ENVIRONMENTAL PERMIT APPLICATION Stockley Park Dcs LON5 to LON8
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Virtus HoldCo Ltd ENVIRONMENTAL PERMIT APPLICATION Stockley Park DCs LON5 to LON8 70051165/LON5-8/001 FEBRUARY 2020 PUBLIC Virtus HoldCo Ltd ENVIRONMENTAL PERMIT APPLICATION Stockley Park DCs LON5 to LON8 TYPE OF DOCUMENT (VERSION) PUBLIC PROJECT NO. 70051165 OUR REF. NO. 70051165/LON5-8/001 DATE: FEBRUARY 2020 WSP 110 Queen Street Glasgow G1 3BX Phone: +44 141 429 3555 Fax: +44 141 429 3666 WSP.com PUBLIC QUALITY CONTROL Issue/revision First issue Revision 1 Revision 2 Revision 3 Remarks 1st Draft for 2nd Draft for client comment & issue client comment/input Date Nov 2019 February 2020 Prepared by C. Daniels, C. Daniels, Consultant Consultant; Signature Checked by D. Schoehuys, D. Schoehuys, Associate Associate Signature Authorised by S Clayton, Associate Signature Project number 70051165 70051165 Report number LON5-8/001 LON5-8/001 File reference \\uk.wspgroup.com\central data\Projects\700511xx\70051165 - Virtus - Generator Legislation Assessment\02 WIP\APPLICATION FINAL TEXTS ENVIRONMENTAL PERMIT APPLICATION PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165/Lon5-8/001 February 2020 Virtus HoldCo Ltd CONTENTS 1 INTRODUCTION 1 2 FORM A SUPPORTING INFORMATION 3 3 FORM B2 SUPPORTING INFORMATION 4 3.1 PRE-APPLICATION DISCUSSIONS 4 3.2 ABOUT THE SITE 5 3.3 ABILITY AS AN OPERATOR 6 3.4 PLANS 6 3.5 SITE CONDITION REPORT 8 3.6 ENVIRONMENTAL RISK ASSESSMENT 8 4 FORM B3 SUPPORTING INFORMATION 9 4.1 LISTED ACTIVITIES 9 4.2 EMISSIONS TO AIR, WATER, LAND 10 5 OPERATING TECHNIQUES 16 5.1 GENERAL 16 5.2 STANDARDS 19 5.3 MANAGEMENT SYSTEMS 19 5.4 GRID RELIABILITY 27 5.5 ENGINE AND SET UP CHOICE 28 5.6 FUEL STORAGE AND DELIVERIES 31 TABLES ENVIRONMENTAL PERMIT APPLICATION PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165/Lon5-8/001 February 2020 Virtus HoldCo Ltd Table 2-1 - Virtus HoldCo Directors 3 Table 4-1 – Types of Activities 9 Table 4-2 – Stockley Park Standby Generators 10 Table 4-3 – Standby Generator Emissions CAT 3516C 12 Table 4-4 – Operational Scenario Emissions 12 Table 5-1 – Routine Operational Scenario 16 Table 5-2 – Estimated Annual Fuel Consumption 17 Table 5-3 - Indicative BAT Requirements for Management Systems from GOV.UK Guidance 23 Table 5-4 - BAT Summary for Data Centre Standby Generators 29 FIGURES Figure 5-1 – Standby Generation for Data Centres Schematic 18 APPENDICES VIRTUS HOLDCO STRUCTURE MAPS AND PLANS AGENCY HABITATS REPORT DRAINAGE PLANS PLANNING STAGE AIR QUALITY HISTORY GENERATOR ENGINE DATASHEET ENVIRONMENTAL PERMIT APPLICATION PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165/Lon5-8/001 February 2020 Virtus HoldCo Ltd 1 INTRODUCTION WSP UK Ltd has been instructed by Virtus HoldCo Ltd, trading as Virtus Data Centres (the Operator, hereinafter called Virtus) to prepare an application for an Environmental Permit (EP) for the site referred to as Stockley Park Campus, Prologis Park West London, off Horton Road, UB11 1HB. The data centre at Stockley Park Campus is connected to the local electricity transmission network via multiple grid connections; however, given the nature of data centres and their requirement to have an available energy supply at all times, the site (once complete) will incorporate up to 72 diesel-fired standby generators across 4 separate buildings. These are referred to as London 5, London 6, London 7 and London 8 and will be operated independently but will all be grouped together in a single data centre campus under the same management system and management structure. The generators will provide power to the site in the event of an emergency situation such as a failure of the electricity transmission network. During such events there is a potential for a delay between fault detection and initial operation of these back-up generators; hence the initial uninterruptible power supply is provided by on-site battery arrays in order to cover this ‘time gap’ and the consequent loss or reduction in the power supply to the data servers. The rated generation capacity of the proposed generators is 2.0, 2.2, or 2.4MWe each with a thermal input of 5.71, 6.29, or 6.86MWth respectively (based on Agency calculation method). The total rated thermal input (under standby power operating conditions) of all generators across Stockley Park Campus will be 443.43MWth on completion (based on current design which may vary through the tender process). The Environmental Permitting (England and Wales) Regulations 2016 (as amended) (EPR) states: “…where two or more appliances with an aggregate rated thermal input of 50 or more megawatts are operated on the same site by the same operator, those appliances must be treated as a single appliance with a rated thermal input of 50 or more megawatts.” The site is therefore considered to be an “installation” as defined in Paragraph 1, Part 1, Schedule 1 of the EPR as: “a stationary technical unit where one or more activities are carried on”. The “activities” that are proposed at the installation are defined in Chapter 1, Schedule 1 of the EPR, under Section 1.1, Combustion Activities. This document is therefore submitted on behalf of the Operator to support the application for a new bespoke Environmental Permit for the site, as per the requirements of Section 2(1), Part 1, Schedule 5 of the EPR. It describes the operating techniques that will be implemented at the facility with respect to the diesel generators to ensure that environmental aspects are managed in compliance with the conditions of the Environmental Permit and in line with Best Available Techniques (BAT) requirements. For the purposes of this application, relevant technical standards in the following documents have been referenced: ENVIRONMENTAL PERMIT APPLICATION PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165/Lon5-8/001 February 2020 Virtus HoldCo Ltd Page 1 of 32 ¡ GOV.UK Develop a management system: environmental permits guidance, 14 January 2019; ¡ GOV.UK Risk assessments for your environmental permit guidance, 10 January 2019; ¡ Data Centre FAQ Headline Approach, dated 01/06/18 and 11/01/2019; ¡ Best Available Techniques (BAT) Reference Document for Large Combustion Plants, 2017 and the associated BAT Conclusions (Establishing Best Available Techniques (BAT) Conclusions, under Directive 2010/75/EU of the European Parliament and of the Council, for Large Combustion Plants, 31 July 2017); ¡ How To Comply With Your Environmental Permit Additional Guidance for Combustion Activities (EPR 1.01), 2014 (withdrawn). ENVIRONMENTAL PERMIT APPLICATION PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165/Lon5-8/001 February 2020 Virtus HoldCo Ltd Page 2 of 32 2 FORM A SUPPORTING INFORMATION Virtus HoldCo Director details are provided below Table 2-1 - Virtus HoldCo Directors Name Address Date of Birth Occupation Lim Ah Doo Director Zulkifli Bin Baharudin Director Neil David Cresswell CEO Bruno Lopez CEO Stephen Geoffrey Miller Director Sio Tat Hiang Director The company structure of Virtus HoldCo Ltd is appended as Appendix A. ENVIRONMENTAL PERMIT APPLICATION PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165/Lon5-8/001 February 2020 Virtus HoldCo Ltd Page 3 of 32 3 FORM B2 SUPPORTING INFORMATION 3.1 PRE-APPLICATION DISCUSSIONS Discussions were held between the Operator and Howard Tee and Guy Elliot of the Environment Agency (EA) on 11th July 2018 to outline the EA’s approach to permitting datacentres and to understand Virtus’ operations and obligations in relation to the EPR, followed up by e-mail on 12th July. A simple pre-application submission was made on-line using the Environment Agency web service, reference number EA/EPR/AP3903PD/A001 in January 2019. A further telephone conversation was held between WSP and Guy Elliot in April 2019 to clarify the general approach. In summary the approach adopted is: ¡ The Environmental Permit application will focus on the standby generators and associated routine activities (engine testing) and not the operation of other datacentre-related activities; ¡ The permit is required for the routine generator testing regime and associated emissions, however the air emissions dispersion modelling assessment submitted with this application will also include emergency operational periods; ¡ There may be a need for an air quality emergency action plan in conjunction with the Local Authority due to the location of the facility and the number of generators; and ¡ Noise impacts could also require a similar emergency action plan with the Local Authority depending on the outcome of the noise assessment. ¡ Best available techniques (BAT) for the generator engine planned maintenance and testing protocol is to minimise emissions at the worst times (limits on the test periods are enforced via planning consent conditions to ensure they are planned outside rush hour peaks). The maximum hours per generator should be logged and reported to be less than 50 hours per year to stay exempt from the Medium Combustion Plant specified generator requirements; ¡ Fuel delivery and storage will be considered in the BAT assessment; ¡ Details of reliability of the grid and connection philosophy etc. is required in the permit application as justification of the unlikely need for the standby role and peak impacts; ¡ A biodiversity pre-application screening assessment was included in the pre-app response; and ¡ The charge for the application was included in the pre-application response. The application comprises the following elements: ¡ Application forms (Parts A, B2, B3 and F1) ¡ Non-technical Summary ¡ Operating Techniques ¡ Environmental Risk Assessment ¡ Air Emissions Impact Assessment ¡ Noise Impact Assessment ¡ BAT discussions ¡ Site Condition Report ENVIRONMENTAL PERMIT APPLICATION PUBLIC | WSP Project No.: 70051165 | Our Ref No.: 70051165/Lon5-8/001 February 2020 Virtus HoldCo Ltd Page 4 of 32 3.2 ABOUT THE SITE The address of the site is: Virtus Data Centres Stockley Park campus Prologis Park West London, off Horton Road, London UB11 1HB OS national grid reference: TQ 07290 80155 Final planning permission for London 8 (the fourth unit currently under development which will be the final to be completed) was received in October 2019, reference 37977/APP/2019/1453.