Go-ahead for "wasteful" power station a missed opportunity

6 February 2009

The government's approval of a large (2000MW) LNG-fired power station at Pembroke is a missed opportunity to develop a greener technology, create much needed jobs and energy, emit less carbon dioxide and not harm the important ecology of the Milford Haven waterway.

The shores of the Milford Haven waterway are an ideal location for building combined heat and power (CHP) systems. If suitably sited, CHP systems could provide heat for the two oil refineries and two LNG terminals at Milford Haven, whilst generating electricity. This would be far more efficient and would cause less environmental harm.

Director of Friends of the Earth Cymru, Gordon James, said:

"The government is urging the public to save energy by switching off stand-by, turning lights off and so on. Yet it is giving the go-ahead to a new power station that will waste over half the energy content of the gas [1], emit almost six million tonnes of carbon dioxide a year[2] and threaten an important marine ecosystem[3].

We have calculated that the heat wasted from the new power station would be equivalent to 40 per cent of Wales' electricity demand[4].

"The government is giving this power station the green light knowing that a much more efficient technology - combined heat and power (CHP) - is available that would generate electricity, use waste heat in neighbouring industrial activities, emit less carbon dioxide and create jobs.

At Milford Haven CHP systems could be built close to the two oil refineries and the two LNG terminals, all of which have a big demand for heat. These technologies are widely used in other countries, such as Denmark.

"With both climate change and energy security now posing such concern, we should be using the best technologies available to meet our energy needs.

"CHP would also prevent the harmful dumping of large quantities of warm water into the ecologically important Milford Haven waterway. It is incredible that the government is ignoring the strong objections of its experts, the Countryside Council for Wales, on this issue [5]. These objections have been backed by an independent legal opinion.

"This decision makes a mockery of the government's claim that it wants to take a lead role in developing the green economy in order to tackle both the economic recession and the immense threat now posed by climate change. And it is a missed opportunity for Wales to fulfil its aim of being a world leader in clean energy".

NOTES

1.Over 20 per cent of the energy content of the gas would be used in liquefying, transporting and re-gasifying it before it could be used at Pembroke power station. This is expected to operate at up to 60 per cent efficiency giving an overall efficiency of less than 50 per cent.

2. RWE npower's environmental report for the Pembroke power station application.

3. The government's environmental watchdog in Wales, the Countryside Council for Wales (CCW), has objected to the proposal because of its adverse impact on the Milford Haven waterway Special Area of Conservation. An independent legal opinion has supported its objections.

4. Two large LNG power stations were originally proposed for the Milford Haven waterway. Overall, the electrical output of the two 2 GWe stations would be in the region of 28.7 TWh/year( 4GWe x 8.76 x 0.82 = 28.7 TWh/year) and the combined waste heat produced would be 20.8 TWh/year (10.4 x 2). Yet only 2 TWh/year would be used for re-gas when 6 TWh/year is needed for re-gas (2 at Dragon and 4 at Exxon) and up to 3 TWhr/year is needed at the refineries.

In comparison, Wales's annual electricity demand is around 22 - 24 TWh/year (estimate in Energy Route Map document Annex C, page 47). So, THE HEAT WASTE FROM TWO LARGE 2GWe CCGTs WOULD BE EQUIVALENT TO AROUND 80% OF WALES'S ELECTRICITY DEMAND (18.8 / 24) - even with 2 TWh/y of heat being used for re-gas at the Dragon terminal and some at Texaco! The one power station at Pembroke would waste heat equivalent to around 40 per cent of Wales' electricity demand.

5. Independent B.A.T Assessment for Pembroke Power Station Cooling Water Discharge

CCW Science report 846 June 2008

RWE Innogy have submitted plans to build and operate a 2000MW gas fired power station, on the site of their former Pembroke power station, situated on Milford Haven, in South Wales.

The developers are proposing to use water from the Haven to provide a once-through direct cooling system. This would result in the discharge of 38 cubic meters per second of water approximately 9 ^oC above that abstracted. (To put this in context the flow equates to about half the flow of the river Wye or three times that of the Dau Cleddau rivers that flow into the Haven. The waste heat represents an energy loss of about 11.75 TWh/year, which equates to about 50% of Wales's current electricity demand).

From the outset CCW have raised serious concerns about the potential impact of this thermal discharge on to biota of Milford Haven SAC. However, the Environment Agency, who will permit this power station, have not fully supported our concerns and have indicated that they are minded to allow the developers request for direct cooling. As a result CCW has formally objected to the Dti (BERR) about this development.

CCW has raised concerns in two main areas that have yet to be resolved by EAW:

1. The potential impacts may lead to significant adverse impact on the SAC and as it stands the proposal is not compatible with the requirements of the Habitats Directive.
2. That direct cooling does not reflect best practice for cooling water discharge to a sensitive receiving environment (Best Available Technique- B.A.T.) as required under the Integrated Pollution and Prevention Directive-IPPC).

In order to better inform our position and ensure our concerns are justified and reasonable CCW commissioned an independent B.A.T. assessment to review the two areas listed above. The work was headed by a leading Barrister in environmental law and a team including a former chief scientist at the Environment Agency.

In terms of issues relating to the Habitats Directive the report concludes that CCW concerns have not been addressed. The approach of the Agency is not considered precautionary enough and they have not established beyond reasonable doubt that the thermal discharge will not have an adverse impact on the SAC.

In terms of B.A.T. it is concluded that the Environments Agency's "acceptance" of direct cooling is not justified, at such a sensitive location. The guidance they are using is at least 11 years out of date and their determination takes no account of best practice, employed at many other sites, since the guidance was written. Current best practice is to employ indirect cooling at such a location.

The report concludes that the developer and EAW should not use direct cooling at Pembroke power station.

The report provides interesting industry generic information as well as very important site-specific information. The report will be submitted to BERR and EAW in support of our ongoing concerns.

For further information please contact Friends of the Earth Cymru on 029 2022 9577