ESB - Environmental Protection · PDF fileESB Marina Generating Station AER 2011 – IPC...
Transcript of ESB - Environmental Protection · PDF fileESB Marina Generating Station AER 2011 – IPC...
ESB Marina Generating Station AER 2011 - IPC License P0578-02
Page 1 of 133
ESB Marina Generating Station
Annual Environmental Report 2011
Required under IPPC License P0587-02
for the period 1st Jan. 2011 to 31st Dec. 2011
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 2 of 133
Contents1. Introduction
License Number
Licensee
Location of Activity
Licensed Activity
Environmental Policy
Environmental Management Organisation Chart and Personnel (Table 1)
2. Summary Information
Self-Monitoring Data
Emissions to Waters / Sewers
Surface Water Monitoring
Emissions to Atmosphere
Wastes Arising
Agency Monitoring and Enforcement
Energy and Water Consumption
Energy Sources and Consumption
Water Sources and Consumption
Environmental Incidents and Complaints
Energy Efficiency Audit Summary
3. Management of the Activity
Schedule of Objectives and Targets for 2011.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 3 of 133
Environmental Management Programme Report 2011
Process Improvement to minimise air emissions
- Emissions to air
- Efficiency
- Ambient air quality
Reduce risk of soil/groundwater pollution
Reduce noise levels generated within the site
IPL License Compliance
Waste Management
License Review
Schedule of Objectives and Targets for 2012
Environmental Management Programme 2009-2013
Pollution Emission Register Proposal
Pollution emission Register Report
License-Specific Reports
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 4 of 133
Appendices
1. Appendix 1 Summary of Emissions 2011
2. Appendix 2 Ambient Air Quality Report 2011
3. Appendix 3 Annual Noise Survey Report 2011
4. Appendix 4 Ground Water Sampling Report 2011
5. Appendix 5 Bunds Testing / Status Report 20011
6. Appendix 6 Environmental Management Programme 2009-2013
6a Additional ongoing projects for 2012
7. Appendix 7 Residuals Management Plan Annual Review
8. Appendix 8 Site Map
9. Appendix 9 Confirmation of Financial Capability
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 5 of 133
1. Introduction
License Register No. P0578-02
Licensee Electricity Supply Board.
Location of the Activity Marina Generating Station, Centre Park Road, Cork.
Licensed ActivityThe production of energy in combustion plant the rated thermal input of which is greater than 50 MW
This Annual Environmental Report
This Annual Environmental Report (AER 2011) is the sixth AER prepared in accordance with the conditions of IPPC License P0578-02. This
Annual Environmental Report covers the period calendar year 2011 and has been prepared in accordance with the EPA’s Guidance Note for the
preparation of an Annual Environmental Report.
The Plant
The combustion plant operated by ESB at Marina Generating Station consists of one open cycle gas turbine (OCGT). The heat recovery element
has now been decommissioned. Maximum output is now 94 MW.
Plant Operations
For Marina in 2011 typical running is at it’s minimum load of 20MW when it is called upon in order to provide emergency voltage and MW
response if required. Of the total number of hours available in 2011 Marina CT ran for 15% of the time with an annual load factor of only 4%. The
average running load for 2011 was 24.6 MW highlighting the low load running typical of a peaking unit (Marina is available from 20 MW to 94
MW). The unit was only started 39 times in the year. During 2011 ESB Marina took over the adjacent oil farm which was previously operated
by the National Oil Reserve Agency (NORA) as our grid code states that we must retain 3 days supply of a back-up fuel. This is equivalent to
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 6 of 133
approximately 1,600t of gasoil. In February 2011 ESB Marina applied to the EPA for a Technical Amendment to our licence in relation to this
change. This was granted in August 2011(Technical Amendment P0578-02/A)
Environmental Improvements
During 2011 we purchased new colour coded waste bins for our kitchen/office area and erected new information/signage to increase
awareness of correct recycling to try and achieve our recycling target of 70% of our waste.
During 2011 the light switches on corridors in the office building were replaced with push button units on timers which turn off these lights
automatically. Various outside flood lights were also replaced with energy efficient units.
In December 2011 21,000 litres of oil was removed from a number of redundant transformers and sent for recovery. See Appendix 5.
The level of risk associated with the storage of oil was further reduced by draining down the main lube oil tank of the now redundant 30 MW
steam turbine which was part of the old combined cycle operation in Marina. This reduced the oil stored on site by 9,800 litres. This operation
took place on 08/10/2009.
A new bunded barrel store was installed for the temporary storage of solid oily waste in drums, empty/near empty drums and disused oil filters
while awaiting collection for disposal .- The operation of the new bunded barrel store is working well and is the only storage area for this
waste. It also improves the safe handling and removal of this waste.
Dry Cell Battery collection boxes were placed in workshops and canteen to provide for segregation of this waste stream. – The canteen and all
workshops bar one are now closed, the collection boxes are now in other prominent work areas such as the thermal control room and
administration office .
In November 2009 the process of removing all bulk chemicals off site began with the decommissioning of the Water treatment plant. This
process is now complete.
On December 10th 2010 a new Data Logger was fitted to our main water meter. Data from this is collected and archived on a half hourly basis.
This helps to track water consumption, highlights any leaks in the system and is a sustainability improvement.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 7 of 133
Environmental Policy and Management Structure
Below are Marina Generating Station’s Environmental Policy and Organisation Chart for Environmental Management. The Station’s Environmental
Policy was revised in early 2006 in preparation for Marina’s re-certification to international standard ISO14001:2004 and again in March 2008 as
part of an annual review of the system for environmental management. It was reviewed and amended in May 2010 and again in May 2011 to take
account of the new operating structure in the station and as part of the annual review of our EMS.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 8 of 133
Environmental Policy
Environmental Policy.
We, the management and staff at Marina, commit to:
Defining, documenting, implementing and maintaining an environmental policy appropriate to the nature, scale and environmental impacts of our activities, products and services as a part of an Environmental Management System certified to ISO 14001,
Preventing pollution and to continually improving our system for managing the impacts of our business on the environment,
Complying with applicable legal requirements and other requirements to which we, as an organisation, subscribe and which relate to the environmental aspects of our business, with regard to noise reduction ,control of air emissions and continuous monitoring of surface water. Total removal of all water treatment bulk chemicals and minimising oil storage requirements.
Striving to continually reduce our waste sent to landfill and increase the volumes sent for recycling, targeting at least recycling 50% of all waste, and to improve our sustainability performance.
Complying with all legal requirements of our IPPC Licence.
Setting and reviewing environmental objectives and targets at regular intervals,
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 9 of 133
Actively promoting environmental awareness through communications and training and making environmental considerations an integral element in all decision making,
Communicating this policy to all employees and to other persons working on our behalf,
Making this policy available to the public.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 10 of 133
1.1 Environmental Management Organisation Chart
Figure 1.1 Company Organisation Chart for Power Generation/Marina Generating Station
GeneralManager
GroupManager
StationManager
Group Chemist
FinancialOfficer
ExecutiveDirector
GroupManager
PlantManager
Group Chemist
FinancialOfficer
Civil Engineer
PaRC x 3Including:Env. Co-ordSafety Co-ord
OCTM x 6
Shared Resources
ESB Marina Generating Station AER 2011 - IPC License P0578-02
Page 11 of 133
Table 1 : Personnel in the above positions and new positions in Marina in November 2009 (post OCGT conversion) are:
Executive Director Donal Crean
Group Production Manager Paul Smith
Plant Manager Gerard Stapleton
Production ManagerPlant Manager
Administration Officer (part time) Eileen O’Donoghue
Group Chemist, (part-time) Liz Stack
Financial Officer, (part time) Paul Prendergast
Civil Engineer (part-time) Tom Hayes
Planning and regulatory Compliance ( PaRC)
Team member & Nominated Safety EngineerDermot Brophy
Planning and regulatory Compliance ( PaRC)
Team member John N OSullivan
Planning and regulatory Compliance ( PaRC)
Team member & Environmental Coordinator Gerard Slyne
Open Cycle Team Members ( OCTM) Paul Murray
Pat Kelly
Tony Conroy
Alan Corbett
William Morrison
Donal Coakley
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 12 of 133
2. Summary Information
2.1 Self-Monitoring Data
Emissions to Waters/Sewers
There are 2 licensed emission points to waters at Marina Generating Station. These
points are listed in Schedule B of license IPPCL P0578-02. These points, listed below,
are subject to emission limit values and are monitored and reported on in accordance with
the terms of the license.
SW 4 & 7 are subject to emission limit values set out in license Schedule B.2
SW4 Surface Water / Station Drainage
SW7 Surface Water/Station Drainage
o Re SW4 – treated sewage effluent discharge ceased at beginning of 2006.
Summary Mass Emission Data for these 2 emission points are given in Table 1 and Table 2
Refer to Table for the parameters measured, the limit values and the frequency of measurement for each of these emission points.
Table 1: SW4 Emission Point - Surface Water
Emission
PointParameter Units
Q1 Q2 Q3 Q4
SW4
Suspended Solids Mg/l
<5 14 29 41
Mineral Oils Ug/l 16.8 ug/l150 22
247
Sewage effluent via SW4 ceased in Jan 06.
# Storm water emissions only after conversion to OCGT.
Table 2: SW7 Emission Point - Surface Water
Emission Point Parameter Units Q1 Q2 Q3 Q4
SW7
Suspended Solids Mg/l <5 13 <3 25
Mineral Oils Ug/l 23.7 270 11 557
ESB Marina Generating Station AER 2011 - IPC License P0578-02
Page 13 of 133
Table 3: Emissions to Water - Licensed Emission Points, parameters, and frequency of measurements
Emission Point Description
Emission Point NoPer
Schedule B Emission Limits.
Mineral Oil
Suspended
SolidsFlow
Monitoring
Frequency
Visual Measured
Interceptor 2 (surface water, town water) plus, until 16th Jan 2006, sewage effluent.
SW4 X Xmax 12m3/hr
Weekly Quarterly
Interceptor 3 (surface water)
SW7 X Xmax
12m3/hr
Weekly Quarterly
Emission Limit Values ->
100mg/l.
Re SW4: For domestic effluent, the original ELV for BOD was 20 mg/l, for suspended solids 30 mg/l. Domestic sewage effluent discharge to the river ceased on 16th Jan 2006
ESB Marina Generating Station AER 2011 - IPC License P0578-02
Page 14 of 133
Surface Water Monitoring
There are 3 licensed Storm Water emission points at Marina Generating Station. These
points, SW 2, 8, and 9 are listed in Schedule C of the IPC license P0578-02 and are
subject to monitoring as set out in schedule C.2.3.
SW2 Storm Water / Station Drainage.
SW8 Storm Water/ Station Drainage
SW9 Storm Water / Station Drainage
Emission Point No. & Description
YearSampled
Q1 Q2 Q3 Q4 Monitoring Frequency
Visual Measured
SW2 [per ref:P0578-02/AP03JD]Interceptor 1 (town water,river water, surface water)
2011Mineral Oil
50.9 324 2304 541 WeeklyQuarterly
2010Mineral Oil 436
ug/l77 ug/l
<10 ug/l
27930 ug/l
Weekly Quarterly
2009 7.5 2 0 <2 Weekly
2008 7.9 3 0 12 Weekly
SW8 [per ref:P0578-02/AP03JD]Interceptor 4 (surface water)
2011Mineral Oil
42995102,8
302304 2694 Weekly
Quarterly
2011Suspended
Solids 274 197 48 18 Weekly Quarterly
2010Mineral Oil
1394 NST NST 24133
Weekly Quarterly
2010Suspended
Solids <5 mg/l NST NST 32 Weekly Quarterly
2009 No flow No flow N/A N/A
2008 7.0 2 N/A 12
SW9 [per ref:P0578-02/AP03JD]Access Road (surface water)
2011Visual Check
Weekly
2010Visual Check
Weekly
2009 No flow No flow N/A N/A
2008 No flow No flow N/A N/A
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 15 of 133
Emissions to Atmosphere in Kilogram - 2011
Fuel Natural Gas Distillate (Gas Oil)
Substance, Kg CO2NOx
as NO2CO2
NOX
as NO2
SOx
as SO2Particulates
2011 35823 51335 710 0.192 ~0 Not measured
2010 141,926,000 121,992 5,710 1.54 0.00064 Not measured
2009 158,386,000 500,627 26,000 40 0.016603 Not measured
2008 258,733,000 883,826 0 0 0 Not measured
2007 213,976,000 734,418 47,000 See ++ 56 Not measured
Particulates and SOx are not applicable to natural gas.
No distillate fuel was burned in 2008.
The licensed annual mass emission limits are based on the allowable concentrations in mg/Nm3 for each emission for each fuel, and the maximum flue gas flow rate of 22,100,000 Nm3 per day.
NOX : 275 mg/Nm3 x max daily flue gas flow rate of 22,100,000 Nm3/day x 365 days on gas
NOX : 400 mg/Nm3 x max daily flue gas flow rate of 22,100,000 Nm3/day x 365 days on distillate
SOX : 110 mg/Nm3 x max daily flue gas flow rate of 22,100,000 Nm3/day x 365 days on distillate
Particulates : 15 mg/Nm3 x max daily flue gas flow rate of 22,100,000 Nm3/day x 365 days on distillate
CO2 figures have been verified under GHG Regulations; Ref GHG Permit 069-02.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 16 of 133
Wastes Arising - Information on each waste stream for 2011
Waste Type Hazardous Non-hazardous
Recyclable 31.51 tonne 6.61 tonne
Non-recyclable 1.93 tonne 7.99 tonne
Total 33.44 tonne 14.60 tonne
Recyclable as % of Total 94% 45 %
Total recyclable as % of total waste 79%
ESB Marina Generating Station AER 2011 - IPC License P0578-02
Page 17 of 133
Non- Hazardous Waste Disposed of in 2011
Collection/Transport Treatment/Disposal
EWC Type of WasteWeight tonnes
Carrier Licence
Storage Area
Disposal/ Recovery
Code
Waste Contractor
Contractors Licence
Final Disposal LocationCert of Export
Cert of Treatment (exported
loads)
20 03 01Mixed Municipal Waste
7.43Greenstar W173-01
D5Greenstar Cork
W0173-01Kinsale Rd, CorkW0012-02
15 01 06 Dry Mixed Recyclables- plastic & paper
1.3Greenstar WO173-01
R3 Recovery
Greenstar Cork
W0173-01 Thornton’s Recycling, DublinW044-02
17 02 01 Timber 6.22Veolia, Cork
WO173-01R1 -Energy
Greenstar Cork
W0173-01WRS FermoyW107-1
16 06 05 Assorted Batteries 0.08Enva
WCP-DC-08-1116-01
R6EnvaWCP-DC-08-1116-01
WCP-DC-08-1116-01
KMK Metal recycling,Tullamore,Co.Offaly113-02
Hazardous Waste Disposed of in 2011
Collection/Transport Treatment/Disposal
EWC Type of WasteWeight tonnes
Carrier Licence
Storage AreaDisposal/ Recovery
CodeWaste Contractor
Contractors Licence
Final Disposal Location
Cert of Export
Cert of Treatment (exported
loads)
13 05 07
Oily water from culverts
7.32
Enva Ireland Ltd
W 0041-1
Enva Ireland Ltd., Portlaoise,Co. Laois
R1Enva Ireland Ltd WCP-DC-08-
1116-01
Enva Ireland Ltd., Portlaoise,Co. Laois
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 18 of 133
13 03 07
PCB free transformer oil
21.0
Enva Ireland Ltd
W 0041-1
Enva Ireland Ltd., Portlaoise,Co. Laois
R9Enva Ireland Ltd WCP-DC-08-
1116-01
Enva Ireland Ltd., Portlaoise,Co. Laois
15 02 02
Solid oily waste 1.05
Enva Ireland Ltd
W 0041-1
Enva Ireland Ltd., Portlaoise,Co. Laois
R9Enva Ireland Ltd WCP-DC-08-
1116-01Lindenschmidt Germany
20 01 21
Fluorescent tubes 1.3
Enva Ireland Ltd
CK WMC 16/01
Enva Ireland Ltd., Portlaoise,Co. Laois
R5 Enva Ireland LtdW 0041-1W 0184-104 714 98089
Irish Lamp Recycling, Kildare
17 06 05
Construction materials containing asbestos
0.39Rilta
CW WMS 346/06
Greenougue Business Park,Rathcoole, Co.Dublin
D1Rilta Environmental CW WMS
346/06Lindenschmidt Germany
16 05 06
Mixture of laboratory chemicals
2.44
Enva Ireland Ltd
CK WMC 16/01
Shannon Environmental,Co.Clare
R1 Shannon Environmental,Co.Clare
W1-11Lindenschmidt Germany
17 06 05
Construction materials containing asbestos
10.19 RiltaCW WMS
346/06
Greenougue Business Park,Rathcoole, Co.Dublin
D1Rilta Environmental CW WMS
346/06Weirshop, Germany
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 19 of 133
2.2 Agency Monitoring and Enforcement
In 2010 the Environmental Protection Agency carried out sampling of emissions to water
emitted from licensed emission points on Marina GS site. Samples were collected on:-
11/01/2011 ( SW4) and (SW7)
23/08/2011 (SW4 and SW7)
There was a site visit on 14/12/2011 by our inspector. He did a site walk about and had
discussions with the plant manager.
Energy and Water Consumption
2.2.1 Energy - Sources & Consumption MWH
2.2.2 Water - Sources & Consumption
Water SourceOn-site Ground Water
On-site Surface Water
Municipal Supply
Year
Quantity m3
0 0 12,232 2011
0 0 5,564 2010
0 0 31,092 2009
0 0 30,703 2008
0 0 32,970 2007
The municipal figure for water delivered is from Marina Operations records of meter readings. On 10/12/2010 a new data logger was fitted to our main water meter. From this, data is collected and archived on half hourly intervals. There was a large reduction in the volume of water used in 2010 due to a marked decrease in process and domestic water usage. There was a large increase in water volume used in 2011 due to various leaks on site which took time to locate and repair.
Energy SourceHeavy
Fuel OilLight
Fuel OilNatural
GasElectricity Coal Year
MWHNCV
N/A 2.71 173,661 820 N/A 2011
N/A 16 691,3881480
#N/A 2010
N/A 97*
776,894**
5230***
N/A 2009
N/A0
*1,276,524 **
7,350***
N/A 2008
N/A 176*
1,056,187**
6,487***
N/A 2007
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 20 of 133
2.3 Environmental Incidents and Complaints
Incidents (0)
Environmental Complaints (0)
2.4 Energy Efficiency Audit for OCGT
Parameter 2007 2008 2009 2010 2011
Thermal Efficiency Generated 38.81% 38.75% 30.72% 21.9% 20.18%
GWH Generated 409.979 492.772 246.05 146.05 35.39
House Load GWH 6.487 7.35 5.23 1.48 0.82
Total Starts 248 195 237 119 39
Gas Consumption TJ 3,820.09 4,614.78 2785 2482.7 625
Distillate Consumption litres 17,610 0 9330 1640 0
The efficiency in 2010 was down due to the permanent conversion from combined cycle
to open cycle in November 2009. 21% efficient is as expected for this type and age of
unit.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 21 of 133
3. Management of the Activity
Environmental management was formalised at Marina Generating Station (GS) with the
establishment of a formal documented Environmental Management System (EMS) in 1999.
This system and its operation were audited and certified to ISO 14001:1996 Standard in 2000
and re-certified in 2003. Re-certification to revised standard ISO14001:2004 took place during
2006.
Since 1999 environmental management has been carried out in accordance with the written
terms and procedures of Marina EMS and its operation has been subject to regular
surveillance audits as part of the independent certification process in addition to internal
audits.
3.1 Schedule of Objectives and Targets for 2012
Objective Target
1. To prevent pollution and to continually improve our system for managing the impacts of our activities on the environment
Complete a range of projects to reduce risk to the environment
2. To operate our installation in compliance with IPPCL P0578-02 and other permits and legal requirements.
Zero non-compliances
3. To promote environmental awareness among all staff and demonstrate our awareness to the public.
Provide training for
Internal auditing
Emergency preparedness
Fire extinguisher usage
Communication to staff
Email correspondence
Issuing policy statement to each employee.
Periodic Briefing
Communication to Public
Display Environmental Policy on Installation’s Notice Board at main entrance
4. To maintain and operate Marina’s EMS in conformance with ISO14001
Zero major non-conformances
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 22 of 133
3.2 Environmental Management Programme Report 2011
ESB operated its Marina installation under IPPC License P0578-02 of 4th Jan 2006.
The environmental policy was reviewed and amended during 2011
Environmental Management System Manual EMS 3 Legislation was updated in Jan. 2011
Progress in implementing the 2011 Environmental Management Programme was as follows:
3.2.1 Process improvement to minimise air emissions
Emissions to Air
The station’s Continuous Emissions Monitoring System (CEMS) was
decommissioned in October 2009 and replaced with a PEMS system. Performance
testing of the PEMS has been carried out by ESB staff and a full QAL2 test was
completed in June/July 2010. The Annual Surveillance Test was not performed in
2011 due to long periods of non running of the machine. This has been discussed
with our inspector.
Efficiency
Air inlet pre-filters and fine filters were changed out during October 2009 to improve
performance of the gas turbine. Average 21% efficient. They were replaced again in
September 2011.
In-house electricity consumption was monitored throughout the year. To minimise
house load the smaller rated UT1 transformer was used as far as practicable in
preference to the larger station transformer.
Ambient Air Quality
The station’s Ambient Air Quality Monitoring System was first installed in Nov 2003
and has continued in operation since then to ascertain the impact of the station’s
emissions to air on ambient air quality. During 2011 this analyser performed
satisfactorily. The resulting air quality and metrological data file has been sent to ESB
PG Environmental Services for analysis. Refer to Appendix 2.
The windsock erected on the station roof as per IPCL P0578-02 was replaced as
necessary.
3.2.2 Reduce risk of soil/groundwater pollution
Bunding of transformers
All transformers on site are bunded with the exception of ESB Networks’ transformers
T105 and T106 which will be bunded as part of a major Transmission Compound
Development Project being undertaken by EirGrid plc and ESB Networks. Piling work
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 23 of 133
for this project was completed in 2008 and construction work commenced early Q2,
2009.This work is ongoing.
Under Marina’s environmental work programme for 2011 repairs were carried out to a
number of bunds. Subsequent testing has revealed that some further repairs are
required. A number of bunded transformers were drained of oil in December 2011
which resulted in 21,000 litres of oil being removed off site for recycling. Please refer
to Appendix 5.
Groundwater sampling
Sampling of groundwater boreholes was carried out bi-annually in accordance with
the terms of IPPCL P0578-02 by an accredited laboratory. The reports are contained
in Appendix 4.
Risk Reduction
Operations Staff carry out a weekly environmental check for leaks on all unbunded
over-ground pipes and any unbunded vessels containing other than clean water, in
accordance with an Environmental Check List. The completed list is retained on file.
3.2.3 Reduce noise levels generated within the site.
The annual noise survey for 2011 was not carried out due to prolonged periods of
non operation of the Marina OCGT plant. This has been discussed with our inspector.
Please refer to Appendix 3.
3.2.4 IPPC License compliance
In 2011, there was no environmental incident. Weekly visual checks are completed on
our interceptors and quarterly monitoring is done by a contractor.
3.2.5 Waste Management
Solid waste is segregated into defined hazardous and non-hazardous waste steams
and disposed of or recycled using licensed Waste Contractors. Section 2.1.4 above
sets out the waste streams disposed of during 2011.
With the exception of waste metal and asbestos, all other waste streams are
managed by a single licensed waste contractor employed by Marina station to
manage all waste removal/disposal operations.
3.2.6 Promote environmental awareness among all staff and demonstrate our awareness to the public.
3.2.6.1 Training
As part of the transition from CCGT to OCGT 8 of the 10 new staff members were
trained on environmental awareness and a copy of our licence given to all staff in
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 24 of 133
October/November 2009. The two remaining staff members are former shift
managers who would have done this training previously. We also had oil spill
response training in April 20011 for four staff members. The remaining six staff
are scheduled for this training in April 2012. We no longer have bulk chemicals on
site.
3.2.6.2 Communications to Staff
Environmental issues are circulated to all staff and quarterly Environmental
Management Group meetings are held on site.
3.2.6.3 Communication to Public
The revised environmental policy was maintained on the Installation’s Public notice board.
3.3 Environmental Management Programme 2009-2013
This programme is set out in Gantt chart format in Appendix 6.
Appendix 6a shows additional projects proposed for 2012.
3.4 Pollution Emission Register Proposal
The information used to produce this report is obtained from sampling of SW 7 emission point and plant operation logs.
3.5 Pollution Emission Register Report
As we no longer have any process water emissions, the monitoring schedule has changed where we do a weekly visual check and do quarterly sampling for mineral oil and suspended solids as per Agency ref: P0578-02/AP03JD (03/09/2009).
3.6 License-Specific Reports
The following recurring reports required under the terms of IPPC License P0578-02 were submitted to the Environmental Protection agency during 2011 by the dates specified in the license.
Reports submitted during 2011 Submission Date
Annual Environmental Report 2010 30th March 2011.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 25 of 133
Appendices
Appendix 1 Summary of Emissions 2011
Appendix 2 Ambient Air Quality Report 2011
Appendix 3 Annual Noise Survey Report 2011
Appendix 4 Ground Water Sampling Report 2011
Appendix 5 Bunds Testing / Status Report 2011
Appendix 6 Environmental Management Programme 2009-2013
Appendix 6a Additional projects for 2012
Appendix 7 Residuals Management Plan for 2011
Appendix 8 Site Map showing groundwater testing boreholes.
Appendix 9 Statement of Financial Capability
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 26 of 133
Appendix 1
Summary of Emissions 2011
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 27 of 133
AER Returns Workbook
Version 1.1.13
REFERENCE YEAR 2011
1. FACILITY IDENTIFICATIONParent Company Name Electricity Supply Board (Marina)
Facility Name Electricity Supply Board (Marina)PRTR Identification Number P0578
Licence Number P0578-02
Waste or IPPC Classes of ActivityNo. class_name
2.1The operation of combustion installations with a rated thermal input equal to or greater than 50MW
Address 1 Marina Generating StationAddress 2 Centre Park RoadAddress 3 CorkAddress 4
CorkCountry Ireland
Coordinates of Location -8.44550 51.8999River Basin District IESW
NACE Code 3511Main Economic Activity Production of electricity
AER Returns Contact Name Gerard SlyneAER Returns Contact Email Address [email protected]
AER Returns Contact Position Environmental coordinatorAER Returns Contact Telephone Number 0214917539
AER Returns Contact Mobile Phone Number 0879851750
AER Returns Contact Fax Number 0214917513Production Volume 35.39
Production Volume Units GWhrNumber of Installations 1
Number of Operating Hours in Year 1325Number of Employees 10
User Feedback/CommentsWeb Address
2. PRTR CLASS ACTIVITIESActivity Number Activity Name
1(c)Thermal power stations and other combustion installations
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 28 of 133
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 29 of 133
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 30 of 133
Appendix 2
Ambient Air Quality Report 2011
This report is pending data analysis
by ESB Power Generation Environmental Services
and will be submitted as soon as it is available.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 31 of 133
Appendix 3
Annual Noise Survey Report 2011
Please see letter sent to the EPA below which explains the reasons as to why this survey did
not take place during 2011 and also the plans to carry out this survey in mid 2012.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 32 of 133
Office of Environmental Enforcement,South/South West Region,Environmental Protection Agency,Regional Inspectorate,Inniscarra,Co.Cork
28 February 2012
Licensee: ESB, Marina Power Station, Centre Park Rd., Cork
License: IPPCL P0578-02
Subject: PEM’s and Noise Monitoring – 2011
Attn: Mr. John Doheny, Inspector
Dear Sir,
Following a site visit by you on December 14th last and your subsequent discussions with Ger Stapleton, the Plant manager, please find his explanations below as to why PEMS and noise monitoring did not occur in ESB Marina in 2011.You will also find details of the programme to address these issues in 2012.We hope this information is to your satisfaction. If you have any further queries or need any clarification on any of the information given below please contact me or the Plant manager (Ger Stapleton).
Yours Sincerely,
____________________
Gerard SlyneEnvironmental Coordinator
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 33 of 133
Testing PEMS equipment and noise monitoring requires having specialist persons on site to perform the tests to the required standard. During the year 2011 Marina CT (Combustion Turbine) started a total of 35 times. As a peaking unit the notice time prior to being called to run is 15 – 30 minutes notice. Under normal circumstances Marina runs at it’s minimum load of 20MW when it is called upon in order to provide emergency voltage and MW response if required. Of the total number of hours available in 2011 Marina CT ran for 15% of the time with an annual load factor of only 4%. The average running load for 2011 was 24.6 MW highlighting the low load running typical of a peaking unit (Marina is available from 20 MW to 94 MW). Given this low running profile and the extremely short notice it has proved almost impossible to get specialists to site while the unit is running.
For Marina to request a test on the system for any purpose there is a large financial penalty. This is built into the grid code and is justified as Marina would be displacing a cheaper unit from the system who would still be entitled to be paid. In order to achieve even a 4 hour test this would cost Marina in the order of €31,000 in gas purchase and penalties. For a lean peaking station this does not make economic sense.
Additionally, if Marina were to request a test it would mean running an inefficient peaking unit for 4 hours thus producing unnecessary amounts of CO2 and NOx etc. From an environmental point of view this would not make sense.
In March / April of 2012 Eirgrid will require Marina to complete a set of maximisation tests on both gas and distillate. This is a planned test and is required by Eirgrid so it removes the fiscal obstacle to performing a test – Eirgrid will be paying for this. This planned test also removes the obstacle of not having any notice to organise testing services for both PEMS and noise. With the notice we will have we will have no problem getting specialists to site. Given this information I would expect to have a suitable PEMS check and noise check carried out prior to June of 2012.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 34 of 133
Appendix 4
Ground Water Sampling Points 2011
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 35 of 133
Summary of Groundwater Analysis Units2009 2010 2011
29-02-08 23-09-08 05-03-09 09-09-09 19-04-11 27-10-11
AGW1 (Driveway
)
Appearance DRY DRY DRY DRY DRY DRYChemical Oxygen Demand (Settled) mg/l DRY DRY DRY DRY DRY DRYTotal Colifirms cfu/100ml DRY DRY DRY DRY DRY DRYE. Coli cfu/100ml DRY DRY DRY DRY DRY DRYElectrical Conductivity (EC) - Site uS/cm DRY DRY DRY DRY DRY DRYTotal 16 EPA PAHs ng/l DRY DRY DRY DRY DRY DRYChloride mg/l DRY DRY DRY DRY DRY DRYNitrate mg/l DRY DRY DRY DRY DRY DRYAmmonical Nitrogen mg/l DRY DRY DRY DRY DRY DRYpH - Site pH Units DRY DRY DRY DRY DRY DRYTemperature DegC DRY DRY DRY DRY DRY DRYTotal Nitrogen mg/l DRY DRY DRY DRY DRY DRY
AGW2 (SE of
GT)
Appearance Clear Clear clear clearSlightly cloudy clear
Chemical Oxygen Demand (Settled) mg/l 19 <15 <15 11 14.2 7.82Total Colifirms cfu/100ml 3 18 7 9 <1 12E. Coli cfu/100ml <1 1 <1 <1 <1 <1Electrical Conductivity (EC) - Site uS/cm 829 330 432 310 1310 500
Total 16 EPA PAHs ng/l <10 <10 0.39 <0.1 <0.17<0.009-
0.027Chloride mg/l 98 29 105 19. 2 223 49Nitrate mg/l 1.9 4.5 2.0 5.9 0.7 3.26Ammonical Nitrogen mg/l 0.3 c 0.2 0.8 0.222 <0.2pH - Site pH Units 7.43 6.81 7.45 7.75 7.9 7.82Temperature DegC 10.1 17.0 9.3 15.0 11.4 10.9Total Nitrogen mg/l 3 3 10 <0.1 1.0 3.6
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 36 of 133
Summary of Groundwater Analysis Units 2009 2010 201105-03-09 09-09-09 19-04-10 14-10-10 19-04-11 27-10-11
AGW3 (Rear of Boiler
House)
AppearanceCloudy /
silty Clear Clear Clear ClearVery
cloudyChemical Oxygen Demand (Settled) mg/l <15 20.6 53 79.5 80.9 126Total Colifirms cfu/100ml 1 <1 <1 <1 <1 1E. Coli cfu/100ml <1 <1 <1 <1 <1 <1Electrical Conductivity (EC) - Site uS/cm 4350 2011 4185 3999 2040 10210Total 16 EPA PAHs ng/l 0.07 0.107 0.326 <0.1 <0.17 1.06Chloride mg/l 1266 1170 1460 3340 229 3250Nitrate mg/l 3.1 <0.3 <0.01 <0.3 <0.5 <0.0677Ammonical Nitrogen mg/l 1.1 0.8 1.26 4.6 1.63 3.22pH - Site pH Units 7.54 7.42 7.00 7.35 8.32 8.5Temperature DegC 10.0 15.4 10.1 15.0 11.0 10.1Total Nitrogen mg/l 4 <0.1 <1 <1 1.5 6.4
AGW4 (Wharf)
Appearance
Dark Grey &
Silty Clear
Dark Grey &
Silty Clear ClearSlightly cloudy
Slightly cloudy
Chemical Oxygen Demand (Settled) <15 <15 <15 171 195 47.7 65.3Total Colifirms 14 14,670 14 10,140 866 120 411E. Coli 5 15 5 <1 37 <1 3Electrical Conductivity (EC) - Site 393 811 393 353 520 570 690Total 16 EPA PAHs <10 0.02 <10 1.06 1.48 1.73 2.63Chloride 64 38 64 11.8 10.3 10 8Nitrate 0.4 6.3 0.4 0.0303 <0.3 <0.5 0.12Ammonical Nitrogen 1.3 <0.2 1.3 <0.2 0.413 0.492 <0.2pH - Site 6.51 7.9 6.51 8.08 7.64 7.9 7.88Temperature 17.1 6.8 17.1 10.7 13.8 11.8 10.4Total Nitrogen 3 13 3 <1 <1 <1.0 1.1
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 37 of 133
Appendix 5
Bunds Testing / Status Report 2011
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 38 of 133
Marina GS Transformer Bunds
Bund #
Type Plant ItemLiquid
VolumeLast tested Result
Next
Test
Date
Comment
1-03 Concrete T107 25 m3 August 08Slight leak at high level
Repairs required
Repairs completed during outage in Sept./Oct. 2011. More repairs needed.
1-01 Concrete T101 23.7 m3 April 07 Passed 2010, April
Repairs will be tendered for during outage in Nov 2011
1-02 Concrete T102 23.7 m3 2008 FailedRepairs required
Repairs completed during outage in Sept./Oct. 2011. Drained of oil in Dec. 2011
1-04
Butyl rubber liner over concrete/concrete lock
UT1 4.27 June 2008 Passed Mid 2011Will be tested in 2012
1-05 S 11 4.27 June 2008 Passed Mid 2011Will be tested in 2012
1-09 UT2 4.27 June 2008 Passed Mid 2011Drained of oil in Dec. 2011
1-12 ST12 4.27 June 2008 Passed Mid 2011Will be tested in 2012
1-13 UT4 4.27 June 2008 Passed Mid 2011Will be tested in 2012
1-06
Spray Sealed over concrete / concrete block
HOT1 0.87 m2
Tested in 2010
Failed. Re-work required
Repairs required
Contractor engaged to carry out repairs in Q1 2011. (Beton Construction)HoT 5 drained of oil in Dec.2011
1-07 HOT5 0.87 m2
1-11 HOT4 1.10 m2
Tested in 2010
Still Leaking. Repairs required
Contractor engaged to carry out repairs in Q1 2011. (Beton Construction HoT 4 drained of oil in Dec.2011
1-10 HOT9 0.87 m2
1-14 HOT6 0.87 m2Re-sealed & Tested 2008
Passed Mid 2011
Repairs will be tendered for during outage in Nov 2011
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 39 of 133
Marina GS Transformer Bunds
Bund #
Type Plant ItemLiquid
VolumeLast tested Result
Next
Test
Date
Comment
1-15 HOT8 0.87 m2Re-sealed & Tested 2008
Failed. Re-work required
Mid 2011
Repairs completed during outage in Sept./Oct. 2011
HOT2 & HOT7
0.87 m2 Redundant Drained 2008Not applicable
Marina GS - Chemical & Oil Tank Bunds
Bund # Type Plant ItemLiquid
VolumeLast tested Result
Next
Test
Date
Comment
3-01Steel on concrete base
Hydrazine Tank
900 litre Nov 04 Passed Decommissioned 2009
3-02 Concrete HCl Tank 20 t Nov 04 Passed Decommissioned 2009
3-03 ConcreteCaustic Tank
20 t Nov 04 Passed Decommissioned 2009
3-04 PlasticHCl ChemStore
1 t (IBC)Installed Q1 2008
Certified Decommissioned 2009
3-05 PlasticSodium Hypochlorite Tank
8.5 t Q1, 2007 Passed Decommissioned 2009
3-06 PlasticSodium Bromide
1 t Nov 04 Passed Decommissioned 2009
2-01 PlasticGT Waste Oil Tank
2,000 litres Q2 2010 Passed.Scheduled to be tested in Q22013
2-02 PlasticWaste Oil Store
Max 350 litres and 1200 litres
Installed Q3 2008
2011New double skin plastic tanks installed 2008.
2-03 Stainless steelG1 lub oil filtration unit
Oil throughput
Decommissioned 2009
3-07 Steel unit with grated floor.
Empty oil drums & solid oily waste.
Installed Q3 2008.
2011Passed
Q3 2014
2-04 Steel unit with grated floor with 2 levels.
Main lub oil store & antifreeze
Q 3 2010. Passed Q3 2013
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 40 of 133
Appendix 6
Environmental Management Programme 2009-2013
Gantt Chart
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 41 of 133
ID Task Name
1 Prevent Pollution/Target Continuous Improvements inEMS and Environmental Performance
2 Rationalise / Reduce oil stocks in stores by 30%
3 Target a Recycling Rate of at least 50%
4 Replace Interceptor No. 4 with new.
5 Promote energy sustainaiblity
6 AIR7 NOx - Measure Continuously
8 Carry out CEMS Annual Surveillance Test
9 Calibrate temperature and pressure annually
10 Change CEMS lamp Q2,2010
11 Calibrate CEMS' O2 Analyser Monthly
24 Install PEMS to replace CEMS
25 Maintain/improve energy efficiency
26 Monitor delta-p ; Install new air inlet filters on GTas required
43 Clean steam condenser CW side
44 Ambient NO2 - Measure Continuously
45 Service NO2 Analyser
56 Calibrate NO2 Analyser
117 Maintain register of NO2 High Alarms
118 Report NO2 Annual Data
124 SOx - Minimise
125 Purchase gas oil <0.1% sulphur only
130 Other Emissions to Air
131 Establish a programme to reduce fugitive emissions[IPPCL719/C6.6]
132 Terminate bulk hydrazine use/dispose of residual
133 Terminate bulk sodium hypochlorite use / dispose of residual
134 Terminate bulk sodium bromide use / dispose of residual
135
136 Other Issues
137 Replace windsock
143 Refurbish gas line cathodic protection
144 WATER145 Oil Store
146 Remove & dispose of all unlableled / out of date materials in oil store
147 Install oil over water detectors into (4 off) interceptors[IPPCL714 C3.8]
150
151 SOIL/GROUNDWATER152 Test integrity of bunds every 3 years [ IPPCL719 C3.6.5]
153 Bund 1-04 (UT1) 3 yearly re-test
154 Bund 1-05 (ST11) 3 yearly re-test
155 Bund 1-09 (UT2) 3 yearly re-test
156 Bund 1-12 (ST12) 3 yearly re-test
157 Bund 1-13 (UT4) 3 yearly re-test
158 Bund 1-06/1-07 (HOT1/5) Re-seal & Re-test
159 Bund 1-10/1-11 (HOTs 4/9) Re-seal & Re-test
160 Bund 1-15 (HOT 8) Repair seal
161 Bund 1-14 (HOT 6)
162 Bund 1-01 (T101)
163 Bund 1-02 (T012) Repair
164 GIS Project
165 Construction incl Bunds T105 & T106
166 Bund Transformers T105 and T106
167 Inspect T105 & T106 WEEKLY
259 Test Groundwater (AWG1,2,3,4) bi-annually
270 Complete overground distillate pipeline (replacesunderground line).
271 Install pipe and commission
272 WATER CONSERVATION273 Lab to Report on water consumption
326
327 NOISE328 Sustain altered startup procedure to avoid excessive noise
329 Carry out annual noise survey at noise sensitive locations
335 Submit Annual Noise Survey Results to EPA as part of AER
341 Inspect noise abatement equipment
347 WASTE348 Acquire/Publish ENVA Quarterly Waste Rpt & % Recycled
368 Remove remnant hazardous waste ex site
369 Miscellaneous seals/gaskets
370 Boiler 4 cladding and spray insulation
371 U4 chimney seals
372 Promote Environmental Awareness amongStaff/Demonstrate to Public
373 Training of Internal Auditors
374 Training of staff in Emergency Response Mgt
375 Emergency Preparedness - Training
376 Provide hands-on training in the use of fire extinguishers
377 Communicate to staff
378 Issue Environmental Bulletin
389 Issue environmental policy to any new member of staff
390 Communicate to public
391 Renew Notices on Installation's Public Notice board
01-01
Shift Mgr
Civil Contractor
Civil Contractor,ESBI
01-01
02-04
02-04
02-04
02-04
External Trainer
Donal L
Jim D
Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q12009 2010 2011 2012 2013 2014 2015
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 42 of 133
Appendix 6 a
Environmental Management Programme 2012
In addition to the Gantt Chart covering the period 2009-2013 we have a number of issues we
would like to continue / progress in 2012.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 43 of 133
Marina 2010/ 2011/ 2012 EMP
Environmental Management Programme 2010/2011/2012
EMP Task DescriptionObjective /
TargetPerson
Responsible CompletionDate 2011 2012 Completion Date
P1/2010/11/12
Bunding Testing Programme 2010/2011/2012: Water tightness tests required on bunds; T107,T101,T102,HOT1,HOT5,HOT4,HOT9,HOT8,waste oil transfer tank @ G.T, oil barrel storage area bund. All mobile bunds to be labelled and begin a testing schedule on them in 2012.
To prove integrity of all bunds to help prevent any leakage of oil to the soil or ground water.
Plant Manager: Mr G. Stapleton.
Q 2 2010
More repairs due in 2011.We await return of contractors.-Tendering & repairs completed on T102,T107 & HOT8 in Sept. by Ring Bros. T107 failed test in Dec. so further repairs needed.
T102, UT2,HOT4,HOT5 were drained of oil in Dec. 2011with a total of 21,000 litres of oil removed for recycling.Empty transformers to be labelled so and possibility of emptying more trafos to be investigated. Portable bunds labelled on 23/2/12. Register also created.
P2/2010/11/12 Old Boat House: Inspect the old boat house near the CW outfall with a view to removal of all its contents off site. (Pat Coleman, senior chemist is due on site shortly to do inspection)
To ensure removal of all hazardous substances from the area.
Q 2 2010 P. Coleman on site on 08/04/2010 for inspection. Report to follow.
Q 2 2010 All haz material removed for proper disposal by licenced contractor.
Q 2 2010 All haz material removed for proper disposal by licenced contractor.Possibility of fencing off this structure to be considered by the plant manager.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 44 of 133
P3/2010/11/12 Chemicals: Do a further search of the site for redundant chemicals that may still be on site. All decommissioned chemical tanks to be labelled so.
To continue to locate and remove from site all redundant chemicals.
Plant Manager: Mr. G. Stapleton
Q 2 2010 Check completed July 2010
Q 4 2011 More chemicals in quarintine awaiting removal by licenced contractor. Feb 23rd -date for removal by licenced contractor.-Complete.
Q 2 2012 Quantity of oil dispersant located & awaiting an SDS from manufacurer to allow removal & disposal by waste contractor.This issue has been addressed & we await arrival of contractor for removal. - 7 barrels (1400 L) of chemicals removed from site by Enva on 24/2/2012.
P4/2010/11/12 EMS: Begin a full review of our EMS - to be completed on a phased basis over the course of the year.
To comply with licence requirements and to amend the EMS where required.
Environmental Co-ordinator : G. Slyne
Q 4 2010 Ongoing.
Q 4 2011 Ongoing.
Q 4 2012 Ongoing.
P5/2010/11/12 Bulk CO2 Tank: Remove R22 refrigerant from the CO2 tank in August 2010. Source alternative to R22 and associated compressor.
To replace R22 refrigerant with a more environmentally friendly substance when current compressor fails.
Plant Manager: Mr G. Stapleton.
Q 3 2010 Work took place on tank during outage in Sept.Status Of refrigerant removal to be confirmed.
Q 4 2010 Refrigerant removal not now an option due to mechinal constraints.
Q 2 2011 New compressor ordered. Now in main stores as a spare part.
P6/2010/11/12 Waste Target: Reduce waste to landfill and increase recycling rates. To meet Enva target rate of 70% recycled and surpass if possible. Clear plastic bags now being used for all waste, for better identification of waste streams and origin.
To decrease levels of waste going to landfill and increase recycling rates by staffbriefings, increase awareness of rise in landfill levy and
All Staff. Q 4 2010 Completed Dec. 2010
Q 4 2011 Ongoing.
Q 4 2012 Ongoing but vigilance required to maintain & increase recycling levels. New waste bins purchased & in service in kitchen area to promote this. Information posters in kitchen also to help increase awareness.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 45 of 133
improve local segregation. Target rate of 70% recycled.
P7/2010/11/12 Energy Efficiency: Commision energy efficiency audit for the refurbished TCR and offices / toilets. CMMS jobs completed in 2011 included push button switches on timers in office block corridors & stairwells. Timer put on basement lighting. Broken external lighting replaced with energy efficient models.
To determine if the new work areas are usingenergy efficiently and to highlight areas for improvement. Implement changes if possible and identify other areas where improvements could be made.
Sustainability champion : Dermot Brophy. All Staff
Q 3 2010 Awaiting news from HO on survey date
Q 4 2010Complete -Report out on 10.02.2011
Q4 2011 Plant manager to review findings and issue recommendations.Some jobs to be entered in CMMS & EMP
P8/2010/11/12
Policy: Review and update our Environmental Policy Statement if required.
To include any changes or improvements to the station environmental performance.
Environmental Co-ordinator : G.Slyne
Q 1 2010 Completed on 12/5/2010
Review completed May 2011
Q2 2012.Review to be completed in May 2012
P9/2010/11/12
Fire fighting foam: Remove all redundant fire fighting foam from site.
To continue to remove any unwanted substances from the site.
Environmental Co-ordinator : G.Slyne
Q 3 2010 -Completed 0n 21/9/2010
P10/2010/11/12 Public Roadway: Inspect boundary fence to public roadway and remove and dispose of any visible litter.
To satisfy a request from CCC that all businesses keep their public
Environmental Co-ordinator : G.Slyne
Q 3 2010 Completed on 20/7/2010
Q3 2011Will be done Summer 2011.
Q4 2012 Will be done twice in 2012.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 46 of 133
boundary litter free.
completed
P11/2010/11/12
Training: Complete Environmental awareness training with staff.
To ensure staff are aware of their environmental obligations and are able to respond correctly in the event of an environmental incident.
Environmental Co-ordinator : G.Slyne
Q 3 2010 Enva training on 21/05/10 for 4 staff & Jim Reynolds training for 8 staff on 27/05/10
4 of the 6 OCTM's received oil spill response training in April 2011
Q 2 2012 Oil spill response training scheduled for April 2012 for remaining staff. One staff member to do Asbestos work coordinators course in Feb.2012.- Completed
P12/2010/11/12 Re-certification to ISO14001: Ensure station licence is continued.
Continued licence certification.
Environmental Co-ordinator: G. Slyne
Complete: Oct. 2010
Q4 2011 Complete: Aug. 2011
Q4 2012
P13/2010/11/12 Compliance with IPPCL and relevant legislation: Monitor compliance with IPPCL, ensure compliance with licence conditions. Track compliance with Environmental legislation through EMS 3 review, legislation updates from HO and through the internal auditing system. Currently in Licence review process re Surface Water regulations 2009.
To keep abreast of any new legislation and ensure station compliance.
Environmental Co-ordinator: G. Slyne
Complete: Dec 2010
Q4 2011 Currently engaged in Licence Review process. Submission sent to agency on Feb. 10th 2012.
Q 4 2012 Ongoing.
P14/2010/11/12 Interceptor Monitoring: Engage a contractor to undertake quarterly inspections for mineral oil and suspended solids on all four interceptors. 2 additional Interceptors located in the oil farm across the road. All 6 Interceptors to be monitored quarterly in 2011.The 2 in the oil farm will be added to the monitoring list when fuel is placed in the storage tank.
To ensure the interceptors are operating correctly in capturing any leakage of contaminants and monitor levels of these.
Plant Manager: Mr G. Stapleton.
Q 2 2010 Contract in place 8/04/2010. Inspections to begin shortly.-16/04/2010. 2nd completed on
Q 4 2011 Ongoing. Contract in place for 2011. 1st samples taken on 22/2/2011. Sampling suspended in the oil
Q 4 2012 Ongoing. Contract in place for 2012. Sampling resumed in the oil farm in Dec.2011.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 47 of 133
15/07/2010 farm until oil is stored in the tank.
P15/2010/11/12 Legionella Monitoring: Engage a contractor to undertake monthly inspections on all water outlets. On 14/02/2011 a new WRAS approved water tank was fitted to feed toilets/showers and sinks and pipework was disinfected & lagged.The old metal tanks on the roof were isolated and decommissioned. A local weekly flushing of showers is now in operation to prevent contamination.
To reduce the risk of legionella in water outlets.
Environmental Co-ordinator; G. Slyne
Complete: Dec 2011
Q 4 2011 Ongoing. Contract in place for 2011.
Q 4 2012 Ongoing. Contract in place for 2012.
P16/2010/11/12 Water Usage: - Fit a data logger to main water meter at front gate to track water usage. On December 10th 2010 a new Data Logger was fitted to our main water meter. Data from this is collected and archived on a half hourly basis. This helps to track water consumption, highlights any leaks in the system and is a sustainability improvement.
To monitor and manage station water usage and reduce if possible. Target use is less than 10/cm per day as we no longer have any process water. Usage is tracked on the water.ie website and monitored on a monthly basis.( more often at present due to ongoing leaks)
Sustainability champion : Dermot Brophy.
Q4 2010 Complete: Dec 2010
Some leaks detected & repaired in 2011. More to be rectified in 2012.
Ongoing. Repairs to ongoing leak at main entrance gate completed in Dec.2011.Water usage still above normal so more repairs required. New water meter to be fitted at main entrance to replace broken one in Feb/ March 2012 by CCC.- These repairs done on 23/2/12 and consumption now down to 18cm from 23cm per day.
ESB Marina Generating Station AER 2011 – IPC License P0578-02
Page 48 of 133
P17/2010/11/12 Oil Farm: The Environmental Aspects need to be reviewed and ensure the oil farm is included in the environmental weekly checklist. Risk assessments are also to be completed for the oil farm. Safe Operating Procedures (SOP's) also to be put in place.The Emergency preparedness and response procedures need to be reviewed and updated to include the oil farm - currently in draft form
To ensure all environmental risks are considered and that controls are adequate and to ensure weekly oil farm monitoring is robust. To ensure compliance with licence conditions and that all risks are covered in the event of an emergency.
Plant Manager, Ger Stapleton. NSE: Dermot Brophy. Environmental Co-ordinator; G. Slyne
Q1 2012 Risk assessments completed & uploaded to IDM in Feb.2012. SOP's also in place. Environmental Aspects reviewed in Feb. 2012. Weekly environmental checklist updated to include the oil farm in Jan.2012. Emergency preparedness & response procedures currently being finalised.( 17/2/12)
Appendix 7
Residuals Management Plan Annual Review 2011
TMS Ref. no. 10073 Rev. 0
“ESB Marina Generating Station
Residuals Management Plan”
This was completed on 25th August 2010.
There were no amendments to the above RMP for 2011.
ENVIRONMENTAL LIABILITIES
RISK ASSESSMENT & RESIDUALS
MANAGEMENT PLAN
Title of Report: Environmental Liabilities Risk Assessment & Residuals
Management Plan
Client: ESB Marina Power Generation Station
Attention: Elizabeth Stack
Date: 25th August 2010
TMS Ref. No: 10073 Rev. 0
Written by: Approved by:
Douglas McMillan Nick Smyth
TABLE OF CONTENTS PAGE
1.0 Introduction 6
1.1 Scope of Work
1.2 Key Assumptions
1.3 Disclaimer
2.0 Site Activities 12
2.1 Site Description
2.2 Plant Operation
2.2.1 Introduction
2.2.2 Instrumentation and Control Room
2.2.3 Fuel Delivery
2.2.4 Power Generation
2.2.5 Water Treatment
2.2.6 Laboratory
2.2.7 Chemical Storage
2.2.8 Oil Storage
2.2.9 Waste Disposal
2.2.10 Management of Change
2.2.11 Emergency Planning
2.3 Emissions
2.3.1 Introduction
2.3.2 Air Emissions
2.3.3 Water Emissions
2.3.4 Noise Emissions
2.4 Ecological Description
2.4.1 River Lee
2.4.3 Groundwater / Soil
2.5 Inventory of Site Plant and Equipment
2.6 Historical Record
3.0 Step 1: Initial Screening and Operational Risk 27
Assessment
3.1.1 Complexity
3.1.2 Environmental Sensitivity
3.1.3 Pollution Record
3.1.4 Classification of Risk
4.0 Step 2: Closure, Restoration, Aftercare Management 32
Plan (CRAMP) – Known Liabilities
4.1 Site Evaluation
4.1.1 Site Description
4.1.2 Plant and Materials
4.1.3 Waste materials
4.1.4 Asbestos
4.1.5 Environmental Incidents
4.1.6 Long-term Liabilities
4.2 Closure Considerations
4.2.1 Introduction
4.2.2 Closure Exclusions
4.2.3 Criteria for Successful Decommissioning
4.3 Implementation of RMP
4.3.1 Strategy
4.3.2 RMP General Activities
4.3.3 Decommissioning
4.3.3.1 Decontamination Works
4.3.3.2 Residual Liquid Fuel, Tankage and Pipelines
4.3.3.3 Residual Chemicals and Tankage
4.3.3.4 Drainage Line Cleaning
4.3.3.5 Tanks & Sumps
4.3.3.6 Plant Disposal
4.4 Building Demolition
4.4.1 Introduction
4.4.2 Removal of Infrastructure and Services
4.4.3 Material and Residues
4.4.4 Demolition Nuisance Mitigation
4.5 Costing & Financing
4.6 Closure Plan Update & Review
4.7 Closure Plan Implementation
4.7.1 Notification of Regulatory Authorities
4.7.2 Test Programme
4.8 Closure Plan Validation
4.9 Restoration and Aftercare Management Plan
5.0 Step 3: Environmental Liability Risk Assessment 51
ELRA) - Unknown Liabilities
5.1 Risk Identification
5.1.1 Identification of Processes
5.1.2 Identification of Risks
5.1.2.1 Fire/Explosion resulting in Emissions to Air
5.1.2.2 Fire/Explosion resulting in Emissions to Water
5.1.2.3 Distillate Leak from Pipeline
5.1.2.4 Natural Gas Leak
5.1.2.5 Hydrogen Leak
5.1.2.6 Mechanical Failure
5.1.2.7 Leak from Drains
5.1.2.8 Oil Leak from Transformers
5.2 Risk Assessment
5.3 Risk Register
5.4 Risk Matrix
5.5 Risk Management Programme
6.0 Quantification of Unknown Environmental 72
Liabilities
6.1 Financial Model
7.0 Environmental Liability Review 74
8.0 Costing & Financing 75
APPENDIX 1. Chemical & Bottled Gas Quantities at Marina
APPENDIX 2. Oil Quantities at Marina.
APPENDIX 3. Large Plant Components & Equipment List
1.0 INTRODUCTION
TMS Consultancy was commissioned by ESB Marina Power Station, County Cork, to
prepare a Residuals Management Plan and to undertake a comprehensive
Environmental Liabilities Risk Assessment (ELRA) in accordance with conditions
10.3 and 12.2 respectively of its Integrated Pollution Prevention and Control (IPPC)
N° 719.
Clause 10.2 requires the licensee to maintain a fully detailed and costed plan for the
decommissioning or closure of the site or part thereof which must be reviewed
annually with proposed amendments notified to the Agency for written agreement as
part of the AER. Clause 12.2 requires the facility to undertake a risk assessment of the
whole site in order to make suitable provisions to cover situations where
environmental liabilities may be incurred. As recommended by the 2009 independent
review of the 2005 RMP and 2006 ELRA this report has been prepared to address
these two licence requirements. This combined report has been prepared to address
these two licence requirements.
1.1 Scope of Work
Environmental liabilities can be subdivided into two main types, known and unknown
liabilities. The quantification and costing of these liabilities is conducted as separate
exercises and different financial instruments are appropriate for each type of liability.
Clause 14 of IPPC Licence Reg. N° 719 requires the preparation and submission to
the Agency of a Residuals Management Plan (RMP) to cover restoration of the site
... following termination, or planned cessation for a period greater than six
months, of use or involvement of all or part of the site in the licensed activity.
Clause 10.2 requires the licensee shall maintain “a fully detailed and costed plan for
the decommissioning or closure of the site or part thereof” which must be reviewed
annually with proposed amendments notified to the Agency for written agreement as
part of the AER. This must include as a minimum: i) a scope statement for the plan;
ii) the criteria which define the successful decommissioning of the activity or part
thereof, which ensures minimum impact to the environment; iii) a programme to
achieve the stated criteria; iv) where relevant, a test programme to demonstrate the
successful implementation of the decommissioning plan; and v) details of costings for
the plan and a statement as to how these costs will be underwritten.
Directive 96/61/EC of 24 September 1996 concerning integrated pollution prevention
and control contains references to the necessary measures “to prevent accidents and
limit their consequences” with the scope of the work to be carried out for the ELRA
defined by Condition 12.2 of Marina’s IPPC Licence:
The Licensee shall arrange for the completion, by an independent and
appropriately qualified consultant, of a comprehensive and fully costed
Environmental Liabilities Risk Assessment for the operation, which will address
liabilities from past and present activities.
The EPA requires an independent professional assessment and costing of potentially
significant environmental liabilities that could arise under plant failure or emergency
conditions, or environmentally significant situations that do not fall under the control
and management regime of the IPPC licence. The purpose of costing such liabilities is
to ensure that the facility can make adequate provisions, via a financial instrument or
other appropriate means, for remediating the potential environmental impairment
which could result.
The EPA Guidance on Environmental Liability Risk Assessment, Residuals
Management Plans and Financial Provision (EPA 2006) was used as the reference
document for preparation of this report. The required approach comprises the
following principal steps:
Step 1: Initial Screening and Operational Risk Assessment
Step 2: Closure, Restoration, Aftercare Management Plan (CRAMP) - Known
Liabilities
Step 3: Environmental Liability Risk Assessment (ELRA) - Unknown Liabilities
Step 4: Financial Provision.
The RMP concerns identification and costing of known liabilities or steps 1, 2 and 4
while the ELRA addresses unknown liabilities or steps 1, 3 and 4 related to the site
covered by IPPC licence n° 719 and adjacent environmental media which could be
impacted by a poorly managed closure and/or emergency scenarios. The procedure for
the work carried out included a desktop study which reviewed the following
documentation:
IPPC Licence N° 719,
ISO 14001-certified Environmental Management System and associated
documentation i.e.:
o EMS1 Policy Manual,
o EMS2 Register of Aspects and Impacts,
o EMS3 Register of Environmental Legislation,
o EMS4 Environmental Programme Manual,
o EMS6 Reference Data Manual and other EMS documentation,
o EMS Procedures
o EMS 9.1 Operational Procedures Manual
o EMS 9.2 Environmental Waste procedures
o EMS10 Environmental Emergency Procedures Manual
o EMS 10.2 Reference Data Manual
o EMS11 Environmental Monitoring procedures
Previous Environmental Risk Assessment & Residuals Management Plan,
Annual Environmental Reports 2005-2010,
Groundwater Monitoring, Bund, Noise and Waste reports,
Air Modelling & Environmental Incident reports,
Firewater Retention Study,
EMG & Management Review meeting minutes,
Audit & EPA site inspection reports,
Site Chemical MSDS.
A site walkover and audit:
Discussions with key ESB Marina personnel,
On-site inspection of additional documentation and records,
Walk-through physical inspection of the power generation plant and site.
Based on this approach, the following information was compiled:
Site location and general context;
Site environmental sensitivity evaluation;
Site history and operational history including full details of site processes;
Site investigations and information available regarding the environmental
performance of the site;
Details of the layout and contents/construction of all site buildings;
Site assets register and details of the type and value of process equipment and
tanks;
Stock inventory, raw materials information and details of all hazardous
materials;
Details of storage arrangements and that bunds and underground services have
been tested as required;
Identification of all items of plant and other materials that may be
decommissioned, rendered safe or removed from the site for disposal or
recovery in the event of closure;
Identification of locations where cleaning, decontamination or remediation
works may be required in the event of decommissioning to prevent
environmental pollution;
Details of waste shipments and waste contractors;
Drawings of the facility (at appropriate scales).
Some of this information was used to prepare a description of site activities in section
2.0.
An initial screening and operational risk assessment was then carried out to determine
the facility’s risk category as described in Section 3.0.
This step was followed for the CRAMP by a description of relevant closure
considerations, criteria for successful closure, closure plan costing, recommendations
for closure plan update and review and description of the requirements for closure
plan implementation and validation. This information is provided in section 4.0.
The ELRA described in section 5.0 required hazard identification, risk assessment,
identification and assessment of risk mitigation measures and development of risk
management programme, and an assessment of the unknown environmental liabilities.
Based on this work, a thorough assessment was made of potential environmental
liabilities requiring remediation to which costs could be assigned. The appropriate
remedial actions are described for these and remediation or corrective costs are
identified.
Finally, section 6.0 assesses and establishes the relevant financial provisions to ensure
that adequate finances are available to cover:
Known environmental liabilities that will arise at the time of facility closure;
Known environmental liabilities that are associated with the aftercare and
maintenance of the facility until such time as the facility is considered to no
longer pose a risk to the environment;
Unknown environmental liabilities that may occur during the operating life of
the facility.
1.2 Key Assumptions
A certain degree of subjectivity and uncertainty is involved in the execution of
ELRAs. Assumptions underpinning this report are as follows:
ESB maintains site conditions in accordance with their IPPC Licence and
their ISO 14001-accredited Environmental Management System (EMS)
(operational since 2000). No provision has been made for costs associated
with any criminal proceedings that could arise, as firstly, it is understood
that there is good will and a strong desire by the ESB to remain compliant
with relevant legislation and EPA requirements, and secondly, such costs
are uninsurable and therefore cannot be underwritten by any third party or
insurance organisation;
The ELRA has been based upon historic and current operational activities.
It does not consider the potential environmental liabilities associated with
significant changes in use of the site, such as redevelopment for other
commercial or industrial purposes by ESB or any other party, as these
would require a separate risk assessment exercise should they arise.
Furthermore, the ELRA does not include a costing of the final clean up of
the site after closure as this is set out in the Residuals Management Plan,
specifically catered for under Condition 10 of the IPPC licence.
1.3 Disclaimer
This report is based on information supplied by ESB Marina Generating Station to
TMS Consultancy.
2.0 SITE ACTIVITIES
2.1 Site Description
Marina Generating Station is a major landmark building located at Centre Park Road,
approximately 2 km from the centre of Cork city. Historically, the station’s original
configuration was a 120 MW capacity conventional thermal plant, developed in two
stages. The ‘A’ Station comprised two 30 MW units dating from 1954 and the ‘B’
Station comprised a single 60 MW unit dating from 1964. The station was fuelled
initially by coal and was converted in 1958 to fuelling by heavy fuel oil (HFO).
The station’s dual fuel (natural gas and distillate oil) combined cycle gas turbine
(CCGT) plant was commissioned in 1979 by the addition of an 85 MW (ISO
conditions) open cycle gas turbine (OCGT) and a heat recovery boiler which fed
steam to a 30 MW legacy steam turbine to provide total electricity generating capacity
of 115 megawatts (MW). The heat recovery boiler feeds either one of two steam
turbines (Units 1 & 2) that were part of the original ‘A’ Station, although the Unit 2
steam turbine has been out of service for some time. ‘A’ Station boilers were removed
in 1995. The ‘B’ Station, comprising the 60 MW boiler and steam turbine (Unit 4),
remains in place but is disused.
The CCGT was converted to open cycle in 2009 and is fired on natural gas supplied
from the national gas network. The CT can also burn gasoil as a standby fuel and that
is supplied from the National Oil Reserve Agency (NORA) storage site adjacent to the
station via a dedicated underground pipeline. The heat recovery boiler was
decommissioned in November 2009 so the maximum output is now 94 MW. Marina’s
role has moved, as new gas-fired plant has been commissioned (Aghada, Aughinish,
Tynagh Power) to being that of a 2-shifting mid-merit plant at times of high system
demand or a support role in times of system emergency. Load factor at the plant and
hours of operation has dropped significantly as a result of which the plant has
switched to operation as open cycle peaking plant. Projected future annual load
factors are in the order of 5 to 10% and annual operating hours 500 to 1000.
The site occupies approximately 18,500m2 or 4.5 acres (standard) located in an
industrial area within Cork city. There are no residential areas in the immediate
vicinity of the site’s boundaries. The site is bounded to the north by the River Lee
and to the south by a disused coal yard (where a transformer compound is currently
being constructed) and the Centre Park Road.
A site further to the south, comprising a tank farm, also formed part of the original
ESB site and has been on long term lease to the National Oil Residues Agency
(NORA). An underground distillate pipeline runs from the tank farm site to the ESB
Marina site. Distillate is used very infrequently, approximately once per year for
proof purposes and/or as standby. An ash disposal area located to the east of the ESB
Marina site also formed a part of the original ESB site. This was sold in 1971. The
area to the south of ESB Marina was operated as a coal storage area in former times
but is now on lease to the Department of Social Welfare.
2.2 Plant Operation
2.2.1 IntroductionThe plant was started 237 times in 2009 at times of high system demand, most
typically in a 2 shift running pattern for 5 to 6 days per week, interspersed with some
24 hour running for some 3,337 operating hours. The plant is run by approximately 10
employees. The Environmental Management System (EMS) which has been running
since 1996 has been ISO 14001 accredited since 2000 and environmental management
is fully integrated into all aspects of site management and operations.
The site operates to a comprehensive set of proactive management controls including
a comprehensive maintenance programme (run through its Computerised
Maintenance Management System or CMMS), operational control procedures,
environmental monitoring, audits and inspections, calibration, emergency plans and
improvement programmes. Full integration of environmental management into the
day-to-day running of the site is achieved by delegation of actions to the station
management team and the Environmental Management Group which holds regular
meetings to identify, discuss and action all relevant issues. Environmental bulletins
are also provided to all staff. As part of 14001 certification and IPPC licence
condition 2.2, an Environmental Management Programme details objectives and
targets to be achieved for the year based on the most pressing environmental issues
identified by the EMS.
2.2.2 Instrumentation & Control Room
Operation of the turbines and other plant is monitored and controlled automatically
from a central control room. The process is tracked by a performance emission
monitoring system (PEMS) on the GT exhaust which monitors NOx (as NO2)
emissions. The main operational control is achieved through good combustion by
keeping oxygen (O2) concentrations as low as possible and burning at the correct
temperatures to minimise NOx generation. Preventive maintenance (PM) is a key
element of plant activities and where possible predictive condition monitoring is
performed to detect onset of plant deterioration. Otherwise plant and equipment is
maintained on a planned cyclical basis in a preventative way before performance
deteriorates or breaks down.
This maintenance system is computerised and managed through the Computerised
Maintenance Management System (CMMS) with unit performance or energy
consumption being measured against a target level whilst operating. Plant reliability
and optimised performance is achieved by undertaking corrective and preventive
work, either during short-term plant shutdowns or longer plant overhauls, usually on
an annual basis. Apart from the routine monitoring of performance, annual energy
efficiency audits of the generating units are carried out and opportunities for energy
efficiency improvement or recovery identified and implemented. Energy efficiency in
2009 was down to periods of open cycle operation during the summer of 2009 and
then the permanent conversion to open cycle operation from September 2009.
Air inlet pre-filters and fine filters were changed out during October 2009 to improve
performance of the gas turbine. In-house electricity consumption was monitored
throughout the year. To minimise house load the smaller rated UT1 transformer was
used as far as practicable in preference to the larger station transformer.
From a safety perspective, turbine runaway of the combustion turbines is prevented by
its protection with a sophisticated set of internationally recognised standards and
manufacturer’s recommendations including alarmed temperature and pressure
controls, continuous vibration monitoring and so on.
2.2.3 Fuel Delivery, Handling and Storage
Natural gas is supplied from the national gas network. The CT can also burn gasoil as
a standby fuel and that is supplied from the National Oil Reserve Agency (NORA)
storage site adjacent to the station via a dedicated underground pipeline.
2.2.4 Power Generation
The OCGT operates by drawing in air for combustion from the atmosphere which is
compressed this to a high pressure by a compressor driven directly by the gas turbine.
The air is mixed with the fuel in the burners and ignited in the combustion chamber to
produce hot gas. The hot gas enters the gas turbine where it causes the blades of the
turbine to turn. As a result the turbine drives its air compressor and generates
electricity for supply to the national grid.
2.2.5 Water Treatment and Cleaning Processes
Wastewaters are produced as a result of infrequent combustion turbine washings.
2.2.5.1 Sewage Treatment Plant EffluentAll Marina site sewage has been discharged into a municipal sewer on Centre Park
road since 2006.
2.2.5.2 Boiler Water BlowdownsBoiler blowdowns have ceased since decommissioning of the last remaining boiler in
September 2009.
2.2.5.3 Combustion Turbine Washings
The station has an off-line compressor water washing system to be used if required
due to performance degradation attributable to dirt on compressor blades. The system
operates by introducing a detergent solution into the compressor for approximately 3
to 5 minutes which is allowed soak for 20 minutes, followed by rinsing with clean
water for a further 15 to 20 minutes. Flowrates are about 0.33 m3 / minute with the
resulting effluent stored in a tank for approved disposal off-site using a licensed waste
contractor.
2.2.6 Laboratory
Laboratory facilities on-site were closed in September 2009 and all chemicals
removed from site.
2.2.7 Chemical Storage
In November 2009 the process of removing all bulk chemicals off site began with the
decommissioning of the Water treatment plant. This process is now complete. Smaller
quantities stored on site are listed in Appendix 1.
2.2.8 Storage of OilsQuantities of oil stored on site are listed in Appendix 2. Any tank and drum storage
areas remaining are stored in impervious bunds and all drainage from bunded areas is
diverted for collection and safe disposal in accordance with condition 3.6 of Marina’s
IPPC licence and are integrity tested at least once every three years. All transformers
on site are bunded (with the exception of T105 and T106) and some repairs were
carried out on bunds in 2009.
Waste oil is stored in one of 2 double-skinned plastic tanks located in a secure storage
shed at the southern end of the main station building. The level of risk associated with
oil storage was further reduced in 2009 by the draining down of the main lube oil tank
of the now redundant 30 MW steam turbine which was part of the old combined cycle
operation in Marina. This operation reduced the quantity of oil stored on site by 9,800
litres.
Operations Staff carried out a weekly environmental check for leaks on all unbunded
over-ground pipes and any unbunded vessels containing other than clean water, in
accordance with an Environmental Check List.
An underground distillate pipeline connects the storage tank directly from the NORA
tankfarm to the combustion turbine where it is used for emergency back-up operation.
All drainage from bunded areas is diverted for collection and safe disposal. Drainage
water from the site passes through the four oil interceptors before discharge off-site.
2.2.9 Waste Disposal
ESB Marina’s waste management system is required under the terms of its IPPC
Licence (Condition 8) and its ISO 14001 accreditation and is focused on waste
segregation and its management. Waste is clearly labelled and appropriately
segregated, stored in designated areas, protected against spillage and leachate run-off
and only handled by authorised waste contractors. Consequently, 382.33 tonnes of
waste was generated in 2009, of which 83.3% of the waste was reused or recycled i.e.
43.9% of hazardous waste and 95.26% of non-hazardous waste.
Non-hazardous waste generated in 2008/2009 included aluminium cans, glass, dry
mixed recyclables (plastic & paper), timber, rockwool insulation, cardboard, green
waste, scrap ferrous metal and mixed commercial waste. The list of hazardous
materials generated in 2008/2009 included contaminated packaging, waste oil, oil-
contaminated material, asbestos waste, oil / water mix, oil filters, lead-acid batteries,
fire-fighting foam, empty oil barrels, fluorescent tubes and adhesive.
A new bunded barrel store was installed in 2009 for the temporary storage of solid
oily waste in drums, empty/near empty drums and disused oil filters while awaiting
collection for disposal. Dry cell battery collection boxes were placed in workshops
and canteen to provide for segregation of this waste stream.
There is one general Waste Management procedure (EMS 9.2-01) and each type of
waste is subject to its own specific procedure (EMS 9.2-02 to EMS 9.2-30). All waste
is disposed of using licensed contractors agreed by the EPA. Depending on the
contract, contractors are either responsible for their own waste removal and disposal
or may use the Station’s own waste disposal facilities.
2.2.10 Management of Change
The means of identifying potential hazards, including environmental impacts,
associated with a modification or change to existing operations is detailed in the
procedures PGTS 15/22 Safety in Plant Modifications and EMS 9.1-06 Consideration
of Environmental Aspects of Plant Modifications. These employ a Plant Modification
Checklist with the aim of ensuring that all associated risks and resultant hazards
which could potentially give rise to an accident are identified and evaluated prior to
implementation of any change.
2.2.11 Emergency Planning
Emergency procedures detail:
Roles and responsibilities,
Procedures for evacuation,
Procedures for reporting emergencies,
Procedures for making plant safe,
Procedures for handover to fire brigade,
Maintenance of fire water systems and water and foam supplies,
Training,
Drills.
Emergency procedures are reviewed regularly and following major plant
modifications. The Plant Manager co-ordinates quarterly drills. Marina maintains an
on-going monitoring programme which consists of the following controls:
Weekly checks are carried out for the presence of liquids in bunds and
sumps, bund drain valves, spills, seepage from traffos and bottled gas
compounds and the contents of the site’s three spill kits;
An Accident/Incident Investigation Standard (PGTS 38/22) is in place to
identify root causes with a view to preventing similar occurrences in the
future;
An OHSAS 18001-certified safety management system is operated on site;
Internal, external and environmental audits
The station's fire fighting system consists of an electric and a diesel powered pump
both of which are rated at 1.6 m3 / minute.
2.3 Emissions
2.3.1 Introduction
There is a comprehensive system of Preventive Maintenance (PM) carried out for
most plant and equipment items including all of those that play a part in
environmental protection. Dedicated PM tasks (CMMS Standard Work Order Cards
or SWOCs) for plant and equipment purely provided for the purposes of
environmental protection and minimizing environmental impact are tagged with the
‘ENVIR’ label and are given priority codes to reflect their relative importance i.e. A,
B or C. A system of corrective or breakdown maintenance runs in tandem with the
PM policy for situations where plant or equipment is subject to deterioration,
imminent failure or breakdown.
Maintenance staff also keep a lookout for potential environmental problems or plant
deterioration such as abnormalities in environmental control equipment, drips from oil
pipe joints, liquid in bunds, evidence of oil staining under a transformer etc. (see EMS
9.1-03 Maintenance of Power Plant to Minimise Environmental Impact).
2.3.2 Air Emissions
There is one licensed emission to atmosphere point at Marina (A1-1 GT Exhaust
Stack) which is monitored in accordance with Schedule B of the station’s IPPC
Licence. The main atmospheric emissions are the greenhouse gas carbon dioxide
(CO2), water (H2O), nitrogen oxides (NOx) and carbon monoxide (CO) when firing on
natural gas and the same plus some small emissions of particulates and SO2 when
firing on gas oil. Gas oil combustion is controlled by national legislation limiting
sulphur content, so gas oil used at Marina is purchased to a legal product specification
limiting S content to less than 0.1%.
The important greenhouse gases from the combustion of fossil fuels are carbon
dioxide (CO2) and nitrous oxide (N2O) with large combustion plants worldwide
responsible for about one-third of all CO2 emissions. CO2 emission is directly related
to the carbon content of the fuels so that gaseous fuels have significantly lower
emissions than other fossil fuels. Thermal efficiency was 30.72% in 2009 down from
38.75% in 2008. The efficiency in 2009 was down to periods of open cycle operation
during the summer of 2009 and also the permanent conversion to open cycle operation
from September 2009. Air inlet pre-filters and fine filters were changed out during
October 2009 to improve performance of the gas turbine.
During 2009, the GT started 237 times, most typically in a 2 shift running pattern for
5 to 6 days per week, interspersed with some 24 hour running for 3,337 operating
hours. 99% of the electrical energy produced in 2009 was from natural gas only as
only a tiny amount of gas oil was used i.e. 776,894 MWH of natural gas and 97 MWH
of gas oil. Total CO2 produced was 158,412 tonnes while total NOx amounted to 500
tonnes.
The station’s Continuous Emissions Monitoring System (CEMS) was
decommissioned in October 2009 and replaced with a PEMS system. Performance
testing of the PEMS was carried out by ESB staff and a full QAL2 test has been
carried out to ensure that measurement accuracy is within required limits.
In open cycle operation dispersion is greatly increased due to the increased
temperature and discharge velocity of the combustion gases and modelling of this
increased dispersion predicted a reduction of impact of approximately 50% with
regard to hourly 99.8%ile NOx values. A NO2 ambient air quality monitor has been in
place at Montenotte since 2003. Data from this is used in combination with Met
Eireann wind speed and direction and plant operation data to identify any adverse
impacts. This monitoring has identified that Marina does not have a significant
detrimental effect on the air quality within the Cork city area with average and peak
NO2 values significantly below relevant air quality standards.
2.3.3 Water Consumption and Emissions
Water consumption stood at 30,703 m3 in 2008 and 31,092 m3 in 2009. This is
expected to decrease significantly for 2010 with the decommissioning of the heat
recovery element. A reserve tank of 675 m3 of town water is situated next to the Gas
Turbine. Water for domestic use and for auxiliary plant cooling requirements is also
stored in roof tanks on A Station boiler house roof (1 x 13 m3 & 1 x 5m3 respectively).
There are no emissions to municipal sewers from the ESB Marina site but there are
four licensed water emission points at Marina Generating Station (SW3 -
Neutralisation Tank effluent), SW4 (Interceptor 2 - surface water, process water, town
water), SW6 (Cooling Water Outfall - river water)) and SW7 (Interceptor 3 - surface
water, process water and boiler blowdown effluent). Interceptors are monitored
visually each week. Interceptor 1, 2, 3, 4 have quarterly mineral oil tests carried out
while Interceptors 2, 3, 4 also have quarterly suspended solids analysis done. SW3
and SW6 are no longer operational with the removal of the heat recovery element.
Reference to these is to be removed from the licence conditions.
There are also three licensed stormwater emission form the site i.e. SW2 receiving
waters through Interceptor 1 (process water, town water, river water, surface water)),
SW8 from Interceptor 4 (surface water) and SW9 (Access Road (surface water))
monitored weekly visually for colour and odour.
Four groundwater monitoring stations - AGW1 (driveway), AGW2 (SE of GT),
AGW3 (rear of boiler house) and AGW4 (wharf) - are tested twice yearly for pH,
COD, nitrate, total ammonia, total nitrogen, conductivity, chloride, cyanide, PAH and
total chloriforms.
Hazardous materials especially all bulk chemicals and wastes are stored in designated
locations protected against spillage. Chemical drum storage is on dedicated storage
racks that incorporate bunds. The drainage system, bunds, silt traps and oil
interceptors are inspected weekly in accordance with an Environmental Checklist.
Any sludge such as sewage sludge or sludge at the bottom of interceptors is removed
or de-sludged as necessary.
2.3.4 Noise EmissionsNoise and vibration are common issues arising from the operation of large
combustion plants especially gas turbines which have the potential for high noise
emissions. Environmental noise surveys carried out at the boundaries of the site in
November 2008 and December 2009 confirmed the station was within its licence
limits of 55 dB(A) during daytime hours and 45 dB(A) at night with no tonal
components present.
2.4 Ecological Description
2.4.1 River Lee
The Marina site is situated beside the River Lee runs into the Cork harbour area with
1,436 hectare of intertidal habitat designated as a Special Protection Area (SPA). The
River Lee is also important for salmon fishing although the waters directly outside the
generating station are not designated as salmonid waters. ESB commissioned Irish
Hydrodata Ltd to complete a thermal plume study which showed that even under
worst-case conditions (neap tide and dump condenser in operation), that the plume
was minimal and has negligible impact on fish movements, which was corroborated
by fisheries census work.
With the decommissioning of the boiler and heat recovery unit discharges are
confined to surface water runoff. Phosphate and ammonia releases ceased in
September 2009.
2.4.2 Groundwater/Soil
An ESBI Groundwater Monitoring Study was carried out for the period 2003 to 2004.
This found groundwater samples were generally cloudy as the result of fines
mobilisation arising from groundwater recharge. Elevated conductivities and chlorides
associated with borehole AGW-3 were considered to result from the influence of the
brackish waters of the Lee. Groundwater was also found to be contaminated with
ammoniacal nitrogen and coliforms which are unrelated to the site’s activities.
Consequently, these were considered to reflect background urban levels associated
with foulwater losses or fertilizers lost from a storage site nearby. The station and its
activities were not considered to be having an adverse impact on soil or groundwater
quality.
2.5 Inventory of site plant and equipment
The current main operational features of the station include the following (a more
complete list of large plant components and equipment is provided in Appendix 6):
One GE/Alstom 85 MW Frame 9B combustion turbine and Alstom
generator
One (decommissioned) CMI exhaust gas heat recovery steam generator
(HRSG)
A refurbished (but decommissioned) Siemens 30 MW steam
turbine/generator
2 decommissioned steam turbines, one 30MW and one 60MW
Two stacks
Water treatment plant (WTP) including bulk chemical storage tanks for
processing of towns water prior to its use in the boiler (decommissioned)
A (decommissioned) neutralisation plant for treating water treatment
effluents
Generator, unit and house transformers
Electrical compound and associated overhead line and cables
A decommissioned, cooling water system comprising pumphouse, inlet and
outlet culverts, and discharge weir, for condenser cooling
Dump condenser and associated plant (decommissioned)
Supporting facilities including the following:
Administrative offices and canteen (canteen now closed)
Chemical laboratory
Water storage tank
Fire protection pumphouse
One workshop and stores
2.6 Historical Record
ESB Marina Generating Station was established in 1954. The station’s original
configuration was a 120 MW capacity coal/oil-fired thermal plant, developed in two
stages. Station A comprised two 30MW coal fired units commissioned in 1954.
Station B comprised a single 60MW unit commissioned in 1964 and subsequently
decommissioned but not dismantled. In 1979 the current 85 MW combined cycle gas
turbine (CCGT) was commissioned. The station converted to oil in 1958 and then to
natural gas in 1979. The three A station boilers were dismantled in 1995.
It was replaced in the early ‘80s to produce a total electricity generating capacity of
115 megawatts (MW) comprised of an 85MW combustion turbine and a waste
recovery boiler which feeds steam to a 30MW steam turbines which formed part of
the original A station. The heat recovery element has now been decommissioned and
maximum output is now 94 MW.
The CT is fired on natural gas supplied from the national gas network. The CT can
also burn gasoil as a standby fuel and that is supplied from the National Oil Reserve
Agency (NORA) storage site adjacent to the station via a dedicated underground
pipeline. Marina’s role has moved to being that of a 2-shifting mid-merit plant at
times of high system demand or a support role in times of system emergency and
operates as open cycle peaking plant, with a lower annual load factor of 5 to 10% and
reduced operating hours. A number of incidents have occurred in the past. These are
discussed in detail in section 4.1.5
3.0 Step 1: Initial Screening and Operational Risk Assessment
3.1 Introduction
A closure plan or Closure, Restoration and Aftercare Management Plan (CRAMP)
provides costings that deal with site decommissioning and known liabilities for the
facility at closure while an Environmental Liability Risk Assessment (ELRA)
considers the risk of unplanned events occurring during the operation of a facility that
could result in unknown liabilities materialising. An initial risk assessment was
carried out in order to categorise Aghada Generating Station as being of risk Category
1, 2 or 3 to identify the suitable CRAMP/ELRA approach for the facility.
A relatively simple risk assessment decision matrix is employed that relies on the use
of the three key aspects of Complexity, Environmental Sensitivity and Pollution
Record.
3.1.1 Complexity
A complexity banding indicates the extent and magnitude of potential hazards
according to the class of activity. This ranges from G1 (least complex) to G5 (most
complex). Marina is classed in section 2 Energy:
2.1 The production of energy in combustion plant the rated thermal input
of which is equal to or greater than 50 MW.
As a generating station producing approximately 1000 megawatts a year it is rated G4
making it automatically a Category 3 risk (see Table 3.1 below) thereby invalidating
the need to complete an initial screening.
Table 3.1. Risk Category.
Risk Category Total Score
Category 1 <5
Category 2 5-23
Category 3 >23
A CRAMP for a Category 3 facility such as Marina, may require, either due to the
nature of the operation (e.g. mining and landfill) or due to the presence of significant
land contamination, a process of extensive restoration and aftercare. This period
would typically include on-going restoration/remediation works, contaminated land
remediation/management and long term monitoring. However, where category 3
facilities (excluding mining and landfill) have demonstrated by way of previous
investigations that long term liabilities are not present, the requirements for RAMP
will be reduced.
The ELRA for a Category 3-risk facility requires a detailed site-specific approach, the
objectives of which are generally:
To identify and quantify environmental liabilities at the facility focusing on
unplanned but possible and plausible events occurring during the operational
phase;
To calculate the value of financial provisions required to cover unknown
liabilities;
To identify suitable financial instruments to cover each of the financial
provisions; and
To provide a mechanism to encourage continuous environmental improvement
through the management of potential environmental risks.
3.1.2 Environmental Sensitivity
The sensitivity of the receiving environment in the vicinity of the facility is evaluated
using an environmental sensitivity sub-matrix which assesses six key environmental
receptors: Human Beings, Groundwater, Surface Water, Air Quality, Protected
Ecological Sites, and Sensitive Agricultural Receptors (see Table 3.2). A score is
applied to each receptor (more sensitive locations receiving a higher score) and these
scores are added to obtain an environmental attribute score. The score is then
classified as Low, Medium or High by checking against a pre-defined Environmental
Sensitivity Classification Table (see Table 3.2).
Although this step, and the steps described in 3.1.3 Pollution Record and 3.1.4
Classification of Risk are not required, due to the fact that Aghada is automatically
classed as a Category 3 facility because of its G4 rating, these sections and the
completed Table 3.2 are useful for completion of the risk assessment process
described in sections 3.2 and 3.3.
Table 3.2. Environmental Sensitivity Sub-Matrix.
Environmental Attribute Environmental Attribute Score
Human Occupation
<50m
50-250m
250-1000m
>1km
Scoring System
5
3
1
0
Plant Score
3
Groundwater Protection
Regionally important aquifer
Locally important aquifer
Poor Aquifer
Vulnerability Rating-Extreme
Vulnerability Rating-High
Vulnerability Rating-Moderate
Vulnerability Rating-Low
2
1
0
3
2
1
0
0
0
Sensitivity of Receiving Waters
Class A
Class B
Class C
Class D
Designated Coastal & Estuarine Waters:
Potentially Eutrophic Coastal & Estuarine Waters:
3
2
1
0
2
1
1*
0
Air Quality and Topography
Complex Terrain
Intermediate Terrain
Simple Terrain
2
1
0
1
Protected Ecological Sites
Within or directly bordering protected site 2
<1km to protected site
>1km to protected site
1
0
0
Sensitive Agricultural Receptors
Fruit, vegetable or dairy farming <50m from site
boundary
Fruit, vegetable or dairy farming 50-150m from site
boundary
Fruit, vegetable or dairy farming >150m from site
boundary
2
1
0
0
Total Environmental Attribute Score: 5
* The EPA have classified Cork Harbour water quality as “intermediate”.
** Intermediate terrain where the elevations of receptors lie between the stack tip elevation and the plume rise elevation,
US EPA (2000) Meteorological Monitoring Guidance for Regulatory Modelling Applications.
Table 3.2. Environmental Sensitivity Classification.
Total Environmental Attribute Score Environmental Sensitivity Classification
Low <7 1
Moderate 7-12 2
High >12 3
The result is 5 or Low (<7) for the station giving it an Environmental Sensitivity
Classification of 2.
3.1.3 Pollution RecordThis is based on the facility’s compliance record and whether significant ground
contamination is present below the facility. Marina Generating Station has had no
complaints and one non-compliance in the past 12 month period - a category 3
incident where an oil leak occurred in the gas turbine steel engine compartment on
09/12/2009. Prompt action by staff ensures that no pollution occurred. A more
significant oil spill occurred in 2003 after which an immediate containment and clean
up operation was carried out, despite which 1000 to 1500 litres of oil was
unaccounted for and may have been released to soil/groundwater. Consequently, the
facility is classed as being minor non-compliant and has a compliance record score of
3 (i.e. Licensed facilities with minor emission non-compliances (< 5 non-compliances
in a 12 month period) are classified as being Minor Non-Compliant and have a score
of 3. Facilities with minor soil and groundwater contamination (i.e. those with
concentrations above background but not posing risk to the environment) are also
considered in the class).
3.1.4 Classification of RiskScores for each of the three aspects – Complexity, Environmental Sensitivity and
Pollution Record - are then multiplied together to give the total score which is read
against the score banding in Risk Category Table (see Table 3.1) to classify the
facility as being low, medium or high risk. The score for the site is:
4 x 1 x 3 = 12
This would classify the site as a Category 2 risk although it is automatically classified
as Category 3 due to its energy generation capacity.
4.0 Step 2: Closure, Restoration, Aftercare Management
Plan (CRAMP) – Known Liabilities
4.1 Site Evaluation
4.1.1 Site Description
A description of the station and its features is given in section 2.1 and an image of the
site layout is given in Figure 1.
4.1.2 Plant and Materials
The site stores a variety of coded items and materials that are used in operations and
maintenance activities, most of which are of little or no environmental significance. A
full list of maximum quantities of chemicals on site is given in Appendix 1 while a
description of the storage and locations of oils is found in section 2.2.9 and a full
description in Appendix 2. Actual quantities remaining at shut-down would likely be
much less due to scaling down of activities prior to closure, allowing a staged
reduction in inventory. Plant and equipment remaining on site at the time of
decommissioning will be sold on to suitable customers. Where this is not feasible they
will be disposed of through the company’s list of registered waste disposal
contractors.
4.1.3 Waste materials
A summary of waste materials and waste generation over the last three years is
presented in section 2.2.9 and a rough inventory of site plant and equipment is given
in section 2.5 with a list of larger equipment given in Appendix 3. The amount of
wastes generated will increase significantly during implementation of the RMP with
the following being of particular note:
Batteries,
Waste lubricating oils,
Waste transformer oils,
Waste chemicals,
WEEE.
Soft stripping of buildings prior to demolition will also generate some of the
following types of items which may be recycled or reused:
Fittings,
Fixtures,
Furniture,
Blinds,
Heaters,
Dryers,
Light switches and sockets,
Piping.
Additional hazardous wastes that may arise during decommissioning would be as
follows:
Smoke detectors,
Chemical paints and additives,
Coolants (spent machine),
Refractory brick from the station chimney,
Silica gel.
Wastes arising during decommissioning will be managed in accordance with
Condition 8 of IPPC Licence Reg. N° 719.
4.1.4 Asbestos
Asbestos was used extensively in the original development at Marina, but all lagging
containing asbestos was removed where known and accessible during an Asbestos
Removal Programme carried out in 2002 to remove all asbestos from A and B station
boilers. There are residual areas where encapsulated asbestos has not yet been
removed, most notably the external cladding to the ‘B’ Station boiler. Asbestos was
not used extensively in the redevelopment of Marina as a CCGT power plant and all
insulating materials that were used are non-asbestos fibres. However, minor amounts
of asbestos may also still be incorporated in certain small items such as gaskets and
gland packing. Consequently, large-scale removal of asbestos insulation and lagging
from the plant will not arise during decommissioning.
4.1.5 Environmental Incidents
In 1981 an incident involving the unloading of two drums of liquid chlorine occurred
when a leak was detected in one of the drums. This was satisfactorily controlled. A
release of weak acid to drain also occurred in 1992 during an acid wash of boiler
tubes and headers. Lime was used to neutralise the leakage before eventual discharge
to the river.
An environmental assessment carried out by ESBI in 1998 detected levels of Poly-
aromatic Hydrocarbon (PAH) contamination at borehole number 2. This was thought
to have arisen from historical storage of coals outside of the licensed area. However,
coals have not been stored there since 1979. The report indicated that PAH would be
expected to disintegrate over time and that levels would approach near background
levels. This assessment also identified potassium cyanide contamination at borehole
number 1 (AGW-1). This contamination was thought to have originated from sources
off-site and since then levels have since declined to <0.05 mg/l. Other exceedences
which may occur in the boreholes e.g. coliforms, chlorides, nitrates etc. are also
believed to originate off-site as there are no sources of these materials on-site.
In 2003 a spill resulted in the release to soils of approximately 1,000 to 1,500 litres of
lubrication oil. This oil is less dense than water, highly viscous, non-volatile and
biodegradable. A study was carried out to determine the consequences of this spill
(ESBI “Combustion Turbine Oil Spill Desk Study”) which concluded that the oil was
unlikely to reach the surface water drainage system and is more likely to have been
taken up by soils under the spill site. It considered that the retention capacity of the
soils along the route from the oil spill to the River Lee might be as high as 5,700 litres
which exceeded the volume of oil spilt.
There were two category three incidents in 2006 and one incident in 2008 and 2009
respectively. All of these were light to moderate oil spills which were successfully
dealt with by site staff to prevent any pollution.
Consequently, any contamination that has arisen as a result of the above incidents has
been dealt with satisfactorily and there is no ongoing impact on station lands.
4.1.6 Long-term Liabilities
The screening process identifies the site as a Category 3 facility making a Restoration
and Aftercare Management Plan including on-going restoration/remediation works,
contaminated land remediation/management and long term monitoring, in addition to
the compulsory Closure Plan. However, as the site has demonstrated by way of
previous investigations that long-term liabilities are not present, these RAMP
requirements should be reduced. Furthermore, the environmental monitoring
programme conducted at Marina is carried out in accordance with the requirements of
Condition 6.1 of its licence. Monitoring in accordance with Schedules B and C is
designed to identify any impacts associated with operation of the station so as to allow
effective remedial action or minimise environmental pollution.
Current knowledge concerning the long-term environmental liability associated with
the site and full compliance with IPPC Licence Reg. N° 719 is expected to ensure that
any additional liabilities will be avoided. Consequently, a significant soil and
groundwater programme at station decommissioning is not anticipated beyond that
which is already carried out as per Schedule C of the licence.
4.2 Closure Considerations
4.2.1 Introduction
The energy market is currently very volatile and the anticipated reduced usage
patterns of the site have not yet materialised so that there are currently no plans or
dates for closure. It is also considered that given its historical landmark status it is
unlikely that the site would be demolished, however, this RMP considers restoration
of the site to an anticipated industrial end use which includes demolition of the
existing building structure. Should no major incidents occur between now and any
future closure date, a clean closure is envisaged for the site. With the inactivation of
the HRSG, steam turbine, water treatment plant and cooling water facility, from an
environmental risk perspective, much of the more significant decommissioning work,
has already been completed.
4.2.2 Closure Exclusions
The structural form of station buildings is conventional structural steel supported on
reinforced concrete foundations. Gantries and walkways for access to plant and
equipment are constructed of stainless/galvanised steel open grating type flooring.
These are supported on steel beams and columns. External walls predominantly
comprise brickwork with some profiled metal cladding and asbestos sheeting (‘B’
Station boiler house). Roofs are constructed of profiled metal decking on purlins
spanning between rafters. The materials used do not pose any environmental threat in
the event of station closure, whether they are demolished or remain in place.
Certain station areas will continue to operate or remain operational. These include
facilities such as the 300 litre diesel tank supplying the diesel engine-powered fire
pump in the fire protection pumphouse. Services that are performed by contractors on
an ongoing basis include the following: hygiene services, general building work,
waste disposal service, rodent control, laundry, lagging, tool hire and specialist
welding. These activities have no implication for the RMP.
All equipment and plant at Marina is the property of the station, other than the
following:
Cylinders in which bottled gas is delivered are the property of the supplier,
who will be responsible for their removal;
The 110 kV compound, including network transformers and associated
cabling, are the property of ESB Networks.
4.2.3 Criteria for Successful Decommissioning
ESB has already successfully decommissioned a number of power stations on the
above basis in the past at Miltown Malbay, Screeb, Gweedore, Allenwood,
Portarlington, Ringsend and Ferbane as well as the HRSG, steam turbine, WTP and
cooling water facility in 2009. Since commissioning of its first unit in the 1950s, the
presence of Marina Generating Station has not resulted in significant environmental
impacts and the station will continue to be operated in a responsible manner. Issues
that are likely to arise upon closure at Marina have all been dealt with successfully in
the past at other ESB sites.
Successful clean closure will be achieved when it can be demonstrated that there are
no remaining environmental liabilities at the site. In practice, this will require
demonstration that the following criteria have been met:
The appropriate decontamination of all plant and equipment using standard
procedures and authorised contractors;
Documented reports of all raw materials dispatched from the site;
All wastes handled, packaged, temporarily stored and disposed or recovered in
a manner which complies with regulatory requirements;
All relevant records relating to waste and materials movement and transfer or
disposal are managed and retained throughout the closure process;
Clearance and documentation indicating final disposal for any asbestos found
to be present in the station.
Documented post-closure soil and groundwater programmes if this need
arises;
The Environmental Management System remains in place and is actively
implemented during the closure period;
Secure archiving of all documentation.
Furthermore, the areas occupied by all/relevant facilities and ancillary areas will be
decommissioned and rehabilitated to a condition where are no constraints on future
land use due to residual contamination or structures. Materials will be treated in such
a manner that:
Equipment and uncontaminated materials will be resold or reused;
Uncontaminated materials that cannot be reused will be recycled;
Contaminated or unrecyclable materials will be disposed of using authorised
waste contractors.
The overall objective is for clean closure of the site with no residual liabilities or
constraints.
4.3 Implementation of RMP
4.3.1 Strategy
ESB intends to manage and execute the RMP using internal resources, supplemented
as necessary and appropriate with external resources. All external resources used for
cleaning, waste disposal, etc. will be fully approved and licensed as appropriate.
A Residuals Management Team will be created to manage and execute the entire
project and key activities will be supervised by personnel with appropriate experience
and expertise. Only suitably qualified personnel will carry out decontamination
works.
Options that will be available with regard to various residuals are broadly as follows:
Reuse - removal for reuse at other ESB power station(s) or return to supplier
Recovery / recycling - sale to third-party
Disposal - final disposal as waste
Waste sent off-site for recovery / recycling or disposal will only be conveyed to
licensed waste contractors and carriers.
4.3.2 RMP General Activities
The activities within the scope of the RMP are as follows:
Cessation of all energy production;
Cancellation of all incoming deliveries of materials to the station;
Termination of all contracts other than those that are concerned with the
RMP or related to safety of personnel or the environment;
Return of materials to suppliers where possible, for resale or reuse;
Isolation and purging of transfer lines from bulk storage to direct pipe
contents back to bulk storage;
Shutting and blanking of supply lines from bulk storage for chemicals to
intermediate storage;
Cleaning and decontamination of all plant and equipment;
Cleaning, decontamination and inspection of bunds, sumps and underground
drains;
Removal of old and obsolete equipment and destocking of the workshops and
stores;
Isolation and disconnection of all electrical supplies to pumps and motors;
Draining of oil from obsolete transformers that cannot be reused elsewhere;
Decommissioning of redundant oil-filled cables and draining of header tanks
and sealing ends;
Cleaning of residues from the boiler and cleaning and blanking off of fuel
lines;
Draining and cleaning of lube oil systems;
Draining of water systems such as raw feedwater tanks, condensate storage
tanks and supplementary cooling systems (carried out in 2009);
Transfer of ion exchange resins to drum storage (carried out in 2009);
Maintenance of parts of the water supply system to provide wash-down and
cleaning facilities during decommissioning and to meet the ongoing needs
for fire protection and sanitary services;
Maintenance of site drainage system and oil interceptors during
decommissioning activities;
Ultimate removal and appropriate disposal of biological filters for foul
effluent;
Secure archiving of all relevant documentation including drawings,
instrumentation diagrams, validation documentation, vendor manuals and
data, project files, maintenance records, inspection records, waste disposal
records and other appropriate documentation;
Maintenance of defined site access procedures and security requirements for
ongoing monitoring of the site from safety, fire protection and environmental
perspectives.
It is anticipated that any necessary decontamination of plant and equipment will be
carried out on site. It will primarily involve cleaning in situ and power washing of
internal and external surfaces. ESB will seek approval from the Agency for any
decontamination procedures and monitoring requirements to be employed. An
appropriate disposal route for all wash waters generated during decommissioning will
be agreed with the Agency prior to disposal.
4.3.3 Decommissioning
4.3.3.1 Decontamination Works
Tanks, pipes, drains and sumps are all regularly tested in accordance with internal
EMS procedures so they will be in good condition (EMS 9.1-04 Maintenance of
Drains, Sewers and Effluent Pipe Lines). An assessment of the level of contamination
will be made for residues or materials including fuels, oils, greases and process
reagents/chemicals. All contaminants will be removed, drained or flushed from
all/relevant plant, tanks and pipelines and residues containing fuels, oils and other
contaminants will be removed off-site for recovery or disposal. All/relevant buildings,
structures, plant and surfaces will be hosed down or flushed out with high pressure
water and treated in the effluent treatment plant if necessary. Any areas of
soil/groundwater with visual contamination will be excavated directly for off-site
treatment and risk assessments will be conducted to establish the most suitable
method of remediation.
4.3.3.2 Residual Liquid Fuel, Tankage and Pipelines
The station's own storage of diesel is limited to small capacity tanks serving diesel
powered items of equipment such as the fire protection pumphouse. Plastic tanks of
small capacity are in use for waste oils. The maximum quantity of liquid fuel will be
used prior to the cessation of power generation so that the minimum quantity remains
on site. Where possible, all pipelines and tanks will be drained using on-site pumps to
“loss of suction” to minimise the remaining residues within tanks and pipework.
Drains in the areas where these facilities are located will be isolated before
commencement of decommissioning activity.
Tankage: The most effective method for cleaning of tanks will be to absorb residues
by scrubbing / flushing. The dissolved liquid will then be pumped to a tanker for
treatment and re-separation and the tank will be jet washed with water / detergent to
remove remaining residues. The tanks will then be suitable for removal for clean
scrapping.
Pipelines: Where necessary, pipework will be cleaned by a variety of methods
including an in-situ pneumatic pipe cleaner / scourer machine (a ‘pig’), retro-jetting
with water, flushing with water or kerosene, or high-pressure air flushing. At this
stage of cleaning the pipework will be in an acceptable state for either retention on
site or removal for clean scrapping.
4.3.3.3 Residual Chemicals and Chemical Storage Tank Cleaning
The main bulk chemicals used at the station and associated tanks have been
decommissioned and removed from site. The use of wet chemistry in the station
laboratory was eliminated with the closure of the lab in September 2009..
4.3.3.4 Drainage Line Cleaning
The discharges of concern are:
• SW2 - Surface Water/Station Drainage
• SW4 - Surface Water/Station Drainage
• SW7 - Surface Water/Station Drainage
• SW8 - Surface Water/Station Drainage
• SW9 - Surface Water/Station Drainage
The above are protected by oil interceptors as appropriate and there is no potential for
impact upon the receiving environment if the drainage system is left in place after
decommissioning. However, cleaning of station drains will be required to mitigate the
potential for oil residues to be present within pipelines. This will involve cleaning
down the drainage system using water jetting, utilising the existing oil interceptor
system and vacuum tankers. Oil interceptors will be cleaned down and all waste and
effluent will be removed for appropriate disposal. No areas of heavy or free product
oil residues that would require steam cleaning are expected. On completion of
decommissioning the site drainage will be in a suitable condition for removal or more
likely to be left in place to continue to provide surface water drainage for the site. The
station will continue to properly operate and maintain the site drainage system prior to
and during implementation of the RMP.
4.3.3.5 Tanks & Sumps
The only remaining notable tank and sump within the station is the turbine lubrication
oil tank associated with the combustion turbine. All waste will be removed from the
above for appropriate disposal and tanks, sumps and associated pipework cleaned
down and decommissioned.
4.3.3.6 Plant Disposal
Mobile plant items include one forklift, several pallet trucks and one van for
movement of materials around site. Fixed plant items and material containers are
listed in Appendix 3. Plant services including pipes and cabling with the majority of
pipelines and transfer lines above ground and welded where reasonably practicable.
All the above will be drained of oils/chemicals and/or decontaminated where
necessary and reused or sold for scrap.
4.4 Building Demolition
4.4.1 Introduction
There will be a logical sequence of demolition works. Due to the unforeseeable nature
of any future demolition work a demolition programme cannot be drawn up.
However, best practice guidelines will be used to draw up a waste management plans
for the Construction and Demolition work which will be carried out under the control
of a C&D Waste Manager. This will address the following aspects of any demolition
project:
Analysis of the waste arisings / material surpluses (pre-
demolition/reclamation audit);
Specific waste management objectives for the project (material recovery
targets);
Methods proposed for the prevention, reuse and recycling of wastes (soft
stripping of reusable items, recycling of non-reusable items, disposal of non-
recyclables);
Material handling processes (degree of segregation, use of crushers and
screeners for aggregate preparation etc.); and
Proposals for education of workforce and plan dissemination programme.
Such a plan will maximise waste prevention and minimisation and ensure demolition
debris is segregated into steelwork, masonry and other materials to maximise the
possibilities for reuse, ideally on site or less preferably, recycling. Disposal will only
be considered as a last resort.
A coherent Demolition Plan will also constitute an integral part of the project C&D
Waste Management Plan to ensure that the sequence of operations to be followed is
predetermined and documented to ensure that an appropriately selected
dismantling/demolition methodology is employed. This will also pay special attention
to the sorting/segregation arrangements to be followed.
4.4.2 Removal of Infrastructure and Services
All drainage and associated services will be carefully removed along with all roads,
hardstand areas and other infrastructure. Decontamination will be carried out as
previously outlined if necessary. As for demolition works, the specific requirements
for infrastructure removal are impossible to foresee so a detailed sequential
programme of removal cannot be produced.
4.4.3 Material and Residues
Provision will be made for the appropriate and authorised disposal of the following:
Process chemicals, reagents and food substances;
Laboratory reagents;
Fuels and oils;
Operational equipment wastes;
Wastewater treatment sludges;
Soil or spoil.
4.4.4 Demolition Nuisance Mitigation
Any demolition works that are carried out in connection with or associated with the
RMP have the potential to lead to elevated noise levels and to creation of dust.
Additional traffic movements will also arise. The following mitigation measures are
proposed:
Noise: All works will be carried out during daylight hours and noise levels
will monitored to ensure compliance with the requirements set out in condition
8 of IPPC Licence Reg. N° 734. Noise minimisation measures will be
employed. These will include such measures as using saw-cutting machinery
instead of rock breaking equipment;
Dust: Surfaces that have the potential to generate dust during their demolition
will be wetted prior to the work commencing. Demolition on windy days will
be avoided as far as possible;
Traffic: While traffic will arise in the removal from site of residuals, this will
coincide with the elimination of current sources of traffic associated with
station operations. It is considered that the demolition related traffic will not
pose undue difficulties.
4.5 Costing & Financing
ESB has a very significant working capital and any decommissioning or closure of
Marina would be a well resourced activity. The company has adequate resources of
finance and manpower to implement the RMP through to completion. More
significantly, ESB makes specific financial provision for closure of its power stations
and this is outlined in the company’s annual accounts. This figure represents the
present value of the current estimate of the costs for closure of generating stations
including Marina at the end of their useful economic life. These costs are recognised
in full at the outset of the asset life, but are discounted to present values using a risk
free rate.
Since the costs are capitalised and initially provided on a discounted basis, the
provision is increased each year by a financing change. This is calculated based on the
provision balance and is included in ESB’s profit and loss account. In this way the
provision equals the estimated closure costs.
Further to the above, Marina covers a significant area in a central location and being
an industrial site it has considerable potential for redevelopment and would be
expected to constitute a considerable asset following decommissioning. Furthermore,
much of the plant and equipment will have significant residual value. The value of the
site and its plant and equipment alone provides a fund that greatly exceeds the
potential costs of decommissioning.
Specific costings have not been developed for the RMP at Marina. However, it is
evident from the limited number of issues that required inclusion in the scope of the
RMP that the company’s financial provisions and the value of the assets at Marina are
orders of magnitude greater than the costs that may be incurred. Estimates of
projected costs associated with site closure are outlined in Table 4.1 below.
In the event of demolition works, a detailed Project C&D Waste Management Plan
will be drawn up as outlined in Section 4.4. Costs in this case will be contingent on a
number of factors including space and time constraints, local authority conditions
attached to the work, material recovery targets imposed by future legislation and
available markets for reuse and recycling.
In the event of demolition works, a detailed Project C&D Waste Management Plan
will be drawn up as outlined in Section 4.4. Costs in this case will be contingent on a
number of factors including space and time constraints, local authority conditions
attached to the work, material recovery targets imposed by future legislation and
available markets for reuse and recycling.
Table 4. RMP Costings.Item Removal CostBuilding demolition 1,000,000Asbestos removal & disposal 15,000Surfaces removal e.g. hardstandings, roads etc. 60,000Pipework (water and sewers) 190,000Electrical services 200,000Security enclosures Already in placeMobile plant 20,000Decommissioning plant 110,000Landscaping and re-contouring 150,000Off-site waste disposal e.g. pipework, oils, equipment etc.
80,000
Power consumption during decommissioning 5,000Engineering construction management during decommissioning
50,000
Facility security & staffing 30,000Test Programme 5,000Environmental Monitoring 5,000Reporting to EPA 3,000Verification Audit/Certification 1,500Hydrogeological site investigation 30,000Subtotal 1,954,500Contingency (25%) 488,625Total (excl. VAT) 2,443,125
Cost components for demolition waste management can be broken down into:
Purchase cost of waste materials;
Handling costs;
Storage and transportation costs;
Revenue generated from sales of reusable/recyclable materials;
Disposal costs including landfill tax.
This will enable proper estimation of total waste concrete, soil and masonry
management costs.
4.7 Closure Plan Update & Review
The RMP is reviewed annually as part of the AER. This review aims to address any
developments at Marina and evaluate the scope of the RMP in the context of any
environmental incidents at the station to update the RMP as necessary. The updated
and reviewed Plan will take account of any relevant changes in site processes,
technology and/or costs.
4.8 Closure Plan Implementation
4.8.1 Notification of Regulatory Authorities
The EPA and local authorities will be given 6 months notice of site closure. The form
of notice will be in accordance with prevailing guidance and on the foot of proper
consultations with the authorities as part of the process.
4.8.2 Test Programme
The monitoring and reporting requirements set out in IPPC Licence Reg. N° 719 will
be complied with in full until the licence is surrendered to the Agency. The
monitoring will identify if any contamination of air, surface water, groundwater or
soils has occurred during the lifetime of the IPPC Licence.
In the event that a future environmental incident causes contamination of these media,
which has not been quantified at the time of the closure of the facility, a specifically-
designed test programme will be established as part of the RMP to identify the nature
and scale of any associated environmental pollution. For example, such test
programmes have already been carried out in relation to the 1998 environmental
assessment and the 2003 oil leak.
Tests will be carried out on wash waters generated during the decontamination works
to confirm that they are suitable for discharge. While testing has already confirmed
that there is no reason to believe that such contamination may be present, oils will be
sampled and tested for PCB contamination.
The main monitoring requirements will relate to groundwater sampling and analysis
as per condition condition 6 of IPPC Licence. The duration of this monitoring before
the site can be considered free of contamination will be agreed with the EPA.
4.9 Closure Plan Validation
Following successful implementation of the RMP after physical closure of the
relevant sections of the site, a validation audit of all aspects relating to the affected
area(s) will be carried out by an independent auditor and a report produced to
demonstrate its successful implementation. It will confirm that there is no continuing
risk of pollution to the environment from the site. The report will address:
Disposal of materials;
Decontamination of items of plant and equipment;
Decommissioning of plant and equipment;
Results of monitoring and testing;
The need, if any, for ongoing monitoring and investigations.
The report will be submitted to the Agency within three months of completion of the
RMP.
In addition to the above validation, in line with ESB’s policy in relation to closure of
its power stations, a full environmental summary report will be prepared. This will
outline the following:
The full history of the power station site from its initial development through
to closure;
The various investigations undertaken and reports prepared during the
operation of the plant;
The actions taken in the course of the RMP.
The Environmental Summary Report will be made available to future users of the site,
whether this is ESB or a third party.
It is expected that the EPA will conduct a post closure audit of the site to satisfy itself
that the facility is fully compliant with its licence conditions at the time of closure in
order to facilitate the formal partial surrender, surrender or transfer of the licence.
4.10 Restoration and Aftercare Management Plan
Site restoration and aftercare management plans are required in the case of landfill
and mining facilities and where there is evidence of soil and groundwater
contamination or there have been spills in the past. In this instance, facilities will be
required to undertake some level of soil and groundwater investigation and risk
assessment and when contamination is detected, there will be site remediation
requirements. The purpose of remediation is to restore the soil and groundwater to a
state that does not pose a risk to the environment. This process will include a suitable
contaminated land risk assessment, which will provide recommendations and a
programme of measures. The general process for the development of a site restoration
and/or remediation proposal typically involves the following steps:
Audit of the site to identify potential sources of contamination and likelihood
of occurrence;
Soil and groundwater investigation;
Qualitative contaminated land risk assessment and conceptual site model;
Quantitative contaminated land risk assessment;
Proposals for the restoration of the site through remediation;
Agreement of the proposal with the EPA.
This scenario is not currently anticipated, however, should the need arise as a result
of some future contamination event the RMP will be revised accordingly as part of its
annual update for the AER.
5.0 Step 3: Environmental Liability Risk Assessment (ELRA) -
Unknown Liabilities
5.1 Risk Identification
The ELRA covers environmental risks leading to a potential or anticipated liability.
Environmental risks cover all risks to surface water, groundwater, atmosphere, land
and human health. There are three main areas that need to be looked at for risk
identification. These include the following:
The identification of potential environmental receptors;
The identification of processes that may be potential hazards to the
environmental receptors and the likely pathways from the source of the
hazard to the environmental receptor;
The identification of the risks related to these processes.
5.1.1 Scope of ELRA
The ELRA should cover environmental risks leading to a potential or anticipated
liability. Environmental risks are deemed to cover all risks to: surface water,
groundwater, atmosphere, land and human health.
5.1.2 Environmental Receptor Identification
Environmental receptors are those environmental media around the site that may be
affected by the ongoing processes at the facility or the failure thereof. The following
receptors were identified:
Human Beings – The site is situated 2 kilometres from the centre of Cork
city with 275,000 inhabitants. The nearest residence is just over 50 metres
from the station boundary;
Soil & Groundwater – there is no direct discharge to groundwater or soil and
activities are principally carried out on hardstand areas. The groundwater
quality is not of sufficient quality to provide an abstractable resource for
consumption;
Surface water – all surface water runoff and effluent ultimately discharges
into the River Lee and from there to Whitegate Bay and Cork Harbour;
Air Quality – air quality monitoring at Montenotte has identified no
significant degradation of air quality as a result of the station’s activities;
Flora and Fauna – principally fisheries in the River Lee and Cork Harbour
with its wader and waterfowl populations.
5.1.3 Identification of Processes
A number of processes are carried out during the operation of the plant, which may
affect the environment. These have been identified and listed below:
Instrumentation and Control Room;
Water Treatment and Cleaning Processes;
Power Generation;
Laboratory;
Chemical and Oil Delivery and Storage;
Waste Storage and Disposal.
All these processes are outlined in detail in section 2.2.
5.1.4 Identification of Risks
Where relevant, hazards are identified in relation to each of the processes outlined in
section 3.2.3 and all possible causes of failure of the process are identified and the
subsequent effects on each environmental receptor considered.
In relation to the risk of fire and explosion the site is designed and operated in
accordance with site-specific Alstom Fire Protection Concepts (GT and Overall Plant
Doc. Codes AGH/00/G/MB15-55321/DO/001 & AGH/00/M/09-004/DO/001) and
Explosion Protection Concepts (GT & CCGT Doc. Codes. AGH/00/G/MB15-
55321/DO/002 & AGH/00/M/09-004/DO/002). Fire protection measures are designed
to fulfil the following requirements:
Inhibiting the outbreak and spread of fire,
Protection of operating personnel,
Early fire detection, warning, and suppression and/or extinguishment, and
Minimising damage resulting from a fire.
Fire risk potential on site has been classified into three areas: category 1 (high),
category 2 (medium) and category 3 (low).
Explosion protection concepts are similar to those for fire protection aiming to:
Inhibit the possibility of an explosion or fire due to gas leakage;
Protect operating personnel;
Detect gas leakage to mitigate the hazard; and
Initiate procedures for a safe plant shut down.
There is no feasible technical method of containment or remediation of releases to the
atmosphere once a fire is burning out of control but many measures can be used to
prevent a fire starting and to prevent a fire from getting out of control. To this end,
comprehensive fire prevention systems are in place at Marina based on the local
applicable codes and standards and Alstom standard plant design, procedures and
safety instructions to prevent and control the occurrence of fires at any location on the
site (see Section 3.2.4). These include both passive and active fire control measures.
Passive measures incorporate fire zoning, segregation and optimal equipment layout
including:
Strategic plant and optimum equipment layout;
Fire zoning segregation and passive fire barriers;
Selection of suitable non-combustible and fire-resistant materials;
Adequate travel distances and fire escape ways;
Emergency escape way lighting;
Bunding of fuel and chemical storage tanks;
Protection of ignition sources;
Containment of fire water run-off.
Where passive measures alone are insufficient, active fire control measures are
provided which incorporate adequate warning and fire-fighting systems including:
Fire and smoke detection systems;
Continuous gas monitoring systems;
Automatic combustible gas warning & alarm system;
Venting of air/gas accumulations;
Automatic/manually operated deluge systems for high risk areas;
Water spray and sprinkler systems;
Ring main hydrant system (with backup electric and diesel pumps);
Fire-fighting pump station;
In-house procedures specific to potential hazards;
Routine self-audits;
Provision of fire-fighting equipment, PPE and staff training;
Fire fighting procedures specific to identified fire emergency scenarios
(updated in 2010).
A comprehensive firewater retention study and risk assessment was carried out for the
station. This assessed the likelihood of uncontrolled fire at each of the six different
locations around the site where oil volumes of 10m3 or more are stored. Each of these
are bunded (except the turbine oil tank due to physical constraints). For each of the oil
and flammable chemical storage areas, an uncontrolled fire was considered (an
uncontrolled fire is defined as a fire which is not extinguished at an early stage, and in
effect destroys its object and generates large volumes of firewater because of its
duration).
For each uncontrolled fire, its likely duration was estimated. This duration, coupled
with the fire-fighting system capacity available, was used to derive a likely volume of
firewater generated. The probability of an uncontrolled fire event was calculated using
a decision tree analysis method. The decision trees for each fire event considered the
following probabilities:
• Electrical fault occurring (transformers);
• Electrical protection system failure (transformers);
• Initial fire occurring;
• 24-hour staff being unable to extinguish fire immediately;
• Fixed deluge system (Water or CO2) failing to detect and extinguish
(Turbines);
• Fire brigade fails to extinguish fire quickly.
Probabilities were estimated using the following:
• Industry experience to date with fire incidents ;
• Staff awareness of fire prevention, control and environmental impact is high
and is constantly improving through the operation of the ISO 14001 certified
EMS;
• The station is equipped with automatic fire detection systems and is manned
24 hourly with staff trained in fire fighting skills;
• Response time of fire brigade is 3 minutes;
• The station is equipped with effective fixed deluge systems for high risk
areas, a hydrant system covering the entire site and ample mobile fire
fighting equipment.
The study concluded that nine significant fire risks were present with a potential, once
every 410 years, to generate up to 3200 m3 of firewater containing up to 6m3 of oil
(since the study was first carried out three of these fire risks have been removed from
the site leaving six in total). The firewater would also be contaminated with foam
concentrate, which is a Nicerol protein foam which is biodegradable and free of
detergents and glycol ether.
Most of the firewater would overflow bunds and make its way to the drainage system
with some oil removal in the interceptors. By closing the interceptor discharge
isolating valve, a significant amount would be likely to back up through the drainage
system and overflow onto the site and from there percolate into the soil and
groundwater. For the worst case scenario, only a relatively small amount of 6 m3 of oil
would be likely to escape to the marine or soil and groundwater environment. With an
oil spill of this size effective remediation measures are possible in the case of soil and
groundwater and effective activation of emergency oil spill response plans would
further minimise the spread and impact of oil in the marine environment. In addition,
the groundwater has no value as drinking water as it is contaminated by nitrogen
compounds and in some places by saline compounds, hydrocarbons and other
compounds originating from sources beyond the site.
Given the low risk of an uncontrolled fire, the likely amounts of oil released to the
environment and the remediation and limitation measures possible in the environment
during and after the event, it was concluded that a Fire Water Retention facility was
not required for the station.
5.1.4.1 Fire/Explosion Resulting in Emissions to Air
Accidental emissions to air could arise in the event of fires or explosions occurring at
the plant. The principal environmental hazard associated with a fire or explosion is the
potential for gaseous releases of toxic or pollutant matter to atmosphere with such
releases temporarily reducing local air quality and impacting on the atmosphere.
Some materials may emit hazardous decomposition products during a fire in addition
to the dangers of smoke raising additional questions of health and safety but in the
case of the station, as there are no significant volumes of flammable chemicals on site
a toxic plume is not considered likely.
5.1.4.2 Fire/Explosion Resulting in Emissions to Water
As described in section 5.1.4 a fire risk assessment was carried out which identified a
one in 410 year risk of 6 m3 of oil reaching the soil or groundwater making the
provision of a firewater retention facility unnecessary and the likelihood of any
serious environmental impact remote.
5.1.4.3 Distillate Leak from Pipeline
Oil is piped to the combustion from the NORA storage site which has the potential to
leak to ground and then to groundwater. Detection is more difficult with underground
pipes. This must be inspected at least every three years for leaks and boreholes are
monitored (Schedule C of IPC Licence).
5.1.4.4 Natural Gas Leak
Should gas escape from a tank, pipeline, cylinder, etc. a flammable vapour cloud will
form, ignition of which could result in a flash fire or a vapour cloud explosion (VCE)
depending on the amount of vapour in the flammable region and the turbulence within
the cloud. Where flammable gas/liquid is released under pressure, a jet flame may
occur in the event of immediate ignition. Delayed ignition of a gas release may also
burn back to the release point causing a jet flame. Consequently, the principal risks
linked to natural gas arise either where:
It is accidentally released and allowed to accumulate within its explosive
limits in a confined space, building or inverted space;
Air is allowed to enter and mix with the gas in spaces that normally contain natural gas.
Potentially hazardous incidents which could occur include:
Leaks from/ruptures of pipelines inside/outside buildings;
Leaks within the gas compressor system;
Leaks within the combustion chambers;
Rupture of natural gas lines;
Failure of the combustion flame on start-up causing gas build-up;
Failure of valves to isolate gas from air-filled spaces through direct failure or
failure of control systems;
Failure of inerting system whereby an inerting gas is used to purge the system
of gas before replacement with air or vice versa;
Failure of gas detection systems and/or emergency ventilation systems or
procedures.
The risk minimization/prevention and safety measures in place include:
Combustion of natural gas (and distillate) is carefully managed, employing a
sophisticated automated control system that ensures the fuel is burned
efficiently, safely and in controlled conditions (according to procedures GDS
9/6 and GDG 22/22 Safe Firing and Safe Handling of Natural Gas);
Routing the natural gas line underground as much as possible;
All underground gas pipes are long term technically sealed, i.e. fully
welded with full hydraulic testing;
Where gas pipes emerge from underground they are in trenches;
There is impact protection for the gas pipeline at all locations;
The gas supply is filtered to remove dust and debris to avoid damage to
pipework and associated control and safety equipment;
Provision of continuous gas monitoring systems;
Proprietary slam shut type valves are in place operating automatically in
response to pressure loss;
Venting of gas/air accumulations;
Nitrogen purging of gas lines and testing with detection equipment for pipeline
maintenance;
Protection of ignition sources from physical damage;
Designation and demarcation of zones with potentially explosive atmospheres;
Manual push-button on fire alarm panel at security can shut-off supply;
All excavation on site is controlled by the permit-to-work system;
Forbidding welding in the area of gas pipework;
Inspection and maintenance program in place.
5.1.4.5 Hydrogen Leak
Hydrogen-derived hazards include:
Escape of hydrogen resulting in accumulation of explosive air/gas mixture;
Escape of hydrogen that has ignited.
Measures taken to eliminate fire risk involves ensuring generator housing remains
filled with pure hydrogen. To this end the building is equipped with suitable vents to
permit the escape of any vented gases while a sophisticated fail safe control system
ensures the hydrogen purity is maintained in a safe range. When maintenance is
carried out the hydrogen is purged with carbon dioxide and vented safely to the
atmosphere. Hydrogen losses are determined by means of regular hydrogen leakage
wipe tests. Continuous monitoring equipment has been provided to enable rapid
detection of leaks and suitable fire fighting equipment is provided.
GDG 18/2 Safe Use of Hydrogen controls operational aspects while other control
measures include the following:
The hydrogen cylinders are kept in protective MCP frames at all times when
on site;
The hydrogen cylinders and hoses are replaced on a regular basis and undergo
regular inspection and maintenance;
Operators are trained in the handling of hydrogen;
The hydrogen storage areas are caged;
SOPs covering the handling of hydrogen are in place;
The hydrogen storage areas are zoned appropriately;
The hoses and pipe work are regularly inspected.
5.1.4.6 Mechanical Failure
The major risk of mechanical failure is of turbine runaway and disintegration.
Internationally approved standards on the monitoring and testing of the overspeed
protection system are rigorously applied. Mechanical failure may also occur as a
result of fatigue, excessive vibration and external interference that can cause
mechanical damage or oil leaks resulting in fire. The plant element most at risk is the
turbine unit. A regular programme of preventive maintenance and in-service
inspection along with continuous vibration monitoring of the turbines is in place. This
ensures the early detection of any mechanical faults and so limits the risk of any such
event occurring.
5.1.4.7 Transformer/Oil Spill
Two House Transformers (HOT 2 and HOT 7) identified as surplus to requirements
were drained of oil in 2008 as was the main lube oil tank of the steam turbine in 2009
(16 m3) as risk reduction opportunities to lower the amount of oil stored on site. After
testing to prove the absence of PCBs in the oil, the oil was drained from these
transformers and recycled. Spills of oils and chemicals constitute the most frequent
environmental incidents at Marina over the past few years i.e. oil leak from a cooler in
2008 and a leak from a the gas turbine steel engine compartment in 2009. However,
none of these or indeed any previous incidents events have yet caused any significant
environmental damage.
The largest quantity of oil which could leak from the main transformer is 25.0 m3. The
worst-case scenario is the whole amount being released to its bund and bund failure
occurring. In such an event, the oil would go straight to the relevant bund or contained
area making the principal risk that of bund failure or runoff out of a building. All
transformers and other oil storage locations are bunded and bunds integrity tested
every three years and regularly inspected (some bund repairs were carried out in 2009
on the foot of test findings). Also the transformer oil filled cables are alarmed to
detect any loss of oil pressure that is indicative of an oil leak and this alarm is checked
monthly. Bunds are checked weekly according to EPA IPC Guidance Note on
“Storage and Transfer of Materials for Scheduled Activities”. The sources of potential
spillage are:
Lube/control/seal oil system for the combustion turbine;
Insulating oil systems for large transformers (traffos) and their associated
bunds T101, T102, T107;
Smaller main unit, house and network transformers and oil-filled cables.
For associated quantities of oil see Appendix 1. Other protection measures include the
provision of alarmed three-compartment oil traps on the surface water drainage
system serving impermeable bunds, provision of locked isolation valves to the fuel
tanks and the provision of a locked distillate oil farm and a locked discharge valve.
Fuel oil tanks and associated pipework are inspected at regular intervals as part of the
PM schedule and fire protection measures are provided.
Oil spill response training is also provided to staff and there are three Emergency Oil
Spill Bins, one adjacent to Gas Turbine Fuel Skids, one adjacent to the waste store
and one in ‘A’ Station Basement between G1 and G2. Also services provided by
Marina’s Waste Contractor include oil clean-up, retrieval, recycling and disposal
employing plant such as vacuum tankers, absorbent materials, and high-pressure
jetting equipment.
For lubricating oils, best international practice has been used to design and select the
most relevant storage and usage areas and protection and fire containment systems.
High-pressure fire fighting systems have been provided and the lubricating oil is
stored in highly ventilated areas.
Waste oils are stored in a plastic bunded oil tank located in a secure storage shed at
the southern end of the main station building. Some other oils are also stored at this
location.
5.1.4.8 Leak from Drains
A leak in the drainage system could result in a variety of substances going to ground
and/or groundwater including sewage effluent, oils, gas oil, chemicals and untreated
effluent. Controls in place include EMS 9.1-04 (Procedure for the Maintenance of
Drains, Sewers and Aqueous Effluent Pipelines) and biannual borehole monitoring to
detect contamination.
5.3 Risk Assessment
The hazards associated with the various processes are tabulated below in a Risk
Assessment Form. Risk classification tables were used to determine risk ratings based
on the chance of occurrence and the severity of each risk. These ratings were
multiplied together to obtain risk scores. A risk register and risk matrix was then
devised to list the critical risks to be assessed during the study. These are dealt with
in sections 3.4 and 3.5.
Table 3.2 Risk Classification Table – Occurrence.
Rating
Occurrence
Category Description Likelihood of
Occurrence (%)
1 Very
Low
Very low chance (0-5%) of hazard occurring in
30yr period
0-5
2 Low Low chance (5-10%) of hazard occurring in 30 yr
period
5-10
3 Medium Medium chance (10-20%) of hazard occurring in
30 yr period
10-20
4 High High chance (20-50%) of hazard occurring in 30
yr period
20-50
5 Very
High
Very high chance (>50%) of hazard occurring in
30 yr period
>50
Table 3.3. Risk Classification Table – Severity.
Rating
Severity
Category Description Cost of
Remediation (€)
1 Trivial No damage or negligible change to environment <€100
2 Minor Minor impact/localised or nuisance €100-€1,000
3 Moderate Moderate damage to environment €1,000-€10,000
4 Major Severe damage to local environment €10,000-€100,000
5 Massive Massive damage to a large area, irreversible in
medium term
€100,000-
€1Million
Table 3.4. Risk Assessment Form.
Risk
ID
Process Potential Hazards Environmental
Effect
Occurrence
Rating
Basis of Occurrence Severity
Rating
Basis of Severity Risk
Score
1 All processes
covered by 6
critical fire risks
Fire/explosion
resulting from
significant fire risks
Emissions to air 1 Failure of all passive
and active fire control
measures. Once every
410 year event.
5 No method of containing
emissions to air so no
costs involved in clean
up. Mitigated by
atmospheric dilution.
5
2 All processes
covered by 6
critical fire risks
Fire/explosion
resulting from
significant fire risks
Firewater emissions to
soil, groundwater and
River Lee
1 Failure of all passive
and active fire control
measures. Once every
410 year event.
5 Contaminated firewater
& oil entering river
ecosystem (containing 6
m3). Cost of cleaning
soil & river bed.
5
3 Fuel Delivery &
Storage
Distillate leak from
pipeline
Emissions to soil and
groundwater
2 Failure of pipeline
inspections
4 Cost of soil/groundwater
remediation
8
4 Power
Generation
Natural gas leak
resulting in
fire/explosion
Emissions to air 1 Failure of all passive
and active fire control
measures
5 No method of containing
emissions to air so no
costs involved in clean
up. Mitigated by
atmospheric dilution.
5
Risk
ID
Process Potential Hazards Environmental
Effect
Occurrence
Rating
Basis of Occurrence Severity
Rating
Basis of Severity Risk
Score
5 Power
Generation
Leak from hydrogen
in generator housing
resulting in
fire/explosion
Emissions to air 1 Failure of all passive
and active fire control
measures
5 No method of containing
emissions to air so no
costs involved in clean
up. Mitigated by
atmospheric dilution.
5
6 Power
Generation
Mechanical failure
(turbine units, fans)
Emissions to
atmosphere and waters
1 Failure of
sophisticated control
mechanisms and PM
4 Remediation of
contaminated soil,
groundwater, riverbed.
4
7 Oil Storage Leak from
transformers/ oil
storage locations due
to bund failure
Emissions to
soil/groundwater
2 Failure of bund
checks, integrity
testing, oil
interceptors and Oil
Spill Response Plan.
4 Quantity of oil in largest
transformer 25 m3. Cost
of soil excavation and/or
GW remediation
8
8 Oil Delivery &
Storage
Leak from drains Emission to
soil/groundwater
2 Failure of pipe
inspection procedures
but difficult to detect
4 Possible undetected leak
of sewage effluent, oil or
chemicals & cost of
8
soil/groundwater
remediation
3.4 Risk Register
Table 3.5. Risk Register.
8 Leak from drainage system resulting in emission to soil/groundwater 2 4 8
1 Fire/explosion resulting in emission to air 1 5 5
2 Fire/explosion resulting in firewater release to River Lee 1 5 5
4 Gas leak resulting in fire/explosion and emissions to air 1 5 5
5 Hydrogen leak resulting in fire/explosion and emissions to air 1 5 5
Risk ID Description Occurrence Rating Severity Rating Risk Score
3 Distillate leak from pipeline to soil and groundwater 2 4 8
6 Mechanical failure of turbine equipment resulting in emissions to soil, groundwater
and surface waters
1 4 4
7 Transformer / oil spill to soil and groundwater due to bund failure 1 4 4
3.5 Risk Matrix
A risk matrix has been developed to display the risks visually with colour coding to
give an indication of the critical nature of each risk (Table 3.6).
Table 3.6. Risk Matrix.
OC
CU
RR
EN
CE
O
V High 5
High 4
Medium 3
Low 2Risk I.D.
3, 8
V. Low 1Risk I.D.
6, 7Risk I.D. 1, 2, 4, 5
Trivial Minor Moderate Major Massive
1 2 3 4 5
SEVERITY
None of the risks fall into the red zone, which would require priority attention, or the
amber zone, which requires mitigation or management action. The green zones in
which the risks are located (two in dark green and seven in light green) are the lowest
level risks and indicate a need for continuing awareness and monitoring on a regular
basis. Whilst they are currently low or minor risks, some (i.e. those in the dark green
zone) have the potential to increase to medium or even high-level risks and so must be
regularly monitored. In these cases, where cost-effective mitigation measures can be
carried out to reduce the risk even further this course of action should be pursued.
3.6 Risk Management Programme
Risk mitigation measures that were identified in the course of the risk assessment are
noted in the following Risk Mitigation Form. Risk scores are also revised and re-
ranked using this Form (see Table 3.9).
Table 3.7. Risk Mitigation Form.
Risk
ID
Process Potential Hazards Risk Score
Before
Mitigation
Possible Mitigation
Measures
Risk
Manager
Timeframes Revised
Occurrence
Rating
Revised
Severity
Rating
Risk
Score
1 All processes
covered by 6
critical fire
risks
Fire/explosion resulting
in emissions to air
5 Ensure continued
implementation of EHS
management system,
adherence to IPPC
licence conditions,
CMMS, checks,
monitoring etc.
(summarised in 5.1.4)
Station
Manager
N/A N/A N/A 5
2 All processes
covered by 6
critical fire
risks
Fire/explosion resulting
from significant fire
risks
5 As per above Station
Manager
N/A 1 4 5
3 Fuel Delivery
& Storage
Distillate leak from
pipeline
8 As per above Station
Manager
On-going N/A N/A 8
4 Power
Generation
Natural gas leak
resulting in
fire/explosion
5 As per above Station
Manager
On-going N/A N/A 5
Risk
ID
Process Potential Hazards Risk Score
Before
Mitigation
Possible Mitigation
Measures
Risk
Manager
Timeframes Revised
Occurrence
Rating
Revised
Severity
Rating
Risk
Score
5 Power
Generation
Leak from hydrogen in
generator housing
resulting in
fire/explosion
5 As per above Station
Manager
On-going N/A N/A 5
6 Power
Generation
Mechanical failure
(turbine units, fans)
4 As per above Station
Manager
On-going N/A N/A 4
7 Oil Storage Leak from transformers
etc. due to bund failure
4 As per above Station
Manager
On-going N/A N/A 4
8 Chemical/Oil
Delivery &
Storage
Leak from drains 8 As per above Station
Manager
On-going N/A N/A 8
This form can be used as a Risk Management Programme, which provides a mechanism for continuous and ongoing environmental risk
management and mitigation in order to reduce the unknown environmental risk at the plant.
6.0 QUANTIFICATION OF UNKNOWN ENVIRONMENTAL
LIABILITIES
6.1 Financial Model
A financial model is required to estimate the environmental liability associated with
the risks identified. Known risks and the associated costs are calculated in the
Residuals Management Plan. The model is defined in terms of the worst, most likely
or best case scenarios. In this case the most likely scenario is taken which selects the
median value of each range used. The median probability and severity are then
multiplied together to determine the most likely cost. Table 6.1 illustrates this.
Table 4.1. Most Likely Scenario Financial Model (EPA, 2006).
Risk Occurrence
Rating
Likelihood of
Occurrence Range
Severity
Rating
Cost
Range (€)
Median
Probability
Median
Severity (€)
Most Likely
Scenario Cost (€)
1 1 0-5% 5 100,000-1M 2.5% 550,000 13,7500
2 1 0-5% 5 100,000-1M 2.5% 550,000 13,7500
3 2 5-10% 4 10,000-100,000 7.5% 55,000 4,125
4 1 0-5% 5 100,000-1M 2.5% 550,000 13,7500
5 1 0-5% 5 100,000-1M 2.5% 550,000 13,7500
6 1 0-5% 4 10,000-100,000 2.5% 55,500 1,375
7 1 0-5% 4 10,000-100,000 2.5% 55,500 1,375
8 2 5-10% 4 10,000-100,000 7.5% 55,000 4,125
Total €66,000
7.0 ENVIRONMENTAL LIABILITY REVIEW
It is recommended that a review of the Environmental Liability Risk Assessment should be carried out
on an annual or biennial basis to capture any changes that occur on-site which may result in
environmental impacts. In particular, the ELRA should be revised should any parts of the site be
decommissioned and/or new plant added. The following steps should be followed as part of this
review:
Update the risk register by adding new risks or omitting redundant risks;
Verify the implementation of the Risk Management Programme;
Ensure that the financial provision continues to satisfactorily cover the facility’s environmental
liabilities;
Verify that the financial instruments continue to provide the required financial provision.
8.0 Costing & Financing
The figure of €2,443,125 calculated in Table 4.1 in Section 4.0 above represents the present value of
the current estimate of the costs for part-closure of Marina at the end of its useful economic life. These
address the known financial liabilities associated with the site.
The figure of €66,000 given in Table 6.1 of Section 6.0 represents the present estimated value of the
unknown financial liabilities associated with the site.
ESB has adequate resources of finance and manpower to implement the RMP through to completion
and will make specific financial provision for closure of the site.
APPENDIX 1. CHEMICAL & BOTTLED GAS QUANTITIES AT MARINA
Chemical Quantity Use
Silica gel 75 kg Transformer oil moisture removal
Carbon dioxide 24 bottles Hydrogen system purge gas
Carbon dioxide 6 t Gas turbine fire fighting system
Lubrication oils 2.5 t Lubrication
Foam concentrate 3.4 t Fire fighting
Antifreeze 4 x 205 litres
Coolant
Hydrogen gas 75 bottles Generator cooling
Nitrogen gas 45 bottles Purging of natural gas lines
Sulphur hexa-fluoride
(SF6)
23 kg Circuit breaker insulation
APPENDIX 2. OIL QUANTITIES IN MARINA
Lube Oil Tanks & Main Transformers (10.5kV/220kV)
CT Lube Oil Tank
17 m3
T101 (bunded)
23.7 m3
T102 (bunded)
23.7 m3
T107 (bunded)
25.0 m3
Main Unit Transformers 10kV/3.5kV/380V
UT1 (bunded)
4.27 m3
UT2 (bunded)
4.27 m3
UT4 (bunded)
4.27 m3
House Transformers 3.3kV/380V
HOT1 (bunded)
0.87 m3
HOT4 (bunded)
1.1 m3
HOT5 (bunded)
0.87 m3
HOT6 (bunded)
0.87 m3
HOT8 (bunded)
0.87 m3
HOT9 (bunded)
0.75 m3
Network Transformers 110kV/38kV
T105 (bunded)
21.1 m3
T106 (bunded)
21.1 m3
ST11 (bunded)
4.27 m3
ST12 (bunded)
4.27 m3
Oil Filled Cables (110kV)
Reference Capacity
Cable Tank Sealing Ends
Trabeg 1, length 150 m located on-site
393 l 600 l 54 l
Trabeg 2, length 150 m located on-site
650 l 180 l 105 l
Kilbarry 1, length 221 m 500 l 150 l 90 l
Kilbarry 2, length 215 m 486 l 150 l 90 l
T107, length 40 m 90 l 150 l 90 l
Lube Oils
1. Perfecto T32:
` 8 x 208 litres
2. Perfecto HT5
2 x 20 litres
3. Alpha SP 460
1 x 25 litres
4. CT Castrol 778
8 x 208 litres
5. Shell traffo oil
1 x 208 litres
6. Fyre wash F2
3 x 208 litres
7. Deusol 140
2 x 208 litres
8. Gilo Therm 140 (CO2)
1 x 208 litres
APPENDIX 3. LARGE PLANT COMPONENTS & EQUIPMENT LIST
Large Plant Components
CT:
Air Intake System
Compressor
Combustion System
Turbine
Couplings and Bolts
Exhaust
Bearings
Auxilaries (inc. pumps & valves)
Fuel System
Electrical and C&I
Generator
MV Equipment
LV Equipment
Transformers
Batteries/Chargers
Hydrogen System
Miscelaneous
Control & Instrumentation
Balance of Plant
Heating & Ventilation
Fire Protections System
Comperssed Air System
Emissions Monitoring System
A Station:
Boiler BOP
Deaerators (4)
HP Module
IP Module
IP Casings and Diaphragms
IP Rotor and Moving Blades
IP casing Studs
Crossover Pipes
LP Module
Bearings
Couplings and Coupling Bolts
Barring Gear
Lube and Safety Oil System
Jacking Oil System
Seal Oil System
Bleed Valves
Feedwater Heaters
Condenser (6) – all decommissioned
Gland Steam System
Air Ejectors
Generator (3) - all decommissioned
Electrical
MV Equiment
LV Equiment
Transformers
Batteries/Chargers
C&I System
Balance of Plant
CW Systems
Auxiliaries
Fuel System
Chemical Treatment
Large Equipment
Boiler 4 (decommissioned)
Sewage holding tank
WTP - pumps, sand filter vessel (empty), instrumentation , valves, PLC control, neutralisation sump
and associated instrumentation
Safety showers & eye baths- 10 approx
HCL bund and bunded acid tank (empty)
4 interceptors
Boiler feed pumps (3)
Raw water storage tank (3)
Cooling water pipeline- inlet and outlet
Lube oil tanks G1 (empty)
Lube oil tank CTs
Auxiliary Cooling Water System
Bulk chemicals tanks (empty)
Gas bottle storage
Transformers and cables as per EMS 10.2
3 Waste laydown areas
PEMS CT
1 air compressor
Appendix 8: Site Map
Appendix 9: Confirmation of Financial Capability.