APPENDIX I: Comments received through EIS Scoping stage (4th June 2013 – 25th June 2013) th

A. Environmental Health Directorate (E-mail dated 20 June 2013) Comments With reference to your e-mail dated 4th June 2013 regarding subject indicated in caption and following review of the Project Description Statement, please be informed that we would like to have the following issues related to public health included in the terms of reference for this proposed development : Construction and (possible) land reclamation phase: • Air quality: o Airborne particulate matter and dusts from excavation and construction processes and waste management of such. o Effects of emissions from heavy vehicles possibly passing through residential area of Marsaxlokk, including airborne dusts from poorly covered vehicles carrying construction/excavation waste. • Noise and vibration from excavation, construction works, and heavy vehicle use including residential thoroughfares. • Emissions and accidental spillage of petroleum products and chemicals delivered to the site to support the operation of heavy equipment, electrical generating equipment and the construction process. • Waste management including construction and excavation waste and hazardous and chemical wastes.

EPD Comments Issues related to air quality and emissions, noise and vibrations during construction and operation, spillages, waste management, odours, impacts on the coast and marine bodies, risk assessment and cumulative impacts have been included in the TORs for the proposed development.

Operational phase of CCGT Plant: • Air emissions from production processes, • Sea Water quality due to emissions or accidental spillage to sea water. • Noise and vibration • Odours • Risk of accidents including explosions, spillages, leakages, fires etc • Waste management and disposal issues of generated waste streams Operational phase of LNG Plant: • Vapours and emissions arising during transfer and storage processes of LNG (gasoil and chemicals) • Air quality from presence of increased number of tankers supplying plant • Sea Water quality due to normal operations and accidental spillage possibly occurring during transfer of LNG to CCGT plant and from transporting tankers • Risk of accidents including explosions, spillages, leakages, fires etc.

The EIS should also include a detailed description of the measures envisaged to prevent, minimize and where possible offset any significant adverse health effects and nuisances on sensitive receptors in the Area of Influence and on the general public. This should include details of monitoring programmes that may be proposed. The EIS should also identify, describe and discuss in detail the possible health effects of any residual impacts that cannot be mitigated. The overall cumulative impacts of the development on receptors in the Area of Influence and the general public are also to be assessed. st

B. Member of general public – Mr. John Pace (E-mail dated 21 June 2013) Comments 1. Introduction It is proposed to comment on the various points in the Project Description Statement in the same order as in the statement. Page 6: A policy decision has been made by the

EPD Comments Comments noted. Issues related to siting and mitigation measures have

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Government of Malta that, from spring 2015, base load electricity should be sourced by Enemalta from an ndependently owned, state of the art, high efficiency power plant powered by natural gas.

been included in the TORs as issues that would need to be discussed in the EIS.

Comment: This in line with the pre election proposals made in the Prezi presentation http://prezi.com/hh0r5pwapr7t/pls-energyvision/? auth_key=444406384b5cb42558b80f1708a5dcb3a5795d0c. However it was expected that once elected and having access to Enemalta data and experience, government would modify the proposal as necessary while keeping to the main objectives. 2. Justification for Proposed Project Page 10: Table 2 2 shows the proposed electricity supply situation as of 2016. By this time, the following principle changes are planned in Malta....etc Comment: This is in line with the Prezi presentation, but may not be the best scheme. It makes more sense to convert Delimara 2B and possibly Delimara 2A to natural gas and leave Delimara 3 as it is. It is a historical fact that combined cycle gas turbines really took off with the advent of natural gas and most development of this plant has been on gas operation. Operating with gas oil decreases the maintenance intervals by 50% and requires the use of water injection for NOx control as well as NOx reduction in the exhaust, while natural gas firing can utilize low NOx combustors. It is a fact that most of the troubles experienced with Delimara 2B were associated with the use of gas oil as fuel. On the other hand Diesel engines using HFO have for long years been standard prime movers on large ships, using the same or similar plant as is installed at Delimara 3. Conversion to natural gas is a complex and expensive operation with hardly any advantages except for the elimination of dust removal plant at the exhaust. It is strongly suspected that the figures given by KEMA in the Prezi presentation were incorrect and that the conversion of Delimara 2B would be much more economical than that of Delimara 3. In addition using natural gas as a fuel requires additional compression. 3. DESCRIPTION OF THE PROJECT 3.1 – CCGT The layout and the description given in the document points to a system consisting of a single gas turbine, a heat recovery boiler and a steam turbine. However the range of output power restricts the probable system to one utilizing the General Electric S206FA with two gas turbines, similar to the configuration of Delimara 2B, but using more advanced gas turbines. Systems using gas turbines by Siemens, Alstom and Mitsubishi are excluded by the output limitation. 3.2 LNG receiving, storage, and regasification facilities The LNG will be stored in insulated and cooled tanks. This is unusual as refrigeration systems are not usually installed in plants of this size, and the LNG is kept in the liquid state by the continuous drawing off of the evaporated gas for use as a fuel. It is not known if the cooling will be a requirement in the specification of the plant, and this would add considerably to the cost of the project. The decision to convert Delimara 3 rather than Delimara 2b will mean that there will be two gas compression levels. 3.3 Onshore and floating options The indication is that a floating storage and regasification unit is preferred to an onshore one. There are many disadvantages in this option. This would appear to circumvent MEPA’s restrictions on land use, but would require a berth of sufficient draft close to the CCGT plant and to the fuelling ships. Maintenance of a floating installation will be more expensive than that of a shore based one. Site B for a land installation is inadvisable. This is known as the spoils area and is reclaimed land made up of material excavated when Delimara phase 1 was built. The ground may prove to be unstable and prone to subsidence. Removing material may also affect the stability of the gas oil tanks inshore as the spoils area acted as an anchor to the platforms on which the tanks were built. An alternative for a land based plant would be Mr Alfred Baldacchino’s villa, which was at one time earmarked for acquisition. It is on solid ground and at a high level so that leakages of gas will dissipate more easily. The difficulty would be the distance from the foreshore and the limitation on the length of cryogenic pipelines.

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3.4 Balance of Plant No comment 3.5 General Since the project has grown by the inclusion of the building of the jetty it is probable that 18 months will be insufficient for the completion of the project. Since the indicated area for the power plant (Area A) is reclaimed land it would be more favourable to site the plant in an area outside the present power station precincts. The plant (probably with 2 gas turbines, not 1 as in the original plans), would need a larger area and extensive piling. The requirement that “The CCGT shall be located in close proximity to the LNG Plant” is best met if both plants are built on solid ground at the south end of the power station area. 3.6 Fuel considerations The value of 2440m3 of LNG per day is reasonable and in line with expected loading. 3.7 Other reagents No comment 4. SITE SELECTION 4.1 Siting criteria and choice of location No comment 4.2 Delimara Power Station Site The 1995 Marsaxlokk Bay Local Plan was drawn up when there was public opposition to the siting of the power station at Delimara, and the alternative of refurbishing Marsa power station was being suggested. The realities of 2013 are different and with the closing down of Marsa there is no other possible site where to install power station plant. The expansion of the power station beyond its present precincts should be considered. Policy MP01 states that “...certain areas are not utilised to their full capacity and the Local Plan accepts that some expansion is possible. This applies to the Delimara Peninsula on the power station site, and the Freeport area.” Alternatives to Areas A and B should be sought. Possible areas are the land on the South between Delimara Road and the Gas Oil tanks and the land on the North in the area of the cable tunnel. The south site has the advantage of having the LNG unloading area, the RSU and the CCGT close together resulting in shorter pipelines and the possibility of using the regasification plant to provide cooling for the CCGT plant. 4.3 Project options Besides the given options the following should be considered: Areas outside the present precincts, as areas A and B are unsuitable Ground level and amount of excavation if areas other than A and B are chosen Feasibility of piling if areas A and B are retained. 4.4 Land and sea use around Delimara Site The use of the area south of the power station site has already been commented upon. The plans consider the construction of a jetty which will be capable of berthing two vessels (the FSRU and the supply vessel) each 300 m long with a draft of 12 m. This will require considerable dredging and may affect shipping inside the harbour. This dredging cannot be done close to the present wharf as it will undermine the sea wall. If the CCGT plant is placed in area A the jetty will have to be close to area A, where the sea is shallow, so a jetty near area B is more feasible, though this would create difficulty when the sea is rough from the South East. The location and the orientation of the jetty will be decided when a decision is taken as to the nature of the storage and regasification unit. It has not been revealed if the jetty will be part of the supply contract or if it will be constructed by Enemalta. 5. Issues and Mitigating Measures

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5.1.1 CCGT Plant No comment 5.1.2 LNG Plant This considers a land based storage and regasification plant. 180 000 m3 of storage represents 74 days use. It appears that large supply vessels will be used with a frequency of one every two months. It is important that deliveries shall be regular and will allow for varying weather conditions, as an alternative fuel will not be available. 5.2 Environmental – neutralizing and disposal There is little to say about the issues here, except that no mention is made of the following important considerations: Emergency Operation: It will be naive to assume that the plant will have no teething troubles and that it will never trip in service. The experience of the similar Delimara 2B plant is that such shutdowns occur. This will induce a sudden downturn in the rate of regasification of the LNG and may result in an overpressure in the LNG tanks. Since these do not withstand pressure a large amount of gas has to be vented to atmosphere and flared. This may be for a few minutes or for hours, if the shutdown is prolonged. Flaring: The report omits any mention of flaring. This is an important consideration as flaring is a major source of pollution, emitting large quantities of carbon monoxide and particulate carbon to the atmosphere. The report should include an estimate of the amount of flaring that will result from expected shutdowns and of the polluting gases and dust produced.

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C. Din l-Art Ħelwa (E-mail dated 21 June 2013) Comments 1. Assessment of Alternatives – Din l-Art Helwa is in favour of operating the Delimara power plant using gas instead of Heavy Fuel Oil (HFO) due to the better environmental performance of gas. It is however understood that the importation of gas to Delimara would be possible through one of two main alternatives: firstly through the importation of natural gas through a pipeline, or secondly by constructing a combination of onshore/floating storage and regasification facilities to enable the importation of liquefied natural gas (LNG) by shipment. These two main alternatives should be assessed as part of this application. Directive 2011/92/EU states that an EIA should include, “an outline of the main alternatives studied by the developer and an indication of the main reasons for his choice, taking into account the environmental effects”. This is important to ascertain that all options have been considered thoroughly and that the best long-term choices are made, with all the relevant environmental information made available to the public. Din l-Art Helwa also would like to have confirmation that it will still be possible to obtain EU funds for a gas pipeline if the onshore/floating LNG facilities are constructed. 2. Revision of National Energy Policy and Strategic Environmental Assessment Malta’s National Energy Policy of 2012 favoured a gas pipeline option (subject to EU funding) and was subject to a Strategic Environmental Assessment (SEA). Din l-Art Helwa notes that if the energy strategy is now being revised to introduce onshore/floating facilities for the storage and regasification of LNG, together with a significant change in the “default pecking order” (p. 74) of energy supply with reduced energy provision through the interconnector, then the National Energy Policy should first be updated and screened for an SEA. The proposed project should then be assessed through an EIA once the SEA stage has been completed. Regulation 3 (1) of the Strategic Environmental Assessment Regulations, LN 497 of 2010, includes “modifications” to

EPD Comments (1) An assessment of the different alternatives in terms of sites, technologies and layouts was included in the TORs for the EIS in question.

(2) Issues regarding the NEP and SEA are beyond the scope of the EIA process; however comments are being noted accordingly.

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plans and programmes that fall under the SEA Regulations. Furthermore, Regulation 4(3) of LN 497 of 2010 specifies that only “minor” modifications may be excluded. 3. Reduced energy provision through interconnector (air emissions) – Din l-Art Helwa notes that the proposal to construct onshore/floating storage and regasification facilities for LNG may imply a potential reduction of energy provision through the interconnector to Sicily. If more energy is generated onshore instead of being imported to Malta through the interconnector, this may imply that overall higher emissions from the energy sector may be generated in Malta than envisaged in the current National Energy Policy. This implication should be assessed in the revision of the National Energy Policy, as well as in terms of the Convention for Long-Range Transboundary Pollution (CLRTAP) and national emission ceilings, with special focus on Malta’s achievement of targets for nitrogen oxides. The environmental benefits or disadvantages of the proposed project with respect to air emission targets should be specified and compared to the current National Energy Policy.

(3) Issues related to air quality have been included in the TORs for the EIS for the proposed power station development.

4. Reduced energy provision through interconnector (cooling water discharge) – If more energy is generated onshore instead of being imported through the interconnector, this may require relatively larger amounts of cooling water with discharge into l-Hofra z-Zghira. This should be assessed when comparing the environmental impact of the two main alternatives for the importation of gas to Delimara.

5. Environmental Impacts on Land and Marine Areas – It is understood that the gas pipeline infrastructure may have less intense environmental impacts on land and marine areas around the Delimara plant, when compared to the construction of onshore/floating LNG facilities. The land and marine impacts of the two main alternatives should be assessed in detail, including the construction of a new jetty, dredging works, land reclamation, and the potential removal or relocation of the HasSaptan refuelling dolphin. 6. Air Emissions – The PDS (p.22) highlights that the new CCGT will have significantly lower emissions that the DPS 1 block for the same amount of electricity produced. According to the current National Energy Policy (p. 74), the DPS 1 block would however only generate a very limited amount of national energy requirements once the interconnector comes on line post-2014. The EIS should include a detailed comparison between a) estimated air emissions generated by the existing Delimara facilities together with the interconnector in line with the current National Energy Policy including conversion to gas, and b) estimated air emissions generated by a combination of the proposed project together with the interconnector and existing Delimara facilities converted to gas. The EIS should also include a comparison of: a) actual emissions at ‘Delimara 3’ operated with HFO, and b) estimated emissions at ‘Delimara 3’ operated with gas, to quantify the environmental benefits. 7. ‘Delimara 3’ Cost Benefit Analysis –

(4) Issues related to water quality, water bodies and marine ecology have been included in the TORs for the EIS for the proposed power station development.

(5) Issues related to land and sea uses have been included in the TORs for the EIS for the proposed power station development.

(6) Issues related to air quality have been included in the TORs for the EIS for the proposed power station development.

(7) Noted.

Enemalta’s Cost Benefit Analysis (CBA) of 2011 which formed part of the ‘Delimara 3’ extension application to MEPA, identified the gas pipeline infrastructure as the best approach for the importation of gas (Annex 1 of CBA) to operate the Delimara plant, including for reasons related to environmental risk and land utilisation. The CBA also included an estimation of emission costs, and this exercise should now be repeated as part of the overall environmental assessment of this application.

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8. Social Impact Assessment – The siting of floating LNG facilities in Marsaxlokk bay with a floating platform, a new jetty and the regular movement of large re-supply tankers, may have an impact on the use and enjoyment of the bay by local residents and commercial outlets, for example, restaurants, tourism outlets, recreational activities such as bathing, diving and fishing, bathing water quality, and the movement and berthing of smaller vessels in the harbour. The bay has a variety of users and is not an exclusively industrial zone. To clearly identify and address the impact of the floating LNG facilities on residents and commercial/tourism activity in the area, compared to the gas pipeline alternative, a full Social Impact Assessment should be carried out. Visual photomontages of all options and other information about the project and the main alternatives should be made available for comment during surveys. 9. Visual Amenity – The siting of onshore/floating LNG facilities in Marsaxlokk bay will impact visual amenity in the area. A study of visual impact should form part of the EIS, including full photomontages of all options of the project in the operational phase with all proposed facilities in place, including the storage tank platform, regasification equipment, a berthed re-supply tanker, the new stacks and the removal of the existing high chimney (as proposed). 10. Renewable Energy –

(8) Impacts on human populations have been included as one of the sections in the TORs for the EIS related to the proposed power station development.

(9) Impacts on landscape and visual amenity have been included in the TORs for the EIS for the proposed power station development.

(10) Noted.

Table 2.2 of the PDS does not include any estimations of renewable energy generation during the lifetime of the proposed project. Estimates for renewable energy should be included in the assessment. (11) Noted. 11. Justification for project – In the section ‘Justification for Project’, the PDS does not give details of specific environmental benefits to be achieved by the proposed project compared to the current National Energy Policy – these should be specified more clearly. Din l-Art Helwa would like to receive a copy of the Terms of Reference for this EIS once they have been drafted.

D. Birżebbuġa Local Council (E-mail dated 24/06/2013) Comments With reference to the Project Description Statement relative to the Delimara Gas driven Power Station, the Birzebbuga Local Council submits the following for consideration when the Terms of Reference for the EIS are drafted:It is to be underlined that the community of Birzebbuga will be impacted by the activities of the projected gas power station, including its ancillary facilities. In particular it will be impacted visually as well as by its emissions and safety features as well as its conforming or otherwise to the various environmental policies/legislative measures referred to in the PDS. Birzebbuga Local Council underlines the need to monitor adequately air emissions, acoustic pollution, light pollution, pollution of the sea as well as impacts on flora and fauna in both Marsaxlokk Bay as well as the surrounding areas. This exercise is to be a cumulative one, that is, it has to take into consideration existing impacts in the area as the point of departure of any assessment.

EPD Comments Issues related to air quality and emissions, environmental risk, noise pollution, light pollution; impacts on the marine environment, impacts on both terrestrial and marine ecology were all included in the TORs for the EIS for the proposed development of the Delimara Power Station.

The supply of gas to be utilised in the power station as well as its method of storage needs to be adequately addressed in particular with reference to both the communities of

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Birzebbuga and Marsaxlokk as well as the users of Marsaxlokk Bay (eg. fishermen, various seacraft enthusiasts, as well as swimming and sports activities). In this respect Birzebbuga Local Council requires that the communities residing around Marsaxlokk Bay (ie. Marsaxlokk and Birzebbuga) be involved through their Local Councils in the Monitoring of the project both during its implementation as well as during its Operational stage.

E. Marsaxlokk Local Council (E-mail dated 25/06/2013) Comments Preamble This document is being submitted as a response by the Marsaxlokk Local Council as part of the consultation process prior to the preparation of an Environment Impact Assessment covering the new LNG fuelled Combined Cycle Gas Turbine, and associated LNG storage facilities. This document is based on the Project Description Statement issued by Enemalta and dated the 31st May 2013. Introduction The utilisation of Natural Gas as a primary fuel for the generation of electrical energy has finally come to the point of realisation. Natural Gas is the cleanest fuel when compared with the other liquid fuels, ie Heavy Fuel Oil ( HFO) and gasoil , currently in use. The Marsaxlokk Local Council has made several representations in the past, aimed at bringing about an improvement of the Air Quality in this and surrounding localities. The change to LNG should particularly benefit the residents in the southern part of the Island, where industrial activity is more intense. This submission focuses on the following points:

EPD Comments Issues related to air quality and emissions, noise pollution, environment risks, issues associated with alternative sites and technologies, and wave studies were all included in the TORs for the EIS for the proposed development of the Delimara Power Station.

Exhaust Emissions from the new LNG CCGT unit and consequent reduction of Emissions from Delimara Power Station as a whole. Noise Emissions from the new LNG CCGT unit. Risks associated with the storage of LNG both on land and shipborne as proposed. Relocation of the storage facility outside the Port of Marsaxlokk. Provision for possible alternative LNG gas pipeline supplies. Wave Studies. Visual Impact Temperature difference at il-Hofra z-Zghira Exhaust Emissions from the new LNG CCGT Plant. Natural Gas is the cleanest fossil fuel available. Particulate Matter PM10 and PM2.5 emissions from the combustion of natural gas in a Gas Turbine should be extremely low in comparison with the technologies currently utilised. The EIA should therefore indicate the marked improvement in these emissions relative to the plant current in operation. Particular attention should be placed in this case on NOx emissions due to the relatively high combustion temepratures. Noise Emission from the new CCGT plant. The proposed site for the location of the the new CCGT plant, marked as site A, places the plant in close proximity of the shoreline . At this point also the plant will be the closest to the village of Marsaxlokk. The CCGT plant currently in operation designated as Phase 2B produces no inconvenient sound emission. The Envirionment Imapct Assessment would do well to assess this issue and indicate the increase in noise, if any, that is to be expected from the operation of the plant. Risks arising from the storage of LNG Gas. The storage of LNG whether on shore or shipborne presents a particular engineering challenge. LNG is maintained in liquid form by maintaining it at temmperature below 162◦C. Above this temperature the gas liquid boils to gas. 1m3 of Liquified Natural gas will produce about 600m3 of Natural Gas in the gas state. These conditions therefore place particular demands on the refrigeration plants that maintain the gas as a cyrogenic liquid. The study should indicate the measures that will be taken in the design of the

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refrigeration plant , including plant redundancy and redundant power sources that will be necessary to maintain the gas as a cryogenic liquid. Inevitably some degree of venting of gas may take place , and therefore the upcoming studies should determine the degree of venting that may occur . This should also include an assessment of the risk of ignition of the vented gas and consequences that may arise on the storage facility located at site B or an LNG Carrier berthed there, and storage facility itself and the resultant impact on Marsaxlokk and environs. It is pertinent to indicate that the storage facility will have a capacity of 180,000m3 of LNG which will cover the supply to the power station for 74 days, a substantial quantity. Relocation of the Storage facility outside the Port of Marsaxlokk. The Project Description Statement published by Enemalta indicates that the LNG gas carrier which may be utilised for LNG Gas Storage will have a capacity of 180,000m3 possibly having an overall length of 300m, a beam of 52 m and requiring a draught of 12m. Such a vessel will present a substantial visual impact if it is ,as the report states, moored indefinately at a location close to the Power Station. It would therefore be prudent to consider the mooring of the LNG Gas carrier outside the port of Marsaxlokk. Regasification of the gas will occur on the vessel and the gas transfered by a submarine pipeline to the power station plant. This option presents a number of advantages: 1. 2. 3.

4.

Any risks that may arise from gas leakages or spills are reduced. The visual impact of the static LNG gas carrier inside the port will be obviated. Possible restrictions to ship movements within the port, including oil Tankers that will for a period of time continue to berth at Delimara Power Station, will be eliminated. The laying of a submarine pipeline and anchoring facilities of the LNG Gas carrier outside the port will replace the need to dredge the port to permit berthing of the storage carrier and also the supply carrier, and also the need to construct mooring facilities will be eliminated.

Provision for possible alternative LNG gas pipeline supplies. The Project Description Statement focuses on the supply of LNG by means of an LNG Carrier. There is no reference to the possibility of delivering Natural Gas through a pipeline from other sources. Our Nation may consider the possibility of laying a pipeline between Malta and Sicily, sometime in the future, connecting to the gas network on mainland Europe. There is also the possibility that prospecting for oil in Maltese Territorial waters will finally bear results and that our nation can possibly also tap into its own resources. The provision for the possible connection of a submarine pipeline to feed Delimara Power Station should not demand any significant capital expense and could be included in the development plan. Wave Studies within Marsaxlokk Bay All infrastructural works along the shoreline of Marsaxlokk Bay affect the wave reflections within the bay. This poses risks to the numerous fishing vessels moored in the port as well as on the shore, both natural (such as sandy beach at il-Maghluq) and on other existing infrastructure (such as pontoons and promenade). Thus, it is being requested that the terms of reference for the EIS would include Wave studies within the port and the respective effect of any added infrastructural works. Visual Impact Marsaxlokk is well known as a picturesque village. In fact it features prominently on almost all tourism brochures. Unfortunately, the existing power station at Delimara peninsula poses a negative visual impact. Thus, it is being requested that the Terms of reference for the EIS would include studies of the visual impact from various viewpoints. The study should include means as to how this impact from both the existing and proposed power station could be reduced. This could include, but not be limited to, proposals for landscaping.

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Temperature difference at il-Hofra z-Zghira Cooling system of the existing Delimara Power Station involves the transfer of seawater from Marsaxlokk Bay to il-Hofra z-Zghira at an increased temperature. This results in an increased temperature of the sea at il-Hofra z-Zghira. It is being requested that the TOR for the EIS include any changes that may result with the new plant. In addition it is being suggested to study the possibility of extending the discharge pipe to a position outside il-Hofra z-Zghira so that this bay is restored to its natural temperature levels. th

F. Prof. E. A. Mallia/Dr. M. Fsadni (Letter dated 25 June 2013) Comments Page 10: The sequence of the changes planned is misleading. The logical (engineering) order is: (1) immediate preparations and planning for securing a supply of LNG; (2) completion of the interconnector (IC); (3) decommissioning of MPS; (4) construction of LNG storage facility and regasification; (5) installation of the new CCGT plant; (6) commissioning and operation of the CCGT plant; (7) conversion of DPS 3 motors (possibly two at a time) to run on LNG; (8) decommissioning of DPS 1 – steam cycle; (9) decommissioning and dismantling of HFO storage.

EPD Comments Issues related to air quality and emissions, noise pollution, environment risks, issues associated with alternative sites and technologies were all included in the TORs for the EIS for the proposed development of the Delimara Power Station.

Page 11: Figure 2-4 appears to be somewhat schematic. Page 12 3.1: If the CCGT will be run at ‘160 MW load or lower during nught time’ the cycle with definitely be significantly under maximum efficiency. It is not clear at what levels the supply through the IC will be managed under our variable demand regime; in turn the operation of the interconnector will impinge on the demand on local generating plant. If the CCGT is run at 160 MW or less at night as suggested, the IC would have to be shut down. Ti date no information is available about minimum IC loading, which would probably be a feature of the IC supply contract. 3.2: The statement that ‘it may be necessary to maintain up to 180,000 m3 of storage capacity at the site’ may not instil public confidence. The storage is much greater than was proposed some months ago. Floating LNG storage is certainly the most rational solution particularly in terms of the timescale targets. But the statement that ‘the size of the tanker would be dependent on what is available on the market’ is somewhat vague and gain could be a major issue of public perception. Such storage capacity would necessitate a ship of roughly 300m length, 50m height and 50m breadth as well as higher superstructure elements. The mooring of an LNG tanker at the Delimara quay would restult ina big visual impact. Indeed, an observer at M’Xlokk or B’Bugia would see the tanker hiding most of the Delimara plant and ridge above. It is certain that the residents will not be pleased with this, even if they raise no objection to the 180,000 m3 storage. The issue of manoeuvering, mooring and positioning, as well as any related safety issue related to the LNG supply ship, particularly in the case of a FSU/FSRU solution, has not been treated. Serious consideration should be given to locating the floating storage on the seaward side of Delimara peninsula to remove visual impacts. This may also facilitate the supply of LNG by tanker. The facility would only be exposed to North Easterlies that are not very frequent and exhibit only long (if high) swells. Anchoring techniques have been well mastered, even in harse North Sea conditions. A fixed, adequately, insulated link to the re-gasifier on land should be possible, if the re-gasifier itself were not on the ship. The complete FSRU solution would have the advantage of a short gas pipeline that is far easier to construct and maintain than a line carrying LNG. 3.4: The mention of ACC is superfluous for very obvious reasons (large structure, power consumption for fans, pumps, etc.).

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3.5: Use of the cooling effects of the LNG gasification necessitates close proximity of the regasifier to the generation plant. During the public consultation the opposite was proposed by Enemalta. Furthermore, it needs to be clarified how signifcant is the cooling effect from the regasification on the cooling water of the Delimara plant. It may be worth considering cooling the intake air to the gas turbines which would increase their efficiency somewhat. Page 14, 3.6: It is assumed that DPS 3 would be run at part load through the switching off of individual engines. This has to be stated clearly. It would be instructive to present variation of fuel consumption estimated on the basis of the different plant following representative daily demand curves. It is unclear how sensitive the quantities are to the choice of plant dispatch. One would assume that maximum possible use of the DPS 3 engines would lead to the highest efficiency of supply. If as stated the CCGT is run in a base load role, the load covered by the IC at minimum demand would be very small. All in alll, the document does not give an indication of the dispatching of the plant (how the various generating units are loaded), and particularly the loading of the interconnector. Page 18, 5.1: No mention is made of the visual impact of the floating LNG storage ship (see above) moored at the quay of DPS. This applies also to 5.3. Page 19: Remarks about possible need to remove NOx from exhaust are too casual. Given the rate of burning of gas, it is possible to compute rate of NOx production and the effects of technology for abatement at source. Final points: No mention is made about training personnel on LNG technology and LNG electricity generating plant, and no mention of training for accident prevention, tackling and mitigation.

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APPENDIX II: Minutes of EIS scoping meeting dated 19th June 2013 Meeting

Scoping Meeting: EA 00014/13: Delimara Gas and Power - CCGT (Combined Cycle Gas Turbine Power Plant) and LNG (Liquified Natural Gas) Receiving, Storage and Regasification Facilities, at, Delimara, Marsaxlokk

Date

19.06.2013

Duration

Circa: 16:00 – 17:45 hrs

Location

MEPA Boardroom

Alex Camilleri (Environment Protection Directorate - EPD) opened the meeting by explaining the agenda and the purpose of the meeting, namely that the applicant, architect and consultant would be delivering a short informative presentation and that attendees are welcome to discuss and raise questions in view of the drafting of the terms of reference for the preparation of the Environmental Impact Statement (EIS). David Galea delivered a presentation on behalf of applicants Enemalta explaining the aims and objectives of this project. Ing. Peter Grima and Perit Peter Zammit continued by presenting the technical details of the proposal while Dr. Paul Gauci (EIA consultant) provided details vis-à-vis the prima-facie environmental issues related to the proposal. Following this presentations, the floor was opened for comments.

Perit Edric Micallef (Marsaxlokk Local Council): Mr. Micallef indicated that the MLC welcomed the new proposals by Enemalta with respect to the gas powered plant, including the conversion of the DPS6 (‘BWSC’ extension). The following queries were made: (1) the coverage of the new EIA i.e. whether it will be assessing all proposed interventions or just the new PS; (2) whether the LNG storage will be temporary or permanent as this would ultimately affect the position taken by the Local Council vis-à-vis the acceptability of the distance from the shore and if there is a possibility of installing a gas pipeline to shore should the FSRU be located further offshore; (3) whether a wave study will be commissioned as part of the EIA; (4) whether the new EIA will also be covering the air quality impacts, including odours, related to the ventilation of the storage tanks; (5) the level of detail in relation to the risk assessment and the level of detail of such and (6) issues related to location (e.g. the possibility of locating the plant in front of the BWSC extension). David Galea (Enemalta): Mr. Galea confirmed that the FSRU can be both temporary and permanent in nature. Furthermore, government is currently assessing the feasibility of the installation of a gas pipeline. Paul Gauci (Consultant): Clarified that the CCGT project will be replacing Delimara 1 and not be in cumulation with it, rather than providing additional supply. Robin Hall (Technical Consultant for Enemalta): Provided further technical details vis-à-vis LNG (which is a cryogenic liquid) and thus a leak from the proposed tanks will not lead to a major change in pressure of the gas inside the tanks and would vaporize quickly upon release on either land or sea. Furthermore, detailed analysis of any risks would be a result through Seveso-related assessment. Ing. Arthur Ciantar (Marsaxlokk Local Council): Made the following comments: (1) Storage facility: risks always exist in terms of both land-based and ship-borne storage, particularly vis-à-vis release of LNG (the density factor of 600, which is substantial). A minor loss in LNG may lead to a substantial release of gas, and also to substantial damage if a point of ignition is found. This may also be of risk to other areas of the Delimara PS. Furthermore, the storage capacity of 180,000 cubic metres (approx. 74 day storage), in the event of an accident, may lead to significant impacts on the immediate environment. (2) Gas pipeline connection: the PDS does not indicate any future plans for a pipeline connection; another possible alternative to the proposal may be a pipeline to storage tank connection which provides relative risk comfort (particularly from an accidental escape of gas). The connection with the EU gas grid and a possibility of having the Maltese gas network feed into such a system was also mentioned. Robin Hall (Technical Consultant for Enemalta): Risk is also present as such plants are designed to decrease risk. The possibility for releases such as gas clouds is also present. For a major FSRU plant, the risk within 1 km is considered to be remote (‘as being hit by lightning’) and the risk from the release from the tankers is more likely,

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however any such releases would need to pass through three layers within the tank before being released into the atmosphere. The risk associated with pipelines is also high and thus risk analysis is essential. Chris Farrugia (Transport Malta): Asked the following: (1) Whether the marine facilities required will be constructed ahead of the new PS or whether these will be eventually be constructed by the operator. The requirement for a breakwater was also questioned, particularly vis-à-vis the storage facilities. (2) Questioned whether any existing berthing facilities have been considered. (3) In terms of configuration, the mooring of the vessel to the jetty should also be taken into consideration. Peter Zammit (Architect – iAS): Replied that existing berth was considered, however draught required is not enough. With respect to the orientation and maneuvering at the jetty, discussions have already been carried out with TM accordingly. PZ also noted that further nautical/marine studies would be required. Furthermore, the offset between the jetty and the mound of material found on site shall be determined by the necessary safety and risk assessments. David Galea (Enemalta): With respect to the query associated with who will be carrying out the ancillary interventions, a clearer position would be at hand once the final proposals are submitted to Enemalta for the necessary evaluation. The possibility associated with whether the proposals will be carried out by Enemalta or by the successful bidder is still undecided. Nathaniel Cutajar (Superintendence of Cultural Heritage – SCH): The SCH requested details vis-à-vis the footprint of the proposed development and whether there would be any new interventions beyond the current footprint of the DPS. David Galea (Enemalta): Replied that the jetty and any related coastal infrastructure would need to be located outside of the current footprint of the DPS. John Grech (Birzebbuga Environmental Action Group – BEAG): Mr. Grech made the suggestion that the storage thanks can be located at Hurd’s Bank. Furthermore, real-time readings of emissions from the Delimara PS were requested in order to have a clearer idea in relation to the chemicals involved in the process. As in the case of the Malta Freeport, two other main concerns are noise emissions and light pollution. Mr. Grech also asked as to where power plants of a similar nature are located. David Pisani (Żminijietna): Mr. Pisani requested the following issues to be included in the Terms of Reference for the EIS: (1) social impacts on the nearby residents, namely Marsaxlokk; (2) study of the prices and (3) the issue of sovereignty vis-à-vis the gas pipeline connection to mainland Europe. David Galea (Enemalta): Confirmed that an assessment of the social and economic impacts from the proposal will be carried out. Prof. Edward Mallia (Friends of the Earth): Made a number of comments in relation to the following: (1) On the land-based storage facility – asked as to whether there is enough space for the 180,000 cubic metres storage capacity for LNG or whether the floating solution is a more viable one. Mr. Mallia also queried how the 180,000 cubic metre capacity was calculated. (2) With respect to the ship-borne solution, Mr. Mallia asked as to whether the FSRU solution would lead to having a ship degasifying and another tanker berthed for replenishment of the supply in question. He also noted that if possible the ship-borne solution should not be anywhere close to Marsaxlokk. (3) Mr. Mallia also commented that de-NOx would be expected to have implications on operational fuel consumption efficiency and should be considered as a certainty, not an option.. David Galea (Enemalta): Provided the following replies: (1) With respect to the total storage capacity being quoted, the projected 180,000 cubic metres are the worst-case scenario that may be stored on site. (2) Given the total capacity to be stored on site, it is likely that around 5 shipments of LNG would be required per year; with the likely possibility of ship-to-ship transfer. (3) In relation to the location of the FSRU further offshore, preliminary studies have indicated that around 10 miles offshore, the installation of the FSRU would bring greater floating solutions and challenges. Wave motion, which may also be another important factor offshore, may lead to increased boil-off gas dispersion. Ing. Arthur Ciantar (Marsaxlokk Local Council): Commented that temperature, however, should not pose problems given the properties of LNG. He also pointed out that siting of the plant offshore could be more acceptable.

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Thomas Leonard (DNV KEMA, Consultants): Commented that siting the plant further offshore would lead to an increase in costs. From a safety point of view, both options (nearer and farther out from the shore) can be engineered to function in a safe manner. Antonio Anastasi (Flimkien għal Ambjent Aħjar – FAA): Made the following comments vis-à-vis the content of the Terms of Reference: (1) The inclusion of a Health Impact Assessment; (2) Issues related to archaeology should be looked into given that the area in front of the PS is seen to be rich in artefacts; and, (3) A public hearing should be carried out further on in the stage as part of the public consultation process. Mario Fsadni: Asked whether the decommissioning of Delimara Phase 1, including the chimney stack, will be considered. Peter Grima (Enemalta): Provided a clarification vis-à-vis new chimneys given that these are required in relation to the new proposals. John Grech (BEAG): Commented that there is no clear indication of the amounts of hazardous waste to be required for the plant or to be generated by the plant. David Galea (Enemalta): Replied that Delimara 3 (BWSC) was not included in the project description given that it is not part of the power-purchase agreement. The interconnector and the conversion of Delimara 3 are being considered separately. DG also replied that the current HFO tanks will be left there as reserved capacity. In terms of hazardous waste, DG pointed out that the amount of urea required for the new plant is less than the amounts required at present. Arthur Ciantar (Marsaxlokk Local Council): Pointed out that there is no mention vis-à-vis the conversion of DPS 1 to gas. Peter Grima (Enemalta): Replied that DPS 1 is currently not energy-efficient and thus converting it to gas-power is not cost-effective.

Alex Camilleri (EPD) closed meeting by thanking the participants and confirming that the issues raised during the meeting will be factored into the formulation of Terms of Reference. Any comments can be sent via email to: [email protected] or by post to the attention of the EIA Team, Environment Protection Directorate, St Francis th Ravelin, Floriana by not later than Wednesday 26 June 2013.

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APPENDIX III: Comments received through EIS Review period (2nd September 2013 – 2nd October 2013) A. Din l-Art Ħelwa (E-mail dated 07/01/2013) Comments 1. EIA Directive 2011/92/EC requires a developer to provide, “an outline of the main alternatives studied by the developer, and an indication of the main reasons for his choice, taking into account the environmental effects.” Yet the draft EIS states that it will not assess any technological alternatives (eg. the supply of gas through a pipeline) since this project is a government policy decision. The EIA Directive does not exempt a developer from assessing alternatives due to a policy decision. This argument would exempt all government projects from the EIA Directive, which is certainly not the case. Furthermore, government policy on energy and with an impact on land use should first be assessed through the Strategic Environmental Assessment procedure and this has not yet been carried out. Further information on this issue can be viewed here: http://dinlarthelwa.org/uncategorized/strategicenvironmental-assessmentrevisionof-national-energy-policy/

ERSLI Responses (1) An answer to this query has been included as part of the second draft submission.

EPD Comments Noted.

2. The report states: “Given that the operator of the CCGT plant/LNG facilities has not been selected yet, the level of details into which the above descriptions of the project and the project management arrangements is limited. However this Coordinator of this EIA submits that the research carried out by the individual ESR authors, their assumptions and the information provided to the EIA Team by Enemalta ensure that the submitted environmental information draw up an accurate picture of the environmental and social implications of the proposed development.” (p.54) Din l-Art Helwa does not agree that the environmental implications of the project are adequately assessed in this draft EIS. The limited level of detail leaves many questions unanswered, for example:

(2) The draft EIA had looked at different alteranative and made a numebr of assumptions to arrive at certain conclusions in relato to impact. Further to the selection of the preferred bidder the EIShas been revisited and data originally assumed has been confirmed or otherwise amended ot reflect the actual submittal of the bidder.

Noted.

a. The EIS does not clearly present which of the three proposed layouts of the CCGT project at Delimara has the least overall environmental impact and which is the preferred option. The EIS must include a clear comparison of all the environmental impacts of the various layouts being considered, to enable the best choice to be made. b. Besides the three proposed layouts, point 1.2.3.5 (p.52) indicates that the operator may propose yet another location for berthing facilities which will require dredging and land reclamation for supply carriers to be accommodated, and notes that the research required for this option has already been carried out – yet the details of this option are not included. This information must be provided for

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assessment and evaluation in this EIS. c. The EIS states that it might be necessary to remove or relocate the existing Has-Saptan re-fuelling dolphin, but does not confirm whether this is the case or not. Point 4.3.12.10 (p.443) on the Has-Saptan dolphin is incomplete and ends mid-sentence. Information on this point may be relevant to choosing which layout option is preferable, in line with Regulation 20(10) of LN 114 of 2007. The EIS must present a full analysis of the predicted cumulative/residual impact of the removal/re-location of the Has-Saptan re-fuelling dolphin, together with the alternatives for this dolphin and proposed mitigation measures, if any. d. The Water Quality Assessment in the EIS notes that, “limited detailed information is available of the required amounts of land reclamation, excavations or dredging.” Information on these matters is relevant to choosing which layout option is preferable. Detailed information on these points must be included for assessment in the EIS in line with Regulation 20(10) of LN 114 of 2007.

Comments noted.

Noted.

e. In its discussion of the disposal of the dredged material, the EIS states that, “The level of confidence in assessing the significance of such impact is presently low. This is mainly due to insufficient data being available on the quality of sediments in the areas to be dredged. Since marine sediments are known to be quite a dynamic phase, sufficient samples will need to be collected to get a picture of the vertical and horizontal distribution of potential contaminants in such sediments. The TORs issued by MEPA forthis EIS stipulate a total of 7 to 15 samples which need to be collected since the approximate amount of dredged material will amount to between 100,000 to 500,000 m3 (MEPA TORs Appendix 4, Table 1). Once this information is available, the likely environmental impact of disposal ofsuch dredged samples at sea, will be more reliably determined, and subsequently, the most environmentally appropriate disposal option could be recommended”. The Coordinator notes that, “the unavailability of the data referred to by Axiak is a function of the level at which this EIS has been formulated. Given that the operator of the proposed development has not been selected yet, a detailed design of the structures required for the CCGT plant and LNG facilities are not available yet. Once the operator is selected and drawings prepared the data will evidently be available.” (p. 302). Detailed information on this matter, together with data on the extent of material to be excavated and dredged, is relevant to choosing which layout option is preferable. The EIS cannot be considered complete before this data is available for assessment, and the disposal method recommended, in line with Regulation 20(10) of LN 114 of 2007.

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f. The Water Quality Assessment states: “Likewise, it is likely that during the construction phase, there will be increased maritime activity to and away from the DPS construction sites. It is yet unclear the extent to which excavation and demolition materials will be transported away from the site via sea transport.” This information must be provided and assessed in the EIS.

Comments noted.

Noted.

g. Point 4.1.5.131 states: “prediction of the impact of the development on the ecological status there is very difficult and with a low level of confidence given that any potential impacts will depend heavily on a number of factors and variables, including the present lack of detail on the exact nature of the works to be undertaken, the level of workmanship and supervision of works, application of precautionary procedures, the hydrodynamic regime of the area, duration of the works and time of the year when the works are carried out (due to the indirect influence on rainfall, wave action and sea currents) and mitigation measures, if any, that will be adopted.” Information on the exact nature of the works to be undertaken and other details must be available for assessment in the EIS, in line with Regulation 20(10) of LN 114 of 2007. h. In the Qualitative Risk Assessment, the EIS states that, “The QRA is based on information and data strictly associated to the location, the site facilities and surroundings, listed below. Given that the operator has not been identified most of the data that is required was not available to Vaccari. For this reason expert estimations were required in order for the QRA to be carried out.” (p.420). The QRA should be carried out when more actual data is available for assessment, instead of estimations. i. The EIS notes that the FSU will need to discharge ballast water into Marsaxlokk bay during the unloading of LNG, but does not provide details of the predicted environmental impact or the relevant regulatory framework. Similarly, the discharge of bilge water is noted but not described in detail as the expected volumes “are not available at this stage”. This information must be provided to assess the environmental impact of this activity in the EIS. j. Regulation 14(2) of LN 114 of 2007 stipulates that the EIS should describe the after-use of the development where the proposed development has a limited life. This information is missing. It should be included in the EIS, irrespective of whether or not further details on decommissioning are provided in the environmental permit at a later stage, as the environmental permit and the EIA are not being carried out as a single procedure for this application. This information may also have a bearing on which of the three layouts is considered to be preferable, as is also indicated in the Social Impact Assessment in this EIS,

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and the data is therefore also required in terms of Regulation 20(10) of LN 114 of 2007. 3. The EPS previously submitted by the same applicant (Enemalta) in its application for the submarine interconnector cable to Sicily states that the Interconnector will enable the closure of the Marsa Power Station. The EPS for the Interconnector states that, “Under the EU’s Large Combustion Plants Directive (LCPD) (EU Directive 2001/80/EC) the Marsa Power Station has exceeded its 20,000 allotted hours in 2011. The Marsa Power Station is not expected to be fully decommissioned before the undersea cable link is connected to the European Power Grid by 2013. At present, the Marsa Power Station provides 45% of the total electricity generating capacity on the Maltese Islands, and if this Power Station will be shut down at this time, this will create an insufficient capacity to meet the full demand for electricity.” In the assessment of alternatives the ‘Do Nothing/Zero Option’ should therefore not include the continued operation of the Marsa Power Station whose decommissioning is dependent on the Interconnector and not on this proposal for a CCGT plant and LNG facilities. For the same reason, any benefits of the new CCGT plant as presented in the EIS should be compared to a scenario which excludes the Marsa Power Station, which is due to be shut down as soon as the Interconnector is in place in 2013/14, well before this proposed CCGT plant is operational. 4. The EIS indicates that NOx air emission targets will be adhered to in line with the Gothenburg Protocol, as long as extensive use is made of ‘clean’ energy from the Interconnector, together with the two gas-fired plants (including Delimara3 extension). What is the expected utilisation rate of the Interconnector, year by year from 2014 to 2020? What is the estimated timeframe for the conversion of the Delimara3 extension to gas? This information must be clearly presented in the EIS.

5. The Project Description Statement states that the Delimara3 extension (when converted to gas) is only expected to have a utilisation rate of 50% once the proposed CCGT plant is operational. What are the expected utilisation rates of the proposed CCGT plant, the Interconnector, and the rest of the Delimara plants,

The baseline scenario taken into consideration was that requested by MEPA which as far as we are informed was based on the current situation which is currently being monitored. We are in full agreement that MPS will be shut down as a result of the interconnector and not as a result of the proposed CCGT. The proposed CCGT will replace DPS 1 and also allow DPS 2A and 2B to be used solely for backup.

Noted.

The EIS covers an application for a new CCGT and assumes that such CCGT will be utilised to satisfy base load requirements. Other considerations such as making more use of the interconnector and reducing the use of the proposed CCGT may result in less environmental impact, but such a decision is not only taken on the environmental impact but on a range of other considerations including but not limited to economical issues. Such considerations are being dealt with in the CBA which will form part of the IPPC permit as requested by MEPA.

Noted.

Refer to answer in query 4.

Noted.

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from 2015 to 2020? What will be the “default pecking order” of the various power plants and the Interconnector? This analysis must be included in the EIS. 6. The Air Dispersion Modelling Study notes that in order to achieve ambient air targets reliably everywhere in the 20km model domain, emission reduction technologies or a 105 m stack would be required, instead of the proposed 75 meter stack (p.3). Please clarify whether the proposed chimney is to be 105m high as recommended by the consultants, or whether emission reduction technologies will be used. A 105 meter stack must be included in the visual impact assessment and in the photomontages, if this is the planned height of the stack. 7. Dredging should not be permitted during the bathing season, as is the case at the Freeport Terminal.

8. As already noted in a previous submission by Din lArt Helwa (http://dinlarthelwa.org/uncategorized/delimara-powerstation-dlh-responsetoeia-scoping/), the overall environmental assessment of this project should include a Cost Benefit Analysis which takes into account the environmental costs of this proposal in comparison with the other technological alternatives. This analysis should be completed before a final decision is made on this application.

As indicated in other sections of the EIS and also through these queries the stack will be 75m high as re runs of the air dispersion model (without abatement technologies) have yielded satisfactory results.

Noted.

No permit for dredging is being requested and such works are not envisaged for the successful execution of the project.

Noted.

The CBA is being undertaken and we have been requested by MEPA to include this study as part of the IPPC permit.

Noted.

B. Environmental Health Directorate (E-mail dated 01/10/2013) Comments The Environmental Health Directorate (EHD) is concerned about possible health impacts on residents during the construction phase especially with regards to the increased heavy vehicle movements carrying construction waste (at least 11,000 heavy vehicle oneway trips over a period of 18 months, should option A be chosen).

ERSLI Responses (1) Option A has been discarded.

EPD Comments Noted.

In the air quality report, traffic was considered (3.8.3.5) but it seems that only the operational stage was considered.

(2) Comment noted.

Noted.

We would therefore recommend that a traffic impact assessment and health impacts from air quality, noise and vibrations be carried out for the traffic movements during the construction phase. The traffic impact assessment should include the proposed route to be taken by these vehicles and description of the sensitive receptors along this route. This was a requirement of the terms of reference- 1.2.4 Access, transportation and related infrastructure.

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Monitoring for air quality and noise along the identified route should be carried out during the construction phase.

(3) Comment noted.

A professional Construction Site Management Plan should be drawn up and strictly implemented to address waste and safety measures and adherence to proper site management practices so as to prevent/mitigate adverse air quality, noise and vibration impacts on sensitive receptors, adverse impacts on marine water bodies from particulate matter, potential contamination by fuel, lubricating oils, accidental spillages of hazardous materials, etc. during the construction phase.

(4) A fully detailed CMP include all necessary documentation as requested by MEPA will be submitted.

Noted; the requirement for the submission of a detailed CMP shall be included as one of the development permit conditions.

Effective mitigation measures and monitoring so as to ensure implementation of all necessary mitigation measures and adherence to work practices throughout all the phases of the project should be proposed and enforced during the construction phase (e.g. upgraded and dedicated roads leading to development bypassing as much as possible residential areas, avoidance of transport during sensitive hours, use of non-polluting (air quality and noise) vehicles, etc. Adequate, safe and proper handling of raw materials on site should also be ensured. A waste management strategy should be adopted and strictly implemented so that all generated waste streams will be contained, separated and disposed of safely through the appropriate facilities and according to the necessary permits/licences. With regards to removal and disposal of any hazardous waste, adherence to regulatory codes and procedures and due diligence should be ensured.

(5) A fully detailed CMP include all necessary documentation as requested by MEPA will be submitted for the construction phase whilst the operational permit will study all aspects of discharges during the operational phase of the project.

Noted; comment above refers.

(6) Comments noted.

Noted.

All marine discharges of any effluents from the CCGT and LNG facilities during the operation phase and other marine discharges of wastewater streams such as run-off, boiler washings, floor washings, etc. are to be treated so as to strictly comply with the relevant legislation controlling such releases. Good practice together with adequate/preventive measures during the operational phase regarding risks to water quality from maritime traffic through operational losses of fuels and oils and regarding accidental spillage of LNG are highly recommended. The EHD strongly recommends that all mitigation measures set down in this document especially those related to dust and other waste management (5.1.4), NOx and PM reduction during operations (5.1.10) and other measures recommended in relation to the social impact report (5.1.11) including the suggested “continuous Impact assessments” and the setting up of a local management committee should be included in the ensuing permit. The remit of such a local management committee should start from the construction phase (e.g. monitoring of air quality and noise due to increased heavy vehicles used during construction) to limit detrimental effects during this stage.

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Mitigation measures aimed at reducing residual impacts (5.2) and the proposals for monitoring programmes (5.5) should also be taken up. Any other unpredicted impacts and nuisances which may arise from this project and that may have a significant adverse effect on public health should be immediately addressed by the applicant and the necessary mitigation measures taken. Complaints lodged by the public regarding any adverse impacts/nuisances should be immediately addressed by the applicant. All complaints lodged and actions taken are to be recorded and such records are to be readily available to the Competent Authorities when requested. N.B. • Page 131 of Co-ordinated Assessment Report (Volume 1, Technical Report); official bathing water monitoring programme is carried out by the Environmental Health Directorate (Superintendence of Public Health, Ministry for Health ) not as stated (Department of Public Health). According to our records, during the official bathing seasons of 2009 and 2010, 258 bathing water samples were collected from official bathing areas Site Codes A 10 to A 15 at Birzebbuga (Pretty Bay and St. George’s Bay). Only 11 samples of the 258 collected exceeded 100 CFU/100mL E. Coli. This amounts to 4.26% and not to 6% as stated (3.4.5.15). “Marsaxlokk (St. George’s Bay and Pretty Bay)” should read: Birzebbuga (St. George’s Bay and Pretty Bay). • Page 444: 4.4.1.2 “The former was prepared by the sociologist Dr Marvin Formosa, who carried out a survey of public views in the villages of Marsaxlokk and Birżebbuġa, while the latter was prepared by Dr Julian Mamo assisted by Dr John Paul Cauchi, both of whom are medical doctors who specialise in public health.” Should read: The former was prepared by Dr Julian Mamo assisted by Dr John Paul Cauchi, both of whom are medical doctors who specialise in public health, while the latter was prepared by the sociologist Dr Marvin Formosa, who carried out a survey of public views in the villages of Marsaxlokk and Birżebbuġa.

(7) Comments noted.

Noted.

C. Civil Protection Department (Letter dated 26/09/13) Comments With reference to the above mentioned proposal, the Civil Protection Department at this preliminary EIA stage following the in-depth risk assessment studies offered, the department finds no objection for the proposals to take place. LNG terminals/installation have a good safety track record and have exhibit a high operational standard of safety record compared with other installation of petrol chemical installations provided a high safety standard of the equipment is continually maintained.

ERSLI Responses Comments noted.

EPD Comments Noted; detailed risk assessment studies and assessment of environmental risk arising from the proposed development have been carried out in parallel as part of the EIS process.

As soon as a decision has been taken to which

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proposal arrangement option is going to be adopted the department will be in a position and be more knowledgeable to consult the safety and risk assessment of the option selected hence gives its views on precautions and safety measured need to be taken and made. D. Birżebbuġa Local Council (E-mail dated 02/10/13) Comments Having perused the contents of the EIS the Birzebbuga Local Council notes that the conclusions reached are qualified as the exact proposal is not yet known.

ERSLI Responses

EPD Comments

Whilst acknowledging that the use of gas instead of HFO will lead to considerable emission improvements and consequently to air quality in the area the following points still need clarification: (1) Noted; no further comments.

1) Whether utilisation of different gas supplies would lead to different types of emissions and if in the affirmative the impacts of the differences on the emissions,

(1) The applicant is not aware of any particular difference in emissions with varyng levelsof methane contained with LNG.

2) An analysis of the cumulative impacts of the emissions taking into consideration traffic emissions, emissions from ships using the Freeport as well as emissions from commercial aeroplanes using the flightpath just over Birzebbuga,

(2) Cumulative impacts have been considered and air quality study highlights values at sensitive receptors

(2) Noted; no further comments.

3) The specific point where the gas utilised by the power station will be stored, the method of storage and an analysis of the risks faced by the Birzebbuga community as well as by those utilising seacraft in Marsaxlokk Bay

(3) This is indicated in the plans included in the original draft and the exact location has been further confirmed following the sleection of the preferred bidder

(3) Noted; no further comments.

4) The impacts in general on all users of Marsaxlokk Bay, those making use of pleasure seacraft, sailing boats as well as fishermen. Birzebbuga Local Council reserves its position until such time as an answer to these issues is known.

(4) The impacts on the individual areas of study have been included inthe EIS.

(4) Noted; no further comments.

E. Malta Resources Authority - Competence, Licencing and Enforcement (E-mail dated 02/10/13) Comments Below please find MRA’s comments on the EIS presented on the development of the Delimara Gas & Power CCGT.

ERSLI Responses Comments noted.

EPD Comments EPD has no further comments to add at this stage..

Authorisation for Electricity Generation. The electricity generation plant has to comply with the Electricity Market Regulations (S.L. 423.22) and applicable network codes. In particular, the electricity generation plant will require an authorisation to construct the plant issued by the Malta Resources Authority as per regulation 11 of Electricity Market Regulations (S.L. 423.22) the prior to construction. In order to obtain an authorisation to construct the electricity generation plant an application has to be submitted to the Authority using the form that may be

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download from : http://mra.org.mt/wpcontent/uploads/2012/08/generation_application_v1.pdf In addition, according to Regulation 4 of the Electricity Market Regulations the operator of the electricity generation plant will require a licence to generate and supply electricity to Enemalta issued by the Authority. Authorisations relating to LNG Importation and Storage. The importation and storage of LNG used to supply fuel to the CCGT plant has to comply with the following legal notices S.L.423.28 (Petroleum for the Inland – Wholesale- Fuel Market and Primary Storage Facilities Regulations) and S.L.423.21 (Natural Gas Market Regulations). To this effect the operator will be required to attain the following authorizations from the Malta Resources Authority. 1.An Authorisation for the operation of a Primary Storage facility. 2.An Authorisation to carry out the functions of a storage systems operator. 3.An Authorisation for the Importation and Wholesale of LNG. 4.An Authorisation to carry out the functions of an LNG system operator. The application for the issue of an ‘Authorisation to operate a primary storage facility’ should be submitted at the design stage and can be downloaded from the link: http://mra.org.mt/wpcontent/uploads/2012/08/884/Primary-StorageApplication-Form.pdf. Documents to be submitted at this stage include a technical proposal compiled by an MRA-approved competent person. This document should describe in detail the design and operations that shall be carried out, including all safety and emergency measures. Permits and other requirements relating to greenhouse gas emissions pursuant to the EU Emissions Trading Scheme. In respect of a new electricity generating plant in which the activity “Combustion of fuels in installations with a total rated thermal input exceeding 20MW” takes place, the following will be required pursuant to Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading within the Community. 1) Greenhouse Gas Emissions Permit: an application for a permit has to be submitted at least 120 days before the commencement of the activity as mentioned above. 2) GHG Emissions Monitoring Plan (for approval by the EU ETS competent authority): submission of the plan at the same time as the submission of an application for a permit.

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3) Operator Holding Account (to be opened for registry accounting purposes): it is suggested that the application for the opening of an OHA and associated documentation be submitted at the same time as the application for a permit, so as to facilitate opening of the account once permit is issued. The above assumes that the plant in question will be a separate plant from existing plants operated by Enemalta. The responsibility for the above lies with the operator of the new plant. Further requirements. The operator is also required to comply with relevant obligations under the following regulations: • Legal Notice 167 of 2011, Natural Gas Market Regulations, 2011 • Regulation (EC) No715/2009 of the European Parliament and of the Council of the 13 July 2009 on condition for access to the natural gas transmission networks and repealing Regulation (EC) No 1775/2005. • Regulation (EC) No 994/2010 of the European Parliament and of the Council of the 20 October 2010 concerning measures to safeguard security of gas supply and repealing Council Directive 2004/67/EC. And any relevant obligations arising from the subsequent transposition of Directive 2012/27/EU of the European Parliament and the Council of the 25 October 2012 on Energy Efficiency. th

F. Birżebbuġa Environmental Action Group (Letter dated 25 September 2013) Comments 1.1.2.5: Energy generated from waste: Just a mention of the incinerator at the Delimara Power Station. We wonder why this is referred to in the EIS. When the subject was discussed at Marsaxlokk, it was almost turned into a riot. I was there together with other members of our Pressure Group. Police stayed out of site and it was with my intervention with the poice that peace was restored. Ex-minister George Pullicino was the main speaker, we knew beforehand the subject of the public meeting – ‘the incinerator’. Seeing the subject raised again, one wonders if this is going to be an issue. Traces of hard metals are present at Il-Hofra iż-Żghira, EIS suggest that heavy metals were present at intake point. Kindly give chemicals, hydrocarbons and hard metals amounts as well as MSDS. Public participation and consultation: Proportionally more persons from Marsaxlokk were asked to comment on the new proposed CCGT then residents of Birzebbuga. On paper, this does not manifest as a beneficial to calculate the opinion poll. As the crow flies Birzebbuga and Marsaxlokk are equal distance from the proposed storage gas ship. Whatever the perception of the opinion poll, Birzebbuga residents felt

ERSLI Responses Comments noted.

Comments noted.

EPD Comments Noted; no further comments to add.

A public hearing, in accordance with the EIA Regulations, 2007 (as amended) was held th on the 27 January 2014.

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ignored and will never accept the excuse that there was no time. The Aarus convention gives the right of information, participation and justice. We would have anticipated that the contractor of the EIA would have organized public consultation as a scoping meeting. Other, less national scale entities, organized direct contact public meetings. Waste program and waste management: EIS is full of propositions and that there is a possibility that the some hazardous waste does exist. As far as waste is concerned, this has to be identified as such. Legal Notices, LN337 of 2001 and LN184 of 2011 as emended. There is the Environment Development Act Cap 504, also L157 of 2001, governs waste codes and finally Waste Hierarch. According to European Waste Code, the plant are regulated by Chapters 10-13-1516-18 (construction) and 19. This will determine hazardous waste. We welcome the use of Natural Liquid Gas as fuel for Deli mara 3 and 4. We can never understand why the option of storage ship anchored on hurds bank was rejected by Enemata. This will save the building of a jetty for mooring storage tanker at Marsaxlokk bay. The alternative will involve laying about 13 nautical miles of submarine pipe line to Power Station. The option of having storage ship along a jetty at the PS will create possible closure of Marsaxlokk bay. This was explained to us during the scoping meeting on 17th September, we were informed that a buffer zone must be adhered to meaning no fishing boats can move in or out of the Bay close to the Green Buffer zone. Or be restricted to an area which can create problems in bad weather. Having a storage ship along a quay will have visual negative effects to Marsaxlokk and Birzebbuga residents.The most area affected by the visual effects are lol-Kavalerizza and Tal Papa Housing Estate. This will also have a social negative effect on property values. IPPC. permit should be permanent not rentable from year to year. This alone can guarantee that the emissions from Delimara 3 and 4. Currently Delimara 3 is over the limits of emissions and this is why the IPPC is renewable from year to year. Best practice should be that every three or five years, experts will define emission, as is done with pharmaceutical producing active ingredient. Trees as -rnbellishment in a Seveso II or Comah plants are illegal for the effects of lightning. Enemata 315t March Depot, and Falzon San Lucian Depot are both illegal for the number of trees planted in such depots. Why not use murals to embellish the whole plant. Oil Tanking at Kalafrana is according to the Seveso II Directive. Sound proofing. We must deviate from the use of trees as sound barriers and go for more modern sound proofing which is tested and approved. Sound can be deflected or amplified. On the same principle as the car silencer, sound can be reduced. As a resident of Birzebbuga I know the effects of humming, continuous noise particularly at night from the Freeport Terminals.

Comments noted.

Comments noted.

Comments noted.

Issues related to waste management shall be included as part of the development permit conditions and the IPPC permit requirements.

Noted; no comments.

further

The issue of noise generated from the proposed development has been discussed in detail in the EIS; however, comments have been taken note

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It is only now that sound values and effects are being calculated. The current tendency is that there are no financial rewards in industrial zones. We beg to defer for the simple reason that the south has been inundated with industrial and commercial entities to the detriment for the residents suffering a degrading in the quality of life and financial losses especially in their property. There is no comparison with living in Mellieha or Gozo, or any other place in the north, with the emissions, noise and light pollution one suffers in the south. Therefore, we insisting that Marsaxiokk`and Qajjenza will be awarded a 5% discount on the electricity bills. Birzebbuga residents will get 3% discount. This is not the first time that local Councils received funds for projects in their vicinity, such as Smart City. The one off payment to Local Councils is not agreeable Current EIA study falls under the prospective phase, monitoring will require current stage study and further retrospective study will decide on the long term strategy.

EIA fails to identify chemicals, hard metals and hydrocarbons. EIA states that these hazardous wastes can be found in il-Hofra lz-Zghajra. The only one way these impurities are found in the Hofra lz¬Zghajra is though cooling water. Fresh water is pumped , after additives are mixed to prevent clogging of algae to cool machinery that produce Power. Hot water is then fed into il-Hofra iz-Zghajra. Alarm System for major fires or large gas leakage. Residents who can be effected by such leakage must be educated to the significance of the alarm. Once a year the alarm will be tested so that new residents will know the significance of the noise. During the last scoping meeting of the 17th we were told that gas is heavier than LNG. We beg to differ because LNG is lighter than air and gas cloud could hover and travel in air. Use of Scrubbers: the EIA reefers to scrubbers in the use of Gas Oil and LNG. Scrubbers as per EIS has a value of 1.5% of the total cost of machinery. This is the only abatement recommended by the EIS for Delimara 3 & 4. Should, because of the cost and maintenance, the use of Scrubbers be dropped. pollutants will have effect the public health and the environment. Release of 291 NXo tones per annum means 5.6 tones per week. "EIA states that the abatement measures may not be required.

of.

Comments noted.

Comments noted.

Noted.

Mitigation and monitoring will be included as a part of the development permit conditions for the proposed development.

Comments noted.

Assessment of the cooling water at ilĦofra ż-Żgħira was carried out in the EIS in the section related to marine water bodies.

Comments noted.

Noted.

Comments noted.

Noted.

To use Safety Guidelines as per World Bank. Demolishment of stack: It's well known that the chimney top is used for repeaters for cellular phones.

Comments noted.

Noted.

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Without these repeaters Birzebbuga, Marsaxlokk and Marsascala will suffer lack of reception in their use to the mobile phones. We recommend that the chimney will remain as a reminder of the polluted emissions release. Users of the stack must clean and paint the top of the chimney. Sea of Marsaxlokk Bay is heavily polluted. We recommend a number of aeration pumps Cadmium, Mercury, Lead, arsenic and hydrocarbons liters the sea bed. Easy way out is to declare no fishing zone as suggested in the EIS. Better solution is to clean the bay. Why rod fishing should be abolished? Marsa locality air and sea are so heavily polluted that it will take years to clean as long as the bottom is not dredged. No consideration was given for the use of Solar Panels in the estimate of power produced. It is estimated that within the next twenty years solar panels will produce 100 KW/h. Permit condition: • real time air monitoring at Marsaxlokk ( Carbon, Argonit, Nitrogen etc). At the expans of Enemalta • Long term sustainable plan. Should the Dolphin be removed due to the close vicinity to the Green danger zone the repercussions must be calculated. Apparently the Dolphin is the only means of transfer fuel to Has Saptan underground fuel depot. This, further proof that our suggestions of anchoring the storage boat on the Hurs Bank. We have good faith in Transport Malta to protect the ship from any collision. Constant satellite monitoring has prevented any accidents in the past. Permanent mooring facilities can be put in place. A Capacity of 180,000 cb meters will provide fuel for 73 days. Therefore the supply ship needs to replenish the storage vessel five to six times annually. Transfer of gas is considered the most dangerous time of the operation, further studies to find the best and safest option. The whole EIS is full of further monitoring and assessment. The domino effect, particularly fuel depots and gas installations must always be considered. Although the EIS quoted the last census the population of Birzebbuga is 12,000 and it is the reason that the next Local Council election can have an extra two candidates who can be elected. EIS quotation is erroneous. Figures should be quoted exact. It is not clear if the mercaptans is added before it s transferred or in Malta.

Comments noted.

Comments noted.

Assessment of the cooling water at ilĦofra ż-Żgħira was carried out in the EIS in the section related to marine water bodies.

Noted.

Comments noted.

Noted.

Comments noted.

Noted.

FSU of selected bidder will have a capacity of approximately 130,000 cubic metres.

Noted; no comments.

Comments noted.

Noted.

Mercaptan will be added during the regassification process.

Noted; no comments.

further

further

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th

G. Superintendence of Cultural Heritage (E-mail dated 14 October 2013) Comments In its correspondence of 5 July 2013, the Superintendence had raised three points regarding the possible cultural heritage impacts of this proposal. All three points have been addressed by the EIS. (1) Impacts on terrestrial cultural heritage appeared to be minimal - The EIS confirmed that no appreciable impacts are identified for any terrestrial cultural heritage. (2) Dredging and construction works on the sea-bed presented potentially high risks to the maritime cultural heritage. - The EIS confirmed the potential risk to marine archaeological assets, both by dredging and piling operations. In particular the EIS identified eight sub-bottom targets buried in the silts within the Area of Study. The archaeological or historical character of these eight targets could not be confirmed. The presence of a surface scatter of artifacts was confirmed both through documentary research and through direct observation of the sea-bed by divers. However the actual density of archaeological artifacts that may be disturbed on the sea-bed surface and within the harbour silts could not be established. (3) Impact on coastal erosion in other sectors of Marsaxlokk Bay - The EIS established that wave action will not be increased by the proposed works. Consequently erosion on coastal heritage sites – such as at Fort Dellimara and at Għar l-Aħmar – should remain constant. In view of the above the Superintendence has no objection to the EIS presented for EA00014/13. The Superintendence also endorses the Mitigation and Monitoring recommendations proposed for the Marine Archaeological Impacts (section 5.5.4 of the Coordinated Assessment Report). All monitoring and investigation activities that may result from the implementation of these recommendations are to be carried out with the approval of the Superintendence and in line with its TOR.

ERSLI Responses Comments noted.

EPD Comments Monitoring related to archaeology and cultural heritage, particularly marine, will be included as part of the development permit conditions.

ERSLI Responses The contents of the letter have been noted and the following points are submitted: Noise.

EPD Comments Noted.

H. Marsaxlokk Local Council (Letter dated 30/09/13) Comments A copy of the letter issued by Marsaxlook Local Council has been included in Volume Six of the EIS.

The EIA presented also includes a study of the Noise levels that would result from layout options A, B & C. Two specific scenarios have been considered namely: the likely impacts that would result during the construction phase, and the noise generated by the plant when in service.

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The report presented states that the impacts that would result during the construction phase, fall within tolerable limits.

Noted; no comments.

further

In this case the Marsaxlokk Local Council has no points to raise on this specific issue, more so when the construction phase itself is of a limited duration. Impacts during Operation. The Noise Impact Assessment also analyses the 3 layout options during the operations phase. For the sake of argument the comments to be presented hereunder shall only consider the new plant operating together with the existing plant. This is perhaps the worst case condition. The situation would be expected to improve once other plants are either not in operation or even decommissioned. Options A, B and C result in a noise level in the range of 25 to 35 dB(A) in basically all residential areas. The report itself in the summary of impacts (Page 412 — Annex 2) Classifies the impacts as being adverse, with a low to moderate severity, and being of a permanent nature. Option B in particular will, quote “bring about changes of +4dB on land and +l2dB on the sea — moderate to severe significance.” (Page 407 — 4.1.9.10 -Annex 3) It will be understood that noise will have a definite impact on the residents, particularly during the summer months, and even more so on the businesses basically the numerous restaurants located all along the sea front, most of which provide services to diners outside. In the light of the above the Marsaxlokk Local Council seeks further clarification on: I. The changes in noise levels compared to the present situation.

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2. Measures that may be undertaken to reduce noise levels to those recorded at present. The EIA process needs to expose ALL areas where changes to noise levels are bound to occur under the right propagation conditions. The areas could be disused fields, walkways, residential areas etc.. Since the basis of the propagation for this EIA is according to ISO 1996, all areas and points are analyzed under the right propagation conditions - i.e. the receiver is always downwind of the source- . It is impossible to have the levels displayed occurring in reality but a display of what could be the worst case scenario for each area or point is feasibly deduced from the approach taken. The levels presented of 25 to 35dBA are already exceeded whether the power station (as at present and as a whole) was in the area or not. The points put forward by the Council of 35 dBA having an impact on the residents and/or restaurants is highly unlikely, since for such levels to be discerned at any one point within Marsaxlokk the following conditions must be true: the sea state must be 0; no activity must be occurring in the area including cars on the roads, the wind must be exactly from the direction of the power station directly towards that point; the other sources in the area must not be in operation and the restaurants closed. And even under such a situation 35dBA would be an ideal situation which many people around the world would like to subscribe to. I can understand the concern of the Council, but if the Council’s concern arises from reference to the levels presented in the WHO Community guidelines (not the night noise guidelines) it would be grossly mislead, as the WHO guidelines are guidelines which represent an ideal situation

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far removed from reality. E.g. If the restaurants are open and the usual traffic on the sea front is underway, the overall level for a period of 5 to 6 hours will be more like 55 dBA. Kindly keep in mind that the study has the possible contributions solely from DPS under the right conditions. The changes which the Options bring about, either with DPS under the present condition or when DPS has Phase 1 deactivated are already displayed in the EIA; showing WHERE the changes will occur and by HOW MUCH the expected changes are expected to be, again under the right propagation. I refer the Council to Figures and pages: Fig. 4.30, Page 405, Fig. 4.32, Page 406, Fig. 4.34, Page 408, Fig. 4.36, Page 409, Fig. 4.38, Page 410, Fig. 4.40, Page 411, Whereby all expected changes and their location is displayed. No particular changes are expected within Marsaxlokk proper, but the EIA process has to display what changes will occur in any area whether it is residential or not. The fields and areas on Delimara peninsula and the areas on the sea in the bay are considered to be part of the environment.

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APPENDIX IV: Comments post-certification (3rd January 2014 – 24th January 2014)1 th

A. Birżebbuġa Sailing Club (Letter dated 20 January 2014) Comments In the name of Birzebbuga Sailing Club, I would like to voice our concerns on how the LNG Storage and Regasification Facilities for the newly proposed Gas power plant development at Delimara will negatively impact our sailing activities in Marsaxlokk Bay. Along the years our sailing areas within Marsaxlokk Bay started to gradually decrease and slowly shift away from the seashore limits of Birzebbuga, this was mainly attributed to the adverse impact of the Malta Freeport operations and aqua cultural activities inside the bay. Consequently the delineated area between Delimara Point and Fort San Lucian foreshores towards Marsaxlokk village is the only remaining part of Marsaxlokk bay where our sailing club members could enjoy clear and unobstructed sailing conditions. Furthermore, dinghy sailing regatta standards specify minimum race course areas to be setup during national sailing competitions and the only remaining location which could cater for such space is precisely the waters in front of Delimara power station. In order to use such spaces, apart race course area A, the club held quite challenging and difficult meetings with Transport Malta officials so that for definite and agreed time periods, we are given authorization to use race course areas D and E (kindly refer to the attached notice to mariners 8/2013) whereby both areas would also overlap the shipping fairway lanes inside the bay so that both could cater for the minimum required race course area specifications. Hence use of the additional course areas D and E are of crucial importance for our racing events in case of adverse weather conditions outside the bay. Due to the reasons listed above, we are really concerned about the proposed gas power plant development, in particular the proposed position of the mooring jetty, the sheer size of the FSU vessel and the safety buffer zone that will presumably be established will permanently limit our ability to host national sailing regattas inside the bay and also moderately hinder a safe passage through the waters leading to

1

ERSLI Responses The points made by the Club are taken, and as stated above, these comments (like all comments made with respect to the EIS) will form an integral part of the documentation produced during this EIA process.

EPD Comments Noted; no further comments.

Volume 7 of the EIS Coordinated Assessment refers.

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Marsaxlokk unless compensatory measures are taken to provide alternative solutions.

B. Din l-Art Ħelwa (E-mail dated 1st February 2014) Comments The permanent presence of such a large LNG storage tanker, together with a supply ship of the same size, is a threat to the power station, the Freeport, fishing boats, and the lives and health of people in the vicinity. Before taking any decisions, studies must be undertaken to consider all alternatives with more safety distance and less traffic movements. Even if the potential frequency of accidents is once in 10,000 years, it can still happen next week. Other suggestions for a new gas-fired power station include an offshore platform, a gas pipeline, and a proposal to base the gas storage in an area at Hal Far. Have these options been studied and compared in adequate detail? If so, why have the studies not been made public? During the hearing it was claimed that mooring outside the bay is not possible, yet many offshore platforms exist which survive harsh weather conditions in the North Sea and elsewhere. More details about this option must be provided before any decisions on the LNG storage location is decided. The proposed FSU is a conventional LNG tanker that will be moored to the jetty at Delimara and utilized as a permanent power station for 20 years. Design and reliability criteria for a movable LNG tanker and a fixed power station must be different since the tanker can regularly be shut down completely and all components inspected and maintained. A fixed power station will be switched on and all components must work continuously and reliably for 20 years. This raises serious concerns about the long term reliability of components that were not designed for this type of operation and suggests that it would be a safer option to have the FSU and regasification plant on the same platform in a remote offshore location. The Risk Assessment is preliminary and must be completed before taking any decisions on the location of the storage of LNG. The assessment lacks precise data on the proposed storage ship and the regasification installation. Too few technical details on the installation are provided, when the devil for safety is often in the detail.

ERSLI Responses (1) The excerpt from the SEA quoted by DLĦ states: More detailed studies are required. At Government level, the type of infrastructure has not yet been identified. Once a decision is taken, detailed assessments including EIA, risk assessment etc would have to be carried out to identify and address any site specific issues In other words, DLĦ do not interpret the SEA correctly. The preparatory work leading to the issue of the third draft of the EIS (which was discussed during the Public Hearing) reviewed the options studied in the first draft and subsequently the proposal submitted by the ElectroGas Malta Consortium.as indicated in the SEA, a decision was made with respect to the natural-gas infrastructure and then the preferred infrastructure system was evaluated through an EIA which includes a Risk Assessment. In the Coordinated Assessment Report (specifically on page 86) there is an explanation, which was provided to the EIA Coordinator by Enemalta, which explained why the 'out-ofM'Xlokk Harbour' option mentioned in the SEA could not be considered in the EIS. This explanation refers to the following issues: There is very little searoom available for a shallow water platform which is fixed to the sea bed. There has been no experience of installing a FSRU at a floating connection point to supply gas continuously to a single point. Any FSRU moored

EPD Comments Noted.

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The assessment also does not adequately consider ship-to-ship collisions, which can cause leaks in the storage tanks on the tanker, and other maritime risks. A full maritime risk analysis must be carried out before any decisions are taken. Collisions can occur between the storage tanker, the incoming LNG tankers, freight ships or fishing vessels. LNG stored on water allows the unrestrained spread of gas in case of a leak. The outflow of LNG on water causes rapid spreading. The report assumes a maximum spread area but this cannot be taken as an accurate fixed value as there are too many unknown variables. For example the effects of a large gas spill combined with the topology of Marsaxlokk and a low southerly wind blowing directly into the harbour have not been adequately considered. The gas dispersion model applied in the QRA is unfit to describe dispersion with a weak southern wind and the uncertain failure probability values. The probabilities given for the failure of components such as hoses and loading arms are uncertain and not reliable. A leak may occur through failure of the permanently functioning loading arm between the storage tanker and the re-gasification plant. This has not been adequately considered, and the effectiveness of a safety water curtain on a large gas spill is not known. The QRA underestimates the most risky scenario of a direct tank breach of either the storage unit or of a supply ship. It estimates the distance 129-133 m based on an assumption from Dutch reports, which are very general and not specific on LNG. On the other hand, from the publications it appears clearly that safety distances for a tank breach are an order of magnitude larger than calculated in the QRA. The EIS coordinator notes that “making more use of the interconnector and reducing the use of the proposed CCGT may result in less environmental impact”. Din l-Art Helwa’s earlier request, submitted in relation to the draft EIS, to outline the utilisation rates of the proposed CCGT plant, the interconnector and the rest of the Delimara plants, is therefore still relevant and should be answered in the EIS which should address all environmental considerations and scenarios. No satisfactory answer has been provided to this question, which has environmental implications.

outside Marsaxlokk Bay, including its attendant pipeline is likely to represent an obstacle to shipping. The severe sea states outside Marsaxlokk Bay would reduce the ability of the FSRU to receive fuel from supply carriers. Such conditions were considered too risky with respect to security of supply. The off-shore option was not however completely set aside, given that in the future, technological developments are bound to render the off-shore option a viable solution. Evidently DLĦ have every right to disagree with the arguments stated in the EIS, but they cannot argue that the public has not been informed through the EIS of the options mentioned in the SEA. One should also keep in mind that in the final analysis the outcome of an EIA is not just the EIS produced by the EIA Coordinator and his team, it also consists of information submitted during the Review and Public Consultation stages of the process by consultees (such as DLĦ) and the public.

(2) Yes. Chapter 2 of the Coordinated Assessment report (of the third draft of the EIS) also refers, on page 104, to a letter from the Chief Officer of the Ports and Yachting Directorate Transport Malta, which states that the simulation studies carried out by his Directorate with respect to the location of the FSU in Marsaxlokk Harbour indicated that there is sufficient room for manoeuvre in the said harbour for both the LNG carrier (8 to 12 calls per annum) and for vessels attracted by other activities located in the harbour (2,700 in 2012).

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The response also notes that the Cost Benefit Analysis is being undertaken as part of the IPPC permit. Once the IPPC permit application is already underway, this information should be brought to the MEPA board for consideration at the same time as the planning application and related EIS. The development planning permit and the environmental permit of this project of national importance should ideally be considered together by the MEPA Board. Din l-Art Helwa requests that the following points are not grouped and provided with a general answer, but instead that each of these points is answered individually and specifically: 1. RISK ASSESSMENT (QRA) Din l-Art Helwa is attaching comments from risk analysis expert Prof Hans Pasman and two relevant articles to this document (Appendix A). The main comments are also reproduced below. 1. The QRA as performed by SGS is not only preliminary in the sense that it lacks precise data on the construction and sub‐systems of storage ship and regasification installation, but it is also seriously incomplete because it does not contain a risk consideration of ship‐to‐ship collisions and other maritime risks, while the pool formation on water from a leak in one of the 35,000 m3 tanks is treated very unsatisfactorily. Regrettably, the latter I became aware of after the public meeting, because these scenarios present consequences on the largest distances. 2. In fact, the permanent presence of at maximum 130,000 m3 LNG in a floating storage unit and the temporary presence of a supply ship with the same amount form a threat to the power station, the container harbour, fishing ships, lives and health of people the vicinity. LNG stored in a water environment allowing unbounded pool formation is inherently much more unsafe than stored on land in a bunded park with double walled tanks. 3. In scenarios B01a and b of a tank wall penetration (gas tanker – release on water) Mr. Roberto Vaccari assumed a maximum pool spread area of 10,000 m2. This assumption was based on three Dutch references ([21], [22], [25]), all known to me. Apart from the fact that I couldn’t find the 10,000 m2 in the reports, nor any statements where it could be derived from, but it may be implied somewhere, I don’t believe it is a fixed value. The area is

The Chief Officer also indicated that it would be essential for him to be provided with a full nautical risk assessment which would enable him to draw up the necessary harbour management plans and emergency procedures. (3) Rather than only studying a theoretical single scenario the purpose of the EIS was to identify and assess the impacts the proposed development would have on the environment, based on a number of scenarios, each representing a worst-case with respect to specific factors. The scenarios presented in the air dispersion sections of the Coordinated Assessment Report of the third draft of the EIS (in chapters 3 and 4) were agreed with the MEPA and were meant to ensure that the worst-cases would result in emissions acceptable under EU directives. Following 2015, Enemalta will be in a position to generate conventional energy through the use of fuels from a diversity of sources. As long as the thresholds and objectives established by EU directives are respected, Enemalta should keep its options open with respect energy mix. (4) As stated during the Public Hearing, the SIA was not a requirement in the Terms of Reference. It was used by the EIA Coordinator as the first phase of what was to be an on-going public consultation process (of which the Public Hearing also formed part). Under the EIA Regulations, the EIA Coordinator was/is only obliged to inform the public of the contents of the EIS between 03 January 2014 and 03 February 2014. Instead he chose to start informing the public in June 2013. By September 2013, the public was made aware of the visual

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determined by the leak rate, the spreading rate and the evaporation rate, and in general it will be larger with a larger rate of outflow. Calculation is complex and difficult. Fay (MIT, US) and Webber (HSL, UK) present equations, but CFD would be better. Not all physical properties of LNG are well known. Validation is not well possible, while there are only results of a few, old, small amount tests available. 4. A recent paper in Process Safety Progress (attached) by a renowned American specialist expert (Mike Hightower, at Sandia) in this particular LNG risk aspect (with huge computer power at his disposal and funding by the US Senate) mentions the following distances depending on whether the cloud is ignited and forms a burning pool, or whether all LNG evaporates and a cloud drifts away: 1 m2 hole, burning pool, Ø = 148 m, injury threshold population (5 kW/m2) = 554 m 2 209 m 784 m 5 405 m 1579 m 1 , dispersion , 148 m, distance to explosion limit 1536 m 2 209 m, 1710 m 5 405 m, 2450m 5. The larger the leak hole the shorter the spill time (40 minutes at 1 m2 to 8 minutes at 5 m2) The paper does not specify all weather conditions as these will have an effect, but it is clear that the distances in the SGS report of 129, 133 and 138 m of the B01 scenarios (page 65 of 88 in revision 2) are a severe underestimate. The probability of such a hole depends much on the conclusions of a maritime risk analysis. 6. About the dispersion model applied in the TNO Riskcurves software can be mentioned that it is a so‐called integral model (2nd generation) taking account of heavy gases such as chlorine. How it behaves with a gas as LNG that is initially heavy, slowly warms up and becomes lighter than air, I don’t know. It is certainly not suited for hilly terrain, buildings and low wind speeds. The only type of models that can calculate this kind of situations is the 3rd generation Computational Fluid Dynamic (CFD) type. The only CFD model that is rather recently validated and approved by the US authorities, is the Norwegian one I already mentioned and is called FLACS. Attached is the 2010 paper. That the US FERC (Federal Energy Regulatory Commission) approved is important, because in the US the safe distance is dependent on the dispersion and dilution till

impacts of the proposed FSU/FSRU when the montages submitted in the first draft of the EIS were made available to the Local Councils of the area and published in the media. It is a well-established reality that during the Review and Public Consultation periods of the EIA process, the media made sure that as many people as possible were made aware of the potential impacts of the proposed development. The response of the public during the 5-week long Public Consultation period 03 January 2014 and 03 February 2014) would constitute a de facto update of the SIA. (5) All the reports submitted in Appendix Two of the EIS (including the noise assessment report and addendum) form an integral part of the EIS. One should also be informed that the Calleja recommendations were not meant to mitigate the impact of the proposed development per se. The noise assessment report also indicates in the detailed 'noise difference map' presented in the report but not in the Coordinated Assessment Report, that an overall improvement in noise impacts resulting from the proposed changes at the DPS (as explained in Chapter 1 of the Coordinated Assessment of the third draft of the EIS) is to be expected. It is unfortunate that some readers of the noise assessment reports seem to have missed this map. (6) Ship to ship collision is treated including all cases in one scenario, the first one, considering the possibility of third ship collision with moored FSU or LNG tanker and introducing in the frequency the traffic of ships in the whole

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half the lower explosion limit, which is 2.5%. 7. Low wind speeds, below 2 m/s, create the most hazardous conditions. Figure 4 shows e.g., test MS27 (Maplin Sands near Thames estuary UK in 1980) at 5.5 m/s wind speed a distance to till 2.5% LNG of about 350 m. The release rate was 23 kg/s. Mr. Vaccari mentions for scenario B01, 732 and 856 kg/s, which I think is not too high, only about 1 m3 per second!! 8. Failure probabilities for the components such as hoses, loading arms, and others are guesses. One cannot rely on it. There is some data collected in the US I expect, but I still have to see a sound data base on LNG components. So, risk figures are rather uncertain. 9. The used model and the risk criteria (individual risk and to a lesser extent societal risk) have to be considered in the Dutch context of Land Use Planning against the background of compromises government‐industry. If people really get upset, as in a recent case of carbon dioxide sequestration pilot test at Barendrecht near Rotterdam, the government backed off, although the risk curves were much below criteria. Also there, many uncertainties played a role. LNG Hazards The risks of LNG operations are large scale spills on water and land, rapid evaporation, cloud formation and further consequences such as flash or pool fire with strong radiant heat effects over large distance. Explosion is usually not considered as methane is a relative low-reactive hydrocarbon which does not explode in the open, but only in confined space. LNG contains however small quantities of the more reactive ethane and propane hydrocarbons. After a spill of LNG, evaporated gas is at first heavier than air but when warming up it becomes lighter and disperses easily. However, as accidents with gasoline and other hydrocarbons have shown, large masses can make a large difference and strong, destructive explosion blast effects have been observed (e.g., Buncefield, UK, Dec. 2005; Jaipur, India, Oct. 2009). A flashing flame accelerates to high velocity but details of the mechanism of the explosions are still unclear. Experiments with LNG with relative small amounts compared to a tank content of 35000 m3 did not show any blast when ignited.

port. The size of the hole have been limited considering that is directly related to the size of the third ship and her speed and both are limited in the port due to nautical reasons. However, the Marine Risk Assessment would close any discussion establishing any required limitation in port traffic. (7) LNG transportation has the safest record in the nautical industry, far away from transportation of any other dangerous goods. (8) The size of a pool is based on the effect of any spillage on a plane surface: the liquid will extend as far as possible and reduce to minimum thickness. Obviously this concept is true on perfectly paved surfaces. It's also true for non-mixing liquids on water, such as oil. But it's not clear for liquid mixing with water or vaporizing gases. In fact the mixing effect and the phase transition effects are working against the enlargement of the extension of the pool and are adding more and more turbulence even to stable and quiet water. For this reason, and based on real accident, the extension is commonly limited. (9) In the last review of the same paper (2012), distances have been reduced and a 5m2 breach is estimated to produce a pool of Ø= 253-546 m and injury threshold population (5 kW/m2) = 922-1894 m, confirming that prediction of these distances are still very difficult, even with huge computer power. Our commitment is in all cases to remove any possibility for a huge breach, higher than 0,5 m, by reducing the impact energy or the third ship speed.

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Occupational hazards are asphyxiation and cold burns. Leaks in contact with normal steel cause embrittlement and loss of structural strength, which on a larger scale can impact a structure’s stability. Boiling Liquid Expanding Vapor Explosion (BLEVE) in case of fire around a tank cannot be excluded but is less probable. Rapid Phase Transitions while boiling on water have so far not posed any threat. SGS considers all this. The report contains a number of statements which show the precarious character of the whole set-up/lay-out, e.g., on page 83 of 88 Conclusions, first paragraph, which highly recommends maritime risk assessments. Indeed, this can also be the summary of the comments made here: do not decide yet, but perform maritime risk assessment and look for alternatives offering more safety distance and less traffic movements. LNG accidents so far have been few, so it can be handled safely, but it is a hazardous substance and a good past record is no guarantee for the future.

(10) Ship to ship collision is not object of the study and a separate marine study has been requested. It's clear that the larger the hole, the bigger the pool, the flammable cloud, etc. Our commitment is in all cases to remove any possibility for a huge breach, higher than 0,5 m, by reducing the impact energy or the third ship speed. Traffic regulation and minimization of the speed would be proposed by the marine study.. (11) Integral models are considered adequate for first approach calculation on the large distance when the size of the obstacles is lower than 10% of the total length of the cloud (hills are 30 m high while cloud can be 300600 m long. (12) Passman is arguing that with our high release rate, we should suggest longer clouds. It’s a comparison, and we take this into account. (13) Being theoretically true that frequencies can be of a factor of 10, it is also true that LNG equipment presents a higher rate of fiability (10 or 100 times more fiable than normal equipment), while we have used generic frequencies, thus we can conclude that any possible underestimation in the frequencies is balanced by the high fiabilty of equipment.

(14) Point noted.

1. Accuracy of QRA studies SGS performed the EIS land use risk assessment applying established methods. QRA is the best way to investigate a safety situation. However, the results have little absolute value, only relative; that is, it is useful to compare options but not more (In Annex 1 the 2000 EU study ASSURANCE is briefly summarized). Failure rates can easily be off

(1) Our conclusions are based on two different parts: risk contour and damage zones. Risk contour was used primarily for comparison between the three options, and involve failure frequencies. Regarding damage zone, they are not subjected to frequencies, thus they are saying what happens if it

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a factor of ten or hundred. It are probabilities which can only be validated if many of the same kind of components exist, fail in the same mode, effect of local conditions can be included and the data can be treated in a statistically sound way. For the components applied here it is not very likely that such a data base exists. And even then, if a frequency can be established as lying in a certain range with an average of once in 10,000 years it can still happen next week. If, the risk source is that close to various kinds of vulnerable receptors as is here the case safety distances are also of interest. Hence, consequence analysis as SGS has performed, provides insight in the distances hazardous effects can reach. The weakness there is that any experimental evidence with amounts as large as a tank content (35000 m3) does not exist (the largest spill in an experiment was not even 70 m3). The effects can be stronger or weaker than predicted. But for the time being we don’t have any other information. However, to state that the maximum extension of a flashing cloud is 962 m (scenario 03.a in the revision 2 of December 2013, see also Drawing #13) is suggesting an accuracy that is not justified. Are you safe at 963 m? What is the opinion of SGS in this matter? 2. Possible scenario of damaging the CCGT installation QRAs are focused on calculating fatalities. A real large hazard in this case is however also the ingestion of leaked natural gas by the combustion devices of the power station. These become uncontrolled due to the fuel that appears all of a sudden in the air intake, even if the concentration in the air is below the explosion limit. This may lead to turbines getting out of control which may end in power failure and further escalation. If the concentration in the cloud is above the explosion limit, it may also cause strong ignition of the cloud. The mechanism of revving up a combustion engine has played a major role in several catastrophic accidents initiated by fuel leakages. SGS did only consider the hazard of a cloud being ignited at the site of the power station which would also cause heavy damage. How much margin is available in the present plan between edge of a possible cloud and air intakes (in view of drawing 13)? Has the topology of the hills surrounding the location been taken in account at a spill in case of a

happens tomorrow. (2) It is important to state that with respect to the new CCGT, turbines from Siemens or GE are generally equipped with systems to protect against pollution of air intake ensuring that the turbine would automatically shut down if the presence of pollutants in the vicinity of the intakes is sensed (when the concentration of oxygen is lower and / or the combustion is not stoichiometric). However, the cited example is true and is catered for in any petrochemical complex, where this is the only possibility for an explosion, being all the other sources removed or protected. Notwithstanding this the report considered 100% ignition probability within the Enemalta Plant, attributed to the presence of electrical equipment, uncovered wires, etc Given that the size of the obstacles (i.e. the Delimara cliffs) to the extension of the gas cloud is less than 10% of the total length of the cloud topography could not be taken into account. (3) In case of a stuck valve, there are redundant safe-guards. Water curtains have been engineered to optimize the dispersion of gas in case of incipient leakage, and a complete set of them over a high structure (i.e. the unloading arm) can develop a virtual wall of up to 50m x 20m = 1000 m2. This protection is in place in any jetty and any LNG tanker, in order to cut off the affected area. Detailed studies such as Failure Tree Analysis (FTA), HAZOP or SIL allocation would guarantee viability of the system to be engineered and purchased. Also, these systems would be certified by third party, inspected before and after installation and tested once in place.

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southern wind of low velocity? 3. Reliability and effectiveness of protective/mitigative measures The largest probability of a leak is the failure of the permanently functioning loading arm between FU and the regasification plant. What experience has been collected with the special safeguards (ERC Emergency Release Couplings) to protect against the failure of a loading hose as mentioned on page 65 of 88 about the ElectroGas proposal and in Annex C? Unreliability of a possibly sticking valve is not included. And what shall be the reliability and the effectiveness of a water curtain, more sophisticatedly called hydro-shield, in relation to scenario 03.a on page 65? Water curtains have been tested only on small scale LNG clouds and the effectiveness depends on many factors which can only be investigated by experiment. Does SGS have an answer? 4. Cloud dispersion aspects Page 38 of 88: With respect to prediction of cloud dispersion with the topological conditions mentioned (30 m high hills in all directions except West), it would make sense to make separately cloud dispersion calculations with a validated CFD code, e.g., FLACS, because the cloud dispersion models in EFFECTS (or DNV’s Phast) are integral models and are unreliable for closein effects and interaction with obstacles and hills. Especially with heavy gas cloud and low wind this can be very important. Cloud dispersion is slowest during windless night condition and high stability, p. 36. The most favorable conditions for long stretching clouds are usually the presence of inversion layers. Please, comment. 5. Ship-to-ship collisions How will the incoming tanker manoeuver? On page 67 of 88 SGS considers in a very rudimentary way the risks of ship-ship collisions in the relative narrow and busy waterways near Marsaxlokk; why not asking this to an institute experienced in investigating ship-ship collisions and grounding? Collisions can occur between the storage tanker (floating storage unit, FSU) or incoming tank ships and departing freighters and fishing vessels, passing ships etc. Outflow of LNG on water causes rapid spreading and violent boil-off. SGS did calculate in scenarios B01.a and .b the consequence of a tank of 35000 m3 emptying after having sustained a hole of 0.36 m2 and reports a flash fire maximum distance of 129 and 133 m. Hightower et al. (Sandia report 2004-6258)1, probably

(4) Integral models are considered adequate for first approach calculation on the large distance when the size of the obstacles is lower than 10% of the total length of the cloud (hills are 30 m high while cloud can be 300- 600m long. The presence of inversion layers is an important issue in the dispersion of hot gases emitted from a stack at a relatively high altitude, comparable to the high of obstacles creating the inversion itself. Also the phenomena can have an important effect on the dispersion of toxic gases, when a very low concentration (few ppm) needs to be simulated (ammonia, chlorine, etc). The effect on the ground level, when simulating concentrations of flammable substances at low temperature, is minimal and can be neglected. (5) Although impact from other vessels has been considered as a credible scenario, detailed ship to ship collision analysis is not the object of THIS study and a separate marine study has been requested. Contact with MARIN has been done. Passman says up 4.5 knots tank will not be penetrated. Typically speed in the area would be limited. 6 knots = 11 km/hour, is very high speed in general for the available manoeuvring circle. Cited case of Boston and Rotterdam is very important, together with Ferrol terminal, is one with the most difficult access through a channel and very close to inhabited areas. (6) Blasts are included in the study. Probability is low according to natural gas behaviour. The only exception is that were the gas cloud touches the existing plant, which represent a 99% explosion

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world’s best experts on LNG risks, expect that even at very low speed and the most safe double walled tanker construction, a 90o collision will result in a tank been pierced. (Up to 4.5 knots the tank will not be penetrated, but at 6 knots collision speed the opening in the tank becomes already 5 m2, although there is a chance that the two ships do not separate after the collision.) An opening of 1 m2 will be sufficient to extend the distance to the lower explosion limit to 1.5 km in case the LNG does not ignite immediately! In Boston and Rotterdam harbors stringent precautions are taken to control traffic when a tank ship arrives, but there is no permanently present FSU moored which increases the probability considerably. For a new LNG terminal in Rotterdam harbor in 2008-9 extensive maritime port safety risk assessments have been performed by the Dutch MARIN institute with longtime experience in ship collision prediction resulting in a detailed admission policy. We appreciate SGS’s conclusion with respect to maritime risk assessment but what will be its comments to ship-to-ship collision consequences? 6. Possible flame acceleration generating blast It is mentioned on page 66 of 88 that as can be expected, a cloud drifting towards the regasification and further to the power station will find an ignition source. The report does not mention flame acceleration due to congestion, but that is the mechanism that makes clouds not only flashing but producing destructive blast. Pipework, fences, greenery, columns and smaller buildings provide congestion. Hence, we agree with the statement that ignition of a cloud drifted inside the plant area shall have to be prevented at all times. SGS suggested to increase the distance between the FSU and the plant. But how far is far enough? The consultant takes as the edge of the cloud the 5% lower explosion limit concentration. But pockets of gas can still be flammable below that average concentration and therefore one takes usually 60% of LEL. What is SGS’ comment? 7. Event frequency increasing human factors The reports confine themselves to a generic land use planning safety aspect and do not consider the effects of operational safety. Organizational and human factors in operation and maintenance have a strong effect on the mentioned failure rates and event frequencies. The reports base themselves on Seveso II and the 2003 Amendment. These directives introduce,

probability and has been considered. With regards to safety distances the question is how far is far enough? It is important to note that the calculated case is the worst case in absence of any safeguards. Containment basins, together with hydroshields and foam and Emergency Shut Down (ESD) logic activated by gas detection would lead a leakage minimisation, pool minimization and evaporation rate minimization. Real accident with 100% emergency systems working will drastically reduce the length of cloud with respect to the calculated distance. (7) HAZOP is extremely important and can give us details about the frequency of each scenario. But the approach of increasing the frequency in the study is not according to the ALARP criteria. What we have to do is to implement additional safeguards and safety instrumented system (SIS) strong enough and certified for each purpose, so that the frequency is controlled. This is done through the extension of HAZOP up to functional safety studies (standard IEC 61511, layer of protection analysis (LOPA), failure tree analysis (FTA), all them based on final design of the plant. It is important to note that in projects of this type it is not normal procedure to arrive at this level of detail prior to the development permit. Such a level of detail is determined prior to the operational permit (IPPC), particularly considering that details are provided by vendors of the different equipment. (8) Lightning or static electricity is absolutely not expected in an LNG tanker. The same applies for a LNG terminal. Human error expected and corrected, all

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besides others, the safety management system and process safety performance indicator metrics. Implementing and maintaining this requires local process safety competence and in view of the complexity of the installation of relatively high expertise level. Meanwhile Seveso III is into force (2012/18/EU) emphasizing the requirement of drawing up internal Enemalta emergency plans and providing data for external community plans, while inspection/auditing requirements are further strengthened. Are there any preparations from the side of Enemalta for the safe operation of the installations, since it needs considerable time to establish this for a complex Seveso top-tier plant? Indeed, the present QRA study can only be considered as preliminary. SGS states at page 41 of 88 commenting on further hazard identification techniques as HazOp: ” Experience teaches us that for highly automated and controlled processes, these techniques add no additional credible scenarios Too few details are available to make more refined analysis.” Our comment is, it may not add new scenarios but it usually can increase significantly the expected frequency of existing scenarios. In case of large safety space this would not be a problem, but in view of the small distances to population, other ship traffic and industrial activities it is a problem, and a definite answer to the question is it safe enough can hardly be given. How do you comment? 8. Operation of resupplying the FSU and of feeding the regasification unit The arrival of fresh supply by LNG tanker and unloading operations are another risk source. In line with the previous point this is a rather frequent operation giving cause to leakages and spills. In itself these spills may not be large, but in case of ignition by lightning or static electricity the problem is possible escalation. The ship structures provide confinement/congestion to spilled gas. The scenarios pertain all to component failures. Why are errors in the human operations not considered? What overfilling precautions have been taken from resupply ship to FSU? How is the continuous LNG flow from FSU to regasification plant controlled? What about loss of power and emergency shutdown e.g., in case of fire? Are any fast acting valves foreseen in case of breaking loose of any of the unloading arms? 9. Threats to the FSU due to events elsewhere in the bay area Threats to the FSU due to events elsewhere

operations are double checked by the distributed control system. Percentage of manual operations executed by man is reduced and all of them are supervised. Control systems are redundant. Overfilling of LNG tanker is not considered credible with state-of-the-art technology. FTA can be done. Flow would be controlled with absolute precision throughout the whole regas operation. The operation is very carefully controlled to obtain a continuous and stable flow. Emergency shutdown is covered, all instruments are linked to double source and or uninterrupted power system (UPS) plus batteries. Instrumentation installed in LNG terminals is provided with selfchecking system and go to safe position in case of disconnection of cable, no signal, fire, damage, etc. ERC is a fast acting valve itself. (9) Domino effects of the proposed LNG plant in the Delimara power station were considered. When considering the domino effect and impacts that multiple installations such as Freeport and Gasco might have it is my opinion, from looking at similar installations, that such a type of study is never promoted by a single consultant or a company, but by the port authority or the any other competent for Seveso Directive compliance. Traffic regulation can result from this and this is not the purpose of this report. If questions are raised focusing on the other installations within the port it could be useful to point out that the installation used in LNG is, for example, safer than that used for LPG. In our opinion, the most important domino effect (and higher risk contribution) is related to existing facilities and should be studied due to the presence of LPG and

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are not considered. What about a hydrocarbon spill in the bay due to a collision between for example a gasoline tanker and another freight ship, causing the gasoline to ignite? What are the operations at the dolphin in the bay? The storage tanker is an easy target for malevolent action, since it is in the field of view from many land position directions. A hole in a tank of 5-7 m2 is not that difficult to obtain. Are any security measures considered? Why are domino effects by other Seveso installations in the area not considered? 10. Construction of the FSU To what specification is the FSU built? Single or double walled? How are the tanks insulated? With what materials? (Some insulating materials lose their insulating properties in case of external fire and may even themselves be combustible). At what pressures are the pressure relief valves set? How frequently can roll-overs be expected? Where is in such case the escaping vapor being led to? 11. Stability of the FSU, its maintenance and its connection with the regasification unit How is the mooring stability assured? How are the motions of the FSU relative to the fixed wall position compensated? How flexible is the connection with the on land installation and how its endurance? How will the maintenance of the FSU be handled? Is there a reserve FSU available? As there is no buffer on land, there should be a continuous supply of gas to the turbines to guarantee power supply. How will the unloading arm, the feed pump etc. behave when permanently loaded? Has there been a reliability and availability study of these parts continuously in contact with the cryogenic? 12. Emergency planning A QRA and scenario analysis serve too for emergency planning. In fact, has there already a preliminary emergency plan drafted for the whole installation? Only small fires will be extinguishable. How will alarming and evacuation of workers and near-by population be organized? Emergency response will have also to come from the community, short response time is essential, how will the local councils cater for that? 13. Need for technical details to appreciate the safety situation We understand that so far few technical details on the installation are provided.

gasoline. (10) The FSU is built to IGC (International Gas Code), IMO, Classification and flag state requirements. The tanks are to be double walled and insulated using pre formed Polyurethane panels with foil barriers and N2 blanket. Insulation is rated for continous cryogenic use. Pressure relief valves will be set to 50 - 70kpa. Rollovers are not anticipated since there is mitigation by internal transfer and monitoring of temperature gradients to identify potential stratification. In the unlikely event that vapour is released from tank relief valves this would be sent to the forward vent riser. (11) Mooring stability is assured using good industry practice and simulations to prove robustness of the mooring arrangement. Motions of the FSU relative to the fixed wall position are compensated for through fendering and flexible hose offloading system. Hose data has been provided to OHSA consultants and included showing bend radius, construction methods and safety records. Detailed Periodic/preventative maintenance system is in place as per class and flag stste requirements. No Reserve FSU is currently envisaged since FSU's are available in the market if an alternative vessel is needed. All systems are designed and rated for continuous use. A RAM study has not been completed but all parts of the system comply with relevant sections of EN1474 and classification rules. (12) Such details are normally made available to the public through the consultation process under the IPPC directive and currently the IED (EIA

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However the devil for safety is often in the detail. So, when can more information be expected? 14. Some detail questions: Page 19 of 88: What purpose serves the propane system? P. 37: Releases on the jetty: 'pipeline from ship to storage tank'. What tank? There is no LNG tank on land, or is there? N.B. There is an extensive Annex D on acceptance criteria, which can also trigger quite a few questions and comments, but I assume Malta does not have quantitative risk criteria cast in law and acceptance will be on adequacy of design, site positioning, lay-out and risk reducing measures taken including the ALARP (as low as reasonably practical). Hence, this annex may not be relevant at this time. SGS does mention in the annex US Department of Energy but not the US FERC acceptance regulation for LNG (exclusion zoning), which is on radiant heat threshold (5 kW/m2) and vapor concentration (50% LEL) limits.

Coordinator) The scope of the preliminary QRA is to determine whether the FSU is compatible with the land use planning or not. As many other projects at this stage, calculation inputs have to be estimated and cannot be definite. For these reason, any permit issued within the IPPC/IED framework in the EU includes limits and restrictions which cannot be exceeded and needs to be corrected during the further phases of the project. (13) The propane system is approximately 10 cubic meters total volume. Its purpose is for use as an intermediary heating system in regasification of LNG thereby preventing freezing of the heating medium. The use of propane increases reliability of the regasification process. There is no LNG tank on land for the storage of LNG. (14) Annex D is generic, not specific for LNG regulation, in fact EN 1473, is not mentioned.

2. NATIONAL ENERGY POLICY 2.1 The Coordinated Assessment of the EIS (p.54) states that, 1.1.1.23 … the SEA states that the Government was to make a decision regarding the preferred infrastructural system [and therefore technology] for gas, which decision would then be evaluated through an EIA, risk assessment and so on: At Government level, the type of infrastructure has not yet been identified. Once a decision is taken, detailed assessments including EIA, risk assessment etc would have to be carried out to identify and address any site specific issues. (ADI, 2012, p. 137) The complete quote from the SEA is actually as follows: “7.121. The use of natural gas for the generation of electricity will result in a reduction in the emissions because this fuel

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has lower emission factors than the fuels currently used for electricity generation. All types of technologies considered require either the building of infrastructure or some sort of intervention. The LNG Terminal has the largest land based requirements whereas impacts from the floating terminal and the pipeline are mainly marine based. The information available at this stage is not sufficient to point to a preferred option, even from an environmental point of view. More detailed studies are required. At Government level, the type of infrastructure has not yet been identified. Once a decision is taken, detailed assessments including EIA, risk assessment etc would have to be carried out to identify and address any site specific issues” (p. 137) It is clear in the full quote that the SEA first calls for detailed studies to decide on a preferred option, including from an environmental point of view. It is only once these studies have been finalised and a decision is taken, that “detailed assessments including an EIA, risk assessment etc would have to be carried out to identify and address any site-specific issues.” Yet the required studies and environmental assessment identifying the preferred choice between an LNG terminal and an LNG gas pipeline have not been presented to the public and do not appear to have been carried out at all. As the EIS quotes paragraph 7.121 from the SEA, Din l-Art Helwa requests that EIS should address the points raised in paragraph 7.121 comprehensively and provide an explanation on why the required detailed studies have not been carried out. Din l-Art Helwa maintains that these studies should have been carried out as part of an update to the National Energy Policy, which would also have ensured that structured and objective public consultation takes place on all options for gas infrastructure. 2.2 The comments on the QRA attached to this document in Appendix One, call for caution in choosing the final option, and requests that all marine-based options should be assessed further. Other comments received by Din l-Art Helwa include a gas pipeline, and a proposal to base the gas storage in an area at Hal Far. Have these options been studied and compared in adequate detail? If so, why have the studies not been made public?

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2.3 The EIS has not provided an adequate answer to the following query made by Din l-Art Helwa in relation to the draft EIS: “ 5. The Project Description Statement states that the Delimara3 extension (when converted to gas) is only expected to have a utilisation rate of 50% once the proposed CCGT plant is operational. What are the expected utilisation rates of the proposed CCGT plant, the Interconnector, and the rest of the Delimara plants, from 2015 to 2020? What will be the “default pecking order” of the various power plants and the Interconnector? This analysis must be included in the EIS.” The EIS coordinator response is as follows: “The EIS covers an application for a new CCGT and assumes that such CCGT will be utilised to satisfy base load requirements. Other considerations such as making more use of the interconnector and reducing the use of the proposed CCGT may result in less environmental impact, but such a decision is not only taken on the environmental impact but on a range of other considerations including but not limited to economic issues. Such considerations are being dealt with in the CBA which will form part of the IPPC permit as requested by MEPA.” The EIS coordinator notes that “making more use of the interconnector and reducing the use of the proposed CCGT may result in less environmental impact”. Din l-Art Helwa’s earlier question, submitted in relation to the draft EIS, to outline the utilisation rates of the proposed CCGT plant, the interconnector and the rest of the Delimara plants, is clearly relevant and should be answered in the EIS which should address all environmental considerations and scenarios. No satisfactory answer has yet been provided to this question, which has environmental implications. The response also notes that the Cost Benefit Analysis is being undertaken as part of the IPPC permit. Once the IPPC permit application is already underway, this information should be brought to the MEPA Board for consideration at the same time as the planning application and related EIS. The development planning permit and the environmental permit of this project of national importance should ideally be considered together by the Board. 3. SOCIAL IMPACT ASSESSMENT Din l-Art Helwa had specifically requested in the previous round of consultation that stakeholders in the area would be shown

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photomontages of the project during the Social Impact Assessment. Yet the Social Impact Assessment for this EIS was carried out in July 2013, well before the photomontages of the final option were available, so stakeholders have not had the opportunity to view any images of the proposed layout and visual impact. Why have stakeholders not been shown upto-date photomontages of the project, when it is clear that visual impact is a major concern? Why was the Social Impact Assessment not updated? 4. NOISE IMPACT ASSESSMENT The Noise Impact Assessment recommends that development in certain areas of Marsaxlokk should be restricted, especially building heights, due to possible noise impacts. This is in line with the mitigation measures proposed in the national Noise Action Plan. Yet this recommendation does not appear to be included in the Coordinated Assessment of the EIS – why has it been left out? How will this issue be addressed and what detailed mitigation measures are being proposed? th

C. Marsaxlokk and Birżebbuġa Local Councils (Letter dated 20 January 2014) Comments Preamble This document is a response to the publication of the Environment Impact Assessment on the new CCGT and Gas Storage Facilities by Electrogas Malta to be established at Delimara Power Station. This follows on a previous submission ref: B.01.01 issued prior to the EIA and B.01.02 by the Marsaxlokk Local Council. Introduction Since the publication of the last two submissions by the Marsaxlokk Local Council, the project presented by the consortium Electrogas was selected as the winning bid for the construction and operation of an LNG fuelled generating plant at Delimara Power Station. The plant shall have a configuration as detailed by Option B in the previous EIA, wherein the gas turbines will be located between the wharf and DPS workshop, and the regasification unit located on land in the vicinity of the oil storage tanks. The LPG shall be stored on an LPG carried moored to a jetty that is to be built in the inlet between the main oil storage facility and Fort

ERSLI Responses (1) It should be noted that the use of the abbreviation LPG is incorrect. The proposed FSU would be storing LNG. The properties of the two fuels are very different. LPG is mainly made up of the heavier-than-air propane and butane and it is mostly used for commercial and domestic applications. It is stored in liquid form under high pressure. LNG differs from LPG due to its properties: natural gas is substantially lighter than air. While LPG is stored under pressure, LNG is stored at a very low temperature, which requires the use of different materials and standards. Currently, LPG is stored in Bengħisa in a facility (approved in 2010) which is situated adjacent to (i) Fort Bengħajsa (to the southwest) and (ii) [to the east] by the oil storage terminal that is located

EPD Comments Noted.

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Delimara. The policy established by the new administration of installing new generating plant fuelled by natural gas with the aim of reducing the coast of electrical power generation and even more so improving the quality of the air by way of cleaner emissions, received favourable consideration both by the Local Council and residents alike. The Local Councils of Marsaxlokk and Birzebbuga, continue to strive to ensure that any development will have a minimum impact on the residents of both localities. Previous submissions have dealth with three specific areas namely: 1. Air quality; 2. Noise emissions; 3. Social Impact. The above mentioned areas still remain matters of interest and this document is to be considered as an addendum to the submissions already made. The volume of data presented in the Consultants ERSLI on behalf of Electrogas Malta in the EIA document is large. The studies presented cover the subject matter in considerable detail. The time allowed after publicatiojn of the EIA, which incidentally occurred just before the Christmas festivities, has put considerable pressure on all attemps to review the document and make detailed submissions on all of the studies. This document therefore concentrates on the main priority that is the main concern of practically all residents of Marsaxlokk and Birzebbuga i.e. the risk associated with the floating gas storage facility within the port of Marsaxlokk. Floating gas storage facility and associated risks Scope of study The coordinated assessment cov ering the whole project, reports on the work of Mr. Vaccari who was charged with the Environmental Risk study. The report presented analyses various accident scenarios to establish the risk presented by the new plant. The approach of the study is set in Section 4.3.3. with particular objectives being indicated in sections 4.3.3.5 and 4.3.3.7 (Annex I) as follows: 4.3.3.5: Risk calculation was based

by the Freeport. LPG carriers make use of the berthing facilities which form part of the said oil terminal, in order to supply the LPG facility. The points made by the Councils are taken, and as stated above, these comments (like all comments made regarding the EIS) will form an integral part of the documentation produced during this EIA process. This EIA Coordinator is sure that the media coverage of the SIA has already made the decision maker (i.e. the Board of the MEPA) aware of the contents of the SIA regarding this matter. (2) The two drafts of the QRA presented in the EIS package were submitted to the OHSA (the lead member of the Maltese competent authority under the Seveso Directive) soon after they were received. (3) As is noted above, the FSU proposal has been studied by the Directorate of the Ports and Yachting Directorate of Transport Malta. Chapter 2 of the Coordinated Assessment report (of the third draft of the EIS) refers to a letter from the Chief Officer of the Directorate, which states that the simulation studies carried out [by his Directorate] with respect to the location of the FSU in Marsaxlokk Harbour indicated that there is sufficient room for manoeuvre in the said harbour for both the LNG carrier (8 to 12 calls per annum) and for vessels attracted by other activities located in the harbour (2,700 in 2012). The Chief Officer also indicated that it would be essential for him to be provided with a full nautical and harbour risk assessments. These assessments are being prepared. The points made by the Councils

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on the scenarios with all relevant consequences (lethality) for the existing situation, using specialised software. 4.3.3.6: Individual risk (expressed per year) is the multiplication of the number of times a major accident per year occurs, with the adverse effect (death) that a person experiences as a result of exposure to the disturbance (toxic effect, heat, pressure wave) 4.3.3.7: To ensure full representation on safety, the calculation of ‘group risk’ is required. The group risk is the risk that at any one time a group of persons are victimes of the same adverse event. Stated consisely: the purpose of the report is to assess the probability of the death of people, and the damage or destruction of buildings and equipment in zone of influence around the new plant.

are taken, and as stated above, these comments (like all comments made with respect to the EIS) will form an integral part of the documentation produced during this EIA process. This EIA Coordinator is sure that the media coverage of the montages has already made the decision maker (i.e. the Board of the MEPA) aware of the issues concerning this matter.

LP Gas characteristics relevant to the assessment of risks Flammability Referring to section 4.3.4.4 the ignition energy of natural gas/air mixture is 0.29mJ (Annex 2). This is indeed a relatively a very small amount of energy and as the report confirm the gas/air mixture may be easily ignited by machinery, cigarettes and static electricity. Asphyxiation and dispertion Natural gas is odourless and colourless. Although the report claims it is not toxic nor carcinogenic it remains a simple asphyxiant gas (Annex 2). The report mentions that a relatively high concentration of the gas is required for asphyxiation, no mention is made of the concentration level that will lead to asphyxia is made. This is of particular impacortance when considering dispersion of the gas in the environment. In fact, section 4.3.4.10 states (Annex 2 and 3) that: “LNG vaporizes rapidly when exposed to ambient head sources such as water, producing circa 600 standard cubic metres of natural gas for each cubic meter of liquid. When spilled on the ground or water, LNG will intially produce a cold vapour that is denser than air and will stay close to the surface or ground. As this cloud mixes with air, it will warm up and disperse into the atmosphere. The downward distances that

(1) Asphyxiation hazard is generally not considered as a hazard for the population. The high concentration requested for this hazard to turn up is generally present only within the fences of the plant or in the vicinity of the jetty, where the presence of the public would be restricted due to security reasons. Asphyxiation is not directly due to the natural gas, but to the lack of oxygen. Oxygen is normally al 20,8%, when below 16%, excessive breathing takes place and below 4-6% the body enters in coma state. To have the 16% of oxygen is required to have more than 20-25% of natural gas in the air.

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the flammable vabours might reach is a function of: LNG spill rate/volume Evaporation rate Prevailing wind conditions. 4.3.4.11 continues that in order to disperse to significant downward distances a vapour cloud must avoid ignition. This essentially means that unless the gas cloud ignired than the possibility exists that a gas cloud could travels significant downward distances surely reaching not only residences around the station but also Marsaxlokk and Birzebbuga.

(2) We agree on " the possibility exists that a gas cloud could traverse significant downward distances " but the conclusion of our simulation is presenting a result compatible with the presence of residences in the area.

This does not exclude that both localities will not be affected in the even of a detonation and deflagration of a gas cloud of relative proportions. This will be dealt with in the sections that follow. The model The evaluation of the risks that the new LPG plant will present is based on a software model. The report quotes the utilisation of a software package i.e. EFFECTS 8.1.8 (Annex 4). Refereneces for the EFFECTS software package which the report claims is copyright of the Dutch research organisation TNO, could not be traced. Detailed metereological data is essential for proper analysis so much so that point 4.3.6.3 (Annex 5) states that the accurate and reliable stability class statistic is recommended in order for the meteorological information to be complete. The report continues that “this statistic is available only for a few locations in Europe. For the remining locations, estimation on the basis of similar weather conditions is considering best approach”. Mr. Vaccari has therefore assumed that no wind data whatsoever covering the Port of Marsaxlokk is available. The port of Cartagena in Spain is deemed by the author to approximate the conditions in the Port of Marsaxlokk. The software model is actually based on the conditions in the Port of Cartagena in Spain rather than the actual conditions in the Port of Marsaxlokk. That the model is based on an approximation will therefore as a condequence draw the accuracy of the results into question. This is a fundamental issue. If one were to view Cartagena (Annex 6) it would be immediately apparent that this port is surrounded to the east and west by high

The query "TNO EFFECTS" on google or any other search engine can easily lead to the TNO web page where documentation is available and contact with TNO can be made. The reader is referred to: https://www.tno.nl/content. cfm?context=thema&content= prop_case&laag1 =896&laag2= 915&laag3= 106&item_ id=1480&Taal=2. One can contact Victor van Swinderen, whose contact details are located in the same page.

All data used to simulate gas dispersion and the maximum extension of damage zones are referred to Malta and have been provided by the official meteorological service. Data from Port of Cartagena in Spain has been introduced only as a reference in the calculation of risk contour. The model has been validated and

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hills, an extensive land mass to the north and a stretch of sea to the south to the coast of Morocco, leading into the straits of Gibraltar. Marsaxlokk Bay (Annex 7) by comparison is larger, and has some high ground to the north which is much lower that the hills to the east and west of Cartagena. The ground to the east, west and south is relatively low ground. The land mass presented by Malta cannot be compared to the land mass of the Iberian peninsula. Moreover our island is what it is, an island in the middle of the Mediterrenean Sea.

is accepted in all the European Union. Application and use of the model according to standards and guidelines.

The basic geography of both sites is so different that it becomes imperative to ask the question as to how could one approximate the conditions in Marsaxlokk Bay utilising the conditions in Cartagena. In taking this line of action, Mr. Vaccari has in fact impaired the validity of the whole assessment. It is obvious to state that an accurate model will depend on accurate site data as stated by Mr. Vaccari himself. The accuracy of the meteorological data is imperative for the creation of a valid software model. By basing the study on data, particularly wind speed data (Annex 5) from the port of Cartagena (vide Annex 6 and 7), the model used is not a representive one of the conditions of Marsaxlokk Bay. This state of affairs requires explanation from Mr. Vaccari as the validity of the whole model is drawn into question. Risk analysis The document as presented lists the various scenarious that have been analysed using specific parameters. Without retracting in any manner on the question of the invalidity of the model, Mr. Vaccari makes a statement which is striking, as follows: 4.3.10.2 (Annex 8): In the case of the DPS a potential domino effect can occur through a fire and explosion. Vaccari lists a number of mechanisms by which fire could spread, and goes further in Point 4.3.10.10 (Annex 9) regarding explosions by stating: “The pressure generated by the combustion wave will depend on how fast the flame propagates and how the pressure can expand away from the gas cloud (governed by confinement). The consequences of explosions range from no damage to total destruction. The

The report includes a list of 14 scenarios, each one bang the worst credible scenario for the considered equipment, according to guidelines and standards accepted in the EU. Number of deaths presented in the Societal Risk Analysis. The existing DPS and the energy dependence of Malta from the DPS supply, makes DPS relevant in the report. The conclusion aims to ensure in the layout that the FSU is located as far as possible from DPS, in order to avoid any possible domino effect between both installations.

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pressure wave caused by a gas explosion can damage personnel and material or it can lead to accidents such as fires.” One assumes that the phase “damage to personnel” should be interpreted as meaning “serious injury or death of personnel”. Considering that these statements are made in the context of the DPS, an explosion and fire could result not only in the loss of life of the operators but also in the oss of plant. The security of supply is therefore now also drawin into question. Vaccari then goes into the general description of the mechanisms of deflagration and detonation and the factors by which these are affected and in point 4.3.10.15 makes a rather odd statement (Annex 10): “Vaccari stresses that gas explosions may be very sensitive to changes in these factors. Therefore it is not a simple task to estimate the consequences of a gas explosion. This is a very important statement, especially more so when read in the context that the site data is on the Port of Cartagena and not the Port of Marsaxlokk. This statement adds further to the degree of doubt of the validity of the model and more so on the validity of the results of the whole assessment. Results The report as presented goes into the analysis of the data and presents a number of contour chracts. These are result from the software model adopted which is being questioned, based on conditions at the Port of Cartagena in Spain. It is difficult to comprend that no wind data at all is available covering the requirements of this study is available. This begs the obvious question, on the basis of which wind data were previous studies carried out, particularly the most recent covering the BWSC plant at the same DPS? What wind data is being used in the design of the structures and also operations at the Malta Freeport Terminal within the Port of Marsaxlokk. Is it at all possible that no wind data exists so much so that Mr. Vaccari was comelled to use wind data from a most distant site in Spain, a site which most obviously has geographical characteristics which are far different from those of the Port of Marsaxlokk. Moreover, Mr. Vaccari stresses the point that the accuracy of the results will depend on the accuracy of the data, pratically undermining the whole study, as the data may not only be inaccurate but even more so totally unrepresentative of the conditions in the Port

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of Marsaxlokk rendering the results invalid. Furthermore in his conclusions, Mr. Vaccari does not exclude the possibility of an accident that could lead to the death of people and destruction of plant and property. The probability of the occurrence of an accident, even if remote, remains a probability. It is not a certainty. Ascribing a probability of say 1 in a 10,000 years to an even does not exclude that the even will not occur tomorrow, within a week, a month or a couple of years. Rather than speaking of the probability of the occurrence of an even once should concentrate further on the worst case scenario. That is to say, if the worst accident had to occur, how many people will be expected to die and what is the extent of the resultant destruction. This is the fundamental question which has not been answered. This is the information that should have been presented in the risk assessment. Social Impacts The result of the social impact assessment carried out last year in the preliminary phase of this project (Annex 11) shows very clearly that 91 per cent of the population of Marsaxlokk weant the LPG tanker to be located outside of the Port of Marsaxlokk. The residents are particularly concerned about the effects an accident will have both on their lives and property. Although there is acceptance that the plant operating on LP gas will be cleaner, practically the whole popluation of Marsaxlokk wants to eliminate any risks of death or destruction by locating the LPG tanter at a safe distance outside the Port of Marsaxlokk. In previous consultations, the Marsaxlokk Local Council had suggested that the location of the LPG tankers within the port should only be a temporary measure, and that all preparations should be made to relocate the storage vessel outsie the harbour, thereby eliminating all risks both to the Delimara Power Station and more importantly to the populations of both localities. The mooring of the LP storage vessel as detailed in the proposal by Electrogas Malta will also have a negative visual impact on Marsaxlokk and Birzebbugia which is already affected by the existing power station. The relocation of the storage vessel outside Marsaxlokk Port will also minimise the native

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visual impact of the development on both localities. Furthermore, the present plans should include for that connection of future gas pipelines. This would enable the connection of gas supplies from other sources, without disrupting operation of the plant. Should this come in fruition, then the storage vessel will no longer be required resulting in an optimal solution eliminating both accident risks and the native visual impact on both localities. Conclusions In view of the observations raised above and in the previous submissions, attention is drawn to the following: (1) The software model used to analyse gas cloud dispersions is based on meteorological data of the Port of Cartagena in Spain which bears no geographical resemblance to the Port of Marsaxlokk at all, and is therefore invalid. (2) The invalidity of the software model automatically invalidates the results of the whole risk analysis. (3) No worst case scenario analysis is presented. (4) No specific indication of deaths and destruction to property in the event of a worst case accident are analysed or presented. This risk has to be established. The Malta Environment and Planning Authority should be requested to address the points mentioned above. Furthermore, MEPA should be requested to instruct Electrogas Malta to make additional preparations for the relocation of the gas storage vessel to a suitable location outside the Port of Marsaxlokk from where a worst case accident will have no effect either on the populations of Marsaxlokk, Birzebbuga, their property, on Enemalta itself, and also on other installations within the Port of Marsaxlokk such as Malta Freeport including st the fuel storage facility and 31 March fuel storage facility belonging to Enemalta in Birzebbuga. In the circumstances mentioned above the undersigned are of the opinion that the location of the LPG floating storage vessel within the Port of Marsaxlokk can only be considered after a proper study has been carried out and the extent of risk to life and property under worst case conditions has been determined.

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Furthermore, it is recommended that, in the present circumstances, the floating storage vessel should be located outside the Port of Marsaxlokk. MEPA should be requested to include this as a condition in the building and IPPC permits. In closing the undersigned are of the opinion that the communities of both localities favour the utilisation of natural gas to fuel the new power plant. However, both communities and economic operators seek at the same time their highest interest; that of preserving their wellbeing, their property and their standard of living. th

D. Member of the public (1) – Ing. John Pace (Email dated 24 January 2014) Comments My comments relate to Air Quality and Risk Assessment. There are three scenarios which have to be considered: 1. Normal operation 2. Emergency operation 3. Accidents Normal operation is dealt with in Appendix 2 Vol iv, which is however limited to NOx and particulate jpollution. Accidents are dealt within the QRA report by Mr Vaccari in Appendix 2 vol vii. However in both cases reference to emergency operation is totally omitted. In normal operation the CCGT plant produces an output and consumes gas so that the regasification plant operates normally. In an emergency the CCGT plant trips and the regasification plant has to close down. The boil off gas in the LNG tanks has to be disposed of as otherwise an overpressure will result in the tanks, which are designed for operation at atmospheric pressure. It is naive to consider that emergencies will not occur, and experience of the existing CCGT plant will enable an estimate of the frequency and duration of such emergencies. Particularly in the first few months of operation it is expected that there will be teething troubles which will have to be resolved and emergencies will be more frequent. There is also the case of planned outages of the whole CCGT plant, when provision has to be made for the prolonged shut down of the regasification plant. In large LNG terminals the plant usually feeds large gas grids, with several power stations, industry and a large domestic load, so that the failure of a single power station will not effect the operation of the

ERSLI Responses (1) When the regasification plant is shut down suddenly the boil off gas will be redirected to a nonvisible combustion chamber (NVCC) located adjacent to the regasification facility. Planned outages are organised to ensure that gas flow is maintained thereby ensuring that power plant gas turbines can be supplied with boil off gas continuously. The regasification unit itself has been designed to ensure continuous operation and thus consumption of boil off gas even during its own maintenance.

EPD Comments Noted.

(2) There is no existing gas fired CCGT plant on the Delimara power plant site. The design of the facility for disposal of excess natural gas is the non-visible combustion chamber (NVCC). The only emergencies envisaged as being associated with the needs for disposal of excess natural gas are ones where the regasification plant or associated equipment becomes nonoperational in which case the NVCC will be utilised. The ElectroGas Malta CCGT power plant configuration and design was selected on the basis of its record of high inherent

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regasification plant and disposal of the boil off gas is not a frequent occurrence. In the case of Delimara there is only one outlet and shut down of the regasification plant will be relatively common. Overpressure in the LNG tanks is provided for by an atmospheric relief valve through a stack and a flaring system. It is possible that supplementary systems will be present to reduce the amount of flaring. Unfortunately no information is given in the project description statement or the EIA on measures to provide for such overpressure. The following questions need to be answered: 1. What provisions are to be made for the disposal of boil off gas when the regasification plant is shut down suddenly when delivering full output, or in the case of a planned outage? 2. An estimate of the frequency and duration of emergencies resulting in flaring of excess natural gas. Such estimates should be based on experience of the existing CCGT plant and of the peculiar nature of a new gas fired plant. 3. The amount of gas flared at various scenarios, and the duration of the flaring. 4. The amount of carbon monoxide and of particulate carbon produced by flaring as a daily maximum and as a yearly total. 5. The effect of the CO and PM emissions on the National Emissions Ceiling and other obligations. 6. The effect of the emissions from flaring on neighbouring populations, including the Delimara power station staff.

reliability in more than 50 installations. It is expected that the CCGT will have reliability in excess of 99% per year throughout its life. Thus, it is anticipated that unplanned shut down of this plant will occur at a frequency of not more than three days per year. There is an envisaged high probability that during these periods the Enemalta gas fired power plant would be available for the consumption of boil off gas or the NVCC. (3) There will be no gas flared under any scenario. The ElectroGas Malta response to the RfP was mindful of, and complied with, the requirement that there should be no gas flaring. This was recognised on the basis that the visual intrusion of a gas flare was deemed inappropriate in the locality of the Delimara Power Plant site. (4) There will be no significant carbon monoxide produced as a consequence of burning natural gas in any situation envisaged on a daily or annual basis. Where boil off gas or operational gas is combusted the product of combustion will be carbon dioxide. There will be no particulate carbon produced from the combustion of natural gas. Natural gas is a cleaner fuel than the liquid fuels currently used on the Delimara site. (5) Flaring is expected to be minimal, and therefore its effects on National Emissions Ceilings is also minimal.

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E. Member of the public (2) – Mr. Alfred Falzon (E-mail dated 28 January 2014) Comments Which part of the coastline from Power Station to light house will be out of bounds to stakeholders, i.e. fishermen, small craft and

ERSLI Responses This is for the MEPA to decide after the assessment by the OHSA

EPD Comments Noted.

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bathers? This coastline is the only shelter from north easterly winds in the whole bay.

of the Risk Assessment reports. th

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F. Member of the public (3) – Mr. Kees de Jong (E-mails dated 4 and 7 February 2014) Comments Kindly accept and confirm receipt of my entry for “Objection to the FSU-based Gas supply for the new 200 MW Powerstation in the Marsaxlokk Bay” Dear …. The NG supply has been considered as possibly in three modes : 1. Pipeline from Gela to Malta 2. FSU inside Marsaxlokk Bay in combi with a re-gasification plant onshore. 3. FSRU well offshore relatively safeguarding installations and human settlements around the bay. Ad 1. By now it will be evident that this mode is technically the safest and most likely the less costly in the long run, albeit that the ultimate control over the pipeline and the gas supply is in the hands of “Italy” which poses a commercial risk. Malta would not like to be put in a position such as Ukraine vs Russia. Ad 2. Even though this might be an attractive solution from an operational view, considerable risks have to be covered by very high premium insurances, which makes this solution unattractive and probably rather costly in the long run. Ad 3. This methodology keeps the bulk of the risks in one place, well away from the bay area , whilst operations are weatherproof with waves up to 7 mt high, which never occur in the Malta waters.

ERSLI Responses *

EPD Comments *Note: Replies provided to the Marsaxlokk and Birżebbuġa Local Councils, Din l-Art Ħelwa and BEAG also apply for this submission.

Before even going into some detail below , let us summarise the overall cost/risk situations: 1. If the government goes ahead (which they will apparently , according to the George Pulicino article –TOM 020214, as the FSU has already been ordered before contract) with a LNG Terminal inside the Bay and a Re-gasification Plant ashore , one way to quantify the risk is the cost of Insurances for the Terminal operations with FSU and Shuttle carrier operations as well as for the onshore regasification and power generating plants. The Insurance will also have to cover the adjacent existing powerplant and the 2 townsites adjacent to that. Moreover, apart from the direct damages etc the cover should also spread over the consequential damages –human, social, commercial- etc. Consider the BP blow-out consequences in theCaribbean. One has to realise that in this set up an accident , even in a theoretical low risk

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situation will result in an absolute national disaster for the population of the townsites (you cannot smell the gas) as well as for the generating plants being out of action. 2. If the off-shore fsru solution will be adopted at a safe distance from the coastline, a serious accident will only happen offshore and wil not affect the 2 townsites , nor the generating plants . The relevant Insurance covers should cost considerably less, compared to the set-up under 1.as there will be rather limited consequential damages, other than temporary powergeneration replacement, until the FSRU is replaced (leased or rented) To overcome the consequences of a fatal accident in the set-up under 1. Huge floating powerstations to the capacity of some 400MW have to be mobilized and commissioned during the re-construction period of the damaged LNG (2x200MW) plants. This will take a considerable time and Malta will have to distribute power on a very selective basis. To overcome the consequences of a fatal accident in the set-up under 2. A replacement FSRU will have to be mobilized from the market . There are already companies , such as HOEGH from Norway , constructing such vessels.

From experiences out of my earlier career I remember 2 areas of great importance when developing a LNG Terminal: 1. Safety and Security criteria and requirements resulting in a large safe area taking up a very substantial navigation , berthing and mooring space in any port. I believe a fixed receiving terminal in Marsaxlokk , incl it’s approach channel with turning bay will cause difficulties for all other shipping in the bay and will require a very substantial investment , due to the fixity of the berthing structure. If I understand the current project planning a fixed wharf structure will accommodate the permanent berthing of the LNG storage Carrier as well as accommodate the regular incoming Shuttle Carrier. The Storage vessel has to be moored at a considerable distance from the plant areas , i.e. the wharf structure to be built well inside the bay away from the shoreline with a well protected safe area around this facility to avoid accidents and their consequences. We have to bear in mind the ship size : L=277 mt. Beam=43 mt. Draft =9.5 > 12.5 mt. Cap.=140,000.-m3 . Gross tonnage= 95,000.-mt

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The usual design and associated approvals, incl. the environmental ones, followed by construction with floating equipment , suffering delays during alternative ship movements, related to the FreePort , will take 2 years or more , depending on the complexity of the superstructure installations to receive the Shuttle carrier in Berth and provide facilities for pumping the – 263 C liquid into the Storage vessel as well as from the Storage Vessel via a Pipe bridge to the regasification plant onshore. Furthermore due consideration must be given to the safety areas in the mouth of the bay and the bay itself when the Shuttle Carrier enters the Bay , using a protected approach- and navigation Channel as well as a safe turning bay for the Shuttle to turn 180 degrees, inside the Marsaxxlokk bay and above all requiring a very large safe area during actual transfer of LNG from Carrier to Storage vessel. The consequential constraints for other shipping movements arriving and departing in and from the bay such as Container vessels , Oil Tankers , Fishing vessels etc will cause costly delays and Demurrage charges . Depending on the final decision of location of permanent Berth/Wharf and the associated Approach Channel with Turning bay at the landward end, it could be that dredging works will be required with the associated problems of installation of silt curtains to stop the turbidity and consequential compensation to the municipalities surrounding the Bay. I therefore do not at all favour the fixed permanent Terminal and if the Pipeline solution will not be adopted, would certainly recommend a FSRU solution but outside the bay in open sea with ample space and with the FSRU moored on a particular type of SBM ( = Single Buoy Mooring which allows the FSRU and Carrier Shuttle , connected in tandem , to rotate with the wind,) see the pic’s in the attachment. A SBM is a complete prefabricated mooring, anchored to the seabed complete with a rotary mooring head allowing flexible pipeline coupling with the FSRU. It is important to apply a “complete” FSRU , incl. a re-gassification plant on board piping actual gas (1380 m3 for every mt. of LNG) to the shorebased storage tanks in order to concentrate the risks in one particular area. Also the FSRU is a completely prefabricated vessel which requires a very limited time of hooking up to the SBM and complete commissioning.

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The FSRU option, is very flexible , as the FSRU (chartered or rented) itself can be replaced as well as the LNG suppliers. Further advantages : avoidance of investment, reduction/elimination of construction time (FSRU – fully operationally pre-fabricated). No land area requirements – vessel berthing, cryogenic, explosion proof storage, regasification factory , etc. The current concept to build the regasification onshore will require a very special protected and insulated ( -263 ‘ F) fixed pipeline construction between the wharf head where the Storage vessel is moored and the plant area ashore with all it’s inherent risks incl the dreaded gas clouds in case of an accident of sorts. . 2. – This related to the design and construction of a Cryogenic Tank Farm – now not considered 3. I have attached above the pdf with a Report on a FSRU floating terminal , provided by my ex-colleagues at < MUC , Oil and Gas Engineering Consultancy> engineering in Holland and who are engineering a new LNG Terminal in Fujairah. My ex-colleague Gert-Jan Roelevink of MUC Fujairah also presented an english language summary of a FSRU feasibility study in the Adriatic Sea (see yellow marked text above) to prove such floating terminal in the Med to be feasible from a wave activity point of view. > > > 4. > - Sustain offloading in 1/1-year storm event, Hs 3.8m >> en Tp 9.9 sec, ok >> >> - Survive 1/100-year storm event, Hs 7.2m en Tp 12.7 sec, ok Such wave hight never occurred in the Maltese waters >> >> - Gert-Jan Roelevink M.Sc. Currently in Fujairah – construction new >> LNG Terminal >> >- Maritime Project Manager > Description: logoMUCMUC Engineering As for some orientation regarding FSRU vessels > see the following website. >1. The proper website :www.hoeghlng.com > > 2. Type in (Internet Explorer) “Three New FSRU Vessels” and the site will open at a location of the HOEGH site (Norwegian Engineering Co.) with a page titled “Four

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New Regasification Vessels etc etc ) ADDENDUM : A separate reference : Seminar , organised by MEUSAC on 240114 @ Hotel The Waterfront , Sliema , titled “Europe from Crisis to Recovery”, subtitled: “National targets for Energy within the Europe 2020 Strategy” Prominent Speakers at this Seminar : Ing. Sandro Lauri & Ing. Simon Scicluna. One of the subjects appearing in the various option comparisons for NG supply for Malta in general and the Delimara Power stations in particular, was the gas pipeline (from Gela to Malta) . As I mentioned in the text of my “Objection” the pipeline option is , in my opinion, technically the safest and in the long run the most economical solution, (provided the Italians are kept under control) , compared with the other 2 options (FSU inside and FSRU outside the bay) . If the FSRU option will be selected , the financial exposure is limited as FSRU’s can be rented or leased (from a World wide Market) for a determined period of time. The same applies for the LNG supplier and it’s Shuttle carriers. LNG , like Oil or Electric Power can be purchased on a Global (oil) or a European (Electric Power) - Spot Market. Ing Scicluna suggested in his comments that the pipeline option and it’s implementation would take up to 7 years. This could be true if political/commercial disagreements will slow down the program. A major supplier , for example ENI , would finance the pipeline under a long term supply contract and design and lay this pipe within 3 years , since pipelaying is much easier compared to the super high voltage Inter Connector, (which should be laid as a matter of extreme urgency – for obvious reasons). Hereby my additional reason for objection to the FSU based LNG supply system. If Malta adopts the far more risky (compared to the other 2 options) FSU option ,considerable investments (for fixed assets) have to be absorbed in terms of major civil engineering structures ,(possibly complemented with substantial Dredging Works), forming the marine terminal to accommodate the FSU as well as the Shuttle Carrier as well as the pipe bridge to feed the re-gasifigation plant onshore. Now if Petro-Gas economists prove the optimum economy (as well as the lowest risk profile) for a gas pipeline connection with

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Sicily , the heavy burden of depreciation of an un-used FSU based Marine Terminal and it’s appendages in Marsaxlokk Bay may well stand in the way of implementing the Best Solution for Malta ... This conclusion should lead to the most logical approach , in my opinion , for the implementation of the next 200 MW LNG/NG fired Power Plant : 1. Complete the 200 MW cap. Interconnector as a matter of great urgency in order to feed Malta with max 200MW from the European , especially from the Dutch (current vast oversupply) spotmarket, and above all to reduce the Plan-Process and Program pressure from the new 200MW LNG/NG Power Plant. 2. Enter in Contracts for the 200 MW LNG/NG – fired , Combined Cycle Power Plant . 3. Enter in LNG Supply Contracts through “a limited risk” FSRU option : Off Shore and on a rental or lease basis of the FSRU. 4. Replace the FSRU option with the completion of a pipeline connection (the safest option) to feed Malta . rd

G. Environmental Health Directorate (EHD – Email dated 3 February 2014) Comments Please note that following review of the EIS Update submitted regarding subject indicated in caption, this Directorate would like to submit the following comments/recommendations regarding this proposed development : The EHD is still concerned about the health effects and amount of nuisance from passing heavy plant vehicles (cranes, trucks, and so on) to and from plant during construction expected to last 18 months. The terms of reference, para 1.2.4 “Access, transportation and related infrastructure required “A forecast of the type, quantity and size of vehicles (and/or vessels) envisaged during each phase and their respective frequency of use, as well as an identification of the routes that vehicles will use to/from and within the site. The required arrangements should also be compared with the relevant existing situation (in terms of structural considerations, stability and state of roads, road width and gradient, turning circles and junctions, type of surfacing, and other physical or environmental constraints, etc). Interventions that would need to be carried out to accommodate the required vehicles (e.g. new or altered access roads”. EHD recommends that the TOR Para 1.2.4 (quoted above) be respected and for

ERSLI Responses (1) Chapter 5 of the Coordinated Assessment Report of the EIS includes a detailed framework for the preparation of a detailed CMP with a strong environmental management chapter. The issues referred to by the Directorate would be discussed in the CMP. It should also be noted that impacts during construction works are of a temporary nature and should be weighed against the long term benefits of the project.

EPD Comments Noted.

(2) The impacts during construction works will be temporary, while one should keep in mind that the new LNG trips will replace the ones which currently transport HFO to the DPS. (3) The points made by EHD are taken, and as stated above, these comments (like all comments made with respect to the EIS) will form an integral part of the

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interventions/mitigation measures during the construction phase to be detailed and carried out during actual construction period with the aim of reducing effects from the increased heavy vehicle traffic on sensitive receptors namely residents along the route to be taken by construction vehicles during the construction period. The EHD is also concerned about possible increase in emissions from maritime transport both during the construction and operational phase. EHD acknowledges that a significant amount of shipping is present in Marsaxlokk bay to service the Freeport and that LNG shipments to the site will be less frequent then present HFO shipments. However, the LNG re supply tankers may however be considerably larger than the oil tankers which currently serve the site. EHD recommends the long term monitoring of noise emitted from all operations so that measures can be taken to mitigate any excess noise. This can be a condition in the IPPC. With regards to the proposed cement batching plant, all measures must be taken to prevent dispersal of dusts and particulate matter from the site. General All mitigation measures to address any sources of air pollution, noise, odours, vibrations and deterioration of water quality especially in bathing areas should be enforced. Appropriate monitoring and complaints handling must be established.

documentation produced during this EIA process.

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H. Birżebbuġa Environmental Action Group – BEAG (Letter dated 3 February 2014) Comments Remarks on EIS as presented on December 2013 Degasification area: 3348sq mt allocated. Footprint 995 sqm waste of land please explain? CCGT (Combined Cycle Gas Turbines) area 12,000 sqm allocated. Footprint 3,000 sqm waste of land please? Addition gas turbine, 2 plus steam turbine from original. The fact that the new EIS refers to the FSU with capacity of 125,000 cu mt means that the mother ship will call at the LNG terminal 12 times/annum. NOx reading 30mg/m3 or 291 tonnes or 0.8 tonnes daily.

ERSLI Responses (1) As stated in different parts of the Coordinated Assessment Report, in this EIA it was assumed, for the purpose of this application, that the Ħas Saptan Dolphin will remain in place. ElectroGas have indicated that the presence of the dophin in its current location would not affect their operations.

EPD Comments Noted.

(2) The ZVI map and the VP6 photomontage are more than sufficient indicators of the visual impact of the proposed development on Birżebbuġa receptors. More montages would simply have shown more of the same.

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It must be guaranteed that the ISO 14001 will be certified and not to standards. Upper tier SEVESO/COMAH it must be guaranteed that on shore installation will be up to 5 magnitude seismic safety. App Vol 7 QRA 2.6 the dolphin is omitted so is Has-Saptan whereas before it was stated that the dolphin will have to be reallocated. Now the dolphin effects are not taken into consideration. The use of 3 loading arms may be a better solution that the cheap 5 flexible hoses. Besides flexible hoses are liable to break because of extreme temperature causing leaks. TM commented on simulations but referred to further studies particularly nautical effects. Recommend that a nautical and harbour risk assessment is required. Capt. David Bugeja. Roll over phenomena which can happen when LNG separates with the consequence that heavy gas floats on top of other gases causing roll-over. Hazid may have the domino effect caused by collision, accidents, extreme meteorological conditions and ship approach further later on. Visual impact: Dr. Elizabeth Conrad reported that six viewpoints were assessed, after consultation with MEPA. These viewpoints were five at Marsaxlokk while only one viewpoint from Birzebbuga. We strongly believe that this maneuver was a concerted based effort to lessen the cumulative negative visual effects that the proposed development would have on Birzebbuga population. As may be confirmed from Fig. 3.3 location of viewpoints, the proposed development including, amongst others the FSU, a new fixed landmark to the Birzebbuga residents. Black ship montage indicated with high cumulative visual impact. This can be clearly visible from Birzebbuga suburbs with high cumulative visual impact. This can be clearly visible from Birzebbuga suburbs with high density population such as Qajjenza Housing Estate, St. Georges Bay area, Secret Heart Promenade, and Pretty Bay Areas, Wied ilBuni and St. Patrick Promenade and finally Tal-Papa Housing Estate with high topography.

(3) The points made by BEAGare taken, and as stated above, these comments (like all comments made with respect to the EIS) will form an integral part of the documentation produced during this EIA process. (4) The recommendations for compensation focused on the needs of the Marsaxlokk population. This does not mean that the Birżebbuġa population should not ask for their share of compensatory measures. (5) There is no directive which regulates cumulative visual impact. (6) The points made by BEAG are taken, and as stated above, these comments (like all comments made with respect to the EIS) will form an integral part of the documentation produced during this EIA process. (7) The noise maps in the Coordinated Assessment Report and in the noise assessment report in Appendix Two [of the EIS] indicate otherwise. One should keep in mind that the EIS is solely concerned with the effects from Delimara and the proposed development. (8) Refer to the response to the previous comment. The noise assessment report and addendum, and the noise maps, should be read in more depth. (9) Refer to the noise maps in the Coordinated Assessment Report and in the noise assessment report/addendum in Appendix Two of the EIS. Most of the noise levels contributed by the DPS are well below the levels mentioned in the

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We regret to note that the cumulative negative visual impact on the residents of Birzebbuga such as the Freeport – DPS – the FSU (floating storage unit) – other fuel supply boats frequently visible. Similarly for some reasons Table 4.8 of the report page 66 item 4, indicated wrongly (Moderate Sensitivity) on the Birżebbuġia sea front, amongst the identified Landscape impacts of the development. Again in Chapter 5 of the report Recommendation and Conclusion refers to the rehabilitation and restoration of open spaces. We ask therefore what are the Recommendation and Conclusion on the residents of Birżebbuġia. We could not find any reference. Reference is here being made to the EU Directive with regards to the cumulative visual impact. Adding to the already negative visual impact to the residents of Birżebbuġia goes against such Directive. Best place for the FSU is outside Marsaxlokk Bay as jointly agreed by the Birżebbuġia and Marsaxlokk Local Council. Taking into consideration other negative effects. Noise Report :- by Julian Mamo and John P. Cachia Long term monitoring should be the order of the day. In view of the information initially supplied by the successful bidder that the new plant is very likely to be noisy. The fact that instead of one, we are now going to have three gas turbines and one steam turbine, the noise level will be extremely high. 3.3 indicates the health problems which may be caused by noise pollution. How can one say that the noise pollution will have a negligible increase and within EU health limits in 2015 scenario, when the onshore and offshore noise levels will be on the increase. EU Directive 2002/49/EC. Exposure to more than 65 dB (A) should be phased out and at no time should be exceeded. Those exposed to levels of between 65 – 55 dB(A) and those currently exposed to less than 55dB(A) should not suffer any increase. WHO Night Noise Guidelines for Europe (2009) No further increase in the long term noise levels should be accepted to this

comment. Furthermore, the area under consideration does not fall under this directive. For that to happen, all the fields from Marsaxlokk to Birżebbuġa would have to be built in the next two years; an unlikely scenario at present. (10) Refer to the response to the previous comment. The noise assessment report and addendum, and the noise maps, should be read in more depth. (11) A monitoring programme is proposed in Chapter 5 of the Coordinated Assessment Report. The expected changes would not reach Birżebbuġa. (12) The population data in the EIS is accurate as it is based on the most recent information available in NSO documents. It is clear from the maps in the QRA that Birżebbuġa is out of range of the type of incidents that are examined in the same QRA. (13) The social impact assessment was not meant to discuss health issues. This was the function of the health impact assessment – which indicates that the shift to gas should have positive health impacts. The points made by BEAG are taken, and as stated above, these comments (like all comments made with respect to the EIS) will form an integral part of the documentation produced during this EIA process. (14) The DPS was included in all the evaluated scenarios. (15) The number of calls is expected to be between 8 and 12 per year depending on demand. No dredging will be needed for this project.

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industrial source only that is the levels under consideration solely from Delimara Power Stations boundary vis-à-vis Marsaxlokk and its environs. It is being proposed that a monitoring program is established, pre and post installation. This is being advised to help deduct any particular changes especially to nigh time level in the area of Marsaxlokk. We insist that Birżebbuġia should be included in all the monitoring stages, where possible at first floor level where the bedrooms are. When one consider the bidder recommendation presented by Fig 4 App 221 which correspond well with fig 6 and 7 while Fig 4 Model of Area of Concern page 23. includes Qajjenza. Wind direction which favors Birżebbuġia direction as the crow flies and considering that the surface water amplifies noise levels. As already said in other reports Birżebbuġia must be considered in the noise monitoring pre and post construction. This will have an effect on the accumulative noise levels particularly at night depending on prevailing conditions. Area identified in the visual report i.e. Qajjenza Housing Estate, St. Georges Bay area, Sacred Heart Promenade and Pretty Bay Areas, Wied il-Buni and St. Patrick Promenade and finally Tal-Papa Housing Estate with high topography. Please quote standards for noise monitoring as scheduled down in Noise Addendum pages 18/19. One must keep in mind that the contractor noted that the new installation is very noisy. Mitigation measures, silencers and under cover. IPPC must consider noise effects very seriously. We confidently say that most personnel at Mepa are still there using the same excuses, and reasoning without ever be honest but follow Government instructions. Mepa, is an Independent Authority and must act to all mitigating measures quoted in the EIS. Environment Survey Report. Roberto Vaccari;Enemalta, will contract The Construction Phase. Gas Power Stations are defined as Upper Tier to COMAH regulations that implement the Seveso Directive as amended by Directive 2003/105/EC and Local Notices LN37 of 2003 and LN/6 of 2005. The competent authorities in Malta are OHSA – MEPA – CPD. QRa is to compare risk level to the ElectroGas Malta Consortium

The points made by BEAG are taken, and as stated above, these comments (like all comments made with respect to the EIS) will form an integral part of the documentation produced during this EIA process. (16) Natural Gas operations do not release sulphur or sulphur compounds into the environment. All the environmental information discovered during the EIA process has been submitted in the EIS. The water temperature will not be reduced, as the amounts of seawater utilised for the heating up of the LNG is minimal, would never in direct contact with the LNG due to the proposed closed loop system and the cooler water is utilised as cooling water for the CCGT plant to optimise efficiency. (17) It should be stressed that the proposed CCGT will be replacing DPS 1 and that DPS 2A and 2B will not be used on a regular basis. The former has been earmarked for temporary use in cases of emergency and the latter as a backup (also temporarily). (18) This issue can only be addressed by the Government. (19) QRA Report includes an Annex with a comparison between arms and hoses, and the conclusion is that last generation of hoses specifically dedicated to LNG are safer than arms. ANNEX C: 'Requirement for use of the frequency and calculation of hardarms and hoses scenarios'. (20) Reference is made to the response in row 10 (on page 4). (21) Roll over phenomenon is prevented by analysis of LNG unloaded and proper storage.

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data. OHSA requested additional QRA (cumulative risk assessment) on Hazard ID study, Hard Arms and Hoses scenario, Risk criteria acceptance in other EU countries and Calculation Output. We ask, why OHSA had to ask for further studies?, why not IPPC, Mepa? Scenario;- Almost plan B but as a whole B. FSU and mother ship supply offshore. Turbines and regasification plant onshore. Capacity of FSU reduced to 125,000 m3 . Meaning that the LNG tanker will call 10/12 times annually. Transfer of LNG from supply ship to FSU is highly dangerous and must be monitored by experts. QRF (quantitative risk assessment) four liquid and one vapour hoses as recommended by ElectroGas are responsible to frequent failure. Position of FSU is safer as reallocated. Our suggestion is still the same. FSU will be safer on the other side of the peninsula or anchored some 30 nautical miles at Hurds bank. Please identify UTM, not in Glossary. LNG has high safety records compared to refineries, and petro chemical plants. Yet it is reported that LNG vapour releases and miner fires and explosions have been reported. That fact is that LNG, unless handled properly by Enemalta employees and administered sensitively and with cautiously, it could be fatal due to nature of the substance and behaviour. Another reason why the FSU should be outside the harbour. Ref to Table 10:- huge difference in atmospheric boiling point between the three elements. Noticeable difference in vapour density. Variances between elements reported in the upper flammable unit. Considerable flash point and auto ignition difference. Use of mobile phones, the commonest way of communication can, ignites LNG vapors. Besides all three gases are cryogenic particularly to the lungs and can cause other body hazards. It can also have fracture effects to metal and concrete. Raped change Transitions, Bleve, use of mercaptan are not considered as QRA yet,

(22) Universal Transverse Mercator. (23) the nature and behaviour of the substance itself must not be a reason enough to discard a project, without taking into consideration the engineering efforts for a safer world. (24) Use of mobile phone would be restricted within the fence and close to the FSU. LNG can cause cold burn if touched or spilled on the body. This hazard is strictly for plant personnel, trained and prepared (always wearing gloves when taking samples). material used for the construction must able to stand the cryogenic temperature when in contact with LNG. (25) RPT and BLEVE are phenomena with a very low probability, which can be completely removed from the facilities if properly designed and managed. Use of mercaptan is not an hazard, in fact can be introduced for safety reasons in order to make natural gas detectable by smelling, as propane gas. (26) Birżebbuġa is out of any contour studied in the QRA report. (27) Wind speed and direction are mentioned in the report and have been provided by official meteorological service. Distances presented are according to low wind speed for any possible direction, thus are presented for the worst meteorological condition. (28) Safety distance between third ship and moored LNG would be set as a result of the marine risk assessment. (29) Detailed HAZOP, LOPA and

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still the negative effects are not considered in this chapter. Vulnerable Targets:- Population zones, Birżebbuġia is not considered in the study. We ar hereby giving calculated distance from proposed FSU tanker. To note these remarks and calculations. :Red refers to Birżebbuġia Kavalerizza Marsaxlokk is 1.5km Malta Freeport 1.25km Qajjenza 1.8km Marsaxlokk 1.6km Birżebbuġia 1.8km A closest resident to FSU is the family across the road from Fourth St. Lucian, closer still than the residents at Kavalerizza. The population of Marsaxlokk is 3277 as per last survey. The population of Birżebbuġia is 997 as per last survey. Population per Sq Kilometer. Marsaxlokk 690/Km2 Birżebbuġia 1100/Km2 Area Marsaxlokk 4.7Km 2 Birżebbuġia 9.2Km2 The report has the following misleading defects:Population at Marsaxlokk see above quoted 3,000. Population at Birżebbuġia see above quoted 8,800. Distance we are quoting is from FSU not DPS as a whole see above. Other considerations:- Workers at Malta Freeport Terminals were not considered even though they are closest to FSU. Wind speed and direction are not mentioned in the report. Distances quoted may vary according to wind speed and direction. If this is not in the Mepa TOR than the expert should have requested further investigations, more so when the expert is a non resident in Malta. Specialised software can only give actual results if data input is correct, garbage in = garbage out

SIL are carried out for any LNG project in further stages of the engineering. Complete domino effect should be taken into account from a general perspective for the whole port area and leaded by the port authority or MEPA. (30) Use of mercaptan is not a hazard, in fact can be introduced for safety reasons in order to make natural gas detectable by smelling, as propane gas. Mercaptan must be added after regasification takes place. QRA Report includes an Annex with a comparison between arms and hoses, and the conclusion is that last generation of hoses specifically dedicated to LNG are safer than arms. (31) No toxicity in the LNG or natural gas. BLEVE are phenomena with a very low probability, which can be completely removed from the facilities if properly designed and managed. Suggested position of the FSU in the QRA report, for obvious reasons, should be agreed by nautical experts, SGS has not been requested to assess this project from a nautical point of view. (32) Any possible domino effect must be prevented by introduction of Emergency shutdown systems, gas detection, firefighting system, etc. Recommendation would be present in the further studies, based on detailed layout.

Quantitative Risk Assessment QRA If all figures are wrong that the reported calculations are wrong as well. Variations exceeding 30% affect the result of QRA. For example, Day time Sunday Marsaxlokk population increase by more than 30%.

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Summer time day and night population considered two folds are Birżebbuġia. Working population at Freeport may vary depending on the number of ships calling at FFT. Distance of stand by ships and ships entering the Marsaxlokk Bay were never considered. Major Accidents Scenarios. Process Hazard Analysis techniques must be used such as Hazid & Hazop, these are generally related to the control. It seems that the Domino effect was calculated on the inhouse DPS, FSU and Re Gasification unit. No other elements were taken in consideration such as the Dolphin and MFT ship movements and fisherman going in and out of Marsaxlokk Bay. We strongly object to the FSU being permanently moored to a new jetty. We say this before any moneys is spent on a new jetty, we will block entry of the supply LNG carrier as protest for ignoring or request to moore the FSU outside harbour. Dr. Roberto Vaccari and his expert advice are opting for the cheapest way for FSU. Human error and the domino effect will be reduced to our satisfaction. The safest place for the FSU and Supply ship will be anchored on the Hurds Bank. This will involve laying down of 30 miles pipe line to shore. TN will have the obligation to protect the FSU from other navigations. This has been our suggestions pre EIE No 1. At the public hearing we asked about the mercaptan. Whenwill this substance is added to the LNG. If there is a danger of flexible hoses as suggested by Electrogas to frequent failure with consequences of frequent undidected gas clouds. Is it going to be a normal occurrernce? Please consider table on page 20 SGS on QRS Presentation of Resulting Risk Comparison. EIS does not refer to the addition of mercaptan. We still want to know at what stage is the mercaptan is added to the gas. QRA Preliminary Report The new plant will be an upper tier Major Accident Hazards. New buildings to house units for LNG must be protected against earthquakes. EIA does not state measured that will be taken while construction. TO train personnel working on Delimara 3&4 about the hazards of Flammable LNG vapours. Note Dleimara 3 after the gas conversion. Residential targert misleading

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due to lower population calculated. Domino Effect Chapter 9.1 Please identify Toxicv Release and Other Hazardoud release. Gas explosion is said to be rear, yet it is quoted that deflagration mode is most common due to the subsonic speed. All these can createBleve, whereas Dr. Vaccari said that there is question of bleve at the public hearing, please clarify. Again like all experts involved in the EIA, Dr. Vaccari put the benefit of the doubt on the Contractor, see Conclusions Chapetr 12. Dr Vaccari also state that the suggest position may not be suitable from the nautical point of view and recommends a nautical risk assessment on. Another recommendation is that HazID are expected to be studied and applied. All these covers the responsibility of Dr. Vaccari in a way as in a case of an accident, he would not be blamed for he has instructed suggestions. Please note Annex A HazID – Layout = possible collision or domino effect in case of accident. Same Annex A, when referred to domino effects no safeguards are given and no recommendations given. Health Impact The Health impact is not included in the summary of impacts (Vol 5) It’s a must to keep rigid standards. As recommended Enemalta or the contractor must conduct an objective and routine monitoring on land, sea and air parameters followed by an independent follow up assessment Social Impact identified the negative effects that may cause health hazards to residents close to the plant. The benefit is the population at large who can stand to gain socio economic improvements on the generation of power. We ask to put a price on the negative issues related to the Marsaxlokk, Zejtun, Birzebbugia residents. World Bank guidelines addresses environment and HSH. Fig 3.1.1 shows a scenario of major pollutants such as Marsa PS, Airport and Freeport facilities. The DPS is not included in the scenario, Why? Let’s not forget that DPS2A will stand by and DPS2B is classed as reserve power generation, both not running on LNG. Frequency of use these can as is to day release toxic gases and PM2.5 and PM10. Shut down of MPS and DPS1 will contribute to much clean air, a positive effect

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for a change. Table 1 Summary of expected changes:- no change in short and long term pollution. As for Noise, we completely disagree, as all three LNG turbines are quote extremely noisey and open to air. Water surface amplifies noise levels and this must be taken into consideration for both Marsaxlokk and Birżebbuġia residents depending on the wind direction. 3.4.1. Please correct number of calls at DPS from six to twelve. Current presence of heavy metals in the bay has to be detected with carcinogenic effects. Dredging the bay will cause these metals to re surface with huge consequences. Quickest solution is to declare bay as no swim area. Cadmium, Chromium and Mercury are present in the bay to-day caused directly by DPS. This has a value on social impact and must be calculated in remuneration. Please consider the last paragraph of 3.4.2 ASOP. 3.4.5. Effluent release: are we to finish with freezing water release instead of + 8° above sea temperature. One must consider the LNG is -1650. An increase of sulphuric acid and biocaf (please define biocaf) is in small amounts, yet it is recommended further investigation from a health perspective. Is there something which we are no coshious about, hidden or unknown. We do not agree that the sea water effluent used to cool machinery and treat gas temperature will be the same as to day, there must be an increase of effluents. Due to the vast volume of water release, treatment of effluent is impossible. Request investigation to study best remedial solution. Recommendation for monitoring outflow and inlet waters for heavy metals being released at il-Hofra Iz-Zgħira at a rate of 43,000m3/hr. General 1 Request cumulative study on visual and noise effects. 2 Monitor constantly various recommendations listed above. Extreme effective training of personnel. 3 Real time monitor at Marsaxlokk of all possible pollutants covering three directions, East, South and South West of Marsaxlokk. 4 Fire fighting station to move from Hal Far to DPS vicinity. 5 Conduct nautical risk assessment as recommended by consultants and Capt

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David Bugeja. 6 Immediate application for ISO 140001 7 Study possibility of FSU being anchored outside, not considering cost value but major accident scenarios, noise and visual effects. 8 Consider EU directive 2002/49/EC dedicated to noise effects more than 55 dB9A0. 9 WHO, night noise guidelines for Europe 2009. No further increase in the long run noise levels should be accepted to industrial source only. Levels under consideration are DPS and MFT and its environs. Request post operation, regular noise monitoring at façade, 4 meters high (bed rooms level) above ground (not sea) levels where possible. 10 More regular consultation with Local Councils and NGOs involved. 11 Consider abdicate planning gain in a form of percentage reduction in power bills. Presented by advisers of the Birżebbuġia Environment Action Group.

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APPENDIX V: Minutes of Public Hearing dated 27th January 2014

Meeting

EIA Public Consultation for EIS in relation to the following development permit applications: -

PA 00021/14 – Combined cycle gas turbine and liquefied natural gas receiving storage, and re-gasification facilities. Site at Delimara Power Station, Triq il-Power Station, Marsaxlokk

-

PA 00022/14 – Construction of jetty and ancillary facilities. Site at Delimara Power Station, Triq il-Power Station, Marsaxlokk th

Date

27 January 2014

Duration

Circa: 16.15 – 19.15 hrs

Location

Skola Primarja St. Thomas Moore, Marsaxlokk

EPD representatives

Perit Vincent Cassar (Chairperson); Mr. Alex Camilleri (Unit Manager – Environmental Assessment Unit)

Minutes taken by

Charmaine Zerafa (EPD)

Perit Vincent Cassar opened the meeting giving details about the proposed developments which are currently subject to the EIS (PA 00021/14 – Combined cycle gas turbine and liquified natural gas receiving storage, and re-gasification facilities. Site at Delimara Power Station, Triq il-Power Station, Marsaxlokk, Malta; PA 00022/14 – Construction of jetty and ancillary facilities. Site at Delimara Power Station, Triq il-Power Station, Marsaxlokk, Malta). Details vis-à-vis the purpose of the meeting were provided, in particular that the meeting was part of the EIA process. It was also clarified that this was not the decision-taking meeting but was being held to present the EIS findings and to gather feedback from the public in due time for any relevant considerations to be factored in during the process. Dr Paul Gauci (ERSLI Consultants Ltd.) delivered a presentation explaining the studies carried out as part of the EIS. Perit Vincent Cassar opened the floor for comments after the presentation. Perit Edric Micallef (Marsaxlokk Local Council - Mayor) Perit Micallef explained that as a Local Council they are representing the residents of the area and their top priority is the safety and health of the community. Other important issues the Local Council wanted to raise are related to the visual and noise impacts, amongst others. Perit Micallef stated that if one considers this application as a stand-alone project, the result would be an increase in pollution levels. However, when viewed holistically within the whole context, the net result would be the entire power station complex working on natural gas and thus the benefit of phasing out the use of heavy fuel oils. He further commented that the Local Council, with the help of experts, submitted a report with several comments, including on the methodology used for the compilation of the risk assessment. He also outlined that in this same risk assessment one finds buffer zones indicating the areas which will be affected by this project but these do not take into consideration the fact that fishermen have no other choice but to go through these indicated high-risk zones to enter the port. Residents do not want to rely on statistics but to eliminate completely any risk factors. The Local Council is also of the opinion that this project could have been proposed in a different way in order to be more visually sensible. Perit Micallef noted that one of the studies factored in the EIA is the social impact assessment, which clearly shows that residents are concerned with regards to the positioning of the floating storage unit (FSU) and would prefer if this is located outside the port and that the gas is delivered to the plant through a pipeline. The Local Council’s main priority is to have the storage unit outside the port so as to protect residents, but should this not be feasible for the time being, one should consider other mitigation measures to minimise the visual impact such as dredging underneath to decrease the height of the unit and different choice of colours to be more coherent with the surroundings. It is of utmost importance that the infrastructure is duly planned to allow for future modifications and further improvements.

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Ing. Arthur Ciantar (Consultant for Marsaxlokk Local Council) Ing. Ciantar further commented that the Council does not have any particular objection to the use of gas and due to the fact that they understand that this is a clean fuel. The main issue is the location of the FSU in the port. Reviews of the studies done in relation to wind triggered questions with regard to the reason why statistics from a port in Cartagena (Spain) were used in order to establish the proposed contours for the risk assessment. The results of these studies are not convincing, and therefore the Council is not comfortable with the contours as provided. The fact that the statistics show that there is a probability of one (1) in ten thousand years (10,000) for an accident to occur is not enough. What will be the consequences should an accident take place? In the conclusion of the risk assessment, the consultant stated that should a large accident take place, there will be an impact on the operation of the power station itself. This means that the security of supply is drawn into question. What will be the extent of destruction and fatalities the country will suffer? Ing. Ciantar asked whether impacts of BLEVE (Boiling Liquid Expanding Vapour Explosion) were dealt with in the Environment Impact Statement and, if so, asked to review the results. Hon. Mario Galea, MP. Hon. Galea stated that during the presentation, Perit Gauci noted that the chimney, which will be of a height of thirty (30) metres, will have a very high temperature causing the pollutants to rise. In this regard, Hon. Galea asked whether there will be any circumstances where this might not take place, thereby resulting in pollutants not dispersing sufficiently. He also pointed out that it was also mentioned that there will be an approximate increase of eight (8) to twelve (12) trips a year to have natural gas delivered to the plant. It is not clear as to whether this translates into one trip per month. Hon. Galea further questioned the procedure should maintenance be needed on the FSU. He asked whether this will be carried out in situ or whether the FSU will have to be taken to the dockyard for the necessary repairs. As previously mentioned by Ing. Ciantar, he also asked what will the effects be on adjacent areas and residents should an accident occur. Mr. Stanley Zammit (Birżebbuġa Local Council - Councillor) Mr. Stanley Zammit noted that a harbour and a nautical risk assessment will be carried out after this process and therefore after the commitment for development is made. There are a number of questions that should be raised regarding issues such as the movement of other vessels, impact on the Ħas-Saptan dolphin, impact on movement of vessels in the Freeport and impact on fishermen. He pointed out that lack of information of the same type was considered a show-stopper for a similar project but of a bigger scale in Trieste (Italy). With reference to the social impact assessment, he commented that the same author of this report clarified that the studies had to be carried out within a limited time. This is reflected in some issues not being considered in detail in this study; for example, the effect on the market value of property in nearby localities. The social impact assessment focused more on the effect of the new turbines and on the mechanical aspect of the project and not on the impacts of the FSU which is of major concern to residents in the area. Mr. Zammit also noted that the reports include a statement saying that Enemalta engineers ruled out the option of having the FSU outside the port. Is it possible to know the reasoning behind this decision? The position of the FSU will have an impact on people’s attitude towards the project. Mr. Edwin Ebejer (Birżebbuġa Environment Action Group - BEAG) Mr. Ebejer stated that with regard to the visual impacts from the proposal, the report only tackled six (6) different viewpoints: five (5) from Marsaxlokk and one (1) from Birżebbuġa. The FSU is visible from all surrounding areas, therefore this raises questions as to whether only these viewpoints were taken into consideration in order to minimise the extent of visual impact presented to the public. He continued commenting that the report mentions recommendations and conclusions for the rehabilitation and restoration of open spaces for the surrounding area of Marsaxlokk. It is not clear why Birżebbuġa was not taken into consideration and it is expected that Birżebbuġa residents are given an equal treatment to those of Marsaxlokk. The Freeport already has a significant visual impact on the surrounding areas and such impact should be minimised as much as possible and not intensified with this new project. In this regard, it is being proposed that the FSU should be placed outside the port. Mr. Dominic Azzopardi (Marsaxlokk resident)

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Mr. Azzopardi questioned whether other locations for this power station were taken into consideration in terms of alternatives. He noted that it is not clear as to why Il-Ħofra ż-Żgħira is not being considered as the location of the FSU given that there already is a tunnel connecting this area to the power plant, and which ultimately can be used for the delivery of gas. Mr. Azzopardi questioned whether during the construction period, heavy vehicles will go through roads in residential areas. He suggested that upgrading of certain roads going through adjacent fields can be carried out in order to be able to use such route, with the aim of minimising impacts on residents. He stated that currently, on days with southerly winds, residents are experiencing odour problems especially when the vessel arrives at the port to deliver fuel to the plant and questioned whether such problems will increase with the new proposal. Mr. Azzopardi also raised the question as to whether the stated height of the chimney of thirty (30) metres is being calculated from sea level. Mr. Angelo Micallef (Marsaxlokk Local Council - Councillor) Mr. Angelo Micallef confirmed that as mentioned this project is subject to the Seveso Directive but questioned the full extent of the impacts on Marsaxlokk and Birżebbuġa. Mr. George Camilleri (Din l-Art Ħelwa) Mr. Camilleri stated that Din l-Art Ħelwa is concerned as to whether any studies were carried out with regard to alternative sites for the FSU. He said that while the applicants and the EIA Coordinator are indicating that other alternatives were taken into consideration, it was still not clear whether any actual studies were carried out with regard to such alternatives, and if so he asked to view the reports for said studies. He also stated that in Din l-Art Ħelwa’s opinion the Quantitative Risk Assessment (QRA) was misleading and superficial. Dr. Hans Pasman (Consultant for Din l-Art Ħelwa) Dr. Pasman commented that the methodology used in the risk assessment is conventional, and classical methods do not provide any certainty. He continued stating that the dispersion model used in the Quantitative Risk Assessment (QRA) is for flat terrain and not for a particular topography (e.g. hills). Thus, a highly specialised model would be required, validated specifically for this kind of situation. Dr. Pasman pointed out that the risk of having a collision between vessels coming in the port and the permanently moored storage unit has not been calculated yet. He also noted that there is no clear picture as to the type of risks that the proposal will generate, particularly with all the marine traffic existing in the area. He also continued by suggesting that the tank ship is moored somewhere else far away from the port, with all security aspects being considered. Dr. Therese Comodini Cachia (Former Birżebbuġa resident) Dr. Comodini Cachia said that living in the area causes everyday stress on residents as they are constantly living with fear of possible accidents. She commented that the way this project was designed took into consideration the financial risks but did not give enough consideration to the risks imposed on the residents. Hon. George Pullicino, MP Hon. Pullicino asked whether the Control of Major Accidents Hazards Committee (COMAH), headed by the Operational Health and Safety Authority (OHSA) and of which the Civil Protection Department (CPD) and the Malta Environment and Planning Authority (MEPA) are members, gave their feedback with regards to the proposed development. He continued by asking whether the Quantitive Risk Assessment (QRA) was submitted to the OHSA as the competent authority, and whether the OHSA have commissioned any experts to review and comment on such report. He also enquired who these experts were and whether he could have a copy of this report. He also asked whether other reports were carried out and whether the OHSA or their experts have commented on these reports. Hon. Pullicino also made a request for a copy of any other reports prepared and any respective comments on them. Hon. Pullicino made a query with respect to the status of the process for the determination of consultation zones. He pointed out that no reference to such zones was made in the presentation, even though it is well known that for such projects it is obligatory to determine consultation zones. He asked whether there was a Cost-Benefit Analysis with regards to other options, such as the purchase of energy from other terminals through the interconnector. He pointed out that the National Energy Plan identified that 70% of the

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required energy would be taken through the interconnector and that with this new project, the interconnector will hardly be used since the base demand of the country is of 160MW and the power station will be providing 210MW. He further declared that the statement saying that the LNG plant was included in the Strategic Environment Assessment (SEA) for the BWSC plant is not true and that if one reads the Strategic Environmental Assessment there is a comment stating that should LNG be considered at a later stage, a Strategic Environment Assessment would need to be carried out accordingly. Hon. Pullicino remarked that the current emission levels are below the ceilings set by MEPA and those accepted by the European Union. The fact that such emissions will be minimised further is positive but not the main issue. The main concern with this project is the storage of LNG and the transfer of the same LNG between the storage unit and the plant. Hon. Pullicino additionally commented that when this project was first presented to the public, it was said that the 3 storage of gas would consist of 60,000 cubic meters (m ) but now the value mentioned is that of approximately 3 140,000m . He also questioned whether the option to have the FSU outside the port is being scrapped because of the pre-determined tight timeframes. He continued by asking whether the statements made by the Local Council consultants were true in relation to the fact that the data used for the gas dispersion model is not correct given that such data is not from Malta. Hon. Pullicino further enquired whether the model used assumed flat terrain when this is not the case around the site in question, as observed by Mr. Pasman. He also asked whether a map showing the manouvering of the supply vessel has been prepared. He asked whether an assessment of the risk related to the possibility of accidents on other installations in the vicinity and their effect on this plant was carried out. Hon. Pullicino also pointed out that in the terms of reference it was stated that the Ħas-Saptan dolphin had to be taken into consideration in the compilation of the reports. However, he noted that such studies were not carried out and there is no conclusion as to whether the dolphin, which handles all of Malta’s aviation fuel, has to move and (if yes) to where. Hon. Pullicino continued by pointing out that in the photomontage showing the FSU from viewpoint four (4), a boat is located in front of the FSU thereby obstructing the view. He also commented that it is not clear as to why the regasification unit is not being located on the storage tanker itself considering the higher risks entailed during the transfer if this is done on land. He also stated that no other existing LNG plant has a floating storage unit and is supplied through a ship-to-ship process. He also asked what the impact on the targets of minimisation of carbon dioxide will be when compared to the targets established by Malta. Dr. Anne Fenech (Maritime Lawyer) Dr. Fenech said that her main concern as a maritime lawyer is the fact that a proper maritime impact assessment was not carried out given that the said port harbours a high level of activity including circa two thousand seven hundred (2700) container ships going in the Freeport, fishermen activity and oil tanking. She stated that, first and foremost, the feasibility of having a permanent FSU of such dimensions and a supply vessel approximately twelve times a year together with the already existing marine traffic has to be established. Ms. Josette Micallef (Resident) Ms. Micallef stated that apart from the already mentioned issues, this project will also affect the sports activities that are carried out in this area, such as yachting and the existing waterpolo pitch. Mr. John Grech (Birżebbuġa Environmental Action Group). Mr. John Grech questioned the amount of land that is being wasted due to the fact that in the EIA the site allocated for 2 the Combined Cycle Gas Turbine (CCGT) has a total area of 12,000 square metres (m ) while the footprint is of 3000 2 2 2 m , and for the regasification the allocated site is of 3348 m while the footprint is of 995 m . He also commented that there is a difference between the size of the FSU as presented in the assessment published in August and that presented in the latest assessment submitted in December. In fact, the EIA indicates that the refueling trips have increased from a total of seven (7) trips a year to a trip each month. Mr. Grech continued by commenting that in the first assessment it was mentioned that the dolphin had to be relocated, however in the latest assessment the dolphin is not being taken into consideration. Mr. Grech stated that it is important to obtain the necessary ISO 14001 certification and not just work on the ISO standards. He also noted that the risks with respect to seismic effects were not considered.

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He continued by asking whether LNG and mercaptan will be delivered already mixed, or whether these will be mixed on the FSU or in another location. He also mentioned that the EIA refers to the possibility of separation of three gases, and pointed out that different types of gases have different volumes, thereby causing some gases to rise which might cause a roll-over effect. He also pointed out that the domino effect was calculated only with regard to the impact that the FSU can have on the power station, but it did not consider other situations that can affect the FSU or the power station itself e.g. Oiltanking Malta, Gasco, etc. Mr. Grech also asked about the effects of the proposal on the employees at the Malta Freeport which is only 1.2 km away from the FSU and stated that the calculations with regards to the population and distances are all wrong. He also commented that the studies have to take into consideration the fact that on Sundays the amount of people at Marsaxlokk increases due to the open market and that in summer the population of Birżebbuġa increases due to summer residents. Mr. Grech emphasised that the FSU should be positioned outside the port, for example at Hurd’s Bank or farther away from Delimara to minimise the visual impact and the cumulative effect which will consist of the FSU, the supply ship, the chimneys, the Freeport and other vessels and structures in the area. Mr. Paul Dalli (Marsaxlokk resident) Mr. Dalli commented that the fact that the level of emissions of HFO is acceptable by the European Union does not mean it is acceptable to the residents who encounter daily health problems due to such emissions, particularly respiratory problems. He said that he is in favour of this project if this will help to reduce pollution and provide cleaner air. Mr. Frans Grech (Marsaxlokk resident) Mr. Grech questioned whether any filters were placed in the existing chimneys and how long it took until these were done. He also questioned whether any studies with regard to the possibility of having the storage unit moored outside the port were carried out. Mr. Alfred Falzon (Marsaxlokk resident) Mr. Falzon asked whether the impact assessment took into consideration stakeholders in relation to sporting activities in the area. Hon. Anthony Bezzina, MP. Hon. Bezzina asked about the effect of this project on the issuing of building permits in the area. Furthermore, he also raised the issue of how long it will take to sail the FSU outside the port and what will be the manoeuvring procedure in the eventuality of an accident. He also made a query with respect to the location of the FSU. Dr. Paul Gauci (EIA Coordinator) Dr. Gauci started by making a clarification with respect to his statement related to the stack emissions in relation to the fact that in certain circumstances, the emissions from the stacks may go up more than 30 metres but this does not mean that the system will not have a constant performance. He was referring to certain cycles of the process, for example cycle 1 when the exhaust will be expelled through the by-pass stack which is of 30m. He continued by explaining that although the by-pass chimney stack is thirty (30) metres high, the very high temperatures will make the virtual height of the stack much higher as the emissions will be shot upwards. Thus, he explained that the concentration of pollutants near the chimney will be lower than the levels established in Legal Notice 11 of 2013. With reference to the viewpoints, he further explained that the location of such viewpoints was established in June while the current proposal was finalised in November. He clarified that the Zone of Visual Influence (ZVI) refers to those locations from where a person can see the highest point of the proposed project and that all photomontages were carried out between June and July and were determined according to the proposal at hand at the time. Perit Gauci stated that there were no other reasons which influenced the choice of location of the viewpoints and that these clearly show that the proposal and the FSU will be clearly visible from surrounding areas. Dr. Gauci explained that research with regard to the environmental performance of natural gas was carried out, including information derived from the US Department of Energy web portal. The results showed that natural gas generates 28% less carbon dioxide (CO2) emissions than diesel and 33% less CO2 than HFO. He explained that the impact of CO2 emissions on the environment is not local but causes the greenhouse effect. Thus, the CO2 generated here in Malta has the same effect as that generated in some other country should we opt to buy energy from somewhere else. He further explained that one of the main focuses of the EIA was the issue of hazardous local pollutants and not the targets established by the country. He also added that the information given indicates that we are close to these targets.

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Dr. Gauci continued by explaining that the social impact assessment was not requested by MEPA as part of the EIS, and that the TORs only requested the assessment of impacts on human populations. The decision taken by the EIA Coordinator and the applicant was to compile a Health Impact Assessment and a Social Impact Assessment, which led to public consultations initiated in June so as to avoid having to wait for the official public hearing to have comments from the public. Mr. David Galea (Project Coordinator) Mr. Galea explained that as indicated in the presentation given by Dr. Gauci, the levels of PM10 will decrease by almost 90%, which is a drastic improvement since these type of emissions are the ones which cause health problems. Mr. Galea continued by saying that from the comments raised by residents, it was noted that the main issue is the location of the FSU in the port and the risks attributed to this scenario. He stated that different options were considered for the location of the FSU and that these were analysed taking into consideration criteria and objectives that needed to be adhered to. Some issues encountered were safety, security of supply, financial issues and issues related to timeframes. He declared that in the context of these objectives, the result was that it would be difficult to have the FSU outside the port especially due to the issue of security of supply due to bad weather. Mr. Roberto Vaccari (QRA expert) Mr. Vaccari stated that the results obtained in the risk assessment were based on internationally recognised methodologies and guidelines, produced in countries like the United Kingdom and the Netherlands. He explained that if comparisons with similar studies in other countries are done, one can notice that the distances that are being proposed for this project are similar to those calculated for similar plants in Europe which are of a larger scale and which manage greater quantities of LNG. He explained that the QRA is a preliminary assessment due to the fact that at this stage it is only being used as a reference for land use planning, in order to understand whether the project fits in the area proposed; and to have a first calculation of the risks that can be endured for each installation in the area. The preliminary QRA presented with the EIS is based on the worst case scenarios and thus takes into consideration scenarios of accidents without any type of safeguards. Mr. Vaccari stated that the QRA included one scenario with regard to different ships manoeuvring in the area and that they are asking for a more complete nautical risk assessment. He clarified that such risk assessment is not being requested to understand whether there is the possibility to have a larger area affected by a collision of two ships but to understand where exactly to impose limits of speed and movement of ships in the area. Mr. Vaccari also explained that the domino effect and the effect on the Delimara Power Station itself were included in the assessment. In fact it was concluded that the Delimara Power Station could be an ignition point itself, hence the choice of putting the jetty in the middle of the bay to be as far away as possible from the power station. He continued by saying that should there be an accident and the gas cloud reached the power station, the cloud can be ignited by the same power station. He confirmed that the weather conditions referred to in the report were all taken from Malta and from the surrounding areas of Marsaxlokk. He also noted that the BLEVE report is of relevance for LPG plants and not for LNG plants as in this case, and that in these circumstances such report would not provide a realistic scenario. Perit Peter Zammit (Project Architect) Perit Zammit explained that the IPPC process will go into more detail with regard to the operational phase, including the safety measures that will be considered for this plant. Ing. Arthur Ciantar (Consultant for Marsaxlokk Local Council) Ing. Ciantar stated that the way this project is being presented gives the impression that the location of the FSU is definitive and that comments given by residents will not be taken into consideration. Ing. Ciantar commented that there are no other plants that use an offshore FSU due to the high level of risks. He said that a BLEVE report can be carried out on any type of liquid substance even if this is not a flammable one, and in this case having LNG at -160°C surely requires a BLEVE assessment to be carried out in order to further understand the extent of an accident should one take place. Mr. Hans Pasman (Din l-Art Ħelwa consultant) Mr. Pasman commented that, although the dispersion model used might be one that is used internationally, it does not mean that it is necessarily suitable for this particular case. He questioned whether this model has been validated with the use of LNG, as the characteristics of LNG are different from those of chlorine, ammonia and other substances. Mr. Sergio Mallia (Journalist, Public Broadcasting Service - PBS) Mr. Mallia quoted previous MEPA Chairman, Mr. Austin Walker as follows: “The people who disagree with the project (referring to national projects) say we are being used as rubber stamps and the people who agree with the project

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including the government expect MEPA to accept it”. Taking this into consideration, Mr. Mallia asked MEPA and Enemalta to state whether the decision in relation to the positioning of the FSU has already been taken or whether this public consultation will make any difference in the decision-taking process. Perit Vincent Cassar (MEPA Chairman) Perit Cassar confirmed that to date MEPA has not taken any decision on the proposal and that the EIA process is still to be finalised. He explained that once the EIA process is finalised this will then be presented to the MEPA Board which consists of fifteen (15) members who are all free to review all aspects of this project and vote as they deem appropriate. He confirmed that all the comments raised during the public hearing were taken note of and will be forwarded to the consultant for further assessment and review. Mr. Costantino Caruana (Marsaxlokk resident) Mr. Caruana commented that residents of Marsaxlokk are not allowed to gather water in their personal reservoirs and questioned the authorities for such a prohibition. He pointed out that the health and safety of residents is to be given priority in this project. He also remarked that there is lack of lighting along the Marsaxlokk promenade.

Perit Cassar closed the meeting by confirming that the points raised have been recorded and noted. He also thanked the participants and invited them to send any further comments, preferably by email to [email protected], or by post to ‘The Director, Environment Protection Directorate, MEPA Head Offices, St Francis Ravelin, Floriana’, by rd Monday 3 February 2014.

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