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Attachment A

Updated Section B.1

Updated Section B.3

Updated Table D.2 (i)

Updated Section B.13

Updated Table Section G.1

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B.1. Applicant

Name*: Electricity Supply Board Address: Moneypoint Generating Station Killimer Kilrush Co.Clare Tel: 065 9080300 Fax: 065 9052455 e-mail:

* This should be the name of the applicant which is current on the date this Licence Application is lodged with the Agency. It should be the name of the legal entity (which can be a limited company or a sole trader). A trading/business name is not acceptable. Name and Address for Correspondence Only application documentation submitted by the applicant and by the nominated person will be deemed to have come from the applicant.

Name: Emma Delaney – ESB International Address: One Dublin Airport Central Dublin Airport Cloghran Co.Dublin Tel: 01-7038039 Fax: 01-6764400 e-mail: [email protected]

CRO No. and address of registered or principal office of Body Corporate CRO No. ESB is not a body corporate and does not have a CRO number as it is a

statutory corporation set up under the Electricity (Supply) Acts 1927 as amended.

Address: Electricity Supply Board Head Office Two Gateway, East Wall Road Dublin 3 Tel: 01 6765831 Fax: 01 6621257 e-mail:

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B.3. Class of Activity

Identify the relevant activities in the First Schedule of the EPA Act 1992, as amended, to which the activity relates:

Class Description Identify Main IED Activity 2.1 Combustion of fuels in installations with

a total rated thermal input of 50 MW or more.

Combustion of fuels in installations with a total rated thermal input of 50 MW or more.

11.5 Landfills, within the meaning of section 5 (amended by Regulation 11 ( 1) of the Waste Management (Certification of Historic Unlicenced Waste Disposal and Recovery Activity) Regulations 2008 (S.I. No. 524 of 2008)) of the Act of 1996, receiving more than 10 tonnes of waste per day or with a total capacity exceeding 25,000 tonnes, other than landfills of inert waste.

B.3A Industrial Emissions Directive

Specify which category/categories of industrial activity referred to in Annex I of the Industrial Emissions Directive (2010/75/EU) is/are to be carried out at the installation.

Category Description Identify Main IED Activity

1.1 Combustion of fuels in installations with a total rated thermal input of 50 MW or more.

Combustion of fuels in installations with a total rated thermal input of 50 MW or more.

5.4 Landfills, as defined in Article 2(g) of Council Directive 1999/31/EC of 26 April 1999 on the landfill of waste receiving more than 10 tonnes of waste per day or with a total capacity exceeding 25 000 tonnes, excluding landfills of inert waste

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Table D.2(i) Waste Acceptance (type and quantities)

EWC Code Waste description

(the actual description of the waste, not the text accompanying the EWC code)

Tonnes per annum

(existing) 2015

Tonnes per annum

(existing) 2014

Tonnes per annum

(existing) 2013

Tonnes per annum

(proposed)

10 01 05 FGD by-product (FGD By-Product Landfill) 124,213 46,678 46,678 Approx 95,000

10 01 02 Pulverised Fuel Ash (Ash Storage Area) 30,152 54,266 105,580 Approx 110,000

10 01 01 Furnace bottom ash (Ash Storage Area) 6,637 5,641 16,736 Approx 17,000

10 13 99 Cement (FGD By-Product Landfill) 902 502 502 Approx 1,000

10 01 02 Pulverised Fuel Ash (FGD By-Product Landfill) 28,456 14,003 14,003 Approx 30,000

Note: Actual proposed quantities will depend on sales of ash off site and level of generation operation.

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B.13 Review of a licence

State the grounds on which an application for a review of a licence is being made and give the reference number to the relevant licence in the register. Response Moneypoint Generating Station holds a current IE Licence P0605-03. Planning permission to increase the capacity of the ash storage area was granted by Clare County Council (Planning Ref No: Reg. Ref. 14/373) on the 14th August 2014. The application was accompanied by a full EIS and NIS. A technical amendment was applied for to enable use of the increased capacity was made and refused by the EPA resulting in this application for licence review. In addition, ESB Wind Development obtained planning permission for the erection of five wind turbines, anemometer masts, electrical substation and control building on the site on the 12th December 2013 (Clare County Council Reg. Ref. 12/74 and An Bord Pleanála PL03.2043). A full EIS and NIS was provided with the planning application. (see Attachments B.13).

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Details of Process related Raw Materials, Intermediates, Products, etc., used or generated on the site

Ref. No or Code

Material/1 Substance

CAS Number

Danger 2 Category

Amount Stored

(tonnes)

Annual Usage

(tonnes)

Nature of Use Organic/ Inorganic

R –

Phrase3S -

Phrase Seveso Yes/No

1. Ash (Coal Fly Ash) Max 3,000,000

100,000 Cement additive No

2. Ash (Bottom Ash) 120,000 Road fill No

3. Acetylene

74-86-2 Explosive

0.165 tonnes

850m3 (100

cylinders) Welding Organic 5, 6, 12 9, 16, 33 No

4. Ammonia Liquor (35%) 7664-41-7 Corrosive

5.2 tonnes 10 Boiler

Treatment Inorganic 34,

36/37/387,26,45 No

5. Ammonium molybdate reagent

12054-85-2 180 litres 720 litres Silica monitor

reagent Inorganic No

6. Antifreeze 1077-21-1 Harmful 350 litres 525 litres ACW

Conditioning

Mobile plant Organic 22 46, 2 No

7. Argon 7440-37-1 None Welding No

1 In cases where a material comprises a number of distinct and available dangerous substances, please give details for each component

2 c.f Article 2(2) of SI No 77/94

3 c.f. Schedules 2 and 3 of SI No 77/94

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Ref. No or Code


CAS Number

Danger 2 Category

Amount Stored

(tonnes)

Annual Usage

(tonnes)


R –

Phrase3S -


8. Carbon Dioxide (18 m3 per cyl.)

124-38-9 Asphyxiant 92 cyl and

100kgs powder

50 cyl and powder as required.

Generator purging and

Fire protection No

9. Coal Typical

3,000,000 Max

2,200,000 Fuel Organic No

10. Control Fluid Pyrogard / pyrotech

25155-23-1 Marine pollutant

3 tonnes 2,665 litres Hydraulic fluid Inorganic 51/53 61 No

11. Electricity 0 572 GWhrs Power Supply No

12. Fluorescein 2321-07-5 None 5 kg As requiredCondenser

leak detection Organic No

13. FP 70 (detail also applies to Nicerol)

7647-14-5

1314-13-2

107-41-5 Non Flammable 2,100 litres

Zero under normal

conditions

Fire Fighting Foam

Organic No

14. Gas Oil (Diesel) 68334-30-5 Harmful 600 tonnes 827 tonnes Standby fuel Organic 40 2,24, 36/37,

43,61,62 No

15. Heavy Fuel Oil 50,000

40,865 in 2016

Fuel Organic Yes

16. Carbo Hydrazide 497-18-7 Toxic

1 Tonne 1 Tonne Boiler

treatment Organic 43, 52/53,38,36

24/25, 26, 28, 36/37/39

No

17. Hydrochloric Acid (36% solution)

7647-01-0 Corrosive 1.2 tonnes 1.2 tonnes Boiler wash neutralisation

Inorganic 34,37 26,45 No

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Ref. No or Code


CAS Number

Danger 2 Category

Amount Stored

(tonnes)

Annual Usage

(tonnes)


R –

Phrase3S -


Chlorine cell cleaning.

18. Hydrogen 7.21m3 per container

1333-74-0 Extremely flammable

0.513 tonnes

6,495 m3 Generator cooling

Inorganic 12 9-16-33 No

19. Ion Exchange Resins Non- hazardous 150 m3 20 m3 Water

Treatment Organic No

20. Laboratory Chemicals No

21. Lubricating oils 13,000 litres

31,000 litres Lubrication No

22. Nicerol 3% Protein foam Concentrate as for FP70

7647-14-5

1314-13-2

107-41-5

Non flammable 2,100 litres As requiredFire

suppression Organic No

23. Nitrogen (Incl. 8% and 2%)

7727-37-9 None 42 cyl 108 cyl

Purging and calibration Instrument Measurement Lines & Lab CHN

Inorganic No

24. Nitrous Oxide 10024-97-2 Asphixiant 2 cyl 2cyl Lab use Atomic

absorption Inorganic 3,7 No

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Ref. No or Code


CAS Number

Danger 2 Category

Amount Stored

(tonnes)

Annual Usage

(tonnes)


R –

Phrase3S -


25. Oxygen 7782-44-7 Oxidising 6 cyl 26 cyl Laboratory use 8 17 No

26. Propane 74-98-6 Flammable 6 tonnes 18.5 tonnes Ignition Fuel Organic 12 9,16,33 No

27.

Reducing reagent containing:

Ascorbic acid EDTA (di sodium salt)

Formic acid

50-81-7

180 litres 720 litres

Silica monitor reagent

No

28. Silica gel 7631-86-9

7646-79-9 None assigned. 75 kgs 40 kgs

Transformer protection

Inorganic 49 No

29. Sodium Chloride (Salt) 7647-14-5 None 0.5 Tonnes 0.1 TonnesWTP

regeneration No

30. Sodium Hydroxide Liquor

(Caustic Soda) (46%)

1310-73-2 Corrosive 100 tonnes 200 Tonnes

WTP regeneration;

boiler water treatment

Inorganic 35 26,37/39,45 No

31. Sulphur hexafluoride (SF6) 2551-62-4 Non flammable gas

1,000kgs 1,000kgs Circuit breaker

insulation Inorganic No

32. Sulphuric Acid 7664-93-9 Corrosive

100 Tonnes

100 Tonnes

WTP regeneration Inorganic 35 2,26,30 No

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Ref. No or Code


CAS Number

Danger 2 Category

Amount Stored

(tonnes)

Annual Usage

(tonnes)


R –

Phrase3S -


33. Sulphuric acid reagents 360 litres 1,440 litresSilica monitor

reagents Inorganic No

34. Water (Town) 7732-18-5 None 8 MillGalls300 Mill

Gals

35. Water Estuarine None 0 115000 tonnes /

hour

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Attachment B

Planning Permission for the Environmental Retrofit Project

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_____________________________________________________________________ PL 03.204329 An Bord Pleanála Page 1 of 4

An Bord Pleanála

PLANNING AND DEVELOPMENT ACTS, 2000 TO 2002

Clare County

Planning Register Reference Number: P03-625

An Bord Pleanála Reference Number: PL 03.204329 APPEAL by An Taisce of The Tailors’ Hall, Back Lane, Dublin against the decision made on the 21st day of August, 2003 by Clare County Council to grant subject to conditions a permission to Electricity Supply Board care of Station Manager, ESB Moneypoint Generating Station, Killimer, Kilrush, County Clare in accordance with plans and particulars lodged with the said Council. PROPOSED DEVELOPMENT: Provision of an Environmental Retrofit Project to abate emissions of sulphur dioxide (SO2) and oxides of nitrogen (NOx) to comply with the conditions of the station’s Integrated Pollution Control (IPC) Licence. The project will involve the installation of Dry Flue Gas Desulphurisation (FGD) technology to reduce emission of SO2 from the chimneys, installation of NOx reduction equipment and construction of purposely engineered landfill areas, within the confines of the station site, for storage and disposal of conditioned FGD by-product all on a site at Moneypoint Generating Station, Killimer, Kilrush, County Clare.

DECISION

GRANT permission for the above proposed development in accordance with the said plans and particulars based on the reasons and considerations under and subject to the conditions set out below.

REASONS AND CONSIDERATIONS

Having regard to:

(a) the nature and scale of the proposed development,

(b) the existing use of the site as an electricity generating station, (c) the environmental benefits of significant reductions in emissions of sulphur

dioxide and nitrogen oxides, and to requirements for reductions in emissions of these gases as set out in European and domestic legislation,

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(d) Government policy in relation to the reduction of greenhouse gases as expressed in the National Climate Change Strategy for Ireland published by the Department of the Environment and Local Government in October, 2000 and as further developed through Ministerial statement, and to Ireland’s forthcoming participation in a European greenhouse gas emissions trading scheme,

(e) existing and proposed conservation designations relating to this area and to the

fact that part of the site, which is currently within a candidate Special Area of Conservation, comprises fill material and is of no particular conservation interest, and

(f) the requirement for a review of the Integrated Pollution Control licence

relating to activities on this site, it is considered that the proposed development would not seriously injure the amenities of the area and would be in accordance with the proper planning and sustainable development of the area.

CONDITIONS

1. The development shall be carried out in accordance with the plans and particulars submitted to the planning authority on the 2nd day of April, 2003, and as clarified and expanded in additional information submitted to the planning authority on the 30th day of June, 2003 and additional information submitted to the Board on the 12th day of January, 2004, except as may be amended by the following conditions. Reason: In order to clarify the development to which this decision relates.

2. The developer shall prepare, submit and agree in writing with the planning

authority a construction method statement to include the following:

(a) the proposed realigned internal access road, buffer strip and rock armouring. The rock armouring shall be placed inside (on the site side) the existing rock armoured coastline and works required in the placement of the rocks and construction of the road shall not interfere with the coastline. Temporary markers shall be provided to delimit the location and extent of proposed rock armour during construction. No additional rock armouring shall be placed in the estuary,

(b) the proposed two surface water discharge pipes to serve the landfill

areas. Disruption to the existing rock armouring shall be minimised, and

(c) the temporary storage of construction materials and plant. No

materials or plant shall be stored within 50 metres of the existing coastline. Proposals for remedial action in the event of any spillage shall be included in the statement.

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A suitably qualified ecologist shall be present during periods of rock placement along the coastal boundary and the construction of the two discharge pipes at the coastline, and shall submit a written report to the planning authority confirming compliance with the terms of this condition. Reason: In order to protect the amenities of the adjoining estuary, which is designated as a candidate Special Area of Conservation and proposed Natural Heritage Area.

3. Before development commences details of the following matters shall be

submitted and agreed in writing with the planning authority:

(a) a landscaping scheme prepared by a landscape architect for the site and a timescale for implementation. Particular attention shall be given to the treatment of the western site boundary where landscaping proposals shall include extensive planting of suitable trees and shrubbery for this location, and planting shall be implemented within one year of the commencement of development,

(b) a colour scheme for the proposed buildings/structures, and

(c) a traffic management scheme for the construction phase of the

development. This shall include details of equipment and materials to be transported by road, identification of proposed haul routes, and an indicative timetable for deliveries. The delivery of any extra wide loads shall be notified and agreed with the planning authority in advance.

Reason: In the interest of visual amenity and road safety.

4. The developer shall pay a sum of money to the planning authority as a

contribution towards expenditure that was and/or that is proposed to be incurred by the planning authority in respect of the provision of recreational and community facilities facilitating the proposed development. The amount of the contribution and the arrangements for payment shall be agreed between the developer and the planning authority or, in default of agreement, shall be determined by An Bord Pleanála.

In the case of expenditure that is proposed to be incurred, the requirement to pay this contribution is subject to the provisions of section 26(2)(h) of the Local Government (Planning and Development) Act, 1963 generally, and in particular, the specified period for the purposes of paragraph (h) shall be the period of seven years from the date of this order.

Reason: To contribute towards the cost of providing community facilities and municipal open space as outlined in the Clare County Development Plan.

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5. The developer shall pay a sum of money to the planning authority as a

contribution towards expenditure that was and/or that is proposed to be incurred by the planning authority in respect of road works (including any necessary restoration or repair works) facilitating the proposed development. The amount of the contribution and the arrangements for payment shall be agreed between the developer and the planning authority or, in default of agreement, shall be determined by An Bord Pléanala.

In the case of expenditure that is proposed to be incurred, the requirement to pay this contribution is subject to the provisions of section 26(2)(h) of the Local Government (Planning and Development) Act, 1963 generally, and in particular, the specified period for the purposes of paragraph (h) shall be the period of seven years from the date of this order.

Reason: It is considered reasonable that the developer should contribute towards the expenditure that was and/or that is proposed to be incurred by the planning authority in respect of works facilitating the proposed development.

Member of An Bord Pleanála duly authorised to authenticate the seal of the Board. Dated this day of 2004.

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Attachment C

Letter relating to Moneypoint Seveso Status

Firewater Risk Assessment – April 2017

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IE0311713-LET-0002_1_01.DOCX

162.TP.15, Issue 7, 10/12/2015

Russia

Singapore

Slovakia

Switzerland

UK

USA

T

E

W

The project delivery specialists

International Office Network

Belgium

China

Czech Republic

India

Ireland

Poland

+353 1 404 0700

[email protected]

www.pmgroup-global.com

Project Management Limited t/a PM Group, is a private company limited by shares, registered in Ireland. Company Registration No. 043789. Registered Office: Killakee House, Belgard Square, Dublin 24, Ireland. Directors D Flinter (Chairman), D Murphy (CEO), F Barry, L Foley, B Gallagher, H Keelan, S Kelly, M Lynam, JC O’Connell, L O’Mahony, A Schouten (British), L Westman Secretary J Sheehan PM Group™ name and logo are trademarks Template Ref: 162.TP.15

PM Group

Killakee House

Belgard Square

Dublin 24

Ireland

Our Reference: IE0311713-LET-0002 24

th March 2017

Sean Rynne ESB Moneypoint Carrowdotia Killimer Co. Clare

Re: EPA Letter - ESB Seveso Status Dear Sean, The Chemicals Act (Control of Major-Accident Hazards involving Dangerous Substances) Regulations 2015 (S.I. No. 209 of 2015), implement in Ireland, the Seveso III Directive (Directive 2012/18/EU). These regulations require operators of establishments where dangerous substances are present, in quantities equal to or in excess of defined thresholds, to take all measures necessary to prevent and mitigate the effects of major-accidents to both human health and the environment. ESB Moneypoint is subject to the COMAH Regulations due to the presence of substances on site that are collectively above the threshold values listed in Column 3, Schedule 1 of the Regulations, i.e. Moneypoint is an ‘Upper Tier’ site. At your request we have reviewed the inventory of dangerous substances present on the ESB Moneypoint site to determine whether the presence of Heavy Fuel Oil (HFO) on site is the main driver behind the site’s Seveso status. The following table compares the quantities stored on site against the qualifying thresholds in Schedule 1 of the Regulations. As per Note 3 in Schedule 1 of the Regulations, substances present in quantities less than 2% of the qualifying thresholds were not considered.

Dangerous Substance

Quantity Stored on

Site (tonnes)

Qualifying Quantity (tonnes) for the application of; % of

Lower % of

Upper Lower-tier requirements

Upper-tier requirements

Heavy Fuel Oil 50,000 2500 25000 2000% 200%

Diesel 600 2500 25000 24% 10%

Propane 6 50 200 12% 3%

Aqueous Ammonia 5.2 100 200 5.2% 2.6%

Hydraulic Fluid 3 100 200 3% 1.5%

Hydrogen 0.513 5 50 20% 1%

Anhydrous Ammonia 0.258 50 200 0.5% 0.1%

Acetylene 0.165 5 50 3.3% 0.3%

% of Lower & upper Tier Qualifying Quantities without HFO 68% 18.5%

As can be seen from the table above, if HFO was removed from site, the site would no longer be classified as a Seveso site of either tier. For any clarifications or queries in relation to this review, please do not hesitate to contact me at 01-4001201. Yours Sincerely,

_________________________ Ciaran Reay EHS Consultant

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Firewater Risk Assessment

Issue date: 10th April 2017

ESB Moneypoint Generating Station Moneypoint Seveso Compliance IE0311713-22-RP-0001, Issue: A

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162.TP.09, Issue 7, 31/03/2014 Formal Issue

Document Sign Off

Firewater Risk Assessment ESB Moneypoint Generating Station Moneypoint Seveso Compliance IE0311713-22-RP-0001, Issue A

File No: IE0311713.22.010

CURRENT ISSUE

Issue No: A Date: 10/04/2017 Reason for issue: For Information

Sign Off Originator Checker Reviewer Approver Customer Approval (if required)

Print Name Ciaran Reay Pat Swords / Orla Duggan

Ciaran Reay

Signature Authorised Electronically

Date 27/02/2017 03/04/2017 10/04/2017

PREVIOUS ISSUES

Issue No

Date Originator Checker Reviewer Approver Customer Reason for issue

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ESB Moneypoint Generating Station Moneypoint Seveso Compliance IE0311713-22-RP-0001, Issue A

10/04/2017

IE0311713-22-RP-0001_A_05.DOCX Page 3 of 58 Formal Issue

Contents

1 Executive Summary 4

2 Introduction 5

3 Site Overview 6

4 Technical and Organisational Measures 9

4.1 ESB Fire Protection Standards 9

4.2 Emergency Response Procedures 10

4.3 Fire Protection Systems 11

5 Risk Assessment – ESB Moneypoint 17

6 Heavy Fuel Oil (HFO) Fire Scenario 23

6.1 Scenario 23

6.3 Emergency Response Procedure 24

6.4 Extinguishing Water Requirements 25

6.5 Controlled Burn Strategy Discussion 26

6.6 Recommendations 27

Appendix A 28

Risk Assessment Methodology 28

Appendix B 37

Firewater Retention Calculation Methodologies 37

Appendix C 46

Controlled Burn Strategy Literature 46

Appendix D 53

HFO Tank Firewater Calculations 53

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10/04/2017


1 Executive Summary

ESB Group operates the Moneypoint Electricity Generating Station (Moneypoint) in Killimer, Co. Clare on the Shannon Estuary. The site consists of approximately 180 hectares in total and has been in operation since 1985.

PM Group was requested to undertake a firewater risk assessment study to determine the requirements for a firewater retention facility at Moneypoint. This study also includes a review of internationally recognised best practice in dealing with large scale tank farm fires involving Heavy Fuel Oils (HFO).

The risk assessment concludes that the risk of firewater run-off from the majority of areas of the site is low and that no dedicated retention infrastructure is required. However, the presence of the bulk HFO tanks (2 x 25,000t) was highlighted in the risk assessment as a high risk area in relation to potential environmental damage in a fire scenario, based on the significant volumes present.

This fire scenario was investigated further to clarify firstly, the likelihood of a fire involving the HFO tanks and secondly the fire fighting strategy in the event of a fire, in order to estimate the volumes of firewater run-off that could be generated.

It was concluded from an extensive literature review on this subject that unless such a fire was brought under control within a short time frame, the success rate of extinguishing a fully developed fuel tank fire would be extremely low. In this regard, the option of a controlled burn strategy was explored. Instead of fighting the fire continuously (which could last up to 2 days due the energy content of the fuel) and generating very significant quantities of contaminated firewater run-off, a controlled burn strategy could be used to prevent the generation of large volume of firewater run-off and thereby minimise the risk of pollution to the adjacent estuary.

This report reviews the appropriateness of a controlled burn strategy for a HFO tank fire at the Moneypoint facility and concludes that consideration should be given to implementing this strategy in consultation with the relevant competent authorities.

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10/04/2017


2 Introduction

Moneypoint is subject to the Chemicals Act (Control of Major-Accident Hazards involving Dangerous Substances) Regulations 2015 (S.I. No. 209 of 2015), commonly known as Seveso III, due to the presence of substances on site that are above the threshold values for those substances listed in Schedules 1 and 2 of the Regulations. Moneypoint is classified as an ‘Upper Tier’ site under these regulations. There are a number of substances stored on site which lead to this classification, with the storage of approximately 50,000t of Heavy Fuel Oil (HFO) being the largest quantity.

Due to this classification, Moneypoint is obliged to implement and manage a rigorous Major-Accident Prevention Policy (MAPP) and a Safety Management System (SMS). In this respect, the following measures have been completed;

- Major-accident hazards have been identified and the necessary measures have been taken to prevent such accidents and to limit their consequences for human health and the environment.

- Adequate safety and reliability have been incorporated into the design, construction, operation and maintenance of the installations, storage facilities, equipment and infrastructure which are associated with major-accident hazards at the establishment.

- Internal and external emergency plans have been drawn up, which will limit the consequences of any major-accident that could occur on-site.

Due to the nature of the substances stored on site, large scale fire scenarios in various areas of the site have been assessed in detail and a range of preventative and protective measures are in place.

Fires involving industrial facilities with large scale storage of hazardous substances are generally controlled by applying large volumes of water or foam. These substances can be transported by firewater run-off to sensitive environmental receptors, causing long term pollution if satisfactory containment is not present. In addition to containment, smart fire fighting practices also need to be implemented, as unnecessarily large volumes of firewater run-off are frequently the main cause of ecological damage to waters due to chemical accidents.1

PM Group was requested to undertake a comprehensive study to determine the requirements for Fire-Water Retention at Moneypoint. The study also included a review of internationally recognised best practice in dealing with transformer fires and also large scale tank farm fires involving Heavy Fuel Oils (HFO).

This study took account of latest European and International guidance documents in the field of environmental damage limitation from fire-fighting water run-off.

1 Environmental Outlook for the Chemicals Industry, 2001 (OECD)

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3 Site Overview

The principal facilities at ESB Moneypoint as shown on the Site 3D Risk Map in Attachment 1 include:

- Production Facilities including the Boiler Houses, Turbine Hall, Ash Handling Plant, SCR (Selective Catalytic Reduction) & FGD (Flue Gas Desulphurisation) Units

- Jetty

- Bulk Fuel Oil & Propane Storage Area

- Coal Yard and Coal Transfer Conveyors & Towers

- Water Treatment Plant

- Chlorination Plant

- Urea to Ammonia (U2A) Plant

- Hydrogen Compound

- Transformers

- Ash Storage Area

- Flue Gas Desulphurisation Landfill

3.1.1 Production Facilities

The production facility buildings accommodate three separate electricity-generating units. Each unit is comprised of:

- Coal mills where the coal is pulverized to a fine powder

- Boiler where the fuel is combusted to generate steam

- Turbine/Generator where the steam is used to power electricity generation

- Electrostatic Ash precipitator where fine ash from the combustion process is collected

- Selective Catalytic Reduction (SCR) unit where ammonia is reacted with the NOx in the boiler flue gas via a catalyst to produce nitrogen gas and water

- Circulating Fluidised Bed Flue Gas Desulphurisation (FGD) unit where burnt lime CaO is hydrated to lime hydrate Ca(OH)2 and then reacted with the SO2 in the flue gas to form calcium sulphate CaSO4 powder and water.

3.1.2 Jetty

The site’s 380m long jetty is located to the south east of the site approximately 100m from the shore. It is designed for the berthing of ships with displacement weights of up to 275,000T. There are approximately 2 No. Heavy Fuel Oil shipments and 15 No. coal shipments annually.

3.1.3 Bulk Fuel Oil & Propane Storage Area

The bulk fuel storage area contains the following fuel storage tanks as well as ancillary pipework and pumps etc. All tanks are bunded except for the propane tank and the double-skinned 20m3 white diesel tank.

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Table 3.1: Description of Tanks in Bulk Fuel Oil & Propane Storage Area

Tank Description No. of Tanks Working Capacity (m3)

25,000 tonne HFO Tank (vertical) for production use

2 24,300 (up to a level of 13m)

300 tonne Diesel Tank (vertical) for production use

2 275 (up to a level of 5.5m)

20m3 White Diesel Tank (double-skinned) for vehicle refuelling

1 20 approximately

15m3 Green Diesel Tank (horizontal) for vehicle refuelling

1 15 approximately

4 tonne Propane Tank (horizontal) for production use

1 N/A

3.1.4 Coal Yard and Coal Transfer Conveyors & Towers

The Coal Yard is a 30 hectare (approximately) coal storage area to the east of the site. Up to 630,000T of coal can be stored in this area. Coal is delivered to the site by marine shipments of up to 150,000T each. Coal is unloaded from the ships using two container crane grab buckets at the jetty and transferred to the coal yard via a series of transfer towers. Additional transfer towers transfer coal from the yard to the site Production Facilities.

3.1.5 Water Treatment Plant (WTP)

The water required for steam generation in the station boilers is recirculated between the pre-heaters, boilers and condensers. Make-up water for this system is taken from the site’s mains water supply and is treated in the Water Treatment Plant (WTP) prior to use. The purpose of the WTP is to de-ionise the water used for steam generation through ion exchange. The ion exchange resins are regenerated using sulphuric acid and sodium hydroxide. These chemicals are supplied in bulk (96% H2SO4 and 46% NaOH). The WTP control systems dilute the sulphuric acid to 2-6% and the sodium hydroxide to 3-5% prior to their use in the regeneration of the ion exchange resins. The maximum throughput of the WTP is 5,000m3/day of water.

3.1.6 Electro-Chlorination Plant

Cooling water for the Moneypoint site is drawn from the Shannon Estuary. Prior to use it is chlorinated in the electro-chlorination plant to prevent microbial growth. The sodium chloride in the seawater is disassociated into Na+ and Cl- ions in the plant electrolysers. The Cl- ions then react with OH- ions to produce hypochlorite which acts as a chlorinator in the water.

The electrolysers are washed using hydrochloric acid. 35% HCl solution is stored in an IBC in a bunded Chemstore beside the Electro-chlorination Plant which is located to the south of the site beside the Hydrogen Compound. The 35% HCl solution is transferred from the IBC to a tank where it is diluted to a concentration of 6% for use. Usage of the 35% HCl solution is at a rate of approximately 1m3 per year.

3.1.7 Urea To Ammonia (U2A) Plant

The Ammonia Generation Plant is located to the east of the main station production buildings adjacent to the Water Treatment Plant. Urea pellets are dissolved in water to form a urea solution. From the urea solution storage tanks the solution is transferred to the hydrolyser as required where it is steam-heated and ammonia gas is evolved. The ammonia gas is then piped to the Selective Catalytic Reduction Unit(s) in the main production area for flue gas treatment.

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3.1.8 Hydrogen Compound

The Hydrogen Compound is located to the south of the site adjacent to the Shannon Estuary. Hydrogen cylinder manifolds are stored in the compound on two trailers, each containing approximately 260kg of hydrogen at a pressure of 228barg. The hydrogen is supplied by BOC Gases.

The trailers are earthed and then connected to the site hydrogen pipework. The compound is a designated ATEX zone with access control.

The hydrogen is used for cooling of the site generators, at a pressure of approximately 4bar.

3.1.9 Transformers

There are 3 No. 400kV transformers on site which are used to step up the voltage of the generated electricity from 17kV to 400kV prior to supply to the national grid. These are located adjacent to the Turbine Hall on the south side. There are other transformers located around the site.

3.1.10 Ash Handling Plant

There are two distinct ashing systems installed in Moneypoint and are appropriately named:

- Wet Ash System

- Dry Ash System

3.1.11 Ash Storage Area

The ash storage area is located to the west of the site on the opposite side of the N67 from the main site. The area has an ash capacity of 3 million m3.

3.1.12 Flue Gas Desulphurization (FGD) Landfill

The by-product of the flue gas desulphurization process is a mixture of calcium sulphate and some water. This by-product is landfilled in the Flue Gas Desulphurization (FGD) landfill located to the east of the site Coalyard.

The FGD by-product is stabilized using ash (from the site combustion process) and cement (purchased for this purpose). The basal containment layer and capping layer of the landfill are constructed and compacted to achieve low permeability. The capping layer is overlain with drainage and soil layers.

3.1.13 General Site Areas

Additional areas on site include the following:

- Security & Visitor Centre Located At The Site Entrance.

- Septic Tanks 1, 2 & 3 – the on-site septic tanks serve the main station, the offices, stores and welfare facilities to the west of the site, and the jetty. The jetty hygiene facilities and septic tank are not currently in use.

- Compressor House – Electrical Generation of Compressed Air for Instruments And Process Requirements.

- Ash Water Pump House

- Waste Collection and Storage Area– hazardous and non-hazardous site waste is gathered in this area prior to removal from site by licensed waste contractors. The main site wastes generated are: mixed/general waste, metal, wood, cardboard, paper, WEEE, oil & oily waste, batteries and fluorescent tubes.

- Miscellaneous non-process buildings including workshops, stores, locker rooms, canteen, offices and car parking

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4 Technical and Organisational Measures

The following section provides further information required to assist the risk assessment process.

A series of controls and safeguards are in place at the ESB Moneypoint site to reduce the likelihood of a major fire incident occurring and to limit the subsequent impact should such an incident occur.

Applicable measures include:

- Primary Containment

- Secondary Containment

- Tertiary Containment

- Control Systems & Instrumentation

- Avoidance of Ignition Sources – ATEX Zones

- Environmental Protection Measures

- Operational Procedures

- Emergency Response Procedures

- Training

The safety control measures documented in this section are managed as part of the safety management system (SMS). The SMS provides a structured hierarchal framework for safety management on-site and is externally accredited to OHSAS 18001. The SMS includes the Safety Policy, Annual Safety Improvement Plan, and documented procedures which are implemented to manage safety on-site.

4.1 ESB Fire Protection Standards

ESB Moneypoint manages the fire safety systems on site in compliance with the ESB Power Generation Technical Standard PGTS 13/22 “Fire Protection in Generating Stations”. This standard derives from the Power Generation Technical Management Framework and also forms part of the OHSAS 18001 Safety Management System. It applies to all ESB Generating Stations.

The purpose of the standard sets out the minimum requirements for fire protection in generating stations including those related to the inspection, testing and maintenance of fire protection systems and equipment. The standard advises that inspection and testing recommendations of equipment suppliers should normally be followed where these are more stringent.

4.1.1 Hot Work Permit

A Hot Work Permit is required for any work involving:

a) Risk of ignition of an explosive atmosphere within a vessel or pipe having contained combustible / flammable substances.

b) Risk of ignition of nearby combustible / flammable material leading to a fire.

c) Risk of creation of an incipient or dormant ignition source that may remain unnoticed immediately after work has ceased, but which may result in a fire some time later.

d) Hot Work within a Confined Space.

- Typical ignition sources include gas welding and cutting, electric welding, the use of blowtorches, grinding and certain high heat lighting sources.

- A check shall be carried out to ensure that firefighting equipment appropriate to the risk is accessible for use within a reasonable distance, and person(s) involved in the hot work are trained in its use.

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- All persons engaged on the work shall be familiar with the procedure for raising the fire alarm.

- Where Hot Work presents a significant fire risk, the use of two or more persons shall be considered as a Control Measure.

- Upon completion of Hot Work and at the end of each work period, a thorough examination shall be made in the immediate area to ensure that all sources of ignition have been extinguished and made safe. Periodic inspections shall be carried out for a subsequent period appropriate to the fire risk. Such inspections can be performed by the person carrying out the work or be delegated (e.g. to shift personnel).

4.2 Emergency Response Procedures

Emergency Response measures are currently in place at the site to deal with a Major Accident if one was to arise.

- Emergency response procedures (ERP) as detailed in the site’s Safety Management System (SMS) include;

- Emergency Procedure in the Event of a Fire

- Procedure in the Event of a Chemical Spill

- Oil Spill Response Procedure

- Internal Emergency Plan

- Security Incident Procedure

- Emergency Procedure Gas Leak Response (Propane & Hydrogen)

- Ammonia Gas Leak Response Procedure

- Shannon Estuary Oil / HNS (Chemical) Spill Contingency Plan

These procedures provide detailed instructions on appropriate actions in responding to the site’s identified potential major accidents.

Relevant emergency response procedures are reviewed with the Local Fire Officer.

4.2.1 Fire Brigade Risk Card

A risk card has been developed by ESB Moneypoint in conjunction with the Clare County Council Fire Officers and the local fire brigade. It is a quick reference guide to site contact details and site hazards.

The fire brigade regularly attends the Moneypoint site to complete exercises and plant familiarisation (29 separate familiarisation visits or training exercises between April 2010 and May 2016 have been completed). Based on historical fire brigade responses and exercises on the Moneypoint site, the response time for the Kilrush fire brigade to reach the site after an emergency call-out is approximately 8 to 12 minutes.

The site emergency response procedures folder is kept at the main gate in the security building and is available for the fire brigade when they arrive on site.

4.2.2 Emergency Response Training

Evacuation Drills

An emergency evacuation drill is conducted at least every 6 months. It is carried out using the normal evacuation alarm and is unannounced unless otherwise decided by written risk assessment. The drill includes a head count of all persons present in the station and the identification of any persons who remain unaccounted for or who are in the station without authorisation. A brief record and report on the evacuation drill is made, noting any recommended improvements.

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Fire Response Training

Table 4.1 outlines the types and frequencies of fire response training provided to ESB Moneypoint staff.

Table 4.1: Fire Response Training

Training Type Staff Type Minimum Frequency

Fire Extinguisher Use All generating station staff 3 years

Fire Response Training

(Appropriate to the work procedures)

Operation staff Monthly

Fire Response Training in conjunction with Clare Fire Brigade

Fire response teams 4 years

Fire Response Team Exercise

Each Fire response shift team

1 year

Other Training

ESB Moneypoint is a member of the Shannon Estuary Anti-Pollution Team Ltd. (SEA-PT). The Shannon Estuary Oil / HNS (Chemical) Spill Contingency Plan2 details the response plan for such spill scenarios, and also lists spill response training and exercises carried out.

4.3 Fire Protection Systems

4.3.1 Fire Detection Equipment

The site evacuation alarm is manually activated from the central Control Room and all sirens within the station boundaries will sound, including in the Coal yard and at the Jetty.

In addition to manual inspection by the shift teams, there are several fire detection systems:

- Manual alarm point

- Smoke detectors, photocell types

- Rate of rise detectors

- Quartzoid bulb detectors

- Temperature Sensors

In the event that smoke/heat detectors are activated in any area of the site an audible and visual alarm will occur in the central Control Room which is manned 24/7. The person in charge in the Control Room will take appropriate action as per the site’s fire response procedures.

4.3.2 Fire Fighting Systems

A mixture of automatic and manual fixed fire fighting systems and manual fire-fighting capabilities by shift teams provide the fire protection at Moneypoint. In order to ensure immediate access to fire extinguishing equipment, it is situated throughout the site at various fire points.

The station’s fire protection system comprises of a hydrant main and deluge system. The ring main is equipped with facilities for the use of both foam and high-pressure water systems. There is a total of 36,368m3 (8 million gallons) of firewater stored in three reservoirs to the north of the site,

2 Available at http://www.sfpc.ie/download/Pollution%20Plan%202013.pdf

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adjacent to the HFO tanks. The associated Pump House is located adjacent to the Water Treatment Plant to the south of the reservoirs. There are two electric pumps and one diesel pump, each with a capacity of 2.3m3/min at 8.3bar pressure.

Automatic and manually operated high-pressure deluge systems protect the areas of the plant most at risk.

Table 4.2 lists the range of fire fighting equipment and systems present in different areas of the site.

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Table 4.2: Fire Fighting Equipment and System across the Moneypoint Site

Area Systems

General Site Area − 2 No. electric firewater pumps and one diesel firewater pump each with a capacity of 2,275 L/min at 8.3bar – connected to landing valves and hydrants.

− 8 million gallons of firewater.

− Pillar hydrants located throughout the site external.

− Landing Valves located at all levels within the station.

− Mather & Platt Deluge System with one electric firewater pump and one diesel firewater pump, each with a capacity of 12,000 L/min at 8.7bar – connected to the fixed deluge systems throughout the station.

− Fire points complete with fire response equipment located throughout the station.

− AF120 Hi-Combat Mobile Foam Units for the rapid deployment of foam extinguishing agent to fires.

− High Expansion Foam Turbex Units.

− Fire Detection systems.

− Colt Ventilation System.

− Site emergency vehicle for transporting injured personnel. The vehicle is equipped with a Stretcher, First Aid Response equipment including a defibrillator. The Health and Safety Executive ambulance is the preferred option, if this ambulance is unavailable or the time is excessive, the station Emergency Vehicle may be used.

− Site Fire Emergency Vehicle is used for the purpose of transporting key site personnel without delay to the location of a site fire. It is equipped with firefighting emergency response equipment such as hoses, branch pipes, foam, inductors etc.

− Approved fire-fighting Personal Protective Equipment.

− Trained personnel.

Coal Yard & Handling Facilities

− Landing valves spaced along the Stacker Reclaimer tracks with associated sprayers.

− Fixed Firefighting pipework on each Stacker Reclaimer.

− Landing Valves and associated fire response equipment at various locations around the coal transfer towers.

− Pillar Hydrant external to the Coalyard Control room.

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Area Systems

− Cameras on conveyor system.

− Infrared detection system on Stacker Reclaimers.

− Fire ring main around the north side of the coalyard with five fire pillar hydrants and five sprayers.

− Fire extinguishers including CO2 extinguishers for use on Stacker Reclaimer electrical components.

− Automatic roof ventilators on the transfer towers.

− Patol fire detection system on the conveyors.

− Water deluge system on 46 of 66 conveyor fire zones.

Jetty

− Landing valves spaced along the length of the jetty.

− Fire points complete with fire response equipment.

− Foam Compound and associated inductors.

− Fire extinguishers including CO2 extinguishers for use on ship unloader electrical components.

Main Station

− High Pressure Water Deluge Systems.

− High Pressure Water deluge with foam proportioning system.

− Landing Valves

− Ventilators for smoke exhaustion.

− Fire Extinguishers and fire response equipment.

− Hose reels.

− AF120 Foam Units.

Bunker − Patol fire detection system and a high-pressure water deluge system. The bunker bay deluge system can be actuated manually from the control room, the bunker bay switchgear room, and outside the entry door to the bunker bay from the boiler house.

− The bunker bay roof ventilation system consists of twenty-six roof fans. In the event of a fire alarm signal arising from the Patol System at the bunkers, all fans will operate at high speed. In the event of a control circuit failure, the fans will automatically start at high speed. Hose reels and fire extinguishers are provided for dealing with incipient fires.

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Area Systems

− Landing valves, fire hoses and branchpipes are provided for fires outside the areas protected by the water deluge system. CO2 extinguishers are also provided near to electric motors for dealing with electric fires.

Mills − Fire extinguishers and Foam Units are provided in the Mill Area for dealing with incipient fires. In addition fire/explosion protection of mills is provided in two ways:

(1) Using inerting steam to prevent explosions by reducing the oxygen concentration (this may also reduce or extinguish any fire present). Inerting steam is normally meant to deal with the explosion risk in a standstill mill;

(2) Using extinguishing deluge water. Water for deluge is supplied via timed solenoid valves to three areas: -

(i) Feeders (timed for 2 min. opening).

(ii) Classifiers (timed for 90 sec. opening).

(iii) Primary Air Inlet Elbows (timed for 45 sec. opening).

Protected Computer Rooms

− Handheld CO2 Extinguishers.

− FM200 Gas extinguishing system.

− Ventilators for smoke exhaustion.

T4001 – T4003 Main Transformers

− Water Spray Deluge System.

Hydrogen Compound − Water Spray Deluge System.

Heavy Fuel Oil & Diesel Tanks and Pump Houses

− Powder & CO2 Hand-held Extinguishers in the Pump House.

− Foam Unit and associated inductors.

− Portable Ground Monitor Spray nozzles for tank cooling available for connection to local hydrants.

Propane Tank − Portable Ground Monitor Spray nozzles for tank cooling available for connection to local hydrants.

Battery Rooms/Switchgear and Relay Buildings

− CO2 Hand-held Fire Extinguishers.

Compressor House − Powder & CO2 Hand-held Fire Extinguishers.

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Area Systems

− AF120 Foam Unit and associated inductors.

FGD Building − Fixed fire fighting pipework connected to landing valves.

− Automatic CO2 Fire Protection.

− Fire points complete with fire response equipment.

− Smoke Extraction.

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5 Risk Assessment – ESB Moneypoint

5.1 Risk Assessment

The following risk assessment of the facility assesses the different areas of the site which are separated from each other by fire-rated walls or significant distances.

Some areas of the site are not included in the following risk assessment, as they contain little or no combustible or flammable materials, and are separated from areas that do by fire walls or significant distances. These are as follows:

- Security Offices / Visitor Centre

- Stores

- Contractors Area

- Administration Building

- Jetty (emergency scenario covered by separate documentation)

Hazardous liquids in the majority of areas are contained and bunded. In addition, if an accidental spillage occurs, spill absorbent materials will be used to prevent spillages going to surface water drains.

The analysis of material storage at the station, in terms of quantities and storage locations, has been based on the inventory of substances supplied by ESB.

The main site areas of concern are as follows;

- Coal Yard

- Coal Conveying System

- Coal Bunker & Mills

- Urea 2 Ammonia Plant Area

- Transformer Area

- Turbine Hall

- FGD Buildings

- HFO Oil Tank Farm

- Diesel Storage Area

Taking into account the information from Sections 3 & 4 of this report regarding the types of infrastructure and equipment present, the quantities of hazardous substances present and also organisational measures and technical measures in place, each area was risk assessed based on the methodology described in Appendix A.

As detailed in the methodology, the site risk in terms of the requirement for fire water run-off risk assessment will be classed as HIGH, MEDIUM or LOW.

- Scenarios with a HIGH risk will require fire water run-off containment if further risk reduction measures are not implemented.

- A MEDIUM risk may not require fire water run-off containment if further risk reduction measures are implemented.

- A LOW risk does not require fire water run-off containment.

Table 5.1 overleaf provides a summary of the risk assessment conclusions.

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Table 5.1: Risk Assessment Summary

Area Fire Risk Assessment Environmental Risk Assessment Overall Fire Water Runoff Risk

Coal Yard

Likelihood

Consequence

Likelihood

Consequence

Fire Risk

Environmental Risk

High Minor Medium Minor Medium Low

Medium Low Low

Coal Conveying System

Likelihood

Consequence

Likelihood

Consequence

Fire Risk

Environmental Risk

High Minor Medium Minor Medium Low

Medium Low Low

Coal Bunker & Mills

Likelihood

Consequence

Likelihood

Consequence

Fire Risk

Environmental Risk

Medium Moderate Low Minor Medium Low

Medium Low Low

Urea 2 Ammonia Plant Area

Likelihood

Consequence

Likelihood

Consequence

Fire Risk

Environmental Risk

Low Moderate Medium Minor Low Low

Low Low Low

Turbine Hall

Likelihood

Consequence

Likelihood

Consequence

Fire Risk

Environmental Risk

Low Severe Medium Minor Medium Low

Medium Low Low

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Area Fire Risk Assessment Environmental Risk Assessment Overall Fire Water Runoff Risk

Transformer Area

Likelihood

Consequence

Likelihood

Consequence

Fire Risk

Environmental Risk

Medium Minor Medium Minor Low Low

Low Low Low

FGD Buildings

Likelihood

Consequence

Likelihood

Consequence

Fire Risk

Environmental Risk

Low Moderate Medium Minor Low Low

Low Low Low

HFO Oil Tank Farm

Likelihood

Consequence

Likelihood

Consequence

Fire Risk

Environmental Risk

Low Severe Medium Severe Medium High

Medium High High

Diesel Tank Area

Likelihood

Consequence

Likelihood

Consequence

Fire Risk

Environmental Risk

Low Moderate Medium Moderate Low Medium

Low Medium Low

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5.2 Risk Assessment Results

The following section compares the risk assessment results against the current fire water containment strategy to determine if additional firewater retention capacity is required on site.

5.2.1 Coal Yard

Overall Fire Risk = High (Likelihood) x Minor (Consequences) = Medium

Overall Environmental Risk = Medium (Likelihood) x Minor (Consequences) = Low

Overall Fire Risk = Medium (L) x Low (C) = Low

Due to the low overall risk associated with this assessment area, no further firewater containment or reduction measures are required.

In the case of a coal-yard fire, the likely scenario is one or more small fires, which have developed from hot spots, this is a normal occurrence in the coal yard storage industry. In these cases, the fires are treated by mechanical means (removal and compaction) rather than using water. The probability of a major uncontrolled stockpile fire is negligible, as coal must have an adequate supply of oxygen (only possible on surface layers) and must be heated before combustion. Uncontrolled stockpile fires have never occurred in the site’s history. For these reasons, existing procedures of visual and temperature monitoring of stockpiles ensure that the risk of an uncontrolled fire remains insignificant. This opinion is based on ESB’s practical experience.

5.2.2 Coal Conveying System

Overall Fire Risk = High (Likelihood) x Minor (Consequences) = Medium




In the case of a conveyor system, it is anticipated that the amounts of firewater generated would be significant. However, most fire water run-off in the coal yard area is likely to make its way to the coal yard drainage discharge settling tank thus removing the majority of solids.

5.2.3 Coal Bunker & Mills

Overall Fire Risk = Medium (Likelihood) x Moderate (Consequences) = Medium

Overall Environmental Risk = Low (Likelihood) x Minor (Consequences) = Low



In the case of a station bunker fire, it is likely that firewater will be contained in the mills or bunkers and will have to be suctioned out.

5.2.4 Urea 2 Ammonia Plant Area

Overall Fire Risk = Low (Likelihood) x Moderate (Consequences) = Low


Overall Fire Risk = Low (L) x Low (C) = Low


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The flammable limits for Ammonia are approximately 16-28% v/v; therefore it is only in the extreme circumstance of a catastrophic failure that an explosive atmosphere would be formed. Even in this scenario a large and intense energy source is necessary to ignite ammonia gas.

The U2A Building has a fixed fire fighting system. It is not expected that large volumes of fire fighting run-off would be produced in this area.

5.2.5 Transformer Area

Overall Fire Risk = Medium (Likelihood) x Minor (Consequences) = Low




The main risk associated with transformer fires is the presence of a large amount of oil in the transformer. The transformers contain approx. 97,000m3 of ‘Shell Diala GX Dried’ insulating oil. The oil is not classified as dangerous to the environment and contains no PCBs (polychlorinated biphenyls).

The transformers are protected by a range of controls measures via the safety management system and also by the in situ protection equipment. These include;

- HP Deluge System: The escalation of any potential fire is controlled by a HP Deluge System with automatic and manual actuation. It is anticipated that the deluge system will bring any fire in the compounds under control within a short time frame.

- All transformers are bunded to 110% of the capacity of the transformer

- Reinforced fire and explosion protection walls are installed where appropriate, as per NFPA 850.

- Fire protection exists in the form of electrical protection relays. These will alarm any incipient faults and trip the transformer before such a fault can reach fire potential. These include some of the following:

- Overcurrent Protection

- Differential Protection

- Over-Fluxing Protection

- Impedance Protection

- Bucholz Relay

- High Temperature Protection

5.2.6 Turbine Hall

Overall Fire Risk = Low (Likelihood) x Severe (Consequences) = Medium




There are good fire detection and suppression measures dispersed throughout the turbine hall including break-glass units, fire extinguishers and a dedicated deluge system fitted with foam proportioning system; this will automatically introduce foam into the fire protection system water lines for the applicable zone. It is anticipated that all firewater run-off will flow to the lower levels of the building and will have to be suctioned out.

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5.2.7 FGD Buildings





The FGD Building has a fixed fire fighting system. It is not expected that large volumes of fire fighting run-off would be produced in this area and that in any case would not pose an environmental risk.

5.2.8 Diesel Storage Area


Overall Environmental Risk = Medium (Likelihood) x Moderate (Consequences) = Medium

Overall Fire Risk = Low (L) x Medium (C) = Low

Due to the low overall risk associated with this assessment area the above information indicates that no further firewater containment or reduction measures are required.

A 1,008m3concrete bund to the north of the site contains the 2 No. 300 tonne diesel fuel tanks and the 15m3 green diesel tank for vehicle refuelling

In addition to being bunded the tanks are situated in a hollow area of bank. In the event of a major incident occurring, firewater that has overflowed the bund would most likely be contained in the hollow.

It is expected that the volumes of fire water run-off produced could be managed on site within the secondary containment and adjacent bunds.

5.2.9 HFO Oil Tank Farm

Overall Fire Risk = Low (Likelihood) x Severe (Consequences) = Medium

Overall Environmental Risk = Medium (Likelihood) x Severe (Consequences) = High

Overall Fire Risk = Medium (L) x High (C) = High

A significant release of HFO to the environment could have a significant adverse ecological impact, particularly on the Shannon Estuary, which is a designated SAC and SPA, and could constitute a major accident to the environment (MATTE).

It is difficult to predict the extent and severity of a release to the Shannon Estuary as it will depend on a number of factors– release amount, release location, if firewater is generated, if spill containment materials can be successfully deployed on site, relative density of the HFO and the estuarine waters, position of the tides at the time of release & weather conditions etc.

The consequence of any such release must be balanced against the extremely low likelihood of the event occurring, taking into account the various control measures implemented by ESB Moneypoint to prevent and mitigate such a release.

Due to the high overall risk (refer to Table 5.1) associated with this assessment area, further assessment of firewater containment measures are examined in the Section 6. The potential firewater run-off generated and subsequent retention requirements have been estimated. Full details of the assumptions and calculations are included in Appendix D.

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6 Heavy Fuel Oil (HFO) Fire Scenario

6.1 Scenario

The proposed worst case scenario for the assessment of the fire-fighting water and retention requirements is a fire at one of the HFO bulk tanks, engulfing the full tank roof area.

For information purposes, there are two HFO Tanks with the following dimensions; Diameter 48m, Height 14.6m, therefore, tank roof area is 1,808m2 and lateral area of tank is 2,200m2. The tanks are situated in secondary containment bunds of approx. 30,000m3 each.

Firstly, the likelihoods around HFO tank fires scenarios are reviewed;

6.2 Likelihood of Fire Events involving HFO

HFO has a flashpoint greater than 70°C. However the in-tank temperature of HFO is up to 50°C in one tank at a time only, the other tank remains at ambient temperature. The higher temperature is to help convey the HFO into the power plant when required. This heating is localised to the draw off points at low level. The areas around the tanks are ATEX zoned and strict control measures are in place.

A quantitative likelihood assessment of each potential major accident involving dangerous substances on site, including major fire scenarios, were estimated in the Seveso Risk Assessment Report (IE0310874-23-RP-0001). The frequencies estimated are based on appropriate data from literature, which are referenced as appropriate in the relevant sections of the Seveso Report. A summary of the likelihood of the potential HFO major fire incidents is provided in Table 6.2, along with a description to the frequency category definitions – Table 6.1. As mentioned previously, the reasoning behind the frequency selections are discussed in detail in the Seveso Risk Assessment Report. The figures in brackets are a reference to the Scenario No. in that Seveso Report.

Table 6.1: Frequency Categories for Risk Ranking

Frequency Category

Definition

I Practically impossible (Predicted frequency < 10-6 y-1)

II Remote ( 10-6 y-1 < Predicted frequency < 10-4 y-1)

III Not likely to occur ( 10-4 y-1 < Predicted frequency < 10-2 y-1)

IV Probable ( 10-2 y-1 < Predicted frequency < 1 y-1)

V Frequent (Predicted frequency > 1 y-1)

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Table 6.2: Summary of HFO Fire Scenarios

HFO Fire Scenario Frequency Category

Definition

Spill of HFO in paved area during transfer and subsequent unbunded pool fire or jet fire (1.1.2.1 & 1.1.2.2)

I Practically impossible

Spill of HFO in bund during transfer and subsequent jet fire or bunded pool fire (1.1.3.1, 1.1.3.2)


Spill of HFO due to tank leak or over-filling and subsequent bunded Pool Fire (1.2.1.1)

II Remote

Spill of HFO due to jetting or bund failure and subsequent unbunded Pool Fire (1.2.2.1)


Catastrophic failure of a HFO Tank and subsequent unbunded Pool Fire (1.2.3.1)


As can be seen from the previous table, the likelihood of fires involving HFO is determined as remote to practically impossible. A literature review of historical bulk storage tank farm fires revealed that the majority of these fires involved very volatile fuels with low flashpoints and capable of forming large vapour clouds e.g. Gasoline at Buncefield.

6.3 Emergency Response Procedure

As per the ESB Emergency Procedure in the Event of Fire SMS 10.2.2;

An oil tank fire will usually be the result of an uncontrolled bund fire, a lightning strike or welding/cutting carried out on the tank in an unsafe manner. This may result in the tank roof blowing off or collapsing, leaving the surface of the oil within the tank burning freely. Such fires involving heavy fuel oil are rare because HFO is not easily ignited. Once burning however, a large HFO tank fire is not easily extinguished.

An oil tank fire presents three special hazards:

1. Structural failure of the tank shell due to its exposure to heat. This can be reduced by spraying water on to the tank sides above the oil level.

2. Slop-over of burning oil into the bund. This is caused by frothing of water deposited by fire-fighting on the oil surface. Slop-overs are usually small in extent but can occur at any time during fire-fighting. They can be controlled by directing foam on to the spill area.

3. Boil-over of the whole tank contents. This is caused by the gradual heating of the oil below the burning surface. The "heat wave" progresses down into the tank of oil at about 400 mm per hour. When this zone (at 250ºC) meets the water layer at the tank bottom, the water is converted explosively into steam which expands thereby propelling burning oil into the air and over a wide area. In Moneypoint the water is drained from the bottom of the oil tanks annually, therefore there could be a substantial quantity of water at the bottom of each tank at any given time.

Boil-over cannot be prevented (except by extinguishing the fire), but warning signs of its imminent occurrence can be easily spotted. The easiest way is to periodically spray the tank side with water. The water will evaporate from the heated area, leaving a clear indication of how far the heat wave has travelled downwards. When this reaches 1.5 metres from the estimated water level, the area within 250 metres should be cleared of all personnel.

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6.3.1 Fire Fighting Approach

On discovery of a fire, the internal emergency plan will be activated. In terms of dealing with a tank farm fire, the emergency response procedure lists the following actions to be taken;

The assistance of the fire brigade should be obtained when tackling an oil tank fire.

- Dispatch at least four persons to the fire location with instructions to make down at least three foam units. Where the tank roof has been blown off, these should be directed on to the burning oil within. Ensure that foam stocks are maintained.

- Detail one person to make ready an AWG jet/spray branch pipe. Should flame impingement on tank walls become significant, water should be directed on to the exposed external surface to provide cooling and prevent tank wall failure.

- Where other oil tanks, buildings or structures are exposed to radiant heat, direct spray branch pipes at them to provide cooling. Should this not be done, structural failure or further ignition could occur.

Where a significant delay is expected in extinguishing the fire, monitor the downward progression of the heat wave into the oil, evacuate fire-fighting personnel when this reached within 1.5 metres of the water layer. The Senior Fire Officer must be briefed on this hazard.

6.3.2 Fire Fighting Resources – HFO Tank Farm Fire Scenario

- Fire Fighting Water Reservoir contains 36,300m3 (8 million gallons)

- Fire Hydrants No.12, 13, 17, 18, 19, 20, & 22 are located around the tank farm bunds

- Foam Units and associated inductors (200 litre foam inductors with 200 litre foam branch pipes are provided at the North and South boundaries of the oil farm)

- Spray nozzles for tank cooling available for connection to local hydrants

- Dry Powder and CO2 Fire Extinguishers are provided for dealing with incipient fires in the pump house

6.4 Extinguishing Water Requirements

BS EN 13565-2:2009 Fixed firefighting systems. Foam systems. Design, construction and maintenance specifies a 90 minute fire fighting operating time when using monitors. If the fire is not extinguished or no progress is being made after this time, then the continued application of fire-fighting water and foam is to be assessed, and consideration should be given to a controlled burn approach and redirecting fire fighting operations to cooling and protecting adjacent installations from radiant heat.

This option is backed up by the excessive volumes of fire-fighting water required to fight a large tank fire, as estimated in the detailed calculations provided in Appendix D.

To summarise, some of these volumes are provided below to express the magnitude of a fire-fighting operation involving large tank farms.

- First of all sufficient extinguishing media, which will be predominately firewater, has to made available to fight the fire and ensure that it does not spread. The second issue is that if the fire cannot be put out successfully, and this does happen with fuel storage, the energy content in the stored fuel can simply be so great that the continued application of firewater would lead to unsustainable volumes of firewater run-off. If this fire was to be fought continuously with water until such time as it burned out, then 413,462m3 would be required. This is an enormous quantity of water, which demonstrates the impracticability of continuously fighting a fuel tank fire, which cannot be extinguished within a reasonable period.

- In the 90 minute scenario, calculations based on the LORURL method (Appendix D) estimate that 2,979m3 of extinguishing water would be required. The calculations also state that the

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amount of foam required in this scenario would be in the region of 80m3. These figures represent the best case of an efficient fire fighting scenario, without taking into account the failure of the majority of the fire fighting extinguishing medium to reach the fire. If the fire is not controlled or extinguished within this time period, the potential for huge volumes of firewater run-off generation becomes a reality.

- There is also the possibility of on-site escalation due to the thermal radiation impact of the fire. Cooling water will need to be applied to the tank on fire, in addition to the other HFO tank and also possibly to other tanks in the vicinity, including the Diesel and Propane tanks and possibly the back of the FGD building. Cooling water to the fire engulfed tank and adjacent HFO tank alone amounts to 1,002m3 (479m3 + 523m3) in the 90 minute scenario. It is predicted that the majority of the cooling water associated with cooling other areas will be uncontaminated.

- If a HFO tank fire is fought for 90 minutes, it is calculated that 3,981m3 (2,979m3 +1,002m3) of contaminated firewater could be generated. Given the combined capacity of the 2 No. HFO bunds (60,553m3) it is concluded that this volume could be retained in the bunds.

- In the event of a catastrophic failure of the tank on fire, this volume increases to 38,135m3 for the 90 minute scenario which can still be accommodated between the two bunds, although in reality if the tank fails, the fire fighting time period will most likely be extended greatly and the potential for larger amounts of firewater to be generated is increased.

In summary, if the tank fire is not under control in this 90 minute time frame, then a fully developed fire will progress. There will be a very low likelihood of extinguishing a fully developed fuel tank fire with the equipment in place. Significant quantities of fire-fighting water and foam concentrate would be put on the fire with little in the way of progress made in efforts to extinguish it. Enormous and unreasonable amounts of fire-fighting water and foam concentrate would be generated and which is beyond the design of a firewater containment pond. In this regard, a controlled burn strategy is a possibility for a fully developed HFO tank fire.

6.5 Controlled Burn Strategy Discussion

As previously stated, if the fire cannot be put out successfully within a specific time period, the energy content in the stored fuel would be simply be so great that the continued application of firewater would lead to unsustainable volumes of firewater run-off being generated. The potential cost of environmental clean-up could far exceed the potential additional site damage associated with a controlled burn approach – consideration should be given to a cost-benefit analysis of this strategy.

Appendix C provides a summary of internationally recognised best practice on fire fighting large atmospheric fuel storage tank fires and the controlled burn strategy approach.

The following table (6.3) describes the situations where a controlled burn might or not might be appropriate and can be used to make a more informed decision on the action to take.

Table 6.3: PPG28 Controlled Burn Guide

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Controlled burn is inappropriate Controlled burn might be appropriate

A controlled burn will increase the risk to people People are not at risk, or a controlled burn will reduce the risk to people

There is a high success forecast for extinguishing the fire with minimal impact on human health and/or the environment

There is a low success forecast of extinguishing the fire

There is a high probability of the fire spreading extensively or to high hazard areas (*)

Fighting the fire with other techniques would pose a significant risk to fire fighters (*)

Important buildings are involved Property is beyond salvage

Fire conditions, meteorological conditions and/or local topography are inappropriate e.g. plume grounding in a populated area

Fire conditions, meteorological conditions and the local topography are appropriate for minimising the air quality impacts

Firewater run-off will drain to an area of low environmental sensitivity or firewater is not polluting

Firewater run-off would damage an area of high environmental sensitivity

Firewater can be contained Firewater run-off would affect potable supply intakes and other abstractions

Firewater run-off could impair the operation of a Sewage Treatment Works

*In such a situation it may be possible to employ a controlled burn once the fire is under control, or alternatively employ other methods to contain the firewater.

6.6 Recommendations

A well-planned and organised emergency response procedure is likely to significantly reduce the potential duration and extent of fire scenarios, and hence reduce firewater volumes requiring containment and management.

In this regard;

- An emergency response plan dealing with tank farm fires needs to be produced that specifically deals with all potential fire fighting scenarios, which could occur in and around the tank farm. The local fire brigade should be consulted in terms of their capabilities in such scenarios and what resources they have and can also potentially call upon from external agencies. This may lead to the requirement for ESB Moneypoint, to provide additional equipment on site than is currently available, if the Fire Brigade advises. The Incident Commander (the attending Fire Brigade senior officer) will make the ultimate decision on the fire-fighting approach to be taken during an incident.

- The option to consider controlled burn strategy needs to be discussed in detail and the decision to employ a controlled burn strategy as an option in the emergency response plan, whenever practicable, must be conveyed to all interested parties: Site Operator, Site Insurers, Local Council, Environmental Protection Agency (EPA), Health and Safety Authority (HSA) and also pre-planning and media implications.

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Appendix A Risk Assessment Methodology

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1 Risk Assessment Methodology

The methodology for this assessment has been developed by PM Group with reference to the Environmental Protection Agency Draft Guidance Note to Industry on the Requirements for Fire-Water Retention Facilities, 1995. This guidance note requires that a firewater risk assessment be carried out followed by a firewater retention requirement calculation. The following assessment method has formed the basis of numerous submissions by PM Group clients to the EPA with respect to firewater retention.

Prior to commencing the assessment the site is logically divided into separate areas on the basis of significant distance and/or fire containment properties. Each of these areas is then assessed for the following:

- Fire Risk which includes the likelihood of a fire occurring and the likely consequences of such a fire.

- Environmental Risk which includes the likelihood of contaminated firewater runoff arising and reaching an environmental receptor and the likely consequences of such an event.

1.1 Fire Risk

The elements of fire risk are assessed, i.e. the likelihood of the event occurring (in this case the likelihood of a fire occurring in the assessment area) and the consequence of the fire.

1.1.1 Likelihood of Fire Occurring

Three conditions are essential for a fire to occur: a fuel source, heat and oxygen. Normally the heat required is initially supplied by an external source, i.e. an ignition source, and then provided by the combustion process. If one of the essential conditions is missing then fire does not occur and, if one of these is removed, then fire is extinguished. Controlling each of these conditions reduces the likelihood of a fire occurring and each condition must be assessed in order to assess the likelihood of a fire occurring.

Therefore the likelihood of a fire occurring depends on a variety of factors including the following:

a) Nature of Materials

Nature of the material which takes into account the presence of fuel sources in the assessment area. Fuel sources include:

- Flammables

- Explosives

- Oxidising Materials

- Other Physio-Chemical Properties

- Combustibles

b) Ignition/Heat Sources

The presence of heat/ignition sources in the assessment area, a contributing factor to which may be system controls. Factors which reduce the likelihood of an ignition source being present include:

- Ex-rating/hazardous area classification

- Permit to work system

- Inerting systems

- Earthing of equipment

- No smoking policy

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- Procedural controls

- Staff training

c) Oxygen

Oxygen is generally present under most fuel storage, handling and use conditions. Some processes use gas inerting, e.g. nitrogen, to eliminate oxygen. In most cases the presence of oxygen is assumed.

Once the facility-specific information regarding factors which will affect the likelihood of a fire occurring has been assessed Table 2.1 can be used to determine that likelihood in terms of High, Medium and Low.

Table A.1: Likelihood of Fire Occurring

Likelihood Factor

High Flammable, oxidising or explosive materials present

and

Potential for ignition source to be present

Medium Flammable, oxidising or explosive materials present

and

Low potential for ignition/heat source to be present

or

Combustible materials only present

and

Potential for ignition/heat source to be present

Low Combustible materials only present

and

Low potential for ignition/heat source to be present

1.1.2 Consequence of a Fire

The potential consequences of a fire can range from being relatively local to being significant. The extent and consequence of a fire will be influenced by the following variables:

- Quantity of flammable/oxidising materials in assessment area

- Fire detection and protection measures

- Emergency response

- Fire containment

- Quantity and nature of firewater runoff generated

a) Quantity of flammable/oxidising materials in assessment area

The quantity of flammable/oxidising materials in the assessment area will be a contributing factor to determining the physical extent of the fire. The nature, thermal radiation levels generated and ability of the fire to spread will all be at least partially determined by the materials present in the assessment area.

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b) Fire detection and protection measures

The purpose of fire detection systems is to identify fire as quickly as possible, thereby maximising effectiveness of fire fighting, and ensuring adequate time for evacuation. Elements of a fire detection/alarm system may include:

- Smoke detectors

- Heat detectors

- Manual call points

- Breakable Glass Units

Fire protection provides immediate fire abatement for on-site facilities. The more efficient the fire detection and protection features are, the less severe the consequences are likely to be. Fire protection facilities may include;

- Sprinkler system, consisting of reservoir, pumps and distribution network including deluge systems

- Fire extinguishers

- Hydrants

- Other extinguishing media (foams, etc.)

c) Emergency response

Efficiency of emergency response procedure can reduce consequences. Crisis management, emergency response training and awareness are preparation tools which improve emergency response.

d) Fire containment

Fire containment limits the spread of the fire, thereby reducing consequences. Fire containment is achieved by;

- Fire rated walls and structures prevent the spread of fire. These are generally rated to resist fire for a specific time period i.e. 1 & 2 hours.

- Distance between areas. A distance of 15 m should be retained between areas of flammable material storage. This will prevent the spread of fire.

e) Quantity and nature of firewater runoff generated

The consequences due to firewater runoff (predominantly environmental) will be proportional to quantity of runoff generated. If large quantities of flammable liquid are present, there is potential for the firewater to spread the flammable material and escalate the fire.

Once the facility-specific information regarding factors, which will affect the consequence of a fire has been assessed, Table 2.2 can be used to determine that likelihood in terms of Severe, Moderate and Minor.

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Table A.2: Consequences of a Fire

Consequences Factor

Severe Large quantities of firewater runoff generated

Poor fire detection/protection/emergency response system

Large storage tank/container damage – release of hazardous materials

Poor fire containment

Moderate Some quantities of firewater runoff generated

Some fire detection/protection/emergency response system

Some storage tank/container damage – release of hazardous materials

Some fire containment

Minor Limited quantities of firewater runoff generated

Good fire detection/protection/emergency response system

Limited storage tank/container damage – release of hazardous materials

Good fire containment

1.1.3 Overall Fire Risk

The agreed likelihood and consequence categories determined for the fire hazard are combined, using the following matrix, to qualitatively predict the fire risk associated with each assessment area.

Table A.3: Overall Fire Risk

Consequences

Severe Moderate Minor

Likelihood High High High Medium

Medium High Medium Low

Low Medium Low Low

1.2 Environmental Risk

The environmental risk is a combination of the likelihood of the event occurring (in this case the likelihood of contaminated firewater being discharged to the environment) and the consequence of the event on the environment.

1.2.1 Likelihood of an Environmental Release

The two principal factors affecting the likelihood of contaminated firewater being released to the surrounding environment are:

- The level of containment provided for materials in the assessment area

- The pathways from the assessment area to environmental receptors

The level of containment provided for spillages and/or releases of a material in the event of a fire situation will affect the extent of contamination of the firewater and the migration potential of any

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contaminated firewater. A number of measures can contribute to a high level of containment on site including:

- Bunding of tanks and other material storage areas (e.g. drum stores) in accordance with recommended guidelines

- The use of spill containment equipment (e.g. spill pallets) for the storage of smaller quantities of materials

- Proper maintenance of all tanks, bunds and other material containing structures

- Procedural controls, e.g. emergency response procedures to contain and mitigate spillages and/or accidental releases of a material

- Maintaining appropriate equipment (e.g. adsorbent materials, booms) on site to contain any spillages and/or accidental releases of a material

The pathway is defined as the physical route by which released materials (i.e. contaminated firewater) may travel from the source to an environmental receptor, such as a receiving waterway. It is necessary to take into account all of the pathways by which the material may reach the environmental receptor. Potential pathways for contaminated firewater include:

- All water drainage systems on site including sewers, drains and culverts

- Any damage to the site drainage systems, which provide other potential pathways (e.g. cracked pipework which allows firewater to drain to underlying soil and groundwater)

- The surface area of the site if the volume of firewater exceeds the capacity of the site drains

- Areas of the site that do not have a hardsurface or relatively impermeable cover (e.g. concrete), which would allow firewater to drain to the underlying soil and groundwater

Factors which limit the potential pathways for contaminated firewater include:

- Control mechanisms incorporated into the site drainage system (e.g. shut-off valves), which can stop or divert the flow of firewater

- Impermeable surfaces on site to prevent firewater draining to the underlying ground and groundwater

Once the facility-specific information regarding factors, which will affect the likelihood of firewater reaching an environmental receptor has been assessed, Table 2.4 can be used to determine that likelihood in terms of High, Medium and Low.

Table A.4: Likelihood of Contaminated Firewater Reaching an Environmental Receptor

Likelihood Factor

High No containment provided for spillages and/or accidental releases of materials

and

Numerous pathways to environmental receptors

Medium No containment provided for spillages and/or accidental releases of materials

and

Some pathways to environmental receptors

Low Containment provided for spillages and/or accidental releases of materials

and

Limited pathways to environmental receptors

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1.2.2 Consequences

The factors influencing the consequences of firewater runoff to the environment are:

- The nature and properties of materials on site

- The quantity of materials on site

- The sensitivity of environmental receptors in the surrounding environment

a) Nature and Properties of Materials

The nature and properties of the material on site will to a large extent determine the consequences of a release of the material to the environment. If the material does not possess any hazardous properties, it is unlikely to have any significant adverse impacts if released to the environment.

Toxicological (eco) and associated classifications of a material can be used to assess the consequences of a release of the material to the environment. Details of these classifications are provided in Appendix A.

A number of physical, chemical and biochemical properties of the material influence the likely environmental fate of the material once it is released to the environment including:

- Water Solubility – Water soluble chemicals will more rapidly disperse in the environment and tend to be more biodegradable

- Octanol / Water Partition co-efficient - This indicates the relative solubility of the material in fatty materials. Fat soluble materials are more likely to bioaccumulate in fatty tissues of fauna and are generally less biodegradable.

- Bioaccumulation Factor – This also indicates the bioaccumulation potential of the material

- Biodegradability –The more biodegradable the material the more rapidly it will degrade in the environment and the less likely it is to have a long term impact

- Volatility – indicated by Vapour Pressure and Latent Heat of Vaporisation –Volatile materials tend to evaporate and disperse more rapidly

- Oxygen Demand of material (BOD) – Materials with high oxygen demand are likely to deplete the dissolved oxygen levels in an aquatic environment and thus have an adverse impact

- The potential visual impact of a material (e.g. dyes, detergents, oil) on a receiving water body will be influenced by a number of physical and chemical properties, such as colour, solubility, dispersal characteristics.

b) Quantity of Materials on Site

The other key factor influencing the consequences of a release of a material to the environment is the quantity of material released. The larger the quantity of material released as contaminated firewater, the greater the consequences on the environment will be. Additionally, there may be threshold quantities below which the escape to a watercourse may not have a significant environmental impact.

c) Sensitivity of Environmental Receptors

The sensitivity of the receiving environment / environmental receptors to which the contaminated firewater is discharged will also influence the consequences of the discharge. Therefore it is necessary to identify the receptors and assess the sensitivity of receptors in the surrounding environment.

The presence and nature of the environmental receptor can be thought of as the fixed point in any hazard or risk assessment. Although the site operator is able to modify sources and, to some extent perhaps, on-site pathways, altering the receptor is more difficult. Short of diverting rivers or moving abstraction points, there is usually little that can be done to change the receptors.

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The following criteria can be used to assess the sensitivity of environmental receptors in the surrounding environment.

- Characteristics of aquifers in the area:

- The vulnerability of the aquifer – Extreme (E), High (H), Moderate (M), Low (L) - based on the Geological Survey of Ireland (GSI) classification system

- The importance of the aquifer – Regionally Important (R), Locally Important (L), Poor (P)

- Aquifers located within Source Protection Zones

- Rivers or other watercourses with a high fisheries potential including rivers designated as salmonid waters and as shellfish waters

- Rivers or other watercourses from which water is abstracted for drinking purposes

- Waters designated as bathing waters

- Areas covered by a scientific or conservation designation such as a Special Area of Conservation (SAC), a Natural Heritage Area (NHA), a Special Protection Area (SPA) or other conservation designation

- Areas covered by special amenity orders or other environmental or recreational designations in the local authority development plan

Once the facility-specific information regarding factors which will affect the consequence of firewater reaching an environmental receptor has been assessed Table 2.5 can be used to determine that likelihood in terms of Severe, Moderate and Minor.

Table A.5: Consequences of Contaminated Firewater Discharged to the Environment

Consequences Factor

Severe Long term adverse environmental effects

Large quantity of hazardous materials released

Materials reach sensitive environmental receptor(s)

Moderate Materials have medium term impact

Medium quantity of hazardous materials released

Materials have limited impact on environmental receptor(s)

Minor Materials are rapidly degraded and dispersed in the environment

Small quantity of hazardous materials released

Materials do not reach any sensitive environmental receptors

1.2.3 Overall Environmental Risk

The agreed likelihood and consequence categories determined for the environmental hazard are combined, using the following matrix, to qualitatively predict the environmental risk associated with each assessment area.

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Table A.6: Overall Environmental Risk

Consequences

Severe Moderate Minor

Likelihood High High High Medium


Low Medium Low Low

1.3 Firewater Run-off Risk

The agreed fire and environmental risk are then used to determine the overall site risk in terms of the requirement for firewater runoff risk assessment.

Table A.7: Risk Associated with Firewater Run-off

Fire Risk

High Medium Low

Environmental Risk

High High High Medium


Low Medium Low Low

Notes:

1. High - Firewater runoff containment will be required if further risk reduction measures are not implemented

2. Medium - Firewater runoff containment may not be required if further risk reduction measures are implemented

3. Low - Firewater runoff containment not required.

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Appendix B Firewater Retention Calculation Methodologies

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1 Calculation Methodologies for the Required Fire Water Retention Capacity

1.1 General

In 1995, the Irish Environmental Protection Agency (EPA) issued a Draft Guidance Note to Industry on the Requirements for Fire Water Retention Facilities3. However, this document does not provide detailed guidance on fire water retention design, including duration of fire event, although it does reference a number of other guides including the UK Construction Industry Research Institute (CIRIA) Report 164 on ‘Design of Containment Systems for Prevention of Water Pollution from Industrial Incidents’. This in turn references in Section 9.6 the German Federation of Chemical Industry (VCI) Guide of 1988’ and the European Insurance Commission (CEA) ‘Guide of 1993 for Assessment of Fire water Run-Off Volumes’. These guides were produced as a consequence of the 1986 Sandoz Agrochemical Warehouse fire in Basle, which due to contaminated fire water polluted the length of the Rhine downstream of Basle and led in time to an update to the EU’s legislation on Control of Major Accident Hazards, i.e. the ‘Seveso’ Directive.

Given the impact of this industrial accident on the Rhine, and the importance of the Chemical sector in Germany, it was not surprising that a committee was formed there to draft a formal building code for fire water retention. This committee comprised government bodies, industry representatives, such as from the VCI, fire services and insurance representatives, who in 1991 produced their LÖRÜRL building code on fire water retention. The LÖRÜRL code then formed the basic principles for the draft guideline produced by the CEA in 1993. However the CEA guide has not been issued since in final form by the CEA.

As regards the situation in early 2016 with respect to firewater retention guidance at a European and Irish level, there are no European guidelines available, either issued through the EU Commission’s Integrated Pollution Prevention and Control Bureau in Seville or by a recognised industry representative association, such as from the insurance sector. In Ireland, the draft 1995 EPA Guidance Note is still in draft form, although the EPA has commenced with a project to prepare a new guidance document in this sector. However, it is not expected that this will be finalised until late 2016 at the earliest.

On an International level the International Organization for Standardisation (ISO) has published:

ISO 26367-1:2011: “Guidelines for assessing the adverse environmental impact of fire effluents – Part 1: General”

ISO/TR 26368:2012 “Environmental damage limitation from fire-fighting water run-off” (Technical Report)

Note under the TBT (Technical Barrier to Trade) Agreement, the WTO (World Trade Organization) recommends its members to use International Standards rather than regional or national ones whenever possible.4

“The Agreement encourages Members to use existing international standards for their national regulations, or for parts of them, unless “their use would be ineffective or inappropriate” to fulfil a given policy objective. This may be the case, for example, “because of fundamental climatic and geographical factors or fundamental technological problems”

However, it is equally important to realise that while regulations ‘rule’, in that they are requirements which have to be complied with, standards ‘support’ in that not only is their use voluntary, but a standard is a

“Document, established by consensus and approved by a recognized body, that provides, for common and repeated use, rules, guidelines or characteristics for activities or their results, aimed at the achievement of the optimum degree of order in a given context”.

5

3 https://www.epa.ie/pubs/advice/licensee/Draft%20firewater%20retention.pdf 4 https://www.wto.org/english/tratop_e/tbt_e/tbt_info_e.htm

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In many respect the knowledge basis and published guidance in this area remains in Germany, indeed the ISO/TR 26368:2012 technical report above references extensively the Sandoz fire and the deterministic approach, i.e. sizing of retention volumes by ‘magic numbers’, developed based on feedback from such specific accidents. The LÖRÜRL building code is still a current regulation in Germany. Indeed, while it is very much tried and trusted, its limitation is that it is specific to installations for storage of water hazardous materials, in particular those which would be defined as ‘chemical warehousing’. While it has been applied in an analogous fashion to production areas, which are associated with the presence of water hazardous materials, this is not exactly satisfactory. As such then, additional more recent ‘deterministic’ guidance for calculating firewater retention volumes has been produced in Germany, such as by the Province of Hessen in 2011 and the German Insurance Industry Association’s (VdS) comprehensive 2013 guidance VdS 25576.

At the Institution of Chemical Engineers Hazards 24 Conference in May 2014, Pat Swords of PM Group presented a paper on “Fire Water Retention – Latest Guidance for Design”, this is provided as Attachment 27. This discusses in some quite considerable detail the LÖRÜRL building code, the guidance from Hessen and the VdS guidance. Furthermore, in December 2014 the German Chemical Industry Association (VCI), produced their guidance on fire water retention, while in August 2015, the Swiss authorities also produced a fire water retention guidance document in August 20158, the latter being in many respects a refinement of previous German codes and guidance. Indeed, in this regard, the authorities in Luxembourg, which is also German speaking, produced in May 2003 a guidance document, which was based on the previous German codes and guidance9.

1.2 LÖRÜRL Methodology for the Calculation of Retention Volume

The German construction ministers’ conference (Bauministerkonferenz) has a formal designation as a conference of competent ministers and senators of the provinces (Länder) for city construction, building and housing matters and goes under the designation ARGEBAU. This published in 1992 the LÖRÜRL code, which was then adopted as a building code by the sixteen provinces (Länder) in Germany10. The principles of the LÖRÜRL building code is that priority is given to measures to reduce the potential for a fire and its consequences, such as restricting the size of a fire section and applying early fire detection and fire-fighting. This then reduces both the overall amount of firewater required to fight a fire and the resulting amount of fire water retention required. The guidelines take into account:

- The type of fire brigade available (public or works or both),

- The type of fire protection technical infrastructure (fire alarm and extinguishing systems),

- The surface area of storage sections (storage heights, densities and quantities of stored goods) and;

- The type of storage (in the open air, in buildings, in containers, in moveable and fixed tanks).

As the actual building codes in the various provinces, such as from the Nordrhein-Westfalen Ministry for Construction and Housing, then clarifies:

5 Formal definition from the International Organization for Standardization (ISO) and its sister organization, the International Electrotechnical Commission (IEC):

http://www.iso.org/sites/ConsumersStandards/1_standards.html 6 http://vds.de/fileadmin/vds_publikationen/vds_2557_web.pdf 7 Also available as a download from: http://www.pmgroup-global.com/pmgroup/media/News-Attachments/Fire-Water-Retention-Hazards-24.pdf 8 http://www.umwelt.tg.ch/documents/Leitfaden_Loeschwasser_Rueckhalt.pdf 9 http://www.environnement.public.lu/guichet_virtuel/etabl_classes/index_formulaires/EXP-136-LW.pdf 10 https://www.is-argebau.de/verzeichnis.aspx?id=991&o=991

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- This guideline legislates exclusively with the calculation of fire water retention facilities for the storage of materials hazardous to waters.

- A fire water retention facility is not necessary, if the materials hazardous to waters are stored below the thresholds according to section 2.1 of the regulations.

Section 2.1 of the LÖRÜRL building code then clarifies:

2.1 This guideline serves for structural facilities (see section 3.1) in which or on which material hazardous to waters;

- of the water hazard class WGK 1 with more than 100 t in each storage section (see section 3.9) or

- of the water hazard class WGK 2 with more than 10 t in each storage section or

- of the water hazard class WGK 3 with more than 1 t in each storage section

- is being stored (see section 3.4).

- If material hazardous to waters of different water hazard class is being stored together, then for the determination of whether the facility lies under the scope;

- 1t of material of WGK 3 is equivalent to 10 t of material of WGK 2 and

- 1t of material of WGK 2 is equivalent to 10 t of WGK 1 material.

- The calculated quantities of water hazard class are to be added.

In Section 3.1 ‘Structural Facilities’ are defined as:

“Structural facilities are connected with the ground and composed of structural materials and structural components. A connection with the ground arises also if the facility through its own weight rests on the ground or if the facility through its usage goals is thereby determined primarily to be used in a fixed location. Storage areas and places in the open air also serve as structural facilities.”

In Section 3.4 ‘Storage’ is defined as:

“Storage is the holding of material for further use, dispatch or disposal”.

In Section 3.9 a ‘Storage Section’ is defined as “part of a store, which;

- in buildings is separated from other rooms through walls and roofs

- in the open is separated through corresponding distances or through walls”.

An unofficial translation of relevant sections of the LÖRÜRL building code is provided in Appendix A11;

- Section 5 addresses: Storage of material in packing, in movable containers, in moveable vessels with a volume of up to 3,000 l and as loose goods in buildings.

- Section 6 addresses: Storage of material in packing, in movable containers, in movable vessels with a volume of up to 3,000 l and as loose goods in the open air.

- Section 7: addresses: Storage of material in fixed vessels as well as movable vessels with a volume of more than 3,000 l.

These details are addressed further in Appendix A. However, clearly what is of most interest with respect to a major fire in a large atmospheric fuel storage tank is the Section 7 of the LÖRÜRL building code, which is valid for this purpose, as it includes within its calculation methodology bund free areas of over 5,000 m2. This calculation method addresses the:

- Volume of flammable liquid stored in the vessel

11 As translated by Pat Swords of PM Group

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- Volume of water in the extinguishing medium (water and associated foam)

- Volume of cooling water applied (typically to the side wall of adjacent tanks)

- Volume of extinguishing foam

- Volume of flammable liquid in the tank, which can be successfully drawn off to other bunds or vessels

- Volume of extinguishing water, which can be drawn off to other fire water retention systems.

It is based on a rule that the fire-fighting time is to be calculated as 30 minutes, plus with the provision of proof in individual cases a burn out rate can be considered.

1.3 Irish EPA Methodology for the Calculation of Retention Volume

Similar to the LÖRÜRL calculation the EPA calculation method is based on a risk assessment which determines the main areas on site where a fire may occur and be contained (i.e. Chemical Storage Warehouse). The calculation is then based on the following:

1. Fire-water likely to be used for the site

2. Largest volume of contaminated water to be retained in any of the main areas

3. Rainfall Allowance

The larger of 1 or 2 is then added to 3 to determine the overall required fire-water retention capacity for the site. For the “Rainfall Allowance” the maximum volume of rainfall to be included is based on 50mm daily rainfall or a 1 in 20 year 24-hour rainfall event, whichever is greater.

1.4 VCI Guidance of December 2014

1.4.1 General

Chapter 8 of this guidance is entitled a quantitative assessment of the retention volume. As this explains:

- The quantitative assessment is always to be constituted as a component of the fire protection strategy.

- It must be distinguished between generalised calculation methods and calculation methods based on individual scenarios. The applicability of the respective method is dependent in the first case on the fire load and the fire protection infrastructure.

- The applicability of the various models is dependent on the respective framework conditions of the project being evaluated. The fundamental assumptions are to be plausibly represented.

- The volume, which is to be retained, is pieced together additively from the volume of material to be retained and the arising volume of extinguishing water to be retained.

1.4.2 Evaluation related to Legal Norms

The prerequisite for evaluation according to this method is the exclusion of further possibilities for channel flow of water (e.g. conveying water over long distances, etc.) or their consideration corresponding to the local factual conditions relevant to the evaluation. Furthermore, these approaches can only be utilised, if according to the fire protection concept no larger quantity of extinguishing water is necessary.

In so far as a raised extinguishing water requirement is to be allowed for based on a higher object protection, the volume to be retained must be measured based on a scenario based approach. An evaporation rate of 50% can be applied.

Note: As Attachment 2 clarifies, based on research by the fire research centre of Karlsruhe, it can be assumed that half of the applied extinguishing water evaporates.

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Musterindustriebaurichtlinie (MindBauRl)12

This is an industry building construction code for fire protection produced by the same ARGEBAU referenced previously. Section 5.1 of this code relates to the general requirements for extinguishing water. As the VCI guidance clarifies:

- The surface area dependent following assessment is possible:

- Fire section area A ≤ 2,500 m2:

- The extinguishing water supply is a minimum of 96 m3/h for an assumed extinguishing duration

of 2 hours.

- From this results a required firewater retention volume of 192 m3 x 0.5 = 96 m

3.

- Fire section area A > 4,000 m2:

- The extinguishing water supply is a minimum of 192 m3/h for an assumed extinguishing

duration of 2 hours.

- From this results a required firewater retention volume of 384 m3 x 0.5 = 192 m

3.

- Values in between can be interpolated.

- If a self-activating extinguishing system is present:

- The extinguishing water supply is a minimum of 96 m3/h for an assumed extinguishing duration

of 1 hour.

From this results a required firewater retention volume of 96 m3 x 0.5 + volumes in dependency

of the layout of the extinguishing system

DVGW Arbeitsblatt W 405

The Deutscher Verein des Gas- und Wasserfaches e.V. (DVGW) is the German subject matter association for gas and water, their Arbeitsblätter (work sheets) are recognised in Germany as general technical rules for the design of infrastructure for the provision of water, gas, etc. W 40513 in particular specifies the provision of the necessary firewater by means of the public potable water supply.

- According to Table 1 of the work sheet an extinguishing period of 2 hours is to be applied.

- The fire water supply for the fire protection amounts to for example 96 m3/h to 192 m

3/h for an

assumed extinguishing period of 2 hours.

- From that results a necessary fire extinguishing retention volume of a maximum of 384 m3 x 0.5

= 192 m3.

- It is to be observed, that with a higher fire risk greater quantities of extinguishing water can be determined (object protection). These are correspondingly to be considered.

Generalised Calculation Approach

This section of the VCI guidance refers to the direct calculation method developed by the German province (Land) of Hessen (Hessenweit abgestimmte Empfehlung, 2011)14 for industrial sites based on empirical data or assessment of the fire load. This is explained in some considerable detail in Attachment 2. As the VCI guideline clarifies, that this is a strongly simplified calculation methodology. As such then if large fire loads or special infrastructure is present, then the following detailed assessment methodology is recommended.

12 http://www.bauordnungen.de/MindBauRL.pdf 13 http://www.feuerwehr-sachsen-anhalt.de/uploads/media/Arbeitsblatt_W405_Bereitstellung_von_Loeschwasser.pdf 14 https://umweltministerium.hessen.de//umwelt-natur/wasser/gewaesserschutz/rueckhalt-von-verunreinigtem-loeschwasser

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Scenario Based Assessment

- For the evaluation of the necessary fire protection measures for a building construct a reality based fire scenario is to be identified and laid down. From the background of the defined achievable protection goals there arises a determined scale of fire-fighting measures. The evaluated scale of the fire-fighting measures requires a determined firewater quantity, which according to the evaluated measures is to be retained.

- For the assessment of the arising fire water quantity on the basis of a scenario based approach, the following basis parameters are to be considered, which influence the quantity of the extinguishing water;

- Type of fire brigade (works fire brigade, public fire brigade)

- Fire section / plant size

- Maximum volume of material released

- Extinguishing period

- Maximum surface area for fire spread / fire compartment surface area (burning surface)

- Water application being applied or can be applied by the fire brigade

- Water application through therein not contained extinguishing systems

- Evaporation rate of 50%

- It is fundamentally to be presumed, that with the presence of a works fire brigade in connection with an early detection system, or an automatic extinguishing system, a fast initiation of the extinguishing measures is guaranteed. As such then a reduced fire spread (area) can be applied. On the basis of this assumption a shorter extinguishing period can be assumed.

- In the case of a public fire brigade it must as a rule be presumed that a later initiation of extinguishing measures occurs. By this means arises a larger fire spread (area). On the basis of this assumption is a longer extinguishing period to be assumed.

1.5 ISO Guidance

It is clear from both ISO guidance documents listed previously in Section 6.1 that these apply to major industrial fires, as can be deduced from the examples of significant fire incidents that they refer to in their annexes. In many respects this would reflect international practice in that fire water retention regulations in many countries would only be applied to larger industrial facilities, while the experience in some Member States, such as Ireland and Germany in its LÖRÜRL code is that such requirements can also apply to some smaller and medium sized industrial facilities.

ISO 26367:2011 defines that there are four ways to reduce risk, which can be implemented at any given site:

a) Prevention

By giving the highest priority to preventing the fire in the first place: for example, segregating or controlling sources of ignition such as segregation of flammable materials

b) Detection

By ensuring that, if a fire does start, it is detected and tackled as quickly as possible. The fitting of automatic detection and protection systems such as sprinklers is one way of doing this. Site operators should seek advice on such systems from fire and rescue services and their insurers.

c) Containment

By installing facilities for containing fire-fighting water, such as storage lagoons or chambers, shut-off valves and isolation tanks or areas.

Note: It is intended that this issue be dealt with specifically in a document under preparation.

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d) Mitigation

By planning with the fire and rescue service suitable fire-fighting strategies, such as

- Reducing the amount of fire-fighting water generated, by using sprays instead of jets,

- Recycling fire-fighting water where this is not hazardous, and

- Controlled burning

In cases where action is required to prevent the fire spreading, such as the application of cooling water to the area around the storage tanks, care should be taken to ensure that this water does not become a pollutant.

In addition ISO 26367-1:2011 highlights how the sensitivity of the environment / receptors for any fire effluent is one of the factors, which should be considered when assessing the environmental impact of fire effluents. This is generally assessed in terms of high, medium and low sensitivity based on national practice for classifying receptors and the nature of the effluent.

Points (a) and (b) above on ‘protection’ and ‘detection’ have already been dealt with in more detail, than ISO 26367-1:2011 provides above, in sections 2 of this report on Risk Assessment Methodology. As regards Point (c) above in relation to ‘containment’, the note which refers to the ‘document under preparation’ is of course the later ISO/TR 26368:2012, which was referred to previously in Section 6.1. While this this Technical Report ISO/TR 26368 is somewhat general in nature, it does define that for calculation of the maximum required retention volume for fire-water run-off, the following quantities should be determined:

a) The total volume of water likely to be used to fight the fire. Methods suitable to determine this volume are presented in the following paragraphs.

b) The volume of containment water to be retained for each of the main site areas.

c) The expected total volume of containment fire water based on the largest volume calculated for each of the main site areas.

d) The expected volume of rainfall, based on maximum level of water retention under normal usage conditions.

e) The total required retention volume for contaminated fire water.

Table B1 in Annex B then provides a summary of some different methodologies for defining fire water retention basins and their main characteristics. In many respects these are quite old, such as the VCI methodology of 1988 for fire protection in warehouses, which was used in forming the basis of the later LÖRÜRL code. As ISO/TR 26368 clarifies size definition can be completed by either:

- “Magic Numbers” which are a deterministic approach based on feedback from specific accidents, such as the Sandoz fire. The LÖRÜRL code and the VCI Guidance of December 2014, referred to previously, would be more modern examples of this approach, in addition to the German Insurance Industry Association’s VDS 2257 guidance and the Swiss guidance of 2015, both previously referred to in Section 5.1 of this report. As ISO/TR 26368 states: “this kind of method is simple to apply, with little input data needed. Nevertheless, “magic numbers” are issued based on only a few case studies and are difficult to extend to every potential fire scenario”. While the knowledge in this area has increased since the references in ISO/TR 26368, it is true that such a technique is inherently more suited to warehouse type situations than complex tank farms.

- “Model curves” provided in ISO/TR 26368, which are based on statistical analysis of; (i) water flow rate versus fire area and; (ii) fire duration versus fire area. The size of the water basin needed is thus the product of the water flow rate by the control time. However, there is considerable variability with respect to these curves, which are based on various hypotheses and approximations of the area of the fire and what is burning.

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- The “risk-based approach” is based on hazard analysis and quantified risk assessment, which goes beyond the simple sizing of retention systems to include the risk management issues associated with the potential release of hazardous materials into the receiving waters surrounding an industrial site. The main steps associated with this approach are; (i) Identification of the hazardous materials; (ii) Identification of the mechanisms of release; (iii) Evaluation of the sensitivity of the receiving environment; (iv) Estimation of the potential volume of contaminated water, such as from a range of pertinent fire scenarios; (v) Consequence analysis of accidental release of water pollutants into the receiving environment. If these consequences are not acceptable, a further process leads to the sizing of a retention capacity.

- The effective sizing step will be based on a frequency / probability analysis obtained from a comprehensive fire safety study of the frequency and magnitude of rain events, frequency of fires and quantity of water to be applied. From a probabilistic point of view, the final sizing may be the result of an iterative process based on the acceptance criterion in terms of frequency of discharge of contaminated waters off-site. The probability that the contaminated water volume will exceed the capacity of the retention basin under consideration can be expressed as a function of the size of the retention capacity.

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Appendix C Controlled Burn Strategy Literature

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1 Controlled Burn Strategy - UK / Ireland Legislative Approach

1.1.1 General

The Energy Institute’s “Model code of safe practice Part 19: Fire precautions at petroleum refineries and bulk storage installations” states in its Section 7.2.6 on Controlled Burn:

Controlled Burn is an operational strategy where the application of fire-fighting media such as water or foam is restricted or avoided, to minimise damage to public health and the environment. In addition, it may be proposed as a design philosophy where the consequences associated with a fire incident have been evaluated and it is deemed appropriate not to extinguish any fire because of low consequence to life safety, the environment, assets, business interruption etc. in applying this strategy.

The strategy would normally be used to prevent water pollution by contaminated firewater. It can also reduce air pollution due to the better combustion and dispersion of pollutants. But it may also have adverse impacts such as allowing or increasing the formation of hazardous gaseous by-products.

Attachment 1 also discusses this issue in some depth. It clarifies that the available guidance in the United Kingdom related to fire water retention is based around Pollution Prevention Guidance (PPG) notes produced jointly by the Environment Agencies for England, Wales, Scotland and Northern Ireland and available on their websites, in particular PPG 18 and PPG 28. PPG 18 is entitled Managing Fire Water and Major Spillages15 and while short on specifics, states in relation to fire-fighting strategies and run-off management that:

The Plan may consider fire- fighting strategies and possible methods of reducing the amount of firewater run-off generated, for example by the use of sprays rather than jets, controlled burn and the possible re-cycling of fire-fighting water, where safe and practicable to do.

PPG 28 on Controlled Burn16 takes this concept a step forward in that it addresses more specifically the concept of controlled burn, and clarifies:

The decision on how to conduct fire-fighting operations is governed by the principles of common law relating to reasonableness. In practice, this means there are likely to be circumstances such as the protection of public water supplies, where it would be reasonable for the Fire and Rescue Service Incident Commander to decide to cease - or limit – fire-fighting operations because the consequences of continuing would be worse than the destruction of property.

The explosion and resulting fire at the fuel depot at Buncefield North of London in 2005, was one of the worst industrial accidents to occur in the UK17. During the fire-fighting operation which lasted five days, high volume pumps were used to extract 25 m3/min of water from a reservoir 2.4 km from the fire, with six more high volume pumps deployed at various locations to serve as boosters. Following the accident the Environment Agency declared Buncefield a Major Accident to the Environment (MATTE), as the chalk aquifer under the site was contaminated to a distance of more than 3 km away. Currently the polluted groundwater is being pumped out through several boreholes and treated to remove fuel and fire-fighting foam residues.

As the Environment Agency has clarified, this remediation work is costing € 1.1 million a year and will have to continue for many years18. As regards lessons learnt, it was clear that a controlled burn strategy could have been more effectively applied and this has led to a revision of PPG 28 on controlled burn by the Environment Agency. The current situation being that the existing PPG 28

15 https://www.sepa.org.uk/media/100544/ppg-18-managing-fire-water-and-major-spillages.pdf 16 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/485191/pmho1005bjit-e-e.pdf 17 http://www.hse.gov.uk/comah/buncefield/buncefield-report.pdf 18 http://www.aidic.it/cet/13/31/077.pdf

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document was withdrawn in December 2015. The Environment Agency website advises that although withdrawn, the PPGs are a source of information on good practice but are not to be used as a source of information on legal requirements, as that information is out-of-date in many PPGs.

1.1.2 Legal Considerations in relation to Controlled Burn

However, it is also worth considering the detailed report prepared in 2000 by the Environment Agency, which led to PPG 28, namely the “Environmental Impact of Controlled Burns - Technical Report P38819”. As this concluded:

- Some of the legal issues are not at present resolved completely, and are likely to be so only following case-law decisions.

This was clarified further within the document in that:

- Best Practical Environmental Option (BPEO) is concerned overwhelmingly with minimising environmental impact, whereas in practice the decision is complicated by other important factors , such as:

- whether immediate action is needed to prevent injury to people in or around the building;

- the legal and financial consequences of allowing fires to burn;

- the requirements of the site owner, insurance company and other organisations involved;

- the legal liability of the Fire Service when allowing a building to burn; and

- social factors, including perceived risk.

As this document further clarifies:

- The Fire Services Act 1947 places a duty on every fire authority to ensure that reasonable steps are taken to prevent or mitigate damage to property resulting from measures taken in dealing with fire. Care must be taken to ensure any controlled burn policy is not in conflict with this duty.

This Act of 1947 was updated by the UK Fire and Rescue Services Act 2004, which under Section 720 requires that fire and rescue authorities must seek to mitigate the damage, or potential damage, to property in exercising their statutory functions.

In Ireland Section 10(2)(a) of the Fire Services Act of 198121 (as amended) requires that a fire authority shall:

- Make provision for the prompt and efficient extinguishing of fires in buildings and other places of all kinds in its functional area and for the protection and rescue of persons and property from injury by fire.

One could argue that Section (3) of the above Act provides some additional flexibility in that:

- A fire authority shall, in the exercise of its functions under subsection (2), have regard (in addition to all other relevant considerations) to the nature of the fire hazards and the probable incidence and extent of fires in its functional area, the character of the area and the value of the property liable to be damaged by fires [emphasis added].

Clearly the above legislative obligations of the fire services are somewhat at variance with the straight forward adoption of a controlled burn strategy. Even though both the UK’s Environmental Agency guidance and the draft guidance from the Irish EPA both alluded to this option, the latter stating:

19 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/290620/strp388-e-e.pdf 20 http://www.legislation.gov.uk/ukpga/2004/21/section/7 21 http://www.irishstatutebook.ie/eli/1981/act/30/section/10/enacted/en/html#sec10

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- The local Fire Authority must be consulted with a view to pre-planning responses to likely scenarios including the scenario of allowing the fire to burn itself out. This will include determining the realistic performance of nearby hydrants, the response of the fire brigade and appliances in an emergency and plans for the minimisation of contaminated firewater as appropriate. This information will be included in the risk assessment report to be submitted to the Agency.

In continental Europe the legal system is different, in that it is based on prescribed ‘civil law’ rather than ‘common law’ interpretation by the Courts. Furthermore, federal and regional based structures are more common, in which administrative structures related to environmental protection and emergency services are often integrated at regional level rather than centralised. As such then there is a greater interface and overlap between structures related to environmental protection and emergency services, plus more defined secondary regulations. For instance, in Germany it is clear in that controlled burn is a reasonably routine practice with the fire services, while the International Maritime Organisation’s “Carriage of Dangerous Goods, Emergency Response Procedures for Ships Carrying Dangerous Goods (EMS Guide)”, which recommends the use of controlled burn in certain circumstances, is part of their secondary legal order (Verkehrsblatt).

1.1.3 ISO Guidance on Controlled Burn

If we refer back to Section 6, it is clear with respect to mitigation that ISO 26267:2011 recognises the use of controlled burn. This is expanded on in more detail in Section 5.3.2 of the technical report ISO/TR 26368:2012 in respect of fire-fighting tactics and the use of controlled burn. The justification for this strategy, in addition to environmental considerations, include circumstances where the fire fighters may not know how to extinguish the fire, and where the risk associated with active fire-fighting are too great for the fire fighters.

As the technical report documents, the choice of this tactic requires complex decision making by the fire management team, which in this context it is important to consider:

- What effect fighting the fire with water or foam may have in terms of potentially contaminating water resources, fisheries, aquatic fauna and flora.

- Whether there is a realistic possibility of managing a controlled burn, without attempting extinguishment, taking into account the accompanying risks of short-term air pollution and longer-term pollution of land and water in the event that the smoke plume comes to ground level, and the risk of fire spread to adjacent structures.

- Whether it is possible to minimise adverse health effects on humans (as this takes priority over environmental concerns).

1.1.4 Environmental Impact of Combustion By-products

The German land use planning guidelines for Seveso sites, prepared by their Commission for Plant Safety (KAS), provides the methodology for initial assessment of separation distances from such sites and sensitive locations. KAS 18 states that experience with fires shows that toxic effects on account of the combustion gases are as a rule negligible for the situation of land use planning. As such therefore the effect to be considered is that of heat radiation22.

This situation was previously clarified in Germany by the technical regulations for hazardous materials (TRGS), which are issued by the Committee, for Hazardous Materials (Ausschuss für Gefahrstoffe) under the Minister for Labour and Social Affairs (Bundesministerium für Arbeit und Sozialordnung). TRGS 514 covers the storage of very toxic and toxic materials in packaging and moveable vessels. It is important to note that the scope of the storage units covered by the regulation is large, for instance stores with a capacity of greater than 800 t or 1,600 m3. The Attachment to TRGS 514 deals with the hazards associated with a fire and is given in translated form below.

22 As documented in Section 2.3: http://www.kas-bmu.de/publikationen/kas/KAS_18.pdf

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Combustion gasses:

1. As a consequence of combustion of organic material such as wood, wool, or chemicals, combustion gases will occur along with the oxygen in the air.

2. These are independent of which material is combusted and are fundamentally to be classified as respiratory poisons.

3. The combustion goes further to full completion:

4. The higher the combustion temperature.

5. The greater the excess oxygen concentration.

6. The longer the combustion gases remain at high temperature (reaction time).

7. The main constituent of the combustion gases are always carbon dioxide (CO2), carbon monoxide (CO) and water vapour (H2O). With the combustion of sulphur, chlorine and nitrogen containing material the occurrence of sulphur dioxide (SO2), hydrogen chloride (HCl), nitrogen oxides (NOx) and cyanide (HCN) must be allowed for according to the combustion conditions (temperature, oxygen availability, length of fire). In the open air the hazard associated with CO and HCN is small, as both gases are lighter than air as well as being combustible.

8. Only with unfavourable combustion conditions, as is found with smouldering fires with relatively low temperatures and/or oxygen deficiency, is an incomplete combustion to be considered. Thereby the materials themselves and their by-products are to be found; these precipitate out according to practical experience in the vicinity of the combustion zone. With smouldering fires a raised concentration of carbon monoxide (CO) is to be considered.

9. In general a hazard to the neighbouring population is not to be expected, if they remain inside buildings with closed windows and doors and shut off any air conditioning present. The basis for this is that the driving off of the hot gases (thermal) causes a strong dilution of the combustion gases such that in fact the combustion gases normally only very slowly penetrate into a ‘closed’ room.

10. Only under very unfavourable circumstances (long persistent smouldering fires, poor weather conditions for dispersion) can an evacuation of the buildings be necessary (under instruction of emergency personnel).

11. Odour pollution can also occur in an even larger distance from the combustion zone. It can occur through the smallest quantity of very odour intensive material.

A similar conclusion has been reached in the Netherlands where one of the most useful texts in Seveso assessments is the Dutch ‘Purple Book’ or to give it its full title; ‘Guideline for Quantitative Risk Assessment CPR 18E, 1999’. In Section 4.6.4 this states “in a fire, unburned toxics and toxic combustion products can be released to the environment”, however, “in the case of open fires, plume rise is assumed to occur immediately and no lethal effects are expected”. In the updated 2009 version of this documentation, ‘Reference Manual Bevi Risk Assessments’, the same conclusions are to be found in Section 12.4.23

In the UK the Health and Safety Executive’s Safety Report Assessment Guidance, 2002, states that in general such plumes are highly buoyant and have little impact off site, but in a high wind, people in high-rise buildings close to the site could be exposed to dangerous concentrations of HCl, NO2, HCN or SO2.

In Switzerland it was found following subsequent investigations to the major Sandoz warehouse fire in Basel in 1986, that the concentrations of toxic contaminants, including mercury and dioxins, within the smoke plume had not posed a serious health risk.

23

http://www.rivm.nl/Documenten_en_publicaties/Professioneel_Praktisch/Richtlijnen/Milieu_Leefomgeving/Handleiding_Risicoberekeningen_Bevi

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1.2 Assessing Extinguishing Requirements

In many respects this is a twofold issue. First of all sufficient extinguishing media, which will be predominately firewater, has to made available to fight the fire and ensure that it does not spread. The second issue is that if the fire cannot be put out successfully, and this does happen with fuel storage, the energy content in the stored fuel can simply be so great that the continued application of firewater would lead to unsustainable volumes of firewater run-off. This can be demonstrated by the calculation below based on the guidance from the province of Hessen (Hessenweit abgestimmte Empfehlung, 2011), which is discussed in previously in Section 6.4.2 and Attachment 1:

- In this case the fire load of the building itself and its contents are assessed in GJ and related to the heat binding capacity of water (2.6 GJ/m

3). For each fire compartment the mobile fire load

Qm (products, storage media, equipment objects, etc) and the immobile fire load Qi (building fire load, insulation, cladding, etc) are to be considered.

Qtot [Gj] = Qm [GJ] + Qi [GJ] (3)

- The fire loads can be investigated in an analogous manner to DIN 18230, while if there are a number of fire compartments within the relevant object, the determining condition is the fire compartment with the highest fire load. Furthermore, it can be assumed that only half of the extinguishing water reaches the fire and is available for extinguishing. Therefore, for the necessary water for fire-fighting, what is calculated in the above manner must be doubled. Half the applied water is associated with heat transfer and evaporation, the other half remains as contaminated fire water and must as a consequence be retained. For the necessary fire water retention volume Rfw the evaluated fire load Qtot is divided by the heat binding capacity of water (note units used):

Rfw [m3] = Qtot [GJ] / 2.6 [GJ/m

3] (4)

- The same guidance recognises that there are additional factors of influence on the retention volume. Firstly, the same correction factors are applied as in the LöRüRl guideline, namely a factor of 1.5 for WGK 2 and a factor of 2 for WGK 3.

If we consider a 25,000t Heavy Fuel Oil tank, then the heat of combustion of Heavy Fuel Oil is about 43 MJ/kg. Therefore Qtot for a fire in such a tank is:

(25,000 x 1,000) x (43 / 1,000) = 1,075,000 GJ

If this fire was to be fought continuously with water until such time as it burned out, then Rfw is:

1,075,000 / 2.6 = 413,462 m3

As Heavy Fuel Oil is classified as WGK 1 by the German Authorities, it is not necessary to increase the above by an additional factor.24 However, this is just an enormous quantity of water, which demonstrates the impracticability of continuously fighting a fuel tank fire, which cannot be extinguished within a reasonable period.

The question then is what volume of extinguishing medium should be applied for the initial fire-fighting phase? As the Energy Institute’s “Model code of safe practice Part 19: Fire precautions at petroleum refineries and bulk storage installations” states in its Annex D,

- This annex provides guidance on typical fire-fighting media application rates for various equipment types and fire scenarios; however, they may require adjustment if equipment spacing is minimal, or according to the results of scenario-based risk assessment. Most of this annex focuses on water and foam as they are the fire-fighting media commonly applied to large petroleum fires for extinguishment and / or cooling.

The same guidance highlights that: “Foam is the most widely used extinguishing medium for large petroleum fires” and that:

24 http://webrigoletto.uba.de/rigoletto/public/language.do?language=english

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- Water is used in fire-fighting at petroleum installations to control fire and act as a cooling medium to protect equipment from the damaging effects of flame impingement or high levels of thermal radiation and convection. It can be used selectively as an extinguishing agent, normally applied as a fine spray. However, water may not be effective as an extinguishing medium for fires involving flammable liquids.

As regards the application of cooling water to adjacent tanks, the Energy Institute’s guidance clarifies:

- Lessons learned from incidents include many cases where water has been over-applied for cooling adjacent tanks, leading to bund flooding, carry-over of product to other areas and excessive discharge of contaminated water offsite, as well as a shortage of water for more critical use.

- For tank fire design events, radiant heat should be calculated. Any exposures to more than 32kW/m

2 should be provided with fixed cooling water systems. Exposures receiving 8 -

32kW/m2 should be cooled, but this can be provided by mobile/portable means providing it can

be deployed in a reasonable time. A water application rate of 2 l/min./m2 is normally sufficient;

this removes 43 kW/m2 thermal radiation at 50 % efficiency, 30 kW/m

2 at 35 %, or 69 kW/m

2 at

80 % respectively. At many installations this may be the maximum practical rate determined by supply and drainage considerations. Rates higher than 2 l/min./m

2 do not provide a

proportionate increase in protection.

The Energy Institute’s guidance then refers to EN 13565-2:2009 “Fixed fire-fighting systems - Foam systems - Part 2: Design, construction and maintenance” for the assessment of foam application rates using monitors to fight full surface fires. In particular Section 5.1 on “Application rates” and Section 5.2 on “Flammable liquid storage tanks, bunds and process areas”.

EN 13565-2:2009 defines the ‘operating time’ as the “minimum time for the supply of the foam extinguishing system with foam concentrate”. This is dependent on the foam type and configuration of the tank, but ranges from 30 minutes to 90 minutes. Indeed, the Energy Institute’s guidance also clarifies:

- Scenario evaluation should be used to calculate total water quantity, but a minimum of two hours’ supply should be considered as a baseline given the potential use of water or foam in a design event fire. However, in practice this figure may vary depending on incident strategy, system run times, etc., as well as the likely duration of any fire and exposure to radiant heat and flame impingement. A realistic estimate of the amount of water required to control the facility’s design event should be determined and there should also be contingency for further supply.

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Appendix D HFO Tank Firewater Calculations

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1 Unofficial Translation of Sections of the LÖRÜRL Building Code

Storage of material in fixed vessels as well as movable vessels with a volume of more than 3,000 l.

Storage of non-combustible liquids and solid combustible material

- For non-combustible liquids in combustible vessels no additional volume for fire water retention is necessary for the liquid, if the bund is present for the liquid.

- For combustible pasty materials, which are stored under raised temperatures (e.g. paraffin), and for solid flammable material (eg organic dusts) it is necessary to decide in the individual case if or which volume of fire water retention is necessary.

Storage of flammable liquids

- Facilities for fire water retention are not required

- For vessels, which are completely embedded underground

- For double walled vessels of steel with a volume of up to 100 m3, which are fitted with an approved leak detection device

- 7.2.2 In so far as bunds for flammable liquids are necessary (according to VbF, VAWS, inspection document) and these are to be used also as fire water retention facilities, then with the bund volume for product escape, an extensively additional free volume must also be present for containment of the fire water as well as extinguishing foam.

- This additional free volume serves as sufficient if;

- with the usage of heavy foam according to DIN 14 493 Part 2 the height of the bund is to exceed by 30 cm the value calculated according to TRbF 110 Nr. 7.4 and TrbF 210 Nr. 3.5 or;

- with a reduction of the filling grade in the vessel or with a measurement and limiting of the filling grade with alarm activation is guaranteed, that sufficient free room – as previously- is maintained ready, or;

- is demonstrable calculated, that the volume suffices. For this serves the formula given in 7.2.3 in which the valuation factors are applied.

- 7.2.3 The calculated proof of the necessary total volume VG of bunding under consideration for adoption of the function of fire water retention is to be calculated according to the equation:

VG = VF + WL + WB + VSch – P – E

- Where:

VG = Total volume requirement

VF = Volume for flammable liquid in m3 according to TRbF 110 Nr. 7.4 and TRbF 210 Nr. 3.5

WL = Water quantity of extinguishing medium in m3 (foam according to DIN 14493 Part 2) multiplied with the valuation factors FG, FL and FF (see section 7.2.4)

WB = Water quantity in m3 from the cooling spray (according to DIN 14495), it so far as it is mixed with the extinguishing water WL, multiplied with the valuation factors FG, FL and FF (see section 7.2.4)

VSch = Extinguishing foam volume in m3 with a taken 50%-decomposition of the foam according to DIN 14493 part 2.

P = into neighbouring bunds or into other vessels transferred flammable liquids in m3

E = in other fire water retention facilities drained fire water or water from extinguishing foam or separated from stored goods uncontaminated fire water in m3 (e.g. to a facility according to TRbF 110 Nr.7.59)

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- 7.2.4 The valuation factors FG, FL and FF according to 7.2.3 are determined as follows:

Valuation factor FF for fire-fighting by the fire brigade

Fire-fighting by the fire brigade Valuation factor

F1 = Public fire brigade FF1 = 1.1

F2 = Work’s fire brigade FL2 = 1.0

- 7.25 If in the case of fire, the stored material from the vessel can be transferred away (e.g. to other vessels), the volume of the stored flammable liquid can be applied as a lower value around the volume P, based on that which during the length of the fire or the fire fighting can be

Valuation factor FG for the size of the bund

Area in m2 Valuation Factor

G1 = Up to 100 FG1 = 0.8

G2 = Over 100 to 1,000 FG2 = 0.9

G3 = Over 1,000 to 2,000 FG3 = 1.0

G4 = Over 2,000 to 5,000 FG4 = 1.05

G5 = Over 5,000 FG5 = 1.1

The area G is the largest free area of the bund (area of bund minus the area of the respectively installed vessels in the bund)

With the division of a bund through separation mounds or walls the factor FG corresponds to the partial area.

Valuation factor FL for extinguishing type / fire extinguishing system

Type of extinguishing / fire extinguishing system Valuation factor

L1 = Mobile fire fighting FL1 = 1.1

L2 = Mobile fire-fighting with automatic fire alarm FL2 = 1.05

L3 = Half stationary non-automatic fire extinguishing system

FL3 = 1.05

L4 = Stationary non-automatic fire extinguishing FL4 = 1.0

L5 = Half stationary non-automatic fire extinguishing with automatic fire alarm

FL5 = 0.95

L6 = Stationary non-automatic fire extinguishing system with fire alarm

FL6 = 0.9

L7 = Stationary automatic fire extinguishing system including automatic fire alarm

FL7 = 0.8

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transferred away. For this a proof is required. The reduction in the necessary volume for the flammable liquid creates room for retention of fire water.

As a rule the fire fighting time is to be calculated as 30 minutes. With provision of proof in individual cases a burn out rate can be considered.

- 7.26 By draining off fire water volume E into other fire water retention facilities or draining off uncontaminated fire water E to a suitable facility further free room can be made available.

Only the volume E of the drained off fire water can be added, that during the course of the fire or the fire fighting is transferred away. For this a proof is required. As a rule a fire fighting time of 30 minutes is to be calculated.

- 7.27 With division of the bund through separation walls these are allowed according to TRbF 110 Nr 7.56 to a height not more than 75% of the height of the outside wall. The separation walls must be as a minimum as high as the necessary foam thickness. The tank mounds are to be executed liquid sealed in the volume range VG – VSch and in volume range VSch foam sealed.

For the purposes of estimating the potential firewater generated and hence retention required for such a scenario the following information is also of assistance.

- As mentioned above, there is the possibility of on-site escalation due to the thermal radiation impact of the fire. Cooling water will need to be applied to the tank on fire in addition to the other HFO tank and also possibly to other tanks in the vicinity including the Diesel and Propane tanks and possibly the back of the FGD building. A demonstrative thermal radiation plot is included in section 8.2.2. As per the ISO guidance mentioned previously, a cooling water application rate of 2 l/min./m2 is normally sufficient; Rates higher than 2 l/min./m2 do not provide a proportionate increase in protection.

- EN13565 indicates that 90 minute fire fighting operating time when using monitors. If the fire is not extinguished or no progress is being made after this time then the continued application of fire-fighting water and foam is to be assessed and consideration should be given to a controlled burn approach and redirecting fire fighting operations to cooling and protecting adjacent installations from radiant heat.

- The foam provided for fighting a fire of this type is ‘Angus Fire FP70’ – a FluoroProtein (FP) Fire Fighting Foam Concentrate designed for extinguishing and securing flammable hydrocarbon liquid fires. FP70 is biodegradable and virtually non-toxic to aquatic organisms. It is based on a natural protein foaming agent and contains no harmful synthetic detergent or glycol agent. FP 70 is intended for use as a 3% solution in water and has an expansion ratio of ≥ 7:1.

- HFO Tank Dimensions: Diameter 48m, Height 14.6m. Therefore, tank roof area is 1,808m2 and lateral area of tank is 2,200m2.

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2 ESB Moneypoint HFO Tank - Fire Water Calculations

Based on the LÖRÜRL calculation method, described in more detail in Appendix A, the required volume VG of fire water retention is calculated according to the equation:

VG = VF + WL + WB + VSch – P – E

Where:

VG = Total volume requirement

VF = Volume of flammable liquid in m3

Volume of HFO in one tank = 24,250m3

WL = Water quantity of extinguishing medium in m3 (according to EN 13565-2:2009) multiplied by

the valuation factors FG, FL and FF

EN 13565 provides application rate formula:

Q = Qth.FC.FO.FH → Q = 4(1.1)(2.75)(1.25) = 15.1 l/min/m2

Area of Tank Roof (Fire Area): 1,808m2

Fire fighting duration: 90 min

Therefore 2,457m3 required.

Applying FG, FG & FF valuation factors, WL= 2,457 x (1.1)(1.05)(1.05) = 2,979m3

WB = Water quantity in m3 from the cooling spray (according to DIN 14495), in so far as it is mixed

with the extinguishing water WL, multiplied with the valuation factors FG, FL and FF

The Energy Institutes guidance recommends cooling spray application rate of 2l/min.

Therefore, applying cooling water at this rate to lateral area of the tank on fire (2,200m2) for 90 minutes and applying FG, FG & FF valuation factors as per WL calculation = 479m3.

VSch = Extinguishing foam volume in m3 with a 50% decomposition rate of the foam according to

EN 13565-2:2009

Foam Volume = 2,979m3 x 7 (Expansion rate) x 50% = 10,427m3

P = into neighbouring bunds or into other vessels

E = in other fire water retention facilities

Therefore; VG = 24,250 + 2,979 + 479 + 10,427m3 – P – E (m3)

VG = 38,135m3

The Heavy Fuel Oil (HFO) Tanks at Moneypoint have sufficient capacity to contain in excess of 120 % of the maximum volume of HFO contained in any one of the tanks. Detailed surveys carried out on site by ESB revealed the respective capacities of the bunds to be;

- Bund 1 (East): 29,668m3

- Bund 2 (West): 30,885m3

Comparing the required retention volume VG (38,135m3) to the volume available in the smaller of the bunds (29,668m3), there is a deficit of 8,467m3, although a large volume of retention would still be available in the adjacent bund even when cooling water is applied to that tank.

Cooling water generated in adjacent bund:

Half the surface area of the other tank will be exposed to the fire and so cooling water will be calculated on this basis.

Therefore, half the lateral surface area in addition to the tank roof area = 2,908m2.

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10/04/2017


Applying cooling water for 90 minutes generates 523m3 of cooling water.

Therefore, Bund 2 would have the following volume available; 30,885m3 – 523m3 = 30,362m3.

This additional volume represents the P & E in the LÖRÜRL calculation method formula.

Foam Concentrate Supply

EN 13565-2:2009 provides a calculation for the quantity of foam concentrate to be made available based on the water demands calculated above.

V = QMax t (Z/100)

Where Qmax is the maximum water demand in litres/min (29,790 litres/min)

Z is the proportioning rate of foam concentrate in % (3% for FP70 Foam)

T is the operating time in minute (90mins)

Therefore, foam concentrate required, V = 80,433 litres.

The scenario assessment provides the volumes required to extinguish the fire within a 90 minute time period and also includes the conservative assumption that the total volume of the tank could be lost during the fire scenario. In reality it is expected that catastrophic tank failure and loss of the entire contents of one tank would not occur if the fire was extinguished in this time frame, therefore considerable volume would be available in the bund for firewater run-off.

Other factors which will limit the limit the uncontrolled release of firewater include;

- Considerable amounts of fire-fighting water (up to 50 %) can be assumed to evaporate as previously stated in guidance referred to in Section 6.4.2.

- The tank farm is situated in a hollow area of a bank. In the event of a major incident occurring, firewater that has overflowed the bund would most likely be contained in the hollow.

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Attachment D

Moneypoint Wind Farm Construction Methodology

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Moneypoint Wind Farm

ESB Wind Development

Construction Methodology

QR320174-F105-009-R-0001

ESBI Civil, Building & Environmental Stephen Court, 18/21 St Stephen’s Green, Dublin 2 Ireland Tel: +353 (0)1 703 8000 Web: www.esbi.ie

October 2012

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Moneypoint Wind Farm

File Reference: QR320174-F105-009-R-0001

Client / Recipient: ESB Wind Development

Project Title: Moneypoint Wind Farm

Report Title: Construction Methodology

Report No.: 1

Rev. No.: 0

Volume 1 of 1

Prepared by: Title

Sarah Stapleton Geotechnical Engineer

Verified by: Brian Murphy Consultant

APPROVED: Gerry Kelly TITLE: Senior Consultant

DATE: October 2012

Latest Revision Summary:

COPYRIGHT © ESB INTERNATIONAL LIMITED ALL RIGHTS RESERVED, NO PART OF THIS WORK MAY BE MODIFIED OR REPRODUCED OR COPIES IN ANY FORM OR BY ANY MEANS - GRAPHIC, ELECTRONIC OR MECHANICAL, INCLUDING PHOTOCOPYING, RECORDING, TAPING OR INFORMATION AND RETRIEVAL SYSTEM, OR USED FOR ANY PURPOSE OTHER THAN ITS DESIGNATED PURPOSE, WITHOUT THE WRITTEN PERMISSION OF ESB INTERNATIONAL LIMITED.

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Contents

1 Introduction 2

2 Purpose of Report 2

3 Project Construction 3

3.1 Scope 3

3.2 Site Operations & Supervision 3

3.3 Construction Schedule 4

3.4 Construction Environmental Management Plan 4

4 Foundations – Turbines T2, T3 & T5 4

5 Foundations – Turbines T1 & T4 5

6 Crane Hardstandings 6

7 Control Building and Compound 7

8 Electrical Works – Cabling 7

9 Turbine Erection and Commissioning 7

Appendix A – Drawing A

Appendix B – Procedure for Dealing with Groundwater in Excavations on the Wind Farm Construction Site B

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1 Introduction A wind farm development is planned at ESB’s Moneypoint Generating Station, which is in Co. Clare, approximately 3 km west of Killimer and 6 km south-east of Kilrush.

The wind farm will comprise five wind turbines which will be used to harness the natural energy of the wind to generate electricity.

Planning permission (Reference Number PL03.130164) was granted by An Bord Pleanála in October 2002 for a similar wind farm development comprising nine turbines on this site. This followed a third-party appeal of Clare County Council’s decision (Ref. P01/1538) to grant permission.

The current planning application (Ref. 12/74) differs from the permitted development in terms of the turbines, there being fewer but larger turbines.

2 Purpose of Report The planning application was lodged with Clare County Council on 10th February 2012. In correspondence dated 3rd April 2012 Clare County Council indicated that further details in relation to the application were required in order that the application be fully assessed before making a decision. In accordance with Article 33 of the Planning & Development Regulations, 2001, as amended, the applicant was requested to submit the additional information as set out in the schedule accompanying the correspondence.

The purpose of this report is to address Item 3 in Clare County Council’s request for further information. This requires that the proposed methodology for the construction of Moneypoint Wind Farm be outlined.

Item 3 in the correspondence of 3rd April reads as follows:

“Regarding the proposed construction/excavation methods for the turbines, please submit a construction methodology statement in which should include, but is not limited to, the following:

(i) Details of how material is to be excavated for the foundation of the proposed turbines. Please confirm whether blasting is required, in particular for turbine T5, which is located on bedrock.

(ii) Where the excavated material is to be stored/ disposed of, please submit haul routes in this regard.

(iii) Source of material for fill related to the proposed craneage pads. Please submit haul routes in this regard.

(iv) Full details to prevent silt laden run off from the excavated material into the adjacent waters.”

This Construction Methodology should be read in conjunction with the following, of which it forms Appendix D:

Moneypoint Wind Farm, Response to Clare County Council’s Request for Additional Information; ESBI Report QR-320174-11-R2

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3 Project Construction

3.1 Scope

Construction will principally involve the following:

Establishing temporary site facilities.

Earthworks for the provision of crane hardstandings and turbine foundations.

Fixing of formwork and steel reinforcement for the turbine foundations.

Construction of reinforced concrete bases with cast-in steel foundation section for the tower and backfilling around foundations.

Reinstatement of areas around turbine bases.

Erection by crane of the pre-fabricated turbine towers and the installation of turbines and rotor blades.

Construction of an additional Control Building within the Electrical Transformer Station.

Installation of underground ducts and cabling from each turbine to the Electrical Transformer Station.

Decommissioning of temporary facilities.

3.2 Site Operations & Supervision

A full construction management team will be deployed on site in accordance with routine site construction procedures. This team will consist of a Resident Site Manager and Assistant Engineers as appropriate.

It is envisaged that the works will be divided into three separate contracts as follows:

Civil Works

Electrical balance of plant (EBOP)

Turbine Supply, Erection & Commissioning.

All construction works will be carried out under appropriate supervision. Works will be carried out by experienced contractors using appropriate and established safe methods of construction. All requirements arising from statutory obligations including the Safety, Health and Welfare at Work Act and associated regulations will be met in full.

Normal working hours during the construction period are expected to be Monday to Friday 08:00 to 20:00 and Saturday 08:00 to 17:00.

Should delivery of wind turbine components be by road rather than to the site’s barge landing facility, abnormal load deliveries may take place outside of peak hours to minimise disruption to other road users.

They will be subject to the requirements of the Road Traffic (Permits for Specialised Vehicles) Regulations, SI 147 of 2009. Coordination with Clare County Council, the National Roads Authority (NRA) and An Garda Síochána will be undertaken to ensure that the haulage operations are acceptable in terms of travel and timing.

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3.3 Construction Schedule

The wind farm installation will require about six months to complete, provided that conditions are not unfavourable. Distinct or separate phases of the project are not planned since it is intended that all turbines will be installed in one phase.

Construction activities for the Civil Works Contract and the Electrical Balance of Plant Contract are likely to take place over a period of four months. The Turbine Supply, Erection & Commissioning Contract is likely to take up to three months to complete.

Nominal time scales for construction works will typically be as follows:

Civil engineering works will take approximately 3-4 months.

Electrical works will take approximately 2-3 months and will be carried out in conjunction with the civil works as far as possible.

Turbine erection will take 1 month and will commence when the bulk of the civil works are complete.

Final reinstatement will take 1 month and will be conducted in parallel with turbine commissioning.

The final programme will be developed in consultation with the turbine manufacturer, based on availability of turbines and projected delivery dates.

3.4 Construction Environmental Management Plan

All site activities will be provided for in an Construction Environmental Management Plan (CEMP) prepared by each Contractor prior to commencement of on-site operations. The Plan will outline the work practices, environmental management procedures and management responsibilities in relation to construction of Moneypoint Wind Farm.

The Plan will set out all measures necessary to ensure the works are carried out in accordance with the specified contractual, regulatory and statutory requirements, as well as the mitigation measures set out herein. Amongst the items to be addressed will be the following:

Control of fuels and oils

Control of concrete

Waste management

Construction monitoring

Traffic management

Pollution contingency plan

All site personnel will be required to be familiar with the CEMP’s requirements as related to their role on site. The CEMP will be a controlled document, which will be reviewed and revised as necessary.

4 Foundations – Turbines T2, T3 & T5 The foundations for Turbines T2, T3 and T5 will be gravity-based spread foundations, whose dimensions will be determined by pre-construction structural design calculations. They constructed according to the following methodology:

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The location of the foundations will be set out from the construction drawings.

An area of approximately 400 m2 will be excavated to the formation level. The formation level will be on a firm bearing stratum and the exact level will be determined by the ground conditions at each turbine.

Excavations will be carried out using excavators with rock breakers. Blasting will not be used at any turbine location.

It is not envisaged that there will be significant inflows of groundwater into the excavations. However, if dewatering of an excavation is required it will be carried out using mobile pumps. Suspended solids will be removed prior to discharging into the environment in accordance with Procedure EMS 9.1-32 in Appendix B.

Surface water will be managed using the existing drainage systems on site in compliance with the existing Integrated Pollution Prevention and Control (IPPC) Licence 605-02 for Moneypoint.

It is expected that much of excavated material will be re-used as fill. Any surplus excavated material will disposed of in designated storage area within the Moneypoint Generating Station site in accordance with existing ESB Moneypoint procedures. There will be no off-site disposal of excavated materials.]

A layer of approximately 150 mm deep concrete blinding will be laid on the exposed formation level and finished leaving a flat level surface.

Reinforcing steel, shuttering, cable ducting and tower anchoring systems will be installed in accordance with the design drawings and requirements.

Concrete will be placed in two phases, namely the base pour and the pedestal pour. The base pour will be undertaken using a concrete pump and the pedestal pour will be carried out using a skip or chute. Concrete will be compacted during both phases using vibrating pokers to the levels and profiles required.

Following a curing period, where the foundation base will be covered to assist curing, formwork will be stripped off and stored for re-use.

The foundation will be backfilled with selected previously excavated material.

5 Foundations – Turbines T1 & T4 The foundations for turbines T1 and T4 will be piled as they are located on made ground. Turbine T1 is in the ash storage area north of the N67 and turbine T4 is located on an area that was recovered from the estuary by placing rockfill material during the site development works phase of the power station construction.

The piles will be founded on natural ground. Bedrock is shallow on the site and it is anticipated that the piles will be founded on rock. The depth, diameter and number of piles will be determined following the site investigation.

The piles at turbine T4 will be drilled through the rockfill material as it would not be possible to drive piles through this fill material. While driven piles are possible at

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turbine T1, this construction technique would require mobilisation of a second piling rig. For that reason, it is likely that the piles for turbine T1 will also be drilled.

The dimensions of the foundations for turbines T1 and T4 will be determined by pre-construction structural design calculations. They will be constructed according to the following methodology:

The location of the foundations will be set out from the construction drawings.

A temporary piling platform will be put in place and the drill rig will set up on the piling platform over the location of each pile.

A hole of the required diameter will be drilled inside a steel casing. The casing is used to ensure the sides of the drill hole stay open in unstable ground.

The pile will be drilled until a suitable bearing stratum on natural ground is reached.

Spoil material from the drill hole will be disposed of on site.

A cage of reinforcing steel will be lowered into the drill hole and concrete will be poured into the piles through tubes from the bottom upwards. The casing will be withdrawn as the concrete is poured.

If voids are found in the fill or bedrock during the site investigation, a sacrificial casing may be used to ensure concrete does not escape into the ground surrounding the drill hole.

A reinforced concrete pile cap will be constructed at the top of each pile. A reinforced concrete ground beam will also be constructed connecting the pile caps together.

Reinforcing steel for the turbine foundation, shuttering, cable ducting and tower anchoring systems will be installed in accordance with the design drawings and requirements.

Concrete will be placed in two phases, namely the base pour and the pedestal pour. The base pour will be undertaken using a concrete pump and the pedestal pour will be carried out using a skip or chute. Concrete will be compacted during both phases using vibrating pokers to the levels and profiles required.

Following a curing period, where the foundation base will be covered to assist curing, formwork will be stripped off and stored for re-use.

The foundation will be backfilled with selected previously excavated material.

6 Crane Hardstandings Crane hardstandings will be required at each turbine to enable a crane to set up and erect the turbines. They will be constructed according to the following methodology:

Topsoil, subsoil and any existing obstructions will be removed and excavated down to a suitable formation level.

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The existing granular material was placed and compacted in layers, and provides a homogeneous surface. The hardstanding will be formed from these materials.

Site won material from the turbine foundation excavations will be incorporated in the hardstandings where possible.

There will be no requirement for imported general fill material as there are sufficient quantities available on site. However, the capping layer for the hardstandings may have to be imported. The total volume of capping material is estimated to be approximately 1,000 m3 (about 100 lorry loads).

There are a number of quarries in close proximity to the site, which could be used to supply stone. The source of imported stone will not be known until a Contract for the Civil Works is in place.

7 Control Building and Compound Construction of the Control Building will be in accordance with the approved layout.

The proposed substation area is within the existing 400kV Electrical Transformer Station compound.

The existing earth grid will be extended.

The substation will be constructed in accordance with the planning drawings.

The compound area will be re-graded with single sized stone.

A palisade fence will be erected around the substation compound to separate it from the main compound.

The existing surface water drainage network will be used.

An appropriately sized bund will be constructed around the transformers.

8 Electrical Works – Cabling All electricity and control cables within the site between the turbines, and from turbines to the Control Building will be buried underground.

An excavator will dig a trench into which the cables will be buried. The cables will be bedded on suitable material at a depth in accordance with all national and international requirements. Warning tape will be installed between the cables and the ground surface. The area will be reinstated on completion of installation.

9 Turbine Erection and Commissioning The turbine will be supplied with a semi-matt finish to an agreed colour.

During transport each turbine will consist of 10 loads comprising of towers (3), blades (3), nacelle (2), hub (1) and small parts (1).

Where transportation by road is the chosen method of delivery to site, specialised transport vehicles will be used, under supervision and permits from local authorities and the Gardai.

Each turbine section will be positioned at the hardstanding area and erected into position by two mobile cranes.

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On completion of all component assembly, internal mechanical fit out of the turbine components and pre-commissioning works on the Supervisory Control and Data System (SCADA) control checks are completed.

The turbine commissioning will commence after the installation and commissioning of the grid connection (main power) to allow the first energisation of each turbine.

After all commissioning checks have been completed the Turbine will enter performance and integrity tests prior to final acceptance by the developer.

After all ‘tests on completion’ have been successfully completed the turbines will be handed over by the Contractor and the periods for warranty and maintenance agreements will commence.

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Appendix A – Drawing: Site Layout

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Appendix B – Procedure for Dealing with Groundwater in Excavations on the Wind Farm Construction Site

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Procedure for dealing with groundwater in Excavations on the windfarm construction site

Page 1 of 2

EMS 9.32 Version: 1.0 Approved: May 12 ESB Moneypoint Environmental

Management System SMS SOP Review: 3 yearly

ESB MONEYPOINT GENERATING STATION

PROCEDURE FOR DEALING WITH GROUNDWATER IN EXCAVATIONS ON

THE WIND FARM CONSTRUCTION SITE

(EMS 9.1-32)

Prepared by:

Reviewed and Validated by:

Date Version No.

J. Wall May 2012 1.0 (Renumbered, cover page & header revise

Latest revision approved by:

Ciaran McManus

Environmental Co-ordinator Moneypoint Generating Station Date: May 2012

Check with the computer system to verify that this is the latest revision prior to use

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Procedure for dealing with groundwater in Excavations on the windfarm construction site

Page 2 of 2

EMS 9.32 Version: 1.0 Approved: May 12 ESB Moneypoint Environmental

Management System SMS SOP Review: 3 yearly Moneypoint Ref. EMS 9.1-21

DE-WATERING OF EXCAVATIONS ON THE WINDFARM CONSTRUCTION SITE. The following procedure shall be used to ensure that un-treated water from excavations on site does not enter the main drainage system on ESB Moneypoint site. The contractor for the works will perform a risk assessment of the task and this is available for review if required. The purpose of this document is to ensure that the procedure followed by our contractors is followed and audited as necessary. Equipment used in the dewatering will be tractor, vacuum tank, oil bunds and oil mats as necessary. As per the method statement all staff involved in this operation will be given a toolbox talk and will have signed off on the procedure before any operation can take place. PROCEDURE

1. Prior to the commencement of any dewatering removal of oil residues will take place using oil bunds and oil mats these will then be disposed of in appropriate containers and removed from site as per ESB Moneypoint standing procedures.

2. For the water extraction to take place the tractor and tank shall be kept at a minimum of two meters back from the edge of the excavation.

3. The tractor operator will place 100mm of suction hose into the excavation.

4. When the tanker is filled (max. 1,500 gallons) extracted water shall be transported to the recycled water settlement lagoon at the eastern side of the Moneypoint site where it will be reutilised as industrial grade water.

EMERGENCY

1. In the unlikely event of a spillage from the tanker, the water will be prevented from entering the ESB Moneypoint Station drains, where possible by blocking the drains adjacent to the spill.

2. ESB Moneypoint will be informed of the occurrence and if required to do so by ESB Moneypoint extra remedial action will take place.

3. The Moneypoint Generation Station “Environmental Emergency Response Procedure” (EMS 10.1-01) will be referenced where necessary.

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Attachment E

Industrial Cooling Systems Conclusions

Large Combustion Plant Conclusions

EMS Procedures

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Conclusions on BAT from the ICS BAT Reference Document (extracts)

The full and complete ICS BAT reference document (December 2001) is available at the EIPPC Bureau website: http://eippcb.jrc.ec.europa.eu/reference/. You may need to refer to this document in completing the form below. SCOPE Identify here the particular processes and activities at the installation that come within the scope of the conclusions on BAT from the ICS reference document (BREF).

Conclusions on BAT Applicability Assessment(describe how the technique applies or not to your installation)

State whether it is in place or state schedule for implementation

Integrated Heat Management:

BAT 1. BAT for all installations is an integrated approach to reduce the environmental impact of industrial cooling systems maintaining the balance between both the direct and indirect impacts. In other words, the effect of an emission reduction has to be balanced against the potential change in the overall energy efficiency. There is currently no minimum ratio in terms of the environmental benefits and the possible loss in overall energy efficiency that can be used as a benchmark to arrive at techniques that can be considered BAT. Nevertheless, this concept can be used to compare alternatives (Chapter 3.2 and Annex II).

Applicable. Once through cooling water system utilised at Moneypoint, Discharge is to the Shannon estuary

Yes Optimised cooling

BAT 2. Reduction of the level of heat discharge by optimization of internal/external heat reuse. In a greenfield situation, assessment of the required heat capacity can only be BAT if it is the outcome of maximum use of the internal and external available and applicable options for reuse of excess heat. In an existing installation, optimizing internal and external reuse and reducing the amount and level of heat to be discharged must also precede any change to the potential capacity of the applied cooling system. Increasing the efficiency of an existing cooling system by improving systems operation must be evaluated against an increase of efficiency by technological measures through retrofit or technological change. In general and for large existing cooling systems, the improvement of the systems operation is considered to be more

Applicable Yes Optimum cooling water flow rate used at Moneypoint

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cost effective than the application of new or improved technology and can therefore be regarded as BAT.

BAT 3. Cooling system and process requirements: a) A change in cooling technology to reduce the environmental impact can only be

considered BAT if the efficiency of cooling is maintained at the same level or, even better, at an increased level. See table 4.1’ Examples of process requirements and BAT’.

b) Hazardous process substances, which involve a high environmental risk to the aquatic

environment in case of leakage, should be cooled by means of indirect cooling systems to prevent an uncontrollable situation.

c) A change in cooling technology to reduce the environmental impact can only be

considered BAT if the efficiency of cooling is maintained at the same level or, even better, at an increased level.

Not applicable

BAT 4. Cooling system and site requirements:

For temperature‐sensitive processes it is BAT to select the site with the required availability of cooling water. See table 4.2 Examples of site characteristics and BAT. Groundwater ‐ it can be BAT to apply a dry cooling system to minimise GW use.

Applicable Once through system. Cooling water discharges to the Lower Shannon Estuary , a designated SAC area with more than adequate capacity to meet the thermal load.

Yes The plant avoids mixing of local thermal plume near intake point. Modelling was used to confirm the design with the intake and discharge locations segregated.

Application of BAT in industrial cooling systems:

BAT 5. For new cooling installations it is BAT to start identifying reduction measures in the design phase, applying equipment with low energy requiring requirement and by choosing the appropriate material for equipment in contact with the process substance and/or the cooling water.

Not Applicable

BAT 6. For existing installations, technological measures can be BAT under certain circumstances. Generally, a change in technology is cost‐intensive where overall efficiency must be maintained. Cost evaluation should then compare investment costs of the change versus the

Applicable Yes Cooling water system

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change in operational costs and validate the reduction effect versus other environmental consequences. For existing wet cooling systems where focus is largely on measures to reduce water use and emissions of chemicals to surface water BAT is operational rather than technological.

operated in the most cost effective manner.

Reduction of energy consumption

BAT 7. It is BAT in the design phase of a cooling system: • To reduce resistance to water and airflow • To apply high efficiency/low energy equipment • To reduce the amount of energy demanding equipment (Annex XI.8.1) • To apply optimised cooling water treatment in once‐through systems and wet cooling towers to keep surfaces clean and avoid scaling, fouling and corrosion.

Not applicable Moneypoint constructed in 1980’s .

BAT 8. In terms of the overall energy efficiency of an installation, the use of a once‐through systems is BAT, in particular for processes requiring large cooling capacities (e.g. > 10 MWth). Table 4.3 BAT for increasing overall energy efficiency.

Applicable Yes Once through system of cooling utilised. System maintained at high efficiency Warm water plume minimised in the Shannon estuary

Reduction of water requirements

BAT 9. For new systems the following statements can be made: • cooling with water is most efficient with respect to overall energy balance; • For new installations a site should be selected for availability of sufficient (surface) water and adequate receiving water in case of large cooling demand; • Cooling demand should be reduced by optimising heat re‐use; • Where water is limited a technology should be chosen that enables different modes of operation requiring less water for required cooling capacity; • In all cases recirculated cooling in an option. See table 4.4 BAT for reduction of water requirements.

Not applicable

BAT 10. Reduction of entrainment of organisms. Applicable Yes

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For once through systems or systems with intakes of surface water, BAT is analysis of biotope in surface water source and optimisation of water velocities in intake channels to limit sedimentation.

Band screen filter in operation sized for expected biotope.

BAT 11. Identified reduction techniques within the BAT‐approach. Analysis of the biotope in surface water source, Optimise water velocities in intake channels to limit sedimentation; watch for seasonal occurrence of macrofouling. see table 4.5 BAT for reduction of entrainment.

Applicable Yes Band screen filter in operation Chlorination of cooling water. Screen cleaning

Reduction of emissions to water

BAT 12. General BAT approach to reduce heat emissions Where the measures generally aim at reducing the ΔT of the discharged cooling water, a few conclusions on BAT can be drawn. Pre‐cooling (Annex XII) has been applied for large power plants where the specific situation requires this, e.g. to avoid raised temperature of the intakewater. Discharges will have to be limited with reference to the constraints of the requirements of Directive 78/659/EEC for fresh water sources. The criteria are summarised in Table 3.6. Reference is made to a provision in Article 11 of this directive regarding derogation of the requirements in certain circumstances.

Applicable Yes Modelling of thermal plume has indicated no significant impact on receiving water. No impact on the designated species Tursiops Truncatus or salmonid species.

BAT 13. General BAT approach to reduce chemical emissions to water. With respect to the selection of chemicals, it has been concluded that a ranking of treatments and the chemicals of which they are composed is difficult if not impossible to carry out in a general way and would be unlikely to lead to BAT conclusions. Due to the large variation in conditions and treatments only a site‐by‐site assessment will lead to the appropriate solution. Such an assessment and its constituent parts could represent an approach that can be considered BAT.

Applicable Chlorination used as an antifoulant in the cooling water intake , residual chlorine less than 0.5 mg/l

Yes Moneypoint operates in accordance with its IE Licence.

BAT 14. 80% of environmental impact is decided on design table, measures should be taken in the design of wet cooling system using the following order of approach: • Identify process conditions (P, T, corrosiveness);

Not applicable

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• Identify chemical characteristics of cooling water sources;• select appropriate material for heat exchanger for both process and cooling water characteristics; • select appropriate materials for other parts of the cooling system; • Identify operational requirements of the cooling system; • Select feasible cooling water treatment using less hazardous chemicals or lower potential for environmental impact; • apply biocide selection scheme; • optimise dosage regime by monitoring of cooling water andsystems conditions;

Identified reduction techniques within the BAT‐approach

BAT 15. Prevention by design & maintenance See table 4.6 BAT for reduction of emissions to water by design and maintenance techniques

Applicable Once through system

Yes Ti applied to tubes of shell&tube heat exchanger in highly corrosive environment or high quality stainless steel with similar performance Condenser and heat exchanger clogging and fouling prevented by use of band screen filters and chlorine dosing maintaining efficiency

BAT 16. Control by optimised cooling water treatment See table 4.7 BAT for reduction of emissions to water by optimised cooling water treatment Reduction of emissions to air

Applicable Chemical dosing of Chlorine to cooling water intake and band screen washer.

Yes FO or FRO ≤ 0.5 mg/l at the outlet for intermittent and shock chlorination of sea water.

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Monitoring of residual chlorine in accordance with the IEL Licence. Cooling water discharge below the 0.5mg/l Chlorine limit

BAT 17. Identified reduction techniques within the BAT‐approach See table 4.8. BAT for reduction of emissions to air Identified reduction techniques within the BAT approach for all wet cooling towers: i) Avoid plume reaching ground level ii) Avoid plume formation iii) Use of less hazardous material iv) Avoid affecting indoor air quality v) Reduction of drift loss

Not applicable

Reduction of noise emissions

BAT 18. Identified reduction techniques within the BAT‐approach See table 4.9 BAT for reduction of noise emissions Identified reduction techniques within the BAT approach for natural draught cooling towers:

i) reduce noise of cascading water at inlet: ii) reduce noise emission around tower base Identified reduction techniques

within the BAT approach for mechanical draught cooling towers: iii) reduction of fan noise iv) optimised diffuser design No Standard commercial cooling tower utilised ‐ low

noise v) noise reduction

Not applicable

BAT to reduce the risk of leakage

BAT 19. Identified reduction techniques within the BAT‐approach See table 4.10 BAT to reduce the risk of leakage.

The following general measures to reduce the occurrence of leakages can be applied:

Applicable Yes (i) Material selected for equipment of wet cooling systems was based on the cooling

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i) select material for equipment of wet cooling systems according to applied water quality

ii) operate the system according to its design

iii) if cooling water treatment is needed, select the right cooling water treatment programme;

iv) monitor leakage in cooling water discharge in recirculating wet cooling systems

by analysing the blowdown

water quality characteristics ii) The cooling water system is operated according to its design (iii) The cooling water treatment has been optimised by design and operation

Reduction of biological risk

BAT 20. Identified reduction techniques within the BAT approach See table 4.11 BAT to reduce biological growth Identified reduction techniques within the BAT approach for all wet recirculating cooling systems: i) reduce algae formation ii) reduce biological growth iii) cleaning after outbreak iv) control of pathogens

Identified reduction techniques within the BAT approach for all open wet cooling towers: v) reduce risk of infection

Not applicable

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EU Commission, Integrated Pollution Prevention and Control, Reference Document on Best Available Techniques for Large Combustion Plants, July 2006


BAT reference Number

BAT Statement Applicability Assessment

State technique and whether it is in place or state schedule for implementation

3.15.1 BAT is to implement and adhere to an Environmental Management System (EMS) that incorporates, as appropriate to individual circumstances, the following features: (see section above)

definition of an environmental policy for the installation by top management (commitment of the top management is regarded as a precondition for a successful application of other features of the EMS)

planning and establishing the necessary procedures

implementation of the procedures, paying particular attention to

o structure and responsibility o training, awareness and

competence o communication o employee involvement o documentation o efficient process control o maintenance programme o emergency preparedness and

response o safeguarding compliance with

environmental legislation. checking performance and taking

corrective action, paying particular

Applicable

Yes

Standardised EMS in place. See Attachment C.2

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attention to o monitoring and measurement

(see also the Reference document on Monitoring of Emissions)

o corrective and preventive action

o maintenance of records o independent (where

practicable) internal auditing in order to determine whether or not the environmental management system conforms to planned arrangements and has been properly implemented and maintained.

o review by top management. Further supporting features of the EMS which

can complement the above stepwise include:

having the management system and audit procedure examined and validated by an accredited certification body or an external EMS verifier

Yes

Accredited external certified body is engaged to routinely audit the EMS and SMS

preparation and publication (and possibly external validation) of a regular environmental statement describing all the significant environmental aspects of the installation, allowing for year-by-year comparison against environmental objectives and targets as well as with sector benchmarks as appropriate

Applicable Yes

Annual Environmental Report issued to EPA and available for public inspection.

implementation and adherence to an internationally accepted voluntary

Applicable Yes

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system such as EMAS and EN ISO 14001:1996. This voluntary step could give higher credibility to the EMS. In particular EMAS, which embodies all the above-mentioned features, gives higher credibility. However, non-standardised systems can in principle be equally effective provided that they are properly designed and implemented.

ESB Moneypoint implements and adheres to ISO14001, 2004 which is audited by an accredited external body.

The EMS is scheduled to be re-certified in May 2017 to !SO 14001:2015

Other features of the EMS

giving consideration to the environmental impact from the eventual decommissioning of the unit at the stage of designing a new plant

Applicable Yes

Consideration has been given to the environmental impact of the decommissioning of the existing power station and a specific Environmental Liabilities Risk Assessment (ELRA) and Closure Restoration and Aftercare Management Plan (CRAMP has been prepared and submitted to the EPA. These will be implemented in accordance with the EMS.

giving consideration to the development of cleaner technologies

Not Applicable

where practicable, sectoral benchmarking on a regular basis, including energy efficiency and energy conservation activities, choice of input materials, emissions to air, discharges to water, consumption of water and generation of waste.

Not Applicable

4.5.2 Unloading, storage and handling of fuel

the use of loading and unloading equipment that minimises the height of fuel drop to the stockpile, to reduce the

Applicable Yes

Fuel unloading occurs at the marine jetty with fuel

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and additives. Coal and ignite (Dust)

Table 4.65: BAT for the unloading, storage, and handling of coal, lignite and additives

generation of fugitive dust. in countries where freezing does not

occur, using water spray systems to reduce the formation of fugitive dust from coal stockpiles

placing transfer conveyors in safe, open areas aboveground so that damage from vehicles and other equipment can be prevented.

using cleaning devices for conveyor belts to minimise the generation of fugitive dust

using enclosed conveyors with well designed, robust extraction and filtration equipment on conveyor transfer points to prevent the emission of dust

rationalising transport systems to minimise the generation and transport of dust within the site

the use of good design and construction practices and adequate maintenance.

deposited into hoppers that feed covered conveyor belts.

Open coal storage in a dedicated coal storage area above ground using stacker retrievers to stockpile and retrieve coal

Facility in the coal yard to handle coal supply to the plant via a hopper and underground conveyor belt system in times of high winds.

Water dust suppression using water system deployed around the coal yard with further dust suppression system adjacent to each Stacker Retriever rail line.

4.5.2 Unloading, storage and handling of fuel and additives. Coal and ignite (Water Contamination )

Table 4.65: BAT for the unloading, storage, and handling of coal,

having storage on sealed surfaces with drainage, drain collection and water treatment for settling out

collecting surface run-off (rainwater) from coal and lignite storage areas that washes fuel particles away and treating this collected stream (settling out) before discharge.

Applicable Yes

Surface water from the coal yard is drained to a dedicate drainage system and then to a settlement lagoon before discharge at SW13. However. settled water from this lagoon is recycled for use within the station (FGD process).

Surface water from the ash storage area is collected in an existing toe drain which discharges to the existing ash lagoon for settlement. This lagoon forms part of the drainage network of the area and ultimately

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lignite and additives discharges to the Shannon Estuary.

A new ash lagoon will also be provided for the ash storage area and this will come into operation in 2018.

4.5.2 Unloading, storage and handling of fuel and additives. Coal and ignite (Fire Prevention )


surveying storage areas for coal and lignite with automatic systems, to detect fires, caused by self-ignition and to identify risk points.

Applicable Yes

Automatic fire detection systems are in place on key sections of the coal handling and conveying system but not at the open air coal storage area.

4.5.2 Unloading, storage and handling of fuel and additives. Lime and Limestone (Dust )


having enclosed conveyors, pneumatic transfer systems and silos with well designed, robust extraction and filtration equipment on delivery and conveyor transfer points to prevent the emission of dust.

Applicable Yes

Dry lime for the FGD process is delivered in sealed tankers and pumped into dry lime silos. It is mixed with water prior to use in the FGD process.

4.5.2 Unloading, storage and

for handling and storage of pure liquified ammonia: pressure reservoirs

Applicable Yes

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handling of fuel and additives. Pure liquefied ammonia (Health and safety risk according to ammonia)


for pure liquified ammonia >100 m3 should be constructed as double wall and should be located subterraneously; reservoirs of 100 m3 and smaller should be manufactured including annealing processes

from a safety point of view, the use of an ammonia-water solution is less risky than the storage and handling of pure liquefied ammonia.

Moneypoint uses ammonia for Selective Catalytic Reduction (SCR ) of NOx to Nitrogen and Oxygen. Ammonia is not delivered to site but is generated on demand in situ by thermal hydrolysis of Urea in the U2A Plant

4.5.4 Combustion For the combustion of coal and lignite, pulverised combustion (PC), fluidised bed combustion (CFBC and BFBC) as well as pressurised fluidised bed combustion (PFBC) and grate firing are all considered to be BAT for new and existing plants. Grate firing should preferably only be applied to new plants with a rated thermal input below 100 MW.

Applicable Yes

Moneypoint operates a pulverised combustion (PC) for coal

4.5.5 Thermal efficiency Conclusion in Table

Table 4.66: Levels of thermal efficiency associated with the application of the

For existing plants with respect to the Unit Thermal Efficiency (net) the achievable improvement of thermal efficiency depends on the specific plant, but as an indication a level of 36 – 40 % or an incremental improvement of more than 3 % points can be seen as associated with the use of BAT

Applicable Yes

Moneypoint is an existing plant with units constructed in the 1980’s. It operates at approximately 36-37% thermal; efficiency when at full load.

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BAT measures

4.5.6 BAT Conclusion on Dust

Table 4.67: BAT for dedusting off-gases from coal- and lignite-fired combustion plants

For existing plant BAT for dedusting requires ESP or FF in combination with FGD (wet) for PC to achieve Dust emission levels of 5-20mg/Nm3 with continuous monitoring in place

Applicable Yes

As part of the environmental retrofit project Moneypoint installed an FGD plant which includes Fabric Filters to enable the station to achieve the required emission standards in the LCP and IE Directives.

4.5.7 Heavy Metals

BAT to reduce the emissions of heavy metals from flue-gases of coal- and lignite-fired combustion plants is to use a high performance ESP (reduction rate >99.5 %) or a fabric filter (reduction rate >99.95 %).

Periodic monitoring of Hg is BAT. A frequency of every year up to every third year, depending on the coal used, is recommended. Total Hg emissions need to be monitored and not only Hg present as part of the particle matter.

Applicable Yes

As part of the environmental retrofit project the station installed SCR and fabric filters both of which contribute to significant reductions on Hg. In accordance with the IED periodic monitoring of Hg is being carried out.

.

4.5.8 SO2 emissions

Table 4.68: BAT for the prevention and control of sulphur dioxides from coal- and lignite-fired combustion plants

BAT for the prevention and control of sulphur dioxides from coal include use of Low sulphur fuel, FGD (wet), FGD (sds), Seawater scrubbing, Combined techniques for the reduction of NOx and SO2 to achieve an emission level between 20-200 mg/Nm3

Applicable Moneypoint has been fitted with flue Gas desulphurisation process using dry lime with Fabric Filters – known as Circulating Fluidised Bed FGD.

Low sulphur coal is used at Moneypoint with occasional use of higher sulphur coals

Continuous SO2 monitoring is in place and emission monitoring reported to the EPA.

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4.5.9 NOx emissions

The BAT conclusion for the prevention and control of NOX emissions and the associated emission levels are summarised in Table 4.69. of the BREF. For existing plants (300MWth with Pulverised Combustion firing on coal) the applicable BAT options are Combination of Pm (such as air and fuel-staging, low NOx burner, reburning, etc.), in combination with SCR or combined techniques.

Continuous monitoring is also required.

Applicable Yes

Moneypoint fitted with Low NOx burners and SCR

NOx is measured on a continuous basis and reported to the EPA

4.5.10 Carbon Monxide (CO)

BAT for the minimisation of CO emissions is complete combustion, which goes along with good furnace design, the use of high performance monitoring and process control techniques, and maintenance of the combustion system. Because of the negative effect of NOX reduction on CO, a well-optimised system to reduce emissions of NOX will also keep the CO levels down to (30 – 50 mg/Nm3 for pulverised combustion, and below 100 mg/Nm3 in the case of FBC).

Applicable Yes

Moneypoint maintains close combustion control with continuous monitoring of CO under the CEMS system. . Moneypoint is also fitted with NOx reduction, see 4.5.9 above)

4.5.11 Hydrogen fluoride (HF) and hydrogen chloride (HCl)

For combustion plants, the wet scrubber process (especially for plants with a capacity of over 100 MWth) and the spray dryer have been considered as BAT for the reduction of SO2. These techniques also give a high reduction rate for HF and HCl (98 – 99 %).

Applicable Yes

Moneypoint fitted with a dry lime FGD system known as the Circulating Fluidised Bed FGD . Dry lime is wetted to react with SOx .

4.5.12 Ammonia (NH3)

The ammonium concentration associated with the use of BAT is considered to be below 5 mg/Nm3 to

Applicable Yes

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avoid problems in the utilisation of fly ash and possibly the smell of the flue-gas in surrounding areas.

The NH3 in ash is monitored on a regular basis.

4.5.13 Water pollution

Table 4.70: BAT for waste water treatment

Regeneration of demineralisers and condensate polishers Neutralisation and sedimentation

Applicable Yes

Regeneration occurs approximately every 8,000 hours of operation Water from this process is directed to the neutralisation sump and is neutralsed recycled to the Industrial Water Storage tank (IWS) .

Condensate polisher water is also neutralised in the neutralisation sump and pumped to the IWS tank on site.

Washing of boilers, air preheaters and precipitators Neutralisation and closed loop operation, or replacement by dry cleaning methods

Applicable?? Yes

Washing of air pre heaters and precipitators can occur during plant major overhaul only with washwater directed to the ash dewatering bins and washwater recycled to the IWS tank.

– “Bang & Clean” technology using small explosives to dislodge ash and silt from the boiler wall and tubes are also used at Moneypoint

Surface run-off Sedimentations or chemical treatment

and internal re-use

Applicable Yes

Surface water from the coal yard and FGD by product landfill is directed to a purpose built lagoon to allow sedmentation to occur. Water from this lagoon is recycled to the FGD Process reduce water demand from the public mains.

Surface water from the ash storage area is collected in

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a toe drain and discharged to the ash lagoon The ash lagoon forms part of the natural drainage of the area.

Will be:

ESB Moneypoint plan to construct an additional ash settling pond which is scheduled to become operational in 2018..

4.5.14 Combustion residues

Utilisation and re-use of combustion residues is identified as the best available option for BAT and is a priority.

Applicable Yes

Moneypoint actively engages in market development for reuse of its combustion residues Moneypoint exports PFA to the cement industry from its dry silo storage areas depending on market demand.. PFA and Bottom ash has also been recovered from the ash storage area (landfill) but further use of this material is awaiting approval from the EPA.

FGD By-product on admixture with cement fly ash and water is reused on site to create a landfill liner layer for the FGD landfill, capping layer for the FGD liner and landfill embankments.

The use of FGD By-product in admixture with cement, fly ash and water will be used for embankment construction and capping layer for the ash disposal landfill development.

6.5 Best available techniques (BAT) for the combustion of

Applicable Yes

Although Moneypoint is a coal combustion plant it is capable of firing on Heavy Fuel Oil (HFO) and stores approximately 50,000 tons of HFO in two storage tanks

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liquid fuels on site.

Moneypoint also stores 600 tonnes of diesel on site to commence firing of boilers.

6.5.1 Unloading, storage and handling of fuel and additives. Coal and ignite (Dust)

Table 6.41 BAT for the unloading, storage, and handling of coal, lignite and additives

the use of liquid fuel storage systems that are contained in impervious bunds that have a capacity capable of containing 50 - 75 % of the maximum capacity of all tanks or at least the maximum volume of the biggest tank. Storage areas should be designed so that leaks from the upper portions of tanks and from delivery systems are intercepted and contained in the bund. Tank contents should be displayed and associated alarms used. The use of planned deliveries and automatic control systems can be applied to prevent the overfilling of storage tanks

Applicable Yes

HFO fuel tanks are located in a bunded area on the Moneypoint site which are impervious to HFO. The bunds have been sized to 110% the capacity of the HFO tanks.

It should be noted that HFO does not flow unless heated which reduces the risk of contamination to the estuary..

Tanks are fitted with high level fill alarms to prevent overfilling and spillage during filling operations.

Diesel tanks 2 x 300 tonnes are located in bunded areas sized to 112% capacity

pipelines placed in safe, open areas aboveground so that leaks can be detected quickly and damage from vehicles and other equipment can be prevented. If buried pipelines are used their course can be documented and marked and safe excavation systems adopted. For underground pipes, double walled type pipes with automatic control of the spacing and special construction of piping (steel pipes, welded connections and no valves in underground section etc.) are BAT

Applicable Yes

HFO pipelines are mainly located above ground on the delivery line from the jetty to the tank farm and from the tank farm to the power station. The exception to this is where the HFO lines pass under the station roads. At these two locations they are ducted through concrete culverts beneath the roads. These locations are inspected regularly to ensure integrity and no leakage.

Diesel tanks are filled from diesel tankers and pipelines

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are located above ground.

surface run-off (rainwater) that might be contaminated by any spillage of fuel from the storage and handling should be collected and treated before discharge.`

Applicable Yes

Gravity drains within the HFO tank farm drain to an internal sump via a single drain line. This has been constructed to include a sealed wall with an upstream submersible pump. Surface water within the bund can only be discharged to external drainage by manually activating the pump following inspection of the surface water.

Water in the diesel bunds is inspected for visual presence of oil. If oil is detected the water is drained and treated as n oily waste for off-site waste disposal.

6.5.1 Unloading, storage and handling of fuel and additives. Lime and Limestone

Table 6.41 BAT for the unloading, storage, and handling of coal, lignite and additives

enclosed conveyors, pneumatic transfer systems and silos with well designed, robust extraction and filtration equipment on delivery and conveyor transfer points to prevent the emission of dust.

Applicable Yes

Dry lime for the FGD process is delivered in sealed tankers and pumped into dry lime silos. It is mixed with water prior to use in the FGD process.

6.5.1 Unloading, storage and handling of fuel and additives. Pure liquefied

for handling and storage of pure liquified ammonia: pressure reservoirs for pure liquified ammonia >100 m3 should be constructed as double wall and should be located subterraneously;

Yes

Moneypoint uses ammonia for Selective Catalytic Reduction (SCR ).

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ammonia (Health and safety risk according to ammonia)

Table 6.5.1: BAT for the unloading, storage, and handling of coal, lignite and additives

reservoirs of 100 m3 and smaller should be manufactured including annealing processes

from a safety point of view, the use of an ammonia-water solution is less risky than the storage and handling of pure liquefied ammonia.

Yes

Ammonia is generated on demand in situ by thermal hydrolysis of Urea in the U2A Plant. This avoids the need to transport and store pure liquefied ammonia.

6.5.3 BAT for liquid fuel-fired boilers

6.5.3.1 Thermal efficiency

For existing plants with respect to the Unit Thermal Efficiency (net) the achievable improvement of thermal efficiency depends on the specific plant, but as an indication a level of 36 – 40 % or an incremental improvement of more than 3 % points can be seen as associated with the use of BAT

Not Applicable Yes

Moneypoint is an existing plant with units constructed in the 1980’s. It operates mainly on pulverised coal with backup potential using HFO at approximately 36-37% thermal; efficiency when at full load

6.5.3.2 Dust and heavy metals emissions

Table 6.42: BAT for dedusting off-gases from liquid fuel fired combustion plants

For existing plant BAT for dedusting requires ESP or FF in combination with FGD (wet) to achieve Dust emission levels of 5-20mg/Nm3 with continuous monitoring in place

Applicable Yes

Moneypoint originally fitted with ESP equipment but upgraded to Fabric Filters as part of the FGD Environmental Retrofit Project to achieve the required standard

6.5.3.3 SO2 emissions

Table 6.43: BAT for the prevention and

BAT for the prevention and control of sulphur dioxides from coal include use of Low sulphur fuel oil, co-combustion of gas and oil and FGD (wet) FGD (sds), Seawater scrubbing, Combined

Applicable Moneypoint has been fitted with Flue Gas Desulphurisation process using dry lime with Fabric Filters.

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control of sulphur dioxide from liquid fuel-fired combustion plants

techniques for the reduction of NOx and SO2

Continuous SO2 monitoring is in place and emission monitoring reported to the EPA.

6.5.3.4 NOX

emissions The BAT conclusion for the prevention

and control of NOX emissions and the associated emission levels are summarised in Table 6.44 of the BREF. For existing plants (> 300MWth) the applicable BAT options are Combination of Pm (such as air and fuel-staging, low NOx burner, reburning, etc.), in combination with SCR or combined techniques.

Continuous monitoring is also required.

Applicable Yes

Moneypoint fitted with Low NOx burners and with SCR

NOx is measured on a continuous basis and reported to the EPA

6.5.3.6 Carbon Monxide (CO)

BAT for the minimisation of CO emissions is complete combustion, which goes along with good furnace design, the use of high performance monitoring and process control techniques, and maintenance of the combustion system. Besides the combustion conditions, a well optimised system to reduce emissions of NOX will also keep the CO levels between 30 and 50 mg/Nm3.

Applicable Yes

Moneypoint maintain close combustion control with continuous monitoring. Moneypoint is also fitted with NOx reduction, see 4.5.9 above)

4.5.12 Ammonia (NH3)

The ammonium concentration associated with the use of BAT is considered to be below 5 mg/Nm3 to avoid problems in the utilisation of fly ash and possibly the smell of the flue-gas in surrounding areas.

Applicable Yes

The NH3 in ash is monitored on a regular basis.

6.5.3.7 Water Regeneration of demineralisers and condensate polishers Neutralisation and

Applicable Yes

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pollution

The BAT measures to avoid or to reduce emissions to water are summarised in Table 6.46.

sedimentation Regeration occurs approximately every 8,000 hours of operationThis is done on a regular basis but the station would have more information. Water from this process is directed to the neutralisation sump and is neutr;ised recycled to the Industrial Water Storage tank (IWS).

Condensate polisher water is also neutralised in the neutralisation sump and pumped to the IWS tank on site.

Surface run-off Sedimentations or chemical treatment

and internal re-use

Applicable Yes

Surface water from the coal yard and FGD by product landfill is directed to a purpose built lagoon to allow sedmentation to occur. Water from this lagoon is recycled to the FGD Process reduce water demand from the public mains.

Surface water from the ash storage area is collected in a toe drain and discharged to the ash lagoon The ash lagoon forms part of the natural drainage of the area.

Will be:

ESB Moneypoint plan to construct an additional ash settling pond which is scheduled to become operational in 2018..

6.5.3.8 Combustion residues

Utilisation and re-use of combustion residues is identified as the best available option for BAT and is a priority.

Applicable Moneypoint actively engages in market development for reuse of its combustion residues. Moneypoint exports PFA to the cement industry from its dry silo storage areas depending on market demand.. PFA and Bottom ash has also been recovered from the ash

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storage area (landfill).

FGD By-product on admixture with cement fly ash and water is reused on site to create a landfill liner layer for the FGD landfill, capping layer for the FGD liner and landfill embankments.

The use of FGD By-product in admixture with cement, fly ash and water will be used for embankment construction and capping layer for the ash disposal landfill development.

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ESB Moneypoint Environmental

Management System

Environmental Policy Manual Page 1 of 15 EMS 1 Version: 22.0 Approved: Mar 17 SMS SOP Review: 1 Year


ENVIRONMENTAL POLICY MANUAL

(EMS 1)

Prepared by:


Date Version No.

G. Noonan May 2008 14.0 (See Revision Record Sheet) J Wall Aug 2010 15.0 (See Revision Record Sheet) J Wall March 2011 15.0 C McManus Feb 2013 16.0 (See Revision Record Sheet) J Casey Nov 2013 17.0 J Casey Jun 2015 18.0 Anthony Kearney Dec 2015 19.0 Anthony Kearney Dec 2016 20.0 J Casey Feb 2017 21.0


B. Kennedy

Station Manager Moneypoint Generating Station Date: Feb 2017

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Management System


Check with the computer network to verify that this is the latest revision prior to use

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REVISION RECORD SHEET

Revision

Date

Summary

Draft 01 22nd October 1995 Issued for comment Draft 02 10th November 1995 Initial comments incorporated Revision 00 28 February 1996 Further comments incorporated Revision 01 28 August 1996 Modified Exhibits. Revision 02 1-9-97 To address the requirements of IS EN ISO

14001 Revision 03 14-7-98 Environmental Management Policy and Key

Objectives Revision 04 30-10-98 Made reference to relevant manuals at

sections 1-18. Also re addressed version numbers of manual

Revision 05 29-06-99 Modified Exhibit 2 showing EMG members Revision 06 24-09-99 Modified Exhibit 2 showing EMG Members to

agree with Intranet slide. Revision 07 10-05-00 Modified Item 12 to refer to EMS ‘instruction

type’ documentation

Revision 08 06/11/01 Revised Station Managers Signature Revision 09 14/08/02

Revised Mpt Organisation Chart (page 11 of 14)

Revision 10 11/11/02 Revised to include IPCL 605 (issued 30/10/02) Revision 11 27/05/05 Revised to include IPCL 669 ( issued 4/2/4)

and revised Policy & Key Objectives and to meet ISO 14002:2004

Revision 12 15/11/05 Revised to take account of changes required by ISO 14001: 2004

Revision 13 28/04/08 Update statement Revision 14.0 06/05/08 Revised to 14 Sections & updated. Header &

cover page revised. Section 6 revised to include Contractors Sections 9 & 11 re. single procedure. Section 11 re. lab procedures. Section 14 re. continual improvement.

Revision 15.0 04/08/10 Revised Station Managers Signature Revision 15.0 16/03/2011 Format revised Revision 16.0 28/02/2013 Biodiversity added to policy Revision 17 Revision 18 Revision 19 Revision 20 Revision 21 Revision 22

20/11/13 30/6/2015 22/12/15 10/10/2016 14/02/2017 03/03/2017

Revised Header and Title Page Updated Licence # Updated Appendix – ESB Policy Statement Minor Updates Minor Updates Update to reflect new 14001:2015 Standard

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Management System


Moneypoint Environmental Policy and Key Objectives.

Moneypoint Generating Station is part of ESB Power Generation Business Unit. It exports approximately 855 Megawatts of electricity produced from steam generation plant burning coal and /or heavy fuel oil. The station location, on the Shannon Estuary, encompasses areas of significant environmental importance. Continuous Environmental Monitoring Systems are installed on all three boilers in conjunction with monitoring stations throughout the site. These demonstrate that the operation of Moneypoint does not have a significant impact on the environment.

In Moneypoint, we believe that: The protection of the environment is an integral part of good business practice including the prevention of

pollution. We have a duty to behave as a good corporate citizen and we must produce electricity with the minimum impact

on our neighbours. We must be committed to the minimisation of waste production and to the safe and efficient recycling of the ash

produced as a product of combustion. We must produce electricity as efficiently as possible and optimise plant operation to minimise losses. We must be open in all our dealings and be responsive to the public in relation to our operations.

To this end, we will: Establish and regularly review environmental performance for our business to ensure full compliance with ESB

standards and E.U./ National legislation on the environment. Take account of environmental considerations in all planning and decision making. Review our environmental programme annually to ensure continual improvement in our environmental

performance. Operate according to IPPCL No: 605-03 and GHG permit No. GHG070-3 Develop and maintain an Environmental Management System to ISO 14001. Develop and regularly review management processes, operational procedures and audit capabilities to ensure

that the systems put in place to prevent environmental damage function effectively. Put in place systems to reduce waste production and to monitor and ensure the safe disposal of waste

produced. Put in place systems and resources to minimise the risk of environmental accidents. Draw up emergency response plans to deal with accidental pollution. Ensure that suppliers of goods and services are considerate of the environmental impact of their dealings with

Moneypoint by advising them of our environmental policy and the environmental standards required of them. Seek to actively promote environmental awareness among our staff. Provide the necessary training and support for staff on environmental matters. Publicly report on an annual basis on our environmental performance. Record and respond swiftly to all complaints on environmental matters. This policy has corporate body endorsement. ESB Moneypoint will Comply the ESB Group Environmental policy available here https://esb.ie/acting-

responsibly/environment/environmental-informationi

Signed : Brendan Kennedy Station Manager

Date :

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TABLE OF CONTENTS

Associated

Manual and Folder

I.S. EN ISO 14001:2004

Requirement Title Page

Revision Record Sheet

Moneypoint Environmental Policy Statement 4.2

Table of Contents

1. Environmental Policy EMS 1 4.1, 4.2

2. Accident Prevention Policy EMS 2 4.3.1

3. Legal Requirements

Other Requirements

EMS 3.1

EMS 3.2

4.3.2

4.5.2

4. Environmental Management Programme

EMS 4 4.3.3

5. Resources, Roles & Responsibilities EMS 5 4.4.1

6. Training, Awareness and Competence EMS 6 4.4.2

7. Communications EMS 7 4.4.3

8. Document & Record Control EMS 8 4.4.4, 4.4.5, 4.5.4

9. Operational Control EMS 9 4.4.6

10. Emergency Preparedness and Response

EMS 10 4.4.7

11. Performance Monitoring and Measurement

EMS 11 4.5.1, 4.5.2

12. Non-conformance, Preventive and Corrective Action

EMS 12 4.5.3

13. Environmental Management System Audits

EMS 13 4.5.5

14. Management Review EMS 14 4.6

Appendix 1 Corporate ESB Environmental Policy

4.2

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1. Environmental Management System Policy

The Environmental Management System of ESB Moneypoint Generating Station is as stated in this Policy Manual (EMS 1). This Manual is divided into 14 separate Sections, each of which has a corresponding Folder EMS 1 to EMS 14 on the controlled document system. These Folders are in turn broken down into Sub-folders. Management and control of the EMS documentation is through the documentation system controlled by the Environmental Co-ordinator.

The policies outlined in this Manual are implemented through documented

procedures and the following subsidiary Manuals held in their respective Folders on the computer system:

EMS 1 Policy Manual

EMS 2 Accident Prevention Policy EMS 3 Legal and Other Requirements EMS 4 Environmental Programme Manual EMS 5 Resources, Roles & Responsibilities EMS 6 Training, Awareness & Competence EMS 7 Communications EMS 8 Document and Record Management EMS 9 Operational Control EMS 10 Emergency Preparedness & Response EMS 11 Performance Monitoring & Measurement

EMS 12 Non-conformance, Preventive and Corrective Action EMS 13 EMS Audits EMS 14 Management Review

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Management System


The station's policy and commitment to environmental protection are laid down in its Environmental Policy Statement contained in this Policy Manual. This station policy has been drawn up with reference to the Corporate ESB environmental policy statement, attached as Appendix 1. It has a positive programme to further improve its environmental performance.

The Environmental Policy Statement applies to all staff at Moneypoint. To ensure

that it is understood, implemented and maintained at all levels within the station, a copy has been issued to each member of staff and controlled copies of this Manual are also available for inspection.

Copies of the policy are displayed throughout the station including areas accessible

to the public. Copies of the policy are also available to the public on request. Contractors will also be made aware of the pertinent sections of the Environmental

Policy that are applicable to them.

This Environmental Policy Manual EMS 1 is contained in EMS 1 Sub-folder 1.1 2. Accident Prevention Policy (Register of Environmental Aspects) A review ‘the General Review’ of the environmental aspects and present

environmentally related activities at Moneypoint was carried out and was approved by the Station Manager. This review was carried out to identify the current position of the environmental aspects of its activities. The report of the general review is a confidential document but is available for examination on a confidential basis by

EMS 10: Emergency Preparedness and Response

EMS 5: Roles and Responsibilities

EMS 9: Operational Control

EMS 8: Document and Record Management

EMS 6: Training, Awareness & Competence

EMS 7: Communications

IMPLEMENTATION AND OPERATION

EMS 2: Accident Prevention Policy

EMS 3: Legal and Other Requirements

EMS 4: Environmental Programme Manual

PLANNING

EMS 11: Performance Measurement and Monitoring

EMS 12: Non-conformances & Corrective Actions

EMS 13: Audit

CHECKING AND CORRECTIVE ACTION

EMS 14: Management Review

MANAGEMENT REVIEW

POLICY

EMS 1: Policy Manual

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Management System


approved interested parties with the approval of the Station Manager. As a follow-on from this review, environmental aspects were identified and their significance assessed. An Accident Prevention Policy (Register of Environmental Aspects) (EMS 2) is maintained and is reviewed in the light of other information available from sources such as regulatory changes, trade magazines, industry related scientific journals, environmental publications, etc., or from ESB Power Generation Safety, Engineering & Environment (PG SEE). The policy is updated as necessary under the responsibility of the Environmental Co-ordinator.

The introduction of new plant and modifications to existing plant are reviewed for

their potential impacts on the environment.

This Accident Prevention Policy Manual EMS 2 is contained in Folder EMS 2.1 3. Legal and other Requirements

Identification and access to legal requirements for the station is a service provided by PG SEE, who commission ESB International (ESBI) to carry out work annually. ESBI then notify the Environmental Co-ordinator of relevant changes. PG SEE provides regular updates to the station on changes to regulatory requirements. A Register of Legislation (EMS 3.1) is maintained at the station. This Register of Legislation EMS 3.1 is contained in EMS 3 Sub-folder 3.1 Other legal requirements include the Integrated Pollution, Prevention and Control Licence and Greenhouse Gas Permit issued by the EPA and planning conditions (of environmental relevance) which are issued by the relevant regulatory authorities. These are included in the Register of Licences and Permits (EMS 3.2). The Environmental Co-ordinator is responsible for ensuring this register is kept up to date. This Register of Licences and Permits EMS 3.2 is contained in EMS 3 Sub-folder 3.2

Compliance with legislation and requirements is carried out in accordance with a documented procedure. This Procedure EMS 3.3-01 is contained in EMS 3 Sub-folder 3.3

4. Objectives, Targets and Environmental Management Programme

Objectives and Targets are identified following a review of the station’s significant environmental impacts. The objectives and targets are consistent with the station’s environmental policy including the commitment to the prevention of pollution and continual improvement. They are detailed in the combined Safety and Environmental Improvement Plan (SMS 4). http://gen.esb.ie/sc/mp/safety/scd/SitePages/Home.aspx These are drawn up taking into account appropriate technical options and the financial and technical constraints under which the station is required to operate.

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The separate elements to be achieved by the various departments and sections within the station are identified and are communicated to all concerned. The resources necessary to achieve the stated targets are included in the station's Business Plan and in the annual budget. The views of interested parties, where appropriate, are considered in the setting of these objectives and targets. Where new developments or modified activities take place at the station, the environmental programme is reviewed and amended where relevant and appropriate.

The EIP incorporates:

the current objectives and targets, including continual improvement targets; the people responsible for their achievement; the time schedule and mechanism for their achievement.

Progress towards achieving the stated objectives and targets is monitored regularly

through the Environmental Management Group and is reported upon quarterly to the Station Manager. Objectives and targets are reviewed by the Environmental Management Group as appropriate and are reset as necessary. The above is carried out in accordance with a documented procedure.

This Procedure EMS 4.2-01 is contained in EMS 4 Sub-folder 4.2

5. Resources, Roles and Responsibility Roles in Moneypoint are shown in the station’s organisation chart contained in Sub-

Folder 5.1. In the absence of the job holder the relevant manager or subordinate will undertake the assigned duties or delegate as required.

The Station Manager has overall responsibility for: the definition and implementation of the station's environmental policy, the level of environmental management the station achieves, the availability of trained and capable staff to manage, perform and verify work

affecting the environment. Line managers are responsible for:

organising and managing personnel reporting to them. management of contractors.

ensuring that the requirements of the Environmental Management System as detailed in this Policy Manual is implemented and maintained in their area of responsibility.

All staff have responsibility for ensuring that they carry out their tasks and duties

according to the station’s environmental policy and in accordance with documented procedures.

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Management System


The Environmental Co-ordinator is the station’s management representative responsible to the Station Manager for the detailed development and implementation of the Environmental Management System and co-ordination of its operation. He/she reports to the station manger on the performance of the environmental management system.

Moneypoint's organisation chart is contained in EMS 5 Sub-Folder 5.1

The Environmental Management Group (EMG) supports the Environmental Co-

ordinator in fulfilling these duties.

The list of EMG members is contained in EMS 5 Sub-folder 5.2

The EMG is operated in accordance with a documented procedure. This procedure EMS 5.3-01 is contained in EMS 5 Sub-folder 5.3 The roles and responsibilities are outlined in SMS 5.2.2 – see http://gen.esb.ie/sc/mp/safety/scd/Standardu20Documents/SMS%205.2.2%20Safety%20Org%20Roles%20and%20Resp.doc

6. Training, Awareness and Competence Moneypoint is committed to ensuring that there is environmental awareness

amongst all staff at the station. It provides training for all personnel in environmental aspects of their work and maintains records of each staff member's training. Staff shall have the appropriate level of qualification and training.

Contractors working on behalf of Moneypoint shall demonstrate that their employees

have the requisite competence and training. Contractors shall be briefed on the environmental issues as part of the site induction process.

The above activities are carried out in accordance with a documented procedure.

This procedure EMS 6.1-01 is contained in EMS 6 Sub-folder 6.1

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Management System


7. Communications The operation of the environmental management system is discussed at

management meetings and team briefing sessions within the station. Periodic reports on developments or trends in the station's environmental

performance are presented to staff within the station. The station maintains open communications on all matters relating to the

environment with all statutory bodies charged with regulation of activities at Moneypoint in accordance with a documented procedure.


All complaints and other communications from parties outside of the station are dealt

with in accordance with a documented procedure.

This procedure EMS 7.1-02 is contained in EMS 7 Sub-folder 7.1 The station shall communicate appropriately on its significant environmental impacts.

It determines the level of communication with external interested parties regarding its environmental performance on a case by case basis.

Reporting to the Environmental Protection Agency (EPA) and other regulatory

bodies is carried out in accordance with documented procedures.

These procedures are contained in EMS 7 Sub-folder 7.1 and EMS 11 Sub-folder 11.1

8. Environmental Management System Documentation This Policy Manual provides direction to the documentation related to the

Moneypoint Environmental Management System and Integrated Pollution Control Licence. The subsidiary manuals which form part of the system are listed in Section 1 of this manual. Together these manuals form the core of the EMS documentation. All of the manuals referred to in Section 1 are controlled in accordance with a document control procedure.

This procedure EMS 8.1-01 is contained in EMS 8 Sub-folder 8.1 These controlled documents are approved by the appropriate person identified in the relevant document and are available to all staff that require their use in the course of activities undertaken. Documents are confidential to the station but are available for examination on a confidential basis by approved interested parties as authorised by the Station Manager.

Records are generated and maintained as an inherent part of the ordinary operations of the station. Appropriate records are maintained to demonstrate the achievement of the required environmental control, the effective operation of the Environmental Management System and progress towards the environmental

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objectives and targets. Records are maintained according to a documented procedure.

This procedure EMS 8.1-02 is contained in EMS 8 Sub-folder 8.1 Relevant records are available for examination on a confidential basis by approved interested parties as authorised by the Station Manager. Environmental Management Procedures are produced in accordance with a documented procedure. This procedure EMS 8.1-03 is contained in EMS 8 Sub-folder 8.1

9. Operational Control The functions, activities and processes at Moneypoint that have or could have, if

uncontrolled, a significant direct or indirect impact on the environment are carried out in accordance with documented procedures. EMS instruction type documentation at the station including environmental operation instructions, standards and guidelines and preventive maintenance policy schedules are reviewed to ensure any environmental aspect of the operations have been adequately addressed to meet the requirements of this manual. This review is carried out in accordance with a documented procedure.

All equipment whose satisfactory functioning is necessary for good environmental

performance is adequately maintained and the station's Computerised Maintenance Management System is used in this regard.

Documented procedures are followed to ensure that suppliers and contractors

comply with the stated environmental policy requirements.

These procedures EMS 9.1-01 to EMS 9.1-23 are contained in EMS 9 Sub-folder 9.1

Waste is managed in accordance with a documented waste procedure.

This procedure EMS 9.2-01 is contained in EMS 9 Sub-folder 9.2 10 Emergency Preparedness and Response

ESB Power Generation, over the years, has developed an Environmental Emergency Response Procedure for all the identified major accident and emergency situations.


As part of the annual review and prior to the introduction of new activities at the station all potential accident and emergency situations are identified and where

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necessary appropriate revisions are made to the Environmental Emergency Response Procedure. This emergency procedure is tested where practicable. Reference Data containing details of the environmental aspects of the station and plans showing the plant layout, oil, chemical and waste storage, and drainage and fire fighting systems are contained in EMS 10 Sub-folder 10.2. The Reference Data Manual EMS 10 is contained in EMS 10 Sub-folder 10.2

11. Performance Monitoring and Measurement

Laboratory procedures relating to environmental testing are also maintained and implemented. These procedures are numbered and filed by the Chemical Section.

Source References for these procedures are contained in EMS 11 Sub-folder 11.1.

Documented procedures are maintained to monitor and measure on a regular basis those aspects that can have a significant impact on the Environment. Information on the station’s emissions to air, discharges to water, noise emissions and waste generated is recorded, so that performance on these issues can be tracked.

Inspection, measuring and test equipment is controlled, calibrated and maintained in accordance with a documented procedure to ensure the accuracy and precision necessary. Appropriate records are held as necessary.

It is the responsibility of individual members of staff at Moneypoint to ensure that portable equipment and instrumentation associated with environmental monitoring, in use by them, are within their calibration dates.

These procedures EMS 11.2-01 to EMS 11.2-18 are contained in EMS 11 Sub-folder 11.2

12. Non-conformance, Preventive and Corrective Action

A documented procedure for dealing with non-conformances and corrective action is in operation at the station. The Environmental Co-ordinator is informed of all significant non-conformances. He/she reviews these non-conformances and following consultation with the relevant manager concerned may decide to investigate further. As a result of the investigation, he/she may propose further corrective action to be taken. This may include documented review of relevant procedures if appropriate. Any corrective or preventive action taken shall be appropriate to the scale of the problem and the degree of environmental impact encountered. This procedure EMS 12.1-01 is contained in EMS 12 Sub-folder 12.1

13. Environmental Management System Audits

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An internal audit of all aspects of the Environmental Management System is carried out to evaluate the effectiveness of the system. An internal audit manual (EMS 13) describes in detail the approach to internal auditing, the audit programme, and the corrective action process. The audit programme is the responsibility of the Environmental Co-ordinator.

This Internal Audit Manual EMS 13 is contained in EMS 13 Sub-folder 13.1

14. Management Review

An internal management review of the Environmental Management System is conducted annually to ascertain the status, effectiveness and adequacy of the system in the light of the conditions prevailing and opportunities for continual improvement. The review is carried out in accordance with a documented procedure containing an agenda in accordance with ISO 14001:2004.


APPENDIX 1

ESB ENVIRONMENTAL POLICY At ESB we are committed to the highest levels of environmental management and sustainability in all aspects of our operations and we commit to leadership in carbon management and energy efficiency. Under this policy we commit to

• Adopting appropriate management structures, management systems and targets to manage sustainability and environmental issues

• Complying with all regulatory, planning and environmental legislation pertaining to our business activities

• Conducting our activities and those of our subsidiary companies in an environmentally responsible manner

• Developing and maintaining effective environmental management systems suitably certified to the requirements of ISO14001

• Acting responsibly in our use of national environmental resources • Contributing to environmental and sustainable policy development at national and EU level • Maximising energy efficiency and conservation in all our activities and encouraging our

customers and suppliers to use our natural resources in a prudent and efficient manner • Identifying the environmental impacts associated with our activities and managing them

appropriately • Identifying and managing significant environmental risks and having emergency response

plans in place • Reducing our internal CO2 carbon footprint by improving the energy efficiency of our

buildings, reducing fuel used in our vehicle fleet and promoting sustainable travel for staff • Reducing water usage, reduce waste streams and increase re- use and recycling in all of

our locations • Minimising the production of all waste as far as practicable and disposing of all residual

wastes in a safe responsible and legislatively compliant manner • Assessing the impact of our operations on biodiversity and reviewing potential opportunities

for enhancement in line with the Biodiversity Policy • Regularly auditing our operations to ensure compliance with relevant legislation

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• Striving for continuous improvement in Environmental and Sustainability performance through setting challenging internal targets and objectives in order to promote efficient use of resources and environmental awareness

• Engaging with our staff to promote environmental awareness and sustainability in the workplace, in the community and in the home

• Working with staff and suppliers to embed sustainability considerations into our procurement activities as well as in our investment and expenditure decisions

• Ensuring all new ESB Buildings will be built to best sustainable standards • Openly reporting on our environmental performance in a verifiable way and communicating

progress against environmental and sustainability targets on an annual basis • Communicating this policy to our staff, suppliers, contractors, partners and customers, with

the aim of ensuring increased awareness and encouraging environmentally sustainable behaviour

• Liaising with external organisations and stakeholders to promote good environmental and sustainable business practices.

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Procedure for Monitoring Efficiency & Energy Usage

Page 1 of 3

EMS 11.2 Version: 4.0 Approved: July 2015

SMS SOP Review: 3 yearly


Procedure For Monitoring Efficiency & Energy Usage

(EMS 11.2-04)

Prepared by:


Date Version No.

G. Noonan May 2008 2.0 (Renumbered, cover page & header revised.) J Wall March 201 3.0 ( Revised and format updated) A Kearney July 2015 4.0 Reviewed and revised as required. Section 4.2 upda


J Casey

Station Chemist/Environmental Co-ordinator Moneypoint Generating Station Date: July 2015

Check with the computer system to verify that this is the latest revision prior to use

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Page 2 of 3



1.0 Purpose

The purpose of this procedure is to ensure that Moneypoint Generation Station endeavours to manage efficiently, energy usage by frequent monitoring of all aspects of the station as per Weekly Efficiency Report prepared by Technical Services.

2.0 Scope

The total electrical energy used at Moneypoint Generation Station. Reference should be made to the Weekly Efficiency Report Folder held by the Operations Manager

3.0 Responsibility

Operations Manager Fuel and Ash Manager. Shift Manager Technical Services Manager

4.0 Procedure. 1. The Technical services department provides a weekly efficiency report on house load

expended versus the target house load. 2. The weekly efficiency report is discussed at the weekly Production Metting normally held

at 12:00 Tuesday. Managers and supervisors attend the meeting as required. 3. Variations in the ratio of target ÷ actual less than one are discussed, investigated and

accounted for with respect to station figures in the report. 4. Controllable losses are reviewed. This includes:

Mills in service, Operating efficiency direct and indirect, (See Weekly Efficiency Report for Detail).

5. Any major variations should be noted and investigated. (Consideration should be

given for variations due to, run ups, shutdowns or trips) 6. Where instrumentation drift / error is suspected or identified by the shift manager or his /

any staff this should be documented and the necessary job cards issued to the relevant department.

7. The operations manager keeps record of meetings. Note:

National Grid “NCC” provides MV90 meters for metering purposes and these agree with station integrators.

Corrective Action.

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Management System


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Job requests are issued through the Computer Maintenance Management System (CMMS) and may be issued by Shift Manager, supervisors and staff.

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