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Attachment A Non-technical Summary List of Contents Page Attachment A A. Non-technical Summary A-1 A.1 Non-technical Summary A-2 A.1.1 General A-2 A.1.2 Open Cycle Gas Turbine Process A-2 A.1.3 Management of the Installation A-3 A.1.4 Existing Environmental Conditions A-4 A.1.5 Emissions Control and Monitoring A-4 A.1.6 Resource Use and Energy Consumption A-8 A.1.7 Materials Handling A-10 A.1.8 Waste Management A-10 A.1.9 Accident, Prevention & Emergency Response A-10 A.1.10 Remediation, Decommissioning, Restoration & Aftercare A-12 For inspection purposes only. Consent of copyright owner required for any other use. EPA Export 27-07-2013:23:21:49

List of Contents · power plant. In addition, key elements of the plant will be maintained as part of a Long Term Service Agreement (LTSA) with the supplier of the gas turbine to

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Page 1: List of Contents · power plant. In addition, key elements of the plant will be maintained as part of a Long Term Service Agreement (LTSA) with the supplier of the gas turbine to

Attachment A Non-technical Summary

List of Contents Page

Attachment A

A. Non-technical Summary A-1

A.1 Non-technical Summary A-2

A.1.1 General A-2

A.1.2 Open Cycle Gas Turbine Process A-2

A.1.3 Management of the Installation A-3

A.1.4 Existing Environmental Conditions A-4

A.1.5 Emissions Control and Monitoring A-4

A.1.6 Resource Use and Energy Consumption A-8

A.1.7 Materials Handling A-10

A.1.8 Waste Management A-10

A.1.9 Accident, Prevention & Emergency Response A-10

A.1.10 Remediation, Decommissioning, Restoration & Aftercare A-12

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Page 2: List of Contents · power plant. In addition, key elements of the plant will be maintained as part of a Long Term Service Agreement (LTSA) with the supplier of the gas turbine to

Attachment A Non-technical Summary

A-1

A. Non-technical Summary

A non-technical summary of the application is to be included here. The summary should

identify all environmental impacts of significance associated with the carrying on of the

activity/activities, and describe mitigation measures proposed or existing to address these

impacts. This description should also indicate the normal operating hours and days per week

of the activity.

The following information must be included in the non-technical summary:

A description of:

- the installation and its activities,

- the raw and auxiliary materials, other substances and the energy used in or

generated by the installation,

- the sources of emissions from the installation,

- the environmental conditions of the site of the installation (e.g. soil and

groundwater, air, noise, surface water),

- the nature and quantities of foreseeable emissions from the installation into each

medium as well as identification of significant effects of the emissions on the

environment,

- the proposed technology and other techniques for preventing or, where this is not

possible, reducing emissions from the installation,

- where necessary, measures for the prevention and recovery of waste generated

by the installation,

- further measures planned to comply with the general principles of the basic

obligations of the operator i.e.

(a) all the appropriate preventive measures are taken against pollution, in particular

through application of the Best Available Techniques (BAT);

(b) no significant pollution is caused;

(c) waste production is avoided in accordance with Council Directive 75/442/EEC of

15 July 1975 on waste; where waste is produced, it is recovered or, where that is

technically and economically impossible, it is disposed of while avoiding or

reducing any impact on the environment;

(d) energy and other resources are used efficiently;

(e) the necessary measures are taken to prevent accidents and limit their

consequences;

(f) the necessary measures are taken upon definitive cessation of activities to avoid

any pollution risk and return the site of operation to a satisfactory state.

(g) measures planned to monitor emissions into the environment.

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Page 3: List of Contents · power plant. In addition, key elements of the plant will be maintained as part of a Long Term Service Agreement (LTSA) with the supplier of the gas turbine to

Attachment A Non-technical Summary

A-2

A.1 Non-technical Summary

A.1.1 General

Greener Ideas Limited (GIL) are applying for an Integrated Pollution Prevention Control

Licence (IPPC) for the operation of the Kilkenny Open Cycle Gas Turbine (OCGT) power

plant. The development will consist of one OCGT generating unit which will provide

approximately 100 MW of electricity to the National Grid system with a thermal efficiency of

approximately 46%. A Site Location Plan is illustrated in Figure A.1.1.

Ancillary development will include: an exhaust stack, air vent stack, inlet air system, a

cooling system, water treatment equipment, compressed air system, natural gas supply and

compression system, a distillate fuel oil supply system, fire protection system, wastewater

system, generator step-up and auxiliary transformers, fuel storage tanks, water storage tanks,

control room / administration building, natural gas supply pipeline and a substation

connection to the National Grid. The development will also include construction of site

drainage systems, a site entrance, boundary fencing, tank bunding, and access roads.

An on-site electrical generator will connect to a single common main transformer where the

voltage will be increased to 110 kV. Electrical power will then be exported from the plant’s

main transformer to the Kilkenny 110kV electricity sub-station where the electricity will be

exported to the national electricity grid.

The power plant will also require smaller auxiliary transformers on the site which will reduce

the voltage for use within the power plant. All outdoor transformers will be bunded, fire and

blast protected to both Eirgrid and relevant international standards such as National Fire

Protection Agency (NFPA) 850.

The facility is classified as a First Schedule Class 2.1 Activity which can be described as

follows:

“The operation of combustion installations with a rated thermal input equal to or greater than

50MW”.

As such the Operator, Greener Ideas Limited, is required to submit an application for an

operational licence, i.e. an IPPC licence, to the Environmental Protection Agency (EPA).

This Non-Technical Summary is submitted as part of the supporting documentation for the

IPPC licence application. This section provides a brief overview of the application only. It is

recommended that the entire document is reviewed in order to obtain detailed information

relating to the application.

A.1.2 Open Cycle Gas Turbine Process

The Open Cycle Gas Turbine (OCGT) process of operation is summarised in the following

paragraphs.

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Attachment A Non-technical Summary

A-3

The turbine will draw air in from the atmosphere across an intake filter where it enters the

compressor. The air is then compressed through a number of compressor stages in the Low

Pressure Compressor (LPC) before being extracted and cooled in an air-water heat exchanger.

The cooled air is then re-admitted to the High Pressure Compressor (HPC) from where it is

compressed to the final pressure required for combustion. Upon exiting the compressor the

compressed air enters the combustion chamber where it is mixed with fuel (i.e. natural gas).

The energy contained in the fuel-air mixture is released through the process of combustion

with the resulting hot combustion gases expanding across the High Pressure Turbine (HPT),

Intermediate Pressure Turbine (IPT) and Power Turbine (PT) sections.

The HPT and IPT generate sufficient power to drive the compressor sections while the PT

converts the remaining thermal energy in the hot combustion gases to mechanical energy.

This mechanical energy is then used to drive the electrical generator which produces electrical

energy.

The exhaust gases exiting the gas turbine are discharged to atmosphere via an exhaust stack.

Figure A.1.2 Site Layout Plan illustrates the infrastructure associated with the plant.

A.1.3 Management of the Installation

Greener Ideas Limited (GIL), which is a joint venture company comprising of Bord Gais and

Mountside Properties Limited, will have ultimate responsibility for the health, safety and

environmental issues relating to the operation of the plant.

Staff will be employed to manage, operate and maintain responsibility for the operation of the

power plant. In addition, key elements of the plant will be maintained as part of a Long Term

Service Agreement (LTSA) with the supplier of the gas turbine to service the turbine and

main ancillary equipment at pre-determined intervals.

The Station Manager will report directly to the Board of GIL. Site specific management

systems and operating procedures will be developed in accordance with GIL procedures and

policies. The Station Manager will be directly responsible for the implementation of the

Operator’s Health and Safety, Environmental and Quality systems, policies and procedures.

The Operations Engineer and the Environment, Health and Safety (EHS) Manager will have

varying degrees of responsibility for their implementation. Operations will be carried out in

accordance with legislative requirements and the conditions of the IPPC licence and planning

permission.

All personnel will be technically competent and suitably qualified to undertake their assigned

tasks. Personnel with responsibilities for operations, maintenance, health and safety and the

environment will receive task specific technical training, as required. A Training Needs

Matrix and Programme will be developed in accordance with changing training needs.

All site personnel will receive Emergency Response and Environmental Awareness Training,

incorporating resource (including waste), energy, water minimisation and noise control

techniques. Additional environmental, health and safety training, including fire fighting and

first aid, will be implemented in accordance with best practice and developing systems.

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Attachment A Non-technical Summary

A-4

A site specific Environmental Management System (EMS) will be developed and

implemented at the facility. The EMS will provide the framework for environmental

management, compliance with appropriate regulatory requirements and the implementation of

the principles of continuous improvement. The implementation of the EMS will include

regular cross-functional management reviews and will be subject to both internal and external

audits.

A.1.4 Existing Environmental Conditions

The site of the proposed plant occupies an area of 1.32 hectares and is situated approximately

3 kilometres east of Kilkenny city centre in the townland of Purcellsinch.

The site is currently in agricultural use for livestock (cattle) grazing. The surrounding land

use is mixed agricultural and industrial with the site bounded by the IDA Business and

Technology Park to the north, the Purcellsinch Wastewater Treatment Plant to the west and

agricultural pastureland to the east and south. There is also one residential property

immediately to the south of the site (on the opposite side of the Sion Road).

The historical land use of the site has been agricultural. There is no evidence to suggest that

there is a risk of ground contamination on site.

There are no watercourses within the application site. The nearest watercourse is the River

Pococke approximately 90 metres to the west of the site boundary. In addition, the River

Nore is located approximately 140 metres south of the site boundary. Both of these

watercourses are designated as part of a Special Area of Conservation (SAC) - (River Barrow

& River Nore SAC, site code 002162).

Existing ambient noise conditions are influenced by industrial activities to the north and west

of the site as well as local traffic on the Sion Road.

The topography of the site averages from approximately 42 metres to 48 metres Ordnance

Datum Malin Head (AOD). It is proposed that the “as built” power plant will have finished

floor levels of between 43.2 metres to 47.2 metres AOD.

A.1.5 Emissions Control and Monitoring

(i) Atmospheric Emissions

The gas turbine will normally be fired on natural gas. Natural gas is a clean fuel resulting in

negligible emissions of Particulate Matter and Sulphur Dioxide, the main atmospheric

pollutants of concern relating to natural gas firing are therefore Nitrogen Oxides (NOx). In

accordance with Best Available Techniques (BAT) technology, the gas turbine generator will

be fitted with a dry low NOx burner to minimise such emissions.

Although the OCGT will normally be fuelled by natural gas, diesel storage and pumping

facilities will also be provided. To comply with the requirements of the CER the storage

capacity of the back-up fuel supply should be such as to allow the plant to be operated for a

period of 3 days, (i.e. approximately 1600 m3).

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Attachment A Non-technical Summary

A-5

Diesel will be limited to a maximum Sulphur content of 0.1%. In accordance with BAT, water

injection will be employed when the plant is operating on diesel to further reduce NOx

concentrations. It is anticipated that the plant will only operate on diesel for short-duration

testing.

Exhaust gases from the OCGT will discharge to the atmosphere via a 26 metre stack. The

stack will incorporate an in-situ proprietary Continuous Emission Monitoring System, CEMS.

The CEMS will continuously monitor atmospheric emissions from the facility in accordance

with the requirements of the IPPC licence.

Due to the quantity of diesel stored on site the facility is not considered to be a Seveso site, as

regulated by the Health and Safety Authority (HSA).

The results of the atmospheric impact assessment indicate that the operation of the OCGT

plant will not lead to any breaches of relevant air quality limit values. Two worst case

modelling scenarios were considered in the air quality impact assessment. Scenario 1 assumed

a 100% annual plant load factor (8,760 hrs) operating on natural gas. Scenario 2, assumed a

100% annual plant load factor when firing on diesel oil. Both scenarios accounted for the

worst-case meteorological conditions for atmospheric dispersal of key pollutants. The results

of the modelling predicted the process contributions of NOx to be negligible, operating within

approximately 25% of the relevant Air Quality Standard (AQS) whilst operating on either

natural gas or diesel oil. Atmospheric emissions of SO2, PM10 and PM2.5 were also found to be

negligible. Overall, maximum short-term and long-term emissions are not considered likely to

impair the environment, regardless of fuel type. In addition, the plant presents a low carbon

solution compared with alternative fossil fuel generation.

Monitoring results will be forwarded to the EPA in accordance with agreed timeframes as

specified in the IPPC licence.

(ii) Emissions to IDA Surface Water Sewer

Surface water within the site will be collected in an underground surface water attenuation

tank. This tank will have a volume of approximately 700m³ as instructed in consultation with

Kilkenny County Council who advised that the surface water collection system should be

designed in order to prevent on-site flooding for the 1 in 100 year event.

The surface water discharge will consist mainly of rainwater. The proposed power plant will

increase the impermeable area on site by approx. 60% as a consequence of the new buildings,

storage structures, tanks, plant items, hardstanding areas and access roads. This will result in

a corresponding increase in surface water run off.

Surface water will be pumped to a exisiting manhole in the IDA surface water sewer network

which ultimately discharges to the River Pococke.

Since increasing the discharge rate of surface water to a water course can increase the risk of

flooding downstream, Local Authorities in Ireland generally request that post-development

discharge rates are restricted so that they mimic pre-development greenfield run-off rates in

order to avoid this. This approach is in line with recommendations in the Greater Dublin

Strategic Drainage Study (GDSDS) and best Sustainable Urban Drainage Systems (SUDS)

practices. For the proposed power plant, discharge to the IDA surface water sewer will

comply with SUDS and other best practice.

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Attachment A Non-technical Summary

A-6

As surface water has the potential to become contaminated with oily substances in some areas

oil interceptors will be installed downstream of the proposed collection system.

In addition to the attenuation built into the design, the following items will also be

implemented in the overall surface water drainage design to effectively manage surface water

at the site:

• Petrol Interceptor – A full retention petrol interceptor has been specified on the surface

water collection system which will act to remove hydrocarbons prior to discharge to

the attenuation tank.

• Forecourt Interceptor – A forecourt interceptor has been specified on the surface water

pipe from the light fuel oil (LFO) unloading pumps bay as this is an area where there

is a greater risk of an oil spillage occurring.

• LFO Bund Sump & Pumping Arrangement – Although the LFO storage tanks are

located within a bunded area, rainwater which falls here is likely to be clean in the

absence of an oil spill or leak. As a result, a sump and pumping arrangement located

within the bund will allow clean rainwater to be pumped into the collection system

when required.

• Down pipes/Gullies – Surface water will be collected from roofed buildings via

standard rainwater down pipes while runoff from un-roofed structures will drain to the

access roads where it will enter via road gullies. Some additional gullies, acco-drains

or similar collection device may be specified at detailed design stage for large un-

roofed paved areas if require. It is also proposed that gullies and drain entry points

will incorporate silt traps to remove any grit or silt which may be washed into the

drainage system.

• Sampling and monitoring points will remain downstream of the collection systems as

indicated.

(iii) Emissions to IDA Foul Sewer

Emissions to the IDA foul sewer will comprise of the following:

• Demineralised water treatment plant effluent (approx. 4.6 m3/h).

• Water treatment for cooling tower (approx. 3 m3/h).

• Cooling tower blowdown (approx. 12 m3/h).

• Foul water (<0.1 m3/h).

Process waste water will comprise effluent from the demineralised water treatment plant

effluent, wastewater from the cooling water treatment plant and cooling tower blowdown. In

order to allow monitoring and control over process wastewater, two underground process

water treatment tanks will be provided. One underground tank will contain demineralised

water treatment plant effluent and effluent from the cooling tower water treatment plant, and

the other will contain cooling tower blowdown.

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Attachment A Non-technical Summary

A-7

Process wastewaters will be monitored at the underground tanks and if required, dosed or

treated to acceptable limits before being pumped to a foul pumping station. From here, the

IDA sewer ultimately discharges to the Kilkenny County Council’s Wastewater Treatment

Plant.

The process wastewater will be treated to regulate the pH to pH 6-9. All other parameters will

be treated to ensure they do not exceed the following daily concentrations – BOD (25mg/l),

Suspended Solids (35mg/l), Nitrate (as N)(10mg/l), Ammonia (as N)(5mg/l), Chloride

(350mg/l), Mineral Oil (20mg/l) and Total Phosphorus (as P) (2mg/l). All elements of the

treatment systems will be monitored on a regular basis to ensure optimum performance and

maintenance.

Any solids collected in the water treatment plant will be removed from site by authorised

contractors.

All chemical conditioning materials required for water treatment or for corrosion control will

be stored in the chemical storage room. Spills and leaks will be cleaned by appropriately

experienced personnel using absorbent materials. The arising waste will be disposed of off-

site by appropriately authorised contractors.

Monitoring of emissions to the IDA foul sewer will be undertaken in accordance with EPA

requirements as specified in the IPPC licence.

(iv) Noise Emissions

Prediction of operational noise levels at nearby receptors was carried out using the CadnaA

noise prediction programme that calculates noise levels in accordance with ISO 9613-2:

Attenuation of Sound Propagation Outdoors: General Method of Calculation, International

Organization for Standardization, 1996. The noise prediction program models the spreading

of sound with distance, the absorption of sound by ground and air, the effects of topography

and screening by buildings. The following assumptions were made when creating the noise

model:

• The equipment comprising the power station and its auxiliary machinery was

modelled as a number of point sources located in space above the ground without any

physical surfaces. This means that noise emissions would, in effect, be able to pass

through the machinery. Such an approach is expected to be conservative and is

considered to be a worst case scenario modelling exercise.

• The noise emission of each piece of machinery was based on data supplied by

potential gas turbine and ancillary equipment suppliers.

• Specific equipment was provided with noise reduction and control measures to reduce

noise emissions. These were included in the noise model.

• Noise sources that were included in the noise model are:

− The main gas turbine system, air inlet filters, heat exchanger and exhaust stack.

− Gas compressors; and Auxiliary plant such as the lubricating oil pumps.

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Attachment A Non-technical Summary

A-8

− Liquid fuel pumps.

The impact of noise from the plant will be restricted to a relatively close area around the site.

A number of noise mitigation measures have been incorporated into the design of the plant to

minimise the impact of such emissions. Mitigation would typically comprise the following

items:

• Locating larger structures such as the raw & fire water storage tank, the demineralised

water storage tank, the water treatment building and chemical storage room between

the main gas turbine and the nearest noise sensitive receptor (neighbouring

commercial building) to provide acoustic screening.

• An enclosure mounted on the skid around the main gas turbine.

• Enclosures around ductwork.

• Splitter-attenuators on the air inlet filters.

• A splitter-attenuator on the exhaust stack.

• Small enclosures around the generator, gas compressors, lubricating oil and fuel oil

pumps.

Overall therefore, with appropriate mitigation, operational noise levels at nearby noise

sensitive receptors would not exceed EPA Guideline noise levels and would not be expected

to be significant. At the nearest commercial building located to the north of the site the

predicted noise impact is 46dB LAeq. It should be noted this building is a commercial/light

industrial unit and would be occupied only during typical working hours (i.e. 09:00 – 18:00).

At the nearest residential properties, which the EPA considers as noise sensitive receptors, the

predicted noise impacts will be within the standard daytime (08:00 – 22:00) and night-time

(22:00 – 08:00) noise levels of 55dB LAr and 45dB LAeq. Regular monitoring, as proposed in

the IPPC licence, will be undertaken at various locations around the site boundary and

environs.

(v) Emissions to Groundwater

There will be no emissions to ground or groundwater from the facility.

A.1.6 Resource Use and Energy Consumption

(i) Resource Use

Raw materials use will include natural gas, diesel, water, conditioning chemicals, coolants,

laboratory smalls, cleaning products and oils and greases.

The principal material consumed during operation of the power plant will be fuel to fire the

gas turbine. The gas turbine will normally be fired on natural gas. The consumption of

natural gas will vary depending on ambient temperature with consumption at a maximum

when the ambient temperature is at its lowest.

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Attachment A Non-technical Summary

A-9

Although the power plant will normally be fuelled by natural gas it is a requirement of the

Commission for Energy Regulation (CER) that a secondary fuel source be stored on site so

that the plant can operate in the case of an interruption or loss of the natural gas supply.

In accordance with the CER Decision Paper Secondary Fuelling Obligations on Licensed

Generation Capacity in the Republic of Ireland (2009), approximately 1600m3 of low sulphur

liquid fuel oil will be stored on site in a bunded vertical cylindrical steel tank. This will be

sufficient to operate the plant at maximum output for approximately 72 hours.

Raw feed water will be sourced from one of, or a combination of, groundwater, municipal

water mains supply or treated ‘grey’ water from Kilkenny County Council’s Wastewater

Treatment Plant.

The plant will require 90m3/hr of raw feedwater. Treated feedwater is primarily required for

three processes as follows:

• Demineralised water primarily for injection into the combustion chamber of the gas

turbine for NOx control.

• Make up to the cooling towers.

• Services water supply for potable water and sanitary services.

The raw water tank will have a total capacity of 6000m3 which will include 420m

3 of water

for fire fighting purposes.

Secondary raw materials include conditioning chemicals, coolants, cleaning products and oils

and greases.

The use of conditioning chemicals will be optimised through controlled dosing. Cleaning

products will be of a water based biodegradable nature wherever possible. A hazardous

detergent is however required for compressor cleaning. Hazardous compressor cleaning

products will be segregated in a locked cabinet with limited access to prevent misuse.

Compressor cleaning wastewater will be disposed of off-site as hazardous waste.

Oils and greases will be used for the lubrication of the main mechanical components in the

plant. Waste oils and oil contaminated rags and wipes will be disposed of as hazardous waste.

Washings arising from general cleaning, within the turbine hall and bulk storage tank bunds,

will be directed via an oil / water interceptor to the process waste water discharge tank.

(ii) Energy Efficiency

The total electricity output from the proposed plant will be up 100 MW during optimum

conditions. The overall generation efficiency will be approximately 46%. An energy

efficiency audit will be undertaken at the facility in accordance with the timeframe specified

in the IPPC licence. Action items arising from the audit will be incorporated into the EMS.

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Attachment A Non-technical Summary

A-10

A.1.7 Materials Handling

Site specific operating procedures will be developed for the use, handling and disposal of raw

materials and waste. Only appropriately trained personnel will be authorised to handle

hazardous materials on site. All chemicals stored will be subject to a COSHH (Control of

Substances Hazardous to Health) assessment and compliance with the requirements of

REACH (EC Regulation 1907/2006 for the Regulation, Evaluation, Authorisation and

Restriction of Chemicals).

The volume of waste generated by site activities will be relatively small. Waste will be

managed on site in accordance with the Waste Management Hierarchy. Where possible the

generation of waste will be avoided. Where this is not possible the production of waste will

be minimised and sent for recovery. Where this is not technically or economically feasible

the waste will be disposed of. All waste will be managed by appropriately authorised

contractors in accordance with relevant legislation.

A waste audit will take place within the timeframe specified in the IPPC licence. The waste

audit process will identify all waste streams generated on site and determine opportunities for

waste prevention, minimisation and re-use which will be incorporated into the EMS.

A.1.8 Waste Management

The volume of waste generated by the facility will be relatively small. Waste will be

managed on site in accordance with the Waste Management Hierarchy. Where possible the

generation of waste will be avoided. Where this is not possible the production of waste will

be minimised and sent for recovery. All waste will be managed by appropriately authorised

contractors in accordance with relevant legislation.

A baseline waste audit will take place within the timeframe specified in the IPPC licence.

The waste audit process will identify all waste streams generated on site and determine

opportunities for waste prevention, minimisation and re-use. The audit will also include an

assessment of current waste management practices and determine if additional opportunities

for waste recovery exist. The findings of the waste audit will be incorporated into, and

managed through, the EMS. An annual waste minimisation report will be developed

demonstrating the efforts made to reduce consumption. A material balance will be included

illustrating the fate of all waste materials.

Records of the quantity, nature, source and quantity of any waste sent for recovery or disposal

will be maintained.

A.1.9 Accident, Prevention & Emergency Response

The facility will have a small operational workforce and will also have capacity to be operated

remotely. Security will be managed on site by a specialist contractor and access to the site

will be restricted.

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All potentially polluting substances, including waste, will be stored in designated areas in

appropriate UN approved containers within bunds, drip trays or spill pallets, as deemed

necessary. All containers and bunds will be inspected regularly to ensure they have not

become damaged or degraded. All areas on site with potentially polluting substances will be

hardstanding with drainage networks directing run-off to contained areas.

All tanks will be contained within bunds and fitted with level gauges and alarms which will

be incorporated into a Planned Preventative Maintenance Programme (PPMP). Plant and

equipment will be regularly inspected and maintained. Any faults detected will be prioritised.

Faults associated with health and safety and environmental equipment will be given highest

priority and action will be taken immediately. Leaks of potentially polluting substances will

be repaired as soon as practicable. Drip trays will be provided immediately, if repair is not

possible the leaking equipment will be appropriately contained prior to safe removal from the

facility.

Accidental spillages will be contained and cleaned immediately by suitably trained personnel.

Spill equipment stocks will be stored at strategic locations around the site. Stocks will be

subject to regular inventory checks. Incidents, accidents and near-misses will be recorded on

site and notified to the appropriate authorities in accordance with licence requirements

Alarms and shut-off valves will be fitted along the gas supply pipeline. Where possible, the

gas pipe will be welded to minimise the occurrence of leaks. Valves and flanges will be fitted

with leak detection alarms connected to the manned control room. Valves on site will be fitted

with manual override mechanisms. Safe shutdown programmes will be incorporated into the

computerised control system. An emergency generator will be provided to supply power to

essential plant in the event of an interruption to power supply.

Good housekeeping practices and regular monitoring of tanks and equipment will minimise

the likelihood of leaks and spills occurring on site and ensure that if any leaks / spills do

occur, they will be contained and controlled immediately.

Site inductions will include safety requirements and emergency evacuation procedures. Site

personnel will be provided with training on accident prevention and emergency response.

Emergency drills will be undertaken in accordance with the recommendations of the local

emergency services.

An Emergency Incident Response Plan will be developed and implemented in consultation

with the local emergency services. The plan will include emergency response contact details

for site personnel and emergency services, maps and plans of the facility, emergency

procedures, chemical inventories and equipment lists.

Fire protection for the power plant will be provided from a combination of fire detection and

alarm systems, combustible gas detection and alarm systems, water spray deluge systems,

sprinkler systems, carbon dioxide suppression systems and mobile fire protection equipment

will be installed in accordance with National Fire Protection Association (NFPA)

recommendations.

The gas turbine enclosure will be protected from fire using an automatic carbon dioxide

gaseous extinguishing system as well as optical flame detection, hydrocarbon sensing and

thermal detectors.

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Water for fire fighting purposes will be contained within a dedicated fire water storage section

of the raw water tank. Any areas to be protected via the water spray deluge system will be

connected to a fire water ring main which will be laid around the power plant.

A Fire Emergency Response Plan will also be developed and implemented in consultation

with Kilkenny County Council.

A.1.10 Remediation, Decommissioning, Restoration & Aftercare

Subject to the granting of an IPPC licence it is anticipated that operations at the facility will

commence in 2013, the plant is expected to be operational for 25 years.

A detailed Residuals Management Plan will be developed and submitted to the EPA within

six months of commencement of operations, or as otherwise agreed with the EPA, in

accordance with Guidance on Environmental Liability, Risk Assessment, Residuals

Management Plans and Financial Provision, EPA (2006). The plan will be reviewed

annually as part of the Annual Environmental Report (AER). The Residuals Management

Plan will include details of costings for the plan and a description of how these costs will be

underwritten.

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