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EIA Update Report for the Keadby 2 Combined Cycle Gas Turbine

Generating Station at Keadby, Lincolnshire

Regarding an application under the Electricity Generating Stations (Variation of Consents) (England and Wales) Regulations 2013 13th June 2018 www.erm.com

Environmental Resources Management Limited Incorporated in the United Kingdom with registration number 1014622 Registered Office: 2nd Floor, Exchequer Court, 33 St Mary Axe, London, EC3A 8AA

Keadby Developments Limited

EIA Update Report for the Keadby 2 Combined Cycle Gas Turbine

Generating Station at Keadby, Lincolnshire

Regarding an application under the Electricity Generating Stations (Variation of Consents) (England and Wales) Regulations 2013 FINAL

June 2018 Prepared by: Kevin Murphy

For and on behalf of Environmental Resources Management Approved by: Dr Kevin Murphy

Signed: Position: Partner Date: 13/06/2018

This report has been prepared by Environmental Resources Management the trading name of Environmental Resources Management Limited, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client. We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above. This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.

CONTENTS

1 INTRODUCTION AND PURPOSE OF THIS EIA UPDATE REPORT 1

1.1 PURPOSE OF THIS REPORT 1 1.2 APPLICATION HISTORY OF THE KEADBY 2 PROJECT 1 1.3 THE PROPOSED VARIATION 2 1.4 SCOPE OF THIS REPORT 2

2 COMPARISON OF THE PROPOSED VARIATION WITH THE 2017

CONSENT 4

2.1 INTRODUCTION 4 2.2 BUILDING/STRUCTURE DIMENSIONS 4 2.3 BUILDINGS/STRUCTURES LAYOUT 9

3 COMPARISON BETWEEN THE LIKELY SIGNIFICANT EFFECTS OF THE

PROPOSED VARIATION AND THE 2017 CONSENT 11

ENVIRONMENTAL RESOURCES MANAGEMENT KEADBY DEVELOPMENTS LIMITED

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1 INTRODUCTION AND PURPOSE OF THIS EIA UPDATE REPORT

1.1 PURPOSE OF THIS REPORT

This Environmental Impact Assessment (EIA) Update Report has been prepared by Environmental Resources Management Ltd (ERM) on behalf of Keadby Developments Limited (‘the Company’). It has been prepared to support an application under section 36C of The Electricity Act 1989 in accordance with the requirements of The Electricity Generating Stations (Variation of Consents) (England and Wales) Regulations 2013 (‘the 2013 Regulations’).

1.2 APPLICATION HISTORY OF THE KEADBY 2 PROJECT

On 10 September 1993, the Company was granted consent (‘the Original Consent’) pursuant to section 36 of the Electricity Act 1989 and a Direction under section 90 of the Town and Country Planning Act 1990 providing for the construction and subsequent operation of a 710 MW combined cycle gas turbine generating station at Keadby, North Lincolnshire. The section 36 consent was subsequently varied on 3rd November 2016 pursuant to section 36C of the Electricity Act 1989 (and the 2013 Regulations) and section 90(2ZA) of the Town and Country Planning Act 1990 (‘the 2016 Consent’) to accommodate an increase in the electrical output of the plant, up to 820 MW. The application submitted in relation to the 2016 Consent included an Environmental Statement (ES) that was prepared in accordance with The Electricity Works (Environmental Impact Assessment) (England and Wales) Regulations 2000 (‘the 2000 EIA Regulations’). The Company subsequently sought a further variation to increase the electrical output of the 2016 Consent, up to 910 MW and to deliver a higher efficiency in electricity generation. This was in response to advances in gas turbine technology that had resulted in the availability of larger, more efficient combined cycle gas turbine (‘CCGT’) units and the economic and environmental benefits of being able to deploy such units. The application submitted included an EIA Report (dated July 2017) that was prepared in accordance with The Electricity Works (Environmental Impact Assessment) (England and Wales) Regulations 2017 (‘the 2017 EIA Regulations’). The EIA Report provided a comparison of the likely significant effects of the development (as proposed to be varied) as compared to those set out in the ES for the 2016 Consent. The variation consent was issued on the 21st December 2017 (‘the 2017 Consent’). The 2017 Consent allows for the development to be constructed and operated in either a single-shaft or multi-shaft plant configuration. The 2017 Consent references a ‘Consolidated Parameter Layout Plan’ that accommodates both configurations and upon which (along with the dimensions at Tables 2.1 and 2.2 of the EIA Report) the EIA of the development was based.


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1.3 THE PROPOSED VARIATION

Since the 2017 Consent was granted the Company has taken the decision to proceed with a multi-shaft plant configuration and a technology provider has been selected. Further detailed design work has also been undertaken, which has resulted in some minor changes to the plant layout and the dimensions of the main buildings and structures, as illustrated by the multi-shaft plan refs. 105_0805_0035_Sheet01_Rev 02 and 105_0805_0037_Sheet00_Rev 00 that form part of the application. In view of the decision to proceed with the multi-shaft plant configuration and the further detailed design work that has been undertaken, the Company is proposing to simplify the consent by changing Condition 13 of the 2017 Consent so that instead of referencing the Consolidated Parameter Layout Plan it references the latest multi-shaft plans. It is also proposed that Condition 13 refers to the updated building/structure dimensions set out within this Report at Table 2.1 below where these supersede those listed at Tables 2.1 and 2.2 of the EIA Report dated July 2017. The changes to Condition 13 will allow for the minor changes to the plant layout and building/structure dimensions and provide greater certainty and clarity to the local planning authority as to the details it will be asked to approve under the condition and the plant that will be built at the site.

1.4 SCOPE OF THIS REPORT

The proposed variation does not introduce any significant new or different effects that require assessment; therefore, this Report focuses on the requirements of Regulation 17 of the 2017 Regulations which states:

“(e) where the application is for a section 36 variation, the main respects

in which the developer thinks that the likely significant effects on the

environment of the development, as varied, will differ from those set out

in—

(i) any EIA report or environmental statement prepared in

connection with the application for the section 36 consent that it is

proposed be varied; and

(ii) if the section 36 consent has previously been varied by a

section 36 variation, any EIA report or environmental statement

prepared in connection with the application for that variation;

(f) a non-technical summary of the information referred to in

subparagraphs (a) to (e).”

As such the likely significant effects of the proposed variation are as reported in the following documents: Environmental Statement (‘ES’) for the Keadby 2 Combined Cycle Gas

Turbine Generating Station at Keadby, Lincolnshire, regarding an application under the Electricity Generating Stations (Variation of Consents) (England and Wales) Regulations 2013, Final Report, February 2016; and

Environmental Impact Assessment (‘EIA’) Report for the Keadby 2 Combined Cycle Gas Turbine Generating Station at Keadby, Lincolnshire,


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regarding an application under the Electricity Generating Stations (Variation of Consents) (England and Wales) Regulations 2013, 24 July 2017.

The remainder of this Report explains how the latest multi-shaft plans that form part of the proposed variation application result in no material changes to the assessment basis used for the EIA of the 2017 Consent or the environmental effects of the Project as now proposed to be built.


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2 COMPARISON OF THE PROPOSED VARIATION WITH THE 2017

CONSENT

2.1 INTRODUCTION

The previous section 36 variation applications, consented on 3rd November 2016 and 21st December 2017, proposed both single and multi-shaft configurations. The proposed variation essentially involves withdrawing the plans and drawings that referred to or accommodated the potential for a single-shaft configuration for the power station and retaining only plans and drawings that are relevant to the multi-shaft configuration that now makes up the intended design. The assessment presented in the EIA Report dated July 2017 for the 2017 Consent focused on a multi-shaft configuration. As such the proposed variation and the 2017 Consent have the same ‘basis of assessment’ in terms of the power station design. The following sections provide verification that the basis of assessment remains effectively unchanged and therefore the conclusions of the EIA Report for the 2017 Consent are equally valid for the proposed variation.

2.2 BUILDING/STRUCTURE DIMENSIONS

Table 2.1 compares building/structure dimension information presented in the EIA Report dated July 2017 (Tables 2.1 and 2.2) and used in the topic assessments that required such data. Making a comparison between the values provided in the rows annotated ‘EIA Report Table 2.1 (Proposed columns)’ with the rows annotated ‘Latest multi-shaft plans (2018), Application

Drawing 105_0805_0037_00_00’ it can be seen that the proposed changes from the 2017 Consent are very small. For the main structures the table also includes the building/structure dimensions provided in the drawings that supported the application for the 2017 Consent.

Table 2.1 Building/Structure Dimensions Comparison

Description Document / Assessment Height (m)

Length (m)

Width (m)

Steam Turbine Hall

What is now proposed in S36C application (2018)

2018 S36c Application Drawing 105_0805_0037_00_00

30 50 39

What was previously proposed in 2017 ES

EIA Report Table 2.1 (S36C ES 2017)

30 50 39

2017 Consent application drawings: N/A N/A N/A

105_0805_0035 00 Rev 2

105_0805_0043 00 Rev 2

Proposed Change 0 0 0

What was previously assessed in 2017 ES

Air Quality modelling input data (see Note 1 below)

28 52 49

Photomontage input data 30 50 39


5


Length (m)

Width (m)

Turbine hall annex for auxiliaries



12 50 14



12 50 14


105_0805_0035 00 Rev 2

105_0805_0043 00 Rev 2



Air Quality modelling input data The model inputs effectively included this annex as part of the Steam Turbine Hall itself and modelled a worst case in terms of building height at 28 m instead of 12 m.


Gas Turbine Hall



27 50 23



27 50 23

2017 Consent application drawings (see Note 5 below):

30 49.2 22

105_0805_0035 00 Rev 2

105_0805_0043 00 Rev 2

Proposed Change 0 0.8 1



25 49 22


Turbine hall annex for GT generator



16 26 19



N/A Table 2.1 only noted the Main Structures of the Proposed Development for purpose of comparison with the Consented Development (see also Note 3 below).

2017 Consent application drawings: 16 25.8 19

105_0805_0035 00 Rev 2

105_0805_0043 00 Rev 2

Proposed Change 0 0.2 0


Air Quality modelling input data N/A Only structures meeting certain criteria of height/distance from the stack are included in the model (see also Note 3 below). This building is less than one third of the worst case (for air quality) stack height of 75 m.



6


Length (m)

Width (m)

Heat Recovery Steam Generator building



52 50 30



52 50 30

2017 Consent application drawings: 52 50 30

105_0805_0035 00 Rev 2

105_0805_0043 00 Rev 2


What was previously assessed in ES


52 49 28


Stack



85 8.5 diameter



75 to 85 8

2017 Consent application drawings: 75 to 85 8

105_0805_0035 00 Rev 2

105_0805_0043 00 Rev 2

Proposed Change 0 0.5


Air Quality modelling input data 75 8

Photomontage input data (see Note 2 below)

85 8

Feed water pumps structure



15 24 20




2017 Consent application drawings: 12 23 19

105_0805_0035 00 Rev 2

105_0805_0043 00 Rev 2



Air Quality modelling input data N/A Only structures meeting certain criteria of height/distance from the stack are included in the model (see also Note 3 below).

Electrical Container PCC



6 19 18






7


Length (m)

Width (m)

105_0805_0035 00 Rev 2

105_0805_0043 00 Rev 2





Generator transformer



9 31 16





105_0805_0035 00 Rev 2

105_0805_0043 00 Rev 2





Regeneration Plant



8 15 13





105_0805_0035 00 Rev 2

105_0805_0043 00 Rev 2




Photomontage input data (see Note 4 below)

8 14 13

Cooling Towers



28 177 25


8


Length (m)

Width (m)



28 192 25


105_0805_0035 00 Rev 2

105_0805_0043 00 Rev 2

Proposed Change 0 -15 0


Air Quality modelling input data N/A N/A N/A


NOTE 1

There are some small differences between the current design data and that used for air quality modelling in the EIA Report dated July 2017. For example, the air quality assessment modelled the steam turbine hall and gas turbine hall at heights 2 m less than the design height, and for the gas turbine hall 1 m less in width and length. In theory, this could have slightly underestimated the building downwash effects of these structures. It also modelled the steam turbine hall at 2 m longer and 10 m wider than the design dimensions which could in theory have slightly overestimated the building downwash effects of this structure. The HRSG building was modelled at 1 m less in length and 2 m less in width but at the design height of 52 m. Being the structure closest to the emissions stack and the tallest structure, the HRSG building will have the greatest influence on building downwash and local dispersion of pollutants. Table 4.7 of the EIA Report (July 2017) presenting dimensions used in the air quality assessment acknowledged this as follows: “Further design evolution since building dimension data were provided to the EIA team for use in the air quality dispersion model has led to small differences in some dimensions of the currently proposed structures versus the modelled ones. The differences are sufficiently small that they are unlikely to materially change the overall assessment findings.” NOTE 2

The emissions stack diameter has been increased slightly from 8 to 8.5 m. The stack diameter is designed to optimise the exit velocity of flue gases from the stack. Too narrow a diameter (and therefore too high velocity) and dispersion is compromised; too wide a stack (and therefore too low velocity) and dispersion is also compromised. The optimum stack diameter and exit velocity is based upon the requirements of the installed gas turbines, as recommended by the technology provider. There is a small amount of variation as there are differences in the emission profile between different types of gas turbine. In practice, there may be some small variation in stack diameter as detailed design proceeds (typically plus or minus 0.5 m or less), but the stack diameter will not be substantially changed for the reasons explained above. The final stack diameter will be determined once the exact plant specifications required for the selected turbine has been determined. These details will be finalised ahead of the Environmental Permit being submitted as they are required for that process. It is reasonable to conclude that a small change in stack diameter will not materially alter the findings of the air quality assessment and the information used from that assessment to


9

assess effects on ecological receptors. From a visual perspective, the Landscape and Visual Impact assessment considered a worst-case stack height of 10 m greater than the likely stack height. An increase in stack diameter of approximately 6% will have no bearing on the likely significance of effects in landscape and visual terms. NOTE 3

As explained where relevant in Table 2.1 above, not all the buildings/structures were included in Table 2.1 of the EIA Report (July 2017) or the air quality modelling assessment. There were two reasons for this: Table 2.1 of the EIA Report focused on the main buildings/structures of the Project; the air quality assessment only needed to consider other structures that could have a building downwash effect, comprising structures that were more than one third of the stack height modelled. This has no bearing on the conclusion of the EIA Report regarding likely significant effects. NOTE 4

A difference in 1 m in the length of the regeneration plant shown in the photomontages from the design length will make no material difference to the findings of the visual impact assessment. NOTE 5

There were some minor discrepancies between the design drawing data and Table 2.1 of the EIA Report of July 2017 (and the air quality modelling and visual impact input data) for the gas turbine hall. Table 2.1 set the height at 3 m below the design height, but the length and width dimensions 2 m and 1 m greater respectively. The air quality modelling used a height of 5 m less than the design height and a length 1 m greater. The visual impact assessment used a height 3 m below the design height, but the length and width dimensions 2 m and 1 m greater respectively. NOTE 6

Although the drawing shows 85m the design is for 75m.

2.3 BUILDINGS/STRUCTURES LAYOUT

The EIA Report (dated July 2017) was based on a layout and positioning of the main buildings/structures presented in Figure 2.2 of that Report, reproduced as Figure 2.1 below. Comparison with the latest multi-shaft plans (refs. 105_0805_0035_01_Rev02 and 105_0805_0037_00_00) shows no material differences.

Heat Recovery Steam Generator

Gas Turbine Building

Steam Turbine Building

Cooling Water Pipework (underground)

Cooling Tower

Stack

Land set aside for future carbon capture technology

installation

DRAWN: OBCHECKED: RMAPPROVED: KM

PROJECT: 0280278

Figure 2.1Site Layout

±

Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

SCALE: See Scale Bar

Path: P:\Projects\0280278_KeadbyGIS_GB_KM\MAPS\EIA 2017\0280278_SiteLayout_A02.mxd

PROJ

ECTIO

N: Br

itish N

ation

al Gr

id

VERSION: A02SIZE: A3

DATE: 24/07/2017

0 20 40 60 80 100Metres

Proposed Development BoundarySite Layout


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3 COMPARISON BETWEEN THE LIKELY SIGNIFICANT EFFECTS OF THE

PROPOSED VARIATION AND THE 2017 CONSENT

Regarding the basis of assessment and input parameters used for assessing the impacts and effects, there is no material difference between the proposed variation and the 2017 Consent. As such, the proposed variation is predicted to have the same environmental effects as the 2017 Consent, which are as reported in the EIA Report dated July 2017.

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