Delimara Gas and Power: Combined Cycle Gas Turbine … Statement_DPS4_Appendix1... · Assessment of Environmental Impacts on Water Quality of Proposed Project. ... The revisions are

Statement on Environmental Impact Statement

Delimara Gas and Power:Combined Cycle Gas Turbine and Liquefied Natural Gas

Receiving, Storage, and Re-gasification Facilities

Appendix OneEIA Consultants’ Statements

Prepared by ERSLI Consultants Limited

on behalf of

ElectroGas Malta Limited

22 September 2016

1

Aplin, Kate

From: Farrugia Fritz at Transport <[email protected]>Sent: 14 September 2016 15:44To: Aplin, KateCc: Bugeja David at Transport; Paul Gauci; Matthew Grech; Catherine Halpin; Lopez,

Gonzalo; DC MaltaSubject: RE: ENEM – AECOM – MEP – 01870 Request for Transport Malta to confirm that

the locations of the Storm Mooring Anchors do not adversely affect the harbourfairway.

Attachments: Working layout overlay 9-9-2016.pdf

Good afternoon

We confirm that on the basis of the information and positions provided, to include the two options as noted in theattached drawing, such an installation will not adversely affect the Marsaxlokk Harbour fairway. In this respect theAuthority does not object to such an installation, subject that:

1. The Environment Resources Authority provide the necessary permit or no objection for the installation ofthe storm mooring.

2. The Planning Authority provide the necessary permit or no objection for the installation of the stormmooring.

3. Post completion of operations relating to the installation of the storm mooring, surveys indicate that thebathymetry has not been adversely affected and that the positions are as noted on the attached drawing.

4. Class approval of the storm mooring is provided in due course, and prior to use. In this respect reference ismade to BUMIARMADA manual OPS-MALT-ALM-MAR-MAN-0005, Inwater Survey in Lieu of Dry Dockingthat states that “for compliance with Class requirements, the storm mooring system equipment shall beinspected at the same time as per BV requirements. In this respect, our understanding is that the installationwill be in line with the standards as prescribed by BV “Classification of Mooring Systems for Permanent andMobile Offshore Units (Rule Note NR 493 DT RO3 E).

Kind Regards

Capt. Fritz FarrugiaDeputy Harbour MasterPorts & Yachting Directorate

Malta Transport CentreMarsa, MRS 1917Malta

Tel: (356) 2291 4410Mobile: (356) 9942 9490Email: [email protected]: www.transport.gov.mt

2

From: Aplin, Kate [mailto:[email protected]]Sent: Wednesday, September 14, 2016 1:56 PMTo: Farrugia Fritz at TransportCc: Bugeja David at Transport; Paul Gauci; Matthew Grech; Catherine Halpin; Lopez, Gonzalo; DC MaltaSubject: ENEM – AECOM – MEP – 01870 Request for Transport Malta to confirm that the locations of the StormMooring Anchors do not adversely affect the harbour fairway.

ENEM – AECOM – MEP – 01870 Request for Transport Malta to confirm that the locations of the Storm MooringAnchors do not adversely affect the harbour fairway.

Dear Fritz

On behalf of ElectroGas Malta, we kindly request that you formally confirm that the locations of the storm mooringanchors, that we have previously sent through, to you do not adversely affect the Marsaxlokk Harbour fairway.

Best regardsKate

Kate Aplin, BSc MICE CEngTechnical Director, Power & EnergyM +44-(0)782-512-2253M [email protected]

AECOMDelimara 4 Power StationTriq il-Power StationMarsaxlokk, MaltaT +356-2165-0701aecom.com

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ADDENDUM TO:

Delimara Gas and Power: Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification

facilities

Environmental Impact Statement

Assessment of Environmental Impacts on Water Quality of Proposed Project

REVISED VERSION 4 DECEMBER 2013

(ECOSERV REPORT REF: 085-13_R)

Submitted by

Victor Axiak

Independent Consultant

Logistic and technical support:

12, Sir Arthur Borton Street Mosta, MST1881

MALTA www.ecoserv.com.mt

7 January 2016

ECOSERV REPORT REFERENCE: 002-16

http://www.ecoserv.com.mt/

1. Introduction The present consultant had been requested by ECOSERV Ltd., to revise the assessment report undertaken in 2013 (Axiak, 20131) on the marine water quality in relation to the Environment Impact Assessment (EIA) for the proposed Combined Cycle Gas Turbine (CCGT) and Liquid Natural Gas (LNG) storage and regasification facility in the 'power station site' in Delimara (DPS).

The revisions are required in the light of new or updated information that was provided to the present consultant in relation to liquid discharges. Such information which was available through email indicated that:

The Gas Facilities shall conform to the emission limits as specified in the environmental impact assessment. The Contractor shall install all equipment necessary that will ensure that the Gas Facilities are able to operate within the specified emission limits throughout the whole operating regime.

For the CCGT the storm water, wash water and oily water (via an oil interceptor) will be discharged into Marsaxlokk Bay, the remaining will discharge via the existing CW outlet.

For the regasification plant the storm water, oily water and floor washing water will be discharged via an oil interceptor to Marsaxlokk Bay and again the rest via the existing CW outlets.

Furthermore an extract from document entitled: ‘B0304 – Emissions to Sea July 2014’, was made available. This is attached as Appendix to this addendum report.

In addition, the Environmental Health Department are also asking for an expert opinion regarding the impact of the discharges on bathing waters.

The original assessment report (Axiak, 2013) had first identified the marine environmental quality status of the area of interest, based on data that was available until 2013. This included identification of land-uses, diffuse and point marine discharges, water and sediment quality, as well as water dynamics as known at that time. Then it gave an outline of the main relevant features of the proposed development, and in particular, to those aspects giving rise to marine discharges. Subsequently it assessed the potential impacts on the marine environment as arising from such discharges. Such discharges included point and diffuse sources, as well as those arising during the construction and operation phase of the development.

The present Addendum Report will first identify any changes/new information on such marine discharges from the new development, as have been made available after the original

1 Axiak, V. 2013. Delimara Gas and Power: Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification facilities. Environmental Impact Statement - Assessment of Environmental Impacts on Water Quality of Proposed Project. Report submitted to Enemalta Corporation (Final version dated 4 December 2013). Ecoserv, Ltd., Malta. Unpublished report; 92 + 19 pp.

2 DRAFT 11 Jan 2016

report (Axiak, 2013). It will then re-assess the potential risks and impacts to the marine quality (including bathing water quality). In doing so, it will use the baseline water quality as had already been identified in the first assessment report in 2013 (Axiak, 2013), as well as the same impact assessment methodology (including definitions of levels of significance, etc.) as in the original report (Axiak, 2013).

This Addendum Report is to be read in conjunction with the original report (Axiak 2013).

2. Updating information on marine discharges In terms of volume, the most significant marine discharge as arising from the current installation at Delimara, as well as from the proposed new power installation, will be that of cooling waters into Hofra z-Zghira. Axiak (2013) had identified the expected changes in the discharge of such cooling waters in Table 9, indicating that the overall discharge rate will be reduced from the current estimated 43,100m3/h to 29,600 m3/h. This amounted to an estimated reduction of 30%. According to the currently available data, when the development will become fully operational, the expected rate of discharge of cooling waters will amount to 31,100 m3/h, which means that the reduction will now amount to 28%. The temperature of discharge will probably remain unaltered, as the expected rates of input and nature of biocides that will be used. With respect to water used for cleaning/cooling of air intakes leading to the air compressors of the gas turbines, Axiak (2013) had stated that insufficient information was then available. Current information indicates that this waste-stream will amount to an average of 0.01 m3/day and that such waters will be treated to comply with the requirements of Directive 2006/1/EC prior to being discharged probably with cooling waters at Hofra z-Zghira. With respect to the other wastewater streams as had been identified in Axiak (2013), most of these have remained unaltered both in terms of volumes and expected chemical profiles. There are however some minor additional details. With reference to Table 10 in Axiak (2013), the wastestream of excess brine from evaporator as arising from the new CCGT plant, the developer has now stated that these waters will be treated prior to discharge. Regarding ballast water arising from the NLG Plant, while the quantities remain unknown at this stage, this wastestream may also be disposed at sea in line with the International Convention for Control and management of Ships’ Ballast Water and Sediments, 2004. As regards floor washings (from NLG Plant), the original estimated volumes generated (0.2 m3/h or 4.8 m3/day) have now been revised to only 5% of the original estimates, ie. 0.01 m3/h or 0.27 m3/day. Similarly rain runoff to be generated from the NLG Plant which was originally estimated as being 15,000 m3/year is now being estimated slightly less at approx. 12,500 m3/year. In addition, the newly available data refer to approximately 1,752 m3/year of ‘Scrub and wash water of new waste-stream from the development which would be treated through the oil interceptor before being discharged at sea. The changes as identified above have been listed in Table 1A below.

3 DRAFT 11 Jan 2016

Evidently in terms of volume, the discharge of cooling waters at Hofra z-Zghira is by far the largest waste-stream. All the rest of the identified waste-streams make up only 0.08% of such volume. Therefore, not taking into account the discharge of cooling waters, the total for all other waste-streams to be discharged at sea originally amounted to 207,250 m3/year (Axiak, 2013). Now according to the revised estimates, these would amount to 211,871 m3/year which represents an increase of only 2.2% from the original estimates. From the information available, most or all waste-streams to be discharged at Marsaxlokk Bay may contain traces of oil. Originally, according to estimates by Axiak (2013), the total volume of such waste-streams discharged at Marsaxlokk Bay would amount to 15,400 m3/year. According to the information now available, this total volume would amount to 18,200 m3/year (an increase of 18% of the original estimate).

4 DRAFT 11 Jan 2016

Tab

le 1

A: W

aste

-str

eam

s ari

sing

from

the

deve

lopm

ent a

s hav

e be

en o

rigi

nally

iden

tifie

d by

Axi

ak (2

013)

and

as n

ow r

evis

ed.

ch

emic

als

trea

tmen

t m

3 /h

m3 /y

lo

catio

n

Axia

k 20

13

Re

vise

d Da

ta (2

014,

15)

Exp

ecte

d ch

ange

s in

Dis

char

ge r

ates

of c

oolin

g w

ater

s at H

ofra

z-z

ghir

a.

from

43,

100

m3 /h

to 2

9,60

0 m

3 /h

HZ

from

43,

100

m3 /h

to 3

1,10

0 m

3 /h

New

CC

GT

Pla

nt

ex

cess

brin

e fr

om e

vapo

rato

r sa

lts, s

cale

con

trol

and

foam

con

trol r

eage

nts

NI

19

0,00

0 at

sea,

HZ

Unc

hang

ed. B

ut to

be

trea

ted

prio

r disc

harg

e di

scha

rges

from

D

emin

eral

izat

ion

Plan

t al

kali,

aci

ds

settl

ing

tank

, pH

co

ntro

l

150

at se

a, H

Z

Unc

hang

ed

HR

SG d

rain

so

dium

pho

spha

te,

amm

onia

, sus

pend

ed

solid

s, ac

id, a

lkal

i

settl

ing

tank

, pH

co

ntro

l 2

65

at se

a, H

Z

Unc

hang

ed

boile

r was

hing

s su

spen

ded

solid

s, ot

hers

se

ttlin

g ta

nk, p

H

cont

rol

6 20

0 at

sea

HZ

Unc

hang

ed

floor

was

hing

s oi

ls, i

ndus

trial

solv

ents

, et

c oi

l int

erce

ptor

0.

2 10

0 at

sea,

MX

40

0 m

3/ye

ar

rain

runo

ff

prob

ably

trac

es o

f oil

NI

25

00

at se

a, M

X

Unc

hang

ed, b

ut n

o tr

eatm

ent

fuel

tank

s dew

ater

ing

(not

on

ly fo

r CC

GT)

Oils

(a ra

nge

of

diffe

rent

hyd

roca

rbon

s de

pend

ing

on th

e na

ture

of t

he fu

el

stor

ed)

oil i

nter

cept

or

20

0 at

sea,

MX

Unc

hang

ed

5 D

RA

FT 1

1 Ja

n 20

16

NL

G P

lant

balla

st w

ater

po

ssib

ly tr

aces

of o

il no

ne

N

I to

spec

ial

cont

ract

or

Unc

hang

ed e

xcep

t tha

t was

te

stre

am m

ay b

e di

scha

rged

at s

ea

(MX)

in

com

plia

nce

with

rele

vant

in

tern

atio

nal c

onve

ntio

ns

bilg

e oi

l/wat

er

mos

tly o

il oi

l int

erce

ptor

NI

to sp

ecia

l co

ntra

ctor

fir

efig

htin

g w

ater

rech

arge

pr

obab

ly n

one,

exc

ept

for s

ome

fire

reta

rdan

t re

agen

ts

none

NI

at se

a

Unc

hang

ed e

xcep

t tha

t was

te

stre

am w

ill b

e di

scha

rged

at s

ea

via

oil i

nter

cept

or (M

X)

floor

was

hing

oi

ls, i

ndus

trial

solv

ents

, et

c.

oil i

nter

cept

or

0.2

100

at se

a, M

X

U

ncha

nged

ra

in ru

noff

pr

obab

ly tr

aces

of o

il N

I

15,0

00

at se

a, M

X

U

ncha

nged

sa

nita

ry w

aste

wat

ers

as d

omes

tic w

aste

wat

er

none

NI

sew

ers

boile

r was

hing

s su

spen

ded

solid

s, ot

hers

oi

l int

erce

ptor

NI

to sp

ecia

l co

ntra

ctor

ra

in ru

noff

from

bun

ded

spac

es fo

r sto

rage

tank

s for

am

mon

ia a

nd u

rea

for

abat

emen

t

prob

ably

trac

es o

f oil

and

of a

mm

oniu

m sa

lts

and

urea

. no

ne

N

I at

sea,

HZ

sea

wat

er c

oolin

g sy

stem

ox

idan

ts a

nd d

isin

fect

ing

agen

ts

Chlo

ride

at m

ax, 0

.2

mg/

L

Efflu

ent t

reat

ed

to D

irect

ive

76/4

64/E

EC

at se

a

3.65

m3 /y

ear

Scru

b an

d w

ash

wat

er

poss

ibly

pol

lute

d w

ash

wat

er

1752

m3 /y

ear.

To b

e tr

eate

d th

roug

h oi

l int

erce

ptor

prio

r to

disc

harg

e at

sea

Wat

er fo

r reg

asifi

catio

n

15

00

at

sea,

HZ

U

ncha

nged

N

I = N

o in

form

atio

n; H

Z H

ofra

iz-Z

ghir

a, M

X =

Mar

saxl

okk

Bay.

6 D

RA

FT 1

1 Ja

n 20

16

3. Re-assessing Impacts of Identified Discharges on Marine Quality Axiak (2013) reviewed the data available on the expected temperature anomalies at Hofra z-Zghira due to the discharge of cooling waters in the location and concluded that these were rather limited in spatial extent. Possibly the increased surface and subsurface currents in the immediate vicinity of the discharge point may be acting as an equally or more significant parameter leading to impact on benthic communities. When taking into consideration all the various data then available, including the considerable reduction in the discharge rate of the cooling waters at Hofra z-Zghira, Axiak (2013) concluded that this would constitute POSITIVE MODERATE impact on water quality at this locality. As a worst case scenario, that is in the case that the expected reduction in the rates of discharge of cooling waters at Hofra z-Zghira will not materialize, the impact will be NEUTRAL. In the light of the recent data which suggest that the expected reduction on discharge rates would be slightly less (28% reduction rather than 30%), then the level of significance of this positive impact at Hofra z-Zghira may be considered to be the same or slight less. In any case, it will be highly unlikely to constitute a negative impact. As regards the other waste-streams to be discharged at Hofra iz-Zghira, Axiak (2013) suggested that these would cause a LOW negative impact, in the immediate vicinity of the outfall. Taking into consideration that according to the new data available, there will be an estimated increase of less than 0.1% in the expected total volume of such discharges, and that their expected chemical profiles will remain unchanged, the resultant negative impact at Hofra iz-Zghira will still be of LOW significance and of very limited spatial extent. With respect to the rest of the expected marine discharges arising from the operation of the new development, and to be discharged at Marsaxlokk Bay, Axiak (2013) predicted the resultant negative impacts on marine quality to be of MODERATE (as a worst case scenario) to LOW levels of significance. It was then pointed out that the actual level of significance will depend on the levels of workmanship and of supervision of the operations involved. Axiak (2013) made a number of recommendations on how to minimize and successfully manage such marine contamination risks. The revised data suggest that the total volume of marine discharges into Marsaxlokk Bay will increase by 18%, from 15,400 m3/year to 18,200 m3/year, which constitute an increase of 18% of the original estimate. While the exact chemical profiles of the various waste-streams would be difficult to predict, it may be assumed that one major constituent contaminant would be oil or petroleum hydrocarbons (PHC). The developer has stated that most of these waste-streams would be treated by an oil interceptor prior to discharge. It is claimed that the resultant waste-stream will contain a maximum of 5ppm of oil. Assuming that this assumption is correct, it may be estimated that on an annual basis and in a worst case scenario (since this would depend on a number of factors, including the real rates of discharges, etc.), approximately 77 kg of oil or PHC will be released into Marsaxlokk Bay as a result of such waste-streams. According to the newly available data, and making the same assumptions, it may be estimated that the annual amount of PHC released into Marsaxlokk will amount to 91 kg. Taking into consideration the fact that the dispersive characteristics of the coastal waters along the present DPS, and the fact that there is little evidence to suggest that oil pollution is currently

7 DRAFT 11 Jan 2016

significantly high in this locality, the level of negative impact of such discharges into Marsaxlokk Bay may be considered at worst to be of MODERATE significance and of limited spatial extent. With respect to the expected impact on the quality of bathing waters of the marine discharges as identified above, a number of points need to be taken into consideration: There are two officially designated bathing waters within Marsaxlokk Bay: Pretty Bay and St. George’s Bay. Both are located in the western half of the bay and are from 2.1 to 2.5 km away from DPS. As such, such bathing waters will be more exposed to anthropogenic pressures arising from Birzebbugia area, especially from the Malta Freeport. And yet according to Axiak (2013) who reviewed the baseline water quality of the general area, it was indicated that these officially designated swimming areas within Marsaxlokk (St George’s Bay and Pretty Bay) were relatively free of sewage pollution (as based on data available over the period 2008 to 2010). Axiak (2013) also indicated that the rest of the waters within the bay, were exposed to chronic pollution by sewage. These include the waters along the DPS. On the other hand, the major contaminant in the identified marine discharges arising from the proposed development and most likely to pose risks to bathing waters is highly unlikely to be sewage (microbiological) but rather PHC. Taking all the above points into consideration, it is highly unlikely that the marine discharges as arising from the DPS (and as identified above) will lead to any additional microbiological risk to the designated bathing waters within Marsaxlokk. Nor will it be likely that the PHC released from such discharges will effect such designated bathing waters. As indicated above, the release of these PHC will exert a moderate negative impact on water quality which would be quite limited in spatial extent along the DPS coastline. As far as it may be ascertained, this area is not a popular bathing area. In any case it is always unwise (if not also illegal) to bath in areas close to such intense industrial activities, as a power station.

8 DRAFT 11 Jan 2016

Appendix

Extract from document entitled: ‘B0304 – Emissions to Sea July 2014’

9 DRAFT 11 Jan 2016

B0304 1

B.03.04 EMISSIONS TO SEA The following table (B.03.04‐1) presents a list of waste water products, some of which are currently being produced at the Delimara Power Station, and others which will be introduced by the new CCGT development, which are discharged to sea. In combination with the existing Delimara Power Station (DPS) the quantities of waste waters discharged into the sea will temporarily increase as the proposed development becomes operational but will ultimately decrease once DPS Phase 1 is decommissioned, and the operational hours of DPS 2A and 2B are reduced. Table B.03.04‐1

Waste Type EWC Nature Current Quantity

Increased Quantity

Disposal route

Sea water cooling system oxidants and disinfecting agents

10 01 26 Sea water with maximum: 0.2mg/L Chloride. Effluent treated to Directive

2006/11/EC

10.8t/yr (0.03

m3/day)

0.01 m3/day**

Liquid treatment to Directive 2006/11/EC requirements

prior to discharge back to sea

Oily water 13 05 07*

Effluent treated to Directive 76/464/EEC

9,933t/yr (27.44

m3/dagy)

0.55 m3/day

Treated through oil interceptor to <5ppm

and which then

can be

discharged tothe sea in accordance

with Directive

76/464/EEC.

HRSG drained water

10 01 22*

Concentrated boiler water with phosphate and

Ammonia

N/A 36 ‐60m3/day Once a

year 65 m3

Treated and discharged to

sea

Discharges from demineralisatio

n tank†

10 01 26 May includes elevated acids or

alkali

Unknown 0.41 m3/day


sea

Excess brine from

evaporator†

10 01 26 May contain traces of scale control reagents

Unknown 520.55 m3/day


sea

B0304 2

Waste Type EWC Nature Current Quantity

Increased Quantity

Disposal route

Scrub and wash water

10 01 99 Possible polluted wash water

N/A 4.8 m3/day (average)

Oil separator,cleaned before

discharge to sea

Floor Washing 10 01 99 Variable contaminants including oils, degreasers.

N/A 0.27 m3/day (may not exceed 1.10

m3/day)

Treated through oil interceptor

and discharged to

sea

Rainwater 10 01 99 Uncontaminated rainwater

Unknown 6.84 m3/day

Discharged to sea

Boiler washings 10 02 22* / 10 01 23

Containing substantial quantities of

suspended solids, variable pH.

N/A 0.55 m3/day

Discharged to sea

following pH control

treatment.

(a) = estimations based on extrapolations from data in Axiak and Delia 2000, and Axiak

2004.

†Demineralised water to be obtained from the existing DPS. Waste water generated

from this process will not differ in composition from existing discharges.

** Calculated as a proportion of the total cooling water from CCGT

The following table (B.03.04‐2) presents an additional list of waste water products that are expected to be generated during the operational phase of the LNG transport and storage process and discharged to sea.

Source of Waste Water

EWC Description Disposal route

Sea water cooling system oxidants and disinfecting agents

10 01 26 0.001 m3/day within sea water with

maximum: 0.2mg/L Chloride. Effluent treated to Directive 2006/11/EC

Liquid treatment to Directive 2006/11/EC

Requirements prior to discharge back to sea

Discharge of water for regasification

05 07 99 36,000 m3/day. Sea water from Marsaxlokk Bay would be used to contribute to the

warming up of LNG and discharged into il‐Ħofra

ż‐Żgħira.

Discharged to sea

B0304 3

Source of Waste Water

EWC Description Disposal route

Ballast water 05 07 99 Possibly containing trace oils. Quantity currently

unknown

Disposal via specialist contractor or discharge to sea provided a suitable Ballast Water Management Plan is implemented which complies

with the International Convention for the Control and Management of Ships' Ballast Water and Sediments, 2004.

Firefighting Water 05 07 99 Possible fire retardant reagents. Quantity

unknown

Discharged to sea via interceptor

Floor Washing 10 01 99 0.27 m3/day. Variable contaminants including

oils, degreasers.

Treated through oil interceptor and discharged to sea

Rainwater 10 01 99 34.16 m3/day of uncontaminated

rainwater

Discharged to sea

The overall expected changes in the discharge rates of cooling waters is presented in Table B.03.04‐3 below.

Table B.03.04‐3

Current Situation Expected Changes

Capacity (MW)

Fuel Cooling water

(m3/day)

Capacity (MW)

Fuel Cooling water

(m3/day)

DPS1 120 HFO 504,000

DPS2A 74 Gasoil (a) 74 Gasoil (a)

DPS2B 110 Gasoil 204,000 110b Gasoil(b) [204,000] (b)

DPS3 149 HFO 326,400 149 NG/Gasoil 326,400

Proposed CCGT

‐ ‐ ‐ 215 NG 384,000

Proposed LNG Compound

‐ ‐ ‐ ‐ LNG 36,000

Total available capacity

453 1,034,400 443 746,400

(a) Included in other discharges. (b) This will be a reserve plant and will only be operational if either DPS 3 or the

proposed CCGT are not in service. Therefore its cooling waters will not be discharged simultaneously with the other streams of cooling waters originating from DPS 3 and the proposed CCGT.

B0304 4

The location of the LNG regasification compound discharge point is shown on drawing

47067567‐1022 of this document. The remainder of the site will utilise the existing outflow

into il‐Ħofra ż‐Żgħira as shown on drawing ENEM‐URS‐E0‐00‐DR‐ME‐00063‐P1.

Surface drainage will be required onsite to transport surface water run‐off to the proposed

attenuation areas prior to discharge into the sea (via oil interceptors). This will require a new

oil interceptor system, which is separate to the existing drainage system at DPS.

Page 1

Report Reference Number: 084‐16 Date: 25th July 2016

TECHNICAL STATEMENT

Addendum to assessment of environmental impacts on water quality

forming part of the EIS for the proposed CCGT and LNG storage and regasification

plant at the Delimara Power Station

Client: ElectroGas Malta Ltd. Level 3, Portomaso Business Centre, Portomaso, St. Julians STJ 4011 Malta

PREAMBLE

Ecoserv Ltd has received a request (on 14 June 2016) from Ms Catherine Halpin on behalf of ElectroGas Ltd, through Dr Paul Gauci, Environment Impact Statement Coordinator) (hereafter ‘the client’), in connection with additional information concerning a modified design1 for the proposed CCGT/LNG storage and regasification plant at the Delimara Power Station. Such request is for a technical statement by Ecoserv which would indicate whether the proposed changes to characteristics of discharges to the marine environment, will result in changes to the assessment of impacts contained in the report of environmental impacts on water quality2 prepared as part of the Environment Impact Statement (EIS) for the same project and in the addendum to same submitted in January 20163. The present document comprises the requested technical statement. 1 Proposal includes a new proposed location for the FSU.

2 Axiak, V. 2013. Delimara Gas and Power: Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification facilities. Environmental Impact Statement ‐ Assessment of Environmental Impacts on Water Quality of Proposed Project. Report submitted to Enemalta Corporation (Final version dated 4 December 2013). Ecoserv, Ltd., Malta. Unpublished report; 92 + 19 pp.

3 Axiak, V. 2016. Addendum to: Delimara Gas and Power: Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage

and regasification facilities. Environmental Impact Statement ‐ Assessment of Environmental Impacts on Water Quality of Proposed Project. Report submitted to Enemalta Corporation (Final version dated 4 December 2013). Ecoserv, Ltd., Malta. Unpublished report; 92 + 19 pp.

ecoserv Ltd 12, Sir Arthur Borton Street

Mosta, MALTA

Telephone: (+356) 2143 1900 Fax: (+356) 2142 4137

Mobile: (+356) 7943 1900 e-mail: [email protected]

VAT Reg no: 1623-1407

Page 2

METHODOLOGY

The following documents provided by Electrogas through Dr Paul Gauci were considered during compilation of the present statement:

1. Document titled ‘Comparison between the development assessed in the first draft and the ElectroGas proposal’, which is reproduced as Table 1 below.

2. Drawings titled ‘Plant layout overlay blockplan sheet 2 of 2’, bearing reference ENEM‐URS‐EO‐00‐DR‐ME‐00083 (rev 05).

3. Drawing titled ‘Malta Anchor Pattern_R8‐Layout’. 4. Presentation file titled ‘ElectroGas Malta ‐ Mooring_preliminary presentation_14‐06‐16. 5. Document titled ‘Ballast Water Management Plan’ bearing reference OPS‐MALT‐ALM‐PLN‐

0001.

6. Document bearing reference ‘B.03.04 Emissions to Sea’ containing a table indicating

summary information on discharges.

7. Drawing bearing reference ENEM‐URS‐EO‐00‐DR‐ME‐00133 (Rev p4) indicating discharge

points.

Table 1. Revisions to development permit PA/00022/14 – Construction of jetty and ancillary facilities summary. Source: Electrogas. Revisions are highlighted in yellow, while the latest ones are specified in the last column of the table (May 2016 cold ironed).

Feature As assessed in EIS 1 As submitted by ElectroGas

As submitted

by ElectroGas (22‐Feb‐16)

Updated by ElectroGas May 2016 (mobilised)

Updated by ElectroGas May

2016 (cold ironed)

General 1No GT unit 3No GT units 3No GT units

3No GT units

3No GT units

1No demineralised water plant



1No demineralised water plant (polishing plant only; Enemalta demin main plant will be used)


1No heat recovery steam generator (HRSG)

3No HRSGs 3No HRSGs

3No HRSGs

3No HRSGs

1No ST 1No ST 1No ST 1No ST 1No ST

Main stacks 1No 75m high 3No 75m high (one per GT)

3No 75m high (one per GT)



Page 3


As submitted




2016 (cold ironed)

Main stack diameter 3m 3.25m 2.90 m w/o insulation 3.10 m with insulation

2.90 m w/o insulation 3.10 m with insulation


By-pass stacks None 3No 30m high (one per GT)




By-pass stack diameter

Not applicable 3.25m 3.85 m w/o insulation 4.05 m with insulation


3.45 m w/o insulation 4.094m with insulation

D3 GRS Stacks Refer to Note (ii)

- - - 2No 10m high

2No. 10m high

D3 GRS Stack diameter

- - - 0.400m 0.400m

Main Stack Flue gas temperature at 24degC/65%RH 90oC 94.6oC 93.7oC 95.3 oC 95.3 oC

By-pass Stack Flue gas temperature at 24degC/65%RH

Not applicable 566oC 565oC 564 oC 564 oC

D3 GRS Stack Flue gas temperature at 24degC/65%RH - - - 200 oC 200 oC

FSU Boilers Flue gas temperature at 24degC/65%RH Refer to Note (iii) - - - 167 oC 330 oC

FSU Service Diesel Gen Flue gas temperature at 24degC/65%RH Refer to Note (iv) 494 oC 494 oC

Main Stack Flue gas flow per stack at 24degC/65%RH

102.06Nm3/s 102.06Nm3/s 102.06Nm3/s

102.06Nm3/s (at 15% O2 db) (132.6 kg/s)

102.06Nm3/s (at 15% O2 db) (132.6 kg/s)

D3 GRS Stack gas flow per stack at 24degC/65%RH - - -

0.150 kg/s 0.150 kg/s

Page 4


As submitted




2016 (cold ironed)

FSU Boilers flue gas flow at 24degC/65%RH - - - 5.39 kg/s

5.5 Nm3/s (7.83 kg/s)

FSU Service Diesel Gen gas flow at 24degC/65%RH - - - 3.21 kg/s 3.21 kg/s

CCGT PM10 emission concentration 3mg/Nm3 5mg/Nm3 5mg/Nm3 5mg/Nm3 5mg/Nm3

CCGT NOx emission concentration

30mg/Nm3

30mg/Nm3

refer to endnote i

30mg/Nm3

refer to endnote i

30mg/Nm3

refer to endnote i

30mg/Nm3

refer to endnote i

(OCGT) PM10 emission concentration Not applicable 5mg/Nm3 5mg/Nm3 5mg/Nm3 5mg/Nm3

(OCGT) NOx emission concentration Not applicable 30mg/Nm3

30mg/Nm3 30mg/Nm3 30mg/Nm3

D3PP GRS Stacks PM10 emission concentration

- - -

Nill Nill

D3PP GRS Stacks NOx emission concentration

- - - <170mg/kWthh (~0.02g/s net)

<170mg/kWthh (~0.02g/s net)

FSU Boilers PM10 net emissions

- - - 0.16 g/sec

Nill

FSU Boilers NOx net emissions

- - - 2.34 g/sec 0.5 g/sec

FSU Service diesel gen PM10 net emissions

- - - 0. 09 g/sec

0.09 g/sec

FSU Service diesel gen NOx net emissions

- - - 3.96 g/sec 3.96 g/sec

Land reclamation None (not conclusive) None None None None

Dredging None (not conclusive) None None None None

Jetty structure Concrete platform supported on concrete piles

Concrete/steel platform supported on piles




Jetty layout FSU/FSRU and supply carrier to berth on opposite sides of jetty

FSU & supply carrier to berth side by side east of jetty




Page 5


As submitted




2016 (cold ironed)

Capacity of LNG terminal

180,000m3 125,000m3 Floating Storage Unit (FSU) Storage Capacity = 125,000m3

Regas Terminal Capacity = 93,845 Nm³/h of Natural Gas

Floating Storage Unit (FSU) Storage Capacity = 125,000m3 Regas Terminal Capacity = 93,845 Nm³/h of Natural Gas


Location of CCGT Area A Area A Area A Area A Area A

Location of LNG terminal

Option A: on-shore in Area B

Not applicable Not applicable

Not applicable

Not applicable

Option B: dockside FSU to SW of DPS

dockside FSU to SW of DPS


Dockside FSU to SW of DPS (south of Area E)


Option C: dockside FSRU to SW of DPS


Not applicable

Not applicable

Location of re-gas Option A: southernmost tip of DPS

Southernmost tip of DPS


Southernmost tip of DPS; Area B




Not applicable

Not applicable



Not applicable

Not applicable

Length of floating unit

300m max FSU/FSRU 285m FSU 283m FSU 283m FSU 283m FSU

Width of floating unit 50m max FSU/FSRU 43.5m FSU 44.8m FSU

44.8m FSU 44.8m FSU

No of supply carrier calls

5 to 7 per annum X 48 hours duration



7 to 9 per annum X 48 hours duration (2No. connections per LNGC call each of 24hrs. Max no of LNCG connections per year 18)


Page 6


As submitted




2016 (cold ironed)

Expected fuel consumption

2,440m3 per day 2,440m3 per day 2,440m3 of LNG per day

2,440m3 of LNG per day


Power plant footprint 3,100m3 3,100m3 12,615 m² 12,615 m² 12,615 m²

NOx released per year

291 tonnes/y 53% efficiency





Cooling water discharge for new CCGT 16,000m3/h 16,000m3/h

16,000m3

/h 16,000m3/h 16,000m3/h

Cooling water discharge from FSU. Refer to Note iii - - -

3,000 m3/h 3,000 m3/h

Cooling water discharge for DPS 3

29,600m3/h 29,600m3/h

EGM/AECOM cannot comment, this is a SEP asset.



Excess brine from evaporator

190,000m3/y discharged at sea


EGM/AECOM cannot comment, this is a Enemalta asset.



HRSG drained water 65m3/y treated and discharged at sea

65m3/y treated and discharged at sea




Page 7


As submitted




2016 (cold ironed)

FSU Boiler Blowdown concentrated water

- - - 3.5 m3/y discharged to sea

30 m3/y discharged to sea at ~100degC. Estimated composition 1. phosphate concentration 15-25 ppm 2. Alkalinity 300ppm 3. Diethylhydroxylamine 0.03-0.1 ppm 4. chloride blowdown over 16 ppm 5. PH 9.8-10.2 6. TDS 2000ppm maximum limit

Rainwater runoff 25,000m3/y discharged at sea


25,000m3

/y discharged at sea



Floor washing 100m3/y treated and discharged at sea





Fuel tanks dewatering

200m3/y discharge at sea





Ballast Water Disposed into Marsaxlokk Bay

Disposed into Marsaxlokk Bay




Bilge oil/water Disposed by specialist contractor

Disposed by specialist contractor




Firefighting water recharge

Disposed at sea Disposed at sea Disposed at sea

Disposed at sea

Disposed at sea

CCGT Sanitary wastewaters

Discharged to sewer Discharged to sewer

Discharged to sewer

Discharged to sewer

Discharged to sewer

Page 8


As submitted




2016 (cold ironed)

Regas Sanitary wastewaters

- - - Collected in cesspit and removed from site by licenced contractor.

Collected in cesspit and removed from site by licenced contractor

FSU Sanitary wastewaters

- - - Treated in WWTP on FSU and discharged via barge

Treated in WWTP on FSU and discharged via barge

Boiler washings Treated & discharged at sea





Discharges from demineralisation tank 150m/y treated &

discharged at sea 150m/y treated & discharged at sea

150m/y treated & discharged at sea



Page 9


As submitted




2016 (cold ironed)


1,500m3/h discharged at sea sea water from Marsaxlokk Bay would be used to contribute to the warning up of LNG and discharged into Marsaxlokk Bay.

Minimal given that sea water will not be used for warming the LNG. Some of the CCGT cooling water would be used in the re-gas system in order to cool the glycol that would be used for the re-gasification process. This water would be discharged into il-Ħofra ż-Żgħira.

Minimal given that sea water will not be used for warming the LNG. Some of the CCGT cooling water would be used in the re-gas system in order to cool the glycol that would be used for the re-gasification process. This water would be discharged into il-Ħofra ż-Żgħira. This discharge is included within the 16,000 m³/h noted above.



Page 10


As submitted




2016 (cold ironed)

Noise: CCGT and HSRG: enclosed with silencers

CCGT and HSRG: not enclosed without silencers

CCGT and HSRG: CCGT is within it’s own insulated enclosure/ container, HRSG is not enclosed HRSG flue gas is without silencers but should not result in significant noise HRSG and steam system vents and relief valves discharge via silencers



CCGT 75.61dB/m2 85dB(A) at the company's fence when plant is in operation

85dB(A) at the company's fence when plant is in operation



85dB(A) at 1m from GT enclosure




85dB(A) at 1m from each equipment inside ElectroGas electricity facilities




75dB(A) within machine rooms, workshops




Page 11


As submitted




2016 (cold ironed)

45dB(A) within facility control building




Generator 112.00dB/m2 112.00dB/m2 112.00dB/m2

FSRU re-gas areas 109.85dB/m2 109.85dB/m2 109.85dB/m2

FSU/FSRU deck areas 75.61dB/m2 75.61dB/

m2 75.61dB/m2

Vaporisers 74.80dB/unit 74.80dB/unit 74.80dB/unit

Ref Item Description Revision Document Reference

1 Mooring and Berthing Dolphins

2No.additional Mooring Dolphins and

The original concept was for 6No. An additional dolphin has been added to each side to allow for additional mooring lines from the NG Cargo Vessel during Ship to Ship unloading operations

Original Layout – PA‐0022‐

14‐21C Revised Layout – ENEM/URS/E0/00/DR/ME/00092


14‐21D Revised Layout – ENEM/URS/E0/00/DR/ME/00089

Original Layout – 0022‐

14‐21E Revised Layout

–

2 Jetty Access Arm The jetty access arm has been relocated to suit the new location of the regas plant

The jetty access arm has been relocated to suit the new location of the regas plant. The location of the jetty itself has not changes.

As Above

APPRAISAL

Examination of the above documentation, in particular the information contained in Table 1 above, indicates the following changes between the revised information provided in 2014/2015 (see Axiak, 2016) and the latest (2016) revisions with respect to potential impacts on water quality: (i) The FUS capacity has been reduced from 180,000m3 to 125,000m3; this implies a reduction in

capacity of some 31%.

Page 12

(ii) The capacity of the Regasification Terminal, which was previously unavailable, is now given at 93,845 Nm³/h (of LNG).

(iii) The number of LNG supply carrier cells has been increased from 5 to 7 per annum to 7 to 9 per annum (X 48 hours duration); this implies a 30% increase in the number of visits by carrier cells per year. Further details provided in the latest (2016) submission indicate two connections per LNGC call each of 24hrs and a maximum number of LNCG connections of 18 per year.

(iv) Information is now available on the cooling water discharge from the FSU – this is 3,000 m3/h.

(v) Information on the cooling water discharge for DPS 3, which was previously 29,600m3/h, has not been confirmed.

(vi) Information on the excess brine from the evaporator, which was previously 29,600m3/h, has not been confirmed.

(vii) Information is now available on the FSU Boiler Blowdown concentrated water – the rate of discharge to the sea is 3.5 m3/y, and the discharge will have the following physico‐chemical characteristics:

Temperature of circa100oC

Phosphate = 15‐25 ppm

Alkalinity = 300ppm

Diethylhydroxylamine = 0.03‐0.1 ppm

Chloride blowdown > 16 ppm

PH of between 9.8 and 10.2

TDS = 2000ppm maximum limit

(viii) Information is now available on disposal of sanitary wastewaters, as follows:

CCGT wastewater will be discharged to the sewer. Regasification wastewater will be collected in a cesspit and removed from site by licenced

contractor. FSU wastewater will be treated in a waste water treatment plant on the FSU and discharged

via barge. (ix) The discharge rate of water for regasification, which was previously indicated at 1,500m3/h

discharged at sea (seawater from Marsaxlokk Bay used to warm up the LNG and discharged into Marsaxlokk Bay), is now given as ‘minimal’, since that seawater will not be used for warming the LNG. Some of the CCGT cooling water will be used in the regasification system in order to cool the glycol that would be used for the regasification process. This water will be discharged into il‐Ħofra ż‐Żgħira and is included within the 16,000 m³/h originally stated for the site (see Axiak, 2013).

With regards to the FSU ballast water (see Table above), the client has confirmed that this will be handled in accordance with the FSU ‘Ballast Water Management Plan’, document reference OPS‐MALT‐ALM‐PLN‐0001. The ballast water will be exchanged when the FSU is in transit from Singapore out in deep ocean water, as recommended by the IMO, so as to also minimize the transfer of harmful aquatic organisms and pathogens from one area of coastal waters (Singapore) to another. After the FSU is moored at the jetty any further ballast water exchange will be wholly between waters all taken from Marsaxlokk Harbour. It is not anticipated that sediment removal will be required whilst the FSU is alongside the jetty, however if this should be required over the

Page 13

operational lifetime of the plant then the sediment will be landed to an appropriate shore reception facility for appropriate treatment; hence there will be no sediment discharge to the marine environment. Overall, assessment of the above latest (2016) changes: (i) will not result in any changes to the impacts on water quality as already detailed by Axiak

(2013; 2016);

(ii) does not call for any different mitigation measures other than those already detailed in Axiak

(2013).

REFERENCES Axiak, V. 2013. Delimara Gas and Power: Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification facilities. Environmental Impact Statement ‐ Assessment of Environmental Impacts on Water Quality of Proposed Project. Report submitted to Enemalta Corporation (Final version dated 4 December 2013). Ecoserv, Ltd., Malta. Unpublished report; 92 + 19 pp. Axiak, V. 2016. Addendum to: Delimara Gas and Power: Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification facilities. Environmental Impact Statement ‐ Assessment of Environmental Impacts on Water Quality of Proposed Project. Report submitted to Enemalta Corporation (Final version dated 4 December 2013). Ecoserv, Ltd., Malta. Unpublished report; 92 + 19 pp.

Joseph A Borg BSc MSc PhD FIBMS CBiol MRSB MMBA Independent Consultant for Ecoserv Ltd 25th July 2016

Page 1

Report Reference Number: 097‐16 Date: 13th September 2016

TECHNICAL STATEMENT

Addendum to assessment of environmental impacts on water quality

forming part of the EIS for the proposed CCGT and LNG storage and regasification plant at

the Delimara Power Station

Client: ElectroGas Malta Ltd. Block D, Ta’ Monita,

Piazza off St Joseph Street, Marsaskala, MSK 1050, Malta

PREAMBLE

Ecoserv Ltd had received a request (on 14 June 2016) from Ms Catherine Halpin on behalf of ElectroGas Ltd, through Dr Paul Gauci, Environment Impact Statement Coordinator (hereafter ‘the client’), in connection with additional information concerning a modified design1 for the proposed CCGT/LNG storage and regasification plant at the Delimara Power Station. Such request was for a technical statement by Ecoserv which would indicate whether the proposed changes to characteristics of discharges to the marine environment will result in changes to the assessment of impacts contained in the report of environmental impacts on water quality2 prepared as part of the Environment Impact Statement (EIS) for the same project and in the addendum to same submitted in January 20163. Ecoserv submitted such statement to the client in August 2016 (Ecoserv, 2016). The present document comprises a further technical statement based on

1 Proposal includes a new proposed location for the FSU.

2 Axiak, V. 2013. Delimara Gas and Power: Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification facilities. Environmental Impact Statement ‐ Assessment of Environmental Impacts on Water Quality of Proposed Project. Report submitted to Enemalta Corporation (Final version dated 4 December 2013). Ecoserv, Ltd., Malta. Unpublished report; 92 + 19 pp.

3 Axiak, V. 2016. Addendum to: Delimara Gas and Power: Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and

regasification facilities. Environmental Impact Statement ‐ Assessment of Environmental Impacts on Water Quality of Proposed Project. Report submitted to Enemalta Corporation (Final version dated 4 December 2013). Ecoserv, Ltd., Malta. Unpublished report; 92 + 19 pp.


Mosta, MALTA

Telephone: (+356) 2143 1900 Fax: (+356) 2142 4137


VAT Reg no: 1623-1407

Page 2

the latest updated information, provided in September 2016, and to queries made by the Environment and Resources Authority (ERA) concerning Ecoserv’s (2016) technical statement.

METHODOLOGY

New information provided by Electrogas/AECOM is presented in the last (7th) column of Table 1 below.

Table 1. Revisions to development permit PA/00022/14 – Construction of jetty and ancillary facilities summary. Source: Electrogas. Revisions considered in Ecoserv’s (2016) statement are highlighted in yellow, while the latest (September 2016) information is stated in the last (7th) column.

Feature As assessed in EIS 1

As submitted by ElectroGas

As submitted by ElectroGas (22‐

Feb‐16)


Updated by ElectroGas May 2016

(cold ironed)

Updates September

2016

General 1No GT unit 3No GT units 3No GT units 3No GT units

3No GT units







3No HRSGs 3No HRSGs 3No HRSGs 3No HRSGs


Main stacks 1No 75m high





Main stack diameter

3m 3.25m 2.90 m w/o insulation 3.10 m with insulation








Not applicable

3.25m 3.85 m w/o insulation 4.05 m with insulation




- - - 2No 10m high

2No. 10m high


- - - 0.400m 0.400m

Page 3




Feb‐16)



(cold ironed)

Updates September

2016


By-pass Stack Flue gas temperature at 24degC/65%RH Not

applicable 566oC 565oC 564 oC 564 oC




Main Stack Flue gas flow per stack at 24degC/65%RH 102.06Nm3/s 102.06Nm3/s 102.06Nm3/s

102.06Nm3/s (at 15% O2 db) (132.6 kg/s)

102.06Nm3/s (at 15% O2 db) (132.6 kg/s)


0.150 kg/s 0.150 kg/s


5.5 Nm3/s (7.83 kg/s)




30mg/Nm3 30mg/Nm3

refer to endnote i

30mg/Nm3

refer to endnote i

30mg/Nm3

refer to endnote i

30mg/Nm3

refer to endnote i

(OCGT) PM10 emission concentration

Not applicable 5mg/Nm3 5mg/Nm3 5mg/Nm3 5mg/Nm3

Page 4




Feb‐16)



(cold ironed)

Updates September

2016

(OCGT) NOx emission concentration

Not applicable 30mg/Nm3 30mg/Nm3 30mg/Nm3 30mg/Nm3


- - -

Nill Nill


- - - <170mg/kWthh (~0.02g/s net)

<170mg/kWt

hh (~0.02g/s net)


- - - 0.16 g/sec

Nill


- - - 2.34 g/sec 0.5 g/sec


- - - 0. 09 g/sec 0.09 g/sec


- - - 3.96 g/sec 3.96 g/sec

Land reclamation

None (not conclusive)

None None None None

Dredging None (not conclusive)

None None None None












180,000m3 125,000m3

Floating Storage Unit (FSU) Storage Capacity = 125,000m3




Location of CCGT

Area A Area A Area A Area A Area A

Page 5




Feb‐16)



(cold ironed)

Updates September

2016



Not applicable Not applicable Not applicable

Not applicable








Not applicable

Location of re-gas

Option A: southernmost tip of DPS







Not applicable



Not applicable


300m max FSU/FSRU

285m FSU 283m FSU 283m FSU 283m FSU

Width of floating unit

50m max FSU/FSRU

43.5m FSU 44.8m FSU 44.8m FSU 44.8m FSU








2,440m3 per day

2,440m3 per day




Power plant footprint

3,100m3 3,100m3 12,615 m² 12,615 m² 12,615 m²







Cooling water discharge for new CCGT 16,000m3/h 16,000m3/h 16,000m3/h 16,000m3/h 16,000m3/h

Page 6




Feb‐16)



(cold ironed)

Updates September

2016

Cooling water discharge from FSU. Refer to Note iii - - - 3,000 m3/h 3,000 m3/h


8,500 m3/h


29,600m3/h 29,600m3/h




14,700 m3/h







HRSG drained water






Page 7




Feb‐16)



(cold ironed)

Updates September

2016




The FSU boiler blowdown concentrated water discharge will only take place during mobilised phase (phase I) with a maximum discharge rate of 30m3/y. This means concentrated water will only be discharged for up to the first 12 months of operation of the new facility, and with a total of 12 episodes of discharge over a 1‐year period.

The estimated composition of the blowdown water remains unchanged.

















Page 8




Feb‐16)



(cold ironed)

Updates September

2016












Disposed at sea

Disposed at sea

Disposed at sea Disposed at sea

Disposed at sea


Discharged to sewer

Discharged to sewer

Discharged to sewer

Discharged to sewer

Discharged to sewer












Discharges from demineralisation tank






Page 9




Feb‐16)



(cold ironed)

Updates September

2016







Page 10




Feb‐16)



(cold ironed)

Updates September

2016


























Generator 112.00dB/m2 112.00dB/m2

112.00dB/m2

Page 11




Feb‐16)



(cold ironed)

Updates September

2016

FSRU re-gas areas 109.85dB/m2 109.85dB/

m2 109.85dB/m2

FSU/FSRU deck areas 75.61dB/m2 75.61dB/m

2 75.61dB/m2


APPRAISAL

Further to Ecoserv (2016), the latest updated information, with respect to potential impacts on water quality is as follows: (i) The volume of cooling water discharge from DPS3 has been reduced from 29600 m3/h to 14700 m3/h. (ii) Cooling water discharge from the existing DPS 2 will be at the maximum rate of 8500 m3/h. (iii) The FSU boiler blowdown concentrated water discharge will only take place during mobilised phase

(phase I) with a maximum discharge rate of 30m3/y. This means concentrated water will only be discharged for up to the first 12 months of operation of the new facility. There will be some 12 episodes of discharge over a one year period. The estimated composition and physical properties of the blowdown water remains unchanged (see Ecoserv, 2016).

With regards to the cooling waters from DPS 2 and DPS 3, the overall situation is therefore as indicated below:

Currently Expected after D1 decommissioning

Detailed seawater consumption

Delimara1:21000m3/hr

Delimara2:8500m3/hr


Delimara1:N/A

Delimara2:8500m3/hr


Delimara4 (CCGT+Regas): 16000m3/hr

Total 44200m3/hr 39200m3/hr

Hence, based on the latest information, there will be an overall decrease (of some 5,000 m3/h), following decommissioning of D1. With respect to the FSU blowdown concentrated water; according to document ‘B.03.04 EMISSIONS TO SEA’ dated June 2016 and provided by Electrogas ‐ discharge of the FSU boiler blowdown will be

Page 12

intermittent, with some 12 episodes per year. Hence, although the exact volume discharged on any one occasion is not known at this stage, this is expected to be a fraction of the total volume (30 m3) discharged over a one‐year period. During any one discharge episode, levels of phosphate (15‐25 ppm), alkalinity (300ppm), diethylhydroxylamine (0.03‐0.1 ppm), chloride (16 ppm), pH (9.8‐10.2) and TDS (2000ppm maximum), present in the effluent are not deemed to result in a significant change of the current chemical status of the concerned Water Body MTC107. Furthermore, although the FSU boiler blowdown will have a considerably elevated temperature of 100oC; given the relatively small volume of discharge (2 – 3 m3) during any one episode, the elevated temperature is expected to lower rapidly as the relatively small volume of water disperses. Hence any adverse impact on water quality (in terms of elevated sea temperature) will be very localised and envisaged to be restricted to surface water and within an area having a radius of some 5 – 10 m. This is not expected to result in a significant change of the current physicochemical status of the concerned Water Body MTC107.

Overall, assessment of the above latest (September 2016) changes (see also Ecoserv, 2016): (i) will not result in any changes to the impacts on water quality as already detailed by Axiak (2013;

2016);

(ii) does not call for any different mitigation measures other than those already detailed in Axiak (2013).

REFERENCES Axiak, V. 2013. Delimara Gas and Power: Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification facilities. Environmental Impact Statement ‐ Assessment of Environmental Impacts on Water Quality of Proposed Project. Report submitted to Enemalta Corporation (Final version dated 4 December 2013). Ecoserv, Ltd., Malta. Unpublished report; 92 + 19 pp. Axiak, V. 2016. Addendum to: Delimara Gas and Power: Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification facilities. Environmental Impact Statement ‐ Assessment of Environmental Impacts on Water Quality of Proposed Project. Report submitted to Enemalta Corporation (Final version dated 4 December 2013). Ecoserv Ltd., Malta. Unpublished report; 92 + 19 pp. Ecoserv (2016). Technical Statement ‐ Addendum to assessment of environmental impacts on water quality forming part of the EIS for the proposed CCGT and LNG storage and regasification plant at the Delimara Power Station. Ecoserv Ltd., Malta. Unpublished report; 13pp.

Joseph A Borg BSc MSc PhD FIBMS CBiol MRSB MMBA Independent Consultant for Ecoserv Ltd 14th September 2016

Page 1

Report Reference Number: 082‐16 Date: 1 August 2016

TECHNICAL STATEMENT

Update to the marine ecology study forming part of the environment impact

statement for the proposed CCGT and LNG storage and regasification plant at the

Delimara Power Station



PREAMBLE

Ecoserv Ltd has received a request (on 14 June 2016) from Ms Catherine Halpin on behalf of ElectroGas Ltd, through Dr Paul Gauci, Environment Impact Statement Coordinator, hereafter ‘the client’, in connection with additional information concerning a modified design1 for the proposed CCGT/LNG storage and regasification plant at the Delimara Power Station. Such request is for a technical statement by Ecoserv which would indicate whether the proposed changes to characteristics of discharges to the marine environment, as well as modifications to specifications of the Floating Storage Unit (FSU) and changes to the location and mooring system of same, will result in changes to the assessment of impacts contained in the report of the marine ecology study2 prepared as part of the Environment Impact Statement (EIS) for the same project. The reader’s attention is also drawn to Ecoserv’s technical statement3 issued in 2015 in response to

1 Proposal includes a new proposed location for the FSU. 2 Ecoserv (2013). Report on marine ecological studies at il‐Hofra z‐Zghira and Delimara, prepared for the Environment Impact Statement in connection with the proposed Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification facilities at Delimara, Malta. Malta: unpublished report, 68pp. 3 Ecoserv (2015). Technical statement: Update to the marine ecology study forming part of the environment impact statement for the proposed CCGT and LNG storage and regasification plant at the Delimara Power Station, Malta. Malta: unpublished report, 5pp.


Mosta, MALTA

Telephone: (+356) 2143 1900 Fax: (+356) 2142 4137


VAT Reg no: 1623-1407

Page 2

proposed small modifications to the design4 for the proposed CCGT/LNG storage and regasification plant at the Delimara Power Station. The present document comprises the requested technical statement in relation to the latest (May 2016) changes to the project design.

METHODOLOGY

The following documents provided by Electrogas, through Dr Paul Gauci, were considered during compilation of the present statement:



3. Drawing titled ‘Malta Anchor Pattern_R8‐Layout’. 4. Presentation file titled ‘ElectroGas Malta ‐ Mooring_preliminary presentation_14‐06‐16. 5. Document titled ‘Ballast Water Management Plan’ bearing reference OPS‐MALT‐ALM‐PLN‐

0001.

6. Document bearing reference ‘B.03.04 Emissions to Sea’ containing a table indicating

summary information on discharges.

7. Drawing bearing reference ENEM‐URS‐EO‐00‐DR‐ME‐00133 (Rev p4) indicating discharge

points.



As submitted




2016 (cold ironed)


3No GT units

3No GT units







3No HRSGs 3No HRSGs

3No HRSGs

3No HRSGs


4 Proposal included modifications for the design of the jetty.

Page 3


As submitted




2016 (cold ironed)

















- - - 2No 10m high

2No. 10m high


- - - 0.400m 0.400m








102.06Nm3/s 102.06Nm3/s 102.06Nm3/s

102.06Nm3/s (at 15% O2 db) (132.6 kg/s)

102.06Nm3/s (at 15% O2 db) (132.6 kg/s)

Page 4


As submitted




2016 (cold ironed)


0.150 kg/s 0.150 kg/s


5.5 Nm3/s (7.83 kg/s)




30mg/Nm3

30mg/Nm3

refer to endnote i

30mg/Nm3

refer to endnote i

30mg/Nm3

refer to endnote i

30mg/Nm3

refer to endnote i





- - -

Nill Nill


- - - <170mg/kWthh (~0.02g/s net)



- - - 0.16 g/sec

Nill


- - - 2.34 g/sec 0.5 g/sec


- - - 0. 09 g/sec

0.09 g/sec


- - - 3.96 g/sec 3.96 g/sec








Page 5


As submitted




2016 (cold ironed)















Not applicable

Not applicable








Not applicable

Not applicable








Not applicable

Not applicable



Not applicable

Not applicable




44.8m FSU 44.8m FSU

Page 6


As submitted




2016 (cold ironed)



















16,000m3

/h 16,000m3/h 16,000m3/h


3,000 m3/h 3,000 m3/h


29,600m3/h 29,600m3/h















Page 7


As submitted




2016 (cold ironed)






25,000m3



























Disposed at sea

Disposed at sea



Discharged to sewer

Discharged to sewer

Discharged to sewer

Page 8


As submitted




2016 (cold ironed)

















Page 9


As submitted




2016 (cold ironed)







Page 10


As submitted




2016 (cold ironed)


















Page 11


As submitted




2016 (cold ironed)












m2 75.61dB/m2












–



As Above

Page 12

Figure 1. Drawing showing the newly proposed mooring system of the Floating Storage Unit (FSU). In the drawing, the FSU shown on the left represents the Unit moored in ‘storm’ mode, while the FSU shown on the right adjacent the jetty represents the Unit moored at other times when not in ‘storm’ mode. Source: Electrogas.

Page 13

APPRAISAL

Examination of the above documentation, in particular the proposed changes indicated in Table 1 and the drawing showing the new design for the FSU mooring system (see Figure 1), indicates the following changes between the original design for the offshore jetty submitted in 2013 (see Ecoserv, 2013) and the latest (2016) proposed revisions: (i) The FUS capacity has been reduced from 180,000m3 to 125,000m3; this implies a reduction in

capacity of some 31%. (ii) The capacity of the Regasification Terminal, which was previously unavailable, is now given

at 93,845 Nm³/h (of LNG). (iii) The length of the FUS has been reduced slightly: from 285 m to 283 m. (iv) The width of the FSU has been increased slightly from 43.5 to 44.8. (v) A new mooring system for the FSU has been proposed, as indicated in Figure 1, which will be

operational only when the position of the FSU is in ‘storm’ mode. This entails the deployment of a permanent mooring system comprising a total of 8 anchors, 2 each located at the northeastern, southeastern, southwestern and northwestern sides of the FSU, and a mooring line (chain) between the anchors and the FUS that will have a length of between 150 m and 180 m.

(vi) The location of the FSU will temporary change such that the unit will be moved westwards during short periods of adverse sea conditions; presumably during high winds that will blow directly onto the western side of the FSU.

(vii) The number of LNG supply carrier cells has been increased from 5 to 7 per annum to 7 to 9 per annum (X 48 hours duration); this implies a 30% increase in the number of visits by carrier cells per year. Further details provided in the latest (2016) submission indicate two connections per LNGC call each of 24hrs and a maximum number of LNCG connections of 18 per year.

(viii) Information is now available on the cooling water discharge from the FSU – this is 3,000 m3/h.

(ix) Information on the cooling water discharge for DPS 3, which was previously 29,600m3/h, has not been confirmed.

(x) Information on the excess brine from the evaporator, which was previously 29,600m3/h, has not been confirmed.

(xi) Information is now available on the FSU Boiler Blowdown concentrated water – the rate of discharge to the sea is 3.5 m3/y, and the discharge will have the following physico‐chemical characteristics:

Temperature of circa100oC

Phosphate = 15‐25 ppm

Alkalinity = 300ppm

Diethylhydroxylamine = 0.03‐0.1 ppm

Chloride blowdown > 16 ppm

PH of between 9.8 and 10.2

TDS = 2000ppm maximum limit

(xii) Information is now available on disposal of sanitary wastewaters, as follows:

CCGT wastewater will be discharged to the sewer.

Page 14

Regasification wastewater will be collected in a cesspit and removed from site by licenced

contractor.

FSU wastewater will be treated in a waste water treatment plant on the FSU and

discharged via barge.

(xiii) The discharge rate of water for regasification, which was previously indicated at 1,500m3/h discharged at sea (seawater from Marsaxlokk Bay used to warm up the LNG and discharged into Marsaxlokk Bay), is now given as ‘minimal’, since that seawater will not be used for warming the LNG. Some of the CCGT cooling water will be used in the regasification system in order to cool the glycol that would be used for the regasification process. This water will be discharged into il‐Ħofra ż‐Żgħira and is included within the 16,000 m³/h originally stated for the site (see Axiak, 2013).

With regards to the FSU ballast water (see Table above), the client has confirmed that this will be handled in accordance with the ‘Ballast Water Management Plan’ document reference OPS‐MALT‐ALM‐PLN‐0001, for the project. The ballast water will be exchanged when the FSU is in transit from Singapore out in deep ocean water, as recommended by the IMO, so as to also minimize the transfer of harmful aquatic organisms and pathogens from one area of coastal waters (Singapore) to another. After the FSU is moored at the jetty any further ballast water exchange will be wholly between waters all taken from Marsaxlokk Harbour. It is not anticipated that sediment removal will be required whilst the FSU is alongside the jetty, however if this should be required over the operational lifetime of the plant then the sediment will be landed to an appropriate shore reception facility for appropriate treatment; hence there will be no sediment discharge to the marine environment, nor introduction of pathogens and non‐native aquatic species. Figure 2 shows an overlay of the latest (2016) proposed mooring system for the FSU in relation to the marine benthic assemblages present within the Delimara study area, as recorded during Ecoserv’s 2013 survey, and which incorporates additional data collected by the company during the same study but not used in Ecoserv’s (2013) report, as well as more recent unpublished data collected in 2015 by the present consultant in relation to research studies held in Marsaxlokk Bay. As can be seen in Figure 2, the proposed mooring system will entail deployment of the 8 anchors and mooring lines on a seabed area that supports the biocoenosis of polluted harbour mud and sandy mud (in places with facies of Cymodocea nodosa). The two anchors that will be deployed on the northwestern side of the FSU will be located just outside the border of the Posidonia oceanica meadow present close by. Overall, when considering the layout of the newly proposed mooring system for the FSU, and translocation of the latter during short periods of adverse sea conditions, as well as the small changes in the length and width of the FSU, these are deemed to not have any additional/different impact on marine ecology other than as described in Ecoserv (2013). Likewise for the latest changes and newly available information on discharges to the sea; these are envisaged to not have any additional/different impact on marine ecology other than as described in Ecoserv (2013).

Page 15

Figure 2. Overlay showing the layout of the newly proposed mooring system for the FSU and the location of the unit itself when not docked adjacent the jetty but moved westwards during short periods of adverse sea conditions, in relation to the marine benthic assemblages present in their vicinity.

Page 16

Overall, assessment of the above changes: (i) in the design of the new mooring system for the FSU, and dimensions and temporary positioning/berthing of the Unit during short period of adverse sea conditions; and (ii) in characteristics of discharges to the marine environment, indicates that the latest (2016) proposed changes to the project:

(i) will not result in any changes to the impacts on marine ecology during both

construction and operational phases as already detailed in Ecoserv (2013);

(ii) will not result in any different impacts on the ecological status of MTC107 other than

those already detailed in Ecoserv (2013);

(iii) does not call for any different mitigation measures other than those already detailed in

Ecoserv (2013).

REFERENCE

Ecoserv (2013). Report on marine ecological studies at il‐Hofra z‐Zghira and Delimara, prepared for the Environment Impact Statement in connection with the proposed Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification facilities at Delimara, Malta. Malta: unpublished report, 68pp.

Joseph A Borg BSc MSc PhD FIBMS CBiol MRSB MMBA Independent Consultant for Ecoserv Ltd 1 August 2016

Page 1

Report Reference Number: 096‐16 Date: 13th September 2016

TECHNICAL STATEMENT

Update to the marine ecology study forming part of the environment impact





PREAMBLE

Ecoserv Ltd has received a request (in September 2016) from ElectroGas Ltd, through Dr Paul Gauci, Environment Impact Statement Coordinator, hereafter ‘the client’, in connection with additional information concerning a modified design1 for the proposed CCGT/LNG storage and regasification plant at the Delimara Power Station. Such request is for a technical statement by Ecoserv which would indicate whether the proposed modification (two options) to the locations of anchors 3 and 4, and length/locations of the respective mooring lines, of the Floating Storage Unit (FSU), will result in changes to the assessment of impacts contained in the report of the marine ecology study2 prepared as part of the Environment Impact Statement (EIS) for the same project.

1 Proposal includes a new proposed location for the FSU. 2 Ecoserv (2013). Report on marine ecological studies at il‐Hofra z‐Zghira and Delimara, prepared for the Environment Impact Statement in connection with the proposed Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification facilities at Delimara, Malta. Malta: unpublished report, 68pp.


Mosta, MALTA

Telephone: (+356) 2143 1900 Fax: (+356) 2142 4137


VAT Reg no: 1623-1407

Page 2

The reader’s attention is also drawn to Ecoserv’s technical statement3 issued in 2015 in response to proposed small modifications to the design4 for the proposed CCGT/LNG storage and regasification plant at the Delimara Power Station, and to Ecoserv’s (2016) technical statement5 dated 1st August 2016 concerning proposed modifications to specifications of the Floating Storage Unit (FSU) and changes to the location and mooring system of same. The present document comprises the requested technical statement in relation to the latest (September 2016) proposed changes to the mooring lines/anchors 3 and 4 of the FSU, for which two options are being provided: Option 1 and Option 2.

METHODOLOGY

The following documents provided by Electrogas were considered during compilation of the present statement:

1. Drawing titled ‘Anchor coordinates’. 2. Drawing titled ‘Anchor coordinates Option 2’.

APPRAISAL

Examination of the drawings provided, showing two options of revised layout of moorings/anchors 3 and 4 of the FSU mooring system (see Figures 1 and 2), indicates the following changes between the previous FSU mooring layout (see Ecoserv, 2016) and the latest (present, September 2016) proposed revised layout: (i) In Option 1, the mooring lines of anchors 3 and 4 are each extended by 25 m to the

southwest, and accordingly the location of each anchor is displaced by 25 m to the southwest.

(ii) In Option 2, the mooring lines of anchors 3 and 4 are each extended by 25 m to the west, and accordingly, the location of each anchor is displaced by 25 m to the west; as a result the locations of the two mooring lines are displaced to the west.

3 Ecoserv (2015). Technical statement: Update to the marine ecology study forming part of the environment impact statement for the proposed CCGT and LNG storage and regasification plant at the Delimara Power Station, Malta. Malta: unpublished report, 5pp. 4 Proposal included modifications for the design of the jetty. 5 Ecoserv (2016). Technical statement: Update to the marine ecology study forming part of the environment impact statement for the proposed CCGT and LNG storage and regasification plant at the Delimara Power Station, Malta. Malta: unpublished report, 16pp

Page 3

Figure 1. Drawing showing the proposed revised mooring Option 1 of the Floating Storage Unit (FSU) in relation to the marine benthic habitats present in the area. The revised layout comprises extending the mooring for each of anchors 3 and 4, and accordingly the locations of the two anchors by 25 m to the southwest – the extended portion of the mooring and new locations of the latter are shown in red. In the drawing, the FSU shown on the left represents the Unit moored in ‘storm’ mode, while the FSU shown on the right adjacent the jetty represents the Unit moored at other times when not in ‘storm’ mode. Source: Electrogas.

Page 4

Figure 2. Drawing showing the proposed revised mooring Option 2 of the Floating Storage Unit (FSU) in relation to the marine benthic habitats present in the area. The revised layout comprises extending the mooring for each of anchors 3 and 4, and accordingly the locations of the latter by 25 m to the west – the displaced portion of the mooring and new locations of the two anchors are shown in red. In the drawing, the FSU shown on the left represents the Unit moored in ‘storm’ mode, while the FSU shown on the right adjacent the jetty represents the Unit moored at other times when not in ‘storm’ mode. Source: Electrogas.

Page 5

Figures 1 and 2 show an overlay of the latest (present, September 2016) proposed mooring layouts – Option 1 and Option 2 respectively ‐ for the FSU in relation to the marine benthic assemblages present within the Delimara study area, as recorded during Ecoserv’s 2013 survey, and which incorporates additional data collected by the company during the same study but not used in Ecoserv’s (2013) report, as well as more recent unpublished data collected in 2015 by the present consultant in relation to research studies held in Marsaxlokk Bay. As can be seen in the two figures, either option of the proposed mooring layout will entail deployment of the two anchors 3 and 4, respective mooring lines, on a seabed area that supports the biocoenosis of polluted harbour mud and sandy mud (in places with facies of Cymodocea nodosa). Overall, when considering the new proposed layout of moorings/anchors 3 and 4 for the FSU, these are deemed to not have any additional/different impact on marine ecology other than as described in Ecoserv (2013). Overall, assessment of the above changes: (i) in the design of the new mooring system for the FSU, and dimensions and temporary positioning/berthing of the Unit during short period of adverse sea conditions; and (ii) in characteristics of discharges to the marine environment, indicates that the latest (2016) proposed changes to the project:

(i) will not result in any changes to the impacts on marine ecology during both

construction and operational phases as already detailed in Ecoserv (2013);

(ii) will not result in any different impacts on the ecological status of MTC107 other than

those already detailed in Ecoserv (2013);

(iii) does not call for any different mitigation measures other than those already detailed in

Ecoserv (2013).

REFERENCE

Ecoserv (2013). Report on marine ecological studies at il‐Hofra z‐Zghira and Delimara, prepared for the Environment Impact Statement in connection with the proposed Combined Cycle Gas Turbine and Liquefied Natural Gas receiving, storage and regasification facilities at Delimara, Malta. Malta: unpublished report, 68pp.

Joseph A Borg BSc MSc PhD FIBMS CBiol MRSB MMBA Independent Consultant for Ecoserv Ltd 23rd September 2016

Paul Gauci <[email protected]>

Re: ENEM – AECOM – MEP – 01874 Transport Malta and Environmental Expertscomments on storm mooring anchor locations1 message

Joseph A Borg <[email protected]> 20 September 2016 at 16:09Reply-To: Joseph A Borg <[email protected]>To: Abela Vassallo Josianne at ERA <[email protected]>, Paul Gauci <[email protected]>Cc: Ellul Nathalie at ERA <[email protected]>, Smith Charlene at ERA <[email protected]>, "Lopez,Gonzalo" <[email protected]>, [email protected], Matthew Grech<[email protected]>, Catherine Halpin <[email protected]>, "Gregory, Paul X (Leeds)"<[email protected]>, [email protected], Aquilina Anthony J at ERA <[email protected]>, RizzoMiraine at ERA <[email protected]>, Piccinino Michelle at ERA <[email protected]>, Camilleri Alexander-Joseph at ERA <[email protected]>, Sarah Debono <[email protected]>, Cousin Christopher atERA <[email protected]>, Farrugia Fritz at Transport <[email protected]>

Dear Ms Abela Vassallo and Dr Gauci

With reference to the query concerning Cymodocea nodosa, I quote from Ecoserv's report of the marine ecological studies dated

August 2013:

"The waters inside Marsaxlokk Bay, par cularly those in its inner reaches and at Delimara already havesome contaminants, as evidenced by the data on water quality from surveys carried out in the past (e.g.see Axiak, 2013). Furthermore, Marsaxlokk Bay is already subjected to considerable vessel traffic andac vi es. Disturbance resul ng from the currents produced by moving vessels and propeller ac on, as wellas anchoring is widespread in the bay including the study area. Several vessels are also mooredpermanently for long periods (several hours to days) in the bay, thereby producing some shading effect.Therefore, the benthic present in the study area are already adapted to life in a harbour environmentwhere some pollu on, disturbance due to dredging ac vi es are present. However, this also means thatsome species, namely the seagrasses Posidonia oceanica and Cymodocea nodosa are already stressed suchthat further stress induced through pollu on of the marine environment result in larger adverse effectsthan would otherwise be experienced by the plants had they been in a be er state of health. However, it isnot envisaged that these species will be at any risk of decima on as a result of such a poten al adverseimpact.

As indicated in the 2013 report, as well and in Ecoserv's statements dated August 2016 and September2016, the seabed area where the moorings will be deployed supports predominantly a biocoenosis ofpolluted harbour mud and sandy mud (in places with facies of Cymodocea nodosa). This means that theseagrass (Cymodocea nodosa) is present in places as sparse patches, many of which are less than 1m2 inarea. It is impossible to determine whether the concerned anchors and por on of the mooring lines willeventually rest on one or more of such patches, given the small size of these patches and that it is nearlyimpossible in prac ce to map the loca on and extent of such patches. However, even if the the anchorsand por on of the mooring lines will come to rest on the seagrass, Cymodocea nodosa is a very resilientspecies and capable of recolonising a disturbed area (including one subjected to physicaldisturbance) rapidly. Furthermore, as already indicated in Ms Abela Vassal's e‐mail below, stands of thissagrass species are very dynamic and tend to change fairly quickly in space and me. Therefore, as alreadystated in the August 2013 and September 2013 statements (copies a ached for ease of reference), theproposed mooring system will not result in any changes to the impacts on marine ecology, includingCymodocea nodosa, during both construc on and opera onal phases as already detailed in Ecoserv's(2013) report of marine ecological studies.

Using expert judgment, I can also confirm that the proposed mooring system will not will not result in anydifferent impacts on the ecological status of MTC107, including algae, Posidonia oceanica andphytoplankton, other than those already detailed in Ecoserv's (2013) report of marine ecological studies, as

Gmail - Re: ENEM – AECOM – MEP – 01874 Transport Malta a... https://mail.google.com/mail/u/0/?ui=2&ik=25bcf2c8a4&view=p...

1 of 5 22/09/2016 08:05

already indicated in the August 2013 and September 2013 statements.

I trust the above is of help.

RegardsJ A Borg

‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐Dr Joseph A BorgSenior Scien fic Consultant

Mobile: (+356) 99495343E‐mail: [email protected]

From: Abela Vassallo Josianne at ERASent: Tuesday, September 20, 2016 11:53 AMTo: Paul Gauci ; [email protected]: Ellul Nathalie at ERA ; Smith Charlene at ERA ; Lopez, Gonzalo ; Michael Sant([email protected]) ; Matthew Grech ; Catherine Halpin ; Gregory, Paul X (Leeds) ;[email protected] ; Aquilina Anthony J at ERA ; Rizzo Miraine at ERA ; Piccinino Michelle at ERA ;Camilleri Alexander-Joseph at ERA ; Sarah Debono ; Joseph A Borg ; Cousin Christopher at ERA ; FarrugiaFritz at TransportSubject: RE: ENEM – AECOM – MEP – 01874 Transport Malta and Environmental Experts comments onstorm mooring anchor locations

Dear Paul,

Your reply has been noted with thanks. It would be appreciated if such statement on Cymodocea nodosa is included inthe report quoted and referred to ERA accordingly.

Thanks

Josianne

From: Paul Gauci [mailto:[email protected]] On Behalf Of Paul GauciSent: Tuesday, 20 September 2016 11:18To: Abela Vassallo Josianne at ERA; '[email protected]'; [email protected]: Ellul Nathalie at ERA; Smith Charlene at ERA; Lopez, Gonzalo; Michael Sant([email protected]); Matthew Grech; Catherine Halpin; Gregory, Paul X (Leeds);[email protected]; Aquilina Anthony J at ERA; Rizzo Aaron at ITS; Rizzo Miraine at ERA; PiccininoMichelle at ERA; Camilleri Alexander-Joseph at ERA; Sarah Debono; Joseph A BorgSubject: Re: ENEM – AECOM – MEP – 01874 Transport Malta and Environmental Experts comments onstorm mooring anchor locations

Josianne

I'm trying to get through to ecoserv. However, I submit that since the area in which the anchors would be located islabelled '... polluted harbour mud...'


2 of 5 22/09/2016 08:05

the impact on Cymodocea nodosa would be of very low significance.

Dr Borg and Sarah Debono are copied in order for them to send an ecoserv statement.

Paul

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Dr Paul GauciSpatial Planning Consultant

ERSLI Consultants1 Spencer6 Triq San Ġorġ PrecaBlata l-BajdaĦamrun ĦMR 1605Malta

Sent from my BlackBerry Passport +35679537670 | BBM: 2C0163F5

From: Abela Vassallo Josianne at ERA

Sent: Tuesday, 20 September 2016 10:55

To: '[email protected]'; [email protected]

Cc: Ellul Nathalie at ERA; Smith Charlene at ERA; Lopez, Gonzalo; Michael Sant([email protected]); Matthew Grech; Catherine Halpin; Gregory, Paul X (Leeds);[email protected]; Aquilina Anthony J at ERA; Rizzo Aaron at ITS; Rizzo Miraine at ERA; PiccininoMichelle at ERA; Camilleri Alexander-Joseph at ERA

Subject: RE: ENEM – AECOM – MEP – 01874 Transport Malta and Environmental Experts comments onstorm mooring anchor locations

Dear Paul/ Dr Borg,

Reference is made to email below.

ERA would like a confirmation that the proposed mooring in Marsaxlokk Bay as described in the “Update to the marineecology study forming part of the environment impact statement for the proposed CCGT and LNG storage andregasification plant at the Delimara Power Station” will not lead to any significant impact on the habitat of Cymdoceanodosa. This confirmation is particularly important noting that this habitat may classify as an Annex I habitat of theHabitats Directive even though Malta has attained sufficiency for this habitat. Furthermore, noting that this species israther dynamic and hence its presence may not always be located within the same area.

Additionally, it is also required that an expert judgment is provided on BQEs (macroalgae, Posidonia and phytoplankton)confirming that there will not be any signifcant impact on such species.

An urgent reply would be appreciated.

Regards,


3 of 5 22/09/2016 08:05

Josianne

Josianne Abela VassalloTeam Manager | Environment Assessment

Environment & Resources AuthorityHexagon House, Spencer Hill, Marsa, MRS 1441, Malta.T | +356 22923721 W | era.org.mt

SAVE PAPER Think before you print this email.

From: Aplin, Kate [mailto:[email protected]]Sent: Friday, 16 September 2016 12:28To: Aquilina Anthony J at ERACc: Ellul Nathalie at ERA; Smith Charlene at ERA; Abela Vassallo Josianne at ERA; Lopez, Gonzalo; MichaelSant ([email protected]); Matthew Grech; Catherine Halpin; Gregory, Paul X (Leeds)Subject: ENEM – AECOM – MEP – 01874 Transport Malta and Environmental Experts comments on stormmooring anchor locations

ENEM – AECOM – MEP – 01874 Transport Malta and Environmental Experts comments on storm mooringanchor locations

Dear Anthony

As discussed during today’s meeting please find attached;

1. The alternative locations of the storm mooring anchors (Original location and Option 2 with anchors 3&4offset 25m)

2. The statement from Transport Malta advising that they present no adverse effect on the harbour fairway

3. The statements from the Marine Ecologists and Archaeologists regarding the original locations of theanchors.

4. The statements from the Marine Ecologists and Archaeologists regarding two alternative 25m offsets ofanchors 3 & 4

I trust that this is sufficient information for you to review and advise Transport Malta of your non-objection to theinstallation of these anchors in either the original or 25m offset locations. If you require any further information orclarifications please do let me know.

Best regards

Kate


4 of 5 22/09/2016 08:05





2 attachments

Ecoserv statement on marine ecology DPS 13-9-16.pdf368K

Ecoserv statement on marine ecology DPS v 1-8-16.pdf1269K


5 of 5 22/09/2016 08:05

Page 1

Report Reference Number: 083‐16 Date: 1 August 2016

TECHNICAL STATEMENT

Update to the marine archaeology study forming part of the environment impact





PREAMBLE

Ecoserv Ltd has received a request (on 14 June 2016) from Ms Catherine Halpin on behalf of ElectroGas Ltd, through Dr Paul Gauci, Environment Impact Statement Coordinator, hereafter ‘the client’, in connection with additional information concerning a modified design1 for the proposed CCGT/LNG storage and regasification plant at the Delimara Power Station. Such request is for a technical statement by Ecoserv which would indicate whether the proposed changes to modifications to specifications of the Floating Storage Unit (FSU) and changes to the location and mooring system of same, will result in changes to the assessment of impacts contained contained in the marine archaeology study2 prepared as part of the Environment Impact Statement (EIS) for the same project. The reader’s attention is also drawn to Gambin’s (2015) technical statement3

1 Proposal includes a new proposed location for the FSU. 2 Gambin, T. (2013) Report on Marine Archaeology for the proposed power station at Marsaxlokk Bay, Malta, August 2013. Ecoserv Ltd, Malta; unpublished report, 59pp. 3 Gambin (2015). Technical statement: Update to the marine archaeology study forming part of the environment impact statement for the proposed CCGT and LNG storage and regasification plant at the Delimara Power Station. Ecoserv Ltd, Malta. Malta: unpublished report, 5pp.


Mosta, MALTA

Telephone: (+356) 2143 1900 Fax: (+356) 2142 4137


VAT Reg no: 1623-1407

Page 2

issued in 2015 in response to proposed small modifications to the design4 for the proposed CCGT/LNG storage and regasification plant at the Delimara Power Station. The present document comprises the requested technical statement in relation to the latest (May 2016) changes to the project design.

METHODOLOGY

The following documents provided by Electrogas, through Dr Paul Gauci, were considered during compilation of the present statement:



3. Drawing titled ‘Malta Anchor Pattern_R8‐Layout’. 4. Presentation file titled ‘ElectroGas Malta ‐ Mooring_preliminary presentation_14‐06‐16.



As submitted




2016 (cold ironed)


3No GT units

3No GT units







3No HRSGs 3No HRSGs

3No HRSGs

3No HRSGs







Page 3


As submitted




2016 (cold ironed)













- - - 2No 10m high

2No. 10m high


- - - 0.400m 0.400m








102.06Nm3/s 102.06Nm3/s 102.06Nm3/s

102.06Nm3/s (at 15% O2 db) (132.6 kg/s)

102.06Nm3/s (at 15% O2 db) (132.6 kg/s)


0.150 kg/s 0.150 kg/s


5.5 Nm3/s (7.83 kg/s)

Page 4


As submitted




2016 (cold ironed)




30mg/Nm3

30mg/Nm3

refer to endnote i

30mg/Nm3

refer to endnote i

30mg/Nm3

refer to endnote i

30mg/Nm3

refer to endnote i





- - -

Nill Nill


- - - <170mg/kWthh (~0.02g/s net)



- - - 0.16 g/sec

Nill


- - - 2.34 g/sec 0.5 g/sec


- - - 0. 09 g/sec

0.09 g/sec


- - - 3.96 g/sec 3.96 g/sec













Page 5


As submitted




2016 (cold ironed)










Not applicable

Not applicable








Not applicable

Not applicable








Not applicable

Not applicable



Not applicable

Not applicable




44.8m FSU 44.8m FSU







Page 6


As submitted




2016 (cold ironed)













16,000m3

/h 16,000m3/h 16,000m3/h


3,000 m3/h 3,000 m3/h


29,600m3/h 29,600m3/h


















Page 7


As submitted




2016 (cold ironed)



25,000m3



























Disposed at sea

Disposed at sea



Discharged to sewer

Discharged to sewer

Discharged to sewer

















Page 8


As submitted




2016 (cold ironed)







Page 9


As submitted




2016 (cold ironed)






















Page 10


As submitted




2016 (cold ironed)








m2 75.61dB/m2












–



As Above

Page 11

Figure 1. Drawing showing the newly proposed mooring system of the Floating Storage Unit (FSU). In the drawing, the FSU shown on the left represents the Unit moored in ‘storm’ mode, while the FSU shown on the right adjacent the jetty represents the Unit moored at other times when not in ‘storm’ mode. Source: Electrogas.

Page 12

APPRAISAL

Examination of the above documentation, in particular the proposed changes indicated in Table 1 and the drawing showing the new design for the FSU mooring system (see Figure 1), indicates the following changes between the original design for the offshore jetty submitted in 2013 (see Gambin, 2013) and the latest (2016) proposed revisions: (i) The length of the FUS has been reduced slightly: from 285 m to 283 m. (ii) The width of the FSU has been increased slightly from 43.5 to 44.8. (iii) A new mooring system for the FSU has been proposed, as indicated in Figure 1, which will be

operational only when the position of the FSU is in ‘storm’ mode. This entails the deployment of a permanent mooring system comprising a total of 8 anchors, 2 each located at the northeastern, southeastern, southwestern and northwestern sides of the FSU, and a mooring line (chain) between the anchors and the FUS that will have a length of between 150 m and 180 m.

(iv) The location of the FSU will temporary change such that the unit will be moved westwards during short periods of adverse sea conditions; presumably during high winds that will blow directly onto the western side of the FSU.

(v) The number of LNG supply carrier cells has been increased from 5 to 7 per annum to 7 to 9 per annum (X 48 hours duration); this implies a 30% increase in the number of visits by carrier cells per year. Further details provided in the latest (2016) submission indicate two connections per LNGC call each of 24hrs and a maximum number of LNCG connections of 18 per year.

Figure 2 shows an overlay of the latest (2016) proposed mooring system for the FSU in relation to the to the map of contacts from the marine archaeological studies carried out within the Delimara study area in 2013, as recorded during the 2013 survey report (Gambin, 2013).

APPRAISAL

Following the study of the above‐mentioned documentation and plans, the undersigned, who carried out the marine archaeological studies for the EIA, finds no objection with the new position of the quay, and no changes are required to the assessment of impacts and conclusions cited in the report submitted in 2013 (see Gambin, 2013). However, it is essential that the following points are noted and adhered to: 1) The proposed locations of the permanent anchors do not coincide with any of the sub‐bottom

targets detected in the course of the 2013 surveys.

2) All monitoring precautions listed in the original report are adhered to. 3) The changes are approved by all competent authorities.

Page 13

Figure 2. Overlay showing the layout of the newly proposed mooring system for the FSU and the location of the unit itself when not docked adjacent the jetty but moved westwards during short periods of adverse sea conditions, in relation to the map of contacts from the marine archaeology study made in 2013 (Gambin, 2013).

Page 14

REFERENCE

Gambin, T. (2013) Report on Marine Archaeology for the proposed power station at Marsaxlokk Bay, Malta, August 2013. Ecoserv Ltd, Malta; unpublished report, 59pp.

Dr Timothy Gambin BA MA PhD (Bristol) Independent Consultant for Ecoserv Ltd

1 August 2016

Page 1

Report Reference Number: 095‐16 Date: 13 September 2016

TECHNICAL STATEMENT

Update to the marine archaeology study forming part of the environment impact





PREAMBLE

Ecoserv Ltd has received a request (in September 2016) from ElectroGas Ltd, through Dr Paul Gauci, Environment Impact Statement Coordinator, hereafter ‘the client’, in connection with additional information concerning a modified design1 for the proposed CCGT/LNG storage and regasification plant at the Delimara Power Station. Such request is for a technical statement by Ecoserv which would indicate whether the proposed modification (two options) to the locations of anchors 3 and 4, and length/locations of the respective mooring lines, of the Floating Storage Unit (FSU), will result in changes to the assessment of impacts contained in the marine archaeology study2 prepared as part of the Environment Impact Statement (EIS) for the same project. The reader’s attention is also drawn to Gambin’s (2015) technical statement3 issued in 2015 in

1 Proposal includes a new proposed location for the FSU. 2 Gambin, T. (2013) Report on Marine Archaeology for the proposed power station at Marsaxlokk Bay, Malta, August 2013. Ecoserv Ltd, Malta; unpublished report, 59pp. 3 Gambin (2015). Technical statement: Update to the marine archaeology study forming part of the environment impact statement for the proposed CCGT and LNG storage and regasification plant at the Delimara Power Station. Ecoserv Ltd, Malta. Malta: unpublished report, 5pp.


Mosta, MALTA

Telephone: (+356) 2143 1900 Fax: (+356) 2142 4137


VAT Reg no: 1623-1407

Page 2

response to proposed modifications to the design4 for the proposed CCGT/LNG storage and regasification plant at the Delimara Power Station, and to Gambin’s (2016) technical statement5 dated 1st August 2016 concerning proposed modifications to specifications of the Floating Storage Unit (FSU) and changes to the location and mooring system of same. The present document comprises the requested technical statement in relation to the latest (September 2016) proposed changes to the mooring lines/anchors 3 and 4 of the FSU, for which two options are being provided: Option 1 and Option 2.

METHODOLOGY

The following documents provided by Electrogas were considered during compilation of the present statement:

1. Drawing titled ‘Anchor coordinates’. 2. Drawing titled ‘Anchor coordinates Option 2’.

APPRAISAL

Examination of the drawings provided, showing two options of revised layout of moorings/anchors 3 and 4 of the FSU mooring system (see Figures 1 and 2), indicates the following changes between the previous FSU mooring layout (see Gambin, 2016) and the latest (present, September 2016) proposed revised layout: (i) In Option 1, the mooring lines of anchors 3 and 4 are each extended by 25 m to the

southwest, and accordingly the location of each anchor is displaced by 25 m to the southwest.

(ii) In Option 2, the mooring lines of anchors 3 and 4 are each extended by 25 m to the west, and accordingly, the location of each anchor is displaced by 25 m to the west; as a result the locations of the two mooring lines are displaced to the west.

Figures 1 and 2 show an overlay of the latest (present, September 2016) proposed mooring system for the FSU in relation the map of contacts from the marine archaeological studies carried out within the Delimara study area in 2013, as recorded in Gambin’s (2013) survey report.


5 Gambin (2016). Technical statement: Update to the marine archaeology study forming part of the environment impact statement for the proposed CCGT and LNG storage and regasification plant at the Delimara Power Station. Ecoserv Ltd, Malta. Malta: unpublished report, 14pp.

Page 3

Figure 1. Drawing showing the proposed revised mooring Option 1 of the Floating Storage Unit (FSU) in relation to sub‐bottom targets detected in the course of the 2013 surveys (Gambin, 2013). The revised layout comprises extending the mooring for each of anchors 3 and 4, and accordingly the locations of the two anchors by 25 m to the southwest – the extended portion of the mooring and new locations of the latter are shown in red. In the drawing, the FSU shown on the left represents the Unit moored in ‘storm’ mode, while the FSU shown on the right adjacent the jetty represents the Unit moored at other times when not in ‘storm’ mode. Source: Electrogas.

Page 4

Figure 2. Drawing showing the proposed revised mooring Option 2 of the Floating Storage Unit (FSU) in relation to sub‐bottom targets detected in the course of the 2013 surveys (Gambin, 2013). The revised layout comprises extending the mooring for each of anchors 3 and 4, and accordingly the locations of the latter by 25 m to the west – the displaced portion of the mooring and new locations of the two anchors are shown in red. In the drawing, the FSU shown on the left represents the Unit moored in ‘storm’ mode, while the FSU shown on the right adjacent the jetty represents the Unit moored at other times when not in ‘storm’ mode. Source: Electrogas.

Page 5

APPRAISAL

On assessing the two proposed revised layouts (Options 1 and 2) of moorings linking anchors 3 and 4 to the FSU, the undersigned, who carried out the marine archaeological studies for the EIA, has no objection to the most recent (September 2016) mooring/anchor layouts, and no changes are required to the assessment of impacts and conclusions stated in the report submitted in 2013 (see Gambin, 2013). However, it is essential that the following points are noted and adhered to: 1) The proposed locations of the permanent anchors do not coincide with any of the sub‐bottom

targets detected in the course of the 2013 surveys.

2) All monitoring precautions listed in the original report are adhered to. 3) The changes are approved by all competent authorities.

REFERENCE

Gambin, T. (2013) Report on Marine Archaeology for the proposed power station at Marsaxlokk Bay, Malta, August 2013. Ecoserv Ltd, Malta; unpublished report, 59pp.

Dr Timothy Gambin BA MA PhD (Bristol) Independent Consultant for Ecoserv Ltd

13th September 2016

Report Reference Number: 123-15_R Date: 18 March 2016

TECHNICAL STATEMENT

Update to Air Dispersion Modelling studies to assess the impact of the proposed

CCGT and LNG storage and regasification plant at the Delimara Power Station

Client: ElectroGas Malta Ltd. Level 3, Portomaso Business Centre, Portomaso, St. Julians STJ 4011 Malta

PREAMBLE

With reference to the request for information received on 19 May 2015 from Ms Catherine

Halpin on behalf of ElectroGas Ltd (hereafter ‘the client’), and in connection with additional

information on a modified design1 for the proposed project received on 6 March 2015 from Dr

Paul Gauci, EIA Coordinator; Ecoserv Ltd and ESS GmbH have been requested to provide a

response in the form of a technical statement on whether the conclusions of the report on Air

Dispersion Modelling (ESS & Ecoserv, 20132) presented as part of the EIS, would still be

applicable to the modified design.

1 Proposal includes modifications for the design of the CCGT, the jetty, the FSU, and regasification facility together with the additions that need to be made in order to supply the Phase 3 Plant with natural gas. 2 ESS GmbH and Ecoserv Ltd, 2013. Air Dispersion Modelling Study to assess the impact of the proposed CCGT and LNG storage and regasification plant, and their air emission load assessment (NO2/NOx, PM10/PM2.5). Study Report Phase III [Addendum to Study Report I, V3, dated 7 November 2013]. Ecoserv Ltd., Malta. Unpublished report. 17 pp


Mosta, MALTA

Telephone: (+356) 2143 1900 Fax: (+356) 2142 4137


VAT Reg no: 1623-1407

Page 1 of 3

mailto:[email protected]

Following a request for clarification by Ecoserv and ESS, the following instructions were

provided3:

“Please submit the Fedra statement regarding the modifications to the DPS plant, the impact on

air-quality of which was originally discussed in Fedra's reports which formed part of the 2013 EIS,

which statement would focus only on the proposed relocation of the CCGT stacks from the

positions indicated in the 2013 drawings to the ones which are indicated in the AECOM update of

2015. In other words, Fedra needs to establish whether or not, the said changes would have a

material effect on the findings and conclusions submitted in his 2013 submissions (re NOx and

PMs) to the said EIS, which would in turn affect the quality of the EIS as a set of documents

which informs the public and MEPA (or the forthcoming Planning Authority) decision makers.”

The present submission constitutes Ecoserv and ESS’ statement, which only considers the effect

of the proposed modifications on the conclusions of the 2013 report, with considerations only

for NOx and PMs, as per the client’s request.

METHODOLOGY

The following documents4 have been taken into consideration during compilation of the

present statement:

1. AECOM, 2015. ElectroGas Malta Limited — Delimara 4 CCGT and LNG Terminal.

Revisions to development permit – with additional details for the environmental

coordinator. Updates to Development permit September 2014 – Updated Feb 2015 (3

pp).

2. Drawings (12 pp)

3. Visuals (Siemens) (4 pp)

3 E-mail from Dr Paul Gauci, EIA Coordinator, to Ecoserv dated 17-3-2016. 4 Received on 6 March 2015.

Page 2 of 3

APPRAISAL

The above-mentioned changes to the design were assessed against the numerous simulations

carried out in generating the results that have been presented in the report on Air Dispersion

Modelling (ESS & Ecoserv, 2013). Ecoserv and ESS confirm that:

• A stack movement of 15 meters in a basically flat domain will not make any significant

difference to the environmental impacts, and in particular the regulatory compliance, of

the proposed plant described in the EIS Report (ESS & Ecoserv, 2013).

Sarah Debono BSc (Hons), MSc DDr.Kurt Fedra Project Manager Director Ecoserv Ltd Environmental Software &

Services GmbH (ESS)

Page 3 of 3

AIR DISPERSION MODELING STUDY

to assess the impact of the proposed CCGT, FSU

and LNG storage and regasification plant, and their

air emission load assessment (NO2/NOx, PM10/PM2.5)

Prepared for ElectroGas Malta Ltd

by:

DDr Kurt Fedra

and

Environmental Software & Services GmbH

2340 Mödling Am Eichkogel 14

AUSTRIA

Tel: (+43) (0)2236 21665 Mob: (+43) (0)664 2451399

web: www.ess.co.at

Ecoserv Ltd

12, Sir Arthur Borton Street, Mosta, MST 1881

MALTA

Tel: (+356) 2143 1900 Mob: (+356) 7943 1900

web: www.ecoserv.com.mt

ECOSERV’S REPORT REFERENCE: 079-16_R

September 2016

(Second revision of original report dated 25-7-2016)

Report on Air Dispersion Modelling Delimara CCGT, FSU & LNG EIA 2016

ESS GmbH & Ecoserv Ltd 11 September 2016

2

1. EXECUTIVE SUMMARY

This report outlines air dispersion modelling scenarios for the additional emission sources proposed at the Delimara CCGT Power Station, which consist of:

FSU main boiler Phase 1, marine oil fired, “main”

FSU aux boiler Phase 2, gas fired “aux”

FSU service gen-set, marine oil fired, “service”

FSU backup emergency diesel gen-set, marine oil fired, “backup”

Delimara 3 GRS gas boilers 1 and 2

While the additional emission sources (FSU based boilers, service generator, backup and GRS boilers) are relatively small, and the sources are only active intermittently, the low/very low (and horizontal) stack configurations (in particular “Service diesel gen-set, marine oil fired, 120 hrs/year, 18 m stack, horizontal release”) may, depending on weather conditions (in case of low wind, low PBL or mixing height) cause relatively high NOx/NO2 levels (well above the hourly NO2 limit of 200 μg/m3). High values are found in the immediate vicinity of the FSU due to the stack geometry and horizontal release), but also possibly extend to two of the sensitive receptor locations (Marsaxlokk, Birzebbuga). Please note that these results are obtained without the complex terrain correction (AERMAP, used in the previous study with a different model release), which apparently generates an error (model artefact) of concentrations increased by an order of magnitude along the coastline, with elevations rising from zero more or less steeply (a known model artefact). This would again increase the probability of limit violations. However, AERMOD is very sensitive to combinations of low wind speed and low PBL (mixing height).

The hourly limit value can be exceeded up to 18 times a year (for NO2) according to Directive 2008/50/EC, which a continuous operation of these sources can easily exceed, even when excluding the immediate vicinity (a radius of 279 m of restricted access) of the FSU. Correcting for the intermittent operations of course reduces the probability of exceeding the regulatory limit considerably (almost two orders of magnitude), but the argument is “probabilistic”. Modifying the orientation of the FSU based stacks (at least for the service gen-set 18m stack) to vertical (which then uses the flue gas exit velocity for an increased “virtual stack” height would solve the (possible) problem, as some sensitivity analysis indicates.

An alternative would be some adaptive scheduling that tries to avoid or limit operations of these sources during unfavourable weather conditions (low wind, low PBL or mixing height) based on short term (5-7 days) forecasting. However, the operation of the service gen-set (according to AECOM) is limited to high wind,



3

“storm” situations which would certainly rule out the possibility for hourly NO2 violations at the sensitive receptor locations.

The main conclusions of the assessment of the above-mentioned FSU based boiler, generators, and the GRS emission points are:

1. Exceedances of hourly NO2 values around the FSU but also at sensitive receptor locations are possible in principle but “very unlikely”, depending on the coincidence of extreme weather (low wind and PBL/mixing height), operations scheduling and limited hours of operations, and in principle easily avoidable by increased release height (physical and/or virtual stack) for the FSU service gen-set. Use of the service gen-set only during high wind situations would rule out the possibility of violations at the sensitive receptor locations.

2. There are no relevant impacts from any of the sources considered when gas fired.

3. There are no relevant impacts from stacks of 44m (or higher) at the sensitive receptor locations.

4. There are no violations of the hourly NO2 standard predicted for wind speeds higher than 2.5 m/s.

5. There is no relevant issue related to annual average concentration limits.

6. There is no relevant issue related to the daily PM10 limit values.

7. In combination with all other sources (Delimara Power Station and background), the new additional sources (FSU based boilers and generator, GRS boiler) do not affect the overall impacts and compliance beyond the hourly NO2 values during their limited hours of operation (point 1 above).

Please note that all numerical data and scenario results can be accessed at:

http://www.ess.co.at/AIRWARE/MALTA (access controlled).



4

Contents 1. EXECUTIVE SUMMARY ..................................................................................... 2

Contents ..................................................................................................................... 4

2. PREAMBLE ......................................................................................................... 5

3. ABBREVIATIONS and ACRONYMS USED ........................................................ 7

4. METHODOLOGY ................................................................................................ 8

5. EMISSIONS: FSU BOILERS AND GENERATORS, D3 GRS ............................. 9

6. SCENARIO ANALYSIS ..................................................................................... 11

6.1 FSU main boiler (Phase 1) ............................................................................. 11

6.2 FSU aux boilers (Phase 2) .............................................................................. 11

6.3 FSU service diesel .......................................................................................... 11

6.4 FSU backup/emergency diesel generator ....................................................... 16

6.5 Delimara 3 GRS boilers .................................................................................. 18

6.6 All DPS, FSU, with background ...................................................................... 18

7. SENSITIVITY ANALYSIS .................................................................................. 20

7.1 Meteorological effects ..................................................................................... 21

REFERENCES ......................................................................................................... 24

APPENDIX I ............................................................................................................. 25



5

2. PREAMBLE Environmental Software & Services GmbH (hereafter ‘ESS’) and Ecoserv Ltd have undertaken studies in 2013 (see Fedra 2013a; 2013b; 2013c) to model the air dispersion of pollutants (NOx and Particulate Matter) and to assess the impacts as part of an Environmental Impact Statement (EIS) concerning the proposed construction of a Combined Cycle Gas Turbine (CCGT) and facilities for receiving, storing and re-gasification of Liquefied Natural Gas (LNG). In June 2016, Ecoserv and ESS were commissioned by ElectroGas Malta Ltd to undertake a review of new information related to the CCGT project, in particular on updates of the design and new emission points from a Floating Storage Unit (FSU) system, and to advise whether this updated information required updates on the outcome of the previous studies (Fedra 2013a; 2013b; 2013c). Terms of reference that were considered for the current review and assessment were: E-mail dated 14-6-2016 from Dr Paul Gauci of ERSLI Ltd to Ecoserv:

“We need to submit updated statements regarding the following: 1. Air quality focusing only on NOx and PMs. ERA have also requested a statement

regarding the generators on the FSU which will need to be turned on on a regular basis in order to ensure functionality when actually needed”

Following clarification, e-mail dated 11-7-2016 from Dr Paul Gauci of ERSLI Ltd to Ecoserv, included additional instructions:

“Can you please submit a quotation and method statement for…the minimalist assessment as per your email for the revised air dispersion modelling to which the following new emission sources are added: 2. Delimara 3 (ex-BWSC) GRS boilers (please note that the emissions for Delimara

3 should be assumed to be the same as submitted in the original EIS) 3. FSU aux boilers (two in operation with horizontal exhaust) 4. FSU service engine (horizontal exhaust) The emissions values are included in the attached file. The NVCC permanent flare pilots are disregarded given the small size. The modeller should note the following regarding the stacks in the FSU. FSU common funnel stack for the aux boilers is horizontal pointing to the True North of the plant as shown in the attached image003.jpg. FSU service CAT diesel gen-set stack is horizontal pointing also to the True North as shown in the attached image003.jpg.”

More recent communication dated 15-7-2016 from Mr Gonzalo Lopez of ElectroGas Malta to Ecoserv specified as follows:

“The new emission sources are attached and correspond to the following cases which we would like to see in the report:



6

1. Mobilized FSU with the FSU main boiler emission source. This operating mode could occur for very limited time during early phases of the commercial operation and no more than 12 months.

2. Cold iron FSU with the new auxiliary boiler as active emission source instead of the FSU main boiler. This operating mode shall prevail during the operative lifetime.

If Case 1 dispersion is adequate and within concentration limits, case 2 would not need to be run as case 1 stand to be a more severe case for both NOx and PM emissions.

Find also attached plan layout of the site and elevation layout of the FSU vessel which will help the modeller to run the model. The modeller should note the followings: 1. The FSU service engine and main boiler horizontal stacks points at the true north

of Delimara site. 2. The new emission sources shall be active for very limited time as per table

below:

Delimara3 GRS gas boiler No. 1 1752hr/yr when D3PP in operation

Delimara3 GRS gas boilers No. 2 1752hr/yr when D3PP in operation

FSU main boiler (phase1) (marine oil fired)

Up to 530hr/yr during first 12 months

FSU aux boiler (phase2) (gas fired) (2x100%)

~530hr/yr

FSU Service diesel gen-set (marine oil fired)

~120hr/yr

In addition to details above, a table with the details of all emission points (physical details and emission information) updated as at 18 July 2016, was also provided. For reference, this table is included in Appendix I of this report.



7

3. ABBREVIATIONS and ACRONYMS USED AERMOD USEPA Gaussian regulatory model, see: USEPA, 2016;

AERMAP AERMOD terrain pre-processor

EEA European Environmental Agency

FSU Floating Storage Unit

GDAS Global Data Assimilation System

GRS Gas Receiving Station

mmif mesoscale model interface,

MW MegaWatt (SI unit); also used for Molecular Weight by EMEA.

NCEP National Centers for Environmental Predictions

NCEP/FNL Final Operational Global Analysis Data

NFR Nomenclature for Reporting, emission source classification

USEPA US Environmental Protection Agency



8

4. METHODOLOGY This report addresses the new, additional emission sources above and beyond the set covered in the Study Reports “Air Dispersion Modelling Study” prepared for Enemalta Corporation, Fedra, K. (2013 a; 2013b; 2013c) The study uses the same model system (AirWare) but with the latest version of the USEPA regulatory model AERMOD (Release 15181), and an extended meteorological data base (2008 – 2015) based on dynamic downscaling of ENCEP/FNL reanalysis data to hourly resolution. These NCEP FNL (Final) Operational Global Analysis data are on 1-degree by 1-degree grids prepared operationally every six hours. This product is from the Global Data Assimilation System (GDAS), which continuously collects observational data from the Global Telecommunications System (GTS), and other sources, for many analyses. The FNLs are made with the same model which NCEP uses in the Global Forecast System (GFS), but the FNLs are prepared about an hour or so after the GFS is initialized. The FNLs are delayed so that more observational data can be used. The GFS is run earlier in support of time critical forecast needs, and uses the FNL from the previous 6 hour cycle as part of its initialization. The analyses are available on the surface, at 26 mandatory (and other pressure) levels from 1000 millibars to 10 millibars, in the surface boundary layer and at some sigma layers, the tropopause and a few others. Parameters include surface pressure, sea level pressure, geopotential height, temperature, sea surface temperature, soil values, ice cover, relative humidity, u- and v- winds, vertical motion, vorticity and ozone. The archive time series is continuously extended to a near-current date. For better comparability with monitoring data, the AERMOD meteorological input data have been processed (mmif) for the location of the Zejtun montoring station. Model domains of 3,5,and 20 km were used with a 50 m receptor grid spacing and an additional set of “sensitive receptor” locations, as used in the previous reports. AERMOD was originally used with the AERMAP terrain corrections. When this was found to generate extreme values (at the coastline or any “cliff” configuration, the model was run with and without the terrain correction, see also: Carruthers et al, (2011), which reports increases in average annual concentrations with AERMAP terrain correction by a factor of up to 18 compared with running the model without terrain correction. All values reported here are based on the runs without AERMAP. A second technical issue is the horizontal orientation of the FSU stacks; AERMOD assumes vertical stacks and calculates plume rise (a virtual stack height) based on physical stack height, flue gas temperature and flue gas exit velocity. To represent this configuration, we retained the flue gas temperature (and associated buoyancy), but set the mechanical component (exit velocity) to 0; a set of sensitivity runs was performed to analyse the dependency of the concentrations calculated on assumptions about the vertical (mechanical) plume rise component, prediction plume impaction into any “hillside” (here: coastal elevation increases).



9

5. EMISSIONS: FSU BOILERS AND GENERATORS, D3 GRS

Stack parameters and emissions The emission inventories provided includes:

FSU main boiler (Phase 1), oil fired, 44 m stack, horizontal Flue gas temperature: 167/200 degC, exit velocity: no value given NOx emission are given with 2.34 g/s; Up to 539 hours/year (or one, first year only)

FSU aux boiler (Phase 2), gas fired, 44m stack, horizontal Flue gas temperature: 330 degC, exit velocity: 8 m/s NOx emission are given with 0.5/1.0 g/s; apparently referring to one and both units respectively, see below. Average load over the year is given with 6% or 530 hours/year.

FSU Service Diesel, marine oil fired, 18 m stack, horizontal, Flue gas temperature: 465 degC, exit velocity: 30 m/s NOx emission are given with 3.96 g/s; as a “worst case” upper limit, an emission value (+50%) of 6 g/s was tested due to the high potential impact of the low and horizontal stack. This source is expected to operate for about 120 hrs/year, so the analysis of compliance against hourly standard will be “probabilistic”. FSU backup/emergency, marine oil fired, 44m stack (assumed horizontal), exhaust temperature: 480 degC, velocity: assumed the same as for the service diesel at 30m/s. NOx emission are given with 6.74 g/s; No expected hours of operation given, but can be assumed to be reasonably small.

Delimara 3 GRS boilers Stack parameters and emissions:

Gas boilers1 and 2 , 2*210kW, 10m stack (presumed vertical) Flue gas temperature: 200, velocity: 12 m/s, 0.02 g/s NOx emissions

Power rating is given as 420 kW. Average load at 20% or 1,752 hours/year, one boiler operating at a time.



10

Emission inventory summary Emission source fuel Stack, m T m/s NOx g/s

FSU main (phase 1) oil 44 330 50 2.3 FSU aux (phase 2) gas 44 200 8 0.5 FSU Service diesel generator oil 18 465 30 4.0 FSU backup/emergency oil 44 480 22 6.7 Delimara 3 GRS boilers gas 10 200 12 0.02 Due to the combination of emission rates and low horizontal stack, the FSU Service diesel gen-set has the highest potential impact on ambient ground level concentrations for low wind/low PBL combinations.



11

6. SCENARIO ANALYSIS Abbreviations used in the summary tables:

NOx: NOx emissions, g/s Vfg: vertical flue gas velocity component, m/s AA: annual average μg/m3 Amax: annual maximum Hmax: hourly maximum Nex: number of hourly exceedance (total in the domain) Rex: maximum number of hourly exceedances at a receptor location

6.1 FSU main boiler (Phase 1) Oil fired, 44 m stack, horizontal orientation, flue gas temperature: 167/200 degC, exit velocity: no value given (please note the flue gas velocity is not considered for the vertical plume rise component. NOx emission are given with 2.34 g/s; Up to 539 hours/year, or 6.2% of the time.

scenario year NOx Vfg AA Amax Hmax Nex

FSU main/min 2015 2.3 0 0.13 2.3 264 11 Note: all concentration are given in μg/m3. No exceedances at the receptor locations.

6.2 FSU aux boilers (Phase 2) gas fired, 44m stack, horizontal orientation Flue gas temperature: 330 degC, exit velocity: 8 m/s NOx emission are given with 0.5/1.0 g/s; referring to one and both units respectively, see below. In Phase 2, the main power supply of the FSU is expected to be land based or “cold ironed”. The operation of the boilers is expected at a low average load of 9 MW, corresponding to an EEA/FNR emission estimate of 0.8 g/s. Average load over the year is given with 6% or 530 hours/year, boils are operated alternatively.


FSU aux/min 2015 0.5 0 0.03 0.53 35 0 The simulation clearly confirm what was to be expected, i.e. no relevant impacts from the aux boiler under “cold ironed” conditions even without any further corrections based on the limited operational scope of 530 hours (6 %).

6.3 FSU service diesel Marine oil fired, NOx emissions: 4.0 g/s,18 m stack, horizontal release (no vertical exhaust momentum assumed); 5 km model domain, 50 m receptor grid spacing.



12

Please note that the 18 m stack height is below the 22 m minimum PBL (Planetary boundary Layer, mixing height) value used by the model.


FSU service/min 2015 4.0 0 1.73 22.6 1,638 >30 Sensitive Receptor locations, 2015 (hourly limit value: 200 μg/m3) Receptor Location AA Hmax Nex Birzebugia 0.9 293.6 8 Ghar Dalam Cave and Museum 0.4 225.0 3 Marsaxlokk 1 1.2 300.8 10 Marsaxlokk 2 1.7 412.0 14 Zejtun 0.8 255.0 3 Zejtun monitoring station 0.7 198.2 0 Compliance: the value of 1.7 μg/m3 exceeds the 3% (of annual average limit value) incremental contribution limit, but completely disappears when corrected for the short-term operation (up to 120 hours/year). Hourly exceedances are all below the allowed maximum number of 18 (50/2008/EC), annual average in the domain is well below the 40 μg/m3 limit value. Please note that all exceedances are occurring during low wind situations with wind speeds below or just above 1m/s. The meteorological data for 2015 include 274 (out of 8760, or 3.1 %) low wind events and at minimum PBL (with two notable exceptions of 468 and 105 m PBL estimates). The average number of hourly violations per year at the most often affected sensitive receptor points (Marsaxlokk 2 or Birzebbuga) over 8 years (70,080 hours) amounts to 13.7 (for continuous operation, and still in compliance on average). At 120 hours of operations or 1.4%, the expected value for exceedances of the hourly limit value at receptor location is 0.2 or 0.4 (using the “max” emission estimate) (or 1/36 or 1/18 of the allowed number according to Directive 2008/50/EC. Please note that this is an average estimate, and does not guarantee less than 18 exceedances in any one year, even if the margin is very large, even when considering an inter-annual variability of 50% – 200% around the mean. To guarantee compliance, the simplest approach would be to raise the (virtual) stack: physically or by vertical (or at least upwards inclined) orientation (see the sensitivity analysis examples below). However, these simple calculations assume that low wind speeds and low PBL are randomly distributed, which is not the case. Both parameters show a well defined autocorrelation in time, i.e., they tend to occur as periods of several hours, clustered, as illustrated below. If, however, the service diesel gen-set as communicated by AECOM) is only operated during storm (high wind) situations, there is no relevant or even measurable impact at the receptor location expected.



13

Low wind events (hourly that show obvious temporal autocorrelation. Annual overview (2008-2015)

scenario year NOx AA Amx Hmax Rex FSU service/min 2015 2.3 1.73 22.6 1,638 14 FSU service/min 2014 2.3 1.70 18.8 1,720 16 FSU service/min 2013 2.3 1.75 20.3 1,932 14 FSU service/min 2012 2.3 1.63 19.5 1,955 9 FSU service/min 2011 2.3 1.68 19.6 1,885 18 FSU service/min 2010 2.3 1.61 15.8 1,851 12 FSU service/min 2009 2.3 1.44 25.3 1,711 9 FSU service/min 2008 2.3 1.89 25.3 1,586 18

As an example, while the 30 highest values for 2009 are observed at 29 distinct dates, but they are concentrated in only 14 distinct locations, around the source.



14

FSU Service generator, 2015 (4g/s NOx emissions), max. number of hourly violations at a receptor location: 14 (Marsaxlokk2)

Service generator, 2015, 6.2 g/s NOx emissions, maximum number of hourly violations at a receptor location: 40 (Marsaxlokk2)



15

Location of hourly maxima immediately around the source under low wind and PBL conditions

The corresponding PM10 values (daily average, limit value: 50 μg/m3) are well below the limit value, with the maximum daily average concentration at 24 μg/m3 And thus below half the limit value.



16

6.4 FSU backup/emergency diesel generator marine oil fired, 44m stack (assumed horizontal), exhaust temperature: 480 degC, velocity: assumed the same as for the service diesel at 30m/s. No expected hours of operation given, but they can be assumed to be reasonably small, which excludes any but extremely short-term impacts


FSU backup generator 2015 6.7 0 0.27 6.28 528 >30 Hourly values above 200μ/m3 are only found in close proximity around the source. Average values (generated with the unrealistic assumption of continuous operation for better comparison) and values at the sensitive receptor location are all well in compliance. The emergency/backup generator has emission values comparable to the FSU service diesel, but shows markedly lower values and no exceedance at any of the sensitive receptor sites. The main and dominating difference is the stack geometry, with 44 versus 18 meters, together with the (uncontrollable, at best predictable) meteorological parameters of wind speed and PBL/mixing height. The meteorological re-analysis data for 2015 shows 274 hours of wind speed below 1m/s of which 66 hours were below 0.5m/s, versus a total of 77 hours when exceedances were simulated.

Wind speed 2015, re-analysis data for the location: Zejtun monitoring



17

Meteo data set for the AERMOD scenarios 2015

Filter for low wind events



18

6.5 Delimara 3 GRS boilers Gas boilers1 and 2 , 2*210kW, 10m stack (presumed vertical) Flue gas temperature: 200, velocity: 12 m/s, 0.02 g/s NOx emissions Power rating is given as 420 kW Average load is given at 20% or 1,752 hours/year, only one oiler operating at a time.

scenario year NOx AA Amax Hmax Nex

D3 GRS 2015 0.02 0.004 0.23 29 0 Despite the very low stack, and due to the very low emissions, no relevant concentrations are to be expected from this source, even when ignoring the limited operation times.

6.6 All DPS, FSU, with background This scenario adds the relevant new sources (service boiler in Phase 1) and the new gas boilers (GRS) to the complete background scenario from the previous report (Fedra 2013a) to analyse the impact of the additional sources on the overall local air quality, and in particular the sensitive receptor locations. The baseline scenario corresponds to the 209 sources, baseline emission with background with the 2015 configuration of the DPS, other small sources, and traffic (roads, airport, harbours) as background emission from other point sources and traffic. Two cases based on 2015 meteorology (for a more direct comparison) and the 20 km domain (including all receptor points) were tried to evaluate possible short-term exceedances during the limited hours of operations: Scenarios considered:

1. Baseline (from the 2013 reports) 2. Baseline plus “FSU main”, (in operation: 539 hours) 3. Baseline plus “FSU main” and “FSU service” (in operation 120 hours)

assuming (worst case) that main and service boilers are operated together. Baseline refers to the scenarios for DPS 3 (converted), 4, background, with 2013 traffic data) but using 2015 meteorology for direct comparison

scenario year NOx AA Amax Hmax Ex% Mar Bir

Baseline 2015 155 8.27 58.7 875 0.075 7 7 Baseline + “FSU main” 2015 160 8.38 58.8 875 0.072 7 7 Baseline + “FSUmain, service” 2015 166 8.84 59.2 1,888 0.072 40 36

Ex%: percentage of hourly exceedances (anywhere, anytime during the year) Mar: number of exceedances at Marsaxlokk Bir: number of exceedances at Birzebbuga



19

FSU and in particular the service boiler (120 hours of operations) do affect the number (or probability) of exceeding the hourly limit value at the two sensitive receptor locations most affected. However, the very short time of operations makes this unlikely (above the 18 hours allowed under Directive 2008/50/EC), but the possibility of exceedances under low wind/low PBL conditions cannot be excluded completely, suggesting raising the stack height or putting in place some adaptive operating schedule that considers the weather (forecast). The effectiveness of these options are explored below.



20

7. SENSITIVITY ANALYSIS To explore the relationship between stack height (physical and virtual) and the ambient concentrations over the domain and the sensitive receptor locations, two sets of simulation were made, based on the FSU service boiler scenario and 2015 meteorology. Two parameters were systematically varied :

Physical stack height (remaining the horizontal orientation) Stack orientation, approximated by the vertical component of the flue gas exit

velocity varied from 0 (horizontal) to 100% (vertical) configuration. NOx emission increased by 50% (worst case “safety marin”).

Physical stack height (horizontal orientation) scenario year NOx St m AA Amx Hmax Rex FSU service/max 2015 6.0 18 2.80 36.8 2,647 40 FSU service/max 2015 6.0 20 2.11 29.5 2,018 18 FSU service/max 2015 6.0 22.5 1.46 22.8 2,380 8 FSU service/max 2015 6.0 25 1.10 17.7 1,517 3 FSU service/max 2015 6.0 30 0.69 13.3 1,058 3 FSU service/max 2015 6.0 35 0.44 10.1 903 0 FSU service/max 2015 6.0 40 0.33 7.65 688 0 FSU service/max 2015 6.0 45 0.27 6.09 474 0 FSU service/max 2015 6.0 50 0.25 5.12 426 0 Note: Stm: physical stack height in meters

Virtual stack (vertical flue gas momentum in m/s for 18m stack) scenario year NOx m/s AA Amx Hmax Nex Rex FSU service/max 2015 6.0 0 2.80 36.6 2,647 368,380 40 FSU service/max 2015 6.0 0.1 2.29 29.8 1,624 268,271 25 FSU service/max 2015 6.0 0.5 1.60 22.2 1,044 97,781 13 FSU service/max 2015 6.0 1.0 1.29 18.0 896 42,453 4 FSU service/max 2015 6.0 3.0 0.88 13.0 671 4,271 0 FSU service/max 2015 6.0 8.0 0.57 8.85 366 181 0 FSU service/max 2015 6.0 15.0 0.42 6.6 310 12 0 FSU service/max 2015 6.0 20.0 0.37 5.7 262 12 0 FSU service/max 2015 6.0 25.0 0.33 5.07 232 1 0 FSU service/max 2015 6.0 30.0 0.31 4.57 192 0 0 Note: m/s effective flue gas velocity (vertical) depending on stack orientation; 0 m/s = horizontal; 15 m/s = 45°. 30 m/s = vertical stack orientation Nex: any exceedance, anywhere, anytime; i.e., N incidences out of a possible 87,600,000 ! E.g., 42,453 exceedances (at 1 m/s) amount to less than 0.05% of all possible exceedances. Rex: hourly excedances at receptor location most affected (Marsaxlokk or Birzebbuga)



21

Combined scenario: 44 m stack (assumed), with standard vertical orientation.

scenario year NOx m/s stack AA Amx Hmax Nex Rex FSU service/max 2015 6.0 30 44 0.17 1.71 88 0 0 Please note that these relationships are non-linear due to the step-function dependency on mixing height; also the different stack orientation results are NOT to be interpreted as “engineering precision”, they are only documenting the principle that raised emission level/virtual stack are critical parameters for dispersion and thus ambient concentrations.

7.1 Meteorological effects While the list of the highest hourly concentration always shows low wind values, there is no significant correlation between wind speed and emission concentration values in general. However, weather and its inter-annual variability does play a significant role: for the ambient concentrations and in particular compliance, – a non-linear step function. To illustrate this, consider a comparison of the “all sources and background” scenarios with meteorology from 2008 and 2012: While 2012 shows not a single exceedance at the receptor locations, the 2008 meteorology yields 569 simulated exceedances at 13 receptors (that is a total of 0.5 %). Please note that regulatory cut-off is defined with 0.21 % (18 out of 8760).

Simulated wind speed versus NOx concentrations, 2015, Zejtun monitoring station



22

While a general pattern of decreasing concentrations with increasing windspeed can be observed, for higher concentrations, the dominant subset of low concentration events (driven by wind direction) precludes any significant statistical relation, which simply indicates that any or even simplified monocausal explanation attempts must fail. The effect is asymmetric: while all instances of extreme concentration coincide with low wind, not all low wind situations lead to high concentrations. While this true for the entire domain around the source, the patterns at any specific location such as the sensitive receptor location is even more complex due to the variable wind direction and thus the main direction of transport from the source.

Relationship of wind speed and PBL (mechanical), 2015, hourly re-analysis data Similar to the windspeed versus concentration example above, there is no significant statistical relation, in particular for the determining low range of PBL values. AERMOD, in principle, offers an optional yet “arbitrary” mechanism to address possible model artefacts under extreme low wind conditions. Also please note that the Gaussian model represents “steady state” conditions, that means that the plumes are expected to extend ad infinitum even when the hourly aggregation period together with the wind speed does not make it possible to reach and impact more remote location: at 0.5 m/s, the most distance location to be reached by a plume during the hours would be less than 2 km from the source.



23

At the same time, the model does not consider “initial conditions”, i.e., the results from the previous hour. To include these effects with the necessary physical detail and spatial and temporal resolution, a more detailed dynamic model Lagrangian, Eulerian, or CFD based, would be required; but this would be constrained to the same “probabilistic” interpretation due to the unknown combination of future weather and operating schedules.

Windrose, and wind speed classes by direction, 2015 hourly re-analysis data

Windrose, and wind speed classes by direction, 2008-2015 hourly re-analysis data



24

REFERENCES

Carruthers DJ, Seaton MD, McHugh CA, Sheng X, Solazzo E, Vanvyve E. (20110 Comparison of the complex terrain algorithms incorporated into two commonly used local-scale air pollution dispersion models (ADMS and AERMOD) using a hybrid model. J Air Waste Management Assoc. 2011 Nov;61(11):1227-35. Fedra, K. (2013a) AIR DISPERSION MODELING STUDY to assess the impact of the proposed CCGT and LNG storage and regasification plant, and their air emission load assessment (NO2/NOx, PM10/PM2.5) Final Study Report V2, Environmental Software and Services GmbH and Ecoserv Ltd, 96pp, Revised version October 2013.

Fedra K. (2013b) AIR DISPERSION MODELING STUDY to assess the impact of the proposed CCGT and LNG storage and regasification plant, and their air emission load assessment (NO2/NOx, PM10/PM2.5) Study Report Phase II, Part 1 [Addendum to Study Report I, V2], Environmental Software and Services GmbH and Ecoserv Ltd, 20 pp, October 2013; Fedra, K (2013c) AIR DISPERSION MODELING STUDY to assess the impact of the proposed CCGT and LNG storage and regasification plant, and their air emission load assessment (NO2/NOx, PM10/PM2.5) Study Report Phase III [Addendum to Study Report I, V2], Environmental Software and Services GmbH and Ecoserv Ltd, 16 pp, November 2013;

USEPA (2016) Preferred/Recommended Models: AERMOD Modelling System. https://www3.epa.gov/scram001/dispersion_prefrec.htm (accessed 20160714)



25

APPENDIX I

Emission Inventory table as provided by ElectroGas Malta Ltd

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ort o

n A

ir D

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elim

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, FS

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016

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& E

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td

18 A

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t 201

6

26

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on

s In

ven

tory

: E

lect

roG

as M

alta

LN

G t

erm

inal

an

d C

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T p

ow

er p

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t (A

EC

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, 18

July

20

16)

Tem

pla

te B

y :

AE

CO

M P

repa

red

by:

GL

Che

cked

by:

RW

. Dat

e: 1

8/07

/201

6

Sou

rce

Nam

e

Flu

e ga

s flo

w r

ate

(kg/

sec)

MW

N

Ox

Em

issi

ons*

(m

g/N

m3)

NO

x E

mis

sion

s (g

/sec

)

NO

x E

mis

sion

s (t

n/yr

)

SO

2 E

mis

sion

s*

(mg/

Nm

3)

S

O2

Em

issi

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(g/s

ec)

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2 E

mis

sion

s (t

n/yr

)

CO

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mis

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s*

CO

E

mis

sion

s (g

/sec

)

CO

E

mis

sion

s (t

n/yr

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PM

10

Em

issi

ons*

(m

g/N

m3)

PM

10

Em

issi

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(g/s

ec)

P

M10

E

mis

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s (t

n/yr

)

Gas

Tur

bine

Gen

erat

or N

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13

2.6

30

3.57

10

3.56

1.

77

0.19

0 5.

51

100

11.9

0 34

5.19

N

il N

il N

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Gen

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or N

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3.56

1.

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100

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imar

a3 G

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boi

ler

No.

1

0.15

27

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19

0

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0.00

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2

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Nil

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0.30

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.

‡ E

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120

hr/y

r. E

mis

sion

s [N

ox]~

1100

mg/

Nm

3, [S

ox]<

350m

g/N

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[Dus

t]<20

mg/

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3 ex

pres

sed

at 1

5%O

2 db

† O

nly

one

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r w

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e in

ope

ratio

n a

t low

load

of 9

MW

th

Rep

ort o

n A

ir D

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odel

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elim

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U &

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6

27

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6)

Tem

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. Dat

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8/07

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(g/s

ec)

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mis

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n/yr

)

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2 E

mis

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/sec

)

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s (t

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)

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(M

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)

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R

Sulphur Dioxide (SO2)Emissions Modelling for

the New LNG Plant atDelimara Power Station,

MaltaPhase 1

P1521

A Report Prepared forADI Associates

byADM Ltd

Old Chambers93-94 West Street

FarnhamSurrey

GU9 7EB, UKTel: +44 (0) 1252 720842

Email: [email protected]: www.AboutAir.com

Principal Author: David Harvey BSc MBA FIAQMClient: ADI Associates

Version/File Issue DateFile=P1521\text\Delimara_AQ_v2.doc 21 April 2016File=P1521\text\Delimara_AQ_v3.doc 26 April 2016File=P1521\text\Delimara_Phase_1_AQ_v5.doc 16 September 2016File=P1521\text\Delimara_Phase_1_AQ_v6.doc 21September 2016

1 INTRODUCTION 1

2 REGULATIONS 2

2.1 INTRODUCTION 22.2 REGULATION 3(3) 2

3 METHODOLOGY 3

3.1 INTRODUCTION 33.2 EMISSIONS DATA 33.3 FACTORS AFFECTING DISPERSION 43.3.1 Physical Characteristics of the Emissions 43.3.2 Climate 53.3.3 Nature of the Surface 63.3.4 Selection of Suitable Dispersion Model 73.3.5 Meteorological Data 83.3.6 Modelling Assumptions 10

4 ASSESSMENT OF IMPACTS 11

4.1 INTRODUCTION 114.2 COMBINED CYCLE GAS TURBINE (CCGT) OPERATION 114.3 OPEN CYCLE GAS TURBINE (OCGT) OPERATION 14

5 DISCUSSION AND CONCLUSIONS 17

5.1 INTRODUCTION 175.2 REGULATION 3(3) 175.3 COMBINED AND OPEN CYCLE GAS TURBINE (CCGT/OCGT) OPERATION 175.4 SUMMARY AND CONCLUSIONS 17

ADM LTD DELIMARA - PHASE 1 AQ1

1 INTRODUCTION

Atmospheric Dispersion Modelling (ADM) Ltd has been commissioned by AdiAssociates Environmental Consultants Ltd to undertake dispersion modellingof emissions to atmosphere from the new Liquefied Natural Gas (LNG) powerstation at Delimara, Malta.

An air quality assessment for the proposed power station was completed inAugust 2013 and included full assessment of emissions of oxides of nitrogen(NOx/NO2) and particulate matter (PM10 and PM2.5) ( 1 ). The report statedemissions of sulphur dioxide (SO2) would be negligible and therefore was notincluded in the assessment.

It has subsequently transpired that LNG sulphur (S) fuel content could be upto 30 mg Nm-3 (273 k, 101.3 kPa) and therefore should be considered.

This study updates the previous work and includes modelling for sulphurdioxide (SO2) at the guaranteed maximum fuel sulphur content.

Predictions are made for routine emissions from the gas turbines operating incombined cycle mode (CCGT) and for emissions from the gas turbinesoperating in open cycle mode (OCGT). OCGT operating will occur for the firstsix months.

The sources of emissions to atmosphere modelled in this assessment are:

Three 75 m high single flue CCGT stacks Three 30 m high single flue OCGT stacks

As with all types of modelling there is a degree of uncertainty in thepredictions which is due to a number of factors including the accuracy of inputdata, reliability of meteorological data, the algorithms used to generate thepredictions and the assumptions made. It is not possible to determine theoverall accuracy of any particular predicted concentration as this will vary andwill be related to the statistic predicted (eg long or short term concentrations)and nature of the emissions (eg whether effected by building downwash orterrain).

(1) ERSLI (December 2013) Delimara Gas and Power Combined Cycle Gas Turbine and Liquefied Natural Gas receiving,storage , and re-gasification facilities. Delimara Power Station.


2 REGULATIONS

2.1 INTRODUCTION

The section described the targets used for the determination of sulphurdioxide (SO2) emission limits for combined cycle gas turbine (CCGT) andopen cycle gas turbine (OCGT) operation.

2.2 REGULATION 3(3)

Regulation 3(3) of the Industrial Emissions (Large Combustion Plants)Regulations (LN 11 of 2013) state that:

For combustion plants permitted after 07 January 2013, the minimum stack heightwhich shall be established during the initial permitting process, shall be such that thecontribution from these combustion plants does not exceed 3% of the limit values inAnnex 7 of the Ambient Air Quality Regulations, for the pollutants specified therein.

Schedule 7 (part AII) of the Ambient Air Quality Regulations (LN 478 of 2010as amended) define the following limit values for SO2 in ambient air:

One day:125 μg/m3, not to be exceeded more than 3 times a calendar year One hour:350 μg/m3, not to be exceeded more than 24 times a calendar year

It is considered that the intention of the Regulation 3(3) was that the 3%percentage was to apply to only annual average concentrations. This wasassumed to be the case for the previous study that considered the impacts ofnitrogen dioxide (NO2) which compared the annual average concentration withthe 3% of the annual average limit value but not compared the hourly averageconcentrations with 3% of the hourly average limit value.

It is considered that an appropriate limit value for short term impacts (ie 1 hourand 24 hour averaging periods) is 10 times the long term limit value which inthis case would be 30% of the short term Ambient Air Quality Regulations.The factor of 10 between long and short term impacts is used by the UKEnvironment Agency (EA) in their risk assessment guidance (1).

However, for the purpose of this study and as instructed by the former MaltaEnvironment & Planning Authority (now the Planning Authority and theEnvironment & Resources Authority), the 3% of the limit value will be appliedto the daily average ambient limit value of 125 µg m-3 not to be exceededmore than 3 times per calendar year.

The target for emissions of sulphur dioxide (SO2) that gives rise to anacceptable impact is therefore 3.75 µg m-3 as a daily average not to beexceeded more than 3 times per year which is equivalent to a 3.75 µg m-3 as99.17th percentile of daily averages.

(1) https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit.


3 METHODOLOGY

3.1 INTRODUCTION

This section describes the methodology and assumptions made for themodelling. Also described are the emissions data used.

3.2 EMISSIONS DATA

Table 3.1 shows the parameters which will describe physical properties ofemissions to atmosphere from the stacks, as required for definition of theemissions in dispersion modelling terms.

Table 3.1 Stack Emissions and Physical Properties

Parameters CCGT OCGT

Number of stacks 3 3Stack Reference A1, B1, C1 A0, B0, C0Number of flues per stack 1 1

UTM Grid Reference (Sector 33 S, WGS 84datum, used in modelling)

A1 459683 3965627 A0 459671 3965607

B1 459669 3965617 B0 459685 3965616

C1 459655 3965606 C0 459699 3965626

UTM Grid Reference (Sector 33 S, ED 50datum)

A1 459765 3965809 A0 459754 3965823

B1 459751 3965799 B0 459740 3965813

C1 459737 3965789 C0 459726 3965803

Stack height (metres) 75 30Flue gas mass flow rate (kg s-1) 132.6 127.7Flue gas emission temperature (deg C) 95.3 564Percentage water (% v/v) 8.34 8.34Percentage oxygen in wet gas (% v/v) 12.98 12.98Exit velocity (m s-1) 21.4 33.1Internal flue exit diameter (metres) 2.90 3.45Actual volumetric flow rate per flue (Am3 s-1) 141.4 309.4Normalised flow rate per flue (Nm3 s-1) (a) 109.7 105.7(a) Corrected to 273 k, dry and 15% v/v O2 (dry).

Modelling is undertaken assuming a sulphur (S) fuel concentration of30 mg Nm-3 (273 k, 101.3 kPa) for both combined cycle and open cycleoperation.

Table 3.2 shows the emission concentration and emission rates used for thisassessment.


Table 3.2 Sulphur Dioxide (SO2) Pollutant Emission Concentration and Rates

Parameter Value

Fuel sulphur (S) content (mg Nm-3) (a) 30Fuel flow at maximum load (kg s-1) 2.517Fuel density (kg Nm-3) (a) 0.78Fuel flow rate (Nm3 s-1) (a) 3.227Sulphur (S) emission rate (mg s-1) 96.8Sulphur dioxide (SO2) emission rate (mg s-1) 193.6

CCGT OCGTExhaust gas flow Rate (Nm3 s-1) (b) 109.7 105.7Sulphur dioxide emission conc (mg Nm-3) (b) 1.77 1.83(a) Correct to 273 k, 101.3 kPa(b) Corrected to 273 k, dry, 15% v/v O2 (dry), 101.3 kPa.

Table 3.2 shows that at the guaranteed maximum fuel sulphur (S) content of30 mg Nm-3 (273 k, 101.3 kPa) this is equivalent to a sulphur dioxide (SO2)emission concentration of 1.77 mg Nm-3 for CCGT and 1.83 mg Nm-3 for opencycle (273 k, dry,15% v/v O2 (dry), 101.3 k Pa).

3.3 FACTORS AFFECTING DISPERSION

There are a number of factors that affect how emissions disperse oncereleased to atmosphere. The four factors having the greatest effect ondispersion are:

physical characteristics of the emissions climate terrain building downwash

3.3.1 Physical Characteristics of the Emissions

Provided that exhaust gases have sufficient velocity at stack exit to overcomethe effects of stack tip downwash, which is almost certainly the case forvelocities of 15 m s-1 or more, the physical characteristics of the flue gases willdetermine the amount of plume rise and, hence, the affect on ground levelpollutant concentrations. The degree of plume rise usually depends on thegreater of the thermal buoyancy or momentum effects. In the case ofemissions from the proposed facility, it will be the thermal effects thatdetermine how high the plume will eventually rise. The exit velocities of21 m s-1 and 33 m s-1 are sufficient to overcome the effects of stack tip downwash.


3.3.2 Climate

The most important meteorological parameters governing the atmosphericdispersion of pollutants are wind speed, wind direction and atmosphericstability.

Wind direction determines the broad transport of the plume and thesector of the compass into which the plume is dispersed.

Wind speed can affect plume dispersion by increasing the initial dilution ofpollutants and inhibiting plume rise.

Atmospheric stability is a measure of the turbulence of the air,particularly of the vertical motions present. For dispersion modellingpurposes, one method of classifying stability is by the use of PasquillStability categories, A to F. Another is by reference to the surface heat fluxpresent at the ground.

Dispersion models, such as ADMS and AERMOD, do not allocate the degreeof atmospheric turbulence into six discrete categories. These models use aparameter known as the Monin-Obukhov length which, together with the windspeed, describes the stability of the atmosphere.

Building Downwash

The presence of buildings can significantly affect the dispersion of theatmospheric emissions. Wind blowing around a building distorts the flow andcreates zones of turbulence that are greater than if the building were absent.Increased turbulence causes greater plume mixing; the rise and trajectory ofthe plume may be depressed generally by the flow distortion. Downwashleads to higher ground level concentrations closer to the stack than thosepresent in the absence of a building.

It is commonly accepted that downwash effects only occur for emissions fromstacks that are less than 2.5 to 3 times the height of the building structures.The structures also have to be sufficiently close to the source for theirinfluence to be significant. The US Environmental Protection Agencysuggests that the zone of influence around a building extends for a distance ofno more than five times the lesser of the structures height or width. Thedispersion model ADMS, however, calculates the effect of buildings out tosixty times the building height.

For the 75 m high main stacks only buildings or structures taller than 30 m willeffect dispersion sufficiently to warrant inclusion in the modelling. For the30 m high by-pass stacks used for open cycle operation buildings orstructures taller than 12 m will effect dispersion sufficiently to warrant inclusionin the modelling. There are no buildings higher than 12 m in the DelimaraPower Station. The highest structures on the site are the three HeatRecovery Steam Generators (HRSGs) at the base of the main stacks that


may have a small effect on dispersion of emissions from the 30 m high by-pass stacks used in open cycle operation. The effects of the HRSGs ondispersion have been included in the modelling.

Table 3.3 shows the building dimensions included in the modelling to simulatethe downwash effects of the HRSGs.

Table 3.3 Dimensions of Buildings Included in the Modelling

Building UTM Grid Reference(metres) Height (m) X Length

(m)Y Length

(m) Angle (deg)

HRSG 1 459709 3965609 17 17 5 47.5HRSG 2 459682 3965588 17 17 5 47.5HRSG 3 459695 3965598 17 17 5 47.5

3.3.3 Nature of the Surface

Terrain

The effects of terrain on dispersion in the region of the facility have beenincluded in the modelling. Figure 3.1 shows the terrain elevations included inthe modelling. The terrain data are UTM coordinates Sector 33 S referencedto WGS 84 datum.


Figure 3.1 Terrain Elevations Included in Modelling (m)

Roughness

The nature of the surface of the terrain can have a significant influence ondispersion by affecting the velocity profile with height and the amount ofatmospheric turbulence. To account for the nature of the site and surroundingarea, a surface roughness length of 0.3 m to 0.5 m depending on the winddirection has been assumed for the dispersion modelling.

3.3.4 Selection of Suitable Dispersion Model

The dispersion models which are widely used to predict ground level pollutantconcentrations are based on the concept of the time averaged lateral andvertical concentration of pollutants in a plume being characterised by aGaussian (1) distribution and the atmosphere is characterised by a number ofdiscrete stability classes. So called ‘new generation’ dispersion models suchas AERMOD and ADMS have been developed which replace the descriptionof the atmospheric boundary layer as being composed of discrete stabilityclasses with an infinitely variable measure of the surface heat flux, which in

(1) A Gaussian distribution has the appearance of a bell shaped curve. The maximum concentration occurs on the centreline.


turn influences the turbulent structure of the atmosphere and hence thedispersion of a plume.

The following are details for two of the commercially available dispersionmodels that are able to predict ground level concentrations arising fromemissions to atmosphere from elevated point sources (ie stacks) which areroutinely used for modelling and assessment work.

AERMOD: The US American Meteorological Society and EnvironmentalProtection Agency Regulatory Model Improvement Committee developedthe dispersion MODdel called AERMOD which incorporates the latestunderstanding of the atmospheric boundary layer. AERMOD is the USEPA regulatory dispersion model.

UK Atmospheric Dispersion Modelling System (ADMS): This is adispersion model developed by the UK consultancy CERC. The modelallows for the skewed nature of turbulence within the atmosphericboundary layer.

In many respects the models are quite similar and in many situations generatesimilar predictions of ground level concentrations. AERMOD was selected asthe model for use in this assessment because of its wide spread internationalacceptability. US EPA version 15181 of AERMOD was used for thisassessment.

3.3.5 Meteorological Data

A necessary input to the dispersion model is the meteorological data. Thesedata are important in determining the location of the maximum concentrationsand their magnitude. The closest location for which there is observation of allthe parameters required for modelling is Malta International Airport, Luqawhich is considered to be representative of the location of the proposeddevelopment. Luqa is about 5 km to the west of the proposed facility.

Figure 3.2, 3.3 and 3.4 are the 2011-2015 wind roses of the meteorologicaldata used in this assessment, from Luqa. The figures show that theprevailing wind direction is from the north west.


Figure 3.2 Windrose for 2011 and 2012 from Luqa


Figure 3.4 Windrose for 2015


3.3.6 Modelling Assumptions

Receptor Grid Spacing

The receptor grid used for this assessment was 5 km by 4 km with a gridspacing of 50 m to allow for predictions to be made at the point of maximumimpact.


4 ASSESSMENT OF IMPACTS

4.1 INTRODUCTION

This section describes the predicted ground/sea level concentrations ofsulphur dioxide (SO2) occurring from both combined and open cycleoperation. Predictions are presented for the guaranteed maximum fuelsulphur (S) content of 30 mg Nm-3 (273 k, 101.3 kPa) which is equivalent to asulphur dioxide (SO2) emissions rate of 194 mg s-1.

4.2 COMBINED CYCLE GAS TURBINE (CCGT) OPERATION

Table 4.1 shows the maximum predicted ground or sea level concentration ofsulphur dioxide (SO2) occurring as a consequence of emissions toatmosphere from the facility operating in combined cycle mode for each of thefive years of meteorological data.

Table 4.1 AERMOD Maximum Predicted Ground/Sea Level Concentrations ofSulphur Dioxide (SO2, µg m-3) for Fuel Sulphur (S) Concentration of30 mg Nm-3 for Combined Cycle Gas Turbine (CCGT) Operation

Year Annual Average 99.17th Percentile ofDaily Average

99.73th Percentileof Hourly Average

2011 0.038 0.22 0.662012 0.035 0.19 0.642013 0.037 0.21 0.662014 0.037 0.22 0.642015 0.038 0.22 0.66

Ambient Limit Value - 125 350Compliance with Reg. 3(3) - 3.75 -

Table 4.1 shows that 2015 meteorological data gives rise to the maximumground/sea level 99.17% percentile of daily average concentrations. The gridmaximum for 2011 to 2015 of 0.22 µg m-3 is substantially less than thatrequired for compliance with Regulation 3(3) which is 3.75 µg m-3.

The following figures are presented to show the distribution of ground/sealevel concentrations of the sulphur dioxide (SO2), assuming a fuel sulphur (S)concentration of 30 mg Nm-3. Predictions are presented for 2015 which givesrise to the maximum impact for daily average connotations.

Figure 4.1; Annual Average Figure 4.2; 99.17th percentile of daily averages


Figure 4.1 AERMOD Predicted Annual Average Ground/Sea Level Concentrations ofthe Sulphur Dioxide (SO2); 2015 Meteorological Data (µg m-3); AssumingFuel Sulphur (S) Emission Concentration of 30 mg Nm-3 equivalent to194 mg s-1 Emissions of Sulphur Dioxide (SO2)Combined Cycle Gas Turbine Operation (CCGT)


Figure 4.2 AERMOD Predicted 99.17th Percentile of Daily Average Ground/SeaLevel Concentrations of the Sulphur Dioxide (SO2); 2015 MeteorologicalData (µg m-3); Assuming Fuel Sulphur (S) Emission Concentration of30 mg Nm-3 equivalent to 194 mg s-1 Emissions of Sulphur Dioxide (SO2)Target: 3.75 µg m-3

Combined Cycle Gas Turbine Operation (CCGT)


4.3 OPEN CYCLE GAS TURBINE (OCGT) OPERATION

For the first six months, the facility will operate in open cycle model withemissions from the gas turbine being released to atmosphere from the 30 mhigh by-pass stacks.

Table 4.2 shows the maximum predicted ground or sea level concentration ofsulphur dioxide (SO2) occurring as a consequence of emissions toatmosphere from the facility operating in open cycle mode for each of the fiveyears of meteorological data.

Table 4.2 AERMOD Maximum Predicted Ground/Sea Level Concentrations ofSulphur Dioxide (SO2, µg m-3) for Fuel Sulphur (S) Concentration of30 mg Nm-3 for Open Cycle Gas Turbine (OCGT) Operation



2011 0.036 0.27 0.802012 0.044 0.38 1.262013 0.049 0.44 1.702014 0.049 0.38 1.272015 0.039 0.39 1.06


Table 4.2 shows that 2013 meteorological data gives rise to the maximumground/sea level 99.17% percentile of daily average concentrations. The gridmaximum for 2013 of 0.44 µg m-3 is substantial less than required forcompliance with Regulation 3(3) which is 3.75 µg m-3.

The following figures are presented to show the distribution of ground/sealevel concentrations of the sulphur dioxide (SO2), assuming a fuel sulphur (S)concentration of 30 mg Nm-3. Predictions are presented for 2013 which givesrise to the maximum impact for daily average connotations.



Figure 4.3 AERMOD Predicted Annual Average Ground/Sea Level Concentrations ofthe Sulphur Dioxide (SO2); 2013 Meteorological Data (µg m-3); AssumingFuel Sulphur (S) Emission Concentration of 30 mg Nm-3 equivalent to194 mg s-1 Emissions of Sulphur Dioxide (SO2)Open Cycle Gas Turbine Operation (OCGT)


Figure 4.4 AERMOD Predicted 99.17th Percentile of Daily Average Ground/SeaLevel Concentrations of the Sulphur Dioxide (SO2); 2013 MeteorologicalData (µg m-3); Assuming Fuel Sulphur (S) Emission Concentration of30 mg Nm-3 equivalent to 194 mg s-1 Emissions of Sulphur Dioxide (SO2)Target: 3.75 µg m-3

Open Cycle Gas Turbine Operation (OCGT)


5 DISCUSSION AND CONCLUSIONS

5.1 INTRODUCTION

This section provides a discussion and conclusions.

5.2 REGULATION 3(3)

It is considered that the intention of Regulation 3(3) was that the 3% criteriashould to apply to annual average limit value concentrations and not to shortterm value concentrations.

For the purpose of this study, the 3% criteria will be applied to the dailyaverage ambient limit value of 125 µg m-3 not to be exceeded more than 3times per calendar year. It is considered that this is a conservativeinterpretation of the requirements of Regulation 3(3). The former MEPAinstructed the Consultants to use this interpretation.

5.3 COMBINED AND OPEN CYCLE GAS TURBINE (CCGT/OCGT) OPERATION

Table 4.1 and Table 4.2 show the maximum predicted 99.17th percentile ofdaily average ground/sea level concentrations do not approach the target of3.75 µg m-3 and therefore the emissions from the gas turbines are complaintwith Regulation 3(3)

5.4 SUMMARY AND CONCLUSIONS

Atmospheric Dispersion Modelling (ADM) Ltd has been commissioned by AdiAssociates to undertake dispersion modelling of emissions to atmospherefrom the new LNG power station at Delimara, Malta.

The modelling shows that emissions to atmosphere at the guaranteedmaximum fuel sulphur (S) content of 30 mg Nm-3 (273 k, 101.3 kPa) arecompliant with Regulation 3(3) and therefore no further mitigation measuresare required.

Sulphur Dioxide (SO2)Emissions Modelling for

the New LNG Plant atDelimara Power Station,

MaltaPhase 2

P1521

A Report Prepared forADI Associates

byADM Ltd

Old Chambers93-94 West Street

FarnhamSurrey

GU9 7EB, UKTel: +44 (0) 1252 720842

Email: [email protected]: www.AboutAir.com

Principal Author: David Harvey BSc MBA FIAQMClient: ADI Associates

Version/File Issue DateFile=P1521\text\Delimara_Phase_2_AQ_v1.doc 20 September 2016File=P1521\text\Delimara_Phase_2_AQ_v2.doc 21 September 2016

1 INTRODUCTION 1

2 REGULATIONS 3

2.1 INTRODUCTION 32.2 REGULATION 3(3) 3

3 METHODOLOGY 4

3.1 INTRODUCTION 43.2 EMISSIONS DATA 43.3 FACTORS AFFECTING DISPERSION 63.3.1 Physical Characteristics of the Emissions 63.3.2 Climate 63.3.3 Nature of the Surface 73.3.4 Selection of Suitable Dispersion Model 83.3.5 Meteorological Data 93.3.6 Modelling Assumptions 11

4 ASSESSMENT OF IMPACTS 12

4.1 INTRODUCTION 124.2 CASE 1 124.3 CASE 2 15

5 DISCUSSION AND CONCLUSIONS 18

5.1 INTRODUCTION 185.2 REGULATION 3(3) 185.3 CASE 1 OPERATION 185.4 CASE 2 OPERATION 185.5 SUMMARY AND CONCLUSIONS 19


1 INTRODUCTION

Atmospheric Dispersion Modelling (ADM) Ltd has been commissioned by AdiAssociates Environmental Consultants Ltd to undertake dispersion modellingof emissions to atmosphere from the new Liquefied Natural Gas (LNG) powerstation at Delimara, Malta.

An air quality assessment for the proposed power station was completed inAugust 2013 and included full assessment of emissions of oxides of nitrogen(NOx/NO2) and particulate matter (PM10 and PM2.5) ( 1 ). The report statedemissions of sulphur dioxide (SO2) would be negligible and therefore was notincluded in the assessment.

It has subsequently transpired that LNG sulphur (S) fuel content could be upto 30 mg Nm-3 (273 k, 101.3 kPa) and therefore should be considered.

Phase 1 of the further modelling worked updated the August 2013 study toincludes modelling for sulphur dioxide (SO2) at the guaranteed maximum fuelsulphur content for emissions from the gas turbines operating in bothcombined cycle mode (CCGT) and for emissions from the gas turbinesoperating in open cycle mode (OCGT). OCGT operation will only occur forthe first six months.

The Phase 1 modelling assessment concluded that emissions to atmosphereat the guaranteed maximum fuel sulphur (S) content of 30 mg Nm-3 (273 k,101.3 kPa) are compliant with Regulation 3(3) and therefore no furthermitigation measures are required (2).

This report presents the emissions data and predictions for Phase 2 of thefurther modelling work which includes modelling of emissions of sulphurdioxide (SO2) from all the sources which will occur during the postcommissioning operation of the facility.

The sources of emissions to atmosphere modelled in this Phase 2assessment are:

3 x D4 PP GT A1, B1, C1 D3PP SG Engines 1&2 D3PP SG Engines 3&4 D3PP DF Engines 1&2 (gas fired) D3PP DF Engines 3&4 (gas fired) D3PP GRS Gas Boiler No 1 D3PP GRS Gas Boiler No 2 FSU Main Boiler (phase 1 oil)

(1) ERSLI (December 2013) Delimara Gas and Power Combined Cycle Gas Turbine and Liquefied Natural Gas receiving,storage , and re-gasification facilities. Delimara Power Station.(2) ADM Ltd (16 September 2016) Sulphur Dioxide (SO2) Emissions Modelling for the New LNG Plant at Delimara PowerStation, Malta Phase 1.


FSU Aux Boiler (phase 2 gas) FSU Service diesel gen-set (oil)

The Phase 2 modelling presented in this report is for two scenarios, Case 1 isa temporary condition and Case 2 is the expected routine emissions.


2 REGULATIONS

2.1 INTRODUCTION

The section described the targets used for the determination of sulphurdioxide (SO2) emission limits for combined cycle gas turbine (CCGT) andopen cycle gas turbine (OCGT) operation.

2.2 REGULATION 3(3)

Regulation 3(3) of the Industrial Emissions (Large Combustion Plants)Regulations (LN 11 of 2013) state that:

For combustion plants permitted after 07 January 2013, the minimum stack heightwhich shall be established during the initial permitting process, shall be such that thecontribution from these combustion plants does not exceed 3% of the limit values inAnnex 7 of the Ambient Air Quality Regulations, for the pollutants specified therein.

Schedule 7 (part AII) of the Ambient Air Quality Regulations (LN 478 of 2010as amended) define the following limit values for SO2 in ambient air:

One day:125 μg/m3, not to be exceeded more than 3 times a calendar year One hour:350 μg/m3, not to be exceeded more than 24 times a calendar year

It is considered that the intention of the Regulation 3(3) was that the 3%percentage was to apply to only annual average concentrations. This wasassumed to be the case for the previous study that considered the impacts ofnitrogen dioxide (NO2) which compared the annual average concentration withthe 3% of the annual average limit value but not compared the hourly averageconcentrations with 3% of the hourly average limit value.

It is considered that an appropriate limit value for short term impacts (ie 1 hourand 24 hour averaging periods) is 10 times the long term limit value which inthis case would be 30% of the short term Ambient Air Quality Regulations.The factor of 10 between long and short term impacts is used by the UKEnvironment Agency (EA) in their risk assessment guidance (1).

However, for the purpose of this study and as instructed by the former MaltaEnvironment & Planning Authority (now the Planning Authority and theEnvironment & Resources Authority), the 3% of the limit value will be appliedto the daily average ambient limit value of 125 µg m-3 not to be exceededmore than 3 times per calendar year.

The target for emissions of sulphur dioxide (SO2) that gives rise to anacceptable impact is therefore 3.75 µg m-3 as a daily average not to beexceeded more than 3 times per year which is equivalent to a 3.75 µg m-3 as99.17th percentile of daily averages.

(1) https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit.


3 METHODOLOGY

3.1 INTRODUCTION

This section describes the methodology and assumptions made for themodelling. Also described are the emissions data used.

Modelling has been undertaken for worst case operation which assumescontinuous emissions from the following sources:

D4PP (3 stacks) D3PP engines (8x engines and 4 combined stacks) D3PP GRS boilers (2 stacks) FSU main boiler running at low load (horizontal stack) FSU CAT service generator (horizontal stack)

In addition to these sources there are 3 small pilot flames located on theRegas plant area. It’s expected that total sulphur dioxide (SO2) emission ratefrom this sources will be 0.075 mg s-1 which is insignificant and will give rise toan negligible impact on air quality and therefore have not been consideredfurther.

Two cases are considered:

Case (1) Mobilized FSU with the FSU main boiler emission source. Case (2) Cold iron FSU with the new auxiliary boiler as active emission

source instead of the FSU main boiler.

Case 1 emissions will only occur during the first year of operation and possiblyonly during the first few weeks. The reason for including modelling of Case 1emissions is as a provision in case the storm mooring system is notcompleted and the FSU would need to keep the main boilers in service forsailing off in a storm mooring event. Therefore the impacts on air quality ofCase 1 emissions emission are temporary and only included in thisassessment for completeness.

3.2 EMISSIONS DATA

Table 3.1 shows the parameters which will describe physical properties ofemissions to atmosphere from the stacks, as required for definition of theemissions in dispersion modelling terms.

The main boiler stack and service diesel generator (sources number 10 and11) have horizontal releases which means there will only be thermal drivenplume rise and no momentum driven plume rise. To remove the effect ofmomentum driven plume rise from the modelling these source have beenmodelled with an artificially low exit velocity of 0.5 m s-1 and a diameter


increased to ensure the correct thermal plume rise. This is a conservativeway of modelling a horizontal source.

Emissions assume a LNG sulphur (S) fuel concentration of 30 mg Nm-3

(273 k, 101.3 kPa).

Table 3.1 Emissions Data

No SourceCase UTM Grid

Reference (a)

StackHeight

(m)

Dia(m)

Velocity(m s-1)

Temp(deg C)

SO2

(g s-1)(1) (2)

1 D4 PP GT A1 459765 3965809

75 2.9 21.4 95.3 0.19459683 3965627

2 D4 PP GT B1 459751 3965799

75 2.9 21.4 95.3 0.19459669 3965617

3 D4 PP GT C1 459737 3965788

75 2.9 21.4 95.3 0.19459655 3965606

4 D3PP SG Engines 1&2 460137 3965687

65 2.1 23.1 170 0.15460055 3965505

5 D3PP SG Engines 3&4 460134 3965685

65 2.1 23.1 170 0.15460052 3965503

6 D3PP DF Engines 1&2 (gas fired) 460104 3965663

65 2.1 21.1 170 0.14460022 3965481

7 D3PP DF Engines 3&4 (gas fired) 460101 3965661

65 2.1 21.1 170 0.14460019 3965479

8 D3PP GRS Gas Boiler No 1 460015 3965649

10 0.4 12.0 200 0.001459933 3965467

9 D3PP GRS Gas Boiler No 2 460017 3965650

10 0.4 12.0 200 0.001459935 3965468

10 FSU Main Boiler (phase 1 oil) -459772 3965155

44 2.1 2.0 (b) 167 0.44459690 3964973

11 FSU Aux Boiler (phase 2 gas) - 459772 3965155

44 2.1 8.0 (c) 330 0.03459690 3964973

12 FSU Service diesel gen-set (oil) 459756 3965157

18 0.52 30.4 (d) 465 0.30459674 3964975

(a) UTM grid references are all zone 33 S and are given for two datum, the first (top) datum is ED50 and second is WGS84. The WGS 84 datum is used in the modelling and the digital terrain data.

(b) Horizontal release, modelled with 0.5 m s-1 exit velocity and diameter of 4.2 m.(c) Horizontal release, modelled with 0.5 m s-1 exit velocity and diameter of 8.4 m.(d) Horizontal release, modelled with 0.5 m s-1 exit velocity and diameter of 4.05 m.

Source 12 (FSU CAT diesel engine, oil) will only operate for an estimated 120hours per year when a storm mooring is forecast. Storm mooring forecastsonly occur for strong winds from the south and therefore will not occur themost frequent wind direction which is from the north west (see Figure 3.2).Given that it is the north westerly wind direction that given rise to themaximum predicted concentrations it is reasonable to exclude source 12 fromthe modelling as it will not be operating during meteorological conditions thatgive rise to the maximum on land concentration.


3.3 FACTORS AFFECTING DISPERSION

There are a number of factors that affect how emissions disperse oncereleased to atmosphere. The four factors having the greatest effect ondispersion are:

physical characteristics of the emissions climate terrain building downwash

3.3.1 Physical Characteristics of the Emissions

Provided that exhaust gases have sufficient velocity at stack exit to overcomethe effects of stack tip downwash, which is almost certainly the case forvelocities of 15 m s-1 or more, the physical characteristics of the flue gases willdetermine the amount of plume rise and, hence, the affect on ground levelpollutant concentrations. The degree of plume rise usually depends on thegreater of the thermal buoyancy or momentum effects. In the case ofemissions from the proposed facility, it will be the thermal effects thatdetermine how high the plume will eventually rise. The exit velocities of21 m s-1 and 33 m s-1 are sufficient to overcome the effects of stack tip downwash.

3.3.2 Climate

The most important meteorological parameters governing the atmosphericdispersion of pollutants are wind speed, wind direction and atmosphericstability.

Wind direction determines the broad transport of the plume and thesector of the compass into which the plume is dispersed.

Wind speed can affect plume dispersion by increasing the initial dilution ofpollutants and inhibiting plume rise.

Atmospheric stability is a measure of the turbulence of the air,particularly of the vertical motions present. For dispersion modellingpurposes, one method of classifying stability is by the use of PasquillStability categories, A to F. Another is by reference to the surface heat fluxpresent at the ground.

Dispersion models, such as ADMS and AERMOD, do not allocate the degreeof atmospheric turbulence into six discrete categories. These models use aparameter known as the Monin-Obukhov length which, together with the windspeed, describes the stability of the atmosphere.

Building Downwash


The presence of buildings can significantly affect the dispersion of theatmospheric emissions. Wind blowing around a building distorts the flow andcreates zones of turbulence that are greater than if the building were absent.Increased turbulence causes greater plume mixing; the rise and trajectory ofthe plume may be depressed generally by the flow distortion. Downwashleads to higher ground level concentrations closer to the stack than thosepresent in the absence of a building.

It is commonly accepted that downwash effects only occur for emissions fromstacks that are less than 2.5 to 3 times the height of the building structures.The structures also have to be sufficiently close to the source for theirinfluence to be significant. The US Environmental Protection Agencysuggests that the zone of influence around a building extends for a distance ofno more than five times the lesser of the structures height or width. Thedispersion model ADMS, however, calculates the effect of buildings out tosixty times the building height.

For the 75 m high main stacks only buildings or structures taller than 30 m willeffect dispersion sufficiently to warrant inclusion in the modelling. There areno buildings higher than 12 m in the Delimara Power Station. The higheststructures on the site are the three Heat Recovery Steam Generators(HRSGs) at the base of the main stacks which will have no effect onemissions from the main stacks.

Emissions to atmosphere from sources that are located on the LNG vessel willbe effected by the physical presence of the ship which has been included inthe modelling.

Table 3.2 shows the building dimensions included in the modelling to simulatethe downwash effects of the LNG vessel.

Table 3.2 Dimensions of Buildings Included in the Modelling

BuildingUTM Grid Reference

(WGS 84, 33 S,metres)

Height (m) X Length(m)

Y Length(m) Angle (deg)

Ship 459750 3965165 30 240 45 90

3.3.3 Nature of the Surface

Terrain

The effects of terrain on dispersion in the region of the facility have beenincluded in the modelling. Figure 3.1 shows the terrain elevations included inthe modelling.


Figure 3.1 Terrain Elevations Included in Modelling (m)

Roughness

The nature of the surface of the terrain can have a significant influence ondispersion by affecting the velocity profile with height and the amount ofatmospheric turbulence. To account for the nature of the site and surroundingarea, a surface roughness length of 0.3 m to 0.5 m depending on the winddirection has been assumed for the dispersion modelling.

3.3.4 Selection of Suitable Dispersion Model

The dispersion models which are widely used to predict ground level pollutantconcentrations are based on the concept of the time averaged lateral andvertical concentration of pollutants in a plume being characterised by aGaussian (1) distribution and the atmosphere is characterised by a number ofdiscrete stability classes. So called ‘new generation’ dispersion models suchas AERMOD and ADMS have been developed which replace the descriptionof the atmospheric boundary layer as being composed of discrete stabilityclasses with an infinitely variable measure of the surface heat flux, which in

(1) A Gaussian distribution has the appearance of a bell shaped curve. The maximum concentration occurs on the centreline.


turn influences the turbulent structure of the atmosphere and hence thedispersion of a plume.

The following are details for two of the commercially available dispersionmodels that are able to predict ground level concentrations arising fromemissions to atmosphere from elevated point sources (ie stacks) which areroutinely used for modelling and assessment work.

AERMOD: The US American Meteorological Society and EnvironmentalProtection Agency Regulatory Model Improvement Committee developedthe dispersion MODdel called AERMOD which incorporates the latestunderstanding of the atmospheric boundary layer. AERMOD is the USEPA regulatory dispersion model.

UK Atmospheric Dispersion Modelling System (ADMS): This is adispersion model developed by the UK consultancy CERC. The modelallows for the skewed nature of turbulence within the atmosphericboundary layer.

In many respects the models are quite similar and in many situations generatesimilar predictions of ground level concentrations. AERMOD was selected asthe model for use in this assessment because of its wide spread internationalacceptability. US EPA version 15181 of AERMOD was used for thisassessment.

3.3.5 Meteorological Data

A necessary input to the dispersion model is the meteorological data. Thesedata are important in determining the location of the maximum concentrationsand their magnitude. The closest location for which there is observation of allthe parameters required for modelling is Malta International Airport, Luqawhich is considered to be representative of the location of the proposeddevelopment. Luqa is about 5 km to the west of the proposed facility.

Figure 3.2, 3.3 and 3.4 are the 2011-2015 wind roses of the meteorologicaldata used in this assessment, from Luqa. The figures show that theprevailing wind direction is from the north west.




Figure 3.4 Windrose for 2015 from Luqa


3.3.6 Modelling Assumptions

Receptor Grid Spacing

The receptor grid used for this assessment was 5 km by 4 km with a gridspacing of 50 m to allow for predictions to be made at the point of maximumimpact.


4 ASSESSMENT OF IMPACTS

4.1 INTRODUCTION

This section describes the predicted ground/sea level concentrations ofsulphur dioxide (SO2) occurring from both operating cases.

Case 1: Emissions during the first yearCase 2: Operation after the first year

See Section 3.2 for details of the emission sources for each Case.

For compliance with Regulation 3(3) it is considered that only concentrationsthat occur on land are relevant as there will be no long term (24 hour average)exposure for concentrations occurring over the sea.

4.2 CASE 1

Table 4.1 shows the maximum predicted ground level concentration ofsulphur dioxide (SO2) occurring as a consequence of Case 1 emissions toatmosphere from the facility operating for each of the five years ofmeteorological data.

Table 4.1 AERMOD Maximum Predicted Ground Level Concentrations of SulphurDioxide (SO2, µg m-3) for Case 1 Emissions



2011 1.42 4.9 15.22012 1.34 5.0 15.22013 1.13 4.6 13.62014 1.10 3.9 13.42015 1.25 4.7 13.2


Table 4.1 shows that 2012 meteorological data gives rise to the maximumground level 99.17% percentile of daily average concentrations. Themaximum daily average ground level concentration of sulphur dioxide (SO2)for 2012 of 5.0 µg m-3 is higher than that required for compliance withRegulation 3(3) which is 3.75 µg m-3. Given that Case 1 emissions will occuronly during the first year of operation and possibly only during only the firstfew weeks it is however likely that there will be no exceedence of theRegulation 3(3).

The following figures are presented to show the distribution of ground/sealevel concentrations of the sulphur dioxide (SO2) for Case 1 operation.


Predictions are presented for 2012 which gives rise to the maximum impactfor daily average concentrations.


Figure 4.1 AERMOD Predicted Annual Average Ground/Sea Level Concentrations ofthe Sulphur Dioxide (SO2); 2012 Meteorological Data (µg m-3); Case 1Operation


Figure 4.2 AERMOD Predicted 99.17th Percentile of Daily Average Ground/SeaLevel Concentrations of the Sulphur Dioxide (SO2); 2012 MeteorologicalData (µg m-3); Case 1 Operation


4.3 CASE 2

Table 4.2 shows the maximum predicted ground level concentration ofsulphur dioxide (SO2) occurring as a consequence of Case 2 emissions toatmosphere from the facility operating for each of the five years ofmeteorological data.

Table 4.2 AERMOD Maximum Predicted Ground Level Concentrations of SulphurDioxide (SO2, µg m-3) for Case 2 Emissions



2011 0.10 0.47 1.02012 0.10 0.42 1.02013 0.10 0.43 1.02014 0.10 0.44 1.02015 0.11 0.48 0.9


Table 4.2 shows that 2015 meteorological data gives rise to the maximumground/sea level 99.17% percentile of daily average concentrations. Themaximum daily average ground level concentration of sulphur dioxide (SO2)for 2015 of 0.48 µg m-3 is substantially less than required for compliance withRegulation 3(3) which is 3.75 µg m-3.

The following figures are presented to show the distribution of ground/sealevel concentrations of the sulphur dioxide (SO2) for Case 2 operation.Predictions are presented for 2015 which gives rise to the maximum impactfor daily average concentration.



Figure 4.3 AERMOD Predicted Annual Average Ground/Sea Level Concentrations ofthe Sulphur Dioxide (SO2); 2015 Meteorological Data (µg m-3); Case 2Operation


Figure 4.4 AERMOD Predicted 99.17th Percentile of Daily Average Ground/SeaLevel Concentrations of the Sulphur Dioxide (SO2); 2015 MeteorologicalData (µg m-3); Case 2 Operation


5 DISCUSSION AND CONCLUSIONS

5.1 INTRODUCTION

This section provides a discussion and conclusions.

5.2 REGULATION 3(3)

It is considered that the intention of Regulation 3(3) was that the 3% criteriashould to apply to annual average limit value concentrations and not to shortterm value concentrations.

For the purpose of this study, the 3% criteria will be applied to the dailyaverage ambient limit value of 125 µg m-3 not to be exceeded more than 3times per calendar year. It is considered that this is a conservativeinterpretation of the requirements of Regulation 3(3). The former MEPAinstructed the Consultants to use this interpretation.

5.3 CASE 1 OPERATION

Case 1 operation will occur for a maximum of one year and possibly only for afew weeks. Case 1 emissions can therefore be considered as beingtemporary and therefore comparison with Regulation 3(3) limit is veryconservative.

Table 4.1 shows the maximum predicted 99.17th percentile of daily averageground level concentrations for Case 1 emissions exceeds the target of3.75 µg m-3.

Given that it is considered that Regulation 3(3) should apply to only annualaverage concentrations and Case 1 emissions are only temporary it isconsidered the predicted exceedence of the 3% Regulation 3(3) target shouldbe disregarded.

The predictions show that the impacts on air quality of emissions of sulphurdioxide (SO2) for Case 1 emissions are not of concern to human healthbecause the impacts are, at the most, 5% of the limit values set to protecthuman health.

5.4 CASE 2 OPERATION

Case 2 operation is predicted to give rise to impacts that are less thanRegulation 3(3) limit and not of concern to human health.


5.5 SUMMARY AND CONCLUSIONS

Atmospheric Dispersion Modelling (ADM) Ltd has been commissioned by AdiAssociates to undertake dispersion modelling of emissions to atmospherefrom the new LNG power station at Delimara, Malta.

The Phase 1 modelling assessment concluded that emissions to atmosphereat the guaranteed maximum fuel sulphur (S) content of 30 mg Nm-3 (273 k,101.3 kPa) are compliant with Regulation 3(3) and therefore no furthermitigation measures are required (1).

This report presents the emissions data and predictions for Phase 2 of thefurther modelling work which includes modelling of emissions of sulphurdioxide (SO2) from all the sources which will occur during the postcommissioning operation of the facility.

The conclusion of the Phase 2 modelling is that for routine emissions from thefacility (Case 2 emissions) the maximum predicted ground levelconcentrations are compliant with Regulation 3(3).

For Case 1 there are predicted to be localised exceedence of the Regulation3(3) limit but it is considered, for the following reasons, that this exceedenceshould be disregarded:

Applying Regulation 3(3) to a 24 hour average is considered to beconservative.

The impacts are less than 5% of the ambient air quality limit values set toprotect human health and therefore are no of concern to human health.

Case 1 emissions are for temporary operation of the facility that will occurfor no more than a year of possibly only for a few weeks until that stormmooring system is completed.

(1) ADM Ltd (16 September 2016) Sulphur Dioxide (SO2) Emissions Modelling for the New LNG Plant at Delimara PowerStation, Malta Phase 1.

EISDelimaraPowerStation

CombinedCycleGasTurbineand

LiquefiedNaturalGasreceiving,

storageandre-gasificationfacilities.

NoiseReportAddendum3

5th September 2016

Prepared by:

…………………………………….

Christian Calleja Dip.Ind.Elec. AMIOA

Nest’ Belvedere str.

Gzira,Malta

Tel. :00356-21313706

Mob: 00356-99458400

E-mail: [email protected]

Web: www.acousticalconsultancy.com

2 | P a g eEIS Delimara Power station Combined Cycle GasTurbineand Liquefied Natural Gas receiving,storage and re-gasification Facilities.- Noise Evaluation. Addendum 3r03

RevisionHistory

Version Revision Date Purpose/Status

01 01 05/07/2016 Draft release.

01 02 05/09/2016 Update re-ERA comments.

01 03 19/09/2016 Update re-ERA comments.


ContentsRevision History.......................................................................................................................................................................... 2

List of Figures ......................................................................................................................................................................... 4

Statement ................................................................................................................................................................................... 4

Introduction................................................................................................................................................................................ 5

Changes in DPS3 –D3PG/ ex-BWSC .......................................................................................................................................... 8

Changes in ElectroGas Proposal – DPS4 ................................................................................................................................... 8

Floating Storage Unit -FSU ...................................................................................................................................................... 11

Monitoring update ................................................................................................................................................................... 12

Mitigation ................................................................................................................................................................................. 13

Annex A ..................................................................................................................................................................................... 14

Annex B ..................................................................................................................................................................................... 18


ListofFigures

Figure 1 the operators within the Delimara Power Station site. ................................................................................................ 6Figure 2 Phases of equipment operation within DPS. ................................................................................................................. 7Figure 3 Re-run of DPS4 from Siemens of area dispersion at 4 meter height above ground according to ISO1996-2. ....... 10Figure 4 FSU measurement points. ............................................................................................................................................. 12Figure 5 Additional 'one time' monitoring positions required for DPS4. ................................................................................. 13

StatementThis document is based on the latest information as supplied by all parties concerned up to the 1st of September 2016.


Introduction

Several small changes in the previously proposed development have been taken on as the project design has been

finalised and implemented. Furthermore, the Delimara Power Station site has been split between three operators (see

Figure 1);

· EneMalta – mainly responsible for Phase 1, Phase 2A and Phase 2B along with their ancillary equipment,

· D3PG – responsible for Phase 3, previously known as the BWSC plant,

· ElectroGas Malta – responsible for the proposed Phase 4, along with the FSU, the Regasification area, and the

Gas Receiving Station feeding Phase 3 and 4.

The various changes or conversions are expected to be concluded within a year or so, making a staged changeover for

the final configuration put forward in the previous EIA stages. Although the final noise emissions from the site to the

locality have been simulated and considered in various ways, this addendum would like to add due consideration for the

changes that have occurred during the design stage. Additional monitoring for the different stages before the final

configuration is required, as the time period for each stage is not known due to possible commissioning issues which

might occur in the process. The phasing of equipment being brought into or out of operation can be seen in Table 1.

The main changes will be the conversion of Phase 3 (DPS3), and the implementation of Phase 4 (DPS4), parts of which

are required for the converted Phase 3.

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DPS Site Phase Phase Equipment Modes of Operation or conversions Present Situation Intermediate Situation Long-term Situation

Phase 1 Standby Standby De-commissioned

Phase 2A

Open Cycle Turbine 1 Emergency Use Emergency Use Cold Standby

Open Cycle Turbine 2 Emergency Use Emergency Use Cold Standby

Phase 2B

CCGT 1 Operating Operating Cold Standby

CCGT 2 Operating Operating Cold Standby

Phase 3

First set of four engines

HFO Operation Operating N/A

Gas Conversion N/A In process Operating

Second set of four engines

HFO Operation N/A N/A

Gas Conversion In process Operating Operating

Phase 4

Three CCGTs

Open Cycle - Bypass Not Operational Operating

Closed Cycle with Steam Generator Not Operational Commissioning

FSU

Shore Power Not Operational N/A Operating

Onboard Power Not Operational Operating N/A

FSU Re-supply Not Operational Operating * Operating *

Re-gasification Not Operational Operating

Gas Regulating Station Not Operational Operating

Operating *= with stated re-supply 12 or more occurrances per year.

Figure 2 Phases of equipment operation within DPS.


ChangesinDPS3–D3PG/ex-BWSC

As previously discussed in Addendum 2, DPS3 will be converting to use LNG as a primary fuel supported by the use of

diesel if necessary. The conversion has started with four of the eight engines, whilst presently four engines are still

running on HFO. The present conversion will be brought online once LNG is being supplied from the Gas Receiving

Station, which is in the care of DPS4.

The changes, both present and the final full conversion, are not expected to make any change to the external noise

emissions to the environment, as all changes are internal i.e. within the enclosed shed.

ChangesinElectroGasProposal–DPS4

During the earlier stages of the EIA, the proposed development was covered for what was known of the proposed

installation at the time. The final design and implementation stage brought about changes to the development as

required by the final design;

· A small area has been added close to DPS2B for a Gas Receiving Station. The plant will consist of gas heaters,

pressure reducing equipment, valves and measuring equipment. The water bath heaters will have small stacks,

circa 10m high and there will be a gas vent for emergencies. It will be feeding both DPS3 and 4.

· A new building to house cooling water switchgear within Area D.

· The regasification area has increased slightly in size due to other plant required.

· The HRSGs have been changed to the vertical type whilst the original proposal was for horizontal HRSGs. This

reduces the length of the powertrain i.e. it has also moved the stacks.

· The originally proposed FSU vessel (Gemini) has been replaced by another vessel (Wakaba Maru). The newly

proposed vessel is 2 meters shorter and nearly 2 meters wider but of the same LNG capacity as originally

proposed. The mating gas manifold is in a slightly different position on the newly proposed vessel hence, the

final position of the vessel would be slightly further south.

· Some of the gas pipeline route layouts have changed but are still underground or along the presently existing

pipe racks.


Two of these development changes could have consequences on the final outputs delivered during the EIA process:

· The HRSGs – that have been changed to the vertical type and according to the contractor are of the natural

ventilation type.

· The FSU – which will be requiring the operation of on-board power i.e. generators and one boiler to be running.

The vertical HRSGs are of the natural ventilation type, which automatically create less noise then the originally proposed

horizontal type with forced ventilation. But in the case of the FSU, in the previous stages of the EIA the on-board

generators and vaporizers were included in the list of considered noise sources, albeit no definitive data of the actual

ship vis-à-vis the environmental emissions is available at present, the exact extent of operating equipment on board is

known. Furthermore, the previous simulations included far more vaporizers and equipment than what the vessel

actually has. The contractor would not have (quite common in the shipping world) the environmental noise emissions of

the ship, as almost all ships are certified for noise related to operators on board whilst the vessel is at cruising speed at

sea. Specific questions were put forward to the operator with regards to the FSU, possibly having been asked to

undertake similar environmental measurements, albeit the likelihood would have been exceptional.

The contractor for Phase 4 i.e. DPS4 has done a re-run for the expected noise levels from DPS4 under the new conditions

– see Figure 3. These would be the results taken individually, at each location under the right conditions i.e. with the

wind direction from the source to the receiver.

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FloatingStorageUnit-FSU

The FSU has been built to and maintained according to NK Rules (Nippon Kaiji Kyokai, known as ClassNK or NK, is a ship

classification society.) and is expected to be certified according to IMO Regulations. Hence, IMO Resolution A.468 (XII) or

as adopted by Maritime Safety Committee on November 2012; Resolution MSC. 337(91) will be implemented for ship

operations. New equipment on board is expected (according to contractor) to be certified according to BV (Bureau

Veritas) Rules. Albeit, these standards are related to noise, they only form methods of defining the noise aboard ships in

terms of those operating the vessel i.e. a form of ‘noise at work’ standard for those living and working aboard the vessel.

Although these standards are required as part of the ship’s operability, they do not establish the emissions to the

environment, neither in the near field nor in the far field of the vessel. There are no standards specifically developed or

accommodated, under which, the total emissions vis-à-vis environmental noise from single port operating ships can be

covered and in most cases the issue is handled on a case by case approach. The IMO Regulations mentioned fulfil

contractual obligations (even on an international basis) but would not help the environmental assessment or assessor in

defining the impact on the environment; this is why in the previous addendum the FSU was modelled with the individual

noise sources and not as one single noise source.

At an earlier EIA stage the individual noise sources expected from the FSU were modelled for a situation whereby the

FSU was to operate with on-board power and four operating vaporizers (Malta’s will only have two). Due to

circumstances of operation, safety and reliability of supply, the FSU will initially operate with on board supply and later,

with shore supply. Active lower deck machinery e.g. boilers for regasification purposes, on board generator, nitrogen

generator etc. will be maintained through her life cycle. Hence, the conclusions from the Noise Report Addendum of 19 th

December 2013 are still valid.

In the case of IPPC reporting for the FSU, due consideration should be given in dealing with the FSU as a single noise

source due to the working areas being classified as ATEX Zones 2 to 0. Although many projects1 have been done to find

ways of measuring ships in harbours or ports, all lack a definitive way of representing the impact of operational ships

within harbour areas as mostly are dealing with noise on board. The only standard that can be used to declare the

emissions from the ship/FSU is EN ISO 2922:2000 “Measurement of airborne sound emitted by vessels on inland

waterways and harbours”. Hence a number of measurements according to said standard should be made prior to the

1 European Neighbourhood and Partnership Instrument Cross-Border Cooperation Mediterranean Sea Basin Programme (ENPI CBCMED) MESP Project “Roadmap on Sustainability Criteria: Guide-lines for Port Environmental Management”; SILENV (Ship InnovativesoLutions to rEduce Noise and Vibrations: www.silenv.eu); International Maritime Organization (IMO) older Resolution A.468 (XII);new Resolution MSC.337 (91) etc.


FSU being in place to define the background noise in the locality. The same set of measurements should be done when

the FSU is in operation – see Figure 4.

The number of measurements made and locations will depend on the final location of the ship. These measurements

should be made to declare the emissions of the ship to the locality.

Figure 4 FSU measurement points.

Monitoringupdate

The previously proposed monitoring positions still hold. But it is also proposed that an exercise to determine the FSU’s

final emissions in place is done along with an additional ‘long term’ measurement in the Tas-Silg area is done along with

the other areas, possibly all long term measurements in Marsaxlokk are done simultaneously. Figure 5 shows the

updated areas for monitoring positions.


Figure 5 Additional 'one time' monitoring positions required for DPS4.

Mitigation

Should, during the initial monitoring of the first operational stages for DPS4, there be detectable changes (constant, or a

confidence level of 90%) in background noise levels by +3dBA at the Marsaxlokk positions; the contractors should enter

discussion with ERA and/or Enemalta about mitigation measures upon being notified of such a situation.

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AnnexB

This is a document supplied from the contractor’s side, listing the final noise model inputs from the contractor. The

result of which is in Figure 3- main document. Below is the email authorizing release of said document.

From: Aplin, Kate [mailto:[email protected]]

Sent: 20 July 2015 10:06

To: AcoustiCal

Cc: Catherine Halpin; Kenyon, Paul; Williams, Rhys; DC Malta; Paul Gauci ([email protected])

Subject: RE: MT1001-SIE_ENG-EGM-0026, Noise Model Documents

Dear Christian

Siemens have confirmed that as long as the documents are published in *.pdf (non editable format) they have no issue

with them being in the public domain.

Best regards

Kate

Kate Aplin

Technical Director / AECOM

The Crescent Centre, Temple Back, Bristol BS1 6EZ, United Kingdom

Mobile: +44 (0) 782 512 2253

Mobile: +356 997 42617

Paul Gauci <[email protected]>

RE: ENEM - AECOM - SGS - 01810 Comments back from ERA regarding the EIS updates1 message

vaccari, roberto (Barcelona) <[email protected]> 31 August 2016 at 08:46To: "Aplin, Kate" <[email protected]>Cc: Paul Gauci <[email protected]>, "Lopez, Gonzalo" <[email protected]>, Matthew Grech <[email protected]>, "[email protected]" <[email protected]>, "Michael Sant ([email protected])"<[email protected]>, DC Malta <[email protected]>, Catherine Halpin <[email protected]>

Hello Kate,

Sorry for my late reply.

I confirm that my statement made reference to the current IPPC process and the studies that have been completed for this.

Regards

Roberto Vaccari

Environment, Health & Safety

Process Safety Development Manager

SGS Tecnos, S.A.

Mobile: +34 689 06 67 52

E-mail: [email protected]

De: Aplin, Kate [mailto:[email protected]]Enviado el: viernes, 26 de agosto de 2016 10:28Para: vaccari, roberto (Barcelona)CC: Paul Gauci; Lopez, Gonzalo; Matthew Grech; [email protected]; Michael Sant ([email protected]); DC Malta; Catherine HalpinAsunto: ENEM – AECOM – SGS – 01810 Comments back from ERA regarding the EIS updates

ENEM – AECOM – SGS – 01810 Comments back from ERA regarding the EIS updates

Dear Roberto

We have received comments from ERA regarding our updated EIS Statement. One of their questions is regarding your letter dated June 22nd which advises that the project changes since the original EIA are compatible with the findings and conclusions of the preliminaryQRA.

ERA’s comment is concerning the penultimate paragraph, where you refer to ‘performing specific and detailed risk analysis studies in the forthcoming phases of the project’. They have interpreted this as possibly meaning that you recommend additional studies to thoseoriginally recommended and that these are in addition to those that we have completed and we are in the process of getting signed of by the relevant competent COMAH Authorities.

I understand from your letter that you are reconfirming that the Preliminary QRA (on which the original EIS was certified) is still valid based on the original assumption that more detailed Risk Assessments would be carried put during the IPPC process. And that the referencein your letter to forthcoming phases of the project is referring to the current IPPC process and the studies that have been completed for this.

Would it be possible for you to either confirm this by email or preferably to update your letter replacing the text ‘particularly in reference to the recommendation of performing specific and detailed risk analysis studies in the forthcoming phases of the project’ with ‘particularlyin reference to the original recommendation of performing specific and detailed risk analysis studies as are currently being processed within the IPPC phase of the project’ or similar words to the same effect, such that the letter may not be misinterpreted thatyou are recommending additional studies to those that are currently being validated by the Authorities.

Feel free to give myself or Paul Gauci a call should you wish to discuss further.

See you in Malta next week

Best regards

Kate





Information in this email and any attachments is confidential and intended solely for the use of the individual(s) to whom it is addressed or otherwise directed. Please note that any views or opinions presented in this email are solely those of the author and do not necessarilyrepresent those of the Company. Finally, the recipient should check this email and any attachments for the presence of viruses. The Company accepts no liability for any damage caused by any virus transmitted by this email. All SGS services are rendered in accordancewith the applicable SGS conditions of service available on request and accessible at http://www.sgs.com/en/Terms-and-Conditions.aspx

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