APPLICATION UNDER SECTION 36 ELECTRICITY ACT 1989: CONSENT TO CONSTRUCT AND OPERATE AN ELECTRICITY GENERATING STATION DAMHEAD CREEK 2

Environmental Statement Non Technical Summary

June 2009

Dalton Warner Davis

Contents

LIST OF ABBREVIATIONS ……,..…………………………………..……….…………………………………1

SECTION 1: Introduction ………………………………………………..………………...…………3 1.1 The Development – Damhead Creek 2 3 1.2 The Developer – ScottishPower 3 1.3 The Purpose of this Document 3

SECTION 2: The Consents Process ……………………………………..……………….…………….5 2.1Consents Required 5 2.2Contact Information 5

SECTION 3: The Need for the Development …...………………………………………..…….7 3.1 Background 7 3.2 Current Power Generation and Electricity Demand 7 3.3 History of Power Generation in the 8 3.4 The Development of Damhead Creek 2 8

SECTION 4: Development Summary …………………………………………………………………….9 4.1 Application Site 9 4.2 Application Site Surroundings 11 4.3 Operational Details 12 4.4 Process Description – The Combined Cycle Principle 13

SECTION 5: Consultations and Additional Studies ………………………………...…..…………..15 5.1 Overview 15 5.2 Scoping Study 15 5.3 Residents’ Information Days 15 5.4 Combined Heat and Power (CHP) Assessment 15 5.5 Carbon Capture Ready (CCR) Feasibility Study 16 5.6 Additional Documents 16 5.7 Future Consultations 16

SECTION 6: The Environmental Impact Assessment ……………………………...……….…………17 6.1 Overview 17 6.2 Air Quality 17 6.3 Noise 18 6.4 Landscape and Visual Impact 18 6.5 Ecology 19 6.6 Water Quality 20 6.7 Geology, Hydrology and Land Contamination 20 6.8 Traffic and Infrastructure 21 6.9 Socio-Economics 21 6.10 Cultural Heritage 22 6.11 Cumulative Impacts 23 List of Abbreviations

AQMA Air Quality Management Areas AQS Air Quality Strategy BERR Department of Business, Enterprise and Regulatory Reform CCGT Combined Cycle Gas Turbine CHP Combined Heat and Power CHPA Combined Heat and Power Association CHPQA Quality Assurance for Combined Heat and Power

CO2 Carbon Dioxide CPI Confederation of Paper Industries DECC Department of Energy and Climate Change DEFRA Department for Environment, Food and Rural Affairs

DLN Dry Low NOx DTI Department of Trade and Industry EHO Environmental Health Officer EIA Environmental Impact Assessment EPR Environmental Permitting Regulations ES Environmental Statement ESA Environmentally Sensitive Area EU ETS European Union Emissions Trading Scheme GW gigawatts GWe gigawatts electrical ha hectare HRSG Heat Recovery Steam Generator km kilometre kV kilovolt LCPD Large Combustion Plant Directive

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m metre MW megawatts MWe megawatts electrical MWth megawatts thermal NGC National Grid Company NHS National Health Service NNR National Nature Reserve

NO2 Nitrogen Dioxide

NOx oxides of nitrogen or Nitrogen Oxides PB Parsons Brinckerhoff RSPB Royal Society for the Protection of Birds SEEDA South East of England Development Agency SPA Special Protection Area SSSI Site of Special Scientific Interest UK United Kingdom

PAGE ## 1. Introduction The Purpose of this Document This document is a Non-Technical Summary of the Environmental Statement (ES) which has The Development – Damhead Creek 2 been prepared to accompany the application for consent to construct and operate an ScottishPower (DCL) Limited (ScottishPower) electricity generating station under Section 36 proposes to construct and operate a Combined of the Electricity Act 1989 for the proposed Cycle Gas Turbine (CCGT) Development. (Damhead Creek 2 or ‘the Development’). The application for Section 36 Consent is made Damhead Creek 2 will constitute Phase 2 of the to the Secretary of State at the Department of Damhead Creek Power Generation Energy and Climate Change (DECC). The ES Development, Phase 1 of which is already in provides extensive details of the Environmental existence and comprises the existing Damhead Impact Assessment (EIA) which was undertaken Creek CCGT Power Station on the Hoo for the Development in full accordance with the Peninsula in . requirements of the Electricity Works Damhead Creek 2 will be located on land (Environmental Impact Assessment) (England immediately east of the existing Damhead and Wales) Regulations 2000 (EIA Regulations). Creek CCGT Power Station which was The undertaking of the EIA followed the commissioned in 2001. completion of an initial scoping study between Damhead Creek 2 will provide 1000 megawatts December 2006 to April 2007 by ERM and a (MW) of power generation capacity at site rated secondary Scoping Study in March 2009 by conditions, and will burn only and Parsons Brinckerhoff Ltd (PB). During these together with the existing power station will Studies, both statutory and non-statutory provide electricity for 1.5 million homes . consultees were consulted to help define the scope of the investigations. The site location can be seen in Figure 1. The resulting ES is considered to include a robust assessment of the Development’s likely The Developer – ScottishPower impact on the environment. The ES considered ScottishPower is an international energy impacts of the Development on: air quality; company employing around 10 000 staff world- noise; landscape and visual amenity; ecology; wide. Through its business of electrical water quality; geology, hydrology and land generation, transmission and distribution contamination; traffic and infrastructure; socio- services, ScottishPower provides electricity to in economics; and cultural heritage. In addition, excess of 5.2 million homes and businesses cumulative impacts were also assessed. across the UK. In addition to the Non-Technical Summary and Through the acquisition of ScottishPower in the Environmental Statement, a number of April 2007 by Iberdrola, the combined Group documents have been prepared in support of has become the fourth largest electricity this application including a: Carbon Capture company in the world, generating over Ready (CCR) Feasibility Study; Combined Heat 40 000 MW of electricity and supplying almost and Power (CHP) Assessment; Design and 22 million customers world-wide. Access Statement; Flood Risk Assessment; Statement to Inform; and Transport Within the UK, ScottishPower owns and Assessment. Further details on these operates a range of electricity generating plants, documents are provided in Section 5 of this which include gas fired power stations; document. fired power stations; hydro-electric pumped storage stations and wind farms. ScottishPower Furthermore, a number of Residents’ is an expert in the operation of gas fired power Information Days have been held in the area of stations, with its UK generation portfolio the Development to help inform members of including around 2000 MW of CCGT plants. the general public about the EIA undertaken Iberdrola’s world-wide generation portfolio and the details of the Section 36 application to includes a further 10 000 MW of CCGT plants. DECC. The existing Damhead Creek CCGT Power Copies of the Section 36 Application (with a Station is owned and operated by plan showing the land to which it relates), ES ScottishPower, and has a successful working (explaining ScottishPower’s proposals in more record since it was commissioned in 2001. detail and presenting full analysis of the PAGE 3 environmental implications) and Non-Technical Further information, including an electronic Summary of the ES may be inspected during copy of the Section 36 application, can be normal office hours at the following addresses: obtained directly from ScottishPower by writing to: x Hoo St Werburgh Library, Church Street, Hoo St Werburgh, , Kent, ScottishPower ME3 9AL; Commercial Development 4th Floor West x Medway Council, Gun Wharf, Dock Road, Cathcart Business Park Chatham, Kent, ME4 4TR; and, Spean Street x Damhead Creek CCGT Power Station, Glasgow Kingsnorth, Medway, Kent, ME3 9TX. G44 4BE

(Based upon the 2008 Ordnance Survey 1:50000 FIGURE 1: SITE LOCATION KEY: scale data map with the permission of Her Majesty's Stationary Office © CROWN COPYRIGHT)

Site Location

PAGE 4 operated on a day-to-day basis. 2. The Consents Other miscellaneous consents and permits will be sought as necessary throughout the course Process of the project.

Consents Required Contact Information Damhead Creek 2 will require consent under Should you wish to make a representation Section 36 of the Electricity Act 1989. This regarding the Section 36 application, then this states that generating stations of greater than should be forwarded to either Medway Council 50 MW electrical output shall not be Planning Department or the Electricity Supply constructed, extended or operated without Consents team at DECC. Addresses for these permission from the Secretary of State at the groups are as follows: DECC. For the Attention of The Chief Executive Consent under Section 36 of the Electricity Act removes the need for the Development to Medway Council obtain planning permission directly from Development Control Medway Council, though the council remains a Gun Wharf Statutory Consultee to the planning process. Dock Road Should the proposed Development be granted a Chatham Section 36 consent by DECC then this will also Kent constitute planning permission under the Town ME4 4TR and Country Planning Act 1990. For the Attention of Mr Gary Mohammed In due course, ScottishPower will separately Electricity Supply Consents apply to the Environment Agency for an Department of Energy and Climate Change Environmental Permit under the Environment 3 – 8 Whitehall Place, Agency Environmental Permitting (England and London Wales) Regulations 2007 (EPR). This permit will SW1A 2HH define the manner in which the Development is

PAGE ## generate more electricity in the areas where it is 3. The Need for the needed. This not only helps negate the need for long power lines, but also gives the added Development environmental benefit of reducing electrical transmission losses which occur as the electricity is transported along the transmission Background lines. Electricity is essential in a modern society. It The UK currently has a generating capacity of powers a huge variety of things, from around 75 gigawatts (GW) based on various computers to lights to kitchen appliances to technologies, the most significant contributions industrial plant. Therefore a growing economy, being from coal fired power stations. However, combined with the innovation to develop the LCPD requires power stations to adhere to electronic devices, leads to a considerable stringent air quality standards. Several plants upwards pressure on the UK energy market. throughout the UK, totalling 12 GW, have opted-out of this obligation and, as such, are At present, a number of substantial challenges required to close by the end of 2015 or after face the UK energy market, including: 20 000 hours of operation after 1 January x The forced retirements of existing 2008 , whichever is sooner. nuclear and coal / oil plant for safety and The operating regimes of these opted-out environmental reasons; and plants will become a commercial decision to be x The ever rising demand for electricity. taken by the plant operators. This means that it will be impossible to predict the timing and Coincident with this rising demand, the UK’s impact of the LCPD on the UK generation existing fleet of plant is ageing, capacity. However, the Energy Markets Outlook and European measures (via the Large Report, produced by BERR (now DECC) and Combustion Plant Directive (LCPD)), which OFGEM in October 2007, has forecast that, require the reduction of emissions from coal based on historical operating patterns, the and oil power plant, will force either their allowance of hours will be reached, by some of modernisation or closure. Therefore, in the the opted-out plants, by early 2012. absence of new-builds or life-extensions, actual electricity production is set to reduce. In addition, around 7.4 GW of generating capacity will be lost by 2020 due to the planned closure of some nuclear generation facilities. Current Power Generation and Electricity Demand The 2007 White Paper on Energy – ‘Meeting the Energy Challenge’ (published by BERR) officially Currently, the bulk of power generation in the recognised the need to replace the retiring UK is located in northern areas of England and power generation capacity in the UK, stating Scotland, either in the vicinity of UK coal fields that: or on the coast where fuel supplies can be “If we are to maintain levels of electricity readily imported. This situation is much the generation capacity equivalent to those same for many renewable forms of generation available today, then new power stations including wind farms and hydroelectric plants need to be built in time to replace these that are generally situated in more remote closures and to meet increases in demand. locations where the resources they require are On this basis, around 20 to 25 GW of new more abundant. power stations will be needed by 2020”. However, the main electricity demand in the UK is in the south (particularly London), the south An additional challenge is presented via the ever rising demand for electricity. Estimates east, the south west and some parts of the 1 Midlands where demand is increasing. from the National Grid Forecasts indicate that between approximately 5.0 GW (Base Demand) The current situation, therefore, requires power and 13.1 GW (High Demand) of new generation to be transported to these areas of high capacity, in addition to that required to replace demand via transmission lines belonging to the closures, will be required by 2020. National Grid. As demand increases, the need to reinforce the electricity transmission system Therefore, meeting the rising energy demands arises and more transmission lines are required. and overcoming the expected losses to the current UK generating capacity represent a An alternative to system reinforcement is to substantial challenge.

PAGE 7 History of Power Generation in the Hoo Peninsula The Hoo Peninsula has a history of . In the 1970 and 1980s, two power stations were constructed. These were the: Kingsnorth Coal Fired Power Station (Kingsnorth Units 1 – 4) with an output of 2000 MW; and, Oil Fired Power Station with an output of 3300 MW. This gave a total generation capacity of 5300 MW on the Hoo Peninsula. However, the generating capacity of the Isle of Grain Oil Fired Power Station has subsequently been reduced to 1320 MW (and may soon be closed completely) and Kingsnorth Coal Fired Power Station is expected to close before 2016. This generation capacity has been, and will be, replaced by existing and proposed power stations. These include the: x Existing Medway CCGT Power Station (750 MW); x Existing Damhead Creek CCGT Power Station (792 MW); x Grain CHP power station (1200 MW), under construction; x Proposed Kingsnorth Super-Critical Coal Fired Power Station (Kingsnorth Units 5 and 6) (1600 MW); and

x Proposed Damhead Creek 2 (1000 MW).

The Development of Damhead Creek 2 Damhead Creek 2 power station is intended to help bolster the generating capacity available to the UK National Grid whilst simultaneously developing a power station close to London, a centre of high demand.

1 Information from National Grid : Seven Year Statement (2009) CCGT Power Station (when Damhead Creek 1 4. Development was to be constructed on both its current site and the area shaded red), and currently Summary contains a number of small ponds. The Development site adjoins an extensive area Application Site of ecological mitigation land (some 26 ha ), which is also shown on Figure 2 as the The site of the Development is immediately to yellow area . This area has been established and the east of the existing Damhead Creek CCGT maintained as part of the Damhead Creek Power Station. In addition to the construction Power Generation Development. The of an additional CCGT Power Station with a mitigation land is owned and managed by nominal output of 1000 MW, the Development ScottishPower, and was developed in order to will include a new 400 kilovolt (kV) electrical mitigate the power generation equipment and substation so that the electricity generated can infrastructure associated with the Damhead be delivered to the National Grid. However, Creek Power Generation Development. connections for this substation will be subject All areas of land to be used for the purposes of to separate applications. The Development will the Development are considered to be poor also allow sufficient space to install Carbon quality and are not used, nor suitable for Capture and Storage technology, if required in agricultural purposes. the future. The Development site lies approximately 3 km The Development site is 23.8 ha in total. A site south-east of the A228, which connects the A2/ plan can be seen in Figure 2, which shows that M2 with the Isle of Grain, and 9 km north-east the site is divided into three main areas: of the city of Rochester. It is situated on the 6.2 hectares (ha) of land lying mainly to the east southern edge of the tongue of land between of the existing Damhead Creek CCGT Power the Thames and Medway estuaries known as the Station. This is the location of the proposed Hoo Peninsula. The village of Development and is shown shaded in red on Hoo St. Werburgh, the nearest settlement, lies Figure 2. This area is low-lying undulating 3 km to the west between the coast and A228. ground sloping to the south east, and currently Historically the area surrounding the consists of mainly unmanaged grassland and Development site was mainly marshland, which hardstanding; was drained in the late 1800s to be used for 3.6 ha of land lying to the north west of the agricultural purposes. For a short period existing Damhead Creek CCGT Power Station. between 1912 and 1920 the Development site This is the location of a proposed 400 kV housed a naval airship facility. In around 1938, substation which will export the electrical construction started on an oil refinery to the energy generated to the National Grid north west of the Development site. The Transmission Network and is shown shaded in was constructed to green on Figure 2. For the most part, this area the south in the early 1970s, and the existing is hardstanding, and is currently unused; and, Damhead Creek CCGT Power Station was constructed between 1999 and 2001. 14 ha of land lying to the north-east of the existing Damhead Creek CCGT Power Station. All areas of the Development site are underlain Approximately 7.5 ha of this area will be used by London Clay, which is covered with temporarily for car parking and the storage of superficial alluvium deposits. There are no materials and equipment during the significant aquifers that are used for water construction phase of the Development. This supply beneath the site. In addition, a area may also be set aside for the installation of contaminated land survey has shown that the Carbon Capture and Storage equipment in the land is not contaminated. future, and thus may be reserved for any such There are no environmental designated sites or development. The remainder of the area would scheduled monuments within the Development be dedicated to ecological mitigation including site boundary though there are a number of additional ponds and habitat enhancement. All designated ecology sites in the vicinity of the land in this area has previously been used to site. dispose of the fly ash from the nearby Kingsnorth Power Station. It is surrounded by The reasons for selection of this site for the ecological mitigation land associated with the proposed Development include, amongst development of the existing Damhead Creek others:

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Area to be used temporarily during construction / Area to be set aside for Area for proposed Damhead Creek 2 Carbon Capture and Storage (CCS) equipment

Ecological mitigation land (owned and Area for proposed 400 kV Substation managed by ScottishPower)

FIGURE 2: SITE PLAN x The close proximity of the 400 kV x Proximity of the Development site to National Grid transmission system; land set aside in the Medway Local Plan as a ‘Major Employment Area’, thereby x A road network that can accommodate raising the potential for the provision of construction traffic; low grade heat improving the overall x Availability of sufficient land; efficiency of the plant, subject to technical and commercial considerations. x Availability of operational staff and technical support from the existing It is therefore considered that the proposed site Damhead Creek CCGT Power Station; is suitable for the intended use of power generation. x Availability of natural gas without any

requirement for a new pipeline; x Reduced visual impact due to the industrial nature of the immediate area;

PAGE 10 Application Site Surroundings Business Park, and has been proposed by Goodman Developments Limited. The existing Damhead Creek CCGT Power Kingsnorth Business Park will include storage Station warehouses and associated infrastructure. However, as works have not yet started on the The existing Damhead Creek CCGT Power development and the original proposed Station lies immediately to the west of the schedule has not been adhered to, the actual Development site, and was commissioned in construction schedule remains unclear. 2001. The power station consists of two gas To the east, the landscape is dominated by the turbines and one associated existing oil-fired Isle of . capable of generating 792 MWe at site rated This Power Station has a boiler house around conditions. ScottishPower purchased the Power 50 m in height and a chimney 244 m in height. Station in 2004. To the south of the Development site is the The existing power station is air cooled and existing coal-fired Kingsnorth Power Station thus has extremely low water discharges. In (Kingsnorth Units 1 – 4), which is owned and addition, the emissions to atmosphere are very operated by E.ON. This Power Station consists low in comparison to similar sized coal and oil of four 500 MW units, each with a boiler and fired plants. This makes the existing Damhead steam turbine. It is cooled by a once-through Creek CCGT Power Station one of the most cooling system with the water abstracted from efficient of its kind in Europe. the and discharged to the Damhead Creek. This Power Station dominates Ecological Mitigation Land the immediate area, with the boiler house rising to a height of around 50 m and the associated The Development site adjoins approximately chimney to 198 m. 26 ha of ecological mitigation land which was established to mitigate the potential ecological Immediately north of the Kingsnorth Power impacts of the power generation equipment Station and immediately south of the and infrastructure of the Damhead Creek Power Development site is an area of land which is Generation development. This mitigation land , currently the subject of an application for including wetlands and exclusive wildlife Section 36 Consent under the Electricity Act habitats is owned and proactively maintained 1989 for the construction of a 1600 MW and managed by ScottishPower. Supercritical Coal-Fired Power Station. Proposed by E.ON, this will be known as The mitigation land is shown in yellow on Kingsnorth Units 5 and 6. Kingsnorth Units 5 Figure 2. and 6 would include two 110 m high boiler A Biodiversity Action Plan has been developed houses, each with a dedicated 198 m high stack, for the ecological mitigation land. This and associated infrastructure. As with the ecological management has seen the existing Kingsnorth Power Station, the plant reintroduction of certain species, including would be directly cooled using water from the Barn Owls and Marsh Harriers. This is a River Medway, which would then be released significant achievement, and a major boost to into the Damhead Creek. biodiversity in the area. Construction of Kingsnorth Units 5 and 6 was due to commence in March 2008 with firing of Other Developments surrounding the the first unit expected in 2012. The project has Application Site been approved by Medway Council, but requires Section 36 Consent approval from the To the north and west of the Development site Secretary of State before any construction lies the Kingsnorth Industrial Estate. works could be started. It is not known when Land to the north east of the Development site, the Kingsnorth Units 5 and 6 Section 36 which borders the ecological mitigation land determination will be made or if a Public discussed above, is filled with pulverized fuel Inquiry (as requested by Medway Council) will ash. This area of land is designated as a future be instigated by the Secretary of State. development area under the Medway Local To the south and east there are blind drainage Plan, and much of it is now the subject of ditches and swales. Damhead Creek joins East outline planning applications to Medway Hoo Creek and the River Medway (about 2 km Council for a business distribution and storage to the east of the Development site). facility. This is known as the Kingsnorth

PAGE 11 In addition, to the north west there are a Operational Details number of high voltage overhead transmission lines that link a number of Power Stations to Damhead Creek 2 will consist of two combined the National Grid Network. These Power cycle gas turbine units. Each unit will comprise Stations include: the Isle of Grain Power a gas turbine and a heat recovery steam Station; the ; the existing generator (HRSG) which will serve steam Damhead Creek CCGT Power Station; and the turbine equipment. The total electrical output existing Kingsnorth Power Station. of the Development will therefore be in the order of 1000 MWe at typical site ambient Other developments in the vicinity of the conditions. application site include the: The gas turbines will burn natural gas only, x Grain CHP Power Station; which is an inherently clean fuel. Natural gas will be brought to the site via the existing gas x Thamesport Quay Extension; pipeline connecting the existing Damhead x Grain Wind Farm; Creek CCGT Power Station to the National Transmission System. As the existing Damhead x Medway Approach Channel Deepening; Creek CCGT Power Station was built to allow for x National Grid expansion there will be no need to install a new Facility, Isle of Grain; gas pipeline to the application site. A new gas receiving facility will be provided on the x Land Reclamation Project at Garrison Development site. Point, ; The electricity generated will be exported to the x Lappel Bank Wind farm; and National Grid via a new substation that will be constructed on land lying to the north west of x New Settlement at Chattenden. the existing Damhead Creek Power Station. The flue gases from each of the two gas turbine Potential for Cumulative Impacts with other units will be discharged to a dedicated 75 m Developments high stack, therefore two new stacks will be constructed. There will be no bypass stacks The EIA has considered the potential for installed to permit power generation in the cumulative impacts associated with two other event of the steam turbine plant being developments in the vicinity of the proposed unavailable. Damhead Creek 2. These are the development of the Kingsnorth Business Park by Goodman The connection offer from National Grid Developments Limited and Kingsnorth Units 5 Company (NGC) is such that Damhead Creek 2 and 6 by E.ON. could enter operation in two phases, the first 500 MW in 2019 and the second in 2022. This Cumulative impacts have been assessed as all would mean that construction of the three projects (Kingsnorth Units 5 and 6, Development would also occur over two phases Kingsnorth Business Park and Damhead Creek with the first starting in 2016 and the second in 2) may be in some stage of construction at the 2019. same time should all three receive planning permission, and also the operational lives of the There is however the possibility of the three projects will overlap for many years. connection offer being amended by NGC to allow for connection of Damhead Creek 2 in The other developments in the vicinity of the one stage depending on a variety of factors application site are, on closer review, including the construction schedule of various considered likely to have negligible cumulative other UK power projects. If this scenario were impacts (when considered in conjunction with to happen, construction of the Development the proposed Damhead Creek 2) due to the would commence in 2013. separation distances between them and the proposed Development. Damhead Creek 2 will operate throughout the year and will be designed to have an expected operational life of 35 years. The total capital investment in the project by ScottishPower will be around £600 million. The operation and

maintenance costs will be of the order of £27 million per annum.

PAGE 12 Process Description – The Combined Cycle The use of air cooled condensers means that Gas Turbine Principle there is no need for cooling towers or a once- through cooling water system, thereby Figure 3 shows a schematic representation of eliminating the environmental impacts the combined cycle gas turbine principle. associated with such systems. These may have The gas turbines compress air with which included a visible plume from a cooling tower natural gas is burned in a combustion chamber. or abstraction from, and discharge to, a local The hot combustion gases then expand through water course. the turbine section, which in turn drives both The flue gases from each CCGT module will be the compressor and an electrical generator. discharged to a dedicated 75 m stack. The The hot exhaust gases still contain recoverable height of the stacks has been determined by a energy and can be used in a HRSG to generate computer dispersion modelling study. There steam. The high-pressure steam produced is will be no bypass stacks installed. used to drive steam turbines to generate additional electricity. The spent steam leaving the steam turbines is condensed (via air cooled condensers) and the resulting condensate returned to the HRSG for re-use.

Exhaust Gases Air Stack Compressor Gas Turbine Generator Heat Recovery GT G Steam Generator

Exhaust

Combustion Chamber Generator Steam G ST Steam Fuel Turbine Air Cooled Condenser

Condensate Feed Water Water

BRAYTON CYCLE RANKINE CYCLE

FIGURE 3: S CHEMATIC REPRESENTATION OF THE COMBINED CYCLE GAS TURBINE PRINCIPLE

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PAGE ## 5. Consultations and Residents’ Information Days ScottishPower has also informed the public of Additional Studies proposals regarding Damhead Creek 2 through Residents’ Information Days where members of ScottishPower and their consultancy teams Overview were available to address questions and queries from the local community. In undertaking the EIA and associated studies, ScottishPower and their consultants have The Residents’ Information Days aimed to: undertaken consultations with a variety of x Raise awareness of Damhead Creek 2 and stakeholders. These have included the Secretary its likely impacts; of State at DECC, the local and regional authorities, local residents and governmental x Receive comments on Damhead Creek 2 and non-governmental organisations. and the scope of the EIA; and x Establish the concerns of stakeholders Scoping Study (be they real or perceived), in order that these can be addressed and, where An initial scoping exercise was undertaken from practical, mitigated. December 2006 to April 2007 by ERM. This described the key environmental issues that ScottishPower held Residents’ Information Days would require detailed evaluation as part of the on Friday 24 November 2006 and on Saturday EIA process. 25 November 2006 at the Hoo St Werburgh Village Hall. A second set of Residents’ A formal request for a Scoping Opinion was Information Days was held on Friday 20 March forwarded to the DECC (formerly the 2009 and Saturday 21 March 2009 at BAe Sport Department of Trade and Industry (DTI)), under and Social Club in Hoo. Prior to the Residents’ Regulation 7 of the EIA Regulations. The Information Days, notices were published in the document was also forwarded to other parties local papers and individual invitations were deemed to have a relevant interest in the sent to a number of householders in the vicinity development. of the site. The organisations consulted included: A Questionnaire / Feedback Form was available x DECC – Electricity Consents Team; at the 2009 Residents’ Information Days which visitors were encouraged to complete to give x English Heritage; their opinion on the Development and ask any x Environment Agency; questions in writing. Details of publicity and consultation are set out in Appendix E of the x The Joint Nature Conservation Environmental Statement. Committee; x Kent County Council; Combined Heat and Power (CHP) Assessment

x Natural England; A requirement of the UK Government is that any proposals for new power generation x Medway Council; and projects should be accompanied by an x The Royal Society for the Protection of assessment of the potential for provision of Birds (RSPB). Combined Heat and Power (CHP) in the vicinity of the proposed site. This is detailed in This scoping exercise was updated in March of “Guidance on Background Information to 2009 by PB and was resubmitted to the above Accompany Notifications under Section 14(1) of parties to confirm that the proposed the Energy Act 1976 and Applications under assessment methodology was still appropriate Section 36 of the Electricity Act given the intervening time between the original 1989” (December 2006). scoping exercise and the submission of the Section 36 application to the DECC. As such, ScottishPower is investigating the potential to incorporate a Combined Heat and Consultation with interested parties has Power (CHP) element into the Development. continued throughout the EIA for the CHP will increase the energy utilisation Development, through meetings and exchanges associated with the Development, and help to of correspondence. reduce the generation of greenhouse gases.

PAGE 15 ScottishPower has identified potential users of proposed storage area; and, heat in the vicinity of the site. The most likely future potential user of heat would be the x If necessary, apply for and obtain proposed Kingsnorth Business Park, planned on Hazardous Substance Consent (HSC) land to the north of the proposed application when applying for Section 36 Consent. site to be developed by Goodman The CCR Feasibility Study undertaken for the Developments Limited. Another potential Development presents the results of the future heat user would be the proposed new required assessments, and concludes that it will Lodge Hill / Chattenden Settlement, be both technically and economically feasible approximately 6 km to the west of the to retrofit Carbon Capture and Storage (CCS) application site to be developed by Land technology to the Development at some point Securities Group Plc. Consultations and within its operating lifetime. discussions have been held with both parties to establish their expected heat demands and to explore future cooperation. Additional Documents

Further users may also be identified or indeed Additional documents prepared in support of forthcoming in the event that the proposed the Section 36 Application for the Development Development is consented and moves towards include a: Design and Access Statement; Flood the detailed design stage. Risk Assessment; Statement to Inform; and Transport Assessment. As a result, ongoing consultation will continue between ScottishPower and local industries and parties in an attempt to identify any possible Future Consultations future CHP opportunities. On completion of the ES and submission of the In addition, to allow for future CHP Section 36 Application, ScottishPower development, the Development design will will publicise the application by placing notices incorporate suitable modifications which will within a newspaper available in the locality of allow for export of heat in the event that a the Development, a national newspaper and suitable user is identified. within the London Gazette. Public notices will also be placed at a number Carbon Capture Ready (CCR) Feasibility Study of locations within the vicinity of the Development site. Copies of the ES will be The European Union (EU) agreed the text of a made available at key locations within the area new EU Directive on the Geological Storage of so that members of the public may view the ES Carbon Dioxide on 17 December 2008, which and make any representations on the requires an amendment to the LCPD such that application. developers of all combustion plants with an electrical capacity of 300 MW or more (and for The local council (Medway Council) will also which the construction / operating license was place a copy of the ES on their Planning granted after the date of the Directive) will carry Register together with any related documents. out a CCR Feasibility Study. Within four months of the application being received, Medway Council will communicate As part of the CCR Feasibility Study, developers their views on the application to DECC, who are required to: will subsequently make a decision on whether x Demonstrate that they have sufficient or not to give consent to Damhead Creek 2. space on or near the site to accommodate Throughout the determination process carbon capture equipment in the future; ScottishPower will continue to address any x Undertake an assessment into the questions or concerns raised by stakeholders technical and economic feasibility of with regard to Damhead Creek 2 and will retrofitting carbon capture technology; continue to inform and advise local residents and interested parties, including hosting x Propose a suitable area of deep geological further Information Days . storage offshore for the storage of

captured CO2; x Undertake an assessment into the technical and economic feasibility of transporting the captured CO2 to their

PAGE 16 existing background levels. 6. The Environmental A conservative view of the operation of the Development was adopted in the modelling so Impact Assessment that a likely “worst case” scenario could be presented. As a result of using this conservative Overview approach, it could be guaranteed that the maximum predicted impact of the potential The Development has been the subject of an operating regime of the Development was EIA in full accordance with the requirements of considered. In addition, there would also be a the EIA Regulations. “factor of safety” built into the air quality assessment. The results of the modelling were The EIA was undertaken to determine the compared to AQS objectives. potential extent of any likely significant environmental impacts, which are both positive Key findings of the analysis were that: and negative, with regard to the Development. x The proposed Development would not In addition, and in accordance with the EIA give rise to high annual ground level Regulations, any measures which are envisaged concentrations of NO . The predicted to avoid, reduce and, if possible, remedy any 2 maximum long term NO concentration significant adverse impacts of the Development 2 due to the proposed Development was were identified. predicted to be 0.4 mg/m3, well within the long term AQS objective of 40 µg/m3. Air Quality The maximum concentration occurs at a point just over 2.2 km to the north east There are a number of air quality automatic of the Development, which is in the monitoring stations that are or have been vicinity of Stoke Saltings just off the coast operated on behalf of the Department for of Stoke. Environment, Food & Rural Affairs (DEFRA) in the UK. The results from the monitoring sites x The predicted maximum increase in short are available on the Internet on the UK Air term NO2 concentrations due to the Quality Archive (www.airquality.co.uk). The operation of the Development is just nearest monitoring stations to the proposed 10.3 mg/m3, which is only 5 per cent of Development site are at Rochester and the AQS objective. The maximum Gillingham Strand. The results from these concentration occurs at the same point as monitoring stations show that the air quality in with the maximum long-term prediction. the area of the Development is generally good and well within the guidelines set out in the UK x The Development will not significantly Air Quality Strategy (AQS) objectives. increase ground level concentrations of NO2 within the various Air Quality During operation of the Development, the Management Areas (AQMA) in the principal atmospheric emissions of concern will vicinity of the application site. be Nitrogen Oxides (NOx). Emission levels of The assessment concluded that the impact of NOx will be maintained below a concentration of 50 mg/Nm3 (25 ppm) as required by the the atmospheric emissions from the LCPD and the Large Combustion Plants Development will be well within the AQS objectives, even when considered in Regulations by using Dry Low NOx (DLN) technology. In brief, this technology pre-mixes conjunction with existing background the fuel and air prior to ignition which concentrations. significantly reduces NOx emissions. During In addition to effects during operation, dust normal operations, there will be no visible may be generated during several activities plume from the two 75 m stacks that will serve associated with the construction works, for to disperse flue gases from the Development. example the excavation work. However, it is As part of the EIA, a dispersion modelling very unlikely during most weather conditions exercise was undertaken. Emissions of Nitrogen that dust generated at the Development site will cause nuisance at houses in the area due to Dioxide (NO2) from the Development were modelled and the resulting ground level the distance of houses from the Development concentrations were calculated. These and the mitigation measures that will be concentrations were then compared to the employed on the Development site. relevant standards, whilst also considering The Development has a positive net effect on

PAGE 17 climate change as it would likely replace other and vibration control on construction and open fossil fuel sources of electricity generation that sites” Parts 1 to 4. This assessment concluded have greater Carbon Dioxide (CO2) emissions that the impact of construction noise is not per unit output. predicted to be significant due to the distances between the Development site and the noise Furthermore, the Development will be designed sensitive locations, and due to the temporary to allow for retro-fitting of Carbon Capture and and changing nature of the noise source. Storage (CCS) equipment. ScottishPower have purchased land adjacent to the site of the proposed Development (shown shaded in blue Landscape and Visual Impact on Figure 2) with the requirement that a proportion of this is to be specifically reserved As part of the EIA, a Landscape and Visual for CCS equipment. Impact Assessment was undertaken. This included the preparation of photomontages from viewpoints agreed with Medway Council. Noise The photomontages formed the basis of the The nearest residential and sensitive areas to Landscape and Visual Impact Assessment the proposed Development are the market undertaken as part of the EIA. The EIA found garden/dog kennels, approximately 1 km to the that the Development would not have any north east and Whitehall Farm, approximately significant effect on the local landscape, which 1.1 km to the north. is already dominated by the existing Kingsnorth Power Station and other industrial plants, An assessment of the operational noise impact, including the existing Damhead Creek CCGT and the subsequent likelihood of complaints as Power Station and the existing Kingsnorth a result of the Development has been Industrial Estate completed in accordance with procedures outlined in BS 4142:1997 “Method of Rating The photomontages were compiled from a Industrial Noise Affecting Mixed Residential series of photographs upon which a model of and Industrial Areas”. Noise levels expected the Development was superimposed. These during the operation of the Development have photomontages aim to give an impression of been predicted based upon test data for similar the likely scale and visual impact of the units. Development. The residential positions chosen for the The main buildings envisaged on the assessment were agreed with an Environmental Development site are the turbine halls, HRSGs, Health Officer (EHO) from Medway Council. air cooled condensers and storage tanks. The These were deemed the noise sensitive remaining plant and equipment will, in the locations. main, be housed in relatively low buildings, of the order of 3 to 6 m in height. The tallest Noise control treatment will be introduced such structures on site will be the 75 m high stacks that the level of noise control provided is that will be similar in appearance to the extensive and is based on complying with the existing 75 m high stacks at the existing appropriate limits. The gas turbines and steam Damhead Creek Power Station. turbines are the most significant sources of noise generation associated with the operation Two sets of photomontages were prepared for of the Development. The gas turbines will be the EIA. The first set considered the impact of contained within acoustic enclosures in order Damhead Creek 2 alone, and the second set to attenuate the noise. Also, it is envisaged that considered the impact of Damhead Creek with the area of the building containing the steam the proposed Kingsnorth Units 5 and 6. turbine will be acoustically treated. Example photomontages can be seen in As a result of these controls, there will be no Figure 4, where View A shows the existing significant noise impacts associated with the landscape, View B shows the impact of proposed Development, and there will not be a Damhead Creek 2, and View C shows the perceptible increase in noise in the site locality. impact of Damhead Creek 2 with the proposed There will be no impact due to operational Kingsnorth Units 5 and 6. These vibration. photomontages show the proposed view of the Development from Turnbridge Hill, Stoke Road. The assessment of the construction noise impact was undertaken in accordance with the Subject to discussions with Medway Council, procedures outlined in BS 5228: 1997 “Noise the final appearance of the Development will

PAGE 18

VIEW A: EXISTING VIEW

VIEW B: DAMHEAD CREEK 2

VIEW C: DAMHEAD CREEK 2 AND KINGSNORTH UNITS 5 AND 6

FIGURE 4: PHOTOMONTAGE FROM TURNBRIDGE HILL, STOKE ROAD

be designed to be similar to the existing thereafter. In addition, consultation with Damhead Creek CCGT Power Station, and various parties (including Natural England and ScottishPower will seek to employ the same the RSPB) was undertaken to help inform the finish as the existing plant. study. The proposed Development site is not covered Ecology by any national or local landscape designations. However, the Medway Estuary is covered by a The ecological section of the EIA was based on a number of landscape and nature conservation detailed desk study and field surveys. A Phase 1 designations. These include the Medway habitat survey of the Development site was Estuary and Marshes Special Protection Area undertaken in 2006, and a number of dedicated (SPA), the Medway Marshes Ramsar Site and the protected species surveys were carried out Medway Estuary and Marshes Site of Special

PAGE 19 Scientific Interest (SSSI). These are located water harvesting will reduce water immediately adjacent to the south eastern most consumption from other sources, adding to the areas of the Development site. In addition, sustainability of the project. three SPAs, three Ramsar sites, one The discharge of any effluents during Environmentally Sensitive Area (ESA), eight construction, including site drainage, will also SSSIs and one National Nature Reserve (NNR) be the responsibility of the construction exist within 10 km of the boundary of the contractor, who will be required by Development site. ScottishPower to reach agreement with the The proposed Development site borders an area Environment Agency and the local sewerage of neutral to calcareous grassland mitigation undertakers, Southern Water, with regard to the land which is managed by ScottishPower. This detailed methods of disposal. Standard good mitigation land was created as part of the working practices should ensure that any existing Damhead Creek CCGT Power Station impacts due to the water discharging from the development. site will be insignificant. Mitigation measures have been proposed to The only process effluent produced by the avoid any significant impacts on the following Development in any real quantity will be the ecological receptors: bats; reptiles; breeding blowdown from the two Heat Recovery Steam birds; and their associated habitats. Generators. Small quantities of boiler water (boiler blowdown) are discharged in order to Whilst no loss of habitat to any designated sites avoid the build-up of impurities in the boiler will occur as a result of the Development, water. This discharge is virtually pure water, landscaping and habitat creation is proposed to containing very small quantities of various replace the loss of habitat which is considered chemicals that are used to prevent corrosion to be of local or higher value, but is outside any and scaling in the boiler. The boiler blowdown locally, nationally or internationally designated will be recovered and reused in the site. demineralization plant as much as is achievable. Net ecological gain for the Development site, in The remainder will all be discharged to the line with planning policy, will include the existing drainage system on the site. translocation of aquatic invertebrates and The quality of the effluent to be discharged enhancement of habitats for terrestrial from the plant will be monitored. It is expected invertebrates and reptiles. The implementation that the following will be monitored: flow; pH; of this should ensure that the development of suspended solids; and oils and grease. These Damhead Creek 2 has no significant ecological discharges will be controlled and will comply impact. with limits set by the Environment Agency in the plant’s Environmental Permit. Water Quality Any areas of the site that are likely to be The supply of water for the construction stage contaminated with oil will drain to oil of the Development will be the responsibility of interceptors to limit visible oil in the water. the construction contractor, and it is expected This surface water, with waters from non- that the water source will be the existing towns contaminated areas, will drain to the existing water supply to the Damhead Creek site. surface water system and then into Damhead Creek. It is expected that all water required by the Development during operation will be taken from the existing towns water supply to the Geology, Hydrology and Land Contamination Damhead Creek CCGT Power Station site. As a result of a series of desk-based and During normal operation, water will only be intrusive investigations, the nature of the required on a day-to-day basis for make-up to geology, hydrology and extent of existing land the boiler water system. contamination beneath the proposed An alternative supply would be to source water Development site is well understood. from bore holes beneath the site. This is A Phase 1 Desk Study has been undertaken for currently being investigated. Any water sourced the Development site to assess the potential of from bore holes would reduce the towns water contaminants to be present on, in or under the requirement. At the detailed design stage of land, which may pose a threat to human health the project, consideration will be given to the or water quality. Baseline conditions were incorporation of rainwater harvesting. This rain subsequently assessed through the undertaking

PAGE 20 of a Phase 2 Intrusive Site Investigation. expected to give rise to additional traffic movements that will be similar to those the Analysis of the soil beneath the Development area experienced during the construction of the site revealed no metal concentrations above the existing Damhead Creek CCGT Power Station. A relevant Soil Guideline Values, or Phytotoxic travel plan would be agreed with the local Guideline Values for the uptake by plants. The Highways Officer prior to the commencement soil is relatively neutral with pH measurements of construction, which will help mitigate the in the range 6.6 to 8.6. Elevated levels of boron potential impact of the proposed works to local were recorded across the Development site with and regional traffic and infrastructure. During the highest measurement occurring in a sample construction, the use of public transport and of ground consisting of pulverised fuel ash. car sharing will be encouraged so as to reduce Asbestos containing materials were found in an the number of vehicles visiting the isolated area of the site and will be treated Development site. ScottishPower would appropriately during development. encourage its construction contractors to The groundwater beneath the Development site provide a minibus service for construction staff. was also analysed. Concentrations of Total In addition to construction staff transport Petroleum Hydrocarbons (TPH) and nickel were movements, construction traffic will consist of slightly above the UK DWS/EQS in all samples. civil works traffic, mechanical works traffic and However, as elevated concentrations of TPH and a small number of abnormal loads for nickel were not found in soils from the components such as the gas and steam Development site, it was concluded that the turbines. The exact number of commercial contamination was most likely from an off-site vehicles and abnormal loads will depend on the source. final configuration of the Development and the The Environment Agency has designated part of number of construction phases expected. the site as Flood Zone 3a. Developments in Approximately 50 heavy commercial vehicles Flood Zone 3a are considered to be ‘at risk of per day will be expected on average, with a flooding from rivers or sea if flood defences are possible peak of 100 per day during the not present’. As a result, a separate Flood Risk construction period. Vehicles bringing Assessment was undertaken which concludes deliveries to the Development site are likely to that the site is not at risk of flooding. be spread throughout the working day. The impact of the construction works on the The number of abnormal loads is likely to be of existing environment at the Development site is the order of 15 to 20 over the full construction considered to be minor as all impacts will be phase. The transport of abnormal loads, which small and of a temporary nature. may lead to delays and cause inconvenience to Decommissioning of the plant will involve other road users, would be timed following similar works and the impact is also considered consultation with the relevant authorities to minor and temporary. minimize disruption to the other road users. The main part of the Development site will be During operation of the Development, there predominantly covered with buildings or areas will be a number of additional traffic of hardstanding. There will be a small amount movements associated with the 50 personnel of landscaped ground but no areas of exposed working at the site. During outages for (un-vegetated) soils. The potential pathways for maintenance, up to 200 temporary staff may the release of residual contaminants will visit the Development for a period of about a therefore be broken. month. Planned major outages will occur about once every 3 years. Traffic and Infrastructure Access to Damhead Creek 2 would be via a Socio-Economics dedicated access road immediately north west Should Damhead Creek 2 be developed in one of the existing Damhead Creek CCGT Power phase (for example, construction starting in Station which connects with Stoke Road. 2013) it is expected that, at its peak, the Roper’s Lane connects Stoke Road to the A228 construction workforce for the Development approximately 1.1 km north east of the would total about 1000. In the event that junction for Hoo St Werburgh and around Damhead Creek 2 is developed in two phases 1.2 km south of High Halstow. (for example, construction of the first phase The construction of the Development is would be in 2016, and the second would start

PAGE 21 in 2019) the construction workforce would the vicinity of the Development site of a palaeo- peak at approximately 600. It is hoped much of channel incised into the London Clay bedrock, the workforce will be recruited locally. containing an important sequence of late- Pleistocene deposits, including a complex Approximately 50 personnel would be required sequence of clay silts containing organic for the operation of the Development. material. In addition, there is potential for early Total investment in the Development will be of prehistoric archaeological material to be the order of £600 million. In addition, present amongst the early Holocene alluvial operational and maintenance costs will be of silts underlying the Development site. the order of £27 million per annum, a Evidence was revealed for multi-period activity significant proportion of which will benefit the from the Late Bronze Age into the Early Iron local economy. Age, when the Development site became part of It is considered that the Development project the early agricultural landscape of the Hoo would have a positive socio-economic impact Peninsula. Situated on low-lying land south- on the surrounding area, by providing west of the main area of arable cultivation and additional jobs and investment whilst also settlement, the Development site was used for helping the wider UK economy through the grazing, and possibly seasonal salt-working. development of a highly cost effective means of During the 2nd and 3rd centuries AD, a electricity generation. Romano-British pottery production site was established within the vicinity of the Cultural Heritage Development site, although its precise location has not been revealed by previous A series of geo-archaeological investigations archaeological and geophysical investigations. were undertaken on and around the Development site as part of the EIA. During the early medieval period the Development site once again became part of The results of these investigations indicated the pastoral landscape of the Hoo Peninsula, that the proposed Development will not result whilst flooding during the medieval period in the loss of any listed buildings, Conservation prompted the building of sea walls along the Areas or Scheduled Monuments, nor is it likely banks of Damhead Creek and Damhead Fleet. to affect their settings. These walls may have survived, albeit in a The results also suggested that a potential exists modified and improved form into the 21st for palaeo-environmental material to be present century. beneath the Development site. Borehole investigations indicated the likely presence in From 1912 the Development site underwent its most intensive period of use, when the RNAS Kingsnorth Naval Airship Station was established. The station was of considerable significance in the history of British naval aviation, despite the fact that it closed just eight years later. There is considerable archaeological potential for remains of one of the First World War airship hangars in the western construction lay-down area. Prior to mitigation, the proposed development of Damhead Creek 2 will have a slight-moderate adverse impact on palaeo-environmental and archaeological remains. It is suggested that an archaeological watching brief is employed at the Development site during the construction stage of the project.

Cumulative Impacts A number of projects may potentially begin construction or operation within the same time frame as the construction and operation of Damhead Creek 2. These include: x The construction of the Kingsnorth Business Park to be located to the north and east of the Development by Goodman Developments Limited; and x The development of the supercritical coal fired power station, Kingsnorth Units 5 and 6 to the immediate south of the proposed Development site by E.ON. These projects would represent the injection of a significant quantity of additional investment into the local economy were they all to proceed, but would also give rise to a variety of environmental impacts in both their construction and operational phases. In addition there are potential cumulative impacts associated with the continued operation of the existing Damhead Creek CCGT Power Station. There would be no potential cumulative issues associated with the continued operation of the existing Kingsnorth Units 1 to 4, save for the visual impact issues which will remain until the plant is demolished. This is because the plant is due to be decommissioned before the proposed Development starts construction. Cumulative Impacts have been considered for the combined effects of the Development with the various projects for all potential impacts. In no cases were the impacts identified considered to be unacceptable.

Dalton Warner Davis