Dŵr ymru yfyngedig (D) - Planning Inspectorate · Dwr Cymru Cyfyngedig (DCC) Interested Party...

Dŵr Cymru Cyfyngedig (DCC)

Interested Party Reference: 10027373

Planning Inspectorate Application Ref: EN010059 Hirwaun Power Station

Written Submissions

OG 8/21/2014

Dwr Cymru Cyfyngedig (DCC) Interested Party Reference: 10027373

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SUBMISSION CONTENTS

1.0 SUMMARY OF REPRESENTATION

2.0 CONTEXT OF REPRESENTATION

3.0 DWR CYMRU CYFYNGEDIG (DCC)

4.0 DCC INVOLVEMENT IN APPLICATION

5.0 LOCAL INFRASTRUCTURE

6.0 DCC CONCERNS

ANNEXES

A) DCC RELEVANT REPRESENTATION

B) DCC SCHEDULE OF LAND & ASSETS

C) COPY OF HIRWAUN POWER LTD EMAIL DATED 15TH AUGUST


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1. SUMMARY OF REPRESENTATION

The Examining Authority (‘The Panel’) has requested a summary of an Interested Party’s

representation where the submission exceeds 1500 words. Accordingly, we trust that the following

summary provides an overview of Dŵr Cymru Cyfyngedig’s (DCC) written representation.

1.1 Sections 2.0 and 3.0 sets out the context of this submission and DCC’s role as a statutory

undertaker. DCC is the sixth largest of the ten regulated water and sewerage companies in

England and Wales. Since 2001, we have been owned, financed and managed by Glas

Cymru. Unique in the water and sewerage sector, Glas Cymru is a company limited by

guarantee and as such has no shareholders.

1.2 Section 4.0 provides an overview of DCC’s involvement in the application process both at

pre-application and examination stage. This section clarifies the extent of liaison with

Hirwaun Power Limited.

1.3 Section 5.0 provides The Panel with an understanding of the location of DCC assets within

the Order Limits.

1.4 Section 6.0 refers to matters raised as part of the Relevant Representation, relating

predominantly to the impact of the proposed development upon water quality and water

resources, given the proximity of the site to Penderyn Reservoir and Hirwaun Water

Treatment Works. Based on the information provided within the application documents and

the further information provided by Hirwaun Power Ltd, DCC is currently satisfied that the

potential impact upon both Penderyn Reservoir and the Water Treatment Works can be

mitigated.

1.5 Section 6.0 also refers to the protection of DCC assets and apparatus and the intention to

provide protective provisions. DCC confirms that discussions on the Provisions with Hirwaun

Power Ltd are in an advanced stage, with an agreed intention to submit such Provisions by

Deadline II of the examination timetable.


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2. CONTEXT OF REPRESENTATION

2.1 This submission by Dŵr Cymru Cyfyngedig (DCC) relates to the proposed Development

Consent Order (DCO) for the construction and operation of Hirwaun Power Station.

2.2 This submission takes into account all documentation made available following submission

of the DCO on 21 March 2014, including:

- Hirwaun Power Limited Application Documents

- Publication of The Panel’s Procedural Decisions

- Publication of The Panel’s first round of written questions

- DCC’s Relevant Representation as attached as Annexe B

- Relevant Representations by other Interested Parties

2.3 This representation is submitted in accordance with Deadline I (21st August) of the

examination timetable as confirmed by The Panel’s Procedural Decision issued on 29th July

2014.


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3.0 DŴR CYMRU CYFYNGEDIG (DCC)

3.1 DCC is the sixth largest of the ten regulated water and sewerage companies in England and

Wales. Since 2001, we have been owned, financed and managed by Glas Cymru. Unique in

the water and sewerage sector, Glas Cymru is a company limited by guarantee and as such

has no shareholders.

Glas Cymru

- Glas Cymru is a single purpose company formed to own, finance and manage DCC.

- The company is ‘limited by guarantee’ and secured ownership of DCC in 2001.

- Glas Cymru, as a ‘not-for-profit’ company, is unique in the UK water industry and the

wider utilities sector.

- With no shareholders, profits are reinvested to improve services and keep customer bills

low.

- Under Glas Cymru’s ownership, DCC cannot diversify into new and riskier business

activities and therefore its only concern is its responsibilities as a water and sewerage

company.

Dŵr Cymru Welsh Water

- 1.4 million household and business customers in Wales and parts of Herefordshire and

Deeside.

- 6th largest of the 23 regulated

water companies in Wales and

England.

- Responsible for operating,

maintaining and upgrading

assets to ensure a safe and

reliable drinking water supply

and to deal effectively with

waste water to protect the

environment.

- We look after 67 reservoirs, and

supplies 828 million litres of

safe, clean drinking water

through 27,000km of pipes to

over three million people every

day.

- Operate around 30,000km of

wastewater pipes – or all the

way to Australia and back - and

deal with over 2,000 blockages a month and manage to stop flooding or pollution in 99%

of cases.


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4.0 DCC INVOLVEMENT IN APPLICATION

4.1 PRE-APPLICATION

DCC were consulted at pre-application stage under section 42 of the Planning Act 2008 as a

Statutory Undertaker for water and sewerage. Accordingly, DCC provided comments in

regard to the impact of the proposed development, specifically drawing the applicant’s

attention to;

- Potential impact of the proposals upon the adjacent Penderyn Reservoir

- Potential impact of the proposals upon Hirwaun Water Treatment Works

- Potential impact upon the structural integrity of DCC assets including sewers and

watermains within the boundary of the development site.

4.2 RELEVANT REPRESENTATION

Following the decision to accept the application for examination, DCC submitted its relevant

representation and registered as an Interested Party. DCC’s relevant representation is

included as Annex B to this submission.

4.3 ENGAGEMENT WITH HIRWAUN POWER LTD (HPL)

During both pre-application and examination stages of the Planning Act 2008 process, DCC

has been actively engaged with HPL in relation to the impact of the development upon our

assets.

We are pleased to confirm that we have recently met with representatives of HPL to discuss

our position and potential impact upon our assets. In addition, we can confirm that

discussions regarding suitable protective provisions have been positive. Further information

is provided in the following sections.


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5. LOCAL INFRASTRUCTURE

It is considered beneficial for The Panel as well as all Interested Parties to be provided with

an overview of DCC assets within the area, and specifically within the Order Limits subject to

this proposed Development Consent Order.

5.1 HIRWAUN WATER TREATMENT WORKS

Hirwaun Water Treatment Works (WTW) is the main potable water treatment facility

supplying water to the immediate area and the Cynon valley as a whole. The communities

supplied include Rhigos, Mountain Ash, Abercwmboi, Penderyn and parts of Aberdare. It can

potentially also feed Ynysybwl, Bryntirion, Glenboi and Darrenlas depending on network

configuration. Hirwaun WTW is fed by Penderyn reservoir, however the reservoir has no

direct catchment and is filled primarily by flows captured in two indirect stream catchments

– the Nant Bodwigiad and Nant Bwllfa. When inflow to the reservoir from these streams

decline they are supplemented by decanting water into Penderyn reservoir from the nearby

Nant Moel impounding reservoir. Should further raw water resource be required, there is a

borehole source available that can pump water into Penderyn reservoir.

Water is extracted from the adjacent Penderyn raw water reservoir and fed directly into the

water treatment works. Following treatment the water enters the onsite Clear Water Tank

(CWT) before being pumped to the Million Gallon/Rhigos Service Reservoir (SRV). From

there the water is pumped further up the valley to the Red Lion SRV as well as gravitating

directly out of the Million Gallon SRV to feed customers within the Cynon Valley.

Although a small quantity of potable water can be transferred into the supply network to

support Hirwaun WTW from the adjacent Taff Valley Hirwaun WTW remains the key potable

water supply for approximately 15,000 properties. Hirwaun WTW treats an average of 4

million litres of water per day.

A site location plan of Penderyn Reservoir and adjacent Hirwaun Water Treatment Works is

provided on the following page.


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5.2 HIRWAUN WASTE WATER TREATMENT WORKS (WwTW)

Hirwaun Waste Water Treatment Works is located close to the application site, and serves

the Industrial Estate, the village of Rhigos and outlying residential properties. Accordingly,

Any flows intended to discharge from this development site to the public sewerage network

would to Hirwaun Waste water Treatment Works.

The public sewerage system serving the area of the proposed development is predominantly

of a separate type, therefore a mixture of foul only and surface water only networks. It

should be noted that the site is crossed by a number of public foul water and surface water

sewers ranging in size from a 150mm diameter up to 450mm diameter. Information on the

location of such assets is included at Annex B of this submission and have since been shared

with Hirwaun Power Limited.


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6. DCC CONCERNS

DCC’s relevant representation attached at Annex B includes the following statement:

The specific concerns for DCC include, but are not limited to, the potential impact on:

a) Penderyn Reservoir

b) Hirwaun Water Treatment Works

c) Hirwaun Wastewater Treatment Works

d) Water resources

e) Water quality

f) DCC’s public sewers as a result of trade effluent discharges

g) The structural integrity of DCC assets and apparatus

h) DCC’s statutory rights of access to its sewers, watermains and associated

Apparatus

i) DCC’s ability to fulfil its statutory obligations

j) DCC’s land and associated rights

For the benefit of The Panel and all Interested Parties, these concerns are expanded upon below.

6.1 PENDERYN RESERVOIR, HIRWAUN WATER TREATMENT WORKS (WTW) & IMPACTS ON

WATER QUALITY & RESOURCES

- WATER RESOURCES

Section 5.1 has provided an overview of Hirwaun Water Treatment Works and its supply

catchment. Although a small quantity of potable water can be transferred into the supply

network to support Hirwaun WTW from the adjacent Taff Valley, Hirwaun WTW remains the

key potable water supply for approximately 15,000 properties.

DCC’s relevant representation identified possible impacts upon this water supply. To provide

further context, DCC’s concern is the vulnerability of supplies in this area since a proportion

of our customers normally fed from Hirwaun WTW are unable to be supplied from other

sources. Therefore, any detrimental harm to the function of Penderyn Reservoir and

subsequently the receiving Water Treatment Works would result in an interruption to supply

for a number of customers.

DCC has reviewed the application documents including the Environmental Statement which

relates to Water Resources. Further, DCC acknowledges information provided by HPL in an

email dated 15th August (attached at Annex C).

Based on this information and in particular details contained in Sections 9.7.17 to 9.7.20 of

the Environmental Statement which states that there will be “no change” to local water

supply resources (potential extra 30m3/d of demand), from a water resources/supply


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perspective DCC is satisfied that the proposed development does not raise any issues in

regard to additional demand placed on the clean water supply network.

Further, it is understood that there is no demand for any process related water supply

generated by this development.

- WATER QUALITY

DCC’s Relevant Representation also referred to the potential impact of the development

upon water quality. In this context, DCC has reviewed the application documents and further

information provided by HPL in its email of 15th August 2014.

DCC has considered the impact on water supply catchments in the vicinity of the site and is

satisfied with the impact of the development upon these areas.

DCC has also reviewed the impact upon the adjacent Penderyn Reservoir and Hirwaun Water

Treatment Works from a water quality perspective. Following a detailed analysis of the

Environmental Statement we concur with HPL’s position that the impact upon Penderyn

Reservoir are deemed to be not significant. DCC draws The Panel’s attention to HPL’s email

of 15th August and Figure’s 6.2 to 6.4 of the Environmental Statement which has been

considered as part of our analysis.

Notwithstanding the above, DCC recommends that provision is made for HPL to notify DCC

of any potential impact upon the reservoir and Water Treatment Works of which it becomes

aware. It is envisaged that such arrangements can be agreed as part of the Protective

Provisions unless The Panel considers that alternative arrangements should be considered.

6.2 HIRWAUN WASTE WATER TREATMENT WORKS (WwTW)

In considering the development proposals, DCC is satisfied that the discharge of domestic

foul flows only from the proposed development site can be accommodated within the public

sewerage system and receiving WwTW. Matters regarding ‘process’ related flows are

covered in section 6.3.

It has been noted that during operation HPL intend to discharge surface water flows to the

public surface water sewer to the south of the site, if determined to be the existing drainage

arrangements for the existing buildings at the site. In the interests of our existing customers

and the environment we encourage the developer to consider methods of Sustainable

Urban Drainage (SUDS). SUDs is an approach to managing surface water runoff which seeks

to imitate natural drainage systems and retain water on or near the site as opposed to

traditional drainage approaches which involve piping water off site as quickly as possible.

SUDs involve a range of techniques including soakaways, infiltration trenches, and

permeable pavements etc. SUDs offer significant advantages over conventional piped


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drainage systems in reducing flood risk by attenuating the rate and quantity of surface water

run-off from a site, promoting groundwater recharge, and improving water quality and

amenity.

In regard to the management of surface water flows deriving from the development site,

DCC encourages HPL to continue to engage with us to discuss and resolve matters.

6.3 DCC’s PUBLIC SEWERS AS A RESULT OF TRADE EFFLUENT DISCHARGES

HPL has advised DCC that any trade effluent waste generated during the power generation

processes will be removed by a licensed contractor and disposed of away from the site. This

is confirmed in HPL’s email of 15th August 2014. DCC therefore concludes that the

development will not dispose of any waste flows via the public sewerage network.

Should circumstances change, DCC invites HPL to discuss any requirements at the earliest

opportunity as an assessment of whether the sewerage network and receiving Waste water

Treatment Works has any capacity to deal with such flows would be required.

For the benefit of The Panel and the developer, DCC advised that should the discharge of

trade effluent, directly or indirectly to the public sewerage system be required, then a

Discharge Consent under Section 118 of the Water Industry Act 1991 should be sought from

DCC.

6.4 THE STRUCTURAL INTEGRITY OF DCC ASSETS AND APPARATUS

DCC owns, operates, maintains, improves and extends the system of public sewers, water

mains and associated apparatus together with treatment works and pumping stations

(‘apparatus/assets’) and has corresponding statutory duties to ensure effectual drainage and

for making available supplies of water.

DCC’s interest is to protect the apparatus/assets.

The spreadsheet and plans attached at Annex B identify all DCC’s apparatus/assets directly

affected by the proposed development.

DCC is negotiating with HPL in relation to the impacts of the proposed development on the

apparatus/assets in order to agree protective provisions to ensure that there is no adverse

impact upon the apparatus/assets and, subsequently, no adverse impact upon DCC’s

statutory duties, rights and powers.

DCC can confirm that discussions around Protective Provisions with HPL are in an advance

stage and it has been agreed between both parties that such provisions will be submitted to

the Examining Authority at Deadline II.


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6.5 DCC’S STATUTORY RIGHTS OF ACCESS TO ITS SEWERS, WATERMAINS AND ASSOCIATED

APPARATUS & DCC’S ABILITY TO FULFIL ITS STATUTORY OBLIGATIONS

DCC’s statutory rights to retain its apparatus in situ, to access, inspect, maintain, renew and

repair apparatus located within or in close proximity to the limits of the proposed

development must not be interfered with. These rights are set out in Sections 158 and 159

of the Water Industry Act 1991 and Part II Schedule 6.

As above, DCC is negotiating with HPL in relation to the potential impacts of the proposed

development on DCC’s statutory rights. Without unfettered access DCC would be unable to

fulfil its statutory obligations to lay, maintain, repair, replace etc. and ultimately provide a

service to its customers; in addition DCC could face a referral to OFWAT, its regulator

followed by enforcement requiring compliance with statutory obligations.

The Draft DCO provides HPL with an element of control over the apparatus. Protective

provisions will ensure that DCC maintains complete control of the apparatus and assets to

enable to fulfil its statutory obligations whilst allowing the HPL development to proceed.

Without these protective provisions, the Draft DCO could result in an interference with

DCC’s statutory duties, rights and powers.

6.6 DCC’S LAND AND ASSOCIATED RIGHTS

DCC must maintain unfettered access to its apparatus and assets at all times for the reasons

set out above.

DCC has reviewed the application documents relating to Compulsory Acquisition

information, specifically the Statement of Reasons, Funding Statement and Book of

Reference (documents 4.1, 4.2 and 4.3 respectively). DCC acknowledges that HPL has

recorded the parcels of land relevant to DCC and DCC’s particular interests within those

parcels. DCC has begun positive discussions with HPL about the protection of apparatus and

assets within those parcels.

1. Dŵr Cymru Cyfyngedig (DCC) is a statutory undertaker responsible for providing over three

million people with a continuous, high-quality supply of drinking water and for taking away,

treating and disposing of wastewater. DCC owns, operates, maintains, improves and extends

the system of public sewers, water mains and associated apparatus together with treatment

works and pumping stations and has corresponding statutory duties to ensure effectual

drainage and for making available supplies of water. DCC’s primary concern within the context

of this application for Development Consent therefore is to ensure that statutory obligations

are met and that our customers and the environment are protected.

2. DCC has actively engaged with Hirwaun Power during the pre-application stage with regard to

the potential impact of the proposed development upon DCC’s assets and apparatus. DCC will

seek to work collaboratively with Hirwaun Power in this context to inform the examination of

the application.

3. The specific concerns for DCC include, but are not limited to, the potential impact on:

a. Penderyn Reservoir b. Hirwaun Water Treatment Works c. Hirwaun Wastewater Treatment Works d. Water resources e. Water quality f. DCC’s public sewers as a result of trade effluent discharges g. The structural integrity of DCC assets and apparatus h. DCC’s statutory rights of access to its sewers, watermains and associated apparatus i. DCC’s ability to fulfil its statutory obligations j. DCC’s land and associated rights

4. The Environmental Statement (‘ES’) refers to the presence of Hirwaun Water Treatment

Works, Penderyn Reservoir and the associated catchment. The ES states that the effect of

emissions from the proposed development upon water quality will be negligible. DCC need to

understand more fully what the effects will be and how the ES arrived at such a conclusion.

DCC also need further details of the water requirements for the proposed development in

order to ensure that an adequate supply can be maintained for all DCC customers.

5. DCC advises that matters relating to emissions and their subsequent effect on water quality

are considered carefully by the Examining Authority (ExA) during the examination of this

application. DCC further advises that the impact from similar developments and the proposed

development should be considered cumulatively by the ExA during the examination of this

application.

6. DCC require details of whether it is the intention of the applicant to apply for discharge

consent for trade effluent to discharge from the proposed development into the public sewer

network.

7. DCC would welcome early engagement with Hirwaun Power in order to determine the

potential impact of the proposed development upon Hirwaun Wastewater Treatment works.

DCC has concerns about the impact of the development upon the capacity of the works and

require further details from Hirwaun Power before submitting more detailed representations.

8. The draft DCO in its current form is inconsistent with DCC’s existing statutory rights and

obligations. In this context DCC will engage with Hirwaun Power with a view to agreeing

protective provisions for inclusion in Schedule 9 of the Draft Development Consent Order

(‘DCO’).

9. In regard to land proposed to be compulsory acquired DCC will provide further information

detailing DCC’s concerns for each affected plot.

10. DCC intends to make detailed representation on the draft DCO during the examination stage

of this PA2008 process.

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A B C D E F G H

HIRWAUN POWER STATION DCC LAND SCHEDULE 15th JULY 2014

HIRWAUN POWER STATION DRAWING NUMBER DCC ASSET NAME TYPE OF DCC APPARATUS DIAMETER OF DCC APPARATUS DCC ASSET NUMBER RIGHTS TO BE ACQUIRED BY HIRWAUN POWER NATURE OF WORKS BY HIRWAUN POWER DCC LEGAL/STATUTORY RIGHTS

Overall Plan Reg5(2)(o) Drawing Number Figure 4 n/a Distribution Water Main 200mm n/a tbc Gas Connection Route and Electrical Connection Route Statutory Rights as shown on Plan 1 of 3

n/a Surface Water Gravity Sewer 300mm n/a tbc Gas Connection Route Statutory Rights as shown on Plan 1 of 3



n/a Foul Gravity Sewer 150mm n/a tbc Gas Connection Route Statutory Rights as shown on Plan 1 of 3

n/a Foul Gravity Sewer 300mm n/a tbc Gas Connection Route Statutory Rights as shown on Plan 1 of 3

n/a Distribution Water Main 6" n/a tbc Gas Connection Route Statutory Rights as shown on Plan 1 of 3

n/a Distribution Water Main 100mm n/a tbc Gas Connection Route Statutory Rights as shown on Plan 1 of 3


n/a Raw Water Trunk Main 315mm n/a tbc Gas Connection Route Statutory Rights as shown on Plan 1 of 3

n/a Abandoned Distribution Water Main 17/7/2001 10" n/a tbc Gas Connection Route and Electrical Connection Route Statutory Rights as shown on Abandoned Apparatus Plan 1 of 2

n/a Abandoned Distribution Water Main 12/12/1992 n/a tbc Gas Connection Route Statutory Rights as shown on Abandoned Apparatus Plan 1 of 2

Gas Connection Routes Drawing Number Figure 5 n/a Distribution Water Main 4" n/a tbc Gas Connection Route Statutory Rights as shown on Plan 2 of 3


n/a Trunk Water Main 300mm n/a tbc Gas Connection Route Statutory Rights as shown on Plan 2 of 3

n/a Abandoned Distribution Water Main 20/9/2001 3" n/a tbc Gas Connection Route Statutory Rights as shown on Abandoned Apparatus Plan 2 of 2

Hirwaun Power Station 15th July 2014

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Plan 1 of 3

Notes:Dwr Cymru apparatus plan

Dwr Cymru Cyf gives this information as to the position of its underground apparatus by wayof general guidance only on the strict understanding that it is based on the best informationavailable and no warranty as to its correctness is relied upon in the event of excavations orother works made in the vicinity of the Company’s apparatus and any onus of locating theapparatus before carrying out any excavations rests entirely on you. It must be understoodthat the furnishing of the information is entirely without prejudice to the provision of the NewRoads and Streetworks Act 1991 and of the Company’s right to be compensated for anydamage to its apparatus.Service pipes are not generally shown but their presence should be anticipated.

Reproduced by permission of Ordnance Survey on behalf ofHMSO. © Crown copyright and database right 2008.

All rights reserved.Ordnance Survey License number 100019534.

EXACT LOCATIONS OF ALL APPARATUSTO BE DETERMINED ON SITE.

15/07/2014Printed on:sgreyPrinted by:

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LEGEND (Representative of most common features)

Private Sewer Transfer

Inspection ChamberLateral Drain

Whilst every reasonable effort has been taken to correctly record the pipe material of DCWW assets, there is a possibility that in some cases pipe material (other than Asbestos Cement or Pitch Fibre) may be found to be asbestos cement (AC) or Pitch Fibre (PF) . It is therefore advisable that the possible presence of AC or PF pipes be anticipated and considered as part of any risk assessment prior to excavation

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Notes:Dwr Cymru apparatus plan








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Notes:Dwr Cymru apparatus plan1:1250 @ initial gas connection from proposed site








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294615, 205959

From: Murray Davies [[email protected]] Sent: 15 August 2014 13:14 To: George Owain Cc: HUTCHISON Robin ([email protected]) Subject: RE: Hirwaun Power - application for Development Consent Follow Up Flag: Follow up Flag Status: Completed Owain Apologies for the late reply, I was hoping to be able to send over the marked up Protective Provisions along with this but time has been against us this week. Please see the following clarifications from our Environmental Consultants and Engineers on the points raised during our meeting. Impacts on Penderyn Resevoir and Hirwaun Clean Water Works Ambient air quality in the vicinity of the Project is currently good and will remain so with the operation of the Project. The principal emissions form the combustion of gas are nitrogen oxides and carbon monoxide; emissions of hazardous pollutants such as dioxins and metals are not associated with gas power stations. Predicted concentrations of nitrogen dioxide and carbon monoxide resulting from the Project at Penderyn Reservoir are imperceptible. Impacts from annual and hourly nitrogen dioxide emission at Penderyn Reservoir are deemed not significant based on the Environment Agency H1 Annex F guidance (Figure 6.2 -6.4 in the ES). Impacts on the Hirwaun Clean Water works are also deemed not significant as ground level concentrations of nitrogen dioxide, the main pollutant of concern, over the works are imperceptible. Therefore air quality at both facilities will not be affected by the proposals. Domestic Waste and Water Connection Requirements A small amount of water will be required for drinking and sanitation purposes but this is not expected to exceed 30 m3/day. An existing mains water supply already provides the International Greetings UK site with mains water for toilets, kitchens etc. It is therefore envisaged that this water supply would continue to be used during operation of the Power Generation Plant for the same purposes. A comparable or slightly number of operational workers would be employed at the Power Generation Plant Site to the number employed at the International Greetings UK facility. Therefore the domestic/sanitary water requirements during operation will be broadly similar. During operation, surface water drainage from the Power Generation Plant Site may be discharged to the DCC surface water sewer to the south of the site if this is determined to be the existing drainage regime for the International Greetings UK site. Consent to discharge surface water runoff to the DCC surface water sewer will be discussed with DCC during detailed design of the Power Generation Plant to ensure that all requirements can be met. Where possible, existing discharge connections will be reused to reduce disruption to the public sewer. Site infrastructure will be designed in accordance with EA Pollution Prevention Guidelines and industry best practice. The drainage system that will be installed to serve the new Power Generation Plant Site will incorporate oil separators designed and manufactured in accordance with BS EN 858-1 to remove hydrocarbons and oils prior to discharge. A programme of regular maintenance will be put in place to ensure the installed infrastructure performs in accordance with design and a detailed emergency response plan will be prepared which will be enacted in the event of a spill of hazardous material. No effluent generated by processes on the Power Generation Plant Site will be discharged to sewers. Any water generated during washing will be retained on the

Power Generation Plant Site in a storage tank and subsequently tanked off-site by a licensed contractor for disposal at an appropriately licensed disposal facility. The proposed Power Generation Plant Site will not increase the impermeable area when compared to the existing International Greetings UK site. Therefore, the development of the Power Generation Plant will not increase the rate or volume of surface water runoff from the site when compared to the existing situation. It is proposed that the foul drainage from the Power Generation Plant will continue to discharge to the DCC public foul sewer located to the south of the Power Generation Plant Site. As noted above, a comparable number of operational workers would be employed at the Power Generation Plant Site to the number employed at the International Greetings UK facility and as a result there is no anticipated impact on foul drainage infrastructure or the receiving Hirwaun Waste Water Treatment Works. Consent to discharge foul water to the DCC foul water sewer will be discussed DCC during detailed design of the Power Generation Plant to ensure that all requirements can be met. Where possible, existing discharge connections will be reused to reduce disruption to the public sewers. Potential for heat to be generated by gas connection pipeline We can confirm that during normal operation no significant heat will be generated. During construction there will be welding activities which should be considered Hot works, however the heat is not predicted to be significant enough to reach any WW assets and is unlikely to take in close proximity to WW assets. Proposed method for crossing the identified raw water main to/from Pendyrn Reservoir We are proposing to open cut that road crossing as at this stage the ground conditions look inconvenient for an auger bore (but not ruling it out). We were aware of this asset and it the pipeline has been considerd in the conceptual design of the gas pipeline undertaken by HPL. We would propose that our crossing would not interfere with the asset and would expect that at detailed design stage HPL would discuss construction method statements with DCC prior to construction. The depth of cover information you provided is useful and would likely suggest that we would go deeper to avoid any issues. Hope the above is helpful and provides some clarity. If you would like to discuss further or have any questions, please let me know. We are currently looking at the PP’s and hope to send a marked up version over early next week. Kind Regards Murray

Stag Energy t: +44 (0)131 550 3380 f: +44 (0)131 550 3399 m:+44 (0)7748 394 762 www.stagenergy.com

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Dŵr ymru yfyngedig (D) - Planning Inspectorate · Dwr Cymru Cyfyngedig (DCC) Interested Party...

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