Annual review of Environmental Performance 2013
www.drax.com
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1 Introduction
This is the eleventh published Environmental Performance Review produced by Drax Group which reviews the environmental performance of and environmental initiatives undertaken by Drax during 2013. Drax Group principally consists of Drax Power Limited (“Drax”) (which has responsibility for the operation and management of Drax Power Station, and the Goole biomass pelleting plant), Haven Power Limited (which is a provider of electricity to business customers within the UK), and Drax Biomass based in the US (which is a development and operating company focused on manufacturing wood pellets). The majority of our environmental impacts are directly associated with the operation of Drax Power Station and these are described in this document. The impacts of our other operations are regularly reviewed, but are generally non-material in relation to this report. During 2013, Drax Power Station was the largest solid fuel fired power station in the UK with five coal fired units and one biomass-fired unit totalling 3,960 megawatts (“MW”) of connected capacity. Its size and characteristics mean that it has a significant impact on the environment. We have recognised this and have put the management of the environment at the heart of our decision-making process. The main impacts from the plant’s operations are to air, water and land. Drax is currently the largest single site emitter of carbon dioxide (“CO2”) in the UK and a significant emitter of sulphur dioxide (“SO2”) and oxides of nitrogen (“NOX”). We regularly discuss our environmental performance and activities with our stakeholders and customers and are sensitive to their views and concerns. We understand our environmental impacts, and our business strategy will see the transformation of the power station from a high carbon, fossil fuel generator to a predominately low carbon, renewable generator fuelled by sustainable biomass. The transformation has started to take place and will continue over the next few years.
Drax has invested in emission control equipment for SO2, operating a wet Flue Gas Desulphurisation (“FGD”) system. All units are equipped with special burners and Boosted Over Fire Air (“BOFA”) systems to lower emissions of NOX. Work is being undertaken to identify suitable NOX abatement techniques and technologies needed to meet future NOX emission limits. We abstract water from the River Ouse and the Sherwood Sandstone aquifer, discharging it back to the River Ouse. The use of water by the plant is a key issue and we understand that, in the future, its importance will increase. We ensure that we manage our water efficiently, continually looking for improvements and will progress these in the coming years. The burning of solid fuels produces ash. Our operations produce on average 1.5Mt of ash every year. To ensure that these materials are utilised as products, they are produced to conform to European construction product standards. Around one million tonnes of ash products are sold into the construction industry every year as a replacement for virgin aggregates and cements and the unsold by-products are landfilled.
2 Environmental Management System
Environmental compliance at Drax is managed under an Environmental Management System (“EMS”) certified to the international standard ISO14001 (see Appendix 1 for
Page 1 certificate). The EMS ensures that we meet our legal and policy commitments to protect and continually improve environmental performance in the course of carrying out our business. The Chief Executive has overall responsibility for the implementation of the Drax Environmental Policy, EMS, environmental compliance and performance of the business, with other staff allocated specific responsibilities. The Company’s environmental strategy is implemented through the Environmental Policy (Appendix 2) and the EMS contains documented procedures for each significant environmental aspect. The performance of the system is monitored against a set of objectives and targets; these are monitored through internal and external audit and reviewed through the Company’s monthly environmental performance meeting. Where incidents or ‘near misses’ have occurred, they are reported, managed and investigated thoroughly through our internal reporting system. Any resulting actions and learning points are also assigned and tracked by the system. Drax has been certified to ISO14001 for many years and the EMS was recertified in 2013. The EMS is a mature system with environmental compliance embedded into all relevant operations and decisions. Our environmental performance record within the sector has been recognised by the Environment Agency with whom we worked to pilot the Environment Permitting Compliance Assurance Scheme. The Scheme is intended to reduce regulatory burdens on the best performing sites whilst maintaining an adequate level of oversight through combining assessment of specific legal compliance with certification to ISO14001. We are continuing to work with the Environment Agency on finalising the findings for the scheme.
3 Engagement with the Local Community
Locally, we continue to engage with parish, town, district and county councillors and officers with the intention of keeping them up-to-date with our business issues and developments. Our regular communications channel with them and other local opinion formers includes an annual consultative meeting, complemented by regular meetings with local councils and other stakeholders.
4 Environmental Objectives
Drax has a series of over-arching environmental objectives. In 2013, these were to: Reducing the environmental impacts of the business where practicable; Optimise the use of natural resources; Improve the management of waste; Raise the environmental awareness of staff and those acting on our behalf; Maintain compliance with environmental legislation; and Prevent pollution.
5 Production
Over the last decade Drax has researched and developed the use of sustainable biomass for electricity generation within the power station. This programme underpins a
Page 2 long term, sustainable future for our existing infrastructure, and necessitates significant investment in infrastructure to accommodate the burning of biomass fuels. Total generation over the last five years is shown in Table 1. In 2013, the net sales of electricity produced from biomass (renewable power) was 2.9TWh Table 1. Generation Outturn Figures
Year 2009 2010 2011 2012 2013
Generation* TWh 22.6 26.4 26.4 27.1 26.3
Load Factor % 68 80 80 82 80
* measured net sales
6 Environmental Compliance
Drax manages and operates under a number of permits and consents across the business. Our Environmental Permits identify the operational techniques, controls and environmental compliance limits for Drax Power Station and the associated ash disposal site, Barlow Mound. The Greenhouse Gas Emissions Permit (issued under the European Union Emissions Trading System (“EUETS”) Directive) identifies the activities, controls and calculation methodology for greenhouse gas emissions (essentially CO2) from Drax Power Station. The water abstraction licences detail the controls, uses and abstraction limits for water taken from the River Ouse and the Sherwood Sandstone Aquifer by the plant. In 2013, Drax operated within all the conditions of its Environmental Permits in relation to management, operations, emissions, and monitoring and information requirements with a key objective being to maintain compliance with no significant* breaches of the regulatory limits defined within these permits. Performance in 2013 was as follows: Significant breaches of Environment Permit 0
Non-compliances with Permits 2 related to control of discharges to waters. Justified Complaints 2 related to noise and transport fugitive dust * significant is defined as a breach of the permit that has or is likely to lead to significant pollution as defined by the Environment Agency The company received no fines or non-monetary sanctions in 2013.
7 Material Usage
We understand our responsibilities in ensuring that the materials used by our process are managed efficiently. The company has set itself challenging targets and made
Page 3 significant investment to ensure that our generation efficiency is the highest of any UK coal fired power station. The sections below describe the raw materials and associated process materials identified to be of importance for our operations.
7.1 Fuel Usage
Data detailing usage of fuels over the last five years are given in Table 2. All of these are non-renewable materials with the exception of biomass, which is sustainable and only purchased where in compliance with the Company’s biomass sustainability policy (see Appendix 3). In 2013, we saw the lowest consumption of non-renewable materials in the last five years. Table 2. Fuel Usage
Fuel Used 2009 2010 2011 2012 2013 (kt measured)
Coal and Petcoke 9,808 10,049 9,810 10,438 9,301
All Fuel Oils 48.0 24.9 23.5 18.8 22.5
Biomass 380.6 907.5 1,265 702.8 1,596
7.2 Other Materials
Other than fuels, several materials have been identified as being important within the generation process rather than for ancillary purposes. These are shown in Table 3. The only direct material used on site is limestone which is used in the Flue Gas Desulphurisation process and results in the production of gypsum. In 2013, 449kt of direct materials were used in the process resulting in the manufacture of 627kt of gypsum product.
Page 4 Table 3. Key Material Usage
Material (t measured) 2010 2011 2012 2013 Gas Oil 1,351 854 458 317 Sodium Hypochlorite 875* 788 532.3 859 Hydrazine Hydrate 144* 162* 118.9 57.5 Caustic Soda 193* 344* 190.5 240.0 Ferric Sulphate 515* 607* 127.7 340.0 Sulphuric Acid 4,960* 3,693* 4,558.9 5,322.5 Propane 39 24 24 18 Limestone 458,000 449,000 485,000 449,000
* Since 2012 the figures have been calculated based on usage rather than delivery (which was used for reporting up until 2011) to allow full disclosure in accordance with Global Reporting Index (GRI). Table 3 contains three non-renewable materials namely gas oil, propane and limestone.
7.3 Recycled Input
In 2013, Drax continued to replace Heavy Fuel Oil (“HFO”) with an alternative product, Processed Fuel Oil (“PFO”) produced from recovered lubricating oils. In 2013, we used 14,318t of PFO resulting in a recycled material input of 0.13% overall.
8 Emissions
There are comprehensive mechanisms in place to ensure that emissions are managed appropriately in accordance with our Environment Permits. These have resulted in considerable investment in the processes managing our emissions. The significant air emission species for the last five years are shown in Table 4. All species are determined through direct measurement in accordance with the permit, other than CO2 where the EUETS permit specifies a calculation methodology. In accordance with its Environmental Permit, Drax Power Station manages and reports its emissions of SO2, NOX and particulate matter in line with the requirements of the National Emissions Reduction Plan (“NERP”). The NERP is an option to demonstrate compliance with the Large Combustion Plant Directive (“LCPD”) and is an annual mass- based emission regime. Operators such as Drax are given annual emission allowances. These can be traded with other participants of the NERP scheme, with each participant having a maximum limit to which additional allowances can be purchased.
In addition to its mass limit, there is also a maximum allowable rate of emission of NOX and SO2 under the Environmental Permit, which is set at 1.8t/GWh.
Page 5 Table 4. Emissions to Air from 2009 - 2013
Total Emissions 2008 2009 2010 2011 2012 2013 (kt)
Carbon Dioxide 22,299* 19,852* 22,391* 21,466* 22,695* 20,319 (calculated)
Sulphur Dioxide 24.5 26.9 27.3 32.1 35.1 31.7 (measured)
Oxides of 38.3 38.2 40.4 38.9 39.2 39.2 Nitrogen (measured)
Particulate Emissions 0.5 0.5 0.6 0.6 0.8 0.8 (measured)
*Data for 2009-2012 have been verified under the EUETS. They include emissions from the FGD but not from biomass.
8.1 Sulphur Dioxide (SO2)
In 2013, Drax emitted 31.7kt of SO2 and purchased 1,000kt of allowances. SO2 emission rates were below the 1.8t/GWh compliance limit. Figures 1 and 2 and Table 5 provide data on the overall performance of the FGD equipment. In 2013, FGD availability improved by 0.7% compared with 2012 while efficiency remained the same. This resulted in a 0.07t/GWh decrease in the annual emission rate as shown in Figure 2. Table 5. FGD Performance 2009-2013
2009 2010 2011 2012 2013
FGD efficiency, % 92.0 91.1 90.8 90.6 90.6
FGD availability, % 96.5 98.8 96.01 97.14 97.21
Limestone used 409 458 448 485 449 (kt measured)
Gypsum generated 646 719 692 779 627 (kt)
Page 6 Figure 1. FGD efficiency and availability performance
FGD Efficiency and Availability 100 98 96 94 92 90 88 86 84 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
Efficiency Availability
Figure 2. Annual sulphur dioxide emission rates
Annual SO2 Emission Rate 1.8
1.6
1.4
1.2
1
T/GWH 0.8
0.6
0.4
0.2
0 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
8.2 Oxides of Nitrogen (NOX)
NOX emission rates were below the 1.8t/GWh compliance limit and, at 39.1kt, were within the site mass limit of 41,903kt. Emission rates over the past ten years are shown in Figure 3.
Page 7 Figure 3. Annual oxides of nitrogen emission rates
Annual Emission Rates of Oxides of Nitrogen 70.0
60.0
50.0
40.0
30.0
20.0
10.0
0.0 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
8.3 Carbon Dioxide (CO ) 2
The power station emits CO2 from the combustion of fuel as well as from the chemical reaction within the FGD process. The CO2 emissions are calculated and verified in compliance with the requirements of the EUETS. The breakdown for 2013 for each of the major combustion and process sources is provided in Table 6. Note that emissions from biomass are counted as zero within the EUETS.
Table 6. CO2 emissions 2013
Actual CO EUETS CO 2 2 (t calculated) (t calculated)
Coal and Petcoke 20,089,607 20,089,607
Biomass 2,799,391 0
Propane 53 53
FGD 157,110 157,110
All Fuel Oils 72,737 72,737
Total 23,118,898 20,319,507
The use of biomass, rather than coal, saved 2.67 million tonnes of CO2 in 2013.
Page 8 Figure 4. Biomass fuel use showing the biomass throughput since 2003.
Biomass 1800 1600 1400 1200 1000 TONNES 800 600 KILO 400 200 0 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
Biomass
Figure 5. Carbon dioxide emission rates
CO2 Emission rates (2005‐2012 EUETS data) 0.85
0.8
0.75 T/GWH
0.7
0.65 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013
CO2 (t/GWh)
Figure 4 shows the impact of improvements in generation efficiency and increased levels of biomass burn in 2013 this is due to the ongoing transformation of Drax to a predominately biomass fuelled generator and the conversion of one of our six generating units to biomass. As shown in Figure 5, in 2013 the rate of CO2 emissions per unit of electricity generated decreased by 0.05t/GWh compared to the previous year due to increased quantities of biomass burnt during the year. The upgraded turbines continue to have their expected performance and impact on our CO2 performance.
The scope 2 CO2 emissions (indirect emissions) generated from the import of electricity for production by the Group in 2013 were 292.8kt CO2e and the total CO2 EUETS emissions for 2013 was 20,319 Mt (excluding biomass). This is the first year we have had to report in accordance with the Greenhouse Gas Emissions (Directors’ Reports) Regulations (Table 7). This has required the collection of additional greenhouse gas emission sources that are currently outside of the scope of our Greenhouse Gas Emissions Permit, such as associated emissions from heavy mobile plant and the gas and electricity use from our fuel pelleting operations. We have developed a system to collect, assess and report the additional emissions information.
Page 9
Table 7. Mandatory Greenhouse Gas Emissions 2013 2013 2012 2012 Activity kt t/GWh kt t/GWh Scope 1 Fossil fuel combustion 20,162 720 22,513 777
Operations 157 6 180 7
Total Scope 1 20,3202 725 22,6931 784 Scope 2 Purchased electricity 293 10 341 10
Total Scope 1 and 2 20,612 736 23,038 794 Biologically-sequestered carbon 2,799 1,214 (biomass combustion) Gross generation TWh 28 29
In accordance with the Greenhouse Gas Emissions (Directors’ Reports) Regulations the Group’s total scope 1 and 2 emissions are 20,612 million tonnes CO2e. The majority of the material emissions are collected and verified as required by the Greenhouse Gas Permit for Drax Power Station. The remaining material sources are gathered and calculated in accordance with Defra guidance using the UK Government conversion factors.
All identified sources of scope 1 and 2 CO2 emissions are collected, monitored and assessed to determine their materiality ensuring that our report gives those emissions that will allow our investors to see the major trends and significant events while eliminating the immaterial emissions. As part of our biomass transformation strategy our GHG reporting has been expanded to incorporate scope 3 emissions from our fuel logistics operations. These scope 3 emissions are identified in Table 8 below. Table 8. Scope 3 Greenhouse Gas Emissions
CO e 2 (t calculated)
2013 2012 Fuel Logistics 459,472 396,017
Page 10 8.4 Particulate Emissions
The particulate emission limit for the station, is 25mg/m3 averaged over each month. Throughout 2013, the plant was compliant with the particulate limits, the average emission rate being 9.3mg/m3 and with a total mass emission of 0.8kt.
8.5 Emissions of Minor Species to Air
The emissions of minor species are given in Table 9. Table 9. Emissions to air of minor species Species Emission (t)
N2O 272 CO 11,512 Methane 146 Volatile Organic 283 Carbon
SO3 298
8.6 Disposals to Land The majority of the ash produced at the plant is sold to the construction industry with the remainder sent for disposal at the adjacent Barlow Mound. Details are shown in Table 10. The station produces ash materials in two different forms, Pulverised Fuel Ash (“PFA”) and Furnace Bottom Ash (“FBA”). - PFA consists of the very fine particles of ash that pass through the boiler and are removed from the exhaust gases. These can be used to replace cement, filler or aggregates in concretes. - FBA consists of the larger pieces of ash that fall to the bottom of the boiler and are subsequently removed. These materials are used as an aggregate to make light weight aggregate blocks. To allow these by-products to be utilised, the industry has agreed a Quality Protocol with the Environment Agency. This document provides a number of criteria to be satisfied for the materials to achieve an ‘end of waste’ status. The key principle of the Protocol is to ensure conformance with the appropriate European product standards.
Page 11 Table 10. Total ash landfilled and sold 2011-2013
2011 2012 2013
Ash to Landfill (t dry) 362,480 546,024 235,800
FBA Sold under Quality 230,344 288,454 248,598 Protocol (t) PFA Sold under Quality 842,438 711,792 828,762 Protocol (t) FBA Sold outside Quality 49,943 0 5106 Protocol (t) PFA Sold outside Quality 121,369 37,639 14,510 Protocol (t)
The quantities and disposal methods for the waste generated can be found in Figure 6, Table 11 and Table 12. The methods of disposal identified in this figure are determined from information provided by the waste management contractors with the exception of ash which is managed internally. The majority of the non-hazardous waste sent to landfill was lagging material removed from the boiler and turbines during maintenance works for which recycling opportunities are limited. The hazardous waste sent to landfill was predominately asbestos-contaminated material for which no alternative disposal option currently exists. Figure 6. Waste disposal by route Tonnes of Waste by Disposal Route 2013 216 32 216 414 Non‐hazardous waste (recycled 1075 or composted) Non‐hazardous waste (energy recovery) Non‐hazardous waste (landfilled) Hazardous waste (recycled composted)
9906 Hazardous waste (energy recovery) Table 11. Waste and recycling
Waste Type (t calculated) 2010 2011 2012 2013 Ash Disposal (landfill) 523,970 362,480 546,024 235,800
The diversion of waste generated during our operations away from landfill (excluding ash) improved from 90% in 2012 to 96% in 2013.
Page 12 Table 12. Hazardous waste movements 2010 2011 2012 2013 Total hazardous transported 231 420 456 464 (t measured) Hazardous waste treated outside UK within the EU 28.1 0 0 0 (t measured) % of hazardous waste 12 0 0 0 treated internationally
9 Water
The majority of the raw water is abstracted from the River Ouse and used as process water for cooling. Additionally it is used for conditioning the PFA for disposal at Barlow Mound and for dust management on the Mound. The high quality water required for boiler make-up water is supplied from licensed boreholes abstracting from the Sherwood Sandstone aquifer. The natural quality of this water makes it suitable for use, after treatment, within the steam system. Additionally, municipal mains water is used for drinking and amenities. This is supplied by Yorkshire Water whose infrastructure is designed to enable the supply of water from a diverse portfolio of assets. Hence, they are unable to identify the precise source of the water they supply to Drax. Water use for 2011-2013 is shown in Table 13. Table 13. Water use
Water Abstraction for Use 2011 2012 2013 3 (Mm measured)
River Ouse Water (surface water) 57.9 56.7 56.9
Mains Water (municipal water) 0.2 0.2 0.3
Borehole Water (groundwater) 2.0 1.8 1.9
Total Water Abstracted 60.1 58.8 59.1
Water Used and Returned (surface 30.9 30.8 31.5 water)
% Water used and returned 51 52 53
Water Use (m3/GWh) 1.1 1.0 1.1
Page 13 The Sherwood Sandstone aquifer is currently identified as ‘over-licenced’ but not ‘over- abstracted’ by the Environment Agency. Under the definition (given in GRI EN9, see Appendix 6) we are currently not significantly affecting this water source. The site has a single water discharge point to the River Ouse which is regularly monitored either through extractive testing or using appropriate online monitoring. The mass discharges to the river are shown in Table 14 for the most material permit parameters. The river is not identified as a protected area nationally or internationally at or below the point of discharge and we do not significantly affect its quality. Table 14. Water quality mass emissions
Parameter 2009 2010 2011 2012 2013
Copper (kg) 727 292 198 223 124
Mercury (kg) 0.11 0.02 0.13 0 0
Cadmium (kg) 18 27 62 34 13
The groundwater under Barlow Mound is monitored in accordance with the site Environmental Permit which requires monitoring of six boreholes. There are compliance requirements on three boreholes (BH4, BH5 and the abstraction borehole) for six parameters and these are shown in Figures 7, 8, 9, 10, 11, and 12, together with the ‘trigger levels’. During 2013 these were well within the compliance limits. Figure 7. Barlow arsenic groundwater monitoring Arsenic Groundwater Monitoiring Results 2013
90 80 70 60 50
UG/L 40 30 20 10 0
BH4 As(ug/l) BH5 As(ug/l) Abs BH As(ug/l) Trigger Level As(ug/l)
Page 14 Figure 8. Barlow boron groundwater monitoring
Boron Groundwater Monitoring Results 2013
1200
1000
800
UG/L 600
400
200
0
BH4 B(ug/l) BH5 B(ug/l) Abs BH B(ug/l) Trigger Level B(ug/l)
Figure 9. Barlow molybdenum groundwater monitoring Molybdenum Groundwater Monitoring Results 2013
300.00
250.00
200.00
150.00
UG/L 100.00
50.00
0.00
BH4 Mo(ug/l) BH5 Mo(ug/l) Abs BH Mo(ug/l) Trigger Level Mo(ug/l)
Page 15 Figure 10. Barlow potassium groundwater monitoring Potassium Groundwater Monitoring Results 2013
35
30
25
20
15 MG/L 10
5
0
BH4 K(mg/l) BH5 K(mg/l) Abs BH K(mg/l) Trigger Level K(mg/l)
Figure 11. Barlow sulphate groundwater monitoring Sulphate Groundwater Monitoring Results 2013
500 450 400 350 300 250
MG/L 200 150 100 50 0
BH4 Sulphate(mg/l) BH5 Sulphate(mg/l) Abs BH Sulphate(mg/l) Trigger Level Sulphate(mg/l)
Page 16 Figure 12. Barlow cadmium groundwater monitoring Cadmium Groundwater Monitoring Results 2013
1.2
1
0.8
UG/L 0.6
0.4
0.2
0
BH4 Cd(ug/l) BH5 Cd(ug/l) Abs BH Cd(ug/l) Trigger Level Cd(ug/l)
10 Biodiversity
There are currently no areas of protected or high biodiversity value adjacent to the power station or on any land that Drax leases or manages. The Company has no significant direct impacts in relation to its activities on areas of high biodiversity value outside of protected areas. Drax manages and maintains Barlow Mound, the restoration of which has had a positive impact on biodiversity generally. Since the construction of the power station, the ash disposal area has been transformed from an old Ministry of Defence munitions site to a mix of agricultural grazing, woodland and wild flower meadows.
11 Products and Services
The ash produced by the power station has always been used as an alternative to virgin aggregates or as a direct replacement for cement in concrete thereby reducing the demand of virgin materials. The ash products produced by the site conform to European technical standards appropriate to their use. The ash products are registered with the European Chemicals Agency as required by the Registration, Evaluation and Authorisation of Chemicals Directive (“REACH”). Gypsum is also produced as a by-product of our operations and is sold to local manufacturing facilities, used to manufacture products such as plasterboard. Gypsum is also registered in accordance with REACH.
Page 17 Table 15. Percentage products sold
% of Product Sold 2009 2010 2011 2012 2013
Pulverised Fuel Ash 55 62 72 58 77
Furnace Bottom Ash 100 100 100 100 100
Gypsum 96 98 99 100 100
12 Energy Consumption
The energy used in the plant is given in Table 16 and Table 17. Table 16. Energy consumption by source
Energy Source 2012 2013
Direct energy purchased* by Coal and Petcoke (non-renewable) 241.4 216.4 primary source Fuel Oils (non-renewable) 0.8 1.0 (PJ calculated)
Biomass (renewable) 12.3 28.5
Total Direct Energy Consumption Total 254.5 245.8 (PJ calculated)
Electricity consumption by Energy Source 2012 2013 primary source (PJ measured) Electricity 6.3 6.0 Table 17. Direct energy consumption by type
Energy Source Energy Consumption (PJ)
Non Renewable 217.4
Renewable 28.5
Overall energy consumption from the stations operations was down 3% with a 10% drop in energy from non-renewable sources. The success of the project to upgrade the high pressure and low pressure turbines has resulted in the Company taking the decision to upgrade three intermediate turbines on selected units from 2014.
Page 18 13 Air Quality and Other Monitoring
To monitor compliance with ambient Air Quality Standards, all coal fired power stations in the UK have installed continuous emission monitors for NOX and SO2 at off-site locations. Drax, Eggborough and Ferrybridge power stations jointly operate a set of monitors in the Aire Valley in line with this requirement. Drax has submitted annual reviews for each year since 2005 to demonstrate compliance with the National Air Quality Strategy (“NAQS”) standards and objectives, and for publication on the public register. Compliance with the air quality criteria in the region is very good with no exceedances of any statutory air quality criteria being caused by Drax. The monitoring of the background levels of nickel and vanadium was originally undertaken in line with Drax Power Station’s permission to burn petroleum coke (petcoke). The data from local villages at Barlow and Hemingbrough are shown in Figures 13 and 14 and continue to confirm the lack of impact of petcoke on local communities. The data indicate local concentrations to be well below statutory or health limits and, because of the similarity of data between the two sites located ‘upwind’ and ‘downwind’ of Drax, are good evidence of an absence of an effect from the power station. The World Health Organisation (“WHO”) has a guideline level of 1µg/m3 in 24 hours period for airborne vanadium and 1µg/m3 for nickel. Figures 13 and 14 show that the average vanadium and nickel ambient concentrations in 2013 were 0.0017µg/m3 and 0.0011µg/m3, significantly lower than the WHO guidelines. Figure 13. Nickel in ambient air Ambient Air Quality Monitoring ‐ Nickel
0.01000
0.00800
0.00600
0.00400
0.00200
0.00000 9/8/2006 9/2/2007 9/4/2007 9/6/2007 9/8/2007 9/2/2008 9/4/2008 9/6/2008 9/8/2008 9/2/2009 9/4/2009 9/6/2009 9/8/2009 9/2/2010 9/4/2010 9/6/2010 9/8/2010 9/2/2011 9/4/2011 9/6/2011 9/8/2011 9/2/2012 9/4/2012 9/6/2012 9/8/2012 9/2/2013 9/4/2013 9/6/2013 9/8/2013 9/10/2006 9/12/2006 9/10/2007 9/12/2007 9/10/2008 9/12/2008 9/10/2009 9/12/2009 9/10/2010 9/12/2010 9/10/2011 9/12/2011 9/10/2012 9/12/2012 9/10/2013 Barlow Hemingbrough
Page 19 Figure 14. Vanadium in ambient air Ambient Air Quality Monitoring Vanadium 0.01000
0.00800
0.00600
0.00400
0.00200
0.00000 9/8/2006 9/2/2007 9/4/2007 9/6/2007 9/8/2007 9/2/2008 9/4/2008 9/6/2008 9/8/2008 9/2/2009 9/4/2009 9/6/2009 9/8/2009 9/2/2010 9/4/2010 9/6/2010 9/8/2010 9/2/2011 9/4/2011 9/6/2011 9/8/2011 9/2/2012 9/4/2012 9/6/2012 9/8/2012 9/2/2013 9/4/2013 9/6/2013 9/8/2013 9/10/2006 9/12/2006 9/10/2007 9/12/2007 9/10/2008 9/12/2008 Barlow 9/10/2009 9/12/2009 Hemingbrough9/10/2010 9/12/2010 9/10/2011 9/12/2011 9/10/2012 9/12/2012 9/10/2013
13 Global Reporting Initiative
The Global Reporting Initiative is an organisation promoting economic, environmental and social sustainability. To achieve these goals they have produced a sustainability reporting framework, the goal of which is to help companies to measure and report on their sustainability performance. This report forms part of our reporting framework, with the performance indicators and the level to which we report against them identified and referenced in Appendix 6. We are continually looking to improve our reporting and increase the number of performance criteria against which we report.
Page 20 Appendix 1. ISO14001:2004 Certificate of approval
Page 21 Appendix 2. Environmental policy
Page 22 Appendix 3. Biomass sustainability policy
Page 23
Appendix 5 Global Reporting Initiative indicators reported
Disclosure Indicator Aspect Location Level EN1 Pages 4, 5 and 25 Materials EN2 Pages 5 and 25 EN3 Pages 18 & 25 Energy EN4 Page 18 & 25 EN8 Page 13, 14 and 25 Water EN9 Page 13,14, 25 and 26 EN11 Page 17 Biodiversity EN12 Page 17 EN16 Pages 5, 6, 8, 9, 10 & 26 EN17 Page 26 EN18 Page 1, 8 & 9 EN20 Emissions, Effluents Pages 5, 6, 7, 8, 11 & 26 EN21 and Waste Pages13, 14 & 26 EN22 Pages 11, 12 & 13 EN24 Page 12, 13, 26 & 27 EN25 Page 13 & 14 Initiatives to mitigate environmental impacts EN26 of products and Page 27 services, and extent of impact mitigation Percentage of products sold and their packaging EN27 Page 27 materials that are reclaimed. EN28 Compliance Page 6
full disclosure partial disclosure
Page 24 Appendix 6. Global Reporting Initiative definitions
The Global Reporting Initiative (”GRI”) disclosures in this report have been prepared in accordance with the GRI Indicator Protocol (available at https://www.globalreporting.org/resourcelibrary/G3.1-Environment-Indicator- Protocols.pdf). The following definitions provide further clarification where required. Indictor Attribute Definition or information For reporting the coal and petroleum coke usage have been reported together Limestone has been defined as a direct material, as it Materials used EN1 and its derivatives are present in the final by-product by Weight The nature of our business means that we currently do not package or use any semi-manufactured parts in any of our products. Material that replaces virgin materials that has been EN2 Recycled input recovered from discard materials Energy purchased for our own consumption excludes any fuel which is available for trading within the reporting year No direct primary energy was produced as defined by the scope of this indictor (0 PJ) Trading of direct primary energy sources was Primary Energy excluded from the scope of this indicator to ensure an Purchased for EN3 appropriate comparable consumption figure for the own Company’s activities was reported consumption Total primary direct energy sold within the scope of the report was 0 PJ Total direct primary energy consumption PJ (direct primary energy purchased plus direct primary energy produced less direct primary energy sold) = 254.5 + 0 - 0 = 254.5 PJ Total electricity consumption includes both electricity generated by the station, as well as electricity purchased from the grid; these numbers are not Indirect Primary EN4 recorded separately Energy The source of the electricity supplied to the power station cannot be identified and comes from a mix of renewable and non-renewable sources Initiatives to provide energy EN6 efficient This indicator has no relevance to our operations products and services The amount of rainwater used by the organisation is not material in relation to reporting under this indicator Total Water EN8 withdrawal by No waste water from other organisations was used Source as a water source
Page 25 Withdrawal of water from the River Ouse is not Water sources significant in accordance with the criteria provided for significantly GRI reporting. EN9 affected by withdrawal of Considering the nature of Yorkshire Water’s water capabilities, our use is significantly less than 5% of the total source requirement for GRI reporting. Direct greenhouse gas emissions for the scope of this report are those required to be reported in Direct compliance with the European Union Emissions Greenhouse Trading System in accordance with the Greenhouse Gas Emission Gas Emissions Permit The greenhouse gas emissions is determined by Calculation based on site specific data
This is calculated using the electrical power required by the station as an input to Annex 3, Table A in the EN16 2012 greenhouse gas conversion factors for company reporting spread sheet (1,669.9GWh) Indirect Greenhouse The only source of indirect greenhouse gas Gas Emission emissions reported against this indicator are from electricity used in operation of Drax Power Station (including both electricity generated by the power station, and sourced from the grid); there are no sources from other combustion processes, physical and chemical processing, transportation of materials, products and waste, venting or fugitive emissions Other relevant . Greenhouse gas emission from transportation of indirect source EN17 fuels has been calculated and determined to be greenhouse gas material. emissions Measurements of NO , SO and particulate matter NO , SO and X X X X are directly measured in accordance with the Large EN20 other significant Combustion Plant Directive and the Environment air emissions Agency’s MCerts scheme The following parameters have been identified as material in relation to water quality within the scope of this report; copper, cadmium and mercury Total Water No water discharged is used by another organisation Discharge by EN21 Quality and The majority of the water discharged from site does Destination not undergo any treatment; the quantity of water discharge from site that has undergone treatment is not material for reporting
Where appropriate hazardous waste discarded is treated to reduce mass and or hazard, with the Treated general exception of asbestos; the asbestos is EN24 Hazardous landfilled in licenced landfill. waste In Figure 6, hazardous waste (landfilled) represents untreated asbestos, whilst hazardous waste (recycled
Page 26 / composted) and hazardous waste (energy recovered) represent treated waste No hazardous waste has been imported by the Company No hazardous waste is exported outside the EU in accordance with EU regulation
Initiatives to mitigate environmental The indicator has no relevance to our operations as impacts of EN26 we cannot mitigate the environmental impacts of the products and end-use of electricity services, and extent of impact mitigation Percentage of products sold and their This indicator has no relevance to our operations as EN27 packaging electricity is not packaged or reclaimed materials that are reclaimed.
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