The Wrexham (Gas Fired Power Station) Order

6.4.3 Volume 4: Environmental Statement Appendix 8.3: Consultation

Planning Act 2008 The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

PINS Reference Number: EN010055 Document Reference Number: 6.4.3 Regulation Number: 5(2) (a) Lead Author: Atkins

Revision: Date: Description: 0 March 2016 Submission version

SEC6.4-ES Appendix TABS.indd 16 10/03/2016 09:48 WREXHAM ENERGY CENTRE ENVIRONMENTAL STATEMENT

Appendix 8.3  Air Quality Consultation

CONSULTATION E-MAILS

8.1.1 Key e-mail correspondence follows between Atkins’ air quality specialists and statutory consultees:

 Natural Resources Wales –Khalid Aazem, Conservation Officer

 Natural Resources Wales – Anna Lewis, Principal Permitting Officer

 Wrexham County Borough Council – Paul Campini, Environmental Health Officer

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From: Paul Campini [mailto:[email protected]] Sent: 18 February 2016 14:03 To: Horrocks, Sarah Cc: Spencer, Jenny Subject: RE: Wrexham Power

Hi Sarah

I am still the air quality contact at WCBC.

The only change of relevance is that the continuous monitoring site at Isycoed was closed on the 1st Jan. The diffusion tube network is still in operation and I’ve attached the results for 2016. These haven’t been ratified nor have they been BAF corrected as I am waiting for the national spreadsheet to be updated. The monitoring data for 2015 is on the Welsh Air Quality website but I’m not sure whether it’s been ratified yet.

In terms of methodology, your proposal to use the new guidance documents would seem wise.

Regards

Paul Campini Technical Officer / Swyddog Technegol Environmental Protection / Diogelu'r Amgylchedd

01978 297431 Wrexham County Borough Council, Guildhall, Wrexham LL11 1AY Cyngor Bwrdeistref Sirol Wrecsam, Neuadd y Dref, Wrecsam LL11 1AY wrexham.gov.uk | wrecsam.gov.uk twitter.com/wrexhamcbc | twitter.com/cbswrecsam facebook.com/wrexhamcouncil | facebook.com/cyngorwrecsam

From: Horrocks, Sarah [mailto:[email protected]] Sent: 15 February 2016 10:17 To: Paul Campini Cc: Spencer, Jenny Subject: RE: Wrexham Power

Dear Paul

It’s been a while since we were last in touch, but I trust you remember the Wrexham Energy Centre planning application? The process is still underway albeit with a slight change to the approach which I have been asked to tell you about.

I should also check, given the time that has passed, that you are still the appropriate contact?

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Wrexham Energy Centre (WEC) comprises a combined cycle gas turbine Power Station Complex (PSC) with integral infrastructure works and an associated Gas Connection. Previously it was expected that the entire scheme would be subject to a Development Consent Order (DCO), as a Nationally Significant Infrastructure Project. Whilst the Gas Connection forms part of the generating station, for the purposes of the Planning Act 2008 in Wales it does not constitute ‘associated development’. A separate application will therefore be submitted to the local planning authority to seek planning permission for the Gas Connection, under the Town and Country Planning Act 1990. However, powers of compulsory acquisition over the land required for the Gas Connection are being sought as part of the DCO application for the Scheme. Each Environmental Statement (ES) topic chapter therefore considers and assesses both the Power Station Complex and the associated Gas Connection individually and then together as the 'WEC'.

Previously it was expected that the entire scheme would proceed under DCO. Whilst this is no longer the case, the assessment itself does not change, as it had already been undertaken taking the PSC and Gas Connection separately and then together. The ES will accompany both the DCO application and the local planning application.

With respect to methodology, are there any changes to your preferred approach to air quality assessment? We will of course now be referring to the IAQM/EPUK updated planning guidance for air quality that was released in 2015, including the more stringent criteria for identifying whether a qualitative assessment is required for changes in traffic. I also note that the H1 Annex F guidance has recently been withdrawn from the UK Government website to be replaced with a simplified approach (https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit). It is my understanding that there is no change to the approach that we have taken for a more detailed air quality assessment, however I have contacted NRW in this regard.

If you are able to send through any updated monitoring data for diffusion tubes for 2015 that would be great. Have you closed any existing sites or started any new ones in the Wrexham Industrial Estate area that would be of relevance to the study?

Many thanks in advance for your time,

Kind regards, Sarah

Sarah Horrocks Associate Consultant, Air Quality & Emissions: Water, Ground & Environment

ATKINS Explore our world of opportunities – www.atkinsglobal.com/careers

Woodcote Grove, Ashley Road, Epsom, KT18 5BW | Tel: +44 1372 756032 | Mob: +44 7803 260476 Email: [email protected] | Web: www.atkinsglobal.com | Careers: www.atkinsglobal.com/careers

From: Paul Campini [mailto:[email protected]] Sent: 09 September 2014 11:08 To: Horrocks, Sarah Subject: RE: Wrexham Power

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Hi Sarah

As discussed yesterday, could you use just the Isycoed site in your model? We believe this to be the more representative of the two sites due it its close proximity to the proposed site. We also agree that using data from the two sites would unnecessarily complicate matters.

Thanks for pointing out the mistake in my progress report, the correct value is the one used in the chart - 9.8 µgm³.

Regards

Paul

From: Horrocks, Sarah [mailto:[email protected]] Sent: 08 September 2014 18:34 To: Paul Campini Subject: RE: Wrexham Power

Hi Paul

Thanks again for your time this morning, it was a very helpful conversation.

To confirm, the key points discussed were:  The Hugmore diffusion tube site has been closed following the opening of the link road, but a new site is running in Llan y Pwll.  Local wind data is not available from Isycoed CMS but Hawarden is considered to be representative of the area  The application of the DMRB for the traffic assessment and screening out the need for quantitative calculation if the HGV increase is less than 200 per day is acceptable  Dispersion modelling of stack emissions will be limited to emissions of NOx and CO given these are the only legislated emissions in IED (justification to be provided for SO2 and PM10 in text)  Sensitive receptors along Bryn Road will be included, and consideration will be given to the proposed prison near Pentre Maelor to the SW.  No known planned developments with stack emissions (other than a small unit associated with the prison which will not lead to in combination effects)  A DMP will be requested as a planning condition – the EIA will include an outline CEMP with proposed dust mitigation although this will be finalised by the eventual developer/contractor

I look forward to hearing your thoughts as to which is the most representative site to use for background. Should one be selected for roadside receptors and another for background or is this over complicating matters when just one conservative value could be used?

In the latest progress report I noticed a discrepancy between the tabulated 2013 NO2 measurement for Isycoed of 7.7 ug/m3 and the value of 10 ug/m3 from the Welsh AQ website – the higher value also appears in the graph showing recent trends. Are you able to shed any light on that?

The Wrexham Energy Centre website contains a library, where you will find the “preliminary environmental information report” which is essentially the beginnings of the EIA. I suggest you stick to the Executive Summary! http://www.wrexham-power.com/library-eng.html

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Do let me know if anything else comes to mind.

Kind regards, Sarah

Sarah Horrocks CEnv CSci MIAQM Associate, Air Quality and Emissions

ATKINS

Woodcote Grove, Ashley Road, Epsom, Surrey KT18 5BW | Tel: +44 1372 756032 | Mob: +44 7803 260476 Email: [email protected] | Website: www.atkinsglobal.com Twitter: www.twitter.com/atkinsglobal | Facebook: www.facebook.com/atkinsglobal LinkedIn: www.linkedin.com/company/atkins | YouTube: www.youtube.com/wsatkinsplc

From: Paul Campini [mailto:[email protected]] Sent: 08 September 2014 14:00 To: Horrocks, Sarah Subject: RE: Wrexham Power

Hi Sarah

Further to the phone call this morning please find attached: The latest LAQM progress report A screen shot of the NO2 diffusion tubes location on the A5156. Please note the tube is actually on a grey roadside telecoms (?) box. Which can be seen on google street view. The NO2 readings for the A5156. Please note neither readings are BAF adjusted though I have included the factor for 2013. The daily PM10 readings for the air quality site at Isycoed for 2014. Please note that these have not been ratified and are considered raw data.

I will discuss which automatic station we would prefer to be used as the models base line with my manager on his return tomorrow.

Regards

Paul

From: Horrocks, Sarah [mailto:[email protected]] Sent: 05 September 2014 17:48 To: Paul Campini Subject: RE: Wrexham Power

Paul,

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to air quality in the WCBC response to the scoping report and PEIR, so I would like to ensure we have covered all local areas of interest. Also, I would like to check on the latest monitoring data for the borough. I have found data on the Welsh Air Quality Forum website but could not see anything for Hugmore Lane in 2014 – has the site closed?

Thanks in advance for your time.

Kind regards Sarah

From: Horrocks, Sarah Sent: 22 November 2012 12:03 To: [email protected] Subject: Wrexham Power

Paul,

Thanks again for your time just now. I thought the following website might be of interest to you – it’s been used for public consultation on various site options and contains some useful background information. http://www.wrexham-power.com/

The NOx emission concentration limit set out in the Large Combustion Plant Directive for new gas turbines (CCGT) is 50 mg/Nm3 - one quarter of the WID limit, and one tenth of the limit for gas engines.

Kind regards, Sarah

Sarah Horrocks CEnv CSci MIAQM

Principal Environmental Consultant Air Quality and Greenhouse Gas Management ATKINS

Woodcote Grove, Ashley Road, Epsom, Surrey KT18 5BW Direct: +44 (0) 1372 756032 Mob: +44 (0 7803 260476 Fax: +44 (0) 1372 756888 Email: [email protected] Website: www.atkinsglobal.com/environment

From: Aazem, Khalid Sent: 18 March 2015 09:54 To: Watson, Alex R Cc: Horrocks, Sarah; Belt, Richard; May, Richard Subject: RE: Wrexham AQ assessment

Follow Up Flag: Follow up Flag Status: Completed

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Hi Alex, Sorry for the delay in responding but I’ve been away for a few days and have been trying to catch up.

However, nitrogen critical loads are generally not applicable to water features, except the permanent dystrophic lakes, softwater lakes or dune slack pools (these are available on APIS).

River Dee Llyn Tegid SAC From recollection the floating water plantain is phosphate limited rather than nitrogen limited (based on my understanding for Montgomery Canal). All of the features are aquatic so there are no nitrogen critical loads that can be applied. Critical levels for ammonia, nitrogen oxides for in-water features are not applicable. So that excludes the Ranunclion water course feature and the floating water plantain that you referred to below.

With regard to the woodland and grassland features, I agree with the reasoning Richard gave on why they happen to be included in APIS. However, they are important for when assessing impacts on the wider countryside as required under NERC Act 2006 S40 the Duty to conserve biodiversity.

Regards, Khalid

From: May, Richard Sent: 10 March 2015 16:11 To: Watson, Alex R Cc: Aazem, Khalid; Horrocks, Sarah; Belt, Richard Subject: RE: Wrexham AQ assessment

Hi Alex

Sorry to say but Khalid has an out of office until the 16th so there won’t be an answer until at least then. Unfortunately it isn’t something that I think anyone else can really advise on.

With thanks, Richard

From: May, Richard Sent: 10 March 2015 15:36 To: Thomas, Rhian; Aazem, Khalid Cc: 'Watson, Alex R'; Horrocks, Sarah; Belt, Richard Subject: RE: Wrexham AQ assessment

Hello Rhian, Khalid

Alex Watson (a consultant at Atkins) has contacted me to ask if we can offer any advice on critical loads for nitrogen deposition for the River Dee/Bala Lake SAC/SSSI – see email below.

Alex was advised to check Apis (and I had a look with him) but it offers no advice on the Ranunculion etc habitat. The current site conservation objectives are silent on the issue.

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Woodland/grassland habitats are listed for the SSSI and do have figures on Apis (Alex refers) but these are not site features (I suspect that these have been included as they are within a mappable boundary to the river course and or are within the fields notified for their geological interest).

Thanks, Richard

Richard May MCIEEM

Swyddog cadwraeth / Conservation officer Cyfoeth Naturiol Cymru / Natural Resources Wales Ffôn / Tel: 03000 653898 E-bost / E-mail: [email protected] / [email protected] Gwefan / Website: www.cyfoethnaturiolcymru.gov.uk / www.naturalresourceswales.gov.uk

Ein diben yw sicrhau bod adnoddau naturiol Cymru yn cael eu cynnal, eu gwella a’u defnyddio yn gynaliadwy, yn awr ac yn y dyfodol.

Our purpose is to ensure that the natural resources of Wales are sustainably maintained, enhanced and used, now and in the future.

From: Watson, Alex R [mailto:[email protected]] Sent: 10 March 2015 12:30 To: May, Richard Cc: Horrocks, Sarah; Belt, Richard Subject: Wrexham AQ assessment

Richard Further to our discussion we are currently looking at a site at Wrexham Industrial Estate and as such our air quality team is assessing potential impacts for emissions.

With regards to the River Dee and Bala Lake SAC and the SSSI we are currently trying to identify which habitats are best used to model the critical loads. As discussed none of the habitats are on the APIS website for critical load comparison and you don’t think that the woodland and grassland habitat should be used.

Can you please let me know how you think we should approach this and which habitat type should be used for assessing critical load.

Unfortunately we are trying to finalise the assessment so a quick reply would be very much appreciated.

Regards

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Alex Watson MCIEEM Principal Ecologist, Environmental Planning

ATKINS 75 years of design, engineering and project management excellence

Chadwick House Birchwood Park Warrington WA3 6AE England

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From: Lewis, Anna [mailto:[email protected]] Sent: 01 March 2016 16:08 To: Horrocks, Sarah Cc: Hughes, Tomos ; Shi, Jiping Subject: RE: Wrexham Energy Centre

Thanks Sarah,

Just to let you know, I have now forwarded your emails onto Tomos Hughes (copied in), who is the NRW casework officer for the Wrexham Energy Centre planning applications. I understand that Tomos has already responded to your colleagues on the changed approach to the applications. However, Tomos will contact you directly if he has any further comments to add.

With regard to the change from H1 Annex F to the “Air Emissions Risk Assessment for your Environmental Permit”, I have checked with my Air Quality colleagues and can confirm that the change in guidance does not affect the approach for detailed air quality modelling which was previously advised by NRW in the email dated 26th August 2014.

Best regards, Anna.

Anna Lewis Prif Swyddog Trwyddedu / Principal Permitting Officer Cyfoeth Naturiol Cymru / Natural Resources Wales

Ffôn/Tel: (03000) 654358

Ffôn symudol/Mobile: (07879) 607877

E-bost/E-mail: [email protected] [email protected]

Gwefan / Website: www.cyfoethnaturiolcymru.gov.uk / www.naturalresourceswales.gov.uk

Ein diben yw sicrhau bod adnoddau naturiol Cymru yn cael eu cynnal, eu gwella a'u defnyddio yn gynaliadwy, yn awr ac yn y dyfodol. Our purpose is to ensure that the natural resources of Wales are sustainably maintained, enhanced and used, now and in the future. Twitter: twitter.com/NatResWales Facebook: facebook.com/NatResWales Flickr: Flickr.com/NatResWales Youtube: youtube.com/NatResWales

From: Horrocks, Sarah [mailto:[email protected]] Sent: 01 March 2016 15:29 To: Lewis, Anna Cc: Collins, Pete Subject: RE: Wrexham Energy Centre

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Anna, Sorry to hear you have been off sick, I trust you are fully recovered now. My planning colleagues may have been in touch separately with the planning team, so they may already have provided an answer – I’ll confirm that. Many thanks Sarah

From: Lewis, Anna [mailto:[email protected]] Sent: 01 March 2016 13:41 To: Horrocks, Sarah Subject: RE: Wrexham Energy Centre

Dear Sarah,

Please accept my apologies for not having yet responded to your email of 15th February. Unfortunately I have been on sick leave and returned yesterday, when I picked up your original message.

I will check that the approach to the air quality modelling still stands and get back to you to confirm by email. I will also check on your questions regarding the DCO, although I may need to forward your email to one of my colleagues in the planning team, in order for them to respond to the DCO aspects.

Apologies for any inconvenience this may have caused.

Best regards, Anna.

Anna Lewis Prif Swyddog Trwyddedu / Principal Permitting Officer Cyfoeth Naturiol Cymru / Natural Resources Wales

Ffôn/Tel: (03000) 654358

Ffôn symudol/Mobile: (07879) 607877

E-bost/E-mail: [email protected] [email protected]

Gwefan / Website: www.cyfoethnaturiolcymru.gov.uk / www.naturalresourceswales.gov.uk

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From: Horrocks, Sarah [mailto:[email protected]] Sent: 01 March 2016 09:35 To: Lewis, Anna Subject: FW: Wrexham Energy Centre

Dear Anna,

I wondered if you had had a chance to look at my email below? I can see that the NRW website now states that you are continuing to follow the Horizontal Guidance produced by the Environment Agency. My understanding is that there are no changes to the preferred approach to detailed modelling that we set out below. Neil Heptinstall at the Environment Agency has confirmed that AQMAU guidance for conversion of NOx to NO2 is extant, as is the AQTAG guidance for ecological sites.

I look forward to hearing from you. Kind regards, Sarah

From: Horrocks, Sarah Sent: 15 February 2016 08:55 To: 'Lewis, Anna' Subject: RE: Wrexham Energy Centre

Dear Anna,

You may recall we corresponded back in 2014 regarding the Wrexham Energy Centre planning application? I trust you are still the correct person to contact with regard to this application?

I have been asked to inform you of a change to the approach to the application and also to check, given the time that has passed, that there are no changes to the preferred methodology for air quality assessment?

With respect to methodology I note that the H1 Annex F guidance has recently been withdrawn from the UK Government website and has been replaced with a simplified approach (https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit). I do not

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believe this affects the approach that we have taken for a more detailed air quality assessment. The approach was previously agreed with your colleagues at AQMRAT in the email chain below. If you could confirm this at your earliest convenience whether there are any new or different requirements I would be most grateful.

Many thanks in advance for your time,

Kind regards, Sarah

Sarah Horrocks Associate Consultant, Air Quality & Emissions: Water, Ground & Environment

ATKINS Explore our world of opportunities – www.atkinsglobal.com/careers

Woodcote Grove, Ashley Road, Epsom, KT18 5BW | Tel: +44 1372 756032 | Mob: +44 7803 260476 Email: [email protected] | Web: www.atkinsglobal.com | Careers: www.atkinsglobal.com/careers From: Lewis, Anna Sent: 26 August 2014 11:40 To: Horrocks, Sarah Cc: Ricks, Steve A; Thomas, Gareth; Macdonald, Eirian; Le Mare, Megan Subject: RE: Wrexham Energy Centre

Sarah,

Further to your email below, I have now received comments on the proposed air quality modelling approach for Wrexham Energy Centre CCGT Power Station from my colleagues in our Air Quality Modelling and Risk Assessment (AQMRAT) Team.

Please be aware that AQMRAT have already commented on the planning preliminary environmental information report. Please also note that AQMRAT are only able to give high level comments on the proposed methodology at this stage, because the development is still in the planning stages.

The response from AQMRAT is in red text below each of the bullet points from your original email as follows:

 We will carry out detailed modelling of the CCGT operational stack emissions

 Minimum stack height was determined using D1 which gave 40-45m

 Initial modelling plus visual impact consideration results in a 50m stack height – confirmed through initial modelling as providing adequate dispersion [We cannot comment on whether the proposed stack height is appropriate at this stage. It’s up the applicant/consultant to propose an adequate stack height that is sufficient to safe guard human health and the environment.]

 Modelling will be undertaken for a 2 stack option (stacks would be ~30m apart), which gives higher concentrations than a single/combined stack [As above. The applicant/consultant should propose the stack height, number of stacks and locations etc.]

3  Modelling will focus on NOx and CO, modelling at the IED limits of 50 & 100 mg/Nm for new CCGT*. [NOX and CO are the only pollutants with monthly Emission Limit Values (ELVs) in the

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Industrial Emissions Directive (IED) for natural gas fired CCGT combustion plants (IED Annex V Part 2).]

 Emissions of SO2 will be negligible as firing will be on natural gas only; emissions of PM10 will be inherently negligible from gas turbines [See above, no ELVs for SO2 and PM in IED for natural gas fired CCGT combustion plants.]

3 3  Model extent will ensure coverage of all areas > 0.3 ug/m NOx (>0.2 ug/m NO2)

 AQMAU “worse case” scenario for NOx to NO2 conversion of 0.7/0.35 for short/long term will be applied [In line with current Environment Agency and Natural Resources Wales guidance for NOX to NO2 conversion. Any assumptions less than these values will have to be fully justified and robust.]

 Results will be compared against AQS objectives/EU limit values for human health

o We’ll report the max hourly for short term NO2 (not a percentile, which in any case will be lower) as this is the appropriate value for comparison with the standard [For short-term standards and emission values which have a number of allowable exceedances per year, percentile predictions is the appropriate method to assess against the standard/limit value. Assessing the max hourly (100th percentile) prediction will be conservative.]

 NOx will be compared against critical levels, and AQTAG guidance used to determine N deposition for critical loads [There are two critical levels for NOX (annual and daily). Assessment should be conducted against both critical levels. Nutrient nitrogen should be assessed against appropriate site specific critical loads for all statutory and non-statutory conservation sites.]

o Assessment will consider international/European sites within 10km and SSSI, NNR, LNR, AW & LWS within 2km [These screening distances are in line with Environment Agency guidance H1 – Annex F.]

o Sites with < 0.3 ug/m3 NOx to be screened out for assessment of critical load as N dep will be negligible – AQMRAT to advise as appropriate [Critical level and critical load assessment should be conducted separately. Assuming that an nutrient nitrogen deposition will be negligible because NOX assessment against the critical levels is insignificant, may not be appropriate.]

o AW and LWS will be compared for PC only, as non-statutory sites do not require consideration against PEC [Background concentrations and deposition should be considered at all statutory and non-statutory conservations sites, PCs and PECs should be reported.]

*One point I forgot to mention on the call was that, in order to address a “worst case scenario” for comparison against short term standards, we will also estimate hourly emissions using the footnote value of 75 mg/Nm3. For comparison with the long term standards we’ll assume 24/7 operation at full load, again a “worst case scenario” as it is considered at this stage unlikely the plant would operate in such a manner. [Where has the 75mg/Nm3 been derived from? As stated above the ELV for NOX of 50mg/Nm3 is a monthly ELV, therefore emission concentrations over shorter time periods are likely to be higher in some instances. IED Annex V Part 4 details assessment of compliance with the monthly ELVs. No validated daily average values should exceed 110% of the monthly ELV and 95% of all validated hourly average values should not exceed 200% of the monthly ELV. 200% of the monthly ELV would be equivalent to 100mg/Nm3.]

Hope this helps. Please don’t hesitate to give me a call if you have any questions.

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Best regards,

Anna.

Anna Lewis Prif Swyddog Trwyddedu / Principal Permitting Officer Cyfoeth Naturiol Cymru / Natural Resources Wales

Ffôn/Tel: (03000) 654358 Ffôn/Tel: (029) 2046 8875

Ffôn symudol/Mobile: (07772) 871852

E-bost/E-mail: [email protected] [email protected]

Gwefan / Website: www.cyfoethnaturiolcymru.gov.uk / www.naturalresourceswales.gov.uk

From: Horrocks, Sarah [mailto:[email protected]] Sent: 18 July 2014 10:54 To: Lewis, Anna Cc: Ricks, Steve A Subject: Wrexham Energy Centre

Anna,

Many thanks for taking the time yesterday to discuss the approach to the air quality assessment for the Wrexham Energy Centre planning application. Thanks also for the voice mail with your email address - I also realised as soon as we closed the call that I didn’t have it, so rang back the Cardiff office and fortunately switchboard was able to provide it!

We are providing more information than might usually be included in an EIA, to cover some of the aspects that a permit would cover, but the developer does not intend to submit a permit now, given the exact plant the CCGT will use has not been determined. We are therefore assessing the scheme under the principles of the Rochdale envelope http://infrastructure.independent.gov.uk/wp-content/uploads/2011/02/Advice-note-9.-Rochdale-envelope- web.pdf

To summarise our conversation yesterday:

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 We will carry out detailed modelling of the CCGT operational stack emissions  Minimum stack height was determined using D1 which gave 40-45m  Initial modelling plus visual impact consideration results in a 50m stack height – confirmed through initial modelling as providing adequate dispersion  Modelling will be undertaken for a 2 stack option (stacks would be ~30m apart), which gives higher concentrations than a single/combined stack 3  Modelling will focus on NOx and CO, modelling at the IED limits of 50 & 100 mg/Nm for new CCGT*.  Emissions of SO2 will be negligible as firing will be on natural gas only; emissions of PM10 will be inherently negligible from gas turbines 3 3  Model extent will ensure coverage of all areas > 0.3 ug/m NOx (>0.2 ug/m NO2)  AQMAU “worse case” scenario for NOx to NO2 conversion of 0.7/0.35 for short/long term will be applied  Results will be compared against AQS objectives/EU limit values for human health o We’ll report the max hourly for short term NO2 (not a percentile, which in any case will be lower) as this is the appropriate value for comparison with the standard  NOx will be compared against critical levels, and AQTAG guidance used to determine N deposition for critical loads o Assessment will consider international/European sites within 10km and SSSI, NNR, LNR, AW & LWS within 2km o Sites with < 0.3 ug/m3 NOx to be screened out for assessment of critical load as N dep will be negligible – AQMRAT to advise as appropriate o AW and LWS will be compared for PC only, as non-statutory sites do not require consideration against PEC

For further information about the development, please see the following links:

The developer’s website: http://www.wrexham-power.com/home-eng.html

Key documents are here: http://www.wrexham-power.com/library-eng.html

The PINS website for Wrexham: http://infrastructure.planningportal.gov.uk/projects/wales/wrexham-energy-centre/

The PINS scoping opinion (includes NRW response in appendix): http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/EN010055/1.%20Pre- Submission/EIA/Scoping/Scoping%20Opinion/130109_EN010055_Scoping%20Opinion.pdf

Just to let you know, there was a previous scoping report published back in 2012 which was for a 1.2 GW facility, but this was subsequently dropped in favour of a smaller facility.

I hope that the above gives you sufficient information to be able to comment on the approach. Do not hesitate to give me a call if anything else comes to mind, otherwise I look forward to hearing back from you at the end of the month, once you’ve had a response from AQMRAT.

Kind regards,

Sarah

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Sarah Horrocks CEnv CSci MIAQM Associate, Air Quality and Emissions

ATKINS

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From: Paul Campini Sent: 09 September 2014 11:08 To: Horrocks, Sarah Subject: RE: Wrexham Power

Hi Sarah

Thanks for pointing out the mistake in my progress report, the correct value is the one used in the chart - 9.8 µgm³.

Regards

Paul

From: Horrocks, Sarah [mailto:[email protected]] Sent: 08 September 2014 18:34 To: Paul Campini Subject: RE: Wrexham Power

Hi Paul

Thanks again for your time this morning, it was a very helpful conversation.

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Do let me know if anything else comes to mind.

Kind regards, Sarah

Sarah Horrocks CEnv CSci MIAQM Associate, Air Quality and Emissions

ATKINS

From: Paul Campini Sent: 08 September 2014 14:00 To: Horrocks, Sarah Subject: RE: Wrexham Power Attachments: PR_Report_2014 web copy.doc; Llan-y-Pwll.docx; Llan-y-Pwll NO2.docx.xls; Isycoed partisol 2014 RAW data.xlsx

Hi Sarah

I will discuss which automatic station we would prefer to be used as the models base line with my manager on his return tomorrow.

Regards

Paul

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From: Horrocks, Sarah [mailto:[email protected]] Sent: 05 September 2014 17:48 To: Paul Campini Subject: RE: Wrexham Power

Paul,

We are currently at the assessment stage for the Wrexham Energy Centre and I wondered if we could have a brief chat early next week about the approach we have taken? I have not seen any comments specific to air quality in the WCBC response to the scoping report and PEIR, so I would like to ensure we have covered all local areas of interest. Also, I would like to check on the latest monitoring data for the borough. I have found data on the Welsh Air Quality Forum website but could not see anything for Hugmore Lane in 2014 – has the site closed?

Thanks in advance for your time.

Kind regards Sarah

From: Horrocks, Sarah Sent: 22 November 2012 12:03 To: [email protected] Subject: Wrexham Power

Paul,

Kind regards, Sarah

Sarah Horrocks CEnv CSci MIAQM

Principal Environmental Consultant Air Quality and Greenhouse Gas Management ATKINS

Woodcote Grove, Ashley Road, Epsom, Surrey KT18 5BW Direct: +44 (0) 1372 756032 Mob: +44 (0 7803 260476 Fax: +44 (0) 1372 756888 Email: [email protected] Website: www.atkinsglobal.com/environment

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From:Paul Campini [mailto:[email protected]] Sent: 02 March 2015 08:37 To: Kirby, Jennifer Subject: RE: Air Quality Data.

Hi Jennifer

Please find attached the Isycoed data as requested. I should mention that there may be some differences to when it eventually goes live on the website after QA checking by Ricardo-AEA

Regards

Paul

From: Kirby, Jennifer [mailto:[email protected]] Sent: 27 February 2015 13:51 To: Paul Campini Subject: Air Quality Data.

Hi Paul,

Thank you for your information about PM2.5 measurements.

With regards to our conversation please could you send me Isycoed PM10 data for the year 2014. I have tried to download data for 2014 however it seems to be missing on the files.

I look forward to hearing from you,

Jennifer

Jennifer Kirby BSc, MSc Graduate Environmental Scientist, Air Quality and Emissions

ATKINS Explore our world of opportunities – www.atkinsglobal.com/careers

Euston Tower, 30th Floor East, 286 Euston Road, London NW1 3AT Tel: +44 2071212903 Email: [email protected] | Web: www.atkinsglobal.com | Careers: www.atkinsglobal.com/careers

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From: Paul Campini [mailto:[email protected]] Sent: 16 March 2015 11:36 To: Kirby, Jennifer Subject: RE: Diffusion Tube location data

Hi Jennifer

Thank you for your comments, they will be looked into.

The final report for 2014 as it stands is on the Council website: http://www.wrexham.gov.uk/english/environment/air_quality/reports.htm or specifically: http://www.wrexham.gov.uk/assets/pdfs/air_quality/progress_2013.pdf

The 2015 report is hasn’t been completed yet and in any event won’t be published until it has been approved by the Welsh Government, after the R&A boards comments have been received. When approved it will be translated and then published. However, the diffusion tube data has been submitted to the Welsh Air Quality Website this morning, though the site hasn’t yet updated to reflect this. I suspect this will be amended in the coming days. This website also holds the data that is publically available for the two continuous monitoring stations in Wrexham.

Regards

Paul Campini Technical Officer / Swyddog Technegol Environmental Protection / Diogelu'r Amgylchedd

 Housing, Public Protection and Environment Department, Ruthin Road, Wrexham LL13 7TU  Adran Tai, Gwarchod y Cyhoedd a’r Amgylchedd, Ffordd Rhuthun, Wrecsam LL13 7TU  Tel/Ffôn: 01978 297431 Fax/Ffacs: 01978 315701  www.wrexham.gov.uk www.wrecsam.gov.uk https://twitter.com/wrexhamcbc www.facebook.com/wrexhamcouncil

We aim to provide our service fairly and we monitor our services to check we are meeting this standard. To help us do this I would be grateful if you would visit the following link http://www.surveymonkey.com/s/ppequalitymonitoring and complete the equality questionnaire, which will only take about 2 minutes of your time. Note that this questionnaire is anonymous.

If you wish to receive a hard copy of the questionnaire or require it in a different language then please telephone 01978 298989 or email your request and postal address to [email protected].

Ein nod yw darparu ein gwasanaeth i chi mewn ffordd deg ac rydym yn monitro ein gwasanaethau i wneud yn siŵr ein bod yn cyflawni’r safon hon. I’n helpu i wneud hyn, byddwn yn ddiolchgar pe byddech yn mynd i’r cyswllt canlynol http://www.surveymonkey.com/s/ppequalitymonitoringwelsh ac yn cwblhau’r holiadur cydraddoldeb, a fydd ond yn cymryd tua 2 funud o’ch amser.

Os hoffech dderbyn copi papur o’r holiadur neu os ydych am ei dderbyn mewn iaith wahanol, yna ffoniwch 01978 298989 neu anfonwch eich cais a’ch cyfeiriad post drwy e-bost i [email protected].

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From: Kirby, Jennifer [mailto:[email protected]] Sent: 05 March 2015 15:45 To: Paul Campini Cc: Horrocks, Sarah Subject: Diffusion Tube location data

Dear Paul,

My team has been working with the diffusion tube data from the Wrexham air quality 2014 report.

Just to let you know that the diffusion tube geographical references in the report, that you sent earlier in the year, had inverted x/y co-ordinates. Would it be possible to be sent a final progress report for 2014? In addition to this do you have a draft 2015 report that you could send us and any provisional 2014 diffusion tube data?

I look forward to hearing from you.

Kind regards,

Jennifer Kirby

Jennifer Kirby BSc, MSc Graduate Environmental Scientist, Air Quality and Emissions

ATKINS Explore our world of opportunities – www.atkinsglobal.com/careers

Euston Tower, 30th Floor East, 286 Euston Road, London NW1 3AT Tel: +44 2071212903 Email: [email protected] | Web: www.atkinsglobal.com | Careers: www.atkinsglobal.com/careers

Consider the environment. Please don't print this e-mail unless you really need to.

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