€ s * Power Generation

Electricity Supply Board Poolbeg Generating Station, Pigeon House Road, Dublin 4, Ireland. Phone: 353-1-668 5300 Fax: 353-1 -668 5545

I Website: www.esb.ie

. . . . . . . . . . . .

Electricity Supply Board Bothair Thig Choluirn, Baile Atha Cliath 4, Eire. Fon: 353- 1-668 5300 Facs: 353- 1-668 5545

Eithrehn Greashin: www.esb.ie

EPA Office of Climate Change, Licensing and Resource Use PO Box 3000 Johnstown Castle Estate Co. Wexford

Re: Technical Amendment to IPPC Licence Reg. No. 577- 02 Schedule 2(i) Emissions to Water

20th November 2008

Dear Sir/Madam

Under Clause 96 of the Protection of the Environment Act 2003, ESB would like to apply to the Agency for a Technical Amendment of the above licence for Poolbeg Generating Station.

The amendment is requireld to Schedule 2(i) Emissions to Water, Emission Point Reference No. SW2, Water treaihnent neutralisation tank - Units 1 ,2 and 3, Ammonia ELVs.

The proposed amendment to the licence conditions are outlined in the attached.

Regards,

Service Manager

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EPA Export 26-07-2013:11:34:25

Plool beg Power Station

IPPCL Technical Amendment Application (Reg. Ref. 577-02)

Year Ammonium Hydroxide 35%

2004 8 - 2005 9 - 2006 6 2007 3 - 2008 2(YTD)

m3

Introduction

Modification is requested to Schedule 2(i) Emissions to 0. SW2- Water Treatment Neutralisation tank - Units 1, 2

The following changes to Ammonia ELVs are requested;

Ammonia (as N): daily 350 mg!l, mass 70 kg/day.

Current ELV - Ammonia (as N): daily 100mg/l, mass 20 kg/day

ESB are requesting a technical amendment due to difficulties in adhering to the current licence ELVs.

No. Polisher Regens Running Load Factor

No. % 31 62 28 61 30 65 15 60

9(YTD) 55( YTD)

ESB has been in contact with the C)EE on this matter previously (1 1/12/06, 13/07/07 and 15/05/08) and has now been advised to contact the Office of Climate Change, Licensing and Resource Use, for a Technical Amendment (EPA Ref. P0577-02/gc14kf). A copy of all previous correspondence on this matter is attached in Appendix 2.

Background

Ammonia in Power Plants

Ammonia is used for corrosion control in the steam/ water circuit of power plants. Corrosion in boiler tubes leads to boiler tube kaks or possible tube ruptures with consequential safety implications to personnel ancl plant. Ammonia is injected into the boiler feedwater and circulates in both steam and water in order to achieve a suitable alkaline pH which will minimise the extent of corrosion ori the ferrous material in the steam/water circuit. A volatile alkalising agent is required and it is international practice to use Ammonia in high pressure/temperature plants, there being no other chemical as effective available.

Contaminant ions are highly ccirrosive in high pressure steam plant. A 'Condensate Polisher Plant' (CPP) is an essential itern of plant used in high pressure steam/water cycles. The CPP strips or 'polishes' the condensed water in the plant cycle of all contaminant ions such as Na, CI and SO4, however, the ammonia used for corrosion control is also stripped from the water. Once exhausted, the resin units used in a CPP are required to be regenerated, a process which occurs at intervals of 20 to 215 days. In the regeneration process Ammonia is stripped from the resin and discharged to the Water Treatment Plant (WTP) neutralisation sump with other effluent from the WTP.

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‘ I ‘

Generating Station

ESB Aghada ESB Great Island ESB Tarbert Synergen Ringsend ESB Poolbeg

Load factors will reduce further again in 2009, and closure of the Thermal Station as per CER-ESB agreement is scheduled for early 201 0.

The current license parameters relate to a continuous process where quarterly grab samples are taken. However this fails to reflect that CPP regeneration is a “batch” process which occurs on an infrequent basis.

Since June 2006 ESB has been rnonitoring ammonia levels from the water treatment plant discharges immediately following regeneration of a CPP (Appendix 1). These indicate the ESB’s inability to routinely remain within the license conditions during these “batch” regeneration periods. However, it !should be noted that the average daily discharges outside regeneration periods are well within limits.

Justification for amendment to €LVs

IPlPcL Parameter Emission Limit Value Reg. No. mgll kglday PO561-04 Ammonia 300 80 P0606-02 Ammonia nla 34 P0607-02 Ammonia (as N) nla 100

P0577-02 Ammonia (as N) 100 20 P0486-01 Ammonia (as N) 500 30

Considering the worst case discharge of 61 kg/day of ammonia and with only 15 regenerations through tile year this equates to an annual discharge of only 915 kg. This is well within a permissible yearly Licence limit of 7300 kg.

The actual consumption of Ammonia has also been dropping over the last few years as a direct reflection of load factor. From the table above only 3 m3 of ammonium hydroxide was consumed last year and 2 m3 to date in 2008.

The theoretical maximirm Ammonia that U1 and 2 polisher resins are designed to absorb and therefore ccluld discharge during regeneration is 112kg. This is calculated from condensate polisher resin manufacturers’ product data. Assuming 15 polishers through the year this equates to maximum annual discharge of only 1680kg. This is well under the permissible yearly licence limit is 7300 kg. However in practice a polisher is never fully e:xhausted when it is regenerated so this figure could never be reached.

The amount of ammonia discharged from Poolbeg is a small fraction of the expected annual discharge of ammonia from the Ringsend wastewater treatment plant at the same discharge point.

Other Power Station IF’PC Licences

While it is realised that ELVs for the different power stations take account of particular local situations, nevertheless it does appear that the Poolbeg ELVs are unduly restrictive.

Ammonia removal technology

ESB has enquired from industry experts abroad as to the possibility of the removal of ammonia from the effluent by e.g. steam stripping. The information is that such removal of ammonia is only feasible for power stations that use DENOX (nitrogen oxide removal) technology, as the condensation and concentration of ammonia is very cost intensive.

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In the context of a power station with limited remnant life, major expenditure on ammonia removal technology, assuming it were feasible, could not be justified.

Environmental Impacit

While dilution is not the solution it is an important consideration to take into account when assessing the impact on the exterrtal environment. The discharge from SW2 is pumped to the Cooling Water channel before the combined effluent from the station enters the external environment. The nominal flow rate of Cooling Water is 52,500m3 per hour, before being discharged into the river Liffoy along a 200m ouFall channel. For example (Appendix 1, 03/05/07) at a concentration of318 mg/l and 125 m /hr in the WTP discharge, this equates to 0.76 mg/l in the Cooling water outfall.

Summary

The current IPPC Licence SW;! - water treatment neutralisation tank emission limit values for ammonia are proving onerous to ESB and on occasion impossible to meet. Discharge of ammonia from SW2 is not consistent on a daily basis but peaks during a polisher regeneration discharge which occurs approximately once a month depending on running regime.

0 There would be no significant Einvironmental impact resulting from the requested increase to the ELVs.

e The reduced operation of Poolbeg power station Units 1, 2 and 3 will reduce the number of condensate polisher regenerations (i.e. ammonia discharges) to a fraction of those heretofore.

0 ESB discharges of ammonia at this location are a small fraction of those arising from the Dublin City Council Ringserid wastewater treatment plant discharges.

e The discrepancy between the Poolbeg power station ELVs and the ELVs for other power stations appear anomalous.

0 Removal of ammonia by e.g. steam stripping would be ,impractical and prohibitively expensive, especially in the context of the remnant station life.

0 ESB wish to amend the daily and kglday licence limit, but do not wish to amend the yearly Ammonia mass discharge figure.

Conclusion

In view of the reasons as surnmeirised above, ESB considers that the current ELVs are restrictive, produce no environmental benefit, and that attempting to achieve same, even if possible, would be unnecessarrly e:lcpensive in the light of the anticipated low load operation and closure over the next few years.

ESB would appreciate if the Agency would consider ESB’s request for a technical amendment to the ELVs as per the following table.

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. ............ ... ..... .~ ......... ............ ...... .

Hourly (mgll)

900 Suspended Solids

Ammonia (as N)

Emission Point Reference No.:

Name of Receiving Waters:

SW2 -Water treatment neutralisation tank - Units 1, 2 and 3.

Liffey Estuary (Cooling water outfall - via Station Drain)

Daily (mgll) Kglday

320 128

Location: 32090E, 23379N

Volume to be emitted: Maximum in any one day:

Maximum rate per hour:

400 m3

250 m3

6-9 I

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Appendix 1 : Historical Ammonia Analysis at SW2 following polisher regeneration.

1 Date Concentration Daily Mass

Volumelhr Ammonia Ammonia 1 Volume m3 y / s + - y = j 2006

2007

23/04/2007

30/04/2007

03/05/2007

I 16/06/06 1 96 I195 I162 I 1 9 I

101 61

56

32

323

289

31 8 125

179

~19/10/2007 I117 1 Lil

2611 0/2007 324

160 20

71 16

1 01/08/2007 1 252 1 131 I103 I 33 I

13/12/2007

2008

07/02/2008

, 128 20'1 I00 26

228 IT:? 79 30

I 12/12/2007 I 243 I 174 I 121 1 42 I

162

204 IO4 126

59 29

64 27 76 23

122 18

I 19/02/2008 1 93 I 185 I111 I 1 7 I

It should be noted that the average daily discharges outside regeneration periods are well within limits.

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Appendix 2: Previous conrespondence with the Agency.

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Power Generation

Electricity Supply Board Poolbeg Generating Station, Pigeon House Road, Dublin 4, Ireland. Bothar Thig Choluim, Baile Atha Cliath 4, Eire. Phone: 353-1 -668 5300 Fax: 353-1-660 5545 Website: www.esb.ie

1 \

EastlNotth East Region Office of Environmental Enforcement Environmental Protection Agency McCumiskey House Richview Clonskeagh road, Dublin 14.

11/12/06

AM: Anne Pearsomr

Ref.:

Re: Ammonia at SVY2

Licence Rogister PO- 577 - 02 - ESB Poolbeg Generating Station

Dear Anne,

Previously on 26/4/06, following analysis of quarterly grab samples, ESB reported to the EPA that the Ammonia\ concentration at SW2 (Water Treatment Plant Neutralisation) exceeded the limit. At the time an un-usual plant operation had taken place where two condensate polishers were regenerated simultaneously. However as this was the second reported exceedence in two years, (1 st exceedence 4 3 2004), a programme was piit in place to monitor the discharge at SW2 for ammonia following the regeneration of each polisher.

The following results have h e n obtained to date: Concent. Volume VolA-Ir WdaY

16th. June 961mg/l 195m3 162m3 18.7kg 4th. Sept 8 0 m g 248m3 78m3 19.8kg 27th. Sept 106mg/I 22 1 m3 127m3h 13.5kg 28th. Sept 222rnd 179m3 5 1 m 3 h 40.0kg

Our ELV for Ammonia at SW2 is 100mg/I and 20kg per day.

As you can see the number of regenerations are relatively infrequent, approximately 25 per annum. However, following the regeneration of a polisher, on both the instantaneous samples and ammonia flow per day we are close to or exceeding out license limits.

The primary mitigation factor- is frequency of polisher regeneration oPeration and

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1 ’ Power Generation 1 ’ Power Generation

Electricity Supply Board Poolbeg Generating Station, Pigeon House Road, Dublin 4, Ireland. Bothar Thig Choluim, Baile Atha Cliath 4, cire. Phone: 353- 1-668 5300 Fax: 353-1 -668 5545 INebsite: www.esb.ie

The annual discharge ofammonia fiom SW2 is of the order of 600kg based on this years polisher regenerations to date. Put in the context of a daily discharge allowance of 20kg/day, averaged over the year this figure is not excessive.

In addition I would like to draw you attention to differences in license limits between similar stations with similar plant. Other plant with smaller units have higher ELV’s.

This note is merely to keep you informed of the status in relation to the issue. The issue is being discussed ~xnbrally and a submission is intended to be proposed fiom head ofice to address this and other licensing issues. In due course Poolbeg may look for an alteration to its Iic~znse parameters.

Regards, Ronan 0 Gadhra

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Ammonia in Power Plants; Ammonia is used for corrcsion control in the s tead water circuit of power plants. Corrosion in boiler tubes leads; to boiler tube leaks or possible tube ruptures with consequential safety implications to personnel and plant. Ammonia is injected into thle boiler feedwater and circulates in both steam and water to achieve a suitable alkaline pH to minimise the extent of corrosion on the ferrous material in the steadwater circuit. A volatile alkalising agent is required and it is international practice to use h m o n i a in high pressure/temperature plants there being no other alternative as effective available.

- - - ~ ~ s ~ e ~ ~ ~ i s ~ e ~ ~ I i ~ 7 ~ P ) - i ~ ~ e ~ l item of G n t used in high pressure steadwater cycles. The CPP strips or ‘polishes’ the condensed water in the

- I_

__

EasVNorth East Region Ofice of Environmental Enforcement Environmental Protection Agency McCumiskey House Richview Clonskeagh Road, Dublin 14.

13’ July 2007

Attn: Ruth Barrllngton

Ref.:

Re: Ammonia iPt S\N2

Licence Regisiter PO- 577 - 02 - ESB Poolbeg Generating Station

Dear Ruth,

Please see enclosed relating tcl Ammonia discharges at SW2.

Introduction I

The Agency’s Audit report for ESB Poolbeg Power Station, dated 15th January 2007 refers. Audit Observation 5 re:lates to Monitoring of Emissions to Water and includes a corrective action which( requires ESB to inform the Agency as to what further actions are being taken in relation to Ammonia emissions from the Water Treatment Plant (WTP) Neutralisation discharge point S W2.

As previously indicated in letter dated 1 lth December 2006 ESB Poolbeg now wishes to request an amendment to Schedule 2 (i) Emissions to Water, Emission Point Reference No. SW2, Ammonia Concentration ELV as is permitted under condition 12.5 of our IPPC license. The submission is outlined below.

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plant cycle of all contaminant ions such as Na, C1 and SO,, (Ammonia used for corrosion control is also stripped from the water). Contaminant ions are highly corrosive in high pressure steam plant. Once exhausted the resin units used in a CPP require to be regenerated, a ~irocess which occurs at intervals of 20 to 25 days. In the regeneration process Ammonia is stripped from the resin and discharged to the WTP neutralisation sump with othtx effluent from the WTP.

Date

ELV 23rdApril 7 30m April 07 3rd May 07

It is not possible to carry out the regeneration procedure of the CPP without discharging Ammonia and it is not feasible to strip the Ammonia from the effluent since it contains traces amounts of Caustic, Sulphuric Acid and Sodium Chloride solutions.

Concentration - Volume VoVHr DailyMass ' mgA - m3 m3 /hr kglday 100 400 250 20 323 189 101 61 289 196 21.5 56 318 100 125 32

- -

Analysis of SW2 to-date As reported on 1 lth December 2006 ESB Poolbeg has been carrying out a review of

its discharge of Ammonia froin emission point SW2. Poolbeg IPPCL requires that the station report quarterly on Ammonia concentration from grab samples at SW2. On 26th April 2006 ESB Poolbeg reported to the EPA that the Ammonia concentration ai SW'2 exceeded the licence limit. At the time an unusual plant operation had taken place where two condensate polishers were regenerated simultaneously. However as h i s was the second reported exceedence in two years, (lst exceedence 4 3 2004) a progr,amme was put in place to monitor the discharge at SW2 for Ammonia following i:he regeneration of each polisher. On 1 lth December 2006 the following results were submitted to the EPA:

I Date

ELV 16th. June06 4th. Sept 06 27th. Sept 06 28th. Sept 06

Since then the following analysis has been carried OUt:(Note ui was not available between 30" Sept 2006 and 4" April 2007, U2 was not available between 24"' October 2006 and 23" Jan 2007. As a new regeneration system was being installed the first regenerations were carried o U ~ in late April).

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3. While dilution is not the solution it is an important consideration to take into account when assessing, the impact on the external environment. The discharge from SW2 is pumped to the Cooling Water outfall before the combined effluent from the station enters the external environment. The nominal flow rate of Cooling Water is 52,500m3 per hour, before being discharged into the river Liffey along a 2001m outfall channel. At a concentration of 3 18 mg/l and 125 m3/hr in the WIT discharge this equates to a dilution of 0.75 mg4 in the c w ___-----

- U&---- ')e

Year

2004 2005 2006 2007

The more recent figures clearly indicate that we are unable to stay within these license parameters during polisher discharges. However the average daily discharges outside regeneration periods are well within limits. (See quarterly grab sample reports).

No. Polisher Regens Ammonia Running Load Factor - Consumed

- 31 8 62% - 28 9 61% 30 6 65%

- No. In3 Y O

2 @D) 1 (YTD)

Justification for amendment to License Parameters

1. As can be setm the number of regenerations are relatively infrequent, approximately 30 per annum. This number will reduce as the unit running Load Factor is set to reduce from 60% to approximately 20% in the coming years. (Load Factor is the percentage of hours the unit runs as a proportion of the yearly total hours). Considering the worst case discharge of 61kg and with 30 polishers through the year this equates to an annual discharge of only 1830kg. This is well under the permissible yearly licence limit of 7300 kg. (20 kg by 365 days).

The consumptior\ of Ammonia has been dropping over the years as a direct reflection of load! factor. Based on 2006 quantities, if all 6 m3 of Ammonia were discharged at SW2 this would equate to a daily discharge of 16.4kg. This is reflected in our daily license limit of 20kdday. However unfortunately the discharges are noit spread evenly through out the year but rather spike when a polisher is regenerated

$

2. The theoretical maximum Ammonia that U1 and 2 polisher resins are designed to absorb and therefore could discharge during regeneration is 1 12kg. This is calculated from condensate polisher resin manufacturers' product data. Assuming 30 polishers through the year this equates to maximum annual discharge of only 3360 kg. This is well under the permissible yearly licence limit is 7300 kg. H'owwer in effect a polisher is never fully exhausted when it is regenerated so this figure could never be reached.

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EPA Export 26-07-2013:11:34:25

4. ESB Poolbeg would like to draw you attention to differences in license limits between similar stations with similar plant. For example: Aghada, which discharges into a similar estuarine aquifer, has only one 270MW plant with limits of 300mg/l and 80kglday. Synergen an independent power station upriver of Poolbeg has limits of 500mgll and ii maximum discharge rate of 50 m3h.. With their CW flow rate of 28800 m3/hr. tihis equates to a potential dilution of 0.86mgll.

Current ELV Proposed ELV

Submission: It is not possible to cany out the regeneration procedure of a polisher without discharging Atnmoniii and it is not feasible to remove the Ammonia from the WTP neutralisation solution. Every effort has been made to reduce the consumption of Ammonia in the cycle process and there are no feasible alternative alkalising agent. Discharge of Ammonia from SW2 is not consistent on a daily basis but peaks during regeneration of polishcrs which occurs approximately every 20 -25 days depending on running regime. Disclharges at the final emission point from the site remain well within the drinking water gpidelines for Ammonia.

-.. Daily Maximum Maximum Maximum Maximum

Concentralion -. , Daily Volume VoVHr Daily Mass Yearly Mass mgh -- m3 m3 /hr kgfday kglyear 100 400 250 20 7300

350 400 250 70 7300 -

While Poolbeg does not wish to amend the yearly Ammonia mass discharge figures we would like to amend the daily and kg/day licence limit..

Under condition 12.5 of our IPPCL ESB Poolbeg request an amendment to Schedule 2 (i) Emissions to Wailer, Emission Point Reference No. SW2, Ammonia Concentration ELV. ESB wishes to propose a new daily limit of 350 mgA and a daily mass discharge of 70

Poolbeg believes that the current ELV’s were determined based on an averaged annual discharge which did not take cognisance of the possibility of daily peaks which could arise . This is demonstrable by the fact that there is no hourly discharge limit as is the case for suspended solids at SW2. Poolbeg has no requirement to amend the yearly Ammonia mass discharge figure of 7,300kg.

Please consider the request and revert to us in due course. If you have any queries or clarifications do not hesitade to contact me

Regards;, __

-____------ _- Services Manager Poolbeg

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EPA Export 26-07-2013:11:34:25

Environmental Enforcement

Mr Ronan 0 Gadhra, Services Manager, Electricity Supply Board (Poolbeg), ESB Poolbeg Generating Station, Pigeon House Road, Ringsend, Dublin 4.

01/08/2007

Environmental Protection Agency Regional Inspectorate, McCumiskey House Richview, Clonskeagh Road, Dublin 14, Ireland An Ghniomhaireacht um Chaomhnu Comhrhaoil Cigireacht Rbigitinach, Teach Mhic Chumascaigh Dea-Radharc, 86thar Cluain Sceach Baile Atha Cliath 14, Eire

1: 453 1 268 0100 F: t353 1 268 0199 E: info@epa.ie W www.epa.ie

/

Lo Call: 1890 33 55 99

/zyk %wN?- Our Ref: PO577-O2/gc 12kf.doc

Dear Mr 0 Gadhra,

I refer to your corresponderice received on 19" July 2007 referring to Ammonia at emission point SW2 in which you requested an amendment under condition 12.5 of IPPC licence PO577-02 to Schedule 2 Q) Emissions to water for daily ammonia concentrations and daily loads at emission point reference SW 2.

Condition 12.5 of IPPC licence PO577-02 states that 'Thefiequency, methods and scope of monitoring, sampling and anal)ses, as set out in this licence, may be amended with the written agreement of the Agemyjdlowing evaluation of test results'. This does not allow for a change to emissions limit values for discharges, so an amendment to Schedule 2 (9 cannot be made through this condition.

I

The Protection of the Environment Act made provision for amendment of a licence or revised licence for the purposes of correcting a clerical error or facilitating a technical amendment under the EPA Act {and the Waste Management Act. The provision for amending licences is provided under Section 96(1) of the EPA Acts 1992-2003 and Section 42B of the Waste Managennent Acts 1996-2005 and each state the following:

(a) correcting any clerical error;

(b) facilitating the doing of any thing pursuant to a condition attached to the licence where the doing of that thing may reasonably be regarded as having been contemplated by the tenm of the condition or the terms of the licence taken as a whole but which was not expressly provided for in the condition, or

kg-- *hd**- a m i i m S d G E G i X T e G E % the relevant requirements of section 83(5) .(EPA Act 1992-2003)/Section 40(4) (Waste Management Acts 1996-2005) ceasing to be satisfied.

\\OWL\OEE\OS. Licence EhforcemenfiIPC Licence EnforcemenhlPC DB Documents\PS7I -580\P0577-02\gc12k 8

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1 : . . - e

i . @ea Environmental

Enforcement

The proposed change to emission limit values cannot therefore be made through the licence or through a technical amendment of the licence and a licence review will be necessary to change these emission limit values. I therefore advise you to write to the EPA’s Office of Climate Change, Licensing & Resource Use at PO Box 3000, Johnstown Castle Estate, Co. Wexford to request a review of your IPPC licence.

Please provide the following in ylour letter to the Office of Climate Change, Licensing & Resource Use:

0 Details of the requeste:d change(s). 0 Reasons for the change(s) requested. 0 Details of any increase or #changes in emissions resulting from the change(s). 0 An assessment of the like1,y impacts of any increasekhanges in emissions. 0 Please also enclose a copy of this letter for their reference.

Please quote the above reference in any future correspondence to the OEE in relation to this matter.

Yours sincerely,

1% Kieran Fahey, -

Inspector, Office of Environmental Enforcement.

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e3 Power Generation

Electricity Supply Board Poolbeg Generating Station, Pigeon House Road, Dublin 4, Ireland. Bothar Thig Choluim, Saile Atha Cliath 4, cire. Phone: 353-1 -668 5300 Fax: 353-1 -668 5545 Website: www.esb.ie

Attention: Ms Ruth Barrington Wice of Environmental Einforcement Environmental Protection Agency McCumiskey House Richview Clonskeagh Road Dublin 14.

Your ref: P0577-02/gcl2kf.doc

15th. May, 2008

Electricity Supply EBoard (Poolbeg). IPPC Licence Reg. No. PO57742 Schedule 2(i) Emissions to Water.

Dear Ms Barrington,

Introduction

ESB are writing with regard to Poolbeg power station's Integrated Pollution Prevention and Control (revlised) Licence PO57742 (1 3 1 2/04). The issue concerns Schedule 2(i) Emissions to Water, SW2 - Water treatment neutralisation tank - Units 1 , 2 and 3, Emission Limit Valuers:

1

Ammonia (as N): daily 100 mgA, mass 20 kglday

You will recall that due to the difficulty in adhering to these ELVs, ESB wrote to the Agency 13/07/07 requestinlg a technical amendment to the IPPC Licence; the following ELVs were requested:

Ammonia (as N): daily 3510 mgA, mass 70 kg/day

ESB's submission outlined the tlechnical issues, and maintained that the amended ELVs requested would have no significant environmental impact. Importantly, ESB committed not to exceed the existinq de facto mass annual limit of 7,300 kg ammonia (as N) (viz. 20 kg X 365 days).

Agency's reply 01/08/07

The Agency in their reply of 01/08r'07 rejected ESB's request.

ESB notes the provisions for amendment of Licences under Section 96(1) (a), (b) and (c) of the Protection of thwJEn '

_- ~ * r ~ S B ~ l i e v e s - t h a a t e c h n ~ ~ ~ p r o " i i s i o n s (a) and (c).

-b#hezAgefx$--

- Re provision (a) - this matter had been raised by ESB prior to the issue of the original IPC Licence (19/04/02). In tlhe Appeal (01/10/01) to the IPC Proposed

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Determination, ESB acknowledged that the IPC Licence Application was in error with respect to the values given for ammonia at SW2, and stated the correct values:

Ammonia (as N): hourly 1,000 mg/l, daily 500 mg/l, mass 100 kg/day

- Re provision (c) - In the letter 13/07/07 to the Agency, ESB calculated that concentrations of ammonia reaching the waters of Dublin Bay would be insignificant, due to dilution in the cooling water discharge channel; ESB is unaware of any relevant quality standard for waters that would be contravened by such discharge. In addition, as the Agency would be aware, the resultant concentration of ammonia in the cooling water discharge channel would be very low in relation to the concentration of ammonia in the Dublin City Council Ringsend wastewater treatment plant effluent, which also discharges to the ESB cooling water channel.

Y

Power Station Operation1

At the time of the IPC 1-icence Application, the number of condensate polisher regenerations was envisaged at approximately 50 per annum. However, the load factor for Poolbeg power station Units 1, 2 and 3 has reduced significantly in recent years. As indicated in the ESB letter 13/07/07, this has resulted in a reduction in the number of condensate polisher regenerations in recent years to approximately 30 per annum, decreasing further last year (2007) to 8, when the load factor for Units 1, 2 and 3 were 14%, 24%, O%I respectively. Load factors are lower again in 2008 and are projected to reduce even further in 2009, with closure as per the CER - ESB Agreement scheduled for end of 2009. Overall therefore the number of condensate polisher regenerations will reduce significantly.

In the context of the existing de facto mass annual limit of 7,300 kg ammonia (as N), discharge at the ELVs requested would result in a total maximum discharge of only 560 kg for the entire year 2007 (&. 70 kg X 8). This is a tiny proportion (of the order of 0.1%) of the expected arinual discharge of ammonia from the Ringsend wastewater treatment plant att the same discharge point.

Ofher Power Station IPPC Licences

As mentioned in ESB's letter of 13/07/07, the ELVs for Poolbeg power station vary significantly from equivalent ELVs; at other power stations with similar plant:

__ -

--dmw r S pa i t i cu IK l~a~ua t ions , nevertheless it does appear that the Poolbeg ELVs are unduly restrictive.

. . . _ -

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‘ w * - t i s - * I

Ammonia remova/ tec,bnology I ESB has enquired from industry experts abroad as to the possibiltty of the removal of ammonia from the effluent by e.g. steam stripping. The information is that such removal of ammonia is only feasible for power stations that use DENOX (nitrogen oxide removal) technology, as the condensation and concentration of ammonia is very cost intensive.

In the context of a power station with limited remnant life, major expenditure on ammonia removal technology, assuming it were feasible, could not be justified,

Summary

The current IPPC Licence SW2 - water treatment neutralisation tank emission limit values for ammonia are proving onerous to ESB and on occasion impossible to meet. On 13/07/07 ESB requested a technical amendment to the IPPC Licence, proposing ELVs that in ESB’s view would have no slgnificant environmental impact (ESB request rejected subsequently by the Agency).

The de facto reduced operation of Poolbeg power station Units 1, 2 and 3 will reduce the number of condensate polisher regenerations (i.e. ammonia discharges) to a fraction of those heretofore. ESB discharges of ammonia at this location are a small fraction of those arising from the Dublin Clty Council Ringsend wastewater treatment plant discharges. The discrepancy between the Poolbeg power station ELVs and the ELVs for other

Removal of ammonia by e.g. steam stripping would be impractical and I power stations appears imornalous.

prohibitively expensive, especially in the context of the remnant station life.

Conclusion

In view of the reasons as summarised above, ESB considers that the current ELVs are restrictive, produce 110 environmental benefit, and that attempting to achieve same, even if possibls!, would be unnecessarily expensfve in the light of the anticipated low load operation and closure over the next few years.

ESB would appreciate if the Agency would reconsider ESB’s request for a technical amendment to the EL\&, and respond as soon as can be managed.

If any further information is required please do not hesitate to contact the undersigned.

n

Yours sincerely, -- - -- - ---

ESB Poolbeg.

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?a Environmental Enforcement

Mr Ronan O’Gadhra Services Manager Electricity Supply Board (Poolbleg) ESB Poolbeg Generating Station Pigeon House Road Ringsend Dublin 4.

Re: Ammonia Emissions at SW2

Environmental Protection Agency Regional Inspectorate, McCurnirkey House Richview, Clonskeagh Road, Dublin 14, Ireland An Ghniornhaireacht urn Chaomhnli Cornhshaoil Cigireacht Rbigihnach, Teach Mhic Chumascaigh Dea-Radharc, B6thar Chain Sceach Baile Atha Cliath 14, Eire

T: +353 1 268 0100 F: t353 1 268 0199 E infoOepa.ie W: www.epa.ie

LoCall: 1890 33 55,99

m Dear Mr O’Gadhra,

I refer to your correspondence dated 15/05/2008 received by the Agency on 19/05/2008 regarding Schedule 2(i) Emissions to Water of IPC licence PO577-02.

As stated in Agency correspondence o f 01/08/2007, ref. gcl2kf, the Office o f Environmental Enforcement cannot facilitate these proposed changes. The Agency’s Office of Climate Change, Licensing and Resource Use is the competent body for dealing with changes to IPC Iiicences. I therefore advise you to contact that Office at PO Box 3000, Johnstown Castle Ektate, Co. Wexford and offer the following information:

0 Details of the requested chiinge 0 Reason for proposed change

Details of any increase olr change in emissions resulting from the proposed change

0 An assessment o f the likely impacts on receiving media of any increaselchange in emissions

0 Details o f previous comlespondence with the OEE in relation to this matter.

Please quote the above reference in future correspondence with the OEE in relation to this matter. I f you have any queries please contact Mr Kieran Fahey at 01 2680100.

Yours sincerely

~-

Office o f Environmental Enforcement

\\OWL\OEE\OS. Licence EnforcemenAlPC Licence EnforcemendlPC DB Documents\P571-580W0577-02\gc14kf 6

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