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EPA Office of Climate Change, Licensing and Resource Use PO Box 3000 Johnstown Castle Estate Co

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EPA Office of Climate Change, Licensing and Resource Use PO Box 3000 Johnstown Castle Estate Co . .. .. .. €s*Power Generation Electricity Supply Board Electricity Supply Board Poolbeg Generating Station, Pigeon House Road, Dublin 4, Ireland. Bothair Thig Choluirn, Baile Atha Cliath 4, Eire. Phone: 353-1-6685300 Fax: 353-1-668 5545 Fon: 353-1-668 5300 Facs: 353-1-668 5545 I Website: www.esb.ie Eithrehn Greashin: www.esb.ie EPA Office of Climate Change, Licensing and Resource Use PO Box 3000 Johnstown Castle Estate Co. Wexford 20thNovember 2008 Re: Technical Amendment to IPPC Licence Reg. No. 577- 02 Schedule 2(i) Emissions to Water Dear Sir/Madam Under Clause 96 of the Protection of the Environment Act 2003, ESB would like to apply to the Agency for a Technical Amendment of the above licence for Poolbeg Generating Station. The amendment is requireld to Schedule 2(i) Emissions to Water, Emission Point Reference No. SW2, Water treaihnent neutralisation tank - Units 1,2 and 3, Ammonia ELVs. For inspection purposes only. Consent of copyright owner required for any other use. The proposed amendment to the licence conditions are outlined in the attached. Regards, Service Manager EPA Export 26-07-2013:11:34:25 Plool beg Power Station IPPCL Technical Amendment Application (Reg. Ref. 577-02) Introduction Modification is requested to Schedule 2(i) Emissions to 0. SW2- Water Treatment Neutralisation tank - Units 1, 2 The following changes to Ammonia ELVs are requested; Ammonia (as N): daily 350 mg!l, mass 70 kg/day. Current ELV - Ammonia (as N): daily 100mg/l, mass 20 kg/day ESB are requesting a technical amendment due to difficulties in adhering to the current licence ELVs. ESB has been in contact with the C)EE on this matter previously (1 1/12/06, 13/07/07 and 15/05/08) and has now been advised to contact the Office of Climate Change, Licensing and Resource Use, for a Technical Amendment (EPA Ref. P0577-02/gc14kf).A copy of all previous correspondence on this matter is attached in Appendix 2. Background Ammonia in Power Plants Ammonia is used for corrosion control in the steam/ water circuit of power plants. Corrosion in boiler tubes leads to boiler tube kaks or possible tube ruptures with consequential safety implications to personnel ancl plant. Ammonia is injected into the boiler feedwater and circulates in both steam and water in order to achieve a suitable alkaline pH which will minimise the extent of corrosion ori the ferrous material in the steam/water circuit. A volatile alkalising agent is required and it is international practice to use Ammonia in high pressure/temperature plants, there being no other chemical as effective available. Contaminant ions are highly ccirrosive For inspectionin high purposes pressure only. steam plant. A 'Condensate Polisher Plant' (CPP) is an essential iternConsent of ofplant copyright used owner in required high forpressure any other use. steam/water cycles. The CPP strips or 'polishes' the condensed water in the plant cycle of all contaminant ions such as Na, CI and SO4, however, the ammonia used for corrosion control is also stripped from the water. Once exhausted, the resin units used in a CPP are required to be regenerated, a process which occurs at intervals of 20 to 215 days. In the regeneration process Ammonia is stripped from the resin and discharged to the Water Treatment Plant (WTP) neutralisation sump with other effluent from the WTP. Year Ammonium No. Polisher Regens Running Load Factor Hydroxide 35% m3 No. % 2004 8- 31 62 2005 9- 28 61 2006 6 30 65 2007 3- 15 60 2008 2(YTD) 9(YTD) 55( YTD) 1 EPA Export 26-07-2013:11:34:25 ‘I ‘ Load factors will reduce further again in 2009, and closure of the Thermal Station as per CER-ESB agreement is scheduled for early 2010. The current license parameters relate to a continuous process where quarterly grab samples are taken. However this fails to reflect that CPP regeneration is a “batch” process which occurs on an infrequent basis. Since June 2006 ESB has been rnonitoring ammonia levels from the water treatment plant discharges immediately following regeneration of a CPP (Appendix 1). These indicate the ESB’s inability to routinely remain within the license conditions during these “batch” regeneration periods. However, it !should be noted that the average daily discharges outside regeneration periods are well within limits. Justification for amendment to €LVs Considering the worst case discharge of 61 kg/day of ammonia and with only 15 regenerations through tile year this equates to an annual discharge of only 915 kg. This is well within a permissible yearly Licence limit of 7300 kg. The actual consumption of Ammonia has also been dropping over the last few years as a direct reflection of load factor. From the table above only 3 m3 of ammonium hydroxide was consumed last year and 2 m3 to date in 2008. The theoretical maximirm Ammonia that U1 and 2 polisher resins are designed to absorb and therefore ccluld discharge during regeneration is 112kg. This is calculated from condensate polisher resin manufacturers’ product data. Assuming 15 polishers through the year this equates to maximum annual discharge of only 1680kg. This is well under the permissible yearly licence limit is 7300 kg. However in practice a polisher is never fully e:xhausted when it is regenerated so this figure could never be reached. The amount of ammonia discharged from Poolbeg is a small fraction of the expected annual discharge of ammonia from the Ringsend wastewater treatment plant at the same discharge point. For inspection purposes only. Consent of copyright owner required for any other use. Other Power Station IF’PC Licences Generating Station IPlPcL Parameter Emission Limit Value Reg. No. mgll kglday ESB Aghada PO561-04 Ammonia 300 80 ESB Great Island P0606-02 Ammonia nla 34 ESB Tarbert P0607-02 Ammonia (as N) nla 100 Synergen Ringsend P0486-01 Ammonia (as N) 500 30 ESB Poolbeg P0577-02 Ammonia (as N) 100 20 While it is realised that ELVs for the different power stations take account of particular local situations, nevertheless it does appear that the Poolbeg ELVs are unduly restrictive. Ammonia removal technology ESB has enquired from industry experts abroad as to the possibility of the removal of ammonia from the effluent by e.g. steam stripping. The information is that such removal of ammonia is only feasible for power stations that use DENOX (nitrogen oxide removal) technology, as the condensation and concentration of ammonia is very cost intensive. 2 EPA Export 26-07-2013:11:34:25 In the context of a power station with limited remnant life, major expenditure on ammonia removal technology, assuming it were feasible, could not be justified. Environmental Impacit While dilution is not the solution it is an important consideration to take into account when assessing the impact on the exterrtal environment. The discharge from SW2 is pumped to the Cooling Water channel before the combined effluent from the station enters the external environment. The nominal flow rate of Cooling Water is 52,500m3 per hour, before being discharged into the river Liffoy along a 200m ouFall channel. For example (Appendix 1, 03/05/07) at a concentration of318 mg/l and 125 m /hr in the WTP discharge, this equates to 0.76 mg/l in the Cooling water outfall. Summary The current IPPC Licence SW;! - water treatment neutralisation tank emission limit values for ammonia are proving onerous to ESB and on occasion impossible to meet. Discharge of ammonia from SW2 is not consistent on a daily basis but peaks during a polisher regeneration discharge which occurs approximately once a month depending on running regime. 0 There would be no significant Einvironmental impact resulting from the requested increase to the ELVs. e The reduced operation of Poolbeg power station Units 1, 2 and 3 will reduce the number of condensate polisher regenerations (i.e. ammonia discharges) to a fraction of those heretofore. 0 ESB discharges of ammonia at this location are a small fraction of those arising from the Dublin City Council Ringserid wastewater treatment plant discharges. e The discrepancy between the Poolbeg power station ELVs and the ELVs for other power stations appear anomalous. For inspection purposes only. Consent of copyright owner required for any other use. 0 Removal of ammonia by e.g. steam stripping would be ,impractical and prohibitively expensive, especially in the context of the remnant station life. 0 ESB wish to amend the daily and kglday licence limit, but do not wish to amend the yearly Ammonia mass discharge figure. Conclusion In view of the reasons as surnmeirised above, ESB considers that the current ELVs are restrictive, produce no environmental benefit, and that attempting to achieve same, even if possible, would be unnecessarrly e:lcpensive in the light of the anticipated low load operation and closure over the next few years. ESB would appreciate if the Agency would consider ESB’s request for a technical amendment to the ELVs as per the following table. 3 EPA Export 26-07-2013:11:34:25 . ............ ... ..... .~......... ............ ...... Emission Point Reference No.: SW2 -Water treatment neutralisation tank - Units 1, 2 and 3. Name of Receiving Waters: Liffey Estuary (Cooling water outfall - via Station Drain) Location: 32090E, 23379N Volume to be emitted: Maximum in any one day: 400 m3 Maximum rate per hour: 250 m3 6-9 I Hourly (mgll) Daily (mgll) Kglday Suspended Solids 900 320 128 Ammonia (as N) For inspection purposes only. Consent of copyright owner required for any other use. 4 EPA Export 26-07-2013:11:34:25 Appendix 1 : Historical Ammonia Analysis at SW2 following polisher regeneration. Concentration Daily Mass y/s+-y=j1 Date Ammonia 1 Volume m3 Volumelhr Ammonia 2006 I 16/06/06 1 96 I195 I162 I19 I 179 2007 23/04/2007 323 101 61 30/04/2007 289 56 03/05/2007 318 125 32 1 01/08/2007 1 252 1 131 I103 I 33 I ~19/10/2007I117 1 Lil 160 20 2611 0/2007 324 71 16 I 12/12/2007 I 243 I 174 I 121 42 I , 1 13/12/2007 128 20'1 I00 26 2008 07/02/2008 228 IT:? For inspection purposes79 only.
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