Combustion Activity Submission Hinkley Point C
NNB Generation Company Limited
UK EPR
Hinkley Point C
Combustion Activity Environmental Permit Application
© 2011 Published in the United Kingdom by NNB Generation Company Ltd. All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means, including photocopying and recording, without the written permission of the copyright holder NNB Generation Company Ltd, application for which should be addressed to the publisher. Such written permission must also be obtained before any part of this publication is stored in a retrieval system of any nature. Requests for copies of this document should be referred to NNB Generation Company Limited, Qube 90 Whitfield Street, London, W1T 4EZ. The electronic copy is the current issue and printing renders this document uncontrolled. Controlled copyholders will continue to receive updates as usual.
NNB-OSL-REP-000252 Combustion Activity Submission Hinkley Point C
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NNB-OSL-REP-000252 Combustion Activity Submission Hinkley Point C Non Technical Summary
NonTechnicalSummary
Purpose of this Report
This report supports the application for a Combustion Activity environmental permit for a new nuclear power station to be situated directly to the west of the existing Hinkley Point B power station. The new power station will be referred to as Hinkley Point C (HPC). The power station has twelve back-up diesel generators, which have a combined thermal input in excess of 50 megawatts thermal (MWth), therefore requiring an environmental permiti under the Environmental Permitting Regulations [1]. It should also be noted that as the combustion plant capacity at HPC will be in aggregate over 20 MWth this will also require an application to be made for an European Union Emissions Trading Scheme (EUETS) permit under the Greenhouse Gas (Emissions Trading Scheme) Regulations 2005 [2]. This permit will be applied for separately and in due course. The operator of the installation will be NNB Generation Company Limited and hereafter referred to as NNB GenCo), which is a wholly owned subsidiary of NNB Holding Company Limited which in turn is 80% owned by EDF Holdings Limited and 20% owned by GB Gas Holdings Limited (a wholly owned subsidiary of Centrica PLC).
This document presents details of the installation and its potential impact on the environment. It explains the requirement to use Best Available Techniques (BAT) to ensure an appropriate balance between costs to the operator and benefits to the environment. It also describes the commitments to implement BAT in areas where information is yet to be developed. A Forward Action Plan (FAP) is proposed to address these areas as the overall programme of work progresses and delivers more detailed information.
Proposed Activities
Each of the two UK EPR units at HPC will require four 18.5 MWth, (which equates to 7.9 megawatts electrical
(MWe)) Essential Diesel Generators (EDGs) and two 7 MWth (2.9 MWe) Station Blackout (SBO) diesel generators. It has been agreed with the Environment Agency that any other combustion plant at HPC with a thermal input of < 3 MWth not required to provide back-up power will not be included within the scope of the permit. The installation to which the environmental permit will apply therefore comprises the twelve diesel generators, their associated fuel storage tanks and interconnecting pipework, all of which will be housed within four purpose built concrete buildings each containing two EDGs and one SBO. The diesel generators are safety classified standby installations and would be routinely only be operated for maintenance purposes and during periodic nuclear safety tests. For the purpose of this application, usage has been assumed conservatively as 60 hours per year for each EDG and SBO (based on operational experience on the most recent ‘N4’ generation of nuclear power station in France). The actual running hours are expected to be lower and will depend on the manufacturer’s recommendations and safety case requirements.
i. The regulated activity is defined under Section 1.1, Part A(1), Paragraph (a) of Schedule 1 of the Environmental Permitting (England and Wales) Regulations 2010 as “Burning any fuel in an appliance with a rated thermal input of 50 megawatts or more”.
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Emissions & Monitoring
Emissions
The main emissions to air will consist of hot flue gas containing oxides of sulphur, nitrogen and carbon; smoke (particulate matter) and traces of organic compounds.
Flue gases will be emitted to air via exhaust stacks, which will be approximately 30 metres in height. Each diesel generator will have an individual stack, a plan which details the location of the stacks is provided in Figure 1 of Appendix B.
The infrequent usage of the plant (< 1% of the year) means that the installation of abatement equipment is not considered to be BAT (given the environmental impacts). Following operational testing and validation of the modelling carried out, this position will be reviewed.
There are no planned process related emissions to water from the diesel generators installation. Any replacement of the cooling water/glycol (anti-freeze) mix will be disposed of as hazardous waste.
Sources of noise from the diesel generators are not expected to be significant, considering their intermittent operation and location within concrete buildings. Site-wide equipment specific noise assessments have been carried out based on the noise sound levels associated with the equipment specified for the Flamanville 3 nuclear power station in France (a similar power station which is already under construction), this showed there to be no significant impacts at the site boundary and to local receptors.
There are not expected to be any odour issues associated with the installation. The only potential source of odour is from fugitive emissions associated with the delivery of diesel fuel. The diesel fuel is kept in vented tanks to prevent over-pressurisation. Although each of the main storage tanks will contain enough fuel for constant operation of 72 hours, it is likely they will be required to be maintained at a high level (for safety reasons). Diesel fuel deliveries will be relatively infrequent and of a short duration reducing the potential for fugitive emissions to air and emissions of odour.
Monitoring
Well controlled combustion is essential to minimising the emissions from the diesel generators. In order to monitor the plant during maintenance testing and operation during periodic nuclear safety tests, basic combustion monitoring equipment will be installed (e.g. temperature, oxygen levels and carbon monoxide). This will inform the operator as to the efficiency of the combustion process which impacts on the levels of pollutants released. The equipment to be used will be determined as part of the procurement process. BAT will be considered as part of this process. Monitoring of fuel consumption in order to calculate CO2 emissions will also be required under the EUETS permit (to be applied for in due course).
Due to the diesel generators being standby plant, it is not proposed to install emissions monitoring as this would be unused for most of the year and the maintenance of Monitoring Certification Scheme (MCERTS) systems and staff certification would place a disproportionate burden on the site in comparison to the use of external MCERTS accredited contractors (where required) which is the preferred approach.
Due to the limited frequency of operation and modelled environmental impact, no environmental monitoring is proposed.
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Environmental Risk Assessment
Emissions Benchmarks
Estimated emissions from the diesel generators' operation are compared against the appropriate BAT based benchmarks in Section 3 of this submission. Benchmarks will be considered in the procurement process and a validation will be carried out once the actual engines have been chosen and installed.
Impact Assessment
An initial screening assessment of environmental impact was carried out for particulate matter, carbon monoxide, sulphur dioxide and oxides of nitrogen. Following this, detailed dispersion modelling has also been carried out to consider the impacts of the emissions on the nearby human and ecological receptors; the screening and modelling showed that none of the emission parameters are likely to have an unacceptable impact on human or ecological receptors.
Habitats Directive
Consideration has been given to the impacts on Habitats Directiveii [3] sites within a 15 km radius and no significant impact to the receptors has been identified.
Managing the Activities
General Management
The Operator will implement an integrated management system of documented procedures covering quality, health and safety and environmental management. The environmental aspects of the management system will be developed to comply with the requirements of BS EN ISO 14001:2004 [4] and will meet the indicative BAT requirements of the regulatory Sector and Horizontal Guidance. As the development of procedures will follow agreement of the detailed design and procurement, the management system will be one of the actions to be delivered through the FAP.
Accident Management Plan
A first environmental accident risk assessment has been carried out on the plant that comprises the installation. The risk assessment focused on the engineered design as the procedural aspects, as discussed above, have yet to be determined. When the engineered and procedural mitigation has been completed, a quantified risk assessment will be completed.
The main risk identified from the operations to be permitted is considered to be the loss of containment of the diesel fuel. This is mitigated by virtue of the containment of the diesel building and the integral bunding (the tanks are located in a bunded area of the diesel building which will be impermeable to the fuel).
NNB GenCo will develop, implement and maintain a hazard and risk management system, which addresses the potential accidents, associated with the installation and provide an accident management plan.
ii. In the UK, the Habitats Directive is implemented by the Conservation of habitats and species regulations 2010 (SI 2010 No. 490)
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Raw Materials
The main raw material used in the diesel generators is diesel fuel oil which will be consistent with BS 2869:2010 [5] and will also comply with the Sulphur Content of Liquid Fuel (SCOLF) (England and Wales) Regulations 2007 [6] (or relevant future standard or legislation). The use of fuel oil will be minimised since, under normal operations, the diesel generators will only be run for safety related testing and maintenance required by the manufacturer.
Other raw materials include lubricating oil, antifreeze and batteries all of which will be required predominantly for maintenance operations to maximise the reliability of the diesel generators.
Energy Efficiency Measures
Fuel oil supplies the energy requirement for the diesel generators. The electricity generated during the test runs will be exported to the National Grid. No operation of the diesel generators will be performed solely for commercial reasons. Electrical consumption by the diesel generators (e.g. for start-up) is considered to be trivial and will not be monitored separately from the wider station usage.
Though not confirmed, it is expected that the diesel generators will also be permitted under the EUETS; this is consistent with the approach taken across the existing UK operational reactor sites.
Avoidance, Recovery and Disposal of Waste
Relatively small quantities of waste will be generated by the operation of the diesel generators. Waste will be managed as part of the overall arrangements on the site.
All wastes generated will be subject to assessment in line with the waste hierarchy and the NNB GenCo Integrated Waste Strategy (IWS) with disposal to landfill being undertaken only when no other options are feasible.
Installation Issues
The installation will be wholly owned and operated by NNB GenCo. There will not be any areas where operational responsibility is unclear.
Permit Surrender
As part of the site decommissioning and permit surrender plan, the diesel generators will be taken out of service when no longer required to support safety related activities on the power station. Although it is not practicable to develop a precise decommissioning and permit surrender plan for the standby generators at this time, the approach will be based on existing plant closure and demolition methodologies for diesel fuelled power plant. It is likely that there will be a continuous improvement in these methodologies over the station life, and the best practice at the time of site closure will be employed.
Decisions on the re-use of plant items, recycling of materials or their disposal as waste will be made at the time of decommissioning, in the light of available technology, economic considerations and legislation.
As part of this process an assessment of land quality will also be carried out to confirm there has been no degradation of land quality during operations under the environmental permit.
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Contents
1 Introduction ...... 1
1.1 Scope of Supporting Data ...... 1
1.2 Proposed Permitted installation...... 3
1.3 Applicable Guidance ...... 4
1.4 Contents of this Submission and Supporting Data...... 4
1.5 Best Available Techniques ...... 5
2 Proposed Activities ...... 7
2.1 Proposed Technology...... 7
2.1.1 Choice of Generators ...... 8
2.1.2 Choice of Fuel ...... 13
2.2 Description of Plant...... 14
2.2.1 Requirement for Combustion Plant...... 14
2.2.2 Plant Description ...... 16
2.2.3 Options for Emissions Control ...... 21
3 Emissions & Monitoring...... 23
3.1 Emissions ...... 23
3.1.1 Point Source Emissions to Air...... 23
3.1.2 Potential Abatement Options for NOX Emissions ...... 25
3.1.3 Potential Abatement Options for SO2 Emissions...... 29
3.1.4 Potential Abatement Options for PM Emissions ...... 30
3.1.5 Other Releases...... 32
3.1.6 Point Source Emissions to Water...... 34
3.1.7 Emissions to Land...... 35
3.1.8 Fugitive Emissions...... 35
3.2 Odour ...... 40
3.2.1 Sources ...... 40
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3.2.2 Complaints History ...... 41
3.3 Noise and Vibration ...... 42
3.3.1 Sources of Noise...... 43
3.3.2 Noise Receptors and Sensitive Sites...... 44
3.3.3 Noise Measurements and Monitoring...... 44
3.3.4 Complaint History...... 45
3.3.5 Initial Risk Assessment ...... 45
3.3.6 Assessment of BAT...... 46
3.4 Monitoring...... 47
3.4.1 Sources of Monitoring Guidance ...... 47
3.4.2 Emissions Monitoring ...... 47
3.4.3 Environmental Monitoring (Beyond the installation)...... 51
3.4.4 Monitoring of Process Variables...... 53
3.4.5 Monitoring Standards (Standard Reference Methods)...... 54
4 Impacts ...... 57
4.1 Impact Assessment...... 57
4.1.1 Local Environment...... 57
4.1.2 Approach to Impact Assessment for Emissions to Air...... 61
4.1.3 Impact Assessment for Emissions to Air ...... 62
4.1.4 Assessment of the Impact of Emissions to Water ...... 74
4.2 The Conservation of Habitats and Species Regulations 2010...... 75
5 Managing the Activities...... 77
5.1 Management Systems...... 77
5.1.1 Management System Requirements...... 79
5.1.2 Operations and Maintenance ...... 79
5.1.3 Competence and Training ...... 81
5.1.4 Accidents, Incidents and Non-Conformances...... 82
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5.1.5 Organisation...... 83
5.2 Accident Management Plan ...... 86
5.2.1 Identification of Hazards...... 87
5.2.2 Environmental Risk Assessment ...... 88
5.2.3 Quantitative Risk Assessment ...... 90
5.3 Raw Materials ...... 97
5.3.1 Raw Materials Selection...... 97
5.3.2 Raw Materials Handling and Storage...... 102
5.3.3 Waste Minimisation Audit (Minimising the Use of Raw Materials).... 104
5.3.4 Water Use ...... 105
5.4 Avoidance, Recovery and Disposal of Waste...... 106
5.4.1 Waste Handling...... 108
5.4.2 Waste Recovery or Disposal ...... 109
5.5 Energy Efficiency Measures ...... 113
5.5.1 Basic Energy Requirements (1) ...... 114
5.5.2 Basic Energy Requirements (2) ...... 115
5.5.3 Further Energy-Efficiency Requirements...... 117
5.6 Permit Surrender/Closure ...... 117
5.6.1 Design and Build ...... 118
5.6.2 Operations During the Lifetime of the Permit ...... 118
5.6.3 Site Closure Plan...... 118
5.7 Installation Issues ...... 120
6 Forward Action Plan ...... 121
6.1 Introduction...... 121
6.2 Generic Design Assessment...... 121
6.3 Forward Action Plan...... 121
6.4 Conclusion...... 125
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7 References and Acronyms ...... 127
7.1 References ...... 127
7.2 Acronyms...... 131
Table 1.2.1 Description of Installation for Permit Application 4 Table 1.4.1 Submission Structure 5 Table 2.1.1 Combustion Plant Included and Excluded from the Installation 7 Table 2.1.2 Comparison of Options Against Fundamental Requirements 9 Table 2.1.3 Comparison of Diesel Generators and Gas Turbine Generators 11
Table 2.2.1 HPC Combustion Plant Size (> 3 MWth) 16 Table 2.2.2 Flamanville 3 Combustion Plant Details 16 Table 2.2.3 Details of LOOP Scenarios [21] 19 Table 2.2.4 Predicted Fuel Use and Storage 21 Table 3.1.1 Point Source Release Nomenclature 24 Table 3.1.2 Stack Emission Characteristics 24 Table 3.1.3 Indicative Composition of Point Source Emissions to Air from the Installation 25
Table 3.1.4 Indicative BAT Requirements for the Abatement of Emissions of NOX 28
Table 3.1.5 Indicative BAT Requirements for the Abatement of Emissions of SO2 30 Table 3.1.6 Indicative BAT Requirements for the Abatement of Emissions of PM 32 Table 3.1.7 Indicative BAT Requirements for the Control of Point Source Emission to Air 33 Table 3.1.8 Indicative BAT Requirements for Fugitive Emission to Air 36 Table 3.1.9 Indicative BAT Requirements for Fugitive Emissions to Surface Water, Sewer and Groundwater 38 Table 3.2.1 HPB Complaints History (Last 5 Years) 41 Table 3.2.2 Indicative BAT Requirements for Odour Control 41 Table 3.3.1 Sources and Estimates of Noise Emissions 44 Table 3.3.2 Assessment of Predicted Specific Noise Levels During Operation of Two UK EPR Units at HPC Against the Lowest Measured Background Noise Levels at the Nearest Receptor Locations 45 Table 3.3.3 Indicative BAT Requirements for Noise 46 Table 3.4.1 Point Source Emissions to Air - Monitoring Requirements 49 Table 3.4.2 Monitoring Arrangements for Point Source Emissions to Air 49 Table 3.4.3 Indicative BAT for Monitoring 50 Table 3.4.4 Indicative BAT Requirements for Environmental Monitoring (Beyond installation) 52 Table 3.4.5 Indicative BAT for Process Variables 54 Table 3.4.6 Indicative BAT Requirements for Monitoring Standards (Standard Reference Methods) 54 Table 4.1.1 Identification of Important and Sensitive Receptors 59 Table 4.1.2 EALs Used to Assess Impacts 64 Table 4.1.3 Background Pollutant Concentrations Used in Modelling Assessment 65 Table 4.1.4 ADMS Assessment: Commissioning Scenario: Human Receptors 67 Table 4.1.5 ADMS Assessment: Commissioning Scenario: Ecological Receptors 68 Table 4.1.6 ADMS Assessment: Routine Testing Scenario: Human Receptors 69 Table 4.1.7 ADMS Assessment: Routine Testing Scenario: Ecological Receptors 70 Table 4.1.8 ADMS Assessment: LOOP Scenario: Human Receptors (Short Term Only) 71 Table 4.1.9 ADMS Assessment: LOOP Scenario: Ecological Receptors (Short Term Only) 72 Table 4.1.10 ADMS Assessment of Long Term Nitrogen and Acid Deposition at the Nearest Ecological Receptor (Commissioning and Routine Testing Scenarios Only) 73 Table 4.2.1 Identification of European Habitats Directive sites within 15 km of the installation 76 Table 5.2.1 Ranking Matrix for Risk Assessment 88 Table 5.2.2 Calibration of Risk Assessment Outputs 1 - Banded 89 Table 5.2.3 Calibration of Risk Assessment Outputs 2 - Descriptive 90 Table 5.2.4 Example Assessment of Accidents Identified and their Environmental Consequences at HPC 91 Table 5.2.5 Indicative BAT Requirements for Accidents at HPC 94 Table 5.3.1 HPC Raw Materials Assessment 100 Table 5.3.2 Indicative BAT Requirements for Material Selection at HPC 102 Table 5.3.3 Fuel Oil Storage and Handling Arrangements for Diesel Generators at HPC 103 Table 5.3.4 Indicative BAT Requirements for Waste Minimisation Audits at HPC 104 Table 5.3.5 Indicative BAT Requirements for Minimisation of Water at HPC 105 Table 5.4.1 Wastes Handling Arrangements at HPC 108 Table 5.4.2 Indicative BAT Requirements for Waste Handling at HPC 109 Table 5.4.3 Wastes for Recovery and Disposal at HPC 111 Table 5.4.4 Indicative BAT Requirements for Waste Recovery or Disposal at HPC 113 Table 5.5.1 HPC Energy Consumption 114
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Table 5.5.2 Indicative BAT Requirements for Basic Energy Requirements (2) 116 Table 5.6.1 Indicative BAT Requirements for Closure of HPC 119 Table 6.3.1 Combustion Activity High level Forward Action Plan 124
Figure 2.2.1 Typical EDG Routine Test Profile 19 Figure 5.1.1 NNB GenCo Company Structure Showing Director Posts 84
Appendix A Site Condition Report Appendix B Site Maps, Plans and Drawings Appendix C Detailed Dispersion Modelling Appendix D Environmental Management System Information Appendix E Application Forms (A, B2, B3 and F1) Appendix F Completed EPR OPRA Spreadsheet
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1 Introduction
This report supports the application for a Combustion Activity environmental permit made by the NNB Generation Company Limited, Registered Number 06937084 (hereafter referred to as NNB GenCo), which is a wholly owned subsidiary of NNB Holding Company Limited which in turn is 80% owned by EDF Holdings Limited and 20% owned by GB Gas Holdings Limited (a wholly owned subsidiary of Centrica PLC). In turn: x EDF Energy Holdings Limited is a wholly owned subsidiary of EDF Energy (UK) Limited, which is a wholly owned subsidiary of EDF International SA, which is a wholly owned subsidiary of Electricité de France S.A; and x GB Gas Holdings Limited is a wholly owned subsidiary of Centrica PLC.
EDF Energy Holdings Limited also own and operate a number of nuclear power stations in the UK, including Hinkley Point B (HPB). The EDF Group of companies also operates 58 nuclear power reactors in France, with a combined capacity of approximately 63 GWe. EDF is the largest nuclear utility in the world.
As NNB GenCo is a newly formed company it does not have a pre-existing organisation and procedures. However, as a member of the EDF Group of companies, NNB GenCo will have access to the resources, experience and expertise of the world’s largest owner and operator of nuclear power stations. NNB GenCo has taken and will take advantage of the experience and resources of its parents and affiliates. However, as the intelligent customer and knowledgeable owner and operator of HPC, NNB GenCo will establish its own organisation and procedures that account for current Office for Nuclear Regulation1 (ONR) and Environment Agency guidance, and these will be developed over time based upon the status of the project.
The combustion activity is associated with the proposed UK EPR units at the Hinkley Point C (HPC) site, adjacent to the existing Hinkley Point A and B power stations. The application is being made under the Environmental Permitting (England and Wales) Regulations 2010 [1]. For clarity, throughout this submission the Environmental Permitting (England and Wales) Regulations 2010 will be referred to as “the EP Regulations” and the new nuclear reactor at HPC will be referred to as the UK EPR. It should also be noted that as the combustion plant capacity at HPC will be in aggregate over 20 MWth this will also require an application to be made for an European Union Emissions Trading Scheme (EUETS) permit under the Greenhouse Gas (Emissions Trading Scheme) Regulations 2005 [2]. This permit will be applied for separately and in due course.
The report is structured in a style consistent with the new Environment Agency Combustion Sector Guidance [7] however, as this is aimed predominantly at the maintenance of existing permits (rather than producing an application for a new process), reference has been made to the format of the current Scottish Environment Protection Agency (SEPA) Combustion Sector Guidance [8] (the Integrated Pollution Prevention and Control (IPPC) Sector Guidance used by the Environment Agency). This was used in the original British Energy Pollution Prevention and Control (PPC) permit applications and provides a more detailed technical framework for producing a new Combustion Activity environmental permit application.
1.1 Scope of Supporting Data
The HPC new build site will comprise two UK EPR units, each with a separate standalone emergency power supply. This will be provided by essential diesel generators, and as the total aggregate rated thermal input of the
1. The Nuclear Directorate of the HSE was subsumed into the Office for Nuclear Regulation (ONR) on 1st April 2011. ONR is currently an Agency of the HSE but will become an independent statutory body in the future.
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combustion engines is in excess of 50 MW, they are prescribed under the EP Regulations (as transposed into UK legislation to comply with the requirements of the IPPC Directive [9]).
The proposed facility will be a new build and as such, this is a new application (rather than the transfer of an existing process into this regulatory regime by virtue of threshold or process change). The regulated activity is defined under Section 1.1, Part A(1), Paragraph (a) of Schedule 1 of the EP Regulations as:
“Burning any fuel in an appliance2 with a rated thermal input of 50 megawatts or more”.
Rated thermal input is defined as the rate at which fuel can be burned at the maximum continuous rating of the appliance multiplied by the gross calorific value of the fuel and expressed as megawatts thermal.
This application will therefore be submitted in accordance with the requirement of Part 2, Chapter 1, and Regulation 12 of the EP Regulations, which states:
“No person can operate a regulated facility except under and by the extent authorised by an environmental permit”
And Part 2, Chapter 2, Regulation 13 of the EP Regulations, which states:
“On the application of an operator, the regulator may grant to that operator, a permit (in these Regulations, an “Environmental Permit”) authorising the operation of a regulated facility.”
The relevant prescribed process under the EP Regulations relates to combustion activities and not specifically to the diesel generators.
For the purposes of this application the term ‘plant’ generally refers to the diesel generators that form the permitted installation and not the wider nuclear power station.
For this reason, all other smaller combustion engines must also be catalogued and an approach to the significance of the smaller plant agreed3. This definition specifically excludes the reactor operations from the scope of the application as radioactive substances activities interactions will be addressed under a separate environmental permit application made under Schedule 23 of the EP Regulations.
As part of developing the EPR for use in the UK, a suite of generic documentation has been produced to aid the site specific adoption of the reactors and to formalise the basic principles to be applied in the regulatory processes. This process is called the Generic Design Assessment (GDA). The GDA reference reactor is based on the Flamanville 3 design.
As part of the GDA process, a generic document has been produced to support an application for a process prescribed under the IPPC Directive [9] (as transposed into UK law in England and Wales through the EP Regulations). The information presented in this submission is broadly consistent with that detailed in the GDA PPC application [10], produced by AREVA and EDF, with deviations clearly stated.
2. Under Section 1.1 of Part 2, Schedule 1 of the Regulations, for the purpose of paragraph (a) where two or more appliances with an aggregate rated thermal input of 50 MW or more are operated on the same site by the same operator those appliances must be treated as a single appliance (i.e. the EDGs are prescribed because the aggregate rated thermal input exceeds 50 MW).
3. A de minimis threshold of 3 MWth has been agreed with the Environment Agency.
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1.2 Proposed Permitted installation
This document is the submission which will be submitted by NNB GenCo for a permit to operate a Part A(1) installation under the EP Regulations4 at the proposed HPC Power Station, located adjacent to the Hinkley Point A (HPA) and Hinkley Point B (HPB) Power Stations near Bridgwater, Somerset.
The installation is located in a coastal area adjacent (to the west) of the HPA Power Station Nuclear Licensed Site Boundary. For the purpose of the EP Regulations the installation will lie within the Nuclear Licensed Site Boundary.
Figures showing the location of the site and the installation boundary are provided in Figures 2, 3 and 1 respectively in Appendix B, the installation boundary has been determined using the “island” approach agreed with the Environment Agency for the permitting of similar EDF Energy (previously British Energy) reactor sites across the UK. This approach ensures that the EP installation permit will apply to prescribed plant only. On the HPC site, there will be four “islands” (diesel buildings), two supporting each reactor (referred to as Reactor 1 and Reactor 2 for the purpose of this submission).
The centre of the HPC site is located at the following Ordnance Survey National Grid Reference (NGR) co- ordinates: x ST 20300 45800
The centres of the four diesel buildings that comprise the installation boundary are located at the following Ordnance Survey NGR co-ordinates: x Reactor 1, Diesel Building 1 ST 20281 45831 x Reactor 1, Diesel Building 2 ST 20460 45831 x Reactor 2, Diesel Building 1 ST 20048 45831 x Reactor 2, Diesel Building 2 ST 20228 45831
In order to ensure power is always available to the site (even in the event of loss of connection/supply to the National Grid), the site proposes to operate a number of essential diesel generators. Although the largest of these is only 18.5 MWth (7.9 MWe) i.e. below the threshold (of 20 MWth) for regulation as a Part B process, the aggregate rated total is in excess of 50 MWth and as such, is prescribed under Part A(1) of the EP Regulations. It has been agreed with the Environment Agency that other combustion plant at HPC with a thermal input of
< 3 MWth and those not required to provide back-up power will not be included within the scope of this environmental permit application. Any future additional combustion plant over 3 MWth (and any back-up combustion plant regardless of size) will be covered through applications for variations to the Environmental Permit.
Table 1.2.1 outlines the scope of the installation. All of the equipment (engines, pipework and fuel tanks) will be housed in specifically designed buildings; these buildings form the extent of the installation. Specifically excluded from the installation are raw material and waste storage facilities. Oily water drains from the permitted installation will be covered in detail in a separate environmental permit application for a water discharge activity.
These areas serve the wider site with the main purpose being to serve the reactor operations. The diesel
4. The Environmental Permitting (England and Wales) Regulations 2010 transpose the requirements of the Integrated Pollution Prevention and Control (IPPC) Directive into national legislation in England and Wales.
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generator wastes and raw materials comprise a minor portion of that required and generated by the wider site operations.
Table1.2.1 DescriptionofInstallationforPermitApplication
ActivitiesintheStationaryTechnicalUnit Schedule1Reference Operator
Combustion of diesel fuel in stand-by diesel Burning of any fuel in an appliance with NNB Generation Company Limited generators, associated fuel storage tanks and a rated thermal input of 50 megawatts pipework. or more.
1.3 Applicable Guidance
The regulatory guidance used in preparing this submission is listed below. Where relevant and appropriate, earlier versions of Environment Agency guidance have also been referenced.
These earlier versions of the guidance are generally sector specific and are aimed at the production of permit applications rather than compliance with existing permits which tends to be the focus of more recent guidance, which is hence less relevant to this application; (one specific area this applies to is indicative BAT requirements): x How to comply with your environmental permit. Getting the basics right: EPR 1.00 (Environment Agency, April 2008) [11]; x How to comply with your environmental permit. Additional guidance for: Combustion Activities: EPR 1.01 (Environment Agency, March 2009) [7]; x IPPC Sector Guidance Note. Combustion Activities V2.03 (Environment Agency, SEPA, Northern Ireland Environment and Heritage Service (NIEHS), 2005) [8]; x Integrated Pollution Prevention and Control Reference Document on Best Available Techniques for Large Combustion Plants (European Commission, July 2006) [12]; x EPR H1 Environmental Risk Assessment Part 1: Simple assessment of environmental risk for accidents, odour, noise and fugitive emissions (Environment Agency, March 2008) [13]; x EPR H1 Environmental Risk Assessment Part 2: Assessment of point source releases and cost-benefit analysis (Environment Agency, March 2008) [14]; and x H5 Site Condition Report - guidance for applicants (Environment Agency, version 2.0, August 2008) [15]. x
1.4 Contents of this Submission and Supporting Data
Table 1.4.1 below outlines the structure of this submission. This structure is based on the current Environment Agency guidance (EPR 1.00 [11] and EPR 1.01 [7]) for the combustion sector. Guidance from current SEPA Combustion Sector Guidance [8] has also been used to ensure all environmental aspects of the installation are addressed.
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Table1.4.1 SubmissionStructure
Section Title BriefDescription
1 Introduction Demonstration of the need for an environmental permit and how the EP Regulations apply.
2 Proposed Activities A description of the prescribed process demonstrating how BAT has been employed.
3 Emissions and Monitoring Detailing the point source and fugitive emissions on the installation. This section also discusses the odour and noise emissions from the plant as well as the process and environmental monitoring to be carried out.
4 Environmental Risk Assessment This section details the environmental benchmarks pertaining to processes of this nature (as outlined in sector guidance) and discusses the environmental impact from the installation.
5 Managing the Activities A description of the environmental management system arrangements across the site and a discussion of the environmental accident risks and mitigation in place. The management, storage and use of raw materials and wastes are also discussed along with justifications for use/disposal.
6 Forward Action Plan There are some areas where the process information is not fully developed. Throughout this document proposals are made to address these gaps indicated either by the text ‘TBC’ (to be confirmed) or by making a reference to the Forward Action Plan (FAP). Section 6 brings together all of these proposals in one place along with a programme for developing information to address any shortfalls identified.
7 References and Acronyms Provides references used in the production of this document as well as definitions of the acronyms/abbreviations used.
Appendix A Site Condition Report A detailed report outlining the baseline site condition (with respect to the pollutants within the installation).
Appendix B Site Maps, Plans and Drawings Drawings detailing the process, installation and Site location.
Appendix C Detailed Dispersion Modelling A copy of the report produced from the detailed dispersion modelling carried out
Appendix D Environmental Management Relevant EMS data (policy, organogram) System Information
Appendix E Application Forms (A, B2, B3 and Completed application forms A, B2, B3 and F1 F1)
Appendix F Completed EPR OPRA Spreadsheet The printed version of the completed EPR OPRA charging spreadsheet.
1.5 Best Available Techniques
BAT is defined (using the definition in Article 2 of the IPPC Directive) as: x 'best available techniques’ shall mean the most effective and advanced stage in the development of activities and their methods of operation which indicate the practical suitability of particular techniques for providing in principle the basis for emission limit values designed to prevent and, where that is not practicable, generally to reduce emissions and the impact on the environment as a whole; x 'techniques' shall include both the technology used and the way in which the installation is designed, built, maintained, operated and decommissioned; x 'available' techniques shall mean those developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration the costs and
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advantages, whether or not the techniques are used or produced inside the Member State in question, as long as they are reasonably accessible to the operator; and x 'best' shall mean most effective in achieving a high general level of protection of the environment as a whole.
BAT will be considered throughout this submission; at a high level in terms of determining the technology to be implemented, at an operational level addressing the techniques and technology used on the installation and at a procedural level detailing how the site is managed and how management arrangements are applied for environmental protection.
As each section of the process is described, the indicative BAT requirement will be stated and the proposed process compared to demonstrate that BAT is achieved or exceeded. Where any variance from BAT is identified or information is not yet available, this is tabulated and reported in Section 6.
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2 Proposed Activities
2.1 Proposed Technology
ScopeoftheActivities
There will be a number of combustion plant at the HPC site. It has been agreed with the Environment Agency that the scope of the environmental permit will include all combustion plant used to provide back-up power.
However, other combustion plant at HPC with a thermal input of < 3 MWth and those not required to provide back-up power will not be included within the scope of the permit. Table 2.1.1 summarises which combustion plant are included and excluded from the installation.
Table2.1.1 CombustionPlantIncludedandExcludedfromtheInstallation
Plant Included/Excluded Reason/Comment
There will be four separated and identical Essential Diesel Generators (EDGs) Included Provision of back-up power. for each UK EPR unit, these are required to restore the power supply in the event of loss of off-site power when house load operation fails or is not possible. In total there will be eight EDGs at HPC as there will be two UK EPR units.
There will also be two further separate ultimate essential diesel generators Included Provision of back-up power. (per UK EPR unit) to supply power to the actuators required in the event loss of both off-site supplies and the EDGs. These plant are referred to as the Station Blackout (SBO) diesel generators and will be started manually from the main control room within two hours (reserve time of batteries) of plant blackout occurring. In total there will be four SBOs at HPC.
In addition to the plant described in the GDA, small diesel generators may To be included Provision of back-up power. also be used to provide back-up power supply to additional site specific through permit At this stage it is not possible to buildings. variation at a later describe these engines or their date. emissions. It is therefore proposed that these diesel generators (and any others that may be required as the site design evolves) will be included in the permit in a later variation.
Domestic heating and auxiliary boilers will be routinely used around the site Excluded These combustion plant are likely
(particularly during periods of cold weather). Fire fighting diesel pumps to be < 3 MWth and will not be located around the site will only be used for short periods in the event of an used for the provision of back-up emergency or during periodic tests. power.
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DeviationsfromGDADocumentation
The differences between this application and information presented in the GDA process are as follows: x The HPC site will have two UK EPR units, instead of the one described in the GDA, resulting in the following changes to plant numbers:
GDA (1 UK EPR unit) HPC combustion activity (2 UK EPR units)
2 Diesel Buildings 4 x Diesel Buildings
4 EDGs and 2 SBOs in total 8 EDGs and 4 SBOs in total
x The size of the diesel generators in the GDA was originally 17.6 MWth for the EDGs and 6 MWth for the SBOs,
representing an electrical output of 7.5 MWe and 2.5 MWe respectively. However, the nominal (electrical) output of both EDGs and SBOs for HPC has been increased due to site specific aspects like the heat sink, which require more power. This is reflected in the following increase in thermal input to the diesel generators:
- EDGs: each generator at HPC will have a thermal input of 18.5 MWth; and
- SBOs: each generator at HPC will have a thermal input of 7.0 MWth. x The operational hours for each diesel generator was originally 20 hours per year in the GDA; this has increased to 60 hours per year for the HPC combustion activity. The 20 hours per year presented in the GDA reflected the manufacturer's minimum operating specification. However, operational experience from the ‘N4’ unit at Civaux in France indicates that the maximum operating time for diesel generators was 50 hours per year. Allowing for a 10 hour margin it has been estimated that the operational hours for each diesel generator at HPC will be 60 hours per year. x The description of combustion emissions presented in the GDA documentation was only concerned with those arising during ‘normal’ operations. However, the combustion activity for HPC considers emissions during commissioning, routine testing and also during Loss Of Off-site Power events, providing a better assessment of potential environmental impacts from the installation. x Total emissions from the EDGs and SBOs have been updated to reflect the changes in operating hours and size of the diesel generators. x Fuel consumption by the EDGs and SBOs has been updated to reflect the changes in operating hours and size of the diesel generators.
2.1.1 Choice of Generators
The selection of diesel generators has been assessed in the GDA as part of a standard design that has been assessed by the Environment Agency and the ONR. This comparison study provides additional evidence to support the technology chosen to provide electrical supply to essential systems, to enable the safe shutdown of the station in case of an emergency. The three feasible technology options for achieving this are: x Compression/spark ignition engines (diesel generators) run on fuel oil; x Gas turbines run on fuel oil; and x Gas turbines run on gas.
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The fundamental requirements for the selected technologies to fulfil their role as emergency back-up generators are: x Reliability; x Fast start-up; and x Independent of off-site systems and services.
In addition, the technologies should cause the least environmental impact.
FundamentalRequirementsAssessment
The first stage in this comparison study is to establish if each option meets the fundamental requirements.
There will be three levels of performance; poor, average and good. If an option performs poorly (i.e. the technology cannot fulfil its role to provide essential systems with electricity), it will be screened out at this stage of the assessment. Options which perform higher than poor will be assessed using further criteria to determine their performance and environmental impact.
The information on reliability and fast start-up presented in Table 2.1.2 below is based on an objective comparison taken from IEEE Standard 446-19957 [16].
Table2.1.2 ComparisonofOptionsAgainstFundamentalRequirements
Option FundamentalRequirements
Reliability FastStartǦUp Independence
Good reliability. When the application requires Fuel will be stored on the site in Problem identified with 100% load in less than 30 tanks. The site will have full reliability: seconds, diesel generator sets control over the tanks. The tanks can be provided to meet this can be located separately and Option 1 An 18.5 MWth diesel generator requirement. can be correctly sized to allow Diesel generators run on fuel has a large number of moving sufficient storage. The fuel can oil parts increasing its vulnerability be sourced from more than one to failure (e.g. thrown piston, supplier who will deliver the fuel crank issues). However, these to site by tanker. can be replaced fairly readily and quickly.
Good reliability. Most gas turbine generator sets Fuel will be stored on the site in Problem identified with require more than 30 seconds tanks. The site will have full reliability: control over the tanks. The tanks Option 2 can be located separately and Certain plant failures, in can be correctly sized to allow Gas turbines run on fuel oil particular throwing a turbine sufficient storage. The fuel can blade, could leave the plant be sourced from more than one inoperable for a longer period of supplier who will deliver the fuel 8 time . to site by tanker.
7. Context provided in the Facility Manager’s Emergency Preparedness Handbook, Bernard T Lewis & Richard P Payant, 2003.
8. Identified through experience, rather than IEEE Standard 446-1987.
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Option FundamentalRequirements
Reliability FastStartǦUp Independence
Good reliability. Most gas turbine generator sets The site will be reliant on an off- require more than 30 seconds site gas source carried to the site Problem identified with reliability: by a pipeline. Should this gas Option 3 supply be interrupted for any Certain plant failures, in reason, the site will have no Gas turbines run on gas particular throwing a turbine emergency back-up generation. blade, could leave the plant inoperable for a longer period of time.
Discussion
The information in Table 2.1.2 above provides evidence that Option 3, gas turbines run on gas, is reliable but performs poorly due to its dependence on off-site systems and services. For this reason, this option will be screened out at this stage. Option 3 also performs averagely in terms of the time taken to start-up.
Option 2, gas turbines run on fuel oil, performs to a very good standard in independence, good for reliability but average for fast start-up. This option will continue to the next part of the assessment.
Option 1, diesel generators run on fuel oil, performs to a very good standard in terms of start-up and independence. Performance was good for reliability. However, the engine is more vulnerable than a gas engine as it has more moving parts. This option will continue to the next part of the assessment.
PerformanceandEnvironmentalImpactAssessment
This section compares the performance and environmental impact of the remaining two options: x Diesel generators run on fuel oil; and x Gas turbine generators run on fuel oil.
The criteria and comparisons in Table 2.1.3 are based on an objective comparison taken from IEEE Std 446-1995 (Revision of IEEE Std 446-1987)9 [16].
The criteria have been ranked in order of importance. The fundamental requirements score the highest (1) and issues of lesser importance score (2) then (3). The best option has been identified for each criterion.
9. Context provided in the Facility Manager’s Emergency Preparedness Handbook, Bernard T Lewis & Richard P Payant, 2003.
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Table2.1.3 ComparisonofDieselGeneratorsandGasTurbineGenerators
Criteria Importanceof Comparison BestOption Criteria
Starting 1 When the application requires 100% load in less than 30 seconds, diesel Diesel generator sets can be provided that meet this requirement. Most gas turbine generator generator sets require more than 30 seconds.
10 Reliability 1 An 18.5 MWth diesel generator is large for this type of plant (e.g. 20 cylinders), Either has a large number of moving parts increasing its vulnerability to failure (e.g. Frequency and thrown piston, crank issues). severity of failure
An 18.5 MWth gas turbine is not unusually small for the type of plant. However certain plant failures, in particular throwing a turbine blade, could leave the plant inoperable for a longer period of time. Each option has its own issues in relation to frequency and severity of failure. However, both options are tried and tested technology with very good standards of reliability.
Independence 1 Fuel oil to supply the diesel or gas turbine engines will be stored on the site in Either tanks. The site will have full control over the tanks. The tanks can be located separately and can be correctly sized to allow sufficient storage. The fuel can be sourced from more than one supplier who will deliver the fuel to site by tanker.
Achievable 2 Regulatory benchmarks are on the whole the same for both types of Either emissions technology: benchmarks [7] 3 Particulate (PM): 15 mg/m ; and 3 Sulphur dioxide (SO2): 66 mg/m
There are different performance benchmarks for oxides of nitrogen (NOX): Diesel generator: 150 mg/m3; and Gas turbine: 125 mg/m3
Efficiency 2 Under full load, the diesel generator operates more efficiently than a gas Either turbine. However, the reduced exercising requirements for the gas turbine normally make the turbine the lower fuel consumer in standby operation.
Ratings 2 Gas turbines are not readily available in sizes < 5 MW, whereas diesel Diesel generator plant ranges from 1.5 MW and upwards. generator
Installation 2 Gas turbines are considerably lighter and smaller and require total cooling and Gas turbine combustion air. Installation costs are normally less than for diesel generators.
Cost 2 Basic diesel generator costs (not installed), are less than that of a gas turbine. Either However, the overall installed cost for both are comparable due to the lower gas turbine installation cost.
Maintenance 2 The gas turbine is a more simple machine than a diesel generator. However, Either repair service for a diesel generator is generally more readily available than for a gas turbine.
Fuel supply 3 Gas turbines and diesel generators can generally burn the same fuel (kerosene Either to No. 2 diesel) and both fuels can be stored on site until required.
Noise 3 Gas turbines operate more quietly and have less vibration than a comparable Gas turbine output diesel generator.
Cooling 3 Diesel generators and gas turbines normally require water-cooling. Either
Exercising 3 The periodic operating requirements under load are more rigid for diesel Gas turbine generator plant than for gas turbines.
10. Identified through experience, rather than IEEE Standard 446-1987.
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Criteria Importanceof Comparison BestOption Criteria
Frequency Response 3 The gas turbine generator is superior in full-load transient frequency response Gas turbine (ANSI/IEEE Std. 446-1995, Chapter. 4) giving it more flexibility once operational.
Discussion
It is clear that, for many of the performance criteria, there is very little difference in performance between the diesel generator and the gas turbine engine. Where there are differences, the importance of the criteria is low and the poorer performing option can usually be improved in performance or to mitigate environmental impact. For instance the noisier diesel generator can be housed in such a way that the noise levels to the environment do not differentiate from the gas turbine.
The assessment shows a very close comparison of the two options; however the one outstanding advantage the diesel generator has over the gas turbine is the ability to start-up in less than 30 seconds. This is the one area where the gas turbine cannot be improved to match the speed of the diesel generator. For this reason the use of diesel generators has been the preferred option in the design of pressurised water reactors around the world. This commonality in design also has other benefits, including: x A wider pool of experience in terms of environment and safety issues, which makes it possible to improve environmental and safety matters using feedback from this experience; and x Optimised staff management (i.e. commonality of training and procedures), which in turn leads to better environmental and safety performance.
Experience
Experience from France in operating a range of standby combustion plant at existing nuclear power stations. (The CP0, CPY, 1300 and N4 denote the distinct generations of French Pressurised Water Reactor (PWR)): x 1300/N4 power stations have standby diesel generators, which have demonstrated a reliability of some 1 x 10-3 (either on operation or on demand). Repair time for such combustion plant has been about 600 hours (operation) and 10 hours (demand); x CPY power stations have standby diesel generators, which have demonstrated a reliability of some 1 x 10-3 (either on operation or on demand). Repair time for such combustion plant has been about 100 hours (operation) and 20 hours (demand); and x CP0/1300/N4 power stations have standby gas turbines run on fuel oil, which have demonstrated a reliability of some 1 x 10-2 (on operation) and 8 x 10-2 (on demand). Repair time for such combustion plant has been about 10 hours (either on operation or on demand).
In summary, the reliability of diesel generators is about one decade higher than for the gas turbines run on fuel oil. Repair times are, however, shorter for gas turbines run on fuel oil.
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Conclusion
This assessment compared three options for the technology to supply an emergency electricity supply to HPC power station. The first screening, using the fundamental requirements for the technology as the assessment criteria ruled out Option 3, Gas turbine run by gas, as it did not fulfil the requirement for independence.
Options 1 and 2 were compared further using criteria from the IEEE standard [16]. The assessment showed that both options were equally matched in most areas and the majority of the differences were found under criteria of relatively low importance. However, the diesel generator performed better than the gas turbine in one particularly important area; fast start-up. Fast start-up is a fundamental requirement of the technology as it is essential to resume, almost instantaneously, a supply of electricity to essential systems. This is why diesel generators are the preferred option in the design of pressurised water reactors around the world, resulting in improved environmental and safety performance associated with a wide pool of operational experience and optimised staff management.
It is concluded that Option 1, diesel generator run on fuel oil, is considered to be the best technology and should be used to provide the emergency electricity supply to the essential systems for HPC power station.
It may be emphasised that: x The choice of diesel generators rather than gas fired engines, for the reactor emergency power supply, is considered to be BAT, with regards to safety aspects and based on the operational experience feedback available on the fleet of French nuclear power stations, which has shown that this equipment is highly reliable and well-tried; x EDGs can be started from cold very quickly (in the less than 30 seconds). This is vital given the role on the site; x Gas turbines are more expensive to purchase than the equivalent size diesel generator due to the high spinning speeds and temperatures they operate at however this is balanced by lower operating expenditure so there is little difference in cost; x Safety case requires EDGs and SBOs to be of diversified technologies (different types of diesel generators will be used); and x The decision to use EDGs is part of the reference design in GDA and safety assessments carried out for the EPR.
In addition to this, EDF Energy and the wider EDF Group of companies have extensive experience in successfully maintaining and operating EDGs on sites across the UK as well as in support of 58 nuclear reactors in France and has provided engineering expertise to the nuclear sector across Asia and the United States of America.
2.1.2 Choice of Fuel
As part of the development process, NNB GenCo has considered suitable fuels for the provision of emergency power. A range of considerations are discussed below. As each plant will only be operated (under normal operations) for maintenance purposes and during periodic nuclear safety tests, the storage of the fuel is an important aspect in decision making.
Reciprocating engines can be operated on diesel (typically C14H30) or a short chain hydrocarbon such as kerosene or petroleum (typically C9H20). There are two main reasons that diesel is the preferred fuel choice: x Diesel is a long chain hydrocarbon which has a greater energy to volume ratio. This means that slightly lower
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volumes need to be stored; and x The long chain hydrocarbons evaporate more slowly than short chain hydrocarbons resulting in a smaller release of fugitive loss to the environment from the storage tanks.
Both of these aspects are key decision making factors where larger volumes of fuel are stored for standby use.
For large combustion plant, the techniques for controlling releases of NOX and particulates (particulate matter (PM)) are based on burner design, the method of atomisation and the control of primary, secondary and tertiary air. A control loop system is required to govern the air and fuel supply and is significant in air pollution control. Such techniques are not appropriate for small installations using compact, high thermal rating compression ignition engines (as there are no burners).
PM can be reduced by the removal of solids from the fuel, this is not considered practicable for a standby system where the benefits from minimal use outweigh the installation and maintenance costs; additional plant equipment also increases the chances of plant failure which could impact on reliability.
Oil (including bitumen) emulsions and many heavy fuel oils have high sulphur contents and may have high vanadium and nickel contents. The use of oil fuels containing sulphur will result in some sulphur dioxide (SO2) releases, (as well as sulphur trioxide), however the EDGs will use low sulphur oils (below 0.1% w/w sulphur) in line with the Sulphur Content of Liquid Fuels (SCOLF) Regulations 2007 [6] (or relevant future legislation). This precludes the need for any form of flue gas desulphurisation (FGD).
There will be a safety requirement to ensure that there is diversity in the fuel supply chain. This will not have an effect on the sulphur content of the diesel fuel used as all suppliers will be able to provide diesel with sulphur levels that comply with the SCOLF Regulations 2007 [6] (or relevant future legislation).
2.2 Description of Plant
2.2.1 Requirement for Combustion Plant
The sizing and number of diesel generators is based on the power demand and the equipment role in each of the emergency situations which form the design basis of the standby/emergency power supply required. The nominal power of the diesel generators is determined by the reference emergency situation (accident) having the greatest power demand [17] together with an additional safety margin.
The functional criteria [17] for the EDG plant state the following: x In order to comply with the principle of segregation of the four electrical divisions, each division must be backed up by an independent diesel (hence the four EDGs); x The plant can be started without any auxiliary power; x The diesel reaches nominal speed (frequency) and voltage within 15 seconds from start-up signal; x In back-up mode, the diesel generator plant provides electrical power at the voltage and frequency defined by the French nuclear industry in RCC-E11; x The auxiliary diesel systems enable each diesel generator plant to function at full load for 72 hours. This
11. AFCEN, Design and Conception Rules for Electrical Equipment of Nuclear Islands (RCC-E) published in Code form.
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period is compatible with the time taken to commission heavy equipment which could be used to provide a long term supply [17]; and x The 15 day Loss Of Off-site Power (LOOP) is taken into account in the design. A LOOP scenario is a loss of connection to the National Grid resulting in a need for the power station to generate it’s own essential power supplies.
The functional criteria for the SBOs states: x SBOs with their auxiliaries are sufficient to provide the required electrical power following a total loss of the external electrical supplies and of the EDGs supplies; x The function of the system is to supply power to all required equipment at a voltage and a frequency fulfilling the safety criteria and with respect to the dynamic and static limits allowed by the equipment; and x The SBOs must be available for operation within two hours after total loss of electrical supplies.
Both the EDGs and SBOs will normally operate only during periodic tests. The tests aim to ensure that the back- up generators and associated equipment are in good working order. SO2 and NOX are produced only during these periodic tests.
There are no other ‘significant’ combustion plant on the site. In previous permit applications (for the operating fleet of EDF Energy nuclear power stations in the UK) where there were numerous smaller combustion plant on the site (and therefore technically prescribed processes), this was managed (with agreement of the Environment Agency) by defining a de minimis threshold.
Below this level combustion sources were not considered significant and appropriate for regulation. In the event that other process related combustion plant are required, NNB GenCo proposes to apply the de minimis approach and notify the Environment Agency as soon as possible of any process plant > 3 MWth.
This approach has, however been applied at the HPC site to exclude non-process sources such as domestic heating, portable grounds maintenance equipment and mobile on-site equipment such as tractors or fork lift trucks.
The diesel combustion engines are only used to provide emergency power supplies. During test runs, any electricity generated will be exported to the National Grid. Day-to-day requirements for power during normal/routine operation, will be provided through on-site generated electricity or external electricity imported from the National Grid.
A list of individual plant on the installation that exceed 3 MWth is provided in Table 2.2.1 below with further detail on the plant proposed for the Flamanville 3 site in France provided in Table 2.2.2; the Flamanville 3 site is the best source of alternative data for the UK EPR and though, not yet operating, the Flamanville 3 plant is significantly further ahead in terms of construction and procurement.
This de minimis threshold approach is largely consistent with that taken during permitting of the standby generation plant at existing EDF Energy reactor sites and with the Environmental Impact Assessment which is being produced to comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 [18].
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Table2.2.1 HPCCombustionPlantSize(>3MWth)
Plant NumberofPlant Size(MWth)
EDG 8 (4 per UK EPR unit) 18.5
SBO 4 (2 per UK EPR unit) 7
Table2.2.2 Flamanville3CombustionPlantDetails
Plant EDG SBO
Engine SEMT PIELSTICK PC2.6 B MTU 20V4000 P63
Speed 600 RMN 1500 RMN
Nominal power 7,465 kW 2,600 kW
Generator Jeumont (JSALT 1009) Ansaldo (GSN 800 K4)
Voltage 10 kV 690 V
2.2.2 Plant Description
The reference reactor unit includes four main EDGs, each rated around 7.5 MWe (17.6 MWth) and two SBOs at around 2.5 MWe (6 MWth). There will be two reactors on the HPC site giving an aggregated thermal input of
176 MWth. The generators are classified as safety equipment, providing back-up power supply to supported systems in the unlikely case of LOOP.
Each of the diesel generators (EDG and SBO) is a self contained plant in a separate room in each of the diesel buildings, the plant comprise: x Diesel fuel system:
The EDG main diesel fuel oil storage tank will have a 180 m3 capacity and the smaller day (2-hour) tank will have a 4 m3 capacity. The capacity of the day (2-hour) tank is sufficient to allow operation at full load or Maximum Combustion Rate (MCR) for two hours. The SBO main diesel fuel oil storage tank will have a 25 m3 capacity and the day (2-hour) tank will have a 3 m3 capacity (sufficient for operating at full load for at least two hours). x Lubricating oil system:
The EDGs will have a self contained lubrication system using a coupling booster pump. A pre-lubrication device fitted with a recirculating electrical pump reduces the time taken for the engine to run on a priority start-up signal. Continuous pre-lubrication is not required for the SBO plant. x Coolant system:
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The cooling system will be air cooled, with a closed loop water based coolant. The heat produced by the diesel generators is transferred via a cooling loop to a heat exchanger. Continuous pre-heating will be undertaken for both the EDG and SBO plant. x Start-up air system:
Each diesel generator will have a complete compressed air start-up plant comprising a compressor, two start- up lines (with one being sufficient to start an engine), start-up valves and one (or more) tanks where the capacity of a single tank is sufficient for several consecutive compressor start-ups without refilling. x Air intake and extract system:
Air will be supplied for combustion and is designed to avoid any recirculation of flow. Combustion air will be taken from outside the building and filtered before use. x Alternator, excitation and protection circuit. x Local instrumentation and control/ alarm signalling. The diesel generators can be started:
- Locally from the control panel to allow tests to be carried out (measurements and plant data are recorded by the panel);
- Remotely from the main control room; or
- Automatically by a signal from the protection systems (only for EDGs, not for SBOs).
The standby diesel generators are proposed to be installed in separate rooms in the diesel buildings; two EDGs and one SBO per building. The buildings will be located separately to protect against damage caused by an aeroplane crash and positioned to allow easy movement of the diesel generators in and out of the buildings for maintenance/replacement purposes. The buildings are designed to withstand a range of internal and external hazards [19].
Each generator will exhaust through its individual stack, which is located on the roof of the diesel building, i.e. about 30 metres above ground level. All tanks will be bunded to meet the requirements of the Oil Storage Regulations 2001 [20].
Both the EDGs and SBOs will undergo test runs to demonstrate reliability. Test runs of each diesel generator will be required every other month and a qualification test will be performed after maintenance and at least once per operating cycle. If for any reason a diesel generator fails to start during a test run, an additional start would be required. The detailed test programme will depend on the station safety specification and manufacturer's recommendations.
Availability
The EDGs are safety related plant qualified as “Category K3 Equipment” according to RCC-E (design and construction rules for electrical components of PWR nuclear islands). This qualification confirms the plant is capable of performing its design functions under seismic and accidental, as well as normal, conditions. The maximum period of time a generator can be unavailable during operation is 28 days. This can be extended for maintenance but must not exceed an additional 14 days.
OperationalRegime
There are three main types of operational regime covered by this application:
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x Commissioning; x Routine testing; and x LOOP events.
Commissioning
During commissioning it is not anticipated that more than one EDG or SBO will be in operation at any one time. Each EDG and SBO will be operated for 242.5 hours and 738 hours, respectively, during its testing period, i.e. 4,892 combined hours. It should be noted that some of the 738 hours needed for commissioning the SBOs will involved tests that can be carried out before the engines are brought to site. The commissioning hours presented therefore represent a conservative estimate of the time for which plant will be run during this phase. It also should be noted that commissioning operations were not considered in the GDA as this is a site specific activity dependant on manufacturer’s recommendations.
RoutineTesting
Experience of operating diesel generator plant in France suggests that each EDG and SBO will be operated for less than 60 hours per year. The conservative assumption is therefore made for the basis of the air quality assessment (see Section 4) and in support of the environmental permit application that a figure of 60 hours per year will be used as the maximum annual run time for each EDG and SBO diesel generator. In reality it is expected that running hours will be much lower than this conservative figure as the required hours for tests are lower.
Figure 2.2.1 below provides a typical load profile for an EDG engine during routine testing, based on operational experience from SZB. In summary the EDG test run will be as follows: x At least 20 minutes to raise the load from 0% to 100%; x Operation at 100% load for 180 minutes; and x At least 20 minutes to reduce the load from 100% to 0%.
A typical EDG routine test will there last somewhere between 3 hours 40 minutes and 5 hours.
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Figure 2.2.1 Typical EDG Routine Test Profile
Typical EDG Routine Test Load Profile (Based on Operational Experience from SZB)
120%
100%
80%
60% % Load 40%
20%
0% 00:00 00:20 00:40 01:00 01:20 01:40 02:00 02:20 02:40 03:00 03:20 03:40 Hours and Minutes
LOOP
The duration of LOOP events cannot be easily determined. However, LOOP frequencies can be assessed and allocated to a significant range of durations. As EPR design principles include an enhanced robustness against LOOP situations, LOOP scenarios are thoroughly assessed within the safety case prepared to support the application for the Nuclear Site License (NSL). The safety case LOOP durations vary from a very short LOOP (less than 2 hours, typically 30 minutes) to a very very long LOOP (15 days). The NSL submission identifies the following LOOP frequencies for HPC:
Table2.2.3 DetailsofLOOPScenarios[21]
Faults FrequencyforNuclearSiteLicenceApplication ExistingAssessmentsforSZB
Short LOOP (< 2h) 6.12 x 10-2/ry in all states 2.60 x 10-2/ry
Long LOOP (between 2 and 24h) Base case: 1.02 x 10-3/ry. Sensitivity: 5.4 x 10-3/ry in all 5.4 x 10-3/ry states.
Very long LOOP (between 24 and 192h) 1.0 x 10-4/ry in all states N/A
Conditional LOOP after Reactor Trip 1.0 x 10-3. 1/3 short LOOP. 2/3 long LOOP 1.1 x 10-4/ry
Note: ry = reactor year
As far as short and long LOOP events are concerned, the above frequencies are understood as follows: x A short LOOP is expected to occur a limited number of times during the lifetime of the plant; and x A long LOOP is expected to occur about once in the lifetime of a fleet of nuclear sites.
Following a LOOP event, the EDGs are not immediately shut down when LOOP is over, in order to ensure that off-site power has been successfully secured.
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PlantItems
There will be total of four diesel buildings at the HPC site, two diesel buildings per UK EPR, with each building housing the following plant: x 2 x EDGs and 1 x SBO; x Compressed air starter systems; x Batteries for SBO start-up; x Engine lubrication circuits; x Engine cooling circuits with their air-coolers; x The pre-heat circuits; x The main and day fuel tanks; x Electrical protection and Instrumentation and Control equipment; and x Technical equipment for operation of the system.
The diesel buildings will include a leaktight discharge area for loading and unloading of tanker vehicles to allow for capture and clean-up of any hydrocarbon leaks occurring during deliveries and will comply with all relevant Pollution Prevention Guidelines (PPGs), e.g. PPG2: Above Ground Oil Storage Tanks [22]. The floor will be built to withstand the physical and chemical actions of hydrocarbons and will be fire resistant. Drainage for floor washings will be connected to the oily water drainage system.
Any storage container with a capacity greater than 200 litres of hazardous material will be stored in a retention area with a volume at least equal to 110% of the capacity of the largest container or 25% of the total capacity of the containers present. This will ensure compliance with the Oil Storage Regulations 2001 [20] as a best practice measure. Drainage in this area will be connected to the oily water system discussed in the separate permit application for a water discharge activity.
The design of the diesel buildings will also minimise hazards that might potentially lead to incidents, accidents or failures associated with: x Pipe leaks and breaks; x Failure of tanks, pumps and valves; x Internal flooding; x Failing loads (i.e. physical damage); x Internal explosion; and x Fire.
Demonstration of these measures will be provided as part of the FAP through development of the Accident Management Plan.
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FuelOil
EDGs and SBOs will use fuel oil grades with characteristics complying with the requirements of the applicable standards. As an example of this, the fuel oil currently used across the operational fleet of EDF Energy UK reactor sites complies with the specification of BS 2869:2010 [5]. The diesel fuel used also complies with the SCOLF Regulations 2007 [6] (or relevant future legislation) which requires a maximum of 0.1% sulphur by weight (BS 2896:2010 specifies a maximum sulphur content of 1%). Table 2.2.4 details the predicted fuel use per year (based on 60 hours of operation per diesel generator).
The engines will be cooled by a mix of water and glycol (at a ratio of 1:1); this will be a closed loop system. Air coolers may also be used if required.
Each diesel generator will be fitted with a crankcase fume extract system. Fumes from the EDG crankcase fume extract system are discharged at roof level (those from the SBOs are recovered into the air intake). Any oil/liquid leakage from the engines will be collected into the hydrocarbon effluent system sumps and routed (depending on their physical and chemical characteristics) to the site dirty lubricating oil drain tank or to a drum for off site recycling or disposal (as appropriate).
Table2.2.4 PredictedFuelUseandStorage
Engine PredictedFuelUseper StorageVolumes(m3) Delivery StorageArrangements EngineperYear(tonnes)
EDG 93 Main tank: 180 Tanker delivery direct to All tanks will be located within diesel building. the diesel buildings in bunded Day tank: 4 rooms.
SBO 22.5 Main tank: 25 Tanker delivery direct to All tanks will be located within diesel building. the diesel buildings in bunded Day tank: 3 rooms.
Note: Fuel use based on pro rata of GDA figure from 20 to 60 hours (Section 2.1.1 of GDA PPC Application [10])
2.2.3 Options for Emissions Control
PrimaryMeasuresforNOXControl
The operation of diesel generators (EDGs and SBOs) will lead to the discharge of NOX, mostly formed by oxidation (fixation) of nitrogen in the combustion air12. Many of the BAT options, relative to management of the burner arrangements, are not applicable in compression ignition engines such as those proposed for the HPC installation.
Optimisation of the diesel generator management with regards to NOX control will be considered at the engine procurement phase as reflected in the design specification. However, these considerations will be considered against equipment reliability which is the priority for diesel generators.
In addition to optimisation at the design and procurement stages, NOX control will also be addressed by the
12. Typical nitrogen content is 0.01 to 0.05% nitrogen by weight. Estimate supplied by Total Fina Ltd for fuel oil.
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maintenance programme applied to the diesel generators (EDGs and SBOs) to ensure optimum performance.
The maintenance of the EDG and SBO will be addressed in the Operator's Maintenance Policy, which will specify the work programme required to maintain the diesel generators in the best possible standby state to ensure optimum engine availability. This work programme will be based on engine running hours and manufacturer’s recommendations. It should be noted that following maintenance activities, which can significantly affect the engine performance, specific tests, such as stack testing, could be performed following completion of the work if deemed necessary.
PrimaryMeasuresforSO2Control
The operation of diesel generators (EDGs and SBOs) will lead to a discharge of sulphur oxides, mainly SO2.
Emissions of sulphur (as SO2) are directly related to the sulphur content of the fuel (i.e. there is no sulphur in the air therefore it is only the sulphur in the fuel that contributes to the SO2). Combustion management cannot be used to reduce SO2 releases. The diesel generators will use a low sulphur fuel oil, which will ensure low emissions of SO2. Fuel oil must contain a maximum of 0.1% sulphur by weight, as required under the SCOLF Regulations 2007 [6] (or the requirements of future legislation).
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3 Emissions & Monitoring
3.1 Emissions
3.1.1 Point Source Emissions to Air
Emissions to air from point sources will only occur when the plant are operated (for the purpose of environmental assessment this has been assumed to be a worst case of 60 hours per diesel generator for operational maintenance purposes and during periodic nuclear safety tests – for justification methodology please refer to Section 2.2). The emissions will be from: x The stacks of the diesel generators, with hot flue/exhaust gases potentially containing the combustion products listed below and traces of volatile organic compounds (VOCs):
- NOX comprising NO2, NO and N2O;
- SO2;
- PM; and
- Carbon dioxide (CO2) and carbon monoxide (CO). x The EDGs crankcase fume extract system vents (the SBO crankcase fume extract is recovered back as intake air). Fumes from this system will be discharged at roof level of the diesel building. This emission will consist of air with traces of lubricating oil fumes. Abatement could be installed in the form of a coalescer filter, however, this is not considered reasonably practicable due to the limited operational hours. If, during operation, this is considered problematic, the situation will be reviewed; and x The EDGs' and SBOs' main and day fuel tanks vents. Although these are point sources, the tanks will be configured such that releases to air would only be expected during filling operations.
Since the EDGs are to be operated on an intermittent basis (i.e. each diesel generator will be operated less than 1% of the year per plant), no continuous stack emissions monitoring system, which would require maintenance, is proposed. The diesel generators could be fitted with simple process control instruments to monitor smoke density and oxygen if required by the Combustion Activity environmental permit and periodic emissions testing during operation could be undertaken. Monitoring ports will be fitted to allow monitoring to be carried out at an agreed frequency if required.
A plan showing the location of the emissions points from the diesel generators across the site is provided in Figure 1 of Appendix B and provides additional information about each of the point sources.
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Table3.1.1 PointSourceReleaseNomenclature
EmissionPointReference Reactor DieselBuilding PlantType GridReference
A1 1 1 EDG ST 20288 45834
A2 1 1 EDG ST 20288 45848
A3 1 1 SBO ST 20277 45813
A4 1 2 EDG ST 20468 45848
A5 1 2 EDG ST 20468 45834
A6 1 2 SBO ST 20456 45813
A7 2 1 EDG ST 20056 45834
A8 2 1 EDG ST 20056 45848
A9 2 1 SBO ST 20044 45813
A10 2 2 EDG ST 20235 45848
A11 2 2 EDG ST 20235 45834
A12 2 2 SBO ST 20224 45813
Manufacturer's data, typical of the size of the EDGs and SBOs that will be installed at the UK EPR power station, is provided in Table 3.1.2. This is indicative of the characteristics of point source emissions to air.
Table3.1.2 StackEmissionCharacteristics
DieselGenerators EmissionPointCharacteristics
StackHeight(m) InternalDiameter EffluxVelocity(m/s) VolumetricFlow 3 (m) Rate(m /s)
EDG vent stacks 30 1 35 10.45
SBO vent stacks 30 1 10 10.45
EDG Crankcase fume extract vents TBC* TBC TBC TBC
Note: Stack data is taken from the dispersion modelling report (Appendix C).
* TBC = To be confirmed. See Section 1.4 for an explanation of the use of this term.
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Table 3.1.3 gives the indicative composition of the point source emissions to air.
Table3.1.3 IndicativeCompositionofPointSourceEmissionstoAirfromtheInstallation
DieselsGenerators EmissionPointComposition(0°C,15%O2101.3Paanddry)
NOX(NO2) SO2 CO Unburned PM (mg/m3) (mg/m3) (mg/m3) Hydrocarbons (mg/m3) (HC)(mg/m3)
EDG vent stacks 1,908 182 150 Trivial 50
SBO vent stacks 1,801 106 150 Trivial 50
EDG crankcase fume TBC TBC TBC Trivial TBC extract vents
Note: Emissions concentrations based on those provided in the GDA but have been changed to reflect an increase in engine size for HPC.
The diesel generators will not be used for long periods of time (i.e. not for commercial gain). The generators are only designed to provide back-up to emergency electrical systems on the HPC site. This infrequent operation over relatively short time periods will result in minimal emissions to air. The level of use will be determined by test and maintenance requirements and unplanned (emergency) events (60 hours per year per diesel generator has been assumed as a worst case).
Due to the low frequency of operation, the fitting of abatement equipment to the diesel generators has not been considered for the reference design, and is not thought to be justified. The following Section 3.1.2 considers potential control systems for the generation of NOX, including primary control measures, control through engine design and secondary abatement techniques that are available to control NOX emissions from diesel generators.
The assessment of available design and operational (and secondary) abatement techniques (should this be necessary) for the abatement of NOX emissions for EDGs and SBOs, are summarised in Section 3.1.2 below.
3.1.2 Potential Abatement Options for NOX Emissions
PrimaryMeasuresforNOXControl
The most important NOX with respect to releases from combustion processes are nitric oxide (NO), nitrogen dioxide (NO2) (i.e. NOX) and nitrous oxide (N2O). Nitric oxide forms over 95% of the total NOX in emissions from most types of combustion plant.
There are three recognised NOX formation mechanisms:
x "Fuel NOX" by conversion of chemically bound nitrogen in the fuel;
x "Thermal NOX" by fixation of nitrogen in the combustion air; and
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x "Prompt NOX" by a mechanism in which molecular nitrogen is converted to NO via intermediate products in the early phase of the flame front with hydrocarbons participating in the reactions.
The first two mechanisms are the only ones of major importance in most combustion plant. Compression Ignition (CI) engines operate differently to those where fuel is injected over a flame/burner arrangement. Unlike petrol engines (spark ignition (SI)) diesel generators have no spark plug. The diesel generator takes air and compresses it, then injects the fuel directly into the combustion chamber (direct injection). It is the heat of the compressed air that ignites the fuel in a diesel generator.
The diesel generator has four stages of operation (hence the name four stroke engine). These are: x Intake stroke -- The intake valve opens up, letting in air and moving the piston down; x Compression stroke -- The piston moves back-up and compresses the air; x Combustion stroke -- As the piston reaches the top, fuel is injected at just the right moment and ignites, the expanding gases forcing the piston back down; and x Exhaust stroke -- The piston moves back to the top, pushing out the exhaust gases created from the combustion out of the cylinder via the exhaust valve.
Fuel NOX formation depends on the oxygen level in the vicinity of the flame. Reducing oxygen levels reduces fuel
NOX. For the CI engine above, it is clear that this aspect is less important as diesel has a relatively low fuel nitrogen content (however regular maintenance is required to ensure that the air feeds do not change as this can lead to a rise in NO formation).
Thermal NOX formation requires temperatures greater than 1,000°C. Reducing peak temperatures reduces thermal NOX formation. The thermal NOX formation route is the most important source of NOX in emissions from oil and gas fired plant but is less relevant in diesel generators as the compressed air combusts at roughly 550°C at the point the diesel is injected. The diesel combusts in excess air meaning that all the fuel nitrogen is oxidised.
However, this excess of air also fully oxidises the carbon to CO2 producing lower levels of CO.
Baseline NOX emissions from unabated internal combustion engines vary with engine size and speed (Revolutions
Per Minute). Larger, lower speed engines will produce more NOX than smaller high-speed engines.
Reducing the level of excess air can reduce NOX emissions by optimising the oxygen levels for combustion therefore minimising the levels of excess oxygen available to oxidise any nitrogen present. CO must also be controlled so there must be sufficient oxygen to allow full complete oxidisation of the carbon. PM emissions may also increase and thermal efficiency may be affected by incorrect combustion settings. All new plant should be designed with combustion control equipment to take account of these concerns (this is discussed further in Section 3.4).
ControlThroughEngineDesign
The principal technique used to reduce NOX emissions is lean burn technology, where the fuel content of the charge is less than stoichiometric. This reduces local temperatures by dilution and ensures there is ample oxygen for good hydrocarbon conversion.
Low NOX emissions from compression ignition engines can also be achieved by combustion modification. The following techniques can be considered for reducing emissions, although their specific applicability is limited by engine design, plant operation and certain fuel parameters. The suitability and choice of a primary measure may not be directly transferable from one engine to another (or between SI – CI engines):
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x Reduction of charge temperature by the addition of water (CI engines). This reduces NOX, but is impractical in most circumstances;
x Tuning for NOX (ignition timing). Reducing the timing angle reduces NOX emissions but it also reduces engine efficiency and increases levels of CO and VOCs; x Fuel/air mixing improvements (CI engines) is generally an option only for new engines such as is the case at HPC; x Reduction of air manifold temperature. Increased after-cooling may reduce the temperature of the air
charged into the cylinders and reduce NOX levels. This technique should be applicable to both existing and new engines; and x Exhaust Gas Recirculation (EGR). Recycling exhaust gas into the air inlet feeds more inert mixture into the
engine and reduces NOX emission. This method of NOX reduction is not recommended for lean burn engines.
All techniques listed above (except lean burn engines) have the drawbacks of reduced efficiency and increased emissions of CO and VOCs. The effective control of combustion conditions is therefore essential if they are used. In addition, any modifications that increase downtime and reduce availability are not acceptable for plant that is safety related and where reliability is crucial.
SecondaryAbatementMeasurestoControlNOX
End-of-pipe flue gas technologies to reduce NOX emissions are generally not a practical cost effective consideration for applications of this type where the plant is only operated on an infrequent basis. However for completeness, a summary of such techniques is included.
These techniques rely on the injection of ammonia, urea or other compounds to react with the NOX in the flue gas and reduce it to molecular nitrogen. They can be divided into: x Selective catalytic reduction (SCR); and x Selective non catalytic reduction (SNCR).
SCR reduces NO and NO2 to N2 by the addition of ammonia or urea solution into the exhaust gas which can be injected at various locations in the flue gas stream. It may also be positioned after exhaust gas de-sulphurisation, although this arrangement would normally require an exhaust gas reheating stage, which may take up as much as 2% of the electrical capacity. This measure typically removes between 80 and 90% of the NOX. The use of SCR requires the storage of liquid ammonia or ammonia solution and produces an additional effluent stream.
SNCR reduces NOX emissions by chemically reducing it to nitrogen and water through the injection of NH2-X compounds into the combustion chamber. SNCR is operated without a catalyst at a temperature of 850°C to 1,100°C. The temperature window and residence time can strongly influence the reagent used (ammonia or urea). Ammonia tends to give rise to lower nitrous oxide formation but urea may be more effective over a slightly larger temperature window and is easier to handle. Abatement efficiencies of up to 80% have been claimed, although efficiencies of 30-50% are more typical.
SNCR also requires a sufficient retention time for the injected reagents to react with NO. Reagent distribution/injection must be optimised and computational fluid dynamics modelling may be useful (and is essential for all new plant) to show reagent behaviours in the combustion chamber.
Considering the very low number of annual running hours, there is no installed end of pipe NOX abatement plant on the proposed reference design for the EDGs/SBOs. It is likely that any abatement plant will require steady
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operating conditions to function effectively and none of the diesel generators would operate within a suitable regime. Therefore any abatement plant would rarely function effectively and be non-operational for most of the year. Both options will also produce an additional effluent stream which would require impact assessment.
Nevertheless, the necessity for a NOX abatement plant on the installation will be examined once the emissions inventory, impact assessment and a review of abatement techniques applicability have been performed. The environmental impact (as required by the EP Regulations) associated with the operation of the EDGs is considered in Section 4.
IndicativeBATRequirementsfortheAbatementofEmissionsofNOX
Table 3.1.4 below outlines the indicative BAT for NOX control and the proposals to be adopted at the HPC site.
Table3.1.4 IndicativeBATRequirementsfortheAbatementofEmissionsofNOX
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Emissions of NOX should be controlled in plant by a combination, as applicable, of:
Combustion control systems The Operator shall control through periodic test and maintenance that EDGs and SBOs reliability is maximised to ensure that, under emergency conditions, they will be able to function in order to safely shut down the nuclear reactors. The maintenance and servicing regime shall ensure routine engine and injection system maintenance and some performance monitoring on the EDGs and SBOs but keeping the running time reasonably low; Due to the low operating frequency of the diesel generators the gains to be made from installing advanced combustion control equipment may be proportionally small when compared to the technical difficulty, practicalities and cost of implementing and maintaining such systems. In addition, the type of testing following maintenance activities (which can significantly affect the engine performance), will be considered and revised as operational experience is gained and commissioning data is produced. For smaller plant (described as < 100 MW or regulated by aggregation of smaller plant), the sector guidance states that the use of combustion modification techniques may be sufficient in the
consideration of BAT for the control of NOX. The EDGs and SBOs are considered “small” by this definition, and in addition will only be operated approximately <1% of the year. These periods of operation are to ensure their efficient and reliable operation in support of the nuclear power station safety case and to comply with best practice for the maintenance of such plant. The characteristics of the standby diesel generators combustion control systems will be further considered at the procurement stage, and a balance between technical feasibility, environmental benefit and cost will be assessed with reliability being a crucial factor.
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Combustion temperature reduction Systems of combustion temperature reduction will be studied with the manufacturer. However, NNB GenCo already has the following information: The engines are designed to operate within defined temperature
ranges and the injection is optimised to have the NOX emission as low as possible with a minimised fuel oil consumption; The installation of advanced temperature control systems would lead to limited environmental gains. For this reason, installing such a system has not been incorporated in the design. Engines are liquid cooled (via radiators) and therefore rely on ambient temperature to provide adequate cooling of components. Advanced gas cooling is unlikely to yield net environmental benefits, given the requirements to draw energy to circulate and cool the gases.
For coal and oil-fired plant, low NOX burners are required where Compression ignition engines do not require burners. applicable
Over fire air (OFA) Not applicable for liquid-fuelled plant.
Flue/exhaust gas recycling (FGR) FGR is most effective on gas or oil systems where the NOX is derived from combustion air rather than the fuel (as in coal fired systems).
FGR can offer 10-20% NOX reduction on oil burning systems but this may result in an increase in PM emissions.
Given the small reduction in NOX emissions compounded by the limited running times and the significant technical/engineering complexities in implementing this process, means that the addition of FGR is not considered to be BAT for the diesel generators.
Reburn Not considered appropriate to the standby essential diesel generators.
Selective Catalytic Removal or Selective Non-Catalytic Removal for The addition of end of pipe abatement equipment is not considered smaller plant (< 100 MW) is considered BAT where required to meet BAT given the creation of an additional effluent stream, the air quality standards or other environmental standards. chemical storage requirements and the predicted environmental impact (see Section 4).
3.1.3 Potential Abatement Options for SO2 Emissions
As stated in the PPC Combustion Sector Guidance Note [8] the abatement techniques, such as end of pipe desulphurisation techniques are BAT for large coal or oil fired plant, whilst the use of low sulphur fuels is a primary BAT measure for all plant.
The source of sulphur, in emissions to air from combustion processes, is the fuel. During combustion the major oxide of sulphur produced is SO2. Sulphur trioxide (produced in smaller quantities during combustion) is adsorbed and reacts with particles in the flue gases. Sulphur trioxide is more likely to pose a problem with low ash fuels (e.g. fuel oils) and its presence is an important contributing factor in acid smutting. Measures used to control SO2 will also result in lower emissions of hydrogen chloride and hydrogen fluoride.
For fuel oils, the SCOLF Regulations set limitations on the sulphur content of liquid fuels. For smaller scale combustion plant, the use of low sulphur fuels (i.e. less than 0.1%) may be sufficient in the consideration of BAT for the control of oxides of sulphur emissions.
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IndicativeBATRequirementsfortheAbatementofEmissionsofSO2
Considering the very low number of annual running hours of the standby essential diesel generators, it is considered that BAT will be achieved by complying with the primary requirement of using low sulphur fuel. Table 3.1.5 summarises the assessment of EDGs and SBOs against the indicative BAT requirements for the abatement of emissions of SO2.
Table3.1.5 IndicativeBATRequirementsfortheAbatementofEmissionsofSO2
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Use of low sulphur fuels is a primary measure. The installation will operate in line with the SCOLF Regulations. The current limit is 0.1% sulphur maximum by weight. The diesel generators will use fuel oil, which complies with the specification BS 2869:2010 or standards applicable at time of procurement and operation. Section 2.1.3 of the Sector Guidance (2005) states that for plant < 100 MW, the use of low sulphur fuels is considered to be BAT.
3.1.4 Potential Abatement Options for PM Emissions
There is no PM abatement plant planned for the diesel generators. However, filtering of fuel could be carried out to lower PM emissions in the unlikely event that PM emissions from the diesel generators become environmentally significant.
The installation’s performance is assessed against indicative BAT requirements for abatement of PM emissions in Table 3.1.6.
The combustion sector guidance EPR 1.01 [7] indicates that abating PM, especially the finer fractions, is a significant method of controlling the release of heavy metals, dioxins and polycyclic aromatic hydrocarbons (PAHs). However, such techniques are considered to be more appropriate for large solid fuel and oil fired plant. The particulate abatement techniques identified in the combustion sector guidance [7], and listed below, are considered in the following sections of this submission: x Electrostatic precipitators (ESPs); x Fabric filters; x Ceramic filters; x Wet scrubbers; and x Cyclones.
It is concluded that the use of such techniques is not BAT for the combustion plant planned for HPC.
ElectrostaticPrecipitators
Electrostatic precipitators are used in both solid and liquid fuelled combustion plant, they are available for small and large-scale plant and can consistently achieve levels of 50 mg/m3. Given the size of the diesel plant, the
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operating regime and the use of high quality fuel, compliant with British Standards, it is not considered proportional to use electrostatic precipitators.
FabricFilters
Bag (fabric) filters when correctly operated and maintained provide reliable abatement to below 10 mg/m3 and are likely to be the appropriate measure for many applications. They cannot generally be used at temperatures over 250°C. Given the size of the diesel plant, the operating regime and the use high quality fuel, compliant with British Standards, it is not considered proportional to use fabric filters.
CeramicFilters
Ceramic filters are available for small combustion plant and are being developed for larger plant. They can normally achieve reliable levels below 10 mg/m3 and have low maintenance requirements. Ceramic filters are able to withstand high temperatures around 800-900°C and offer the same level of protection as fabric filters. Given the size of the diesel plant, the operating regime and the use of high quality fuel, compliant with British Standards, it is not considered proportional to use ceramic filters.
For CI engines, PM removal efficiency is heavily dependent upon fuel quality. For many CI engines particulate abatement is not required. New CI engines (such as those to be employed on the HPC site) should be capable of achieving the given unabated release levels through efficient combustion. This is further validated by the impact assessment provided in Section 4 of this submission.
WetScrubbers
In a wet scrubber, the flue gas stream is brought into contact with the scrubbing liquid, by spraying it with the liquid, by forcing it through a pool of liquid, or by some other contact method, so as to remove the PM. New CI engines (such as those to be employed on the HPC site) should be capable of achieving the given unabated release levels through efficient combustion. This is further validated by the impact assessment provided in Section 4 of this submission.
Cyclones
Cyclones provide a method of removing larger particulates from a flue gas stream. The general principle of inertia separation is that the particulate-laden gas is forced to change direction. As gas changes direction, the inertia of the particles causes them to continue in the original direction and be separated from the gas stream. The walls of the cyclone narrow toward the bottom of the unit, allowing the particles to be collected in a hopper. The cleaner air leaves the cyclone through the top of the chamber, flowing upward in a spiral vortex, formed within a downward moving spiral. New CI engines (such as those to be employed on the HPC site) should be capable of achieving the given unabated release levels through efficient combustion. This is further validated by the impact assessment provided in Section 4 of this submission.
IndicativeBATRequirementsfortheAbatementofEmissionsofPM
The PPC combustion sector [8] guidance provides a table of indicative BAT requirements (Section 2.2.4) for the control of PM to air, these are discussed in Table 3.1.6.
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Table3.1.6 IndicativeBATRequirementsfortheAbatementofEmissionsofPM
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Where particulate abatement is required, the options include: The installation will use only high-grade fuel oil in the standby diesel generators. Therefore emissions of PM originating from the input Electrostatic precipitators (ESPs); fuel will be minimised. Fabric filters; or Following the H1 impact assessment and detailed dispersion Ceramic filters. modelling, the installation of such abatement (e.g. fabric filter) to reduce PM emissions is not considered BAT. Should actual operating emissions be environmentally significant, this approach will be reassessed.
3.1.5 Other Releases
CO2,COandVOCs
The operation of diesel generators results in emissions of CO2, CO and VOCs.
x All measures to reduce fuel use will also reduce CO2 emissions and fuel with a low ratio of carbon content to
calorific value reduces CO2 emissions; x Elevated CO and VOC emissions indicate poorly controlled combustion and may also indicate higher releases of other pollutants. As CI engines burn fuel in an excess of air, CO is minimised through increased oxidation,
excess oxygen, can however lead to increased NOX generation highlighting the importance of controlling the air feeds into the process (and therefore available oxygen). Good combustion control is required to minimise releases; and x Where necessary, the use of catalytic oxidation in the exhaust gas stream will reduce CO emissions to less than 100 mg/m3.
It is recognised in the Combustion Sector Guidance [7] that, at the present stage of research development, the only means of abatement of CO2 emission is to minimise the operation of the diesel generators. This is currently the case as the plant will only be operated for test and maintenance purposes to ensure reliability.
The reduction of CO in small stationary diesel generators using catalytic oxidation in the exhaust stream may be feasible. However, due to the low running hours of the diesel generators, there would be limited environmental benefit in using catalytic oxidation. Therefore the minimisation of CO and VOCs will be addressed by plant maintenance to ensure efficient and reliable combustion, which will in turn ensure minimised releases. No abatement is proposed.
HalogensandDioxins
Halogens (hydrogen chloride and hydrogen fluoride) are produced during the combustion of coal and oil and some biofuels and waste derived fuels. Techniques used for abating SO2 will also reduce these gases.
Dioxins can potentially be formed by the combustion of any carbon containing fuel in the presence of trace quantities of chloride. Dioxins are usually present in both the particulate and vapour phases and accordingly measures to reduce PM emissions will also significantly reduce emissions of these compounds. FGD systems can enhance dioxin removal as can some SCR systems employed for NOX reduction. These systems should not be relied upon as primary measures to abate dioxins (which should be minimised through combustion control and
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fuel quality), to concentrations below or close to the limits of current measurement and analysis techniques. The prevention of conditions that favour the formation of dioxins and furans immediately following combustion is important. This is achieved by the following design specifications: x Reduction of post-combustion gases by cooling them quickly from higher temperatures through the temperature range of approximately 400°C down to 250°C, to avoid prolonged exposure in the temperature range known to favour dioxin and furan formation; and x Minimise the presence of PM and chloride bearing metal impurities that are known to facilitate dioxin and furan formation.
On the HPC installation, gases will be discharged directly after combustion thus ensuring a rapid cooling. The combustion process will operate at around 550°C. Due to the low chlorine levels in the fuel and operating regime (i.e. limited hours), no additional abatement is proposed for dioxin abatement.
IndicativeBATRequirementsfortheControlofPointSourceEmissiontoAir
The installation’s performance is assessed against indicative BAT requirements for point source emissions to air in Table 3.1.7.
Table3.1.7 IndicativeBATRequirementsfortheControlofPointSourceEmissiontoAir
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
VOC and dioxins - these should be minimised through good In general, the plant will only be run for testing, post maintenance combustion control. checks and during periodic nuclear safety tests, in order to ensure availability during emergency conditions. Combustion control will be kept within normal operational ranges through engine servicing and Operator checks.
The benchmark values for point source emissions to air, listed in This will be the responsibility of the Operator at the site specific Section 3.2.1, should be achieved unless alternative values are stage. Validation testing will be carried out as part of the justified and agreed with the Regulator. commissioning programme.
The main chemical constituents of the emissions should be VOCs (methane equivalent carbon) will be tested and reported in identified, including VOC speciation where practicable. accordance with the permit when issued. VOCs are not anticipated to be a significant component of the exhaust gases and, as such, speciation is not considered to be necessary to demonstrate BAT.
Control of Visible PM Plumes
Even where particulate benchmarks are already met, the aim should Visual impacts from plumes on start-up and during operation will be be to avoid visible emissions. However, because plume visibility is assessed at the site specific stage. extremely dependent on the particle size and reflectivity, the angle Given that the EDGs and SBOs will be only operated for of the light, and the sky background, it is accepted that even when maintenance purposes and during periodic nuclear safety tests (at BAT is employed, and very low emissions are being achieved, some normal operating conditions) any impact should be limited. plumes may still be visible under particular conditions. A visual assessment will be carried out as part of the commissioning programme and during maintenance testing.
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Control of Visible Condensed Water Plumes
The need to minimise water vapour plumes should always be There is not expected to be any significant water vapour in the EDGs considered as, in addition to possible local visual amenity issues, in and SBOs exhausts. severe cases, plumes can cause loss of light, fogging, icing of roads, The EDGs and SBOs should not give rise to plumes that have a visual etc. High moisture content can also adversely affect plume impact outside the site boundary. dispersion so, where practicable, water content of the exhaust stream should be reduced. Ideally, the exhaust should be discharged at conditions of temperature and moisture content that avoids saturation under a wide range of meteorological conditions, including cold damp conditions.
The use of primary energy to reduce a plume simply because it is This will be considered post commissioning when operational visible is not considered BAT. However, it may be appropriate to use information is available. Experience of operating similar plant in the waste or recovered heat. For example, heat in a gas stream prior to UK and France has not shown plume visibility to be an issue. wet scrubbing can be used for re-heating the exhaust stream after scrubbing, by means of a gas-gas heat exchanger. The use of energy for exhaust gas re-heat should be balanced against the benefits gained.
For cooling towers, plume abatement may be achieved by There are no cooling towers for the standby diesel generators. combining conductive heat exchange and evaporative cooling, in the design of the tower. The degree of abatement required will depend upon local conditions and the distance from the towers at the nearest sensitive area. Plume modelling should be employed by an applicant to confirm that the visible (condensed) plume will not ground beyond the boundary fence nor reach areas of habitation at a height that will cause significant loss of light. As a guide, the width of the plume should not file an arc, which subtends an angle greater than 10° when viewed vertically from the ground.
This approach is consistent with other standby diesel plant operated by EDF in France and in UK where combustion control is used as the main control measure to minimise pollutants. Secondary abatement techniques are not considered BAT due to the operating profile.
3.1.6 Point Source Emissions to Water
NNB GenCo envisages no, or minimal, point source emissions to water from the diesel generators themselves. There is the potential for point source emissions to water from associated plant (i.e. outwith the installation). The main issues are: x Cooling system losses or replacement (water/glycol mix) will be disposed off site as hazardous waste, this is a closed loop system and these are expected to be minor; x There will be surface water run off and potentially contaminated drainage from oil storage – all oily water drains on site will be routed through an oil/water separator (this will be covered in detail under a separate environmental permit application for a water discharge activity); x Cleaning chemicals used for housekeeping purposes may be used and minor volumes of washings generated but these are not process related;
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x Firefighting run off will be considered as a site-wide issue (the diesel buildings comprise a minor area of the site); and x Accidental releases are discussed separately in Section 5.
As there are no process related point source releases to water, no further discussion on releases to water is considered necessary. The indicative BAT requirements for point source releases to water have therefore not been assessed.
3.1.7 Emissions to Land
There are no planned releases to land from the installation. All waste arisings will be disposed of off-site using licensed contractors. Predicted waste arisings and the associated management arrangements are described in Section 5.
3.1.8 Fugitive Emissions
A fugitive emission is an emission to air, water or land from an activity from a localised or diffuse source which is not controlled by an emission or background limit. Fugitive emissions are generally taken to include dust, VOCs, litter and fugitive releases to water and ground.
FugitiveEmissionstoAir
Given the nature of the installation (i.e. no combustion of solid fuel or waste) the discussion of fugitive emissions to air only considers emissions of VOCs and does not consider dust or litter.
General guidance on the control of fugitive emissions to air, the implementation of which can be regarded as BAT, has some relevance to the proposed diesel generators. Although the descriptions are more applicable to activities which are more complex and present a greater risk to the environment than diesel fuel combustion for electricity generation purposes, they are nevertheless included below for completeness. x Enclose open vessels and fit abatement equipment to vents; x Install sealed transfer (vapour balance) systems; x Use sub-surface filling via (anti-syphon) filling pipes extended to the bottom of the container; x Use floating roof tanks and bladder roof tanks; x Treat specific releases (by techniques such as adsorption or condensation); x Use tank vent systems that minimise breathing losses (e.g. the use of pressure/vacuum valves). Fit knock-out pots and appropriate abatement equipment where necessary; x Inventory management; x Reduce leakage from pipework or fluid transport systems; and x Use white paint, insulation and active temperature control to reduce the temperature in storage tanks.
The diesel fuel will be stored in tanks therefore most of the techniques listed above can be discounted. There will be small emissions to air of fuel oil vapour, a saturated hydrocarbon VOC emission, from the vents of the
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fuel oil storage tanks. During tanker filling operations, vapour will be displaced from the main storage tanks supplying the diesel generators. There will also be emissions associated with the transfer to day storage tanks from the main tanks. The EDG and SBO diesel fuel tanks will be ‘closed’ vessels equipped with vents for safety purposes. This is considered to be BAT with regards to the abatement of fugitive emissions to air.
IndicativeBATRequirementsforFugitiveEmissiontoAir
Table 3.1.8 assesses indicative BAT requirements for fugitive emissions to air.
Table3.1.8 IndicativeBATRequirementsforFugitiveEmissiontoAir
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
VOCs
When transferring volatile liquids, the following techniques should The fuel oil used for the standby generator will be diesel, which is be employed - subsurface filling via (anti-syphon) filling pipes not considered to be a particularly volatile liquid and less volatile extended to the bottom of the container, the use of vapour balance than other fuel oils (with the exception of heavy fuel oil). lines that transfer the vapour from the container being filled to the The delivery of diesel to the installation should be an infrequent one being emptied, or an enclosed system with extraction to occurrence due to the limited use of the EDGs and SBOs. suitable abatement plant. The diesel fuel tanks will be closed tanks, situated inside ventilated Vent systems should be chosen to minimise breathing emissions (for buildings, which will allow minimum evaporation. The only potential example pressure/vacuum valves) and, where relevant, should be for fugitive emissions arises during filling operations. Pressure relief fitted with knock-out pots and appropriate abatement equipment. and vacuum valves will be fitted as standard. Maintenance of bulk storage temperatures as low as practicable, taking into account changes due to solar heating etc. The following techniques should be used (together or in any combination) to reduce losses from storage tanks at: Atmospheric pressure: Tank paint with low solar absorbency; Temperature control; Tank insulation; Inventory management; Floating roof tanks; Bladder roof tanks; Pressure/vacuum valves, where tanks are designed to withstand pressure fluctuations; and Specific release treatment (such as absorption condensation).
FugitiveEmissionstoSurfaceWater,SewerandGroundwater
There are no fugitive releases to surface water, sewer or groundwater identified as a result of normal operations.
As a result of abnormal or emergency operations, there are number of sources that could cause emissions to surface waters or sewer. There are no pathways to groundwater as the installation and wider site will be covered in competent hardstanding and the drains will be newly installed as part of a contained drainage system.
The main sources are: x Loss of containment of antifreeze/cooling fluid;
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x Loss of containment from fuel tanks; x Loss of containment of lubricating oil; and x Loss of containment from a fuel tanker during delivery.
These issues are discussed in detail in Section 5.
In order to reduce the probability and hazard of these scenarios occurring, commitments have been made by NNB GenCo to comply with best practice in the management, maintenance and control of these potential fugitive releases. Unlike other UK reactor sites, the fuel tanks for the diesel generators will be housed in the same building as the engines. In order to reduce the impact of a spillage, the tanks will be located in a self- contained area of the diesel building which will significantly reduce the potential of a release to the environment.
The consideration of environmental interactions at the design stage has ensured that risks posed by the permitted plant have been engineered out. This engineered approach also applies to the inventories of coolant/antifreeze and lubricating oil that is used in the generators. The exact design for the diesel buildings will be provided to the Environment Agency (if required) once it has been confirmed, this will also include the arrangements for pumping out any spillages from the diesel building basements. NNB GenCo will also ensure that the interior of the building is appropriately lined or coated to prevent any egress of oil as a result of longer term leaks or spills (given the design life of the plant is 60 years, this is an important aspect). Regular inspections will be carried out as part of the requirements of the Integrated Management System (IMS).
Consistent with other UK sites and best practice, areas associated with frequent handling of lubricating oil will have oil spillage kits available at the point of handling. Although the design of the site drainage system has not been completed, oil interceptors will be installed.
Key points that NNB GenCo will address during the design and construction of the diesel buildings are: x Engineering systems to minimise leakages from pipes and ensure swift detection if they do occur; x Provide leak detection for sub-surface pipework, sumps and storage vessels; x Ensure that surfacing and containment of drainage facilities are adequate for all operational areas, taking into consideration collection capacities, surface thicknesses, strength/reinforcement, falls, materials of construction, permeability, resistance to chemical attack, and inspection and maintenance procedures; and x The development of an inspection and maintenance programme for impervious surfaces and containment facilities (as part of the IMS).
For tanker delivery operations, the risk shall be assessed and consideration will be given to the installation of the following measures to minimise risk to the environment from spillage: x An impervious surface; x Spill containment kerbs; x Sealed construction joints; and x Connection to a sealed drainage system.
Key guidance documents that NNB GenCo will consider are:
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x Pollution Prevention Guidelines – Above-ground oil storage tanks: PPG2 (Environment Agency, February 2004) [22] gives information on tanks and bunding which have general relevance beyond just oil; x Pollution Prevention Guidelines – Use and design of oil separators in surface water drainage systems: PPG3 (Environment Agency, April 2006) [23]; x The Control of Pollution (Oil Storage) (England) Regulations 2001 [20] – are generally applicable to the storage of any potentially polluting liquid; and x Pollution Prevention Guidelines – Safe storage – drums and intermediate bulk containers: PPG26 (Environment Agency, May 2011) [24].
Generally, where structures are designed to work without secondary containment (such as lagoons and concrete effluent treatment plant and in this case a subsurface building), maintenance and regular inspections will be provided to a level that will provide equivalent protection.
IndicativeBATRequirementsforFugitiveEmissionstoSurfaceWater,SewerandGroundwater
The design of the reference diesel generators includes protection against fugitive emissions, which could impact on land, water and groundwater. Compliance with the indicative BAT requirements for fugitive emissions to water, listed in Table 3.1.9, will be addressed at the site specific detailed design stage. When produced, the IMS will include procedures relating to the inspection of the surfaces and sumps, where needed, under the responsibility of the Operator.
Table3.1.9 IndicativeBATRequirementsforFugitiveEmissionstoSurfaceWater,SewerandGroundwater
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
1. For subsurface structures: The main diesel tanks will be held in a fully bunded room to capture any potential spills. establish and record the routing of all installation drains and subsurface pipework; All pipework will be internal to the building to ensure that the engineered bund in the building is not compromised. identify all sub-surface sumps and storage vessels; When the internal layout of the diesel buildings is finalised, this will engineer systems to minimise leakages from pipes and ensure swift detection if they do occur, particularly where hazardous detail all pipework and sumps. This will be provided to the (i.e. Groundwater-listed) substances are involved; Environment Agency as part of the FAP. As part of the development of the IMS, a maintenance programme provide secondary containment and/or leakage detection for will be developed, this will be provided as part of the FAP. sub-surface pipework, sumps and storage vessels; and establish an inspection and maintenance programme for all subsurface structures, e.g. Pressure tests, leak tests, material thickness checks or CCTV.
All sumps should: The basement area and any engineered sumps (to contain spillages) will be resistant to the fuel oil stored. The sumps will not be be impermeable and resistant to stored materials; connected to the site drainage systems effectively isolating and be subject to regular visual inspection and any contents bunding the tanks. pumped out or otherwise removed after checking for Regular housekeeping will be carried out across the installation; this contamination; will include periodic inspections of the diesel buildings for leaks and where not frequently inspected, be fitted with a high level the integrity of the bund and sealant/liner. probe and alarm, as appropriate; and be subject to programmed engineering inspection (normally visual, but extending to water testing where structural integrity is in doubt).
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
2. For surfacing: All operations within the diesel buildings are described above and will take place in a full bunded environment. design appropriate surfacing and containment or drainage facilities for all operational areas, taking into consideration Tanker deliveries will take place adjacent to the diesel buildings. collection capacities, surface thicknesses, strength Although the delivery areas have not yet been designed best practice /reinforcement; falls, materials of construction, permeability, will be incorporated to the design to mitigate against minor spillages resistance to chemical attack, and inspection and maintenance during delivery and major spillages as a result of tanker failure. procedures; As part of the IMS, an inspection and maintenance programme will have an inspection and maintenance programme for be implemented that will cover the delivery areas. impervious surfaces and containment facilities; and unless the risk is negligible, have improvement plans in place where operational areas have not been equipped with: an impervious surface; spill containment kerbs; sealed construction joints; and connection to a sealed drainage system.
3. All above-ground tanks containing liquids whose spillage could be All of the fuels storage tanks will be housed within the diesel harmful to the environment should be bunded. For further buildings and are discussed under point 1 of this table. information on bund sizing and design, see the Releases to water references. Bunds should: be impermeable and resistant to the stored materials; have no outlet (that is, no drains or taps) and drain to a blind collection point; have pipework routed within bunded areas with no penetration of contained surfaces; be designed to catch leaks from tanks or fittings; have a capacity greater than 110 percent of the largest tank or 25 percent of the total tankage, whichever is the larger; be subject to regular visual inspection and any contents pumped out or otherwise removed under manual control after checking for contamination; where not frequently inspected, be fitted with a high-level probe and an alarm, as appropriate; and where possible, have tanker connection points within the bund, otherwise provide adequate containment; be subject to programmed engineering inspection (normally visual, but extending to water testing where structural integrity is in doubt).
Storage areas for IBCs, drums, bags, etc, should be designed and All wastes and raw materials used on the installation will be stored operated to minimise the risk of releases to the environment. In in dedicated facilities outside the installation boundary. These areas particular: are not considered directly associated to the proposed installation as their primary purpose is to serve the reactor building, the storage of Storage areas should be located away from watercourses and lubricating and waste oils from the diesel generators will comprise a sensitive boundaries, (e.g. those with public access) and should minor portion of the volumes handled. be protected against vandalism; These areas will be designed in line with best practice. Storage areas should have appropriate signs and notices and be clearly marked-out, and all containers and packages should be clearly labelled; The maximum storage capacity of storage areas should be stated and not exceeded, and the maximum storage period for containers should be specified and adhered to; Appropriate storage facilities should be provided for substances with special requirements (e.g. flammable, sensitive to heat or light) and formal arrangements should be in hand to keep separate packages containing incompatible substances (both “pure” and waste); Containers should be stored with lids, caps and valves secured and in place - and this also applies to emptied containers;
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
All stocks of containers, drums and small packages should be regularly inspected (at least weekly); and Procedures should be in place to deal with damaged or leaking containers.
Where information on the design of the diesel buildings has not yet been developed, this will be recorded in the FAP (Section 6) and a programme of work provided.
3.2 Odour
A preliminary odour assessment has been carried out as part of this submission (considering the early development of the design). A review of the installation based on the knowledge available to date has been carried out to give an indication of likely odour sources. A review of the HPB installation sources and complaints has also been carried out to support this assessment. Figure 8 of Appendix C shows the local human receptors around the HPC site. The receptors shown are also considered with respect to noise impacts in Section 3.3 below.
3.2.1 Sources
The diesel generators are not considered to have a significant odour related environmental impact, the potential sources of odour are: x Diesel vapour vented during tank filling operations; x Combustion gases from plant operations (maintenance runs and periodic nuclear safety tests); and x Crankcase fume extract system venting from the EDGs.
Annual diesel use (per plant) is estimated to be 93 m3 and 22.5 m3 for the EDGs and the SBOs respectively. Diesel has a longer chain carbon than some alternative fuels making it less volatile and having a higher energy value (requiring less fuel to be used). For the EDGs (the main potential source of odour), this equates to less than one full refill of the main storage tanks per year though it is recognised that regular refilling will take place to maintain the tanks at a level consistent with the safety case requirements. Under a worst case scenario, if the tanks are refilled after use, then each tank would be topped up every month. However, each filling operation would be very brief (likely to be less than half an hour). There is no history of complaints from undertaking similar filling operations on EDF Energy sites.
Combustion gases will be vented from the stack at a height of 30 metres. This stack height has been determined to give an optimum dispersion in relation to compliance with air quality standards and will also disperse any odour associated with the combustion process. The combustion process will be set up and maintained correctly to ensure the complete combustion of the fuel which will reduce any potential odour. The diesel operations will be kept to a minimum as they will only be run for test and maintenance purposes.
The crankcase fume extract system releases only occur from the EDGs (the SBO crankcase vent is to be recovered into the intake air). As part of the safety case, the two diesel generators have to be of a different type to prevent a common fault affecting all of the standby plant (this is why the recovery of the crankcase vent is not possible on the EDGs). The releases from the EDGs will be vented at the roof level of the diesel buildings. Each diesel will run for under 1% of the year. Experience across the EDF Energy fleet has shown crankcase vent releases do not cause an odour problem.
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3.2.2 Complaints History
As the HPC installation has no operational history or complaints record, information from the HPB site (relating to sensitive receptors) and the SZB site (as the most modern diesel generator in the EDF Energy fleet) has been provided. At the time of writing, HPB has only received four odour complaint in the last 5 years and none in the last three years. HPB uses gas turbines for standby duties. SZB, which uses diesel generators for standby duties, has not received any complaints in the last 5 years. The history of HPB complaints is detailed in Table 3.2.1.
Table3.2.1 HPBComplaintsHistory(Last5Years)
Date Complaint
June 2006 Diesel odours noted from operating of gas turbines
July 2006 Diesel odours noted from operating of gas turbines
August 2006 Phone call received from local resident with reference to kerosene odour from the station.
April 2009 Odours from kerosene noted during running of the gas turbines
Based on experience of operating the combustion plant at HPB and SZB, the HPC installation is not expected to cause odour related environmental impact. This position is consistent with that observed at the other operational reactor sites managed by EDF Energy.
However, if odours are considered problematic or if complaints of odour are received when operating, an assessment of the source and impacts will be carried out in line with the sector guidance [7] and the H4 Horizontal Guidance on Odour Management [25] (currently under review following consultation).
Odour issues associated with the operation of a number of EDGs together to support the power station under emergency conditions have not been considered. The probability of such an event occurring is low and in the event that the plant is needed to safely operate or shut down the reactor operations, any associated odour release would be of minor concern.
IndicativeBATRequirementsforOdourControl
Compliance with the indicative BAT requirements for odour control is given in Table 3.2.2.
Table3.2.2 IndicativeBATRequirementsforOdourControl
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
1. The requirements for odour control will be installation-specific and depend on the sources and nature of the potential odour. In general:
2. Where odour can be contained, for example within buildings, the The diesel fuel tanks will be closed tanks, situated inside a Operator should maintain the containment and manage the temperature controlled buildings to reduce volatilisation. The only operations to prevent its release at all times. potential for fugitive (odorous) emissions arises during filling operations from the vent. Pressure relief and vacuum valves will be fitted as standard.
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
3. Where odour releases are expected to be acknowledged in the N/A Permit, (i.e. contained and treated prior to discharge or discharged for atmospheric dispersion): For existing installations, the releases should be modelled to demonstrate the odour impact at sensitive receptors. The target should be to minimise the frequency of exposure to ground level concentrations that are likely to cause annoyance; For new installations, or for significant changes, the releases should be modelled and it is expected that the Operator will achieve the highest level of protection that is achievable with BAT from the outset; Where there is no history of odour problems then modelling may not be required although it should be remembered that there can still be an underlying level of annoyance without complaints being made; and Where, despite all reasonable steps in the design of the plant, extreme weather or other incidents are liable, in the view of the Regulator, to increase the odour impact at receptors, the Operator should take appropriate and timely action, as agreed with the Regulator, to prevent further annoyance (these agreed actions will be defined either in the Permit or in an odour management statement).
4. Where odour generating activities take place in the open, (or N/A potentially odorous materials are stored outside) a high level of management control and use of best practice will be expected.
5. Where an installation releases odours but has a low N/A environmental impact by virtue of its remoteness from sensitive receptors, it is expected that the Operator will work towards achieving the standards described in this Note, but the timescales allowed to achieve this might be adjusted according to the perceived risk.
3.3 Noise and Vibration
Nuclear power stations produce noise during normal operation. Sources include systems such as diesel generators, transformers, turbine generator units, Heating, Ventilation, And Conditioning (HVAC) systems and pumps. There are not considered to be any vibration issues associated with operations within the installation.
The primary noise sources of an operational standby diesel generator include the following: x Emissions from the discharge stack; x Running of diesel generators; x Pumps; and x Maintenance.
The noise sources associated with the operation of the reactor are outwith the scope of this submission. It is also of note that the reactor operations will run continuously whereas the running of each diesel is predicted to be less than 1% of the year.
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The noise and vibration sources associated with operation of the plant within the installation are listed in Table 3.3.1. This table shows the location (the building that houses it) and the assumptions used to calculate the acoustic power for each source of noise. Until final manufacturing and test of the equipment for the UK EPR are available, each sound source has been assigned an acoustic power range based on similar sources for which data is available from operating PWRs in France.
The detailed assessment has been performed taking into account the actual site environment. Where noise issues are deemed to be relevant, the Technical Guidance Note for the Combustion Sector [8] has been followed, and thus H3 Part 2 Noise [26] has been consulted and information on the following has been provided: x The main sources of noise and vibration within the permitted installation and also any less frequent sources of noise and vibration; x The nearest noise-sensitive sites; x Conditions or limits on noise/vibration imposed by other regulatory regimes; x The local noise environment; and x Any environmental noise measurement surveys, modelling, or any other noise measurements, and any specific local issues and proposals for improvements.
In an area covered by the Environmental Noise Regulations 2006 [27], site noise levels should, as far as practicable, be less than a value of 55 dB(A) during the day and 50 dB(A) at night time.
3.3.1 Sources of Noise
The operation of the EDGs as a standby facility means that they are only intermittently operational for test purposes, and noise associated with their activity is therefore intermittent.
Test run frequency and duration is a requirement of the nuclear safety case. The foreseen cumulated duration of all diesel generators during commissioning is 4,892 hours in total and will be 720 hours per year at max for routine testing during the operational phase. Although test runs will be scheduled during the daytime (wherever possible), it must be noted that the diesel generators may operate at night during LOOP conditions.
Only in case of grid connection loss would the EDGs be operated continuously until the connection was restored. This could be several days (the diesel storage tanks are sized to give 72 hours continuous operation); and though the associated noise would thus be continuous, it would not accumulate or increase with time (i.e. the noise levels from an 1 hour run are the same at a receptor as a 72 hour run).
Table 3.3.1 contains a list of the noise sources within the installation13, which are hoppers associated with cooling the diesel generators. Additional sources from normal operations include tanker deliveries (fuel pumping) and the operation of mobile plant (in the form of small generators or compressors during outage periods).
13. Noise levels taken from the Table 6 (page 32 of 64) of AREVA NP/EDF, UK EPR, Pre-Construction Environmental Report, Chapter 3: Aspects having a bearing on the environment during operation phase, UKEPR-0003-030, Issue 01, 2008
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Table3.3.1 SourcesandEstimatesofNoiseEmissions
Building NoiseSources PowerofEquipment(dB(A)) Numberof Sources
Diesel Diesel Building 1 of EPR units 1 Hopper 01VB 89.4 per opening 3 and 2 Hopper 01VB 87.7 per opening 3
Hopper 03VB 105 per opening 3
Diesel Building 2 of EPR units 1 Hopper 01VB 89.4 per opening 3 and 2 Hopper 01VB 87.7 per opening 3
Hopper 03VB 105 per opening 3
It should also be noted that none of the plant associated with the combustion activity installation is included in the top 20 HPC noise sources identified in Chapter 11 (Noise and Vibration) of the Environmental Statement [28] being submitted to the Infrastructure Planning Commission.
3.3.2 Noise Receptors and Sensitive Sites
The location of the installation is such that it is relatively distant from areas of residential housing, which would be classed as the nearest sensitive receptor. There are six areas surrounding the installation that could be classed as sensitive receptors.
These are: x Doggets, 1 km south; x The village of Shurton 1.2 km south; x Wick Farm 1.3 km south east; x Little Dowden's Farm 1.6 km to the east; x The village of Knighton 1.8 km south west; and x The settlement of Lilstock >3 km west.
3.3.3 Noise Measurements and Monitoring
Chapter 11 (Noise and Vibration) of the Environmental Statement [28] includes the results from modelling (using CadnaA computational predictive software) of noise propagation from industrial plant and processes across the HPC site and prediction of impacts at the nearest sensitive receptors, including Knighton Farm, Doggetts and Wick Farm.
The modelling and assessment results are presented in the Table 3.3.2
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Table3.3.2 AssessmentofPredictedSpecificNoiseLevelsDuringOperationofTwoUKEPRUnitsatHPCAgainstthe LowestMeasuredBackgroundNoiseLevelsattheNearestReceptorLocations
Receptor SoundPressureLevel(dB(FreeǦfield)) Difference(dB) Predicted noiselessthan 5dBabove Predicted Lowestmeasuredbackground background # specificnoise level(LA90,T) level(LAeq,T (neutralwind)) Day Night Day Night
Knighton Farm 31.9 30 30 +1.9 +1.9 Yes
Doggetts 27.7 32 30 -4.3 -2.3 Yes
Wick Farm 30.3 37 36 -6.7 -5.7 Yes
Note: # Minimum value of 30 dB LA90,T due to limitations of BS4142:1997 [29] methodology. The assessment indicates that, taking into account the limitations of BS4142:1997 [29], predicted noise levels under neutral wind conditions will be acceptable.
In conclusion, the modelling and assessment indicate that: x Taking into account the limitations of BS4142:1997 [29] assessment method predicted noise levels under neutral wind conditions will be acceptable; x Worst case operational noise levels at the nearest residential dwellings should not exceed the recommended target criterion and are therefore assessed as minor impacts; and x The results for the nearest sensitive receptors identified above indicate that the hoppers are not in the top 20 noise sources from HPC at these locations.
3.3.4 Complaint History
Complaints histories have been reviewed for SZB as the operator with the most recently installed diesel generators, and HPB due to its similar proximity to the same receptors as the HPC installation.
In the last 5 years, neither HPB nor SZB has received any noise complaints.
3.3.5 Initial Risk Assessment
At this stage in the development programme, from the available information, it is not possible to discount the possibility that during their operation, the diesel generators have the potential to disturb sensitive receptors in the proximity of the site. However the risk is minimised due to the following factors: x The standby diesel generators will be housed in concrete buildings which offers significant attenuation of the noise generated through combustion operations; x The diesel generators will be part of the site routine maintenance programme, and, as such, will be maintained to a high standard that is reflective of the operational control required at a nuclear power station; x The intermittent nature of the diesel generators operation is such that noise is not generated on a continual
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basis. Where periodic tests and maintenance are required, they should be planned within daylight hours where possible, to minimise potential disturbance to local residents; and x The closest receptor to the site is > 1 km from the site.
3.3.6 Assessment of BAT
The EP Regulations require installations to be operated in such a way that “all the appropriate preventative measures are taken against pollution, in particular through the application of BAT”. The definition of pollution within the Sector Guidance Note includes “emissions that may be harmful to human health or quality of the environment, cause offence to human senses or impair or interfere with amenities and other legitimate uses of the environment”.
Although the diesel generators do have the potential to disturb sensitive receptors during testing operation, they operate for relatively short periods during the year, all reasonable measures to minimise noise levels will be taken by the Operator as presented in Section 3.3.5 above.
Table 3.3.3 discusses the installation’s performance in relation to the indicative BAT requirements for noise.
Table3.3.3 IndicativeBATRequirementsforNoise
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Identification of the main sources of noise and vibration (including The main noise sources on the installation are detailed in Table infrequent sources), the nearest noise-sensitive locations and 3.3.1. relevant environmental surveys which have been undertaken and the The nearest noise sensitive receptors are identified in Section 3.3.2. techniques and measures used for the control of noise. Details of noise measurement and modelling are provided in Section 3.3.3. Techniques and measures used for the control of noise are provided in Sections 3.3.4 and 3.3.5.
The Operator should employ basic good practice measures for the This requirement will be addressed as a key part of the purchasing control of noise, including adequate maintenance of any parts of strategy. Appropriate maintenance will be carried out during plant or equipment whose deterioration may give rise to increases in operations and recorded as part of the preventative maintenance noise. programme.
The Operator should also employ such noise control techniques to The techniques employed at the design stage to minimise the noise ensure that the noise from the installation does not give rise to are the generators are housed in concrete buildings. reasonable cause for annoyance, in the view of the Regulator and, in Rating Levels are a site specific issue; the combustion plant are sized particular, should justify where either Rating Levels (L ) from the Aeq,T according to the reference accident demand. installation exceed the numerical value of the Background Sound
Level (LA90,T).
Further justification will be required should the resulting field rating Modelling from the Flamanville operations have shown that noise level (LAR,T) exceed 50 dB by day and a façade rating level exceed 45 levels from the entire reactor operations will not exceed these dB by night, with day being defined as 07.00 to 23.00 and night thresholds. The installation comprises a small part of the site and 23.00 to 07.00. does not include the main noise sources.
In some circumstances “creeping background’ may be an issue. Monitoring as part of the commissioning programme will provide a Where this has been identified in pre-application discussions with baseline to prevent noise creep. In addition, the plant is only the local authority, the Operator should employ such noise control planned to be operated for maintenance purposes and during techniques as are considered appropriate to minimise problems to periodic nuclear safety tests, and as safety plant will be maintained an acceptable level within the BAT criteria. to the highest standards.
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Noise surveys, measurement, investigation (which can involve Noise levels from the installation are not considered to be a concern detailed assessment of sound power levels for individual items of however, monitoring will be carried out and if necessary, a noise plant) or modelling may be necessary for either new or existing management plan will be produced. It is likely given the operating installations depending upon the potential for noise problems. nature of the installation that any noise management plan would be Operators may have a noise management plan as part of their site wide and include the diesel plant. management system.
3.4 Monitoring
3.4.1 Sources of Monitoring Guidance
There are a number of sources of guidance in determining the appropriate monitoring equipment and techniques to be applied at a permitted installation
Those potentially relevant to this installation include: x Environment Agency combustion sector guidance EPR 1.01 [7]; x M1 sampling requirements for stack emissions monitoring [30]; x Guidance on undertaking an Operator Monitoring Assessment (OMA) Audit [31]; x M2 monitoring of stack emissions to air [32]; x M8 ambient monitoring strategy [33]; x M9 ambient monitoring methods [34]; x M13 monitoring hydrogen sulphide and total reduced sulphur in atmospheric releases and ambient air [35]; x M15 Monitoring PM10 and PM2.5 [36]; x M16 monitoring VOCs to air from industrial installations [37]; x M17 monitoring of PM in ambient air around waste facilities [38]; x M20 quality assurance of continuous emissions monitoring systems [39]; and x Consideration has been given to this guidance in the determination of BAT for the diesel emissions. Where monitoring is performed, it will be consistent with the Environment Agency Monitoring Certification Scheme (MCERTS).
3.4.2 Emissions Monitoring
The installation comprises 12 diesel generators in four separate buildings (two EDGs and one SBO per building) which discharge through 12 separate stacks with each stack emitting combustion gases for as assumed maximum of 60 hours per year.
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This figure is based on operating experience of SZB and the most recent French ‘N4’ type nuclear power station (and closest operational comparison with the UK EPR) and is likely to be conservative (the required time of testing being 20 hours per engine). This bounding scenario equates to less than 1% of the year for each combustion plant and would therefore mean that any monitoring equipment would lay dormant for over 99% of the year.
It is proposed that there will be no emissions monitoring equipment fitted to the diesel exhaust stacks but that monitoring ports are incorporated into the design to allow monitoring to be carried out. It should be noted that there will be monitoring or process variables CO, temperature and oxygen (Section 3.4.4). There are no emissions to controlled waters either directly or indirectly from the installation.
MonitoringofEmissionstoAir
The combustion of diesel produces a gaseous emission containing five main pollutant parameters:
x NOX;
x SO2; x CO; x PM; and x VOCs.
Table 3.4.1 and Table 3.4.2 outline the emissions points on the installation and the monitoring methods currently considered BAT. Where available, monitoring standards should be used in the following order of priority as given in the European IPPC Bureau’s Reference Document (BREF) on the General Principles of Monitoring: x Comité Européen de Normalisation (CEN); and x International Standardisation Organisation (ISO)
These will be reviewed prior to monitoring being carried out to ensure the most relevant standards are applied. It is envisaged that any monitoring requirements of the permit will be met through the use of external contractors who will use MCERTS accredited facilities, methods and staff.
In the event that in-house facilities or equipment is used, then the same standards and methods will be applied and detailed procedures produced to document the methods and techniques used.
The design of sampling ports will be consistent with Environment Agency guidance document M1 [30] and BS EN 15259:2007 [40]. European standard, EN14181:2004 (Stationary source emissions - Quality assurance of automated measuring systems) [41] will not apply as it is not proposed to install continuous emissions monitoring. For the sampling of PM, the location of the port in relation to the dispersion across the profile of the stack will also be considered in line with BS ISO 9096:2003 [42] (or appropriate).
The point source emissions to air from the installation are detailed in Section 3.1 of this submission (Table 3.3.1). Table 3.4.1 and Table 3.4.2 below detail the expected pollutants for each release point and the methods to be applied to monitoring.
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Table3.4.1 PointSourceEmissionstoAirǦMonitoringRequirements
Reference Description Discharges Monitoring
A1, 2, 4, 5, 7, 8, 10, 11 EDG emissions NOX, SO2, VOC, CO, PM TBC
A3, 6, 9, 12 SBO emissions NOX, SO2, VOC, CO, PM TBC
Table3.4.2 MonitoringArrangementsforPointSourceEmissionstoAir
Substanceor Monitoring Monitoring MonitoringMethod14 OtherSpecifications Parameter Point Frequency
NOX (as NO2) A1-A12 TBC A range of extractive methods are available. Technical Guidance Note Monitoring Standard BS EN 14792:2005 [43] (TGN) M22 [44] should be applied
SO2 A1-A12 TBC Various methods include BS EN 14791:2005 [45], TGN M21 [46] and TGN M22 [44].
PM A1-A12 TBC BS EN 13284-1:2002 [47] (if < 50 mg/m3) or Isokinetically to the BS ISO 9096:2003 [42] (if > 50 mg/m3) requirements of BS ISO depending on the concentration 9096:2003 [42] or future appropriate standard.
CO A1-12 TBC A range of extractive methods are available. TGN M22 [44] Monitoring Standard BS EN 15058:2006 [48] should be applied
VOC A1-12 TBC Various extractive methods, standards include BS US EPA Method 18 [50] EN 13649:2002 [49] and TGN M22 [44].
As discussed, monitoring of the diesel emissions will be carried out as part of the commissioning programme of work. This data will be used to validate (or revise) the dispersion modelling carried out. The availability of plant due to manufacturer’s maintenance requirements and periodic nuclear safety tests will also affect the number of running hours (and is likely to reduce this significantly). If necessary, a revised impact assessment will be provided.
MonitoringofEmissionstoWaterandSewer
No emissions are proposed to be made from the installation to water or to sewer. Although there are expected to be some emissions to drains/sewer from the release of surface water run off; these releases are not process related.
MonitoringofWasteEmissions
Waste from the EDGs and SBOs will be recorded as a contribution to the total waste generated from the installation activities. This record will be maintained as part of the overall management of the power station,
14. Methods outlined are consistent with Section 2 – Periodic Sampling Standards of the Environment Agency, Technical Guidance Note (Monitoring) M2 Monitoring of Stack Emissions to Air [32].
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under the Operator's responsibility (waste management and handling is discussed further in Section 5.4).
IndicativeBATforMonitoringofEmissions
The indicative BAT requirements for monitoring provided in the IPPC Combustion Section Guidance [7] are shown below and a comparison with the proposed activities at the installation is provided.
Compliance with the indicative BAT requirements for monitoring is given in Table 3.4.3.
Table3.4.3 IndicativeBATforMonitoring
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Monitoring should generally be undertaken during all phases of For EDGs and SBOs, the engines start-up and shut down within a operation (i.e. commissioning, start-up, normal operation and very short period of time, and monitoring is therefore not shutting-down) unless the Regulator agrees that it is inappropriate. considered necessary, unless explicitly required. Monitoring will be carried out as part of the commissioning programme and operational monitoring will be carried out in line with the environmental permit.
Continuous monitoring (or at least sampling in the case of water) Continuous monitoring of air emissions is not considered to be and recording are likely to be required under the following appropriate at the installation due to the intermittent and limited circumstances: operation of the plant. Continuous Emission Monitors (CEMs) would be unused for much of the year (>99%) whilst the EDGs and SBOs Where the potential environmental impact is significant or the are in stand-by mode. concentration of substance varies widely; Discharges to water from the site will be intermittent and due to run Where a substance is abated continuous monitoring of the off rather than process operations and as such continuous substance is required to show the performance of the monitoring is not appropriate. abatement plant. For example continuous monitoring of dust is needed after a fabric filter to show the effectiveness of the No abatement is proposed for the diesel generators. filter and indicate when maintenance is needed, or sampling BOD from an effluent treatment plant; and Where other control measures are required to achieve satisfactory levels of emission (e.g. material selection).
Where effective surrogates are available, they may be used to This may apply to the calculation of SO2 emissions. As sulphur minimise monitoring costs. releases are directly related to fuel throughput, the rate of sulphur
(and therefore SO2) release can be accurately calculated.
Where monitoring shows that substances are not emitted in Not considered to be applicable. significant quantities, it may be possible to reduce monitoring frequency.
Monitoring and reporting of Emissions to Air
Where appropriate, periodic visual and olfactory assessment of Visual and olfactory assessments will be carried out as part of the releases should be undertaken to ensure that all final releases to air maintenance process. These assessments will be recorded as part of should be essentially colourless, free from persistent trailing mist or the site Integrated Management System. fume and free from droplets.
Many plants in this sector will be subject to the detailed monitoring N/A requirements of Annex VIII of the Large Combustion Plant Directive (LCPD).
Monitoring and reporting of emissions to water and sewer
For combustion plants co-incinerating waste and operating air Not applicable to the diesel generator installation. pollution control equipment with an aqueous discharge, Operators should comply with Article 8 or Annexes III and IV of the Waste incineration Directive (WID).
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
The Operator should also have a fuller analysis carried out covering a The contribution of the emissions of the diesel generators to water broad spectrum of substances to establish that all relevant and sewer is considered as not significant. substances have been taken into account when setting the release If necessary, testing can be carried out by the Operator at the limits. This should cover the substances listed in Schedule 5 of the commissioning stage. Regulations, unless it is agreed with the Regulator that they are not applicable. The need to repeat such a test will depend upon the potential variability in the process and, for example, the potential for contamination of raw materials. Where there is such potential, tests may be appropriate.
Any substances found to be of concern, or any other individual Not considered to be applicable. substances to which the local environment may be susceptible and upon which the operations may impact, should also be monitored more regularly. This would particularly apply to the common pesticides and heavy metals. Using composite samples is the technique most likely to be appropriate where the concentration does not vary excessively.
Monitoring and reporting of waste emissions
For waste emissions, the following should be monitored and Waste from the EDGs and SBOs will be recorded as a contribution to recorded: the total waste generated from the site activities. This record will be maintained as part of the overall management of the power station, The physical and chemical composition of the waste; under the Operator's responsibility. Its hazard characteristics; and Handling precautions and substances with which it cannot be mixed.
3.4.3 Environmental Monitoring (Beyond the installation)
EnvironmentalMonitoring
Environment Agency guidance states that environmental monitoring may be required, when: x There are vulnerable receptors; x The emissions are a significant contributor to an Environmental Quality Standard (EQS) that may be at risk; and x Modelling work requires validation.
There are ecological receptors in close proximity to the installation (see Section 4) however, detailed dispersion modelling has been carried out which shows that the concentrations at these receptors are sufficiently dispersed and will not be of concern. In addition, each engine is relatively small and operates for approximately 1% of the year. As part of the commissioning programme, monitoring of process releases will be carried out to validate the modelling work.
There is no risk to land quality as a result of plume deposition. There are no effluent releases from the installation. Releases of odour and noise are discussed in Sections 3.2 and 3.3, respectively.
As the procurement programme develops and equipment is purchased, indicative plant specific releases will become available to refine the current impact assessments and where significant impacts are identified, a review of the approach to monitoring and environmental protection will be required.
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IndicativeBATRequirementsforEnvironmentalMonitoring(Beyondinstallation)
Table 3.4.4 provides a comparison of the indicative BAT requirements against the proposed operations on the HPC installation.
Table3.4.4 IndicativeBATRequirementsforEnvironmentalMonitoring(Beyondinstallation)
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Describe the proposed measures for monitoring emissions, including Emissions monitoring will be carried out as part of the any environmental monitoring, and the frequency, measurement commissioning process. This will be described in detail in the methodology and evaluation procedure proposed. Commissioning Plan. There are no plans to carry out environmental monitoring; this approach may be revised if the emissions monitoring highlight areas of concern.
The Operator should consider the need for environmental The emissions from the installation will be intermittent and probably monitoring to assess the effects of emissions to controlled water, of limited environmental impact. Nevertheless this has to be groundwater, air or land, or emissions of noise or odour. confirmed during the commissioning stage by a detailed impact assessment. Environmental monitoring beyond the installation is unlikely to be considered to be proportionate, given the low level and nature of emissions from the installation. There are no process related effluents generated. The processes operated at the installation are inherently non- odorous, and therefore monitoring of the odour beyond the site boundary is expected not to be considered appropriate. This will be assessed in more detail when the plant is commissioned. Although combustion engines do generate noise, the location and containment of the engines within solid structures and buildings maintains an effective barrier between the source and the receptor. Routine noise monitoring is therefore not expected to be required although as noted in Section 3.3 this will be confirmed at the commissioning stage.
Environmental monitoring may be required, for example, when: This is will be informed by the Environmental Impact Assessment (see Section 4) There are vulnerable receptors; The emissions are a significant contributor to an Environmental Quality Standard (EQS) that may be at risk; The Operator is looking for departures from standards based on lack of effect on the environment; and To validate modelling work.
The need should be considered for: Discussed above. Groundwater, where it should be designed to characterise both quality and flow and take into account short- and long- term variations in both. Monitoring will need to take place both up-gradient and down-gradient of the site; Surface water, where consideration will be needed for sampling, analysis and reporting for upstream and downstream quality of the controlled water; Air, including odour; Land contamination, including vegetation, and agricultural products; Assessment of health impacts; and Noise.
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Where environmental monitoring is needed, the following should be Environmental monitoring is not expected to be required. In the considered in drawing up proposals: event that this changes, then any assessment will be consistent with BAT. Determination to be monitored, standard reference methods, sampling protocols; Monitoring strategy, selection of monitoring points, optimisation of monitoring approach; Determination of background levels contributed by other sources; Uncertainty for the employed methodologies and the resultant overall uncertainty of measurement; Quality assurance (QA) and quality control (QC) protocols, equipment calibration and maintenance, sample storage and chain of custody/audit trail; and Reporting procedures, data storage, interpretation and review of results, reporting format for the provision of information for the Regulation.
3.4.4 Monitoring of Process Variables
The management of the installation once operational is expected to include the monitoring of a limited range of process variables that may affect emissions to the environment through plant operation or direct discharge (nominally CO, temperature and oxygen to control the combustion process). The relevant variables are summarised in Table 3.4.5. Operational monitoring will be carried out to record process variables such as: x Hours of operation; x Consumption of diesel; and x Consumption of lubricants and cleaning chemicals (in the frame of the station balance of substance consumption).
This level of information will be used to look for any longer term trends in operations such as increased fuel consumption or waste generation.
IndicativeBATforProcessVariables
Indicative BAT for monitoring process variables is outlined in Table 3.4.5 along with the proposed approach for HPC.
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Table3.4.5 IndicativeBATforProcessVariables
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Some process variables may affect the environment and these Fuel to be used in diesel generator engines must contain less than should be identified and monitored as appropriate. Examples might 0.1% sulphur (in line with the SCOLF Regulations). This will limit the be: amount of sulphur released to the atmosphere during combustion and therefore reduces the environmental impacts associated with For solid and liquid fuel fired plants, fuel feedstock should be higher SO concentrations in the environment. sampled and analysed at a frequency and manner appropriate 2 to the type of plant concerned; The flue gas temperature of the EDGs will be monitored during testing to ensure combustion temperatures are at an appropriate Differential pressure across abatement equipment which can level to maintain full combustion with maximum efficiency therefore indicate removal efficiency, filter failures, etc reducing the likelihood of higher pollutant concentrations, Potential difference across EP plates; particularly CO, PM and VOCs. Reagent injection or feed rates; and Oxygen content of flue gas.
3.4.5 Monitoring Standards (Standard Reference Methods)
Until the details of appropriate monitoring are developed, any monitoring standards cannot be described. However Table 3.4.6 outlines the indicative BAT requirements for any such monitoring.
Table3.4.6 IndicativeBATRequirementsforMonitoringStandards(StandardReferenceMethods)
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
As far as possible, Operators should ensure their monitoring Any monitoring arrangements will be consistent with the arrangements comply with the requirements of MCERTS where requirements of MCERTS. Table 3.4.2 outlines the current preferred available, for example using certified instruments and equipment, methods for monitoring however it is recognised that these methods and using a stack testing organisation accredited to MCERTS may change by the time the plant is operational and a review will be standards. Where the monitoring arrangements are not in carried out prior to any monitoring taking place. accordance with MCERTS requirements, the Operator should It is likely that this will be through the use of external contractors. provide justification and describe the monitoring provisions in detail. See MCERTS approved equipment for future information on MCERTS and a listing of MCERTS equipment.
Sampling and Analysis Standards
The analytical methods given in Appendix 1 of the Guidance should The monitoring methods outlined in Table 3.4.2 have been taken be used. If other substances need to be monitored the standard from updated Environment Agency guidance (M2) [32]. This should be selected in the order of priority as given in the Guidance. document reflects the hierarchy in monitoring methods and this will be reflected in any monitoring carried out. Bureau’s Reference Document on the General Principles of Monitoring. This order is: Comité Européen de Normalisation (CEN); and International Standardisation Organisation (ISO).
If the substance cannot be monitored using CEN or ISO standards All of the parameters emitted from the diesel generators can be then a method can be selected from any one of the following: monitored using either CEN or ISO standards. American Society for Testing and Materials (ASTM); Association Française de Normalisation (AFNOR); British Standards Institution (BSI); Deutsches Institute fur Normung; United States Environmental Protection Agency (US EPA); and Verein Deustcher Ingenieure (VDI).
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
If the substance cannot be monitored using any of the standards above then other methods may be adapted for use, following the requirements for validation in ISO 17025. For stack emission monitoring the following occupational methods may be adapted: Methods for the Determination of Hazardous Substances (MHDS) series published by the Health and Safety Executive (HSE); National Institute for Occupational Safety and Health (NIOSH); and Occupational Safety and Health Administration (OSHA).
The intended application of the standard method must always be taken into account. For example, a CEN method may be less suitable than another less rigorously validated standard method if the application is not one for which the CEN method was developed. Operators should be expected to be able to demonstrate compliance with the above hierarchy and validate use of non-standard methods, in-house designed/developed methods, standard methods used outside their intended scope and modifications of standard methods to confirm that these methods are fit for purpose. These procedures will be formalised under forthcoming European standards.
Further guidance on standards for monitoring gaseous releases relevant to the EP Regulations is given in the Monitoring Guidance. A series of updated Guidance Notes covering this subject is being prepared. This guidance specifies manual methods of sampling and analysis that will also be suitable for calibration of continuous emission monitoring instruments. Further guidance relevant to water and waste is available from the publications of the Standing Committee of Analysts.
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4 Impacts
4.1 Impact Assessment
The Environment Agency Technical Guidance Note for the Combustion Sector [7] details specific requirements that should be addressed with regard to the assessment of environmental impacts from the installation activities. Guidance for the assessment of environmental impacts is provided in the horizontal guidance document H1 [13], published by the Environment Agency.
This section of the application therefore provides an assessment of the impact of all releases from the installation, undertaken in accordance with the requirements of the H1 guidance note. In particular, the assessment considers the impact of releases to air from the EDGs and SBOs. The scenarios considered are discussed in more detail in Section 4.1.2.
4.1.1 Local Environment
The HPC Power Station is located approximately 12 km to the north-west of the town of Bridgwater in the county of Somerset. The centre of the HPC site is located at the following Ordnance Survey NGR co-ordinates: x ST 20300 45800
A regional location map is provided in Figure 2 of Appendix B.
The installation is approximately 66 hectares in size, and is located in a rural and relatively remote coastal area that is relatively flat. The facility is bounded to the north by Bridgwater Bay and Severn Estuary and to the east by the HPA and HPB Power Stations. The nearest residential locations are farms and villages situated at least 1 km to the west, south and east.
InstallationSiteLayout
The layout of the installation is discussed in Sections 1 and 2, and presented in Figure 1 of Appendix B.
ImportantandSensitiveReceptors
Annex F [13] of the H1 guidance details the ecological receptors and distances to be considered, these are: x Special Protection Areas (SPAs), Special Areas of Conservation (SACs) or Ramsar Sites within 10 km of the installation (or 15 km, where the installation accommodates coal- or oil-fired power station); and x Sites of Special Scientific Interest (SSSIs), National Nature Reserves (NNRs), Local Nature Reserves (LNRs), local wildlife sites and ancient woodland within 2 km of the location of the installation.
Table 4.1.1 summarises information on sensitive receptors within 15 km of the installation, identified using the Magic15 website. Though the installation is not a coal or oil-fired power station, a 15 km radius has been adopted as more comprehensive approach, as the diesel generators will operate on diesel and the aggregated capacity will exceed 50 MWth.
15 Multi-Agency Geographic Information for the Countryside: Accessible online at: http://www.magic.gov.uk/website/magic/.
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Site Check Reports have been obtained from the Magic website and employed as a key source of information on this project. Full citations of European Sites within 15 km of the site and SSSIs within 2 km of the site, as required by the European Union (EU) Habitats Directive (92/43/EEC) [3] and Countryside and Rights of Way Act 2000 (CRoW) [51] procedures, have been obtained from the English Nature website (http://www.english- nature.org.uk/) and have informed the impact assessment.
The international and national statutory designations around HPC site are provided in Figures 4 and 5 of Appendix B.
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Table4.1.1 IdentificationofImportantandSensitiveReceptors
No. ReceptorName ScreeningCategory Receptor Reference Emissions,Pathway&PotentialEffect Locationofsupportinginformation Type
1 Severn Estuary Ramsar Sites within Ramsar UK11081 Emissions: discharges to air and water. Refer to Section 4.1, 4.2 and dispersion 15 km modelling report (Appendix C). Pathway - air: atmospheric dispersion and deposition to land and water. 2 Severn Estuary Special Protection Areas SPA UK9015022 Pathway - water: via on-site effluent treatment plant before being within 15 km discharged to Bridgwater Bay. Potential effect: no likely significant effect due to control measures in place 3 Severn Estuary Special Area of SAC UK0013030 and operating regime; there are no process releases to water from the Conservation within installation. English Nature's assessment of the condition of the SSSI 15 km identifies that 89.9% of Bridgwater Bay SSSI is 'favourable condition'. English Nature also identify that key pressures on littoral sediments is 4 Severn Estuary SSSI within 15 km SSSI 1002600 'coastal squeeze', meaning land-use pressures rather than pollution from 5 Bridgwater Bay SSSI within 2 km SSSI 1001166 emissions.
6 Blue Anchor To Lilstock SSSI within 2 km SSSI 1001374 SSSI is designated for geological rather than ecological or conservation N/A Coast purposes. There are therefore no potential effects from emissions from the installation.
7 Mendip Limestone Special Areas of SAC UK0030203 Emissions: discharges to air. Refer to Section 4.1, 4.2 and dispersion Grasslands Conservation within Pathway: atmospheric dispersion and deposition to land. modelling report (Appendix C). 15 km Potential effect: Given the conservation interest of the sites, it is considered 8 Roebuck Meadows SSSI within 2 km SSSI 100164 that there is no likely significant effect due to the control measures in place and the effective operating regime that is implemented. 9 The Quantocks SSSI within 2 km SSSI 1001391
10 GE Mare Farm Fields SSSI within 2 km SSSI 1001041
11 Cleeve Hill SSSI within 2 km SSSI 1001365 See 7, 8, 9 and 10. See 7, 8, 9 and 10.
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No. ReceptorName ScreeningCategory Receptor Reference Emissions,Pathway&PotentialEffect Locationofsupportinginformation Type
12 Steep Holm SSSI within 2 km SSSI 1001362 See 7, 8, 9 and 10. See 7, 8, 9 and 10.
13 Berrow Dunes SSSI within 2 km SSSI 1001372 See 7, 8, 9 and 10. See 7, 8, 9 and 10.
14 Exmoor & Quantock Special Areas of SAC UK0030148 See 7, 8, 9 and 10. See 7, 8, 9 and 10. Oakwoods Conservation within 15 km
15 Residential areas to the Human population Housing N/A Emissions: discharges to air. These receptors represent the closest west, south and east receptors in each direction. The dispersion Pathway: atmospheric dispersion and deposition to land. Knighton Farm modelling report (Appendix C) provides a Potential effect: no likely significant effect due to control measures in comprehensive list of local receptors and Shurton place. their exact locations. Doggetts Wick Farm Zipe Farm Idson Farm Browns Cottage Trighorn Farm Little Dowdens Farm
16 As above for Bridgwater Sensitive Watercourses See 1-3 above See 1-3 above See 1-3 above See 1-3 above Bay and Severn Estuary (1 - 3)
17 None identified Sensitive Groundwaters N/A N/A Not located within a groundwater protection zone N/A
18 None identified within Sensitive Areas of the N/A N/A There are no air quality management areas (AQMAs) within 2 km of the N/A 2 km of the site Atmosphere site
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4.1.2 Approach to Impact Assessment for Emissions to Air
H1Assessment
The Environment Agency’s H1 guidance note [13] provides a methodology to assess the risks to the environment and human health from facilities that produce discharges to the environment, where there are separate Environmental Assessment Levels (EALs) for ecological receptors, these are also considered. The point source emissions to air released from the proposed UK EPR units during the operation phase of the new build development (as outlined above) have been initially screened following the H1 methodology. The emissions assessed include CO, SO2, NOX as NO2 and PM below 10 microns (PM10) and 2.5 microns (PM2.5) as well as deposition of acid and nitrogen associated with emissions of NOX and SO2.
The approach taken is discussed in detail in this section with further detail provided Appendix C.
The following steps of the H1 methodology have been followed for initially screening the operational point source emissions to air: x Calculation of the Process Contribution (PC) for individual pollutants; x Screening out of insignificant emissions; and x Identification of releases of substances that may be deemed to be significant, and therefore detailed modelling is required to further assess the impacts of these emissions.
To determine the significance of the releases to the environment, the software developed to support the guidance note has been used to determine the PC of the substances. The PC of a substance emitted to air is the concentration of the emitted substance after dispersion. Estimation of the long-term and short-term PCs of substances released to air is calculated using the following formula:
PCair DF u RR where:
3 PCair = process contribution to air (g/m ).
DF = dispersion factor, expressed as the maximum average ground level concentration per unit mass release rate (g/m3/g/s), based on annual average for long term releases and hourly average for short term releases.
RR = release rate of substance (g/s).
The short-term and long-term PCs of substances emitted to air are then compared against the relevant short- term and long-term EALs for emissions to air provided in the Environment Agency H1 guidance note [13]. The EALs are selected based on the local circumstances, i.e. the use of objectives set for the protection of vegetation and ecosystems for assessments in relation to sensitive vegetation, and objectives set for the protection of human health for human or residential receptors.
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The following criteria are applied to determine whether the emissions are considered significant: x Process Contribution (long-term) will be regarded as significant in the event it is greater than 1% of the long- term environmental benchmark (i.e. the EAL); and x Process Contribution (short-term) will be regarded as significant in the event it is greater than 10% of the short-term EAL.
Detailed dispersion modelling may be required in order to obtain more accurate estimates of process contributions than those obtained through using the simplified calculation methods detailed above.
For long-term effects, the need for detailed modelling is determined through calculating the total Predicted Environmental Concentration (PEC) of that substance by summing the background concentration and the PC:
PECair PCair longterm background concentrationair where:
3 PECair = predicted environmental concentration to air (g/m ).
3 PCair long-term = process contribution to air (g/m ).
Modelling of long-term effects may be appropriate if the long-term PEC is above 70% of the relevant long-term EAL, or in locations where an air quality management area (AQMA) has been designated for an emitted substance.
For short-term effects, modelling may be appropriate if the short-term PC is more than 20% of the difference between twice the background concentration and the relevant short-term EAL.
If there are any local receptors which are sensitive to any of the emissions that have not been screened out, then modelling of long-term and short-term effects may be needed.
4.1.3 Impact Assessment for Emissions to Air
ScenariosConsidered
An H1 assessment was undertaken for the standby plant for the following three scenarios, based on the information set out in Section 2.2.2 (Operational Regime): x The commissioning scenario recognises that although only one EDG or SBO is likely to be in operation at any one time the total number of hours of operation will be higher than during routine testing. The scenario uses emission rates for the EDGs as these are higher than those for the SBOs and assumes the following operation profile:
- Long term impacts are assessed on the basis of 4,892 hours combined operation of the EDGs (8 x 242.5 hours) and SBOs (4 x 738 hours) per year. It should be noted that some of the 738 hours per year identified for commissioning the SBOs will involved tests that can be carried out before the engines are brought to site, and as such the scenario for long term emissions from commissioning will over-estimate impacts. In addition, there is likely to be a nine month gap during the commissioning of the diesel generators meaning that the commissioning tests will take place over a period of more than one year therefore the results of the assessment should be considered to be conservative.
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- Short term impacts are assessed on the basis that one EDG is operational continuously throughout the year. x The routine test scenario covers operation of the plant for maintenance purposes and periodic nuclear safety tests. Testing of back-up diesel generators will take place individually, with only a single generator running at a time. The scenario uses emission rate for both the EDGs and SBOs and assumes the following operational profile:
- Long term impacts are assessed on the basis of 720 hours combined operation of the EDGs (8 x 60 hours) and SBOs (4 x 60 hours) per year; and
- Short term impacts are assessed on the basis that one EDG is operational continuously throughout the year. x The worst case LOOP scenario covers an event resulting is loss of off site power for 24 hours, with all eight EDGs operating for 25 hours. The scenario does not include emissions from the SBOs as these would only operate if the EDGs failed to start-up. The scenario only considers short term impacts as the short term nature of such events means the emissions would be unlikely to contribute significantly on an annual average basis.
Further justification for the scenarios considered is provided in Section 2.1.1 of Appendix C.
ConclusionofH1Assessment
The results are presented in Section 3 of Appendix C, which shows that both short and long term impacts to human and ecological receptors cannot be screened out as insignificant. For this reason, full air dispersion modelling was undertaken to assess emissions of NO2, NOX, SO2, CO, PM10 and PM2.5 as well as acid and nitrogen deposition associated with the emissions of NO2, NOX and SO2.
DetailedAirDispersionModelling
A full justification for the approach used for the detailed air dispersion modelling is provided in Section 2.1.3 of Appendix C.
The advanced atmospheric dispersion model ADMS 4 (version 4.2 with Surfer Version 9.0) was used to model the commissioning, routine testing and LOOP scenarios identified above to enable comparison with the relevant EALs shown in Table 4.1.2, which are referred to as: x Air Quality Objectives (AQO) and Air Quality Standards (AQS) for human receptors; and x Environmental Quality Standards (EQS) for ecological receptors.
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Table4.1.2 EALsUsedtoAssessImpacts
Substance HumanHealthAQO/EAL EcologicalEQS/EAL
LongTerm ShortTerm LongTerm ShortTerm (μg/m3) (μg/m3) (μg/m3) (μg/m3)
NO2 40 (annual mean) 200 (99.79 percentile of 1-hour mean)
NOX 30 (annual mean) 75 (24-hour mean)
SO2 266 (99.9 percentile of 15-minute 20 (annual mean) mean)
350 (99.73 percentile of 1-hour mean)
125 (99.18 percentile of 24-hour mean)
CO 30,000 (1-hour mean)
10,000 (8-hour rolling mean)
PM10 40 (annual mean) 50 (90.41 percentile of 24-hour mean) - -
PM2.5 25 (annual mean)
The modelling was used to calculate the PCair at the following locations: x All farms and residences in close proximity to the site have been considered. The locations of the farms, residences and villages were chosen based on inspection of maps, satellite imagery of the area and a visit to the site and surrounding area. Furthermore, receptors at local public footpaths and the archaeological site of interest, Pixies Mound, have been included within the assessment; and x There are also several ecological designated sites in proximity to the Hinkley Point site, with results presented for:
- Bridgwater Bay SSSI which is also captured within the Severn Estuary SPA/SAC/Ramsar site;
- Bridgwater Bay national nature reserve (NNR); and
- Blue Anchor to Lilstock SSSI.
The modelled PCair was added to the background concentrations identified in Table 4.1.3 to calculate the PECair.
To calculate the short-term PCair the background was taken to be twice the long term background.
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Table4.1.3 BackgroundPollutantConcentrationsUsedinModellingAssessment
Substance AnnualAverageBackground ShortTermBackgroundConcentration Concentrationfor2009(μg/m3) (μg/m3)(2xannualaverage)
a SO2 1.8 3.6
b NO2 6.8 13.6
b NOX 11.5 23
CO c 78.5 157
b PM10 18.2 36.4
d PM2.5 7.9 15.8
Notes to Table 4.1.3:
a 2009 annual mean background concentration of SO2 assumed to be equal to 2008 annual mean SO2 concentration obtained from the baseline air quality monitoring campaign. Background concentration of formaldehyde assumed to be negligible.
b 2009 annual mean background concentrations of NO2, NOX and PM10 obtained by applying the ratio for 2008 to 2009 annual mean concentrations from Defra's UK Air Quality Archive (average of the four 1 km x 1 km grid squares closest to Hinkley Point) to 2008 annual mean pollutant concentrations obtained from the baseline air quality monitoring campaign. c Background concentration of carbon monoxide taken from Defra's UK Air Quality Archive (average of the four 1 km x 1 km grid squares closest to Hinkley Point). 2001 background map of CO annual mean concentrations factored to 2009 using published Defra annual adjustment factors.
d 2009 annual mean background concentration of PM2.5 taken from Defra's UK Air Quality Archive (average of the four 1 km x 1 km grid squares closest to Hinkley Point).
ResultsforAirQuality
A summary of the results of the modelling assessment is provided in the following tables: x Table 4.1.4: impact on human receptors under the commissioning scenario;
Table4.1.5:impactonecologicalreceptorsunderthecommissioningscenario;
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x Table 4.1.6: impact on human receptors under the routine testing scenario; x Table 4.1.7: impact on ecological receptors under the routine testing scenario; x Table 4.1.8: impact on human receptors under the LOOP scenario; and x Table 4.1.9: impact on ecological receptors under the LOOP scenario.
Further details of the approach to modelling and results for all receptors are provided in Appendix C.
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Table4.1.4 ADMSAssessment:CommissioningScenario:HumanReceptors
Subs. LongTerm ShortTerm
EAL Background PEC Location PECas EAL Background PEC Location PECas (Ɋg/m3) (Ɋg/m3) (Ɋg/m3) %EAL (Ɋg/m3) (Ɋg/m3) (Ɋg/m3) %EAL
NO2 40 (annual average) 6.8 7.78 (NO2) Trighern Farm 19.4% 200 (99.79 percentile 1-hr mean) 13.6 34.8 Doggetts 17.4%
115 Footpath & Pixie’s Mound 57.6%
SO2 266 (99.9 percentile 15-min mean) 3.6 10.8 Doggetts 4.1%
34.9 Footpath & Pixie’s Mound 13.1%
350 (99.73 percentile 1-hr mean) 9.36 Doggetts 2.7%
30.6 Footpath & Pixie’s Mound 8.7%
125 (99.18 percentile 24-hr mean) 6.11 Doggetts 4.9%
CO 30,000 (1-hr mean) 157 163 Doggetts 0.5%
182 Footpath & Pixie’s Mound 0.6%
10,000 (8-hr rolling mean) 161 Doggetts 1.6%
PM10 40 (annual mean) 18.2 18.2 Trighern Farm 45.6% 50 (90.41 percentile 24-hr mean) 36.4 36.6 Wick Farm 73.2%
PM2.5 25 (annual mean) 7.9 7.94 Trighern Farm 31.7%
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Table4.1.5 ADMSAssessment:CommissioningScenario:EcologicalReceptors
Subs. LongTerm ShortTerm
EAL Background PEC Location PECas EAL Background PEC Location PECas (Ɋg/m3) (Ɋg/m3) (Ɋg/m3) %EAL (Ɋg/m3) (Ɋg/m3) (Ɋg/m3) %EAL
NOX 30 (annual mean) 11.5 23.2 Severn Estuary/ 77.5% 75 (24-hr mean) 23 230 Severn Estuary/ 307% Bridgwater Bay Bridgwater Bay
SO2 20 (annual mean) 1.8 2.94 Severn Estuary/ 14.7% Bridgwater Bay
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Table4.1.6 ADMSAssessment:RoutineTestingScenario:HumanReceptors
Subs. LongTerm ShortTerm
EAL Background PEC Location PECas EAL Background PEC Location PECas (Ɋg/m3) (Ɋg/m3) (Ɋg/m3) %EAL (Ɋg/m3) (Ɋg/m3) (Ɋg/m3) %EAL
NO2 40 (annual average) 6.8 6.94 Trighern Farm 17.4% 200 (99.79 percentile 1-hr mean) 13.6 34.8 Doggetts 17.4%
115 Footpath & Pixie’s Mound 57.6%
SO2 266 (99.9 percentile 15-min mean) 3.6 10.8 Doggetts 4.1%
34.9 Footpath & Pixie’s Mound 13.1%
350 (99.73 percentile 1-hr mean) 9.36 Doggetts 2.7%
30.6 Footpath & Pixie’s Mound 8.7%
125 (99.18 percentile 24-hr mean) 6.11 Doggetts 4.9%
CO 30,000 (1-hr mean) 157 163 Doggetts 0.5%
182 Footpath & Pixie’s Mound 0.6%
10,000 (8-hr rolling mean) 161 Doggetts 1.6%
PM10 40 (annual mean) 18.2 Trighern Farm 45.5% 50 (90.41 percentile 24-hr mean) 36.4 36.6 Wick Farm 73.2%
PM2.5 25 (annual mean) 7.9 7.91 Trighern Farm 31.6%
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Table4.1.7 ADMSAssessment:RoutineTestingScenario:EcologicalReceptors
Subs. LongTerm ShortTerm
EAL Background PEC Location PECas EAL Background PEC Location PECas (Ɋg/m3) (Ɋg/m3) (Ɋg/m3) %EAL (Ɋg/m3) (Ɋg/m3) (Ɋg/m3) %EAL
NOX 30 (annual mean) 11.5 13.25 Severn Estuary/ 44.2% 75 (24-hr mean) 23 230 Severn Estuary/ 307% Bridgwater Bay Bridgwater Bay
SO2 20 (annual mean) 1.8 1.97 Severn Estuary/ 9.9% Bridgwater Bay
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Table4.1.8 ADMSAssessment:LOOPScenario:HumanReceptors(ShortTermOnly)
Subs. EAL Background PEC Location PECas%EAL (Ɋg/m3) (Ɋg/m3) (Ɋg/m3)
NO2 200 (99.79 percentile 1-hr mean) 13.6 136 Doggetts 68.0%
372 Footpath & Pixie’s Mound 186%
SO2 266 (99.9 percentile 15-min mean) 3.6 41.1 Doggetts 15.5%
127 Footpath & Pixie’s Mound 47.7%
350 (99.73 percentile 1-hr mean) 36.7 Doggetts 10.5%
98.7 Footpath & Pixie’s Mound 28.2%
125 (99.18 percentile 24-hr mean) 18.7 Doggetts 15.0%
CO 30,000 (1-hr mean) 157 189 Doggetts 0.6%
249 Footpath & Pixie’s Mound 0.8%
10,000 (8-hr rolling mean) 180 Doggetts 1.8%
PM10 50 (90.41 percentile 24-hr mean) 36.4 38.0 Doggetts 75.9%
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Table4.1.9 ADMSAssessment:LOOPScenario:EcologicalReceptors(ShortTermOnly)
Subs. EAL Background PEC Location PECas%EAL (Ɋg/m3) (Ɋg/m3) (Ɋg/m3)
NOX 75 (24-hr mean) 23 933 Severn Estuary/Bridgwater Bay 1,275%
SO2
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ResultsforNitrogenandAcidDeposition
Emissions of NOX and SO2 can also be deposited from the air to land or water. The high turbidity of the adjacent Severn Estuary means that algal productivity is generally low, and as such nutrient enrichment associated with deposition of nitrogen from emissions to air is considered unlikely to be significant for all three scenarios. Similarly, the characterisation of the Severn Estuary by the Marine Biological Association16 does not indicate that it is sensitive to acidification. This is reflected by the lack of background data or critical loads available on the webpage www.apis.ac.uk, which is used by environmental regulators to assess impacts associated with nitrogen deposition.
However, for completeness, Table 4.1.10 provides details of the nitrogen and acid deposition rates expected adjacent to the installation at the Severn Estuary SPA/SAC/Ramsar and Bridgwater Bay SSSI.
Table4.1.10 ADMSAssessmentofLongTermNitrogenandAcidDepositionattheNearestEcologicalReceptor (CommissioningandRoutineTestingScenariosOnly)
Scenario NitrogenDeposition(kgN/ha/yr) AcidDeposition(keq/ha/yr)
Commissioning 1.71 0.26
Routine testing 0.25 0.04
SummaryandConclusions
The impacts from the diesel generators have been considered under three operating scenarios: x The commissioning scenario recognises that although only one EDG or SBO is likely to be in operation at any one time, total operation over the course of a year will be 4,892 hours (EDGs: 8 x 242.5 hours. SBOs: 4 x 738 hours); x The routine test scenario recognises that although only one EDG or SBO is likely to be in operation at any one time, total operation over the course of a year will be 720 hours (EDGs: 8 x 60 hours. SBOs: 4 x 60 hours); and x The worst case LOOP scenario covers an event resulting in loss of off site power for 24 hours, with all eight EDGs operating for 25 hours. The scenario does not include emissions from the SBOs as these would only operate if the EDGs failed to start-up. The scenario only considers short term impacts as the short term nature of such events means the emissions would be unlikely to contribute significantly on an annual average basis.
In summary, with the exception of the impacts identified below, emissions from the essential diesel generators are unlikely to cause any relevant EALs to be exceeded even when background effects are taken into consideration:
16. Characterisation of European Marine Sites: The Severn Estuary: Marine Biological Association Occasional Publication No. 13 (http://www.mba.ac.uk/nmbl/publications/charpub/pdf/Severn_Estuary.pdf).
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ShortTermNO2ImpactsonHumanReceptors
Under the LOOP scenario the impact on human receptors from emissions of NO2 at the footpath located north of the HPC site and also the Pixie’s Mound monument would exceed the EAL (200 g/m3). However, for a breach of the air quality standard to occur at these locations would require a member of the public to be present in this area for a total period of 18 hours and would also require those hours to coincide exactly with the worst-case meteorological conditions conducive to the formation of elevated ground level concentrations. It is extremely unlikely that these requisites will be realised and, in practice, a breach of the air quality standard is not expected for a 24 hour LOOP event.
ShortTermNOXImpactsonEcologicalReceptors
Under all three scenarios considered the impact on ecological receptors from emissions of NOX at the Bridgwater Bay SSSI, which is adjacent to the site, would exceed the 24-hour mean EAL (75 g/m3).
3 x The PECair for the commissioning and routine testing scenarios is 307% of the EAL (230 g/m ). However, the derivation of this value is based on continuous operation of an EDG over an entire 24-hour period, which is considerably in excess of the 3 hour 40 minutes to 5 hour load profile described in Section 2.2.2 (Operational Regime – Routine Testing). Furthermore, the 75 g/m3 daily mean EAL is derived from the 2000 World Health Organisation (WHO) Air Quality Guidelines for Europe. The WHO state in this document that, with reference
to the daily mean NOX guideline level:
“There is insufficient data to provide these levels with confidence at present.”
Consequently, it is considered that greater emphasis should be placed on achievement with the more
established NOX annual mean air quality standard.
3 x The PECair for the LOOP scenarios is 1,275% of the EAL (933 g/m ). However, as for the commissioning and test scenario, it is considered that greater emphasis should be placed on achievement with the more
established NOX annual mean air quality standard, for which contributions from the LOOP scenario, averaged over the period of a year, are likely to be negligible. It should also be noted that this is a conservative estimate based on a 24 hour LOOP event (25 continuous hours of operation of eight EDGs). Such an event is highly unlikely, with most LOOP events, should they actually occur (which, in itself, has a low probability of occurrence), lasting for a maximum duration of only 2 hours. As such, the contribution to 24 hour mean concentrations will be considerably less than that predicted above.
4.1.4 Assessment of the Impact of Emissions to Water
PreliminaryScreeningofReleasestoWater
Emissions to water associated with the regulated activities undertaken at the installation are listed in Sections 2 and 3 of this submission. Both of these other sections should be referred to for additional information and context relevant to the following discussion.
NNB GenCo envisages no, or minimal, point source emissions to water from the diesel generators themselves. As there are direct point source emissions to water arising directly from the process an impact assessment of releases to water has not been undertaken.
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4.2 The Conservation of Habitats and Species Regulations 2010
In April 2010, The Conservation of Habitats and Species Regulations [52] replaced The Conservation (Natural Habitats & c.) Regulations 1994 as the principal means by which the Habitats Directive [3] is transposed into domestic legislation in England and Wales.
The Habitats Regulations implement the EU Birds17 [53] and Habitats18 [3] Directives, both of which aim to protect a network of sites in the UK that have rare or important habitats and species. The sites designated pursuant to the Birds Directive are known as Special Protection Areas (SPAs), and aim to conserve the habitats that support regularly occurring migratory or certain rare or vulnerable birds, to ensure their survival and reproduction in their area of distribution. Prior to classification by the UK Government, the sites are known as potential SPAs (pSPAs). The Habitats Directive establishes the process for the designation of Special Areas of Conservation (SACs); these are sites that support habitats and/or species, which are rare or threatened on a European scale. Before the SAC designation is ratified by the European Commission the sites are referred to as candidate SACs (cSACs). SPAs and SACs are collectively known as ‘European sites’ or ‘Habitats sites’ and form part of a European network known as Natura 2000.
The EP Regulations require that the Habitats Regulations [52] are taken into consideration to determine whether the installation activity will have a significant effect on any of the sites protected under these regulations. This section of the report provides a further assessment of whether the installation is likely to have a significant impact on a European site in the UK, and an assessment of the implications of the installation for the purposes of these Regulations.
As identified in Section 4.1 (Table 4.1.1) there are three Habitats Directive sites within 15 km of the installation: x The Severn Estuary which is designated as a Special Protection Area (SPA), Special Area of Conservation (SAC) and Ramsar Site; x The Mendip Limestone Grasslands which is designated as a Special Area of Conservation (SAC); and x The Exmoor and Quantock Oakwoods which is designated as a Special Area of Conservation (SAC).
These are listed below in Table 4.2.1, along with a description of their designations, distance and direction from the installation.
17. The Birds Directive (European Communities Council Directive on the Conservation of Wild Birds (79/409/EEC) as consolidated by Directive 2009/147/EC) aims to preserve, maintain or re-establish biotopes and habitats to maintain populations of all species of wild birds naturally occurring in the Member States.
18. The Habitats Directive (European Communities Council Directive on the Conservation of Natural Habitats and Wild Fauna and Flora (92/43/EEC, amended by 97/62/EC)) requires measures to be taken to maintain or restore to favourable conservation status habitats and/or species which are rare or threatened on a European scale.
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Table4.2.1 IdentificationofEuropeanHabitatsDirectivesiteswithin15kmoftheinstallation
Title,Designation Distancefrom Description &Reference Site
Severn Estuary, SPA, Adjacent to The Severn Estuary is located between Wales and England in south-west Britain. It is a large UK9015022 power station estuary with extensive intertidal mud-flats and sand-flats, rocky platforms and islands. RAMSAR, UK11081 boundary to Saltmarsh fringes the coast backed by grazing marsh with freshwater ditches and occasional SAC UK0013030 north, east and brackish ditches. The seabed is rock and gravel with sub-tidal sandbanks. The estuary's classic south funnel shape, unique in the UK, is a factor causing the Severn to have the second- highest tidal range in the world (after the Bay of Fundy in Canada). This tidal regime results in plant and animal communities typical of the extreme physical conditions of liquid mud and tide- swept sand and rock. The species-poor invertebrate community includes high densities of ragworms, lugworms and other invertebrates forming an important food source for passage and wintering waders. A further consequence of the large tidal range is an extensive intertidal zone, one of the largest in the UK. The site is of importance during the spring and autumn migration periods for waders moving up the west coast of Britain, as well as in winter for large numbers of waterbirds, especially swans, ducks and waders.
Exmoor & Quantock 6.7 km to south This site supports extensive tracts of old sessile oak woods in conjunction with heath. They are Oakwoods, west rich in bryophytes, ferns (including Dryopteris aemula) and epiphytic lichens, the latter often SAC, UK0030148 associated with old pollards, since parts are former wood-pasture rather than the oak coppice that is more common with this type. In the Barle Valley the woods also occur in mosaic with glades and small fields and the combination results in good populations of fritillary butterflies.
Mendip Limestone 14.9 km to north Coastal and inland sections of the Carboniferous Limestone outcrops of the Mendips. The Grasslands, east coastal headland and inland hills support the largest area of CG1 Festuca ovina – Carlina SAC, UK0030203 vulgaris grassland in England, including two sub-types (CG1a Carex humilis and CG1c Trinia glauca sub-communities) known from no other site in the UK. Areas of short-turf CG2 Festuca ovina – Avenula pratensis grassland also occur inland. The site is exceptional in that it supports a number of rare and scarce vascular plants typical of the oceanic southern temperate and Mediterranean elements of the British flora. These include white rock-rose Helianthemum apenninum, Somerset hair-grass Koeleria vallesiana and honewort Trinia glauca. Transitions to limestone heath (4030 European dry heaths) situated on flatter terrain also occur.
The impacts on these sites from the emissions from installation have been assessed in Section 4.1 and are not considered to be likely to significantly affect a European Site. There are no process releases to water and therefore no impact to the Severn Estuary and the impacts to air from the diesel generators on ecological receptors were screened out by the H1 assessment.
In view of this it is not considered that an appropriate assessment of the likely impact under the Habitats Regulations is required. However, NNB GenCo is aware of the importance of these sites and will continue to review the emission from the installation and the site as a whole.
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5 Managing the Activities
5.1 Management Systems
Due to the development of the overall programme of work, the detailed site design and layout has not yet been finalised and any procedural mitigation has not been produced. Therefore this section of the submission follows an overall approach which describes how the Integrated Management System (IMS) will be developed and implemented to provide evidence that the Operator has adopted a robust approach to the identification, management and mitigation of environmental impacts. The IMS will cover all on-site activities to ensure a holistic and consistent approach is taken; the IMS will also cover off-site activities where applicable (e.g. supply chain management). Due to the early stage of development of the IMS, the tables of indicative BAT requirements have not been incorporated; it is likely that as the environmental function of the IMS develops, it will initially be suited to the exploratory work to be carried out on the site before focussing on the construction impacts prior to being tailored around the operational impacts of the reactor site (and, for the purpose of this submission, the installation).
NNB GenCo recognises that, the development of effective management arrangements, integrated in the company management systems, are key to ensuring a high standard of environmental performance and ensuring regulatory compliance. In order to reflect the complexity of regulating sites with environmental permits, the Environment Agency has produced Core Environmental Permitting Guidance [54] as well as specific guidance on environmental management systems (EMS) [55]. The guidance states that:
“complex regulated facilities are encouraged to put in place a formal EMS externally certified (by a UKAS accredited certification body) and strongly suggests registration followed by certification to one of the following standards:
x BS EN ISO 14001:2004 [4] (the International Organisation for Standardisation) – worldwide standard
x The Eco Management and Audit Scheme (EMAS);
x BS 8555:2003 [56] (British Standards) through the Acorn Scheme; or
x The Green Dragon Environmental Standard (England and Wales only).
These standards require that the management system include safeguards for legal compliance and a commitment to continuous improvement of environmental performance.”
The key aspects to be addressed by an EMS are: x The identification and minimisation of pollution risks; x Operations and maintenance; x Accidents; x Incidents and non-conformances; x Site closure; x Staff training and competence;
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x Odour, noise and emissions management plans; and x Documentation of legislation and other requirements.
NNB GenCo will implement these EMS requirements through a site-wide IMS.
NNB GenCo will make every effort to ensure that the strategy for management systems fulfils the requirements laid down in these documents and guidance. Although the approach described in this document relates specifically to the operations phase (specifically the permitted installation), appropriate systems will also be put in place for the construction and decommissioning phases recognising the differences in operations on site and the systems necessary to manage environmental performance.
The approach to the development of suitable management arrangements will be supported by the company’s aim to drive towards certification to the international environmental standard, BS EN ISO14001:2004 [4] once the management systems are mature. Due to the long construction time associated with the building of the plant, it is feasible that BS EN ISO14001:2004 [4] certification may be obtained before the plant becomes operational. The intention to achieve triple certification (BS EN ISO 14001:2004, BS EN ISO 9001:2008 [57] and OHSAS 18001:2007 [58]) during construction is presently being discussed at a senior management level. The systems implemented will be site wide and will include operations on the installation during the construction, commissioning, operations and decommissioning phases. The environmental aspects will be part of a full IMS covering environment, health, safety and security arrangements.
It is proposed that the management systems and management arrangements are developed according to the milestones of the project development with the ability to fully comply with the permit limitations and conditions at the point of its issuance. Specific management controls associated with managing the permitted combustion plant will be developed before they are required for use on site but in the full knowledge of the detailed final design and as built construction. In order to ensure that the team developing the instructions have all the information necessary for the development of instructions that are accurate and fit for use, the instructions will be developed at a later date, when this information is available. All documentation will be developed in due time to ensure that there is proportionate consultation with the appropriate stakeholders, including the Regulator. All parties undertaking activities on behalf of the site licensee will be trained using controlled management arrangements, before they undertake any activities. Management arrangements will be in place before the commissioning milestone is achieved.
The development of the management systems to support these arrangements is progressing and interim arrangements relating to the present key management requirements are in the process of being implemented. This includes policies, management baseline, prospectus and manual, personnel competency controls, management control of documentation and records (including security arrangements), management of design change and incorporation of BAT formally into the design process.
Changes made by the Architect Engineer to the design of the permitted installation will be fully assessed by NNB GenCo through the company’s modifications assessment process. This procedure is designed to screen and assess the significance of any design changes on the HPC project. This includes impacts on environmental permits and consents.
As part of the development of suitable integrated management arrangements NNB GenCo has produced a set of strategies and forward actions to control the development of management arrangements. The strategies include requirements for non-radiological management arrangements and quality. The actions will include: x A review of relevant technical guidance notes provided by the Environment Agency, such as those in draft/consultation form at the time of writing; x A review of existing EDF Energy documentation to understand the procedures and processes currently used
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at the existing sites; x Consultation with the key stakeholders within EDF Energy to gain an appreciation of their expectations for an integrated management system and ensure early engagement; x Consultation with key stakeholders regarding the key organisational roles and responsibilities required to ensure compliance and ensure consistency with the organisation baseline; x A review of the applicable EDF and NNB GenCo documentation, to identify procedures already developed that can be used to support the development of the integrated management system; x Communication with all the parties involved in the development of the integrated management system; and x A final review of the legislation and guidance to ensure compliance with the applicable regulations.
5.1.1 Management System Requirements
The Environment Agency Combustion Sector guidance note [7] requires consideration of the proposed management systems for the following aspects: x Operation and Maintenance; x Competence and training; x Accidents, incidents and non-conformance; and x Organisation.
5.1.2 Operations and Maintenance
Operations
As part of the development of the management system, overarching management arrangements associated with Operating Rules will be developed to ensure that any operation that may affect safety and environmental performance is supported by an adequate safety case and assessment of environmental impacts with the key requirement of minimising waste and emissions through the application of BAT. The provision of ensuring that operating Rules are appropriate to the nature and scale of the activities being undertaken, as well as the regulatory requirements will be advised by a formally documented and controlled environmental aspects assessment process. The basis of this process is likely to build on the present arrangements that are in place at the UK EDF Energy sites, the arrangements will be amended to ensure that they take full account of NNB GenCo and the information and data that have been (and will be produced) during impact assessments undertaken for the regulatory application processes.
Operating rules will set conditions and limits to ensure that the plant or process is kept in a safe condition with optimal environmental performance. For the development of the Operating Rules, consideration is being given to the approach that was taken for the SZB PWR and to approaches being taken at other EPR units under construction, which includes utilisation of the MERITS methodology (Methodically Engineered Restructured and Improved Technical Specifications). From an environmental perspective, all guidance available to date and made available before the finalisation of the arrangements will be consulted and will underpin the development of management arrangements.
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A strategy has been developed to ensure that appropriate development and application of Environmental Operating Rules. The key aims and principles of the Operating Rules management arrangements are to ensure that all operational safety and environmental conditions and limits, as presented in the safety case as well as in any other environmentally pertinent documentation, are specified in the Operating Rules.
For the purposes of commissioning there are specific requirements under the NSL to ensure that the licensee has adequate arrangements to control all the testing, inactive and active commissioning of plant and systems that may affect safety on the nuclear licensed site. These will be developed to ensure appropriate environmental controls are in place as required under other permits and authorisations. The owner of this document is the NNB GenCo Head of Operational Development. The Head of Operational Development is responsible for the implementation of this strategy in order to develop and implement an authorised set of arrangements for commissioning. The NNB GenCo key stakeholders that will be consulted as appropriate during the production of all documentation and other supporting arrangements will include the Head of Environment. The commissioning documentation will ensure that environmental impacts are fully documented, taken into account and that there are appropriate arrangements, including suitably qualified personnel in place to ensure safe operation and appropriate environmental performance.
Directly related to the overarching Operating Rules, management arrangements will be associated with the creation of Operating Instructions.
This will ensure that written Operating Instructions are produced for those operations which may affect environmental (and safety) performance and that all these operations are undertaken in accordance with the instructions. Instructions will be developed so as to be clear and unambiguous and will be consistent with the environmental aspects/impacts assessments, safety case and their assumptions. Limits will be produced and will be specified in compliance with Operating Rules. The Operating Instructions will specifically highlight Operating Rules where these exist and require operations to be undertaken in accordance with them, and with any other parameters which minimise the risk from other hazards and/or minimise the production of waste emissions and emissions and risks to the environment as far as reasonably practicable. Arrangements for document control and distribution will be controlled through other management arrangements, together with arrangements to validate the instructions and changes to them, and to bring them into use at the appropriate time. These requirements will also apply in their entirety for temporary Operating Instructions.
The key aims and principles of the Operating Instructions arrangements are as follows: x To ensure that any operation which may affect safety or environmental performance is performed in accordance with approved Operating Instructions; x To ensure that the Operating Instructions include any instructions necessary in the interests of safety and environmental performance to ensure that the conditions and limits of the Operating Rules are implemented; and x To ensure that adequate arrangements are made and implemented for the preparation, review and amendment of the Operating Instructions.
Maintenance
Maintenance systems will be developed as part of the process of the development of appropriate operational management arrangements. A bespoke maintenance management platform will be used to manage maintenance and will be integrated into the NNB GenCo management systems. The experiences of the EDF Energy Existing Nuclear sites will be important in developing suitable management arrangements for maintenance. Expertise of the parent company and plant vendors will also be key to developing appropriate maintenance management arrangements.
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In order to ensure appropriate levels of control during shutdown for maintenance or any other reason, management arrangements will be developed to ensure that safety and environmental performance will be maintained. The key aims of these maintenance management arrangements are as follows: x To ensure that all maintenance schedule activities that require unavailability of any plant or process to allow any examination, maintenance, inspection or testing to be performed are identified, planned, actioned, reviewed and recorded; and x To ensure that procedures are in place to enable the safe shutdown, and subsequent safe re-start, of any plant or process to allow any examination, maintenance, inspection or testing to be performed.
5.1.3 Competence and Training
A major part of the IMS development programme is to provide assurance that all staff, contractors and any other personnel who control supervise and/or carry out operations on the nuclear site are fully trained for the tasks that they carryout, are fully aware of the potential environmental issues associated with the activities that they carryout and they are fully competent for the roles that they undertake. This therefore applies to all duly authorised persons (DAPs) and other suitably qualified and experienced persons (SQEPs).
Further, the Operator will provide adequate instructions to all persons allowed on the site so they are aware of the risks and hazards associated with the plant and its operations, the precautions that must be taken to minimise the risks to themselves and others and the actions to be taken in the event of accident or emergency. Detail of the Compliance Arrangements and supporting documentation for instructions to persons on site are expected to change during the Station lifecycle, particularly at changeover points from construction, to commissioning, into operation and close of operations.
To this end, the Operator is progressively developing a system of procedures which will encompass: x An integrated company policy which summarises how training arrangements will be implemented; x A summary of environmental and safety roles and responsibilities; x Organisational arrangements and responsibilities; x Procedural documentation; x Standards, manuals and guidance; and x A fully developed compliance matrix.
Training arrangements that have been demonstrated to comply with required regulations are already implemented on UK operating (EDF Energy) sites. These will form the basis of training arrangements developed in subsequent life cycle phases. A review of these arrangements has been performed to determine whether they are appropriate for NNB GenCo and to identify any gaps against the regulatory requirements. It has been noted that there will be aspects of these arrangements that will not be applicable on NNB GenCo sites due to the different training requirements for new build sites. Conversely, the applicant recognises that since this is a new build site there are additional requirements which may not be relevant, or are less relevant to established sites. The applicant will ensure that all those people on the site who carry out activities during design, construction, manufacture, commissioning, operation or decommissioning of a nuclear installation or who have responsibility for any action which may affect environmental performance or safety are adequately trained for that purpose. Assurance procedures are being developed so that the necessary training requirements are identified for each activity that individuals who carry out these activities can demonstrate that they have received such training and that records are kept to demonstrate that individuals have been trained.
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It is envisaged that the system will be based on top down arrangements of which the requirements for training under the environmental permit for Schedule 1 Part A combustion plant will be a part. The upper tier of these arrangements will be an overall integrated policy for training for activities that may impact on plant environmental performance and safety. The arrangements that will be developed will require the production of a comprehensive schedule or programme for each person or group of persons on the site, in which the training requirements for each role are specified and the training requirements of an individual are identified. However, responsibility for ensuring that persons are trained lies with their Manager.
The Head of Training is responsible for defining NNB GenCo’s approach to compliance and has overall responsibility for the NNB GenCo management arrangements. The responsibility for implementing the requirements will lie with Department Managers and Heads of Section.
5.1.4 Accidents, Incidents and Non-Conformances
As with the other operational arrangements, a full set of management arrangements (i.e. site-wide and incorporating operations on the permitted installation) for the management of incidents and non-conformances at site will be in place 9 months before (reactor) fuel arrives at site. Management arrangements for incidents and non-conformances are to ensure reporting of management issues at this stage in the project. These arrangements are as follows: x Procedure for notification, recording, investigation and reporting of incidents; x Identification of incidents that are to be reported to the regulator; and x Roles and responsibilities of those involved.
This system will be developed in line with the key stages of the development of the nuclear power station. This means that suitable systems will be in place prior to the construction phase as well as prior to the commissioning phases. At the construction stage, detailed coverage for direct ‘nuclear’ incidents is not required. In practice, however, the key difference with the full system will be that contractors will play a dominant part at the construction stage.
In terms of operations, a system will be developed for notification, recording, investigation and reporting of incidents. This will include initial registration of incidents, their classification and investigation (with associated actions).
As with most of the management arrangements that will be in place at the installation it is intended to follow ONR and Environment Agency guidance and the practical experience of other licensees, and have a single system for incidents and for unexpected or unusual occurrences. Therefore, the compliance arrangements sit within the larger overall NNB GenCo Management System arrangements.
The arrangements involving response to incidents will be part of a system of management arrangements that includes: x Document control; x Communications with the Regulatory Authorities; x Examination, Maintenance, Inspection and Testing (i.e. in the case of deficiency); x Leakage and Escape of Waste (i.e. in the case of loss of containment);
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x System for capturing and disseminating operating experience; x Documents, Records, Authorities and Certificates; and x Quality Assurance.
Incidents will be handled through their identification as Unexpected Events, defined as an unexpected or unplanned situation that causes, or has the potential to cause, actual loss to people, the environment, assets or Company image. Furthermore, NNB GenCo recognises that, as well as training for specific skills required, effective roll-out of an incident handling system also requires general awareness-raising amongst all staff and the development of a culture that encourages recognition and reporting of potential issues. All documentation developed will be based on the expertise obtained by EDF Energy at their operational sites. However, it is proposed that appropriate new documentation is produced, taking account of existing EDF Energy practice, which fully complies with the present legislation but is reworked to meet NNB GenCo requirements, and guidance from Environment Agency, ONR and other appropriate sources. As part of the FAP, an Accident Management Plan will be developed (this is discussed further in Section 5.2).
5.1.5 Organisation
Organogram
At this stage in the development of the IMS, the operational organisational structure has not been defined. Figure 5.1.1 shows the current NNB GenCo organisational structure (based around director responsibilities). The management arrangements and structure of the company will be reviewed and revised at key points later in the project lifecycle, for example when the company begins commissioning activities and again prior to operation.
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Figure 5.1.1 NNB GenCo Company Structure Showing Director Posts
NNB GenCo Board
Chairman & Managing Non-Executive Directors Director (Construction, Nuclear UK EPR™ Project Safety) [B] EDF Energy Strategy Director
EDF Energy Legal Company Counsel Safety Director Secretary & Legal (2) Counsel
Special Projects Director
Client Director of Project Director EPR Architect Pre-operations Human Resources Construction Planning & Finance Director HPC Director Director Director Director External Affairs [B] [B] [B] [B] (1) [B] [B] [B]
(1) The Pre-operations Director post will evolve into the Operations Director/Chief Nuclear Officer (CNO) on the Board.
(2) The Safety Director will attend Board and NSRAC meetings but will not be a member of the Board.
[B] NNB GenCo Board member
KeyManagementRoles
This section details the present formal management roles. Site level management roles will be communicated to the regulatory agencies at a suitable time. The descriptions of the management roles presented below are summaries only. Detailed descriptions are available upon request.
At the time of writing, the key management roles at this phase of the development that are relevant to this submission are: x Managing Director of NNB GenCo: Serves as Chairman of the NNB GenCo Board as well as the Chief Executive of the management team and a member of the Board of NNB Holding Company. Leads the Board and represents the Company externally. Monitors that the business is properly constituted, is supplied with appropriate information and that interfaces with stakeholders are working properly. The Managing Director (MD) is accountable for NNB GenCo’s compliance with legislation including health, safety, security and environmental legislation. As Chief Executive, the MD leads the executive functions and monitors that the Company operates safely and complies with legislative and regulatory requirements, and that appropriate internal control processes, including quality assurance arrangements, are in place to ensure high levels of safety, security and environmental protection within the Company.
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x Safety Director: The Safety Director will report to the MD and will have responsibility for oversight of all safety and environmental issues in the project and overall organisation. The Safety Director will oversee the ‘internal challenge’ team, which has an inspection function and independent review function for safety documentation, including documentation relating to environmental protection (with technical support from other functions, as appropriate). He is also responsible for the independent reporting of safety and environmental performance, issues and concerns to the Managing Director and Board. x Project Director – Hinkley Point C: Reports directly to the Managing Director of the Company and is a Director of the Company. He is responsible for the HPC Project (including Project Control, Schedule and Cost Management and Risk Management) and is the lead for the UK regulatory relationship, licensing, environmental permitting and security. Together with oversight of the Design Authority, he leads the project ‘EPC’ approach of Engineering (process, procedures and management of detailed design during construction phase, engineering of ‘non nuclear’ plant and buildings), Procurement (completion of procurement and contract management including all aspects of on-site construction) and Construction (management of all on- and off-site construction and associated development works). In addition, he leads on Licensing - obtaining the nuclear site licence and environmental permits required for commissioning and operation. x Head of Nuclear and Environmental Licensing and Security: Responsible for the regulatory arrangements required to apply for, and maintain compliance with, the Nuclear Site Licence, operational Environmental Permits and security plan. x Head of Environment: Reports to the Head of Nuclear and Environmental Licensing and Security. Responsible for environmental permitting and is the main interface with the Environment Agency on regulatory issues. The Head of Environment is also responsible for the environmental management arrangements, supporting NNB GenCo environmental policy development, reviewing aspects of the design and operation of the plant relating to the environmental permit (via the provision of suitable Radioactive Waste Advisers) and supporting the Article 37 submission preparation. There is a key interface with EDF DIN in this role. x Pre-operations Director: Responsible for preparation for operational activities and is the customer lead for commissioning activities. Also responsible for the Training function. Will evolve into the Operations Director/Chief Nuclear Officer (CNO). x Head of Operational Development: The Head of Operational Development is responsible for the implementation of the Hinkley Point Operational Development Strategy. The strategy provides the process by which a robust operational organisation structure will be developed to enable the UK EPR to be operated safely and effectively in the UK regulatory framework. x Director of Planning and External Affairs: Responsible for all activities within this Directorate to achieve NNB GenCo’s development objectives. The Director reports directly to the NNB GenCo Managing Director and is an Executive Director of the Company. The lead contact for planning matters and planning consents with the Department for Energy and Climate Change (DECC), Infrastructure Planning Commission (IPC), the local planning authorities, the Environment Agency and Natural England. x Head of Waste & Decommissioning: This post includes development of the Funded Decommissioning Programme (FDP), management of site specifics relating to strategic waste management (including Intermediate Level Waste and solid Low Level Waste) and spent fuel management issues, providing the Intelligent Customer interface with key suppliers and all other waste planning issues at this stage in the project. x Human Resources Director: The Human Resources Director is responsible for all policy matters addressing human resources in support of NNB GenCo activities. This includes establishing suitable Human Resource (HR) management arrangements (including platforms, processes and procedures) within NNB GenCo both now and into the future. The HR Director reports directly to the MD of NNB GenCo.
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x Finance Director: Responsible for all financial and internal control activities within NNB GenCo. This includes the finance policy, audits, investor relations, strategic business development, information management strategy, policy and services which support the new nuclear build development objectives of constructing and operating the fleet of UK EPRs in the UK. The Finance Director reports directly to the MD of NNB GenCo and is an Executive Director of the Company.
5.2 Accident Management Plan
This section will describe the mechanisms developed by the Operator to enable the identification, assessment, management and mitigation of hazards associated with the activities undertaken at the installation under normal operation and abnormal operating conditions.
The Control of Major Accident Hazards (COMAH) is dealt within a separate site specific application.
The installation will implement a well developed hazard and risk management systems and a philosophy of safe working practices to minimise the potential for environmental impacts.
This section of the application requires a detailed quantified risk assessment of feasible incidents that can have an environmental impact. This analysis should cover accidents and their consequences, including spills and abnormal operation, taking into consideration the methodology proposed in Combustion Sector Guidance Note EPR 1.01 [7].
Due to the development of the overall programme of work, the detailed site design and layout has not yet been finalised and any procedural mitigation has not been produced.
Therefore this section of the submission follows the overall approach taken to describe how the IMS will be developed and implemented to provide evidence that the Operator has adopted a robust approach to the identification, management and mitigation of environmental impacts. This section also provides details where appropriate, of the potential hazards that will be addressed in the Accident Management Plans, in time, this will also operate to identify the roles and responsibilities of personnel in the management of accidents, arrangements for communication in such an event, how such incidents should be managed in the event of occurrence and an assessment of causes of event and changes to operations/procedures to prevent recurrence.
This section discusses the approach to be taken and highlight the main risks identified (based on the current design and experience from other sites). This section of the application therefore currently comprises a relatively high level environmental risk assessment; a quantified risk assessment will not be carried out as any outcome would add little value at this stage (given the engineering and procedural mitigation that has yet to be undertaken before it can be implemented). As part of the FAP, a detailed Accident Management Plan and quantified risk assessment will be provided.
The analysis already performed in both the PCER (Sub-chapter 3.3 [59]) and the Pollution Prevention and Control (PPC) GDA document [10] includes the fuel oil tanks for the diesel generators.
Based on operating and permitting experience across the UK, typical hazardous events that will be addressed as the site design is developed are: x Significant loss of fuel oil during delivery; x Damage to the fuel oil tanks and bunds through accidental rupture or spontaneous failure of tank, leading to loss of (oil) tank contents; x Loss of fuel oil from distribution system during transfer from the main storage tanks to the day storage tanks;
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x Loss of fuel oil from distribution system during transfer from the day storage tanks to the burner; x Loss of containment of lubricating oil; x Fire/explosion of combustible materials, including fuel oil; x Loss of antifreeze during delivery/storage/dispensing; and x Mal operation of the diesel generators.
Other scenarios may be identified as the design of the plant develops, together with the assessment of the associated environmental impacts.
5.2.1 Identification of Hazards
The identification of environmental hazards associated with the operation of the plant has informed the development of the PCER in the GDA.
When implemented, the management system will enable the identification of potentially adverse environmental impacts arising from operations under normal and abnormal conditions, by virtue of the following: x Plant risk assessments; x The Schedule for the assessment and maintenance of plant and machinery that are identified as presenting a risk of potentially adverse environmental impacts; x Operating Procedures and Job Instructions; x Plant modification/change management procedures; and x The Environmental Aspects Register.
The development of these documents and compliance with the periodic review of the environmental aspects register and records of non conformances with the management system and operational requirements, enables the operator to characterise the significance and probability of potential adverse environmental impacts, and to implement, and where appropriate, to review the efficiency of the accident mitigation and management measures.
Details of the documentation referenced above are provided in the following sections.
EnvironmentalRiskAssessment
A preliminary risk assessment carried out for the environmental permit application (and reflecting the level of detail available) has identified a number of typical hazardous events (accident scenarios) as listed above. These will be discussed further in Section 5.2.2.
ScheduleofInspectionsandEnvironmentalMaintenance
A schedule of Inspections and Environmental Maintenance has not yet been developed. Once the detailed design of the plant has been finalised, a preliminary schedule can be prepared. This will be a dynamic document influenced by the commissioning process and ongoing operations. Where equipment is identified has having an environmental protection role, this will be recorded and appropriate maintenance and inspection will be carried
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out. This will be recorded as a procedure within the site management system.
OperatingProcedures/JobInstructions
Procedures will be developed to cover key operations on the installation. These will include the running of the diesel plant and delivery/refilling of the fuel tanks and will incorporate any actions required for environmental protection.
EnvironmentalTrainingNeedsAssessments
As part of every individual’s annual appraisal, a review of training needs will be carried out and where an individual has an environmental responsibility, appropriate training will be provided. All needs including environmental ones will be recorded and appropriate measures taken to deliver the required training. This will be managed through the central training/HR process.
5.2.2 Environmental Risk Assessment
This section of the submission will provide a description of the procedures/methodology for identifying and assessing environmental risk. A quantified risk assessment has not been provided as the processes and mitigations are not sufficiently developed to either reflect the protection measures in place or to commit to specific measures. A full quantified risk assessment will be provided as part of the FAP.
The approach to the assessment of hazards with the potential for environmental impacts will be in accordance with the requirements of the Environment Agency H1 Guidance Note: Environmental Assessment and Appraisal of BAT (May 2004). This is also consistent with the revised approach presented in the updated H1 Environmental Risk Assessment (April 2010) guidance document that is currently in consultation (specifically Annex A: Amenity and accident risks from installations and Waste Operations).
The identified hazards will be reviewed in accordance with the approach provided by the Regulator (along with any additional risks identified), as provided in the 2004 H1 Guidance Note (there is no guide on quantification provided in the new guidance). To enable an accurate and meaningful quantitative assessment of the likelihood and environmental significance of the identified accident scenarios, this will be delivered through the FAP, the quantitative values and definitions of their meaning that will be applied are provided in the ranking matrix given in Table 5.2.1.
Table5.2.1 RankingMatrixforRiskAssessment
“S”Severityofenvironmentalimpact “L”Likelihoodofevent
1. Minor Nuisance onsite only (no off-site effects). 1. Extremely Incident occurs less than once in a million No outside complaint. unlikely years.
2. Noticeable Noticeable nuisance offsite, e.g. discernable 2. Very unlikely Incident occurs between once per million odours. and once every 10,000 years. Minor breach of permitted emissions, but environmental harm. One or two complaints from the public.
3. Significant Severe and sustained nuisance, e.g. strong 3. Unlikely Incident occurs between once per 10,000 offensive odour or noise disturbance. years and once every 100 years. Major breach of permitted emissions with possibility of prosecution.
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“S”Severityofenvironmentalimpact “L”Likelihoodofevent
Numerous public complaints.
4. Severe Hospital treatment required. 4. Somewhat Incident occurs between once per hundred unlikely and once every 10 years. Public warning & off-site emergency plan invoked. Hazardous substance releases into water course with ½-mile effect.
5. Major Evacuation of local populace. 5. Fairly probable Incident occurs between once per 10 years and once per year. Temporary disabling and hospitalisation. Serious toxic effect on beneficial or protected species. Widespread by not persistent damage to land. Significant fish kill over 5 mile range.
6. Catastrophic Major airborne release with serious offsite 6. Probable Incident occurs at least once per year. effects. Site shutdown. Serious contamination of groundwater or watercourse with extensive loss of aquatic life.
This assessment methodology is presented in Table 5.2.2.
Table5.2.2 CalibrationofRiskAssessmentOutputs1ǦBanded
LikelihoodofEvent SeverityofEnvironmentalImpact
Minor Noticeable Significant Severe Major Catastrophic
1 2 3 4 5 6
Extremely Unlikely 1 1 2 3 4 5 6
Very Unlikely 2 2 4 6 8 10 12
Unlikely 3 3 6 9 12 15 18
Somewhat Unlikely 4 4 8 12 16 20 24
Fairly Probably 5 5 10 15 20 25 30
Probable 6 6 12 18 24 30 36
An inventory of the potential hazardous events has been developed by identifying scenarios for different events and activities on the site, and recording the likelihood and the environmental significance of these events, should they occur.
The worst possible or maximum ‘Environmental Consequence’ by media of each event is listed, and the consequence has then been considered and allocated the appropriate numerical value (from Table 5.2.1) shown under ‘S’ for the severity of any outcome, and ‘L’ for the likelihood of the event occurring. The risk is then calculated by multiplying the severity and likelihood numbers. The results of this are shown under the column ‘R’.
S = Severity, L = Likelihood, R = Risk, (S x L = R)
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Interpretation of the risk scores are provided at Table 5.2.3, which provides comments on the severity/acceptability of the hazard.
Table5.2.3 CalibrationofRiskAssessmentOutputs2ǦDescriptive
RiskScore MagnitudeofRisk Consideration
6 or less Insignificant Low or negligible levels of risk, low or negligible impacts. Adherence to good operational practices will adequately control these risks.
8 – 12 Acceptable Lower level of possible impact, but major severity or high likelihood would require consideration of further actions to reduce risk.
15 - 20 Unacceptable Combination of high likelihood or major impact would require further assessment and possible actions to reduce risk.
24 or more Severe Immediate resolution required.
5.2.3 Quantitative Risk Assessment
Table 5.2.4 provides an example of environmental risk assessment for the accidents identified in the hazard assessments for the standby generators at the HPC installation. The table does not provide a quantitative assessment of the hazards associated with the activities undertaken at the installation; this will be provided when detailed design data is available and will be calculated in accordance with the methodology described above. Table 5.2.4 also provides details of the types of measures that may be implemented at the site to control and mitigate such events to achieve BAT.
The final column in Table 5.2.4 contains a comment on the controls applied; it should be noted that the cause of the events has not necessarily been identified (e.g. for a fire, the specific source of ignition has not always been considered, rather a general assessment of the likelihood of the event and the types of precautions to be applied).
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Table5.2.4 ExampleAssessmentofAccidentsIdentifiedandtheirEnvironmentalConsequencesatHPC
HazardousEvent PotentialEnvironmentalConsequences RiskAssessment Comments/Controls byMedia S L R
Raw Material Delivery
Significant loss of diesel during Air: Short term localised air impact, some TBC TBC TBC Transfers of oils by tanker and bowser have sound primary containment; the need for secondary delivery (tankers) or transfer (by odour. containment will be assessed as a part of the design risk assessment. Risks will reduced by the design bowser). Water: Spillage likely to be contained on site. of the surface water system and procedures requiring spill mats to be placed over any local surface water drains; it is also likely that oil interceptors will be included in the design of the drainage system. Land: Unlikely impact on ground as Procedures will also be developed for filling of main oil tanks. All operations will comply with the Oil operational area of site is likely to be new Storage Regulations. hard standing and all drains will be new. Transfers will be supervised by appropriately trained and supervised site personnel (in addition to the Key receptor: Bristol Channel. vehicle drivers). Tanks will be checked for capacity before filling to prevent over filling and will have Pathway: Still to be determined but likely to level indication/alarms and emergency cut off switches. Any small spillage contained in delivery be site drains. pipework will be managed through local containment. The site drainage system has still to be developed (as part of the FAP) and this process will consider the risks of tanker failure. Vehicle speeds will be controlled by site speed limits and all plant will be housed within the diesel building providing protection against vehicle damage.
Raw Material Storage
Diesel fuel storage. Air: Short term localised air impact, some TBC TBC TBC The tanks and associated pipework are fully enclosed within the diesel buildings which will act as an Damage to the diesel tanks and odour from building ventilation. impermeable bund. Any loss would be fully contained. bunds through accidental impact, Water: Spillage would be contained within Damage from accidental impacts (e.g. vehicles) is unlikely with the tanks being indoors. rupture or spontaneous failure of the diesel building. tank leading to loss of all tank Land: Unlikely as any spillage would be contents. contained within the building.
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HazardousEvent PotentialEnvironmentalConsequences RiskAssessment Comments/Controls byMedia S L R
Raw Material Distribution Systems
Loss of diesel fuel from the Air: Short term localised air impact, some TBC TBC TBC All of the pipework is fully contained within the diesel buildings. Any leaks (minor or major) would be distribution system (pipework) during odour from building ventilation, minor for fully contained. The internal structure of the basement will be finished in an impermeable material transfer from the bulk storage tanks smaller spills and unlikely to be noticeable off (either building material or oil resistant coating). to the combustion plant. site. Water: Spillage would be contained within the diesel building. Land: Unlikely as any spillage would be contained within the building.
Fire
Major fire and/or explosion of Air: Significant local air quality impact from TBC TBC TBC Although possible, fire/explosion is not likely (based on operational experience). Areas, which pose a combustible materials, including combustion products/ dust/ smoke, etc. significant threat of fire such as oil storage facilities, will be protected by dedicated installed fire diesel fuel. Water: Fire water releases would arise and prevention and mitigation systems. Extensive controls will be incorporated into the plant design to after filling the diesel building basement may both prevent explosions and fires (‘zoned’ electrical equipment, alarms, automatic fire systems etc.) and minimise impact. overflow into the site drainage system. The volume of the basement area of the diesel buildings is able to hold a significant volume of water. Land: Unlikely impact on ground due to the extensive hardstanding and new drainage This is considered to be sufficient for fire water in the event of a fire; this will be addressed in more detail through the FAP. system installed within the installation. The station may operate a fire team and (if so) will develop and maintain a fire plan to deal with minor incidents; the diesel buildings will be part of a site-wide fire plan. More significant fires will be dealt with in collaboration with Somerset Fire Brigade.
Operation of the Combustion Plant
Failure or mal-operation of the diesel Air: Release of black smoke and PM TBC TBC TBC In order to monitor the quality of fuel combustion, basic process monitoring will be incorporated (e.g. generators. oxygen, CO and temperature monitoring). The plant is only planned to be operated for maintenance Water: No impact purposes and periodic nuclear safety tests, during which the operations will be closely observed and Land: No impact recorded to demonstrate the reliability of the combustion plant (so any failure of mal-operation will be noticed). If the combustion process is not operating as expected or may be causing off-site impacts the combustion plant will be shut down procedures relating to scenarios such as this will determine the specific actions required by the operator.
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HazardousEvent PotentialEnvironmentalConsequences RiskAssessment Comments/Controls byMedia S L R
Loss of containment of the cooling Air: No impact. TBC TBC TBC The drainage system for the area housing the cooling circuit has not yet been designed. As part of the system (50% ethylene glycol). FAP, this scenario will be considered and appropriate mitigation put in place to prevent the fluid Water: Spillage would be contained within reaching surface water drains. The fluid will then be removed by a licensed contractor and disposed of the diesel building. as hazardous waste. Land: Unlikely as any spillage would be contained within the building.
Loss of containment of lubricating oil Air: Short term localised air impact, some TBC TBC TBC All of the pipework is fully contained within the diesel buildings. Any leaks (minor or major) would be odour from building ventilation. fully contained. The internal structure of the basement will be finished in an impermeable material (either building material or oil resistant coating). Water: Spillage would be contained within the diesel building. Land: Unlikely as any spillage would be contained within the building.
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ConclusionsofRiskAssessment
As a quantified risk assessment has not been provided and many of the risk mitigation measures (both engineered and procedural) have not yet been determined there are no quantified worst case risks specific to the HPC installation.
On the basis of the current plant design and the decision to fully enclose the tanks and generators in the diesel building, the risks that are considered to be the most significant on similar UK sites would appear to have both a reduced probability and hazard (when compared to existing operational sites); this results in a lower overall risk.
IndicativeBATRequirementsforAccidents
Table 5.2.5 details the indicative BAT requirements from the sector guidance and provides a commentary on the proposed approach for the HPC installation. This recognises the limitations of the approach taken and the proposal to provide further data through the FAP.
Table5.2.5 IndicativeBATRequirementsforAccidentsatHPC
IndicativeBAT Procedure/Comment
Identify the hazards to the environment posed by the Installation. Particular areas to consider may include, but should not be limited to, the following:
Transfer of substances (e.g. loading or unloading from or to Table 5.2.4 identifies the likely hazards associated with operations vessels); on the installation.
Overfilling of vessels; Table 5.2.4 identifies the likely hazards associated with operations on the installation.
Failure of plant and/or equipment (e.g. over-pressure of When determined, compliance with the site inspection and plant vessels and pipework, blocked drains); maintenance and testing schedules are considered to mitigate these hazards. Appropriate alarms to reduce the likelihood of overfilling or over pressurisation will be considered in the Procurement phase.
Failure of containment (e.g. bund and/or overfilling of The main fuel storage tanks have been designed to protect the drainage sumps); environment and are housed in an engineered bund within a dedicated building. Actual tank specifications are not yet known, but will be designed and specified in accordance with appropriate requirements and practice at the time (e.g. tank material and manufacturers testing regime).
Failure to contain firewater; The basement areas would house a significant volume of firewater, in addition, dedicated fire suppression systems may be installed and surface water drains are likely to include oil interceptors (although procedures will be in place to isolate any local surface water drains). Firewater from the installation will be considered as part of the site- wide Fire Plan which will identify potential risks to the environment.
Making the wrong connections in drains or other systems; Not relevant for processes undertaken on the installation (there are no process effluents generated under normal operations). The diesel buildings are fully contained and isolated from external discharge routes. There are no other fuel sources and all deliveries will be overseen by suitably trained site staff.
Preventing incompatible substances coming into contact; Procedures will be in place for tanker deliveries to ensure that only diesel fuel is transferred into the tanks and all deliveries will be overseen by a member of site staff.
Unexpected reactions and/or runaway reactions; Not relevant for processes undertaken at the installation, only diesel fuel will be stored on the installation.
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IndicativeBAT Procedure/Comment
Release of effluent before adequate checking of its Not relevant for processes undertaken at the installation, there are composition has taken place; no planned effluent releases.
Failure of mains services; and The diesel generators are standby plant designed to operate without mains power and provide power in the absence of mains power. In the absence of mains power, the SBO plant can be used.
Vandalism. The site will be protected by high level security systems.
Assess the risks - having identified the hazards, the process of assessing the risks can be viewed as addressing six basic questions:
What is the estimated probability of their occurrence? (Source Table 5.2.4 above provides an assessment of each of the identified and frequency); hazards using the risk evaluation and classification matrix discussed above. A fully quantified risk assessment will be provided a part of What gets out and how much? (Risk evaluation of the event); the FAP. The methodology described and applied above is consistent with Where does it get to? (Predictions for the emission – what are the pathways and receptors?); current and proposed Environment Agency guidance (H1, Part 1) and is considered BAT. What are the consequences? (Consequence assessment – the effects on the receptors);
What are the overall risks? (Determination of the overall risk and its significance to the environment); and
What can prevent or reduce the risk? (Risk management – measures to prevent accidents and/or reduce their environmental consequences).
The depth and type of assessment will depend on the characteristics of the Installation and its location. The main factors which should be taken into account are:
The scale and nature of the accident hazard presented by the The methodology takes into account the presence of on and off site installation and the activities; receptors within the vicinity of the installation, and the sensitivity of the environmental setting of the area. The extent of the hazard is The risks to areas of population and the environment significantly reduced by the consideration of environmental issues (receptors); and at the design stage, this is particularly evidenced through the housing within the diesel building and bunding of the tanks. The nature of the installation and complexity or otherwise of the activities and the relative difficulty in deciding and justifying the adequacy of the risk control techniques.
Identify the techniques necessary to reduce the risks including:
An inventory should be maintained of substances, present or The management system implemented by the operator will comply likely to be present, which could have environmental with this requirement. consequences if they escape. It should not be forgotten that many apparently innocuous substances can be environmentally damaging if they escape (e.g. a tanker of milk spilled into a watercourse could destroy its ecosystem). The permit will require the Regulator to be notified of any changes to the inventory;
Procedures should be in place for checking raw materials and The integrated management system to be implemented will cover wastes to ensure compatibility with other substances with this aspect. Refer to Section 5.3 for details of raw materials and which they may accidentally come into contact; Section 5.4 for details of wastes.
Storage arrangements for raw materials, products and wastes Storage arrangements are considered to comply with the indicative should be provided to minimise risks to the environment; BAT requirement.
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IndicativeBAT Procedure/Comment
There should be automatic process controls backed-up by The site will have extensive systems for maintaining control in manual supervision, both to minimise the frequency of emergencies, and the standby systems discussed here are part of emergency situations and to maintain control during that. emergency situations. Instrumentation will include, where The operation of the standby plant will be undertaken only when appropriate, microprocessor control, trips and process essential and the systems are robustly engineered to ensure this interlocks, coupled with independent level, temperature, flow availability with reliability being the crucial factor. and pressure metering and high or low alarms. The measures proposed at the site are considered to constitute BAT.
Physical protection measures, such as suitable barriers to All operations will be fully enclosed within the diesel buildings, prevent damage to equipment from the movement of including the main tanks, which will be contained in engineered vehicles, should be in place as appropriate; bunds and are away from site traffic.
Appropriate secondary containment should be provided, e.g. The building will act as secondary containment and will be bunds and catchpots, building containment; impermeable to the diesel fuel stored inside.
Techniques and procedures should be implemented to prevent The tanks will incorporate appropriate alarms. Any over flow would overfilling of storage tanks (liquid or powder), e.g. level be contained within the diesel building. The delivery/transfer measurement, independent high-level alarms, high-level cut- system may also incorporate an emergency shut off system. off, and batch metering;
Where the installation is situated in a floodplain, consideration The flood risk to the installation (and wider site) is addressed in the should be given to techniques which will minimise the risk of Environmental Statement [60] produced as part of the EIA process. the flooding causing a pollution incident or making one worse.
installation security systems to prevent unauthorised access The security to be employed will be typical of nuclear installations in should be provided as appropriate and should include the UK and appropriate maintenance arrangements will be maintenance arrangements where necessary; developed.
There should be formal systems in place for the logging and Provision for the reporting and recording of the incidents will be recording and recording of all incidents, near-misses, changes provided as part of the integrated management system. to procedures, abnormal events and findings of maintenance inspections;
Procedures should be established to identify, respond to and Provision for this is provided as part of the integrated management learn from such incidents; system.
Safe shutdown procedures should be in place; The operating manual will make extensive provision for safe shutdown procedures, the diesel plant is a key part of the safety shutdown procedures.
The roles and responsibilities of personnel involved in accident These will be established and tested as part of a site-wide management should be identified; emergency testing regime.
Communication channels with emergency services and other These will be established and tested as part of a site-wide relevant authorities should be established, and available for emergency testing regime. use in case of emergency.
Appropriate control techniques should be in place to limit the These issues will be addressed as part of the accident management consequences of an accident, such as isolation of drains, plan. provision of oil spillage, alerting of relevant authorities and evacuation procedures.
Procedures should be in place to ensure that the composition Extensive provision, including work instructions will be made within of the contents of a bund sump, or sump connected to a the integrated management system for the monitoring of sump drainage system, are checked before treatment or disposal; contents or spillages prior to discharge or disposal.
Personnel training requirements should be identified and This will be addressed through the central training programme. training provided;
Drainage sumps should be equipped with a high-level alarm or This aspect of the diesel building has not yet been designed sensor with automatic pump to storage (not to discharge); however as the tanks are in the diesel building, any major spillage there should be a system in place to ensure that sump levels would be contained in the event of a sump overflowing. There will are kept to a minimum at all times; be no requirement to pump out rain water so a permanent sump pump is not required.
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IndicativeBAT Procedure/Comment
High-level alarms etc. should not be routinely used as the Fuel deliveries will take place regularly to maintain the fuel stocks at primary method of level control; a high level. On-site staff will have an estimate of the fuel required based on running hours and deliveries will be closely supervised. At the purchasing stage, tanks with a visual fill level indicator will be considered as will a fill level alarm (prior to the high level alarm).
Adequate redundancy or standby plant should be provided This will be provided where required (the combustion/power system with maintenance and testing to the same standards as the is completely dedicated to standby use and includes for main plant; contingency).
Spill contingency procedures should be in place to minimise Spill contingency procedures will be determined following the accidental release of raw materials, products and waste design of the drainage in place as detailed within Section 5.1. materials and then to prevent their entry into water
Process waters, site drainage waters, emergency firewater, The drainage system for the site has not yet been designed (FAP). chemically contaminated waters and spillages of chemicals The issues raised in this aspect of indicative BAT will be considered should, where appropriate, be contained and where at a site wide level to ensure any system employed is necessary, routed to the effluent system, with provision to comprehensive and consistent. The installation will not routinely contain surges and storm-water flows, and treated before generate process effluent. emission to controlled waters or sewer. Sufficient storage A copy of the site drainage plans as they relate to the installation should be provided to ensure that this could be achieved. will be provided to the Environment Agency as part of the FAP; the There should also be spill contingency procedures to minimise ability of effectively isolate or contain the site from the marine the risk of accidental emission of raw materials, products and environment will be considered as part of the design process. waste materials and to prevent their entry into water. Any emergency firewater collection system should also take account of the additional firewater flows or fire-fighting foams. Emergency storage lagoons may be needed to prevent contaminated firewater reaching controlled waters (see Refs. 14 and 15); and
Consideration should be given to the possibility of The Diesel Building offers a complete bund for any spillages. The containment or abatement for accidental emissions from vents only pathway for release is through failure of the tank seals and safety relief valves/bursting discs. Where this may be resulting in a minor release of hydrocarbon vapour. inadvisable on safety grounds, attention should be focused on reducing the probability of the emission;
5.3 Raw Materials
This section of the application considers the use of raw materials and water, the techniques implemented to minimise the use of these materials and their associated impact. The section will therefore consider: x The characteristics and the environmental impacts associated with the raw materials to be used in the regulated activities; x The measures implemented to reduce/optimise the efficient use of raw materials; x Measures in place to reduce the water requirement at the installation; and x As standby plant, the raw material requirements for the diesel plant are significantly reduced.
5.3.1 Raw Materials Selection
This section of the submission provides an inventory of the raw materials associated with the operation of the regulated activities, demonstrates that the environmental characteristics of the raw materials sourced are well understood and that these materials are managed in a way that minimises the potential for spillage and loss of
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containment.
The raw materials associated with the operation of the installation are:
Diesel Fuel: Fuel consistent with BS 2869:2010 (or relevant standards at time of procurement and operation) will be used for the all standby diesel generators (see Section 2.1). The approximate total fuel consumption for the 12 combustion plant (supporting both reactors) is estimated to be 834 tonnes per year; (based on EDG and SBO testing resulting in running for 60 hours per year for each engine). This is based on operating experience of the most recent French ‘N4’ type nuclear power station (closest operational comparison with the UK EPR) and is considered to be conservative.
Lubricating Oil: For the diesel generators; standard lubricating oil type SAE 40 is recommended. The amount of oil used per annum depends of the chemical analysis performed on samples that will be regularly taken, whose results may or may not lead to the replacement of oil at a frequency to be established. Each of the EDGs holds 1.8 m3 of lubricating oil (which differs to the data provided in the GDA) and each of the SBOs holds 0.335 m3. It should be noted that the maintenance programme for the diesel generator cooling system will help quantify actual consumption of lubricating oils and generation of waste oils.
Antifreeze: The proposed material used in the diesel generators cooling system is consistent with that detailed in the UK EPR reference design. The cooling liquid used for the dry air coolers (the heat produced by the diesel generators will be transferred to the cooling loop via a water/air heat exchanger) and the autonomous circuits consists of ready-to-use 50/50 mixture of monoethylene glycol and water and is stored on site in drums. For EDG engines the cooling system capacity is approximately 8 m3 in total, comprising 5 m3 for the first circuit known as the High Temperature Cooling Water Circuit, and 3 m3 for the second circuit, the Low Temperature Cooling Water Circuit. The cooling system capacity for SBOs is approximately 3 m3 in total, comprising 1.7 m3 for high temperature and 1.3 m3 for the low temperature water circuits.
The cooling circuits are replenished with the antifreeze solution using a storage tank (approximately 1 m3), which is filled directly from drums; this tank and the drums are stored in a dedicated raw materials storage facility which serves the entire site. This storage facility is excluded from the scope of the installation (as a result of its prime purpose being to serve non-combustion plant). Cooling mixture drained from the cooling circuits during maintenance will be disposed of as a hazardous waste.
Batteries: These components are used to supply the speed governor of the SBOs. The demand for replacement batteries will be determined by the manufacturer’s recommendations; as an estimate the batteries will be replaced annually (to ensure they continue to hold/provide power). On this basis, 4 batteries per SBO may be required per year.
Other materials that may be reasonably included but which are to be confirmed include: x Detergents and cleaning chemicals for the combustion plant; x Water for cleaning; x Water for demineralisation to replace cooling fluid losses; x Ignition gases (for engine start-up); and x Maintenance spare parts.
This section of the application demonstrates that the Operator has a system in place to identify and understand the environmental characteristics of the raw materials it sources, and that, where appropriate, substitute raw materials with reduced environmental characteristics are used.
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Typically, it may be possible to replace raw materials with alternatives with a reduced environmental impact. However, for the standby plant design, the selection of currently proposed raw material is considered justified, based on the following criteria: x The use of diesel generators rather than gas fired generators is based on options assessment provided in Section 2 of this submission, which has shown that this equipment is highly reliable and well-tried. Moreover the use of compressed gaseous fuel with pipes would introduce new hazards to the site, the recent reduction in the sulphur content of diesel fuel under SCOLF Regulations 2007, means that compared with the benefit of using Class C2 kerosene, there is little difference. Diesel fuel also has a greater calorific value per unit and a lower volatility (than kerosene), thus reducing vent losses during filling operations (the justification for the choice of plant type and fuel is provided in Section 2); x Lubricating oil is used in all engines to prevent the build up of heat from friction, facilitate the smooth movement of parts and increase the life time of the plant. The type of lubricating oil to be used will depend on the manufacturer’s specification for the diesel plant and the raw material demand will be determined by the maintenance regime and the frequency that the oil is to be replaced; x The use of monoethylene glycol in cooling systems is an industry standard and is used in the currently operating EDF reactor sites. The cooling circuits are closed loop systems and will be topped up to degraded coolant as and when required; and x There is no alternative to the use of batteries. The SBOs are present to restart the station in the event of a total blackout.
Table 5.3.1 provides an inventory of the raw materials requirement of the proposed installation as it is currently known. This will be updated as additional information is developed through the collation of further data from the following sources:- x Material safety data sheets (MSDS); x The BS grade or class of raw material used; x Appropriate substitutes to the raw materials currently used if applicable; and x Justification for not using the alternative raw materials where appropriate.
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Table5.3.1 HPCRawMaterialsAssessment
RawMaterialand ChemicalComposition AnnualUsagein FateofRawMaterialin EnvironmentalImpact AlternativeofLower ReasonforUseofRaw Application CombustionPlant theCombustionPlant Potential EnvironmentalImpact Material
Fuel Oil-Diesel Hydrocarbon - BS 2869:2010 Estimated as 834 tonnes for Combustion of gas to air as Emission to air of NOX, SO2, Natural Gas - lower level of Storage of pressurised gas (or applicable standard at both reactors (93 tonnes per exhaust gases. CO , CO, VOCs and PM. PM and small reduction in and reliance of external As fuel for the diesel 2 time of procurement and EDG and 22.5 tonnes per SO emissions piped supplies are discounted generators. Marine pollutant 2 operation). SBO) on safety and security of Small spillages to ground will supply grounds biodegrade. Major spillage to ground will Kerosene - lower level of PM No major environmental penetrate sub soils-risk of and sulphur emissions. benefit. The sulphur content of the grade of fuel is limited groundwater contamination. Lower sulphur containing to 0.1%. Spillages unlikely as all tanks grade of fuel oil are inside a building and fully Reliability and experience of bunded. operating diesel generators is a key factor.
Lubricating Oil Assumed to be a mineral oil Annual usage on combustion Waste oil from maintenance Marine pollutant None Recommended by to SAE 40 - there will also be plant is estimated as activities will be recycled manufacturer. Used for diesel generators Produces a hazardous waste. trace additives. 3.5 tonnes (4,032 litres) (450 litres/year per EDG and Degrades in soil over time. 108 litres/year per SBO) for two UK EPR units.
Antifreeze Monoethylene Glycol Initial fill usage is estimated 100% to hazardous waste Marine Pollutant Considered to be no engine No engine compatible as 38 m3 by the diesel compatible alternative of alternative Used by diesel generators and small pumps generators per UK EPR unit. lower environmental impact After this, usage will be restricted to loss replacement.
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RawMaterialand ChemicalComposition AnnualUsagein FateofRawMaterialin EnvironmentalImpact AlternativeofLower ReasonforUseofRaw Application CombustionPlant theCombustionPlant Potential EnvironmentalImpact Material
Batteries Unknown. To be Low- estimated 16 Recycled or re-used after Corrosive and toxic Compressed air starting No significant environmental Main use is for SBO start-up determined. batteries/cells are replaced refurbishing off site. systems can be used but benefit per annum battery power provides an and for power to SBO speed independent supply as regulators. required by Safety case
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IndicativeBATRequirementsforMaterialSelectionatHPC
Table 5.3.2 details the indicative BAT requirements and commentary on the approach to be taken for materials selection at the HPC installation.
Table5.3.2 IndicativeBATRequirementsforMaterialSelectionatHPC
IndicativeBATfromGuidance HowtheInstallationActivitiesaddressIndicativeBAT
The Operator should maintain a list of raw materials and their A register will be maintained as part of compliance with the Control properties as noted above. of Substances Hazardous to Health (COSHH) Regulations [61], Material Safety Data Sheets for all raw materials will be held in the station. These sheets will list the properties of all raw materials and branded products used on the site and provide toxicological and ecological data and information on suitable disposal routes.
The Operator should have procedures for the regular review of new The review of materials is a requirement of the COSHH developments in raw materials and for the implementation of any Regulations [61] and this is performed by a specialist contractor for suitable ones with an improved environmental profile the site. The priority for review is materials classed as COSHH Essentials with less frequent review for the less hazardous materials. The station will comply with the COSHH Regulations [61].
The Operator should have quality-assurance procedures for There are Company Specifications for major commodities, such as controlling the impurity content of raw materials. fuel oil, which specify permitted impurity contents; these will be applied to the HPC site where applicable. Manufacturer’s recommendations will also be incorporated and local specifications for materials will be developed.
The Operator should complete any longer-term studies needed into No significant less polluting options for raw materials proposed for the less polluting options and should make any material use on the combustion plant, have been identified in Table 5.3.1. substitutions identified.
5.3.2 Raw Materials Handling and Storage
The only raw materials to be stored on the installation are the fuels, all other raw materials will be stored in dedicated site-wide facilities that are outwith the scope of the installation. During the design and operation of these facilities, BAT will be considered both from engineering and procedural perspectives.
FuelOil
The standby diesel generators on the installation will use diesel fuel oil with characteristics complying with the SCOLF Regulations 2007 and BS 2869:2010 (or standards applicable at time of procurement and operation). The design of the installation will allow the supply to be delivered by road tanker and transferred into the main storage tanks, which are located inside the diesel buildings. The tanks will be all inside the building which will be made impermeable to the fuel and regularly maintained and inspected. The tanker delivery arrangements and drainage system have not yet been designed; these arrangements will be provided as part of the FAP under the Accident Management Plan.
Oil storage areas of the installation will meet the requirements of the Control of Pollution (Oil Storage) (England) Regulations 2001.
A summary of the fuel storage and handling arrangements are given in Table 5.3.3.
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Table5.3.3 FuelOilStorageandHandlingArrangementsforDieselGeneratorsatHPC
Diesel ExpectedAnnualFuel FuelOilStorage MethodofDelivery Notes OilUsage
EDGs 93 tonnes per EDG One main storage tank By tanker to main Main and day tanks are per EDG, each of 180 m3 storage tanks located within bunded capacity. areas within the diesel One day tank per EDG, building each of 4 m3 capacity
SBOs 22.5 tonnes per SBO One main storage tank By tanker to main Main and day tanks are per SBO, each of 25 m3 storage tanks located within bunded capacity areas within the diesel building One day tank per SBO, each of 3 m3 capacity
LubricatingOil
The handling and storage of lubricating oil are associated with the operation of EDGs and SBOs.
Each EDG and SBO will have its own lubricating oil system; the specific oil to be used will be based on manufacturer’s recommendations and is expected to be to SAE 40 standard. The main oil storage will consist of either the engine sump if this constitutes an oil reserve, or storage tank and oil return line. The EDGs' engine sump will hold approximately 1.8 m3 of oil, whilst the SBOs will hold approximately 0.335 m3 of oil. Dirty lubricating oil and waste oil from maintenance activities can be collected in sumps and transferred to the station waste oil tank for disposal, this is to be confirmed for the HPC site.
All storage of lubricating oil will be held outwith the installation.
Water
The diesel generators are cooled by primary and secondary (high and low temperature) sealed cooling systems, which contain water and glycol. Therefore there is no need for the handling or storage of water, top up from drums of a pre-mixed solution can be provided where required.
MiscellaneousHandlingandStorage
The following operations associated with the diesel generators involve minimal storage and handling requirements due to the use of site-wide facilities.
FireProtection
The Diesel Building rooms will be protected by the station fire protection systems.
Antifreeze
The EDGs and SBOs are cooled by demineralised water in re-circulating systems, which contain antifreeze. The total fluid volume in the cooling systems (for all diesel plant on site) is 76 m3, of which 50% is ethylene glycol (38 m3). These are sealed systems and replacement fluid will be stored and delivered from outwith the installation.
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5.3.3 Waste Minimisation Audit (Minimising the Use of Raw Materials)
As specified in the Combustion Sector Guidance Note EPR 1.01 [7], a waste minimisation audit is required at least every four years by the Operator. For a new station a first audit will have to be carried out within 2 years of the issue of the permit, this requirement will be captured in the site management system.
The raw materials in use on the installation (as detailed in Table 5.3.1) are: x Diesel fuel; x Lubricating oil; x Antifreeze; and x Batteries.
This raw material requirement will be determined by the plant maintenance requirements leaving little scope for reducing the use.
IndicativeBATRequirementsforWasteMinimisationAuditsatHPC
Table 5.3.4 shows the indicative BAT requirements for waste minimisation audits on the HPC installation based on the information available. Where additional information is required, this will be provided through the FAP.
Table5.3.4 IndicativeBATRequirementsforWasteMinimisationAuditsatHPC
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
The Operator should carry out a waste minimisation audit at least There are minimal raw materials planned to be used on the every 4 years. If an audit has not been carried out in the 2 years prior installation with the requirement being driven by manufacturer’s to submission of the application, and the details made known at the recommendations to maintain the life of the plant. time of the application, then the first audit shall take place within 2 A waste minimisation audit will be carried out within 2 years of the years of the issue of the permit. The methodology used and an plant operating under its permit. This will give the Operator time to action plan for reducing the use of raw materials should be generate data on waste arisings and for a stable operating submitted to the Regulator within 2 months of completion of the profile/regime to be established following commissioning. audit. The audit should be carried out as follows: The Operator should analyse the use of raw materials, assess the opportunities for reductions and provide an action plan for improvements using the following three essential steps: process mapping; materials mass balance; and action plan.
The use and fate of raw and other materials, including by-products, Table 5.3.1 outlines the raw materials proposed to be used and their solvents and other support materials, such as fuels, catalysts and fate. Fuel will be fully combusted and oil and batteries will be abatement agents, should be mapped onto a process flow diagram recycled. The glycol will be in closed loop circuits and any accidental (see the Waste minimisation support references). losses will be disposed of as hazardous waste. This should be achieved by using data from the raw materials inventory and other company data as appropriate. Data should be incorporated for each principal stage of the operation in order to construct a mass balance for the installation
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Using this information, opportunities for improved efficiency, There is little scope to improve the efficiency of the raw material use changes in process and waste reduction should be generated and as the usage is driven by maintenance requirements, periodic nuclear assessed. An action plan should then be prepared for implementing safety tests and manufacturer’s recommendations rather than plant improvements to a timescale approved by the Regulator. demand. This is due to the combustion plant being standby plant rather than in continuous use.
5.3.4 Water Use
As noted in Section 3.2, there is no use of water for the operation of the standby diesel generators. Minor volumes may be required for cooling system top-up and cleaning however this requirement is not significant (some water will also be used in the initial cooling system fill). No further assessment is required for the environmental permit application for the EDGs and SBOs.
IndicativeBATRequirementsforMinimisationofWateratHPC
Table 5.3.5 shows the indicative BAT requirements taken from the sector guidance, although there are no process effluent releases from the installation, commentary on the BAT requirements has been provided for consistency.
Table5.3.5 IndicativeBATRequirementsforMinimisationofWateratHPC
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
The Operator should carry out a regular review of water use (water The Installation does not have a process water requirement. efficiency audit) at least every 4 years. If an audit has not been carried out in the 2 years prior to submission of the application and the details made known at the time of the application, then the first audit should take place within 2 years of the issue of the permit. Flow diagrams and water mass balances for the activities should be produced; Water-efficiency objectives should be established, with constraints on reducing water use beyond a certain level being identified (which usually will be installation-specific); Water pinch techniques should be used in the more complex situations such as chemical plant, to identify the opportunities for maximising reuse and minimising use of water; and Within 2 months of completion of the audit, the methodology used should be submitted to the Regulator, together with proposals for a time-tabled plan for implementing water reduction Improvements for approval by the Regulator.
The following general principles should be applied in sequence to reduce emissions to water: Water-efficient techniques should be used at source where Cooling is provided by closed loop systems. possible; Water should be recycled within the process from which it issues, by treating it first if necessary. Where this is not practicable, it should be recycled to another part of the process that has a lower water-quality requirement; and In particular, if uncontaminated roof and surface water cannot Uncontaminated roof and surface water are not suitable for use in be used in the process, it should be kept separate from other the cooling systems. There are no effluent arisings to be segregated discharge streams, at least until after the contaminated streams
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
have been treated in an effluent treatment system and been from surface water arisings. subject to final monitoring.
Measures should be in place to minimise the risk of contamination This is addressed in Section 3 (for normal operations) and in Section of surface waters or groundwater by fugitive releases of liquids or 5.2 for abnormal operations). solids
The water-quality requirements associated with each use should be There are no process effluent releases from the installation. established, and the scope for substituting water from recycled sources identified and input into the improvement plan. Less contaminated water streams, such as cooling waters, should be kept separate from more contaminated streams where there is scope for reuse - though possibly after some form of treatment. Most wastewater streams will however need some form of treatment but for many applications, the best conventional effluent treatment can produce water that is usable in the process directly or when mixed with fresh water. Though treated effluent quality can vary, it can often be recycled selectively - used when the quality is adequate, discharged when the quality falls below that which the system can tolerate.
In particular, the cost of membrane technology continues to reduce, N/A and they can be applied to individual process streams or to the final effluent from the effluent treatment plant, as appropriate. In some applications in some Sectors, they can supplement (or possibly completely replace) the ETP plant so that most water is recyclable and there is a greatly reduced effluent volume. Where the remaining, possibly concentrated, effluent stream is sufficiently small – and particularly where waste heat is available - further treatment by evaporation can lead to zero aqueous effluent. Where appropriate, the Operator should assess the costs and benefits of using membrane techniques to minimise water usage and effluent discharge.
Water usage for cleaning and washing down should be minimised Housekeeping procedures will be developed prior to commencing by: operations. The indicative BAT requirements will be considered at this stage. vacuuming, scraping or mopping in preference to hosing down; reusing wash water (or recycled water) where practicable; and using trigger controls on all hoses, hand lances and washing equipment.
Fresh water consumption should be directly measured and recorded Fresh water is not a process requirement during normal operations. regularly at every significant usage point - ideally on a daily basis.
5.4 Avoidance, Recovery and Disposal of Waste
The requirements under this section are to: x Demonstrate appropriate measures are in place to ensure that waste produced by the activities is avoided or reduced, or where waste is produced it is recovered wherever practicable or otherwise disposed of in a manner which minimises its impact on the environment; x Review and record at least every 4 years whether changes to those measures should be made; x Take any further appropriate measures identified by the review; x Outline the techniques implemented for the storage, handling and transport of wastes at the site in order to
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minimise the associated environmental impacts, e.g. dust, release of VOCs, spillages, etc; and x Detail the techniques implemented to minimise and optimise the recovery of wastes.
The storage of wastes from the installation will generally be carried out as a site-wide activity with dedicated facilities provided that are outwith the installation boundary. Site-wide procedures will cover the activities on the installation; these will be developed as part of the Integrated Management Systems and will be provided as part of the FAP. In preparation, a site Integrated Waste Strategy (IWS) document has been produced to develop an approach to the management of all radioactive and non-radioactive waste types across the HPC site, including those on the installation.
The IWS document outlines the current strategy for managing radioactive and non-radioactive wastes arising from the site-preparation, construction, operation and decommissioning of the UK EPR nuclear power station at HPC; this incorporates the wastes generated by operations within the installation and is based on the expected waste and spent fuel generation and management practices throughout the lifecycle of the HPC site.
The IWS shows that there is a management strategy for all the waste streams to be produced on the installation and that they have been appropriately planned for. The IWS refers to a range of other documentation for HPC which provide more details on the waste management strategies for HPC and their development.
The document shows that waste management strategies have been developed taking into account all relevant factors and key principles including: x Minimisation of waste via implementation of the waste hierarchy; x Application of Best Available Techniques (BAT); x Review and application of operational experience feedback (OEF) in design, operation and decommissioning; x Delivery of compliance with relevant regulatory obligations (e.g. licence conditions, authorisations and permits) and Government policy and strategy objectives (e.g. a progressive reduction of UK radioactive discharges); and x Consideration of a full range of health, safety, environmental, security, economic and social issues.
NNB GenCo has developed a policy for environmental optimisation and a series of principles that support its application. These principles apply to all NNB GenCo staff involved with the design, procurement, construction, commissioning, operation and decommissioning where the application and demonstration of BAT is required. The principles below apply to waste from the installation: x Determine and implement appropriate techniques at the most appropriate stage (i.e. design, procurement, construction, commissioning, operation, decommissioning and site restoration) of the project lifecycle and promote opportunities for further optimisation during future phases of the project; x Demonstrate the application of best practice, guidance and standards to select techniques and that where the application of best practice, guidance and standards is not possible, that a meaningful range of alternatives have been considered; x Demonstrate that the selection of techniques employed to deliver optimised performance are recorded through a series of arguments that, when taken together and underpinned by demonstrable and defensible evidence, support the selection of the techniques; and x Adopt a proportionate approach ensuring the efforts expended match the benefits expected or achieved through an open, transparent, inclusive process which is recorded and maintained.
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5.4.1 Waste Handling
The main wastes generated across the installation are: x Lubricating oil; x Cooling fluid (50% water, 50% ethylene glycol); x Oily cloths/absorbent pads from minor spills/drips; x Batteries (for starting the SBOs); and x Replaced parts as part of preventative or reactive maintenance.
Table 5.4.1 below identifies the individual waste streams and provides estimates of the annual arisings and containment measures in place. As these facilities have not yet been designed and are outwith the scope of the installation, indications of the measures to be employed have been included.
Table5.4.1 WastesHandlingArrangementsatHPC
WasteStream EstimatedAnnual PrimaryContainment Secondary TertiaryContainment Volume(m3) e.g.Skip,Drum Containmente.g.Bund e.g.Hardstanding
Batteries (used on 16 lead acid batteries. Likely to be stored To be determined. The waste store will be an the SBOs only) For this application it has internally on pallets prior Measures such as sloping area of competent hard to transfer off site. floors, bunded pallets and standing. been assumed that each isolated drainage will be SBO will have 4 lead acid considered. batteries, which will be replaced on an annual basis.
Lubricants 4 (based on 450 litres/year Waste lubricating oil will All oil tanks will employ Any oil will be stored on per EDG and be stored in a bunded tank secondary containment an area of competent hard 108 litres/year per SBO). prior to transfer off site. whether through bunding standing. or building design.
Coolants N/A Coolant is only stored in Consideration will be given Connection/fill points will the cooling system. There in the design of the be given specific are no plans to store spent drainage system to areas consideration to hold any cooling fluid as they are where the loss of coolant losses prior to pumping closed loop systems. can enter drains. out for off-site disposal.
Oil contaminated N/A Oily wastes will be stored The storage containers will Any oily wastes will be wastes in sound containers prior be indoors. Any loss of stored on an area of to off- site disposal. containment is unlikely to competent hard standing. cause a problem as the waste will be absorbed by the cloths/pads.
The IWS will incorporate arrangements for compliance with legal requirements for the storage, management and transfer of wastes from the installation and the Operator will implement best practices waste management across the site through the IMS.
The activities undertaken at the installation are expected generate a small range of waste streams. As detailed at Table 5.4.1 above, wastes will be segregated and stored in appropriate facilities to minimise the potential for environmental impacts. The wastes will be stored within dedicated areas, which will contain appropriate pollution prevention measures. Although these are outwith the installation, the indicative BAT requirements will
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still be considered to implement best practice.
Waste arising from the operation of the standby diesel generators will be handled together with the other non- radioactive waste arising from HPC activities site-wide, and will be subject to segregation, storage, recovery or disposal, as outlined in the NNB GenCo IWS.
IndicativeBATRequirementsforWasteHandlingatHPC
Table 5.4.2 outlines the indicative BAT requirements from the sector guidance and provides commentary in relation to the proposal for the HPC installation.
Table5.4.2 IndicativeBATRequirementsforWasteHandlingatHPC
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Characterisation and quantification of each waste stream, and See above (Section 5.4.1). description of measures for waste management, storage and handling.
A system should be in place and maintained which records the NNB GenCo will implement and maintain an appropriate system for quantity, nature and origin of any waste that is disposed of or retaining and checking waste management duty of care recovered. Also, where relevant, the destination, frequency of documentation. collection, mode of transport and treatment method for those wastes.
Wastes should be segregated wherever practicable, and the disposal NNB GenCo will segregate wastes and store securely until disposed routes identified. Disposal should be as near to the point of of at an appropriately permitted waste management facility. generation as is practicable. Disposal options will be chosen through application of the proximity principle and the waste hierarchy.
Records should be maintained of any waste sent off-site (Duty of NNB GenCo will implement and maintain an appropriate system for care). retaining and checking waste management duty of care documentation.
All appropriate steps should be taken to prevent emissions from The standby diesel generators will not produce waste streams having waste storage or handling (e.g. liquid or solid spillage, dust or VOC significant emissions, such as dust or odour. emission, and odour). Spillage kits will be located in all handling areas and the waste storage area shall have containment for spills.
The remaining BAT requirements are considered to apply only to N/A coal/heavy oil fired plant and are therefore not addressed herein.
5.4.2 Waste Recovery or Disposal
This section is required to demonstrate that the operator has evaluated the opportunities to optimise the recovery of wastes from the regulated processes only and where technically and financially feasible, routes for the recovery of the waste streams generated at the site have been secured for all waste produced by the installation.
The IWS document outlines the approach to environmental optimisation with respect to waste arisings across the HPC site and the application of the waste hierarchy.
Environmental optimisation is another cornerstone of the development of the IWS. The application of BAT is the means by which environmental optimisation is achieved. Importantly, the application of BAT is a continuous and iterative process. For the ongoing application of BAT and optimisation of waste management strategies during
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the construction and operation (and ultimately decommissioning) of HPC, NNB GenCo has adopted the approach based on the statement in Environment Agency’s guidance on BAT that:
“The application of BAT is broadly equivalent to best practicable means (BPM) and best practicable environmental option (BPEO)”.
It is through the application of BAT that many of the waste management principles are primarily demonstrated as part of the environmental optimisation process. The application of BAT is based on four key environmental principles, as set out in the IPPC Directive: x The use of low-waste technology; x The efficient use of resources; x The prevention and reduction of the environmental impact of emissions; and x The use of less hazardous substances.
This broad approach is consistent for both radioactive and non-radioactive waste arisings although the means of demonstration will vary depending on the regulatory regime. Not every waste management practice can achieve all of these principles, but consideration of them against the UK EPR design during the GDA process has shown how the design for HPC has been optimised with the aim of reducing environmental impacts.
Table 5.4.3 details waste arisings and disposal methods to be employed across the HPC installation.
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Table5.4.3 WastesforRecoveryandDisposalatHPC
WasteSource WasteDescription EuropeanWaste ReleaseFrequency AnnualQuantityǦ Containment Disposal/RecoveryRoute Catalogue(EWC) CombustionPlant
Diesel generator cooling Antifreeze 14 10 01* Aqueous liquid Infrequent - during <0.5 tonnes Off-installation. To be stored To be determined (new circuits wastes destined for off-site maintenance or spillage in a dedicated facility glycol/water recycling treatment (aqueous liquids pending off-site disposal. technology now available). wasted containing dangerous This will be reviewed nearer substances) the time to see if processes exist in the UK.
Diesel generators Lubricating Oil 13 02* Waste engine gear Infrequent - during 3.1 tonnes Drummed at source and Recovered. and lubricating oils. The maintenance (possibly stored in the Oil Stores exact type (and therefore full annual) compound prior to transfer EWC code) is still to be to road tanker. determined.
Diesel generators Diesel Fuel (unused) 13 07 01* Wastes of liquid Infrequent (non-routine) - Variable Any large volumes moved Recycled. fuels (fuel oil and diesel) tank emptying activities and directly by road tanker. maintenance Small volumes stored in drums prior to transfer to road tanker.
Diesel generators (SBOs only) Starter and other used 16 06* Batteries and Very infrequent - Variable. For this application Handled by designated Recycled. batteries accumulators maintenance/routine it has been assumed that personnel and stored in replacement each SBO will have 4 lead designated pallet box in bulk acid batteries, which will be chemical store. replaced on an annual basis (16 in total).
Plant areas Oily Rags 15 02 Absorbents, filter Infrequent Low Designated lockable drums at To be determined. materials, wiping cloths and source then drums are taken protective clothing. Note: this to the Oil Stores Compound. waste may be hazardous by virtue of the proportion of oil in the waste.
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WasteSource WasteDescription EuropeanWaste ReleaseFrequency AnnualQuantityǦ Containment Disposal/RecoveryRoute Catalogue(EWC) CombustionPlant
Plant areas General Mixed Waste 20 03 01 Municipal wastes Infrequent Very low, < 1 tonnes per Designated bins to central Recycled or incinerated (household waste and similar annum skip. where possible with landfill commercial, industrial and only used where no other institutional wastes) including options available (in line with separately collected fractions waste hierarchy). (mixed municipal waste).
Note: Within the EWC, * is used to denominate hazardous wastes
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The non-radioactive solid waste management strategy is designed to comply with the requirements of the Waste Framework Directive [62] as implemented in the UK by the EP Regulations (incorporating the PPC Regulations 2000 and Waste Management Licensing Regulations 1994 (both now revoked in England)) and the Environmental Protection (Duty of Care) Regulations 1991 [63]. By ensuring compliance with these regulations in terms of minimising waste production, storing and transferring waste responsibly, the requirements of the Waste Framework Directive will be met. Comprehensive waste management procedures will be implemented for all waste streams through the site IMS.
IndicativeBATRequirementsforWasteRecoveryorDisposal
Table 5.4.4 details the indicative BAT requirements for waste recovery or disposal and provides a commentary on the approach to be employed on the HPC installation.
Table5.4.4 IndicativeBATRequirementsforWasteRecoveryorDisposalatHPC
IndicativeBATfromguidance HowtheInstallationActivitiesaddressIndicativeBAT
Description of the way each waste stream is recovered or disposed of
Waste should be recovered, unless it is technically or economically This guidance will be followed for all of the main waste streams impractical to do so. from the installation. Where waste streams are disposed of to landfill there are considered to be no feasible recovery or reuse options.
Where waste must be disposed of, the Operator should provide a The only waste disposed of will be minor volumes of general waste detailed assessment identifying the best environmental options for (although this is still to be determined). In order to maximise the waste disposal – unless the Regulator agreed that this is benefits from numerous smaller waste sources, the IWS will look at unnecessary. For existing disposal activities, this assessment may be wastes across the whole site rather than just the installation, this will carried out as an improvement condition to a timescale to be increase the viability of smaller streams for recovery. approved by the Regulator.
For installations burning solid and some liquid fuels, ash will often The combustion installation does not produce ash. be the major waste produced. Accordingly the Operator should consider alternative technically and economically feasible uses, for these. For example bottom ash can be used as an aggregate and PFA can be used in cement manufacture and for other construction products. Other by-product streams, such as FGD gypsum manufacture can also be used in the construction sector.
Where disposal occurs, the Operator should justify why recovery is N/A technically or economically not feasible.
The Operator shall regularly audit the waste disposal/ recovery Regular audits of waste contractors will be carried out as part of the routes to ensure that their waste is being properly handled and dealt IMS. with.
5.5 Energy Efficiency Measures
This section of the application is required to demonstrate that the Operator: x Understands the energy required for the operation of the regulated facilities and has quantified the
associated emissions of CO2; x Has benchmarked the energy required to produce a unit of power generated by the plant; and x Has considered opportunities to reduce energy consumption at the installation.
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As a new process, the regulator will be keen to see that energy efficient measures have been incorporated into the design of the process and these should be documented in the application.
It is expected that the combustion activity on site will be permitted under the EUETS; this is consistent with the operating EDF Energy nuclear power stations in the UK.
5.5.1 Basic Energy Requirements (1)
EnergyConsumption
The volume of fuel to be used on the installation has been calculated on the basis of the fuel throughput (93 tonnes per EDG and 22.5 tonnes per SBO giving a total of 834 tonnes) and the number of operating hours (assuming 60 hours per diesel generator). In addition to the diesel fuel used on the installation, there will be a minor amount of electricity required in starting the plant, this will be provided by the reactor (i.e. parasitic load rather than imported from the National Grid).
The electrical efficiency of the generating plant is unknown however, estimated figures are provided in the GDA PPC application which indicates a design efficiency of 42.5% based on the thermal input and electrical output figures.
Table5.5.1 HPCEnergyConsumption
Energysource Delivered Generated (MWh)
Delivered(Tonnes) Delivered(MWh) Primary(MWh) %oftotal
Diesel 834 4,007 9,435 42.5 4,007
Electricity used N/A N/A N/A N/A N/A
Notes: There is no electrical information available. Diesel energy is based on calculated electrical and thermal input with each diesel generator operating for 60 hours.
EnergyProduction
All the electricity produced from loaded test runs will be exported to the grid with that generated by the reactor, this is minor and will not be measured separately. This figure can be measured but it is not proposed to do so due to the infrequent use and low levels of export. As outlined in Table 5.5.1, these exports can be calculated.
SpecificEnergyConsumption
The Specific Energy Consumption (SEC) is a performance benchmarking measure used to show the amount of electricity used to produce a specific product or unit of output. This is of limited importance for standby plant as efficiency is a secondary measure to reliability/availability and under normal operations, plant will only be operated for maintenance purposes and during periodic nuclear safety tests. It is also important to remember that based on the designed operating regime, the plant is only operating in its optimum state for a short period before being shut down.
It is therefore not possible to provide meaningful data on Specific Energy Consumption as a performance
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benchmark; a more appropriate performance benchmark would be the reliability/ availability of the plant; this figure will be an important consideration in the procurement process.
EnvironmentalEmissions
Environmental emissions from the combustion of fuel oil (fuel usage is addressed in Section 5.3) can be predicted based on projected usage. As the electricity demand of the diesel is met by the reactor, there are no
CO2 releases to consider.
Based on an annual diesel use of 834 tonnes and assuming complete oxidation during combustion (based on a 19 carbon content of 86.1% [64]); this equates to 2,633 tonnes of CO2 released as a result of maintenance of the diesel plant and operation during periodic nuclear safety tests. It is also likely that this figure will be significantly pessimistic as it is based on the worst case year of an existing plant.
Environmental emissions from the electrical demand of the diesel generators are unknown however during normal operations, the power will be provided from the nuclear power station which has a minimal carbon footprint in relation to the combustion of fossil fuels.
Detailed information can be provided once the procurement process has identified the specific diesel plant for the site.
5.5.2 Basic Energy Requirements (2)
As standby plant, each plant operates for less than 1% of the year and is operated only for maintenance purposes during periodic nuclear safety tests.
Operating,MaintenanceandHousekeepingMeasures
The energy consumption of the essential diesel generators will be minimised as they will be operated on the following basis only: x To provide emergency power to the main plant (not part of normal operations); x In accordance with the requirements of the periodic nuclear safety/manufacturers testing regime to prove reliability; x Planned maintenance; and x Qualification tests in case of modification.
The diesel generators will be serviced and maintained in accordance with the manufacturers’ specifications.
The efficiency of the combustion process will be demonstrated by emissions testing, which this does not require the plant to be operated longer than is necessary. Due to the limited operational hours of the diesel generators, it is considered that the investment in any additional energy efficiency measures would be disproportionate and not considered to be BAT.
19. Using the calculation 1180 (mass of diesel in tonnes) x 0.861 (proportion of diesel that is carbon) x 44/12 (mass increase of carbon to
CO2 based on the atomic weights of the elements).
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EnergyManagementTechniques
The diesel generators are designed to supply a specific standby or essential power need, and as such the plant are typically operational for the purposes of reliability testing only. For this reason, energy management techniques such as monitoring energy flows or targeting areas for reduction are not considered to be appropriate.
EnergyManagementPlan
The application requires the inclusion of an Energy Management Plan. This plan is required to demonstrate that the Operator has considered all relevant techniques to minimise energy consumption, and consider the associated reduction in CO2 emissions. Due to the low operational hours and standby nature of the diesel plant, it is considered inappropriate that an Energy Management Plan is included in the application or is required as a permit condition; this application outlines the justification for the plant running hours, this will be reduced wherever possible. The generators are designed and should be available for the duty they are intended for over 60 years.
IndicativeBATRequirementsforBasicEnergyRequirements(2)
Many of the indicative BAT issues identified in the IPPC guidance note H2 (Energy Efficiency) are more appropriate to activities that consume power on a near continuous or batch basis (such as chemical plant or the iron and steel industry), rather than stand-by power generation. For consistency, however, the indicative BAT tables have been included in this energy section (Table 5.5.2). The following sections consider how energy consumption is minimised.
Table5.5.2 IndicativeBATRequirementsforBasicEnergyRequirements(2)
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Measures for improvement of energy efficiency
1. Operating, maintenance and housekeeping measures should be in Following the identification of specific diesel plant at the HPC site, place in the following areas, where relevant and which have a the maintenance regime will be determined and appropriate significant impact on the efficient use of energy at the installation: procedures produced. Under normal operating circumstances, the (Indicative checklists of appropriate measures are provided in plant is only operated for maintenance; reliability is a critical feature Appendix 2 of the guidance note H2 Energy efficiency for IPPC): of the plant and the maintenance regime is designed to maximise this with the efficiency of the plant being a secondary but still air conditioning, process refrigeration and cooling systems important consideration. (leaks, seals, temperature control, evaporator/condenser maintenance); As the scope of the installation only includes the diesel generators, fuel storage tanks, generators and pipework, the majority of the operation of motors and drives; plant listed are not relevant. Those issues considered relevant will be compressed gas systems (leaks, procedures for use); addressed during the commissioning programme. condenser and cooling systems; feedwater heating systems; steam distribution and utilisation systems (turbines, leaks, traps, insulation); heat recovery systems; space heating and hot-water systems; lubrication to avoid high-friction losses; boiler operation and maintenance, e.g. optimising excess air; gas turbine/engine operation; and other maintenance relevant to the activities within the installation.
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
2. Basic low-cost physical techniques should be in place to avoid The plant procured for the HPC installation will be designed to gross inefficiencies. These should include insulation, containment exclude such gross inefficiencies. The performance and efficiency of methods, (such as seals and self-closing doors), and avoidance of the plant will be considered at the procurement stage however, unnecessary discharge of heated water or air (e.g. by fitting simple because of the operating regime, reliability will be the primary control systems such as timers and sensors). factor.
3. Energy-efficient building services should be in place to deliver the The building will have a dedicated ventilation system however; the requirements of the Building Services section of the guidance note extent of the installation excludes all other areas outside the Diesel H2 Energy efficiency for IPPC. For energy intensive industries these Buildings. issues may be of minor impact and should not distract effort from the major energy issues, but they should nonetheless find a place in the programme, particularly where they constitute more than 5 percent of the total energy consumption.
4. Energy management techniques should be in place, according to The plant is planned to be inoperative for 99% of the year. The the requirements of Section 2.3 noting, in particular, the need for main energy demands will be for building ventilation and lighting. monitoring of energy flows and targeting of areas for reductions. As these systems have not yet been designed, there is no information available and will be addressed as part of the FAP.
5. An energy efficiency plan should be provided that: It is proposed that at the procurement phase, an energy efficient well designed plant will be identified and purchased. identifies all techniques relevant to the installation, including those listed above and in Section 2.7.3, that are applicable to Following commissioning and when operational information has the installation; been produced, an assessment of the viability of any energy improvements will be carried out as part of an energy plan. estimates the CO2 savings that would be achieved by each measure over its lifetime; and, in the case where the activities are NOT covered by a EUETS or DPA; provides information on the equivalent annual costs of implementation of the technique, the costs per tonne
ofCO2 saved and the priority for implementation. A procedure is given in the Energy Efficiency Guidance Note.
5.5.3 Further Energy-Efficiency Requirements
It is proposed that the plant will be permitted under EUETS; this approach is consistent with the nuclear power station standby diesel generators currently operated by EDF Energy. The indicative BAT requirements for Further Energy Efficiency Requirements (as outlined on Section 2.7.3 of the IPPC Combustion Sector Guidance [7]) are therefore not required.
5.6 Permit Surrender/Closure
This section describes the measures that will be taken to ensure, that, on the surrender of the environmental permit, the site will be decommissioned in a sensitive manner, in order to minimise the potential for environmental impacts associated with the decommissioning, dismantling and demolition of the plant.
The nuclear power station and diesel generators will be designed and built for a 60 year operation period. Although it is not practicable to develop a precise decommissioning plan for the standby generators at this time, the plant has been designed to minimise environmental impacts associated with the decommissioning and dismantling activities.
Accordingly, arrangements for the shutting down and decommissioning of the essential diesel generators will be incorporated into the HPC Decommissioning Plan for the whole site. When developed, appropriate information will be provided to the Environment Agency as part of the FAP; this will be taken from the site-wide site closure plan.
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5.6.1 Design and Build
This section will provide details of any measures undertaken to address the potential for pollution during the decommissioning of the plant. This is also considered in the Site Condition Report (Appendix A).
The key aspects for the decommissioning of the installation are the fuel tanks and the lubricating oil circuits (and associated pipework). The diesel buildings have been designed with a bunded impermeable basement to contain any spillages and hence minimise the extent of any ground contamination which might require remediation on (or before) closure.
5.6.2 Operations During the Lifetime of the Permit
As part of the IMS, the site will develop and implement a comprehensive register of incidents that will include leaks and spills. As the diesel generators are fully contained in concrete buildings, the potential for environmental pollution during operations is limited.
5.6.3 Site Closure Plan
The site decommission plan for the HPC installation has not yet been developed. The plant on the installation will provide safety related back-up power to the main reactor plant and as such will be part of a site wide decommissioning plan.
Key stages of decommissioning the diesel plant will be: x Draining of the cooling fluid for off-site recovery/treatment; x The removal of the fuels (for off-site re-use) and cleaning of the pipework and tanks; and x The removal of the lubricating oil (for off-site recycling) and cleaning of the circuit.
All of these operations will take place in the diesel buildings which, by virtue of the sealed impermeable basement area, is designed to act as a large bund preventing any environmental impact. The diesel plant will be drained and cleaned in the diesel building prior to removal. This specific approach to be taken to these activities will be subject to on-going review and finalised/agreed with the Environment Agency prior to being implemented. The disposal route of the diesel generators, tanks and pipework will depend on the physical state of the individual plant items and the building has been designed with large doors to allow the installation and removal of large plant items (as part of commissioning and decommissioning).
As part of the FAP (and when sufficient information becomes available), a Decommissioning Plan will be produced and that portion pertaining to the installation will be provided to the Regulator. This will include (but not be limited to) consideration of the following: x Stored materials suitable for re-use/recycling will be sold and taken from the site. Any other stored substances, hazardous and non-hazardous, will be removed from site for disposal; x In accordance with normal operating procedures, water that is not contaminated or hazardous will be drained to a suitable outfall; x The plant will be made safe for dismantling by draining or venting liquids and gases from vessels and pipework and then purging pipes and vessels of gases. Closed vessels, pipes and other equipment, which could contain hazardous gases, will be tested to ensure that they are safe before entry is permitted or they are dismantled;
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x The plant will be permanently disconnected from sources of energy or danger, such as electricity, fuel, and water supplies; x Once plant is completely disconnected, drained, purged and tested, as appropriate, it will be certified as being out of commission and safe for handing over to a competent contractor for dismantling and demolition; x The plant will be made safe for dismantling and demolition work, in accordance with the normal safety procedures such as the issue of health and safety permits for work; and x A competent contractor (or contractors) will be appointed to undertake dismantling, disposal and demolition. Lead contractors will be nominated who will produce safety plans and method statements for the work (for approval by NNB GenCo).
Given the timescales involved with decommissioning, this approach may change. Changes will be communicated to the regulator as required by the environmental permit.
IndicativeBATRequirementsforClosure
The indicative BAT requirements for site closure and the nature of information which will need to be included in the application are given in Table 5.6.1.
Table5.6.1 IndicativeBATRequirementsforClosureofHPC
IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
Operations during the Lifetime of the Permit
Operations during the life of the permit should not lead to any The condition of the proposed installation site will be described in deterioration of the site if the requirements of the other sections of the Site Condition Report. Given the pollution prevention measures this and the specific-sector notes are adhered to. proposed for the installation and the effective arrangements for environmental management, training and awareness, it is Should any instances arise which have, or might have, impacted on considered there is little likelihood of pollution associated with the the state of the site, the Operator should record them along with any further investigation or ameliorating work carried out. This will regulated activities. ensure that there is a coherent record of the state of the site In the event changes are proposed to the regulated activities, the throughout the period of the IPPC permit. This is as important for potential for pollution associated with these activities will be the protection of the Operator as it is for the protection of the assessed. environment. Any changes to this record should be submitted to the Regulator.
Steps to be taken at the design-and-build stage of the activities
Care should be taken at the design stage to minimise risks during The consideration of environmental issues at the design stage has decommissioning. For existing installations, where potential lead to a process that has engineered out the main potential risks problems are identified, a programme of improvements should be that are seen on sites of this nature across the UK. By housing the put in place to a timescale agreed with the Regulator. Designs storage tanks and generators in an impermeable building, this also should ensure that: ensures that the commissioning activities will be carried out in the confines of a bunded area. underground tanks and pipework are avoided where possible (unless protected by secondary containment or a suitable This will be formalised through production of a commissioning monitoring programme); plan. There is provision for the draining and clean-out of vessels and pipework prior to dismantling; Lagoons and landfills are designed with a view to their eventual clean-up or surrender; Insulation is provided that is readily dismantled without dust or hazard; and Materials used are recyclable (having regard for operational or
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IndicativeBATfromGuidance HowtheInstallationActivitiesAddressIndicativeBAT
other environmental objectives).
The site-closure plan
A site closure plan should be maintained to demonstrate that, in its The Decommissioning Plan will provide information to inform the current state, the installation can be decommissioned to avoid any development of the Site Closure Plan. This will be provided pollution risk and return the site of operation to a satisfactory state. through the FAP. The plan should be kept updated as material changes occur. Common sense should be used in the level of detail, since the circumstances at closure will affect the final plans. However, even at an early stage, the closure plan should include: either the removal or the flushing out of pipelines and vessels where appropriate and their complete emptying of any potentially harmful contents; plans of all underground pipes and vessels; the method and resource necessary for the clearing of lagoons; the method of ensuring that any on-site landfills can meet the equivalent of surrender conditions; the removal of asbestos or other potentially harmful materials unless agreed that it is reasonable to leave such liabilities to future owners; and methods of dismantling buildings and other structures, see Closure references which gives guidance on the protection of surface and groundwater at construction and demolition-sites testing of the soil to ascertain the degree of any pollution caused by the activities and the need for any remediation to return the site to a satisfactory state as defined by the initial site report.
For existing activities, the Operator should complete any detailed This is not an existing site. A decommissioning plan will be studies, and submit the site closure plan as an improvement provided as part of the FAP. condition to a timescale to be agreed with the Regulator but in any case within the timescale given in Section 1.1. Note that radioactive sources are not covered by this legislation, but decommissioning plans should be coordinated with responsibilities under Schedule 23 of the Environmental Permitting (England and Wales) Regulations 2010 (Radioactive Substances Regulation).
5.7 Installation Issues
The EDGs and SBOs are plant dedicated to the HPC nuclear power station, the installation will be wholly owned and operated by NNB GenCo. There are no other permit holders and therefore no issues relating to the allocation of responsibility across the installation.
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6 Forward Action Plan
6.1 Introduction
NNB GenCo is planning to build and operate the proposed new nuclear power station at HPC. We are applying for a number of consents, licences and permits, including the Combustion Activity environmental permit to allow operation of combustion plant with an aggregate rated thermal input > 50 MWth.
NNB GenCo has developed this submission so that it can be considered in parallel with the application to the Infrastructure Planning Commission (IPC) for a Development Consent Order. The information presented in this submission is consistent with that required by the Environment Agency for determining the application for a Combustion Activity environmental permit and outlines operational plant, management and controls that will deliver a good standard of environmental protection.
On receipt of this application the Environment Agency, having assessed it to ensure it is complete, that it is duly made and having placed it on the public register, will invite comments as part of the consultation process. The Environment Agency may engage in additional consultation activities including consultation on the draft Combustion Activity environmental permit and the decision document. The Environment Agency’s approach is tailored to specific local circumstances.
6.2 Generic Design Assessment
In parallel to the site applications, EDF and AREVA are seeking a Statement of Design Acceptability (SODA) from the Environment Agency and a Design Acceptance Confirmation (DAC) from the ONR for the UK EPR design through the Generic Design Assessment (GDA) process. GDA involves a rigorous and structured examination of design information by the nuclear regulators over a period of several years. At the end of the assessment period the regulators will issue reports on their findings, confirming whether they judge the generic design to be satisfactory from a safety, security and environmental aspect.
This submission for HPC uses information taken from the GDA process conducted between the Requesting Party (EDF and AREVA) and UK Regulators (ONR and Environment Agency). Much of the information submitted to the regulators as part of the GDA process has been made accessible to the public via various websites.
There are recognised differences between the GDA and this document but these are due to x Site-specific aspects (including the co-location of 2 EPR units and operating hours); and x Operator-specific aspects.
6.3 Forward Action Plan
Given the current stage of development of the site, this section includes a FAP. This defines the activities necessary to achieve compliance with all of the Combustion Activity environmental permit conditions prior to commissioning of the combustion plant at HPC. The FAP provides a route map of how NNB GenCo will develop from a competent applicant to a competent Combustion Activity environmental permit holder and operator in a timely fashion. This recognises the various stages of development of the project and the evolution of the organisation through design, construction, commissioning and operation. NNB GenCo will have a number of hold points as part of its management of the process of building and commissioning HPC. These hold points include a number of actions and requirements that must be satisfied in order for NNB GenCo to proceed to the
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next phase of the project. These may be linked to certain regulatory, organisational or commercial requirements that must be completed prior to commencing to the next stage. Thus the development of the project is controlled and co-ordinated. It is recognised that the Environment Agency may decide to implement pre- operational conditions as part of their Combustion Activity environmental permit determination. These could impose requirements that would necessitate the completion of specific activities prior to operation. This ensures that the necessary checks and balances are in place prior commissioning and operation of the combustion plant.
The FAP provides a clear summary of the commitments NNB GenCo is making as part of this application. There are seven of these high level actions that cover a variety of topics that need to be delivered on different timescales: some relatively early on in the project phase, others that are required much later, including after several operational cycles. These high level actions reflect topics considered important by NNB GenCo as part of the progression towards being a competent operator.
Each action has been split into activities that need to be delivered in order to complete the commitment. Each action is also accompanied by a description and an explanation of the timing of the action. These actions are delivered through the procedure for management of commitments. This includes the capturing of an action and managing its delivery. Summarised below is a description of the high level actions.
Action1:ConfirmationofDesignDetails
Prior to commissioning of the combustion plant, NNB GenCo will provide a completed description of the plant and infrastructure, including a justification of how the final design prevents or minimises impacts on the environment. Specific information will be provided on: x Diesel buildings, including:
- Design of tanks, bunds, pipework, sumps and drainage systems;
- Equipment for handling any spilled hazardous liquids; and
- Specific details of the preventative maintenance programme to prevent loss of containment of hazardous materials. x Site drainage plan, including the specification of the oil-water interceptor system and arrangements to prevent hazardous materials contaminating the marine environment in the event of loss of containment.
Action2:ConfirmationofProposedEmissionsandMonitoringTechniques
Prior to commissioning of the combustion plant, NNB GenCo will confirm the proposed emissions to air and provide details of the proposed monitoring techniques. Specific information will be provided on: x Stack emission characteristics for the EDG crankcase fume extract vents; x Composition of point source emissions to air from the EDG crankcase fume extract vents, which are expected to be trivial; x Anticipated fugitive VOC emissions from the EDG and SBO fuel main storage tanks, which are expected to be trivial; and x Monitoring arrangements for the eight EDGs and four SBOs, including frequency.
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Action3:DevelopmentoftheIntegratedManagementSystem
Prior to commissioning an IMS will be developed to meet business needs for the whole site. This will include, but not be limited to, the arrangements to ensure that the environmental permit requirements on management system are met. A description of how the management system will be developed is provided in Section 5.1.
The main areas are summarised below: x Operation and maintenance procedures, including:
- Maintenance plans and measures for the prevention and mitigation of leaks of hazardous substances, including hydrocarbons from the diesel generator cooling systems; and
- Procedures for the avoidance, recovery and wastes as well as waste storage and handling procedures. x Competence and training; x Accidents, incidents and non-conformance; and x Organisational management.
Action4:DevelopmentoftheAccidentManagementPlan
Prior to commissioning NNB GenCo will develop a detailed accident management plan for the combustion plant. The plan will augment the information proved in Section 5.2 and will: x Provide a quantified risk assessment of hazards that take into account the engineering and procedural mitigation measures that will be in place before commissioning begins; and x Address how environmental risks will be prevented and mitigated during commissioning, and in particular will address the storage and handling of hazardous materials during commissioning tests.
Action5:DevelopmentoftheSiteClosurePlan
Prior to commissioning NNB GenCo will develop a site closure and decommissioning plan for the combustion plant. A full description of how the site closure plan will be developed is provided in Section 5.6. The site closure plan will be maintained to demonstrate that, in its current state, the installation can be decommissioned to avoid any pollution risk and return the site of operation to a satisfactory state. The plan will be kept updated as material changes occur. The early stage closure plan will include the following details: x Approach for the removal or the flushing out of pipelines and tanks and the complete emptying of any potentially harmful contents; x Plans of all underground pipes and vessels; x The removal of potentially harmful materials; and x Methods of dismantling buildings and other structures.
Action6:ValidationofEmissions
During commissioning NNB GenCo will review emissions from the combustion plant to assess whether the emission levels are as anticipated in this submission, in particular the following emissions will assessed:
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x Emissions of NOX, SO2, CO and PM from the EDGs and SBOs; and x Visibility of the plume from emissions to air.
Where the emissions are not as anticipated in this submission, then proposals will be made to improve performance and will confirm that impacts from actual emissions to air are acceptable or prompt a review of abatement requirements.
Action7:DevelopmentofEnvironmentalManagementPlans
Once the combustion plant is operational NNB GenCo will review environmental performance to identify areas where further improvements could be made. The key commitments for this include:
x Review NOX generation by the diesel generators and identify process modifications that could further
minimise emissions of NOX; and x Development of an energy management and improvement plan.
SummaryofHighLevelForwardActionPlan
Table 6.3.1, below, presents a summary of the high level FAP described above by NNB GenCo for this HPC submission. The use of a FAP, as used in other regulatory regimes, does not preclude the Environment Agency developing additional requirements and using any of the available mechanisms, such as Pre-operational conditions, within the Combustion Activity environmental permit to ensure NNB GenCo achieves the requirements necessary prior to operation. NNB GenCo, as part of the demonstration of being a competent applicant and a responsible operator feels it is important to recognise those areas that require further attention and to provide a clear path of how and when we will deliver these. The FAP, along with the appropriate procedures and processes to manage it are the means by which NNB GenCo will meet these obligations.
Table6.3.1 CombustionActivityHighlevelForwardActionPlan
Ref. Action Timing Justification
1 NNB GenCo will provide a completed description Prior to installation at The design of the diesel buildings and site drainage of the plant and infrastructure, including a site system has not yet been finalised. However justification of how the final design prevents or sufficient information has been provided for the minimises impacts on the environment. Specific Environment Agency to determine the application. information will be provided for the diesel buildings and site drainage arrangements.
2 NNB GenCo will provide final confirmation of the Prior to installation at The only emissions not fully described in this emissions to air and provide details of the site application are likely to be trivial (e.g. crankcase monitoring techniques that will be used. vents, diesel tank vents). This information will be provided once these emissions have been described in more details.
3 NNB GenCo will develop an integrated Prior to installation at The integrated management system is in the early management system to ensure that the site stages of development, but will be developed to environmental permit requirements on meet the indicative BAT requirements for management system are met. management systems. Sufficient information has been provided for the Environment Agency to determine the application.
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Ref. Action Timing Justification
4 NNB GenCo will develop a detailed accident Prior to installation at Detailed engineering and procedural controls for management plan for the combustion plant that site the combustion plant have not yet been finalised. provides a quantified risk assessment of hazards As more information becomes available it will be that take into account the engineering and used to undertake and influence the environmental procedural mitigation measures and addresses risk assessment to ensure that appropriate how environmental risks will be prevented and measures are in place to prevent and mitigate the mitigated during commissioning. consequences of accidents and incidents.
5 NNB GenCo will develop a site closure and Prior to installation at The design of the diesel building will include decommissioning plan for the combustion plant. site consideration of its eventual decommissioning. When further information is available this will be used to prepare the site closure plan.
6 NNB GenCo will review emissions from the During commissioning The assessment of impacts from emissions to air is combustion plant to assess whether the emission dependent on information provided by the levels are as anticipated in this document. manufacturers. There is the possibility that actual Where the emissions are not as anticipated in emissions may not meet these requirements. this submission, then proposals will be made to Validation of the emissions will ensure that impacts improve performance without reducing the from actual emissions to air are not unacceptable. reliability of the generators and without grossly Any options assessment on reduction of emissions disproportionate cost with regard to the yearly will include an assessment against the reliability operational time; and will confirm that impacts criteria of the diesel engines to ensure that their from actual emissions to air are acceptable or safety function is not affected in any way. prompt a review of abatement requirements.
7 NNB GenCo will review environmental During the operational The commissioning process will ensure that all performance to identify areas where further phase combustion plant operates appropriately. However, improvements could be made, including a review further improvements may also be possible as
NOX generation by the diesel engines noting that operational familiarity with the plant grows, and the highest priority remains the nuclear safety the action reflects best practice. Any options purpose of the generators and the development assessment on reduction of emissions and energy of an energy management and improvement consumption will include an assessment against the plan. reliability criteria of the diesel engines to ensure that their safety function is not compromised and that it is not grossly disproportionate with regard to cost compared to the low yearly operation time of the engines.
6.4 Conclusion
NNB GenCo believes this document contains sufficient information to enable the Environment Agency to determine whether a Combustion Activity environmental permit can be granted.
NNB GenCo believes it has demonstrated that the proposed combustion plant at HPC represents the application of BAT and that impacts on the environment are minimised as far as reasonably practicable. NNB GenCo undertakes regular reviews of technology and guidance so as to demonstrate the ongoing application of BAT.
NNB GenCo is submitting this document to the Environment Agency so it can undertake a determination of this application, including a consultation on our submission. NNB GenCo will respond to any requests for clarification and information from the regulator in a timely and efficient manner to enable it to complete its process.
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7 References and Acronyms
7.1 References
[1] The Environmental Permitting (England and Wales) Regulations 2010 (SI 2010 No. 675)
[2] Greenhouse Gas (Emissions Trading Scheme) Regulations 2005 (SI 2005 No. 925)
[3] Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (as amended)
[4] BS EN ISO 14001:2004 Environmental management systems -- Requirements with guidance for use
[5] BS 2869:2010 Fuel oils for agricultural, domestic and industrial engines and boilers
[6] The Sulphur Content of Liquid Fuels (England and Wales) Regulations 2007 (SI 2007 No. 79)
[7] Environment Agency, How to comply with your environmental permit. Additional guidance for: Combustion Activities, EPR 1.01, version 4.0, March 2009
[8] Environment Agency, SEPA, NIEHS, IPPC Sector Guidance Note Combustion Activities V2.03, 2005
[9] Council Directive 2008/1/EC concerning integrated pollution prevention and control.
[10] AREVA NP & EDF, PPC Application – Generic Information for UK EPR, UKEPR-00004-001 Issue 00, 30.06.2008
[11] Environment Agency, How to comply with your environmental permit. Getting the basics right: EPR 1.00, April 2008
[12] Integrated Pollution Prevention and Control Reference Document on Best Available Techniques for Large Combustion Plants (European Commission July 2006).
[13] Environment Agency, H1 Environmental Risk Assessment Part 1: Simple assessment of environmental risk for accidents, odour, noise and fugitive emissions, March 2008
[14] Environment Agency, H1 Environmental Risk Assessment Part 2: Assessment of point source releases and cost-benefit analysis, March 2008
[15] Environment Agency, H5 Site Condition Report - guidance for applicants, version 2.0, August 2008
[16] Institute of Electrical and Electronics Engineers , IEEE 446-1995 - IEEE Recommended Practice for Emergency and Standby Power Systems for Industrial and Commercial Applications, July 1996
[17] AREVA NP/EDF, UK EPR, Pre-Construction Safety Report, Chapter 9: Auxiliary Systems (Sub chapter 9.5, Section 2.1.1.2), UKEPR-0002-095 Issue 02, 30.06.2009
[18] The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (SI 2009 No. 2263)
[19] AREVA NP/EDF, UK EPR, Pre-Construction Safety Report, Sub-chapter 1.2 – General description of the unit, UKEPR-0002-012, Issue 01, 22.06.2009
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[20] The Control of Pollution (Oil Storage) (England) Regulations 2001 (SI 2011 No. 2954)
[21] NNB GenCo WME/HPC/TECH/10/250. Hinkley Point C Combustion Activity Permit Application - Additional Air Quality Modelling to Cover LOOP Scenario
[22] Environment Agency, Pollution Prevention Guidelines – Above-ground oil storage tanks: PPG2, February 2004
[23] Environment Agency, Pollution Prevention Guidelines – Use and design of oil separators in surface water drainage systems: PPG3, April 2006
[24] Environment Agency, Pollution Prevention Guidelines – Safe storage – drums and intermediate bulk containers: PPG26, May 2011
[25] Environment Agency, Technical Guidance Note: H4 – Odour management, v1.2 Consultation DRAFT, June 2009
[26] Environment Agency , Horizontal Guidance Note IPPC H3 (part 2) Integrated Pollution Prevention and Control (IPPC) Horizontal Guidance for Noise Part 2 – Noise Assessment and Control, Version 3, 2004
[27] The Environmental Noise (England) Regulations 2006 (SI 2006 No. 2238) (as amended)
[28] EDF Energy, Hinkley Point C, Environmental Statement, Chapter 11 (Noise and Vibration), 2011
[29] BS 4142:1997, Method for rating industrial noise affecting mixed residential and industrial areas
[30] Environment Agency, Technical Guidance Note (Monitoring) M1 Sampling requirements for stack emission monitoring, Version 6, January 2010
[31] Environment Agency, Guidance on undertaking an Operator Monitoring Assessment of emissions to air and/or water. Industrial installations regulated under the Environmental Permitting Regulations, version 3, 2009
[32] Environment Agency, Technical Guidance Note (Monitoring) M2 Monitoring of stack emissions to air, Version 7, August 2010
[33] Environment Agency, Technical Guidance Note M8, Environmental Monitoring Strategy – Ambient Air, 2000
[34] Environment Agency, Technical Guidance Note M9, Monitoring Methods for Ambient Air, 2000
[35] Environment Agency, Technical Guidance Note M13, Monitoring hydrogen sulphide and total reduced sulphur in atmospheric releases and ambient air, 2001
[36] Environment Agency, Technical Guidance Note (Monitoring) M15, Monitoring PM10 and PM2.5, version 1, October 2006
[37] Environment Agency, Technical Guidance (Monitoring) M16, Monitoring volatile organic compounds in stack gas emissions, version 3, April 2011
[38] Environment Agency, Technical Guidance Document (Monitoring) M17, Monitoring of particulate matter in ambient air around waste facilities, March 2004
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[39] Environment Agency, Technical Guidance Note (Monitoring) M20, Quality of assurance of continuous emission monitoring systems – application of BS EN 14181 and BS EN 13284-2,version 2.3, June 2010
[40] BS EN 15259:2007 Air quality. Measurement of stationary source emissions. Requirements for measurement sections and sites and for the measurement objective, plan and report
[41] BS EN 14181:2004 Stationary source emissions. Quality assurance of automated measuring systems
[42] BS ISO 9096:2003 Stationary source emissions. Manual determination of mass concentration of particulate matter
[43] BS EN 14792:2005 Stationary source emissions. Determination of mass concentration of nitrogen oxides (NOx). Reference method: Chemiluminescence
[44] Environment Agency, Technical Guidance Note (Monitoring) M22, Measuring stack emissions using FTIR instruments, version 2, March 2011
[45] BS EN 14791:2005 Stationary source emissions. Determination of mass concentration of sulphur dioxide. Reference method
[46] Environment Agency, Technical Guidance Note (Monitoring) M21, Stationary source emissions – A procedure to use an Alternative Method for measuring emissions of sulphur dioxide, using instrumental techniques, version 1.1, January 2010
[47] BS EN 13284-1:2002 Stationary source emissions. Determination of low range mass concentration of dust. Manual gravimetric method
[48] BS EN 15058:2006 Stationary source emissions. Determination of the mass concentration of carbon monoxide (CO). Reference method: non-dispersive infrared spectrometry
[49] BS EN 13649:2002 Stationary source emissions. Determination of the mass concentration of individual gaseous organic compounds. Activated carbon and solvent desorption method
[50] US Environmental Protection Agency, Method 18 – Measurement of Gaseous Organic Compound Emissions by Gas Chromatography
[51] Countryside and Rights of Way Act 2000 (2000 c. 37)
[52] Conservation of Habitats and Species Regulations 2010 (SI 2010 No. 490)
[53] Directive 2009/147/EC on the Conservation of Wild Birds
[54] Environment Agency Core Environmental Permitting Guidance Version 2 November 2009.
[55] Environment Agency, Horizontal Guidance Note H6 – Environmental Management Systems, 2010
[56] BS 8555:2003 Environmental management systems. Guide to the phased implementation of an environmental management system including the use of environmental performance evaluation
[57] BS EN ISO 9001:2008 Quality management systems. Requirements
[58] OHSAS 18001:2007 OHSAS18001 Occupational health and safety management systems. Requirements
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[59] AREVA NP/EDF, UK EPR, Pre-Construction Environmental Report, Chapter 3: Aspects having a bearing on the environment during operation phase, UKEPR-0003-030, Issue 01, 2008
[60] EDF Energy, Hinkley Point C, Environmental Statement, 2011
[61] The Control of Substances Hazardous to Health Regulations 2002 (SI 2002 No. 2677)
[62] Directive 2008/98/EC on waste and repealing certain Directives
[63] Environmental Protection (Duty of Care) Regulations 1991 (SI 1999 No. 2839)
[64] Rose, J. W., Cooper, J. R., The British National Committee of the World Energy Conference, Technical Data on Fuel, 7th edition, 1977
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7.2 Acronyms
Acronym/Abbreviation Definition
Association Française pour les règles de conception, de construction et de surveillance en exploitation des Chaudières Electro-Nucléaires AFCEN (French society for design and construction and in-service inspection rules for nuclear islands)
Association Française de Normalisation AFNOR (French national organisation for standardisation)
AQMA Air Quality Management Area
AQO Air Quality Objective
AQS Air Quality Standard
ASTM American Society for Testing and Materials
BAT Best Available Techniques
BPEO Best Practicable Environmental Option
BPM Best Practicable Means
BREF/Bref Best Available Technique Reference Documents
BSI British Standards Institution
CCTV Closed Circuit Television
CEMs Continuous Emissions Monitoring/Continuous Emission Monitors
Comité Européen de Normalisation CEN (The European Committee for Standardisation)
CI Compression Ignition (Engine)
CO Carbon Monoxide
CO2 Carbon Dioxide
COMAH Control of Major Accident Hazards
COSHH Control of Substances Hazardous to Health
CRC Carbon Reduction Commitment
CRoW Countryside and Rights of Way Act 2000
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Acronym/Abbreviation Definition
DAC Design Acceptance Confirmation
DAP Duly Authorised Person
Defra Department for Environment, Food and Rural Affairs
DF Dispersion Factor
Division Ingenierie Nucléaire DIN (Nuclear Engineering Division)
EAL Environmental Assessment Level
EDG Essential Diesel Generator
EGR Exhaust Gas Recirculation
EIA Environmental Impact Assessment
EMAS Eco Management and Audit Scheme
EP Regulations Environmental Permitting Regulations 2010
EQS Environmental Quality Standard
ESP Electrostatic precipitator
EU European Union
EUETS European Union Emissions Trading Scheme
EWC European Waste Catalogue
FAP Forward Action Plan
FGD Flue Gas Desulphurisation
FGR Flue/exhaust Gas Recycling
GDA Generic Design Assessment
HPA Hinkley Point A
HPB Hinkley Point B
HPC Hinkley Point C
HSE Health and Safety Executive
HVAC Heating, Ventilation, And Conditioning
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Acronym/Abbreviation Definition
IBC Intermediate Bulk Container (1 m3 volume)
IEEE Institute of Electrical and Electronics Engineers
IMS Integrated Management System
IPC Infrastructure Planning Commission
IPPC Integrated Pollution Prevention and Control
ISO International Standardisation Organisation
IWS Integrated Waste Strategy
Keq Kilo Equivalent
LCPD Large Combustion Plant Directive
LNR Local Nature Reserve
LOOP Loss Of Off-site Power
MCERTS (Environment Agency’s) Monitoring Certification Scheme
MCR Maximum Combustion Rate
MERITS methodology Methodically Engineered Restructured and Improved Technical Specifications
MHDS Methods for the Determination of Hazardous Substances
MSDS Material Safety Data Sheets
MWe Megawatts electrical
MWth Megawatts thermal
N/A Not Applicable
N2O Nitrous oxide
NGR National Grid Reference
NIEHS Northern Ireland Environment and Heritage Service
NIOSH National Institute for Occupational Safety and Health
NNB GenCo NNB Generation Company Limited
NNR National Nature Reserve
NO Nitric Oxide
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Acronym/Abbreviation Definition
NO2 Nitrogen Dioxide
NOX Oxides of Nitrogen
NSL Nuclear Site License
OEF Operational Experience Feedback
OFA Over Fire Air
OMA Operator Monitoring Assessment
ONR Office for Nuclear Regulations
OSHA Occupational Safety and Health Administration
PAHs Polycyclic Aromatic Hydrocarbons
PC Process Contribution
PCER Pre-Construction Environment Report
PEC Predicted Environmental Concentration
PM Particulate Matter
PM10 Particulate Matter with a Diameter < 10 m
PM2.5 Particulate Matter with a Diameter < 2.5 m
PPC Pollution Prevention and Control
PWR Pressurised Water Reactor
QA Quality Assurance
QC Quality Control
Règles de Conception et de Construction des Matériels Electriques des RCC-E Centrales Nucléaires (Design and Conception Rules for Electrical Equipment of Nuclear Islands)
RR Release Rate
SAC/cSAC Special Area of Conservation/candidate Special Area of Conservation
SBO Station Blackout
SCOLF Regulations 2007 Sulphur Content of Liquid Fuels Regulations 2007
SCR Selective Catalytic Reduction
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Acronym/Abbreviation Definition
SEC Specific Energy Consumption
SEPA Scottish Environment Protection Agency
SI Spark Ignition (Engine)
SNCR Selective Non Catalytic Reduction
SO2 Sulphur Dioxide
SODA Statement of Design Acceptability
SPA/pSPA Special Protection Area/potential Special Protection Area
SQEP Suitably Qualified and Experienced Person
SSSI Site of Special Scientific Interest
SZB Sizewell B
TBC To Be Confirmed
TGN Technical Guidance Note
Verein Deustcher Ingenieure VDI (Association of German Engineers)
VOC Volatile Organic Compound
WHO World Health Organisation
WID Waste Incineration Directive
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Appendix A Site Condition Report
NNB-OSL-REP-000252 Combustion Activity Submission Hinkley Point C Appendix A
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NNB-OSL-REP-000252 Combustion Activity Submission Hinkley Point C Site Condition Report
NNB Generation Company Limited
UK EPR
Hinkley Point C
Combustion Activity Environmental Permit Application Site Condition Report
© 2011 Published in the United Kingdom by NNB Generation Company Ltd. All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means, including photocopying and recording, without the written permission of the copyright holder NNB Generation Company Ltd, application for which should be addressed to the publisher. Such written permission must also be obtained before any part of this publication is stored in a retrieval system of any nature. Requests for copies of this document should be referred to NNB Generation Company Limited, Qube 90 Whitfield Street, London, W1T 4EZ. The electronic copy is the current issue and printing renders this document uncontrolled. Controlled copyholders will continue to receive updates as usual.
NNB-OSL-REP-000244 Combustion Activity Submission Hinkley Point C Site Condition Report
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NNB-OSL-REP-000244 Combustion Activity Submission Hinkley Point C Site Condition Report
Purpose of this Report
This document represents the Site Condition Report (SCR) for the back-up diesel generators for the proposed Hinkley Point C (HPC) Power Station development located near Bridgwater in Somerset to be owned and operated by NNB Generation Company Limited (NNB GenCo). The diesel generators and directly associated plant and activities form the Installation. The SCR is required to be submitted to the Environment Agency as part of an application for an Environmental Permit under Regulation 13 of the Environmental Permitting (England and Wales) Regulations 2010, as amended.
The SCR is designed to be a live document which is maintained throughout the lifetime of operation of an Installation, from permit application to permit surrender. It provides a centralised source for relevant data and site records; such as ongoing environmental and/or infrastructure monitoring/testing carried out during the lifetime of the Installation with the aim of protecting the land from pollution arising due to the operation of the Installation. It should be noted that the scope of the SCR is limited to non-radiological contamination.
The report format and contents are set out in accordance with Environment Agency H5 SCR Guide for Applicants v2 (4 August 2008). In accordance with the H5 guidance, Sections 1 to 3 have been completed for the permit application stage; Sections 4 to 7 require to be maintained by NNB GenCo during the lifetime of the Installation; and Sections 8 to 10 are required to be completed as part of an application to surrender an Environmental Permit. The sections of the report are summarised below.
EnvironmentalPermitSiteConditionReport
Permit Application Stage: Section 1 Introduction and Site Details
(Current stage) Section 2 Condition of the Land at Permit Issue
Section 3 Permitted Activities
Operational Phase: Section 4 Changes to the Activity
(To follow issue of an Section 5 Measures Taken to Protect the Land Environmental Permit)
Section 6 Pollution Incidents that may have had an Impact on Land, and their Remediation
Section 7 Soil Gas and Water Quality Monitoring
Permit Surrender Application Section 8 Decommissioning and Removal of Pollution Risk Stage:
Section 9 Reference Data and Remediation
Section 10 Statement of the Site Condition
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Contents
1 Introduction and Site Details...... 1
1.1 Introduction 1 1.2 Site Details 2
2 Condition of the Land at Permit Issue...... 3
2.1 Introduction 3 2.2 Condition of the Land at Permit Issue 4
3 Permitted Activities...... 10
Table1.1 SiteDetails 2 Table2.1 ConditionoftheLandatPermitIssue 4 Table3.1 PermittedActivities 10
Appendix A Figures
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1 Introduction and Site Details
1.1 Introduction
This document represents the Site Condition Report (SCR) for the back-up diesel generators for the proposed Hinkley Point C (HPC) Power Station development located near Bridgwater in Somerset to be owned and operated by NNB Generation Company Limited (NNB GenCo). HPC will consist of two UK EPR units, referenced in this SCR as Unit 1 and Unit 2.
The Installation is not yet constructed however the information presented in this report is broadly consistent with that detailed in the Generic Design Assessment (GDA) Pollution Prevention and Control (PPC) application (UKEPR-00004-001, Issue 00, 30 June 2008), produced by AREVA and EDF, with deviations clearly stated. The only parts of the site identified as being an Installation subject to Environmental Permitting under Schedule 1 to the Environmental Permitting (England and Wales) Regulations 2010 (the Regulations) are the diesel generators, as the total thermal input of these combustion plants will exceed 50 MW. An application for a permit to operate is being made under the Regulations. The activities undertaken at the Installation constitute a prescribed process for the purposes of the Regulations, as defined in Section 1.1 of Schedule 1 to the Regulations.
The overall purpose of the SCR is to describe the condition of the land and groundwater at the site and allow the Operator to demonstrate that these environmental receptors have been protected throughout the lifetime of the Installation. At the point of permit surrender a Surrender SCR must be produced to demonstrate that the site is in a satisfactory state so that the Environment Agency can allow the permit to be surrendered. The Application SCR, which describes the condition of the land and groundwater at the site at the beginning of the permitted operations, is designed to allow a comparison to be made with the condition of the land prior to and during the permitted operations and at the point of permit surrender. It should be noted that the scope of the SCR is limited to non-radiological contamination.
The SCR is designed to be a live document which is maintained throughout the lifetime of operation of an Installation, from permit application to permit surrender. It provides a centralised source for relevant data; such as ongoing environmental monitoring and/or infrastructure monitoring/maintenance carried out during the lifetime of the Installation with the aim of protecting the land from pollution arising due to the operation of the Installation. Any remedial works required following the accidental release of potentially polluting substances to the land during the permitted operations will also be documented and referenced in the SCR. Future updates of the SCR will include information from various complementary studies.
The report format and contents are set out in accordance with Environment Agency H5 SCR Guide for Applicants v2 (4 August 2008).
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1.2 Site Details
Table1.1 SiteDetails
NNB Generation Company Limited Nameoftheapplicant
Hinkley Point C Power Station Activityaddress Near Bridgwater Somerset TA5 1UD
The site is approximately centred at National Grid Reference (NGR) Nationalgridreference ST 20300 45800
Application Site Condition Report (Ref: NNB-OSL-REP-000244) July DocumentreferenceanddatesforSiteConditionReportat 2011 permitapplicationandsurrender
Figure 1 Site Location (Ref. HPC-GEN037-XX-000-DRW-000007) Documentreferenceforsiteplans(includinglocationand Figure 2 Site Layout and Installation Boundary (Ref. HPC-GEN037- boundaries) XX-000-DRW-000003) Copies of Figure 1 and 2 are included in Appendix A of this report.
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2 Condition of the Land at Permit Issue
2.1 Introduction
This section details the sources of desk study information researched to describe the condition of the land at the Installation at the start of the permitted activities. In addition, previous site investigation reports for the Installation site area have been reviewed and are discussed in the context of the baseline site condition.
Each UK EPR is served by two buildings housing the diesel generators. Consequently there are a total of four Installation areas and these are identified as Areas 1 to 4 on Figure 2. Areas 1 and 2 serve Unit 1 (the easternmost UK EPR) and Areas 3 and 4 serve Unit 2. ‘The site’, as discussed in this report, refers to the wider HPC station site boundary.
The Environment Agency’s Environmental Permitting Regulations (EP Regulations) H1 Part 1 Environmental Risk Assessment horizontal guidance (March 2008) requires that risks to environmental and human receptors are assessed for the activities at the Installation. This is covered in the main application.
Environment Agency H5 guidance states that samples of soil or groundwater should be collected (and appropriate analysis carried out) where there is evidence that there is, or could be, existing contamination and: x The environmental risk assessment has identified that the same contaminants are a particular hazard; or x The environmental risk assessment has identified that the same contaminants are a hazard and the risk assessment has identified a possible pathway to the land or groundwater.
The guidance also states that it may not be essential to take samples of soil or groundwater where: x The environmental risk assessment identified no hazards to land or groundwater; x The environmental risk assessment identifies only limited hazards to land and groundwater and there is no reason to believe that there could be historical contamination by those substances that present the hazard; or x The environmental risk assessment identifies hazards to land and groundwater but there is evidence that there is no historical contamination by those substances that pose the hazard.
As the Installation is not yet constructed the environmental risk assessment is based upon the available design information and the assumption that the built Installation will comply with or exceed the industry pollution prevention standards at the time of construction.
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2.2 Condition of the Land at Permit Issue
References used in Table 2.1 below are listed at the end of the table in ‘supporting information’.
Table2.1 ConditionoftheLandatPermitIssue
EnvironmentalSetting
Geological mapping provided within the Envirocheck® report (Sheet 279 Weston-Super-Mare, 1:50,000 scale) Geology indicates that superficial deposits are likely to be absent or relatively thin beneath the Installation and across the majority of the site. Alluvium (clay, silt, sand and gravel) is indicated as a linear feature following the route of Holford Stream, 100 m south of the site. Beach and Tidal Flat Deposits (clay, silt, sand and gravel) are indicated beyond the site boundary to the north. The solid geology map indicates that the site is located on or close to several geological boundaries. The Installation, and the majority of the site, is located upon the Lias Group (Langport Member, Blue Lias Formation and Charmouth Mudstone Formation) comprising interbedded mudstone and limestone. Due to faulting, in the south-eastern part of the site there is an uplifted exposure trending east-west comprising mudstones of the Mercia Mudstone Group (which may include halite-stone at depth), mudstones and limestones of the Westbury Formation and Cotham Member, and Blue Anchor Formation mudstones. It is noted in the AMEC Phase 2 Supplementary Investigation report for the Built Development Area West (BDAW) (15011/TR/00031, Rev 0, Work in Progress), that there is a linear depression along the southern side of the uplifted block. AMEC has reviewed Sheet Memoir 279 of the British Geological Survey in its Phase 2 report. This describes the geological conditions found in the offshore reef between Benhole Farm and Stolford, a cross-section which includes the majority of the northern boundary of the site (running approximately from the site western boundary to the area beyond the site to the east). The geological sequence reportedly comprises a series of limestone, mudstone and shale horizons of varying (though typically no greater than 2 m) thickness. The Memoir describes the strata as gently dipping northwards, between Benhole Farm (west of site) and the existing Hinkley Point Power Station Complex (east of site). The area of Alluvial deposits (along Holford Stream) described above is noted to occur above a fault. A northeast- trending faulted zone runs from the southeast corner of the site northeast to Bridgwater Bay, beneath the footprint of the existing Hinkley Point A and B Power Stations. Intrusive investigations have been undertaken as part of the planning application process for the Hinkley Point C Power Station and further summary of site geology obtained from these investigations can be found in the Environmental Impact Assessment (EIA) (Chapter 14 of Environmental Statement).
Summary of Ground Conditions Encountered during 2009 Site Investigation A Phase 2 Supplementary Site Investigation was carried out by AMEC (Phase 2 Supplementary Investigation for the BDAW 15011/TR/00031 (5788001759/TS5/01), Prel D, September 2010), with a subsequent investigation of the eastern area relating to Installation Area 2 (Phase 2 Contamination Assessment (Non Radiological) of the Built Development Area East (BDAE) and Southern Construction Periphery Area (SCPA), 15011/TR/00151, BPE, November 2010). The initial investigation scope included excavation of 26 No trial trenches (of which TRE13A relates to Installation Area 3) to a maximum depth of 5 m below ground level (bgl) with a single trial pit (TR2_13) from the latter investigation relating to Installation Area 2. These investigations generally confirmed the ground conditions described in published geology. The investigation included the majority of the site area and Installation and the adjacent area to the northeast. The findings of the investigation are summarised below. x Made Ground was not typically encountered on site but was encountered in one location west of the site in the vicinity of Benhole Farm, adjacent to a derelict barn. This comprised construction/demolition wastes and was described as slightly gravelly cobbly sandy clay with occasional gravels of brick, glass and clay tile. Pockets of hard cemented sand within the made ground were noted to have a slight hydrocarbon odour. Roots and binding rope were also present. The made ground extended to a depth of 0.33 m; x The surface soils on site comprised topsoil supporting vegetative growth. This soil consisted of slightly sandy clay with varying gravel content and decaying plant material. The gravel recorded in the natural soils was derived from the underlying geology of the location, in general either of mudstone or limestone lithologies. The average thickness of the topsoil encountered beneath the site was 0.3 m with a maximum thickness of 0.6 m recorded in a trial trench in the north of the site. Trial trenches were terminated within the Blue Lias, which comprised either mudstone or an impenetrable (meaning no further progress possible with the excavator) limestone unit. These two rock types were found to be interbedded but typically the impenetrable limestone was encountered at shallower depths with a reduction in the thickness of weathered mudstone strata within the eastern area of the site in areas of steep sloping grazed fields. The shallow mudstone and limestone was often heavily weathered and recovered as sandy gravelly clay; and x The Mercia Mudstone formation was recorded within a trial trench offsite to the south. This was observed by AMEC to comprise deep red and dark grey interbedded clay and weathered mudstone.
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EnvironmentalSetting
Groundwater Vulnerability mapping provided within the Envirocheck® report (Sheet 42, Somerset Coast, 1:100,000 Hydrogeology scale) indicates that the site is underlain by a Minor Aquifer (variably permeable). This is associated with the Lias Group. The Environment Agency has recently changed the way it classifies groundwater bodies and the rock strata underlying the site would now be classed as a Secondary A Aquifer. The soils at the site are classified as having an intermediate leaching potential. Groundwater is likely to flow generally northwards, in hydraulic continuity with the sea. Tidal influence is possible given the site’s proximity to the Severn Estuary. Shallow groundwater flow may be influenced by the presence of streams or drains, causing local variations in the direction of flow. During the Phase 2 Supplementary Investigation by AMEC (15011/TR/00031, Rev 0, Work in Progress) groundwater seepage was observed by AMEC at 4.26 m bgl in a trench close to Area 3 of the Installation and at 3.5 and 4.4 m bgl in a trench in the far west of the site. In both instances seepage occurred within weathered mudstone units which overlaid a harder unit (mudstone by Area 3 and limestone in the west of site). A Preliminary Conceptual Groundwater Model has been produced for the site and this describes the following features: x In the wider area groundwater in the fractures of the Lias Group is reported to be fed by rainfall recharge and to flow approximately south to north, either directly or following baseflow discharge to surface water. The Penarth Group/Mercia Mudstone forms a lower boundary to the system; x At the site the general natural flow regime is reported to be intercepted by an upfaulted inlier of Mercia Mudstone on the southern margin of the site which may effectively ‘dam’ the groundwater flow sufficiently for water tables to rise and groundwater flow to be diverted into the surface water system as baseflow, particularly towards the Holford Stream located within 100 m south of the site; and x It is considered by AMEC that the site is likely to be largely self-contained as a groundwater system, bounded by the Mercia Mudstone/Penarth Groups beneath, the faulted inlier to the south, and the Bristol Channel to the north. Cross-section figures contained within the AMEC report indicate a shallow water table in the Lias Group with local variations in the direction of groundwater flow, with groundwater following the gently undulating site topography and providing baseflow to streams or drains. The site is not within a Groundwater Source Protection Zone. The Envirocheck® report lists one groundwater abstraction within 2 km of the site. This is located over 1.5 km southwest of the site at a single well in Stogursey used for abstracting water for general farming and domestic use. This abstraction point is likely to be up hydraulic gradient of the site. Further information on hydrogeology obtained from investigations completed in support of the planning application for the Hinkley Point C Power Station is presented in the Environmental Impact Assessment (Chapter 14 of Environmental Statement).
The Envirocheck® report indicates that an unnamed stream is present on site; entering the site from the west and SurfaceWaters flowing east then north between the two Installation buildings (Areas 1 and 2) of UK EPR Unit 1 towards the coast at Bridgwater Bay (Severn Estuary). Land drainage ditches are also present in the vicinity of the site. The Phase 1 Desk Study report (15011/TR/00022 (5788001693/TS5/01), Prel E, March 2010) by AMEC included a site reconnaissance and the report describes the stream running between the Unit 1 buildings as an ephemeral agricultural drainage ditch, arising in a field in the southwest of the site and running within a linear depression through the site central area to the tidal foreshore deposits (Severn Estuary) at the site’s northern boundary. A land drainage ditch runs parallel to a track southwest of the site and crosses through the south-eastern corner of the site. A further drain is located adjacent to the southernmost area of the site. These two water features are described in the AMEC report as ephemeral agricultural drainage ditches which appeared to have no flow. It is also noted by AMEC that the ditches may be seasonally dry. According to AMEC’s Summary of Terrestrial Surface Water Quality report (15011/TN/00079, BPE, December 2009) Holford Stream is located within 100 m south of the site and OS mapping indicates that this flows in an easterly direction towards the coast. A stream known as Bum Brook is located 840 m south of the site flowing east. This is fed by a tributary known as Bayley’s Brook at a point 860 m south of the site. A second tributary known as Stogursey Brook is located further east and feeds Bum Brook at a point 755 m south of the site. The bifurcation of Bum Brook, to form West Brook and East Brook, is located 1.26 km southeast of the site and these watercourses flow northeast to feed the Severn Estuary. The Environment Agency does not currently monitor any of the watercourses on site. According to the Environment Agency web site the nearest monitoring point is located approximately 2 km east of the site and is for Stogursey Brook at the Stringston/Dodington Tributary and Confluence with the sea. The water quality was last assessed in 2008 and scored ‘C’ (fairly good) for Chemistry, ‘A’ (very good) for biology, ‘5’ (high) for nitrates and ‘5’ (very high) for phosphates. Local surface water quality data has been collected in the documents identified below and they will be used to update the next version of the SCR: x EDF Energy, Hinkley Point C, Environmental Statement, Chapter 15 Surface Water, 2011; x AMEC, Surface Water Quality Environmental Impact Assessment Technical Note, 15011/TR/00139, Prel E, March 2011; and x AMEC, Summary of Groundwater Quality (Campaigns 1, 2, 3 and 4) Non-Radiochemical Analysis Results for
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EnvironmentalSetting
the Built Development Area East and Southern Construction Phase Area, 15011/TN/000158, Prel D, February 2011. The Environment Agency Flood Map indicates that the site is not within an area identified as being affected by flooding. The area immediately north of the site along the coast is shown to be at risk from flooding (Zone 3) from the sea. The area south southeast of the site is also shown to be at risk from a flood event (Zone 3) with an additional area shown to be at risk from an extreme flood event (Zone 2) south of the site. The flood zone follows the route of Bum Brook and then covers several streams and drains south and east of the existing Hinkley Power Station. Further information on flood risk is also provided in the AMEC Surface Water Quality EIA Technical Note (15011/TR/00139, Prel E, March 2011), which will be used to update the next version of the SCR. As the Installation is not yet constructed and detailed design not yet confirmed, there is the potential that some or all of the watercourses on site will be diverted and/or converted to flow as culverts.
The site is bound to the north by Bridgwater Bay, at an embankment descending to a shingle beach along the Bristol SensitiveLand Channel. The Envirocheck® report indicates that Bridgwater Bay immediately north of the site has several statutory Uses nature designations. Bridgwater Bay has been designated by Natural England as a National Nature Reserve (NNR) and a Site of Special Scientific Interest (SSSI). The Severn Estuary has been designated a Ramsar Site, Special Area of (SAC) Conservation and Special Protection Area (SPA). Bridgwater Bay is designated for the succession of habitats it comprises; ranging from extensive intertidal mudflats, saltmarsh, shingle beach to grazing marsh, intersected by a network of freshwater and brackish ditches. The area supports internationally and nationally important numbers of over-wintering and passage migrant waders and waterfowl. The ditches and ponds contain a diverse invertebrate fauna including six nationally rare species and eighteen nationally scarce species. The site is an integral part of the Severn Estuary system and is ecologically linked to the Somerset Levels which provide alternative winter feeding grounds for waders and wildfowl.
PollutionHistory
No pollution incidents are known by NNB GenCo to have taken place on site. Pollutionincidents There are no Contaminated Land Register Entries or Notices on site or within 2 km of the site. thatmayhave The Envirocheck® report records no pollution incidents to controlled waters within a 1 km radius of the site. affectedtheland The Envirocheck® report records one Prosecution Relating to Authorised Processes Pollution Incident located 487 m east of the Installation at the Hinkley Point A Power Station. This occurred on 11 October 1995 and is described as a release of radioactive gases. No impact to land was recorded.
Site History HistoricallandǦ A review of historical maps provided in the Envirocheck® report was carried out and is summarised below. usesand The 1886 map shows the site is greenfield. Tree-lined field boundaries are apparent and some wooded areas are associated present, including Branland Copse in the east of the site. Benhole Farm is located offsite at the site’s western contaminants boundary. The site remains largely unchanged until 1976 mapping when a Sewage Works appears, located centrally on site (north of Installation Area 1 but not within it), comprising two large circular tanks (filter beds), a small rectangular tank and four to six rectangular settling tanks . The 1976 map also shows an Accommodation Camp in the east of the site (southeast of Installation Area 2 but not within it) including numerous long rectangular buildings or cabins, access roads, a canteen and hall, and four electrical substations. This may have been associated with a construction project at the neighbouring Hinkley Power Station complex. The 1980/1983 map is the first map to show the Hinkley Point A and B Power Stations developed to the east of the site. A square building is shown in the east of the site and may be part of the adjacent power station complex. The Accommodation Camp in the east of the site is no longer shown. A covered reservoir is indicated offsite to the east of the site boundary. The 1980/1983 mapping no longer shows Benhole Farm, indicating that it may have been demolished. An access road or path is shown running north to south past the Sewage Works on site and then east towards the Hinkley Power Stations. By 1995 mapping the Sewage Works is labelled as disused. Two small square buildings or structures appear to the south of the square building in the east of the site. The 2006 mapping no longer shows the Sewage Works, indicating that it may have been demolished. The square building in the east of the site may have been demolished and two more small buildings are now present south of it, in the east of the site. No further significant changes to the site are noted. With the exception of the Hinkley Power Stations to the east of the site the surrounding land use has remained predominantly agricultural. Potential On Site Sources No potential sources of contamination have been identified within the Installation boundaries. An on-site area approximately 60 m north of Installation Area 1 was historically a Sewage Works, including sludge filter beds and settling tanks, between 1976 and 1995. The spreading of solids derived from the treated sewage onto fields on site is possible and this may have taken place within the Installation boundary, however, this is
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PollutionHistory
unconfirmed. Contaminants associated with sludge beds include metals, organic pollutants (e.g. solvents, pesticides, fuel oils, polychlorinated biphenyls (PCBs) – depending on the industries that were serviced by the sewage works) and pathogens. The generation of methane, carbon dioxide and to a lesser extent hydrogen sulphide is possible. The likelihood of such contamination being present within the Installation area is considered to be low, but will be considered in future updates of the SCR. The area of the site used historically as an Accommodation Camp, located approximately 25 m east of Installation Area 2, is a potential source of contamination by transformer oils (hydrocarbons and PCBs). Hydrocarbon fuels (diesel or petrol) used in site vehicles and generators associated with the Camp are also a potential source of contamination; other possible contaminants include solvents and waste oils. Any contamination from the former camp is likely to be localised and it is considered unlikely that this could migrate onto the Installation area. The northern half of the former Accommodation Camp has since been developed as a car park, and the southern half (in the southeast of the site between the strip of woodland remaining at Branland Copse and the site boundary) is agricultural land. The Envirocheck® report identifies a Licensed Waste Management Facility (household, commercial and industrial waste transfer station) operated by Magnox Electric Ltd on site. This is associated with Hinkley Point A Power Station and is located approximately 250 m north northwest of Installation Area 1. The licence was issued on 12 May 2006. This facility may be a potential historic or ongoing source of contamination, although given its distance from the Installation and the local topography and anticipated groundwater flow direction impact on the Installation is considered unlikely. It is understood that Magnox are in the process of surrendering the licence for this facility and that post-closure assessments have been carried out to date and have not identified contamination. Potential Off Site Sources The existing Hinkley Point A and B Power Stations to the east of the site are a potential source of contamination. Contaminants associated with power stations include fuel oils, lubricating oils, metals, water treatment chemicals, asbestos, solvents and PCBs. Other contaminants (including radiological) may be present off-site. There are known off-site sources of hydrocarbon contamination associated with the adjacent HPA site. The Envirocheck® report identifies various waste facilities including landfills on the neighbouring Hinkley Power Station land, the nearest landfill being 500 m east of site and 800 m east of Installation Area 2. The landfills in this area are described as containing industrial, household, inert and/or special wastes and some may still be active. On site migration from the identified offsite potential sources is considered unlikely given the local ground conditions, which will limit the potential for migration in soils or groundwater. Offsite migration of hydrocarbons from the adjacent HPA site could migrate towards HPC during construction dewatering.
The Installation areas are currently greenfield with no known historic contamination. Further comment on the Visual/olfactory ground contamination status of the site of the Hinkley Point C Power Station is provided in the Environmental evidenceof Impact Assessment (Chapter 14 of Environmental Statement). existing No visual or olfactory evidence of contamination was noted on site during the Phase 1 Desk Study and Preliminary contamination Non Radiological Site Investigation (15011/TR/00022 (5788001693/TS5/01), Prel E, March 2010), the Phase 2 Supplementary Investigation (15011/TR/00031, Rev 0, Work in Progress) or the Phase 2 Contamination Assessment (Non Radiological) of the BDAE and SCPA (15011/TR/00151, BPE, November 2010) by AMEC. A double humped mound feature is located immediately north of the Installation Area 2. This feature originates from demolition and construction materials. This feature is considered likely to be hydraulically down gradient from this part of the installation.
The Installation is not yet constructed and detailed design is still to be confirmed. The outline design of pollution Evidenceof prevention measures for the Installation is discussed in Section 3 under Permitted Activities and in the main damageto Environmental Permit application. pollution prevention measures
The majority of the site has been subject to previous intrusive site investigation and no contamination requiring Evidenceofhistoric remediation has been identified to date. Contamination relating to construction and demolition materials was contamination identified in the double humped mound feature, but this is considered to be hydraulically down gradient to the (e.g.historicalsite Installation Area 2 and therefore unlikely to impact the baseline conditions of the Installation areas. investigation, The Phase 2 Supplementary Investigation (15011/TR/00031, Rev 0, Work in Progress) by AMEC includes assessment, recommendations that a surface water, groundwater and ground gas monitoring programme is undertaken and that any Made Ground encountered across the site during construction works should be segregated and stockpiled remediationand separately from natural soils, inspected and where necessary subjected to analytical testing to confirm their verificationreports contamination status and suitability for re-use. ifavailable) Baseline concentrations for the Installation is referenced in the supporting documents, Phase 2 Supplementary Investigation (15011/TR/00031, Rev 0, Work in Progress) and the Phase 2 Contamination Assessment (Non Radiological) of the BDAE and SCPA (15011/TR/00151, BPE, November 2010).
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PollutionHistory
The following intrusive locations provide baseline soil analytical data for each Installation Area: Installation Area 1 (Unit 1) – No locations within 50 m; Installation Area 2 (Unit 1) – TR2_13; Installation Area 3 (Unit 2) – TRE13A; and Installation Area 4 (Unit 2) – No locations within 50 m Surface water, groundwater, and ground gas monitoring has now been completed (see documents identified below), and this information will be used to update the next version of the SCR: x AMEC, Phase 2 Contamination Assessment (Non Radiological) of the Built Development Area East and Southern Construction Phase Area, 15011/TR/00151 (5788001945/TS5/), Prel E, December 2010; x AMEC, Surface Water Quality Environmental Impact Assessment Technical Note, 15011/TR/00139, Prel E, March 2011; x AMEC, Summary of Groundwater Quality (Campaigns 1, 2, 3 and 4) Non-Radiochemical Analysis Results For the Built Development Area East and Southern Construction Phase Area, 15011/TN/00158, Prel D, February 2011; and x AMEC, Final Ground Gas Risk Assessment for Built Development Area East and Southern Construction Phase Area, 15011/TR/00166, Prel A, October 2010. It should be noted that LNAPL was found in trial pits TE416 series° near to borehole CBH2_54 on the Built Development Area East (15011/TR/00151 (5788001945/TS5/), Prel E, December 2010).
Baseline ground condition data (including soil and groundwater analysis results) for the site of the Hinkley Point C Baselinesoiland Power Station is presented in the Environmental Impact Assessment (Chapter 14 of Environmental Statement). In groundwater areas of the Installation where no baseline data has been collected to date, and where NNB GenCo considers that referencedata baseline data is required, further investigation will be undertaken as required, closer to the start of the permitted operations. Evidence of how this approach is being applied has been provided in ‘evidence of historic contamination’ above. The results from the assessments identified will be incorporated into future versions of the SCR. Soil sampling and chemical analysis has been undertaken at the site during three recent site investigations by AMEC; the Preliminary Non Radiological Site Investigation (15011/TR/00022 (5788001693/TS5/01), Prel E, March 2010), Phase 2 Supplementary Investigation (15011/TR/00031, Rev 0, Work in Progress) and the Phase 2 Contamination Assessment (Non Radiological) of the BDAE and SCPA (15011/TR/00151, BPE, November 2010). These investigations are discussed above under ‘Geology’ and ‘Hydrogeology’. The suite of chemical analysis for soils included metals, pH, polycyclic aromatic hydrocarbons (PAHs), volatile organic compounds (VOCs) and speciated total petroleum hydrocarbons (TPH). The baseline soil conditions for Installation Area 2 and 3 are provided with reference to intrusive locations TRE13A and TR2_13, respectively. Groundwater quality monitoring has been carried out at the site by AMEC, with the latest Summary of Groundwater Quality (Campaign 5) Non-Radiochemical Analysis Results (15011/TN/00060, Prel B) reported in October 2009 and Groundwater Preliminary Environmental Impact Assessment reported in February 2011 (see Supporting Information below). Eleven existing piezometers were monitored for a range of chemical parameters including metals, major ions, pH, cyanide, PAHs, polychlorinated biphenyls (PCBs), TPH and VOCs. The report includes recommendations for further monitoring and for adjustments to the suite of chemical analysis based on the monitoring results. These groundwater monitoring locations were not within the immediate vicinity of the proposed Installation Areas. The need for ongoing groundwater monitoring during the operation of the Installation will be reviewed by NNB GenCo once the final detailed design of the Installation is known. The suite of chemical analysis during future monitoring to assess groundwater conditions during the permitted operations would need to be tailored to assess the presence and concentration of substances used and handled at the Installation (principally fuel oil, lubricant oil and waste oil). In general, given that the Installation will be constructed to be compliant with current pollution prevention standards the risk of releases to ground occurring is expected to be negligible. The design and management of the facility should be such that it will be possible for NNB GenCo to demonstrate that no releases to ground have occurred as a result of operations at the Installation through infrastructure monitoring and inspections. However, if buried or semi-submerged infrastructure is present which has the potential to contain fuels and oils then ongoing environmental monitoring will be considered by NNB GenCo during the lifespan of the Environmental Permit. It is noted that existing groundwater monitoring Installations may be removed or become damaged during construction work for the new UK EPRs and that new monitoring installations may be needed as a consequence. The location of any future groundwater monitoring installations will also need to be reviewed based on the final detailed design of the installation.
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PollutionHistory
The information provided in this section of the SCR is based on the following documents: Supporting x Envirocheck® report (18 November 2009, Order Number 29401017_1_1); information: x AMEC, Phase 2 Supplementary Investigation for the Built Development Area West, 15011/TR/00031, Rev 0, Work in Progress; x EDF Energy, Hinkley Point C, Environmental Statement, Chapter 14, 2011; x AMEC, Phase 1 Desk Study and Preliminary Non Radiological Site Investigation for the Built Development Area West, 15011/TR/00022 (5788001693/TS5/01), Prel E, March 2010; x AMEC, Summary of Terrestrial Surface Water Quality Non-Radiochemical Analysis Results (Campaigns 1 – 6), 15011/TN/00079, BPE, December 2009; x AMEC, Phase 2 Contamination Assessment (Non Radiological) of the Built Development Area East and Southern Construction Area, 15011/TR/00151, BPE, November 2010; x AMEC, Summary of Groundwater Quality (Campaign 5) Non-Radiochemical Analysis Results for EDF Controlled Land, 15011/TN/00060, Prel B, October 2009; x Department of the Environment (DOE) Industry Profile for Sewage Works and Sewage Farms, 1995; x Department of the Environment (DOE) Industry Profile for Power Stations (excluding nuclear power stations), 1995; x AMEC, Final Ground Gas Risk Assessment for the Built Development Area West, 15011/TR/00123, BPE, September 2010;
References anticipated to be used in next revision of this report: x AMEC, Phase 2 Supplementary Investigation for the Built Development Area West, 15011/TR/00031 (5788001759/TS5/01), Prel D, September 2010; x EDF Energy, Hinkley Point C, Environmental Statement, Chapter 15 Surface Water, 2011; x AMEC, Surface Water Quality Environmental Impact Assessment Technical Note ,15011/TR/00139, Prel E, March 2011; x AMEC, Summary of Groundwater Quality (Campaigns 1, 2, 3 and 4) Non-Radiochemical Analysis Results For the Built Development Area East and Southern Construction Phase Area, 15011/TN/000158, Prel D, February 2011; x AMEC, Summary of Groundwater Quality (Campaigns 1, 2, 3 and 4) Radiochemical Analysis Results for the Built Development Area East and Southern Construction Phase Area, 15011/TR/00161, Prel D, February 2011; x AMEC, Phase 2 Contamination Assessment (Non Radiological) of the Built Development Area East and Southern Construction Phase Area, 15011/TR/00151 (5788001945/TS5/), Prel E, December 2010; x AMEC, Final Ground Gas Risk Assessment for Built Development Area East and Southern Construction Phase Area, 15011/TR/00166, Prel A, October 2010.
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3 Permitted Activities
Table3.1 PermittedActivities
Permitted Introduction activities The two UK EPRs will be constructed to the same design specifications. The UK EPRs are referenced as Unit 1 and Unit 2, with Unit 1 located in the east of the site and Unit 2 in the west of the site. Each UK EPR is served by 4 No Essential Diesel Generators (EDGs) and 2 No Station Blackout diesel generators (SBOs) located within two purpose- built buildings. A total of four discrete buildings, each containing two EDGs and one SBO, form the Installation and these are shown on Figure 2 as Areas 1 to 4. The Installation boundary is currently limited to the extent of these four buildings however this may be subject to amendment as the detailed design progresses, and in consultation with the Environment Agency. The eight EDGs are identical diesel generators which can provide sufficient generating capacity to restore power supply to the UK EPRs in the event of loss of off-site power. The four SBOs are identical and can provide sufficient power, in the event of a total loss of external electrical sources and of EDGs to supply all required equipment at a suitable voltage. As noted above there are four diesel generator buildings within the Installation and each contains the following plant: x Two EDGs each with one bulk fuel storage tank of 180 m3 capacity, one day tank of 4 m3 capacity, and associated ancillary equipment including delivery pipes and fuel pumps; and x One SBO with one bulk fuel tank of 25 m3 capacity, one day tank of 3 m3 capacity, and associated ancillary equipment including delivery pipes and fuel pumps. This gives a total fuel oil holding capacity of 792 m3 for each UK EPR and a total of 1,584 m3 for the Installation. As noted above all of the fuel tanks will be located inside the same buildings as the generators. The detailed design of the tanks and their layout inside the buildings is not yet known. It is likely that each building will be constructed to form a bund and this may include some form of internal drainage e.g. to a collection sump which can be pumped out. Drainage within the diesel buildings will be connected to the oily water system discussed in the separate permit application for a water discharge activity and there will be no direct connection to the site’s surface water drainage system. Lubricating oil will be contained within the diesel generators; 335 litres per SBO and 1.8 m3 per EDG. No other storage of lubricating oil will take place within the Installation other than during maintenance activities when used oil will be drained from the diesel generators and fresh oil added as required. The storage of these materials will take place outside the Installation boundary in a suitable oil storage area. The EDGs and SBOs will be cooled by demineralised water, containing anti-freeze (typically a 50/50 mixture of monoethyleneglycol and water), in re-circulating systems. Storage of antifreeze will take place outside the Installation boundary in a suitable chemical storage area. Cooling mixture drained from the cooling circuits during maintenance will be collected in a suitable container and disposed of as hazardous waste. The drainage system will allow the capture and testing of any potentially contaminated run-off from the process. This could include traces of anti-freeze solution or fuel or oil from the generators or storage tanks. The bunds and/or any associated sumps will be routinely checked for antifreeze, oil and fuel, and if acceptable the contents will be transferred to the surface water system for discharge (it is likely that the wider Hinkley Point C Power Station surface water drainage will ultimately be by controlled discharge to the Severn Estuary). If antifreeze or quantities of oil are found in bunds or sumps then these will be removed by pumping out to a suitable container and disposed of as hazardous waste.
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Permitted A summary of the measures to be employed at the site to prevent pollution is provided below by Installation activities activity. (continued) Bulk Fuel Storage and Secondary Containment The detailed design of the fuel storage facilities is not yet known, however, it is likely that all tanks will be located in buildings. The pollution prevention measures for fuels and oils stored and handled at the Installation will be of a standard which complies with or exceeds the relevant standards applicable at the time of construction. The Control of Pollution (Oil Storage) (England) Regulations 2001 (the Oil Storage Regulations) currently set out the measures operators storing more than 200 litres of oil must take to prevent oil leaks and spills to the environment. These regulations apply to external tanks, however, tanks within a building are not currently covered by the regulations. Current best practice for above ground oil storage in bulk tanks is published by the Environment Agency as Pollution Prevention Guidelines (PPG) 2 (February 2004). In accordance with these guidelines NNB GenCo will make provision for the following in the design and construction of the Installation: x That safe access to the tanks is possible for maintenance; x Areas where oil storage is undertaken are surfaced with material which is impermeable to the substances stored and isolated from surface water drainage systems; x Tanks are of sufficient strength and structural integrity so that they are unlikely to leak during normal operations, are positioned on appropriately designed and constructed supports, and if possible have a design life of twenty years; x Tanks are type tested to a recognised standard under a quality assurance system complying with BS EN ISO 9001:2000*, and steel tanks comply with BS 799-5:1987*; x Installation of tanks is carried out by technicians registered with a professional scheme such as that operated by Oil Firing Technical Association (OFTEC); x Tanks and their ancillary equipment (such as sight gauges, valves and vent pipes) are situated within an oil tight secondary containment system such as a bund; x Shut-off valves will be installed at extended fill points, drip trays or other containment systems will be present at fill points, and remote fill points will be avoided where possible (if used they will comply with BS 799-5:1987*); and x Fixed pipework will be above ground where possible and where this is supplying oil to fixed appliances will comply with BS 5410*. *The primary and secondary containment measures will be compliant with these standards or future amendments/standards valid at the time of construction. Use of devices such as high level alarms to prevent overfilling will be employed in bulk tanks as this is current best practice. An automatic overfill prevention device will be required if the tank and vent pipe cannot be seen from where the filling operation is controlled. Building Regulations require that internal tanks are located within a fire resistant chamber. It is not known whether the bulk fuel tanks will be stand alone tanks or hydraulically linked, however a general rule for secondary containment is that it is adequate to contain 110% of the tank capacity or a minimum of 25% of the total capacity of several tanks within a bunded area. Secondary containment will be designed to meet or exceed this capacity. Bulk tanks at the Installation will benefit from being located within a building offering protection from weather and avoiding rainwater ingress. Fuel Pumps and Delivery Pipes Fuel pumps will either be located such that any leaks can be captured in the secondary containment serving the tanks or alternative secondary containment measures will be employed. Pumps will be fitted with a check valve in their feed line to prevent the tank contents emptying in the event of damage to the pump or feed line. Underground pipework will be avoided in the design if possible and if used will be double skinned and/or laid in accessible ducts where possible.
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Testing and Inspection The EDGs and SBOs will be test run every other month to ensure reliability. The detailed test programme will depend on the HPC safety specification, manufacturers’ recommendations and testing frequency. All tanks, pipes and pumps will be subject to regular inspections as part of the Installation’s Environmental Management System (EMS). High level alarms and other equipment will also be subject to regular testing. Underground pipework, if present, will be tested for leaks at least every five or ten years, depending on whether there are mechanical joints. Manufacturer's test instructions will be followed and other guidance, such as British Standard 5410 Parts 1 and 2, which has information about pipework pressure testing. NNB GenCo will ensure that systems are in place during site operations to generate alerts when equipment tests are due and when equipment is likely to be reaching the end of its design life. Tests and inspections will be carried out by competent persons. Fuel Delivery by Road Tanker Diesel delivery to the bulk tanks will be by road tanker via connection of the tanker’s flexible delivery hose to a fill point either within the diesel generator building or within a designated bunded area outside the building. The offloading process will be compliant with the Oil Storage Regulations with regard to collection of drips during filling, general housekeeping, location of fill points and use of automatic shut-off valves. Drainage from the tanker offloading area will be controlled to prevent any fuel spills or leakages reaching ground or surface water drainage, however, the detailed design of the site drainage is not yet known. Adequate measures will be taken by NNB GenCo to ensure that the risk of tanker collision on site is managed; with due consideration given to traffic route design, on-site signage, speed limits, barriers, driver and/or banksman training and site housekeeping.
NonǦpermitted Drummed storage of lubricating oil, waste oil, antifreeze and waste cooling mixture used or produced at the activities Installation will take place on site but outside the Installation boundary. The handling and storage of these materials will be compliant with best practice (e.g. the Environment Agency’s PPG26 for storage and handling of undertaken drums and intermediate bulk containers) to prevent spills and leaks during transport and to ensure that spills or leaks from stored containers (prior to use or disposal) are captured and dealt with quickly, in order to prevent releases to ground or to surface water drains. Quantities of oils and chemicals stored on site will be managed to ensure that the minimum volumes required for safe site operations are maintained but (where possible) not exceeded.
Document Figure 1, included in this report, shows the Site Location and Figure 2 shows the Site Layout and Installation referencesfor: Boundary. The Environmental Risk Assessment is included in the main Environmental Permit application document. Ǧ Planshowing activitylayout; and Ǧ Environmental risk assessment.
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Appendix A Figures
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Figure 1 Location of site
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Figure 2 Installation Boundary
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NNB-OSL-REP-000244 Combustion Activity Submission Hinkley Point C Appendix B
Appendix B Site Maps, Plans and Drawings
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Figure 1 Installation Boundary and Point Source Emissions to Air Combustion Activity Submission Hinkley Point C Appendix B
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Figure 2 Location of site Combustion Activity Submission Hinkley Point C Appendix B
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Figure 3 Location of site in relation to HPA and HPB Power Stations Combustion Activity Submission Hinkley Point C Appendix B
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Figure 4 International Statutory Designations Combustion Activity Submission Hinkley Point C Appendix B
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Figure 5 National Statutory Designations Combustion Activity Submission Hinkley Point C Appendix B
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Appendix C Detailed Dispersion Modelling
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NNB 022
15011/TR/00174 Issue 03 - BPE June 2011
Air Quality Modelling Report
C ONTENTS
EXECUTIVE SUMMARY ...... IV 1.0 INTRODUCTION ...... 1 1.1 Scope of the study ...... 1 2.0 METHODOLOGY ...... 2 2.1 Operational emissions to air ...... 2 2.1.1 Assessment scenarios ...... 3 2.1.2 H1 screening assessment ...... 5 2.1.3 Detailed dispersion modelling ...... 8 3.0 RESULTS ...... 18 3.1 Operational emissions to air – H1 screening assessment results...... 18 3.1.1 Commissioning scenario ...... 18 3.1.2 Routine test scenario ...... 18 3.1.3 LOOP event scenario ...... 19 3.1.4 H1 assessment summary ...... 20 3.2 Operational emissions to air – detailed dispersion modelling results ...... 20 3.2.1 Commissioning scenario - human receptor results ...... 21 3.2.2 Routine test scenario - human receptor results ...... 22 3.2.3 LOOP scenario (24 hour event) – human receptor results ...... 24 3.2.4 Commissioning scenario - ecological receptor results ...... 26 3.2.5 Routine test scenario - ecological receptor results ...... 27 3.2.6 LOOP scenario (24 hour event) – ecological receptor results ...... 28 4.0 CONCLUSIONS ...... 29 5.0 REFERENCES ...... 31
T ABLES
Table 1: Details of LOOP scenarios Table 2: Environment Agency recommended pollutant deposition velocities Table 3: Identification of worst-case meteorological year for pollutant dispersion
F IGURES
Figure 1: Buildings and stacks set up in the ADMS model for EPR units C1 and C2 Figure 2: Wind rose for Hinkley Point for 2005 Figure 3: Wind rose for Hinkley Point for 2006 Figure 4: Wind rose for Hinkley Point for 2007 Figure 5: Wind rose for Hinkley Point for 2008 Figure 6: Wind rose for Hinkley Point for 2009 Figure 7: Wind rose for Hinkley Point for 2005 to 2009 Figure 8: Locations of local human receptor points in the ADMS model Figure 9: Locations of ecological designated sites in close proximity to Hinkley Point 3 Figure 10: Predicted annual mean NO2 concentrations (μg/m ) for Commissioning scenario th 3 Figure 11: Predicted 99.79 percentile 1-hour mean NO2 concentrations (μg/m ) for Commissioning and Routine Test scenarios
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3 Figure 12: Predicted annual mean NO2 concentrations (μg/m ) for Routine Test scenario 3 Figure 13: Predicted annual mean NO2 concentrations (μg/m ) for LOOP scenario 3 Figure 14: Predicted annual mean NOx concentrations (μg/m ) for Commissioning scenario 3 Figure 15: Predicted 24-hour mean NOx concentrations (μg/m ) for Commissioning and Routine Test scenarios Figure 16: Predicted nitrogen deposition flux (kg N ha-1 y-1) for Commissioning scenario Figure 17: Predicted acid deposition flux (keq ha-1 y-1) for Commissioning scenario 3 Figure 18: Predicted annual mean NOx concentrations (μg/m ) for Routine Test scenario Figure 19: Predicted nitrogen deposition flux (kg N ha-1 y-1) for Routine Test scenario Figure 20: Predicted acid deposition flux (keq ha-1 y-1) for Routine Test scenario 3 Figure 21: Predicted 24-hour mean NOx concentrations (μg/m ) for LOOP scenario
A PPENDICES
Appendix A: Input parameters for H1 screening assessments Appendix B: Input parameters for ADMS 4 assessment Appendix C: Air quality standards and objectives Appendix D: Results of H1 screening assessments Appendix E: Results of ADMS 4 dispersion modelling
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G LOSSARY
AADT Annual Average Daily Traffic flows CERC Cambridge Environmental Research Consultants CO Carbon monoxide DF Dispersion Factor DMRB Design Manual for Roads and Bridges EA Environment Agency EAL Environmental Assessment Level EDF Électricité de France EDG Emergency Diesel Generator EHO Environmental Health Officer EPR European Pressurised Reactor EQS Environmental Quality Standards EU European Union
H2CO Formaldehyde HGV Heavy Goods Vehicle IPC Infrastructure Planning Commission LAQM Local Air Quality Management
LMO Monin-Obukhov length
NH3 Ammonia NO Nitric oxide
NO2 Nitrogen dioxide
NOx Nitrogen oxides; a collective term used to represent nitric oxide (NO) and nitrogen dioxide (NO2)
O3 Ozone
PCair Process Contribution to air
PM10 The term PM10 refers to the fraction of particles with aerodynamic diameters equal to, or less than, 10 μm. More precisely, the definitions specify the inlet cut-off for which 50% collection efficiency by a particle separator is obtained for these sizes RR Release Rate SBO Station Black Out Generator SDC Sedgemoor District Council
SO2 Sulphur dioxide UKMO United Kingdom Meteorological Office VOC Volatile Organic Compound WSC West Somerset Council
Zo Surface roughness
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EXECUTIVE SUMMARY
The purpose of this document is to provide Électricité de France (EDF) with the methodology, input parameters and output of the Environment Agency H1 Environmental Risk Assessment methodology screening assessments and dispersion modelling studies undertaken to support an environmental permit application. The scope of the report includes:
x Initial H1 screening of emissions to air from the European Pressurised Reactor (EPR) units (C1 and C2) and ancillary buildings during the various operational phases; and
x Air quality dispersion modelling of emissions from the EPR units (C1 and C2) and ancillary buildings (for those pollutants identified as requiring detailed assessment by the H1 screening procedure) during the various operational phases.
Details of the Environment Agency H1 screening assessments and dispersion modelling studies undertaken for operational emissions to air are presented within this report. The H1 assessments undertaken failed to screen out the majority of operational emissions to air from requiring detailed dispersion modelling.
The operational dispersion modelling study adopted a cautious approach, with predicted concentrations and number of exceedences of air quality objectives being an extreme worse-case.
The assessment has determined that breaches of the air quality standard/objective/environmental assessment levels for the pollutants considered in this study are unlikely at all human receptors assessed during the commissioning routine plant test and 2 hour LOOP event scenarios. Exceedences of the 99.79 percentile 1-hour mean
NO2 air quality standard were predicted at certain foot path receptors. However, for a breach of the air quality standard to occur at these locations would require a member of the public to be present in this area for a total period of 18 hours during the LOOP event, which is extremely unlikely.
Breaches of the non-statutory 24-hour mean NOx guideline value at Bridgwater Bay NNR and Bridgwater Bay SSSI/Severn Estuary SPA/SAC/Ramsar were predicted by the assessment for the commissioning and routine test scenarios. However, for this to occur, it would require continuous operation of an EDG over a full 24-hour period, which is unlikely to occur in practice. It is also considered that greater emphasis should be placed on achievement with the more established statutory annual mean NOx air quality standard due to the uncertainty in the 24-hour guideline.
Additionally, breaches of the non-statutory 24-hour mean NOx guideline value at these receptors were predicted for the 24-hour LOOP scenario. However, such an event is highly unlikely; most LOOP events will last for a maximum duration of only 2 hours and there is a low probability of a LOOP event actually occurring. Consequently, adverse effects on ecological receptors are considered highly unlikely.
As breaches of the air quality standard/objective/environmental assessment levels are unlikely during the actual operation of the plant, the assessment concludes that emissions discharged to air from the commissioning and operation of the EPR units do not pose a significant concern with regards to air quality.
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1.0 INTRODUCTION
AMEC have been commissioned by Électricité de France (EDF) to undertake a detailed assessment of the potential air quality impacts resulting from the operation of the proposed Hinkley Point C nuclear power station, which will consist of two UK European Pressurised Reactors (UK EPRs) at Hinkley Point, Somerset.
This report presents the methodology, input parameters, and results of the initial screening assessments and dispersion modelling studies undertaken as part of this assessment. The assessment supports the application under Schedule 1, Part 2, Chapter 1, Section 1.1, Part A(1)(a) of the Environmental Permitting (England and Wales) Regulations 2010 for an environmental permit to operate the backup diesel generators associated with the EPR units.
1.1 Scope of the study
An initial screening of emissions to air from the backup generators associated with the EPR units (C1 and C2) during the commissioning and operational phases of the proposed development was performed following the Environment Agency H1 Environmental Risk Assessment methodology1. For those operational emissions not screened out by the H1 assessment, detailed dispersion modelling was then undertaken.
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2.0 METHODOLOGY
The methodologies adopted for undertaking the air quality impact assessment were agreed with EDF and Environmental Health Officers (EHOs) of both West Somerset Council (WSC) and Sedgemoor District Council (SDC).
2.1 Operational emissions to air
The potential operational emissions to air arising from a single EPR unit and its associated infrastructure will primarily be from the following sources:
x Sulphur dioxide and nitrogen oxides (SO2 and NOx), carbon monoxide (CO) and particulate matter (PM10 and PM2.5) in the exhaust gases from engines of backup diesel generators during periodic testing:
For each EPR unit there are four main backup electricity generators (Emergency Diesel Generators or EDGs) each rated around 7.5MWe, and two final emergency backup generator sets (Station Black Outs or SBOs) each rated around 2.5MWe. This is safety equipment, providing backup power supply in the unlikely case of loss of the main off-site power supply when house load operation fails, so that the EPR unit can be secured and the reactor cooled. These backup generators routinely operate during periodic tests, which represent an estimated 60 hours per year for each of the EDGs and SBO generators. Each EDG and SBO will also be operational for 242.5 hours and 738 hours once in the commissioning phase, respectively, during the initial commissioning of the plant (as a worst case, assumed to be during a period of one year). These emissions will be discharged via exhaust stacks (one per generator), approximately 30 metres in height, located on the roof of the diesel generator buildings. Each diesel generator building will house two EDGs and one SBO; thus there will be two diesel generator buildings per EPR.
x Auxiliary boilers, fire fighting and hydrant diesel pumps, domestic heating boilers, and small diesel engines associated with the Spent Fuel Interim
Storage Facility and the Security Force Control Centre (SO2, NOx, CO, PM10 and PM2.5):
Domestic heating and auxiliary boilers will be routinely used around the site (particularly during periods of cold weather). Fire fighting diesel pumps located around the site will only be used for short periods in the event of an emergency or during periodic tests. Small diesel engines will also be used to provide backup power supply to the Spent Fuel Interim Storage Facility and the Security Force Control Centre buildings. Emissions from these sources will be discharged to air via their own flue gas vents.
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2.1.1 Assessment scenarios
The assessment considers emissions to air during three potential emission scenarios:
Commissioning scenario
This scenario assesses all potential releases to air from the EDGs and SBOs during the commissioning of the plant.
It is not anticipated that more than one EDG or SBO will be in operation at any one time during plant commissioning. As such, maximum short-term concentrations have been determined assuming that one EDG is operational continuously throughout the commissioning phase (as a worst case, assumed to be during a period of one year); this approach enables the particular meteorological conditions conducive to producing transient peaks in ground level concentrations to be appropriately considered. Emission rates from the EDGs are greater than those occurring from the SBOs, hence the decision to only consider EDG emissions for the short-term assessment. The maximum predicted concentration from any particular EDG is reported in the results section.
With respect to longer-term pollutant concentrations, the maximum modelled annual mean concentrations, assuming continuous operation of any particular generator, have been factored by taking into account the combined annual operational hours of all EDGs and SBOs, i.e. 4,892 combined hours during the commissioning phase (assumed to be one year).
Routine test scenario
The routine test scenario presents the likely potential impacts to be expected as a result of the standard EDG/SBO testing, which will be scheduled throughout the lifetime of the power station. It is understood that testing of the backup diesel generators will take place individually, with only a single generator running at any one time. Consequently, the approach with regards to predicting short-term and long-term concentrations during this scenario is consistent with that used for the commissioning scenario but with combined annual operational hours factored accordingly.
Loss of off-site power scenario
This scenario will cover a credible loss of off-site power (LOOP) situation where grid connection for the planned twin UK EPR units is lost2.
As EPR design principles include an enhanced robustness against LOOP situations, LOOP scenarios are thoroughly assessed within the safety case. Safety case LOOP durations vary from very short LOOP (less than 2 hours, typically 30 minutes) to very long LOOP (15 days).
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As far as LOOP frequencies are concerned, the NSL Draft Application Dossier (May 2010) provides the information as detailed in Table 1 below.
Table 1: Details of LOOP scenarios
Faults Frequency for NSL Living PSA for SZB Short LOOP (< 2h) 6.12E-2/ry in all states 2.60E-2/ry
Long LOOP (between 2 and Base case: 1.02E-3/ry 5.4E-3/ry 24h) Sensitivity: 5.4E-3/ry in all states Very long LOOP (between 24 1.0E-4/ry in all states N/A and 192h) Conditional LOOP after 1.0E-3 1.1E-4/ry Reactor Trip 1/3 short LOOP 2/3 long LOOP
Building on this information, a very long LOOP scenario appears to be too unlikely to be a credible worst case scenario.
As far as short and long LOOP are concerned, the above frequencies assumed as follows:
x A short LOOP is expected to occur a limited number of times during the lifetime of the plant;
x A long LOOP is expected to occur about once in the lifetime of a fleet of nuclear sites.
From an engineering judgment perspective, events (including LOOP) which are unlikely to occur over the lifetime of fleet of EPR sites should not be considered ‘credible’. Thus, both above scenarios could be seen as reasonable credible worst- case situations.
If one considers the whole range of LOOP scenarios, it can be derived from the above table that short LOOP scenarios (up to 2 hours) represent more than 95% of the possible LOOP scenarios. Therefore, a 2-hour LOOP scenario can reasonably stand for a credible worst-case scenario.
While coping with a LOOP scenario, EDGs are not immediately shut down when LOOP is over. A limited amount of supplementary time needs to be considered. Even if it is difficult to assess this duration, an order of magnitude of one hour can be reasonably assumed.
Taking the above information into account, a 2-hour LOOP duration is considered credible, which would mean a 3-hour duration for EDG operation. This LOOP scenario would involve all eight EDGs running simultaneously.
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The shorter term air quality standards for NO2 and SO2 permit a certain number of exceedences of the standard concentration over a calendar year. These are summarised as follows:
3 x NO2: 18 exceedences of the 1-hour mean 200μg/m standard concentration; and
3 x SO2: 35 exceedences of the 15-minute mean 266μg/m objective concentration, 24 exceedences of the 1-hour mean 350 μg/m3 standard concentration and 3 exceedences of the 24-hour mean 125μg/m3 standard concentration.
Consequently, a 2-hour LOOP scenario (3 hours of EDG operation) would not result in non-compliance with the air quality standards since the event duration is
less than the permitted number of exceedences, e.g. even if the 1-hour mean NO2 standard concentration is breached during each hour of the LOOP event, this would only result in 3 of the 18 exceedences permitted by the standard. Similarly, a 2-hour LOOP scenario is unlikely to lead to a breach of the air quality standards for those pollutants with concentration averaging periods longer than the event
duration, e.g. 24-hour mean PM10, 8-hour mean CO and annual mean concentrations.
Therefore, a 2-hour LOOP event scenario has not been subject to detailed assessment. However, a 24-hour LOOP event scenario (25 hours of EDG operation) has been considered in order to take account of a potential scenario (however unlikely) whereby LOOP occurs for longer than a 2-hour period. This particular assessment still does not consider longer term (annual mean) concentrations as the short-term nature of the event means emissions from this scenario are unlikely to contribute significantly on an annual averaged basis.
2.1.2 H1 screening assessment
An initial screening assessment of operational emissions to air was undertaken for the commissioning and operational scenarios following the methodology provided in the Environment Agency’s H1 Environmental Risk Assessment guidance1.
The following steps of the H1 methodology have been followed for screening the non-vehicular operational point source emissions to air:
x Calculate the Process Contribution to air (PCair);
x Screen out insignificant emissions; and
x Identify the need for detailed modelling.
Calculation of the Process Contribution to air (PCair)
The Process Contribution of a substance emitted to air is the concentration of the emitted substance after dispersion. Estimation of the long-term and short-term
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Process Contributions (PCs) of substances released to air is achieved using the following formula:
PCair DF u RR
where:
3 PCair = process contribution to air (μg/m ).
DF = dispersion factor, expressed as the maximum average ground level concentration per unit mass release rate (ȝg/m3/g/s), based on annual average for long term releases and hourly average for short term releases.
RR = release rate of substance (g/s).
The release rates used in this study are presented in Table A1 and Table A2 of Appendix A, for the commissioning and routine test scenarios respectively. All release rates were either obtained from information made available from EDF or
the equipment manufacturer, with the exception of release rates for PM10 and CO discharged from the backup diesel generators. These release rates were calculated from Environmental Benchmark values for emissions to air for a compression ignition engine running off liquid fuel, published in Annex 1 of the Environment Agency’s Environmental Permitting Regulations sector guidance for Combustion Activities3.
Long-term and short-term dispersion factors for varying effective release heights are provided within the H1 guidance. For releases at heights other than those provided, linear interpolation is required to determine dispersion factors. The dispersion factors used in this study are provided in Table A1 and Table A2 of Appendix A, for the commissioning and routine test scenarios respectively.
It is important that process contribution concentrations, particularly short-term concentrations, are calculated on the same basis as corresponding environmental benchmarks, i.e. over the same averaging period or percentile exceedence. It is therefore necessary to apply suitable long-term and short-term conversion factors to the calculated process contribution concentrations. The H1 guidance provides suitable short-term conversion factors, whilst long-term conversion factors have been calculated based upon the number of hours of pollutant release in a calendar year; if the release is only for few hours per year, annual average concentrations will only be a very small fraction of the concentrations from a full year (8760 hours) running of the equipment. For example, if emissions are evacuated for a total of 60 hours per year, a long-term conversion term factor of 0.0068 would be applied to the calculated long-term PC (60/8760). A full set of conversion factors used in this study is provided in Table A1 and Table A2 of Appendix A, for the commissioning and routine test scenarios respectively.
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Screen out insignificant emissions
The short-term and long-term PCs of substances emitted to air are then compared against the relevant short-term and long-term environmental benchmark (Environmental Quality Standard (EQS) or Environmental Assessment Level (EAL)) for emissions to air provided in the Environment Agency H1 guidance. The environmental benchmarks are selected based on the local circumstances, i.e. the use of objectives set for the protection of vegetation and ecosystems for assessments in relation to sensitive vegetation, and objectives set for the protection of human health for human or residential receptors. The human health and ecological environmental benchmarks of importance to this study are provided in Table A3 of Appendix A.
The following criteria are applied to determine whether the emissions are considered significant:
x Process Contribution (long-term) > 1% of the long-term environmental benchmark; and
x Process Contribution (short-term) > 10% of the short-term environmental benchmark.
Identify the need for detailed modelling
Detailed dispersion modelling of any of the air emissions not screened out in the previous step may be required in order to obtain more accurate estimates of process contributions than those obtained through using simplified calculation methods.
For long-term effects, the need for detailed modelling is determined by calculating
whether the sum of the long-term PCair and the long-term background concentration exceeds 70% of the relevant long-term environmental benchmark.
For short-term effects, modelling may be appropriate if the short-term PCair is more than 20% of the difference between twice the long-term background concentration and the relevant short-term environmental benchmark.
The long-term (annual) background pollutant concentrations used in this study are presented in Table A4 of Appendix A. These 2009 annual mean background concentration values were either obtained from the Defra UK Air Quality Archive (UKAQA)4 background pollutant maps for the four 1km x 1km grid-squares closet to Hinkley Point or factored from the 2008 annual mean pollutant concentration results obtained from the 6-month baseline air quality monitoring programme undertaken at Hinkley Point between February and September 2009. Any annual factoring was undertaken following the methodology provided in Defra LAQM.TG(09) guidance5. Full details and results of the air quality monitoring programme are presented in the report ‘Final Air Quality Monitoring Report’ (2010). Whilst it is noted that the H1 scenarios being considered could only occur once the EPR units are constructed and commissioned or operational (2017 for the C1 EPR unit, 2020 for the C2 EPR unit), use of 2009 background pollutant concentrations
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provides a worst-case approach, as it is widely acknowledged that background pollutant concentrations are expected to decline in future years as a result of Government and EU policies and legislation to reduce pollutant emissions5.
If there are any local receptors which are sensitive to any of the emissions that have not been screened out, then modelling of long-term and/or short-term effects may be needed.
Since there is only one development scenario to be assessed for the commissioning and operational phases, the other stages of the H1 assessment methodology (e.g. quantification of the photochemical ozone creation potential and calculation of the environmental quotient for each substance) are not considered to be applicable and have therefore not been undertaken. The H1 methodology has been used as a tool to identify those operational emissions from the proposed development that warrant dispersion modelling and detailed assessment with respect to potential air quality effects.
All input data required for the H1 screening assessments was determined through consultation with EDF and information obtained from the equipment manufacturers. All input data used in the H1 assessments are presented in Appendix A.
2.1.3 Detailed dispersion modelling
Detailed dispersion modelling was undertaken for those operational emissions to air that were identified by the H1 screening methodology as requiring further detailed assessment. ADMS 4 Version 4.2 modelling software with Surfer Version 9 was used for this study.
The results of the initial H1 screening assessment undertaken (see Section 3.1) showed that detailed dispersion modelling was required for the majority of pollutant emissions discharged from all release points. Consequently, with the exception of those sources that, due to their size (e.g. auxiliary boilers and engines from the Spent Fuel Interim Storage Facility), are unlikely to contribute significantly to ground level concentrations outside the site boundary, a detailed assessment of all potential emissions to air from the plant are considered within the operational emissions detailed dispersion modelling sections.
Model background
ADMS 46 is one of the so-called “next generation” atmospheric dispersion models, developed by Cambridge Environmental Research Consultants (CERC). The software consists of a main dispersion module based on a Gaussian distribution in stable and neutral conditions and a skewed Gaussian plume model in convective conditions. The main difference in the treatment of the atmospheric boundary layer compared to first generation Gaussian dispersion models is that ADMS models
atmospheric stability in terms of the Monin-Obukhov length (LMO) rather than using discrete Pasquill Classes which were adopted in some earlier dispersion codes.
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Single or multiple sources of various types (point, area, volume, jet) can be modelled and advanced features such as the modelling of building downwash, atmospheric chemical reactions, wet and dry deposition, and the effects of the terrain or a coastline are available. ADMS 4 includes a meteorological pre-
processor which calculates parameters such as LMO from the raw meteorological data.
Model scenarios
The modelled scenarios are consistent with those described in Section 2.1.1.
Discharged emissions and stack parameters
Details of the potential releases, including the pollutant discharge rate, volumetric flux, and temperature are given in Table B1 of Appendix B. All model input parameters were determined through consultation with EDF and information made available from the equipment manufacturers.
ADMS was run with emissions from each stack being discharged from a point source, appropriate for a stack of small diameter. For the purposes of this assessment, it has been assumed that the emergency diesel buildings and stacks are located and aligned as illustrated in Figure 1.
Buildings
The proposed site surrounding the discharge stacks is fairly complex with several buildings which will affect the dispersion of the discharged pollutants.
Local buildings affect wind flow, and consequently dispersion, at two general scales. At the regional scale, buildings contribute to surface roughness, whilst at the local scale, buildings affect dispersion from an elevated release by inducing local turbulence that can draw down the pollutant released from the stack to ground level close to the stack.
The effect of buildings on dispersion was modelled using the ADMS advanced ‘Buildings’ option. Parameters such as size, shape and position relative to the stacks were used to model the proposed reactors and ancillary buildings. It is not possible to input irregularly shaped buildings directly into ADMS. In order to accommodate the shape of the reactor buildings, each reactor building was modelled as a cylinder surrounded on four sides by rectangular ancillary buildings (Figure 1). The turbine halls and other buildings affecting dispersion from the stacks have also been included as separate rectangles. The dimensions of each building and their positions relative to the stack are presented in Table B2 of Appendix B.
Surface roughness
The extent of mechanical turbulence (and consequently, mixing) in the lower boundary layer is affected by the roughness of the ground over which the air is
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passing. The area to the south of the Hinkley Point site is mainly rural with small hamlets, and to the north of the site is the Bristol Channel. The Hinkley Point A and B power station sites to the east are densely populated with buildings.
A surface roughness value of 0.3m was use in the dispersion modelling runs, consistent with the agricultural land surrounding the site.
Terrain
The surrounding terrain to the east, west and south of the site consists of gently undulating farmland interspersed with farms and small villages, whilst to the immediate north of the proposed development site lies the Bridgwater Bay.
There are no significant terrain features in the area immediately surrounding the site and the effects of complex data were not modelled.
Meteorological data
Annual hourly sequential meteorological data was obtained for 2005 to 2009 generated using the United Kingdom Meteorological Office (UKMO) Numerical Weather Prediction model for the Hinkley Point site. The data are provided in a text format file containing 43824 sequential hours of data (from 1 January 2005 to 31 December 2009), with the following parameters provided for each hour:
x Wind speed (at 10m);
x Wind direction (degrees);
x Cloud amount (oktas);
x Temperature (oC);
x Sensible heat flux (W m-2);
x Boundary layer depth (m);
x Precipitation rate (mm h-1); and
x Relative humidity (percentage).
Wind-roses for each year between 2005 and 2009 are shown in Figures 2 to 6, whilst Figure 7 shows the overall wind-rose for the years 2005 to 2009.
The ADMS model was run independently for each year of meteorological data in order to identify the year which produced the highest predicted concentrations, i.e. the worst-case scenario. The meteorological data for this year, if considered to be representative of the typical meteorological conditions at the site, was then used for the study.
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Removal by dry and wet deposition
The predominant route by which emissions will affect land in the vicinity of a process is by deposition of atmospheric emissions. Potential ecological receptors can be sensitive to the deposition of pollutants, particularly nitrogen and sulphur compounds, which can affect the character of the habitat through eutrophication and acidification.
Deposition processes in the form of dry and wet deposition remove material from a plume and alter the plume concentration. Dry deposition occurs when particles and gases are brought to the surface by gravitational settling and turbulence. They are then removed from the atmosphere by deposition on the land surface. Wet deposition occurs due to rainout (within cloud) scavenging and washout (below cloud) scavenging of the material in the plume. These processes lead to a variation with downwind distance of the plume strength and may alter the shape of the vertical concentration profile as dry deposition only occurs at the surface.
Near to sources of pollutants, dry deposition is the predominant removal mechanism7. Dry deposition may be quantified from the near-surface plume concentration and the deposition velocity8:
, ,0 Fd vd C x y
where:
-2 -1 Fd = dry deposition flux (ȝg m s )
-1 vd = deposition velocity (m s )
C x, y,0 = ground level concentration (ȝg m-3)
Assuming irreversible uptake, the wet deposition rate is found by integrating through a vertical column of air:
z F /C dz w ³ 0
where:
-2 -1 Fw = wet deposition flux (ȝg m s ), an intrinsic function of rainfall rate
/ = washout co-efficient (s-1)
C = local airborne concentration (ȝg m-3)
z = height (m)
The washout co-efficient is an intrinsic function of the rate of rainfall.
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Draft Environment Agency guidance AQTAG069 recommends deposition velocities for various pollutants. These are presented in Table 2 below.
Table 2: Environment Agency recommended pollutant deposition velocities
Pollutant Deposition Velocity (m s-1)
Short Vegetation Long Vegetation
NOx 0.0015 0.003
SO2 0.012 0.024 Source: Environment Agency (2006) ‘Technical Guidance on Detailed Modelling Approach for an Appropriate Assessment for Emissions to Air’, AQTAG06 Working Draft Version 9, 12/05/06.
In order to assess the impacts of deposition, habitat-specific critical loads and critical levels have been created. These are generally defined as10:
“a quantitative estimate of exposure to one or more pollutants below which significant harmful effects on specified sensitive elements of the environment do not occur according to present knowledge.”
It is important to distinguish between a critical load and a critical level. The critical load relates to the quantity of a material deposited from air to the ground, whilst critical levels refer to the concentration of a material in air.
The critical loads used to assess the impact of compounds deposited to land which result in eutrophication and acidification are expressed in terms of kilograms of nitrogen deposited per hectare per year (kg N ha-1 y-1) and kilo equivalents deposited per hectare per year (keq ha-1 y-1). To enable a direct comparison against the critical loads, the modelled total deposition flux (ȝg m-2 s-1) must be converted into an equivalent value.
The annual deposition flux of nitrogen can be expressed as:
§ K · T § M · F ¨ 2 ¸ t F ¨ N ¸ NTot ¨ ¸ ¦ i ¨ ¸ © K 3 ¹ i 1 © M i ¹
where:
-1 -1 FNTot = Annual deposition flux of nitrogen (kg N ha y )
2 4 2 -1 K2 = Conversion factor for m to ha (= 1x10 m ha )
9 -1 K3 = Conversion factor for ȝg to kg (= 1x10 ȝg kg )
t = Number of seconds in a year (= 3.1536x107 s y-1)
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i = 1,2,3…….T
T = Total number of nitrogen containing compounds
F = Modelled deposition flux of nitrogen containing compound (ȝg m-2 s-1)
M N = Molecular mass of nitrogen (kg)
M = Molecular mass of nitrogen containing compound (kg)
Similar relationships prevail to allow the annual deposition flux of sulphur from SO2 to be quantified.
The unit eq (1 keq Ł 1,000 eq) refers to molar equivalent of potential acidity resulting from, example, sulphur, oxidised and reduced nitrogen, as well as base cations. Conversion units are provided in AQTAG(06)9:
1 keq ha-1 y-1 = 14 kg N ha-1 y-1
1 keq ha-1 y-1 = 16 kg S ha-1 y-1
For the purposes of this assessment, dry deposition rates of nitrogen and acidic equivalents have been calculated by applying the short vegetation deposition velocities detailed in AQTAG(06)9 to the modelled annual mean concentrations of
NOx and SO2. Wet deposition has not been assessed since this is not a significant contributor to total deposition over shorter ranges7, 9.
The model has been run without plume depletion such that downwind concentrations and, hence, deposition rates are over predicted. Additional over prediction is likely to occur by considering concentration estimates at a height of 1.8m above ground level (representative of the approximate breathing zone height of an individual); deposition is a function of the ground level concentration, as opposed to concentration at height, where, for elevated releases, concentrations are generally higher.
Exposure groups and receptor grid
There are several local farms and residential properties close to the site where occupants may be exposed to emissions arising from the operation of the proposed power station.
All farms and residences in close proximity to the site have been considered. The locations of the farms, residences and villages were chosen based on inspection of maps, satellite imagery of the area and a visit to the site and surrounding area. Furthermore, receptors at local public footpaths and the archaeological site of interest, Pixies Mound, have been included within the assessment. Distances and bearings to the farms and villages are presented in Table B3 of Appendix B and are illustrated in Figure 8.
There are also several ecological designated sites in proximity to the Hinkley Point site. Distances and bearings to the designated sites located beyond 2km from the
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site are also presented in Table B3 of Appendix B, whilst those in immediate proximity to the site are illustrated in Figure 9.
In addition to these discrete receptors, pollutant air concentrations were output on a 4km x 4km model grid extending in the East–West plane from 318270 E to 322270 E with a spacing of 40m, and in the North–South plane from 143820 N to 147820 N also with a spacing of 40m. This allowed for the accurate representation of pollutant concentrations predicted in the study area in the form of contour plots.
All predicted pollutant concentrations were output at a height of 1.8m above ground level, which is representative of the approximate breathing zone height of an individual.
Direction is provided in Schedule 1, Part 1, 2(a) through (c) of the Air Quality Standards Regulations 201011 regarding locations where compliance with standards set to protect human health need not be assessed:
“Compliance with the limit values directed at the protection of human health does not need to be assessed at the following locations:
a) any location situated within areas where members of the public do not have access and there is no fixed habitation;
b) on factory premises or at industrial locations to which all relevant provisions concerning health and safety at work apply;
c) on the carriageway of roads and on the central reservation of roads except where there is normally pedestrian access to the central reservation.”
In accordance with the above, an assessment of model predictions at the existing Hinkley Point A and B sites has not been made as this would be representative of workplace exposure at an industrial location where members of the public do not have access.
Background pollutant concentrations
Short-term background pollutant monitoring data are not available for a full year’s period at Hinkley Point. Therefore, following the H1 guidance (which states that in the case of assessing short-term effects the background concentration is assumed to be twice the long-term ambient concentration), the short-term background
concentrations of NO2, NOx, SO2, CO, PM10 and PM2.5 used in the ADMS model have been taken to be twice the annual 2009 background concentrations presented in Table A4 of Appendix A. Similar to the H1 assessment, whilst it is noted that the model scenarios being considered could only occur once the EPR units are constructed and commissioned or operational (2017 for the C1 EPR unit, 2020 for the C2 EPR unit), use of 2009 background pollutant concentrations is considered valid as it provides a worst-case assessment approach.
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Model output
Short-term concentrations have been predicted in order to assess compliance with the current statutory air quality standards and objectives set out in Appendix C.
NOx, SO2, PM10, CO, NH3 and H2CO concentrations were therefore calculated for a 1-hour averaging period, whilst SO2 concentrations were also calculated for 15- minute and 24-hour averaging periods. In addition, PM10 concentrations were calculated for 24-hour averaging periods, whilst CO concentrations were also calculated over running 8-hour averaging periods. This has been achieved using the “long term” mode of ADMS; the “short term” mode does not allow for percentile values and objective limit exceedences to be calculated.
NOx to NO2 conversion
Emissions of NOx from combustion processes are predominantly in the form of nitric oxide (NO). Excess oxygen in the combustion gases and further atmospheric
reactions cause the oxidation of NO to nitrogen dioxide (NO2). NOx chemistry in the lower troposphere is strongly interlinked in a complex chain of reactions involving
VOCs and Ozone (O3). Two of the key reactions interlinking NO and NO2 are detailed below:
O2 NO2 hv o NO O3 (R1)
NO O3 o NO2 O2 (R2)
Where hv is used to represent a photon of light energy (i.e. sunlight).
Taken together, reactions R1 and R2 produce no net change in O3 concentrations and NO and NO2 adjust to establish a near steady state reaction (photo- equilibrium). However, the presence of VOCs and CO in the atmosphere offer an
alternative production route of NO2 for photolysis, allowing O3 concentrations to increase during the day with a subsequent decrease in the NO2:NOx ratio.
However, at night, the photolysis of NO2 ceases, allowing reaction R2 to promote the production of NO2, at the expense of O3, with a corresponding increase in the NO2:NOx ratio. Similarly, near to an emission source of NO, the result is a net increase in the rate of reaction R2, suppressing O3 concentrations immediately downwind of the source, and increasing further downwind as the concentrations of NO begin to stabilise to typical background levels12.
Given the complex nature of NOx chemistry, the Environment Agency’s Air Quality Modelling and Assessment Unit (AQMAU) have adopted a pragmatic, risk based
approach in determining the conversion rate of NO to NO2 which dispersion model practitioners can use in their detailed assessments. The AQMAU guidance advises
that the source term should be modelled as NOx (as NO2) and then suggests a tiered approach when considering ambient NO2:NOX ratios:
x Screening Scenario: 50% and 100% of the modelled NOx process contributions should be used for short-term and long-term average
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concentration, respectively. That is, 50% of the predicted NOx concentrations should be assumed to be NO2 for short-term assessments and 100 % of the predicted NOx concentrations should be assumed to be NO2 for long-term assessments;
x Worst Case Scenario: 35% and 70% of the modelled NOx process contributions should be used for short-term and long-term average
concentration, respectively. That is, 35% of the predicted NOx concentrations should be assumed to be NO2 for short-term assessments and 70% of the predicted NOx concentrations should be assumed to be NO2 for long-term assessments; and
x Case Specific Scenario: Operators are asked to justify their use of percentages lower than 35% for short-term and 70% for long-term assessments in their application reports.
In line with the AQMAU guidance, this assessment has used the ‘Worst Case
Scenario’ approach in determining the conversion rate of NOx to NO2 for the detailed modelling assessment, and the ‘Screening Scenario’ approach for the initial H1 assessment.
Model limitations
ADMS 4 cannot model dispersion for meteorological data lines (hourly data within the meteorological input file) with calm wind conditions, if either the puff, fluctuations, radioactive decay, hills or coastlines model options are selected. Meteorological data lines with wind speed at a height of 10m which are less than 0.75m/s are therefore skipped.
The coastline module option in ADMS 4 was not implemented for the purposes of this study. The module requires additional meteorological parameters which were not available, such as the difference in temperature between the sea surface temperature and the near surface temperature over land, or the sea surface temperature and surface temperature over land.
Pollutant emission associated with the emergency diesel generators only occur for a limited number of hours of the year. Despite being primarily interested in assessing predicted pollutant concentrations against short-term air quality standards, such standards are based upon the number of exceedences of a threshold concentration over a full calendar year. Pollutant concentrations have therefore been calculated for each 1-hour line of meteorological data for a year, assuming pollutant release for each hour, and in the case of predicted annual mean concentrations have been multiplied by the fraction of number of hours per year of operation for each scenario to obtain the contribution of diesel generator emissions to the annual mean. It is not possible to apply such a procedure to the predicted short-term pollutant concentrations. Had the testing schedule of the diesel generators been known, it would have been possible to use the “time- varying source” option of the ADMS 4 model to produce pollutant concentration
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data resembling the “real” likely exceedences expected for an operating scenario, for both long-term and short-term pollutant emissions.
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3.0 RESULTS
This section presents the results of the H1 screening assessment of operational emissions to air undertaken as part of the air quality impact assessment for the proposed development.
The air quality standards (AQSs), objectives (AQOs) and environmental assessment levels (EALs) pertinent to the results in this section are detailed in Appendix C.
3.1 Operational emissions to air – H1 screening assessment results
The results of the H1 assessments undertaken are presented in Appendix D. The
short-term and long-term Process Contributions to air (PCair) calculated for both the commissioning scenario, the routine test and the LOOP scenario are presented in Table D1 of Appendix D.
3.1.1 Commissioning scenario
Human health receptors
Following H1 methodology, the PCair values calculated for the commissioning scenario were compared with the relevant human health EQS/EALs in order to determine their significance and screen out insignificant emissions. This showed that emissions of all pollutants could not be screened as insignificant. Further consideration of these emissions was therefore required in order to determine if detailed air modelling was necessary (see Table D2 of Appendix D).
From those emissions identified above that could not be screened as insignificant, detailed air modelling was then found to be required for all pollutants (see Table D3 of Appendix D).
Ecological receptors
Comparison of the relevant ecological EQS/EALs with the calculated PCair values showed that long-term emissions of SO2 and NOx from the engines of the backup diesel generators could not be screened as insignificant. These emissions therefore required further consideration in order to determine if detailed air modelling was necessary (see Table D2 of Appendix D).
For these emissions, detailed air modelling was then found to be required for all pollutants (see Table D3 of Appendix D).
3.1.2 Routine test scenario
Human health receptors
For the routine test scenario, comparison of the calculated PCair values with the relevant human health EQS/EALs showed that emissions of all pollutants could not
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be screened as insignificant. Further consideration of these emissions was therefore required with regards to human health receptors, in order to determine if detailed air modelling was necessary (see Table D2 of Appendix D).
From those emissions identified that could not be screened as insignificant, detailed air modelling was then found to be required for all pollutants with the
exception of long-term PM10 and PM2.5 emissions (see Table D3 of Appendix D).
Ecological receptors
Considering the ecological receptors, comparison of the relevant ecological
EQS/EALs with the calculated PCair values showed that no emissions could be classed as insignificant. These emissions therefore required further consideration in order to determine if detailed air modelling was necessary (see Table D2 of Appendix D).
From those emissions identified above that could not be classed as insignificant, detailed air modelling was then found to be required for all pollutants (see Table D3 of Appendix D).
3.1.3 LOOP event scenario
Human health receptors
For the routine test scenario, comparison of the calculated PCair values with the relevant human health EQS/EALs showed that emissions of all pollutants could not be screened as insignificant. Further consideration of these emissions was therefore required with regards to human health receptors, in order to determine if detailed air modelling was necessary (see Table D2 of Appendix D).
From those emissions identified that could not be screened as insignificant, detailed air modelling was then found to be required for all pollutants (see Table D3 of Appendix D).
Ecological receptors
Considering the ecological receptors, comparison of the relevant ecological
EQS/EALs with the calculated PCair values showed that no emissions could be classed as insignificant. These emissions therefore required further consideration in order to determine if detailed air modelling was necessary (see Table D2 of Appendix D).
From those emissions identified above that could not be classed as insignificant, detailed air modelling was then found to be required for all pollutants (see Table D3 of Appendix D).
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3.1.4 H1 assessment summary
The H1 assessments undertaken failed to screen out the majority of operational emissions from requiring detailed dispersion modelling. As a result, the detailed operational dispersion modelling considered all potential emissions that may occur during the commissioning, routine test and LOOP scenarios.
3.2 Operational emissions to air – detailed dispersion modelling results
This section sets out the results of the dispersion modelling and compares predicted ground level concentrations to ambient air quality standards. The predicted concentrations resulting from the process are presented with background concentrations and the percentage contribution that the predicted environmental concentrations would make towards the relevant AQS/AQO/EAL.
Results are presented for the meteorological year resulting in the highest ground level concentrations, as a worst-case assumption. The worst-case was determined
separately for long and short-term concentrations, based on NOx process contributions at the human receptor experiencing the maximum process contribution during the commissioning scenario (see Table 3).
Table 3: Identification of worst-case meteorological year for pollutant dispersion
Predicted Ground Level Concentration due to 3 Process Emissions (ȝg/m ) Year
NOx annual mean NOx 99.79 percentile of 1-hour mean
2005 2.32 60.56 2006 2.23 54.63 2007 2.36 57.31 2008 2.24 52.60 2009 2.50 50.09 Notes:
Determination based on maximum predicted NOx PC at any human receptor during commissioning and without consideration of annual operational hours.
From the above predicted ground level concentrations, it can be seen that 2009 meteorological data produces the highest predicted concentrations for long-term means, whilst 2005 meteorological data produces the highest predicted concentrations for short-term means. Therefore, as a worst-case assumption, results using 2009 and 2005 data for long-term and short-term means, respectively, are reported in the following sections.
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3.2.1 Commissioning scenario - human receptor results
NO2 concentrations
The maximum annual mean NO2 PEC (i.e. the contribution from the process and background concentration) at the discrete human receptors considered in this assessment is predicted as 7.78μg/m3. This value is 19.4% of the 40μg/m3 air quality standard and occurs at Trighern Farm.
The maximum 99.79 percentile 1-hour mean PEC at the discrete human receptors considered in this assessment is predicted as 34.80μg/m3. This value is 17.4% of the 200μg/m3 air quality standard and occurs at Doggetts.
At the footpath and Pixies Mound receptors, the maximum 99.79 percentile 1-hour mean PEC is predicted as 115.14μg/m3, 57.6% of the 200μg/m3 air quality standard.
Predicted NO2 concentrations at all human receptors considered in the assessment for the commissioning scenario are detailed in Table E1 of Appendix E. Figure 10
and Figure 11 illustrate the annual mean NO2 concentrations and the 99.79 percentile 1-hour mean concentrations, respectively, predicted for the commissioning scenario.
PM10 concentrations
The maximum annual mean PM10 PEC at the discrete human receptors considered in this assessment is predicted as 18.24μg/m3. This value is 45.6% of the 40μg/m3 air quality standard and occurs at Trighern Farm.
The maximum 90.41 percentile 24-hour mean PEC at the discrete human receptors considered in this assessment is predicted as 36.61μg/m3. This value is 73.2% of the 50μg/m3 air quality standard and occurs at Wick Farm.
Predicted PM10 concentrations at all human receptors considered in the assessment for the commissioning scenario are detailed in Table E2 of Appendix E.
PM2.5 concentrations
The maximum annual mean PM2.5 PEC at the discrete human receptors considered in this assessment is predicted as 7.94μg/m3. This value is 31.7% of the 25μg/m3 air quality standard and occurs at Trighern Farm.
Predicted PM2.5 concentrations at all human receptors considered in the assessment for the commissioning scenario are detailed in Table E3 of Appendix E.
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CO concentrations
The maximum 1-hour mean CO PEC at the discrete human receptors considered in this assessment is predicted as 163μg/m3. This value is 0.5% of the 30,000μg/m3 environmental assessment level and occurs at Doggetts.
At the footpath and Pixies Mound receptors, the maximum 1-hour mean PEC is predicted as 182μg/m3, 0.6% of the 30,000μg/m3 environmental assessment level.
The maximum rolling 8-hour mean CO PEC at the discrete human receptors considered in this assessment is predicted as 161μg/m3. This value is 1.6% of the 10,000μg/m3 air quality standard and occurs at Doggetts.
Predicted CO concentrations at all human receptors considered in the assessment for the commissioning scenario are detailed in Table E4 of Appendix E.
SO2 concentrations
The maximum 99.9 percentile 15-minute mean SO2 PEC at the discrete human receptors considered in this assessment is predicted as 10.83μg/m3. This value is 4.1% of the 266μg/m3 air quality objective and occurs at Doggetts.
At the footpath and Pixies Mound receptors, the maximum 99.9 percentile 15- 3 3 minute mean SO2 PEC is predicted as 34.87μg/m , 13.1% of the 266μg/m air quality objective.
The maximum 99.73 percentile 1-hour mean SO2 PEC at the discrete human receptors considered in this assessment is predicted as 9.36μg/m3. This value is 2.7% of the 350μg/m3 air quality standard and occurs at Doggetts.
At the footpath and Pixies Mound receptors, the maximum 99.73 percentile 1-hour 3 3 mean SO2 PEC is predicted as 30.57μg/m , 8.7% of the 350μg/m air quality standard.
The maximum 99.18 percentile 24-hour mean SO2 PEC at the discrete human receptors considered in this assessment is predicted as 6.11μg/m3. This value is 4.9% of the 125μg/m3 air quality standard and occurs at Doggetts.
Predicted SO2 concentrations at all human receptors considered in the assessment for the commissioning scenario are detailed in Table E5 of Appendix E.
3.2.2 Routine test scenario - human receptor results
NO2 concentrations
The maximum annual mean NO2 PEC (i.e., the contribution from the process and background concentration) at the discrete human receptors considered in this assessment is predicted as 6.94μg/m3. This value is 17.4% of the 40μg/m3 air quality standard and occurs at Trighern Farm.
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The maximum 99.79 percentile 1-hour mean PEC at the discrete human receptors considered in this assessment is predicted as 34.80μg/m3. This value is 17.4% of the 200μg/m3 air quality standard and occurs at Doggetts.
At the footpath and Pixies Mound receptors, the maximum 99.79 percentile 1-hour 3 3 mean NO2 PEC is predicted as 115.14μg/m , 57.6% of the 200μg/m air quality standard.
Predicted NO2 concentrations at all human receptors considered in the assessment for the routine test scenario are detailed in Table E6 of Appendix E. Figure 12 and
Figure 11 illustrate the annual mean NO2 concentrations and the 99.79 percentile 1-hour mean concentrations, respectively, predicted for the routine test scenario.
PM10 concentrations
The maximum annual mean PM10 PEC at the discrete human receptors considered in this assessment is predicted as 18.21μg/m3. This value is 45.5% of the 40μg/m3 air quality standard and occurs at Trighern Farm.
The maximum 90.41 percentile 24-hour mean PEC at the discrete human receptors considered in this assessment is predicted as 36.61μg/m3. This value is 73.2% of the 50μg/m3 air quality standard and occurs at Wick Farm.
Predicted PM10 concentrations at all human receptors considered in the assessment for the routine test scenario are detailed in Table E7 of Appendix E.
PM2.5 concentrations
The maximum annual mean PM2.5 PEC at the discrete human receptors considered in this assessment is predicted as 7.91μg/m3. This value is 31.6% of the 25μg/m3 air quality standard and occurs at Trighern Farm.
Predicted PM2.5 concentrations at all human receptors considered in the assessment for the routine test scenario are detailed in Table E8 of Appendix E.
CO concentrations
The maximum 1-hour mean CO PEC at the discrete human receptors considered in this assessment is predicted as 163μg/m3. This value is 0.5% of the 30,000μg/m3 environmental assessment level and occurs at Doggetts.
At the footpath and Pixies Mound receptors, the maximum 1-hour mean PEC is predicted as 182μg/m3, 0.6% of the 30,000μg/m3 environmental assessment level.
The maximum rolling 8-hour mean CO PEC at the discrete human receptors considered in this assessment is predicted as 161μg/m3. This value is 1.6% of the 10,000μg/m3 air quality standard and occurs at Doggetts.
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Predicted CO concentrations at all human receptors considered in the assessment for the routine test scenario are detailed in Table E9 of Appendix E.
SO2 concentrations
The maximum 99.9 percentile 15-minute mean SO2 PEC at the discrete human receptors considered in this assessment is predicted as 10.83μg/m3. This value is 4.1% of the 266μg/m3 air quality objective and occurs at Doggetts.
At the footpath and Pixies Mound receptors, the maximum 99.9 percentile 15- 3 3 minute mean SO2 PEC is predicted as 34.87μg/m , 13.1% of the 266μg/m air quality objective.
The maximum 99.73 percentile 1-hour mean SO2 PEC at the discrete human receptors considered in this assessment is predicted as 9.36μg/m3. This value is 2.7% of the 350μg/m3 air quality standard and occurs at Doggetts.
At the footpath and Pixies Mound receptors, the maximum 99.73 percentile 1-hour 3 3 mean SO2 PEC is predicted as 30.57μg/m , 8.7% of the 350μg/m air quality standard.
The maximum 99.18 percentile 24-hour mean SO2 PEC at the discrete human receptors considered in this assessment is predicted as 6.11μg/m3. This value is 4.9% of the 125μg/m3 air quality standard and occurs at Doggetts.
Predicted SO2 concentrations at all human receptors considered in the assessment for the routine test scenario are detailed in Table E10 of Appendix E.
3.2.3 LOOP scenario (24 hour event) – human receptor results
As discussed in section 2.1.1, annual mean concentrations resulting from a LOOP event have not been assessed due to the short term nature of the release which is unlikely to contribute significantly to concentrations averaged over longer time periods.
NO2 concentrations
The maximum 99.79 percentile 1-hour mean NO2 PEC at the discrete human receptors considered in this assessment is predicted as 136μg/m3. This value is 68.0% of the 200μg/m3 air quality standard and occurs at Doggetts.
At the footpath and Pixies Mound receptors, the maximum 99.79 percentile 1-hour 3 3 mean NO2 PEC is predicted as 372μg/m , 185.8% of the 200μg/m air quality standard. However, for a breach of the air quality standard to occur at this location would require a member of the public to be present in this area for a total period of 18 hours and would also require those hours to coincide exactly with the worst- case meteorological conditions conducive to the formation of elevated ground level concentrations. It is extremely unlikely that these requisites will be realised and, in
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practice, a breach of the air quality standard is not expected for a 24 hour LOOP event.
Predicted NO2 concentrations at all human receptors considered in the assessment for the LOOP scenario are detailed in Table E11 of Appendix E. Figure 13
illustrates the 1-hour mean NO2 concentrations predicted for the LOOP scenario.
PM10 concentrations
The maximum 90.41 percentile 24-hour mean PM10 PEC at the discrete human receptors considered in this assessment is predicted as 37.96μg/m3. This value is 73.2% of the 50μg/m3 air quality standard and occurs at Doggets.
Predicted PM10 concentrations at all human receptors considered in the assessment for the LOOP scenario are detailed in Table E12 of Appendix E.
CO concentrations
The maximum 1-hour mean CO PEC at the discrete human receptors considered in this assessment is predicted as 189μg/m3. This value is 0.6% of the 30,000μg/m3 environmental assessment level and occurs at Doggetts.
At the footpath and Pixies Mound receptors, the maximum 1-hour mean CO PEC is predicted as 249μg/m3, 0.8% of the 10,000μg/m3 environmental assessment level.
The maximum rolling 8-hour mean CO PEC at the discrete human receptors considered in this assessment is predicted as 180μg/m3. This value is 1.8% of the 10,000μg/m3 air quality standard and occurs at Doggetts.
Predicted CO concentrations at all human receptors considered in the assessment for the LOOP scenario are detailed in Table E13 of Appendix E.
SO2 concentrations
The maximum 99.9 percentile 15-minute mean SO2 PEC at the discrete human receptors considered in this assessment is predicted as 41.13μg/m3. This value is 15.5% of the 266μg/m3 air quality objective and occurs at Doggetts.
At the footpath and Pixies Mound receptors, the maximum 99.9 percentile 15- 3 3 minute mean SO2 PEC is predicted as 126.77μg/m , 47.7% of the 266μg/m air quality objective.
The maximum 99.73 percentile 1-hour mean SO2 PEC at the discrete human receptors considered in this assessment is predicted as 36.68μg/m3. This value is 10.5% of the 350μg/m3 air quality standard and occurs at Doggetts.
At the footpath and Pixies Mound receptors, the maximum 99.73 percentile 1-hour 3 3 mean SO2 PEC is predicted as 98.71μg/m , 28.2% of the 350μg/m air quality standard.
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The maximum 99.18 percentile 24-hour mean SO2 PEC at the discrete human receptors considered in this assessment is predicted as 18.69μg/m3. This value is 15.0% of the 125μg/m3 air quality standard and occurs at Doggetts.
Predicted SO2 concentrations at all human receptors considered in the assessment for the routine test scenario are detailed in Table E14 of Appendix E.
3.2.4 Commissioning scenario - ecological receptor results
NOx concentrations
The maximum annual mean NOx PEC at the ecological receptors considered in this assessment is predicted as 23.24μg/m3. This value is 77.5% of the 30μg/m3 air quality standard and occurs at the Severn Estuary SPA/SAC/Ramsar/Bridgwater Bay SSSI.
The maximum 24-hour mean NOx PEC at the ecological receptors considered in this assessment is predicted as 230μg/m3. This value is 307% of the 75μg/m3 environmental assessment level and occurs at the Bridgwater Bay NNR. However, this value is derived based on continuous operation of an EDG over an entire 24- hour period, which is unlikely to represent the actual operational profile. Furthermore, the 75ȝg/m3 daily mean EAL is derived from the 2000 World Health Organisation (WHO) Air Quality Guidelines for Europe13. The WHO state in this
document that, with reference to the daily mean NOx guideline level:
“There is insufficient data to provide these levels with confidence at present.”
Consequently, it is considered that greater emphasis should be placed on
achievement with the more established NOx annual mean air quality standard.
Predicted NOx concentrations at all ecological receptors considered in the assessment for the commissioning scenario are detailed in Table E15 of Appendix
E. Figure 14 and Figure 15 illustrate the annual mean NOx concentrations and the 24-hour mean NOx concentrations, respectively, predicted for the commissioning scenario.
SO2 concentrations
The maximum annual mean SO2 PEC at the ecological receptors considered in this assessment is predicted as 2.94μg/m3. This value is 14.7% of the 20μg/m3 air quality standard and occurs at the Severn Estuary SPA/SAC/Ramsar/Bridgwater Bay SSSI.
Predicted SO2 concentrations at all ecological receptors considered in the assessment for the commissioning scenario are detailed in Table E16 of Appendix E.
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Deposition
The maximum nitrogen and acid deposition rates at the ecological receptors considered in this assessment are predicted as 1.71kg N ha-1 y-1 and 0.26keq ha-1 y-1, respectively. The significance of these values in the context of critical loads and critical levels is discussed elsewhere and is not part of the scope of this document.
Predicted deposition rates at all ecological receptors considered in the assessment for the commissioning scenario are detailed in Table E20 of Appendix E. Figure 16 and Figure 17 illustrate the nitrogen and acid deposition fluxes, respectively, predicted for the commissioning scenario.
3.2.5 Routine test scenario - ecological receptor results
NOx concentrations
The maximum annual mean NOx PEC at the ecological receptors considered in this assessment is predicted as 13.25μg/m3. This value is 44.2% of the 30μg/m3 air quality standard and occurs at the Severn Estuary SPA/SAC/Ramsar/Bridgwater Bay SSSI.
The maximum 24-hour mean NOx PEC at the ecological receptors considered in this assessment is predicted as 230μg/m3. This value is 307% of the 75μg/m3 environmental assessment level and occurs at the Bridgwater Bay NNR. However, as for the commissioning scenario, it is considered that greater emphasis should be
placed on achievement with the more established NOx annual mean air quality standard.
Predicted NOx concentrations at all ecological receptors considered in the assessment for the routine test scenario are detailed in Table E17 of Appendix E.
Figure 18 and Figure 15 illustrate the annual mean NOx concentrations and the 24- hour mean NOx concentrations, respectively, predicted for the routine test scenario.
SO2 concentrations
The maximum annual mean SO2 PEC at the ecological receptors considered in this assessment is predicted as 1.97μg/m3. This value is 9.9% of the 20μg/m3 air quality standard and occurs at the Severn Estuary SPA/SAC/Ramsar/Bridgwater Bay SSSI.
Predicted SO2 concentrations at all ecological receptors considered in the assessment for the routine test scenario are detailed in Table E18 of Appendix E.
Deposition
The maximum nitrogen and acid deposition rates at the ecological receptors considered in this assessment are predicted as 0.25kg N ha-1 y-1 and 0.04keq ha-1 y-1, respectively. The significance of these values is discussed elsewhere and is not part of the scope of this document.
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Predicted deposition rates at all ecological receptors considered in the assessment for the routine test scenario are detailed in Table E20 of Appendix E. Figure 19 and Figure 20 illustrate the nitrogen and acid deposition fluxes, respectively, predicted for the routine test scenario.
3.2.6 LOOP scenario (24 hour event) – ecological receptor results
As discussed in section 2.1.1, annual mean concentrations resulting from a LOOP event have not been assessed due to the short term nature of the release which is unlikely to contribute significantly to concentrations averaged over longer time periods. In this regard, deposition estimates have not been provided since the critical loads are based on the deposition of nitrogen and acid equivalents over the period of a year.
NOx concentrations
The maximum 24-hour mean NOx PEC at the ecological receptors considered in this assessment is predicted as 933μg/m3. This value is 1,275% of the 75μg/m3 environmental assessment level and occurs at the Bridgwater Bay SSSI/Severn Estuary SAC/SPA/Ramsar. However, as for the commissioning and test scenario, it is considered that greater emphasis should be placed on achievement with the
more established NOx annual mean air quality standard, for which contributions from the LOOP scenario, averaged over the period of a year, are likely to be negligible.
It should also be noted that this is a conservative estimate based on a 24 hour LOOP event (25 continuous hours of operation of eight EDGs). As discussed in section, such an event is highly unlikely, with most LOOP events, should they actually occur (which, in itself, has a low probability of occurrence), lasting for a maximum duration of only 2 hours. As such, the contribution to 24 hour mean concentrations will be considerably less than that predicted above.
Predicted NOx concentrations at all ecological receptors considered in the assessment for the routine test scenario are detailed in Table E19 of Appendix E.
Figure 21 illustrates the 24-hour mean NOx concentrations predicted for the LOOP scenario.
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4.0 CONCLUSIONS
The H1 assessments undertaken failed to screen out the majority of operational emissions to air from requiring detailed dispersion modelling.
The operational dispersion modelling study adopted a cautious approach, with predicted concentrations and number of exceedences of air quality objectives being an extreme worse-case. For the purposes of this study, the following assumptions were made, which will lead to a significant overestimate of the predicted pollutant concentrations and the number of exceedences of the short- term air quality objective limit concentration values:
x Emissions from the EDGs and SBOs have been assumed to be discharged for every 1-hour meteorological line of data for a full calendar year when, in reality, each EDG and each SBO will only run for 60 hours per year during routine testing and for 242.5 hours and 738 hours, respectively, during the commissioning phase;
x The use of 2009 background concentration data were used as opposed to lower predicted background values in future years.
The assessment has determined that breaches of the air quality standard/objective/environmental assessment levels for the pollutants considered in this study are unlikely at all human receptors assessed during the commissioning routine plant test and 2 hour LOOP event scenarios. Exceedences of the 99.79
percentile 1-hour mean NO2 air quality standard were predicted at certain foot path receptors. However, for a breach of the air quality standard to occur at these locations would require a member of the public to be present in this area for a total period of 18 hours during the LOOP event which is extremely unlikely.
Breaches of the non-statutory 24-hour mean NOx guideline value at Bridgwater Bay NNR and Bridgwater Bay SSSI/Severn Estuary SPA/SAC/Ramsar were predicted by the assessment for the commissioning and routine test scenarios. However, for this to occur, it would require continuous operation of an EDG over a full 24-hour period, which is unlikely to occur in practice. It is also considered that greater emphasis should be placed on achievement with the more established statutory
annual mean NOx air quality standard due to the uncertainty in the 24-hour guideline.
Additionally, breaches of the non-statutory 24-hour mean NOx guideline value at these receptors were predicted for the 24 hour LOOP scenario. However, such an event is highly unlikely; most LOOP events, should they occur, will last for a maximum duration of only 2 hours and there is a low probability of a LOOP event actually occurring. Consequently, adverse effects on ecological receptors are considered highly unlikely.
As breaches of the air quality standard/objective/environmental assessment levels are unlikely during the actual operation of the plant, the assessment concludes that
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emissions discharged to air from the commissioning and operation of the EPR units do not pose a significant concern with regards to air quality.
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5.0 REFERENCES
1 Environment Agency. H1 Environmental Risk Assessment. Annex (f) – Air emissions (2010).
2 Hinkley Point C Combustion Activity Permit Application - Additional Air Quality Modelling to Cover LOOP Scenario WME/HPC/TECH/10/250 (2010).
3 Environment Agency. How to comply with your environmental permit. Additional guidance for: Combustion Activities (EPR 1.01) (2009).
4 Department for Environment, Food and Rural Affairs (Defra). UK Air Quality Archive (2010) http://laqm1.defra.gov.uk/review/tools/background-maps-info.php?year=2008
5 Department for Environment, Food and Rural Affairs (Defra). Local Air Quality Management Technical Guidance LAQM.TG(09) (2009).
6 Cambridge Environmental Research Consultants (CERC) Ltd. ADMS 4 – User Guide version 4.2 (2010).
7 Fangmeier, A. et al. Effects of Atmospheric Ammonia on Vegetation – A Review, Environmental Pollution, 86 (1994).
8 Chamberlin, A.C. and Chadwick, R.C. Deposition of Airborne Radioactive Vapour. Nucleonics, 11, 22-25 (1953).
9 Environment Agency. Technical Guidance on Detailed Modelling Approach for an Appropriate Assessment for Emissions to Air, AQTAG06 Working Draft Version 9, 12/05/06 (2006).
10 Nilsson, J. and Grennfelt, P. Critical Loads for Sulphur and Nitrogen. Miljorapport 1988:15. Nordic Council of Ministers, Copenhagen (1988).
11 HMSO. SI 2010/1001: Environmental Protection - The Air Quality Standards Regulations 2010 (2010).
12 Gillani, M.V. and Pliem, J.E. Sub-Grid Scale Features of Anthropogenic Emissions of NOx and VOC in the Context of Regional Eulerian Models. Atmospheric Environment, 30, 2043- 2059 (1996).
13 World Health Organization (WHO). Air Quality Guidelines for Europe (2000).
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FIGURES
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Figure 1: Buildings and stacks set up in the ADMS model for EPR units C1 and C2
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Figure 2: Wind rose for Hinkley Point for 2005 Figure 4: Wind rose for Hinkley Point for 2007 Figure 6: Wind rose for Hinkley Point for 2009
350° 0° 10° 340° 4000 20° 350° 0° 10° 350° 0° 10° 330° 30° 340° 20° 340° 20° 800 1000 320° 40° 330° 30° 330° 30° 3000 320° 40° 320° 40° 310° 50° 600 800 310° 50° 310° 50° 300° 60° 2000 300° 60° 600 400 300° 60° 290° 70° 290° 70° 290° 400 70° 1000 200 280° 80° 280° 80° 280° 200 80° 270° 90° 270° 90° 270° 90° 260° 100° 260° 100° 260° 100° 250° 110° 250° 110° 250° 110° 240° 120° 240° 120° 240° 120° 230° 130° 230° 130° 220° 140° 230° 130° 220° 140° 210° 150° 220° 140° 200° 160° 210° 150° 210° 150° 190° 180° 170° 200° 160° 0 3 6 10 16 (knots) 200° 160° 190° 170° 190° 180° 170° 180° Wind speed 0 3 6 10 16 (knots) 0 3 6 10 16 (knots) 0 1.5 3.1 5.1 8.2 (m/s) Wind speed Wi n d sp e e d 0 1.5 3.1 5.1 8.2 (m/s) 0 1.5 3.1 5.1 8.2 (m/s)
Figure 3: Wind rose for Hinkley Point for 2006 Figure 5: Wind rose for Hinkley Point for 2008 Figure 7: Wind rose for Hinkley Point for 2005 to 2009
350° 0° 10° 0° 0° 340° 800 20° 350° 10° 350° 10° 330° 30° 340° 800 20° 340° 5000 20° 330° 30° 330° 30° 320° 40° 320° 40° 320° 40° 600 4000 310° 50° 600 310° 50° 310° 50° 300° 60° 3000 400 300° 60° 300° 60° 400 290° 70° 290° 70° 290° 2000 70° 200 280° 80° 200 280° 80° 280° 1000 80° 270° 90° 270° 90° 270° 90° 260° 100° 260° 100° 260° 100° 250° 110° 250° 110° 250° 110° 240° 120° 240° 120° 240° 120° 230° 130° 230° 130° 220° 140° 230° 130° 210° 150° 220° 140° 220° 140° 200° 160° 210° 150° 210° 150° 190° 180° 170° 200° 160° 200° 160° 0 3 6 10 16 (knots) 190° 180° 170° 190° 180° 170° Wind speed 0 3 6 10 16 (knots) 0 3 6 10 16 (knots) 0 1.5 3.1 5.1 8.2 (m/s) Wind speed Wind speed 0 1.5 3.1 5.1 8.2 (m/s) 0 1.5 3.1 5.1 8.2 (m/s)
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Figure 8: Locations of local human receptor points in the ADMS model
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Figure 9: Locations of ecological designated sites in close proximity to Hinkley Point
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3 Figure 10: Predicted annual mean NO2 concentrations (μg/m ) for Commissioning scenario
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th 3 Figure 11: Predicted 99.79 percentile 1-hour mean NO2 concentrations (μg/m ) for Commissioning and Routine Test scenarios
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3 Figure 12: Predicted annual mean NO2 concentrations (μg/m ) for Routine Test scenario
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3 Figure 13: Predicted annual mean NO2 concentrations (μg/m ) for LOOP scenario
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3 Figure 14: Predicted annual mean NOx concentrations (μg/m ) for Commissioning scenario
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3 Figure 15: Predicted 24-hour mean NOx concentrations (μg/m ) for Commissioning and Routine Test scenarios
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Figure 16: Predicted nitrogen deposition flux (kg N ha-1 y-1) for Commissioning scenario
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Figure 17: Predicted acid deposition flux (keq ha-1 y-1) for Commissioning scenario
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3 Figure 18: Predicted annual mean NOx concentrations (μg/m ) for Routine Test scenario
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Figure 19: Predicted nitrogen deposition flux (kg N ha-1 y-1) for Routine Test scenario
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Figure 20: Predicted acid deposition flux (keq ha-1 y-1) for Routine Test scenario
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3 Figure 21: Predicted 24-hour mean NOx concentrations (μg/m ) for LOOP scenario
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APPENDIX A
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INPUT PARAMETERS FOR H1 SCREENING ASSESSMENTS
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Table A1: Input data for commissioning H1 screening assessment
Substance Physical height Effective height Release rate of Dispersion factor, Dispersion factor, Long-term Short-term Process released of release of release substance, RR DFlong-term DFshort-term conversion conversion to air (m) (m) (g/s) (μg/m3/g/s) (μg/m3/g/s) factor factor
SO2 15-min 30 0 2.93 148 3900 0.02768 1.34
SO2 1-hr 30 0 2.93 - 3900 - 1.00
SO2 24-hr 30 0 2.93 - 3900 - 0.59
NO2 30 0 30.66 148 3900 0.02768 1.00 Exhaust gases from engines of backup diesel generators during commissioning (EDGs) NOx 30 0 30.66 148 3900 0.02768 0.59 CO 30 0 2.41 - 3900 - 0.70 CO 30 0 2.41 - 3900 - 1.00
PM10 30 0 0.80 148 3900 0.02768 0.59
PM2.5 30 0 0.80 148 - 0.02768 -
SO2 15-min 30 0 0.40 148 3900 0.08425 1.34
SO2 1-hr 30 0 0.40 - 3900 - 1.00
SO2 24-hr 30 0 0.40 - 3900 - 0.59 NO 30 0 6.80 148 3900 0.08425 1.00 Exhaust gases from engines of backup diesel 2 generators during commissioning (SBOs) NOx 30 0 6.80 148 3900 0.08425 0.59 CO 30 0 0.57 - 3900 - 0.70 CO 30 0 0.57 - 3900 - 1.00
PM10 30 0 0.19 148 3900 0.08425 0.59
PM2.5 30 0 0.19 148 - 0.08425 -
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Table A2: Input data for routine test H1 screening assessment
Substance Physical height Effective height Release rate of Dispersion factor, Dispersion factor, Long-term Short-term Process released of release of release substance, RR DFlong-term DFshort-term conversion conversion to air (m) (m) (g/s) (μg/m3/g/s) (μg/m3/g/s) factor factor
SO2 15-min 30 0 2.93 148 3900 0.00685 1.34
SO2 1-hr 30 0 2.93 - 3900 - 1.00
SO2 24-hr 30 0 2.93 - 3900 - 0.59
NO2 30 0 30.66 148 3900 0.00685 1.00 Exhaust gases from engines of backup diesel generators during periodic testing (EDGs) NOx 30 0 30.66 148 3900 0.00685 0.59 CO 30 0 2.41 - 3900 - 0.70 CO 30 0 2.41 - 3900 - 1.00
PM10 30 0 0.80 148 3900 0.00685 0.59
PM2.5 30 0 0.80 148 - 0.00685 -
SO2 15-min 30 0 0.40 148 3900 0.00685 1.34
SO2 1-hr 30 0 0.40 - 3900 - 1.00
SO2 24-hr 30 0 0.40 - 3900 - 0.59 NO 30 0 6.80 148 3900 0.00685 1.00 Exhaust gases from engines of backup diesel 2 generators during periodic testing (SBOs) NOx 30 0 6.80 148 3900 0.00685 0.59 CO 30 0 0.57 - 3900 - 0.70 CO 30 0 0.57 - 3900 - 1.00
PM10 30 0 0.19 148 3900 0.00685 0.59
PM2.5 30 0 0.19 148 - 0.00685 -
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Table A3: Environmental Quality Standards (EQSs) and Environmental Assessment Levels (EALs) used in the H1 screening assessments
Human health EQS/EAL Ecological EQS/EAL Process Substance released Long-term Short-term Long-term Short-term to air (μg/m3) (μg/m3) (μg/m3) (μg/m3)
266 20 SO - - 2 15-min (15-minute mean) (annual mean) 350 SO - - - 2 1-hr (1-hour mean) 125 SO - - - 2 24-hr (24-hour mean) 40 200 NO 2 (annual mean) (1-hour mean) - - Exhaust gases from engines of backup diesel 30 75 generators (EDGs and SBOs) - commissioning and NO x - - (annual mean) (24-hour mean) operational phases 10000 CO - (8-hour mean) - - 30000 CO - (1-hour mean) 40 50 PM 10 (annual mean) (24-hour mean) - - 25 PM 2.5 (annual mean) - - -
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Table A4: Background pollutant concentrations used in H1 assessment Annual average Substance background Process released to concentration for air 2009 (μg/m3)
a SO2 1.8 b NO2 6.8 b Exhaust gases from engines of backup NOx 11.5 diesel generators during periodic testing CO c 78.5 b PM10 18.2 d PM2.5 7.9
a 2009 annual mean background concentration of SO2 assumed to be equal to 2008 annual mean SO2 concentration obtained from the baseline air quality monitoring campaign. Background concentration of formaldehyde assumed to be negligible.
b 2009 annual mean background concentrations of NO2, NOx and PM10 obtained by applying the ratio for 2008 to 2009 annual mean concentrations from Defra’s UK Air Quality Archive (average of the four 1km x 1km grid squares closest to Hinkley Point) to 2008 annual mean pollutant concentrations obtained from the baseline air quality monitoring campaign.
c Background concentration of carbon monoxide taken from Defra's UK Air Quality Archive (average of the four 1km x 1km grid squares closest to Hinkley Point). 2001 background map CO annual mean concentrations factored to 2009 using published Defra annual adjustment factors.
d 2009 annual mean background concentration of PM2.5 taken from Defra's UK Air Quality Archive (average of the four 1km x 1km grid squares closest to Hinkley Point).
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APPENDIX B
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INPUT PARAMETERS FOR ADMS 4 ASSESSMENTS
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Table B1: Stack parameters and emission rates for EDGs and SBOs and non-diesel generator emissions to air
Parameter Value Units EDG emissions Stack internal diameter 1.0 m Stack height 30.0 m Exit velocity 35 m/s Ambient temperature of discharge gases 375 ƕC
SO2 emission rate 2.93 g/s
NOx emission rate 30.66 g/s
PM10 emission rate 0.80 g/s CO emission rate 2.41 g/s SBO emissions Stack internal diameter 1.0 m Stack height 30.0 m Exit velocity 10.0 m/s Ambient temperature of discharge gases 515 ƕC
SO2 emission rate 0.40 g/s
NOx emission rate 6.80 g/s
PM10 emission rate 0.19 g/s CO emission rate 0.57 g/s
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Table B2: Building and stack data
Centre Centre Height Lengthor Breadth Anglefrom BuildingorStack location location Shape (m) diameter(m) (m) north(o) (easting) (northing) Buildings C1Ͳ1 320369 145927 46 119 63 0 rectangular C1Ͳ2 320369 145812 62 56ͲͲcircular C1Ͳ3 320381 145771 34 86 26 90 rectangular C1Ͳ4 320364 145854 30 73 29 90 rectangular C1Ͳ5 320411 145812 32 56 24 0 rectangular C1Ͳ6 320328 145812 32 56 24 0 rectangular C2Ͳ1 320139 145927 46 119 63 0 rectangular C2Ͳ2 320139 145812 62 56ͲͲcircular C2Ͳ3 320151 145771 34 86 26 90 rectangular C2Ͳ4 320144 145854 30 73 29 90 rectangular C2Ͳ5 320181 145812 32 56 24 0 rectangular C2Ͳ6 320098 145812 32 56 24 0 rectangular C1Ͳ7 320460 145831 26 40 28 0 rectangular C2Ͳ7 320281 145831 26 40 28 0 rectangular C1Ͳ8 320228 145831 26 40 28 0 rectangular C2Ͳ8 320049 145831 26 40 28 0 rectangular AͲ1 320254 145928 35 66 82 90 rectangular AͲ2 320542 146081 16 37 137 90 rectangular AͲ3 320608 146080 25 65 150 90 rectangular AͲ4 320379 146045 16 82 55 90 rectangular AͲ5 320149 146045 16 82 55 90 rectangular AͲ6 320472 145948 13 39 31 90 rectangular AͲ7 320467 145890 16 25 24 90 rectangular AͲ8 320139 145680 13 64 28rectangular AͲ9 320003 145938 13 64 28rectangular Stacks EDG_2_C1b 320460 145831 30 1.00ͲͲcircular EDG_2_C2a 320281 145831 30 1.00ͲͲcircular EDG_2_C1a 320228 145831 30 1.00ͲͲcircular EDG_2_C2b 320049 145831 30 1.00ͲͲcircular EDG_1_C1b 320460 145821 30 1.00ͲͲcircular EDG_1_C2a 320281 145821 30 1.00ͲͲcircular EDG_1_C1a 320228 145821 30 1.00ͲͲcircular EDG_1_C2b 320049 145821 30 1.00ͲͲcircular SBO_C1b 320460 145841 30 1.00ͲͲcircular SBO_C2a 320281 145841 30 1.00ͲͲcircular SBO_C1a 320228 145841 30 1.00ͲͲcircular SBO_C2b 320049 145841 30 1.00ͲͲcircular
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Table B3: Locations of human and ecological discrete receptors Distance Bearing Receptor Easting Northing from stacks from stacks (m) a (o) a Human Receptors Trighern Farm 322655 145238 2439 103 Zipe Farm 321934 144561 2063 127 Wick Farm 321578 144620 1750 132 Doggetts 320599 144714 1126 164 Knighton Farm 319375 144512 1569 215 Shurton village 320185 144256 1541 184 Bullen Farm 319150 144550 1681 222 Point south of Knighton 319250 144250 1856 214 Burton village 319350 144050 1976 208 Warren`s Farm 319850 143981 1863 193 Newnham Bridge 320661 144169 1669 167 Wick village 321550 144550 1778 134 Gunter`s Grove 321158 144115 1895 152 Point west of Wick 321250 144650 1500 140 Caravan Park 321750 143950 2358 141 Wick Park Cottage 321650 143550 2629 149 Farringdon Hill Farm 321350 143450 2577 155 Kennels south Farringdon 321350 143250 2760 157 Idson Farm 322428 144387 2568 123 Upper Cock Farm 322950 143450 3553 131 Lower Cock Farm 323350 143350 3924 129 Woolstone Farm 323750 144350 3758 113 Chalcott Farm 323351 144813 3224 108 Whitewick Farm 323493 145272 3255 99 Stolford Farm 323163 145824 2883 89 Browns Cottage 323096 145123 2895 103 Little Dowdens Farm 322750 145650 2474 93 Cole Pool 319254 143674 2355 206 Stogursey 320260 143185 2609 180 Wick House Farm 321599 144541 1819 134 West End Cottage 322691 145607 2418 94 Footpath - Benhole Lane South 319715 144975 995 215 Footpath - Benhole Lane North 319561 145814 719 272 Footpath - Coastal 319858 146152 554 310 Pixies Mound 320890 145573 649 110 Ecological Receptors ER_1 Huntspill River NNR 329300 145600 9022 91 ER_2 Berrow Dunes SSSI 329700 150500 10530 63 ER_3 Blue Anchor To Lilstock Coast SSSI 318000 145200 2356 255 ER_4 Brean Down SSSI 329000 159000 15825 33 ER_5 Ge-Mare Farm Fields SSSI 315500 142400 5862 235 ER_6 The Quantocks SSSI 315200 141100 6917 227 ER_7 Roebuck Meadows SSSI 313200 135400 12576 214 ER_8 Roebuck Meadows SSSI 313400 135000 12800 213 ER_9 SSSI 329800 147600 9690 79 ER_10 Steep Holm SSSI 322800 160700 15118 10
a Distances and bearings calculated from the mid-point between the two EPR reactors.
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APPENDIX C
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AIR QUALITY STANDARDS AND OBJECTIVES
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Table C1: European Union Air Quality Standards and Objectives
Concentration Date to be Achieved Permitted Averaging Pollutant (μg/m3 unless and Maintained Exceedences Each Period otherwise stated) Thereafter Year
PM2.5 25 *** 1 year Target value enters n/a into force 1/1/2010. Limit value enters into force 1/1/2015. SO2 350 1 hour Limit value enters into 24 force 1/1/2005. 125 24 hours Limit value enters into 3 force 1/1/2005. NO2 200 1 hour Limit value enters into 18 force 1/1/2010 40 1 year Limit value enters into n/a force 1/1/2010. * PM10 50 24 hours Limit value enters into 35 force 1/1/2005. ** 40 1 year Limit value enters into n/a force 1/1/2005. ** Lead 0.5 1 year Limit value enters into n/a force 1/1/2005 (or 1/1/2010 in the immediate vicinity of specific, notified industrial sources; and a 1.0 μg/m3 limit value applies from 1/1/2005 to 31/12/2009). CO 10 mg/m3 Maximum daily Limit value enters into n/a 8 hour mean force 1/1/2005. Benzene 5 1 year Limit value enters into n/a force 1/1/2010. ** Ozone 120 Maximum daily Target value enters 25 days averaged 8 hour mean into force 1/1/2010. over 3 years Arsenic 6 ng/m3 1 year Target value enters n/a into force 1/1/2012. Cadmium 5 ng/m3 1 year Target value enters n/a into force 1/1/2012. Nickel 20 ng/m3 1 year Target value enters n/a into force 1/1/2012. Polycyclic 1 ng/m3 1 year Target value enters n/a Aromatic (expressed as into force 1/1/2012. Hydrocarbons concentration of Benzo(a)pyrene) * Under the new Directive the member State can apply for an extension of up to five years (i.e. maximum up to 2015) in a specific zone. Request is subject to assessment by the Commission. In such cases within the time extension period the limit value applies at the level of the limit value + maximum margin of 3 tolerance (48 μg/m for annual NO2 limit value). ** Under the new Directive the Member State can apply for an extension until three years after the date of entry into force of the new Directive (i.e. May 2011) in a specific zone. Request is subject to assessment by the Commission. In such cases within the time extension period the limit value applies at the level of 3 3 the limit value + maximum margin of tolerance (35 days at 75μg/m for daily PM10 limit value, 48 μg/m for annual PM10 limit value). *** Standard introduced by the new Directive.
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Title Metric Averaging Date to be Achieved Permitted Period and Maintained Exceedences Each Thereafter Year 3 PM2.5 20 μg/m Based on 3 year Legally binding in n/a Exposure (AEI) * average 2015 (years concentration 2013,2014,2015) obligation PM Based on 3 year n/a 2.5 Percentage Reduction to be Exposure average reduction reduction** attained where target + all measures to possible in 2020, reach 18 μg/m3 determined on the (AEI) basis of the value of exposure indicator in 2010
* Average Exposure Indicator. AEI is determined as a 3-year running annual mean PM2.5 concentration averaged over the selected monitoring stations in agglomerations and larger urban areas, set in urban background locations to best assess the PM2.5 exposure to the general population.
** Depending on the value of AEI in 2010, a percentage reduction requirement (0, 10, 15, or 20%) is set in the Directive. If AEI in 2010 is assessed to be over 22 μg/m3, all appropriate measures need to be taken to achieve 18μg/m3 by 2020.
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Table C2: UK National Air Quality Objectives
Concentration Date to be achieved by and Pollutant Applies National Air Quality Objective measured as maintained thereafter FOR THE PROTECTION OF HUMAN HEALTH
50 μg m-3 not to be exceeded UK 24 hour mean 31 December 2004 more than 35 times a year UK 40 μg m-3 Annual mean 31 December 2004
Indicative 2010 objectives for PM10 (from the 2000 Strategy and 2003 Addendum) have been replaced by Particles (PM10 ) an exposure reduction approach for PM2.5 (except in Scotland – see below). 50 μg m-3 not to be exceeded Scotland 24 hour mean 31 December 2010 more than 7 times a year Scotland 18 μg m-3 Annual mean 31 December 2010
UK (except -3 25 μg m 2020 Scotland) Particles (PM ) -3 2.5 Scotland 12 μg m 2020 Exposure Annual mean Reduction Target of 15% reduction in UK urban concentrations at urban Between 2010 and 2020 areas 1 background 200 μg m-3 not to be exceeded UK 1 hour mean 31 December 2005 more than 18 times a year NO2 UK 40 μg m-3 Annual mean 31 December 2005 100 μg m-3 not to be exceeded O UK 8 hour mean 31 December 2005 3 more than 10 times a year 266 μg m-3 not to be exceeded UK 15 minute mean 31 December 2005 more than 35 times a year 350 μg m-3 not to be exceeded SO UK 1 hour mean 31 December 2004 2 more than 24 times a year 125 μg m-3 not to be exceeded UK 24 hour mean 31 December 2004 more than 3 times a year Polycyclic aromatic UK 0.25 ng m-3 B[a]P As annual average 31 December 2010 hydrocarbons
-3 Running annual UK 16.25 μg m 31 December 2003 mean
England -3 5 μg m Annual average 31 December 2010 Benzene and Wales Scotland & -3 Running annual Northern 3.25 μg m 31 December 2010 mean Ireland
-3 Running annual 1,3 Butadiene UK 2.25 μg m 31 December 2003 mean Maximum daily running 8 hour CO UK 10 mg m-3 mean/in Scotland as 31 December 2003 running 8 hour mean UK 0.5 μg m-3 Annual mean 31 December 2004 Lead 0.25 μg m-3 Annual mean 31 December 2008
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Concentration Date to be achieved by and Pollutant Applies National Air Quality Objective measured as maintained thereafter FOR THE PROTECTION OF VEGETATION AND ECOSYSTEMS
-3 NOx UK 30 μg m Annual mean 31 December 2000 UK 20 μg m-3 Annual mean 31 December 2000 SO2 UK 20 μg m-3 Winter average 31 December 2000 Target value of 18,000 μg m-3 based on AOT40 to be calculated Average over 5 Ozone UK from 1 hour values from May to 1 January 2010 years July, and to be achieved, so far as possible, by 2010
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APPENDIX D
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RESULTS OF H1 SCREENING ASSESSMENTS
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Table D1: Short-term and long-term Process Contributions to air (PCair) calculated by H1 methodology for the Commissioning, Routine Test and LOOP event scenarios
Commissioning Routine Test LOOP Process Process Process Process Process
Contribution, PCair - Contribution, PCair - Contribution, PCair - Contribution, PCair - Contribution, Substance released to long short long short PCair - short air (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3)
SO2 15-min 116.0 15312.2 25.4 15312.2 122497.4
SO2 1-hr - 11427.0 - 11427.0 91416.0
SO2 24-hr - 6741.9 - 6741.9 53935.4
NO2 1344.1 59787.0 276.2 59787.0 478296.0
NOx 1344.1 70548.7 276.2 70548.7 564389.3
CO 8-hr - 6599.1 - 6593.5 52634.4
CO 1-hr - 9427.3 - 9419.2 75192.0
PM10 35.7 1840.8 7.3 1840.8 14726.4
PM2.5 35.7 - 7.3 - -
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Table D2: Comparison of short-term and long-term Process Contributions to air (PCair) of substances emitted to air for the Commissioning, Routine Test and LOOP event scenarios against the relevant EQS/EAL Commissioning Routine Test LOOP Human Human Health Human Health Ecological Ecological Ecological Substance released to Human Health Human Health Ecological Ecological Health air EQS/EAL PC EQS/EAL PC EQS/EAL PC EQS/EAL PC EQS/EAL EQS/EAL PC EQS/EAL PCair - EQS/EAL PCair - EQS/EAL PCair - EQS/EAL PCair - air - air - air - air - air - PC long short long short long short long short air - short short Insignificant? Insignificant? Insignificant? Insignificant? Insignificant? Insignificant? Insignificant? Insignificant? Insignificant? Insignificant?
SO2 15-min - No No - - No No - No -
SO2 1-hr - No - - - No - - No -
SO2 24-hr - No - - - No - - No -
NO2 No No - - No No - - No -
NOx - - No No - - No No - No
CO 8-hr - No - - - No - - No -
CO 1-hr - No - - - No - - No -
PM10 No No - - No No - - No -
PM2.5 No - - - No - - - - -
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Table D3: Identification of need for detailed modelling of emissions to air for the Commissioning, Routine Test and LOOP event scenarios using H1 methodology Commissioning Routine Test LOOP Human Health Ecological Human Health Ecological Human Health Ecological Substance released to Long-term Short-term Long-term Short-term Long-term Short-term Long-term Short-term Short-term Short-term air detailed detailed detailed detailed detailed detailed detailed detailed detailed detailed modelling modelling modelling modelling modelling modelling modelling modelling modelling modelling required? required? required? required? required? required? required? required? required? required?
SO2 15-min - Yes Yes - - Yes Yes - Yes -
SO2 1-hr - Yes - - - Yes - - Yes -
SO2 24-hr - Yes - - - Yes - - Yes -
NO2 Yes Yes - - Yes Yes - - Yes -
NOx - - Yes Yes - - Yes Yes - Yes
CO 8-hr - Yes - - - Yes - - Yes -
CO 1-hr - Yes - - - Yes - - Yes -
PM10 Yes Yes - - No Yes - - Yes -
PM2.5 Yes - - - No - - - - -
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APPENDIX E
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RESULTS OF ADMS 4 DISPERSION MODELLING
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Table E1: NO2 Concentrations at Human Receptors - Commissioning
Receptor AnnualMean 99.79%Ͳile1ͲhourMean %PECof %PECof AQS PC PEC AQS PC PEC AQS AQS TrighernFarm 40 0.98 7.78 19.4% 200 10.24 23.84 11.9% ZipeFarm 40 0.65 7.45 18.6% 200 11.64 25.24 12.6% WickFarm 40 0.62 7.42 18.6% 200 14.52 28.12 14.1% Doggetts 40 0.27 7.07 17.7% 200 21.20 34.80 17.4% KnightonFarm 40 0.46 7.26 18.1% 200 15.81 29.41 14.7% Shurtonvillage 40 0.19 6.99 17.5% 200 13.40 27.00 13.5% BullenFarm 40 0.48 7.28 18.2% 200 14.79 28.39 14.2% PtsthofKnighton 40 0.35 7.15 17.9% 200 12.71 26.31 13.2% Burtonvillage 40 0.28 7.08 17.7% 200 11.02 24.62 12.3% Warren`sFarm 40 0.20 7.00 17.5% 200 10.66 24.26 12.1% NewnhamBridge 40 0.14 6.94 17.4% 200 12.75 26.35 13.2% Wickvillage 40 0.53 7.33 18.3% 200 13.82 27.42 13.7% Gunter`sGrove 40 0.19 6.99 17.5% 200 10.78 24.38 12.2% PtwestofWick 40 0.50 7.30 18.3% 200 15.94 29.54 14.8% CaravanPark 40 0.24 7.04 17.6% 200 9.18 22.78 11.4% WickParkCottage 40 0.15 6.95 17.4% 200 7.79 21.39 10.7% FarringdonHillFarm 40 0.12 6.92 17.3% 200 7.51 21.11 10.6% KennelsSFarringdon 40 0.10 6.90 17.3% 200 7.30 20.90 10.4% IdsonFarm 40 0.56 7.36 18.4% 200 9.53 23.13 11.6% UpperCockFarm 40 0.25 7.05 17.6% 200 6.58 20.18 10.1% LowerCockFarm 40 0.25 7.05 17.6% 200 5.87 19.47 9.7% WoolstoneFarm 40 0.51 7.31 18.3% 200 6.39 19.99 10.0% ChalcottFarm 40 0.69 7.49 18.7% 200 7.66 21.26 10.6% WhitewickFarm 40 0.59 7.39 18.5% 200 7.77 21.37 10.7% StolfordFarm 40 0.49 7.29 18.2% 200 7.55 21.15 10.6% BrownsCottage 40 0.77 7.57 18.9% 200 8.50 22.10 11.1% LittleDowdensFar 40 0.74 7.54 18.9% 200 9.92 23.52 11.8% ColePool 40 0.21 7.01 17.5% 200 8.78 22.38 11.2% Stogursey 40 0.10 6.90 17.2% 200 7.82 21.42 10.7% WickHouseFarm 40 0.54 7.34 18.4% 200 13.44 27.04 13.5% WestEndCottage 40 0.80 7.60 19.0% 200 10.14 23.74 11.9% FPͲBenholeLaneS ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ 200 35.91 49.51 24.8% FPͲBenholeLaneN ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ 200 73.43 87.03 43.5% FPͲCoastal ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ 200 101.54 115.14 57.6% PixiesMound ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ 200 74.23 87.83 43.9%
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Table E2: PM10 Concentrations at Human Receptors – Commissioning
Receptor AnnualMean 90.41%Ͳile24ͲhourMean %PECof %PECof AQS PC PEC AQS PC PEC AQS AQS TrighernFarm 40 0.04 18.24 45.6% 50 0.19 36.59 73.2% ZipeFarm 40 0.02 18.22 45.6% 50 0.20 36.60 73.2% WickFarm 40 0.02 18.22 45.6% 50 0.21 36.61 73.2% Doggetts 40 0.01 18.21 45.5% 50 0.19 36.59 73.2% KnightonFarm 40 0.02 18.22 45.5% 50 0.15 36.55 73.1% Shurtonvillage 40 0.01 18.21 45.5% 50 0.12 36.52 73.0% BullenFarm 40 0.02 18.22 45.5% 50 0.17 36.57 73.1% PtsthofKnighton 40 0.01 18.21 45.5% 50 0.12 36.52 73.0% Burtonvillage 40 0.01 18.21 45.5% 50 0.10 36.50 73.0% Warren`sFarm 40 0.01 18.21 45.5% 50 0.09 36.49 73.0% NewnhamBridge 40 0.01 18.21 45.5% 50 0.12 36.52 73.0% Wickvillage 40 0.02 18.22 45.5% 50 0.19 36.59 73.2% Gunter`sGrove 40 0.01 18.21 45.5% 50 0.10 36.50 73.0% PtwestofWick 40 0.02 18.22 45.5% 50 0.21 36.61 73.2% CaravanPark 40 0.01 18.21 45.5% 50 0.10 36.50 73.0% WickParkCottage 40 0.01 18.21 45.5% 50 0.07 36.47 72.9% FarringdonHillFarm 40 0.00 18.20 45.5% 50 0.06 36.46 72.9% KennelsSFarringdon 40 0.00 18.20 45.5% 50 0.05 36.45 72.9% IdsonFarm 40 0.02 18.22 45.6% 50 0.16 36.56 73.1% UpperCockFarm 40 0.01 18.21 45.5% 50 0.08 36.48 73.0% LowerCockFarm 40 0.01 18.21 45.5% 50 0.07 36.47 72.9% WoolstoneFarm 40 0.02 18.22 45.5% 50 0.11 36.51 73.0% ChalcottFarm 40 0.03 18.23 45.6% 50 0.13 36.53 73.1% WhitewickFarm 40 0.02 18.22 45.6% 50 0.11 36.51 73.0% StolfordFarm 40 0.02 18.22 45.5% 50 0.08 36.48 73.0% BrownsCottage 40 0.03 18.23 45.6% 50 0.15 36.55 73.1% LittleDowdensFar 40 0.03 18.23 45.6% 50 0.13 36.53 73.1% ColePool 40 0.01 18.21 45.5% 50 0.07 36.47 72.9% Stogursey 40 0.00 18.20 45.5% 50 0.06 36.46 72.9% WickHouseFarm 40 0.02 18.22 45.6% 50 0.19 36.59 73.2% WestEndCottage 40 0.03 18.23 45.6% 50 0.15 36.55 73.1%
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Table E3: PM2.5 Concentrations at Human Receptors – Commissioning
Receptor AnnualMean %PECof AQS PC PEC AQS TrighernFarm 25 0.04 7.94 31.7% ZipeFarm 25 0.02 7.92 31.7% WickFarm 25 0.02 7.92 31.7% Doggetts 25 0.01 7.91 31.6% KnightonFarm 25 0.02 7.92 31.7% Shurtonvillage 25 0.01 7.91 31.6% BullenFarm 25 0.02 7.92 31.7% PtsthofKnighton 25 0.01 7.91 31.7% Burtonvillage 25 0.01 7.91 31.6% Warren`sFarm 25 0.01 7.91 31.6% NewnhamBridge 25 0.01 7.91 31.6% Wickvillage 25 0.02 7.92 31.7% Gunter`sGrove 25 0.01 7.91 31.6% PtwestofWick 25 0.02 7.92 31.7% CaravanPark 25 0.01 7.91 31.6% WickParkCottage 25 0.01 7.91 31.6% FarringdonHillFarm 25 0.00 7.90 31.6% KennelsSFarringdon 25 0.00 7.90 31.6% IdsonFarm 25 0.02 7.92 31.7% UpperCockFarm 25 0.01 7.91 31.6% LowerCockFarm 25 0.01 7.91 31.6% WoolstoneFarm 25 0.02 7.92 31.7% ChalcottFarm 25 0.03 7.93 31.7% WhitewickFarm 25 0.02 7.92 31.7% StolfordFarm 25 0.02 7.92 31.7% BrownsCottage 25 0.03 7.93 31.7% LittleDowdensFar 25 0.03 7.93 31.7% ColePool 25 0.01 7.91 31.6% Stogursey 25 0.00 7.90 31.6% WickHouseFarm 25 0.02 7.92 31.7% WestEndCottage 25 0.03 7.93 31.7%
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E4: CO Concentrations at Human Receptors – Commissioning
Receptor 1ͲhourMean Rolling8ͲhourMean %PECof %PECof EAL PC PEC AQS PC PEC EAL AQS TrighernFarm 30000 3 160 0.5% 10000 2 159 1.6% ZipeFarm 30000 4 161 0.5% 10000 2 159 1.6% WickFarm 30000 4 161 0.5% 10000 2 159 1.6% Doggetts 30000 6 163 0.5% 10000 4 161 1.6% KnightonFarm 30000 4 161 0.5% 10000 3 160 1.6% Shurtonvillage 30000 4 161 0.5% 10000 2 159 1.6% BullenFarm 30000 5 162 0.5% 10000 3 160 1.6% PtsthofKnighton 30000 4 161 0.5% 10000 2 159 1.6% Burtonvillage 30000 3 160 0.5% 10000 2 159 1.6% Warren`sFarm 30000 3 160 0.5% 10000 2 159 1.6% NewnhamBridge 30000 4 161 0.5% 10000 2 159 1.6% Wickvillage 30000 4 161 0.5% 10000 2 159 1.6% Gunter`sGrove 30000 3 160 0.5% 10000 2 159 1.6% PtwestofWick 30000 5 162 0.5% 10000 3 160 1.6% CaravanPark 30000 3 160 0.5% 10000 2 159 1.6% WickParkCottage 30000 3 160 0.5% 10000 1 158 1.6% FarringdonHillFarm 30000 2 159 0.5% 10000 1 158 1.6% KennelsSFarringdon 30000 2 159 0.5% 10000 1 158 1.6% IdsonFarm 30000 3 160 0.5% 10000 2 159 1.6% UpperCockFarm 30000 2 159 0.5% 10000 1 158 1.6% LowerCockFarm 30000 2 159 0.5% 10000 1 158 1.6% WoolstoneFarm 30000 2 159 0.5% 10000 1 158 1.6% ChalcottFarm 30000 2 159 0.5% 10000 2 159 1.6% WhitewickFarm 30000 2 159 0.5% 10000 1 158 1.6% StolfordFarm 30000 3 160 0.5% 10000 2 159 1.6% BrownsCottage 30000 3 160 0.5% 10000 2 159 1.6% LittleDowdensFar 30000 3 160 0.5% 10000 2 159 1.6% ColePool 30000 3 160 0.5% 10000 2 159 1.6% Stogursey 30000 2 159 0.5% 10000 1 158 1.6% WickHouseFarm 30000 4 161 0.5% 10000 2 159 1.6% WestEndCottage 30000 3 160 0.5% 10000 2 159 1.6% FPͲBenholeLaneS 30000 8 165 0.6% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲBenholeLaneN 30000 17 174 0.6% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲCoastal 30000 24 181 0.6% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ PixiesMound 30000 25 182 0.6% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E5: SO2 Concentrations at Human Receptors – Commissioning
Receptor 99.9%Ͳile15ͲminuteMean 99.73%Ͳileof1ͲhourMean 99.18%Ͳileof24ͲhourMean %PECof %PECof %PECof AQO PC PEC AQS PC PEC AQS PC PEC AQO AQS AQS TrighernFarm 266 4.44 8.04 3.0% 350 2.76 6.36 1.8% 125 1.30 4.90 3.9% ZipeFarm 266 4.63 8.23 3.1% 350 3.16 6.76 1.9% 125 1.32 4.92 3.9% WickFarm 266 5.35 8.95 3.4% 350 3.91 7.51 2.1% 125 1.39 4.99 4.0% Doggetts 266 7.23 10.83 4.1% 350 5.76 9.36 2.7% 125 2.51 6.11 4.9% KnightonFarm 266 5.58 9.18 3.5% 350 4.21 7.81 2.2% 125 2.21 5.81 4.6% Shurtonvillage 266 4.96 8.56 3.2% 350 3.50 7.10 2.0% 125 1.83 5.43 4.3% BullenFarm 266 5.19 8.79 3.3% 350 3.91 7.51 2.1% 125 1.83 5.43 4.3% PtsthofKnighton 266 4.66 8.26 3.1% 350 3.37 6.97 2.0% 125 1.65 5.25 4.2% Burtonvillage 266 4.06 7.66 2.9% 350 2.90 6.50 1.9% 125 1.50 5.10 4.1% Warren`sFarm 266 3.90 7.50 2.8% 350 2.81 6.41 1.8% 125 1.39 4.99 4.0% NewnhamBridge 266 4.60 8.20 3.1% 350 3.34 6.94 2.0% 125 1.31 4.91 3.9% Wickvillage 266 5.30 8.90 3.3% 350 3.71 7.31 2.1% 125 1.37 4.97 4.0% Gunter`sGrove 266 4.04 7.64 2.9% 350 2.88 6.48 1.9% 125 1.10 4.70 3.8% PtwestofWick 266 6.02 9.62 3.6% 350 4.24 7.84 2.2% 125 1.95 5.55 4.4% CaravanPark 266 3.67 7.27 2.7% 350 2.35 5.95 1.7% 125 0.89 4.49 3.6% WickParkCottage 266 2.97 6.57 2.5% 350 2.08 5.68 1.6% 125 0.68 4.28 3.4% FarringdonHillFarm 266 2.98 6.58 2.5% 350 2.03 5.63 1.6% 125 0.63 4.23 3.4% KennelsSFarringdon 266 2.84 6.44 2.4% 350 1.94 5.54 1.6% 125 0.55 4.15 3.3% IdsonFarm 266 3.85 7.45 2.8% 350 2.55 6.15 1.8% 125 1.01 4.61 3.7% UpperCockFarm 266 2.66 6.26 2.4% 350 1.75 5.35 1.5% 125 0.52 4.12 3.3% LowerCockFarm 266 2.70 6.30 2.4% 350 1.52 5.12 1.5% 125 0.48 4.08 3.3% WoolstoneFarm 266 3.02 6.62 2.5% 350 1.72 5.32 1.5% 125 0.80 4.40 3.5% ChalcottFarm 266 3.60 7.20 2.7% 350 2.04 5.64 1.6% 125 0.97 4.57 3.7% WhitewickFarm 266 3.58 7.18 2.7% 350 1.97 5.57 1.6% 125 0.73 4.33 3.5% StolfordFarm 266 3.75 7.35 2.8% 350 1.91 5.51 1.6% 125 0.63 4.23 3.4% BrownsCottage 266 3.96 7.56 2.8% 350 2.22 5.82 1.7% 125 1.02 4.62 3.7% LittleDowdensFar 266 4.30 7.90 3.0% 350 2.57 6.17 1.8% 125 0.81 4.41 3.5% ColePool 266 3.40 7.00 2.6% 350 2.32 5.92 1.7% 125 1.10 4.70 3.8% Stogursey 266 2.99 6.59 2.5% 350 1.99 5.59 1.6% 125 0.82 4.42 3.5% WickHouseFarm 266 5.11 8.71 3.3% 350 3.60 7.20 2.1% 125 1.32 4.92 3.9% WestEndCottage 266 4.80 8.40 3.2% 350 2.64 6.24 1.8% 125 0.92 4.52 3.6% FPͲBenholeLaneS 266 10.26 13.86 5.2% 350 7.94 11.54 3.3% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲBenholeLaneN 266 21.98 25.58 9.6% 350 17.71 21.31 6.1% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲCoastal 266 31.27 34.87 13.1% 350 26.97 30.57 8.7% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ PixiesMound 266 26.74 30.34 11.4% 350 19.70 23.30 6.7% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E6: NO2 Concentrations at Human Receptors – Routine Test Receptor AnnualMean 99.79%Ͳile1ͲhourMean %PECof %PECof AQS PC PEC AQS PC PEC AQS AQS TrighernFarm 40 0.14 6.94 17.4% 200 10.24 23.84 11.9% ZipeFarm 40 0.10 6.90 17.2% 200 11.64 25.24 12.6% WickFarm 40 0.09 6.89 17.2% 200 14.52 28.12 14.1% Doggetts 40 0.04 6.84 17.1% 200 21.20 34.80 17.4% KnightonFarm 40 0.07 6.87 17.2% 200 15.81 29.41 14.7% Shurtonvillage 40 0.03 6.83 17.1% 200 13.40 27.00 13.5% BullenFarm 40 0.07 6.87 17.2% 200 14.79 28.39 14.2% PtsthofKnighton 40 0.05 6.85 17.1% 200 12.71 26.31 13.2% Burtonvillage 40 0.04 6.84 17.1% 200 11.02 24.62 12.3% Warren`sFarm 40 0.03 6.83 17.1% 200 10.66 24.26 12.1% NewnhamBridge 40 0.02 6.82 17.1% 200 12.75 26.35 13.2% Wickvillage 40 0.08 6.88 17.2% 200 13.82 27.42 13.7% Gunter`sGrove 40 0.03 6.83 17.1% 200 10.78 24.38 12.2% PtwestofWick 40 0.07 6.87 17.2% 200 15.94 29.54 14.8% CaravanPark 40 0.04 6.84 17.1% 200 9.18 22.78 11.4% WickParkCottage 40 0.02 6.82 17.1% 200 7.79 21.39 10.7% FarringdonHillFarm 40 0.02 6.82 17.0% 200 7.51 21.11 10.6% KennelsSFarringdon 40 0.02 6.82 17.0% 200 7.30 20.90 10.4% IdsonFarm 40 0.08 6.88 17.2% 200 9.53 23.13 11.6% UpperCockFarm 40 0.04 6.84 17.1% 200 6.58 20.18 10.1% LowerCockFarm 40 0.04 6.84 17.1% 200 5.87 19.47 9.7% WoolstoneFarm 40 0.07 6.87 17.2% 200 6.39 19.99 10.0% ChalcottFarm 40 0.10 6.90 17.3% 200 7.66 21.26 10.6% WhitewickFarm 40 0.09 6.89 17.2% 200 7.77 21.37 10.7% StolfordFarm 40 0.07 6.87 17.2% 200 7.55 21.15 10.6% BrownsCottage 40 0.11 6.91 17.3% 200 8.50 22.10 11.1% LittleDowdensFar 40 0.11 6.91 17.3% 200 9.92 23.52 11.8% ColePool 40 0.03 6.83 17.1% 200 8.78 22.38 11.2% Stogursey 40 0.01 6.81 17.0% 200 7.82 21.42 10.7% WickHouseFarm 40 0.08 6.88 17.2% 200 13.44 27.04 13.5% WestEndCottage 40 0.12 6.92 17.3% 200 10.14 23.74 11.9% FPͲBenholeLaneS ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ 200 35.91 49.51 24.8% FPͲBenholeLaneN ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ 200 73.43 87.03 43.5% FPͲCoastal ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ 200 101.54 115.14 57.6% PixiesMound ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ 200 74.23 87.83 43.9%
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E7: PM10 Concentrations at Human Receptors – Routine Test Receptor AnnualMean 90.41%Ͳile24ͲhourMean %PECof %PECof AQS PC PEC AQS PC PEC AQS AQS TrighernFarm 40 0.01 18.21 45.5% 50 0.19 36.59 73.2% ZipeFarm 40 0.00 18.20 45.5% 50 0.20 36.60 73.2% WickFarm 40 0.00 18.20 45.5% 50 0.21 36.61 73.2% Doggetts 40 0.00 18.20 45.5% 50 0.19 36.59 73.2% KnightonFarm 40 0.00 18.20 45.5% 50 0.15 36.55 73.1% Shurtonvillage 40 0.00 18.20 45.5% 50 0.12 36.52 73.0% BullenFarm 40 0.00 18.20 45.5% 50 0.17 36.57 73.1% PtsthofKnighton 40 0.00 18.20 45.5% 50 0.12 36.52 73.0% Burtonvillage 40 0.00 18.20 45.5% 50 0.10 36.50 73.0% Warren`sFarm 40 0.00 18.20 45.5% 50 0.09 36.49 73.0% NewnhamBridge 40 0.00 18.20 45.5% 50 0.12 36.52 73.0% Wickvillage 40 0.00 18.20 45.5% 50 0.19 36.59 73.2% Gunter`sGrove 40 0.00 18.20 45.5% 50 0.10 36.50 73.0% PtwestofWick 40 0.00 18.20 45.5% 50 0.21 36.61 73.2% CaravanPark 40 0.00 18.20 45.5% 50 0.10 36.50 73.0% WickParkCottage 40 0.00 18.20 45.5% 50 0.07 36.47 72.9% FarringdonHillFarm 40 0.00 18.20 45.5% 50 0.06 36.46 72.9% KennelsSFarringdon 40 0.00 18.20 45.5% 50 0.05 36.45 72.9% IdsonFarm 40 0.00 18.20 45.5% 50 0.16 36.56 73.1% UpperCockFarm 40 0.00 18.20 45.5% 50 0.08 36.48 73.0% LowerCockFarm 40 0.00 18.20 45.5% 50 0.07 36.47 72.9% WoolstoneFarm 40 0.00 18.20 45.5% 50 0.11 36.51 73.0% ChalcottFarm 40 0.00 18.20 45.5% 50 0.13 36.53 73.1% WhitewickFarm 40 0.00 18.20 45.5% 50 0.11 36.51 73.0% StolfordFarm 40 0.00 18.20 45.5% 50 0.08 36.48 73.0% BrownsCottage 40 0.00 18.20 45.5% 50 0.15 36.55 73.1% LittleDowdensFar 40 0.00 18.20 45.5% 50 0.13 36.53 73.1% ColePool 40 0.00 18.20 45.5% 50 0.07 36.47 72.9% Stogursey 40 0.00 18.20 45.5% 50 0.06 36.46 72.9% WickHouseFarm 40 0.00 18.20 45.5% 50 0.19 36.59 73.2% WestEndCottage 40 0.00 18.20 45.5% 50 0.15 36.55 73.1%
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E8: PM2.5 Concentrations at Human Receptors – Routine Test
Receptor AnnualMean %PECof AQS PC PEC AQS TrighernFarm 25 0.01 7.91 31.6% ZipeFarm 25 0.00 7.90 31.6% WickFarm 25 0.00 7.90 31.6% Doggetts 25 0.00 7.90 31.6% KnightonFarm 25 0.00 7.90 31.6% Shurtonvillage 25 0.00 7.90 31.6% BullenFarm 25 0.00 7.90 31.6% PtsthofKnighton 25 0.00 7.90 31.6% Burtonvillage 25 0.00 7.90 31.6% Warren`sFarm 25 0.00 7.90 31.6% NewnhamBridge 25 0.00 7.90 31.6% Wickvillage 25 0.00 7.90 31.6% Gunter`sGrove 25 0.00 7.90 31.6% PtwestofWick 25 0.00 7.90 31.6% CaravanPark 25 0.00 7.90 31.6% WickParkCottage 25 0.00 7.90 31.6% FarringdonHillFarm 25 0.00 7.90 31.6% KennelsSFarringdon 25 0.00 7.90 31.6% IdsonFarm 25 0.00 7.90 31.6% UpperCockFarm 25 0.00 7.90 31.6% LowerCockFarm 25 0.00 7.90 31.6% WoolstoneFarm 25 0.00 7.90 31.6% ChalcottFarm 25 0.00 7.90 31.6% WhitewickFarm 25 0.00 7.90 31.6% StolfordFarm 25 0.00 7.90 31.6% BrownsCottage 25 0.00 7.90 31.6% LittleDowdensFar 25 0.00 7.90 31.6% ColePool 25 0.00 7.90 31.6% Stogursey 25 0.00 7.90 31.6% WickHouseFarm 25 0.00 7.90 31.6% WestEndCottage 25 0.00 7.90 31.6%
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E9: CO Concentrations at Human Receptors – Routine Test
Receptor 1ͲhourMean Rolling8ͲhourMean %PECof %PECof EAL PC PEC AQS PC PEC EAL AQS TrighernFarm 30000 3 160 0.5% 10000 2 159 1.6% ZipeFarm 30000 4 161 0.5% 10000 2 159 1.6% WickFarm 30000 4 161 0.5% 10000 2 159 1.6% Doggetts 30000 6 163 0.5% 10000 4 161 1.6% KnightonFarm 30000 4 161 0.5% 10000 3 160 1.6% Shurtonvillage 30000 4 161 0.5% 10000 2 159 1.6% BullenFarm 30000 5 162 0.5% 10000 3 160 1.6% PtsthofKnighton 30000 4 161 0.5% 10000 2 159 1.6% Burtonvillage 30000 3 160 0.5% 10000 2 159 1.6% Warren`sFarm 30000 3 160 0.5% 10000 2 159 1.6% NewnhamBridge 30000 4 161 0.5% 10000 2 159 1.6% Wickvillage 30000 4 161 0.5% 10000 2 159 1.6% Gunter`sGrove 30000 3 160 0.5% 10000 2 159 1.6% PtwestofWick 30000 5 162 0.5% 10000 3 160 1.6% CaravanPark 30000 3 160 0.5% 10000 2 159 1.6% WickParkCottage 30000 3 160 0.5% 10000 1 158 1.6% FarringdonHillFarm 30000 2 159 0.5% 10000 1 158 1.6% KennelsSFarringdon 30000 2 159 0.5% 10000 1 158 1.6% IdsonFarm 30000 3 160 0.5% 10000 2 159 1.6% UpperCockFarm 30000 2 159 0.5% 10000 1 158 1.6% LowerCockFarm 30000 2 159 0.5% 10000 1 158 1.6% WoolstoneFarm 30000 2 159 0.5% 10000 1 158 1.6% ChalcottFarm 30000 2 159 0.5% 10000 2 159 1.6% WhitewickFarm 30000 2 159 0.5% 10000 1 158 1.6% StolfordFarm 30000 3 160 0.5% 10000 2 159 1.6% BrownsCottage 30000 3 160 0.5% 10000 2 159 1.6% LittleDowdensFar 30000 3 160 0.5% 10000 2 159 1.6% ColePool 30000 3 160 0.5% 10000 2 159 1.6% Stogursey 30000 2 159 0.5% 10000 1 158 1.6% WickHouseFarm 30000 4 161 0.5% 10000 2 159 1.6% WestEndCottage 30000 3 160 0.5% 10000 2 159 1.6% FPͲBenholeLaneS 30000 8 165 0.6% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲBenholeLaneN 30000 17 174 0.6% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲCoastal 30000 24 181 0.6% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ PixiesMound 30000 25 182 0.6% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E10: SO2 Concentrations at Human Receptors – Routine Test
Receptor 99.9%Ͳile15ͲminuteMean 99.73%Ͳileof1ͲhourMean 99.18%Ͳileof24ͲhourMean %PECof %PECof %PECof AQO PC PEC AQS PC PEC AQS PC PEC AQO AQS AQS TrighernFarm 266 4.44 8.04 3.0% 350 2.76 6.36 1.8% 125 1.30 4.90 3.9% ZipeFarm 266 4.63 8.23 3.1% 350 3.16 6.76 1.9% 125 1.32 4.92 3.9% WickFarm 266 5.35 8.95 3.4% 350 3.91 7.51 2.1% 125 1.39 4.99 4.0% Doggetts 266 7.23 10.83 4.1% 350 5.76 9.36 2.7% 125 2.51 6.11 4.9% KnightonFarm 266 5.58 9.18 3.5% 350 4.21 7.81 2.2% 125 2.21 5.81 4.6% Shurtonvillage 266 4.96 8.56 3.2% 350 3.50 7.10 2.0% 125 1.83 5.43 4.3% BullenFarm 266 5.19 8.79 3.3% 350 3.91 7.51 2.1% 125 1.83 5.43 4.3% PtsthofKnighton 266 4.66 8.26 3.1% 350 3.37 6.97 2.0% 125 1.65 5.25 4.2% Burtonvillage 266 4.06 7.66 2.9% 350 2.90 6.50 1.9% 125 1.50 5.10 4.1% Warren`sFarm 266 3.90 7.50 2.8% 350 2.81 6.41 1.8% 125 1.39 4.99 4.0% NewnhamBridge 266 4.60 8.20 3.1% 350 3.34 6.94 2.0% 125 1.31 4.91 3.9% Wickvillage 266 5.30 8.90 3.3% 350 3.71 7.31 2.1% 125 1.37 4.97 4.0% Gunter`sGrove 266 4.04 7.64 2.9% 350 2.88 6.48 1.9% 125 1.10 4.70 3.8% PtwestofWick 266 6.02 9.62 3.6% 350 4.24 7.84 2.2% 125 1.95 5.55 4.4% CaravanPark 266 3.67 7.27 2.7% 350 2.35 5.95 1.7% 125 0.89 4.49 3.6% WickParkCottage 266 2.97 6.57 2.5% 350 2.08 5.68 1.6% 125 0.68 4.28 3.4% FarringdonHillFarm 266 2.98 6.58 2.5% 350 2.03 5.63 1.6% 125 0.63 4.23 3.4% KennelsSFarringdon 266 2.84 6.44 2.4% 350 1.94 5.54 1.6% 125 0.55 4.15 3.3% IdsonFarm 266 3.85 7.45 2.8% 350 2.55 6.15 1.8% 125 1.01 4.61 3.7% UpperCockFarm 266 2.66 6.26 2.4% 350 1.75 5.35 1.5% 125 0.52 4.12 3.3% LowerCockFarm 266 2.70 6.30 2.4% 350 1.52 5.12 1.5% 125 0.48 4.08 3.3% WoolstoneFarm 266 3.02 6.62 2.5% 350 1.72 5.32 1.5% 125 0.80 4.40 3.5% ChalcottFarm 266 3.60 7.20 2.7% 350 2.04 5.64 1.6% 125 0.97 4.57 3.7% WhitewickFarm 266 3.58 7.18 2.7% 350 1.97 5.57 1.6% 125 0.73 4.33 3.5% StolfordFarm 266 3.75 7.35 2.8% 350 1.91 5.51 1.6% 125 0.63 4.23 3.4% BrownsCottage 266 3.96 7.56 2.8% 350 2.22 5.82 1.7% 125 1.02 4.62 3.7% LittleDowdensFar 266 4.30 7.90 3.0% 350 2.57 6.17 1.8% 125 0.81 4.41 3.5% ColePool 266 3.40 7.00 2.6% 350 2.32 5.92 1.7% 125 1.10 4.70 3.8% Stogursey 266 2.99 6.59 2.5% 350 1.99 5.59 1.6% 125 0.82 4.42 3.5% WickHouseFarm 266 5.11 8.71 3.3% 350 3.60 7.20 2.1% 125 1.32 4.92 3.9% WestEndCottage 266 4.80 8.40 3.2% 350 2.64 6.24 1.8% 125 0.92 4.52 3.6% FPͲBenholeLaneS 266 10.26 13.86 5.2% 350 7.94 11.54 3.3% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲBenholeLaneN 266 21.98 25.58 9.6% 350 17.71 21.31 6.1% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲCoastal 266 31.27 34.87 13.1% 350 26.97 30.57 8.7% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ PixiesMound 266 26.74 30.34 11.4% 350 19.70 23.30 6.7% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E11: NO2 Concentrations at Human Receptors – LOOP
Receptor 99.79%Ͳile1ͲhourMean %PECof AQS PC PEC AQS TrighernFarm 200 72 86 42.8% ZipeFarm 200 83 97 48.3% WickFarm 200 96 109 54.7% Doggetts 200 122 136 68.0% KnightonFarm 200 99 113 56.3% Shurtonvillage 200 88 102 50.9% BullenFarm 200 95 109 54.4% PtsthofKnighton 200 85 98 49.1% Burtonvillage 200 77 91 45.3% Warren`sFarm 200 73 86 43.2% NewnhamBridge 200 84 98 48.8% Wickvillage 200 95 109 54.4% Gunter`sGrove 200 77 91 45.3% PtwestofWick 200 108 121 60.7% CaravanPark 200 65 79 39.4% WickParkCottage 200 57 70 35.1% FarringdonHillFarm 200 56 70 34.8% KennelsSFarringdon 200 52 66 32.9% IdsonFarm 200 68 81 40.7% UpperCockFarm 200 48 62 31.0% LowerCockFarm 200 44 58 28.8% WoolstoneFarm 200 48 62 30.9% ChalcottFarm 200 55 69 34.5% WhitewickFarm 200 55 69 34.5% StolfordFarm 200 56 70 35.0% BrownsCottage 200 60 74 36.9% LittleDowdensFar 200 70 84 41.9% ColePool 200 65 79 39.3% Stogursey 200 53 67 33.4% WickHouseFarm 200 93 106 53.1% WestEndCottage 200 71 85 42.5% FPͲBenholeLaneS 200 154 168 84.0% FPͲBenholeLaneN 200 358 372 185.8% FPͲCoastal 200 303 317 158.3% PixiesMound 200 330 343 171.7%
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E12: PM10 Concentrations at Human Receptors – LOOP
Receptor 90.41%Ͳile24ͲhourMean %PECof AQS PC PEC AQS TrighernFarm 50 1.36 37.76 75.5% ZipeFarm 50 1.45 37.85 75.7% WickFarm 50 1.50 37.90 75.8% Doggetts 50 1.56 37.96 75.9% KnightonFarm 50 1.23 37.63 75.3% Shurtonvillage 50 0.98 37.38 74.8% BullenFarm 50 1.11 37.51 75.0% PtsthofKnighton 50 0.98 37.38 74.8% Burtonvillage 50 0.76 37.16 74.3% Warren`sFarm 50 0.76 37.16 74.3% NewnhamBridge 50 0.88 37.28 74.6% Wickvillage 50 1.29 37.69 75.4% Gunter`sGrove 50 0.69 37.09 74.2% PtwestofWick 50 1.48 37.88 75.8% CaravanPark 50 0.76 37.16 74.3% WickParkCottage 50 0.50 36.90 73.8% FarringdonHillFarm 50 0.45 36.85 73.7% KennelsSFarringdon 50 0.39 36.79 73.6% IdsonFarm 50 1.25 37.65 75.3% UpperCockFarm 50 0.58 36.98 74.0% LowerCockFarm 50 0.56 36.96 73.9% WoolstoneFarm 50 0.80 37.20 74.4% ChalcottFarm 50 0.92 37.32 74.6% WhitewickFarm 50 0.83 37.23 74.5% StolfordFarm 50 0.58 36.98 74.0% BrownsCottage 50 1.09 37.49 75.0% LittleDowdensFar 50 0.93 37.33 74.7% ColePool 50 0.53 36.93 73.9% Stogursey 50 0.48 36.88 73.8% WickHouseFarm 50 1.32 37.72 75.4% WestEndCottage 50 1.01 37.41 74.8% FPͲBenholeLaneS ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲBenholeLaneN ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲCoastal ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ PixiesMound ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E13: CO Concentrations at Human Receptors – LOOP
Receptor 1ͲhourMean Rolling8ͲhourMean %PECof %PECof EAL PC PEC AQS PC PEC EAL AQS TrighernFarm 30000 20 177 0.6% 10000 14 171 1.7% ZipeFarm 30000 22 179 0.6% 10000 15 172 1.7% WickFarm 30000 25 182 0.6% 10000 17 174 1.7% Doggetts 30000 32 189 0.6% 10000 23 180 1.8% KnightonFarm 30000 26 183 0.6% 10000 20 177 1.8% Shurtonvillage 30000 26 183 0.6% 10000 16 173 1.7% BullenFarm 30000 27 184 0.6% 10000 19 176 1.8% PtsthofKnighton 30000 24 181 0.6% 10000 17 174 1.7% Burtonvillage 30000 21 178 0.6% 10000 14 171 1.7% Warren`sFarm 30000 23 180 0.6% 10000 13 170 1.7% NewnhamBridge 30000 27 184 0.6% 10000 15 172 1.7% Wickvillage 30000 26 183 0.6% 10000 17 174 1.7% Gunter`sGrove 30000 25 182 0.6% 10000 12 169 1.7% PtwestofWick 30000 29 186 0.6% 10000 17 174 1.7% CaravanPark 30000 20 177 0.6% 10000 11 168 1.7% WickParkCottage 30000 18 175 0.6% 10000 9 166 1.7% FarringdonHillFarm 30000 19 176 0.6% 10000 9 166 1.7% KennelsSFarringdon 30000 17 174 0.6% 10000 9 166 1.7% IdsonFarm 30000 18 175 0.6% 10000 13 170 1.7% UpperCockFarm 30000 15 172 0.6% 10000 9 166 1.7% LowerCockFarm 30000 13 170 0.6% 10000 8 165 1.7% WoolstoneFarm 30000 15 172 0.6% 10000 9 166 1.7% ChalcottFarm 30000 15 172 0.6% 10000 12 169 1.7% WhitewickFarm 30000 16 173 0.6% 10000 10 167 1.7% StolfordFarm 30000 20 177 0.6% 10000 13 170 1.7% BrownsCottage 30000 17 174 0.6% 10000 12 169 1.7% LittleDowdensFar 30000 23 180 0.6% 10000 12 169 1.7% ColePool 30000 20 177 0.6% 10000 12 169 1.7% Stogursey 30000 18 175 0.6% 10000 8 165 1.6% WickHouseFarm 30000 25 182 0.6% 10000 16 173 1.7% WestEndCottage 30000 24 181 0.6% 10000 12 169 1.7% FPͲBenholeLaneS 30000 42 199 0.7% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲBenholeLaneN 30000 92 249 0.8% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲCoastal 30000 75 232 0.8% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ PixiesMound 30000 84 241 0.8% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E14: SO2 Concentrations at Human Receptors – LOOP
Receptor 99.9%Ͳile15ͲminuteMean 99.73%Ͳileof1ͲhourMean 99.18%Ͳileof24ͲhourMean %PECof %PECof %PECof AQO PC PEC AQS PC PEC AQS PC PEC AQO AQS AQS TrighernFarm 266 30.67 34.27 12.9% 350 19.31 22.91 6.5% 125 9.25 12.85 10.3% ZipeFarm 266 30.80 34.40 12.9% 350 22.09 25.69 7.3% 125 8.74 12.34 9.9% WickFarm 266 35.51 39.11 14.7% 350 25.33 28.93 8.3% 125 9.51 13.11 10.5% Doggetts 266 37.53 41.13 15.5% 350 33.08 36.68 10.5% 125 15.09 18.69 15.0% KnightonFarm 266 33.61 37.21 14.0% 350 26.05 29.65 8.5% 125 13.47 17.07 13.7% Shurtonvillage 266 29.64 33.24 12.5% 350 23.57 27.17 7.8% 125 12.72 16.32 13.1% BullenFarm 266 33.03 36.63 13.8% 350 25.21 28.81 8.2% 125 12.71 16.31 13.1% PtsthofKnighton 266 30.01 33.61 12.6% 350 21.68 25.28 7.2% 125 11.00 14.60 11.7% Burtonvillage 266 27.19 30.79 11.6% 350 20.78 24.38 7.0% 125 9.96 13.56 10.9% Warren`sFarm 266 26.16 29.76 11.2% 350 19.38 22.98 6.6% 125 9.74 13.34 10.7% NewnhamBridge 266 28.15 31.75 11.9% 350 22.68 26.28 7.5% 125 8.18 11.78 9.4% Wickvillage 266 35.23 38.83 14.6% 350 24.89 28.49 8.1% 125 8.47 12.07 9.7% Gunter`sGrove 266 26.53 30.13 11.3% 350 20.55 24.15 6.9% 125 8.09 11.69 9.3% PtwestofWick 266 36.05 39.65 14.9% 350 29.24 32.84 9.4% 125 10.88 14.48 11.6% CaravanPark 266 23.88 27.48 10.3% 350 17.27 20.87 6.0% 125 5.76 9.36 7.5% WickParkCottage 266 20.61 24.21 9.1% 350 14.94 18.54 5.3% 125 4.96 8.56 6.9% FarringdonHillFarm 266 21.51 25.11 9.4% 350 14.75 18.35 5.2% 125 4.84 8.44 6.7% KennelsSFarringdon 266 20.39 23.99 9.0% 350 13.39 16.99 4.9% 125 3.92 7.52 6.0% IdsonFarm 266 27.58 31.18 11.7% 350 18.17 21.77 6.2% 125 7.45 11.05 8.8% UpperCockFarm 266 19.07 22.67 8.5% 350 12.83 16.43 4.7% 125 3.89 7.49 6.0% LowerCockFarm 266 20.31 23.91 9.0% 350 11.68 15.28 4.4% 125 3.73 7.33 5.9% WoolstoneFarm 266 21.22 24.82 9.3% 350 12.53 16.13 4.6% 125 5.79 9.39 7.5% ChalcottFarm 266 24.33 27.93 10.5% 350 14.82 18.42 5.3% 125 6.96 10.56 8.5% WhitewickFarm 266 25.48 29.08 10.9% 350 14.66 18.26 5.2% 125 5.35 8.95 7.2% StolfordFarm 266 25.77 29.37 11.0% 350 14.24 17.84 5.1% 125 4.64 8.24 6.6% BrownsCottage 266 26.59 30.19 11.3% 350 15.99 19.59 5.6% 125 7.36 10.96 8.8% LittleDowdensFar 266 30.58 34.18 12.8% 350 17.80 21.40 6.1% 125 5.47 9.07 7.3% ColePool 266 23.44 27.04 10.2% 350 16.73 20.33 5.8% 125 7.34 10.94 8.8% Stogursey 266 19.81 23.41 8.8% 350 13.93 17.53 5.0% 125 6.17 9.77 7.8% WickHouseFarm 266 34.59 38.19 14.4% 350 24.71 28.31 8.1% 125 8.59 12.19 9.7% WestEndCottage 266 32.87 36.47 13.7% 350 18.73 22.33 6.4% 125 5.85 9.45 7.6% FPͲBenholeLaneS 266 49.73 53.33 20.0% 350 41.70 45.30 12.9% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲBenholeLaneN 266 123.17 126.77 47.7% 350 95.11 98.71 28.2% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ FPͲCoastal 266 94.54 98.14 36.9% 350 81.63 85.23 24.4% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ PixiesMound 266 107.91 111.51 41.9% 350 89.18 92.78 26.5% ͲͲͲ ͲͲͲ ͲͲͲ ͲͲͲ
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E15: NOx Concentrations at Ecological Receptors – Commissioning Receptor AnnualMean 24ͲhourMean %PECof %PECof AQS PC PEC EAL PC PEC AQS AQS BridgwaterBaySSSI/ SevernEstuary 30 11.74 23.24 77.5% 75 206 229 305.3% SPA/SAC/Ramsar BridgwaterBayNNR 30 11.01 22.51 75.0% 75 207 230 306.7% BlueAnchortoLilstock 30 0.73 12.23 40.8% 75 39 62 82.7% SSSI
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E16: SO2 Concentrations at Ecological Receptors – Commissioning Receptor AnnualMean %PECof AQS PC PEC AQS BridgwaterBaySSSI/ SevernEstuary 20 1.14 2.94 14.7% SPA/SAC/Ramsar BridgwaterBayNNR 20 1.02 2.82 14.1% BlueAnchortoLilstock 20 0.07 1.87 9.4% SSSI
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E17: NOx Concentrations at Ecological Receptors – Routine Test Receptor AnnualMean 24ͲhourMean %PECof %PECof AQS PC PEC EAL PC PEC AQS AQS BridgwaterBaySSSI/ SevernEstuary 30 1.75 13.25 44.2% 75 206 229 305.3% SPA/SAC/Ramsar BridgwaterBayNNR 30 1.62 13.12 43.7% 75 207 230 306.7% BlueAnchortoLilstock 30 0.10 11.60 38.7% 75 39 62 82.7% SSSI
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E18: SO2 Concentrations at Ecological Receptors – Routine Test Receptor AnnualMean %PECof AQS PC PEC AQS BridgwaterBaySSSI/ SevernEstuary 20 0.17 1.97 9.9% SPA/SAC/Ramsar BridgwaterBayNNR 20 0.15 1.95 9.8% BlueAnchortoLilstock 20 0.01 1.81 9.1% SSSI
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E19: NOx Concentrations at Ecological Receptors – LOOP Receptor 24ͲhourMean %PECof EAL PC PEC AQS BridgwaterBaySSSI/ SevernEstuary 75 933 956 1274.7% SPA/SAC/Ramsar BridgwaterBayNNR 75 861 884 1178.7% BlueAnchortoLilstock 75 412 435 580.0% SSSI
AMEC 15011/TR/00174 Issue 03 - BPE Air Quality Modelling Report
Table E20: Deposition Rates at Ecological Receptors – Commissioning and Routine Test
TestNitrogenDeposition CommissioningNitrogen TestAcidDeposition(keq CommissioningAcid Receptor (kgNhaͲ1yͲ1) Deposition(kgNhaͲ1yͲ1) haͲ1yͲ1) Deposition(keqhaͲ1yͲ1) BridgwaterBaySSSI/ SevernEstuary 0.25 1.71 0.04 0.26 SPA/SAC/Ramsar BridgwaterBayNNR 0.23 1.55 0.03 0.23 BlueAnchortoLilstock 0.01 0.11 0.002 0.02 SSSI
AMEC 15011/TR/00174 Issue 03 - BPE Combustion Activity Submission Hinkley Point C Appendix D
Appendix D Environmental Management System Information
NNB-OSL-REP-000252 Combustion Activity Submission Hinkley Point C Appendix D
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NNB-OSL-REP-000252
Combustion Activity Submission Hinkley Point C Appendix E
Appendix E Application Forms (A, B2, B3 and F1)
NNB-OSL-REP-000252 Combustion Activity Submission Hinkley Point C Appendix E
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NNB-OSL-REP-000252 Form EPA: Application for an environmental permit – Part A about you Application for an environmental permit Part A – About you
You will need to fill in this part A if you are applying for Where you see the term ‘document reference’ on the form, a new permit, applying to change an existing permit give the document references and send the documents with or want to transfer an existing permit to yourself. the application form when you’ve completed it. Please read through this form and the guidance Contents notes that came with it. Please write clearly in the 1 About you answer spaces. 2 Applications from an individual 3 Applications from an organisation of individuals Note: if you believe including information on a public register 4 Applications from public bodies would not be in the interests of national security you must 5 Applications from companies tick the box in section 5 of F1 or F2 and enclose a letter telling 6 Your address us that you have told the Secretary of State/Welsh ministers. 7 Contact details We will not include the information in the public register 8 How to contact us unless directed otherwise. It will take less than one hour to fill in this part of the application form.
1 About you Are you applying as an individual, an organisation of individuals (for example, a partnership), a company (this includes Limited Liability Partnerships) or a public body? An individual Now go to section 2 An organisation of individuals (for example, a partnership) Now go to section 3 A public body Now go to section 4 A registered company or other corporate body ✔ Now go to section 5
2 Applications from an individual 2a Please give us the following details Name Title (Mr, Mrs, Miss and so on) First name Last name Date of birth (DD/MM/YYYY) Now go to section 6
3 Applications from an organisation of individuals 3a Type of organisation For example, a charity, a partnership, a group of individuals or a club 3b Details of the organisation If you are an organisation of individuals, please give the details of the main representative below. If relevant, provide details of other members (please include their title Mr, Mrs and so on) on a separate sheet and tell us the document reference you have given this sheet. Contact name Title (Mr, Mrs, Miss and so on) First name
EPA Version 3, April 2011 page 1 of 5 Form EPA: Application for an environmental permit – Part A about you 3 Applications from an organisation of individuals, continued Last name Date of birth (DD/MM/YYYY) Now go to section 6 4 Applications from public bodies 4a Type of public body For example, NHS trust, local authority, English county council 4b Name of the public body 4c Please give us the following details of the executive An officer of the public body authorised to sign on your behalf Name Title (Mr, Mrs, Miss and so on) First name Last name Position Now go to section 6 5 Applications from companies or corporate bodies 5a Name of the company NNB GENERATION COMPANY LIMITED 5b Company registration number 06937084 Date of registration (DD/MM/YYYY) 17/06/2009 If you are applying as a corporate organisation that is not a limited company, please provide evidence of your status and tell us below the reference you have given the document containing this evidence. Document reference Now go to section 6
6Your address 6a Your main (registered office) address For companies this is the address on record at Companies House. Contact name Title (Mr, Mrs, Miss and so on) First name Last name Address 40 Grosvenor Place London
Postcode SW1X 7EN Contact numbers, including the area code Phone 020 7242 9050 Fax Mobile Email
EPA Version 3, April 2011 page 2 of 5 Form EPA: Application for an environmental permit – Part A about you 6 Your address, continued
For an organisation of individuals every partner needs to give us their details, including their title Mr, Mrs and so on. So, if necessary, continue on a separate sheet and tell us below the reference you have given the sheet. Document reference for the extra sheet 6b Main UK business address (if different from above) Contact name Title (Mr, Mrs, Miss and so on) First name Last name Address The Qube 90 Whitfield Street London Postcode W1T 4EZ Contact numbers, including the area code Phone Fax Mobile Email
Now go to section 7
7 Contact details 7a Who can we contact about your application? This can be someone acting as a consultant or an ‘agent’ for you. Contact name Title (Mr, Mrs, Miss and so on) First name Last name Address The Qube 90 Whitfield Street London Postcode W1T 4EZ Contact numbers, including the area code Phone Fax Mobile Email
EPA Version 3, April 2011 page 3 of 5 Form EPA: Application for an environmental permit – Part A about you 7 Contact details, continued 7b Who can we contact about your operation (if different from question 7a)? Contact name Title (Mr, Mrs, Miss and so on) First name Last name Address
Postcode Contact numbers, including the area code Phone Fax Mobile Email
7c Who can we contact about your billing or invoice? As in question 7a ✔ As in question 7b Please give details below if different from question 7a or 7b. Contact name Title (Mr, Mrs, Miss and so on) First name Last name Address
Postcode Contact numbers, including the area code Phone Fax Mobile Email
EPA Version 3, April 2011 page 4 of 5 Form EPA: Application for an environmental permit – Part A about you 8 How to contact us If you need help filling in this form, please contact the person who sent it to you or contact us as shown below. General enquiries: 08708 506 506 (Monday to Friday, 8am to 6pm) Textphone: 08702 422 549 (Monday to Friday, 8am to 6pm) Email: [email protected] Website: www.environment-agency.gov.uk If you are happy with our service, please tell us. It helps us to identify good practice and encourages our staff. If you’re not happy with our service, please tell us how we can improve it. Please tell us if you need information in a different language or format (for example, in large print) so we can keep in touch with you more easily.
Feedback (You don’t have to answer this part of the form, but it will help us improve our forms if you do.) We want to make our forms easy to fill in and our guidance notes easy to understand. Please use the space below to give us any comments you may have about this form or the guidance notes that came with it.
How long did it take you to fill in this form? 15 minutes We will use your feedback to improve our forms and guidance notes, and to tell the Government how regulations could be made simpler. Would you like a reply to your feedback? Yes please No thank you
For Environment Agency use only Date received (DD/MM/YYYY) Payment received? No Our reference number Yes Amount received £
EPA Version 3, April 2011 page 5 of 5
Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit Application for an environmental permit Part B2 – General – new bespoke permit
Fill in this part of the form together with parts A, F1 It will take less than two hours to fill in this part of the or F2 if you are applying for a new bespoke permit. application form. You also need to fill in part B3, B4, B5, B6, or B7 (this Contents depends on what activities you are applying for). 1 About the permit Please note we cannot issue your permit for a relevant 2 About the site waste operation or mining waste facility until you 3 Your ability as an operator have an appropriate planning consent. Please look at 4 Consultation 5 Planning status the guidance for this part for more information. 6 Supporting information Please read through this form and the guidance 7 Environmental risk assessment notes that came with it. Please write clearly in the 8 How to contact us answer spaces. Appendix 1 – Low impact installation checklist
1 About the permit 1a Customer reference number What is your customer reference number? If you do not have a customer reference number, leave this blank. The customer reference number is a unique identification number which tells us who you are. It is always made up of one letter and nine numbers in this order A111111111. 1b Discussions before your application If you have had discussions with us before your application, give us the case reference or details on a separate sheet. Tell us below the reference you have given this extra sheet. EPR/ZP3238FH/A001 Case or document reference 1c Is the permit for a site or for mobile plant? Site ✔ Now go to section 2 Mobile plant Now go to question 1d Note: The term ‘mobile plant’ does not include mobile sheep dipping unit. Mobile plant 1d Have we told you during pre application discussions that we believe that a mobile permit is suitable for your activity? No Yes 1e Have there been any changes to your proposal since this discussion? No Now go to section 3 Yes You should send us a description of the activity you want to carry out, highlighting the changes you have made since our pre- application discussions. Document reference Now go to section 3
EPB2 Version 3, April 2011 page 1 of 9 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit 2 About the site (but not mobile plant) 2a What is the site name, address, postcode and national grid reference? Site name Hinkley Point C Power Station Address Near Bridgwater Somerset
Postcode TA5 1UD National grid reference for the site (for example, ST 12345 67890) ST 20300 45800 2b What is the type of regulated facility type for the site you are applying for (if only one)? Note: if you are applying for more than one regulated facility then go to 2c. Installation ✔ Now tick the relevant box in question 2b1 Waste operation Now tick the relevant box in question 2b2 Mining waste operation Now tick the relevant box in question 2b3 Water discharge activity Now go to question 3d Groundwater activity (point source) Now go to question 3d Groundwater activity (discharge onto land) Now go to question 3d What is the national grid reference for the regulated facility (if only one)? (See the guidance notes on part B2.) As in 2a above Different from that in 2a ✔ Please fill in the national grid reference below National grid reference for the regulated facility SECTION 1.2 What is the type of activity? 2b1 Installation 2b2 Waste operation Intensive farming installation Landfill gas facility Local authority (Part A (2) and Part B) Opra charged activity Low impact installation (see question 2d below) Pet cemetery Opra charged activity ✔ Use of waste in construction (up to 50,000 tonnes) Paragraph-17 installation Use of waste in construction (50,000 to 100,000 tonnes) Use of waste in reclamation, restoration or improvement of land (up to 50,000 tonnes) Use of waste in reclamation, restoration or improvement of land (50,000 to 100,000 tonnes) Treatment of waste to produce soil, soil substitutes, road stone and aggregate Manufacture of timber and construction products from waste 2b3 Mining waste operation Non Opra charged activity Opra charged activity
Now go to question 2d
EPB2 Version 3, April 2011 page 2 of 9 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit 2 About the site, continued 2c If you are applying for more than one regulated facility on your site, what are their types and their grid references? See the guidance notes on part B2. Regulated facility 1 National grid reference What is the regulated facility type? Installation Now tick the relevant box in question 2c1 Waste operation Now tick the relevant box in question 2c2 Mining waste operation Now tick the relevant box in question 2c3 Water discharge activity Now go to question 3d Groundwater activity (point source) Now go to question 3d Groundwater activity (discharge onto land) Now go to question 3d What is the type of activity? 2c1 Installation 2c2 Waste operation Intensive farming installation Landfill gas facility Local authority (part A (2) and part B) Opra charged activity Low impact installation (see question 2d below) Pet cemetery Opra charged activity Use of waste in construction (up to 50,000 tonnes) Paragraph-17 installation Use of waste in construction (50,000 to 100,000 tonnes) Use of waste in reclamation, restoration or improvement of land (up to 50,000 tonnes) Use of waste in reclamation, restoration or improvement of land (50,000 to 100,000 tonnes) Treatment of waste to produce soil, soil substitutes, road stone and aggregate Manufacture of timber and construction products from waste 2c3 Mining waste operation Non Opra charged activity Opra charged activity Regulated facility 2 National grid reference What is the regulated facility type? Installation Now tick the relevant box in question 2c1 Waste operation Now tick the relevant box in question 2c2 Mining waste operation Now tick the relevant box in question 2c3 Water discharge activity Now go to question 3d Groundwater activity (point source) Now go to question 3d Groundwater activity (discharge onto land) Now go to question 3d
EPB2 Version 3, April 2011 page 3 of 9 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit 2 About the site, continued What is the type of activity? 2c1 Installation 2c2 Waste operation Intensive farming installation Landfill gas facility Local authority (part A (2) and part B) Opra charged activity Low impact installation (see question 2d below) Pet cemetery Opra charged activity Use of waste in construction (up to 50,000 tonnes) Paragraph-17 installation Use of waste in construction (50,000 to 100,000 tonnes) Use of waste in reclamation, restoration or improvement of land (up to 50,000 tonnes) Use of waste in reclamation, restoration or improvement of land (50,000 to 100,000 tonnes) Treatment of waste to produce soil, soil substitutes, road stone and aggregate Manufacture of timber and construction products from waste 2c3 Mining waste operation Non Opra charged activity Opra charged activity Use several copies of this page or separate sheets if you have a long list of regulated facilities. Send them to us with your application form. Tell us below the reference you have given these extra sheets. Document reference for the extra sheets Now go to question 2d 2d Low impact installations (installations only) Are any of the regulated facilities low impact installations? No ✔ Yes If yes, tell us how you meet the conditions for a low impact installation. (See the guidance notes on part B2 – Appendix 1.) Document reference Tick the box to confirm you have filled in the low impact installation checklist in appendix 1 for each regulated facility. 2e Treating batteries Are you planning to treat batteries? (See the guidance notes on part B2.) No Yes Tell us how you will do this, send us a copy of your explanation and tell us below the reference you have given this explanation. Document reference for the explanation 2f Multi operator installation If the site is a multi operator site (that is there is more than one operator of the installation) then fill in the table below the application reference for each of the other permits. Table 1 – Other permit application references
EPB2 Version 3, April 2011 page 4 of 9 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit 3 Your ability as an operator If you are only applying for a standalone water discharge or for a groundwater activity, you only have to fill in question 3d. 3a Relevant offences (for installations and waste operations only – see the guidance notes on part B2) Have you, or any other relevant person, been convicted of any relevant offence? No ✔ Now go to question 3b Yes Please give details below Name of the relevant person Title (Mr, Mrs, Miss and so on) First name Last name Date of birth (DD/MM/YYYY) Position at the time of the offence Name of the court where the case was dealt with Date of the conviction (DD/MM/YYYY) Offence and penalty set Date any appeal against the conviction will be heard (DD/MM/YYYY) If necessary, use a separate sheet to give us details of other relevant offences (and post conviction plans if relevant) and tell us below the reference number you have given the extra sheet. Document reference of the extra sheet For specified waste activities only Have you sent us a post conviction plan for this offence? No You must send us a post conviction plan with this application and give us the document reference below Document reference Yes Please give us the reference for the post conviction plan you have sent and the date sent in Post conviction plan reference Date sent in (DD/MM/YYYY)
3b Technical ability (for specified waste management activities and waste operations only – see the guidance notes on part B2) Please tell us which scheme you are using to show you have the suitable technical skills and knowledge to manage your facility.
Not applicable - not a specified waste management activity or waste operation
Document reference or references for the evidence you provide to show you are keeping to your chosen scheme.
-
Now go to question 3c
EPB2 Version 3, April 2011 page 5 of 9 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit 3 Your ability as an operator, continued 3c Finances (for installations, waste operations and mining waste operations only) Have you or any relevant person ever been made bankrupt or had insolvency proceedings taken against you? No ✔ Yes Please give details below
We may want to contact a credit reference agency for a report about your business’s finances. Landfill, Category A mining waste facilities and mining waste facilities for hazardous waste only How do you plan to make financial provision (to operate a landfill or a mining waste facility you need to show us that you are financially capable of meeting the obligations of closure and aftercare)? Bonds Escrow account Trust fund Lump sum Other Give the document reference for the proof you are supplying Provide a plan of your estimated expenditure on each phase of the landfill or mining waste facility. Give the document plan reference Now go to question 3d 3d Management systems (all) Does your management system meet the conditions set out in our guidance? No Yes ✔ What management system will you provide for your regulated facility? EC Eco-Management and Audit Scheme (EMAS) ISO 14001 BS 8555 (Phases 1–5) Green Dragon Own management system ✔ Please make sure you send us a summary of your management system with your application. Document reference or references Main application - Section 5.1
4 Consultation (fill in 4a to 4c for installations and waste operations and 4d for installations only) Could the waste operation or installation involve releasing any substance into any of the following? 4a A sewer managed by a sewerage undertaker No ✔ Yes Please name the sewerage undertaker 4b A harbour managed by a harbour authority No ✔ Yes Please name the harbour authority
EPB2 Version 3, April 2011 page 6 of 9 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit 4 Consultation, continued 4c Direct into relevant territorial waters or coastal waters within the sea fisheries district of a local fisheries committee No ✔ Yes Please name the fisheries committee 4d Is the installation on a site for which: 4d1 a nuclear site licence is needed under section 1 of the Nuclear Installations Act 1965? No Yes ✔ 4d2 a policy document for preventing major accidents is needed under regulation 5 of the Control of Major Accident Hazards Regulations 1999, or a safety report is needed under regulation 7 of those Regulations? No Yes ✔
5 Planning status For relevant waste operations, but not mobile plant operations, and relevant mining waste facilities only. Otherwise go to section 6 if this does not apply to you. Tick which situation applies to you (do not fill in this section if you are making an application for mobile plant). I have planning permission I have a certificate of lawful existing use or development I have an established use certificate The General Permitted Development Order 1995 applies I do not need planning permission Please provide proof I have applied for planning permission but have not yet had a decision (You can still apply but we will not issue your permit until you can provide us with proof that you have got the permission you need) Name of the planning authority Provide a copy of the relevant planning application or permission Document reference of the application or permission
6 Supporting information 6a Provide a plan or plans for the site (but not any mobile plant) Mark the site boundary or discharge point, or both, in green – see the guidance notes on part B2. Main application - Appendix B Document reference or references of the plans 6b Provide the relevant sections of a site condition report if this applies (See the guidance notes on part B2 for what needs to be marked on the plan) Main application - Appendix A Document reference of the report 6c Provide a non technical summary of your application (see the guidance notes on part B2) Main application - Non Technical Summary (before contents) Document reference of the summary
7 Environmental risk assessment Provide an assessment of the risks each of your proposed regulated facilities poses to the environment. The risk assessment must use H1 or an equivalent method. Main application - Section 4 Document reference for the assessment
EPB2 Version 3, April 2011 page 7 of 9 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit 8 How to contact us If you need help filling in this form, please contact the person who sent it to you or contact us as shown below. General enquiries: 08708 506 506 (Monday to Friday, 8am to 6pm) Textphone: 08702 422 549 (Monday to Friday, 8am to 6pm) Email: [email protected] Website: www.environment-agency.gov.uk If you are happy with our service, please tell us. It helps us to identify good practice and encourages our staff. If you’re not happy with our service, please tell us how we can improve it. Please tell us if you need information in a different language or format (for example, in large print) so we can keep in touch with you more easily.
Feedback (You don’t have to answer this part of the form, but it will help us improve our forms if you do.) We want to make our forms easy to fill in and our guidance notes easy to understand. Please use the space below to give us any comments you may have about this form or the guidance notes that came with it.
How long did it take you to fill in this form? 20 minutes We will use your feedback to improve our forms and guidance notes, and to tell the Government how regulations could be made simpler. Would you like a reply to your feedback? Yes please No thank you
For Environment Agency use only Date received (DD/MM/YYYY) Payment received? No Our reference number Yes Amount received £
EPB2 Version 3, April 2011 page 8 of 9 Form EPB: Application for an environmental permit – Part B2 general – new bespoke permit Plain English Campaign’s Crystal Mark does not apply to appendix 1. Appendix 1 – Low impact installation checklist
Installation reference
Condition Response Do you meet the condition?
A – Management techniques Provide references to show how your application Yes meets condition A. No
References
B – Aqueous waste Effluent created m3/day Yes No
C – Abatement systems Provide references to show how your application meets condition C. Yes No References
D – Groundwater Do you plan to release any hazardous Yes Yes substances or non hazardous pollutants No No into the ground?
E – Producing waste Hazardous waste Tonnes per year Yes No Non hazardous waste Tonnes per year
F – Using energy Peak energy consumption MW Yes No
G – Preventing accidents Do you have appropriate measures to prevent spills Yes Yes and major releases of liquids? (See ‘How to comply’.) No No
Provide references to show how your application meets condition G.
References
H – Noise Provide references to show how your application meets condition H. Yes No References
I – Emissions of polluting Provide references to show how your application meets condition I. Yes substances No References
J – Odours Provide references to show how your application meets condition J. Yes No References
K – History of keeping to the Say here whether you have been involved in any Yes regulations enforcement action as described in Compliance No History Appendix 1 explanatory notes.
EPB2 Version 3, April 2011 page 9 of 9
Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Application for an environmental permit Part B3 – New bespoke installation permit
If you are applying for a new bespoke permit for an 4 Monitoring installation, fill in this part of the form, together with 5 Environmental impact assessment parts A, B2 and F1. 6 Resource efficiency and climate change 7 How to contact us Please read through this form and the guidance Appendix 1 – Specific questions for the combustion sector notes that came with it. Please write clearly in the Appendix 2 – Specific questions for the chemical sector answer spaces. Appendix 3 – Specific questions for the intensive farming It will take less than three hours to fill in this part of the sector application form. Appendix 4 – Specific questions for the clinical waste sector Appendix 5 – Specific questions for the hazardous and non Contents hazardous waste recovery and disposal sector 1 What activities are you applying for? Appendix 6 – Specific questions for the waste incineration 2 Emissions to air, water and land sector 3 Operating techniques Appendix 7 – Specific questions for the landfill sector
1 What activities are you applying for? Fill in table 1a below with details of all the activities listed in schedule 1 of the Environmental Permitting Regulations (EPR) and all directly associated activities (DAAs) (in separate rows) that you propose to carry out at the installation. Fill in a separate table for each installation you are applying for. Use a separate sheet if you have a long list and send it to us with your application form. Tell us below the reference you have given the document. Document reference
EPB3 Version 3, April 2011 page 1 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit
Table 1a – Types of activities
Schedule 1 listed activities
Installation name Schedule 1 references Description of the Activity Activity capacity (See Annex IIA or IIB (disposal Hazardous waste Non hazardous waste (See note 1) (See note 2) note 3) and recovery) codes and treatment capacity (if this treatment capacity (if this descriptions applies) (See note 3) applies) (See note 3)
Add extra rows if you Put your main activity For installations that take For installations that take For installations that take need them. If you do not first waste only waste only waste only have enough room go to the line below or send a separate document and give us the document reference here
HPC Combustion Plant 1.1 Part A (1) a) (i) 8xEDG @18.5MWth 176.00
4xSBO @7MWth each
Directly associated activities (See note 4)
Name of DAA Description of the DAA (please identify the schedule 1 activity it serves)
Add extra rows if you need them
Raw materials and waste storage
For installations that take waste Total storage capacity (See note 5 below)
Annual throughput (tonnes each year)
EPB3 Version 3, April 2011 page 2 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit 1 What activities are you applying for?, continued Notes 1 Quote the section number, part A1 or A2 or B, then paragraph and sub paragraph number as shown in part 2 of schedule 1 to the regulations. 2 Use the description from schedule 1 of the regulations. Include any extra detail that you think would help to accurately describe what you want to do. 3 By ‘capacity’, we mean: ● the total incineration capacity (tonnes every hour) for waste incinerators; ● the total landfill capacity (cubic metres) for landfills; ● the total treatment capacity (tonnes each day) for waste treatment; ● the total storage capacity (tonnes) for waste storage operations; ● the processing and production capacity for manufacturing operations; or ● the thermal input capacity for combustion activities. 4 Fill this in as a separate line and give an accurate description of any other activities associated with your schedule 1 activities. You cannot have DAAs as part of a mobile plant application. 5 By ‘total storage capacity’, we mean the maximum amount of waste, in tonnes, you store on the site at any one time. Types of waste accepted For those installations that take waste, for each line in table 1a (including DAAs), fill in a separate document to list those types of waste you will accept onto the site for that activity. Give the List of Wastes catalogue code and description. If you need to exclude wastes from your activity or facility by restricting the description, quantity, physical nature, hazardous properties, composition or characteristic of the waste, include these in the document. Send it to us with your application form. Please provide the reference for each document. You can use table 1b as a template. If you want to accept any waste with a code ending in 99, you must provide more information and a full description in the document. Document reference for this extra information N/A
Table 1b – Template example – types of waste accepted and restrictions
Waste code Description of waste
Example Example 02 01 08* Agrochemical waste containing dangerous substances 06 01 02* Hydrochloric acid
2 Emissions to air, water and land Fill in table 2 below with details of the emissions that result from the operating techniques at each of your installations. Fill in one table for each installation. Table 2 – Emissions (releases)
Installation name HPC Combustion Plant
Point source emissions to air
Emission point reference and location Source Parameter Quantity Unit
See Main Application - Section 3.1.1
Point source emissions to water (other than sewers)
EPB3 Version 3, April 2011 page 3 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit 2 Emissions to air, water and land, continued Table 2 – Emissions, continued
Emission point reference and location Source Parameter Quantity Unit
See Main Application - Section 3.1.6
Point source emissions to sewers, effluent treatment plants or other transfers off site
Emission point reference and location Source Parameter Quantity Unit
See Main Application - Section 3.1.6
Point source emissions to land
Emission point reference and location Source Parameter Quantity Unit
See Main Application - Section 3.1.7
Supporting information 3 Operating techniques 3a Technical standards Fill in table 3a for each activity at the installation you have referred to in table 1a above and list the relevant technical guidance note (TGN) or notes you are planning to use. If you are planning to use the standards set out in the TGN, there is no need to justify using them. You must justify your decisions in a separate document if: ● there is no technical standard; ● the technical guidance provides a choice of standards; or ● you plan to use another standard. This justification could include a reference to the Environmental Risk Assessment provided in section 7 of part B2 (General Bespoke Permit) of the application form. The documents in table 3a should summarise the main measures you use to control the main issues identified in the H1 assessment or technical guidance. For each of the activities listed in table 3a, describe the type of operation and the options you have chosen for controlling emissions from your process.
EPB3 Version 3, April 2011 page 4 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit 3 Operating techniques, continued Table 3a – Technical standards Note: Fill in a separate table for each activity at the installation.
Installation name HPC Combustion Plant
Schedule 1 activity or directly associated activity Relevant technical guidance note Document reference (if description (You will need to refer to ‘How to comply’ for all appropriate) permits)
‘How to comply’
1.1 Part A(1) (a) (i) (a) Additional guidance for combustion activities EPR 1.01, Version 4.0, March 2
IPPC SGN for Combustion Activities V2.03, 2005
If appropriate, use block diagrams to help describe the operation and process. Give the document references you use for each diagram and description. Document reference - 3b General requirements Fill in a separate table 3b for each installation. Table 3b – General requirements
Installation name HPC Combustion Plant
If the TGN or H1 assessment shows that fugitive releases are an important issue, send Document reference or references us your plan for managing fugitive releases Not an important issue - Main App. Section 3.1.8 If the TGN or H1 assessment shows that odours are an important issue, send us your Document reference or references odour management plan Not an important issue - Main App. Section 3.2 If the TGN or H1 assessment shows that noise or vibration are important issues, send Document reference or references us your noise or vibration management plan (or both) Not an important issue - Main App. Section 3.3
3c Types and amounts of raw materials Fill in table 3c for all schedule 1 activities. Fill in a separate table for each installation.
Table 3c – Types and amounts of raw materials
Installation name HPC Combustion Plant
Capacity (See note 1 below)
Schedule 1 activity Description of raw Maximum amount Annual throughput Description of how the material and (tonnes) (tonnes each year) raw material is used composition material (See note 2 below) including any main hazards (include safety information sheets)
See Main Application Section 5.3
Notes 1 By ‘capacity’, we mean the total storage capacity (tonnes) or total treatment capacity (tonnes each day). 2 By ‘maximum amount’, we mean the maximum amount of raw materials on your site at any one time.
EPB3 Version 3, April 2011 page 5 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit 3 Operating techniques, continued Use a separate sheet if you have a long list of raw materials, and send it to us with your application form. Please also provide the document reference you have given the extra sheet. Document reference See Main Application Section 5.3 3d Information for specific sectors For some of the sectors, we need more information to be able to set appropriate conditions in the permit. This is as well as the information you may provide in sections 5, 6 and 7. For those activities listed below, you must answer the questions in the related document. Table 3d – Questions for specific sectors
Sector Appendix
Combustion See the questions in appendix 1
Chemicals See the questions in appendix 2
Intensive farming See the questions in appendix 3
Clinical waste See the questions in appendix 4
Hazardous and non-hazardous waste recovery and disposal See the questions in appendix 5
Incinerating waste See the questions in appendix 6
Landfill See the questions in appendix 7
General information 4 Monitoring 4a Describe the measures you use for monitoring emissions by referring to each emission point in table 2 above You should also describe any environmental monitoring. Tell us: ● how often you use these measures; ● the methods you use; and ● the procedures you follow to assess the measures. Document reference for this information See Main Application Section 3.4 4b Point source emissions to air only Provide an assessment of the sampling locations you have used to measure point source emissions to air. The assessment must use M1 (see the guidance notes on part B3). Document reference of the assessment See Main Application Section 3.4
5 Environmental impact assessment 5a Have your proposals had an environmental impact assessment under Council Directive 85/337/EEC of 27 June 1985 [Environmental Impact Assessment] (EIA)? No Now go to section 6 Yes ✔ Please provide a copy of the environmental statement and, if the procedure has been completed: ● a copy of the planning permission; and ● the committee report and decision on the EIA. Document reference for the copy To be provided later.
6 Resource efficiency and climate change If the site is a landfill, you only need to fill in this section if the application includes landfill gas engines. 6a Describe the basic measures for improving how energy efficient your activities are Document reference of this description See Main Application Section 5.5.1 and 5.5.2 6b Provide a breakdown of any changes to the energy your activities use and create Document reference of the breakdown See Main Application Section 5.5.1
EPB3 Version 3, April 2011 page 6 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit 6 Resource efficiency and climate change, continued 6c Have you entered into, or will you enter into, a climate change levy agreement? No ✔ Describe the specific measures you use for improving your energy efficiency. Document reference of this description See Main Application Section 5.5.3 Yes Please give the date you entered (or the date you expect to enter) into the agreement (DD/MM/YYYY) Please also provide documents that prove you are taking part in the agreement. Document reference of the proof you are providing 6d Tell us about, and justify your reasons for, the raw and other materials, other substances and water you will use Document reference of this document See Main Application Section 5.3 6e Describe how you avoid producing waste in line with Council Directive 2006/12/EC on waste If you produce waste, describe how you recover it. If it is technically and financially impossible to recover the waste, describe how you dispose of it while avoiding or reducing any effect it has on the environment. Document reference for your description See Main Application Section 5.4
7 How to contact us If you need help filling in this form, please contact the person who sent it to you or contact us as shown below. General enquiries: 08708 506 506 (Monday to Friday, 8am to 6pm) Textphone: 08702 422 549 (Monday to Friday, 8am to 6pm) Email: [email protected] Website: www.environment-agency.gov.uk If you are happy with our service, please tell us. It helps us to identify good practice and encourages our staff. If you’re not happy with our service, please tell us how we can improve it. Please tell us if you need information in a different language or format (for example, in large print) so we can keep in touch with you more easily.
EPB3 Version 3, April 2011 page 7 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Feedback (You don’t have to answer this part of the form, but it will help us improve our forms if you do.) We want to make our forms easy to fill in and our guidance notes easy to understand. Please use the space below to give us any comments you may have about this form or the guidance notes that came with it.
How long did it take you to fill in this form? 30 minutes We will use your feedback to improve our forms and guidance notes, and to tell the Government how regulations could be made simpler. Would you like a reply to your feedback? Yes please No thank you
For Environment Agency use only Date received (DD/MM/YYYY) Payment received? No Our reference number Yes Amount received £
EPB3 Version 3, April 2011 page 8 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Plain English Campaign’s Crystal Mark does not apply to appendices 1 to 7. Appendix 1 – Specific questions for the combustion sector 1 Identify the type of fuel burned in your combustion units (including when your units are started up, shut down and run as normal). If your units are dual fuelled (that is, use two types of fuel), list both the fuels you use Fill in a separate table for each installation. Installation reference Type of fuel When run as normal When started up When shut down Coal
Gas oil 1.00 1.00 1.00 Heavy fuel oil Natural gas WID waste Biomass (see notes 1 and 2 below) Biomass (see notes 1 and 2 below) Biomass (see notes 1 and 2 below) Biomass (see notes 1 and 2 below) Biomass (see notes 1 and 2 below) Other Notes 1 Not covered by WID. 2 ‘Biomass’ is referred to in www.opsi.gov.uk/si/si2002/20020914.htm. Give extra information if it helps to explain the fuel you use. Gas oil is used during normal operation, start-up & shut-down Document reference 2 Give the composition range of any fuels you are currently allowed to burn in your combustion plant Fill in a separate table for each installation. Fuel use and analysis Installation reference HPC Combustion Plant - Gas oil will be compliant with SCOLF Parameter Unit Fuel 1 Fuel 2 Fuel 3 Fuel 4 Maximum percentage % of gross thermal input Moisture % Ash % wt/wt dry Sulphur % wt/wt dry Chlorine % wt/wt dry Arsenic % wt/wt dry Cadmium % wt/wt dry Carbon % wt/wt dry Chromium % wt/wt dry Copper % wt/wt dry Hydrogen % wt/wt dry Lead % wt/wt dry Mercury % wt/wt dry Nickel % wt/wt dry Nitrogen % wt/wt dry Oxygen % wt/wt dry Vanadium mg/kg dry Zinc mg/kg dry Net calorific value MJ/kg
EPB3 Version 3, April 2011 page 9 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Appendix 1 – Specific questions for the combustion sector, continued 3 If NOx factors are necessary for reporting purposes (that is, if you do not need to monitor emissions), please provide the factors associated with burning the relevant fuels Fill in a separate table for each installation.
Installation reference HPC Combustion Plant - NOx factors will not be used for rpting Fuel NOx factor (kgt–1)
Fuel 1 Fuel 2 Fuel 3 Fuel 4 Note: kgt–1 means kilograms of nitrogen oxides released for each tonne of fuel burned. 4 Will your combustion plant be subject to the Large Combustion Plant Directive? (see Government guidance) No ✔ Now fill in part F Yes
5 Is your plant an existing plant (a plant licensed before 1 July 1987)? a new plant (a plant licensed on or after 1 July 1987 but before 27 November 2002, or a plant for which an application was made before 27 November 2002 and which was put into operation before 27 November 2003)? or a new-new plant (a plant for which an application was made on or after 27 November 2002)? 6 If you run more than one type of plant or a number of the same type of plant on your installation, please list them in the table below Fill in a separate table for each installation.
Installation reference Type of plant Number within installation Existing New New-new Gas turbine (group A) Gas turbine (group B)
7 If you run an existing plant, have you submitted a declaration for the ‘limited life derogation’ set out in Article 4(4)(a) of the LCPD? No Now go to section 9 Yes 8 Have you subsequently withdrawn your declaration? No Yes 9 List the existing large combustion plants (LCPs) which have annual mass allowances under the National Emission Reduction Plan (NERP), and those with emission limit values (ELVs) under the LCPD
Installation reference LCPs under NERP LCPs with ELVs
EPB3 Version 3, April 2011 page 10 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Appendix 1 – Specific questions for the combustion sector, continued 10 Do you meet the monitoring requirements of the LCPD? No Provide details Document reference Yes
EPB3 Version 3, April 2011 page 11 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Appendix 2 – Specific questions for the chemical sector 1 Please provide a technical description of your activities The description should be enough to allow us to understand: ● the process; ● the main plant and equipment used for each process; ● all reactions, including significant side reactions (that is, the chemistry of the process); ● the material mass flows (including by products and side streams) and the temperatures and pressures in major vessels; ● the all emission control systems (both hardware and management systems), for situations which could involve releasing a significant amount of emissions – particularly the main reactions and how they are controlled; ● a comparison of the indicative BATs and benchmark emission levels standards in Technical Guidance Notes (TGNs) EPR 4.01, EPR 4.02 and EPR 4.03, and chemical sector BREFs. Document reference 2 If you are applying for a multi purpose plant, do you have a multi product protocol in place to control the changes? No Yes Provide a copy of your protocol to accompany this application Document reference 3 Does the Solvents Emissions Directive (SED) apply to your activities? No Yes Fill in the following 3a List the activities which are controlled under the SED
Installation reference
Activities
3b Describe how the list of activities in question 3a above meets the requirements of the SED Document reference
EPB3 Version 3, April 2011 page 12 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Appendix 3 – Specific questions for the intensive farming sector 1 For each type of livestock, tell us the number of animal places you are applying for
Installation reference
Type of livestock Number of places
2 Is manure or slurry exported from the site? No Yes 3 Is manure or slurry spread on the site? No Yes
EPB3 Version 3, April 2011 page 13 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Appendix 4 – Specific questions for the clinical waste sector If you are applying for an activity covered by the Waste Incineration Directive and wish to accept clinical waste you should fill in questions 1, 2 and 3 of this appendix. Note: If your procedures are fully in line with the standards set out in EPR5.07 then you should tick the ‘yes’ box and provide the procedure reference. There is no need for you to supply a copy of the procedure. 1 Are pre acceptance procedures in place that are fully in line with the appropriate measures set out in section 2.2 of EPR 5.07 and which are used to assess a waste enquiry before it is accepted at the installation? No Provide justification for departure from EPR 5.07 and submit a copy of the procedures Document reference Yes Document reference 2 Are waste acceptance procedures in place that are fully in line with the appropriate measures set out in section 2.2 of EPR 5.07, and which are used to cover issues such as loads arriving and being inspected, sampling waste, rejecting waste, and keeping records to track waste? No Provide justification for departure from EPR 5.07 and submit a copy of the procedures Document reference Yes Document reference 3 Are waste storage, handling and dispatch procedures, and infrastructure in place that are fully in line with the appropriate measures set out in section 3.2 of EPR 5.07? No Provide justification for departure from EPR 5.07 and submit a copy of the procedures Document reference Yes Document reference 4 Are monitoring procedures in place that are fully in line with the appropriate measures set out in section 3.3 of EPR 5.07? No Provide justification for departure from EPR 5.07 and submit a copy of the procedures Document reference Yes Document reference 5 Are you proposing to either ● accept an additional waste not included in table 2.1 of section 2.1 of EPR 5.07, or ● apply a permitted activity to a waste other than that identified for that waste in table 2.1? No Yes Provide justification Document reference 6 Please provide a summary description of the treatment activities undertaken on the installation. This should cover the general principles set out in section 2.1.4 of EPR 5.07 Document reference 7 Please provide layout plans detailing the location of each treatment plant and main plant items and process flow diagrams for the treatment plant Document reference
EPB3 Version 3, April 2011 page 14 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Appendix 5 – Specific questions for the hazardous and non hazardous waste recovery and disposal sector Note: If your procedures are fully in line with the standards set out in SGN 5.06 then you should tick the ‘yes’ box and provide the procedure reference. There is no need for you to supply a copy of the procedure. 1 Are pre acceptance procedures in place that are fully in line with the appropriate measures set out in section 2.1.1 of SGN 5.06, and which are used to assess a waste enquiry before it is accepted at the installation? No Provide justification for departure from SGN 5.06 and submit a copy of the procedures Document reference Yes Document reference 2 Are waste acceptance procedures in place that are fully in line with the appropriate measures set out in section 2.1.2 of SGN 5.06, and which are used to cover issues such as loads arriving and being inspected, sampling waste, rejecting waste, and keeping records to track waste? No Provide justification for departure from SGN 5.06 and submit a copy of the procedures Document reference Yes Document reference 3 Are waste storage procedures and infrastructure in place that are fully in line with the appropriate measures set out in section 2.1.3 of SGN 5.06? No Provide justification for departure from SGN 5.06 and submit a copy of the procedures Document reference Yes Document reference 4 Provide a layout plan giving details of where the installation is based, the infrastructure in place (including areas and structures for separately storing types of waste which may be dangerous to store together) and capacity of waste storage areas and structures Document reference 5 Provide a summary of the treatment activities carried out on the installation. This should cover the general principles set out in section 2.1.4 of SGN 5.06 and the specific principles set out in sections 2.1.5 to 2.1.15 as appropriate of SGN 5.06 Document reference 6 Provide layout plans giving details of where each treatment plant is based, the main items at each plant, and process flow diagrams for the treatment plant Document reference or references
EPB3 Version 3, April 2011 page 15 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Appendix 6 – Specific questions for the waste incineration sector If you are proposing to accept clinical waste please also fill in questions 1, 2 and 3 of appendix 4 above. 1a Do you run incineration plants as defined by the Waste Incineration Directive (2000/76/EC) (WID)? No You do not need to answer any other questions in this appendix Yes WID applies 1b Are you subject to WID as an incinerator or co incinerator? As an incinerator As a co incinerator 2 Do any of the installations contain more than one incineration line? No Now go to section 4 Yes 3 How many incineration lines are there within each installation? Fill in a separate table for each installation
Installation reference
Number of incineration lines within the installation
Reference identifiers for each line
You must provide the information we ask for in questions 4, 5 and 6 below in separate documents. The information must at least include all the details set out in section 2 (‘Key Issues’) of TGN S5.01 (under the subheading ‘European legislation and your application for an EP Permit’). 4 Describe how the plant is designed, equipped and will be run to make sure it meets the requirements of Council Directive 2000/76/EC, taking into account the categories of waste which will be incinerated Document reference 5 Describe how the heat created during the incineration and co incineration process is recovered as far as possible (for example, through combined heat and power, creating process steam or district heating) Document reference 6 Describe how you will limit the amount and harmful effects of residues and describe how they will be recycled where this is appropriate Document reference For each line identified in question 3, answer questions 7 to 13 below Question 3 identifier, if necessary 7 Do you want to take advantage of the Article 13 allowance (see below) if the particulates, CO or TOC continuous emission monitors (CEM) fail? No Yes Article 13 WID allows ‘abnormal operation’ of the incineration plant under certain circumstances when the CEM for releases to air have failed. Article 13 (4) sets maximum half hourly average release levels for particulates (150mg/m3), CO (normal ELV) and TOC (normal ELV) during abnormal operation. Describe the other system you use to show you keep to the requirements of Article 13(4) (for example, using another CEM, providing a portable CEM to insert if the main CEM fails, and so on).
EPB3 Version 3, April 2011 page 16 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Appendix 6 – Specific questions for the waste incineration sector, continued 8 Do you want to replace continuous HF emission monitoring with periodic hydrogen fluoride (HF) emission monitoring by relying on continuous hydrogen chloride (HCl) monitoring as allowed by WID Article 11(4)? Under WID Article 11 (4), you do not have to continuously monitor emissions for hydrogen fluoride if you control hydrogen chloride and keep it to a level below the HCl ELVs. No Yes Please give reasons for doing this
9 Do you want to replace continuous water vapour monitoring with pre analysis drying of exhaust gas samples, as allowed by WID Article 11 (5)? Under WID Article 11 (5), you do not have to continuously monitor the amount of water vapour in the air released if the sampled exhaust gas is dried before the emissions are analysed. No Yes Please give your reasons for doing this
10 Do you want to replace continuous hydrogen chloride (HCl) emission monitoring with periodic HCl emission monitoring, as allowed by WID Article 11 (6)? Under WID Article 11 (6), you do not have to continuously monitor emissions for hydrogen chloride if you can prove that the emissions from this pollutant will never be higher than the ELVs allowed. No Yes Please give your reasons for doing this
EPB3 Version 3, April 2011 page 17 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Appendix 6 – Specific questions for the waste incineration sector, continued 11 Do you want to replace continuous HF emission monitoring with periodic HF emission monitoring, as allowed by WID Article 11 (6)? Under WID Article 11 (6), you do not have to continuously monitor emissions for hydrogen fluoride if you can prove that the emissions from this pollutant will never be higher than the ELVs allowed. No Yes Please give your reasons for doing this
12 Do you want to replace continuous SO2 emission monitoring with periodic sulphur dioxide (SO2) emission monitoring, as allowed by WID Article 11 (6)? Under WID Article 11 (6), you do not have to continuously monitor emissions for sulphur dioxide if you can prove that the emissions from this pollutant will never be higher than the ELVs allowed. No Yes Please give your reasons for doing this
13 If your plant uses fluidised bed technology, do you want to apply for a derogation of the CO WID ELV to a maximum of 100 mg/m3 as an hourly average, as allowed by WID Annex V (e)? No Does not apply Yes Please give your reasons for doing this
EPB3 Version 3, April 2011 page 18 of 19 Form EPB: Application for an environmental permit – Part B3 new bespoke installation permit Appendix 7 – Specific questions for the landfill sector 1 Provide your Environmental Setting and Installation Design (ESID) report Document reference 2 Provide your hydrogeological risk assessment (HRA) for the site Document reference 3 Provide your stability risk assessment (SRA) for the site Document reference 4 Provide your landfill gas risk assessment (LFGRA) for the site Document reference We have developed templates for these four reports which can be found within H1 – Landfill Annex. 5 Provide your proposed plan for closing the site and your procedures for looking after the site once it has closed Document reference
EPB3 Version 3, April 2011 page 19 of 19
Form EPF: Application for an environmental permit – Part F1 Opra, charges, declarations Application for an environmental permit Part F1 – Opra, charges and declarations
Fill in this part for all applications for installations, Contents waste operations, mining waste operations and 1 Working out charges groundwater discharges onto land. 2 Opra scores 3 Payment For applications for water discharge and point source 4 The Data Protection Act 1998 groundwater discharge activities you need to fill in 5 Confidentiality and national security part F2 instead. 6 Declaration Please read through this form and the guidance 7 Application checklist notes that came with it. Please write clearly in the 8 How to contact us answer spaces. 9 Where to send your application It will take less than two hours to fill in this part of the application form.
1 Working out charges (you must fill in this section) You have to submit an application fee with your application. You can find out the charge by either looking at the relevant standard rules permit page, the ‘Making an application’ webpage at http://www.environment-agency.gov.uk/business/topics/ permitting/32318.aspx, or the current environmental permitting charging scheme on our website at www.environment-agency.gov.uk which sets out our charges under the Environmental Permitting Regulations. Please remember that the charges are revised on 1 April each year and that there is an annual subsistence charge to cover the costs we incur in the ongoing regulation of the permit. Note: for Opra charged Tier 3 Facilities you also need to complete the Opra profile detail in table 2. Table 1 – Working out charges
Type of application OPRA CHARGED TIER 3 INSTALLATION Summary of charges Tier 2 facilities Charge identifier Number of facilities Charge for each Charges due (£) facility (£)
0.00 0.00 0.00 0.00 0.00 0.00 0.00 Tier 3 facilities Total Opra charging score for × charge multiplier = 220.00 201.00 44,220.00 installations (and fill in section 2) Total Opra charging score for waste × charge multiplier = 0.00 operations (and fill in section 2) Total Opra charging score for mining × charge multiplier = 0.00 waste facilities (and fill in section 2) Other charges 0.00 Total charges due 44,220.00
EPF1 Version 3, April 2011 page 1 of 6 Form EPF: Application for an environmental permit – Part F1 Opra, charges, declarations 2 Opra scores (does not apply to standard facilities, any other tier 2 permit applications (e.g. groundwater land spreading activities), or water-discharge or groundwater point source discharge activities) Fill in table 2 below for your current Opra profiles at the time you make this application. Fill in ● one summary table for all installations; ● one for all waste facilities; ● one for all category A mining waste facilities and mining waste facilities for hazardous wastes. For transfers you will need to submit a revised OPRA profile to include your own Operator performance. Note: this will not change the set transfer fee. Table 2 – Summary of Opra scores Activity references HPC Combustion Plant Complexity band Number of activities (or Band score Charging score individual mining waste facilities) within each band A B C 3 45 135 D E Emissions Band Band score Charging score Air - - 0 Water - - 0 Land - - 0 Sewer - - 0 Waste input - - 0 Offsite waste - - 0 Other Band Band score Charging score Location B 6 10 Operator’s performance E <2 75
Compliance rating (not - - - applicable for new applications) Total Opra charging score 220 If you are submitting a bespoke application, you must include a completed electronic copy in Excel of the current Opra spreadsheet.
3 Payment Tick below to show how you have paid. Cheque ✔ Postal order Cash Tick below to confirm you are enclosing cash with the application Credit or debit card Electronic transfer (for example, BACS) Remittance number Date paid (DD/MM/YYYY) How to pay Paying by cheque, postal order or cash Cheque details Cheque made payable to Environment Agency Cheque number Amount £ 44,220.00 EPF1 Version 3, April 2011 page 2 of 6 Form EPF: Application for an environmental permit – Part F1 Opra, charges, declarations 3 Payment, continued You should make cheques or postal orders payable to ‘Environment Agency’ or ‘Environment Agency Wales’ as appropriate and make sure they have ‘A/c Payee’ written across them if it is not already printed on. Please write the name of your company and application reference number on the back of your cheque or postal order. We will not accept cheques with a future date on them. Note: we will process cheques once your application is confirmed as having been duly made – normally within 10 working days unless information is missing. We do not recommend sending cash through the post. If you cannot avoid this, please use a recorded delivery postal service and enclose your application reference details. Please tick the box below to confirm you are enclosing cash. I have enclosed cash with my application Paying by credit or debit card If you are paying by credit or debit card, please fill in the separate form CC1 and enclose it with the application. We will destroy your card details once we have processed your payment. We can accept payments by Visa, MasterCard or Maestro card only. Paying by electronic transfer BACS reference Applying for a permit in Wales? If you choose to pay by electronic transfer and you are applying for a permit in the EA Wales region, you will need to use the following information to make your payment. Company name: Environment Agency Wales Company address: PO Box 663, Cardiff, CF24 0TP Bank: Barclays Bank Plc Address: 15 Queen Square, Bristol, BS1 4NP Sort code: 20-13-42 Account number: 00440108 Payment reference number: PSCAPPXXXXXYYY You need to create your own reference number. It should begin with PSCAPP (to reflect that the application is for a permitted activity) and it should include the first five letters of the company name (replacing the X’s in the above reference number) and a unique numerical identifier (replacing the Y’s in the above reference number). The reference number that you supply will appear on our bank statements. You should also email your payment details and a reference number to [email protected] or fax it to 02920 466 404. If you are making your payment from outside the United Kingdom, it must be in sterling. Our IBAN number is GB42 BARC2013 4200 4401 08 and our SWIFTBIC number is BARC GB22. If you do not quote your reference number, there may be a delay in processing your payment and application. Applying for a permit in England? If you choose to pay by electronic transfer and you are applying for a permit for another (English) region, you will need to use the following information to make your payment. Company name: Environment Agency Company address: Income Dept 311, PO Box 263, Peterborough, PE2 8YD Bank: Barclays Bank Plc Address: 15 Queen Square, Bristol, BS1 4NP Sort code: 20-13-42 Account number: 20744646 Payment reference number: PSCAPPXXXXXYYY You need to create your own reference number. It should begin with PSCAPP (to reflect that the application is for a permitted activity) and it should include the first five letters of the company name (replacing the X’s in the above reference number) and a unique numerical identifier (replacing the Y’s in the above reference number). The reference number that you supply will appear on our bank statements. You should also email your payment details and reference number to [email protected] or fax it to 01733 464 892. If you are making your payment from outside the United Kingdom, it must be in sterling. Our IBAN number is GB42 BARC2013 4220 7446 46 and our SWIFTBIC number is BARC GB22. If you do not quote your reference number, there may be a delay in processing your payment and application. Now read section 4 below. 4 The Data Protection Act 1998 We, the Environment Agency, will process the information you provide so that we can: ● deal with your application;
EPF1 Version 3, April 2011 page 3 of 6 Form EPF: Application for an environmental permit – Part F1 Opra, charges, declarations 4 The Data Protection Act 1998, continued ● make sure you keep to the conditions of the licence, permit or registration; ● process renewals; and ● keep the public registers up to date. We may also process or release the information to: ● offer you documents or services relating to environmental matters; ● consult the public, public organisations and other organisations (for example, the Health and Safety Executive, local authorities, the emergency services, the Department for Environment, Food and Rural Affairs) on environmental issues; ● carry out research and development work on environmental issues; ● provide information from the public register to anyone who asks; ● prevent anyone from breaking environmental law, investigate cases where environmental law may have been broken, and take any action that is needed; ● assess whether customers are satisfied with our service, and to improve our service; and ● respond to requests for information under the Freedom of Information Act 2000 and the Environmental Information Regulations 2004 (if the Data Protection Act allows). We may pass the information on to our agents or representatives to do these things for us. Now read section 5 below.
5 Confidentiality and national security We will normally put all the information in your application on a public register of environmental information. However, we may not include certain information in the public register if this is in the interests of national security, or because the information is confidential. You can ask for information to be made confidential by enclosing a letter with your application giving your reasons. If we agree with your request, we will tell you and not include the information in the public register. If we do not agree with your request, we will let you know how to appeal against our decision, or you can withdraw your application. You can tell the Secretary of State that you believe including information on a public register would not be in the interests of national security. You must enclose a letter with your application telling us that you have told the Secretary of State and you must still include the information in your application. We will not include the information in the public register unless the Secretary of State decides that it should be included. Only tick the box below if you wish to claim confidentiality for your application Please treat the information in my application as confidential Tick the box below if you have written to the Secretary of State or Welsh ministers to claim national security for your application I attach a letter stating that I have written to the Secretary of State or Welsh ministers explaining why my information should not be included on the public register for national security reasons Now go to section 6
6 Declaration If you knowingly or carelessly make a statement that is false or misleading to help you get an environmental permit (for yourself or anyone else), you may be committing an offence under the Environmental Permitting (England and Wales) Regulations 2010. A relevant person should make the declaration (see guidance notes on part F1). If you are transferring all or part of your permit, both you and the person receiving the permit must make the declaration. I declare that the information in this application is true to the best of my knowledge and belief. I understand that this application may be refused or approval withdrawn if I give false or incomplete information. If you deliberately make a statement that is false or misleading in order to get approval you may be prosecuted. I confirm that my standard facility will fully meet the rules that I have applied for (this only applies if the application includes standard facilities) Tick this box to confirm that you understand and agree with the declaration above, then fill in the details below ✔ Name Title (Mr, Mrs, Miss and so on) Mr First name A. Christopher Last name Bakken, III on behalf of (for example, if applying on behalf of a company – see guidance to this form) NNB Generation Company Limited
EPF1 Version 3, April 2011 page 4 of 6 Form EPF: Application for an environmental permit – Part F1 Opra, charges, declarations 6 Declaration, continued Position Project Director - Hinkley Point C Today’s date (DD/MM/YYYY) 29/07/2011 For transfers only – declaration for person receiving the permit A relevant person should make the declaration (see guidance notes on part F1). I declare that the information in this application to transfer an environmental permit to me is true to the best of my knowledge and belief. I understand that this application may be refused or approval withdrawn if I give false or incomplete information. If you deliberately make a statement that is false or misleading in order to get approval you may be prosecuted. Tick this box to confirm that you understand and agree with the declaration above Name Title (Mr, Mrs, Miss and so on) First name Last name on behalf of (for example, if applying on behalf of a company – see guidance to this form) Position Today’s date (DD/MM/YYYY) Now go to section 7
7 Application checklist (you must fill in this section) Tell us what you have sent with this application. The correct application fee under our charging scheme ✔ Tick the box to say you have included the fee List all the documents you have included. If necessary, continue on a separate sheet and tell us the reference you have given the document below. Document reference Main application and Appendix A (SCR)
Question reference Document title Document reference
B2 6b Appendix A of Main Application All other questions answered in the Main Application Document
EPF1 Version 3, April 2011 page 5 of 6 Form EPF: Application for an environmental permit – Part F1 Opra, charges, declarations
8 How to contact us If you need help filling in this form, please contact the person who sent it to you or contact us as shown below. General enquiries: 08708 506 506 (Monday to Friday, 8am to 6pm) Textphone: 08702 422 549 (Monday to Friday, 8am to 6pm) Email: [email protected] Website: www.environment-agency.gov.uk If you are happy with our service, please tell us. It helps us to identify good practice and encourages our staff. If you’re not happy with our service, please tell us how we can improve it. Please tell us if you need information in a different language or format (for example, in large print) so we can keep in touch with you more easily.
9 Where to send your application (for how many copies to send see the guidance note on part F1) Please send your filled in application form to: Permitting Support Centre Quadrant 2 99 Parkway Avenue Parkway Business Park Sheffield S9 4WF
Feedback (You don’t have to answer this part of the form, but it will help us improve our forms if you do.) We want to make our forms easy to fill in and our guidance notes easy to understand. Please use the space below to give us any comments you may have about this form or the guidance notes that came with it.
How long did it take you to fill in this form? 30 minutes We will use your feedback to improve our forms and guidance notes, and to tell the Government how regulations could be made simpler. Would you like a reply to your feedback? Yes please No thank you
For Environment Agency use only Date received (DD/MM/YYYY) Payment received? No Our reference number Yes Amount received £
EPF1 Version 3, April 2011 page 6 of 6 Combustion Activity Submission Hinkley Point C Appendix F
Appendix F Completed EPR OPRA Spreadsheet
NNB-OSL-REP-000252 Combustion Activity Submission Hinkley Point C Appendix F
THIS PAGE IS LEFT INTENTIONALLY BLANK
NNB-OSL-REP-000252 Operational Risk Appraisal (Opra) for Installations under EPR
NNB Generation Company Case EPR/ZP3238FH/A001 Organisation Name Limited Number
Version 3.6 Opra Scheme Version 3.6
Full instructions for the use of this spreadsheet are contained in the accompanying documentation. It is recommended that the user fills in the spreadsheet following the order of worksheets listed below (click on the appropriate tab at the bottom of the screen). Not all worksheets require input, for those that do, the fields that may require input have no background colour. The sequence of worksheets is divided into two sections Sheets 1 to 11 are concerned with the input of data. Sheet 12 is the summary for the Opra Scores and Sheet 13 displays the charges. If you cannot see the whole of this box or it is very small, please click 'View' and adjust 'Zoom' level.
1 Listed Activities 9 Emissions Summary Please refer to the Opra Scheme for Installations for the look-up tables and No input is required. Output screen only. Summary of emissions. guidance. 10 Location Use abbreviated descriptions, select the Schedule 1 references and bands from the pick lists provided. 11 Operational Management 2 Other Activities Please enter Part A(2), Part B and aggregated activities onto this sheet. 12 Opra Summary 3 Complexities No input is required. Output screen only. The emissions are shown separately. Summary of complexities and rules applied 4 Emissions to Air 13 Calculation No input is required. Charges with separate emissions totals. It is 5 Emissions to Water possible to clear the scores and recalculate the charges to include any amendments. 6 Emissions to Land
7 Emissions to Sewer For queries about the scheme or the operation of the spreadsheet, please contact the Environment Agency by email: 8 Emissions to Waste [email protected]
For EA Use Consolidated Permit
Page 1 of 32 Page 2 of 32 Listed Activities - Complexity Attribute
Organisation: NNB Generation Company Limited Case Number: EPR/ZP3238FH/A001
Former Permit Regulatory Totals before any rules are Ref (If Description of Activity Schedule 1 Reference Complexity applied applicable)
1 Back-up diesel generators 1.1 Part A (1) a) (i) C A 0 2 Back-up diesel generators 1.1 Part A (1) a) (i) C B 0 3 Back-up diesel generators 1.1 Part A (1) a) (i) C C 3 4 D0 5 E0 6 7 8 9 10 11 12 13 14 15 16 17 18 If there is insufficient space please 19 attach a paper record 20 21 22 23 24 25
If Rule 4 applies - please complete Other Activities sheet
2 of 18 11/07/2011 Page 3 of 32 Page 4 of 32 Aggregation and Schedule1 Part A(2) and Part B Activities - see Chapter 4
Organisation Name: NNB Generation Company Limited If there is insufficient space Case Number: EPR/ZP3238FH/A001 please attach a paper record
Schedule 1 Part A(1) - Rule 4 Aggregation Details Former Permit Ref (If Aggregation Description Schedule 1 Ref Complexity applicable) Group 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Rule 4 Not Applied
List of Schedule 1 Part (A) 2 and Part B Activities included in the Installation Enter description of Activity Schedule 1 Reference 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Page 5 of 32 Page 6 of 32 EPR- Installations Charging Scheme Complexity - Application of Rules
Company NNB Generation Company Limited Permit EPR/ZP3238FH/A001
Former Permit Description / Schedule 1 Rule 3 Rule 5 not Rule 6 not Rule 7 Not Ref (if Aggregation Complexity Ref Capping applied applied Applied applicable) Group 1 Back-up diesel generators 1.1 Part A (1) a) (i) C CCCC 2 Back-up diesel generators 1.1 Part A (1) a) (i) C CCCC 3 Back-up diesel generators 1.1 Part A (1) a) (i) C CCCC 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30
Summary of Rules Applied Rule 3 No These totals will be carried forward and used to calculate Rule 4 No the Opra Risk Summary and Calculation of Charges Rule 5 No Rule 6 No Rule 7 No
Scores after Rules applied (Used for calculation of Charges) Scores before rules applied (Used for Remaining summary of Risk) Complexity First 6 Complexities complexities Total A 0000 B 0000 C 3033 D 0000 E 0000 Capped 000
Page 7 of 32 Page 8 of 32 Emissions to Air
Emissions Attribute - Releases to Air
Organisation Name: Please check that the data is entered in the NNB Generation Company Limited correct units. The Emission Index will only show if the data Case Number: EPR/ZP3238FH/A001 entered exceeds the threshold.
Please tick box if this sheet is applicable
Substance Units Emission Maximum Emission Notes Threshold Quantity Index
5 of 18 11/07/2011
Page 9 of 32 Page 10 of 32 Emissions to water
Emissions Attribute - Releases to Water
Orgnisation Name: NB Generation Company Limit Please check that the data is entered in the correct units. Case Number: EPR/ZP3238FH/A001 The Emission Index will only show if the data entered exceeds the threshold.
Please tick box if this sheet is applicable
Emission Maximum Emission Substance Units Threshold Quantity Index Notes
6 of 18 Page 11 of 32 11/07/2011 Page 12 of 32 Emissions Attribute Releases to Land
Organisation Name: eneration Company Limited Please check that the data is entered in the correct units. Case Number: PR/ZP3238FH/A001 The Emission Index will only show if the data entered exceeds the threshold.
Please tick box if this sheet is applicable
Emission Maximum Emission Substance/Landfill Type Units Threshold Quantity Index Notes Inert waste Tonnes year 1000 0 Non hazardous waste (non biodegradable) Tonnes year 350 0 Hazardous waste Tonnes year 100 0 Non hazardous waste (biodegradable) Tonnes year 100 0
Total 0
7 to 18 11/07/2011 Page 13 of 32 Page 14 of 32 Emissions to sewer
Emissions Attribute - Off-site Disposals to Sewer
Orgasination Name: NNB Generation Company LimitedPlease check that the data is entered in the correct units. Case number: EPR/ZP3238FH/A001 The Emission Index will only show if the data entered exceeds the threshold.
Please tick box if this sheet is applicable
Emission Maximum Emission Substance Units Threshold Quantity Index Notes
8 of 18 Page 15 of 32 11/07/2011 Page 16 of 32 Emissions Attribute - Off-site Disposals of Waste
Organisation Name: eneration Company Limited Please check that the data is entered in the correct units. Case Number: PR/ZP3238FH/A001 The Emission Index will only show if the data entered exceeds the threshold.
Emission Maximum Emission Substance Units Threshold Quantity Index Notes Inert waste Tonnes year 1000 0 Non hazardous waste (non biodegradable) Tonnes year 350 0 Hazardous waste Tonnes year 100 0 Non hazardous waste (biodegradable) Tonnes year 100 0 Total 0 Weighting Factor 0.33 (Weighting factor = 0.33) Weighted Total 0
Emissions Attribute - Off-site Recovery, Recycling, Re-use of Waste
Company eneration Company Limited Please check that the data is entered in the correct units. Permit PR/ZP3238FH/A001 The Emission Index will only show if the data entered exceeds the threshold.
Emission Maximum Emission Substance Units Threshold Quantity Index Notes Inert waste Tonnes year 1000 0 Non hazardous waste (non biodegradable) Tonnes year 350 0 Hazardous waste Tonnes year 100 0 Non hazardous waste (biodegradable) Tonnes year 100 0
Total 0 Weighting Factor 0.1 (Weighting factor = 0.1) Weighted Total 0 Off-Site Total 0
9 of 18 11/07/2011 Page 17 of 32 Page 18 of 32 Emissions Attribute Summary Sheet
Organisation: B Generation Company Limited Case Number: EPR/ZP3238FH/A001 Air Pathway Overall Emission Index Water Air 0 Land Water 0 Sewer Land 0 Sewer 0 Waste Off Site Waste Off Site 0 Waste Input Waste Input 0
Band 5 Pathway Band 4 Air 0 - 3 Water 0 - 2 Land 0 - Sewer 0 - 1 Waste Off Site 0 - 0 Waste Input 0 - Air Water Land Sewer Waste Waste Off Site Input
10 of 18 11/07/2011 Page 19 of 32 Page 20 of 32 Location Attribute
Location Attribute
Organisation Name: NNB Generation Company Limited Case Number: EPR/ZP3238FH/A001
Parameter Yes/No Available Score Human Occupation/Presence: a) if within 50m of the installation site boundary No 5 or: 0 b) if greater than 50m but less than 250m of boundary No 3 or: c) if greater than 250m but less than 1km of boundary No 1 Statutory sitesdesignated under Wildlife and Countryside, Habitats legislation: a) if a Habitats "appropriate assessment" is required Yes 3 3 or b) if only CROW Act 2000 assessment required No 2 a) if on an aquifer and within a Groundwater Protection Zone No 2 or 0 b) if on an aquifer and not within a Groundwater Protection Zone No 1 (Data obtained from Agency Published Guidance) Sensitivity of receiving waters (information available from Agency's Whats in my back yard "Whats in my back yard" web site), if: a) grade 5 No 1 3 b) river category grade 4 or 3 No 2 c) river category grade 2 or 1 or esturial Yes 3 a) If there are direct runs off to water without interceptors or other active control measures No 2 or 0 b) If as above but there are interceptors or active control measures No 1 a) If within an Air Quality Management Zone (AQMZ) and emit pollutant that has been declared for that AQMZ No 3 or b) If within 2km of an Air Quality Management Zone (AQMZ) and emit 0 pollutant that has been declared for that AQMZ No 2 or c) as a) except do not emit polutants that have be declared for the No 1 AQMZ If within a flood plain No 2 0 Maximum Score = 20 Total 6 Band A = 0 - 4, B = 5 - 8, C = 9 - 12, D = 13 - 17 and E = 18 - 20 Band B
Location Attribute Profile
Location Attribute Totals Score Occupation 0 5 Habitats 3 4 Aquifers 0 3 Receiving Waters 3 2
Run OffScore 0 1 Air Quality 0 Flood Plain0 0 Plain Flood Run Off Habitats Waters Aquifers Receiving Air Quality Occupation
11 of 18 11/07/2011 Page 21 of 32 Page 22 of 32 Operator Performance
Yes/No Points Points scoredPost or group responsible for each Document reference (*) available requirement or date by which systems will be in place (*see para 4.4.2)
Operations and Maintenance section - 20% Effective operational and prev maintenance sys shall be employed on all aspects of the process where any failure could impact on the environment. 1 Are there documented operating No 2.0 0.0Systems under devlopment Available prior to procedures for operations that may have commissioning an adverse impact on the environment?
2 Is there a defined procedure for No 2.0 0.0Systems under devlopment Available prior to identifying, reviewing and prioritising items commissioning of plant for which a preventative maintenance regime is appropriate? 3 Are there documented procedures for No 2.0 0.0Systems under devlopment Available prior to monitoring emissions or impacts? commissioning 4 Is there a preventative maintenance No 1.0 0.0Systems under devlopment Available prior to programme for those items of plant whose commissioning failure could lead to impact on the environment? 5 Does the preventative maintenance No 1.0 0.0Systems under devlopment Available prior to programme include regular checks and commissioning formal inspections of 'static' items such as tanks, pipework, retaining walls, bunds and ducts? 6 Do the operations and maintenance No 2.0 0.0Systems under devlopment Available prior to systems include auditing environmental commissioning performance? 7 Are the reports, results and No 2.0 0.0Systems under devlopment Available prior to recommendations arising from audits commissioning made available to senior management on a regular basis? 8 In the last two years, has there been any No -2.0 0.0 notifiable incident or release for which lack of maintenance was a contributory cause ? 9 In the last two years, has there been any No -3.0 0.0 notifiable incident or release for which the root cause could not be identified?
Operations and Maintenance Total 12.0 0.0 0.0% 0.0
Competence and Training - 20% The Operator shall ensure that all relevant management and operational staff (including contractors and those responsible for purchasing equipment and materials) receive adequate training with regard to their responsibilities under the Permit. Particular attention should be given to the following: Minimisation of all potential environmental effects from operation under normal, abnormal, start up and shut down circumstances; Prevention of accidental emissions and action to be taken when accidental emissions occur; and The need to report deviation from the permit.
1 Has a training needs assessment been No 3.0 0.0 Systems under devlopment Available prior to carried out which: commissioning Identifies all posts for which Systems under devlopment specific environmental awareness training is required; and Identifies the scope and level to which such training is to be given? 2 Are training systems in place for all relevant staff that cover the following factors: the regulatory requirements No 2.0 0.0Systems under devlopment Available prior to associated with the Permit as they commissioning affect their work activities and responsibilities; likely potential environmental No 2.0 0.0Systems under devlopment Available prior to impacts which may be caused by plant commissioning under their control. This should cover both normal and abnormal circumstances; reporting procedures to inform No 1.0 0.0Systems under devlopment Available prior to supervisors or managers of deviations commissioning from permit conditions; procedures to be used by No 2.0 0.0Systems under devlopment Available prior to supervisors or managers and for the commissioning reporting of deviations from permit conditions to the Agency; and
prevention of accidental emissions No 2.0 0.0Systems under devlopment Available prior to and action to be taken when accidental commissioning emissions occur? 3 Are the skills and competencies necessary No 1.0 0.0Systems under devlopment Available prior to for key posts documented and are records commissioning of training needs and training received maintained? 4 Do the key posts include contractors, No 1.0 0.0Systems under devlopment Available prior to those responsible for liaising with commissioning contractors and those purchasing equipment and materials?
12 of 18 Page 23 of 32 11/07/2011 Operator Performance
Yes/No Points Points scoredPost or group responsible for each Document reference (*) available requirement or date by which systems will be in place (*see para 4.4.2)
5 Do you assess the potential environmental No 1.0 0.0Systems under devlopment Available prior to risks posed by the work of contractors and commissioning provide instructions to contractors about protecting the environment while working on site? 6 In the last 2 years, have there been any no -2.0 0.0 notifiable incidents or releases, which it has been identified that lack of training was a contributory cause ? 7 If there industry standards for training in -2.0 0.0 this sector (e.g. WAMITAB) if so do you apply them? (If no industry standards please leave blank) 8 Are individual and organisational training No 2.0 0.0 needs reviewed on a regular (e.g. annual) basis?
Competance Training Total 17.0 0.0
Emergency planning - 20% The Operator shall maintain an accident management plan which identifies potential events or failures which might lead to an environmental impact. The plan shall identify: the likelihood of, and the actions to be taken to minimise, these potential occurrences; the environmental consequences and an action plan to deal with such occurrences; The Operator shall have a written procedure for handling, investigating, communicating and reporting of incidents and actual or potential non-compliance with permit conditions including taking action to mitigate any impacts caused and for initiating and completing corrective action. In the case of abnormal emissions the operator shall; investigate and undertake remedial action immediately; promptly record the events and actions taken; and ensure the Regulator is made aware, as soon as practicable. 1 Is there an accident plan that complies No 4.0 0.0Systems under devlopment Available prior to with guidance covering the following commissioning aspects of foreseeable scenarios: liklihood, consequences,actions to prevent, action to take in the event it occurs? 2 Has the plan identified areas where 1.0 0.0 improvement is needed? 3 Where improvement has been identified, -2.0 0.0 does the plan include an implementation programme with acceptable timescales to the Agency? If not, 2 points will be deducted. 4 Are there written procedures for handling, No 1.0 0.0Systems under devlopment Available prior to investigating, communicating and commissioning reporting actual or potential non compliance with operating procedures or emission limits? 5 Are there written procedures for handling, No 1.0 0.0Systems under devlopment Available prior to investigating, communicating and commissioning reporting environmental complaints?
6 Are there written procedures for No 2.0 0.0Systems under devlopment Available prior to investigating incidents, (and near-misses) commissioning including identifying suitable corrective action and following up implementation of that action? 7 In the last 2 years, have there been any No -2.0 0.0 notifiable incidents or releases for which it has been identified that lack of emergency planning was a contributory cause ?
8 Are there audit records of investigations No 3.0 0.0Systems under devlopment Available prior to into non compliance, complaints and commissioning incidents? Does the audit cover follow up actions? Do the audit reports go to senior managers? Emergency planning Total 12.0 0.0
Organisation - 40% The following aspects of site management procedures and controls may not be in the permit conditions but are likely to have an impact on the Agency resources required to apply the Env Permitting Regulations. 1 Do you operate an externally audited environment management system, if so answer one of the following questions. N.B Please enter your Certificate Number, Name of certification body and their UKAS Registration Number in the space for document reference. 1.1 Is your Environmental Management No 20 0 System EMAS registered? If yes select Y and go to question 4. 1.2 Is your Environmental Management No 15 0 System certified to ISO 14001? If yes enter Y and go to questions 3 and 4.
13 of 18 Page 24 of 32 11/07/2011 Operator Performance
Yes/No Points Points scoredPost or group responsible for each Document reference (*) available requirement or date by which systems will be in place (*see para 4.4.2)
1.3 Is your system an Environmental 12 0 Mangement System subject to external audit through a third party audit programme with a published methodology (excludes in-house company audit programme). If yes enter and go to questions 3 and 4. Sub Total Max 20 0.00 2 If you do not operate an externally audited environmental management system then assessyour system against the criteria below:
2.1 Has your company adopted an environmental policy and programme which : includes a commitment to 1.0 0.0 continual improvement and prevention of pollution? includes a commitment to comply 1.0 0.0 with relevant legislation, and with other requirements that the organisation subscribes to? identifies, sets, monitors and 1.0 0.0 reviews environmental objectives, independently of the permit? 2.2 Are there procedures that incorporate environmental issues into the following areas (as supported by demonstrable evidence e.g. written procedures): the control of process change on 1.0 0.0 the installation; design and review of new 1.0 0.0 facilities (including provision for their decommisioning), engineering and other capital projects; capital approval; 1.0 0.0 purchasing policy; 1.0 0.0 2.3 Are there audits, at least annually, to 1.0 0.0 check that all activities are being carried out in conformity with the above requirements? 2.4 Are they independent? (name the 2.0 0.0 auditing body) 2.5 Are there reports annually on 1.0 0.0 environmental performance, objectives and targets, future planned improvements and or facilitate (participate in) local community liaison meetings? 3 Does your company produce a public No 1.0 0.0 environmental statement? You may score in this box for ISO 14001 and industry systems but not for EMAS as this is a requiremen for EMAS.
4 Within the past 5 years have you failed to 0 -2.0 0.0 meet an improvement condition either set by the Agency in a Permit or Variation by the due date, without prior agreement? (minus 2 for each failure). ADD NUMBER OF FAILURES NOT Y OR N
Organisational Totals 20.0 0.00
Enforcement History (0 to -40% weighting)
Notice etc Date Issued Date Spent 1 Enforcement , Improvement or Works 0 None 0 Notices issued in the past year by the 1st - 5 Environment Agency under any legislation, 2nd -10 by the Health and Safety Executive 3rd or more relevant to the COMAH Regulations or by -40 local authorities under Part I of the Environmental Protection Act 1990 or relevant notice or Abatement Notices issued by local authorities or magistrates courts under Part III of the Environmental Protection Act 1990 (in all cases, other than any overturned on appeal by the Operator)
2 Formal cautions issued by the 0 None 0 Environment Agency in respect offences 1st - 5 under any legislation in the last 3 years. 2nd -10 3rd or more -40
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Yes/No Points Points scoredPost or group responsible for each Document reference (*) available requirement or date by which systems will be in place (*see para 4.4.2)
30Prohibition, Suspension or Revocation None 0 Notices issued by the Environment 1st - 10 Agency under any legislation, by the 2nd or more Health and Safety Executive relevant to -40 the COMAH Regulations or by local authorities under Part I of the Environmental Protection Act 1990, (other than any overturned on appealed by the Operator) in the last 3 years
40Convictions on prosecutions brought by None 0 the Environment Agency under any 1st - 15 legislation, by the Health and Safety 2nd or more Executive relevant to the COMAH -40 regulations or by local authorities (in respect of offences under Parts I or III of the Environmental Protection Act 1990) in last 5 years (in last 10 years where a term of imprisonment was imposed on the Operator) (other than any overturned on appeal) [NB each individual offence counts separately].
Enforcement History Total Entered Spent Extant Score 1 Enforcement or Works Notices 0 0 0 If score is -40 please refer to Methodology page 2 Formal Cautions 0 0 0 24 3 Prohibition, Suspension or Revocation 00 0 0 Notices 4 Convictions on Prosecutions 0 0 0
Enforcement History Total (min -40) 0
Management Performance
1.0 0.9 0.8 0.7 0.6 0.5 0.4 0.3 Weighted Score 0.2 0.1 0.0 Maintenance 20% Training 20% Emergency Organisation 40% Enforcement Overall average Planning 20% History Penalty -up weighted score to 40%
Band E= less than 2 BAND= E D= 2 to 3.99, C= 4 to 5.99, B= 6 to 7.99 , A= 8 to 11
Company : NNB Generation Company Limited Permit: EPR/ZP3238FH/A001
Data calculations generating the above graph Summary Max Score from Normalised to Weighting Weighted score above scale out of 10
Maintenance 20% 12.00 0.00 0.00 20.00 0.0 Training 20% 17.00 0.00 0.00 20.00 0.0 Emergency Planning 20% 12.00 0.00 0.00 20.00 0.0 Organisation 40% 20.00 0.00 0.00 40.00 0.0 Enforcement History Penalty -up to 40% -40.00 0.00 0.00 40.00 0.0
Overall average weighted score 0.0
15 of 18 Page 26 of 32 11/07/2011 Opra Banded Profile
Organisation Name: NNB Generation Company Limited Case Number: EPR/ZP3238FH/A001
Profile before any rules or capping Opra Banded Profile used for applied charging Attribute Number Band Number Band Complexity 0A0A 0B0B 3C3C 0D0D 0E0E Emissions Air - - Water - - Land - - Sewer - - Waste Off Site - - Waste Input - - Location BB Operator Performance EE
16 of 18 11/07/2011 Page 27 of 32 Page 28 of 32 Organisation Name: NNB Generation Company Limited Case Number: EPR/ZP3238FH/A001 EPR Installations Application Charge Calculation (excludes Compliance Rating) Scoring Summary - Financial
Attribute Band Score Total Score Complexity A 0 2 0 B 0 15 0 C 3 45 135 D 0 82 0 E 0 110 0 Emissions to Air - 0 Emissions to Water - 0 Emissions to Land - 0 Emissions to Sewer - 0 Emissions to Off-site Waste - 0 Emissions - Waste Input - 0 Location B 10 Operator Performance E 75 Total Opra charging score 220.00
Indicative Fees & Charges Part A(2) and Part B Activities Application Fee £ 44,220.00 Please ensure that you have completed these entries in the Listed Activities sheet. The charge shown will not include any charges associated with Local Authority Part A (2) or Part B activities that Subsistence Charge* £ 21,560.00 form part of the installation. Refer to Installations Charging Scheme for further details. Substantial Variation £ 24,200.00 Opra Charge Multipliers Standard Variation £ 12,320.00 Application 201 Subsistence 98 Partial Surrender £ 21,120.00 Substantial Variation 110 Standard Variation 56 Full Surrender £ 27,280.00 Partial Surrender 96 Full Surrender 124 Closure £ - Closure (Landfill only)
* Does not take into account Compliance Rating
Page 29 of 32 Page 30 of 32 Compliance Rating
Category* Events Score per event Total 1 0 60 0 2 0 31 0 30 4 0 4 0 0.1 0
Compliance Index 0
Compliance Rating Band A
Compliance Rating Multiplier 95% * Under Compliance Classification Scheme (CCS)
Opra Score Without Compliance Rating 220 Including Compliance Rating 209
Subsistence Fee: £ 20,482.00
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