BORD NA MÓNA plc

EDENDERRY POWER LIMITED BALLYKILLEEN, CO. OFFALY

PEAKING POWER PLANT

ENVIRONMENTAL IMPACT STATEMENT

For inspection purposes only. Consent of copyright owner required for any other use. November 2007

Report P04E0715A – R1

Stephen Court, 18/21 St. Stephen's Green, 2, Ireland. Telephone: +353-1-7038000 Fax: +353-1-6616600

EPA Export 26-07-2013:00:59:35 Edenderry Power Limited Environmental Impact Statement

Peaking Power Plant Report P04E0715A – R1

Table of Contents

NON-TECHNICAL SUMMARY...... 1

1. INTRODUCTION ...... 7

2. DESCRIPTION OF PROJECT...... 11

3. ALTERNATIVES ...... 19

4. HUMAN BEINGS...... 23

5. AIR EMISSIONS...... 25

6. CLIMATE / TRANSBOUNDARY AIR POLLUTION ...... 20

7. SOILS & GROUNDWATER...... 23

8. LANDSCAPE...... 24

9. ECOLOGY...... 36

10. WATER...... 37

11. NOISE...... 40

For inspection purposes only. 12. TRAFFIC...... Consent of copyright owner required for any other use. 43

13. MATERIAL ASSETS ...... 46

14. CULTURAL HERITAGE...... 48

15. INTERACTION OF IMPACTS ...... 49

APPENDIX A: AIR EMISSIONS MODELLING REPORT

APPENDIX B: NOISE MODELLING REPORT

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NON-TECHNICAL SUMMARY

INTRODUCTION

Bord na Móna plc intends to increase the electricity generation capacity of its Edenderry Power Limited (EPL) power station at Ballykilleen, Clonbullogue, Co. Offaly. This will comprise the installation of a stand-alone gasoil (diesel) fired Peaking Power Plant with a rating of up to approximately 104 MW. Electricity generated will be exported to the national grid from the site via the existing ESB substation at the EPL plant. This will have adequate capacity to take the additional power output without the need for new overhead lines or buried cables. Plant of this type is already installed at ESB’s Peaking Power Plant at Rhode, Co. Offaly. The Peaking Power Plant will not impact on use of other fuels. Bord na Móna is committed to retaining the current electricity generation capacity at the site. An Environmental Impact Assessment has been undertaken to examine the likely significant impacts of the project on the environment. The results are presented in this Environmental Impact Statement (EIS), which supports a planning application to . The conclusions of the EIS are contained in this Non-Technical Summary. Environmental aspects of existing operations at Edenderry Power Plant are regulated by the Environmental Protection Agency (EPA) in accordance with Integrated Pollution Prevention and Control Licence (IPPC Licence) Register Number P0482-02 issued in January 2006. This project will require that the IPPC Licence be reviewed by the EPA. Bord na Móna acquired full ownership of Edenderry Power Limited in 2006.

For inspection purposes only. THE PROJECT Consent of copyright owner required for any other use.

Proposed Plant

The area in which the peaking plant will be located is fully within the boundaries of the existing power station. The plot lies between the existing Intermediate Peat Storage building and the embankment that provides visual separation of the existing facilities from the Clonbullogue – Edenderry R401 . The plant will be a stand-alone gasoil (diesel) fired peaking plant designed to operate during short periods of peak demand in the national electricity system. The fundamental characteristics required of such plant are that it should be capable of starting quickly when required. It is currently envisaged that the plant will comprise two Pratt & Whitney TwinPac generating units, although similar plant by other manufacturers may be offered in the course of open tendering. The power plant will typically be of modular design for ease of transport and rapid installation. Minimal construction activities are required. The power units are compact in design with the maximum height of most of the assembly not exceeding 5 m. The air

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intake components are expected to be up to 10m high and stacks through which exhaust gases will be emitted will be up to 20 m high. Concrete foundations are required to take the plant loads and a hard-standing working area will be provided in the vicinity of the plant. The proposal does not involve alteration in existing ground levels.

Method of Operation

Gas turbine technology is widely applied and is used in such diverse applications as modern jet engines and electrical genertaors. A gas turbine extracts energy from a flow of hot gas produced by combustion of fuel in a stream of compressed air. It has an upstream air compressor mechanically coupled to a downstream turbine and a combustion chamber in between. Energy is released when compressed air is mixed with fuel and is ignited in the combustor. The resulting gases are directed over the turbine's blades, spinning the turbine and mechanically powering the compressor. Finally, the gases are passed through a nozzle generating additional thrust by accelerating the hot exhaust gases by expansion back to atmospheric pressure. The rotating turbine is coupled to an electrical generator, which produces electricity as it spins. Gasoil (diesel) that has a statutory maximum sulphur content of 0.1% will be used as fuel and consumption for each of the two units will be approximately 12.5 t/hour of gasoil when in operation. On-site storage will be provided.

Water injection will be used for abatement of emissions of nitrogen oxides (NOx). This involves the injection of water into the combustion chamber. This reduces the combustion temperature and so reduces the formation of thermally-produced NOx. The rate of water injection will be almost equivalent to that of fuel, i.e. 12.5 t/hour for each unit, and an adequate back-up supply will be provided through additional on-site storage. For inspection purposes only. The basic technology toConsent be employedof copyright owner in therequired project for any otheris well use. understood and has been used

successfully in many equivalent projects both nationally and internationally. The Peaking Power Plant will not significantly add to the main potential hazards arising at the power station. There are no implications for health and safety. While the plant will not be required to operate every day, it is envisaged that, when called upon, it will typically operate for between 5 hours and 10 hours per day. Plant operation is expected to be for about 1,000 hours per year but up 1,500 hours of operation could arise.

Alternatives

The plant will be a peaking plant designed to operate during short periods of peak demand in the national electricity system. Plant of this type provides a necessary service on the system that cannot be provided by other types of plant. In the short - medium term at least, current and future demand for electricity generation capacity in Ireland will remain predominantly supplied by fossil fuel plants. However, renewable and alternative sources of power will play an increasingly important role in meeting power needs in the future.

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Government policy in support of renewable energy sources, and electricity generation from wind in particular, requires that back-up electricity generation capacity must be available at short notice during periods when the wind resource is low. Peaking plant characteristics are ideally suited to meet this requirement and provide a good fit in terms of reliable and flexible operation. The expected increase in installed wind generation capacity, in line with Government targets and EU objectives, will further increase the need for peaking plant with these characteristics in the future. The Peaking Power Plant will provide a natural back-up for wind generation. It will not inhibit the growth of alternative energy supplies but rather will facilitate it.

IMPACT OF THE DEVELOPMENT

The possible impacts of the development were examined. This was done by assessing the environment in terms of the existing conditions, the impact of the proposed development and the measures taken to mitigate impacts where arising.

Human Beings The presence of the existing EPL power station has coincided with growth in population in Edenderry and Clonbullogue that has surpassed that occurring elsewhere in Co. Offaly The additional generation at EPL will not impact negatively on population numbers. The proposal will lead to employment during the construction stage and the project investment will impact positively as regards the local economy. In the longer term there will be an ongoing requirement for maintenance support, services and equipment. The payment of local authority rates will provide indirect long-term benefit for the broader community It is envisaged that future employment at EPL Power Plant will remain similar to current levels and operation of the additional plant will be fully integrated with existing operations. The proposed development Forwill inspection enhance purposes the only. viability of EPL operations as a whole by Consent of copyright owner required for any other use. increasing and broadening its role in the Irish electricity sector. This will significantly strengthen the ability of EPL to remain competitive in the long term.

Air Emissions The emissions to the atmosphere from the Peaking Power Plant that are of possible concern are nitrogen oxides (NOx), sulphur dioxide (SO2), carbon monoxide (CO), particulate matter and carbon dioxide (CO2).

The plant will utilise state-of-the-art low-NOx technology and achieve the emission limit values (ELVs) determined by the EU Commission as representing Best Available Technology (BAT) in the EU Large Combustion Plant Directive (2001/80/EC).

The assessment of air quality impacts focused on NOx and SO2. Because the proposed development will be of the most advanced of its kind available, very low levels of CO and particulate matter will be emitted. In addition, CO2 emissions do not affect ambient air quality. An air dispersion study of the emissions from the Peaking Power Plant was carried out, taking into account the previously permitted emissions at the existing EPL power station.

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A set of seven sensitive receptors in the area surrounding the plant were identified. The predicted contributions to ground level concentrations of SO2 and NOx due to emissions from the Peaking Power Plant in combination with the existing EPL power station are low and show that the plant will not have a significant adverse effect on air quality outside of the site with concentrations well below the relevant national air quality standards. The modelling indicated elevated concentrations in the immediate vicinity of the plant, within the site boundary.

Climate and Transboundary Air Pollution The proposal will utilise high efficiency state-of-the-art technology and participate in the EU emissions trading scheme. Emissions arising from the proposed plant will not be significant in the context of global climate. The plant will not give rise to significant transboundary environmental impact. It will assist in the achievement of national obligations regarding limiting transboundary air pollution and sectoral targets.

Soils and Groundwater The development does not involve any discharges to soil or groundwater.

Landscape The Peaking Power Plant involves structures that are generally low-profile. Each generating unit assembly will be about 5 m high with the air intakes at either end being 10 m high. The highest components of the assembly are the exhaust stacks, which are 20 m high. The ancillary systems that are of consequence visually are the additional storage tanks for gasoil and treated water, which will be up to 15 m. All of the above will be lower than the more important visual elements of the existing power station, which include the turbine hall (25 m high), boiler house (48 m), stack (70 m For inspection purposes only. high and fitted with aviationConsent ofwarning copyright owner lights), required cooling for any other towers use. (15 m high) and intermediate peat storage building (21.5 m high). There will be no visible air emissions. The former rural character of much of the visual catchment has already been significantly modified to a predominantly industrial one by the existing power station and its associated transmission lines. The installation of the Peaking Power Plant will reinforce rather than significantly extend this character within the wider landscape setting.

Ecology The area of the EPL site in which the Peaking Power Plant will be located is a heavily modified one in ecological terms and the proposal will not result in loss of significant amounts of habitat, albeit that it is already heavily modified and is of no conservation value. Modelling of the dispersion of air emission from the Peaking Power Plant in combination with the permitted emissions from the existing EPL power station demonstrates that air quality standards for the protection of vegetation and ecosystems will not be breached.

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Water Treated water from the existing power station will be used in the Peaking Power Plant for abatement of air emissions. When in full operation, consumption will be at a rate of 25 t/hour. However, no new sources of water supply will be required and the additional requirement will be met within the limits currently applying at the power station. Additional storm water will be generated from the transformation of certain areas to impermeable surfaces but the additional volume arising will be handled by the existing drainage system and will be imperceptible in the context of the site.

Noise Construction is expected to take place over a short period and will generally be restricted to daytime hours. It is not expected that noise from construction activities will create significant impacts. Operations at the existing power station are subject to daytime and night-time noise limits applying at the nearest noise sensitive location. The station is in compliance with these limit values, which will continue to apply following installation of the new plant. The Peaking Power Plant is of a type that is designed for use in urban areas and a high degree of noise attenuation is built into the design. Modelling of impacts of noise emissions has indicated that thee noise impact of the Peaking Power Plant is very low and that its contribution has a minimal effect on the current noise levels at the nearest noise sensitive location.

Traffic When in full operation, fuel consumption at the Peaking Power Plant will be at a rate of 25 t/hour. With the proposed plant likely to operate up to 10 hours per day when in operation, the haulage of gasoil, which will be confined to the Regional Roads, is likely to generate a

maximum of 10 vehicles per For day. inspection For purposesthe forecasted only. operation for 1,000 hours annually and deliveries restrictedConsent to of week-days,copyright owner required the foraverage any other use. daily traffic will be less than 4

vehicles. The increase in traffic is well below the thresholds commonly applied in determining traffic impacts. Under previous grants of planning permission, EPL is permitted to transport up to 100,000 t of fuel and up to 100,000 t of auxiliary fuel to the plant by road annually. If the maximum of 10 vehicles daily associated with the Peaking Power Plant is taken as occurring constantly, and full allowance is taken for other permitted deliveries, the total arising would be approximately 45 vehicles daily. This total traffic is significantly less than that forecasted in the application on which grant of permission for development of the power station was made and is evidently very low.

Material Assets Demand for electricity is a key indicator of performance and growth in the national economy. EPL is already engaged in meeting this demand and the Peaking Power Plant will facilitate EPL’s ongoing contribution to ensuring that adequate electricity supplies are available to support economic activity and growth in Ireland.

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The use of the site for electricity generation is well established and similar continued use will not adversely impact on other land uses in the area and is compatible with the Offaly County Development Plan. Since the proposed development will only involve minor infrastructural changes to the existing power station, there will be no requirement to provide additional services to the site. It is envisaged that existing services serving the site will be sufficient to cater for the development.

Cultural Heritage The development does not involve use of any greenfield or previously undeveloped area of the site. It will not give rise to significant environmental impacts.

Interaction of Impacts No significant interaction of the impacts is foreseen.

CONCLUSION

The equipment used will be of the most advanced technological design available. The significant environmental impacts from the project have been examined and the best available control technologies have been applied in an integrated approach. With the application of various mitigation measures, there are no impacts that are considered unacceptable. It is therefore concluded that the proposed Peaking Power Plant will not result in significant environmental impacts.

For inspection purposes only. Consent of copyright owner required for any other use.

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1. INTRODUCTION

1.1 SCOPE Bord na Móna plc intends to increase the electricity generation capacity of its Edenderry Power Limited (EPL) power station at Ballykilleen, Clonbullogue, Co. Offaly. This will comprise the installation of a stand-alone gasoil (diesel) fired peaking electricity generating plant with a rating of up to approximately 104 MW. This is similar to the electricity generating installation at Rhode, Co. Offaly and elsewhere. This Environmental Impact Statement (EIS) has been prepared to accompany an application by Bord na Móna to Offaly County Council for full planning permission for the project. Environmental aspects of existing operations at the EPL power station are regulated by the Environmental Protection Agency (EPA) in accordance with Integrated Pollution Prevention and Control Licence (IPPC Licence) Register Number P0482-02 issued by the EPA in January 2006. This installation of the additional plant will require that the existing IPPC Licence be reviewed by EPA. The Peaking Power Plant will not impact on use of other fuels. Bord na Móna is committed to retaining the current electricity generation capacity at the site.

1.2 FORMAT AND PREPARATION This EIS has been prepared in accordance with the provisions of the European Communities (Environmental Impact Assessment) Regulations, 1989 - 1999. These give effect to Council Directive 85/337/EEC and Council Directive 97/11/EC amending For inspection purposes only. Directive 85/337/EEC Consenton the of copyright assessment owner required of for the any othereffects use. of certain public and private projects on the environment. The EIS is presented in the grouped-format structure with each category (Human Beings, Noise, etc.) being considered under the separate headings: Receiving Environment; Impact of the Development; Mitigation (where appropriate); and Conclusions (where appropriate). Using this approach, the EIA provides the competent authorities and the public with a comprehensive understanding of the project, the existing environment, the impacts and the mitigation measures proposed. Every effort has been made in the preparation of the document to keep it as concise as possible while also ensuring that relevant material is adequately covered. It reflects the EPA Advice Note on Current Practice (in the preparation of Environmental Impact Statements) and the Guidelines on the Information to be Contained in Environmental Impact Statements. The order of presentation has been adjusted to aid comprehension. The method of presentation can be summarised as follows:

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• Section 1 provides an introduction to the project, describing the method of preparation and identifying those responsible, and outlining the existing licensing and permitting at the existing EPL power station.

• Section 2 provides a description of the proposed development in terms of the site, the main plant and its method of operation, and ancillary systems.

• Section 3 considers alternatives to the proposed development in terms of electricity generation and site selection.

• Sections 5 – 15 consider the environmental impacts of the proposed development with detailed focus on the issues considered to be of potential significance.

1.3 METHODOLOGY Throughout the EIS the receiving environment is described in the context of the current situation, i.e. with the EPL power station in operation. The EIS includes consideration of both short-term effects during the period of construction and long-term effects arising from operation of the project. This EIS was prepared by ESB International Limited, Stephen Court, 18-21 St. Stephen's Green, Dublin 2, Ireland. Specific studies of certain aspects of the power station environment and the likely significant effects of the proposal were commissioned from specialist consultants. The following persons/companies contributed to the preparation of the EIS:

• Air: Bord na Móna Environmental

• Noise: Project Management Limited No difficulties such as technical deficiencies, lack of information or knowledge were encountered in compiling any specified information for the EIS. For inspection purposes only. Consent of copyright owner required for any other use. 1.4 EXISTING LICENSING AND PERMITTING Planning Permission The planning history of the site is as follows:

• An Bord Pleanála Ref. PL 19.107858 - Permission was granted by An Bord Pleanála in December 1998 for a peat fired electricity generating station subject to conditions (Planning Authority Ref. 02/437).

• Planning Authority Ref. 98/493 - Permission was granted by Offaly County Council in September 1998 for a pumphouse for water abstraction from the Figile River at Clonbullogue.

• An Bord Pleanála Ref. RL2032 - The Board decided that the proposed use of biomass and meat and bone meal as auxiliary fuels in the power station was development and was not exempted development.

• An Bord Pleanála Ref. PL 19.211173 – Permission was granted by An Bord Pleanála in May 2005 for material change from use as a power station for electricity generation

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by combustion of peat to use as a power station and a waste recovery facility for the electricity generation by combustion of a mix of fuels including biomass and recovered (treated) meat and bone meals subject to conditions (Planning Authority Ref. 04/210) Integrated Pollution Prevention and Control (IPPC) EPL applied for an Integrated Pollution Control Licence (IPC) and IPC Licence Register No. 482 was granted by the EPA in July 1999 for the following:

• Class 2.1: The production of energy in combustion plant the rated thermal input of which is equal to or greater than 50 MW. An application was made to the EPA in October 2002 for a revised Licence to co-fire the plant with biomass (wood material) and (treated) Meat and Bone Meal (MBM) with the use of MBM in the fuel mix being up to a maximum of 10% per annum on average. In January 2006, EPL was issued with IPPC Licence Register No. P0482-02 by the EPA to carry out the following activities:

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

• Class 11.1: The recovery of disposal of waste in a facility, within the meaning of the Act of 1996, which facility is connected or associated with another activity specified in this Schedule in respect of which a licence or revised licence under Part IV is in force or in respect of which a licence under the said Part is or will be required. Greenhouse Gas Emissions Permit Greenhouse gas emissions Permit Register Number IE-GHG007-02 was granted by EPA in December 2004 in substitution for the GHG permit granted in March 2004 and bearing Permit Register No. IE-GHG075-01. The previous GHG permit was superseded by this permit. For inspection purposes only. Consent of copyright owner required for any other use. The Permit authorises the station to undertake activities resulting in emissions of specified greenhouse gases from listed emission points. It also contains requirements that must be met in respect of such emissions, including monitoring and reporting requirements. Allowances for emissions to air of greenhouse gases are allocated through the National Allocation Plan and the Permit obliges the station to surrender allowances to the EPA equal to the annual reportable emissions of carbon dioxide equivalent from the station in each calendar year. The holders of Greenhouse Gas Emissions Permits may buy and/or sell such allowances subject to the proper notification to the Registry Manager.

1.5 POLICY BACKGROUND Under the Local Government Planning and Development Act, 2000, Planning Authorities are obliged to make Development Plans for their functional area every six years. The Offaly County Development Plan 2003 - 2009 is the framework document for guiding and controlling future developments in the county. Section 3: Objectives outlines specific objectives that the Council intends to pursue over the lifetime of the Plan. Section 3.10 in relation to electricity states as follows:

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3.10.1 Electricity Power Supplies

It is Council policy to cater for the expansion of electricity developments in the county to cater for natural growth, new and existing large customers and to ensure in so far as is possible that the necessary infrastructure is in place to support the existing and future economy in Offaly. The proposed development is compatible with the provisions of the County Development Plan.

For inspection purposes only. Consent of copyright owner required for any other use.

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2. DESCRIPTION OF PROJECT

2.1 PROJECT OVERVIEW It is intended to develop an electricity Peaking Power Plant with a nominal capacity of approximately 104 MW at the EPL power station at Clonbullogue, Co. Offaly. Connection to the national grid will be made as for the EPL power station via the existing ESB compound within the existing power station site, to which overhead lines are already connected. The plant is similar to plant installed by ESB at its facilities at Aghada, Co. Cork, Rhode, Co. Offaly and Killala, Co. Mayo. In each of these instances, the relevant planning authority considered that the nature of the development did not warrant an Environmental Impact Statement.

2.2 THE DEVELOPER In 1997 the Government put in place a competition to award the development of a new peat-fired power plant. The competition was won by Imatran Voima Oy (IVO), an international energy company based in Finland. Edenderry Power Limited, a 100% subsidiary of IVO was responsible for construction, ownership, maintenance and operations, and electricity generation and sales for the plant, which has a rated capacity of 128 MW. In 2006, in line with its plans for broadening and extending its involvement in the Irish energy market, Bord na Móna plc purchased full ownership of Edenderry Power Limited. Bord na Móna is a semi-state body formed to develop Ireland’s peat reserves to best advantage. Its first developments were based on harvesting sod peat, which was used in

power stations and as a household For inspection fuel.purposes From only. the late-1950s onwards, developments Consent of copyright owner required for any other use. were based on milled peat, used for the production of electricity, for the manufacture peat briquettes and the production of growing media and composts. Throughout its history, since its foundation in 1946, Bord na Móna has at all times and in all its areas of activity placed great emphasis on local and national economic development. Bord na Móna seeks to conduct all aspects of its business in an environmentally sensitive manner. It is committed to minimising the impact of its activities on the natural environment. The company has established an environmental management system, which specifically addresses its impacts on environmental resources. Bord na Móna is the majority shareholder in Renewable Energy Ireland Ltd., which established Ireland‘s first commercial windfarm at Bellacorick, Co. Mayo. With respect to energy, it is company policy to grow its market share in electricity generation in Ireland, including renewables. This includes developments of the additional electricity generation proposed at the EPL power station. The Government’s Energy White Paper - A Sustainable Energy Future For Ireland – published in March 2007 noted as follows:

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Bord na Móna, as well as delivering on its existing core business, is developing new strategic directions with full Government support including renewable energy, waste to energy, energy research and development, and power generation.

The installation of the proposed Peaking Power Plant is part of this move to develop and expand Bord na Móna’s role in electricity generation in Ireland and it is evidently strongly supported at Government level.

2.3 THE SITE Overall Site The existing power station is located between the town of Edenderry and the village of Clonbullogue in northern Co. Offaly, which has long been associated with the power industry. It is adjacent to Kilcumber Bridge on the R401 Regional Road, approximately 3 km north of Clonbullogue. The nearest dwelling to the site is located to the south-east at approximately 170 m from the site boundary . The topography of the site is relatively flat and is at an elevation of approximately 70 metres (m) above Ordnance Datum (OD). The general area in the vicinity of the station is the flat peatlands of the , which border the site to the north and east. The site is bordered to the southeast by the River Figile, which is a tributary of the River Barrow, and to the west by the Clonbullogue – Edenderry R401 Regional Road. The EPL site occupies an area of 8.88 hectares (22 acres). It was a greenfield site until 1998 when construction of the existing power station commenced. Construction was completed in 2000 and following commissioning the plant has been in commercial operation since 2001. The power station is supplied with peat For inspection purposes only. from the Bord na MónaConsent depot of copyrightto the north-eastowner required forof any the other site. use.

No part of the site or its surroundings is designated for nature conservation purposes. Development Area The area in which the peaking plant will be located is fully within the boundaries of the existing power station. The plot lies between the existing Intermediate Peat Storage building and the embankment that provides visual separation of the existing facilities from the Clonbullogue – Edenderry R401 Regional Road. The area has been used in the past on an occasional basis as a temporary carpark when contractors have been engaged in significant works at the station. Most of the area in which the plant will be located already has a hardcore finish.

2.4 EXISTING PLANT The main buildings that comprise the existing power station are as follows: boiler house, turbine hall, 70 m high stack, water treatment plant, office and control building, intermediate peat storage building, workshop, stores. Other site infrastructure includes cooling towers, electrostatic precipitators with an efficiency of 99.8% for removing ash

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from flue gases, transmission substation, oil storage area, settlement basin and car park. Existing operations at the station can be broadly considered as follows:

• Fuel handling system including a intermediate storage facility with conveyors and screw reclaimers, oil storage and handling including a 400 m³ capacity tank for medium fuel oil and 70 m³ capacity tank for gasoil.

• Meat and bonemeal (MBM) handling system (this remains to be installed).

• Bubbling fluidised bed boiler incorporating a dry limestone injection system for reduction of emission of sulphur dioxide.

• Steam turbine and condenser.

• Raw water supply with cooling water requirements being met by abstraction of water from the River Figile with a supplementary supply from two on-site groundwater wells.

• Water treatment plant for treating incoming water to achieve a high purity prior to its use in the plant.

• Cooling water circuit comprising induced draft cooling towers and cooling tower pond.

• Ash handling system.

• Settlement pond with a capacity of 3,000 m³ that allows settling out of suspended solids prior to aqueous discharge to the River Figile.

• Transformer and electrical system providing connection to the ESB 110 kV system, low voltage interface with ESB equipment, and power supplies for plant and control systems.

• Plant control system principally for the steam turbine, water treatment plant, condensate cleaning plant and boiler protection, and Control Room. For inspection purposes only. Consent of copyright owner required for any other use.

2.5 PROPOSED PLANT The plant will be a ‘peaking plant’ designed to operate during short periods of peak demand in the national electricity system. The fundamental characteristics required of such plant are that it should be capable of starting quickly when required. The plant option under consideration consists of two Pratt & Whitney (P&W) TwinPac generating units. The general arrangement of the main elements of the development are shown in Figure 2.1 and a view of a typical TwinPac installation is shown in Figure 2.2. Each TwinPac comprises two inter-linked gas turbines driving a common generator and having a rated electrical output of 52 MW (104 MW total). Each power unit is self- contained and comprises gas turbines, common electrical generator, inlet air filters and ducting, exhaust ducting and auxiliary systems. The plant incorporates four exhaust stacks, one for each gas turbine. Equivalent P&W generating units are installed at ESB’s Rhode Peaking Power Plant. The output of gas turbines is sensitive to ambient air conditions. In a typical configuration the output can decrease by about 5% for a change in temperature from -5 ºC to +9 ºC due to a decrease in capacity of the compressor to take in air from the atmosphere.

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The power plant will typically be of modular design for ease of transport and rapid installation. The TwinPac modular assembly process is shown in Figure 2.3. Minimal construction activities are required. The power units are compact in design with the overall area occupied by a single power unit being 37 m x 17 m approximately. They are low profile units with only the air intakes (10 m) and the exhaust stacks (20 m) exceeding 5 m in height. Concrete foundations are required to take the plant loads and a hard-standing working area is necessary in the vicinity of the plant. Assembly of the power plant is rapid, requiring a period of approximately one month from delivery to site to first operation. A gas turbine extracts energy from a flow of hot gas produced by combustion of fuel oil in a stream of compressed air. It will have an upstream air compressor mechanically coupled to a downstream turbine and a combustion chamber in between. Energy is released when compressed air is mixed with fuel and is ignited in the combustor. The resulting gases are directed over the turbine's blades, spinning the turbine, and mechanically powering the compressor. Finally, the gases are passed through a nozzle generating additional thrust by accelerating the hot exhaust gases by expansion back to atmospheric pressure. Energy is extracted in the form of shaft power, compressed air and thrust, in any combination, and is used to power aircraft, trains, ships and electrical genertaors. Combustion Turbine The combustion turbine will consist of an air compressor, a combustion chamber, a turbine and an electricity generator coupled together. The air compressor, combustion turbine and electricity generator will be attached to one main driving shaft which rotates at high speed. For inspection purposes only. The air compressor takesConsent in oflarge copyright quantities owner required of forair any from other use.the atmosphere and compresses it

into the combustion chamber from where it flows through the turbine. Fuel is then injected into the combustion chamber. This addition of heat energy and combustion gases raises the temperature of the combined gases to more than 1,000 ºC and greatly increases the velocity of these gases through the turbine. The effect of this high velocity gas flow through the turbine will drive the turbine with sufficient power to enable it to drive both the air compressor to supply air and the electricity generator to produce the rated electrical power output. See Figure 2.4. The expansion of the hot gases through the turbine and the extraction of mechanical work from them via the turbine reduces the temperature of the gases to approximately 350 ºC. The hot gases are discharged to atmosphere via a stack. Plant Fuel and Water Low sulphur content gasoil (maximum 0.1% S) will be used as fuel. Each power unit will consume up to 12.5 t/hour of gasoil when in operation. Water injection will be used for abatement of air emissions by controlling formation of nitrogen oxides (NOx). This involves the injection of water into the combustion chamber. This reduces the combustion temperature and so reduces the formation of thermally-

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produced NOx. Plant Operations The plant will operate as required to meet peaks in the national demand for electricity. These do not normally occur at night-time and night-time operation is therefore not envisaged. This could, however, arise in the event of unavailability of other generation capacity in the system. While the units will not necessarily be required to operate every day, it is envisaged that the units, when called upon, will typically operate for between 5 hours and 10 hours per day. Plant operation is expected to be for about 1,000 hours per year but up 1,500 hours of operation could arise. The plant will be operated in combination with the existing power station to ensure continuous availability. It is generally expected that the individual power units will operate at maximum output or not at all. Significant part-load running is not anticipated. The number of power units in operation at any one time will depend on the size of the peak load experienced. Units would be brought on load as required. Plant Efficiency The plant will have an exported efficiency of approximately 35-36%. This means that 35- 36% of the chemical energy contained in the fuel will be converted to exported electrical energy, i.e. net of house load. The existing plant at EPL has an overall design efficiency of 38.4%. The plant will employ state-of-the-art technology recognised as being the most advanced for temporary power production application. Combustion Turbine Compressor Washing For inspection purposes only. Plant output and efficiencyConsent may of copyright be reduced owner required by for deposits any other use. accumulating on the compressor blades. Because filters on the air inlet structure only remove coarse particles, cleaning of the compressor blades is necessary. On-load Washing: On-load washing takes place when the combustion turbine is in operation. Demineralised water is injected into the gas compressor end of the combustion turbine, flows through the compressor and the turbine and exits via the stack as vapour. A small quantity of detergent or surfactant may be added to the water, as determined by the supplier of the combustion turbine. Off-Load Washing: Off-load washing takes place when the combustion turbine is not in operation. A small quantity of diluted detergent or surfactant is injected into the compressor. This is followed by rinsing with demineralised water. Effluent from the washing is collected in a sump with the waste material being removed off site for disposal.

2.6 ANCILLARY SYSTEMS Gasoil Delivery, Storage and Treatment Gasoil will be delivered by road tanker and will be held in two untreated gasoil storage tanks (capacity of 650 m³ approximately each). The tanks will be vented and vents will be

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fitted with oil vapour traps. A special gasoil unloading area will be provided and this will incorporate spill collection features. The gasoil will be treated by a fuel conditioning plant prior to use in the gas turbines and the conditioned gasoil will be stored in a separate day tank (capacity approximately 800 m³). The sludge from the fuel conditioning process will be held in a small capacity tank prior to removal by an appropriately licensed waste contractor. All tanks and fuel conditioning plant will be located within a bund in accordance with best practice. The conditioned gasoil will be pumped to the gas turbine injection pumps, (which are self- contained within the gas turbine assembly, via an oil filter and then onto the gas turbine burners. Water Storage

A supply of water of up to 25 m³/hour will be required for use in NOx suppression and this will be provided from the water treatment plant at the existing EPL power station. Additional storage of treated water with a capacity of approximately 2,500 m³ will be provided in two tanks that will be located adjacent to the cooling towers. The water supply requirement is within the capacity of the existing plant and the existing limits on wastewater streams will not be compromised. A control and instrumentation system is already in place for the complete automatic control of the water treatment system including regeneration and effluent control. Instrumentation includes rate of flow meters, pressure and differential pressure gauges, pH meters, analysers (including silica analyser) and conductivity meters. The discharge from the effluent tank will continue to be monitored for pH. Generator Cooling For inspection purposes only. Generators will be air-cooled.Consent of copyright For the owner size required of forcombustion any other use. turbines envisaged, generator stator and rotor cooling can be achieved using air. Electrical Transformers The generated voltage from each power unit will be stepped up at a generator transformer. Transformers will be outdoor, three phase and oil immersed. The high voltage windings will be 110 kV and each will have an on-load tap changer. The transformers will be bunded according to best practice, to prevent oil spillage. The transformers will be connected to an extended ESB substation by underground cables and no new overhead lines will be required. Control and Instrumentation A complete control and instrumentation system will be put in place to achieve effective control and monitoring of the operation. The system will automatically control the plant during all steady-state conditions, plant abnormalities, start-up and shutdown. Plant safety will be monitored and the system will automatically effect an emergency shutdown in a fail-safe manner where required. All unnecessary shutdowns will be avoided. The system will provide the operator with all necessary information to oversee the plant.

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2.7 HAZARDS AND SAFETY The basic technology to be employed in the project is well understood and has been used successfully in many equivalent projects elsewhere. The Peaking Power Plant will not significantly add to the main potential hazards arising at the power station. These result from the storage of quantities of combustible material and the presence of high-voltage equipment. These potential hazards are already managed successfully within the existing EPL power station. The Peaking Power Plant will be designed with fire protection and detection systems that will be compliant with all relevant statutory requirements and internationally recognised best practice. A fire main system, continuously pressurised by standard fire pumps with redundant capacity, is already in place at the EPL power station and will be extended to contain and extinguish a fire which might arise from a gasoil leak. The existing deployment of dry powder and CO2 fire extinguishers will be extended to cover the additional plant. The additional water storage capacity will be available to augment and support the existing fire-fighting systems at the EPL power station. Protection measures to reduce the risk of hazard arising from the gasoil storage area will include the provision of a bund to the storage area and isolation valves to the fuel tanks, and the protection of ignition sources, particularly electrical equipment, in the vicinity of the storage areas. The bunding provided around the fuel tanks will provide passive protection by protecting personnel, plant and the environment from spillage, by protecting the tanks and associated equipment from external damage, by reducing the surface area of any liquid spills, thereby reducing the rate of evaporation and also by reducing the size of any fire that may occur, and by reducing the heat radiation from any fires that may occur.

Under the EC (Control of MajorFor inspection Accident purposes only.Hazards Involving Dangerous Substances) Consent of copyright owner required for any other use. Regulations, 2006, the Peaking Power Plant does not present a major accident risk. Access to the EPL power station is strictly controlled and the existing site security measures will be applied to the additional plant.

2.8 CONSTRUCTION AND OPERATION All construction works will be carried out under appropriate supervision. Works will be carried out by experienced contractors using appropriate and established safe methods of construction. All requirements arising from statutory obligations including the Safety, Health and Welfare at Work Act and associated regulations will be met in full. Plant commissioning will follow completion of the construction phase and will involve setting up and testing the equipment to ensure that it is fully functional and that all technical, environmental and safety requirements have been met. Personnel welfare and safety at the station are of primary importance and station management at EPL is committed to ensuring that the power station is as safe and healthy as possible to work in. Staff will be trained to operate and maintain the additional plant to a high degree of proficiency and will be capable of dealing with any emergency on

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the site, including fire. Prior to operation, a comprehensive set of operating procedures will be drawn up for operation of the plant and all plant operators will be fully trained. A formal Environmental Management System (EMS) is already in place at EPL. It provides order and consistency for organisational efforts to address environmental concerns through the allocation of resources, assignment of responsibilities, and ongoing evaluation of practices, procedures and processes. The system is fully documented and meets the requirements of the international standard for Environmental Management Systems ISO 14001 - Specification with guidance for use. The EMS will be updated and revised to include the additional plant.

2.9 DECOMMISSIONING Closure and aftercare of the EPL power station are addressed in the station’s Residuals Management Plan, which is a requirement of IPPC Licence Register No. P0482-02. The Residuals Management Plan will be updated and revised to take account of the additional plant.

For inspection purposes only. Consent of copyright owner required for any other use.

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Figure 2.2: Typical P&W TwinPac Installation

EPA Export 26-07-2013:00:59:36 For inspection purposes only. Consent of copyright owner required for any other use.

Figure 2.3: TwinPac Modular Assembly Process

EPA Export 26-07-2013:00:59:36 Figure 2.4: Schematic Diagram – Open Cycle Gas Turbine with Water Injection for NOx Abatement

FUEL WATER

COMBUSTION CHAMBER STACK

GAS AIR COMPRESSOR For inspection purposes only. GENERATOR Consent of copyrightT ownerURB requiredINE for any other use.

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3. ALTERNATIVES

3.1 REQUIREMENT FOR ADDITIONAL PLANT The need for additional generating capacity on an electrical system is determined primarily by the growth in system demand. The forecast of future electricity demand is related to growth in national economic activity. In Ireland, from the mid-1940s to the late-1970s, with the exception of a short period following the first international oil crisis in 1973, there was a steady annual growth in electricity demand in the range of 8% - 10%. Following the second oil crisis in 1979, growth rates were low in the first three years of the 1980s before a recovery to about 4% annually over the following few years. The upturn in the economy following the recession of 1987/1988 has resulted in an average annual growth rate in electricity demand of 5% or more since then. There is a close link between electricity demand and the general performance and growth in the national economy, although growth in demand for electricity actually surpasses national economic growth. Over the past 25 years, there has been a steady increase world-wide in electricity's share of the final energy market and this has been mirrored in Ireland. Concern over environmental issues has caused a change throughout the world in the emphasis of policy relating to growth in energy and electricity demand. The priority is now to contain the growth in energy demand to a level no higher than is necessary to sustain economic growth. In line with EU policy, Ireland has sought to reduce the rate of growth of electricity demand by way of greater supply side and end-use efficiency, while at the same time

seeking to avoid constraints For inspectionon economic purposes only. development. Current policy reflects this Consent of copyright owner required for any other use. change towards the management of demand growth rather than marketing for growth. At the same time, it is recognised that, due to the versatile nature of electricity, growth in demand is consistent with and a prerequisite for stabilisation in overall energy consumption.

3.2 NOT PROVIDING THE PLANT Irrespective of other changes in the future structure of the electricity sector in Ireland arising from changes in the internal market in electricity, sustained economic growth into the future will ensure that the need to install additional generation capacity continues to arise. There is increasing pressure on the electricity supply system and increased demand is particularly significant during short periods in the winter months or when power stations are out of service for maintenance or repair. New power generating stations are in the course of construction at present or are planned over the next few years to meet the additional demand and to ensure a safe margin of reserve capacity into the future. However, the age of some of the existing plant and its consequent less than optimum availability does not provide the required secure margin.

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Additionally, the overall electricity generation system requires a proportion of plant of the type proposed and as growth in the overall system continues a requirement for further capacity of this type arises. The option of not providing the proposed plant could result in there being a shortfall in generation output necessary to meet customer demand. Additionally, it would not meet Bord na Móna’s need for future commercial power generation in the Irish electricity market. This role is outlined in the Government’s Energy White Paper - A Sustainable Energy Future For Ireland- published in March 2007. Amongst the Actions in support of Strategic Goal 1: Delivering Competition and Consumer Choice in the Energy Market is as follows: We will encourage BGE and Bord na Móna to develop their role in power generation and supply … The White Paper notes that, amongst others factors, achieving an adequate safety margin between electricity supply and demand requires additional generating plant including flexible plant.

3.3 ALTERNATIVE PLANT TYPES The plant will be a peaking plant designed to operate during short periods of peak demand in the national electricity system. Such plant provide a necessary service on the system and this service cannot be provided by other types of plant. Combined Cycle Gas Turbine (CCGT) configurations are not suitable for peaking duty. The proposed plant represents a high standard of environmental performance compared with alternatives such as conventional diesel engines. The fundamental characteristics required of peaking plant are that it should be capable of starting quickly when required.

Compared to base load plant, For inspectionsuch as purposes the only.existing EPL power station, that operates at Consent of copyright owner required for any other use. reasonably constant output throughout most of the year, the design philosophy supporting peaking plant is based on flexible operation and rapid start-up at short notice to meet rapidly changing demand conditions with less emphasis on maximising efficiency given the low annual operational hours. Notwithstanding this, the peaking plant installed at EPL will represent state-of-the-art technology for peaking plant of its size. Peaking plant and base load plant are not mutually exclusive. Both types of plant are required by all grid systems to allow them to function economically and reliably. Peaking plant and base load plant play different but important roles in system load management. Both types of plant are necessary and neither is more important than the other. The increase in new base load plant on the system in Ireland in recent years to meet new demand and to replace decommissioned plant has not removed the requirement for peaking plant nor will it into the future. Thus, peaking plant forms a critical part of electricity generation infrastructure nationally and plays a vital role in system load management.

3.4 RENEWABLE ENERGY SUPPLIES Power generation from renewable and alternative sources will play an increasingly

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important role in meeting electricity needs in the future. However, they are not a realistic alternative to the proposed Peaking Power Plant at EPL. Indeed, further development of renewables will be facilitated by the availability of the proposed plant. The terms renewable and alternative energy supplies are usually used to describe wind, hydro, solar, tidal wave power, biomass processes, and the use of waste materials through waste combustion and landfill gas. Renewable sources of energy offer significant benefits that are recognised in European and national policy support for increased use of renewable energy. Bord na Móna Energy Limited is already a major supporter of renewables in Ireland. In the wind energy sector, it was a the majority shareholder in the establishment of Ireland‘s first commercial windfarm at Bellacorick, Co. Mayo. It is also in partnership in the permitted Oweninny Windfarm in Co. Mayo, which consists of 180 turbines with a total capacity of approximately 270 MW. Additionally, it is already a supporter of biomass energy through its permitted co-firing of the existing EPL power station. Government policy in support of renewable energy sources, and electricity generation from wind in particular, requires that back-up electricity generation capacity must be available at short notice during periods when the wind resource is low. Peaking plant characteristics, as described above, are ideally suited to meet this requirement and provide a good fit in terms of reliable and flexible operation. The expected increase in installed wind generation capacity, in line with Government targets and EU objectives, will further increase the need for peaking plant with these characteristics in the future. The EPL Peaking Power Plant will provide a natural back-up for wind generation and it will not inhibit the growth of alternative energy supplies. Peaking plant is required in all grid systems. An increasing peaking capacity requirement

is expected as wind energy penetration For inspection purposes continues only. in line with Government and EU Policy. Consent of copyright owner required for any other use.

3.5 ALTERNATIVE SITES There are other possible sites where peaking power plant could be located. However, the EPL site is already associated with power generation and other sites offer no significant advantages in terms of environmental impacts. There is an adequate water supply already available to EPL. For control of NOx emissions a suitable volume of treated water will be available from the existing water treatment plant at EPL without modification. This confers a significant advantage for the location there of the Peaking Power Plant. Sufficient space is available at EPL to accommodate the power plant. The location of the Peaking Power Plant at EPL requires no further reinforcement or development of the electricity transmission grid. Location of the plant at most other potential sites would require new overhead high voltage transmission lines. Furthermore, the presence of the general site infrastructure including elements such as fire fighting systems permits optimum use of existing facilities and avoids duplication of such facilities at another site.

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Other sites do not offer the equivalent advantages that the EPL site offers in terms of availability of a supply of treated water and access to the electricity transmission system.

3.6 CONCLUSIONS Electricity generating plant of the type proposed is required by the national grid and particularly so in the context of increasing overall demand and increasing development and penetration of alternative energy supplies. The proposed plant is of a type currently used internationally for peaking duty. Substantial fixed generating capacity is not available at short notice and with acceptable environmental performance. The generating plant represents a high standard of environmental performance compared with alternatives. The chosen site is already connected to the National Grid via high voltage power lines which will cater for the power generated and additional overhead lines or buried cables will not be required. Based on the above, there are no alternatives that offer significant advantages.

For inspection purposes only. Consent of copyright owner required for any other use.

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4. HUMAN BEINGS

The Receiving Environment reflects the presence of Edenderry Power Plant since its commissioning in 2001.

4.1 RECEIVING ENVIRONMENT Over the last 5 - 10 years, population trends in Ireland have changed dramatically. Until about the mid-1990s, these trends were largely determined by labour market conditions in Ireland and in the countries to which Irish people migrated. Overall, there had been a long-term trend towards significant levels of emigration. However, the trend towards emigration has reversed, becoming a strong and continuing trend towards net in- migration, fuelled by very strong domestic economic growth rates. The EPL power station is located in the Clonbullogue Electoral Division of Edenderry No. 1 rural district of Co. Offaly. The populations of each from Census of Ireland data produced by the Central Statistics Office are shown in Table 3.1. Table 4.1: Population Trends

Area 1991 1996 2002 Change (91-02)

State 3,525,719 3,621,035 3,917,336 + 11.1%

Co. Offaly 58,494 59,117 63,702 + 8.90%

Edenderry No. 1 Rural 8,865 8,605 10,193 + 15.0%

Clonbullogue 577 566 650 + 12.7%

The population of the State increased in the period 1991 – 2002. While the increase in Co. Offaly was lower than that experienced nationally, significant growth was recorded For inspection purposes only. both in the general EdenderryConsent of copyrightarea and owner in required Clonbullogue. for any other use.

Population density in Co. Offaly is lower than in adjoining counties and is significantly below the national average. However, this is partly explained by the extent to which the county is covered by bog. The existing EPL power station has a major impact on the industrial rate base in Co. Offaly, paying approximately €1 M annually in rates charges to Offaly County Council. The surrounding area is characterised by variable intensity farming and peat production. Peat production, dairying, grassland management and dry cattle are the main activities in the area. Bord na Móna is a unique feature in the socio-economic structure of Co. Offaly. It is one of the largest employers in the county and is the largest employer in the Edenderry area. The total expenditure annually at EPL on payroll is approximately €3.5M with a further approximately €2 M expenditure on contractors and services. Annual expenditure on fuel is approximately €30 M, which sustains up to 250 jobs in peat harvesting and related activity. There is an economic multiplier effect of this expenditure in the region, from retail and service industries particularly, over and above station expenditure on local services.

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The latest available figures from the Central Statistics Office show that income per capita for Co. Offaly was €16,733 in 2004, when it was 89% of the national average. The station provides secure employment with better than average wages. The impact of the power station is to increase the average income in the county significantly as a result of the employees’ incomes and those of people employed in spin-off service industries.

4.2 IMPACT OF THE DEVELOPMENT As the proposed development contains no residential component, it is unlikely to have any significant direct impact on the composition of the population in the immediate area. The presence of the existing EPL power station has not impacted negatively on population numbers and, indeed, its presence has coincided with growth in population in Edenderry and Clonbullogue that has surpassed that occurring elsewhere in Co. Offaly. It is concluded that the additional generation at EPL will not impact negatively on population numbers. At peak employment, approximately 20 - 25 jobs will be created during construction, albeit that it will over a short period. There will be also be indirect employment in the manufacture of building materials and equipment used in construction. A requirement for some temporary or medium-term accommodation may arise during project construction. It is envisaged that future employment at the EPL power station will remain similar to current levels. Operation of the additional plant will be an integral part of station operations. In the overall context of employment and redeployment of existing personnel at EPL, there will be no separate employment associated with the Peaking Power Plant. Additional employment opportunities may arise through the provision of goods and services associated with operation of the plant. The proposed development will enhance the viability of the EPL power station operations as a whole by increasing and For broadeninginspection purposes its only. role in the Irish electricity sector. This will Consent of copyright owner required for any other use. significantly strengthen the ability of EPL to remain competitive in the long term. During the construction phase there will be significant expenditure on the civil, mechanical and electrical infrastructure. This expenditure will result in economic benefit to the local, regional and national economy. During the operational phase there will expenditure annually on consumables with additional expenditure occurring on plant maintenance.

4.3 MITIGATION No mitigation of impacts is required.

4.4 CONCLUSIONS The project will be positive for the local and national economy.

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5. AIR EMISSIONS

5.1 RECEIVING ENVIRONMENT Power Plant Emissions The Peaking Power Plant will be fired on low sulphur gasoil (0.1% S). The emissions to atmosphere of possible concern are nitrogen oxides (NOx), sulphur dioxide (SO2), carbon monoxide (CO), particulate matter (dust) and carbon dioxide (CO2).

This air quality assessment is focused on NOx and SO2. Because the proposed development will be of the most advanced of its kind available, very low levels of CO (<20 mg/m3) and particulate matter (<6 mg/m3) will be emitted. In addition, carbon dioxide emissions do not affect ambient air quality. The impact of CO2 emissions and the long- range impacts of SO2 and NOx emissions on the global/European environment are discussed elsewhere where climatic issues are addressed.

Emissions of NOx and SO2 to atmosphere result from fossil fuel combustion in the domestic, industrial/commercial and transport sectors. NOx arises from the oxidation of fuel or air nitrogen in high temperature combustion processes; the amount emitted is a function of fuel used and combustion conditions, such as peak temperature. NOx is a mixture of nitrogen oxides, principally NO (nitric oxide) and NO2 (nitrogen dioxide). SO2 is produced by the oxidation of sulphur contained in fuels, with emission rates depending on the sulphur content of the fuel utilised. Pollutant concentrations in air are determined mainly by weather conditions and local emission sources. The impact of emissions from point sources is controlled by the use of stacks that are designed to ensure good dispersion and thereby minimise any air quality impacts at For inspection purposes only. ground level. Air dispersionConsent fromof copyright point owner sources required for is any now other well use. understood, enabling confident and conservative prediction of performance to be made. Thus, modern chimney design in conjunction with increased regulation, more stringent emission standards and cleaner fuels, ensures that large point sources are not a source of air quality problems. Air Quality Standards

Air quality in the vicinity of the site can be characterised with respect to SO2 and NOx by reference to relevant statutory air quality standards, which specify permitted ambient concentrations of various pollutants in air in order to protect human health and the environment. National air quality standards (Table 5.1) are contained in the Air Quality Standards Regulations, 2002 (SI 271 of 2002). These standards are the limit values specified in EU Directive 1999/30/EC.

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Table 5.1: National Air Quality Standards (SI 271 of 2002)

Pollutant Criteria Limit Value Compliance Date (µg/m3)

SO2 Hourly – 99.7% (not to be exceeded 350 January 2005 more than 24 times per year)

Daily – 99.2% (not to be exceeded 125 January 2005 more than 3 times per year)

Annual average (for protection of 20 January 2001 ecosystems)

NO2 Hourly – 99.8% ( not to be exceeded 200 January 2010 more than 18 times per year)

Annual average (for protection of 40 January 2010 human health)

Annual average (for protection of 30 vegetation)

5.2 IMPACT OF THE DEVELOPMENT A Pratt & Whitney Twinpac consists of two gas turbine (GT) units with the exhaust air from each of the GT units being discharged to atmosphere via a rectangular (2.47 m x 3.07 m cross-section, area 7.58 m²) stack of 20 m height. There will be two exhaust stacks on each TwinPac unit. A summary of the emission characteristics of each GT unit is presented in Table 5.2. From January 2008 the maximum sulphur content for gasoil will reduce from 0.2% to 0.1%, resulting from the implementation of EU Directive 1999/32/EC. Emissions of SO2 were estimated to be about 3.5 g/s from each GT unit, based on a maximum sulphur content of 0.1% and operating For at inspection full load. purposes only. Consent of copyright owner required for any other use.

Table 5.2: Emission Characteristics for Each Exhaust Stack

T (ºC) Volume Velocity SO2 SO2 (g/s) NOx NOx (g/s) (m3/s) (m/s) (mg/Nm3) (mg/Nm³)

350 199.4 26.3 55 3.5 120 7.5

The plant will utilise state-of-the-art low NOx technology and achieve the ELVs determined by the EU Commission as representing Best Available Technology (BAT) in the EU Large Combustion Plant Directive (2001/80/EC).

It is estimated that for oil-fired combustion, over 95% of the total nitrogen oxides (NOx) in the exhaust gas is emitted as nitric oxide (NO) with the remainder (< 5%) emitted as nitrogen dioxide (NO2). The mass concentration of NOX in the exhaust gases from GTs is more complex compared to SO2 emissions. It is related not only to the amount of combustion air available and chemistry of the fuel being burned but also to the temperature within the flame area in the combustion chamber. NOx may be formed thermally or from the chemical-bound nitrogen or ‘fuel’ nitrogen. Thermal NOx results from the thermal disassociation and subsequent reaction of nitrogen and oxygen molecules in

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the combustion air and the quantity formed depends on the combustion temperature. Gasoil has a small chemically bound nitrogen content and so most of the NOx emitted from the GT unit will be from thermal NOx. The NOx emission rate from each of the four exhaust stacks was calculated to be 7.5 g/s, based on a maximum emission concentration of 120 mg/Nm³.

5.2.1 Air Quality Dispersion Modelling

The AERMOD air dispersion model was used to predict the air quality impact in the locality of the power station. This advanced prediction model for air pollution studies simulates essential atmospheric physical processes and provides refined concentration estimates over a wide range of meteorological conditions and modelling scenarios. The emission rates used for the existing plant related to firing on peat and a mixture of peat and biomass. While the facility is licensed to use a mixture of peat and MBM, the emission limit values for this fuel type are considerable lower. Therefore, the emission rates used represent the worst case emission levels from the existing boiler stack.

Annual average levels of 7.7 µg/m³ and 3.3 µg/m³ for NO2 and SO2 were used to represent ambient air quality. A set of seven specific sensitive receptors, as shown in Figure 5.1, were selected. These consisted of dwelling houses identified from aerial photography of the site and surrounding area as well dwelling houses noted in the vicinity. The full Report of the modelling is as presented in Appendix A hereto and is summarised in Table 5.3. The pattern of concentration contours reflects the effect of building wake effects downwind of the site due to the presence of the existing EPL power station. Table 5.3: Summary of Ground Level Concentrations

Receiver Sulphur Dioxide (µg/m³) Nitrogen Dioxide (µg/m³) For inspection purposes only. Consent of copyright owner required for any other use.

Hourly 99.7 Daily 99.8 Annual Daily 99.2 Annual percentile percentile Average percentile Average

Maximum 401 306 45 313 68

Sensitive Receptor 196 75 8.6 78 10.7

Limit Value 350 125 20 200 40

5.2.2 Predicted Sulphur Dioxide (SO2) Impact

Hourly

The highest predicted 99.7 percentile of hourly SO2 concentrations at a sensitive receptor due to the emissions from both GT units and the existing EPL power station operating at maximum output was 196 µg/m³. This hourly concentration occurs at SR2 and is 56% of the hourly NAQS limit value. The highest predicted level is 401 µg/m³. However, this occurs within the site boundary, at about 85 m of the GT units. There is a rapid decrease in predicted levels beyond the site

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boundary. Daily

The highest predicted 99.2 percentile of daily SO2 concentrations at a sensitive receptor was 75 µg/m³, which is 60% of the daily NAQS limit value. This occurs at SR3. The highest predicted level, which occurs within the site boundary, is 306 µg/m³. These predicted levels are based on the emission scenario where the existing EPL power station is on full load and both GT units are operating continuously over the 24 hours, with no reduction in load during the day. This represents a worst-case maximum impact scenario as normally the each of the GT units will not be on load continuously and when in operation load will vary during the day. Annual The highest predicted annual average at a sensitive receptor was 8.6 µg/m³, occurring at SR5 to the north of the site. This predicted long-term ground level concentrations represents 43% of the NAQS limit value. The maximum predicted concentration is 305 µg/m³, which occurs within the site and decreases rapidly with distance.

5.2.3 Predicted Nitrogen Dioxide (NO2) Impact

Hourly

The highest predicted 99.8 percentile of hourly NO2 concentrations at a sensitive receptor is 78 µg/m³, occurring at SR1. This is less than 40% of the hourly NAQS of 200 µg/m³. The maximum level of 313 µg/m³ occurs within the site but this concentration decreases rapidly with distance. Annual For inspection purposes only. Consent of copyright owner required for any other use. The annual average NO2 concentrations at a sensitive receptor are predicted to be less than 11 µg/m³, occurring at SR1. This predicted long-term ground level concentration is very low and below 27% of the annual NAQS of 40 µg/m³. The highest annual average level of 68 µg/m³ occurs within the site but this concentration decreases rapidly with distance.

5.3 MITIGATION The proposed plant will utilise Best Available Techniques (BAT) as required by the EU Integrated Pollution Prevention and Control Directive and will meet the ELVs specified in the EU Large Combustion Plant Directive considered to represent BAT for the class of installation involved.

5.4 CONCLUSIONS While the worst case scenarios indicate elevated concentrations at the site, no adverse impact on air quality is predicted at sensitive receptors in the surrounding area due to the operation of the proposed Peaking Power Plant.

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For inspection purposes only. Consent of copyright owner required for any other use.

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6. CLIMATE / TRANSBOUNDARY AIR POLLUTION

6.1 RECEIVNG ENVIRONMENT

6.1.1 Climate

It has been determined that the atmospheric concentration of greenhouse gases is increasing. Greenhouse gases include water vapour (H2O), carbon dioxide (CO2), ozone (O3), methane (CH4), nitrous oxide (N2O) and also industrial gases such as sulphur hexafluoride (SF6), hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs). Carbon dioxide is the most significant greenhouse gas from the perspective of anthropogenic emissions to air. With the exception of the industrial gases, greenhouse gases occur naturally as part of the carbon and nitrogen cycles in the environment. Fossil fuel combustion for energy use is the primary reason for human induced increased CO2 concentrations. The UN Framework Convention on Climate Change (1992) led to international negotiation on reducing greenhouse gas emissions, in particular CO2 from developed countries. Under the 1997 Kyoto Protocol to the UN Convention and a subsequent EU burden sharing agreement, Ireland is committed to limiting annual national emissions of a basket of six greenhouse gases to 113% of 1990 levels on average for the period 2008 - 2012. In this regard Government published a National Climate Change Strategy for Ireland in October 2000. This sets out greenhouse gas emission projections and the measures Government intends to adopt to ensure that the national target is achieved.

National greenhouse gas emissions for 1990 amounted to 53.75 Mt (CO2 equivalent) with the energy sector, mainly electricity production, accounting for 11.6 Mt of CO2. The

National Climate Strategy projected For inspection purposesthat business only. as usual CO2 emissions from the Consent of copyright owner required for any other use. energy sector would grow by 62% above the 1990 level by 2010. An indicative sectoral target was set in the Strategy limiting CO2 emissions growth for the sector to 13%, viz. to a total of 13.16 Mt CO2 by 2010. It was envisaged that this target would be met without affecting overall levels of electricity generation or use by fuel switching, i.e. towards less carbon intensive fuels, by increased use of renewables and by improving the efficiency of energy transformation. As part of an EU-wide strategy to facilitate achievement of the EU's commitments under the Kyoto Protocol, an EU Emissions Trading Directive was developed. This has required mandatory participation since 2005 by large combustion plant such as EPL in an EU-wide CO2 emissions trading scheme.

6.1.2 Transboundary Air Pollution

Emissions of SO2 and NOx, which arise in the main from fossil fuel combustion in the transport and energy sectors, are transported over long distances and undergo chemical transformations in the atmosphere. In Europe, the long-range atmospheric transport of SO2 and NOx contributes to regional problems of acidification and eutrophication of soils and waters (acid rain, dry deposition) and also to air pollution (SO2 and NO2 levels,

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secondary particulate formation) over a wide area. The Government has entered into agreements at EU and international level to control national emissions of SO2 and NOx. The obligations were agreed having regard to the economic costs that will be imposed and their impact on national social and economic development. The electricity sector has been assigned specific emissions targets by Government and is currently required to control annual NOx and SO2 emissions at 42 kt and 82 kt respectively. Further progressive reduction in sectoral emissions will be required to assist national compliance with reduced emissions ceiling for NOx and SO2 agreed for 2010 under the Gothenburg Protocol and EU Directive 2001/81/EC on national emission ceilings for certain atmospheric pollutants. According to Environment In Focus 2002 Key Environmental Indicators for Ireland published by the EPA, national emissions in 2000 were as follows:

• Nitrogen Oxides (NOx): Annual emissions were 125.1 kt of which 39.7 kt was emitted by the electricity sector.

• Sulphur Dioxide (SO2): Annual emissions were 131.5 kt of which 79.9 kt was emitted by the electricity sector.

6.2 IMPACT OF THE DEVELOPMENT Plant operation is expected to be for about 1,000 hours per year but up 1,500 hours of operation could arise. Table 6.1 shows the estimated annual air emissions from the plant for 1,500 hours of operation. Table 6.1: Annual Air Emissions

CO2 NO2 (as NO2 but 90% NO) SO2

120 kt 162 t 75 t For inspection purposes only. Consent of copyright owner required for any other use.

6.2.1 Climate

In July 2004 the EU Commission approved a National Allocation Plan(NAP) for Ireland. Under this plan Government is committed to allocating approximately 14.4 Mt per annum in CO2 allowances to the energy sector for the period 2005 – 2007 with a further amount as a New Entrant Reserve. The draft National Allocation Plan for 2008-2012 (NAP2) was issued for consultation in October 2007. It is anticipated that proposed Peaking Power Plant will obtain an allocation of allowances from the New Entrant Reserve and purchase any further allowances required. The EU emissions trading scheme requires that emissions in excess of a target be offset by reductions elsewhere within the emissions trading area. In light of these caps on national emissions from the sectors covered from 2005 onwards, the future operation of the proposed additional plant at EPL will not cause an increase in global CO2 emissions.

The incremental CO2 emission arising from the development is estimated conservatively to be 120 kt annually, which is <1% of the allocation to the energy sector.

In light of the quantities of CO2 associated with the global carbon cycle and the quantities

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emitted from fossil fuel combustion on a global basis (c. 6 billion tonnes of carbon in 1990), it is apparent that the project will have no significant impact on the climate system. The increased emissions arising from the project will not compromise the National Climate Change Strategy. The presence of the plant will facilitate further development of renewable energy sources whose operation is a key component of the Strategy. Thus, while its operation will lead to specific atmospheric emissions, the presence of the Peaking Power Plant will have an overall beneficial impact on CO2 emissions.

6.2.2 Transboundary Air Pollution

Nitrogen Oxides (NOx): Under the EU National Emissions Ceiling Directive (2001/81/EC) national emissions of NOx must be maintained below 65 kt annually from 2010 onwards. The annual contribution by the Peaking Power Plant of 162 t of NOx is evidently insignificant, representing <0.25% of the national ceiling.

Sulphur Dioxide (SO2): Under the EU National Emissions Ceiling Directive (2001/81/EC) national emissions of SO2 must be maintained below 42 kt annually from 2010 onwards.

The annual contribution by the Peaking Power Plant of 50 t of SO2 is evidently insignificant, representing <0.18% of the national ceiling.

As with CO2, the above must also be viewed in the context of the increasing penetration of renewables that the presence of the Peaking Power Plant facilitates.

6.3 MITIGATION The proposed plant will utilise Best Available Techniques (BAT) as required by EU IPPC Directive (96/61/EC) and will meet the ELVs specified in the EU Large Combustion Plant Directive (2001/80/EC) considered to represent BAT for the class of installation involved.

No further mitigation is proposed. For inspection purposes only. Consent of copyright owner required for any other use.

6.4 CONCLUSIONS Emissions arising from the project will not be significant in the context of global climate or transboundary air pollution.

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7. SOILS & GROUNDWATER

7.1 RECEIVING ENVIRONMENT The only current emission to ground of that of treated effluent from the power station’s Puraflo domestic sewage secondary treatment plant. The discharge is to a percolation area covering an area of approximately 300 m². The EPL power station was constructed on a greenfield site with no record of historic groundwater contamination. Since commissioning in 2000 the plant has operated in accordance with its IPPC Licence Register Number P0482-02 (IPC Licence 482 at time of granting). The Licence requires that the station shall maintain groundwater monitoring wells at two locations. Monitoring is carried out biannually for pH, hardness and Organohalogens. This routine monitoring of groundwater and records since commissioning indicate that the EPL power station is not having a negative impact on the underlying ground or groundwater.

7.2 IMPACT OF THE DEVELOPMENT The Peaking Power Plant does not involve emissions to ground and no impacts will therefore arise. Monitoring of groundwater will continue to be carried out in accordance with the terms of the station’s IPPC Licence.

7.3 MITIGATION No mitigation of impacts is required.

For inspection purposes only. Consent of copyright owner required for any other use. 7.4 CONCLUSIONS The proposed development will not result in significant impacts to soil or groundwater.

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8. LANDSCAPE

8.1 RECEIVING ENVIRONMENT The major effects of the existing EPL power station on the adjoining landscape arise from the built elements, their size and scale. The more important existing visual elements include the following: Boiler house (48 m high), Turbine hall (25 m high), Stack (70 m high and fitted with aviation warning lights), Cooling towers (15 m high) and Intermediate peat storage building (21.5 m high). In addition to the main structures there are smaller buildings, storage tanks, etc. Despite the sizes of the above, with some significant buildings being relatively close to the R401 Regional Road, the existing power station is well shielded from most views and it is only in very close proximity that the major elements are visible and even then their scale relative to the receiving landscape is not dominant. Visible plumes / emissions principally comprise water vapour and arise predominantly from the main stack and from the cooling towers. The meteorological conditions that promote visible water vapour occur for limited periods only and are cold temperatures, low wind speed and low solar heating. The site is not included in any landscape designation. The R401 Regional Road provides important regional and local links but is of no national importance in terms of tourism and leisure development. The passes to the south of Edenderry at a distance of about 3.5 km from the site and is an amenity of national importance. There are some short-distance views to the site but there are very few open longer distance views.

For inspection purposes only. 8.2 IMPACT OF THE DEVELOPMENTConsent of copyright owner required for any other use.

Visual intrusion arising from the construction phase will be short-term due to the limited extent of the works involved. The Peaking Power Plant involves low-profile structures. Each generating unit assembly will be about 5 m high with the air intakes at either end being 10 m high. The highest components of the assembly are the exhaust stacks, which are 20 m high. Plant of this type is already installed at ESB’s Rhode plant and the attached Figures 8.1 & 8.2 show the scale of the equipment that will be provided. The ancillary systems that are of consequence visually are the additional storage tanks for gasoil and water. The two tanks for storage of treated water will be up to 14 m tall but their location beside the existing cooling towers that are 15 m means that they will not be visually prominent. Storage tanks for untreated and treated gasoil will be < 10 m tall and will be located within a bund that will be approximately 2.5 m high. All items of plant and all ancillary systems will be founded at existing ground level and the proposal does not involve alterations in the site profile. While plant that differs slightly in composition from that described above may be offered

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by tenderers, any refinements and amendments to the design will not significantly alter the basic concepts to be incorporated in the development or the anticipated visual impacts. Air emissions will not be visible. There will be no visual impact arising from additional overhead high voltage transmission lines. All elements of the Peaking Power Plant will evidently be of significantly lower height than the main elements of the existing EPL power station. Furthermore, the additional stacks will not exceed the height of the Intermediate Peat Storage Building, which is the element of the existing plant that is closest to the proposed additional plant. Taking the above into consideration, the significant features of the existing power station will continue to determine the facility’s zone of visual influence and its degree of visibility. The existing power station will define the scale of the overall development within the broader landscape. No additional longer distance views will be created and further dominance within the landscape character will not arise. The character of the site is currently determined by the presence of the existing power station, whose development has significantly and permanently altered the character of the site from that of low lying marginal farmland to that of a heavily developed industrial site. The existing power station has created a visual impact within its wider landscape setting and has inevitably changed the former rural character of the immediate area to that of being predominantly industrial. The station has an important role as a landmark and reference in the landscape to residents and travellers. By virtue of its engineered structures and location, where visible, the Peaking Power Plant will be also perceived as being industrial in character. Its installation within the lands of the existing station and predominantly viewed together with existing structures from areas For inspection purposes only. already experiencing visualConsent ofimpact copyright ownerfrom required the stationfor any other will use. reinforce the existing industrial character rather than extending it to any significant extent. When moving away from the site and where it is visible, a point is reached where the power station becomes a distant industrial landmark in an otherwise essentially rural landscape. The addition of the Peaking Power Plant will not change that perception at such distances. The technology employed allows a facility which has a reduced visual mass when compared to the existing station, even though it has a broadly similar rated capacity. The Peaking Power Plant’s location within the site of the power station will result in less visual impact than if it were to be built on a separate site, due to the visual benefits of clustering large scale developments in the landscape. At present there are limited views into the site between the mounds at either side of the entrance roadway. The extent of facilities that are visible in such views will increase but this visibility only arises over a very short length of the R401 Regional Road. The location of the Peaking Power Plant in relation to the existing station will generally result in a coherent composition within the landscape. Overall, the existing power generating site context and the absence of the need to construct further overhead lines

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are undoubtedly very significant advantages in comparison with the limited extent of any adverse visual impacts.

8.3 MITIGATION Given the size of the Peaking Power Plant, it is not feasible to totally screen or conceal it. However, its principal elements are simple geometric shapes and as such have a substantial element of mitigation incorporated in their design. In addition, the repetitive or geometric arrangement of the layout adds to the sense of order in the development. A significant source of visual and landscape impacts at large facilities is frequently not the main structures but rather the smaller components such as conveyor systems, piperacks, marshalling areas, carparks, etc. which form an essential part of such development. To mitigate the impact of these areas within the existing power station mounding that is up to about 7 m high and is planted with shrubs and bushes is already provided along the road adjoining the site. These mounds substantially reduce the impact of low-level development associated with the main plant and provide a substantial screen to the power station when viewed from the R401 Regional Road. They also contribute to a sense of scale when the power station is viewed from a distance. This mounding will also aid in mitigating the impacts of the Peaking Power Plant. The use of non-reflective colours in grey or similar for surface finishes will aid in reducing impact Site lighting will be cowled and directed inwards to reduce night-time impacts.

8.4 CONCLUSIONS The proposed development will not result in significant visual impacts.

For inspection purposes only. Consent of copyright owner required for any other use.

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EPA Export 26-07-2013:00:59:36 Figure 8.1: P&W Twinpac Unit – Side & Front View

For inspection purposes only. Consent of copyright owner required for any other use.

EPA Export 26-07-2013:00:59:36 Figure 8.2: P&W Twinpac Unit – Side & Rear View

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9. ECOLOGY

9.1 RECEIVING ENVIRONMENT There are no environmentally designated areas within the site boundary of the power plant. Two sites of interest approximately 5 km from the site are as follows:

• The Long Derries, SAC, Site Code 000925 to the north east;

• The Grand Canal, NHA, to the north. Peregrine falcon has used the roof of the boiler house at the EPL power station periodically over a number of years for hunting purposes. Condition No. 10 of the grant of planning permission (Ref. PL.211173) for co-firing of the power station required that consultation should take place with the National Parks and Wildlife Service prior to the commencement of that development. This consultation has taken place. A number of studies have been undertaken, but, while EPL has provided a nesting box, no nesting has occurred. The care of the species is ongoing as the bird still visits the plant.

9.2 IMPACT OF THE DEVELOPMENT The area of the EPL power station site in which the Peaking Power Plant will be located is a heavily modified one in ecological terms and the proposal will not result in loss of significant amounts of habitat, albeit that it is already heavily modified and is no conservation value. Modelling was undertaken of the dispersion of air emission from the Peaking Power Plant in combination with the permitted emissions from the existing EPL Plant. (See Section 5.) The modelling demonstrates that air quality standards for SO2 and NO2 for the protection For inspection purposes only. of vegetation and ecosystemsConsent of copyright as outlined owner required in the for anyAir other Quality use. Standards Regulations, 2002

(SI 271 of 2002) will not be breached. The introduction of Peaking Power Plant will have no effect on the use of the general site by peregrine falcon.

9.3 MITIGATION No mitigation of impacts is required.

9.4 CONCLUSIONS The proposed development will not result in significant impacts to ecology.

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10. WATER

10.1 RECEIVING ENVIRONMENT Emissions to Water There are three main sources of trade effluent at the existing EPL power station, as follows:

• Cooling Water Discharge: Purging of water in the cooling water circuit is carried out to prevent a build-up of dissolved solids arising from evaporation of water in the cooling towers that could lead decreased plant efficiency.

• Boiler Blowdown: Boiler blowdowns comprise discharges of high purity boiler water in which accumulation of impurities has arisen.

• Water Treatment Effluent: Incoming water is treated to achieve a high purity. The treatment plant includes ion-exchangers and regeneration of these resins results in waste streams that are treated for pH correction prior to discharge. All wastewaters are ultimately discharged to the River Figile via a retention lagoon (settlement pond) that functions as a balancing mechanism to equalise the wastewater characteristics. Under normal operating conditions the quantity of trade effluent is estimated at 40 m³/hr. Effluents are neutralised to pH 6-9 prior to discharge There are two main sources of water used at the existing EPL power station as follows:

• River Water: Up to 200 m³/hr is used principally for producing plant cooling water.

• Well Water: Up to 10 m³/hr is used principally for producing demineralised water. For inspection purposes only. Consent of copyright owner required for any other use. The two on-site wells that provide the above supply to the water treatment plant are also used to provide the domestic supply to the site. The limestone aquifer into which the wells have been drilled has been the subject of a hydrogeological investigation, which has determined that one of the wells is capable of producing 400 m³/day, although only 120 m³/day is actually abstracted for demineralised water production. Based on the upper reach of annual operating hours at 1,500, the equivalent continuous additional demand is approximately 102 m³/day. Storm Water Discharge Rain water from impermeable areas at the power station flows into surface water drains that discharge to the settlement pond. Oil interceptors are provided on surface water drains serving carparks, truck unloading areas and all other areas where there is potential for loose oils. Any peat residues that may be entrained in the surface water are allowed to settle out in the settlement pond and from here water is pumped to the Figile River. The existing storm water emissions are monitored continuously for flow, temperature and pH, Total Organic Carbon and conductivity, and on a monthly basis for Biochemical

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Oxygen Demand (BOD), Suspended Solids, Total Dissolved Solids, Ammonia, Ortho- phosphate (as P), Mineral Oils, (as N) Petroleum Range Organics, Diesel Range Organics, and Oils, fats & greases. The discharge is visually inspected weekly.

10.2 IMPACT OF THE DEVELOPMENT Emissions to Water No additional waste water streams will be created by the proposed development. Water injection will be used for abatement of NOx formation and this will be sourced from the existing water treatment plant. The requirement for additional supply is well within the capacity of the existing plant. Current volumetric limits on the discharge to the settlement pond are as follows:

• Maximum in any one day: 1,500 m³

• Maximum rate per hour: 65 m³ ELVs applying to the above are as follows:

Parameter Emission Limit Value Temperature 25 ºC (max) pH 6 – 9 Toxicity 10 TU mg/l kg/day BOD 25 20 Suspended Solids 200 160 Total Dissolved Solids 4000 6000 Ammonia (as N) 5 4 Total phosphorous (as P) 0.2 0.16

Oils Fats & Greases For inspection purposes 20 only. 16 Consent of copyright owner required for any other use. Mineral Oils 20 16 Residual Chlorine 0.02 - The development of the Peaking Power Plant will not result in exceedance of the above volumetric limits or ELVs. Adequate water supply is available without the need to identify new sources and the settlement pond already receives treated discharges from the water treatment plant. Storm Water Discharge A large part of the site area will remain unpaved, allowing rainwater to percolate freely into the ground. Rainwater will be collected in the fuel storage bund, in the transformer bunds and from paved site areas. Clearly, the volume of additional storm water generated from the transformation of certain areas to impermeable surface will be so low as to be of no consequence.

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10.3 MITIGATION The storm water discharge will be routed via an oil interceptor. No other mitigation of impacts is required.

10.4 CONCLUSIONS The proposed development will not give rise to significant environmental impacts.

For inspection purposes only. Consent of copyright owner required for any other use.

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11. NOISE

11.1 RECEIVING ENVIRONMENT Noise limits for operation of the existing EPL power station at the nearest Noise Sensitive Location (NSL) are set in IPPC Licence Register Number P0482-02. Condition 4.3.1 of the Licence requires as follows:

Noise from the activity shall not give rise to sound pressure levels (Leq,30 mins) measured at specified noise sensitive locations which exceed the limit value(s). Schedule B Emissions Limits specifies as follows in B.4 5 Noise Emissions:

Daytime dB(A) L (30 minutes) Night-time dB(A) L (30 minutes) Aeq Aeq

Note 1 Note 1 55 45

Note 1: There shall be no clearly audible tonal component or impulsive component in the noise emission from the activity at any noise sensitive location Annual noise surveys to monitor and ensure continued compliance with noise limits are

conducted as one of the conditions of the Licence. The LA90 noise level represents the sound pressure level exceeded for 90% of the monitoring period and is recognised as a good indicator of background noise, i.e. excluding peak noise events such as intermittent road traffic. Since the existing EPL power station operations are relatively constant, it is considered

that the LA90 values provide a reasonable representation of the facility’s contribution to ambient noise. Noise levels from the existing EPL power station are in compliance with the above.

11.2 IMPACT OF THE DEVELOPMENT For inspection purposes only. Consent of copyright owner required for any other use. Construction Construction is expected to take place over a short period and will generally be restricted to daytime hours. Construction works will effectively be limited to a small amount of excavations and concreting and subsequent installation of pre-assembled components. Excavations will be necessary for foundations and for cabling and concreting will be required for construction of foundations. These activities tend to be the noisiest activities during most construction projects. It is not envisaged that foundations for the main structures will require piling. Construction noise will be assessed in accordance with BS 5528:1997 – Noise and vibration control on construction and open sites. While no formal limits exist for construction noise, in recognition of the temporary nature of activities, noise limits that are higher than those associated with permanent installations are generally acceptable. Standards that have been applied to large civil engineering projects tend to fall in the

range of 65-75 dB(A)Leq (12 hour) for daytime construction activities. It is not expected that noise from construction activities will create significant impacts.

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Operation The various plant components are contained in acoustic enclosures and there are no particular issues associated with plant start-up or shut down. There are no significant sources of environmental vibration associated with the Peaking Power Plant. The most potentially significant source of noise from the Peaking Power Plant is that radiated from the top of the stack. This is broad band combustion noise from the gas turbine. A further potential noise source is the air inlet. This can emit blade-passing frequency noise if not attenuated. Silencing of this source is straightforward and poses no problems. The Bruel & Kjaer Predictor Type 7810 software package was used to model the noise levels to be emitted to the surrounding environment from the Peaking Power Plant. Predictor Type 7810 is a proprietary noise calculation package for computing noise levels in the vicinity of industrial sites. Calculations are based on the International Standard ISO 9613-2: 1996 “Acoustics – Attenuation of Sound Outdoors – Part 2: General Method of Calculation. The full Noise Modelling Report is presented in Appendix B hereto. Noise data specific to proposed the plant and recorded data of ambient conditions at the nearest NSL provided the baseline against which the incremental effect of the Peaking

Power Plant was assessed. For the reasons previously described, the ambient LA90 values were used to represent the existing noise regime. Noise level predictions were made for a grid of receiver points around the site and isocontours of the noise levels thereby generated to give an overall picture of the spatial distribution of noise levels within the grid. Table 11.1 details the predicted maximum noise levels (dBA) at the nearest noise sensitive location due to the addition of the Peaking Power Plant and its cumulative impact with the existing EPL power station.

Table 11.1: Predicted Noise For Level inspection and purposes Cumulative only. Effects Consent of copyright owner required for any other use.

Receiver Predicted Noise Ambient Noise Cumulative Noise

Level dBA Level dBLA90 Level dBA

NSL Daytime 37 47 47

NSL Night-time 37 45 46

As would be expected from plant designed for location in urban areas, the noise impact of the Peaking Power Plant is very low. The results of the cumulative noise modelling show that the noise contribution from the Peaking Power Plant has a minimal effect on the current noise levels at the nearest NSL. It is be noted that the human ear cannot perceive changes in sound level of less than 3 dBA. The currently applying noise limits for operation of the existing EPL power station will continue to apply following installation of the Peaking Power Plant and ongoing compliance with these limits will ensure that no significant impacts will arise.

11.3 MITIGATION The Peaking Power Plant will be located at the most distant feasible position within the

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EPL power station site relative to the nearest noise sensitive location. The existing buildings and plant provide a significant element of screening. Construction Heavy construction activity will be carried out during daytime hours only and construction plant and equipment will comply with the requirements of the EC (Construction Plant and Equipment) (Permissible Noise Levels) Regulations. Construction noise will also be mitigated by adopting recognised good practice. Operation The generating plant to be used is designed for use in urban areas and a high degree of noise attenuation will be built into its design.

• Turbine noise radiated from the gas discharge at the top of the stack is attenuated by a broadband high-temperature discharge silencer.

• Combustion turbine compressor noise is attenuated by an appropriate inlet silencer.

• Items of plant that are sources of noise are enclosed in appropriate acoustic enclosures.

• Transformer noise is minimised by design and by screening as well as by blast walls provided for fire/safety protection.

11.4 CONCLUSIONS It is concluded that noise generated at the Peaking Power Plant will not impact significantly on the environment.

For inspection purposes only. Consent of copyright owner required for any other use.

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12. TRAFFIC

12.1 RECEIVING ENVIRONMENT Under the grant of planning permission in 1998 (Ref. PL 19.107858) for construction of the existing EPL power station, it is permitted to transport up to 100,000 t of fuel to the plant by road annually. However, to date all transport of fuel to the plant has been by rail. Forecasts of the likely traffic impacts associated with road haulage of 100,000 t of peat annually were assessed as part of that application. The calculations provided with the application forecasted that 20 vehicles per day would likely be generated by the then proposed and subsequently permitted transport of fuel. Under the grant of planning permission in 2005 (Ref. Ref. PL.211173) for co-firing of the existing EPL power station, it is permitted to transport up to 100,000 t of auxiliary fuel to the plant by road annually. The calculations provided with the application forecasted that 15 vehicles per day would likely be generated by the then proposed and subsequently permitted transport of auxiliary fuel. Forecasts of the likely traffic impacts associated with this road haulage were assessed as part of that application against the background of the previously permitted delivery of 100,000 t of peat annually by road. Traffic surveys were conducted in September 2003 as part of the assessment of impacts of the co-firing proposal. The 12-hour flow on the R401 Regional Road at the site entrance was recorded as 1,307 vehicles of which 218 vehicles (16.7%) were Heavy Goods Vehicles (HGVs). It is not believed that either traffic volumes or patters have changed in the interim to the extent of invalidating the survey results. Based on this data, the estimated Annual Average Daily Traffic (AADT) from the National Roads Authority’s RT201 Expansion Factors for Short Period Traffic Counts was calculated as being in the range 1,347 – 1,788 vehicles. For inspection purposes only. Data showed entry / exitConsent of of vehicles copyright owner at requiredthe EPL for any entrance other use. as being 86 cars and 8 HGV

(two-way total flow) over the 12-hour survey period. The application on which the initial planning permission was based forecasted traffic generation at 380 AADT which included 70 “other delivery / visitor vehicles”, a significant proportion of which would evidently be HGVs. This is significantly greater than surveyed traffic.

12.2 IMPACT OF THE DEVELOPMENT The regional road network, which has been improved by Offaly County Council since the construction of existing EPL power station, will be adequate to meet the proposed traffic loads during both construction and operation. Construction The major components of the plant will be preassembled, thereby reducing the number of deliveries involved. In addition to items of plant, the major requirement will be for concrete for construction of foundations. Overall, traffic arising from the construction phase will be short-term due to the limited

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extent of the works involved and significant impacts are not expected. Operation When in operation, fuel consumption at the proposed plant will be at a rate of 12.5 t/hr of gasoil for each of two units. With the proposed plant likely to operate up to 10 hours per day when in operation, the haulage of gasoil is likely to generate a maximum of 10 vehicles per day. Haul routes will be confined to the Regional Roads and the direction of approach is not significant in relation to traffic flows. If this is taken as occurring constantly, which it evidently will not, and allowance is taken for full deliveries of 100,000 t of peat annually and 100,000 t of auxiliary fuel annually, the total arising would be approximately 45 vehicles daily. This is significantly less that that forecasted in the application on which grant of permission Ref. PL 19.107858 was made. The Institution of Highways and Transportation outlines a structured approach to undertaking transport assessments in its Guidelines for Traffic Impact Assessment (1994). These guidelines are recognised as representing best practice and they recommend that a traffic impact assessment should normally be produced where either of the following thresholds is exceeded:

• Additional traffic exceeds 10% of the existing two-way traffic on the adjoining road (130 – 180 vehicles approximately, based on survey data from September 2003).

• Additional traffic exceeds 5% of the existing two-way traffic on the adjoining road where there is traffic congestion (65 – 90 vehicles approximately, based on survey data from September 2003). The forecasted increase in traffic is lower than either of the above thresholds and a separate traffic impact would not normally be warranted. By implication, the impact on

traffic is not significant. For inspection purposes only. Consent of copyright owner required for any other use. Insofar as fuel importation is concerned, the existing EPL power station currently generates no HGV traffic and traffic generated by this proposal will essentially be new to the local roads network in the vicinity of the power station. Given that the generation of 310 employee vehicles and 70 other deliveries / visitors was previously considered acceptable, it is concluded that proposed level of additional traffic associated with this proposal is acceptable. In practice, with the forecasted annual hours of operation being 1,000 hours, a total annual traffic of 1,000 deliveries is envisaged. The average daily traffic with deliveries restricted to week-days will be less than 4 vehicles rather than the maximum of 10 considered above. Furthermore, it is assumed in the above that all traffic will approach and leave that plant in the same direction, which is evidently not necessarily the case. Actual impacts will be even less than considered and the existing road network has the capacity to cater for the increased traffic arising from this proposal.

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12.3 MITIGTION No mitigation of impacts is required.

12.4 CONCLUSIONS The proposed development will not give rise to significant environmental impacts.

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13. MATERIAL ASSETS

13.1 ENERGY SUPPLY Demand for electricity is a key indicator of performance and growth in the national economy, with growth in demand for electricity actually surpassing national economic growth. Sustained economic growth requires that adequate electricity generating capacity be available. The last two decades have seen significant growth in demand for electricity. Peak demand was 2,460 MW in 1990/91 and reached 5,035 MW in 2006. Further growth is expected with peak demand possibly reaching up to 6,000 MW by 2010. EPL is already engaged in meeting the energy demand in Ireland and the Peaking Power Plant will facilitate EPL’s ongoing contribution to ensuring that adequate electricity supplies are available to support economic activity and growth in Ireland. It will ensure that national economic development is not constrained by shortfalls in the availability of electric power. No mitigation of impacts is required.

13.2 LAND USE The use of the site for electricity generation is well established. New developments have the potential to adversely impact on adjoining existing development through factors such as building density, standards of construction, overall appearance of the site, overlooking, overshadowing, lighting, traffic generation, severance of access and general nuisance such as noise and dust.

EPL is well established at Forthe inspection site purposesand it only. is unlikely that the proposed incremental Consent of copyright owner required for any other use. development will cause any change in the values of adjoining properties or alter public perceptions of the area and its amenities. There will be no overlooking or overshadowing and continued use for electricity generation will not adversely impact on other land uses in the area and is compatible with the Offaly County Development Plan. No mitigation of impacts is required.

13.3 INFRASTRUCTURAL SERVICES These impacts include the effects that arise as a result of services required by a development such as telecommunications, water, electricity supply, sewage disposal, solid waste disposal and the local road network. Since the proposed development will only involve minor infrastructural changes to the existing power station, there will be no requirement to provide additional services to the site. It is envisaged that existing services serving the site will be sufficient to cater for the proposed development. The development will not place any additional demand on the existing electricity network,

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but rather will contribute to providing a constant reliable supply to the national grid and to electricity users throughout Ireland. The existing telecommunications serving the power station will be sufficient to meet the needs of the proposed development. There will be an increased requirement for water supplies. See Section 9. No new significant solid waste streams will be created The amounts of waste arising will vary from year to year, depending on the level of operation and maintenance activity. The principal waste materials arising will be waste oils, a waste stream that is already managed within the existing EPL power station. No mitigation of impacts is required.

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14. CULTURAL HERITAGE

14.1 RECEIVING ENVIRONMENT Cultural heritage aspects of the site were investigated initially in 1995 and no sites of archaeological interest were identified. A further more detailed investigation, which comprised a documentary search and field inspection, was undertaken in 1998. The study concluded that there was no evidence of any archaeological activity on the site.

14.2 IMPACT OF THE DEVELOPMENT The proposed development does not involve use of any greenfield or previously undeveloped area of the site.

14.3 MITIGATION No mitigation of impacts is required.

14.4 CONCLUSIONS The proposed development will not give rise to significant environmental impacts.

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15. INTERACTION OF IMPACTS

There is no foreseen significant interaction of the impacts described in the statement.

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EPA Export 26-07-2013:00:59:37 APPENDIX A AIR EMISSIONS MODELLING REPORT

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EPA Export 26-07-2013:00:59:37 APPENDIX B NOISE MODELLING REPORT

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