected by the matters set out in this permit shall have convenient access to a copy of it kept at or near the place where those duties are carried out.

1.2 Energy efficiency

1.2.1 The operator shall:

(a) take appropriate measures to ensure that energy is used efficiently in the activities;

(b) take appropriate measures to ensure the efficiency of energy generation at the permitted installation is maximised;

(c) review and record at least every four years whether there are suitable opportunities to improve the energy efficiency of the activities; and

(d) take any further appropriate measures identified by a review.

1.3 Efficient use of raw materials


(a) take appropriate measures to ensure that raw materials and water are used efficiently in the activities;

(b) maintain records of raw materials and water used in the activities;

(c) review and record at least every four years whether there are suitable alternative materials that could reduce environmental impact or opportunities to improve the efficiency of raw material and water use; and

(d) take any further appropriate measures identified by a review.

1.4 Avoidance, recovery and disposal of wastes produced by the activities

1.4.1 The operator shall take appropriate measures to ensure that:

(a) the waste hierarchy referred to in Article 4 of the Waste Framework Directive is applied to the generation of waste by the activities;

(b) any waste generated by the activities is treated in accordance with the waste hierarchy referred to in Article 4 of the Waste Framework Directive; and

(c) where disposal is necessary, this is undertaken in a manner which minimises its impact on the environment.

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1.4.2 The operator shall review and record at least every four years whether changes to those measures should be made and take any further appropriate measures identified by a review.

2 Operations

2.1 Permitted activities

2.1.1 The operator is only authorised to carry out the activities specified in schedule 1 table S1.1 (the “activities”).

2.2 The site

2.2.1 The activities shall not extend beyond the site, being the land shown edged in green on the site plan at schedule 7 to this permit.

2.3 Operating techniques

2.3.1 The activities shall, subject to the conditions of this permit, be operated using the techniques and in the manner described in the documentation specified in schedule 1, table S1.2, unless otherwise agreed in writing by the Environment Agency.

2.3.2 If notified by the Environment Agency that the activities are giving rise to pollution, the operator shall submit to the Environment Agency for approval within the period specified, a revision of any plan or other documentation (“plan”) specified in schedule 1, table S1.2 or otherwise required under this permit which identifies and minimises the risks of pollution relevant to that plan , and shall implement the approved revised plan in place of the original from the date of approval, unless otherwise agreed in writing by the Environment Agency.

2.3.3 Any raw materials or fuels listed in schedule 2 table S2.1 shall conform to the specifications set out in that table.

2.3.4 The operator shall ensure that where waste produced by the activities is sent to a relevant waste operation, that operation is provided with the following information, prior to the receipt of the waste:

(a) the nature of the process producing the waste;

(b) the composition of the waste;

(c) the handling requirements of the waste;

(d) the hazardous property associated with the waste, if applicable; and

(e) the waste code of the waste.

2.3.5 The operator shall ensure that where waste produced by the activities is sent to a landfill site, it meets the waste acceptance criteria for that landfill.

2.3.6 For the following activities referenced in Schedule1, table S1.1: A1. The activities shall not operate for more than 1500 hours per year per engine.

2.4 Improvement programme

2.4.1 The operator shall complete the improvements specified in schedule 1 table S1.3 by the date specified in that table unless otherwise agreed in writing by the Environment Agency.

2.4.2 Except in the case of an improvement which consists only of a submission to the Environment Agency, the operator shall notify the Environment Agency within 14 days of completion of each improvement.

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2.5 Pre-operational conditions

2.5.1 The activities shall not be brought into operation until the measures specified in schedule 1 table S1.4 have been completed.

3 Emissions and monitoring

3.1 Emissions to water, air or land

3.1.1 There shall be no point source emissions to water, air or land except from the sources and emission points listed in schedule 3 tables S3.1 and S3.2

3.1.2 The limits given in schedule 3 shall not be exceeded.

3.1.3 The emission values from emission points A7, A8, A9, A10 and A11 listed in schedule 3 table S3.1, measured during periods of abatement equipment malfunction and breakdown shall be disregarded for the purposes of compliance with Table S3.1 emission limit values.

3.1.4 Periodic monitoring shall be carried out at least once every 5 years for groundwater and 10 years for soil, unless such monitoring is based on a systematic appraisal of the risk of contamination.

3.2 Emissions of substances not controlled by emission limits

3.2.1 Emissions of substances not controlled by emission limits (excluding odour) shall not cause pollution. The operator shall not be taken to have breached this condition if appropriate measures, including, but not limited to, those specified in any approved emissions management plan, have been taken to prevent or where that is not practicable, to minimise, those emissions.


(a) if notified by the Environment Agency that the activities are giving rise to pollution, submit to the Environment Agency for approval within the period specified, an emissions management plan which identifies and minimises the risks of pollution from emissions of substances not controlled by emission limits;

(b) implement the approved emissions management plan, from the date of approval, unless otherwise agreed in writing by the Environment Agency.

3.2.3 All liquids in containers, whose emission to water or land could cause pollution, shall be provided with secondary containment, unless the operator has used other appropriate measures to prevent or where that is not practicable, to minimise, leakage and spillage from the primary container.

3.3 Odour

3.3.1 Emissions from the activities shall be free from odour at levels likely to cause pollution outside the site, as perceived by an authorised officer of the Environment Agency, unless the operator has used appropriate measures, including, but not limited to, those specified in any approved odour management plan, to prevent or where that is not practicable to minimise the odour.


(a) if notified by the Environment Agency that the activities are giving rise to pollution outside the site due to odour, submit to the Environment Agency for approval within the period specified, an odour management plan which identifies and minimises the risks of pollution from odour;

(b) implement the approved odour management plan, from the date of approval, unless otherwise agreed in writing by the Environment Agency.

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3.4 Noise and vibration

3.4.1 Emissions from the activities shall be free from noise and vibration at levels likely to cause pollution outside the site, as perceived by an authorised officer of the Environment Agency, unless the operator has used appropriate measures, including, but not limited to, those specified in any approved noise and vibration management plan to prevent or where that is not practicable to minimise the noise and vibration.


(a) if notified by the Environment Agency that the activities are giving rise to pollution outside the site due to noise and vibration, submit to the Environment Agency for approval within the period specified, a noise and vibration management plan which identifies and minimises the risks of pollution from noise and vibration;

(b) implement the approved noise and vibration management plan, from the date of approval, unless otherwise agreed in writing by the Environment Agency.

3.5 Monitoring

3.5.1 The operator shall, unless otherwise agreed in writing by the Environment Agency, undertake the monitoring specified in the following tables in schedule 3 to this permit:

(a) point source emissions specified in table S3.1

3.5.2 The operator shall maintain records of all monitoring required by this permit including records of the taking and analysis of samples, instrument measurements (periodic and continuous), calibrations, examinations, tests and surveys and any assessment or evaluation made on the basis of such data.

3.5.3 Monitoring equipment, techniques, personnel and organisations employed for the emissions monitoring programme and the environmental or other monitoring specified in condition 3.5.1 shall have either MCERTS certification or MCERTS accreditation (as appropriate), where available, unless otherwise agreed in writing by the Environment Agency.

3.5.4 Permanent means of access shall be provided to enable sampling/monitoring to be carried out in relation to the emission points specified in schedule 3 tables S3.1 unless otherwise agreed in writing by the Environment Agency.

4 Information

4.1 Records

4.1.1 All records required to be made by this permit shall:

(a) be legible;

(b) be made as soon as reasonably practicable;

(c) if amended, be amended in such a way that the original and any subsequent amendments remain legible, or are capable of retrieval; and

(d) be retained, unless otherwise agreed in writing by the Environment Agency, for at least 6 years from the date when the records were made, or in the case of the following records until permit surrender:

(i) off-site environmental effects; and

(ii) matters which affect the condition of the land and groundwater.

4.1.2 The operator shall keep on site all records, plans and the management system required to be maintained by this permit, unless otherwise agreed in writing by the Environment Agency.

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4.2 Reporting

4.2.1 The operator shall send all reports and notifications required by the permit to the Environment Agency using the contact details supplied in writing by the Environment Agency.

4.2.2 A report or reports on the performance of the activities over the previous year shall be submitted to the Environment Agency by 31 January (or other date agreed in writing by the Environment Agency) each year. The report(s) shall include as a minimum:

(a) a review of the results of the monitoring and assessment carried out in accordance with the permit including an interpretive review of that data;

(b) the resource efficiency metrics set out in schedule 4 table S4.2;

(c) the performance parameters set out in schedule 4 table S4.3 using the forms specified in table S4.4 of that schedule and

(d) where condition 2.3.6 applies the hours of operation in any year;

4.2.3 Within 28 days of the end of the reporting period the operator shall, unless otherwise agreed in writing by the Environment Agency, submit reports of the monitoring and assessment carried out in accordance with the conditions of this permit, as follows:

(a) in respect of the parameters and emission points specified in schedule 4 table S4.1;

(b) for the reporting periods specified in schedule 4 table S4.1 and using the forms specified in schedule 4 table S4.4; and

(c) giving the information from such results and assessments as may be required by the forms specified in those tables.

4.2.4 The operator shall, unless notice under this condition has been served within the preceding four years, submit to the Environment Agency, within six months of receipt of a written notice, a report assessing whether there are other appropriate measures that could be taken to prevent, or where that is not practicable, to minimise pollution.

4.3 Notifications

4.3.1 In the event:

(a) that the operation of the activities gives rise to an incident or accident which significantly affects or may significantly affect the environment, the operator must immediately—

(i) inform the Environment Agency,

(ii) take the measures necessary to limit the environmental consequences of such an incident or accident, and

(iii) take the measures necessary to prevent further possible incidents or accidents;

(b) of a breach of any permit condition the operator must immediately—

(i) inform the Environment Agency, and

(ii) take the measures necessary to ensure that compliance is restored within the shortest possible time;

(c) of a breach of permit condition which poses an immediate danger to human health or threatens to cause an immediate significant adverse effect on the environment, the operator must immediately suspend the operation of the activities or the relevant part of it until compliance with the permit conditions has been restored.

4.3.2 Any information provided under condition 4.3.1 (a)(i) or 4.3.1(b)(i) where the information relates to the breach of a condition specified in the permit, shall be confirmed by sending the information listed in schedule 5 to this permit within the time period specified in that schedule.

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4.3.3 Where the Environment Agency has requested in writing that it shall be notified when the operator is to undertake monitoring and/or spot sampling, the operator shall inform the Environment Agency when the relevant monitoring and/or spot sampling is to take place. The operator shall provide this information to the Environment Agency at least 14 days before the date the monitoring is to be undertaken.

4.3.4 The Environment Agency shall be notified within 14 days of the occurrence of the following matters, except where such disclosure is prohibited by Stock Exchange rules:

Where the operator is a registered company: (a) any change in the operator’s trading name, registered name or registered office address; and

(b) any steps taken with a view to the operator going into administration, entering into a company voluntary arrangement or being wound up.

Where the operator is a corporate body other than a registered company: (c) any change in the operator’s name or address; and

(d) any steps taken with a view to the dissolution of the operator.

4.3.5 Where the operator proposes to make a change in the nature or functioning, or an extension of the activities, which may have consequences for the environment and the change is not otherwise the subject of an application for approval under the Regulations or this permit:

(a) the Environment Agency shall be notified at least 14 days before making the change; and

(b) the notification shall contain a description of the proposed change in operation.

4.3.6 The Environment Agency shall be given at least 14 days notice before implementation of any part of the site closure plan.

4.3.7 Where the operator has entered into a climate change agreement with the Government, the Environment Agency shall be notified within one month of:

(a) a decision by the Secretary of State not to re-certify the agreement;

(b) a decision by either the operator or the Secretary of State to terminate the agreement; and

(c) any subsequent decision by the Secretary of State to re-certify such an agreement.

4.4 Interpretation

4.4.1 In this permit the expressions listed in schedule 6 shall have the meaning given in that schedule.

4.4.2 In this permit references to reports and notifications mean written reports and notifications, except where reference is made to notification being made “immediately”, in which case it may be provided by telephone.

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Schedule 1 – Operations

Table S1.1 activities

Activity reference

Activity listed in Schedule 1 of the EP Regulations

Description of specified activity

Limits of specified activity

A1

Section 1.1 A(1) (a): Burning any fuel in an appliance with a rated thermal input of 50 megawatts or more.

5 Reciprocating Spark Ignition gas engines for the production of electricity

From receipt of natural gas to discharge of exhaust gases, and the generation of electricity.

Operation of combustion plant for no more than 1500 hours per year per engine.

Directly Associated Activity

A2 Directly associated activity Surface water drainage to Salhouse Pool

Handling and storage of site drainage from external areas of the site until discharged to the Salthouse Pool

A3 Directly associated activity Miscellaneous utility systems(including emergency diesel generator, lubrication systems, control systems)

From receipt of raw materials to dispatch for use

Table S1.2 Operating techniques

Description Parts Date Received

Variation Application BM4406IU/V006

Section 3 of the application document “ Roosecote Power Station Application to vary Permit EPR/BM4406IU For Centrica Distributed Generation Limited” provided in response to section 3a –technical standards, Part C3 of the application form

01/07/2016

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Table S1.3 Improvement programme requirements

Reference Requirement Date

IP1 A written plan shall be submitted to the Environment Agency for approval detailing measures required in order to prevent, and where that is not possible, minimise visible emissions during start-up and shutdown periods, in accordance with section 2.2.of TGN V2.03 “IPPC Sector Guidance Note for Combustion Activities",27 July 2005. This plan shall address those issues documented within sections 2.1,5.2/3 and 4.3.6 of the application, and shall include a timetable for the implementation of any such measures in order to ensure compliance with this condition. The plan shall be implemented by the operator from the date of approval in writing by the Environment Agency.

Complete

IP2 The Operator shall undertake an assessment into the containment measures on site. This shall include, but not be limited to bunding of distillate fuel oil storage tanks. The assessment shall take into account the requirements of section 2.2.6 and 2.2.9 of TGN V2.03 'IPPC Sector Guidance Note for Combustion Activities', 27 July 2005. A written report summarising the findings, together with a timetable for any improvements identified shall be submitted to the Environment Agency.

Complete

IP3 The Operator shall assess current monitoring equipment, personnel and organisations employed for air emissions monitoring (as specified within table S4.1 of this Permit) for compliance with MCERTS (condition 3.6.3), as specified within section 2.10.1.7 of the application. A written summary shall be provided to the Agency documenting the findings, together with a timetable for any improvements identified. The notification requirements of condition 2.5,2 shall be deemed to have been complied with upon submission of this plan.

Complete

IP4 The Operator shall carry out a further noise survey in accordance with the assessment procedure given in BS4142: 1997 Method for rating industrial noise affecting mixed residential and industrial areas. A written summary shall be provided to the Agency documenting the findings of the survey, together with a comparison to the assessment provided within appendix E of the application. The summary shall include a timetable for the implementation of any proposed improvements, as appropriate, and shall seek written approval from the Agency to the timescales indicated within the summary.

Complete

IP5 The Operator shall carry out monitoring for emissions to air of Carbon Monoxide from emission point A1 for the validation of current in-house methods, in accordance with table S4.1. Prior to undertaking such monitoring, the Operator shall submit a plan detailing proposed monitoring methods to the Agency for agreement. The plan shall have regard to Agency Technical Guidance Note M2 for monitoring. The results of the monitoring shall be reported to the Agency together with a summary report for the validation of current monitoring methods, in accordance with table S4.1. This report shall also identify any variations, which might exist, between monitoring results. This assessment shall be used to assess the requirement for either the reduction of, or setting of any additional monitoring parameters.

Complete

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IP6 The Operator shall assess options available for reducing emissions of NOx in order to meet benchmark levels, as detailed within section 3.2 of TGN V2.03 "IPPC Sector Guidance Note for Combustion Activities', 27 July 2005. A written report summarising the assessment shall be submitted to the Agency. This shall take into account air emissions data as provided within the application and; monitoring, as required by schedule 4 of the permit, and shall re-assess information on NOx control technologies, as provided within section 5.4.1 of the application. The report shall include a timetable for the implementation of any proposed improvements, as appropriate, and shall seek written approval from the Agency to the timescales indicated within the report.

Complete

IP7 The Operator shall carry out a waste minimisation audit, in accordance with section 2.4.2 of TGN V2.03 'IPPC Sector Guidance Note for Combustion Activities’, 27 July 2005. A summary of the audit shall be submitted to the Agency together with a timetable to implement any necessary improvements identified.

Complete

IP8 The Operator shall carry out a water efficiency audit, in accordance with section 2.7 of TGN V2.03 ‘IPPC Sector Guidance Note for Combustion Activities', 27 July 2005 A summary of the audit shall be submitted to the Agency together with a timetable to implement any necessary improvements identified.

Complete

IP9 The Operator shall carry out an Energy efficiency audit, in accordance with section of TGN V2,03 "IPPC Sector Guidance Note for Combustion Activities”, 27 July 2005 A summary of the audit shall be submitted to the Agency together with a timetable to implement any necessary improvements identified.

Complete

IP10 The Operator shall produce a written site closure plan, in accordance with section 2.11 of V2.03 'IPPC Sector Guidance Note for Combustion Activities", 27 July2005. A copy of the plan shall be submitted to the Environment Agency.

Complete

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IP11 The Operator shall undertake a review of the existing screening measures at the intakes and outfalls which provide and discharge water to and from the Installation. The review shall be undertaken with reference to the Eels (England and Wales) Regulations 2009 (SI 2009/3344) and the Environment Agency „‟Safe Passage of Eel‟‟ Regulatory Position Statement version 1 dated July 2012. The Operator shall submit details of the arrangement suitable to meet the requirements for the safe passage of eels [of the Eels (England and Wales) Regulations 2009 (SI 2009/3344)] by either:- � Providing a written proposal for the installation of an eel screen. � Providing a written proposal to the modification of existing screening arrangements. � Providing a written response with an explanation and description of how the existing screening arrangements can be regarded to meet the requirements for the safe passage of eels [of SI 2009/3344] either without change or with mitigation measures. � Providing a written response setting out a case for an exemption In all cases, the proposal shall be submitted in writing for the approval of the Environment Agency. Where appropriate, each proposal shall contain an assessment of alternative options considered including impacts on other fish species and an explanation of why the proposed option has been chosen. Where installation of eel screen; modification of existing arrangements; or mitigation measures are proposed, the submission shall contain relevant timescales for installation in accordance with the Safe Passage of Eel Regulatory Position Statement version 1 dated July 2012. The proposals shall be implemented in accordance with the Environment Agency’s written approval.

Complete

IP12 The Operator shall submit a report in writing to the Environment Agency for acceptance. The report shall define and provide a justification of start-up and shut down definitions for the gas engines.

3 months prior to completion of commissioning

IP13 The operator will provide written notification to the Environment Agency of the date when commissioning of the gas engine units is complete

1 month after completion of commissioning

IP14 The operator shall provide a commissioning report to the Environment Agency, detailing

i) The results of the commissioning programme: and ii) Any significant changes to the information provided in the pre-

operation condition report.

1 month after completion of commissioning

IP15 The Operator shall establish the methane emissions from the engines and compare these to the manufacturer’s specification and appropriate benchmark level as agreed in writing with the Environment Agency.

Based on the conclusions of this assessment the Operator shall propose an appropriate proposal to assess potential methane slip for the lifespan of the engines and outline an action plan that will be followed in the instance that emissions above the manufacturer’s specification or appropriate benchmark level are identified.

The result of the assessment and the proposed action plan shall be submitted in writing to the Environment Agency for approval.

12 months from commissioning or as otherwise agreed in writing with the Environment Agency.

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IP16 The Operator shall establish emissions of carbon monoxide and formaldehyde from the engines.

Using this information, an assessment of the impacts of carbon monoxide emissions and possible impacts of formaldehyde should be undertaken in line with our H1 guidance or equivalent methodology. A review of the emission levels in comparison to the relevant benchmark levels shall also be carried out. A written report detailing the findings of the assessment of the emissions, predicted impacts and the review in comparison to the relevant benchmarks should be submitted to the Environment Agency for approval.

12 months from commissioning or as otherwise agreed in writing with the Environment Agency.

Table S1.4 Pre-operational measures

Reference Pre-operational measures

1

The operator shall submit a report to the Environment Agency providing detailed design(s) for the new gas engines and a finalised location plan. The operator shall undertake a review of the final detailed design/ plans for the new unit(s) prior to construction to ensure that:

1) the final design will meet the requirements of BAT; . 2) the application still accurately reflects the final operating proposals; and 3) the environmental impact assessment still accurately reflects the predicted

impacts from the proposal.

The operator shall submit a written report to the Environment Agency for approval, 3 months prior to construction, detailing the findings of this review.

2 The operator shall inform the Environment Agency in writing prior to fuel being burned for the first time in the new gas engine units.

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Schedule 2 – Waste types, raw materials and fuels

Table S2.1 Raw materials and fuels

Raw materials and fuel description Specification

Natural Gas -

Diesel Oil <0.1% sulphur light fuel oil (diesel)

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Schedule 3 – Emissions and monitoring

Table S3.1 Point source emissions to air from spark ignition engines- emission limits and monitoring requirements

Emission point ref. & location

Parameter Source Limit (including unit)-these limits do not apply during start up or shut down.

Reference period

Monitoring frequency

Monitoring standard or method

A7,A8,A9,A10,A11 Oxides of Nitrogen (NO and NO2

expressed as NO2

Spark Ignition engine exhausts number 1-5 fired on natural gas

95 mg/m³ - Annually BS EN 14792

Carbon Monoxide

No limit set - Annually BS EN 15058

Oxygen No limit set - Annually BS EN 14789

Water Vapour No limit set - Annually BS EN 14790

As required by the Method Implementation Document for BS EN 15259

No limit set - Pre-operation and where there is a significant operational change

BS EN 15259

A12 Exhaust from black start diesel generator

No limit set -

Table S3.2 Point Source emissions to water (other than sewer) – emission limits and monitoring requirements

Emission point ref. & location

Parameter Source Limit (incl. unit)

Reference period

Monitoring frequency

Monitoring standard or method

W1 on site plan in schedule 7 prior to discharge to Salthouse Pool

No parameters set

Surface water run off from roofs, roads and hard standing

- - No permanent sampling access required

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Schedule 4 – Reporting

Parameters, for which reports shall be made, in accordance with conditions of this permit, are listed below.

Table S4.1 Reporting of monitoring data

Parameter Emission or monitoring point/reference

Reporting period Period begins

Oxides of nitrogen

A7, A8, A9, A10, A11 Every year 1 January

Carbon Monoxide

A7, A8, A9, A10, A11 Every year 1 January

Table S4.2: Annual Production/treatment

Parameter Units

Electricity Exported MWhr

Table S4.3 Performance parameters

Parameter Frequency of assessment Units

Engine operating hours Annually Operating Hours for each gas engine, total plant operating hours & number of runs

Table S4.4 Reporting forms

Media/

parameter

Reporting format Date of form

Air Form Air 1 or other form as agreed in writing by the Environment Agency

December 2016

Energy Usage

Form energy 1 or other form as agreed in writing with the Environment Agency

December 2016

Other performance Indicators

Form performance 1 or other form as agreed in writing by the Environment Agency

December 2016

Gas Engine operating hours

Form operating hours or other form agreed in writing with the Environment Agency

December 2016

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Schedule 5 – Notification

These pages outline the information that the operator must provide.

Units of measurement used in information supplied under Part A and B requirements shall be appropriate to the circumstances of the emission. Where appropriate, a comparison should be made of actual emissions and authorised emission limits.

If any information is considered commercially confidential, it should be separated from non-confidential information, supplied on a separate sheet and accompanied by an application for commercial confidentiality under the provisions of the EP Regulations.

Part A

Permit Number

Name of operator

Location of Facility

Time and date of the detection

(a) Notification requirements for any malfunction, breakdown or failure of equipment or techniques, accident, or emission of a substance not controlled by an emission limit which has caused, is causing or may cause significant pollution

To be notified within 24 hours of detection

Date and time of the event

Reference or description of the location of the event

Description of where any release into the environment took place

Substances(s) potentially released

Best estimate of the quantity or rate of release of substances

Measures taken, or intended to be taken, to stop any emission

Description of the failure or accident.

(b) Notification requirements for the breach of a limit

To be notified within 24 hours of detection unless otherwise specified below

Emission point reference/ source

Parameter(s)

Limit

Measured value and uncertainty

Date and time of monitoring

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(b) Notification requirements for the breach of a limit

To be notified within 24 hours of detection unless otherwise specified below

Measures taken, or intended to be taken, to stop the emission

Time periods for notification following detection of a breach of a limit

Parameter Notification period

(c) Notification requirements for the detection of any significant adverse environmental effect

To be notified within 24 hours of detection

Description of where the effect on the environment was detected

Substances(s) detected

Concentrations of substances detected

Date of monitoring/sampling

Part B – to be submitted as soon as practicable

Any more accurate information on the matters for notification under Part A.

Measures taken, or intended to be taken, to prevent a recurrence of the incident

Measures taken, or intended to be taken, to rectify, limit or prevent any pollution of the environment which has been or may be caused by the emission

The dates of any unauthorised emissions from the facility in the preceding 24 months.

Name*

Post

Signature

Date

* authorised to sign on behalf of the operator

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Schedule 6 – Interpretation

“accident” means an accident that may result in pollution.

“Air Quality Risk Assessment” has the meaning given in Annex D of IED Compliance Protocol for Utility Boilers and Gas Turbines.

“application” means the application for this permit, together with any additional information supplied by the operator as part of the application and any response to a notice served under Schedule 5 to the EP Regulations.

“authorised officer” means any person authorised by the Environment Agency under section 108(1) of The Environment Act 1995 to exercise, in accordance with the terms of any such authorisation, any power specified in section 108(4) of that Act.

“Black Start” means the procedure to recover from a total or partial shutdown of the UK Transmission System which has caused an extensive loss of supplies. This entails isolated power stations being started individually and gradually being reconnected to other power stations and substations in order to form an interconnected system again.

“calendar monthly mean” means the value across a calendar month of all validated hourly means.

“CEN” means Commité Européen de Normalisation.

“Combustion Technical Guidance Note” means IPPC Sector Guidance Note Combustion Activities, version 2.03 dated 27th July 2005 published by Environment Agency.

“disposal”. Means any of the operations provided for in Annex I to Directive 2008/98/EC of the European Parliament and of the Council on waste.

“DLN” means dry, low NOx burners.

“Energy efficiency” the annual net plant energy efficiency means the value calculated from the operational data collected over the year.

“EP Regulations” means The Environmental Permitting (England and Wales) Regulations SI 2010 No.675 and words and expressions used in this permit which are also used in the Regulations have the same meanings as in those Regulations.

“emissions of substances not controlled by emission limits” means emissions of substances to air, water or land from the activities, either from the emission points specified in schedule 3 or from other localised or diffuse sources, which are not controlled by an emission limit.

“groundwater” means all water, which is below the surface of the ground in the saturation zone and in direct contact with the ground or subsoil.

“Industrial Emissions Directive” means DIRECTIVE 2010/75/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 24 November 2010 on industrial emissions.

“MCERTS” means the Environment Agency’s Monitoring Certification Scheme.

“Natural gas” means naturally occurring methane with no more than 20% by volume of inert or other constituents.

“ncv” means net calorific value.

“operational hours” are whole hours commencing from the first unit ending start up and ending when the last unit commences shut down.

“quarter” means a calendar year quarter commencing on 1 January, 1 April, 1 July or 1 October.

“recovery” means any of the operations provided for in Annex II to Directive 2008/98/EC of the European Parliament and of the Council on waste.

“SI” means site inspector.

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Where a minimum limit is set for any emission parameter, for example pH, reference to exceeding the limit shall mean that the parameter shall not be less than that limit.

Unless otherwise stated, any references in this permit to concentrations of substances in emissions into air means:

• in relation to emissions from combustion processes, the concentration in dry air at a temperature of 273K, at a pressure of 101.3 kPa and with an oxygen content of 3% dry for liquid and gaseous fuels, 6% dry for solid fuels; and/or

• in relation to emissions from gas turbine or compression ignition engine combustion processes, the concentration in dry air at a temperature of 273K, at a pressure of 101.3kPa and with an oxygen content of 15% dry for liquid and gaseous fuels; and/or

• in relation to emissions from non-combustion sources, the concentration at a temperature of 273K and at a pressure of 101.3 kPa, with no correction for water vapour content.

“year” means calendar year ending 31 December.

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Schedule 7 – Site plan

Full site installation boundary plan

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Expanded plan showing emission point locations

© Crown Copyright. All rights reserved. Environment Agency, 100026380, 2016.

END OF PERMIT

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Documents

PROPOSED STACK CONFIGURATION FOR THE GAS ENGINE PROJECT … · 2017-12-01 · Report Reference: 2016/RPSSCH5-1 2 PROPOSED STACK CONFIGURATION FOR THE GAS ENGINE PROJECT – A BAT