wheelabrator kemsley generating station power upgrade · chpqa chp quality assurance. chpqi chp...

Wheelabrator Kemsley Generating Station Power Upgrade

Preliminary Environmental Information Report (PEIR)

Volume 1 - Main TextMarch 2017

Planning Inspectorate Ref: EN010083

www.wtikemsley.co.uk

QUALITY MANAGEMENT

Prepared by: Andrew Stevenson, Mark Barrett and Nina Fionda

Authorised by: Christopher LeCointe

Date: 02/03/2017

Project Number/Document Reference:

OXF9163

Contents

COPYRIGHT © RPS

The material presented in this report is confidential. This report has been prepared for the exclusive use of K3 CHP Ltd shall not be distributed or made available to any other company or person without the knowledge and written consent of RPS.

WTI Kemsley Generating Station – Power Upgrade: PEIR

March 2017

[This page has been left blank intentionally]

WTI Kemsley Generating Station – Power Upgrade: PEIR Contents

March 2017 i

Glossary of Abbreviations and Definitions

AADT Annual Average Daily Traffic Flow

AAWT Annual Average Weekly Traffic

ACC Air Cooled Condenser

ACS American Cancer Society

Acute effect An effect that occurs within a short time after exposure

ADD Average Daily Dose

ADMS Atmospheric Dispersion Modelling System – a proprietary model for the assessment of effect of emissions to air from point sources and road sources

AEP Annual Exceedance Probability

Air pollutant A substance present in the atmosphere at concentrations that are elevated, usually by human activities. Most air pollutants occur naturally in the atmosphere at low concentrations

ALA Acquisition of Land Act 1981.

Ambient concentrations Concentrations of airborne substances in outdoor air

AOD Above Ordnance Datum, i.e. meaning a level above mean sea level.

APFP Regulations The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009. Sets out detailed procedures that must be followed for submitting and publicising applications for Nationally Significant Projects.

Applicant K3 CHP Limited (K3 CHP) company no. 09240062 registered at Portland House (8th Floor), Bressenden Place, London, SW1E 5BH. K3 CHP Ltd is a wholly owned subsidiary of WTI UK Ltd

Application The Application for a Development Consent Order made to the Secretary of State under Section 37 of the Planning Act 2008 in respect of the Proposed Development, required pursuant to Section 31 of the Planning Act 2008 because the Proposed Development is a Nationally Significant Infrastructure Project under Section 14(1)(a) and Section 15 of the Planning Act 2008 by virtue of being an onshore generating station in England or Wales of 50 Megawatts electrical capacity of more.

Application Site The land corresponding to the Order Limits that is required for the construction; operation and maintenance of the Proposed Development.

AQMA Air Quality Management Area

Associated Development

Defined under Section 115(2) of The Planning Act 2008 as development which is associated with the principal development and that has a direct relationship with it. Associated development should either support the construction or operation of the principal development, or help address its impacts. It should not be an aim in itself but should be subordinate to the principal development.

ATC Automatic Traffic Count

Average daily dose The estimated mean dose received by an individual over the course of a day

Averaging time A reference time period e.g. an average daily dose is reported for an averaging time of one day

BAP Biodiversity Action Plan.


March 2017 ii

BAT Best Available Techniques

BGL Below Ground Level

BGS British Geology Survey

Bioaccumulation The process by which chemicals are taken up into an organism either directly by exposure or indirectly through consumption of contaminated material. Concentrations can accumulate higher up the food chain to levels significantly higher than the original exposure concentration

Book of Reference A reference document providing details of all landownership interests within the Order Limits as shown on the Land Plan.

BPEO Best Practicable Environmental Option

BREEAM Building Research Establishment Environmental Assessment Method, a benchmark for appraising the sustainability of building design, construction and operation

BREF European BAT Reference Document

BS British Standard.

C&I Commercial & Industrial Waste.

C&RT Canal and River Trust.

CAA Civil Aviation Authority.

CAFE Clean Air for Europe Programme

Carcinogenic Slope Factor

An upper bound on the increased cancer risk from a lifetime of oral (ingestion) exposure to a substance based on the dose-response relationship of the substance

CCG Clinical Commissioning Group.

CDA Critical Drainage Area

CDM Construction Design and Management

CEMP Construction Environmental Management Plan.

CfD Contract for Difference.

CFMP Catchment Flood Management Plan

Chemicals of Potential Concern

Substances identified through the risk assessment process as being of concern to human health

CHP Combined Heat and Power. A technology that puts to use the residual heat of the combustion process after generation of electricity that would otherwise be lost to the environment.

CHPQA CHP Quality Assurance.

CHPQI CHP Quality Index.

Chronic effect An effect that occurs over a long time period or following a long period of exposure

Chronic bronchitis A daily cough with production of sputum for 3 months, two years in a row

CIBSE The Chartered Institute of Building Services Engineers.

CIE Commission Internationale de l’Eclairage.

Climate change A change in the average state of the climate and/or the variability of its properties, considered by many scientists to be exacerbated by anthropogenic emissions of greenhouse gases such as carbon dioxide.


March 2017 iii

CMS Construction Method Statement

CO2 Carbon dioxide

Cohort study A study in which a particular health effect, is compared using groups of people who are alike in most ways but differ by a defined characteristic, such as exposure to a source of pollution for example

COMEAP Committee on the Medical Effects of Air Pollution

Commercial and Industrial (C&I) waste

Waste generated from businesses, such as factories, utility and transport companies, shops, offices, hotels, restaurants, schools and hospitals. It also includes public sector organisations, such as local authorities, and construction and demolition (C&D) companies. It would be delivered to Site after processing to satisfy recycling requirements.

Competent Authority The decision-making authority within the context of the Conservation of Habitats and Species Regulations 2010. It is the role of the competent authority to make judgements required by the Regulations, following consultation with Natural England. The competent authority is entitled to require the applicant/proponent of the project or plan to supply the information that it requires to make those judgements.

Concentration – response function

An equation that represents, for example, the relationship between the predicted concentration of a pollutant in the air and the exposed population response

Congeners Substances with molecules that share slightly different chemical structures

Consents and Licences required under Other Legislation

A supporting document setting out the other consents and licences that are required for the construction and operation of the Proposed Development that are not being included within the Development Consent Order.

Construction Traffic Management Plan (CTMP)

A CTMP outlines the proposed approach to controlling the flow of general traffic, construction traffic and access for pedestrians, equestrians and cyclists during the works, limiting as far as possible disruption and delays.

COPC Compound of Potential Concern

Core Strategy The key development plan document for each local planning authority, which sets out an overall vision, strategic objectives, delivery strategy and management & monitoring arrangements.

COT Committee on Toxicology

Critical Level Concentrations of pollutants in the atmosphere above which direct adverse effects on receptors, such as human beings, plants, ecosystems or materials, may occur according to present knowledge.

Critical Load The deposition rate of either nitrogen or acid above which scientific studies identify that adverse effects on a given species or habitat has been known to occur. The Critical Load for a given habitat or species will differ depending upon a range of factors. Critical Loads are usually given as a range rather than a single value. Deposition rates above the Critical Load may or may not result in an adverse effect in practice depending on the specific situation.

CSF Cancer Slope Factor

CSU Consents Services Unit

Cumulative effects Effects that may arise from a combination of the project’s effects with those of other existing or planned developments in the area.

Curfew The time after which stricter requirements (for the control of obtrusive light) will apply; often a condition of use of lighting applied by a


March 2017 iv

government controlling authority, usually the local government.

DAS Design and Access Statement.

DCLG Department for Communities and Local Government.

DCO A Development Consent Order made by the relevant Secretary of State pursuant to The Planning Act 2008 to authorise a Nationally Significant Infrastructure Project. A DCO can incorporate or remove the need for a range of consents which would otherwise be required for a development. A DCO can also include rights of compulsory acquisition.

DCO Site The site for which the DCO is sought. The Application Site.

DCO Site Boundary The boundary of the DCO Site, also referred to as the Order Limits. The DCO Site Boundary incorporates land required for all components of the Proposed Development and covers an area of 14.6 hectares (ha).

DECC Department for Energy and Climate Change.

Deaths brought forward This does not constitute new/additional deaths but represents a reduction in life expectancy for those whose health is already seriously compromised, where one death brought forward represents a cumulative two to six month loss of life expectancy for the population exposed

Decommissioning A process to remove something from active status.

Development Plan A statutory document or a set of documents prepared and adopted by a planning authority which set the local policies governing development within its administrative area.

Development Plan Document (DPD)

One of the local documents that comprise part of the development plan.

Dioxins/Furans This is the abbreviated name for a family of toxic substances that share a similar chemical structure and a common mechanism of toxic action. They include the congeners polychlorinated dibenzo dioxins (PCDDs) and polychlorinated dibenzo furans (PCDFs).

Dose The USEPA define ‘Dose’ as, the amount of a substance available for interaction with metabolic processes or biologically significant receptors after crossing the exchange boundary of an organism.

An equivalent definition is, the amount of a substance taken up by an exposed individual following inhalation, ingestion or absorption across the skin

Dose-response relationship

The relationship between the dose and the proportion of exposed individuals observed to demonstrate effects

E Illuminance – The quantity of light, or luminous flux falling on a unit area of a surface in Lux (lx). One Lux is equivalent to one lumen per square metre.

EA Environment Agency.

EAL Environmental Assessment Level

EC European Commission

EfW Energy from waste. A power station that generates energy in the form of electricity or heat from the incineration or pyrolysis of waste products.

EH English Heritage.

Eh Horizontal Illuminance in Lux (lx).


March 2017 v

EIA Regulations The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 setting out how the EIA of Nationally Significant Infrastructure Projects must be carried out and the procedures that must be followed.

ELV Emission Limit Value

Emissions The substances or mass of a substance emitted into the atmosphere

EN European.

EN-1 Overarching National Policy Statement for Energy.

EN-3 National Policy Statement for Renewable Energy Infrastructure.

EN-5 National Policy Statement for Electricity Networks Infrastructure.

Environmental Impact Assessment (EIA)

Environmental Impact Assessment. The assessment of the likely significant environmental effects of a development undertaken in accordance with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009.

Environmental Statement (ES)

Report in which the process and results of an Environment Impact Assessment are documented.

EPA Environmental Protection Act 1990.

EPR Environmental Permitting Regulations

Epidemiology The study of populations in order to determine the frequency and distribution of disease and to measure risks

EU European Union

European Site A term used in this report to refer collectively to Special Areas of Conservation, Special Protection Areas or Ramsar sites, which are internationally protected ecology sites.

Ev Ev = Vertical Illuminance in Lux (lx).

Exception test A test which may allow a site to be developed in Flood Zones 2 or 3 where it can be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk.

Excess Lifetime Risk The probability that an individual will develop cancer over a lifetime as a result of exposure to specific carcinogenic chemicals through multiple exposure pathways

Explanatory Memorandum

A document that explains the intended purpose and affect of a DCO and the authorisations and powers that it seeks.

Exposed population The population exposed to a meaningful change in air pollutant concentrations

Exposure The US EPA define ‘exposure’ as, the condition of a chemical contacting the exchange boundary of an organism.

A broader definition is, the amount of a substance inhaled, ingested or present at the skin surface

Exposure (Direct) Inhalation of air containing substances at predicted concentrations

Exposure (Indirect) Results from contact of human and ecological receptors with soil, plants or water bodies on which emitted chemicals have been deposited

Exposure Duration The length of time that a receptor is exposed via a specific pathway

Exposure Frequency This is the amount of time a receptor is exposed to COPCs by all pathways. The HHRAP assumes that receptors are exposed 350 days a year, with a 2 week period away from the relevant exposure location


March 2017 vi

Exposure Pathway This is the route that a chemical takes from its source, through the environment to the individual being exposed

Exposure Scenario The combination of relevant exposure pathways to which an individual receptor may be exposed to specific substances

FGD Flue Gas Desulphurisation.

FGT Flue Gas Treatment

Fine particulate Matter Size fractions of particulate matter smaller than PM10. In this report represented by PM2.5

Finished Floor Level (FFL)

The height above Ordnance Datum (AOD) at which the ground floor of the buildings will be built.

Flood Risk Assessment (FRA)

The formal assessment of flood risk issues relating to the Proposed Development. The findings are presented in an appendix to the Environmental Statement.

Flood Zone 1 Land with an Annual Exceedance Probability of less than 0.1% risk from fluvial flooding.

Flood Zone 2 Land with an Annual Exceedance Probability of between 0.1% and 1% risk from fluvial flooding.

Flood Zone 3b An area defined as the functional floodplain, that the area where water has to flow or be stored in the event of a flood. Land which would flood with a 1 in 20 (5%) annual probability or greater in any year, or is designed to flood in a 0.1% event should provide the starting point for designation of Flood Zone 3b.

Fluvial The processes associated with rivers and streams and the deposits and landforms created by them.

FMfSW Flood Map for Surface Water

Formal Consultation Statutory consultation in accordance with Section 42, 46, 47 and 48 of the

PA 2008.

FRMS Flood Risk Management Strategy

Fuel

Waste derived fuel (WDF) used in the Proposed Development to generate electricity (any other ‘fuels’ used in the process are described separately,

e.g. diesel

GCV Gross Calorific Value.

GHG Greenhouse Gas

Glare A sensation that is produced by bright areas within the field of vision and may be experienced either as discomfort glare or disability glare. Glare caused by reflections in specular surfaces is usually known as veiling reflections or reflected glare.

GP General Practitioner

GW Gigawatt

GWh Gigawatt Hour

GWP Global Warming Potential

Ha Hectares. A metric measurement of area.

HA The Highways Agency.

Habitat Regulations Assessment

A term used in this report to refer to the entire process required to determine compliance of a plan or project with the Conservation of


March 2017 vii

habitats and Species regulations 2010 and Habitats Directive.

Hazard Something (e.g. an object, a property of a substance, a phenomenon or an activity) that can cause adverse effects

Hazard Index (HI) The total chronic hazard attributable to exposure to all COPCs through a single exposure pathway

Hazard Quotient The comparison of oral and inhalation exposure estimates to reference dose and reference concentration values

HDPE High-density Polyethylene

Heavy Goods Vehicle (HGV)

Vehicles with a gross weight in excess of 3.5 tonnes.

HHRA Human Health Risk Assessment

Host local authority The local authority whose area the Application Site lies within. In this case, Wakefield Metropolitan District Council.

HSE The Health and Safety Executive.

HTP Human Toxicity Potentials

Human Health Risk Assessment Protocol (HHRAP)

A structured approach to quantifying the risks to human health associated with exposure to compounds of potential concern

HQ Hazard Quotient

I Light Intensity in Candelas (cd).

ILP The Institute of Lighting Professionals.

IED Industrial Emissions Directive, EU Directive 2010/75/EU

IEMA Institute for Environmental Management and Assessment

IHT Institute of Highways and Transportation

Ingestion The act of eating or drinking a substance that may then result in the substance being taken up via the digestive system

Inhalation The act of breathing in a substance that may then result in the substance being taken up via the respiratory system

Industrial Risk Assessment Program

A commercially available computer program developed to calculate excess life time risk and hazard index values following the requirements from the 2005 U.S. EPA-OSW Human Health Risk Assessment Protocol

Industrial Emissions Directive

A directive of the European Union, the requirements of which will replace requirements of the Waste Incineration Directive (WID) by 2013

Informal Consultation Non-statutory consultation in accordance with Section 42, 46, 47 and 48 of

the PA 2008.

Infrastructure Planning Commission (IPC)

An independent body established on 1 October 2009 under the Planning Act 2008 to streamline the planning system for nationally significant infrastructure projects (NSIPs). Its role was to examine applications for Nationally Significant Infrastructure Projects. The Localism Act 2011 abolished the IPC and transferred its functions to the Planning Inspectorate. A National Infrastructure Directorate has been formed within the Planning Inspectorate, to examine applications for Nationally Significant Infrastructure Projects and to make recommendations to the Secretary of State who is the decision-maker.

International Toxic Equivalent

This weighs the toxicity of the less toxic compounds as a fraction of the toxicity of a reference compound. In the case of dioxins the toxicity of each individual congener is weighted to 2,3,7,8-TCDD, which is given a


March 2017 viii

reference value of 1

IOM Institute of Occupational Medicine

IRAP Industrial Risk Assessment Programme

IRR Internal Rate of Return.

ITAs Integrated Transport Authorities.

K3 CHP K3 CHP Limited, a joint venture that has been formed between SSE Generation Limited and Wheelabrator Technology Inc (the Applicant).

KCC Kent County Council

km Kilometres.

kV Kilovolts.

L Luminance in Candelas per square metre (cdm-2).

Land Plan A plan showing all of the land that is required for the Proposed Development over which rights are to be sought as part of the DCO.

Landscape Character Area (LCA)

Areas of homogenous landscape or townscape character. Typical components defining character include landform, land cover, settlement pattern, form and enclosure.

LAT Local Area Team.

LCA Life Cycle Assessment.

LCP Large Combustion Plant

LDF Local Development Framework

LEC Levy Exemption Certificate.

LG Lighting Guide.

Lifetime In estimating the average lifetime exposure of individual receptors or populations to substances, a lifetime is taken to be 70 years

Life Table A way of summarising mortality rates for the age classes within a population

Likely Significant Effect A particular stage in the assessment process covered by the Conservation of Habitats and Species Regulations 2010 and the Habitats Directive. The judgement is made with reference to the interest features of the European site and its conservation objectives. A project for which the ‘likely significant effects’, either alone or in combination with other plans or projects, cannot be dismissed and must be taken forward to the Appropriate Assessment stage.

Limits of deviation The lateral limits shown on the Works Plan(s) and the vertical limits (upwards and downwards) determined by reference to the section plan(s) submitted as part of the Application and within which the Proposed Development may occur.

Lipophilic A substance is considered lipophilic if it is readily dissolved in fat-like solvents

Listed Building A building that has been placed upon the Statutory List of Buildings of Special Architectural or Historic Interest. Under this status a building may not be demolished, extended or altered without listed building consent from the local planning authority or the Secretary of State.

Local Development Framework

The system of plan making introduced by the Planning and Compulsory Purchase Act 2004. It is a suite of local development documents produced by the local planning authority, which collectively form the spatial planning


March 2017 ix

strategy for its area.

Local Nature Reserve A non-statutory site of local importance for wildlife, geology, education or public enjoyment.

Local Plan Local Plans provide a detailed framework of spatial and strategic policies against which development applications can be assessed in a local planning authority area.

Local Wildlife Site (LWS)

A non-statutory designation covering a discrete area of land which is considered to be of local significance for its wildlife features.

Lower Respiratory System (LRS)

The human respiratory system below the larynx

Lv Veiling Luminance – A measure of the loss of visibility caused by the disability glare from the obtrusive light installation.

m Metres.

MBT Mechanical Biological Treatment

MCC Manual Classified Turning Count

MCZ Marine Conservation Zone

Media For the purposes of this assessment, media are parts of the wider environment that a substance could be contained within. This includes soil, water, air, biota etc

Metals The 12 metals, in their elemental form or contained within compounds, for which emission limit values are defined within the Waste Incineration Directive

Mitigation measures A term used in EIA to describe measures proposed to prevent, reduce and where possible offset any significant adverse environmental effects.

MJ/kg megajoules per kilogram

Morbidity The incidence or prevalence of disease/ill health in a population

Mortality The incidence of death or the number of deaths in a population

MRF Materials Recycling Facility

Municipal solid waste (MSW)

Waste from households and the household-like component of commercial and industrial waste.

MW Megawatts, equal to one million Watts, a measure of the power capacity.

MWe Megawatts of electrical energy. A measurement of the amount of electricity that will be exported to the national transmission system.

MWh Megawatt hour of electricity produced.

MWth Megawatt of thermal energy, which is the energy input or output including both electricity and heat.

National Planning Policy Framework (NPPF)

The National Planning Policy Framework which came into effect on 27 March 2012 (with some transitional arrangements) replaces the majority of national planning policy other than NPSs. The NPPF is part of the Government's reform of the planning system intended to make it less complex, to protect the environment and to promote sustainable growth. It does not contain any specific policies on Nationally Significant Infrastructure Projects but its policies may be taken into account in decisions on DCOs if the Secretary of State considers them to be both important and relevant.

National Policy Statement (NPS)

National Policy Statements are produced by Government under the Planning Act 2008 and provide the policy framework for Nationally


March 2017 x

Significant Infrastructure Projects. They include the Government’s view of the need for and objectives for the development of Nationally Significant Infrastructure Projects in a particular sector such as energy and are used to determine applications for such development.

Nationally Significant Infrastructure Project (NSIP)

Nationally Significant Infrastructure Projects are defined by the Planning Act 2008 and cover projects relating to energy (including generating stations, electric lines and pipelines); transport (including trunk roads and motorways, airports, harbour facilities, railways and rail freight interchanges); water (dams and reservoirs, and the transfer of water resources); waste water treatment plants and hazardous waste facilities. These projects are only defined as nationally significant if they satisfy a statutory threshold in terms of their scale or effect.

NCV Net Calorific Value [of a fuel], in units of MJ/kg.

NE Natural England.

NERC ACT S41 Natural Environment And Rural Communities Act Section 41.

NGET National Grid Energy Transmission plc.

Nitrogen Dioxide (NO2) A molecule composed of one nitrogen atom and two oxygen atoms, present in outdoor air as a gas

NOx Nitrogen Oxides, comprising primarily nitric oxide (NO) and nitrogen dioxide (NO2). NO2 has defined air quality objectives for ambient air for the protection of human health and designated ecological receptors.

NPV Net Present Value.

NRSWA New Roads and Street Works Act 1991.

NSIP A Nationally Significant Infrastructure Project that must be authorised by the grant of a DCO under The Planning Act 2008.

ONS Office of National Statistics

Order The Kemsley Generating Station Power Upgrade Order, being the DCO that would be made by the Secretary of State authorising the Proposed Development, a draft of which has been submitted as part of the Application.

Order Limits The limits of the land to which the Application for the DCO relates and shown on the Land Plan and Works Plans within which the Proposed Development must be carried out and which is required for its construction and operation. The Application Site.

OS Ordnance Survey

Oxides of nitrogen (NOx)

A collective term for all gases composed of nitrogen and oxygen, including nitrogen dioxide

PA Planning Authority (within the Biodiversity Strategy).

PA Planning Act (within the Lighting Strategy).

PAH Polycyclic aromatic hydrocarbon

PA 2008 The Planning Act 2008 setting out legislation in relation to applications for NSIPs, including pre-application consultation and publicity, the examination of applications and decision making by the Secretary of State.

Particulate Matter Solid particles, aerosols or liquid droplets suspended or carried in the air and includes the same matter after it has deposited onto a surface. For the purposes of this application the term includes all size fractions of suspended matter, such as dust, PM10 and PM2.5.


March 2017 xi

Pathway A term used to represent a series of sequential physical or chemical actions by which a substance is transported from a source, through the environment to a receptor. Typically described using a label that relates to the mechanism that receptors are exposed by, e.g. inhalation pathway

PCDD Polychlorinated di benzo(p)dioxin

PCDF Polychlorinated di benzo furans

PEC Predicted Environmental Concentration, that is the combination of the Process Contribution (PC) and the Ambient Concentration (AC)

PEI Preliminary Environmental Information.

PES Primary Energy Savings.

Photocell A light sensing device used for switching/controlling luminaires.

PICADY Model development by TRL, used for predicting capacities, queues, delays and accident risk at priority intersections

PINS The Planning Inspectorate. A Government agency responsible for receiving and administering the acceptance and examination of applications for NSIPs on behalf of the Secretary of State.

Polycyclic aromatic hydrocarbons

A group of several hundred chemically related persistent organic compounds of various chemical structures and toxicity. Benzo[a]pyrene is used in National air quality regulations as a marker species for reporting concentrations of PAH in ambient air

PM10 Mass per cubic metre of particles passing through the inlet of a size selective sampler with a transmission efficiency of 50% at an aerodynamic diameter of 10 micrometres

PM2.5 Mass per cubic metre of particles passing through the inlet of a size selective sampler with a transmission efficiency of 50% at an aerodynamic diameter of 2.5 micrometres

PM1 Mass per cubic metre of particles passing through the inlet of a size selective sampler with a transmission efficiency of 50% at an aerodynamic diameter of 1 micrometre

Population All people living in a defined area

PPE Personal Protective Equipment

PPG Pollution Prevention Guidelines

Predicted concentrations

Mass of pollutant per volume of air. Normally expressed as mean values over a defined time period, as calculated using dispersion models

Preliminary Environmental Information Report (PEI) Report

A report which is a requirement of Regulations 2 and 10 of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 which is prepared during the pre-application process to support consultation on the project proposal. It presents initial environmental information on the Proposed Development.

PFRA Preliminary Flood Risk Assessment

Process Contribution An indication of the expected contribution of emissions from a given development to ground level concentrations and deposition of pollutants at a particular location.

Proposed Development The development to which the Application relates and which requires a DCO and as listed at Schedule 1 of the draft Order.

PSCCS Proposed Stakeholder and Community Consultation Strategy.

PTEs Passenger Transport Executives.


March 2017 xii

Q1-4 Quarters 1-4. 3 month periods of each calendar year, with Q1 equating to the months of January to March inclusive and so on.

Queue length Maximum average queue length in cars

Ramsar Site Wetlands of international importance, designated under the Ramsar Convention.

Receptors People (both individually and communally) and the socio-economic systems they support.

Reference concentration (RfC)

An estimated daily concentration of a chemical in air, the exposure to which over a specific exposure duration poses no appreciable risk of adverse health effects, even to sensitive populations

Reference Dose (RfD) A daily oral intake rate that is estimated to pose no appreciable risk of adverse health effects, even to sensitive populations, over a 70 year lifetime

Relative risk The likelihood of the event in an exposed group relative to those who have not been exposed

Requirements The ‘requirements’ at Schedule 2 of the draft Order that, amongst other matters, are intended to control the final details of the Proposed Development as to be constructed and also to control its operation, amongst other matters (e.g. control of noise levels and delivery hours) to ensure that it accords with the EIA and does not result in unacceptable impacts.

Residual effect The environmental effect of a proposed development which remains after mitigation measures have been incorporated into the design.

RFC Ratio of flow to capacity (where 1.0 would represent a flow at capacity)

RGL Rating Glare Limit – A metric used for the assessment of glare.

RHI Renewable Heat Incentive.

Risk An estimation of the probability that an adverse health impact may occur as a result of exposure to chemicals in the amount and by the pathways identified.

RO Renewable Obligation.

ROC Renewable Obligations Certificate.

Runoff The water flow that occurs when soil is infiltrated to full capacity and excess water from rain, melt water, or other sources flows over the land.

Scheduled Monument A nationally important archaeological site or historic building that is legally protected against disturbance, damage or unlicensed metal detecting.

SCI Statement of Community Involvement.

SDC Selby District Council.

SEGI Site Of Ecological Or Geological Interest.

Sensitivity analysis A procedure by which numerical estimates are tested to aid the interpretation of predicted values

Sequential Test A planning principle that seeks to identify, allocate or develop areas of land in Flood Zone 1 before other areas in Flood Zones 2 and 3.

Site Waste Management Plan (SWMP)

A SWMP sets out how building materials, and resulting waste, is to be managed during the project.

SLL Society of Light and Lighting.


March 2017 xiii

SNCR Selective Non-Catalytic Reduction, a secondary abatement technique for the control of emissions of nitrogen oxides from a stationary combustion source

SoCC Statement of Community Consultation, a requirement to support applications under the Planning Act 2008, setting out the nature of community consultation to be undertaken under Section 47 of the PA 2008.

SoCG Statement of Common Ground.

SGV Soil Guidelines Values

SoS The Secretary of State. The decision maker for DCO applications and head of Government department. In this case the SoS for the Department for Business, Energy & Industrial Strategy

Source Protection Zone (SPZ)

An area defined by the Environment Agency around a groundwater abstraction to limit activities within that area and protect the abstraction.

Special Area of Conservation (SAC)

High-quality conservation sites that are protected under the European Union Habitats Directive, due to their contribution to conserving those habitat types that are considered to be most in need of conservation.

SPA Special Protection Areas

SRF Solid Recovered Fuel

SSSI Nationally designated Sites of Special Scientific Interest, an area designated for protection under the Wildlife and Countryside Act 1981 (as amended), due to its value as a wildlife and/or geological site.

Statement of Reasons A statement setting out the reasons and justification for the compulsory acquisition of land or rights in land within the Order Limits.

STOR Short Term Operating Reserve

SFRA Strategic Flood Risk Assessment

Sulphur Dioxide (SO2) A molecule composed of one sulphur and two oxygen atoms, present in outdoor air as a gas

Sustainable Drainage Systems (SuDS)

Surface water drainage methods that take account of quantity, quality and amenity issues.

SBC Swale Borough Council

TA Transport Assessment

TC Traffic Contribution to ambient air concentrations of pollutants arising from vehicles associated with the construction or operation of the Proposed Development

TDI Tolerable Daily Intake

TDS Total Dietary Study

TEF Toxic Equivalency Factor

TEMPRO Trip End Model Presentation Program, software used to predict traffic growth

The Site The site of the Proposed Development located on land to the east of Kemsley Paper Mill National Grid Reference: TQ921666. The Application Site or Order Limits.

Threshold The dose or exposure level below which no appreciable effects on human health are observed

Tolerable Daily Intake A World Health Organisation definition of the dose of a substance that an individual could be exposed to on each day of an entire lifetime, at which


March 2017 xiv

appreciable health risks do not occur. See similar ‘reference dose’ term used by USEPA

tpa Tonnes per annum

Transport Assessment (TA)

The formal assessment of traffic and transportation issues relating to the proposed development. The findings are usually presented in a report, which accompanies the planning application. A summary is often included within an ES, particularly where it provides context for consideration of other issues, e.g. traffic noise and emissions.

Travel Plan (TP) A Travel Plan is a document which includes a series of measures and initiatives which will be introduced to enhance the range of transport opportunities that are available, ultimately aiming to increase the use of sustainable transport modes.

Unit Risk Factor (URF) The upper bound excess lifetime cancer risk estimated to result from continuous exposure to a substance at a concentration of 1µgm-3 in air

UDP Unitary Development Plan

UKPN UK Power Networks

URL Upward Lighting Ratio of the installation – the maximum permitted percentage of luminaire flux that goes directly into the sky. This metric is often used as a measure of ‘sky-glow’.

US EPA United States Environmental Protection Agency

Waste Used to refer to waste generate by the Proposed Development (not waste derived fuel, which is referred to as ‘fuel’.

Waste Incineration Directive (WID)

A directive of the European Union (ref: 2000/76/EC) that defines the minimum standard of environmental performance that must be achieved by installations burning waste or waste derived fuels. Now consolidated into the Industrial Emissions Directive (2010/75/EU).

WBCDS World Business Council for Sustainable Development

WDF Waste Derived Fuel. Processed from sources of municipal solid waste, commercial and industrial waste and waste wood.

WEEE Waste Electric and Electronic Equipment

WHO World Health Organisation

Works Plan Plan(s) showing the numbered works referred to at Schedule 1 of the Order and submitted with the Application.

WRATE Waste and Resources Assessment Tool for the Environment.

WRI World Resources Institute.

WTI Wheelabrator Technologies Inc.

Years of life lost A statistical measure of mortality effects at the population level


March 2017 xv

Contents

1 Introduction

2 The Proposed Development

3 Need, Alternatives and Design Evolution

4 Assessment Methodology and Significance Criteria

5 Landscape, Townscape and Visual Resources

6 Ecology and Nature Conservation

7 Hydrology & Flood Risk

8 Hydrogeology & Ground Conditions

9 Historic Environment

10 Transport and Access

11 Climate, Air Quality and Health Impacts

12 Noise and Vibration

13 Land Use, Amenity and Socio-Economics

14 Summary of Significant Effects

WTI Kemsley Generating Station – Power Upgrade: PEIR

[This page has been left blank intentionally]

WTI Kemsley Generating Station – Power Upgrade: PEIR Chapter 1

March 2017 1-1

1 Introduction

1.1 This Preliminary Environmental Information Report (PEIR) has been prepared on behalf of K3

CHP Limited (the Applicant) in support of an application (the Application) that will be made to the

Secretary of State (SoS) for Department for Business, Energy & Industrial Strategy under Section

37 of the Planning Act 2008, seeking an ‘Order’ granting Development Consent (a Development

Consent Order, or DCO) for an Energy from Waste (EfW) Combined Heat and Power (CHP)

station – the generating station. The Order is a draft Order until it is confirmed by the Secretary of

State.

1.2 The DCO will provide the necessary authorisations and consents for the construction a n d

operation of an ‘Energy from Waste’ generating station of up to 75 megawatts electrical (MWe)

gross output and related development (the Proposed Development). The Proposed

Development is located on land to the east of Kemsley Paper Mill, Kemsley, Sittingbourne, Kent,

within the administrative boundary of Swale Borough Council (SBC).

1.3 The Project for Environmental Impact Assessment EIA purposes is the Generating Station and all

the other permanent and temporary development/works, including the Incinerator Bottom Ash

(IBA) Recycling Facility.. The Proposed Development is those elements of the Project for which

Development Consent is specifically sought i.e. the Generating Station including its construction

laydown area, steam pipe connection to the paper mill, electricity connection to the grid, surface

water drainage and landscaping, an outfall to the Swale Estuary and means of access. The

Proposed Development excludes the construction and use of the consented IBA Recycling

Facility which forms part of the Project purely for EIA purposes but for which development

consent is not specifically sought as this will be built pursuant to an extant planning permission.

Background

1.4 The Wheelabrator Kemsley Generating Station is a consented energy from waste plant which is

currently under construction that will provide low pressure steam to the existing Kemsley Paper

Mill and low carbon electricity to the grid. The Generating Station will help to diversify the long

term energy requirements at the Paper Mill which is the second biggest recovered fibre-based

paper operation in Europe.

1.5 K3 CHP Ltd (the Applicant) is preparing an application for Development Consent the primary

purpose of which is to secure an increase in the maximum electrical power output of the

consented Wheelabrator Kemsley Generating Station, from 49.9 Megawatts electrical (MWe) to

up to 75 MWe – the power upgrade application. The route to consent for the power upgrade is

described in Section 2.

1.6 An Environmental Statement (ES) for the Generating Station (previously referred to as the

Sustainable Energy Plant) was prepared in 2010 (the 2010 ES) and planning permission

subsequently granted by Kent County Council under the Town and Country Planning Act 1990 in

March 2012 – ‘the TCPA development’. A summary of the existing permissions is provided at

Section 3.


March 2017 1-2

1.7 The proposed increase in the power output of the Generating Station to an up to 75MWe facility

means that consent to operate at that level will need to be granted by the Secretary of State for

the Department for Business, Energy & Industrial Strategy under the Planning Act 2008 which

replaced the licensing provisions of the Electricity Act 1989, Section 36, for new generating

stations greater than 50MW capacity1. The Wheelabrator Kemsley Generating Station Power

Upgrade (referred to as ‘the Proposed Development’) is to be built pursuant to the terms of extant

planning permissions for the generating station, with the same benefits, but the applicant now

wishes to operate the plant with a greater maximum electrical output. The consented scheme

already allows the plant to operate at up to 49.9 MWe (gross) but the Applicant now wishes this

maximum limit to increase to up to 75 MWe (gross). The power upgrade is the only reason for

needing to seek a DCO. However, in order to secure one complete consent for the Proposed

Development, the applicant will also seek consent for its construction and operation. There will

be no change to the types and quantum of fuel throughput, nor any changes to emissions.

1.8 The upgraded generating station is considered to be a Nationally Significant Infrastructure Project

(NSIP) requiring a Development Consent Order to be made under the provisions of the 2008 Act.

In England, the Planning Inspectorate examines applications for development consent2.

1.9 The Applicant is seeking to secure a DCO under the Planning Act 2008 for the development and

proposes to undertake a voluntary Environmental Impact Assessment (EIA) to ensure all of the

environmental effects of the proposed development and the IBA facility as consented are

assessed in a formal EIA compliant with the EIA regulations relevant to the new DCO3. In

submitting the application in this way, it is expected that the existing permission will be treated as

a material consideration in the Secretary of State’s decision making process.

1.10 The Proposed Development will be capable of producing low carbon electricity through the use of

pre-processed Solid Recovered Fuel (SRF) waste, Municipal Solid Waste (MSW) and

Commercial and Industrial (C&I) waste. It will therefore make a positive contribution toward

addressing a number of national waste management and energy challenges, namely:

the UK Government's climate change commitments, which necessitate achieving an

ambitious reduction in UK greenhouse gas emissions (principally CO2);

security of national electricity supply, which can be addressed through having a mix of

energy generating technologies and a diverse range of fuel sources;

maximising energy recovery from wastes obtained from the processing of various

sources of SRF, MSW, C&I waste into fuel suitable for use in the Proposed Development;

1 The 2008 Act sets out thresholds above which certain types of infrastructure development are considered to be nationally

significant – in this case an electricity generating station of greater than 50MWe capacity

2 Previously NSIPs were dealt with by the Infrastructure Planning Commission (IPC). Under the Localism Act 2011, the IPC was

abolished and its functions transferred to the Planning Inspectorate’s National Infrastructure Directorate.

3 The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009


March 2017 1-3

complementing recycling initiatives by accepting waste after these initiatives have been

carried out, thereby forming part of an integrated waste management system and

supporting the waste hierarchy; and

positive use of waste materials that may otherwise be disposed of to landfill, saving

valuable landfill space. This will also result in a reduction in greenhouse gas emissions

(including methane) that would otherwise have been generated from the breakdown of the

waste materials had it gone to landfill.

1.11 The Applicant has demonstrated that there is demand in the market for energy from waste

electricity generating facilities in the South East of England, which is one of the reasons why

the Applicant has decided to progress the Proposed Development. The need that exists for

the Proposed Development is outlined in Chapter 3 Need, Alternatives and Design Evolution

of this PEIR, which also describes the alternatives that have been considered during the

evolution of the Proposed Development.

The Applicant

1.12 The Applicant, K3 CHP is a special purpose vehicle that has been formed by Wheelabrator

Technologies Inc. (Wheelabrator) to develop low carbon electricity generating plant. The

Applicant has an existing lease for land within the Application Site that is within the control of

DS Smith, while the draft DCO may seek the necessary powers and authorisations in

respect of any land that lies outside the Applicant’s control. The Applicant will also be the

operator of the Proposed Development.

1.13 Kemsley Paper Mill is owned and operated by DS Smith Plc, the UK’s largest paper and

packaging producer, employing circa 5000 people nationally at 50 sites. Kemsley Paper Mill

produces approximately 800,000 tonnes of recycled paper each year for its range of paper-based

products..

1.14 Wheelabrator is the second largest US energy-from-waste business, and is an industry leader in

the conversion of everyday residential and business waste into clean energy. Wheelabrator has

a platform of 23 power-producing assets across the US and UK — 19 energy-from-waste facilities

(three under construction), four independent power plants as well as four ash monofills and three

transfer stations. Wheelabrator has an annual waste processing capacity of over 6.8 million

tonnes (7.5 million US tons), and a total combined electric generating capacity of 853 megawatts.

1.15 Wheelabrator also recovers metals for recycling into commercial products. The company’s vision

‘To develop, deliver and realise the potential of clean energy’ speaks to Wheelabrator’s ongoing

commitment to the development of clean energy solutions for its customers and local

communities. Wheelabrator is owned by Energy Capital Partners, an energy-focused private

equity firm. For more on Energy Capital Partners, please visit www.ecpartners.com. For more on

Wheelabrator, please visit www.wtienergy.co.uk.

1.16 Further information on the Applicant and the Proposed Development can be found by going on to

the project website: http://www.wtikemsley.co.uk/

http://www.wtikemsley.co.uk/


March 2017 1-4

1.17 K3 CHP Limited has appointed RPS to manage the EIA process and to provide specialist topic

input. RPS is a member of the Institute of Environmental Management and Assessment (IEMA)

Quality Mark.

The Proposed Development

1.18 The Applicant is already constructing the generating station which was consented by Kent

County Council (KCC). The Environmental Impact Assessment (EIA) for the Proposed

Development must allow for the changing baseline which is the active construction site. The

PEIR also presents a comparison between the KCC consented power station and the DCO

project. This approach is outlined in more detail in Chapter 4 Assessment Methodology and

Significance Criteria.

1.19 The Proposed Development is known as ‘Kemsley Generating Station Power Upgrade’ and will

be located on a site adjacent to the Kemsley Paper Mill owned and operated by DS Smith Plc.

The Project Site (referred to in the remainder of the PEIR as ‘the Site or Assessment Site’)

extends to approximately 14.6 hectares (ha) and consists primarily of land that originally formed

part of the paper mill and used for coal storage (including land that is currently being used in

connection with the construction of the generating station), and other land (some of which is

outside the Generating Station site) that is required for access roads, drainage and landscaping,

ecology mitigation, electricity connection to the grid, a steam export pipe to the paper mill and a

surface water drainage outfall pipe to the Swale Estuary. The Assessment Site boundary

coincides with the DCO Order Limits because land subject to the IBA consent is to be used as a

construction compound for the generating station.

1.20 The extent of the Site is shown in Figure 1.1. The Site and its surroundings, and the

relationship with the paper mill and Swale estuary are shown in Figure 1.2. A detailed

description of the Proposed Development is provided in Chapter 2 The Proposed

Development.

1.21 The Project for EIA purposes comprises of the following developments:

The Kemsley Generating Station (previously referred to as the Sustainable Energy Plant)

currently being constructed in accordance with the planning permission granted by Kent

County Council in March 2012 (and as amended thereafter), and for which development

consent is sought principally for a power upgrade including:

o the surface water drainage outfall to the Swale Estuary for which a deemed Marine

License, deemed Flood Risk Activity Permit, and deemed Footpath Diversion may be

sought if required;

o means of access;

o landscaping and drainage;

o habitat creation and management;


March 2017 1-5

o a temporary construction laydown area;

o an electricity connection to the grid; and

o a steam connection to the paper mill.

The IBA Recycling Facility granted planning permission in February 2017 which would serve

the Wheelabrator Kemsley Generating Station but which does not form part of the

development consent application. This development will be implemented to serve the

generating station and is therefore assessed as part of the same EIA Project..

1.22 Figure 1.1 shows the extent of the Project Site area for EIA purposes which is the same area as

the Order Limits of the Kemsley Generating Station Proposal Site. Figure 1.4 shows the extent of

the Generating Station proposal site, and the extent of the IBA Recycling Facility site.

1.23 Environmental impacts have been studied systematically as part of the EIA process, and the

results are presented within this PEIR. This PEIR builds on the environmental survey and

assessment work completed in support of the earlier applications for the access road, generating

station and IBA facility (see below).

1.24 The baseline for the assessment has been derived from previous studies in and around the Site

conducted in support of earlier applications, and updated where necessary for the Application for

Development Consent (the DCO Application). Because the site is an active construction site, it

has been necessary for the EIA to fix the existing site conditions at a moment in time during the

progress of construction – taken to be March 2017. The conceptual construction site plan as of

March 2017 is shown in Figure 1.3. This is explained further in Chapter 4 Assessment

Methodology and Significance Criteria.

1.25 The EIA has considered impacts resulting from the construction, operation and decommissioning

phases of the Proposed Development and the PEIR proposes measures to avoid, eliminate,

reduce or mitigate any significant adverse effects on the environment. The PEIR will be widely

consulted upon prior to finalising the Environmental Statement that will accompany the

Application for Development Consent.

1.26 The EIA also addresses ‘residual’ impacts, defined as impacts remaining following the

implementation of mitigation measures. Finally, the EIA addresses the potential cumulative

impacts of the Proposed Development in combination with other relevant known proposed or

consented schemes, as outlined in Section 4: EIA Methodology; list of cumulative schemes.

Project Site Location & Surrounding Area

1.27 The Assessment Site is located to the east of the Kemsley Paper Mill Complex operated by DS

Smith Plc, Barge Way, Kemsley, Sittingbourne within the administrative areas of Kent County

Council (KCC) and Swale Borough Council (SBC).

1.28 Sittingbourne is situated approximately 2.6km south of the application site and is located centrally

in north Kent. The town of Maidstone is situated approximately 19.5km to the south west and

Gillingham is 15km to the west.


March 2017 1-6

1.29 The Project Site adjoins the Kemsley Paper Mill complex, and lies within an area allocated for

and being developed as a large area of industrial and commercial development which extends

broadly from the edge of Sittingbourne and to the east of the A249 and to Ridham Dock to the

north. It is

accessed from the A249 to the north west via Barge Way to the north along an improved internal

access road recently constructed to serve the Project Site, Kemsley Paper Mill complex and the

Knauf jetty.

1.30 The Site is bounded by the Kemsley Paper Mill complex to the west beyond which are the

residential areas of Kemsley and Milton Regis within the settlement of Sittingbourne,

approximately 0.75km from the Project Site’s boundary.

1.31 To the north, the Project Site is bounded by an area of reedbed known as Kemsley Marshes

which is situated to the east of the improved access road which serves the Project Site. To the

east of the improved access road is a HGV trailer park area which serves the Kemsley Paper Mill

complex.

1.32 Beyond Kemsley Marshes, along Barge Way, Ridham Dock is located approximately 1.4km from

the Project Site. The industrial and commercial area also served by Barge Way is situated

between Kemsley Marshes and Ridham Dock. The A249 from which access to the site is derived

via Barge Way is located is located approximately 1.1km to the north-west the Project Site.

1.33 The site is bounded by the Swale Estuary to the east with the Isle of Sheppey being located

across the Estuary, approximately 0.35km from the Project Site. To the south the site is bounded

by an area of restored landfill (circa. 11Ha in area) within the Kemsley Paper Mill Complex.

1.34 A network of surface drainage channels is located within immediate area of the site with drainage

channels running to the east of the improved access (and to the west of the Generating Station

complex site) on a south to north alignment, and to the north of Kemsley Marshes in west to east

alignment towards the Swale Estuary.

1.35 In addition to the recent applications related to the Proposed Development and the IBA Recycling

Facility, the Project Site has itself has an extensive planning history. These are summarised in

Chapter 3 – Need, Alternatives and Design Evolution.

Kemsley Generating Station Site

1.36 The extent of the Proposal Site (to which the Order Limits of the DCO would apply) is

approximately 14.60 ha in area, as shown on Figure 1.1. The Proposal Site comprises of the site

of the Generating Station complex, and the construction site village as well as the improved

access road, electricity grid connection, steam pipe connection, and surface water drainage

outfall.

1.37 The different elements of Works pertaining to the draft Order are summarised in Table 1.1 below

and shown on Figure 1.4 - Overall Works Plan.


March 2017 1-7

Table 1.1 - DCO Works Areas

Works Areas Ha

Work No.1a: Generating Station 11.93

Work No.1b: Generating Station, supporting buildings, works and areas 4.08

Work No.2: Access 2.88

Work No.3: Electricity Connection to Grid and Steam Connection to Paper Mill 0.87

Work No.4a: Landscaping & drainage 3.21

Work No.4b: Outfall to Swale (above MHWS) 0.67

Work No.5: Marine Works Plan (between MHWS & MLW) 1.47

1.38 The majority of the Proposal Site will be taken up by the Generating Station complex

(approximately 11.93 ha) its internal access road, concrete apron, surface water drainage

infrastructure and attenuation pond, and landscape areas (incorporating habitat areas), referred

to as Works No. 1A. The Proposal Site extends into the Intertidal area between Mean High Water

Springs (MHWS) and Mean Low Water (MLW) to provide an area in which to locate and construct

the surface water outfall.

1.39 The improved access road and its drainage infrastructure and attenuation ponds are largely

complete. The construction village area coincides with the consented IBA Recycling Facility Site,

which in turn overlaps the Proposal Site. The Proposal Site also incorporates the electricity grid

and steam pipe connections and routes (shown as limits of deviation).

1.40 The topography of the Proposal Site and surrounding area is generally flat with an elevation of

approximately 5 to 6 metres Above Ordnance Datum (m AOD).

1.41 Construction commenced on the Proposal Site in July 2016 with the implementation of the

improved access road permissions (see planning history below). In accordance with the extant

planning permission granted by Kent County Council (KCC) the construction of the Generating

Station complex (Works No. 1B) commenced in August 2016 (see planning history below).

1.42 Prior to the commencement of development on the Generating Station site as shown on Work

Number 1B, the historic use of that part of the Proposal Site was mostly subject to natural

colonisation by vegetation comprising of scrub and unimproved neutral grassland,

Ephemeral/short perennial, and tall ruderal in addition to significant areas of spoil and

hardstanding resulting from the contractor’s laydown area established during the construction of


March 2017 1-8

the Phase 2 extension to the existing fluidised combustion plant associated with the existing CHP

(Combined Heat and Power) plant within the Kemsley Paper Mill complex.

1.43 The Proposal Site has an extensive site history relating to the Kemsley Generating Station itself,

and the improved access road. These are summarised in Chapter 3 – Need, Alternatives and

Design Evolution.

The Incinerator Bottom Ash (IBA) Recycling Facility Site

1.44 The IBA Recycling Facility Site’s location is centred upon OS grid reference TQ920667 (NGR

592169, 166647), and comprises 2.65 hectares of land which is broadly rectangular in shape and

is accessed via the improved access road located to the west.

1.45 The site is located immediately adjacent to the Proposal Site currently under construction to the

south, an area of reed bed to the north, and Barge Way beyond. The Kemsley Paper Mill

Complex lies to the west of the site and the Swale Estuary to the east.

1.46 The IBA Recycling Facility site is currently being used as the construction village associated with

the construction of the Generating Station. The site has been previously associated with landfill

uses, a tramway and railway sidings and was host to stockpiles of various material over recent

years.

1.47 Prior to the commencement of the Generating Station construction, the site was mostly

comprised of bare ground, having previously been temporarily cleared of all vegetation during the

implementation of the Ecology Enhancement and Mitigation Plan (EMMP) in accordance with the

extant permission for the Generating Station. Prior to clearance, the site comprised regenerating

neutral grassland and some areas of dense scrub along with piles of temporarily-stored spoil. The

site was cleared of vegetation and the associated reptile population translocated to surrounding

habitat (as per the EMMP).

1.48 The nearest watercourses to the proposed development are the ditch running parallel to (and

under) the access road to the immediate west, ditches and ponds within the marsh to the north,

the Swale Estuary to the east and Milton Creek to the south.

1.49 Planning permission was granted by Kent County Council for the construction and operation of an

Incinerator Bottom Ash (IBA) Recycling Facility on land adjacent to the Kemsley Sustainable

Energy Plant on 9 February 2017 (KCC reference SW/0265/2016).

Potential Environmental Sensitivities/ Receptors

1.50 When undertaking an EIA it is important to understand which receptors will be considered as part

of the assessment. Key receptors for each topic area have been identified as part of the

assessment process and full details are included in the relevant chapters. Where distances are

quoted here and in following chapters the distance is defined (unless otherwise stated) as the

shortest distance between two described locations, for example from closest point of the red line

boundary to the closest point of a designated site boundary. The potentially sensitive receptors to

the Proposed Development include:

human receptors –


March 2017 1-9

o local residential properties in close proximity to the industrial area of Kemsley;

o local residents of the surrounding urban areas including Sittingbourne;

o pedestrians including users of local recreational facilities such as the Saxon Shore Way

coastal path ;

o General public users of land adjacent to the site during construction/ decommissioning

including vehicle users;

o Construction workers, including site visitors;

o Site end users (e.g. staff and visitors to site) during operation and maintenance;

ecological receptors –

o ecological receptors such as species and habitats immediately within and adjacent to

the Site particularly those identified as qualifying features of nearby designations;

o The Swale Special Protection Area (SPA) (adjacent to the eastern red line boundary)

o The Swale Ramsar (adjacent to the eastern red line boundary);

o Medway Estuary and Marshes SPA (2.1 km north);

o Medway Estuary and Marshes Ramsar (2.1 km north);

o Thames Estuary and Marshes SPA (8.7 km north west);

o Thames Estuary and Marshes Ramsar (8.7 km north west);

o Queensdown Warren SAC (9.3 km south west);

o Outer Thames Estuary SPA (8.0 km north);

o The Swale Estuary Marine Conservation Zone (MCZ) (within the project site);

o The Swale Site of Special Scientific Interest (SSSI) (adjacent to the eastern red line

boundary);

o Medway Estuary and Marshes SSSI (2.1 km north);

o Elmley National Nature Reserve (NNR) (0.4 km east);

o Isle of Sheppey (marsh harrier habitat)

hydrological/ flood risk, geological and hydrogeological receptors –

o Swale Estuary, to the east of the Site,


March 2017 1-10

o Land that is susceptible to flood risk

o groundwater resources;

cultural heritage, landscape and visual receptors

o Designated landscapes including the North Kent Marshes Special Landscape Area

(SLA), an Area of High Landscape Value approximately 1 km to the south east of the

site, the Kent Downs Area of Outstanding Natural Beauty (AONB);

o Castle Rough scheduled monument approximately 500 m to the south west and the

remains of the Old Murston Church approximately 1.6 km to the south;

o The Saxon Shore Way long distance path as it follows the top of the sea defences

which line The Swale and Milton Creek;

o Several small settlements, public rights of way and roads which provide vantage points

for receptors to gain views back to the site; and

o Water-borne receptors using Swale Estuary for both leisure and commercial purposes.

traffic and transport receptors –

o local transport network including junctions to the Motorway network; and

other receptors

o Air Quality Management Area (AQMA) (4 No. within 10km)

o Residential noise receptors in Kemsley nearest to the site, for example at Reams Way,

Walsby Driv and Murston Caravan Park, Kings Hill Farm and Little Murston together with

users of Saxon Shore Way. .

1.51 Figures 1.6 Statutory and Non-statutory designations and 1.7 Heritage assets, illustrate the key

environmental considerations within the study area (the Site and surrounding areas).

The DCO Process

1.52 The Proposed Development falls within the definition of a ‘Nationally Significant Infrastructure

Project’ (NSIP) under Section 14(1)(a) and Section 15(2) of the Planning Act 2008 because it

is an onshore generating station within England, that will have a generating capacity greater

than 50 MWe output. As such, a Development Consent is required to authorise the Proposed

Development under Section 37 of the Planning Act.

1.53 Development Consent is granted by the SoS by means of an ‘Order’ (a DCO). A DCO has the

effect of granting planning permission in addition to a range of other consents and

authorisations. Section 115 of the Planning Act also provides for DCO to include consent for

‘associated development’, that is, development that is associated with (i.e. to either support the


March 2017 1-11

construction or operation of or help to address the impacts of) the ‘principal development’

(i.e. the generating station).

1.54 An application for Development Consent will be submitted to the Planning Inspectorate (PINS)

acting on behalf of the SoS. Subject to the application being accepted, PINS will examine it and

make a recommendation to the SoS, who then subsequently decides whether to grant a

DCO.

The EIA Scoping Exercise

1.55 A voluntary EIA is being carried out and an ES will be produced and submitted in support of the

DCO application in accordance with Regulation 5 (2)(a) of the Infrastructure Planning

(Applications: Prescribed Forms and Procedure) Regulations 2009 (‘APFP Regulations’).

1.56 The issues to be addressed within the ES were identified in the EIA Scoping Report

submitted to PINS in December 2016 (Appendix 1.1). This Scoping Report was informed by

experience from the earlier applications. The SoS’s Scoping Opinion was received on 20th

January 2017, including the formal responses received by PINS from consultees on the EIA

Scoping Report (Appendix 1.3). Key issues raised in the Scoping Opinion are summarised at

the start of each technical chapter of the PEIR and have been considered during the EIA

process. .

1.57 The EIA scoping process confirmed that the following topics did not need to be considered as

part of the EIA of the Proposed Development and could be scoped out:

Health Impacts Assessment

Hydrocarbon emissions from construction HGVs

Transboundary effects

Purpose of the PEIR

1.58 The Preliminary Environmental Information (PEI) Report is being published for the formal

(statutory) consultation (under Sections 42 and 47 of the Planning Act 2008). Consultation

will run between 8th March 2017 and 19th April 2017. PEI is defined as ‘information referred to

in Part 1 of Schedule 4 (information for inclusion in environmental statements) which (a) has

been compiled by the applicant; and (b) is reasonably required to assess the environmental

effects of the development (and of any associated development)’.

1.59 In order to enable the consultees to develop ‘an informed view of the project’ (as required by the

Infrastructure Planning (Environmental Impact Assessment Regulations 2009 (the EIA

Regulations), this PEI Report presents preliminary findings of the environmental assessments

undertaken to date. This will allow consultees the opportunity to provide informed comment on

the Project, the assessment process and preliminary findings through a consultation process prior

to the finalisation of the Environmental Statement (ES).

1.60 Feedback on the PEI report received from both Section 42 consultees (statutory bodies) and

Section 47 consultees (members of the public), along with a summary of other issues raised


March 2017 1-12

during consultation relevant to the Proposed Development will be recorded. The final ES will

include reference to where issues raised were considered further and whether they have

informed the evolution of the project design. Where feedback from the earlier consultation

exercises has also contributed to the adoption of design changes, approaches to construction or

specific mitigation measures, they will be described in detail in Chapter 3 Need, Alternatives

and Design Evolution.

Consultation

1.61 Consultation is integral to the preparation of DCO applications and the development of a

comprehensive and balanced EIA of the development in question. The views of consultation

bodies and the local community serve to focus the environmental studies and to identify

specific issues that require further investigation as well as to inform aspects of the design

of the Proposed Development. It is an on-going process as part of design development.

1.62 The Planning Act 2008 requires applicants for Development Consent to carry out formal

(statutory) pre-application consultation on their proposals. There are a number of requirements

as to how this consultation must be undertaken that are set out in the Act and related

regulations.

1.63 Section 42 of the Planning Act 2008 requires the applicant to consult with ‘prescribed

persons’, which includes certain consultation bodies such as the EA and Natural England (NE),

relevant statutory undertakers, relevant local authorities, those with an interest in the land as

well as those who may be affected by the development.

1.64 Section 47 of the Planning Act 2008 requires the applicant to consult with the local

community on the development. Prior to this, the applicant must agree a Statement of

Community Consultation (SoCC) with the relevant local authorities. The SoCC must set out the

proposed community consultation and, once agreed with the relevant local authorities, a SoCC

Notice must be published in local newspapers circulating within the vicinity of the land in

question. The community consultation must then take place in accordance with the agreed

SoCC.

1.65 In addition to the above, Section 48 of the Planning Act 2008 places a duty on the

applicant to publicise the proposed application in the ‘prescribed manner’ in a national

newspaper, The London Gazette and local newspapers circulating within the vicinity of the

land.

1.66 Finally, Section 49 places a duty on the applicant to take account of any relevant

responses received to the consultation and publicity that is required by Sections 42, 47 and 48.

1.67 The Applicant has consulted widely as part of the previous applications and the Proposed

Development has been influenced by that feedback. However, consultation both formal and

informal referred to in this section is the renewed consultation dedicated to the DCO as

prescribed in the Act and not any other historic consultation.


March 2017 1-13

1.68 The pre-application consultation that has been undertaken by the Applicant is briefly outlined

below and will be more fully documented within the Consultation Report that forms part of the

application for Development Consent:

Informal (non-statutory) consultation - this has encompassed early meetings with SBC and

KCC and key consultation bodies; informal consultation with the local community local to the

Site between September 2016 to March 2017, including a number of public exhibitions; and

informal consultation with the relevant local authorities on the preparation of the SoCC for

the community consultation under Section 47;

Formal (statutory) consultation, comprising:

o Section 47 – formal consultation on the SoCC with the relevant local authorities;

publication of the SoCC Notice between 18 November 2016 and 16 December 2016;

o Section 42 and Section 48 – formal consultation with ‘prescribed persons’ (relevant

consultation bodies); between 8 March 2017 and 19 April 2017; and

o EIA related consultation – this has taken place alongside the informal and formal pre-

application consultation and relates specifically to issues of assessment methodology

raised during and after the scoping and PEI stages.

1.69 EIA related consultation forms an important part of the overall pre-application consultation

process. The Scoping Opinion from the SoS and consultation on the PEI Report in

particular have informed the development of the EIA and assisted in the preparation of the

final ES. Furthermore, a key characteristic of the EIA consultation has been the on-going

dialogue with the key consultees following the EIA scoping process and the preparation of

the PEI Report to inform the final ES.

1.70 The issues that have been raised through consultation have in part been considered and

addressed within the design evolution of the Proposed Development and will be fully addressed

after consultation within the ES. The pre-application consultation undertaken by the Applicant

will be fully documented within the Consultation Report that forms part of the DCO

application. This includes a separate section on EIA related consultation as recommended

within the PINS Advice Note on the preparation of consultation reports.

Timing of the Proposed Development

1.71 Construction started in July 2016 and subject to the DCO being granted, the generating station

will operate at up to 75MWe gross capacity from Q4 2019 In the absence of a DCO being

granted, the generating station will operate at up to 49.9MWe from the same date. This is

because the turbine installed will be capable of operating at either capacity through a limiter

device.


March 2017 1-14

Environmental Permit

1.72 The Proposed Development will require an Environmental Permit under the Environmental

Permitting (England and Wales) Regulations 2010, as amended. The consented generating

station has an existing permit to operate granted by the EA in July 2011. It is intended that an

application for an updated Environmental Permit for the power upgrade will be submitted to the

EA within a similar timescale to the DCO application so that a permit can be issued by the EA

during the DCO determination process. The IBA will also need its own permit which will be

submitted at the same time so that consultees can understand the effects of all processes within

the project site. This ES has considered all potential environmental effects of the Proposed

Development, and will therefore also inform and support the Environmental Permitting process.


March 2017 2-15

2 The Proposed Development

Overview

2.1 The Wheelabrator Kemsley Generating Station is a consented energy from waste plant which is

currently under construction that will provide low pressure steam to the existing Kemsley Paper

Mill and low carbon electricity to the grid. The Generating Station will help to diversify the long

term energy requirements at the Paper Mill which is the second biggest recovered fibre-based

paper operation in Europe.

2.2 K3 CHP Ltd (the Applicant) is preparing an application for development consent the primary

purpose of which is to secure an increase in the maximum electrical power output of the

consented Wheelabrator Kemsley Generating Station, from 49.9 Megawatts electrical (MWe) to

up to 75 MWe – the power upgrade application.

2.3 An Environmental Statement (ES) for the Generating Station was prepared in 2010 (the 2010 ES)

and planning permission has already been granted by Kent County Council under the Town and

Country Planning Act 1990. A summary of the existing permissions is provided in Chapter 3 –

Need, Alternatives and Design Evolution.

2.4 The proposed increase in the power output of the Generating Station to an up to 75MWe facility

means that consent to operate at that level will need to be granted by the Secretary of State for

Department for Business, Energy & Industrial Strategy (DBEIS) under the Planning Act 2008,

which replaced the licensing provisions of the Electricity Act 1989, Section 36, for new generating

stations greater than 50MW capacity4. The new consent will be in the form of a Development

Consent Order (DCO).

2.5 The Wheelabrator Kemsley Power Upgrade (referred to as ‘the Proposed Development’) is to be

built pursuant to the terms of extant planning permissions which consented the existing facility,

with the same benefits, but the applicant now wishes to operate the plant with a greater maximum

electrical output. The consented scheme already allows the plant to operate at up to 49.9 MWe

(gross) but the Applicant now wishes this maximum operational limit to increase to up to 75 MWe

(gross). The power upgrade is the only reason for needing to seek a DCO. However, in order to

secure one complete consent for the facility, the applicant will also seek consent for its

construction and operation. There will be no change to the types and quantum of fuel throughput,

nor any changes to emissions in comparison with the consented facility.

2.6 During normal operation, with steam being supplied to the Paper Mill, it is anticipated that the

Kemsley Generating Station will be capable of exporting approximately 45 MWe net low carbon

electricity to the grid through the use of pre-processed Solid Recovered Fuel (SRF) waste

Municipal Solid Waste (MSW) and Commercial and Industrial’ (C&I) waste. The upgraded facility

would be considered a Nationally Significant Infrastructure Project (NSIP) requiring a DCO to be

made under the provisions of the 2008 Act. In England, the Planning Inspectorate examines

4 The 2008 Act sets out thresholds above which certain types of infrastructure development are considered to be nationally

significant – in this case an electricity generating station of greater than 50MWe capacity


March 2017 2-16

applications for development consent. In seeking to secure a new consent under the Planning

Act 2008 for the Proposed Development, the Applicant is also undertaking a voluntary

Environmental Impact Assessment (EIA) to ensure all of the environmental effects of the Projects

as previously consented and proposed going forward from March 2017 are assessed in a formal

EIA, compliant with the EIA regulations relevant to the new consent5. In submitting the application

in this way it is expected that the existing permissions will be treated as a material consideration

in the Secretary of State’s decision making process.

2.7 The detailed design of the project is now at an advanced stage and the EPC Contractor is in its

first year of the construction programme, main activities being the civil works on site. The Works

Plan (see Figure 1.4) defines the areas within which each element of the development is being

constructed.

2.8 Timing for the construction and operation of the development is as follows:

Construction work has commenced in Quarter 3 of 2016 and will consist of approximately

36 months of on-site construction work. The construction phase is therefore anticipated to

be completed by Quarter 3 of 2019; and

The Proposed Development is expected to commence full commercial operation in Q3 of

2019.

2.9 It is envisaged that the project will have an operating life of up to 40 years and so

decommissioning would be currently anticipated to commence in approximately 2059.

2.10 Power output will be influenced by the amount of fuel throughput and the Net Calorific Value

(NCV) of the fuel which will vary depending on the fuel content. The anticipated fuel throughput

of the facility is between 500,000 to 550,000 tonnes per annum (tpa) with an assumed average

NCV of 10.5 MJ/ kg, but the range is expected to vary from 8.5 to 13 MJ/kg. Electricity generation

does not vary with NCV.

2.11 The fuel used by the project will be delivered by road. As the plant is a merchant facility it will be

capable of accepting fuel from a variety of sources which themselves may change over the

lifetime of the plant. The preferred transport route for different fuel contracts will be determined on

a case by case basis through discussions with the fuel supplier, based on proximity to the site,

volume of fuel, and the prevailing economic considerations at the time. However, for assessment

purposes, and based upon the assumptions used on the consented facility, it has been assumed

that fuel will be sourced from within Kent County with the balance from London, the South East

and elsewhere in the UK.

2.12 The finished ground level of the main buildings area of the Site is assumed to be nominally 6.3m

AOD. The ground is being levelled across an area suitably sized to accommodate the structures,

storage and access and parking requirements. Areas surrounding the buildings are more likely to

be landscaped and undulating. They will not necessarily be levelled from existing pre-

development levels as there is no technical requirement to do this.

5 The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009


March 2017 2-17

2.13 For EIA purposes, in addition to the Kemsley Generating Station for which development consent

is sought, the project also comprises of the consented Incinerator Bottom Ash (IBA) Recycling

Facility on the adjoining site and which will serve the Kemsley Generating Station. Planning

permission for the IBA Recycling Facility was granted by Kent County Council in February

2017and as such, does not form part of the application seeking development consent..

Summary of Carbon Benefits

2.14 The Kemsley Generating Station will produce electrical power and steam once it is fully

operational. Power will be sold to the grid and 50MWth of thermal energy in the form of steam will

be available for export to the paper mill which will complement the paper mill’s own steam

generation and usage capacity. The paper mill currently operates an 80MWe CHP unit fired by

natural gas and a combustion unit utilising mill rejects and offcuts to produce additional steam for

internal usage.

2.15 The parallel operation of the Kemsley Generating Station and the paper mill CHP means that

there are a range of scenarios along a continuum where steam or electricity generation can be

prioritised as the mill requires it. For example, at times when less steam is required, more

electricity can be exported to the grid and visa versa. As a consequence, the facility can operate

on a range of heat balances.

2.16 The operating mode used in this environmental assessment uses an artificial case where all

maxima are stated. However, the application for an Environmental Permit has selected a nominal

operating mode. These are complimentary assessments and don’t contradict each other. The

range of operating modes are summarised in Table 2.1 and as a graph at Plate 2.1 below.

Table 2.1 – Modes of Operation – Range of Heat Balances

Units Min Max Average

Range of steam supply to the paper mill tph 4 110 70

Range of electricity exported to the grid MWe 34 60 45


March 2017 2-18

Plate 2.1 Kemsley Generating Station Steam Export Vs. Net Electrical Power Export

2.17 In quantifying the balance of carbon benefits of the Proposed Development, the components to

be considered include:

Transport – the difference in carbon expenditure as a result of waste transport mileage and

modes used;

Avoided Carbon Release – the carbon that wouldn’t be released as the waste decomposes

in a landfill site (assuming a degree of landfill gas recovery);

Avoided Fossil Fuel Use – the substitution of fossil fuels for both the heat and electricity

generation; and

2.18 Overall, the proposed development is anticipated to offer a significant climate change mitigation

benefit. The overall greenhouse gas (GHG) emission reductions expressed in tonnes of carbon

dioxide equivalent (tCO2e) per annum will be set out in the ES.

2.19 The proposed development’s direct GHG emissions from waste combustion and resources

consumption are roughly balanced by the GHG emissions reductions due to the energy it exports,

which displaces conventional electricity generation from a mix of sources for the national grid and

existing steam generation for the Kemsley paper mill.

2.20 The proposed development’s benefits in the context of climate change policy will be provided in

Chapter 11 Climate, Air Quality and Health Impacts.

0

10

20

30

40

50

60

70

0 20 40 60 80 100

Ne

t P

ow

er

(MW

e)

Steam export (t/h)

Steam export vs Net Power

Steam export vs Net Power


March 2017 2-19

Overview of the Process

The Generating Station

2.21 In outline, the process will be as follows:

Reception of Waste Fuel

o The plant will be capable of processing 550,000 tonnes of pre-treated waste fuel

comprising Solid Recovered Fuel (SRF) waste, Commercial & Industrial (C&I) waste,

and Municipal Solid Waste (MSW);

o The plant may accept up to approximately 25,000 tonnes per annum of waste plastic

from the Kemsley Paper Mill (included in the above);

o The pre-treated waste fuel will be delivered to the plant by HGV, within an enclosed

vehicle and weighed upon entry;

o The vehicles will transport the pre-treated waste fuel to a reception area that receives

the waste, referred to as the Tipping Hall and Waste Fuel Bunker;

o The pre-treated waste fuel will be tipped into the bunker which is designed for a storage

capacity of up to 5 days fuel

Thermal Treatment

o Overhead cranes transfer the pre-treated waste fuel into the furnace feed hopper for

each combustion line;

o Heat is applied to break the waste down into gases;

o An inclined, reciprocating, metal grate slowly moves the fuel through the heating

process, with minimum operating temperatures of 850°C;

o Primary combustion air is fed into the furnace through the underside of the grates by a

primary air fan. Secondary air will also be injected at high velocity through nozzles

positioned in the walls of the combustion chamber above the level of the waste. This will

create turbulence to help achieve complete combustion;

o Bottom ash will be ejected and cooled (quenched in water);

Conversion to a Transportable Form of Energy

o The steam generation system is located above the grate. Hot combustion gases pass a

series of boiler tubes filled with water, where the gasses are cooled. The water in the

tubes is heated to generate high-pressure steam. The steam is used to drive a turbine

generator and produce electricity for sale to the grid as well as producing steam for both


March 2017 2-20

internal usage and supply to the paper mill. Some electricity produced is used to run

the plant – this is the parasitic load.

o Low pressure steam is extracted for use as process steam within the paper mill to dry

product. The steam required in the mill will be used at 10.6 to 11barg. The steam is

conveyed from the steam turbine to the paper mill’s low pressure steam header via a

pipe bridge constructed over the mill’s internal road to the south of the Generating

Station site;

o The Wheelabrator Kemsley Generating Station will generate up to 75 MWe gross

electricity. The electrical energy is generated in the synchronous generator at a voltage

of 11kV. This is transformed to a voltage of 400V and 660V to supply the plant itself.

Electricity exported from the plant is fed to the local distribution grid via a transformer

operating at 132kV. The plant will produce an average of 50 MWth per hour of steam

which will be fed to Kemsley Paper Mill as an integral part of its energy supply;

o The facility is a Combined Heat and Power (CHP) plant because heat from the process

is used by the paper mill for drying product;

o The Generating Station is a recovery operation under the R1 calculation of Waste

Framework Directive.

o In return to the steam provided to the paper mill, condensate water at 50°C will be

returned to the Wheelabrator Kemsley Generating Station.

Flue Gas Treatment

o Combustion gasses will be cleaned in Flue Gas Treatment (FGT) system to control

emissions of nitrogen oxides, acid gases, particulates, dioxins and furans and heavy

metals;

o The dry conditioned flue gas treatment system turns nitrogen oxides (NOx) produced

during combustion to nitrogen and steam. The reducing agent is dry urea, which reacts

with nitrogen dioxide of the flue gases within a temperature range of 850°C and 950°C;

o The flue gas is also treated with hydrated lime which enables separation of chloride and

sulphur dioxide. A dry sorption reactor (Powdered Activated Carbon) is introduced to the

flue gas to separate heavy metals, dioxins and furans by adsorption;

o The gas then passes through a fabric filter where particulates (fly ash) are removed.

Most of the material precipitated in the fabric filter is initially reactivated and then re-

circulated back to the flue gas treatment reactor using screw conveyors. The remainder

is transported by conveyors to residue silos . Once collected, the ash is loaded into

sealed containerised vehicles and transported from the site for disposal within a

permitted facility;


March 2017 2-21

o No waste water is produced in the dry conditioned flue gas treatment system;

o The cleaned exhaust gases will be released to atmosphere via a stack (one for each

combustion line) 90 m high (with the top of the stack fixed at 96.3 m AOD);

o Continuous emissions monitors analyse and record the properties of stack emissions

and relay the data back to the control room.

Operation, Availability and Maintenance

o The Generating Station will operate 24 hours per day, seven days per week with

planned offline periods for maintenance.

o Fuel will also be delivered on a 24 hours per day, seven days per week basis.

o It is assumed that each combustion line will have >90% availability as a result of

planned and unplanned downtime. A two line plant provides operational flexibility during

periods of maintenance, enabling one line to be shut down whilst the second continues

to operate. Down time will be for a period of about 3 weeks per line per year.

Performance Parameters

2.22 Table 2.2 sets out the expected overall design performance of the Proposed Development. The

design fuel, NCV and thermal load of the Proposed Development will be stipulated in the design

specification.

Table 2.2 Performance Parameters

Units Total

Maximum generation capacity of the facility MWe Up to 75

Expected net electrical output to the grid MWe Circa 45

Expected net efficiency (power and steam) % Circa 49.2%

Assumed annual average fuel NCV MJ/Kg 10.5

Expected annual availability % Circa 91.3%

Expected annual exported electricity to grid GWh Circa 360

Fuel throughput based on NCV of 10.5 MJ/ kg and annual availability tpa Circa 550,000

Expected steam exported to the Paper Mill MWth Circa 50

Parasitic load MWe Up to 6.4

2.23 The layout of the Proposed Development is shown in Figure 2.1a.


March 2017 2-22

Components of the Proposed Development

2.24 This section provides further detail on the components of the Proposed Development within the

DCO (Application Site) red line boundary for which consent is sought.

The Proposed Development will comprise an energy from waste CHP and associated

buildings, structures and plant, including:

fuel reception and storage facilities, consisting of a tipping hall, a shredder, storage bunker

and cranes;

a combustion system housed within a boiler hall comprising two combustion lines and

associated boilers;

a steam turbine and generator housed within a turbine hall;

a bottom ash handling system, including storage hall and ash collection bay;

a flue gas treatment system, including residues and reagent storage silos and tanks;

two stacks and associated emissions monitoring systems;

a cooling system comprising air cooled condenser (ACC) units;

a compressed air system;

urea storage tanks;

a waste water pit;

a demineralised water treatment plant and polishing plant;

fire water tanks and fire protection facilities;

diesel generator for emergency shut down only;

pipe racks and pipe runs;

CHP (low pressure steam to paper mill) and condensate water return from the paper mill;

an administration and control building;

a workshop;

a stores building;

main access road


March 2017 2-23

hardstanding, internal vehicular access roads, vehicle turning and waiting areas, pedestrian

footpaths;

staff and visitor car parking;

an external fuel tank;

2 weighbridges;

a surface water attenuation pond and surface water drainage connection and pipework to the

Swale Estuary;

a connection to the electricity grid including transformer and connection to sub-station. A

Grid Connection Statement will be presented with the application;

an external waste water pit

an electrical switch yard HV transformers;

external lighting;

hard and soft landscaping and biodiversity enhancement measures.

fencing, boundary treatment and other means of enclosure;

signage;

CCTV and other security measures; and

2.25 Supporting buildings and works for which consent is not sought include:

telecoms and utilities apparatus and connections; and

foul sewer connection and drainage system.

2.26 A DCO is not sought for the construction and operation of the IBA recycling facility as permitted

under the TCPA in February 2017. This will be built and operated pursuant to this planning

permission.

Design

2.27 The design of the Proposed Development has followed an iterative process based on preliminary

environmental assessments, consultation with statutory and non-statutory consultees and

engagement with contractors and equipment providers. Chapter 3 Need, Alternatives and

Design Evolution describes this process further, including options that have been considered

and discounted or amendments made to the concept design.

2.28 A number of the key design features of the Proposed Development are presented in the below

table.


March 2017 2-24

Table 2.3 Design Parameters

Design Aspect Height (m

AOD)

Gross

External

Area (m2)

Tipping Hall 27.3 2310

Fuel Bunker building 42.3 2590

Control room and administration block 42.3 457

Boiler hall 56.3 1858

Stairs and lift 59.8 73

Substation compound & control room 13.3 2419

Circuit breaker, transformer and switchyard 9.5 429

Turbine hall 29.5 1031

Air Cooled Condensers (ACC) 31.2 2594

Stack 96.3 24

Ash collection bay 27.5 544

Workshop 29.5 787

Weighbridge gate house 12.8 505

2.29 The appearance and material finishes of the Generating Station have been selected in response

to the surrounding context. Plans and elevations of the Generating Station are shown at Figures

2.1a to 2.1c. In summary, the Generating Station’s side panels will be constructed from cladding

comprising of:

At the lower level - Anthracite coloured, vertically laid trapezoidal profile insulated cladding

panel

A random cladding pattern consisting of horizontally laid micro-rib profile insulated cladding

panels made up of terracotta, merlin grey, anthracite, hamlet panels

At the upper level – Albatross Grey coloured horizontally laid micro-rib profile insulated

cladding panels

2.30 Chapter 5 provides an assessment of the Landscape and Visual Amenity effects.

Development Description by Process Area

Fuel Reception and Storage

2.31 The fuel reception and storage will comprise two weighbridges and a fully enclosed fuel reception

area, incorporating a tipping hall and enclosed fuel storage bunker. Fuel will be delivered by

heavy goods vehicles.

2.32 Upon arrival the vehicles will be identified and weighed. The tipping hall will be fully enclosed, and

maintained under slight negative pressure to reduce the risk of odours escaping. The storage


March 2017 2-25

bunker will be of sufficient size to hold up to five days of waste fuel, to facilitate the Proposed

Development being able to operate 24 hours a day.

2.33 The pre-treated waste fuel will be delivered to the plant by covered delivery vehicles. The loads

will be weighed upon entry to the site at the weighbridge located at the site entrance. The delivery

vehicles will transport the waste fuel to the reception hall using the dedicated circulatory access

roads within the site. All delivery vehicles will be directed to the unloading bay where the pre-

treated waste fuel will be tipped into the bunker. The plant, and therefore the bunker, is designed

to accept up to 3000 tonnes per day. The plant will process waste through the thermal treatment

process at a rate of up to 2 x 37 tonnes per hour.

2.34 Access to and from the reception hall will be via entrances fitted with fast acting doors which will

remain closed unless vehicles are entering or exiting the hall. The floor area within the hall will be

periodically washed down to ensure clean operation.

2.35 The fuel bunker is accessed from seven gates which are controlled by the crane driver or by a

member of staff in the tipping hall to ensure they only open when discharge from a vehicle is to

take place. The bunker arrangement takes the form of a rectangular pit set down in to the floor of

the reception area. It will have a depth of 6.5 metres below the general floor level of the plant.

Within the bunker, the fuel will be mixed to provide for a regular mix to the plant and is then fed to

the charging hoppers which in turn feed the grate stoker in the furnace located within the boiler

house.

2.36 Operators will monitor the waste fuel flow via an automated weighing system and CCTV system

in the control room.

2.37 The fuel bunker is ventilated under negative pressure by the primary air fan. During normal

operation the exhaust air is fed into the incineration system.

Combustion System

2.38 Two combustion lines and associated boilers will be located in the boiler hall. While there are

several alternative technologies available for combustion of waste fuel, the technology considered

to represent best available technique (BAT) for the Proposed Development is a reciprocating

grate- based system.

2.39 The generating station will be designed and operated to meet the requirements of the Industrial

Emissions Directive (IED) and its operations will be strictly regulated by the EA under an

Environmental Permit6. Combustion will be automatically controlled through the fuel feed rate,

addition of combustion air and control of the grate, in order to achieve complete combustion of the

fuel and control emissions of pollutants. Process optimisation will be maintained through

monitoring of oxygen and carbon monoxide levels and temperatures within the combustion

system.

6 An Environmental Permit was granted by the EA for the KCC Generating Station and a revised permit is

being sought for the power upgrade project.


March 2017 2-26

2.40 The hot combustion gases produced during the combustion process will pass through the boiler

to raise steam, before being passed to the Flue Gas Treatment (FGT) system discussed below.

Steam Turbine

2.41 It is proposed that the two combustion lines will serve a single steam turbine. The turbine is CHP

enabled and is designed to provide optimum efficiency when supplying steam to the paper mill

and electrical power to the grid.

Cooling System

2.42 The Proposed Development will receive feed water from the paper mill in return of the steam

exported for re-use within the water steam cycle.

2.43 ACCs condense steam from the turbine exhaust by cooling low pressure steam with air. The

steam travels down the inside of finned metal tubes whilst air is blown by fans across the outside

of the tubes. As the steam loses heat it cools and then condenses. The condensate is collected in

a condensate tank and then pumped to a feed water tank ready for recirculation back to the

boilers.

Flue Gas Treatment (FGT)

2.44 The flue gas treatment system will be designed to achieve the emission limit values specified in

the IED and enforced through the Environmental Permit granted for the operation of the Proposed

Development.

2.45 Each combustion line will be fitted with:

Selective Non-Catalytic Reduction (SNCR) using dry urea for the abatement of emissions of

nitrogen oxides (NOx) if required;

lime (or suitable equivalent) injection for the abatement of acid gases including

sulphur dioxide;

activated carbon injection for the abatement of dioxins and furans and heavy metals; and

fabric bag filters for the abatement of particulate emissions, including the injected lime and

activated carbon. Residues from the bag filters are reactivated and recirculated into the into

the FGT system.

2.46 Details of the specific measures to be installed to minimise air quality impacts arising from any

emissions from the process are presented in Chapter 11 Climate, Air Quality and Health

Impacts.

Stacks

2.47 Treated flue gases will be emitted to the atmosphere via two flues each housed within their own

stack located to the Southwest of the boiler house. Flue gas will be emitted from the flues with a

velocity in excess of 19 m/s. Combined with the thermal buoyancy of the warm gas, the flue

gases will rise before becoming dispersed.


March 2017 2-27

2.48 The stack will be built to the minimum height necessary to ensure adequate dispersion of the

emitted pollutants (as defined through air quality dispersion modelling and further described in

Chapter 11 Climate, Air Quality and Health Impacts). Based on the studies carried out and

consultation feedback (as described in Chapter 3 Need, Alternatives and Design Evolution),

the decision has been made to fix the stack height at 96.3 m AOD. The results of the air

dispersion modelling used to inform this decision are provided in Chapter 11 Climate, Air

Quality and Health Impacts.

2.49 The stacks will be fitted with aviation lighting albeit that no present requirement from an operating

airport exists. As a worst case, the EIA will assess the effects of lighting on the basis it may be

used.

Ash Handling System

2.50 Two types of solid by-products will be produced from the operation of the Proposed Development,

each of which has separate handling and disposal arrangements.

2.51 Bottom ash is the burnt-out residue from the combustion process. The ash will be discharged to a

bottom ash bunker and quenched in water. Bottom ash is combined with Boiler ash and will be

either removed from site or recycled at the planned adjacent IBA facility (see below).

2.52 The EIA will assess the effects of both direct export of raw IBA (and boiler ash) and the traffic

associated with the consented IBA recycling facility exporting products (recovered metal and

IBAA).

2.53 FGT residues will comprise fine particles of ash and residues from the flue gas treatment process,

which will be collected in the bag filters. The FGT residue will be stored in a sealed silo adjacent

to the flue gas treatment facility. Due to the alkaline nature of the FGT residues, they are

classified as hazardous waste (in much the same way as cement). As a result, the residues will

be transported by road in a sealed tanker to an appropriate treatment facility.

Supporting Facilities

Workshops and Other Buildings

2.54 Mechanical and electrical workshops and stores will be required for maintenance activities. The

workshops and stores will either be located in the admin / control building, or within a dedicated

building to the south of the ACC.

2.55 The control room and offices will be located adjacent to the bunker/boiler as outlined in the

concept site layout drawing.

Bulk Material Storage

2.56 Above ground diesel storage tank will be installed for the emergency diesel generator and

auxiliary burners. The tanks will have a storage capacity of approximately 150 m3.

2.57 Above ground bulk storage silos or tanks for the storage of FGT reagents (for example urea

solution, hydrated lime, activated carbon powder) and FGT residue will also be installed. They will

have a total capacity of around 1470 m3.


March 2017 2-28

Demineralised Water Plant

2.58 A demineralised water treatment plant will be required to provide demineralised water for boiler

makeup. The water treatment plant will be supplied by raw water from the paper mill with public

water supply as a back-up.

Diesel Generators

2.59 The Proposed Development will require emergency diesel generator to ensure safe shutdown in

the event of a loss of grid power. One emergency diesel generator will be installed inside the

building.

Site Access, Roads and Gatehouses

2.60 During both construction and operation, HGV access will be via Swale Way and Barge Way and

via the dedicated site access road.

2.61 A new internal site road will be constructed within the Site, a spur off the access road built for the

paper mill, with the road following a route to the east of the paper mill to the access ramp for the

tipping hall and to the site car park. The dedicated access road to the Proposed Development for

deliveries will allow for HGVs to queue within the Site without affecting other traffic flows.

Foul Sewer Connection

2.62 A connection to the foul sewer will be needed for sanitary connection from Offices/ Admin/

Welfare facilities.

Storm Attenuation and Drainage

2.63 The drainage strategy for the Proposed Development (presented within the Flood Risk

Assessment for the Proposed Development, Appendix 7.2) assumes the use of a new pond for

storm water attenuation prior to discharge to the Swale Estuary. The surface water network is

expected to discharge to the Swale Estuary to the East of the site. The required attenuation will

be accommodated within the Site in the form of one attenuation pond which has already been

constructed. Drainage from larger hardstanding areas will pass through oil interceptors.

Rain Water Capture System

2.64 Rainwater harvesting will be utilised in order to reduce process water demand. Rainwater will be

collected from roof gutters and collected into the attenuation pond. Use of harvested rainwater is

likely to be limited primarily to wash down cleaning and water top-up for ash quenching.

Firewater and Fire Protection

2.65 The fire protection strategy for the Proposed Development will be developed to comply with the

requirements of the Building Regulations. Appropriate standards will also be referenced to

provide the necessary fire safety design. Additional fire protection will be provided with reference

to British Standards.

2.66 In case of a fire, the connection to the surface water drainage system will be closed and surface

run-off (firefighting and rain water) will be contained within the Site.


March 2017 2-29

Parking

2.67 The Proposed Development parking arrangements consist of dedicated staff/ visitor and

operatives car parks accessed via the main access. Car parks will be surfaced and provided with

oil interceptors.

Fencing and Site Security

2.68 Security systems will be provided to cover the Site as a standalone facility. This will include

paladin fencing, intruder alarms and turnstiles to manage people access. A wooden close-

boarded fence has been erected along the northern site boundary to screen the site from

Kemsley Marsh as an ecological mitigation measure.

Lighting

2.69 It is envisaged that external lighting will be required throughout the night as the Proposed

Development will operate 24 hours a day.

2.70 A Lighting Strategy is being prepared which will set out the approach to lighting for each part of

the Proposed Development.

Biodiversity Enhancements and Landscaping

2.71 A comprehensive strategy of habitat creation and landscaping with associated monitoring and

maintenance will accompany the DCO application. The Habitats Management Plan (HMP) will

set out the principles of habitat creation and management and landscape design that will be

adopted in the operational development.

Grid Connection

2.72 The Proposed Development will require a connection to export electricity to the distribution

network, owned and operated by UK Power Networks. The grid connection will be to the existing

substation located within the paper mill site to the immediate west and the necessary

infrastructure is already in place.

The IBA Recycling Facility

2.73 IBA is a by-product of the incineration treatment process of waste materials at EfW facilities. The

recycling process will extract valuable recyclable products such as ferrous and non-ferrous metals

and produce a secondary aggregate for the construction industry known as Incinerator Bottom

Ash Aggregate (IBAA). IBA processing therefore moves the management of more waste up the

waste hierarchy, contributes to sustainable waste management and contributes to sustainable

aggregates production.

2.74 The IBA Facility is not part of the DCO Proposed Development as it has already been consented.

However, it is a complementary facility integral to the sustainable management of IBA produced

by the Generating Station. The EIA has assessed the Kemsley Generating Station complete with

the IBA Facility to provide a complete assessment of the entire site operations. The IBA process

is described below.


March 2017 2-30

The IBA Process

2.75 IBA is conveyed to the Recycling Facility from the adjacent Generating Station via conveyor to the

dedicated IBA storage area, where it is stored prior to being transferred to the process building

using mobile plant. Here, it is fed into a feed hopper for processing using a variety of mechanical

processes, including vibrating screens, magnetic and eddy current separation. The process

screens, separates and sizes the IBA and extracts the ferrous and non-ferrous metals. The

processed IBA aggregates (IBAA) material is fed by conveyor for storage in temporary stockpiles

in the dedicated storage area adjacent to the process building in the north-west section of the

site. From storage, it is loaded to vehicles for removal from the recycling facility and onward

delivery. Recovered ferrous and non-ferrous metals are stored separately in containers pending

their removal from the facility for recycling.

2.76 All IBAA leaving the recycling facility will be sheeted. All product and other materials will leave the

site via the exit to the private road that links to Swale way and Barge Way and the wider highway

network beyond having been weighed prior to leaving.

2.77 The layout, plant and equipment, and the buildings have the design capacity to accommodate

and process up to 140,000 tonnes per year of IBA.

Storage Building

2.78 There will be a dedicated storage building for incoming IBA along the southern boundary of the

site. This will be a steel frame construction with block panels to the side walls and covered. The

storage building will have open frontages to the yard for the movement and storage of raw IBA.

Process Building

2.79 To the north of the central yard will be a larger Process Building, of steel frame construction. This

building will be enclosed by vertically laid profiled metal cladding and a profiled metal cladding

roof. The building will have roller shutter doors and one building entrance opening.

2.80 Within the Process Building will be the plant and equipment necessary for the crushing and

screening of the IBA and the removal and sorting of metals using magnets and eddy currents.

Storage Areas

2.81 External to the Process Building, in the north west of the site, will be an external storage area for

processed IBAA. This will be stockpiled externally at heights no more than 10 m, with heights

reducing towards the enclosing boundaries.

2.82 External containers, for direct loading to vehicles, will be used for the storage of separated ferrous

and non-ferrous metals, located alongside the Process Building.

Parking

2.83 Parking will comprise a total of 8 spaces, including a marked space for disabled, allow for visitor

spaces and one motorbike parking space. A minimum of two undercover bicycle parking spaces

for staff will be available in the car parking. Provision is made for short term HGV parking

adjacent to the site staff parking area for drivers on breaks and, if required, whilst awaiting use of

the weighbridge.


March 2017 2-31

Drainage

2.84 All operational areas of the IBA site will be hard surfaced with an integral drainage system to

manage both surface and foul drainage. The drainage system design will include provision to be

able to reuse drainage water for onsite requirements such as yard cleaning and dust suppression.

All site drainage will be managed via a sealed drainage system.

2.85 The onsite surface water drainage network for the site will be split into two separate drainage

systems such that clean surface water runoff from building roof areas will be collected and

discharged separately from runoff from external IBA storage and handling and vehicle parking

areas. External hardstanding areas will be drained via a Class 1 bypass oil interceptor, sized to

treat the full area of hardstanding to which it serves.

2.86 Clean surface water will be stored on site and discharged through a series of controls to the

Swale Estuary through a new outfall.

Landscaping

2.87 Landscaping will be integral with that established for the permitted Generating Station described

above.

Hours of Operation

2.88 The IBA Recycling Facility is directly linked to the operations of the Generating Station, therefore

the IBA Recycling Facility has been modelled on operating on a 24/7 basis with the only

restriction being movements of HGV between 07.00 and 23.00 hrs. This includes working on

Monday to Fridays, Saturdays, Sundays and Public Holidays throughout the year.

Access and Transport

2.89 The IBA facility will have a single access from the Generating Station access road. There will be

no imports of raw IBA other than by the conveyor system described above, therefore the traffic

will comprise staff vehicles and HGVs collecting loads of IBAA (approx. 42 HGV movements on

average per day) for transport off site.

Design

2.90 A summary of the key design features of the IBA recycling facility used in the assessment of the

Project are presented in the below table.

Table 2.4 IBA Design Parameters

Design Aspect Height

(mAOD)

Gross

External Area

(m2)

Process building 17.63 5,964

IBA Storage and Drop Down 18.15 1,971

Rainwater tanks 8.5 16

Office and Welfare 8.95 83

Metal Storage bays 12.12 52


March 2017 2-32

Generating Station and IBA Employment

2.91 The Wheelabrator Kemsley Generating Station will employ approximately 50 full time employees

comprising operator shift staff, maintenance employees, weighbridge operators and

administrative staff and plant management. In addition, an average of 100 contractors will be

employed for planned shutdowns.

2.92 Some 6-12 staff will be employed at the IBA Recycling Facility with a maximum of 6 per shift.

2.93 During construction, approximately 500 contractors will work at the Generating Station and IBA

works site.

Timescales

2.94 It is intended that the application for development consent for the up to 75 MWe facility will be

submitted by June 2017 whilst the consented scheme is under construction.

2.95 First operation of the Generating Station is planned for July 2019. Construction of the IBA facility

will be timed to coincide with the first operation of the Generating Station.

Proposed Development Operation

Summary of Inputs and Outputs

Process Inputs

2.96 In addition to the pre-treated waste fuel, the Proposed Development also uses a number of raw

materials during the combustion and processing operations. Table 3.5 illustrates the materials to

be used and the typical annual usage of each.

Table 2.5 Generating Station Raw Material Usage Estimates

Raw Material Process

Maximum guaranteed

consumption

Typical Annual

Usage

No. of

Annual

Deliveries

by road

No. of

Weekly

Deliveries Qty Metric Qty Metric

Hydrated lime (Ca(OH)2)

Flue gas treatment – acid gas scrubbing

1,010 kg/h 8,080 t/y 404 8

Solid urea Flue gas treatment – NOx reduction

132 kg/h 1,056 t/y 53 1

Activated carbon

Flue gas treatment – removal of dioxins/ heavy metal

24 kg/h 192 t/y 10 0.2

Low sulphur diesel

System start-up and back-up fuel

36,200 kg per startup per boiler

362 t/y 18 0.3


March 2017 2-33

Raw Material Process Maximum guaranteed

consumption

Typical Annual

Usage

No. of

Annual

Deliveries

by road

No. of

Weekly

Deliveries

Total water demand

Boiler feed water supplied via demineralized water plant; potable water provided via public water supply; harvested water and fire water

N/A N/A 24,073 m3/y N/A N/A

2.97 For SNCR flue gas treatment urea will be used. Hydrated lime, urea, activated carbon and diesel

are assumed to be delivered to the Site by HGV.

2.98 The following additional consumables will be utilised for operation and maintenance of the

Proposed Development:

hydraulic oils and silicone based oils; and

boiler water dosing chemicals.

2.99 All chemicals will be stored in fully bunded areas, with each bund having a volume of 110% of the

stored capacity. Diesel for use on process start-up and temperature control will be stored in

bunded above ground storage tanks

2.100 The establishment of new utilities and/or connections to exiting utilities will be required in respect

of the public water supply and foul sewer. The following utilities are expected to be required:

public water supply, for use as potable water, in welfare facilities, as back-up for boiler feed

water and firefighting provision;

raw water supply from the paper mill

foul sewer connection

2.101 The Proposed Development will supply its own electricity when operational. The estimated

parasitic load of the Proposed Development is approximately 6.4 MWe. The grid connection will

allow for import of electricity when the Proposed Development’s turbine generator is offline.

Process Outputs/Residues

Bottom Ash

2.102 Bottom ash is defined as ash from the grate mechanism in the combustion system and ash

captured within the boiler (boiler ash) prior to entering the FGT system. It is removed from the

combustion system and stored in a bottom ash bunker until such time it can be removed from

site.


March 2017 2-34

2.103 It is intended that the ash would be transferred to the adjacent IBA recycling facility where it will

be processed to produce a substitute aggregate material.

2.104 The likely volume of bottom ash production from the Proposed Development has been estimated

in Table 3.6 below.

Table 2.6 Generating Station Residue Production Estimates

Units Assumed Average NCV

Fuel (10.5 MJ/kg)

Fuel use T/y 550,000

Bottom ash (wet) T/y 137,500

FGT residue & Fly Ash T/y 24,800

FGT Residue

2.105 FGT residue is the second main solid by-product from the Proposed Development. The FGT

residue will contain fly ash and reaction products from the hydrated lime and powdered activated

carbon injection. This material is designated as hazardous waste and therefore is required to be

treated before disposal to landfill. It will be stored in dedicated enclosed silos on site before being

transported to and disposed of in an appropriate off-site facility, in line with relevant hazardous

waste legislation.

Effluent and Wastewater

2.106 Liquid effluent will be produced from the boiler water treatment system and from boiler blowdown.

No process effluent water will be discharged directly from the site under normal operating

conditions, as it will be used to quench the hot bottom ash. A liquid effluent storage tank or pit

also called a decantation pit will be installed to balance effluent in the system and for use in the

event of abnormal operation.

2.107 The Kemsley decantation pit will be constructed below ground as a water retaining concrete

structure in accordance with BS EN 1992-3:2006 ‘Design of Concrete Structures – Part 3: Liquid

retaining and containment structures’. Where necessary, pipes transporting this process water to

the process effluent tank may be buried slightly below ground. Process water pipe work will be

constructed of suitable materials to prevent leakage.

2.108 A connection to the foul sewer will be needed for sanitary connection from Offices/ Admin/

Welfare facilities.

Heat

2.109 As discussed above, the hot gases from the combustion process will pass through a boiler to

raise steam. The steam will then be passed through a single steam turbine from the two

combustion lines, which will generate electricity, with the steam subsequently being piped to the

paper mill. Process water is subsequently returned to the CHP for re-use within the water steam

cycle.

2.110 The electricity that is produced will be exported to the distribution network (as described above).


March 2017 2-35

Access and On-Site Vehicle Movements

Vehicular Access and Movements

2.111 As described above, operational traffic will enter the Site via Barge Way.

off M2) via A249 and Swale Way; and

north from Swale Way via Barge Way.

via the existing Kemsley Paper Mill northern access

2.112 Staff vehicle movements would follow the same route of access. Vehicle movements to the Site

have been calculated based on the following assumptions that have been used for the purposes

of the EIA:

Up to 550,000 tonnes of pre-treated waste fuel per annum;

HGVs with net 22 tonne weight would be used for delivery of the pre-treated waste fuel. Fuel

will be delivered in enclosed containers, for example those that utilise walking floors;

Pre-treated waste fuel will be delivered to the site on a 24 hour, seven days per basis.

IBAA exports are assumed to be via road vehicles. Both IBAA and metals are exported.

Due to the IBAA density, it is assumed a maximum of 22 tonnes of IBAA can be transported

per HGV;

Total Generating Station staff numbers are expected to be around 48. The Station will

operate with 3 shifts per day during the periods 07:00-14:00, 14:00-22:00 and 22:00-07:00.

A further 6 staff would be working at the IBA facility. IBA facility working hours are 07:00 to

23:00 7 days per week working two shifts per day during the periods 07:00 to 15:00 and from

15:00 to 23:00; and

Based on standard modal splits, approximately 85% of staff travelling to the site are

assumed to arrive as car drivers, with the remainder as passengers/ bus/ cycle/ walk/ rail /

motorcycle.

2.113 As explained in Chapter 10 Transport and Access, both the Generating Station and the IBA are

consented developments. Assumptions on Traffic movements entering the site have not changed

from those original consents. Whilst this EIA assesses the overall impact of the total traffic

movements to the Site, the IBA does not form part of the Application for Development Consent for

the Proposed Development.

Hours of Operation

2.114 The Generating Station will operate 24 hours per day, 7 days per week with programmed offline

periods for maintenance. For the purposes of the traffic calculations only, it is calculated that


March 2017 2-36

deliveries will be for an equivalent of 47 weeks of the year (to account for outages of single or

both lines during the year, whereby the volume of fuel arriving at the site may be reduced), 6 days

per week - Monday to Saturday 0700-18:30, resulting in 287 delivery days per year. In reality

deliveries will potentially occur across 52 weeks of the year, though volumes will vary when

outages occur. Extended delivery hours are also included in the DCO, and considered in the

Environmental Statement, as discussed in Chapter 10 Transport and Access and Chapter 12

Noise and Vibration.

Site Parking, Pedestrian & Cycle Access

2.115 Pedestrian and cycle access to the site will be via the new access road. Cycle parking facilities

are provided with the Generating Station site. Staff parking at the site will be in 65 dedicated

spaces with a further 5 spaces provided for disabled drivers.

Employment

2.116 It is anticipated that during the operational phase, the Project will generate 48 full-time permanent

jobs for the operation of the generating station as well as 6 other full-time jobs at the IBA recycling

facility. A breakdown of estimated jobs by skill level is provided in Chapter 13 Land Use,

Amenity and Socio-economics.

Maintenance, Start-up and Shutdown

Maintenance

2.117 The Proposed Development would be operated and maintained by a dedicated Operations and

Maintenance team. A maintenance plan will be established setting out weekly, monthly, annual or

longer interval inspections, tests and maintenance activities to be undertaken.

Start-up and Shutdown

2.118 The process will be started and stopped, under the supervision of trained employees. This means

that the control system will start the process in a controlled and safe manner, but the operator will

have various “hold” points where checks are made before proceeding to the next stage. The

process will be started using fuel oil to reach safe combustion temperatures before any solid fuels

are added. The flue gas cleaning system and emissions monitoring will be in operation before any

solid fuel is added.

2.119 Process shut down will be carried out in a controlled manner by reversing the start-up process.

Emergency controls will be in place for emergency shut downs.

Hazard Prevention and Emergency Planning

Health and Safety

2.120 The Applicant aims to protect human health by safely and responsibly managing site activity. A

Health and Safety Plan covering the works, commissioning and operation of the Proposed

Development will be written. Competent and adequately resourced CDM Coordinator and

Principal Contractor will be appointed. The Applicant will ensure that its own staff, its designers

and contractors follow the Approved Code of Practice (ACoP) laid down by the CDM Regulations

2015. Details of health and safety controls that will be employed at the Proposed Development


March 2017 2-37

during operation will be provided in the proposed development description to be included with the

application.

Emergency Planning

2.121 Written procedures clearly describing responsibilities, actions and communication channels will

be available for operational personnel dealing with emergencies. Procedures will be externally

audited and contingency plans written in preparation for any unexpected complications.

Environmental Controls

Environmental Management

2.122 The Applicant will operate an ISO 14001:2004 accredited Environmental Management System

(EMS) Generating Station. The EMS will be used to identify, control and eliminate or minimise

environmental risk during the design and construction process. A site-specific management plan

will be established to cover all aspects of the works through construction, commissioning and

operation. The plans will identify risk and outline procedures to minimise or eliminate risk,

incorporating best practice and guidance.

2.123 As discussed previously, an application to vary the existing Environmental Permit will be required

for the operation of the site, in relation to the power upgrade, and is being prepared alongside the

DCO application.

Emissions to Air

2.124 The Proposed Development will comply with the IED so that the impact of emissions to air, soil,

surface water and ground water, to the environment and human health will be minimised. Specific

details regarding control of emissions and a summary of IED emission limit values for the

Proposed Development are set out in Chapter 11 Climate, Air Quality and Health Impacts.

2.125 Sampling and analysis of pollutants, including dioxins and furans, will be carried out to

appropriate standards (e.g. ISO, national, or international standards). Exhaust emission levels will

be monitored by a Continuous Emissions Monitoring System (CEMS) and discharged through the

single stack.

2.126 Continuous monitoring of key process variables will be carried out as required by IED.

Odour and Dust Suppression

2.127 Fugitive dust emissions will be minimised through the use of the enclosed tipping hall, silos for the

collection of FGT residue and a quench system for bottom ash.

2.128 Buildings will be kept at a slight negative pressure to minimise odour release into the

environment, with the air drawn into the plant for use as primary combustion air. During the

construction and operational phases of the Proposed Development, monitoring of any dust and

odour complaints received will be undertaken regularly and appropriate responses will be

initiated.


March 2017 2-38

Vermin

2.129 Due to the operational nature of the Proposed Development with a high turnover of fuel in the

bunker, it is not considered to be a suitable habitat for vermin. This is based on the Applicant’s

experience of other similar developments.

Effluent

2.130 During normal operation there will be no direct discharge of process effluent from the Proposed

Development. Blowdown and wash water will be recycled within the Proposed Development and

buffered through waste water tank. Under abnormal operating conditions, there is no need to

discharge this process effluent.

Noise

2.131 Noise levels will be regulated as defined in Section 72 of the Control of Pollution Act 1974

(amended 1989) and will conform to British Standard ISO 140-4 (1998) (Ref 3-7). A noise

assessment for the Proposed Development is presented in Chapter 9 Noise and Vibration.

Geographical Source of Fuel

2.132 As the Proposed Development would be a merchant facility, the letting of contracts to obtain

adequate fuel supplies would be a matter for commercial consideration. Given that contracts will

vary over the operational lifetime of the development, the Transport Assessment has made some

reasonable worst case assumptions about the geographical sources of fuel and these are

explained in Chapter 10 Transport and Access.

Construction Programme and Methods

Introduction

2.133 The Applicant has appointed an EPC contractor for the main works. The Applicant is committed

to ensure the safe working environment for all employees and contractors. A Construction Method

Statement (CMS) has been prepared by the contractor. This CMS will set out the key measures

to be employed during the works to control health and safety and minimise the impacts on the

local environment.

2.134 The entire site preparation and construction programme is anticipated to take approximately 36

months from commencement to take over. The baseline for this assessment is the progress of

construction to March 2017. Table 2.7 below gives an indicative construction programme.

Table 2.7 Indicative Construction Programme

2016 2017 2018 2019

Quarter 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4

Construction X X X X X X X X X X X

Detailed Engineering

X X X X X X X X

Earth Works X X X


March 2017 2-39

2016 2017 2018 2019

Main Civil Works X X X X X X X X

Process Works X X X X X X X

Commissioning X X X X

Works completed prior to March 2017

Preliminary Works

2.135 Preliminary works included surveys, decontamination measures, erection of signage and

temporary fencing, installation and diversion of utility services within the Site, preparation of the

contractor’s laydown area and temporary facilities, and provision of wheel washing facilities.

2.136 The Site is a large area which has previously been used as an inert land fill site.. Due to the

nature of the site, the enabling works required are minimal. The main requirements of the

enabling works are levelling of the Site, and creating construction laydown areas and contractor

compounds, as described below.

Access

2.137 Temporary access to the construction area was gained from two points on the internal paper mill

road to the southwest of the site until the main access road was completed. A new access road

with its own drainage and landscaping was completed under a separate permission submitted by

the paper mill owners DS Smith.

2.138 The access arrangements were constructed as part of a wider project to build HGV trailer

storage, weighbridges and access control for the paper mill. The access works were contiguous

with the preliminary works on the generating station site.

Levelling of Site

2.139 Initially the Site needed to be levelled to make a level working platform. The works associated

with this levelling were minor as the site is relatively flat. Topsoil has been stockpiled within the

Site and retained for landscaping. The ground level around the main process buildings and the

contractor’s compound has been levelled to approx. 5.9 - 6.3 m AOD (see Figure 1.3

Construction site concept plan).

2.140 The contractor will manage the material balance to avoid the need for material to be removed

from Site. Removal of material will also be minimised by using excess material for onsite

landscaping, ground levelling and construction of ramps where possible

Construction Laydown

2.141 The contractor will provide temporary site facilities within the Site. The contractor will be

responsible for creating the necessary laydown areas as required by the programme of works

within the confines of the Site. Space within the development area has been allowed for

construction laydown.


March 2017 2-40

Works ongoing from March 2017

Spoil Storage

2.142 The excess spoil material generated during construction will be stored temporarily within the main

construction site boundary. If necessary suitable measures will be put in place to prevent

sediment being washed off site, and the stockpiles will be monitored/ measured for wash away.

Existing Utilities

2.143 Suitable measures will be implemented in accordance with standard guidance to ensure safe

working in the vicinity of existing overhead cables, such as height signs.

Infrastructure

2.144 Internal access roads will require extension to the entrance of the Proposed Development (within

the DCO (Application Site) red line boundary).

2.145 Temporary water, electricity and communications connections will be made within the red line site

boundary to facilitate the works. A site car park will be constructed. Main Civil and Process Works

2.146 Piling will be required during the construction of the Proposed Development. The buildings will

then be constructed to facilitate the installation of process equipment.

Construction Staff

2.147 It is estimated that during construction, there will be around 500 personnel contracted to work on

site at the peak of construction. The peak of construction activity is anticipated to be in Q1 2018.

Construction staff are anticipated to travel to site via the existing trunk road.

Construction Hours of Work

2.148 Construction working hours will generally be Monday to Friday 0700 to 1900 (inclusive) and

Saturdays and Sundays 0700 to 1600. The exceptions to this are activities using the concrete

slip-forming method, construction using pour methods for concrete laying and internal process

works relating to mechanical and/or electrical equipment installation. No construction activities

will take place on Bank or Public Holidays. Chapter 12 Noise and Vibration sets out specific

mitigation and control measures required to prevent disturbance from construction activities.

2.149 All piling would be by way of auger, other than where an alternative method is required for

structural reasons. No impact piling would take place between 1 April and 31 August in any given

year to avoid disturbance to breeding birds.

2.150 Activities that could generate a noise nuisance are sheet piling, use of impact wrenches, concrete

scabbling, use of reversing sirens, delivery of feed stock for the concrete batching plant and

concrete jack hammering. Lighting for night time working will be designed so as not to cause a

nuisance outside of the site in relation to views from residential receptors or light disturbance.

Construction Traffic/ Site Access

2.151 The designated route for delivery of construction plant and materials is via Barge Way. All HGVs

will access the Site in this manner. It is not possible at this stage to identify the exact number and

size of such abnormal loads, as these will be dependent on the supplier of the plant, which is yet


March 2017 2-41

to be determined. Such loads will be identified in advance to the local authorities, and suitable

routes and delivery times agreed to minimise any potential.

2.152 Traffic management information will be issued to suppliers and subcontractors in a timely manner

in the form of directions and maps to ensure that full compliance to this route is achieved

throughout the project.

2.153 Upon completion of unloading, the vehicle will be checked for cleanliness and cleaned to a

satisfactory standard at the wheel wash location.

2.154 HGV traffic will exit the site north onto Barge Way, then travel along Swale Way to the A249,

where it can join the M2 motorway.

2.155 During night time working the noise impact of vehicles will be limited by restricting the speed limit

of vehicles to 10 mph and prohibiting the use of radios, horns and idling engines. Concrete

deliveries from off-site would therefore only be required in the event of a failure of any on-site

batching plant during critical activities. Such deliveries will be assessed within TA as appropriate.

Construction Plant and Machinery

The mobile plant and equipment expected to be used during the course of the

construction of the Project are listed in Appendix 12.1. Storage of Construction Plant and

Materials

2.156 There will be gravelled laydown areas positioned close to access roads on the Site where any

materials will be unloaded and then transported to the area of works. It is not envisaged that

these will be for long term storage of materials (six months or more).

2.157 At the end of the shift, mobile plant will be returned to a secure overnight plant storage area

where drip trays can be utilised under the various types of plant if needed.

2.158 Storage areas for flammable/ toxic/ corrosive materials will be located in a separate locked fenced

off area. Material data sheets will be available for all these materials and the COSHH (Control of

Substances Hazardous to Health) assessments kept within the relevant Risk Assessment for the

task, all subject to the Applicant’s approval.

Lighting

2.159 Construction temporary site lighting is proposed to enable safe working on the construction site in

hours of darkness. Construction temporary lighting will be arranged so that glare is minimised

outside the construction site. A lighting strategy has been developed for the Proposed

Development to cover construction and operational phases.

Wheel Wash Facilities

2.160 A self-contained wheel wash will be installed prior to the exit of the Site onto the public highway.

2.161 For loads unable to use the fixed wheel wash, a localised wheel washing will be set up to cater for

these individually and as required to ensure no detrimental effect to the highway.


March 2017 2-42

Construction Method Statement (CMS)

2.162 The Applicant will require that the contractor produces and maintains a CMS to control site

activities to minimise any impact on the environment. This will include industry best practice

measures, and specific measures set out in this document. As this forms part of an existing

planning requirement, the current CMS is presented at Appendix 2.1.

Site Waste Management Plan

2.163 In order to manage and monitor waste generated on Site, a Site Waste Management Plan will be

developed, which will allow for waste streams to be estimated and monitored and goals set with

regards to the waste produced. As this forms part of an existing planning requirement, the current

SWMP is presented at Appendix 2.2

2.164 The Applicant will require that the contractor separates the waste streams on Site, prior to them

being taken to a waste facility for recycling. All waste removal from Site will be undertaken by fully

licensed waste carriers and taken to licensed waste facilities.

Commissioning

2.165 Commissioning of the Proposed Development will include testing and commissioning of the

process equipment. This will involve both cold and hot commissioning.

Decommissioning

2.166 The Proposed Development is expected to have an operating life of 40 years. At the end of

operation it is expected that the Proposed Development will have some residual life remaining

and an investment decision would then be made based on the market conditions prevailing at that

time. If the operating life were to be extended the Proposed Development would be upgraded and

re-permitted in line with the legislative requirements at that time.

2.167 At the end of its operating life, the most likely scenario is that the Proposed Development and all

equipment would be shut down and removed from the Site. Prior to removing the plant and

equipment, all residues and operating chemicals would be cleaned out from the plant and

disposed of in an appropriate manner. This would include bottom ash and FGT residues and any

remaining operating chemicals such as hydrated lime, activated carbon, boiler water treatment

chemicals or aqueous ammonia. The bulk of the plant and equipment would have some limited

residual value as scrap or recyclable materials, and the contractor will be encouraged to use

materials that could be recycled.

2.168 Prohibited materials such as asbestos, polychlorinated biphenyls (PCBs), ozone depleting

substances and carcinogenic materials, will not be allowed within the Proposed Development,

and other materials recognised to pose a risk to health (but which are not prohibited) will be

subject to detailed risk assessment.

2.169 Prevention of contamination is a specific requirement of the Environmental Permit for the

operation of the Proposed Development therefore it is being designed such that it will not create

any new areas of ground contamination as a result of construction or operation. Once the plant

and equipment have been removed to ground level, it is expected that the hard standing and


March 2017 2-43

sealed concrete areas will be left in place. Any areas of the Proposed Development that are

below ground level will be backfilled to ground level to leave a levelled area.

2.170 A Decommissioning Plan (including Decommissioning Environmental Management Plan) would

be produced and agreed with the Environment Agency as part of the environmental permitting

and site surrender process. The Decommissioning Environmental Management Plan would

consider in detail all potential environmental risks on the site and contain guidance on how risks

can be removed or mitigated. This would include details of how surface water drainage should be

managed on the Site during the decommissioning and demolition. The Plan would also consider

how the attenuation pond should be managed and whether there would be environmental benefits

from retaining this feature.

2.171 The Decommissioning Plan would include an outline programme of works. It is anticipated that it

would take nine to twelve months to decommission the site fully.

2.172 During decommissioning and dismantling, there would be an electrical demand, as well as

requirement for office, accommodation and welfare facilities.

2.173 The Site closure sequence will be devised with reference to the following points.

decommissioning and making safe: The sequence would consider how each part of the

Proposed Development is isolated and the physical disconnection of feeds and services,

including drainage. Careful thought would be given to the handling and management of

materials and fluids that have a potential to present an environmental hazard. A permit to

work system would be employed to ensure safe hand over of systems;

service re-routing: Services may traverse decommissioned areas. If so, these would

require an appropriate diversion. All redundant cabling would be removed and

redundant drains and ducts filled;

management and monitoring of assets: Access to decommissioned areas would be

controlled to ensure that no unauthorised entry is gained. Access would only be granted

for inspections and, where diversions are not possible, emergency egress. A programme of

inspections would be prepared to ensure that the integrity of the decommissioned areas

are maintained until final demolition is achieved;

demolition: Specialist demolition may be required, e.g. the stack; and

remediation: If surveys indicate that the land quality has deteriorated because of

operational activities then steps would be required to restore the land to its original

condition as far as practicable.

2.174 The designer has a legal obligation to consider decommissioning and demolition under the CDM

Regulations 2015.

2.175 Decommissioning activities would be conducted in accordance with the appropriate guidance and

legislation at the time of site closure. All decommissioning activities will be carried out in

accordance with the waste hierarchy and materials and waste produced during site closure would


March 2017 2-44

be stored in segregated areas to maximise reuse and recycling. All materials that cannot be

reused or recycled would be removed from site and transferred to suitably licensed waste

recovery/ disposal facilities. It is anticipated that a large proportion of the materials resulting from

the demolition will be recycled and a record will be kept to demonstrate that the maximum level of

recycling and reuse has been achieved.

2.176 Upon completion of the decommissioning programme, including any remediation works that might

be required, the Environment Agency will be invited to witness a post- decommissioning

inspection by site staff. All records from the decommissioning process will be made available for

inspection by the Environment Agency and other interested parties.


March 2017 3-1

3 Needs, Alternatives and Design Evolution

Introduction

3.1 This chapter of the ES will set out the need for the Proposed Development and the consideration

of alternatives in relation to the Proposed Development and the wider Project. It will also set out

the design evolution process for the Generating Station, from the original concept design through

to the current design that is the subject of the application for Development Consent. In particular,

this will include an explanation of where changes have been made to the design as a result of

feedback received during the consultation process to date as well as through the process of

evaluation and environmental assessment.

3.2 The consideration of alternatives and design evolution will be undertaken with the aims of

preventing or reducing adverse environmental effects (following the hierarchy avoid, reduce and,

if possible, remedy) while maintaining operational efficiency and cost-effectiveness.

The Need for Energy from Waste Infrastructure

National Policy Context

3.3 The need for the development is set out below in the context of national policy. National Policy

Statements (NPSs) have been developed to guide the decision making process for Nationally

Significant Infrastructure Projects (NSIPs). The NPSs define the national need for certain types

of infrastructure, as well as the issues to be considered by the examining body when assessing

whether a location is acceptable for the type and scale of development proposed.

3.4 The NPSs of relevance to this application include:

Overarching Energy National Policy Statement (EN-1) (DECC, 2011a);

Renewable Energy Infrastructure National Policy Statement (EN-3) (DECC, 2011b); and

Electricity Networks Infrastructure National Policy Statement (EN-5) (DECC, 2011c).

3.5 NPS EN-3, together with the Overarching NPS for Energy (EN-1), provides the primary basis for

decisions on applications for ‘nationally significant renewable energy infrastructure’ defined at

section 1.8 of EN-3, which includes ‘energy from biomass and/or waste (DECC, 2011b)’.

3.6 The Overarching NPS for Energy (EN-1 Part 3) emphasises that the UK needs all of the types of

energy infrastructure covered by EN-1, including energy from waste, that it is for industry to

propose new energy infrastructure projects within the strategic framework set by the Government

and that applications should be considered on the basis that the Government has demonstrated

need as described and that substantial weight should be given to the contribution which projects

make towards satisfying need. EN-1 Part 4 goes on to state that the decision maker should

“…start with a presumption in favour of granting consent to applications for energy NSIPs…

unless any more specific and relevant policies set out in the relevant NPSs clearly indicate that

consent should be refused” (DECC, 2011a).


March 2017 3-2

3.7 As part of the UK’s need to diversify and decarbonise electricity generation, the Government is

committed to dramatically increasing renewable energy generation and it notes that increasingly

this may include plant powered by the combustion of waste and/or biomass, helping to avoid

over-dependence on a single fuel type. Among current national waste policy, the Government

‘Review of Waste Policy in England 2011’ prioritises efforts to manage waste in line with the

waste hierarchy while a further goal is to ensure “Recovery of energy from waste makes an

important contribution to the UK’s renewable energy targets minimising waste to landfill and

helping to meet UK carbon budgets”.

3.8 EN-3 Part 2.5 states that “Electricity generation from renewable energy is an important element in

the Government’s development of a low-carbon economy… a significant increase in generation

from large-scale renewable energy infrastructure is necessary to meet the 15% renewable energy

target’. Specifically “The recovery of energy from the combustion of waste, where in accordance

with the waste hierarchy will play an increasingly important role in meeting the UK’s energy

needs…” and that the recovery of energy from the combustion of waste forms an important

element of the waste management strategy in England and Wales (DECC, 2011b). This section

goes on to recognise the role that recovery of energy from waste can play in the delivery of waste

management services in the UK, as long as schemes comply with the waste hierarchy and do not

prejudice local, regional and national waste management strategies and plans.

3.9 Changes to the current mix of electricity generating plant are occurring as a large number of

existing oil, coal and nuclear power stations close as a result of the requirements of the European

Industrial Emissions Directive (IED) (incorporating the requirements of the former Large

Combustion Plant Directive (LCPD)) and/or as power stations reach the end of their operational

lives. Projections quoted in EN-1 indicate that some 22 Gigawatts (GW) of electricity generating

capacity will need to be replaced in the period up to 2020 (DECC, 2011a). This clearly underlines

the urgency of the need to provide new electricity generating capacity to ensure security of supply

to homes and businesses. EN-1 Part 3.4.4 also specifically recognises the increasing need in the

UK for ‘dispatchable’ power, providing the ability to meet variations in electricity demand and

supply, as can be provided by the proposed development. This section states that “As more

intermittent renewable electricity comes onto the UK grid, the ability of biomass and Energy from

Waste to deliver predictable, controllable electricity is increasingly important in ensuring the

security of UK supplies” (DECC, 2011a).

3.10 In addition to the national planning policy position in relation to the need, the need for the

proposed Generating Station has been previously established by the extant planning permission

which is currently being constructed.

Fossil Fuel Dependency of the Paper Mill

3.11 NPS EN-1 also provides support for the CHP element of the proposal in relation to the steam

provided to the paper mill. It identifies that to be “economically viable as a CHP plant, a

generating station needs to be located close to industrial or domestic customers with heat

demands. The distance will vary according to the size of the generating station and the nature of

the heat demand. For industrial purposes, customers are likely to be intensive heat users such as

chemical plants, refineries or paper mills.”


March 2017 3-3

3.12 It further establishes support for the proposed development and its displacement of energy

generated from fossil fuels through provision of substantial additional positive weight. It sets out

that the “Utilisation of useful heat that displaces conventional heat generation from fossil fuel

sources is to be encouraged where, as will often be the case, it is more efficient than the

alternative electricity/heat generation mix. To encourage proper consideration of CHP, substantial

additional positive weight should therefore be given by the IPC to applications incorporating

CHP.”

3.13 The energy requirements of the Kemsley Paper Mill are currently met by the onsite Combined

Heat and Power (CHP) plant which is fuelled by natural gas, a fosil fuel based energy source and

by an Energy from Waste (EfW) plant which burns rejects from the paper making process. Both

plants are owned and operated by E.ON. The mill is an intensive user of energy, consuming 55

MWe per hour of electricity and 150 MWth per hour of steam. The price of natural gas is forecast

to increase over the long term and will continue to be volatile.

3.14 Although natural gas will remain as a significant source of energy for the mill, there is a strategic

need for the Kemsley Paper Mill to diversity its fuel source and reduce its reliance on natural gas.

The proposed development will reduce its dependence on fossil fuel, improve the carbon footprint

of Kemsley Paper Mill, ensure a greater degree of energy supply security and improve the

competitive position of the mill.

Waste Hierarchy

3.15 The proposed development would contribute to meeting the landfill diversion targets under the

European Landfill Directive by diverting material that is otherwise likely to be landfilled consistent

with the waste hierarchy, utilising non-hazardous materials diverted from landfill in accordance

with the Waste (England and Wales) Regulations 2011, which are derived from the Waste

Framework Directive 2008/98/EC, Waste Management Plan for England (2013) and the National

Planning Policy for Waste 2014.

3.16 This will save landfill space and reduce the associated methane emissions, whilst providing low

carbon electricity in accordance with the aims of the Energy White Paper 2007, the UK

Renewable Energy Strategy (2009) and NPSs for Energy 2011.

Consideration of Alternatives

3.17 The EIA Regulations require that the Applicant provide ‘An outline of the main alternatives studied

by the Applicant and an indication of the main reasons for the Applicant’s choice, taking into

account the environmental effects’.

3.18 Whilst a number of alternatives were considered in the original ES, in terms of both sites and

technologies, the consideration of alternatives in the case of the current Proposed Development

needs to be made in the context of the extant permission which is currently being constructed.

Accordingly, there are only two main considerations of alternatives, as the Proposed

Development will proceed either in the accordance with the extant planning permission (as at

present); or in accordance with the power upgrade upon the development consent being granted.


March 2017 3-4

3.19 This is therefore a consideration of alternative technology and the consideration of alternative

sites is settled. However, the reasons for the site location are summarised in an Alternative Sites

Report that was prepared and submitted with the 2010 ES (included at Appendix 3.1).

3.20 The consideration of alternative capacity is effectively a Do Nothing Scenario; a choice between

generating up to 49.9MWe in accordance with the extant consent; or generating up to 75 MWe

from the same fuel throughput. The additional benefits to the environment of increased

renewable energy capacity are summarised in Chapter 11 Climate, Air Quality and Health

Impacts.

Alternative Electrical Output

3.21 As set out above, the consented scheme allows for power generation of up to 49.9 MWe. During

development and detailed design of the consented scheme, K3 CHP Limited has identified the

opportunity to increase the efficiency of the plant and so increase its electrical output. An

alternative option of an increase to up to 75 MWe has therefore been considered following the

grant of permission by Kent County Council. This option is now proposed to be taken forward

securing a greater efficiency for the CHP.

Design Evolution

Design Options

3.22 The proposed design and layout evolved through an iterative process that was informed by the

landscape setting, taking into account the views of key stakeholders and the community, to

ensure that the design was able to accommodate the technical requirements and capacities whilst

responding positively to the setting of the site.

3.23 The proposed finishes were selected to give variation of texture to reduce the visual impact of the

overall mass of the structure. All building materials were chosen having regard to sustainability

considerations.

Changes to the Design following the Grant of Planning Permission

3.24 The design and layout of the generating station buildings continued to evolve following the grant

of planning permission SW/10/444 from Kent County Council through a series of non-material

amendments which are summarised below. The full details of the non-material amendments is

provided in Appendix 3.2

Wheelabrator Kemsley Generating Station

Kent County Council approved a non-material amendment to the site layout and building

footprints (planning ref. PAG/MC/SW/10/444/R) in September 2013. In summary, the non-

material amendments included:

o The number of air cooled condensers reduced from 10 to 8 including a reduction in

building size;


March 2017 3-5

o Replacement of Incinerator Bottom Ash Maturation and Storage Facility with firewater

tank, landscaping and a surface water attenuation pond (replacement for deleted

surface water attenuation swale);

o Repositioning of stack arrangement 37m to the east;

o Raising of development platform 0.5 m from 5.8 mAOD to 6.3 mAOD;

o Revised access arrangements to tie-in with permitted scheme; and

o Non material repositioning of flue gas treatment building, fuel bunker building, tipping

hall and associated structures, elevations and cladding.

Kent County Council approved a further non-material amendment to the building footprint,

elevation and site layout (planning ref. SW/10/444/RA) in December 2015. In summary, the

non-material amendments included:

o Repositioning of substation and transformers with 2 alternative options; and

o Non material alterations to footprint, position, elevations, and cladding of air cooled

condensers, turbine hall, flue gas treatment building, fuel bunker building, tipping hall

and associated structures including gatehouse and weighbridge, and fire water tanks,

etc.

3.25 The location of the Generating Station, IBA Facility and the areas used for access, utilities and

drainage are shown on the overall works plan at Figure 1.4.

3.26 Following the appointment of the Engineering, Procurement and Construction (EPC) contractor in

July 2016, a further NMA application is to be submitted to Kent County Council in Q1 2017 which

seeks approval for the refinements to the approved scheme developed by the EPC contractor

since their appointment. This NMA application will form the basis of the submission drawings

submitted for the Proposed Development to which the DCO application relates. In summary, the

main non-material amendments to be sought are summarised below:

Site Layout

3.27 A comparison of the proposed amended site layout with the 2015 NMA site layout shows that:

The internal access road and concrete apron are almost identical;

The footprint of the main buildings is almost identical in length and width and configuration;

The Air Cool Condenser building is in broadly the same location but is of reduced length and

width;

The stack is located in the same position;


March 2017 3-6

The substation and transformer compound located along the northern boundary is replaced

as the Substation and Transformer Compound adjacent to the Stack is extended westwards,

and a Transformer Compound is positioned to the north of the Turbine Hall;

The fuel and waste water tanks are relocated into a compound along the northern boundary

but which is significantly smaller in relation to the substation and transformer compound

previously in that location; and

Other small amendments; including a small gas bottle store added to the ID Fan Building; a

Hydraulic Room and a HVAC Cooler Compound added at the junction of the Tipping Hall

and Bunker Hall.

Elevations

Scale and Mass

3.28 The height of the Tipping Hall, Bunker Hall, Boiler Hall, ID Fan Hall, APC/FGT Hall, Admin Stair,

Stack, and Turbine Hall all remain the same as the most recently approved NMA secured in 2015.

3.29 The height of the Bottom Ash Hall has been increased by 1.1m from 20.10m to 21.2m.

3.30 A small Soot Blower has been added to the Turbine Hall elevation.

3.31 The height of the Air Cool Condensers has increased by 0.87m from 24.00 m to 24.87m, as a

consequence of the increase in the stilt height being raised from 11.00m to 13.65. However, the

area of elevated cladding has been reduced.

3.32 Importantly, we note that the slab level is to remain at 6.3mAOD as previously approved with the

2013 NMA application.

Appearance

3.33 The appearance of the building remains largely unchanged as the same cladding type and colour

is proposed. The only changes to the buildings appearance will result from a change to horizontal

instead of the vertical cladding panels on the upper elevations; and a change back to random

cladding panel pattern around the lower elevations as originally approved in 2012 rather than the

uniform cladding panel pattern that has been approved since.

3.34 It is proposed that the Soot Blower is cladded in terracotta to match the adjacent Admin Stair

when viewed from the south west.

Access to Wheelabrator Kemsley Generating Station

3.35 The following applications have been made in relation to access provisions to serve the Kemsley

Generating Station:

Application to Kent County Council for the formation of an improved access road and

associated development to serve the Wheelabrator Kemsley generating station (planning ref.

SW/12/1001) (granted November 2012);


March 2017 3-7

Application to Kent County Council for a non-material amendment to provide for the

repositioning and change to the capacity of the pond to accommodate surface water

drainage from the access road (planning ref. PAG/SW/12/1001) (granted August 2013); and

Application to Kent County Council for the variation of Condition 6 of planning permission

SW/12/1001 to provide the formation of improved access road and associated development

to serve Wheelabrator Kemsley Generating Station (planning ref. SW/13/1257) (granted

February 2014).

Access Road to serve Kemsley Paper Mill

3.36 In addition, the following applications have been made in relation to the existing paper mill:

Application to Swale Borough Council for formation of new rear access road and extension to

trailer park to serve the Kemsley Paper Mill, together with security cabin and drainage pond

(planning ref. SW/12/1011) (granted October 2012); and

Application to Swale Borough Council for non-material amendment to planning permission

SW/12/1011 for formation of new rear access road and extension to trailer park, together

with security cabin and drainage pond (planning ref. SW/12/1011/NMA) (granted May 2014).

Incinerator Bottom Ash (IBA) Recycling Facility

3.37 Subsequent to the removal of the IBA Maturation and Storage Facility from the scheme in 2013

through a NMA (see above), planning permission was secured for an IBA Recycling Facility on

the adjacent site to serve the Generating Station. In addition, to maturation and storage of the raw

IBA produced as a by-product of the Generating Station, the provision of an IBA Recycling Facility

will ensure that the raw IBA itself is also managed as a resource, that material is recovered and

recycled and that landfilling is avoided. It therefore contributes to maximising the recovery and

recycling of municipal/household and industrial waste.

3.38 The consented Facility includes all that is necessary to receive, store and process Incinerator

Bottom Ash (IBA), producing recyclable metals and creating secondary aggregates known as

Incinerator Bottom Ash Aggregate (IBAA). These secondary aggregates are used in the

construction industry, especially for sub-base. Their use in this way reduces the need for primary

won aggregates. The recycling process would maximise the removal of ferrous and non-ferrous

metals from within the IBA; these metals are also recycled. IBA processing through the Facility

will therefore move the management of more waste up the waste hierarchy contributes to

sustainable waste management and contributes to sustainable aggregates production.

References

Department of Energy and Climate Change (2011a) Overarching National Policy Statement for

Energy (EN-1), July 2011.

Department of Energy and Climate Change (2011b) National Policy Statement for Renewable

Energy Infrastructure (EN-3), July 2011.


March 2017 3-8

Department of Energy and Climate Change (2011c) National Policy Statement for Electricity

Networks Infrastructure (EN-5), July 2011.

wheelabrator kemsley generating station power upgrade · chpqa chp quality assurance. chpqi chp...

Documents