Kinneil Terminal Gas Fired CHP Plant Project Kinneil... · 1.7 Air Quality 21 1.8 Land Quality, Geology and Hydrogeology 21 ... The CHP Plant is intended to be operated commercially

Kinneil Terminal Gas Fired CHP Plant Project Environmental Statement Volume 1 - Non-Technical Summary BP Exploration Operating Company Limited

14 July 2015

Kinneil Terminal Gas Fired CHP Plant Project Environmental Statement Volume 1- Non-Technical Summary

Atkins 5137345-500-RPT-002 │July 2015 │

Notice This report was produced by Atkins Ltd. for BP Exploration Operating Company Limited for the specific purpose of producing an Environmental Statement for the Kinneil Terminal Gas Fired CHP Plant Project for submission as part of the Section 36 Application for the Project.

Atkins Limited assumes no responsibility to any other party in respect of or arising out of or in connection with this document and / or its contents.

This document has 37 pages including the cover.

Document history

Job number: 5137345 Document ref: 5137345-500-RPT-002

Revision Purpose description Originated Checked Reviewed Authorised Date

Rev A Internal draft Misc. ES JK - 01/07/15

Rev 001 Draft for client comment Misc. ES JK AB 02/07/15

Rev 002 Final Report Misc. ES AM AB 14/07/15


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Table of Contents

Chapter Page 1. Non-Technical Summary 1

1.1 Introduction 1

1.2 Rationale for the Development and Alternatives 3

1.3 Description of the Site and its Surroundings 5

1.4 Description of the Development 7

1.5 Planning and Planning Policy 19

1.6 EIA Methodology 20

1.7 Air Quality 21

1.8 Land Quality, Geology and Hydrogeology 21

1.9 Water Quality 22

1.10 Flood Risk 23

1.11 Noise and Vibration 24

1.12 Ecology 25

1.13 Landscape and Visual 26

1.14 Historic Environment 26

1.15 Transport 27

1.16 Aviation 27

1.17 Socio-economics 27

1.18 Cumulative and In-combination Effects 28

1.19 Summary of Assessment 30

1.20 References 32

Figures Figure 1-1 Location of Kinneil Terminal Relative to its Surrounds .............................................................. 2

Figure 1-2 Location of the Proposed CHP Plant within Kinneil Terminal .................................................... 2

Figure 1-3 Overview of Proposed Construction Programme ...................................................................... 8

Figure 1-4 Estimated Construction Workforce Profile ................................................................................. 8

Figure 1-5 Site Access ................................................................................................................................ 9

Figure 1-6 Indicative Layout Configuration 1 (3GTs, 5 Boilers) - Iso-view ............................................... 13




Figure 1-10 Location of Proposed CHP Plant Relative to Proposed Biomass Plant .................................. 29


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Preface This Environmental Statement (ES) has been prepared in support of an Application under Section 36 (S36) of the Electricity Act 1989 to construct and operate a gas fired CHP Plant at Kinneil Terminal, Grangemouth, Falkirk. The S36 Application is also supported by a Planning Statement.

The ES includes a Non-Technical Summary (NTS), which provides an ‘executive summary’ of the statement and its findings, presented in a non-technical manner. The ES comprises the following three volumes:

Volume 1 NTS;

Volume 2 ES Main Text; and

Volume 3 Technical Appendices.

This volume (Volume 1) comprises the Non-Technical Summary.

A Flood Risk Assessment, a Transport Statement and a report containing ‘Information for Habitats Regulations Assessment - Stage 1 Screening’ have been prepared as standalone reports and are included as part of Volume 3 (Technical Appendices).

The ES and S36 Application documentation may be viewed at the following locations during the statutory consultation period:

Falkirk Council Development Services Abbotsford House David’s Loan Falkirk FK2 7YZ

Grangemouth Library Bo’ness Road Grangemouth FK3 8AG

Scottish Government Library Victoria Quay Edinburgh EH6 6QQ

Grangemouth One Stop Shop 5 York Lane Grangemouth FK3 8BD

The Section 36 Application can be viewed online via http://eplanning.falkirk.gov.uk/online/

Further copies of the main ES and Technical Appendices may be purchased for £250 per hard copy, alternatively these are available on CD free of charge. Copies of the NTS are available free of charge. Please contact Andrew Muir for copies:

Atkins Axis 6 West 10 Holliday Street Birmingham B1 1TF Telephone: 0121 483 5482 Email: [email protected]

If there are any queries on this project, or if you would wish further information please contact: Andrew Muir (via the above contact details).

Kinneil Terminal Gas Fired CHP Plant Project Environmental Statement Volume 1 – Non-Technical Summary

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1. Non-Technical Summary

1.1 Introduction

Overview 1.1.1 BP Exploration Company Limited (hereafter referred to as ‘BP’, or ‘the Applicant’) is seeking to

install a gas fired Combined Heat and Power (CHP) Plant at a location within the existing BP Kinneil Terminal, on the south bank of the Firth of Forth Estuary, in the Kerse of Kinneil.

1.1.2 Kinneil Terminal is adjacent to the PetroIneos Grangemouth Refinery, the Ineos Petrochemical Plant, the Ineos Utility Plant and the Versalis Petrochemical Plant (here after referred to as the Grangemouth Petrochemical Complex). The Terminal is located within Falkirk Council’s administrative area. The location of Kinneil Terminal is shown on Figure 1-1 and the location of the proposed CHP Plant is shown on Figure 1-2.

1.1.3 The Kinneil Terminal processes approximately 40% of the North Sea crude oil production. The oil is brought to the site via the Forties Pipeline System (FPS). The process at the Kinneil Terminal extracts the gaseous hydrocarbons and removes water, stabilises and sweetens the oil (by removing carbon dioxide and hydrogen sulphide), thus making the crude oil safe for further processing, storage and shipment. The oil separation processes result in the production of a dry, clean gas with similar characteristics to natural gas.

1.1.4 If this gas is not used at the rate at which it is produced, the rapid rise in system pressure would necessitate flaring of the gas to atmosphere in the first instance, and either longer term flaring or reduction in FPS crude oil flows from the North Sea. At present the dry gas can only be used by export to a neighbouring plant within the Grangemouth Petrochemical Complex, or through flaring at the Kinneil Terminal. Flaring, storage of this gas and / or use of the gas in the National Transmission System (NTS) are not considered to be feasible options.

1.1.5 The Kinneil Terminal requires steam for heat energy to drive the separation processes, as well as to support intermittent smokeless flaring. The normal steam demand is broadly required in direct relationship to the dry gas production rate; however, occasional flare steam (steam to mix with the flare combustion flame to reduce smoke) is a significant step change addition to this demand. The steam demand is currently supplied by the neighbouring Ineos Utility Plant. There is no steam production facility at the Kinneil Terminal.

1.1.6 The proposed CHP Plant Project is intended to replace the function of the neighbouring Ineos Utility Plant by combusting the dry gas in steam boilers and / or gas turbines (GTs) in order to meet all of the Kinneil Terminal’s process steam requirements. In addition, any surplus energy produced from the dry gas will be converted to electricity (either indirectly (by driving steam turbines) using any excess steam generated), or directly (in the GTs)). Any surplus electricity would be exported to the Grid via a new connection to Grangemouth Substation. The CHP Plant is intended to be operated commercially from the start of 2018 until 2030.

1.1.7 The existing Kinneil Terminal site is an ‘Upper Tier’ listed site under the Control of Major Accident Hazards (COMAH) Regulations 1999 and it has a Permit to operate from the Scottish Environment Protection Agency (SEPA) under the Pollution Prevention and Control (PPC) (Scotland) Regulations1. The proposed CHP Plant will also require a PPC Permit from SEPA.

1.1.8 As the proposed CHP Plant is anticipated to generate more than 50 MW of electrical power (MWe) it requires consent under Section 36 (S36) of the Electricity Act 1989 from Scottish Government. Consequently the proposed CHP Plant Project requires an Environmental Impact Assessment (EIA). The findings of the EIA are presented in the form of an Environmental Statement (ES). This document is ES Volume 1 (the Non-Technical Summary).

Developer Profile 1.1.9 BP is one of the world’s leading international oil and gas companies, with operations in 80

countries and 84,500 employees globally. In the UK, BP is involved in the exploration, development and production of oil and natural gas. BP transports, sells and trades energy products and develops and manufactures petrochemicals for industrial and consumer goods, as well as refining and marketing fuel and lubricants. More information on BP’s operations and environmental policy is available at www.bp.com.


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Figure 1-1 Location of Kinneil Terminal Relative to its Surrounds

Figure 1-2 Location of the Proposed CHP Plant within Kinneil Terminal


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Project Execution, Key Milestones and Programme 1.1.10 The design phase of the proposed CHP Plant commenced Quarter 1(Q1) 2014. A meeting was

held between BP, Atkins and the Scottish Government Energy Consents Deployment Unit (ECDU) in August 2014, where it was agreed that the proposed CHP Plant Project would require an S36 Application and an EIA.

1.1.11 A Scoping Report2 for the proposed CHP Plant Project was submitted to Scottish Ministers on 9th October 2014. The Scoping Opinion3 was received from the ECDU on 10th December 2014. The process of undertaking the EIA then began, culminating with the planned submission of the ES, along with the S36 application in July 2015. Assuming no public local inquiry, or delay, the target date for determination of S36 Application by Scottish Ministers is Q4 2015 / Q1 2016. The application to SEPA for the PPC Permit for the CHP Plant is expected to be submitted in the first half of 2016.

1.1.12 The proposed CHP Plant Project is likely to be constructed by a ‘build own operate’ (BOO) third party companyi. It is anticipated that finalisation of the design and the appointment of the main (BOO) Contractor will be in Q4 2015. Commencement of site preparation works is planned for Q1 2016, with the main construction and commissioning works taking place from Q2 2016, through to Q1 2018. The CHP Plant is intended to be operated commercially from early of 2018 until 2030.

Document Structure 1.1.13 This document is divided into a further 18 Sections, each of which summarises the corresponding

Chapter from ES Main Report (Volume 2) and a further, final, Section providing references.

1.2 Rationale for the Development and Alternatives

Rational and Need 1.2.1 Kinneil Terminal produces a dry gas stream that is very similar to natural gas. The only export route

for the dry gas is as a feedstock or fuel in a neighbouring third party plant. The reliability of this route has, in BP’s view, potential uncertainties in relation to the third party’s internal and external markets. Currently, the only alternative is to flare the gas in the first instance and either continue long term flaring (with reduction in FPS crude oil imports from the North Sea), or cease operations of the FPS crude oil import pipeline entirely (thereby halting oil and gas production from a large part of the North Sea). In order to safeguard production rates at Kinneil Terminal, BP needs to be satisfied that there is a long term and secure way to ensure that the dry gas can be ‘removed’ from the process.

Alternatives Proposed Alternatives to the CHP Plant

1.2.2 Five possible alternative options for the use of the dry gas have been identified and considered:

flaring: - is not considered to be a suitable option due to the existing Kinneil PPC Permit limitations

and compliance with current operating guidance and legislation for this industry, storage of the gas:

- is not feasible as the gas volumes are too great and the costs would be prohibitive, export to the NTS for use as commercial fuel:

- is not feasible as a result of the gas composition, which contains more ethane and propane than is acceptable for commercial natural gas;

use by third parties as a fuel or feedstock: - is feasible and is the current method for use of the dry gas. However, this option is

associated with significant business risk for BP and the FPS generally as BP is wholly dependent on the third party’s gas use and the third party’s business operations. Therefore, FPS is continually exposed to the third party’s business risks, with no ability to influence these. Due to the quantities and nature of the dry gas, there is no alternative local third

i Projects of the Build-Own-Operate (BOO) type involve a private developer financing, building, owning and operating a facility, (e.g. the CHP Plant). The BOO would be required to construct the Project in accordance with agreed design specifications


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party that could use the dry gas. Furthermore, global markets are not attractive to shipping the dry gas product elsewhere; and

use within the Kinneil Terminal (i.e. the proposed CHP Plant Project): - is the preferred option in terms of risk and in terms of sustainability of the FPS business.

The Kinneil Terminal requires steam for processing operations and to support intermittent smokeless flaring. Thus, the primary function of the CHP Plant will be to produce steam for use in the Kinneil Terminal. It is intended that any surplus steam is to be used to generate electricity, which can be used for export to the Grid (via Grangemouth Substation).

Site Alternatives

1.2.3 For new build ‘standalone’ projects the justification of site selection is usually one of the main areas that requires the consideration of alternatives. The proposed CHP Plant Project will use the dry gas produced at the Kinneil Terminal and supply steam to Kinneil Terminal, and so the CHP Plant is best located close to the Terminal.

1.2.4 An area to the east, outside the Kinneil Terminal boundary, was identified and considered. Apart from being a greenfield site, this location was discounted for a number of reasons including: the distance from the source of the dry gas and steam supply (resulting in a minor increase in hydrocarbon gas leak risk due to the longer length of pipework and thermal energy losses from the steam pipework), the requirement to route new pipes directly through the Terminal (which would require a shutdown, or working amongst a live plant) and the need to extend Kinneil Terminal’s high security boundary fencing.

1.2.5 Within the Terminal there are only three areas which have the necessary space to house the CHP Plant, an area to the north, an area to the south and an area to the west:

the area to the north is considered to be unsuitable due to its close proximity to the high and low level gas flares;

the area to the south is not considered to be suitable as it needs to remain free from obstacles to minimise the potential effects of a gas release at Kinneil Terminal; and

the area to the west has sufficient space, and is located the shortest distance from the dry gas supply and steam delivery pipes. It is also the preferred option in terms of meeting safety criteria.

1.2.6 All three areas are brownfield sites and are within the existing high security boundary fencing for Kinneil Terminal. However, only the western area is suitable for use as the CHP Plant site and this is the site that has been selected

Summary 1.2.7 Taking all factors into consideration, the use of the dry gas on a site located within and to the west

of the Kinneil Terminal (i.e. the proposed CHP Plant Project) is the preferred option.

1.2.8 In addition to providing an acceptable route to utilise the dry gas, providing process steam for the terminal and generating surplus electricity for export to the grid, the proposed CHP Plant Project is expected to provide the following associated benefits:

safeguarding production rates at Kinneil Terminal which will assist with local and national economic stability as it will: - help to ensure the continued security of jobs at the Kinneil Terminal and in the North Sea oil

and gas fields which export oil through FPS, - help to ensure the ongoing nationally significant economic benefits associated with FPS

and the North Sea oil & gas installations that export oil via FPS, - help to ensure the continued security of jobs for the employees of related downstream

industrial processes; and introduction of a significant demand for construction personnel and support services during the

27 month construction programme.


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1.3 Description of the Site and its Surroundings

CHP Plant Site Location 1.3.1 The proposed CHP Plant will be located on the western side of the existing Kinneil Terminal, as

indicated in Figure 1-1. An Ordnance Survey (OS) grid reference of NS 960 805 is considered to be representative of the centre of the Kinneil Terminal. The approximate centre of the CHP Plant Site is at OS grid reference NS 956 804.

1.3.2 The proposed Site is located in the Forth Valley within the low lying coastal plain of the southern shore of the Forth Estuary, The shoreline of the Forth Estuary, part of the Firth of Forth Special Protection Area (SPA), Ramsar site and Site of Special Scientific Interest (SSSI), forms part of the northern boundary of the Kinneil Terminal. Kinneil Kerse and farm land lies to the east, with the village of Bo’ness beyond. Grangemouth Road (A904 trunk road) bounds the south and south west of the Kinneil Terminal. Bordering the A904, to the south, is an area of Ancient Woodland, with arable farmland containing scattered properties further south. The River Avon runs along the north western boundary of the Kinneil Terminal (and the CHP Plant Site), with the Grangemouth Petrochemicals Complex immediately beyond the River to the west and north west.

CHP Plant Site Description 1.3.3 The overall CHP Plant Development Site is on brownfield land within the Kinneil Terminal boundary

and comprises four areas:

the main CHP Plant Site, which is to the west of the Kinneil Terminal; and three small areas that have been identified on the eastern side of the Kinneil Terminal for use

as possible Laydown Areas during the construction phase of the proposed CHP Plant Project.

1.3.4 The location of the CHP Plant Site is shown on Figure 1-2 bounded in red. The main CHP Plant Site covers an area of approximately 4.5 hectares (ha). The locations of the potential Laydown Areas are shown on Figure 1-2 bounded in blue. The CHP Plant Site and three areas bounded in blue are all used as storage / Laydown Areas at present.

1.3.5 The main CHP Plant Site houses two firewater ponds. As part of the proposed CHP Plant Project the two firewater ponds will be infilled. The western pond is redundant but the eastern pond remains part of the Terminal’s fire management strategy. Known underground services are a public sewer which is understood to cross the site from east to west and 33 kV cables that run along an existing fence line in a roughly south to north direction. Otherwise, the site is not known to have been built on previously.

1.3.6 The location of the existing dry gas supply from the Kinneil Terminal to the neighbouring Ineos Petrochemical Plant is in the north east corner of the proposed CHP Plant Site. This is also the location at which the steam supply from the Ineos Utility Plant is received at Kinneil Terminal. It is intended that the CHP Plant Project will interface with these connections.

1.3.7 To the immediate south of the proposed CHP Plant Site (within the Kinneil Terminal boundary) is an area containing large crude oil storage tanks owned by PetroIneos. To the north of Laydown Area 1 are the two Kinneil Terminal Flare Stacks. The River Avon is to the west of the proposed CHP Plant Site, approximately 10 m away at its closest point. Kinneil Terminal, Kinneil Kerse and farm land lies to the east of the proposed Development Site.

Topography and Land Use 1.3.8 The topography of the area within which the CHP Plant site lies is largely open and flat. The

landform rises to the south (beyond the A904) and towards the east from about 50 to 70 m above ordnance datum (AOD), to form a series of rolling coastal hills. The site level currently ranges from 3.1 m AOD to 4.1 m AOD. In order to reduce the risk of flooding to an acceptable level, the area of CHP Plant Site that will be built onii will be raised to +4.62 m AOD.

ii The area that will be built on (and hence raised) includes all areas where there will be buildings, structures, equipment, roads and

paved areas.


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1.3.9 Land use in the vicinity of the Terminal is comprised of a mixture of industrial commercial, residential and agricultural uses. To the north west, west and south west the land is predominantly built up and land use is dominated by industry and housing. The land to the south and south east is predominantly farm land, with some woodland.

Settlements, Amenities and Transport Links 1.3.10 The nearest settlements to Kinneil Terminal are Grangemouth, which borders the Grangemouth

Petrochemical Complex (to the west), Bo’ness (to the north east) and Polmont (to the south west), all of which are situated approximately 2 to 3 km away. The nearest dwellings (Polmonthill Cottage and Inveravon Cottages) are approximately 0.6 km from the proposed CHP Plant Development Site boundary, to the south and south west. The population within the area around the Kinneil Terminal falls into the following wards4.

Grangemouth 18,724; Bo’ness and Blackness population 14,791; and Lower Braes population 13,114.

1.3.11 As would be expected, there is a range of community facilities (e.g. schools, parks, libraries, churches, health centres etc.) associated with the nearby residential areas. Although the proposed CHP Plant lies within a largely industrial area, there are several public footpaths and areas of recreational value in the vicinity of the Kinneil Terminal. Recreational resources within 2 km include Grangemouth Golf Club and Grangemouth Sports Stadium.

1.3.12 Kinneil Terminal has excellent communication links. Grangemouth Road (A904) bounds the south and south west boundaries of the Kinneil Terminal. The A905 is in close vicinity of the CHP Plant site and both the A905 and A904 connect to the M9 Motorway which is located approximately 2 km south. The M9 links Grangemouth with Edinburgh, Falkirk and Stirling.

1.3.13 Grangemouth Docks is located to the north west. The Kinneil Terminal is just over 7 km to the south east of the Kincardine Bridge and approximately 17 km to the west of the Forth Road Bridge. The nearest main airport is Edinburgh (Turnhouse), over 20 km to the south east. The Bo’ness and Kinneil railway line comes in from Birkhill to the south and veers east, running largely parallel to the A904 and terminates at Bo’ness Station.

Air Quality 1.3.14 Falkirk Council has four active Air Quality Management Areas (AQMAs), the closest of which is the

Grangemouth AQMA5. This was designated in 2005 and covers an area encompassing the Grangemouth Petrochemical Complex and adjacent areas. The Grangemouth AQMA was declared as a result of breaches of the fifteen minute Air Quality Strategy (AQS) objective for sulphur dioxide (SO2), which were due to elevated emissions of this pollutant from industrial sources in the area.

1.3.15 Falkirk Town Centre AQMA is the second closest AQMA to the Development Site, located approximately 6.5 km to the west. It was declared in 2013 due to exceedences of the AQS objectives for nitrogen dioxide (NO2) and particulate matter (PM10).

Geology, Hydrogeology and Hydrology 1.3.16 The Forth Estuary lies within a sedimentary basin of the Carboniferous era, comprising

carboniferous limestone, millstone grit and coal measures. The Forth area is covered by superficial quaternary deposits of raised beach and marine deposits, boulder clay, glacial sand and gravel and alluvium.

1.3.17 Made Ground deposits of unknown thickness are understood to be present across most areas of the proposed Site. Made Ground overlays former tidal flat and tidal river deposits of clays, silts, sands and gravels to approximately 35 m bgl. The solid geology beneath the CHP Plant site is Upper Limestone Formation from the Clackmannan Group.

1.3.18 Boreholes records indicate that groundwater is encountered towards the base of the shallow Made Ground and / or within the top of the underlying silty clay (superficial deposits) at depths between 0.8 m and 4.0 m bgl. The regional groundwater flow is anticipated to be towards the Forth Estuary.


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1.3.19 The proposed CHP Plant Site is underlain by the Stirling and Falkirk bedrock and localised sand and gravel aquifer. This is a moderately productive aquifer with overall quality status described as 'poor'. The CHP Plant Site is within a Drinking Water Protection Zone (DWPZ) where the groundwater body has a 'Pass' status.

1.3.20 The Forth Estuary is the dominant surface water feature in the area. The ‘V’-shaped Estuary is a sheltered arm of the North Sea and the estuary of the River Forth. From the tidal water limit at Stirling to the Isle of May the Forth is 96 km long6 and covers an area of 1,670 km2. In the offshore areas of the eastern Firth the water is deep (sometimes over 60 m in depth), saline, continuous with the North Sea and therefore categorised as marine. The area of the Estuary closest to the Kinneil Terminal is referred to as the Middle Forth Estuary. In 2008 SEPA classified the Middle Forth Estuary as having an overall status of Moderate ecological potential with overall ecological status of Moderate and overall chemical status of Pass.

1.3.21 The River Avon runs along the north western boundary of Kinneil Terminal, and separates the Terminal from the Grangemouth Petrochemical Complex. The stretch of the River Avon adjacent to Kinneil Terminal is tidal.

1.3.22 There are no current, licensed groundwater abstractions, consents to discharge to ground or groundwater, or recorded pollution incidents on or within 500 m of the CHP Plant Development Site Boundary. There are five licensed water abstraction points within 5 km of Kinneil Terminal, the nearest being 2 km away. The Kinneil Terminal has consent to discharge hydrotest water and clean surface water runoff to the River Avon and waste water (via an Effluent Treatment Plant (ETP)) to the Forth Estuary. There are no discharges to public sewer from Kinneil Terminal.

1.3.23 Public water supply is mainly obtained from reservoirs as well as some lochs rather than groundwater abstraction.

Flood Risk 1.3.24 A number of historical flooding events have affected the Grangemouth area; however, flooding has

not been recorded for the proposed CHP Plant Development Site. The Site is at high risk from tidal flooding, low risk from fluvial flooding and at low risk from ground water flooding (however, the main influence on groundwater levels within the CHP Plant Development Site will be the tidal levels and groundwater is likely to be in hydraulic connectivity with the Estuary).

Natural Heritage 1.3.25 There are several nationally and internationally designated sites of importance for nature

conservation in the vicinity of the proposed Development. The nearest is the Firth of Forth SPA / Ramsar site / SSSI, which is just under 500 m from the proposed Development Site boundary at its nearest point. As noted previously, there are several areas of Ancient Woodland to the south of the site, on the south side of the A904 / A905. The closest ancient woodlands are Grangemouth Road Woods and Avon Banks Wood (which forms part of the Avon Gorge SSSI).

1.3.26 There are no landscape designations on the proposed Development Site. Part of the South Bo’ness Special Landscape Area (SLA) is within 2 km of the proposed Site.

1.3.27 The proposed CHP Plant Development Site contains no designated heritage assets. However, a considerable number of designations, of high to very high value, are present within 1 km, including parts of the Antonine Wall (AW) World Heritage Site (WHS), several Scheduled Monuments and a number of listed buildings.

1.4 Description of the Development

Construction and Commissioning Phase Management

1.4.1 The appointed lead Contractor will prepare a Construction Environmental Management Plan (CEMP) and this will be submitted to Falkirk Council in advance of any construction works being undertaken. The CEMP will ensure that the effects of any potential construction impacts will be avoided or, where this is not possible, minimised and controlled. The CEMP will include, for example, procedures for waste management, transport management, control of pollution (including prevention of contaminants entering water courses and groundwater) and dust control and will identify and describe good site practice measures.


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1.4.2 A site investigation (SI), including testing for contaminants has been undertaken at the CHP Plant Site; however the results from this will not be available in time for use and consideration in the EIA. The results of the SI will be submitted to Falkirk Council during the S36 Application determination period and will be used to inform the CEMP / WMP.

Construction Programme, Working Hours and Workforce

1.4.3 It is expected that construction and commissioning (hereafter referred to as 'construction phase') of the proposed CHP Plant Project will take up to 27 months to complete. An overview of the proposed construction programme is provided in Figure 1-3. Preliminary construction work is expected to commence in Quarter 1 of 2016, with commercial operation planned for the start for 2018, or as soon thereafter as possible.

Figure 1-3 Overview of Proposed Construction Programme

1.4.4 Construction hours will be in part dictated by the project schedule, however typical working hours are expected to be Monday to Friday, 38 hours week (07:45 to 16:30; with a 14:00 finish on Friday). If the project is behind schedule alternative options may be considered

1.4.5 The construction workforce is expected to peak at approximately 400 for a 10 month period. An indicative construction manpower profile is provided in Figure 1-4.

Figure 1-4 Estimated Construction Workforce Profile

Construction Worker Facilities

1.4.6 The location of proposed CHP Plant Site is within an area that could be affected by a flammable gas release. BP's policy is not to locate staff permanently within such an area unless they are in a blast resistant building. For construction work or overhaul programmes, the number of staff located on site is kept to a minimum. Thus, it is proposed to locate construction worker facilities outside the proposed CHP Plant Site wherever reasonably practicable. As part of a separate project, and irrespective of the proposed CHP Plant Project, BP intends to create a Contractor Compound on the fields to the east of Kinneil Terminal. It is expected that the Compound will be used for various BP projects and that it will include

offices; welfare facilities (e.g. mess room, showers); and car parking facilities.


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1.4.7 The construction of the Contractor Compound will be the subject of a separate and independent planning consent with construction works being anticipated to commence around Q4 2015. Thus, the Compound should be ready in time for use for the proposed CHP Plant Project. In the event that the Compound is not available for use by the CHP Plant Project, an alternative solution for the location of the construction workers facilities will be found and agreed with Falkirk Council.

Construction Working Areas

1.4.8 Due to the nature of the CHP Plant location (i.e. within an area that could be affected by a flammable gas release), it is the intention to minimise onsite fabrication works. Attempts will be made to modularise equipment for ease of installation onsite and to enable some of the equipment finishing works (e.g. welding and fixing component parts) to be completed offsite, prior to final delivery. The location of any offsite works has not been finalised but it is likely to be in Grangemouth Docks area and at a location that is already approved for this type of use.

1.4.9 For onsite works, some of the area within the CHP Plant Site will be available for use during the construction period (i.e. as a general Laydown Area and for storage). In addition, there are three areas bounded in blue on Figure 1-2 that could also be used as potential Laydown Areas and for storage if required.

Site Access

1.4.10 During the construction period, access to the proposed CHP Plant Site is expected to be from the south via Gate 10 (off the roundabout Grangemouth Road (A904)), or, via the West Gate, which is at the intersection of Forties Road and Grangemouth Road (as indicated on Figure 1-5). Access to the proposed Contractor Compound will be either via Kinneil Terminal, via Gate 10 or via a new access off Grangemouth Road.

Figure 1-5 Site Access

Construction Traffic

1.4.11 The peak workforce (400) is expected to result in approximately 150 vehicles entering and leaving the site at the start and end of working shifts (i.e. during peak periods).There are expected to be around 6,000 Heavy Goods Vehicles (HGVs) arriving at Kinneil Terminal over the construction period, with average truck movements of 8 per weekday. At the peak of construction there may be up to 60 trucks per day arriving at the site. HGVs are expected to access the site via the M9, and enter the site itself through the Gate 10 or the West Gate. It is estimated that there will be 30 abnormal loads requiring access to the site during the construction period. These are mostly expected to be 4-5 m wide, and none is expected to be over 10 m wide. The preferred route for abnormal loads is from either the M9 or Grangemouth Port.


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Construction Works and Execution

1.4.12 At this stage in the Project, a schedule of works and a detailed construction programme are not available. However, activities associated with the construction phase are likely to be fairly standard to any construction project for industrial facilities.

1.4.13 There are four phases of construction, some of which will overlap:

site preparation (estimated to take 2 months); civil works (estimated to take 8 months); mechanical works (estimated to take 14 months); and commissioning (estimated to take 5 months).

1.4.14 Site preparation and preliminary civil works have been addressed as part of the EIA for the proposed CHP Plant Project. However, it is likely that BP will apply for a local planning consent to undertake these works in advance of being granted the S36 Consent. The reason for this approach relates solely to trying ensure that the CHP Plant can be constructed in time to commence commercial operation at the start of 2018.

1.4.15 Foundation for buildings / structures / equipment will be piled using approximately 2,000 pre-cast concrete piles, each with a cross-sectional area of 270 mm2. The main environmental impacts associated with piling typically relate to noise and vibration. Piles will be driven using low noise equipment and this method has been used recently in the Terminal to install additional infrastructure with no adverse environmental impacts reported. The use of augured piling techniques could further reduce the noise levels; however, this is not considered practical for the proposed CHP Plant Project on the basis of the ground conditions at the site, in particular the depth to groundwater. The auger method of piling is considered to be more likely to have the potential to result in water and soil contamination of the associated concrete pile, which could reduce the solidity of the piles to an unknown and potentially unacceptable level.

1.4.16 Piling activities and crushing pile tops are expected to take place after the preliminary civil works over a three months period. It has been assumed that there could be a maximum of four hydraulic hammer rigs on the site at any one time. Once this is complete, the last stages of the civil works are digging subsurface foundations; and creation of slabs and road.

1.4.17 The 14 month period of mechanical works involves: material deliveries, module deliveries, construction of general structures, auxiliary assembly, welding and testing, cabling and wiring and mechanical fitting. The maximum height of the temporary construction cranes is not anticipated to be any greater than 70 m.

1.4.18 As part of an on-going programme of site maintenance works, it is understood that BP plans to reinforce the embankment along the River Avon and, at the same time, raise the height of it. It is expected that these works would take place prior to the operational phase of the CHP Plant Project. The reinforcement / raising works are outside the scope of the proposed CHP Plant Project.

Construction Materials

1.4.19 It is estimated that raising the site level will require approximately 22,000 m3 of fine stone aggregate. Soils and crushed concrete pile resulting from site preparation and civils works will be reused onsite as fill material where it is feasible to do so (and subject to contaminant testing results). Where it is practical and competitive, vendors will be encouraged to bring in materials and equipment via Grangemouth Dock. It is anticipated that most of the larger items will be brought in via this route.

Construction Emissions, Discharges and Wastes

1.4.20 The general philosophy for the Project will aim to ensure that emissions, discharges and waste generation from construction activities will be prevented or minimised at source. For discharges and wastes that cannot be avoided, the preferred options will be re-use, recycling or recovery and finally disposal. Any waste disposal and waste recovery activities will be undertaken in accordance with relevant legislation. The construction of the proposed CHP Plant Project is not expected to result in the generation of any atypical construction emissions, discharges or wastes.

1.4.21 Emissions to atmosphere will primarily result from activities that could generate dust and / or exhaust gas emissions resulting from the use of vehicles and diesel fuelled equipment.

1.4.22 Construction emissions and wastes are expected to be primarily generated as a result of general site preparation works, civil works and commissioning.


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1.4.23 The largest volume of waste material generated is expected to be soils and crushed concrete pile resulting from site preparation works. Subject to the findings of the SI and contaminant testing, soils (and crushed concrete pile tops) will be reused onsite as fill material. If the SI determines that existing excavated material requires treatment (onsite or offsite) this will be discussed and agreed with Falkirk Council and SEPA and incorporated into the CEMP.

1.4.24 Other than soils and crushed pile tops, the main wastes are likely to consist of general waste construction materials (e.g. metal, wood and plastic). There could also be small quantities of waste chemical substances (e.g. paints, solvents, fuels, oils and lubricants). General packaging waste will either be removed by the suppliers for re-use or removed by licenced contractors. In addition, construction worker facilities are anticipated to generate domestic and office type wastes. All wastes will be handled, stored and disposed of in accordance with good practice and the relevant legislation.

1.4.25 Any fuel or chemicals that are stored onsite for use during the construction period will be stored in bunded areas or double skinned storage tanks (as appropriate) to protect against leakage and spills to ground.

1.4.26 Construction of the proposed CHP Plant Project will not result in any routine aqueous discharges. Occasion discharge may occur for example as a result of plant / vehicle washing and from the de-watering of the firewater ponds. Pressurised systems will require hydro-testing to confirm their integrity prior to operation. As the waste water from this process will be effectively clean, it is the intention to re-use this water as make-up for the Terminal’s existing wet cooling towers, or in other grey water systems.

1.4.27 Surface water runoff and site drainage could also generate an aqueous effluent. Any water that could contain contaminants will be tested to confirm its suitability (or otherwise) for discharge. All discharge / disposal options will be discussed and agreed with SEPA prior to discharge.

Process Overview 1.4.28 The proposed CHP Plant will involve the installation of a number of GTs (with Heat Recovery

Steam Generators (HRSGs)) and / or gas fired steam boilers (with one or more steam turbines). The combustion units will utilise the surplus dry gas that is produced at Kinneil Terminal. The CHP Plant will provide Kinneil Terminal with steam for processing (heating) purposes and to support intermittent smokeless flaring. The normal process steam demand is broadly required in direct relationship to the dry gas production; however, the occasional requirement for flare steam (steam to mix the combustion flame to reduce smoke) is a significant step change addition to this demand.

1.4.29 Surplus dry gas and steam will be used to generate electricity, which will be used to support the needs of Kinneil Terminal and for export of any surplus electricity to the Grid. The surplus electricity is expected to be exported in underground cables to the existing Grangemouth Substation approximately 1 km away. New cables will need to be laid for this function. The onsite 275 kV switchyard and new connection cables to the substation are expected to be supplied and installed by Scottish Power Electrical Networks (SPEN). The proposed CHP Plant Project includes the civil enabling works and the installation of the electrical transmission equipment within the CHP Plant Site area. However, any planning consents and environmental impact considerations in relation to the electrical connection external to the CHP Plant Site are outside the scope of the proposed CHP Plant Project; these will be the responsibility of SPEN and are not considered further herein.

1.4.30 The CHP Plant will also require a natural gas supply for backup, for example, when steam is required but dry gas is not available. Negotiations are ongoing to secure the natural gas supply. Any planning consents and environmental considerations for the gas connection are outside the scope of the proposed CHP Plant Project. These are expected to be completed by the gas network operator and are not considered further herein. In the event that natural gas is unavailable when required as a back-up fuel, it is intended to use propane gas on a short term basis (typically this is expected to be for a few days per year).

Project Design and Evolution 1.4.31 First and foremost the design of the CHP Plant needs to meet the requirements of Kinneil Terminal

by combusting the dry gas at the rate at which it is produced (without provision for storage) and by producing the process steam required for use within Kinneil Terminal. The dry gas is projected (based on 2014 data) to have a maximum thermal energy content of 323 MWth in 2018, which will reduce to approximately one third of this value by 2030. In the short term, the dry gas supply will


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fluctuate continuously with the flow rate being generally within 30% of the maximum projected rates however it will at times vary to a greater extent and occasionally it could reduce to zero.

1.4.32 The CHP Plant also needs to be capable of operating on a backup fuel so that it would be able to generate steam when dry gas was not available (e.g. if the Terminal needed to start from ‘cold’). Secondary requirements include conversion of surplus dry gas energy to electricity (the electricity will be used to supply Kinneil Terminal's needs, with any excess being exported to the National Grid). Consequently, the design needs to incorporate a high level of flexibility, to ensure it can cope with dry gas compositional variations, as well as factors such as uncertainties in the predictions of crude oil production rates and the future of the electricity market.

1.4.33 The appointment of the BOO Contractor (due Q3 2015) and the detailed design phase (Q4 2015) will not take place until after completion of the ES and submission of the S36 Application. This means that final design is not available for the EIA. However, it is considered that the level of information available and the design works undertaken to date are sufficient to allow a robust assessment of the potential environmental effects of the proposed CHP Plant Project.

1.4.34 The main area of uncertainty in the design relates to the selection and Configuration of the power generating equipment (i.e. steam boilers GTs and HRSGs and steam turbines). The other components of the Project (e.g. the gas plant, cooling systems, demineralised water treatment, materials storage and switchyard) are well defined, whatever Configuration is selected.

1.4.35 The issues associated with the selection of the power generating equipment relate to a number of factors, in particular:

variability of the dry gas production (e.g. fluctuations in composition and rate of production); uncertainty in the projected dry gas production rates; and uncertainty in the future of the electricity market.

1.4.36 These factors mean that the design needs to incorporate a high level of flexibility and that the different options for the final design are associated with different levels of commercial risk.

1.4.37 In the absence of a final design, it was proposed that the best way to proceed with the EIA would be to use the ‘Rochdale Envelope’ approach to assess the possible configuration options. As part of this approach, where there are differences between these options and operating scenarios, and where these are considered to be material to the EIA process, a ‘worst case’ assessment will be carried out. The ‘worst case’ Configurations and operating scenarios need to be representative of a realistic worse case (to result in likely effects). The worst case configurations and operating scenarios may be different for different EIA topics (e.g. what is worst for air quality may not be worst for noise etc.).

1.4.38 In March 2015 two indicative layout configurations were produced for use in the EIA under the Rochdale Envelope approach. These layouts were based on the proposed CHP Plant Project having at least one GT but no more than 3GTs (each GT would have a HRSG). In addition to the GT(s) a mix of high pressure (HP) and medium pressure (MP) boilers was selected to ensure that the CHP Plant could use all of the dry gas and to ensure that there was sufficient flexibility available in terms of redundancy / standby plant.

1.4.39 The two indicative layout configurations were identical in all ways other than at the northern end of the development, where the GTs and boilers are to be located. In combination, the two extremes of indicative layout configurations were considered to encompass the envelopes of the preliminary CHP Plant configurations being proposed by candidate third party construction companies as well as other reasonably foreseen options. The two indicative configurations are illustrated in Figure 1-6 and Figure 1-7.

1.4.40 The EIA process began in earnest using the two ‘extreme’ indicative layouts (Configurations 1 and 2). The impact assessment of the proposed CHP Plant Project for all environmental topic areas is based on layout Configurations 1 and 2, with the exception of air quality (and the assessment of ecological effects relating to air quality).

1.4.41 As the EIA progressed a number of discussions were held with SEPA to ensure that the level and scope of assessment (particularly for the air quality assessment of stack gases), under the Rochdale Envelope approach, would be sufficient to enable SEPA to determine whether the proposed CHP Plant Project was ‘consentable’, under PPC Regulations.


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Figure 1-6 Indicative Layout Configuration 1 (3GTs, 5 Boilers) - Iso-view



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1.4.42 After careful consideration, SEPA requested that, even if there was no intention to use all of the installed steam and power generating equipment at any one time, the assessment needed to consider the total installed capacity of the proposed CHP Plant Project. SEPA also requested that the assessment should consider not just the maximum amount of the dry gas that could be used, but the total maximum volume of fuel that could be combusted at any one time (i.e. dry gas supplemented with natural gas). Whilst it was recognised that when there is sufficient dry gas to meet the needs of Kinneil Terminal, there is no intention to operate the proposed CHP Plant by supplementing the dry gas with natural gas, it was felt that this was a theoretical possibility and as such needed to be considered.

1.4.43 The information from this consultation process was fed back to the design engineers. This, along with the evolution and enhancement of the design, resulted in the Project Engineers refining the two ‘extreme’ Configurations to develop four indicative Configurations specifically for the air quality assessment. The reasonably envisaged, new combustion equipment Configurations were considered to be a number of GTs (from zero to three) and a number of combustion boilers, with the number of these increasing as the number of GTs decreases. Each GT would have an associated HRSG with supplementary firing. The indicative options are:

Configuration 3 (Option 1): 0 GTs, 5 HP boilers, 2 MP boilers, (i.e. a total of 7 stacks); Configuration 4 (Option 2): 1 GTs,4 HP boilers, 2 MP boilers, (i.e. a total of 7 stacks); Configuration 5 (Option 3): 2 GTs, 2 HP boilers, 2 MP boilers, (i.e. a total of 6 stacks); and Configuration 6 (Option 4): 3 GTs, 0 HP boilers, 3 MP boilers, (i.e. a total of 6 stacks).

1.4.44 The outer extremes of the new indicative configurations (No. 3 with 0 GTs and No. 6 with 3GTs) are illustrated in Figure 1-8 and Figure 1-9.



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1.4.45 In addition to the four refined indicative Configurations (numbers 3 to 6), a set of criteria were developed to provide limits for key elements of the overall design, for whatever final design Configuration and layout was selected. These are:

maximum thermal input capacityiii 549 MWth; maximum rated electrical generating capacity 159 MWe; maximum combined GT thermal input capacity 270 MWth maximum combined steam boiler thermal input capacity 445 MWth maximum combined HRSG supplementary firing thermal input capacity 183 MWth; and maximum number of combustion units (GTs and boilers combined) 10.

Operation of the CHP Plant Project Management

1.4.46 The proposed CHP Plant will require a PPC Permit to operate under the PPC (Scotland) Regulations 2012, which aim to provide an integrated approach to pollution control preventing emissions into air, water or land wherever this is practicable, taking into account waste management. Where prevention is not possible, the aim is to minimise emissions in order to achieve a high level of protection for the environment as a whole. Under the PPC (Scotland) Regulations, the proposed CHP Plant will be required to demonstrate the application of Best Available Techniques (BAT).

1.4.47 Operation and management of the facility will be undertaken in accordance with:

the requirements of the Permit to operate, which will be issued and regulated by SEPA; and standard industry good practice guidance and legislation.

iii It is intended that the CHP Plant operates only on dry gas to a maximum of 323 MWth. The maximum thermal input capacity is the total input capacity of all of the installed combustion equipment. There would be no value in operating all of the installed combustion equipment as some of the steam generated could not be used or converted into electrical power and so it would effectively be wasted. The maximum thermal energy that could ‘usefully’ be used is in the region of 400 to 440 MWth.


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1.4.48 The existing Kinneil Terminal is accredited under ISO 14001 Environmental Management Systems (EMS). It is expected that the EMS will be extended to cover the operation of the new CHP Plant. The existing Kinneil Terminal is an Upper Tier site under the COMAH Regulations. The proposed CHP Plant would not itself be a COMAH site; however, the operation of the CHP Plant Project will need to comply with the requirements of relevant safety related legislation.

Design Life and Operating Philosophy

1.4.49 The CHP Plant is expected to be in commercial operation from 2018 to 2030. The standard design life for the equipment is 25 years. If operation after this period is still desirable and feasible, the necessary permits will be obtained for continued use. If operation after this period is not desirable, or feasible, the CHP Plant will be decommissioned.

1.4.50 The CHP Plant is designed to support the operational requirements of Kinneil Terminal and therefore contains an element of redundant equipment. As the proposed CHP Plant Project progresses and the dry gas availability diminishes, some or all of the GTs and / or HP boilers may need to be shutdown.

1.4.51 It is intended to operate the proposed CHP Plant on a 24 hours a day, seven days a week basis, in line with the steam and power requirements for operation of the Kinneil Terminal.

Staffing, Access and Facilities

1.4.52 It has been estimated that there will be a maximum of 20 new staff in total, with not more than 4 new staff working per shift. Typically, staff are expected to work either 8 or 12 hour shifts. It is not anticipated that there will be a need for more than three staff changes in any 24 hour period.

1.4.53 Site access will be via the Gate 10 (see Figure 1-5). Workers at the CHP Plant will use the existing staff and parking facilities within Kinneil Terminal. The CHP Plant is expected to be operated under similar constraints to the Kinneil Terminal itself. Therefore operational staff will only visit the CHP Plant on a temporary basis throughout the working day. The CHP Plant Central Control Room (CCR) is expected to be incorporated into the existing blast resistant CCR at the Kinneil Terminal; however, if that is not possible due to space constraints, a control building will be constructed within the CHP Plant Site.

Process Inputs, Outputs and Connections

1.4.54 The proposed CHP Plant will be supplied with the following main resource inputs:

dry gas; natural gasiv (as a backup fuel); electrical power (import via 33 kV busbar); nitrogen and instrument / service airv; potable water; and condensate return.

1.4.55 The proposed CHP Plant will produce the following ‘outputs’:

process steam (for heating); flare steamvi; and power (for export via 33 kV busbar).

1.4.56 The CHP Plant will share information with the Kinneil Terminal’s distributed control system (DCS) and safety shutdown system.

iv In the event that natural gas is unavailable as a back-up fuel at the time required, it is intended to use propane gas as a short term back-up fuel (typically this is expected to be for a few days per year at most). Propane gas would be imported by existing pipework from existing storage facilities within the Grangemouth Petrochemical Complex using existing systems (that are used currently for a cold start of Kinneil Terminal).

v It has not yet been decided whether nitrogen and instrument air will be supplied by the Kinneil Terminal or generated / stored on the CHP Plant Site. These facilities have not been shown on any of the indicative layout plans. Such facilities, if required, would be relatively small in relation to the other structures and equipment on the site.

vi Flare steam is simply process steam that is be used to enable smokeless flaring.


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Operation, Equipment and Structures 1.4.57 The main elements and physical features of the proposed CHP Plant Development include:

gas reception area; GT Building (with GT(s) and HRSG(s)); steam boilers, each with a canopy roof; steam turbine building; air cooled condensers; two switchyard areas and transformers; water storage tanks (for raw water, demineralised water and firewater); water treatment plant (to produce demineralised water); chemical / maintenance store; and emergency generator and fire pumps.

1.4.58 The largest building will be the steam turbine building (approximately 88 m x 26 m). It is anticipated that buildings will be no more than 25 m in height and the stacks no more than 50 m. The stack height of 50 m is compatible with the height of the majority of stacks that exist elsewhere within the wider Grangemouth Petrochemicals Complex. By way of comparison, the existing flare stacks at Kinneil Terminal are between 46 m and 88 m in height.

1.4.59 The existing dry gas supply from the Kinneil Terminal to the Grangemouth Petrochemical Complex is located in the north east corner of the intended CHP location and the CHP Plant will interface with this supply. Dry gas will be received at the Gas Plant, which will have facilities to condition the dry (or natural) gas ready for use in the GTs and / or boilers.

1.4.60 Each GT’s exhaust will be connected to a HRSG to convert waste exhaust heat to steam. Each HRSG will have its own exhaust stack of height no greater than 50 m. The HRSGs will have the facility for supplementary firing to enable additional generation of steam. The GTs are intended to have dry low oxides of nitrogen (NOx) combustions systems capable of achieving the required exhaust emission limits. The gas turbines are intended to be housed in a building of sufficient size to enable their routine maintenance activities to be completed under cover.

1.4.61 The boilers will be capable of combusting 100% dry gas, natural gas or a combination of the two gases. The boiler combustion system will be a low NOx design capable of achieving the required exhaust emission limits. Each boiler will be provided with a canopy roof but otherwise will be open on each side. Each boiler will have its own exhaust stack of height no greater than 50 m.

1.4.62 The CHP Plant will include up to three condensing pass-out steam turbines. Each steam turbine will be connected to its own electrical generator. The maximum total nominal output of the combined steam turbines (whether 1, 2 or 3) is envisaged to be approximately 99 MWe. Steam from the exhaust of the steam turbines will be condensed in air cooled steam condensers. The steam turbines will be housed in an enclosed building.

1.4.63 The boilers will require a feed of demineralised water and hence a demineralised water treatment plant (WTP) is required, along with raw and demineralised water storage tanks. The WTP will use potable water and is anticipated to be designed around Reverse Osmosis (RO) technology (which minimises the use of chemical treatment). This technology would be expected to recover at least 75% of the raw water for use as feedwater for the steam system. The remaining water is unrecoverable, resulting in a hard water waste stream.

1.4.64 It is anticipated that the surface water drainage and water discharges for the proposed CHP Plant will tie into the existing systems at the Kinneil Terminal, which is regulated by SEPA through the PPC Permit. Kinneil Terminal does not have any discharges to the public sewer.

Operational Emissions, Discharges and Waste 1.4.65 The operation of the CHP Plant will generate gaseous, liquid and solid waste streams. The design

of the CHP Plant, adherence to the PPC Permit requirements, the EMS and compliance with BAT will limit the potential for any adverse effects associated with emissions, discharges and wastes from the operation of the proposed CHP Plant.


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Atmospheric Emissions

1.4.66 The main atmospheric emission consists of combustion gases resulting from burning gas in the GTs and boilers. Emissions from the boilers will be emitted to atmosphere via the HRSG / boiler stacks. The main pollutants of concern are NOx and carbon monoxide (CO). Emissions of particulates and SO2 will be negligible (sulphur is removed from the dry gas elsewhere within the Kinneil Terminal).

Venting and Flaring

1.4.67 There will not be any new flares as a result of the proposed CHP Plant Project. The CHP Plant gas systems are intended to route any vented gas (e.g. from an over-pressurisation event) to the existing Kinneil Terminal flare system. Occasionally operations (e.g. start-up / warm-up of the HRSGs and boilers) could result in the requirement for steam to be vented to atmosphere.

Aqueous Discharges

1.4.68 The main sources of waste water as a result of the proposed CHP Development are:

boiler blowdown water; unrecoverable water from the WTP; and clean and potentially contaminated surface water runoff (via site drainage).

1.4.69 The boiler blowdown will consist of demineralised water containing small quantities of steam conditioning chemicals (e.g. pH adjustment chemicals and oxygen scavengers) and an increased dissolved solids content. It is intended that the boiler blow down water and the unrecoverable water from the WTP would be used as make-up water in the Kinneil Terminal’s wet cooling towers, or in other grey water systems. If it is not possible to use the boiler blowdown and unrecoverable WTP waste water at Kinneil Terminal, these streams will be discharged in accordance with the existing discharge consent for Kinneil Terminal, via the existing discharge pipeline to the Forth Estuary.

1.4.70 As per the existing Kinneil Terminal drainage system, it is intended that surface water runoff from clean, undeveloped areas will be collected via drainage ditches and routed through an existing interceptor before discharge to the River Avon. Any potentially contaminated surface water runoff will be collected, treated in the Kinneil Terminal Effluent Treatment Plant (ETP) and discharged to the Forth Estuary.

Solid Wastes

1.4.71 The process of producing steam and electricity does not generate large quantities of solid wastes. Typical process wastes will be limited to those associated with the maintenance of process equipment (such as oily rags, waste lubricating oils). Wastes will be segregated, stored, handled, labelled, packaged and disposed of in accordance with good practice and the relevant legislation. The design of the CHP Plant will ensure that the potential for accidental releases (e.g. leaks and spills) is minimised.

1.4.72 Onsite operations, including the generation, handling, storage and transportation of wastes will comply with the requirements of BAT and will be conducted following the strict control measures that will be in place as a result of the PPC Permit issued by SEPA and the site’s EMS. These measures will limit the potential for adverse impacts associated with operational waste generation and disposal.

Decommissioning 1.4.73 The CHP Plant is expected to be in commercial operation from 2018 to 2030. If operation after this

period is not desirable, or feasible, the CHP Plant will be decommissioned. At this early stage in the proposed CHP Plant Project, no further information is available relating to the decommissioning phase. However, as a guideline, it is anticipated that decommissioning activities will be similar to those that could occur during the construction phase of the Project. At the end of the life of the CHP Plant, and prior to decommissioning, a detailed assessment will be undertaken to address environmental impacts associated with decommissioning, thus, decommissioning is not discussed in any further detail in the ES.


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Process Alternatives and BAT Considerations 1.4.74 The BAT Reference Document (BREF) for the Refining of Mineral Oil and Gas7 (hereafter referred

to as ‘Refineries BREF’) is the most relevant one to the CHP Plant Project when it is burning dry gas. The Large Combustion Plant (LCP) BREF8 would apply for the combustion of natural gas from the National Transmission System (NTS) (the back-up supply). It was agreed with SEPA that the Industrial Emissions Directive (IED) limits should be applied to this Project.

1.4.75 The most practical option for the final CHP equipment configuration must take account of flexibility, availability, cost and environmental impact of the available technology. It is concluded that the combustion equipment needs to contain four or more combustion devices in order to achieve the flexibility and availability aims for the life of the CHP Plant.

1.4.76 It is considered that the most appropriate plant configuration to achieve the main aim of the project would be a number of small gas fired steam generators coupled with one or more steam turbines with associated air cooled condensing systems. A number of the steam boilers could be substituted with small GT / HRSG units which could still achieve the same technical aims (albeit at a higher investment cost). The final number of GT units chosen would depend on future market speculation, but is considered limited to three units of approximately 90 MWth input / 30 MWe output each.

1.4.77 The exhaust emissions of the GT / HRSG and steam boilers would be compliant with the IED using low NOx burner technology in both equipment types. The equipment would be operated within their emission compliant operating ranges verified by the use of continuous emissions monitoring (CEMs).

1.4.78 The CHP Plant would use extraction condensing steam turbines to make more efficient use of the steam energy in the generation of electricity (in compliance with the Energy Efficiency BREF9). Cooling of the steam turbine exhaust results in greater electrical efficiency. Cooling would be achieved using air cooled condensers, which in comparison to direct water cooling or evaporative cooling options are considered to be BAT compliant for this site. This is due to capacity restrictions in the site’s potable water supply (which is insufficient for water based cooling options) and the potential for environmental impacts that are associated with the construction and operation of a water abstraction system.

1.4.79 Waste heat is considered to be minimised by the use of the technology employed. The remaining waste heat is of a low grade. There is no practicable demand within a reasonable distance of the CHP Plant, nor one which could easily accept a varying, unsteady and continually declining supply. On this basis the CHP is considered to be BAT compliant with the Energy Efficiency BREF.

1.4.80 Demineralised water required for the steam feedwater system will be produced from the potable mains supply via the use of RO technology. This method is considered to comply with BAT guidance by minimising the requirement and toxicity of regenerative chemicals.

1.4.81 Measures to control and minimise noise have been incorporated into the design.

1.5 Planning and Planning Policy 1.5.1 The S36 Application will be assessed against the content of the Development Plan. The

Development Plan for the area has until recently comprised:

the Falkirk Structure Plan (2007); and the Falkirk Local Plan (2010).

1.5.2 However it is anticipated that the Falkirk Local Development Plan (LDP) will be adopted in 2015. When adopted, the LDP will replace the current Structure Plan and Local Plan with a single planning document which will guide development in the area for the period 2014 – 2034.

1.5.3 In addition to the LDP, proposals should be developed in accordance with national planning policy and guidance, emerging policy, and other policies as relevant. Of particular relevance to the proposed CHP Plant Project is the planning policy and guidance contained in the following documents:

National Planning Framework 3 (June 2014) (NPF3); Scottish Planning Policy (June 2014) (SPP); Planning Advice Notes (PANs); Electricity Generation Policy Statement (2013); and Supplementary Planning Guidance (including Frontiers of the Roman Empire (Antonine Wall).


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1.5.4 A separate Planning Statement has been submitted in support of the S36 Application. The Planning Statement provides:

a description of the LDP and other planning policies pertaining to the proposed CHP Plant Project;

an assessment of the proposed CHP Plant against the relevant, aims and objectives and individual polices of the LPD; and

conclusions on the compatibility of the proposal with the LDP as a whole.

1.6 EIA Methodology EIA Scope and General Assessment Methodology

1.6.1 The need for an EIA and an ES has been established in conjunction with the ECDU on the basis of the nature and scale of the proposed Development and the potential for significant environmental effects. The ES has been submitted along with the S36 Application to assist Scottish Ministers and consultees with considering the significance of any environmental effects associated with the proposed CHP Plant Project, and in reaching a decision as to whether S36 Consent should be granted.

1.6.2 Prior to submitting the S36 Application, Scottish Ministers were asked for a formal opinion (known as a Scoping Opinion) on the information to be supplied within the ES. A Scoping Report2 and the request for a formal Scoping Opinion were submitted to the ECDU on 9th October2014. The Scoping Report provides an opportunity for Scottish Minsters and the consultees to highlight any additional issues that they believe should be addressed within the EIA; and to identify any sources of information, which may be of interest in the course of the EIA. The Scoping Opinion3 was issued on the 10th December 2014. The responses from consultees within the Scoping Opinion have been taken into consideration, as relevant, in undertaking the EIA.

1.6.3 Wherever possible, accepted impact assessment standards and guidelines have been followed in the EIA. The preparation of the ES has taken into account relevant legislation, regulations and general advice guidance relating to good practice. For each ‘environmental discipline’ (e.g. air quality, noise, ecology etc.) the ES has detailed the relevant legislation and policy, assessment methodology and significance criteria, baseline conditions, impact assessment (for the construction and operational phases), mitigation measures and the residual impact assessment. In-combination and cumulative impacts (as a result of the proposed CHP Plant Project and other planned developments) have also been considered.

1.6.4 The assessment of effects has taken a ‘realistic’ approach in that it has assumed that the proposed CHP Plant Project will be designed, constructed and operated in accordance with relevant legislation, regulations, policies and guidelines and that general ‘good practice’ will be employed. The assessment also takes into consideration the fact that the appointed Contractor will produce a comprehensive CEMP (including a Waste Management Plan (WMP) and a Transport Management Plan (TMP)), to be agreed with Falkirk Council, and that the operation of the Project will be controlled and managed through incorporation into the Kinneil Terminal’s EMS and through a PPC Permit (regulated by SEPA). Whereas these environmental management and control measures may be considered as forms of mitigation, they have been considered to be an integral part of the proposed CHP Plant Project proposals and have not been specified as specialist mitigation measures in the assessments. Mitigation measures have not been suggested for impacts with beneficial effects, or those that are neutral, negligible or ‘not significant’.

Consultation

1.6.5 Consultation is an important and fundamental component of the EIA process. It allows interested and affected parties and organisations to become involved in the planning and development process of a development and ensures that their concerns, ideas and aspirations for a development project are taken into consideration.

1.6.6 Information from the consultation process has been used to inform, influence and refine certain elements of the design of the project. Information from consultees has also been used to refine the EIA methodology (as presented in the Scoping Report), thereby ensuring that the consultees are in agreement with the methodology that was employed for the EIA.


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1.7 Air Quality 1.7.1 The assessment identified the following as the main potential sources of impacts on air quality:

dust from construction activities; vehicle emissions as a result of increased traffic during the construction and operational

phases; and combustion emissions from the boiler and HRSG exhausts.

1.7.2 The potential effect of these emissions on human health and ecological receptors was addressed.

1.7.3 The assessments of effects of dust emissions during the construction phase of the Project were undertaken in line with the Institute of Environmental Management and Assessment (IAQM) Guidance and taking account of a comprehensive CEMP being in place, incorporating good practice measures for the control of dust. The assessment considered the likelihood of dust effects in the context of the overall scale and nature of the development and the sensitivity of neighbouring land uses. The site was determined to be of ‘low’ risk for effects on property and negligible for human health and ecological effects. With the CEMP in place no significant effects relating to dust emissions are anticipated and all property and receptors are likely to remain unaffected by dust throughout the construction period.

1.7.4 Road traffic emissions were considered in accordance with the Environmental Protection UK (EPUK) / IAQM (2015) guidance for land use planning. Changes to traffic flow data during the construction and operational phases of the CHP Plant Project were evaluated against the indicative criteria therein and determined to have an insignificant impact on local pollutant concentrations and as such, an insignificant effect on local receptors for human health and ecology.

1.7.5 The main component of the assessment was a study of the potential effects of the combustion gas emissions from the CHP Plant stacks during operation. As the design is not finalised, a ‘Rochdale Envelope’ style approach has been applied

1.7.6 Stack emissions were assessed by means of a detailed air dispersion modelling study for the relevant pollutants regulated under the IED. The AERMOD model was used to estimate maximum ground level pollutant concentrations at nearby residential and ecological receptors. Several conservative assumptions regarding emissions were applied i.e. combustion of the dry and natural gas at the ‘useful’ thermal input capacity, constantly emitting at the IED limits, 24 hours a day throughout the year and ‘worse case’ [sic] conversion ratios for NOx to NO2.

1.7.7 On that robust basis, it has been demonstrated that the CHP Plant stack emissions will not lead to any exceedences of statutory air quality criteria at sensitive receptors. Total concentrations (including the background contribution) of NO2 and CO will continue to be below respective Air Quality Strategy (AQS) objectives at the locations of sensitive human health receptors. The effect of stack emissions is, in line with EPUK / IAQM Guidance, considered to be ‘not significant’. Ecological effects of NOx and nitrogen deposition at international sites of importance for nature conservation, as well at national and local sites, were found to be insignificant.

1.7.8 The CHP Plant Development is not expected to result in significant effects as a result of impacts on air quality and specific mitigation measures are not proposed.

1.8 Land Quality, Geology and Hydrogeology 1.8.1 At the Scoping Stage, the assessment of the impact of the operational phase of the proposed CHP

Plant Project on land quality was scoped out.

1.8.2 The assessment identified the following sources with the potential to result in impacts on land / groundwater quality during the construction period:

contaminated soils; contaminated groundwater / surface water; ground gas; and fuel spills, leaking containers.

1.8.3 The potential impacts of the Project were assessed for their potential effects on:

onsite / offsite human receptors; existing services and property offsite; underlying groundwater resource; and surface water receptors.


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1.8.4 At this time, contaminant testing results from intrusive SI works are not available and the assessment was based on existing information, including historic SI information for the surrounding area. Prior to construction, intrusive SI works will identify specific ground conditions and areas of contamination that may have the potential to affect the impact assessment process and appropriate control / remediation measures will be incorporated into the design (as required).

1.8.5 The assessment has been undertaken on the basis that control measures for the construction phase will be in place, including the production of a robust CEMP and Risk Assessment Method Statement (RAMS) for the proposed works. These documents will take account of the management of groundwater, the use of appropriate PPE measures, dust suppression measures when required, measures to limit infiltration of rainwater through exposed soil surfaces, and segregation of stockpiled materials to prevent cross-contamination. Gas monitoring from monitoring installations will also be undertaken onsite prior to construction works to investigate the gas regime so as to confirm the level of risk that will be present and allow appropriate mitigation measures to be designed (if required).

1.8.6 The assessment of the potential impacts from the construction phases of the proposed CHP Plant has identified that there is potential for a neutral or minor adverse effects (which are not significant) during the construction phase. Minor effects potentially include:

effects on human health (construction workers) as a result of dermal contact with, inhalation of, and / or ingestion of, contaminants (if present in soil, soil-derived dusts, and / or water);

effects on human health (construction workers) as a result of inhalation of ground gas; and effects on property from migration of ground gas.

1.8.7 The CHP Plant Development is not expected to result in significant effects as a result of deterioration in land quality or on groundwater, and specific mitigation measures are not proposed.

1.9 Water Quality 1.9.1 The assessment identified the following sources with the potential to result in impacts on land /

groundwater quality during the construction period:

leaks / accidental spillages of chemicals / fuels; aqueous waste stream discharges (for example, those arising from plant washing, discharges

of water associated with the in-fill of the firewater ponds and hydro-test water); migration of contaminants from contaminated land (if soils are contaminated); delivery of higher loads of fine sediment; and litter accumulation in waterbodies.

1.9.2 During operation the main sources of potential impacts are:

leaks / accidental spillages of chemicals / fuels; and aqueous discharges (surface water runoff and process waste water).

1.9.3 The potential impacts of the Project were evaluated for their potential effects on:

Forth Estuary; River Avon; River Carron; Grange Burn; and Forth and Clyde Canal.

1.9.4 The main routes of exposure of water bodies are via the onsite drains, the River Avon and the Forth Estuary. Surface water runoff from undeveloped areas will be discharged to the River Avon (as per the existing Kinneil Terminal drainage system). Potentially contaminated surface water runoff from developed areas and process effluent will be routed to the Kinneil Terminal ETP prior to discharge via pipeline to the subsea diffuser in the Forth Estuary (as per the existing Kinneil Terminal drainage system).

1.9.5 The assessment of effects has taken a realistic approach in that it has accounted for construction impacts being controlled and managed through the application of good practices and the development and implementation of a comprehensive CEMP. On this basis, it is considered that construction activities could result in:

negligible impact on the River Carron, Grange Burn, and Forth and Clyde Canal; a neutral impact (neutral effect, which is not significant) on the Forth Estuary; and a minor impact (minor effect, which is not significant) on the River Avon.


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1.9.6 The aqueous discharges that arise from the operation of the site will be regulated by SEPA and permitted via the existing PPC permit. On this basis, it has been assessed that operational activities could result in:

negligible impact on the River Carron, Grange Burn, and Forth and Clyde Canal; a neutral impact (neutral effect, which is not significant) on the Forth Estuary; and a minor impact (minor effect, which is not significant) on the River Avon.

1.9.7 The CHP Plant Development is not expected to result in significant effects as a result of any potential deterioration of water quality and specific mitigation measures are not proposed.

1.10 Flood Risk 1.10.1 There is no knowledge of flooding to the proposed Development Site to date from any of the

identified sources (including, tidal, fluvial, groundwater, surface water and sewer flooding).

1.10.2 The assessment of flood risk has assumed that:

appropriate good working practices will be applied during the construction period and that a CEMP will be produced and implemented;

flood risk will be managed through: - providing a safe refuge above the extreme water level within the CHP Plant building, - providing a flood resilient building structure (e.g. concrete floors; raised electrical

equipment), - providing a flood warning system, and - safe evacuation routes and evacuation procedures;

consideration has been given to reducing the risk to buildings by providing flow paths which divert flows away from the building; and

surface water runoff will be managed through an appropriately designed surface water drainage system.

1.10.3 The site level currently ranges from 3.1 m AOD to 4.1 m AOD. In order to reduce the risk of flooding to an acceptable level:

the area of CHP Plant Site that will be built onvii will be raised to +4.62 m AOD, with its side sloped at 1 in 3 down to existing ground levels;

the proposed finished floor levels of the buildings will be 4.77 m AOD; and critical equipment within the buildings will be raised above the finished floor level to provide

additional resilience from flooding, taking into consideration an allowance for freeboard.

1.10.4 The site is at high risk from tidal flooding but the finished floor level of the buildings will be set at the 0.5% Annual Exceedance Probability (AEP) tidal level (including surge and effects of climate change). During the construction and operational phases, the site is also at risk from more extreme tidal events (above 0.5% AEP). The risk from extreme tidal flooding will be managed by providing a flood warning system; safe evacuation routes; and evacuation procedures. On this basis the tidal flood risk is considered to result in neutral to minor effects (which are insignificant) for both the construction and operational phases.

1.10.5 There is a low risk of fluvial flooding from the River Avon, with the CHP Plant Site being protected by earth embankments. The significance of effects is considered to be neutral for the construction phase and neutral for the operational phase.

1.10.6 The site is at low risk of flooding from groundwater but the main influence on groundwater levels within the CHP Plant Development Site will be the tidal levels. The measures to manage the tidal and surface water flood risk incorporated into the design of the site are suitable for managing the groundwater flood risk such that the significance of groundwater flood risk is considered to result in neutral to minor effects (which are insignificant) for both the construction and operational phases.

1.10.7 There will be an increase in compacted soils and / or impermeable areas associated with the proposed development, and, therefore an increase in surface water runoff. As part of the CEMP, surface water runoff will be managed such that it will not increase the risk of flooding at the proposed CHP Plant Development Site, or to land within the surrounding area during the

vii The area that will be built on (and hence raised) includes all areas where there will be buildings, structures, equipment, roads and

paved areas.


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construction period. During operation, surface water runoff will be managed through an appropriately designed surface water drainage system connecting into the existing drainage system for Kinneil Terminal. The significance of the effects of the development on surface water runoff is considered to be minor (which is insignificant) during the construction period and during operation.

1.10.8 It is expected that there will be no significant flood risk impacts during the construction or operational phases of the CHP Plant Development. Therefore no specific mitigation measures are deemed necessary. Whilst there are no significant effects in relation to flood risk, BP will:

continue to liaise with Falkirk Council to ensure it is informed of any changes to the standard of protection of the site with particular regard to any proposed flood defences along the Forth Estuary frontage; and

continue to liaise with SEPA to ensure it is informed of any changes to the flood warning system provided.

1.10.9 A detailed Flood Risk Assessment (FRA) has been undertaken in line with Scottish Planning Policy. The report for the FRA has been prepared as a standalone document and has been submitted as part of the S36 Application for the proposed CHP Plant Project.

1.11 Noise and Vibration 1.11.1 The potential for vibration impacts was considered and scoped out of the assessment for the

construction phase and for operation.

1.11.2 The noise assessment identified 16 residential noise receptors and 9 ecological noise receptors. The nearest residential receptors are dwellings approximately 0.6 km to the south west and the nearest ecological receptor (the Firth of Forth SPA and Ramsar site), just under 0.5 km to the north.

1.11.3 The main sources of noise with the potential to result in effects on noise sensitive receptors will be from:

additional traffic during the construction and operational phases; construction works at the proposed CHP Plant Site; and operation of the proposed CHP Plant

1.11.4 The impact of noise from construction traffic on local roads has been assessed as negligible, which is not a significant effect. Operational traffic is insignificant and, in agreement with Falkirk Council, operational traffic noise was scoped out of the noise assessment.

1.11.5 During the construction phase, piling is likely to be the most audible noise source at all identified receptor locations. Noise predictions for the construction phase of the development have shown that noise levels would be well below the significance threshold (and below existing background noise levels) for all stages of works at all receptors. The effects are thus considered to be neutral, which is not significant.

1.11.6 Using the worst-case site layout configuration for noise generation (indicative Configuration 2, nine boilers and one GT (see Figure 1-7)) operational noise levels during typical operation are predicted to be lower than any of the baseline noise measurements. The effects are thus considered to be neutral, which is not significant. This is not a guarantee of inaudibility but it can be taken as a positive indication that operational noise from the proposed plant will fall below existing background noise levels during both daytime and night-time at most Noise Sensitive Receptors (NSRs), especially given the layers of conservatism that have been built into the assessment.

1.11.7 Steam venting is significantly noisier than normal operation but only happens occasionally (e.g. during boiler start-up, which, as a worst case, is estimated to take place for a maximum of half an hour, once per week). In theory, based on a highly conservative assessment, noise effects at NSR 1 (Polmonthill Cottage) and NSR 3 (Inveravon Cottages) could be assessed as ‘significant’ during steam venting as the noise predictions are 53.5 dB LAeq,30min (i.e. above 50 dB LAeq,30min). Noise as a result of venting at these receptors does not reach the 5 dB above background threshold (50 dB), which would be considered ‘likely to be an indication of an adverse impact.’ Noise as a result of venting is expected to occur for no more than half an hour, less than once per week.

1.11.8 The CHP Plant will be designed and operated in accordance with the relevant BAT guidance to ensure that noise emissions are acceptable. Mitigation measures will be considered further as the design progresses and will be incorporated into the design if it is feasible and practical to do so. However, as it is not yet known whether any of these measures would actually be required in the


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final design, they have not been included in the assessment of residual effects. Once the configuration and layout of the design have been finalised, noise predictions for steam venting will be recalculated and, if necessary, additional measures will be introduced to ensure that noise levels at all identified receptors are not significant.

1.12 Ecology 1.12.1 The nearest ecological receptors are the habitat of the site itself, the River Avon and the Firth of

Forth SPA and Ramsar site (which is just under 0.5 km to the north).

1.12.2 Potential impacts of the proposed CHP Plant Project on ecology during the construction period are:

loss of habitat as a result of construction; disturbance of otter using the River Avon; visual disturbance of wintering, autumn passage and breeding birds using the Firth of Forth

SPA, Ramsar site and SSSI; disturbance of wintering and autumn passage birds using the Firth of Forth SPA and Ramsar

site as a result of noise and vibration; disturbance of breeding birds using the Firth of Forth SSSI as a result of noise and vibration; pollution of the River Avon and the Firth of Forth as a result of water and sediment runoff, or as

a result of accidental spills; noise and vibration disturbance to fish, particularly those that are qualifying features of the

River Teith SAC; and pollution of statutory designated sites as a result of airborne emissions from additional traffic,

construction plant and machinery.

1.12.3 Potential impacts of the proposed scheme on ecology during operation are:

disturbance of wintering and autumn passage birds using the Firth of Forth SPA and Ramsar site as a result of noise and vibration;

disturbance of breeding birds using the Firth of Forth SSSI as a result of noise and vibration; effects of waste water discharge on water quality in the River Avon and the Firth of Forth; noise and vibration disturbance to fish, particularly those that are qualifying features of the

River Teith SAC; and pollution of statutory designated sites as a result of airborne emissions from additional traffic

and from stack gas emissions.

1.12.4 The habitats within the CHP Plant Development Site itself are of negligible ecological value and are considered to be inhospitable to faunal species. Mitigation for loss of habitats is not considered to be required due to the limited extent of works and the negligible ecological value.

1.12.5 With regard to potential disturbance impacts, noise levels are not predicted to result in any changes in bird behaviour, during either the construction or operational phases and there are no predicted effects as a result of visual disturbance. Therefore, no significant effects on the conservation status of birds that are qualifying features of the designated sites or on the integrity of the Firth of Forth SPA and Ramsar site are predicted and no mitigation is required. No effects on fish that are qualifying features of the River Teith SAC are predicted. Significant effects on the conservation status of otters using the River Avon are not predicted. No effects on ecology as a result of pollution or from reduction in air or water quality have been identified.

1.12.6 To summarise, the assessment has been undertaken on the basis that standard pollution control measures and general good practice construction measures with relation to ecology will be followed for the construction and operational phases of the proposed CHP Plant Project. No ecologically significant impacts are predicted on the integrity of designated sites nor on the conservation status of habitats or species, in particular the important bird assemblages associated with the Forth Estuary or the fish populations of the River Teith SAC.

1.12.7 The CHP Plant Development is not expected to result in any significant effects and so specific mitigation measures are not proposed.

1.12.8 A Habitats Regulation Assessment (HRA) is required under the Conservation (Natural Habitats &c) Regulations 1994 (as amended). A separate report has been prepared to provide information for the competent authority to undertake a Stage 1 (screening) of the HRA process in relation to the proposed CHP Plant Project.


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1.13 Landscape and Visual 1.13.1 There are no landscape designations on the site. There are no National Scenic Areas, Areas of

Wild Land, Gardens and Designed Landscapes, Regional Parks, Country Parks, Nature Reserves or Tree Preservation Orders within the Landscape and Visual Impact Assessment (LVIA) Study Area.

1.13.2 There are five Local Character Areas / Landscape Character Types within the Study Area. South Bo’ness SLA is approximately 0.5 km from the proposed CHP Plant Site and is recognised as being important for recreation. The AW WHS is (at its nearest point) approximately 0.9 km from the CHP Plant Site boundary. The nearest settlement is Grangemouth. The nearest transport routes are the A904 / A905 and the M9. The Bo’ness and Kinneil Railway and a number of public paths and cycle routes are located within the LVIA Study Area (including National Cycle Route (NCR) 76).

1.13.3 The potential impacts on the site and surrounding LVIA Study Area during the construction period are summarised as:

construction of the new built form; presence of components (e.g. construction equipment and vehicles, materials, storage areas

etc.); associated short term large crane activity; increased heavy and light duty vehicle movements; and potential for increased lighting during the construction period in the winter months.

1.13.4 For operation, the Zone of Theoretical Visibility (ZTVs) show that potential landscape and visual on predicated on the identified landscape character areas, the SLA and some visual receptors within the LVIA Study Area from the introduction of tall structures.

1.13.5 The effects of the proposed CHP Plant Project that are considered to be significant in terms of the EIA Regulations are:

Viewpoint 1 (the AW near Nether Kinneil): - Construction - moderate adverse effect, - Operation - moderate adverse effect,

Viewpoint 4 (the North bank of River Avon near Grangemouth Petrochemical Complex): - Construction - major adverse effect, - Operation - moderate adverse effect,

1.13.6 When considering these results, it is important to note that the proposed CHP Plant Project is set within the context of the Grangemouth Petrochemical Complex.

1.13.7 Given the proximity of the CHP Plant Site to viewpoints 1 and 4, it is considered that:

it is not feasible to mitigate construction effects beyond existing good practice; and mitigation for operation is limited to careful consideration of design materials to improve the

landscape experience at this location, and this is already assumed to be part of the design process.

1.14 Historic Environment 1.14.1 In the Scoping Report2, it was proposed that assessment of the operational phase of the CHP Plant

Development on heritage assets would be ‘scoped out’ of the EIA process. This approach was confirmed though consultation. During consultation, the assessment of effects on the setting of heritage assets was also scoped out. Thus, the assessment of potential effects on the historic environment is limited to those associated with the removal of, or material damage to, archaeological deposits as a result of the construction phase of the BP CHP Plant.

1.14.2 Construction works have been assessed to result in the following permanent direct construction impacts:

a low adverse impact (in relation to the likely extent of the asset, and the localised impact of piling) on any shell midden deposit on the site, a potential asset of medium importance. This will result in a minor adverse effect, which is insignificant; and

a low adverse impact (in relation to the likely extent of the asset) on any structures relating to the Bo’ness Canal, a potential asset of medium importance. This will result in a minor adverse effect, which is insignificant.


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1.14.3 The CHP Plant Development is not expected to result in any significant effects in relation to the historic environment and so specific mitigation measures are not proposed.

1.14.4 Whilst there are no significant effects on cultural heritage assets, the following will be undertaken:

SI borehole logs will be examined by an archaeologist to determine whether there are likely to be shell middens worthy of recording on the site. If so, a limited Archaeological Watching Brief will be undertaken during ground works; and

SI data will be examined by an archaeologist to determine whether there are likely to be remains of the Bo’ness Canal on the site. If so, recording will be carried out by means of an Archaeological Watching Brief during ground works.

1.15 Transport 1.15.1 In the context of the existing road use, operation of the proposed CHP Plant is considered to have

a negligible effect in relation to traffic and transport impacts and the assessment of the operational phase of the development was ‘scoped out’ of the EIA process.

1.15.2 Impacts on residents associated with transport related air quality and noise are addressed in Section 1.7 and 1.11 respectively. The transport assessment only addresses the potential impacts associated with the CHP Plant Project proposals in terms of the potential for effects on the surrounding road networks. Thus, the main potential impact is:

an increase in road traffic due to construction vehicles (workers and deliveries) accessing the site, potentially leading to adverse effects on the users of the local highway network.

1.15.3 It is not considered that there is a significant road safety issue in the vicinity of the site and so impacts relating to accidents have not been considered further.

1.15.4 The findings of the transport assessment indicate that, as a worst case, the increase in road traffic during peak periods would be less than 8%. The effects of the construction of the proposed CHP Plant Project on the local road network and surrounding area are considered to be low / negligible and ‘not significant’.

1.15.5 Mitigation is not a requirement for non-significant effects that are assessed to be of negligible or low significance. Thus, no specific mitigation measures are proposed in relation to effects associated with road transport. However; a number of good practice measures have been provided for inclusion in the CEMP.

1.15.6 A Transport Statement (TS) has been prepared as a standalone report for the construction phase of the proposed Project as part of the S36 Application.

1.16 Aviation 1.16.1 At the Scoping Stage of the proposed CHP Plant Project, it was not expected that the CHP Plant

would be likely to result in effects to aviation. However, the Scoping Report2 and Scoping Opinion3, both recommend that this should be verified during the EIA process.

1.16.2 A standalone study was undertaken to address the points made in the Scoping Opinion3 and to expand on the investigation of the potential for aviation impacts. The study concluded that the new CHP Plant Development is unlikely to result in the degradation of any aviation-linked radar or communications services, or those serving maritime activity. In addition, the development is situated no closer than 18 km to the nearest airport and would not impact on safeguarding zones or on en-route procedures.

1.17 Socio-economics 1.17.1 In the context of the existing industrial area, operation of the proposed CHP Plant is considered to

have a negligible effect in relation to potential socio-economic impacts and so the assessment of the operational phase of the development has been scoped out of the EIA process.

1.17.2 Given the scale of the Project the most significant socio-economic impacts are likely to be related to employment and supply chain. Potential impacts of the scheme during the construction period are likely to include the following:

creation of temporary construction jobs (peak work force of 400); indirect / induced employment (supply chain and employee spend);


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demand for local services / amenities; and temporary disruption to local residents and businesses.

1.17.3 The assessment has determined that the construction phase of the CHP project could give rise to the following temporary impacts and effects:

a minor beneficial impact resulting in a slightly positive effect (not significant, minor beneficial effect) in terms of employment; and

a negligible impact resulting in little or no effect (not significant, negligible effect) in relation to disruption.

1.17.4 Mitigation is not a requirement for beneficial impacts or for those assessed to be of negligible significance. Thus, no specific mitigation measures are proposed in relation to effects associated with socio-economic factors. However, the following will be undertaken:

BP will continue to maintain close links and communication with the local communities and businesses in relation to the planned construction works and that early warning of potentially disturbing activities is given to existing businesses and nearby residents. This should help to minimise the effects of disturbance; and

consideration will be given to registering with the Considerate Constructors Scheme and by adhering to the Code of Considerate Practice.

1.18 Cumulative and In-combination Effects 1.18.1 Cumulative impacts can arise when an impact from one project occurs at the same time as an

impact from another project in the vicinity (for example, two concurrent construction projects).

1.18.2 The cumulative impacts of existing operational facilities (e.g. the Kinneil Terminal and the Grangemouth Petrochemicals Complex) are already accounted for through the baseline studies for each EIA topic area. Thus, only proposed developments are considered in the assessment of cumulative impacts. Proposed developments have been identified through consultation with Falkirk Council and only include 'known' developments (i.e. those that have already applied for, or been granted, Planning Consent).

1.18.3 Only one planned development has been identified for the assessment of cumulative effects and that is the extant planning permission for Forth Energy to construct a biomass plant on Central Dock Road, Grangemouth. The biomass project is located approximately 3 km to the north west of the proposed CHP Plant Project. The location of the proposed biomass Project relative to the proposed CHP Plant Project is illustrated in Figure 1-10. Details of the proposed biomass project, including the ES can be found on Forth Energy’s website.

1.18.4 It is understood that although consent has granted, the site is not being developed at present due to a lack of financial support. However, since the consent exists the biomass plant could theoretically be built and so the potential cumulative effects of the construction and operational phases of the biomass plant and the proposed CHP Plant have been considered.

Construction

1.18.5 Construction of the proposed CHP Plant Project is planned for Q1 2016, i.e. in less than 9 months’ time, for a period of 27 months (including commissioning). There are at present no plans to undertake the biomass plant development. Even if this situation changed, it is not likely that construction works would begin at the same time as those for the proposed CHP Plant Project. At worst, the construction periods for the two Projects would be staggered.

1.18.6 Taking into account this and a number of additional factors (including, the production of a robust and comprehensive CEMP for the proposed CHP Plant Project, the physical distance between the two projects and the assessment of the significance of the effects of the proposed CHP Plant Project) it is not considered likely that significant cumulative effects would occur, for any receptor type, as a result of the combined impacts associated with the coincident construction of the proposed CHP Plant Project and the biomass plant.


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Figure 1-10 Location of Proposed CHP Plant Relative to Proposed Biomass Plant

Operation

1.18.7 Operation is due to commence in 2018. It is expected that the site will only operate commercially until 2030.The consideration of the potential for cumulative effects, has been undertaken on a topic by topic basis, as a result of the biomass and CHP Plant projects being operational at the same time. The assessment of the potential for cumulative effects has taken into account the fact that operation and management of the facilities will be undertaken in accordance with:

the requirements of the Permit to operate, which will be issued and regulated by SEPA; and standard industry good practice guidance and legislation.

1.18.8 The existing Kinneil Terminal is accredited under ISO 14001 Environmental Management Systems (EMS). It is expected that the EMS will be extended to cover the operation of the new CHP Plant.

1.18.9 With the exception of the effects of the following, operation of the proposed CHP Plant Project has not been predicted to result in significant adverse residual effects:

occasional effects of noise venting at 2 residential receptors; and visual effects at viewpoints 1 and 4.

1.18.10 Venting is likely to occur at most once per week and for half an hour. Viewpoints 1 and 4 are non-residential and close to the site (1 is the AW near Nether Kinneil and 4 is at the North bank of River Avon near Grangemouth Petrochemical Complex).

1.18.11 At the Scoping Stage, the assessment of the impact of the operational phase of the proposed CHP Plant Project on land quality, the historic environment, transport and socio-economics was scoped out. Hence, the potential for significant cumulative effects as a result of the combined operation of the proposed CHP Plant Project and the biomass plant are considered unlikely and not significant.

1.18.12 The assessment of the potential for cumulative effects for the other topic areas concluded that the potential for significant cumulative effects as a result of the combined operation of the proposed CHP Plant Project and the biomass plant are not considered likely and / or would not be significant.


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In-combination Effects Overview

1.18.13 In-combination effects can occur when an operation (or operations) gives rise to several types of effects on a single receptor (e.g. the combination of air quality, noise and traffic effects at a particular residential property). The receptors that are considered to have the potential for in-combination effects are:

humans; land and groundwater; surfaces; and ecological receptors.

1.18.14 Built heritage assets, archaeology and the ‘landscape’ are not considered to be susceptible to in-combination effects. Effects associated with flooding are not considered further in the in-combination assessment, as flooding would be a one-off a-typical event.

Human Receptors

1.18.15 With the exception of the effects of the following, the proposed CHP Plant Project has not been predicted to result in significant adverse residual effects:

occasional effects of noise venting at 2 residential receptors; and visual effects at viewpoints 1 and 4 during the construction and operational phases.

1.18.16 Venting is likely to occur at most once per week and for half an hour. Viewpoints 1 and 4 are non-residential and close to the site (1 is the AW near Nether Kinneil and 4 is at the North bank of River Avon near Grangemouth Petrochemical Complex). Even when considered together, the various potential effects of the proposed CHP Plant Project are not considered likely to result in significant adverse in-combination impacts on human receptors.

Land and Groundwater

1.18.17 Land (and subsequently groundwater) is unlikely to be affected by deposition of atmospheric emissions as these are not expected to be significant (either during the construction period or operation). Thus in-combination effects to land and groundwater are not expected.

Surface Waters

1.18.18 Surface waters are unlikely to be affected by deposition of atmospheric emissions as these are not expected to be significant (either during the construction period or during operation).

1.18.19 Contamination (existing or new) of the soils beneath the site can subsequently affect groundwater and ultimately surface waters (via migration through groundwater). The impacts of all potential activities (for operation and construction) that could adversely affect water quality have been assessed. The assessment concluded that overall, effects would be of neutral to minor significance at worst.

Ecological Receptors

1.18.20 The ecological assessment has already considered combined effects and concluded that impacts on ecological receptors as a result of the construction and operational phases of the proposed CHP Plant Project not to be significant.

1.19 Summary of Assessment 1.19.1 A comprehensive and robust environmental assessment has been undertaken to determine the

potential for likely significant effects as a result of the construction and operational phases of the proposed CHP Plant.

1.19.2 With the exception of the following, the proposed CHP Plant Project has not been predicted to result in significant adverse residual effects:

occasional effects of noise venting at two residential receptors during operation; and visual effects at viewpoints 1 and 4 during the construction and operational phases.


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1.19.3 Steam venting will not occur as part of the day to day operation of the site. It will only happen occasionally (e.g. during boiler start-up) which, as a worst case, is estimated to take place for a maximum of half an hour, once per week. The assessment is considered to be conservative as it is based on a number of worst case assumptions.

1.19.4 The effects are assessed as ‘significant’ during steam venting as the noise predictions at these locations (53.5 dB LAeq,30min), are within the range of 0-5 dB above the background level (50 dB LAeq,30min). An increase of 0-5 dB has been considered, in the assessment methodology for the Project, as a ‘moderate impact’, which is considered to result in a significant effect. However, the noise increment during venting does not reach 5 dB above background. BS 4142 states: ‘a difference of around +5 dB is likely to be an indication of an adverse impact’; implying that an increase of less than 5 dB may not be an adverse impact. Nonetheless, potential mitigation measures have been identified and will be considered further as the design of the CHP Plant evolves. If feasible and practical, mitigation measures will be incorporated into the final design to reduce the potential impact of steam venting.

1.19.5 Viewpoints 1 and 4 are non-residential and close to the site (1 is the AW near Nether Kinneil and 4 is at the North bank of River Avon near Grangemouth Petrochemical Complex).

1.19.6 Given the proximity of the CHP Plant Site to viewpoints 1 and 4, it is considered that:

it is not feasible to mitigate construction effects beyond existing good practice; and mitigation for operation is limited to careful consideration of design materials to improve the

landscape experience at this location, and this is already assumed to be part of the design process.

1.19.7 When considering these results, it is important to note that the proposed CHP Plant Project is set within the context of the Grangemouth Petrochemical Complex.

1.19.8 An assessment has been undertaken to determine the potential for in-combination significant effects and for significant effects as a result of the cumulative impacts of the proposed CHP Plant with the Forth Energy biomass plant.

1.19.9 The assessment concluded that the proposed CHP Plant Project would not result in significant adverse cumulative or in-combination effects.


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1.20 References

1 Pollution Prevention and Control (Scotland) Regulations 2012, SSI 2012 No. 360; 20th December 2012.

2 BP Kinneil Terminal Gas Fired CHP Plant, Environmental Scoping Report, Atkins, 9th October 2014.

3 The Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2000, Scoping Opinion of Scottish Ministers for the proposed BP Kinneil Terminal Gas Fired Combined Heat and Power Plant, at the BP Terminal, Bo’ness Road, Grangemouth, 10th December 2014.

4 http://www.falkirk.gov.uk/services/corporate_neighbourhood/policy_performance_ review/research_information/ward_constituency_profiles/ward_maps_profiles/ward_maps_and_profiles.aspx.

5 http://aqma.defra.gov.uk/aqma/local_authorities.php?la_id=371.

6 Forth Estuary Forum, http://www.forthestuaryforum.co.uk.

7 European Commission, JRC Science and Policy Reports, Best Available Techniques (BAT) Reference Document for the Refining of Mineral Oil and Gas, Industrial Emissions Directive 2010/75/EU, (Integrated Pollution Prevention and Control), Pascal Barthe, Michel Chaugny, Serge Roudier, Luis Delgado Sancho, 2015; http://eippcb.jrc.ec.europa.eu/reference/BREF/REF_BREF_2015.pdf.

8 European Commission Integrated Pollution Prevention and Control Reference Document on Best Available Techniques for Large Combustion Plants, July 2006; http://eippcb.jrc.ec.europa.eu/reference/BREF/lcp_bref_0706.pdf.

9 European Commission, Reference Document on Best Available Techniques for Energy Efficiency, February 2009, http://eippcb.jrc.ec.europa.eu/reference/BREF/ENE_Adopted_02-2009.pdf .

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