attachment 1 – ea amendment application form · (a) attachment 1 – ea amendment application...

26 August 2020

Team Leader, Energy, Extractive and South West Queensland Compliance Department of Environment and Science Level 7, 400 George Street BRISBANE QLD 4000

Santos Ref: EQ20-12 3310-GLNG-5-8.7-0318

Dear

Application to Amend Environmental Authority EPPG00712213

Santos GLNG Pty Ltd, Total GLNG Australia, KGLNG Liquefaction Pty Ltd and PAPL (Downstream) Pty Limited encloses an application to amend the GLNG Liquefied Natural Gas Facility Environmental Authority EPPG00712213 (EA).

The application has been prepared in accordance with sections 226 and 226A of the Environmental Protection Act 1994 (Qld).

The following information is attached in support of the amendment application: (a) Attachment 1 – EA Amendment Application Form; and (b) Attachment 2 – Supporting Information. The amendment application has been prepared as a minor amendment. The application fee of $340.90 was paid upon lodgement of the application.

Please contact should you have any questions in relation to the application.

Yours sincerely,

On behalf of GLNG Operations Pty Ltd

mailto:[email protected]

Attachment 1 – EA Amendment Application Form

Attachment 2 – Supporting Information

Attachment 2 - Supporting Information for an Environmental Authority (EA) amendment application Petroleum Facility Licence (PFL) 10 EA (EPPG00712213)

Table of Contents 1.0 Introduction ................................................................................................................................. 1

2.0 Application Description.............................................................................................................. 2

2.1 Flaring Operations .............................................................................................................. 3

2.1.1 Normal Operating Conditions ................................................................................ 4

2.1.2 Planned Maintenance ............................................................................................ 4

2.1.3 Unplanned Flaring Events (GLNG Plant upsets and emergencies) ...................... 5

2.2 Flaring Event Mitigation Measures ..................................................................................... 6

2.2.1 Plant Optimisation .................................................................................................. 6

2.2.2 Flaring Contingency Management Plan ................................................................ 6

2.3 Flare System Monitoring ..................................................................................................... 7

2.4 Operational Alternatives to Current Flaring Regime ........................................................... 8

2.5 Proposed Change to EA EPPG00712213 ........................................................................ 14

2.5.1 Number of flaring events ...................................................................................... 14

2.5.2 Existing conditions/definitions .............................................................................. 15

2.5.3 Proposed conditions/definitions ........................................................................... 15

3.0 Site Description ......................................................................................................................... 18

4.0 Environmental Values and Potential Impacts ........................................................................ 20

4.1 Air ..................................................................................................................................... 20

4.1.1 Background Air Quality ........................................................................................ 20

4.1.2 Sensitive Receptors ............................................................................................. 22

4.1.3 Environmental Values and Quality Objectives (Air) ............................................. 22

4.1.4 Dispersion Modelling Assumptions ...................................................................... 25

4.1.5 Potential Impacts and Mitigation Measures ......................................................... 26

5.0 Legislative Considerations ...................................................................................................... 30

5.1 Environmental Protection Act 1994 (Qld) ......................................................................... 30

5.1.1 Requirements for an EA Amendment Application (s226 and s226A EP Act) ..... 30

5.1.2 CSG Activities Requirements for EA Amendment Applications (s227 EP Act) ... 33

5.1.3 Underground Water Rights - EA Amendment Applications (s227AA EP Act) ..... 34

5.1.4 Assessment Level Decision for Amendment Application (s228 EP Act) ............. 34

5.1.5 The Standard Criteria (EP Act) ............................................................................ 35

5.2 Environmental Protection Regulation 2019 (EP Reg) ...................................................... 38

5.2.1 Environmental Objective Assessment ................................................................. 38

5.2.2 Prescribed matters for particular resource activities (s24AA EP Reg) ................ 39

Santos GLNG l PFL10 EPPG00712213 - Amendment Application l 26 August 2020 Page i

5.2.3 Environmental Protection Policies (EPP) ............................................................ 39

5.2.4 Additional Regulatory Requirements ................................................................... 41

5.3 Environmental Offsets Act 2014 (Qld) .............................................................................. 42

Tables Table 1: Evaluation of alternatives to current operations and flare design ............................................. 9

Table 2. Frequency and duration of flaring events with visible smoke ................................................. 14

Table 3. Background concentrations used in modelling assessment ................................................... 21

Table 4. Environmental values and air quality objectives (Schedule 1of the Environmental Protection (Air) Policy 2019) ................................................................................................................................... 24

Table 5. Relevant ambient air quality objectives and standards for hydrocarbons .............................. 24

Table 6: Requirements EA Amendment Application (s226 and s226A EP Act) ................................... 30

Table 7: Minor Amendment (Threshold) Assessment .......................................................................... 34

Table 8: Standard Criteria (EP Act) ...................................................................................................... 36

Table 9: Schedule 5, Part 3, Table 1- Air .............................................................................................. 38

Table 10: Environmental Protection (Air) Policy 2019 .......................................................................... 40

Figures Figure 1. Site location ........................................................................................................................... 19

Figure 2. Air contaminants monitored at the Gladstone monitoring stations ........................................ 20

Figure 3. Sensitive receptors within a 10km radius of the LNG Plant .................................................. 23

Appendices Appendix A – GLNG Environmental authority visible smoke allowance review, prepared by KBR, dated July 2020’ .............................................................................................................................................. 43

Appendix B – GLNG: Air Quality Assessment of Dry and Wet Flares, prepared by Katestone, dated July 2020 ...................................................................................................................................................... 44

Appendix C - Flaring Contingency Management Plan .......................................................................... 45

Appendix D – Procedure for Recording Flaring Events ........................................................................ 46

Appendix E – QCLNG EA EPPG00711513, Schedule B – Air Emissions ........................................... 47

Appendix F – Proposed Amendment to the Environmental Authority (EPPG00712213) ..................... 48

Santos GLNG l PFL10 EPPG00712213 - Amendment Application l 26 August 2020 Page ii

Abbreviations and Units

Acronym Description

AHD Australian Height Datum

APLNG Australia Pacific Liquefied Natural Gas

BPEM Best Practice Environmental Management

CCTV Closed-circuit television

CEMS Continuous Emissions Monitoring System

CO Carbon Monoxide

CSG Coal Seam Gas

DES Department of Environment and Science, Queensland

EA Environmental Authority

EDV Emergency Depressuring Valve

EGF Enclosed Ground Flare

EIS Environmental Impact Statement

EO Act Environmental Offset Act 2014

EO Reg Environmental Offset Regulation 2014

EPP Air Environmental Protection (Air) Policy 2019

EP Act Environmental Protection Act 1994

GAMSv3 Gladstone Airshed Modelling System Version 3

GHG Greenhouse gas

GLNG Collectively, Santos GLNG Pty Ltd, Total GLNG Australia, KGLNG Liquefaction Pty Ltd and PAPL (Downstream) Pty Limited

LNG Liquefied Natural Gas

MOF Materials offloading facility

MPGF Multi-Point Ground Flare

MW MegaWatt

NO Oxides of Nitrogen

PAH Polycyclic Aromatic Hydrocarbons

PFL Petroleum Facility Licence

PIN Penalty Infringement Notice

PLF Product loading facility

PM2.5 Particulate matter less than 2.5 microns

PM10 Particulate matter less than 10 microns

QCLNG Queensland Curtis Liquefied Natural Gas

SDPWO Act State Development and Public Works Organisation Act 1971

SEIS Supplementary Environmental Impact Statement

SMS Santos Management System

Santos GLNG l PFL10 EPPG00712213 - Amendment Application l 26 August 2020 Page iii

Acronym Description

TCEQ Texas Commission on Environmental Quality

Santos GLNG l PFL10 EPPG00712213 - Amendment Application l 26 August 2020 Page iv

1.0 Introduction Santos GLNG Pty Ltd, TOTAL GLNG Australia, PAPL (Downstream) Pty Limited and KGLNG Liquefaction Pty Ltd (collectively, GLNG) are applying to amend the GLNG Liquefied Natural Gas (LNG) Facility Environmental Authority EPPG00712213 (EA) for Petroleum Facility Licence 10 (PFL 10).

PFL 10 is located on Curtis Island, within the Curtis Island Industry Precinct of the Gladstone State Development Area, Queensland. The LNG Plant comprises of two trains, Train 1 and Train 2 which were commissioned in 2015 and 2016 respectively. The LNG Plant processes coal seam gas to produce LNG.

This application is in response to correspondence received from the Department of Environment and Science (DES) requiring GLNG to apply for an amendment to the EA by 26 August 2020 to address an alleged non-compliance with condition B2 of the EA. This application seeks to amend Schedule B – Air emissions of the EA to expressly authorise the duration and frequency of visible smoke emissions associated with flaring from the LNG Plant during planned and unplanned plant maintenance (start-up/shutdown), plant upsets and plant emergencies.

Pursuant to section 224 of the Environmental Protection Act 1994 (Qld) (EP Act), a holder of an EA may make an application to the assessing authority seeking an amendment to an EA.

GLNG has prepared this document in accordance with sections 226 and 226A of the EP Act and considered the DES ‘Guideline – Application requirements for petroleum activities’ (DES, 2013).

GLNG considers that the proposed amendment satisfies all requirements of the definition of a minor amendment (threshold) (in accordance with section 223 of the EP Act) (refer to Section 5.1.4).

Santos GLNG l PFL 10 EPPG00712213 - Amendment Application l 26 August 2020 Page 1

2.0 Application Description The EA authorises visible smoke and particulate emissions associated with flaring for no more than five minutes in any two hour period during normal operating conditions (condition B18).

B18 Visible smoke and particulate emissions must not be permitted for more than five minutes in any two hour period during normal operating conditions.

‘Normal operating conditions’ is defined in the EA as ‘the ongoing operation of the LNG plant following commissioning and excludes start-up, shut-down, maintenance or calibration of emission monitoring devices’.

The release of visible smoke from the LNG Plant outside of the definitions of condition B18 has been considered to cause an environmental nuisance at a nuisance sensitive or commercial place by DES on two occasions, resulting in the issuing of two separate Penalty Infringement Notices (PIN). PINs for the alleged breach of condition B2 have been received for operations associated with the commissioning of Train 1 in 2015 and major planned maintenance shutdown of Train 1 conducted in 2019.

B2 The release of dust and/or particulate matter resulting from the activities must not cause an environmental nuisance at any nuisance sensitive or commercial place.

Based on the above, it is apparent there is a gap in the EA for visible smoke emissions from flaring generated as part of other types of common plant operational scenarios that are critically important to ongoing plant operations (i.e. outside of ‘normal operating conditions’). These scenarios include flaring associated with plant start-up and shut-down for planned and unplanned plant maintenance, plant upset conditions and in emergency situations.

To rectify this gap, this application seeks to amend Schedule B – Air emissions of the EA to expressly authorise the duration and frequency of visible smoke emissions associated with all operational flaring scenarios at the LNG Plant. This includes visible smoke from flaring associated with ‘normal operating conditions’ as well as that necessary for planned and unplanned plant maintenance (start-up/shut-down), plant upsets and emergency situations.

To support this amendment application GLNG:

• engaged KBR to perform a third-party review and endorsement of operational scenarios identified by GLNG which have historically produced visible smoke emissions from the LNG Plant flaring system. The report ‘GLNG Environmental authority visible smoke allowance review, prepared by KBR, dated July 2020’ (KBR Third Party Review) (Appendix A) presents the findings of this third party review. The findings are referenced throughout this report; and

• engaged Katestone Environmental Pty Ltd (Katestone) to undertake an air quality assessment to quantify the air emissions from the release of visible smoke from the LNG Plant flares, and to describe the potential impact of the emissions on the receiving environment. The report GLNG: Air Quality Assessment of Dry and Wet Flares, prepared by Katestone, dated July 2020 (Appendix B) presents the findings of this assessment. The findings are referenced throughout this report.

The proposed EA conditions are contained in section 2.5.3.


2.1 Flaring Operations A flaring system is in place at the LNG Plant to allow excess gas to be burnt off in a safe and controlled way for maintenance activities, unplanned repairs, plant upsets or emergency situations.

Flaring is a standard process for safe operations, ensuring hydrocarbons are safely combusted and are not directly emitted to the atmosphere. The LNG Plant flare system includes four separate flaring stacks: the Wet Process Flare, Dry Process Flare, Back-up Wet and Dry Flare, and the Marine Flare:

• the Wet Process Flare (authorised contaminant release point A13 common to Train 1 and Train 2) is designed to handle warm hydrocarbon streams that may be saturated with water vapour and/or contain free liquid hydrocarbons and water;

• the Dry Process Flare (authorised contaminant release point A15 common to Train 1 and Train 2) is designed to handle cryogenic hydrocarbons, both vapour and liquid;

• the Back-up Wet and Dry Flare (authorised contaminant release point A16 common to Train 1 and Train 2) is a spare which can be either used as a wet or dry flare; and

• the Marine Flare (authorised contaminant release point A14 common to Train 1 and Train 2) is designed to handle LNG vapours from the LNG Storage Tanks in the event of Boil Off Gas Compressors failure and/or ship loading.

During normal operating conditions, natural gas flows continuously through the LNG Plant. A small quantity of this gas is combusted in the flares in a pilot flame, designed to provide a continuous ignition source such that any gas sent to the flare is immediately combusted. The pilots produce a small smokeless flame which emits small volumes of carbon dioxide, nitrogen oxides and water vapour. Additionally, a flare purge is in place to prevent any air ingress into the flare system. The flare purge involves a small injection of low pressure fuel gas (or nitrogen) at the extremity of the flare headers to provide a continuous sweep of gas. This is a necessary safety requirement and reduces the risk of an explosive mixture forming in the flare system.

During normal flaring conditions, flared gas from the LNG Plant is primarily methane (~98%) with small amounts of nitrogen, carbon dioxide, ethane and traces of heavier hydrocarbons (C3+) such as propane and ethylene (~2%). Combustion of these gases does not produce visible smoke. Under certain conditions, and outside of normal operating conditions, such as during plant shutdown/start-up, maintenance, upset conditions, and in certain emergency situations, there is a requirement to flare refrigerants (ethylene and propane) that are used in the liquefaction process. The combustion efficiency of the flare may be reduced by the presence of the refrigerants and nitrogen (used for purging gas lines in the facility) during flaring events. The flaring of these refrigerants can result in visible smoke. This predominantly occurs from the Wet and Dry Process Flares.

The flaring of refrigerants and nitrogen results in the emission of Oxides of Nitrogen, Carbon Monoxide, Total Hydrocarbons (Methane, Ethane, Ethylene, Acetylene, Propane and Propylene), particulates in the form of PM2.5 and PM10 and trace Polycyclic Aromatic Hydrocarbons (PAH’s). Emission rates from flaring events are typically variable.

Flaring which results in visible smoke is unavoidable as it is required to maintain plant safety. Flaring of this nature is normally infrequent, and of short-duration. The following sections describe flaring scenarios where visible smoke is reasonably expected during daylight hours. Please note for the purpose of this application, the following definitions have been used for the terms ‘daylight hours’, ‘flaring event’, ‘normal operating conditions’, ‘plant maintenance activities’ and ‘visible smoke’:


“daylight hours” means those between sunrise and sunset times as shown on the Australian Government Geoscience Australia webpage < http://www.ga.gov.au/geodesy/astro/sunrise.jsp>. “flaring event” means an event where flammable gas is combusted through a flare and produces visible smoke either: (i) continuously for more than 5 minutes; or (ii) multiple instances of visible smoke occurring consecutively with a total duration of more than 5 minutes, provided that the consecutive instances of visible smoke occur due to the same underlying cause, discharges through the same valve or flare source and occurs within a two hour window. “normal operating conditions” means the ongoing operation of the LNG plant, excluding start-up, shutdown, maintenance, upset conditions, an emergency and LNG ship management. “plant maintenance activities” means the maintenance shutdowns (and subsequent start-ups) where equipment at the plant is inspected and, if needed, repaired or replaced to ensure the ongoing safe operation of the plant. “Ringlemann number” means a visually comparative scale used to define levels of opacity, where clear is 0, black is 5 and 1 through 4 are increasing levels of grey as used in describing smoke from combustion of hydrocarbons. “visible smoke” means a visible suspension of carbon or other particles in air measured by a Ringelmann number greater than 2.

2.1.1 Normal Operating Conditions

Visible smoke is generally not expected at the LNG Plant during normal operating conditions as outlined in section 2.1. However, where flaring events resulting in visible smoke are required for normal operating conditions, these flaring events are scheduled to be undertaken at night as much as possible so as to ensure compliance with EA condition B18 and to minimise any impacts to visual amenity. Refer to section 4.0 of Appendix A for a description of the types of activities which may result in flaring events from normal operations.

2.1.2 Planned Maintenance

Flaring events may occur when conducting planned maintenance, including routine maintenance activities and during major plant shutdowns/start-ups. These maintenance activities ensure the safe and efficient operation of the LNG Plant. Some maintenance activities require de-inventory of the gas process lines and/or refrigerant lines to enable safe access for maintenance/inspection purposes. As far as practicable, refrigerant is recovered by transferring inventory to storage, with the remaining refrigerant vapours requiring flaring. Additionally, during start-up following maintenance and/or shutdown events, the refrigerant circuits are charged with propane and ethylene. Some flaring events will occur as nitrogen and dry fuel gas are displaced by the refrigerants. Refrigerant is expensive and takes a long lead time to arrive on site. Therefore, GLNG makes every effort to re-inventory refrigerant and minimise refrigerant losses via the flare.

Planned flaring events to facilitate routine maintenance activities occur approximately 4 times each year. These maintenance activities tend to be based on short to medium-term planning in response to plant condition monitoring and not from long-term planning (like for a major shutdown). Given the short lead time for such maintenance activities, it is not always possible to undertake the flaring event during


http://www.ga.gov.au/geodesy/astro/sunrise.jsp

the night, particularly when plant safety is under threat. Refer to section 5.0 of Appendix A for a description of the types of routine maintenance activities which may result in flaring events.

Major plant shutdown maintenance is typically conducted on each LNG train once every 4 years and involves complete removal of hydrocarbons from the train for internal inspection and maintenance. These are safety mandated inspections, which also enable preventative maintenance to be carried out which minimises the need to undertake additional train shutdowns and additional major flaring events. Refer to section 6.0 of Appendix A for a description of the types of activities during a major shutdown which may result in flaring events. Due to the scheduled nature of these activities, flaring that can result in visible smoke is planned to occur during the night as far as practicable. However, some flaring processes may still carry over into daylight hours.

2.1.3 Unplanned Flaring Events (GLNG Plant upsets and emergencies)

2.1.3.1 GLNG Plant Upsets

Unplanned flaring events can occur at any time during plant upset conditions on either or both LNG trains. Upset conditions may result from instrumentation failure, poor response of the control system to a particular event or inadvertent action by an operator or maintenance personnel and are not intentionally planned by GLNG. Flaring associated with upset conditions is generally the result of the programmed actions taken by control or safety systems in response to the upset in order to preserve the integrity and safety of the facility. Upset conditions do not include emergency events.

Most unplanned flaring events are of a relatively short duration (approximately 15 minutes), however, in some cases, the duration is extended due to the time for detection and potential complications occurring with the event. Upset conditions cannot be mitigated by planning for night-time operation. Because upset conditions are not scheduled, GLNG has accounted for the possibility of there being up to 7 upset events in any 12 month period. Refer to section 7.0 of Appendix A for a description of the types of unplanned activities which may result in flaring events.

2.1.3.1 GLNG Plant Emergencies

Consistent with section 466B of the EP Act, emergency situations are those where:

(a) the health and safety of personnel and/or the broader community is threatened; or (b) environmental harm is threatened.

Flaring and subsequent visible smoke emissions at the LNG Plant may be necessary to prevent or minimise harm to people and the environment. Examples of an emergency event at the LNG Plant include the lifting of a pressure safety valve or where hydrocarbon is being released to the atmosphere from damaged plant infrastructure and depressurisation to the flare is initiated to minimise the hydrocarbon release. GLNG cannot plan or schedule emergency situations. As such, the flare system acts as a safety relief system during such situations and therefore needs to operate as designed and not be restricted in any way.

Given the above, GLNG is of the view that the frequency and duration of visible smoke resulting from emergency flaring events should not be limited by the conditions of the EA. As such, an emergency event is not considered to be subject to flaring limits as proposed by new condition (B20) (refer to section 2.5.3), nor should it be considered an environmental nuisance in accordance with existing Condition B2.


2.2 Flaring Event Mitigation Measures GLNG has implemented the following measures, in accordance with the Environmental Protection (Air) Policy 2019 (EPP Air), to reduce the frequency of flaring and duration of visible smoke from flaring events. These include:

(a) the implementation of plant optimisation measures (see section 2.2.1); and (b) the development of a Flaring Contingency Management Plan (Appendix C) (see section 2.2.2).

2.2.1 Plant Optimisation

The efficient operation of the LNG Plant is the best mitigation available to reduce the number of unplanned flaring events. The following plant optimisation measures are in place which aid in minimising the frequency and duration of visible smoke from flaring events:

• appropriate training of personnel in plant operating procedures to ensure the plant is operated in accordance with the LNG Plant design;

• process control and safety instrument systems for the safe and efficient operation of the plant within normal parameters;

• performance monitoring for process improvement and optimisation; • a plant maintenance campaign to ensure integrity and reliability of plant equipment; • a plant trip reduction campaign, whereby every trip is investigated and mitigations implemented

to prevent/minimise future trips of the same nature; • refrigerant (the principal cause of visible smoke) recovery rather than flaring; • detailed planning and scheduling of maintenance activities so necessary flaring can occur at

night; and • deferring unplanned (not upset nor emergency) flaring until night-time, where practicable and

safe to do so.

These measures are further explained in sections 4 to 7 of Appendix A.

GLNG is investigating additional plant optimisation measures to further reduce incidences of visible smoke. These are to be considered on their practicality for implementation and feasibility. These measures include (refer sections 4 to 7 of Appendix A):

• high rate flare purging to minimise lingering visible smoke after a release of heavier hydrocarbons to the flare system; and

• planning simultaneous flaring where feasible from multiple sources rather than separately to reduce the total duration of flaring events.

2.2.2 Flaring Contingency Management Plan

GLNG has developed a Flaring Contingency Management Plan which includes management measures to reduce the frequency and duration of gas being flared and any associated visible smoke. The management measures include:

• appropriate training of personnel in plant operating procedures to minimise flaring as far as practicable;

• routine monitoring of the flare to ensure the flare is operating satisfactorily; • installation of process alarms to advise operators of upset conditions within the plant prior to

gases being flared. This may provide operators adequate time to react, and as such minimise the possibility of the operational upset resulting in a flaring event;


• reporting of all flaring in monthly operations meetings so as to review and investigate causation, response and mitigation;

• monitoring of refrigerant compressors and turbines to ensure equipment is operating at optimal performance;

• development of emergency procedures for non-routine situations to deal with foreseeable risks and hazards including corrective responses to prevent and mitigate environmental harm; and

• recording of all planned and unplanned flaring events, their cause, and where required, the corrective actions implemented into a Flaring Register. This provides learnings to prevent and mitigate future flaring events.

These management measures are “…in accordance with industry practice.”1 as ratified by the HRL Technology Group as part of the independent environmental audit commissioned by DES in 2016.

To ensure the Gladstone community remains informed, as part of the Flaring Contingency Management Plan, GLNG also advises key community stakeholders, including DES, of planned maintenance activities and forecast flaring events. Notification is provided a minimum of 24 hours in advance of activities commencing.

2.3 Flare System Monitoring The GLNG flare system is monitored in several ways. Plant operators can observe live plant data, including data trends, plant set points and plant alarms. Continuous monitoring systems currently in place comprise the following:

• ultrasonic flowmeters are installed on each flare to monitor the flare gas flow rate which allows for a total flare volume to be calculated;

• a temperature detector and transmitter is installed on each flare header to measure the temperature of gas to the flare; and

• CCTV of the flare tips, which show the size of the flame and any associated smoke (during daylight hours).

GLNG also implements the Procedure for Recording Flaring Events (Appendix D) which defines the requirements for the recording of flaring events at the LNG Plant. The procedure includes a Flaring Event Register for the recording of flaring events whether planned (i.e. normal operations, routine maintenance or planned shut-down / start-up) or unplanned (i.e. upset). When a flaring event has been identified, the following information is recorded in the Flaring Event Register:

• time flaring commenced;

• nature of operations at the time of flaring;

• specific cause of flaring;

• Ringelmann Score (1-5);

• actions taken to minimise flaring intensity and duration; and

• time flaring stopped.

1 Page 46, ‘Environmental Audit of Flaring at Santos Gladstone Liquefied Natural Gas (GLNG) Plant, prepared by HRL Technology Group Pty Ltd, dated May 2017


2.4 Operational Alternatives to Current Flaring Regime Whilst mitigation and management measures are effective at minimising flaring events and the occurrence of visible smoke, the events cannot be eliminated from the existing plant flare system. Table 1 evaluates the feasibility of flare design alternatives and changes in operations that may further minimise or eliminate the incidence of visible smoke emissions. Feasibility is considered from the perspectives of technical implementation, effectiveness of operation and capital cost. Whilst a number of the options presented in Table 1 may be technically feasible and/or effective at minimising flaring events, some options have excessive financial implications and are not deemed feasible at this point in time.


Table 1: Evaluation of alternatives to current operations and flare design

Option Option Details Technically Feasible Effective Capital Cost

(Note 1) Implementation Feasibility

Reduced rate of flaring of refrigerants

Reduction in refrigerant flow to the flare so that visible smoke is not produced.

Yes

No

A significant flow reduction is considered impractical to implement given the system volumes and likely operational delays.

Per the HRLTG Environmental Audit “it is highly unlikely that flaring of ethylene and propane via the current flaring system can be done without producing smoke.”2

N/A

No.

While this option is technically feasible, it is not considered effective. As such this option is not considered suitable for implementation by GLNG.

Dilution of refrigerants sent to the flares

Dilute flared refrigerants with fuel gas in order to reduce visible smoke production from the flares.

Yes

No

Dilution is highly unlikely to be an effective means of reducing visible smoke with the current flaring system, requiring substantial wastage of fuel gas and reduction in refrigerants flow rate.

Per the HRLTG Environmental Audit “it is highly unlikely that flaring of ethylene and propane via the current flaring system can be done without producing smoke.”3

N/A

No.

While this option is technically feasible, it is not considered effective. Additionally this option:

• will result in significantly increased GHG emissions, combustion emissions, loss of valuable product and additional light pollution; and

• requires large volumes of fuel gas during start-up and shutdown activities, when refrigerant purging and charging activities are underway.

2 Page, 106, ‘Environmental Audit of Flaring at Santos Gladstone Liquefied Natural Gas (GLNG) Plant, prepared by HRL Technology Group Pty Ltd, dated May 2017 3 Page, 106, ‘Environmental Audit of Flaring at Santos Gladstone Liquefied Natural Gas (GLNG) Plant, prepared by HRL Technology Group Pty Ltd, dated May 2017




Given the above, this option is not considered suitable for implemented by GLNG.

Reduced frequency of refrigerant flaring

Trip reduction campaign, with trips investigated and mitigations implemented to prevent/minimise future trips.

Strategies to avoid/minimise requirement for plant defrosting outside of major shutdowns.

Plan simultaneous flaring where feasible from multiple sources rather than separately.

Plan for necessary flaring at night.

Yes

(methods employed by GLNG where practicable)

Partial

Planned flaring events are managed by reducing flaring frequency as far as practicable through the application of the strategies listed in the option details, however, unplanned flaring events cannot be controlled.

N/A Yes - methods employed by GLNG where practicable.

Transfer of increased amount of remnant refrigerant vapour from one LNG train to another

Reduction in the amount of refrigerant released to the flares during major plant shutdowns, by transferring remnant refrigerant vapour from one LNG train to another and therefore reducing the duration of the flaring event.

Yes

Partial (dependent on achievable vapour recovery rates)

Expected to be partially effective depending on transfer rates that can be achieved (affected by system operating pressures).

There is a risk that extended vapour recovery operations may prolong shutdown operations – this can have safety implications.

Nil

Yes.

The feasibility of this option is currently being investigated, however it is noted that this option if implemented will be partially effective and may have safety implications.

Replace Existing Flare Tips

Install new tip to increase velocity and entrain additional air No. No N/A

No.

This option is not technically feasible nor considered effective. As such, this option is




Insufficient flare backpressure

Low confidence in performance during low-rate events and in ethylene service

not considered suitable for implementation by GLNG.

Retrofitting Flare with Fuel Gas Assist:

Inject fuel gas into the flare stream, creating turbulence and entraining combustion air

Retrofit of the existing flare for fuel gas injection line and replacement of the existing flare tip. Extended plant shutdown for installation.

Yes.

Uncommonly used in industry and feasibility is dependent on availability of fuel gas during start-up and shutdown activities, when refrigerant purging and charging activities are underway.

More commonly seen in cases where flare gas stream has an energy content that is too low for combustion requirements.

Partial

Significant volumes of fuel gas would be required and would be unlikely to be effective to reduce visible smoke production.

N/A

No.

While this option is technically feasible, and considered partially effective, this option will result in significantly increased GHG emissions, combustion emissions.

Given the above, this option is not considered suitable for implemented by GLNG.

Retrofitting Flare with Steam Assist:

Inject high pressure steam into the flare stream, creating

Installation of a new steam generation system requiring additional plot space as well as steam lines and flare tip modifications requiring a major shutdown for an extended duration.

No.

Steam assist can be an effective means of achieving smokeless burning with the potential for improved effectiveness compared to an air assist system.

Partial.

Requires additional fuel, GHG emissions and combustion emission for steam generation

N/A

No.

Whilst this option is partially effective, it is not technically feasible as GLNG does not produce steam on site. As such, this option is not considered suitable for implementation by GLNG.




turbulence and entraining combustion air

More momentum can be supplied from high-pressure steam to enhance ambient air entrainment and mixing.

However, large quantities of steam are required and GLNG does not current produce steam on site.

Retrofitting Flare with Air Assist:

Inject air at the flare tip to create turbulence and entrain additional combustion air

Retrofit of the existing flare with installation of a large air duct (approximately 4m in diameter) or high-pressure air supply line and replacement of the existing flare tip, requiring a major shutdown for an extended duration. At least two new low pressure blowers or high pressure compressors would be required.

No.

An air assisted design is not considered technically feasible for the existing system as there is no space available for changes in the design. Installation of air ducts would also lead to increased wind loading on the existing structure, in excess of current design limits.

Partial.

While technically possible to install this technology on a new flare system, there are performance risks associated with flame stability and the potential risk of internal combustion due to the large flare tip (likely > 3m) required to achieve smokeless flaring. To the Vendor / GLNG’s knowledge, a flare tip of this size has not been demonstrated in industry.

>$50M

No.

While this option is partially effective, this option is not technically feasible. Additionally, this option:

• will require additional power demand, with associated fuel burn, GHG emissions and combustion emissions; and

• is cost prohibitive




Enclosed flare:

Install a new partial capacity enclosed ground flare (EGF)

New installation of enclosed ground flare with capacity limit of 100 t/hr. EGF conceals flames inside the chamber and minimises light and noise emissions.

Yes.

Automated flare diversion required (rupture disk safeguard).

Partial (90% of events).

Effective for the majority of flaring events except if the EGF is undergoing maintenance or in emergency high flow flaring events. In an emergency high flow flaring event, flaring would be from both EGF and existing elevated flares with smoke emissions expected.

>$120M

No.

While this option is effective and is technically feasible, this option is overly cost prohibitive. Additionally, this option will result in small increases in GHG emissions for additional EGF purge/pilot gas.

Ground flare:

Install a new walled multi-point ground flare (MPGF)

Expect no visible smoke produced under most scenarios including emergency high flow scenarios

Yes.

Potential for installation without an additional shutdown.

Installed on some other Australian LNG facilities (APLNG, Darwin LNG)

Yes (close to 100%) >$200M

No.

While this option is effective and is technically feasible, this option is overly cost prohibitive. Additionally, this option requires a large plot space (estimated area of 40,000m2 with consideration of radiation clearances required) which is not available on the PFL tenure.

Note 1 = Capital costs are presented in Australian Dollars and are estimates only. Costs are not based on vendor quotations and do not include the cost of lost production during shutdown for installation.


2.5 Proposed Change to EA EPPG00712213

2.5.1 Number of flaring events

GLNG reviewed the total number of flaring events from the LNG Plant over a one year period (4 May 2019 to 3 May 2020) which was considered to be reflective of typical LNG Plant operations. 188 events were identified, however the majority of these events occurred at night or otherwise with a non-visible smoke emission (i.e. Ringleman 0 – 1).

The prediction of flaring events per annum can be indicative only. The actual number of flaring events will vary significantly from year to year, depending on the maintenance and shutdown work planned for that year, actual plant experience with malfunctioning valves or other equipment, and the number of plant upsets experienced. The KBR review (Appendix A) found that a reasonable number of permitted flaring events with visible smoke would be 15 per annum with an approximate total of 8 hours of visible smoke per annum (refer to Table 2) to allow safe and efficient management of the LNG Plant.

Table 2. Frequency and duration of flaring events with visible smoke

Category Events/yr Duration/yr

Normal Operations 0 0

Planned Maintenance 4 160 minutes

Major Shutdown/Start-up 4 180 minutes

Plant Upsets 7 130 minutes

Total 15 470 minutes (7.8 hrs)

Upon further review of the flaring events, GLNG has concluded that with careful management and detailed planning of scheduled events, GLNG can likely comply with the number and duration of visible smoke events as currently prescribed on the QCLNG EA EPPG00711513 for planned and unplanned maintenance. That is 14 events with a total duration of 7 hours per annum. GLNG recognises that the QCLNG visible smoke conditions were the product of a comprehensive assessment process involving the DES and QCLNG which commenced in May 2017 and concluded on 29 June 2018. Appendix E presents the QCLNG flaring conditions in full.

Adoption of the QCLNG authorisations for the GLNG LNG Plant is considered appropriate as:

• the QCLNG environmental authority conditions contemplate visible smoke allowances for operating scenarios other than ‘normal operating conditions’. They also recognise the likelihood of additional visible smoke being generated during plant shut-down and start-up by allowing a longer duration of visible smoke for these activities;

• the QCLNG Plant is of a similar design to the GLNG LNG Plant as such, it is appropriate to apply the same visible smoke conditions to both facilities. This will ensure consistent regulation and community expectation between the facilities and will streamline the oversight of flaring activities by DES;

• the conditions will provide GLNG with an identifiable flaring framework, providing clear limits on the production of visible smoke during operational activities; and

• the public will benefit by having consistent flaring expectations of QCLNG and GLNG and will minimise impacts to the visual amenity of the Gladstone community.


Compliance with the proposed condition set (refer section 2.5.3) will have cost implications for GLNG, as there will be increased standby times and longer non-operational periods, particularly during large scale maintenance events. Additionally, detailed and careful planning of scheduled events will be required to comply with the proposed conditions. Despite this, GLNG is committed to strong environmental management and to respecting the interests of the communities in which GLNG operates. Therefore, to ensure visible smoke emissions from the GLNG LNG Plant associated with planned and unplanned plant maintenance (start-up/shutdown), plant upsets and during emergencies, are expressly authorised, GLNG seeks the inclusion of new conditions in Schedule B – Air emissions of EA EPPG00712213 as outlined in section 2.5.3 below and presented in Appendix F.

2.5.2 Existing conditions/definitions (B2) The release of dust and/or particulate matter resulting from the activities must not cause an

environmental nuisance at any sensitive or commercial place.

(B18) Visible smoke and particulate emissions must not be permitted for more than five minutes in any two hour period during normal operating conditions.

Existing definitions:

“normal operating conditions” means the ongoing operation of the LNG plant following commissioning and excludes start-up, shutdown, maintenance or calibration of emission monitoring devices.

2.5.3 Proposed conditions/definitions (B2) The release of dust and/or particulate matter resulting from the activities must not cause an

environmental nuisance at any sensitive or commercial place, unless the release occurs as a result of an emergency, or is authorised by this environmental authority or the EP Act.

(B20) Flaring events, except for those resulting from an emergency, occurring outside of normal operating conditions must not exceed:

a) 7 hours per annum during daylight hours; and b) 14 times per annum during daylight hours; and c) 30 minutes of continuous visible smoke during daylight hours except as authorised under

condition (B21).

(B21) Notwithstanding condition (B20)(c), flaring events must not exceed 90 minutes of continuous visible smoke at any one time in the following circumstances:

a) A flaring event associated with a plant maintenance activity that was planned to be completed outside of daylight hours, but was required to be undertaken during daylight hours to ensure the safe operation of the plant; or

b) A flaring event associated with a plant maintenance activity that was not planned and was required to be undertaken during daylight hours to ensure the safe operation of the plant

(B22) The holder of this authority must keep records of each flaring event to determine compliance with condition (B20) and (B21) and provide these records to the administering authority on request. Records must include, but not be limited to:

a) The duration of each flaring event; and b) The operational planning that was implemented to minimise flaring; and c) The operational controls that were implemented during flaring; and d) If the flaring event exceeds 30 minutes, the circumstance under condition (B21) which

caused this exceedance.


Proposed Definitions:

“daylight hours” means those between sunrise and sunset times as shown on the Australian Government Geoscience Australia webpage < http://www.ga.gov.au/geodesy/astro/sunrise.jsp>. “emergency” means (a) either— (i) human health or safety is threatened; or (ii) serious or material environmental harm has been or is likely to be caused; and (b) urgent action is necessary to— (i) protect the health or safety of persons; or (ii) prevent or minimise the harm; or (iii) rehabilitate or restore the environment because of the harm. “flaring event” means an event where flammable gas is combusted through a flare and produces visible smoke either (i) continuously for more than 5 minutes or (ii) multiple instances of visible smoke occurring consecutively with a total duration of more than 5 minutes, provided that the consecutive instances of visible smoke occur due to the same underlying cause, discharges through the same valve or flare source and occurs within a two hour period. “normal operating conditions” means the ongoing operation of the LNG plant, excluding start-up, shutdown, maintenance, upset conditions, an emergency and LNG ship management. “plant maintenance activities” means the maintenance shutdowns (and subsequent start-ups) where equipment at the plant is inspected and, if needed, repaired or replaced to ensure the ongoing safe operation of the plant. “Ringelmann number” means a visually comparative scale used to define levels of opacity, where clear is 0, black is 5 and 1 through 4 are increasing levels of grey as used in describing smoke from combustion of hydrocarbons. “visible smoke” means a visible suspension of carbon or other particles in air measured by a Ringelmann number greater than 2.

2.5.3.1 Variations to QCLNG conditions

Minor variations to the conditions of the QCLNG environmental authority have been proposed, as described below. These are to provide clarity in their implementation only. The duration and frequency of visible smoke allowances have not been altered.

Condition B2 and definition of emergency

(B2) The release of dust and/or particulate matter resulting from the activities must not cause an environmental nuisance at any sensitive or commercial place, unless the release occurs as a result of an emergency, or is authorised by this environmental authority or the EP Act.

“emergency” means (a) either— (i) human health or safety is threatened; or (ii) serious or material environmental harm has been or is likely to be caused; and (b) urgent action is necessary to— (i) protect the health or safety of persons; or (ii) prevent or minimise the harm; or (iii) rehabilitate or restore the environment because of the harm.

This variation expressly excludes visible smoke emissions generated in accordance with the conditions of the EA, EP Act or in emergency situations. The inclusion of the definition of emergency replicates that prescribed in section 466B of the EP Act.

Definition of flaring event

“flaring event” means an event where flammable gas is combusted through a flare and produces visible smoke either (i) continuously for more than 5 minutes or (ii) multiple instances of visible smoke occurring consecutively with a total duration of more than 5 minutes, provided that the consecutive



instances of visible smoke occur due to the same underlying cause, discharges through the same valve or flare source and occurs within a two hour window.

The variation to the definition of a ‘flaring event’ is important to ensure events that result in sporadic flaring are not considered multiple flaring events. For example, when conducting valve testing or repairs, valves may need to be stroked, cycling through an open and closed position, multiple times in order to confirm functionality. The required frequency and duration of each valve stroke cannot always be pre-determined. As far as possible, blocked in valves are utilised to avoid flaring and these activities are planned for night time when visible smoke is expected, however, this may not always be feasible in the case of an upset event such as a leaking valve or inadvertent valve operation. The valve testing/stroking/repair event listed in Table 5.1 of Appendix A makes reference to multiple valve stroking being classified as 1 flaring event. GLNG considers that such occasions should be considered a single event, from a single initiating cause. This clarity is important to ensure the proposed allowance of 14 events per annum in condition (B20)(b) is not unreasonably exhausted.

Definition of normal operating conditions

“normal operating conditions” means the ongoing operation of the LNG plant, excluding start-up, shutdown, maintenance, upset conditions, an emergency and LNG ship management.

The variation to the definition ensures that an emergency is excluded from the definition of ‘normal operating conditions’.

Definition of plant maintenance activities

“plant maintenance activities” means the major maintenance shutdowns (and subsequent start-ups) where equipment at the plant is inspected and, if needed, repaired or replaced to ensure the ongoing safe operation of the plant.

This variation is to ensure that both routine maintenance and major maintenance activities are captured by the definition of plant maintenance activities as both types of maintenance activities can result in a flaring event/s. As outlined in section 2.1.2, some maintenance activities require de-inventory of the gas process lines and or refrigerant lines. Where the refrigerant cannot be de-inventoried to storage tanks, the refrigerant is flared which can potentially result in flaring events. Additionally, during start-up following maintenance and/or shutdown events, the refrigerant circuits are charged with propane and ethylene. Routine maintenance activities tend to be based on short to medium-term planning in response to plant condition monitoring and not from long-term planning (like major shutdowns). Therefore, it is not always possible to undertake the flaring event during the night, particularly when plant safety is under threat. Flaring events may occur approximately 4 times per annum from routine maintenance and 4 times per annum from major plant shutdowns (refer to Table 2).


3.0 Site Description PFL 10 is located in the south-west section of Curtis Island, Gladstone. It covers approximately 378 ha across lot 1 on SP 235007, lot 7 on SP 39683, lot 1 on SP 228184, lot 4 on SP 235936 and a portion of lot 4 SP 235007, located within the Curtis Island Industry Precinct of the Gladstone State Development Area. The facility is adjacent to the QCLNG and APLNG LNG facilities, with heavy industry being a key land use across the wider Gladstone and Gladstone Harbour region (refer to Figure 1).

The LNG Plant is comprised of two LNG trains, two LNG tanks and a flare system, as well as other associated infrastructure. LNG Plant Train 1 and LNG Plant Train 2 are fully commissioned and operational.

The topography of the LNG Plant comprises low rounded hilly land (20 – 45 m AHD), intermediate steep hilly land (50 – 75 m AHD) and steep high hilly lands (>120 m AHD). Undulating slopes extend towards the coast and merge with estuarine supra-tidal flats, which are fringed by tidal mangrove flats along the coastline.

An Environmental Management Precinct also adjoins the LNG Plant – a precinct created as part of the approval and development of the three Curtis Island LNG Facilities. The northern section of the island is predominantly comprised of State Forest, Conservation Park and National Park, as well as the LNG industry proponent’s joint Monte Christo Offset area.

Gladstone harbour and its surrounds (including the southern end of Curtis Island) is a major industrial centre with a number of major industrial and mineral processing facilities located in the region, which all contribute to the industrial value identified for the area including: • Australia Pacific LNG; • Boyne Smelters Limited; • Cement Australia; • Fisherman’s Island Northern Expansion; • Gladstone Pacific Nickel Refinery; • Gladstone Power Station; • Orica Chemical Complex; • Queensland Alumina Limited; • Queensland Curtis LNG; • Rio Tinto Aluminium Yarwun; • Wiggins Island Coal Export Terminal; and • Wiggins Island Rail Project.


Figure 1. Site location


4.0 Environmental Values and Potential Impacts As described in Section 2.0, the scope of this amendment is limited to the release of contaminants to the atmosphere in the form of visible smoke, including the visual amenity of the aesthetic environment within the vicinity of the GLNG LNG Plant. As such, air is the only identified environmental value that is described in this application. The activity is not expected to result in any new or different impacts to the environmental values of water, biodiversity, land, acoustic, land, rehabilitation and waste and are therefore not discussed further.

4.1 Air

Katestone carried out an air quality assessment to quantify the visible smoke emissions from the LNG Plant flares during flaring events and the potential impacts of those emissions on the receiving environment. The results of this assessment are summarised in section 4.1.4. The air quality assessment is attached in full as Appendix B.

4.1.1 Background Air Quality The LNG Plant is located within the Curtis Island Industrial Precinct of the Gladstone State Development Area. The use designation of the industrial precinct includes high impact industry limited to natural gas (liquefaction and storage). The greater Gladstone Harbour region is a major industrial centre and a significant influence on the air quality of Gladstone airshed.

DES maintain a network of eight air quality monitoring stations throughout Gladstone to check compliance with ambient air quality guidelines, identify long-term trends in air quality, investigate local air quality concerns and assess the effectiveness of air quality management strategies (DES 2020). The location of the monitoring stations within the Gladstone region and contaminants monitored by each are indicated in Figure 2.

Figure 2. Air contaminants monitored at the Gladstone monitoring stations Despite the industrial nature of the locality, environmental impact assessments show that, apart from the close proximity to the Gladstone Power Station and during regional scale pollution events such as bushfires and dust storms, the air quality of the region meets the Environmental Protection (Air) Policy 2019 (EPP Air) criteria for the protection of human health, wellbeing and the health and biodiversity of ecosystems.

For the assessment of impacts to air quality, background concentrations of CO and, PM2.5 and PM10 were sourced from DES monitoring data from the Gladstone air monitoring stations. For NOX emissions, a two-level approach was adopted by Katestone to predict the cumulative effect of emissions from the


LNG Plant sources other than the flares, and existing, approved and other potential industrial developments in the Gladstone region. This assessment utilised the Gladstone Airshed Modelling System Version 3 (GAMSv3), a regional airshed dispersion modelling tool developed by Katestone for the Department of State Development, Tourism and Innovation, for use in planning studies. GAMSv3 incorporates observed meteorological information from the network of Bureau of Meteorology (BoM) and DES meteorological stations across the Gladstone region into both The Air Pollution Model (TAPM) and CALMET meteorological models. The GAMS emissions sources for NOx are as follows:

• Hourly variable emissions of oxides for nitrogen for the Gladstone Power Station for the period 1 April 2006 to 31 March 2007;

• Annual average emissions of oxides of nitrogen for: o Rio Tinto Alcan Boyne Smelter – Aluminium smelter; o Queensland Alumina Limited (QAL) Alumina refinery; o Cement Australia (QCL) – Cement manufacturing plant; o Rio Tinto Alumina Yarwun – Alumina refinery; and o Orica Australia Pty Ltd.

• Approved and proposed LNG facilities (emissions of NOx based on EIS and SEIS): o Australia Pacific LNG; o Queensland Curtis LNG; o LNG Limited Fishermans Landing; and o Arrow LNG.

No background concentrations were assumed for the assessment of hydrocarbons or PAHs in accordance with conventional practice.

Table 3 provides a summary of the source of the background levels used in the assessment.

Table 3. Background concentrations used in modelling assessment

Pollutant Value Source

Carbon monoxide (CO) Modelled GLNG plant plus 250 μg/m3

DES monitoring data from Beacon Avenue, Boyne Island

Nitrogen dioxide (NO2)

GAMS – existing and approved industries in the Gladstone region plus other LNG plants as listed above

GAMSv3 - existing and approved industries in the Gladstone region plus other LNG plants as listed above

PM2.5 Modelled GLNG plant plus 17.7 μg/m3

DES monitoring data for South Gladstone, 95th percentile 24-hour for 2019

PM10 Modelled GLNG plant plus 36 μg/m3

DES monitoring data average 95th percentile 24-hour from South Gladstone, 2019

Hydrocarbons N/A – in accordance with conventional practice

N/A – in accordance with conventional practice

PAHs N/A – in accordance with conventional practice

N/A – in accordance with conventional practice


4.1.2 Sensitive Receptors The potentially sensitive receptors (including protected areas) located within approximately 10km of the LNG Plant include (refer to Figure 3): • Tide Island (Note: this is leased by GLNG); • Witt Island; • Compigne Island; • Turtle Island; • The Curtis Island Environmental Management Precinct; • the industrial, commercial and residential areas of Gladstone, Yarwun, Targinie and

Fishermans Landing; • Yarwun State School; • Gladstone State School; • the residential areas of Curtis Island (Southend); • Quoin Island; • Curtis Island National Park; • Curtis Island Conservation park; • Curtis Island State Forest; and • Targinie State Forest.

4.1.3 Environmental Values and Quality Objectives (Air) Section 6 of the EPP Air prescribes potential environmental values relevant to the air environment. The environmental values relevant to this amendment application include:

a) the qualities of the air environment that are conducive to protecting the health and biodiversity of ecosystems; and

b) the qualities of the air environment that are conducive to human health and wellbeing; and c) the qualities of the air environment that are conducive to protecting the aesthetics of the

environment, including the appearance of buildings, structures and other property; Section 7 and Schedule 1 of the EPP Air prescribes air quality objectives for protecting or enhancing environmental values. The relevant air quality indicators for the amendment application are:

• Oxides of nitrogen (NOX);

• Carbon monoxide (CO);

• Hydrocarbons including: Methane, Ethane/ethylene, Acetylene, Propane, Propylene;

• Particulate matter in the form of PM2.5 and PM10 (flare gases containing propane and ethylene);

• Polycyclic Aromatic Hydrocarbons (PAHs) (flare gases containing propane and ethylene); and

• Visibility reducing particles.


Figure 3. Sensitive receptors within a 10km radius of the LNG Plant


The EPP Air quality objectives relevant to the key air pollutants that may be generated from the LNG Plant flares are presented in Table 4. Table 4. Environmental values and air quality objectives (Schedule 1of the Environmental Protection (Air)

Policy 2019)

Air Quality Indicator Environmental Value

Air Quality Objective

μg/m3 ppm Averaging Period

Allowable Exceedance

Carbon monoxide (CO) Health and wellbeing 11,000 9 8 hours 1 day/year

Nitrogen dioxide (NO2)

Health and wellbeing 250 0.12 1 hr 1 day/year

62 0.03 1 year

Health and biodiversity of ecosystems 33 0.016 1 year

PM2.5 Health and wellbeing 25 24 hours

8 1 year

PM10 Health and wellbeing 50 24 hours

25 1 year

Visibility reducing particles

Protecting aesthetic environment

20km visibility in the air environment

1 hour

As described above, hydrocarbons are also a relevant air quality indicator for the amendment application. The combustion of methane, propane or ethylene in the flares is likely to produce small quantities of hydrocarbons. The EPP Air does not provide any assessment criteria for the hydrocarbons listed above, as such it is common practice to consider, and where appropriate adopt, an air quality objective for a specific substance from another jurisdiction. As a result, air quality objectives from the following guidelines and standards have been adopted for the hydrocarbons identified in the air quality assessment:

• National Exposure Standards for Atmospheric Contaminants in the Occupational Environment (NOHSC:1003(1995)); and

• Texas Commission on Environmental Quality (TCEQ) Effects Screening Levels 2008.

The hydrocarbon emissions likely to be emitted from the flares are presented in Table 5 with their respective air quality objective.

Table 5. Relevant ambient air quality objectives and standards for hydrocarbons



μg/m3 Averaging Period Source

Acenaphthylene (as acenaphthene)

Health 1 1 hour TCEQ

Acetylene Health 26,600 1 hour TCEQ




μg/m3 Averaging Period Source

Anthracene Health 0.5 1 hour TCEQ

Benz(a)anthracene Health 0.5 1 hour TCEQ

Benzo(g,h,i)perylene Health 0.5 1 hour TCEQ

Chrysene Health 0.5 1 hour TCEQ

Dibenzo(a,h)anthracene (as acenaphthene)

Health 0.5 1 hour TCEQ

Ethane Health 12,000 1 hour TCEQ

Ethylene (Ethene) Health 13.9% by volume 3 Simple Asphyxiant NOHSC:1003/TECQ

Fluoranthene (Benzo(j,k)fluorene)

Health 0.51 1 hour TCEQ

Fluorene Health 0.52 1 hour TCEQ

Methane Health 13.9% by volume 3 Simple Asphyxiant NOHSC:1003/TECQ

Phenanthrene Health 0.5 1 hour TCEQ

Propane Health 18,000 1 hour TCEQ

Propylene Health 8,750 1 hour TCEQ

Pyrene Health 0.5 1 hour TCEQ

1 Air quality objective not found: Fluoranthene (or Benzo(j, k)fluorene) is a polycyclic aromatic hydrocarbon (PAH) and a structural isomer of the alternant PAH pyrene. Consequently, the same 1-hour average air quality objective of 0.5 μg/m3 has been applied for this assessment.

2 Air quality objective not found: Fluorene is a PAH, and consequently, in line with other PAHs referenced by the TCEQ Effects Screening Levels an air quality objective of 0.5 μg/m3 has been applied for this assessment.

3 To maintain oxygen content in air greater than 18% by volume

4.1.4 Dispersion Modelling Assumptions A dispersion modelling assessment using the dispersion model CALPUFF was conducted to determine the potential impacts due to the flaring operations. Modelling was based on the following three real GLNG flaring scenarios:

• Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities. This scenario resulted in high propane emissions.

• Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities. This scenario resulted in high propane emissions.

• Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed to open. This event resulted in worst case methane emissions due to a plant upset. Whilst the flaring of methane is unlikely to produce particulate matter, elevated methane levels were modelled to result in elevated levels of other contaminants (e.g. carbon monoxide and oxides of nitrogen).


These three scenarios were identified as having the maximum potential for impact and as such represent worst-case emissions potential. As outlined in section 2.1 the flaring of refrigerants (e.g. propane) may result in visible smoke.

The impact assessment is considered to be conservative given the application of the following assumptions:

• flaring events were modelled to occur continuously for a 24-hour period. In reality, a flaring event may occur over a number of minutes or up to 24-hours; and

• all other plant and equipment at GLNG operates at the same time as the flaring event. In reality, the visible smoke emissions are typically associated with the shutdown of one processing train and, therefore, emissions from other plant and equipment will be reduced (refer to Appendix B for an overview of the operating plant for the various flare scenarios). A summary of other plant equipment included in the assessment and pollutants emitted from them is summarised in Table 11 of Appendix B.

The dispersion modelling provided predictions of nitrogen dioxide, PM2.5, PM10, carbon monoxide and hydrocarbon concentrations at sensitive receptors. Ground-level concentrations for short-term 1-hour and 24-hour averaging periods were determined as the releases from the flares are expected to range from minutes up to 24-hours. An assessment against longer term averaging periods was therefore not undertaken.

4.1.4.1 Source characteristics, emission factors and rates

Because of their nature, flares cannot be practically measured in the field. Consequently, Katestone applied emission factors to estimate the emissions. Flare emissions were based on US EPA AP-42 documents (Chapter 13.5, Industrial Flares), other literature information (McEwen et al. (2012)) and process information supplied by GLNG. Section 2.4 of Appendix B prescribes the emission factors and rates applied by Katestone for each of the air pollutants: NOX, CO, total hydrocarbons (in methane equivalents), PM2.5, PM10 and PAHs.

Additionally, due to the large amount of heat and buoyancy generated by the flare, it could not be modelled as a stack source. To model the flare emissions appropriately, the US EPA Screen 3 methodology was used to generate the pseudo stack characteristics (effective height and diameter) for the flare. The source characteristics used in the dispersion modelling are provided in Table 10 of Appendix B.

4.1.5 Potential Impacts and Mitigation Measures

The potential impacts from flaring events has been considered with regards to the release of contaminants to the atmosphere, and the visual amenity of the aesthetic environment.

4.1.5.1 Air Quality Impacts

The assessment conducted by Katestone quantified the visible smoke emissions from the LNG Plant flares during flaring events and the potential impacts of those emissions on the receiving environment.

For the three scenarios modelled, the predicted ground-level concentration for the relevant air quality indicators was modelled for the flare in isolation; and for the flare in isolation, flare with other plant equipment and the flare with other plant equipment plus background. The results of the dispersion modelling conducted by Katestone for the potential three worst case emissions demonstrate that the predicted ground-level concentrations of NO2, CO, PM2.5, PM10, hydrocarbons and PAHs were well below the relevant air quality objectives (EPP Air and/or relevant standards and guidelines) at all sensitive receptors (including residential receptors and protected areas).


The results of the modelling are presented in sections 4.1.5.1.1 and 4.1.5.1.2.

4.1.5.1.1. Dispersion modelling results – Flare in isolation The results of the three flare scenarios modelled are presented in Table 14 to Table 19 of Appendix B. The predicted ground-level concentrations are the maximum predicted and are due to the flare in isolation. The results show that the predicted ground-level concentrations of pollutants are well below the relevant air quality objectives, as follows:

• Maximum 1-hour average ground-level concentrations of NO2 predicted at a receptor less than 3% of the objective

• Maximum 8-hour average ground-level concentration of CO predicted at a receptor less than 1% of the objective

• Maximum 24-hour average ground-level concentrations of PM10 predicted at a receptor less than 5% of the objective

• Maximum 24-hour average ground-level concentrations of PM2.5 predicted at a receptor less than 9% of the objective

• Maximum 1-hour average ground-level concentrations of hydrocarbons (ethane, ethylene, acetylene, propane and propylene) predicted at a receptor less than 0.4% of the relevant objectives

• Maximum ground-level concentrations of PAHs are well below (less than 0.7% of) the relevant objectives.

4.1.5.1.2. Dispersion modelling results – Flare including background Table 20 to Table 22 of Appendix B summarise the cumulative maximum concentrations of NO2, CO, PM10 and PM2.5 for the three scenarios. Table C1 to Table C3 in Appendix C of Appendix B present the predicted ground-level concentrations for each modelled dry and wet gas flare scenario as well as a breakdown of predicted concentrations due to flare in isolation, flare with other plant equipment and flare with other plant equipment plus background. The results show that the predicted ground-level concentrations NO2, CO, PM2.5 and PM10 are well below the relevant air quality objectives, as follows:




4.1.5.2 Visual Amenity

As demonstrated above, while the visible smoke produced during flaring events maintains air quality objectives in the Gladstone region visual aesthetics of Gladstone may be impacted by visible smoke. Section 15 of the EP Act defines environmental nuisance as an "unreasonable interference or likely interference with an environmental value…”

The visible smoke emissions generated from flaring events may be acute for a short period, however the plume does not affect the visibility of the whole air shed as would bush fires or dust storms. Visibility is only affected in the direct line of site of the plume.

GLNG is proposing (by way of the proposed EA conditions) to have a maximum total of 14 flaring events per annum, for a duration of 7 hours during daylight hours and with a maximum release time of 90


minutes at any one time. When considering these events over the period of a day and a year, the proposed visible smoke emissions are for a short duration, are intermittent in nature and occur infrequently. Should GLNG utilise the full proposed 7 hours allowance in a year, this represents 0.08% of hours in a year whereby the community may be impacted by visible smoke. Further, the highest potential for visible smoke to be generated (and of longer duration) is during plant shutdowns and start-ups for plant maintenance. These are scheduled to occur once every 4 years per train and will be limited to a maximum 90 minute release. In context of these events over a year, this is considered minimal and reasonable and should not constitute a nuisance. Further, these allowances represent worst case scenarios – flaring events will vary year to year, dependent on plant operations required during a given period.

As outlined in section 2.1 and verified by KBR as a third party, all flaring events “are considered reasonable and reflect a balance between enabling safe and efficient operation of the LNG plant and a strong drive to minimise visible smoke emissions affecting public visual amenity”. Further, the DES imposed the visible smoke authorisations for the QCLNG Plant on the QCLNG environmental authority. Given the similarity between the QCLNG and GLNG flare designs, this outcome has set a precedent for what is a reasonable compromise between plant operability, plant safety and visual impact to the community.

4.1.5.3 Mitigation Measures

GLNG already implements a series of mitigation and management measures to reduce the frequency and duration of visible smoke from flaring events. These have been described in section 2.2 and include:

• the implementation of plant optimisation measures (see section 2.2.1); and • the development a Flaring Contingency Management Plan (Appendix C) (see section 2.2.2);

Flaring resulting in visible smoke is unavoidable to maintain plant safety. However, avoidance of circumstances necessitating flaring is the best mitigation measure available to GLNG. This can be archieved through personnel training, implementation of detailed plant operating procedures, undertaking of regular plant maintenance and through detailed event investigation. GLNG is continually working to minimise the frequency of flaring wherever possible.

The results of the air quality impact assessment demonstrate the flaring events are not significantly contributing to the Gladstone airshed and that GLNG are able to maintain the protection of the health of the community as well as other nature-based sensitive receptors. The cap on frequency and duration of visible smoke proposed as part of this EA amendment should also assist in alleviating impacts to visual amenity. GLNG will make every possible effort to plan for flaring events to occur during the night.

GLNG is committed to good environmental management and to protecting and promoting the interests of the communities in which it operates. GLNG will continue to engage with key community stakeholders prior to undertaking forecast flaring and will continue to seek operability improvements to minimise impacts to the visual amenity of the community, whilst maintaining plant safety and efficiency.

4.1.5.4 Monitoring

Flare system monitoring undertaken by GLNG is described in Section 2.3. The existing monitoring regime is focused on the measurement of the frequency, duration and visibility (Ringelmann Score) of visible smoke. This includes visual monitoring captured via CCTV and assignment of a Ringelmann Score as well as gas temperature and gas flow rate measurements. In GLNG’s view, this monitoring is sufficient to demonstrate compliance with the proposed conditions in section 2.5.3 (namely conditions B20 - B22). A determination of the cause of the flaring event and actions taken to minimise the flaring is also recorded as part of GLNG’s Procedure for Recording Flaring Events. This information is what is


necessary for GLNG to understand why and how a flaring event occurred and to identify a root cause and corrective actions to prevent future recurrences wherever practicable.


5.0 Legislative Considerations

5.1 Environmental Protection Act 1994 (Qld)

5.1.1 Requirements for an EA Amendment Application (s226 and s226A EP Act)

Section 226 and 226A of the EP Act specifies the requirements for an EA amendment application. Table 6 contains a summary of the EP Act requirements assessed against this proposed amendment application.

Table 6: Requirements EA Amendment Application (s226 and s226A EP Act)

Section of the EP Act Relevance to amendment application

s226(1)(a) be made to the administering authority

The EA amendment application has been lodged with DES who is the administering authority for the EP Act.

s226(1)(b) be made in the approved form Refer to Attachment 1 of the application package, which includes the Application to amend an environmental authority.

s226(1)(c) be accompanied by the fee prescribed under a regulation

The application fee of $340.90 was paid upon lodgement of this application.

s226(1)(d) describe the proposed amendment Refer to Section 2.0.

s226(1)(e) describe the land that will be affected by the proposed amendment

Refer to Section 3.0.

s226(1)(f) include any other document relating to the application prescribed under a regulation.

Refer to the information provided throughout this supporting report.

s226A(1)(a) describe any development permits in effect under the Planning Act for the carrying out of the relevant activity for the authority; and

The following development permits have been obtained for the Materials offloading facility (MOF) and Product loading facility (PLF):

• Development Approval - Prescribed Tidal Works – Materials Offloading Facility (DA/264/2011) (modified DA/264/2010);

• Development Approval Operational works that is the removal, destruction or damage of marine plants associated with the MOF, the Pioneer MOF and haul road (DA 2011DB0082);

• Development Approval - Prescribed Tidal Works – Product Loading Facility (DA/603/2012); and

• Development Approval for Prescribed Tidal Works – Curtis Island Temporary Pioneer Barge Ramp Facility (DA/258/2010).

s226A(1)(b) state whether each relevant activity will, if the amendment is made, comply with any eligibility criteria for the activity

Not applicable – There are currently no eligibility criteria relevant to the activities proposed by the amendment application.

s226A(1)(c) if the application states that each relevant activity will, if the amendment is made, comply with any eligibility criteria for the activity— include a declaration that the statement is correct

Not applicable – There are currently no eligibility criteria relevant to the activities proposed by the amendment application.



s226A(1)(d) state whether the application seeks to change a condition identified in the authority as a standard condition

Not applicable - The respective EA does not contain any standard conditions.

s226A(1)(e) if the application relates to a new relevant resource tenure for the authority that is an exploration permit or GHG permit—state whether the applicant seeks an amended environmental authority that is subject to the standard conditions for the relevant activity or authority, to the extent it relates to the permit

Not applicable - The application does not relate to a new resource tenure.

s226A(1)(f) include an assessment of the likely impact of the proposed amendment on the environmental values, including—

(i) a description of the environmental values likely to be affected by the proposed amendment;

This amendment is limited to the release of contaminants to the atmosphere. As such, air is the only identified environmental value described in Section 4.0 of this application.

(ii) details of any emissions or releases likely to be generated by the proposed amendment;

The amendment does not seek to authorise any new emissions, but seeks to amend the conditions that relate to flaring authorised by the conditions of Schedule B - Air.

Katestone have conducted an air quality assessment to quantify the visible smoke emissions from the LNG Plant flares during flaring events and the potential impacts of those emissions on the receiving environment. The results of this assessment are summarised in Section 4.1.5 and included as Appendix B.

(iii) a description of the risk and likely magnitude of impacts on the environmental values;

The assessment conducted by Katestone quantified the visible smoke emissions from the LNG Plant flares during flaring events and the potential impacts of those emissions on the receiving environment.

For the three scenarios modelled, the predicted ground-level concentration for the relevant air quality indicators was modelled for the flare in isolation; and for the flare in isolation, flare with other plant equipment and the flare with other plant equipment plus background. The results of the dispersion modelling conducted by Katestone for the potential three worst case emissions demonstrate that the predicted ground-level concentrations of NO2, CO, PM2.5, PM10, hydrocarbons and PAHs were well below the relevant air quality objectives (EPP Air and/or relevant standards and guidelines) at all sensitive receptors (including residential receptors and protected areas).

The results of the modelling are presented in sections 4.1.5.1.1 and 4.1.5.1.2.

The aesthetics of the environment have the potential to be impacted from visible smoke emissions caused by the flaring events. The impact on the aesthetics of the environment from visible smoke emissions is for a short duration, is of an intermittent nature and happens infrequently.



(iv) details of the management practices proposed to be implemented to prevent or minimise adverse impacts;

GLNG's existing air quality management will continue to be implemented in accordance with the management hierarchy for air emissions, including:

• Avoid/Minimise – o Implementation of plant optimisation measures

including the following: A trip reduction campaign, whereby every trip

is investigated and mitigations implemented to prevent/minimise future trips of the same nature;

Where practical, the transfer of refrigerant (the principal cause of visible smoke) to an on-line compressor string (including to another train if necessary) rather than flaring;

Development of strategies to avoid/minimise the requirement for plant defrosting (required for hydrate/heavier hydrocarbon removal which can result in visible smoke) outside of major shutdowns to minimise the total duration of flaring events;

Detailed planning and scheduling of maintenance activities so necessary flaring can occur at night; and

Deferring unplanned flaring until night-time, where practicable and safe to do so.

o GLNG is investigating additional plant optimisation measures to further reduce incidences of visible smoke. These are to be considered on their practicality for implementation and economic feasibility. These measures include: High rate flare purging to minimise lingering

visible smoke after a release of heavier hydrocarbons to the flare system; and

Planning simultaneous flaring where feasible from multiple sources rather than separately to reduce the total duration of flaring events.

o GLNG has developed a Flaring Contingency Management Plan (Appendix C) which includes management measures to reduce the frequency and duration of gas being flared and any associated visible smoke. The management measures are presented in Section 2.2.2. The management measures are in, ‘…in accordance with industry practice.”4 As ratified by the HRL Technology Group as part of the independent environmental audit commissioned by DES in 2016.

• Manage – o The GLNG flare system is monitored in several

ways. Plant operators can observe live plant data including CCTV of the flare tips which show the size of the flame and smoke (during daylight

4 Page 46,‘Environmental Audit of Flaring at Santos Gladstone Liquefied Natural Gas (GLNG) Plant, prepared by HRL Technology Group Pty Ltd, dated May 2017


Section of the EP Act Relevance to amendment application hours), data trends, plant set points and plant alarms.

o GLNG has implemented the Procedure for Recording Flaring Events which defines the requirements for the recording of flaring events at the LNG Plant. The management of flaring events assists in ensuring compliance with the conditions of EA EPPG00712213 and in minimising the potential for community complaints relating to visible smoke. The procedure includes a Flaring Event Register which is a requirement of the Flaring Contingency Management Plan whether the flaring event is planned (normal operations or planned shut-down/start-up) or unplanned (i.e. upset).

o Air emissions monitoring will continue in accordance with the existing conditions of the EA.

o Air monitoring is undertaken by a suitably qualified and experienced person and in accordance with the conditions of the EA and the Environmental Protection Regulation 2019 (Qld).


(v) details of how the land the subject of the application will be rehabilitated after each relevant activity ceases;

Rehabilitation of the LNG Plant will be undertaken in accordance with the requirements of the conditions of the EA, namely Schedule H - Petroleum Infrastructure.

s226A(1)(g) include a description of the proposed measures for minimising and managing waste generated by any amendments to the relevant activity;

It is not expected the proposed amendment will result in the generation of new types of waste. The current avoidance and management practices will continue to be used and the conditions of Schedule E will be complied with.

s226A(1)(h) include details of any site management plan or environmental protection order that relates to the land the subject of the application;

Not applicable – There is no relevant site management plan or current Environmental Protection Orders relating to land located within PFL 10.

5.1.2 CSG Activities Requirements for EA Amendment Applications (s227 EP Act)

Section 227 of the EP Act specifies requirements for an amendment application for coal seam gas (CSG) activities where the application:

(a) relates to an EA for a CSG activity; and

(b) the proposed amendment would result in changes to the management of CSG water; and

(c) the CSG activity is an ineligible ERA.

This amendment application is for the LNG Plant and associated infrastructure which are not CSG activities under the EP Act. This section of the Act is not applicable.


5.1.3 Underground Water Rights - EA Amendment Applications (s227AA EP Act)

Section 227AA of the EP Act specifies the requirements for an amendment application where the application involves changes to the exercise of underground water rights for a petroleum lease. This amendment application relates to PFL 10 and is therefore not applicable.

5.1.4 Assessment Level Decision for Amendment Application (s228 EP Act)

GLNG considers this amendment application to be a minor amendment. Refer to Table 7 for further information concerning the determination of this application being a minor amendment.

Table 7: Minor Amendment (Threshold) Assessment

Minor amendment (threshold), for an environmental authority, means an amendment that the administering authority is satisfied -

Relevance to amendment application

(i) is not a change to a condition identified in the authority as a standard condition, other than

The EA does not identify any standard conditions. (i) a change that is a condition conversion; or

(ii) a change that is not a condition conversion but that replaces a standard condition of the authority with a standard condition for the environmentally relevant activity to which the authority relates; and

(ii) Does not significantly increase the level of environmental harm caused by the relevant activity; and

The application does not seek an increase to the release of visible smoke at the LNG Plant. The EA presently contains conditions which authorise flaring. Further the EA contemplates exceptions for periods outside normal operating conditions, such as for start-ups, shut-downs and maintenance. In GLNG’s view, this application principally seeks greater clarity and transparency for GLNG’s operations with respect to flaring. The air quality assessment GLNG: Air Quality Assessment of Dry and Wet Flares, July 2020 (Appendix B), demonstrates that the predicted ground level concentration of the key air pollutants from flaring events are well below the relevant air quality objectives defined by the EPP Air and the relevant guidelines and standards at all sensitive receptors (including residential receptors and protected areas) (refer to section 4.1.5).

Therefore, according to the results of the air quality assessment undertaken by Katesone, in GLNG’s view the proposed amendment would not result in an increase in the level of environmental harm caused by the activity.

(iii) Does not change any rehabilitation objectives stated in the authority in a way likely to result in significantly different impacts on environmental values than the impacts previously permitted under the authority; and

The proposed amendment does not seek to change any rehabilitation objectives.

(iv) Does not significantly increase the scale or intensity of the relevant activity; and

The amendment seeks to amend Schedule B – Air emissions of the EA to expressly authorise the duration and frequency of visible smoke emissions associated with flaring from the LNG Plant during planned


Minor amendment (threshold), for an environmental authority, means an amendment that the administering authority is satisfied -

Relevance to amendment application

and unplanned plant maintenance (start-up/shutdown), plant upsets and plant emergencies. The scale and intensity of the relevant activity approved by the EA has not changed. We say this because: • there is no change to size or throughput

of the facility; and • there are no additional release locations

or emissions proposed from that which is authorised by the EA.

Further, dispersion modelling has shown that flaring events have no significant impact on air quality at all sensitive receptors (including residential receptors and protected areas) and air quality remains well below the relevant air quality objectives of the EPP Air and the relevant guidelines and standards.

(v) Does not relate to a new relevant resource tenure for the authority that is – (iii) a new mining lease; or (iv) a new petroleum lease; or (v) a new geothermal lease under the Geothermal

Energy Act; or (vi) a new GHG injection and storage lease under the

GHG storage Act; and

The proposed amendment does not relate to a new resource tenure for the authority.

(vi) Involves an addition to the surface area for the relevant activity of no more than 10% of the existing area; and

No additional surface area is proposed as part of this amendment.

(vii) For an environmental authority for a petroleum activity – (i) if the amendment involves constructing a new pipeline

– the new pipeline does not exceed 150km; and

The amendment does not involve constructing a new pipeline more than 150km in length or extending an existing pipeline.

(ii) if the amendment involves extending an existing pipeline – the extension does not exceed 10% of the existing length of the pipeline; and

The amendment does not involve extending an existing pipeline.

(viii) If the amendment relates to a new relevant resource tenure for the authority that is an exploration permit or GHG permit - the amendment application under section 224 seeks an amended environmental authority that is subject to the standard conditions for the relevant activity or authority to the extent it relates to the permit.

The amendment does not relate to a new relevant resource tenure that is an exploration permit or GHG permit.

5.1.5 The Standard Criteria (EP Act)

The standard criteria (as defined by Schedule 4 of the EP Act) are required to be considered by the administering authority for deciding site-specific applications (Table 8).


Table 8: Standard Criteria (EP Act)

Schedule 4 EP Act Relevance

a) the following principles of environmental policy as set out in the Intergovernmental Agreement on the Environment – (i) the precautionary principle; (ii) intergenerational equity; (iii) conservation of biological diversity and

ecological integrity; and

The proposed amendment was contemplated within the context of intergenerational equity and sustainable development. The amendment will not result in significant or permanent impact to the existing environmental values of Curtis Island as demonstrated in section 4.1.5. Flaring events will be:

o minimised through the implementation of the plant optimisation measures outlined in section 2.2.1 to comply with the conditions of the LNG EA and the amendments sought by this application to conserve biological diversity and ecological integrity;

o managed in accordance with the management measures stated in the Flare Contingency Management Plan (refer to section 2.2.2); and

o recorded in accordance with the Procedure for Recording Flaring Events (refer to section 2.3);

The proposed amendment was contemplated within the context of the precautionary principle. The release of contaminants to air from flaring events as sought by this amendment application do not pose a threat of serious or irreversible environmental harm, and scientific uncertainty does not exist as to the level of potential environmental harm as demonstrated in the supporting information provided with this amendment application. Compliance with the existing and proposed conditions of the LNG EA relating to the release of contaminants to air from flaring events will continue to be met during the conduct of the authorised activities to achieve best practice environmental management (BPEM).

b) any Commonwealth or State government plans, standards, agreements or requirements about environmental protection or ecologically sustainable development

The proposed activities would be undertaken in accordance with the applicable requirements of the following:

• EP Act; • Environment Protection and Biodiversity Conservation

Act 1999 (Cth); • Nature Conservation Act 1992 (Qld); • Vegetation Management Act 1999 (Qld); • Environmental Offsets Act 2014 (Qld); • Fisheries Act 1994 (Qld); and • Planning Act 2016 (Qld).

The relevance of these Acts to this application is referenced throughout the supporting information.

c) any relevant environmental impact study, assessment or report

N/A

d) the character, resilience and values of the receiving environment

The character, resilience and values of the receiving environment are described in Section 4.0.

e) all submissions made by the application and submitters

The amendment application seeks to amend Schedule B – Air emissions of the EA to expressly authorise the duration and frequency of visible smoke emissions associated with flaring from the LNG Plant during planned and unplanned plant maintenance (start-up/shutdown), plant upsets and


Schedule 4 EP Act Relevance plant emergencies. Based on the threshold assessment completed in Table 7, GLNG is of the opinion that the EA amendment application is considered to be a minor amendment and as such, would not be subject to public notification.

f) Best Practice Environmental Management (BPEM) for activities under any relevant instrument, or proposed instrument, as follows- (i) an environmental authority; (ii) a transitional environmental program; (iii) an environmental protection order; (iv) a disposal permit; (v) a development approval;

The HRLTG Environmental Audit states: • ”..the flare has been designed to meet the best

practice design standards as outlined by the US EPA Code of Federal Regulations (ref. 40 CFR 60.18 and 40 CFR 63.11).”5

• The ”..Flaring Contingency Plan which maintains Management Measures that HRLTG consider to be in accordance with industry practice.”6

• “During process upsets or emergencies HRLTG considers Santos’ operations to be in line with industry practice.”7

g) Financial implications of the requirements under an instrument, or proposed instrument, mentioned in paragraph (g) as they would relate to the type of activity or industry carried out, or proposed to be carried out under the instrument;

GLNG will continue to provide adequate funds, equipment and staff time to comply with the conditions of the amended EA.

h) Public Interest The proposed amendment is in the public interest. The activities proposed under this amendment will allow for flaring events to occur outside of normal operating conditions and as such allow for safe and efficient continued operation of the LNG Plant.

The LNG Plant has been approved as an infrastructure facility that is of significance, particularly economically or socially, to Queensland and the Fitzroy and South West Statistical Divisions being the region in which the facility is located, under section 125(1)(f) of the SDPWO Act.

The generation and sale of LNG provides key royalties for the State of QLD. Further gas produced by the LNG Plant play an important role as a cleaner and lower-carbon emitting alternative to coal.

The amendment application seeks to amend Schedule B – Air emissions of the EA to expressly authorise the duration and frequency of visible smoke emissions associated with flaring from the LNG Plant during planned and unplanned plant maintenance (start-up/shutdown), plant upsets and plant emergencies. Dispersion modelling has shown that flaring events have no significant impact on air quality at all sensitive receptors (including residential receptors and protected areas) and air quality remains well below the

5 Page 25, Environmental Audit of Flaring at Santos Gladstone Liquefied Natural Gas (GLNG) Plant, prepared by HRL Technology Group Pty Ltd, dated May 2017 6 Page 46, Environmental Audit of Flaring at Santos Gladstone Liquefied Natural Gas (GLNG) Plant, prepared by HRL Technology Group Pty Ltd, dated May 2017 7 Page 46, Environmental Audit of Flaring at Santos Gladstone Liquefied Natural Gas (GLNG) Plant, prepared by HRL Technology Group Pty Ltd, dated May 2017


Schedule 4 EP Act Relevance relevant air quality objectives of the EPP Air and the relevant guidelines and standards.

The amendments will provide certainty to the local community around the parameters for visible smoke generation and will ensure consistent regulation and community expectations between the like LNG facilities. They will also assist in minimising visual amenity impacts to the Gladstone community.

i) Site management plan (SMP) There are no SMPs applicable to the application.

j) Integrated environmental management system (IEMS) or proposed IEMS

The Santos Management System (SMS) will be implemented for the proposed activities.

k) Other matters prescribed under a regulation The Environmental Protection Regulation 2019 (Qld) prescribes an environmental objective assessment relating to an environmental management decision as an additional matter for the standard criteria. Sections 2.0 to 4.0 address the matters raised in the environmental objective assessment.

5.2 Environmental Protection Regulation 2019 (EP Reg) Section 235 of the EP Act (major amendment) and section 241 of EP Act (minor amendment), both require the administering authority to consider any relevant regulatory requirement in deciding an amendment application. However, in accordance with section 48(2)(b) of the EP Regulation, an amendment application is not considered an environmental management decision if it relates to an application for a minor amendment of an environmental authority. Notwithstanding, the sections of the EP Regulation potentially relevant to the application are provided below.

5.2.1 Environmental Objective Assessment

Section 51 of the EP Regulation describes the matters to be considered by the administering authority in making an environmental management decision. For the purposes of this amendment application, sections 51(1)(a) and (b), require the administering authority to: • carry out an environmental objective assessment against the environmental objective and

performance outcomes mentioned in Schedule 5, Part 3, Tables 1 and 2. The objective assessment is also prescribed as an additional matter for the standard criteria (section 53A); and

• consider the environmental values declared under the EP Reg. The air quality components of Schedule 5, Part 3, Table 1 of the EP Reg, provided in Table 9, are considered relevant to this amendment application.

Table 9: Schedule 5, Part 3, Table 1- Air

Schedule 5, Part 3, Table 1 EP Reg Relevance to amendment application

Air

Environmental Objective

The activity will be operated in a way that protects the environmental values of air

Refer to Section 4.1.3

Performance Outcomes


1 There is no discharge to air of contaminants that may cause an adverse effect on the environment from the operation of the activity.

Refer to Section 4.1.4 and 4.1.5

2 All of the following- (a) fugitive emissions of contaminants

from storage, handling and processing of materials and transporting materials within the site are prevented or minimised;

The proposed amendment would not result in additional storage, handling, processing, or transport of materials within PFL 10 that may cause fugitive emissions.

(b) contingency measures will prevent or minimise adverse effects on the environment from unplanned emissions and shut down and start up emissions of contaminants to air;

Flaring events will be: o minimised through the implementation of the plant

optimisation measures outlined in section 2.2.1 to comply with the conditions of the LNG EA and the amendments sought by this application to conserve biological diversity and ecological integrity;

o managed in accordance with the management measures stated in the Flare Contingency Management Plan (refer to section 2.2.2); and

o recorded in accordance with the Procedure for Recording Flaring Events (refer to section 2.3).

Dispersion modelling has shown that flaring events have no significant impact on air quality at all sensitive receptors (including residential receptors and protected areas) and air quality remains well below the relevant air quality objectives of the EPP Air and the relevant guidelines and standards.

(c) releases of contaminants to the atmosphere for dispersion will be managed to prevent or minimise adverse effects on environmental values.

Refer to Section 4.1.4 and 4.1.5

5.2.2 Prescribed matters for particular resource activities (s24AA EP Reg)

Section 226 of the EP Act, specifies the general requirements for an EA amendment application. This includes item (1)(n) which specifies any other documents relating to the application prescribed under a regulation. Section 24AA of the EP Regulation describes the prescribed documents for an application for environmental authority for a CSG activity.

This amendment application is for the LNG Plant and associated infrastructure which are not CSG activities under the EP Act. This section of the Act is not applicable.

5.2.3 Environmental Protection Policies (EPP)

Section 51(1)(c) of the EP Regulation requires consideration of the management hierarchy, the environmental values, the quality objectives and the management intent of all EPPs. The Environmental Protection (Air) Policy 2019 is considered relevant to this amendment application (refer to the assessment provided in Table 10) and has been assessed in detail in Section 4.1.


5.2.3.1 Environmental Protection (Air) Policy 2019

Table 10: Environmental Protection (Air) Policy 2019

Legislative considerations State how the legislation has been considered and any conditions proposed

Environmental values to be enhanced or protected

a) Health and biodiversity of ecosystems

b) Human health and wellbeing c) Aesthetics of the environment

(appearance of buildings, structures and other property)

d) Agricultural use of the environment

Refer to Section 4.1.3

Air Quality Objectives: a) Consideration of the objectives as

stated in schedule 1, column 3 and how these will be achieved for the activity/s.

GLNG considers that the air quality objectives in Schedule 1, column 3 will be met for the flaring events through compliance with proposed and existing EA conditions and implementation of the management measures outlined in Sections 2.2 and 4.1.5

Management hierarchy: a) Avoid; b) Recycle c) Minimise; d) Manage.

GLNG's existing air quality management will continue to be implemented in accordance with the management hierarchy for air emissions, including:

• Avoid/Minimise – o Implementation of plant optimization measures

including the following: A trip reduction campaign, whereby every trip is

investigated and mitigations implemented to prevent/minimise future trips of the same nature;

Where practical, the transfer of refrigerant (the principal cause of visible smoke) to an on-line compressor string (including to another train if necessary) rather than flaring;

Development of strategies to avoid / minimise the requirement for plant defrosting (required for hydrate/heavier hydrocarbon removal which can result in visible smoke) outside of major shutdowns to minimise the total duration of flaring events;

Detailed planning and scheduling of maintenance activities so necessary flaring can occur at night; and

Deferring unplanned flaring until night-time, where practicable and safe to do so.

o GLNG is investigating additional plant optimisation measures to further reduce incidences of visible smoke. These are to be considered on their practicality for implementation and economic feasibility. These measures include: High rate flare purging to minimise lingering visible

smoke after a release of heavier hydrocarbons to the flare system; and

Planning simultaneous flaring where feasible from multiple sources rather than separately to reduce the total duration of flaring events.

o GLNG has developed a Flaring Contingency Management Plan (Appendix C) which includes


Legislative considerations State how the legislation has been considered and any conditions proposed

management measures to reduce the frequency and duration of gas being flared and any associated visible smoke. The management measures are presented in Section 2.2.2. The management measures are in, ‘…in accordance with industry practice.”8 As ratified by the HRL Technology Group as part of the independent environmental audit commissioned by DES in 2016.

• Manage – o The GLNG flare system is monitored in several ways.

Plant operators can observe live plant data including CCTV of the flare tips which show the size of the flame and smoke (during daylight hours), data trends, plant set points and plant alarms.

o GLNG has implemented the Procedure for Recording Flaring Events which defines the requirements for the recording of flaring events at the LNG Plant. The management of flaring events assists in ensuring compliance with the conditions of EA EPPG00712213 and in minimising the potential for community complaints relating to visible smoke. The procedure includes a Flaring Event Register which is a requirement of the Flaring Contingency Management Plan whether the flaring event is planned (normal operations or planned shut-down/start-up) or unplanned (i.e. upset).

o Air emissions monitoring will continue in accordance with the existing conditions of the EA.

o Air monitoring is undertaken by a suitably qualified and experienced person and in accordance with the conditions of the EA and the Environmental Protection Regulation 2019.


5.2.4 Additional Regulatory Requirements

Chapter 4, Part 3 of the EP Regulation includes additional regulatory requirements, which must be considered by the administering authority in making an environmental management decision where the management decision relates to an activity mentioned in either section 58 or 63 of the EP Regulation. The amendment application does not relate to an activity mentioned in section 58 or 63 of the EP Regulation.

8 Page 46, ‘Environmental Audit of Flaring at Santos Gladstone Liquefied Natural Gas (GLNG) Plant, prepared by HRL Technology Group Pty Ltd, dated May 2017


5.3 Environmental Offsets Act 2014 (Qld) N/A - The amendment application will not have a significant residual impact on a prescribed environmental matter.


Appendix A – GLNG Environmental authority visible smoke allowance review, prepared by KBR, dated July 2020

Santos GLNG l PFL 10 EPPG00712213 - Amendment Application l 26 August 2020

KBR Energy Solutions, Consulting

Level 16, 300 Murray Street, Perth, Postal address: Locked Bag #3, 66 St George’s Terrace, Perth Western Australia 6831 www.kbr.com | Tel: +61 8 6444 3000 | ABN No: 91 007 660 317

The future, designed and delivered

GLNG OPERATIONS PTY LTD

GLNG ENVIRONMENTAL AUTHORITY

VISIBLE SMOKE ALLOWANCE REVIEW

THIRD-PARTY REVIEW

July 2020

92201-SAN-RT-A-00001

Revision: 0

REV DATE DESCRIPTION PREPARED CHECKED APPROVED QA

A 26/06/2020 Issued for GLNG Review F den Boer M McLean

B 10/07/2020 Re-issued for GLNG Review F den Boer M McLean

0 15/07/2020 Issued for Use F den Boer M McLean M McLean M McLean

RELIANCE NOTICE This document is issued pursuant to an Agreement between KBR Pty Ltd and/or its subsidiary or affiliate companies (“KBR”) and GLNG OPERATIONS PTY LTD which agreement sets forth the entire rights, obligations and liabilities of those parties with respect to the content and use of the document. Reliance by any other party on the contents of the document shall be at its own risk. KBR makes no warranty or representation, expressed or implied, to any other party with respect to the accuracy, completeness, or usefulness of the information contained in this document and assumes no liabilities with respect to any other party’s use of or damages resulting from such use of any information, conclusions or recommendations disclosed in this document. This document/software contains technical information that is subject to U.S. and any other applicable export control regulations, including restrictions on the export, sale, or transfer of U.S.-origin items (goods, technology, or software) to sanctioned or embargoed countries, entities, or persons. It may not be exported or re-exported except as authorized under applicable export control requirements.

http://www.kbr.com/

92201-SAN-RT-A-00001 Page 2 of 26 Revision: 0 July 2020

CONTENTS

ABBREVIATIONS 3

EXECUTIVE SUMMARY 4

INTRODUCTION 6

BASIS AND ASSUMPTIONS 7

3.1 Plant Flare Facilities 7

3.2 Definitions 7

3.3 LNG Plant Terminology 8

3.4 EA Flare Permit 9

3.5 Flare Ringelmann Readings 10

3.6 Measured Plant Data 10

NORMAL OPERATIONS 12

PLANNED MAINTENANCE 14

MAJOR SHUTDOWN / START-UP 17

PLANT UPSET EVENTS 20

TOTAL VISIBLE SMOKE FLARING ALLOWANCE AND MANAGEMENT 23

8.1 Total Visible Smoke Flaring Events 23

8.2 Comparison to QGC EA Permit 23

8.3 Visible Smoke Flaring Management 24

8.4 EA Permit Definition Recommendations 24

REFERENCES 26


ABBREVIATIONS

APC Advanced Process Control

AS Australian Standard

BOG Boil-Off Gas

DES Department of Environment and Science

EA Environmental Authority

EDP Emergency Depressurisation

ESD Emergency Shutdown

ESDF Emergency Shutdown Inlet Feed

ESDP Emergency Shutdown Process

FG Fuel Gas

GLNG Gladstone Liquified Natural Gas

LNG Liquified Natural Gas

mtpa Millions of tonnes per annum

N2 Nitrogen

NRU Nitrogen Rejection Unit

PCV Pressure Control Valve

PSV Pressure Safety Valve

QCLNG Queensland Curtis Liquified Natural Gas

QGC Queensland Gas Company, operator for QCLNG facility

S Ringelmann Number

SDP Shutdown Process

TIAC Turbine Inlet Air Chilling System

XV Shutdown (Solenoid) Valve


EXECUTIVE SUMMARY

The GLNG facility is equipped with an elevated pipe type flare and from time to time visible smoke is

produced, as a result of maintenance or plant upset operations. GLNG’s EA currently includes

provisions for “visible smoke and particulate emissions” (black smoke) during normal operating

conditions, limited to no more than five minutes in any two hour period. However, no quantified

flaring limits have been specified for abnormal operating conditions e.g. planned maintenance, upset

conditions or shutdown / start-up. An allowance for visible smoke emissions during abnormal

operating conditions is required to reflect operating requirements at the LNG plant.

GLNG has undergone an internal exercise to identify operational scenarios which have historically

produced visible smoke emissions from the flare. This has included quantification of the expected

duration and frequency of each event with consideration of mitigation methods already employed at

the LNG plant. GLNG have requested KBR to perform a third-party review and endorsement of the

visible smoke scenarios and mitigations, which is the subject of this report.

GLNG have analysed flaring events from 4 May 2019 to 3 May 2020, as a typical year of operation,

including a major train shutdown and start-up. Events were categorised and visible smoke allowances

given for each type of event. ‘Visible’ smoke for the purposes of this review is smoke with a

Ringelmann number greater than 2 occurring in daylight hours, with night-time events excluded. As

part of this review, the events and allowances were reviewed, considering other events which may

occur based on the plant configuration and experience with other plants. Reasonable visible smoke

allowances were given to each type of event, in order to allow safe and efficient plant operation

considering the installed facilities.

The proposed allowances per category of event are summarised in Table 1.1. Most events are of a

duration less than 30 minutes, however an allowance of up to 90 minutes is required in some

instances.

Table 1.1: Visible Smoke Flaring Allowance Summary



Planned Maintenance 4 160 mins

Major Shutdown / Start-up 4 180 mins

Plant Upsets 7 130 mins

Total 15 470 mins (7.8 hrs)

These allowances are considered reasonable and reflect a balance between enabling safe and efficient

operation of the LNG plant and a strong drive to minimise visible smoke emissions affecting public

visual amenity.


The actual number of visible smoke flaring events will vary significantly from year to year, depending

on the maintenance and shutdown work planned for that year, actual plant experience with

improperly functioning valves or other equipment, and the number of plant upsets experienced.

These tend to be somewhat random in occurrence, and long periods of no upsets may be followed by

several in short succession. The overall proposed visible smoke allowance is considered reasonable to

allow for what may occur in one year, based on the plant recent experience, the level of plant

equipment and complexity and GLNG personnel expertise to manage operations. It is expected that

in many years the actual number and duration of visible smoke events will be less than the total in

Table 1.1, however this may not always be the case.

The neighbouring QGC LNG plant has an amended EA Permit which allows up to 14 events and 7 hours

of visible smoke per year. The totals in Table 1.1 slightly exceed the QGC EA limits. It should be noted

that the estimated allowances are not precise, and are based on what may occur in one year. It is

expected that in many years a reduced allowance will be adequate, and careful sustained

management of flaring activities will allow operation within the QGC EA allowances.

Visible smoke flaring management includes:

• Trip reduction campaign, with every trip investigated and mitigations implemented to

prevent/minimise future trips.

• Transfer of refrigerant to an on-line compressor string (including to the other train if necessary),

rather than flaring.

• High rate flare purge to minimise lingering visible smoke after release of heavier hydrocarbons to

the flare system.

• Strategies to avoid/minimise requirement for plant defrosting outside of major shutdowns.

• Plan simultaneous flaring where feasible from multiple sources rather than separately.

• Plan for necessary flaring at night.

• Defer unplanned flaring till night-time where possible.


INTRODUCTION

The Gladstone LNG (GLNG) plant is located at Curtis Island near Gladstone in Queensland, Australia

and is operated by GLNG Operations Pty Ltd on behalf of Joint Venture Participants including Santos,

PETRONAS, Total and KOGAS. The plant takes gas delivered from onshore gas fields and converts it

into LNG for sale. The plant commenced operation in 2015 and has a nameplate capacity of 7.8 mtpa

in two trains.

GLNG’s EA currently includes provisions for “visible smoke and particulate emissions” (black smoke)

during normal operating conditions. However, no time or event flaring limits have been specified for

abnormal operating conditions e.g. planned maintenance, upset conditions, shutdown / start-up, etc.

An allowance for visible smoke emissions during abnormal operating conditions is required to reflect

operating requirements at the LNG plant.

GLNG has undergone an internal exercise to identify operational scenarios which have historically

produced visible smoke emissions from the flare. This has included identification of the expected

duration and frequency of each event with consideration of mitigation methods already employed at

the LNG plant.

GLNG have commissioned KBR to perform an independent third-party review of the visble smoke

events associated with operation of the LNG plant. The scope of the review includes:

• Review of the operating scenarios identified by GLNG and verification to GLNG historical flaring

events;

• Review of the frequency and duration of events; and

• Review of mitigation methods for reduction of visible smoke events.

The scope of the review is limited to visibility aspects of smoke (for public visual amenity impact) and

does not address health or safety aspects.

The purpose of this report is to document the findings of this review.


BASIS AND ASSUMPTIONS

3.1 Plant Flare Facilities

The GLNG plant generally operates with no flaring apart from very minor flare pilots and flare purge

gas. Flaring is required from time to time, in order to safely perform maintenance activities and to

effectively manage plant upset scenarios including start-up, shutdown, trip events, etc.

The GLNG facility is serviced with 4 elevated flares:

• B-1901 Wet flare

• B-1902 Dry flare

• B-1903 Marine / Storage flare

• B-1906 Wet / Dry flare

The Wet, Dry and Wet / Dry flares share a common support structure and ancillaries. The Wet / Dry

flare is a common spare for the Wet and Dry flares and is not normally in use. These flares are elevated

and are subject to generate visible smoke when heavier hydrocarbons are combusted. Visible smoke

results from incomplete oxidation of heavier hydrocarbons, with some generation of carbon

particulates in addition to other combustion products. When flaring feed gas (or methane refrigerant

gas), negligible visible smoke generation is expected, as the feed gas is devoid of heavier hydrocarbons

for the GLNG facility (in contrast to many other LNG facilities). Flaring from the propane or ethylene

refrigerant circuits is expected to result in visible smoke, with some generation of carbon particulates

from these molecules.

The Marine / Storage flare is dedicated to boil-off gas from the LNG storage tanks and from LNG

tankers and associated equipment. This gas is normally essentially all methane, with a small amount

of nitrogen, and burns with a clean flame (Ringelmann number of 0 to 1).

3.2 Definitions

The review is based on Environmental Authority definitions (from Ref. 1 and 2) as follows.

“Normal operating conditions” means the ongoing operation of the LNG plant following

commissioning and excludes start-up, shut-down, maintenance or calibration of emission monitoring

devices.

This definition is assumed to exclude ‘upset’ conditions, and LNG ship management is included in

‘normal operating conditions’ (from Ref. 2).

“Flaring event” means an event where flammable gas is combusted through a flare and produces

visible smoke continuously for more than 5 minutes. (Ref. 2).

“Visible smoke” means a visible suspension of carbon or other particles in air measured by a

Ringelmann number greater than 2. (Ref. 2)


Ringelmann scores are generally given in whole numbers from 0 (clear) to 5 (black), and therefore by

this definition visible smoke is a smoke intensity of Ringelmann score of 3, 4 or 5. However, quarter

numbers are allowed according to AS 3543 (see Section 3.5), and therefore “greater than 2” can be

considered 2.25 or higher.

“Plant maintenance activities” means the maintenance shutdowns (and subsequent start-ups) where

equipment at the plant is inspected and, if needed, repaired or replaced to ensure the ongoing safe

operation of the plant (adapted from Ref. 2).

Based on Ref. 2 EA, flaring events are to be restricted if they occur in daylight hours, with night-time

flaring events being unrestricted. “Daylight hours” means those between sunrise and sunset times as

shown on the Australian Government Geoscience Australia webpage

<http://www.ga.gov.au/geodesy/astro/sunrise.jsp>. (Ref. 2).

From the EA Permit, flaring limits do not apply in the event of an emergency. An “emergency” is

defined in Ref. 5, clause 466B as:

An emergency exists if—

(a) either—

(i) human health or safety is threatened; or

(ii) serious or material environmental harm has been or is likely to be caused; and

(b) urgent action is necessary to—

(i) protect the health or safety of persons; or

(ii) prevent or minimise the harm; or

(iii) rehabilitate or restore the environment because of the harm.

Specifically for the purposes of this review, an emergency event is considered to have occurred and

resulted in flaring in situations where the pressure in a system has reached PSV set pressure resulting

in a PSV lifting, or where a hydrocarbon release to atmosphere has occurred from an item of piping

or equipment, and depressurisation to flare is initiated in order to minimise and limit the release to

atmosphere. Events of this nature are not considered as subject to flaring limits.

3.3 LNG Plant Terminology

The GLNG LNG plant consists of two independent parallel processing facilities called trains. Each train

contains the gas processing and liquefaction facilities in order to produce LNG, using three

refrigeration cycles (based on propane, ethylene and methane). Refrigeration cycles are driven by gas

turbine powered compressors, arranged in two strings for each LNG train, with each string consisting

of three gas turbine driven compressors (one each for propane, ethylene and methane). An LNG train

may operate with either one or both strings operational. Each refrigerant compressor contains

multiple stages, operating at distinct pressure levels, in order to maximise plant efficiency.



At natural gas liquefaction temperatures, substances such as water or heavier hydrocarbons will

freeze and will tend to cause blockages within the liquefaction facilities. These substances may

potentially be introduced from the feed gas or when facilities are open to the atmosphere during

maintenance activities, and must be removed to ensure proper operation of the facilities. This is

achieved in a process called defrost (or dry out following maintenance), where warm dry feed gas is

used to vaporise these substances and remove them from the facilities. Defrost gas must be directed

to flare for safe disposal. The defrost procedure may also be used in order to warm up cold sections

of the plant in order to achieve a safe working temperature prior to maintenance activities.

In order to safely conduct intrusive maintenance activities on the LNG train facilities, hydrocarbons

must first be removed. Propane and ethylene refrigerants are transferred as far as practicable to

storage, another train or another compressor string. Remaining vapours need to be flared. Residual

vapour at atmospheric pressure is still hazardous and is purged from the facilities using nitrogen

vapour. Multiple purging steps are required to ensure all affected areas have a safe very low level of

hydrocarbons prior to intrusive maintenance work being conducted. Purged vapours (a mixture of

hydrocarbons and nitrogen) are safely disposed of to the plant flare.

Following completion of intrusive maintenance work, any oxygen which has entered the processing

facilities must be removed, and this is also achieved using a nitrogen purge. When oxygen content is

reduced to a very low level, hydrocarbons may be safely introduced. The first hydrocarbons

introduced may be defrost gas (warm dry feed gas), following which the defrost gas is displaced by

refrigerant in the propane and ethylene circuits.

3.4 EA Flare Permit

3.4.1 Current Regulations

The current EA Permit (Ref. 1) limits visible smoke according to clause B19:

(B19) Visible smoke and particulate emissions must not be permitted for more than five minutes in

any two hour period during normal operating conditions.

This clause is specifically applicable to normal operating conditions, and no specific guidance is given

for limitations associated with maintenance, start-up and shutdown operations. Due to the public

visibility of the flare however, public visual amenity may be affected by visible smoke events, and this

could be limited according to clause J1:

(J1) When the administering authority advises the holder of a complaint alleging environmental

nuisance, the holder must investigate the complaint and advise the administering authority in writing

of the action proposed or undertaken in relation to the complaint.

3.4.2 Visible Smoke Flaring Event

Visible smoke is not currently defined in the GLNG EA Permit. This review is premised on visible smoke

being defined as smoke of intensity greater than Ringelmann number 2, occurring in daylight hours

(from Ref. 2). Flare smoke events occurring at night are not quantified in this report.


The definition of what constitutes ‘an event’ is important to properly quantify visible smoke

occurrences. Some events may result in sporadic flaring, with a valve to flare cycling through open

and closed positions. This should properly be considered as a single event, from a single initiating

cause. This should be clarified in the definitions, such that any allowance is not prematurely and

unreasonably exhausted. A proposed guideline is that: a single event may include multiple instances

of visible smoke appearance, provided that each instance of visible smoke occurs due to the same

underlying cause, discharges through the same valve or flare source and occurs within a two hour

window. (The two hour limit is derived from the criteria used for visible smoke allowance in normal

operations, and is considered a reasonable guideline without being overly restrictive or unlimited).

3.4.3 Visible Smoke in Normal Operations

Note that the current stipulation of EA clause B19 (Visible smoke and particulate emissions must not

be permitted for more than five minutes in any two hour period during normal operating conditions)

is assumed to remain with any revised EA Permit. This clause is not specific to daylight hours, and

therefore could be interpreted to also apply at night-time. Considering visible smoke affecting public

amenity is essentially a daytime issue, it would be reasonable to conclude that night-time flaring from

normal operations is acceptable, and has been assumed for this report.

3.5 Flare Ringelmann Readings

Visible smoke is defined in terms of a Ringelmann number, which is a method commonly used to

assess the opacity of flares and exhausts. The method requires a trained operator and is somewhat

subjective. To obtain consistent results as far as possible, the guidelines in Australian Standard AS

3543 (Ref. 3) should be followed.

The flare should be observed from a location:

• perpendicular to the direction of the plume (wind direction).

• at least 3 stack heights away from the flare base.

• have good lighting (sun at right angles to line of observation).

A video record allows later viewing and assessment of Ringelmann number and durations, which may

not be practicable for an operator required to perform other tasks at the time of flaring. The zoom on

the camera should be such as to obtain a similar reading as a manual standard reading under AS 3543

conditions.

Ringelmann (S) numbers are generally noted in whole numbers, though AS 3543 does allow estimation

to the nearest quarter number in favourable conditions.

3.6 Measured Plant Data

The GLNG plant has been operating for approximately 5 years, and can be considered to be in a stable,

mature operating phase, focused on continuous and incremental improvement and optimisation.

Operations are focused on minimising flaring due to the economic impact (particularly refrigerant is

expensive and main cause of visible smoke flaring) as well as the environmental and societal impact.


Plant flaring data over a period of 1 year from 4 May 2019 to 3 May 2020 has been assessed by GLNG.

This data records the time, duration, intensity (Ringelmann number, S) and cause of the flaring that

occurred. In total, 188 flare entries were recorded. These entries were categorised into the following

categories:

• Normal operations;

• Planned maintenance;

• Major shutdown / start-up; and

• Plant upset events.

For this third-party review, the same categorisation was used, and mostly events were kept in the

same category, with some modifications to stay in line with definitions. Proposed allowances were

reviewed to determine if these were reasonable considering plant experience, possible mitigations

and controls, as well as experience on other plants. Allowances were adjusted in some instances to

better reflect plant requirements in the future. Events which were not experienced by GLNG over the

one year of recorded data, but which have occurred on other LNG plants and could reasonably occur

at GLNG based on the plant configuration, were also noted and added to the listing of possible events.

Note that historical data was assessed by GLNG based on S = 2 or greater. This provides a conservative

basis, as visible smoke is defined as S > 2, and therefore would not include readings of 2. This

conservatism is appropriate considering the subjective nature of smoke intensity readings, and the

possibility of intermediate Ringelmann number readings.

Visible smoke flaring mitigations have been considered for each flaring event according to the

following hierarchy:

1. Avoid /eliminate event occurring.

2. Minimise flaring amount and duration.

3. Perform flaring during night hours.

4. Perform flaring during daylight hours if essential.

This follows the premise that night-time flaring, while undesirable from an operational perspective,

will not be regulated and will not be subject to allowances. Activities resulting in visible smoke flaring

that can reasonably be conducted at night are therefore not given an allowance in the following

sections.

Visible smoke flare mitigation by major plant modifications and capital works is outside the scope of

this review.


NORMAL OPERATIONS

As noted in Section 3.1, visible smoke flaring is generally not expected at the GLNG facility in normal

operations. The events recorded in Table 4.1 have been identified as occurring during normal

operations which may potentially result in visible smoke flaring. Note that short duration flaring (less

than 5 minutes per 2 hours) is not considered to constitute a flaring event (Section 3.4). As per Section

3.4, visible smoke is not permitted in normal operations, and therefore no allowances have been

made, with mitigations required to avoid this occurring. One of the mitigations is to perform flaring

activities at night, and this should be included as an allowable exception in any EA revision.

In the following tables, S is used as abbreviation for Ringlemann number (per Ref. 3.).

Table 4.1: Normal Operation Flare Events

Event Visible Smoke

Allowance Mitigation Comment

Propane Compressor Start (compressor casing drain)

0 events/yr Transfer to on-line compressor string (depressurise off-line string).

Minor drainage (after pressure reduction) will generally not result in S > 2.

Start-up at night.

Compressor start would generally be associated with an upset or major maintenance operation, however may be classified as normal operation if shutdown and start-up for production planning reasons or minor maintenance.

Procedure has been developed to minimise flaring, though total elimination is not possible.

Ethylene Compressor Start (pressure reduction maybe required)

0 events/yr

Propane reclaimer operation

0 events/yr

Efficient reclaimer column operation will minimise refrigerant losses and visible smoke generation. Most light ends can be removed with S < 2.

Operated at night where possible.

Removing non-condensables associated with a major shutdown should be considered as part of shutdown event. Reclaimer operation for built up non-condensables e.g. N2 from seals or from refrigerant supply can be considered normal operations. This is a relatively rare event and can be planned for night operation.

A leaking exchanger may cause a significant increase in requirement for reclaimer operation. This should still be able to be managed nightly. Other options e.g. piping to methane loop could be considered.

Ethylene reclaimer operation

0 events/yr

Propane refrigerant delivery via tanker

0 events/yr Frequency of tanker delivery has been reduced with implementation of seal gas recovery.

Transfer hoses gravity drained as far as possible.

Flaring involved to purge transfer hoses. Propane tankers are required to be a day activity. Minor (low rate, short duration) flare smoking as propane progresses through flare header, generally S < 2.


Event Visible Smoke

Allowance Mitigation Comment

Ethylene refrigerant delivery

0 events/yr Requirement minimised with seal gas recovery.

Night activity.

Fuel Gas (FG) purge to flare for compressor restart (where FG temperature less than agreed limit)

0 events/yr

Duration expected to be < 5 minutes

Fuel gas purge should be S = 0 to 1

Vapour return line maintain <0°C (BOG control valve opening)

0 events/yr Duration expected to be < 5 minutes

BOG flaring should be S = 0 to 1

Gas up / cool down (warm LNG ship)

0 events/yr Generally non-visible (S = 0 to 1)

Flaring of return vapour from the ship is required until the dewpoint is less than -90°C.

Generally project ships are used, with residual LNG essentially methane. Risk of occasional non-project ships with significant heavies content in future, which would result in significant visible smoke flaring. This has not occurred at GLNG to date. This is a risk to be managed with ships in this condition to be minimised. Flaring to be conducted at night as far as possible.

Heavies purge from propane, ethylene circuits

0 events/yr Make up refrigerant specification to minimise heavies content.

Plan as night activity.

Possible requirement in future (reduced purge with seal gas recovery).

Bleed down pressure in compressors when shutdown (for pressure control, not part of re-start)

0 events/yr Generally not required if pressures can be contained.

Bleed to on-line compressor string if possible.

Plan as night activity if required.

Can be required in some cases where pressure is building up in compressor circuit.

As summarised in Table 4.1, normal operation is generally conducted without visible smoke flaring.

Some events as noted in the table may result in minor flaring. Minor daytime visible smoke flaring is

consistent with the GLNG EA Permit clause B19 which allows visible smoke not exceeding 5 minutes

in a 2 hour period for normal operations. Flaring events will be planned to be conducted at night as

far as possible, though there is some risk that longer events will be required in daytime in order to

maintain safe and efficient operations (non-normal operation). This will be considered as a plant upset

event (allowances in Section 7).


PLANNED MAINTENANCE

Planned maintenance includes all ongoing maintenance activities conducted on the LNG facilities to

ensure facilities are kept in a safe, efficient and proper operating state, outside of major shutdown

maintenance periods. These maintenance activities tend to be based on short to medium term

planning resulting from plant condition monitoring, and not from long term planning.

Planned maintenance events will involve visible smoke flaring in order to create a safe working

environment, and events and proposed allowances are summarised in Table 5.1.

Table 5.1: Planned Maintenance Flare Events

Event Visible Smoke

Allowance Mitigations Comments

Project based maintenance activities.

Flaring from depressurisation where required to break containment.

0 events/yr

Project work to be conducted in major shutdown as far as practicable (unless part of a compressor string). Conduct at night as far as possible.

Minor project work is planned, and associated flaring is conducted at night.

Some risk of carryover work into day hours.

Valve testing / stroking / repair.

Flaring from depressurisation around valve.

2 events/yr, 40 mins

Valve maintenance program during major shutdowns to minimise work between shutdowns.

Valve stroking/testing to be with blocked in valve as far as possible to avoid flaring.

Conduct activities at night (not always feasible).

Valve testing for the identification of a passing valve, valve stroking to ensure valves can act when required (i.e. does not get stuck) and the planned repair of known problematic valves.

Multiple valve stroking / depressurisation to flare may be required in some instances – should be classified as 1 flare event.

Ethylene fan bank internal inspection

0 events/yr

Depressurise to other compression string. Coincide with other compressor maintenance program or major shutdown.

Conduct flaring at night.

Ethylene coolers included in compressor isolations, may require scheduled or unscheduled inspection / repair. To be included with other compressor activity.

Propane fan bank internal inspection

0 events/yr

Bank operated warm prior to isolation to minimise inventory.

Conduct flaring at night.

Configuration of propane condenser does not allow each bank to be lined up to flare, however temporary hoses may be used for purging. This requirement can be minimised by operating bank warm and eliminating condensed liquid prior to purging.


Event Visible Smoke

Allowance Mitigations Comments

Turbine Inlet Air Chilling System (TIAC) maintenance Flaring where required to break containment. For purging non-condensables and potentially for compressor start-up

0 events/yr

Transfer propane to on-line machines.

Conduct at night as far as possible.

TIACs provide additional capacity / efficiency for the main refrigerant drivers, and planned shutdowns are possible whilst maintaining production.

Some risk of carryover work into day hours.

General maintenance for refrigeration units - XV repair, inspections, strainer cleaning, etc. Flaring to depressurise equipment to be worked on.

1 event/yr, 90 mins

Train maintenance generally planned for major shutdown.

Conducted at night as far as practicable.

XV repair may be covered by valve repair above.

Allows for train shutdowns, with partial train purging, defrosting.

Only 1 event allowed for, for carryover from planned night-time work into the day. Max duration of 90 minutes is reasonable to achieve full purging (e.g. propane circuit).

P1601 defrost recorded S = 2, cold gas can sometimes result in higher S scores, possibly due to residual refrigerant or accumulated heavies in the process.

Defrosting as required for hydrate / heavies removal

1 event/yr, 30 mins

(One event also allowed for in major shutdown)

Proper operation of mol sieve beds to minimise risk of water accumulation.

Coincide with other maintenance activity.

Operation at night (risk of carryover into day).

Accumulation of heavies may be able to be avoided using a dedicated layer in the mol sieve beds – could be considered in future if this is an ongoing issue.

Operation should be S < 2 for the main part of the flaring, however will be higher when heavies are released.

Compressor start-up after maintenance activity. Flaring from casing drains etc..

0 events/yr

Transfer to other string or train if possible.

Start-up at night.

Similar to compressor start-up in normal operations.

Can take ~35 mins.

Reclaimer operation following maintenance

0 events/yr

(Allowance for displacement given in major shutdown)

Minimise volume of N2 ingress.

Efficient reclaimer operation.

Operate at night.

May not always be practicable to restrict to night operation. With reclaimer properly running, low rate venting from reclaimer can be achieved with S < 2.

The total allowance is 4 events per year, with a total duration of 160 minutes.


As in normal operations, no allowance is given for compressor start-up. The main mitigation should

be to transfer fluids from casings drains or excess pressure (if applicable) to another compressor

string. Procedures and minor modifications (e.g. bypass of check valves if required) to allow this

operation should be developed as required. Similarly an allowance is not given for reclaimer operation

as visible smoke should not be produced when this is operated efficiently.

The main mitigation for planned maintenance is to conduct essential flaring events at night as far as

possible. This may become overly restrictive in some cases, e.g. additional requirements are identified

during the day and need to be actioned to ensure safe work can continue. This is addressed under

valve testing / repair.

Historically GLNG have conducted flaring for defrost activities to manage accumulation of

components which may freeze inside equipment, and this requirement can be expected in the future.

It may not always be feasible to conduct this at night, and further work on feed gas treatment

processing to minimise the requirement for this activity may be considered.

Plant equipment in feed gas, LNG storage & loading and methane circuit are generally excluded –

flaring from these areas should be S = 0 to 1. Flaring from these areas may result in S = 2 to 3 in some

cases, as a result of residual heavies in the gas or associated with residual propane (or ethylene) in

the flare lines. At times this can result in visible smoke flaring in excess of 5 minutes and will need to

be carefully monitored. A mitigation method used by the plant is to temporarily increase the flare

purge rate following release of heavier gas / liquids into the flare line. In order to avoid additional

flaring (to reduce visible smoke), nitrogen sweep should be used where possible.


MAJOR SHUTDOWN / START-UP

Major shutdown maintenance is conducted on each LNG train once every 4 years. This involves

complete shutdown of the train, gas freeing of the entire train and internal inspection / maintenance.

This is required for safety mandated inspections, to ensure the plant remains safe, efficient and

operable. As far as possible, preventative maintenance will be conducted during this shutdown, to

minimise the risk of train shutdowns in intervening periods. Flaring is reduced by minimising the

number of shutdowns as far as practicable. This shutdown will typically be over a period of weeks and

is followed by removal of air and moisture which may have entered piping and equipment using

nitrogen followed by defrost gas (dry, warm feed gas). Refrigerants can then be introduced and the

train restarted.

Visible smoke events and allowances are summarised in Table 6.1. Allowances are on a per year basis,

(similar to the QGC EA Permit allowances which are on an annual basis). A major shutdown is not

required every year (typically every second year), and this will result in a greater allowance for

planned maintenance and other events in non-shutdown years.

Table 6.1: Major Shutdown / Start-up Flare Events

Event Visible smoke

allowance GLNG request

Mitigations Comments

Propane de-inventory

for a train 0 events

Recovery to online train minimises flaring required.

Planned night activity

Ensure all liquid is drained from all points prior to flaring.

Consider possibility to line up to low stage in on-line train to allow recovery of propane vapour.

Propane de-inventory

for a train - purges

1 event/yr

90 minutes

Planned night activity (risk of carryover to day-time)

Risk of carryover into day, e.g. if effective isolation has not been achieved at all points.

Flare allowance for carryover into day (share allowance with ethylene). Later purges with high N2 concentration should have S < 2. An allowance of 90 minutes for purging of an entire system is appropriate.

Note that each purge is considered a separate flaring event due to the time interval between purges.

Ethylene de-inventory

for a train 0 events

Recovery to online train minimises flaring required.


Consider possibility to line up to low stage in on-line train.

Ethylene de-inventory

for a train - purges

(incl. in propane purge allowance)


Risk of carryover into day, e.g. if effective isolation has not been achieved at all points. Purging should be able to be simultaneous with propane system if planned.


Event Visible smoke

allowance GLNG request

Mitigations Comments

Warm up/ defrost (to

allow safe working on

cold equipment)

1 event/yr

30 mins

Mostly at night and with S = 0 to 1, however may be periods with S > 2 when accumulated heavies are displaced.

Not always required (e.g. 2018). Total expected duration is 18 hours.

Potential to partially warm up using compressor circulation can be considered.

Dry out/ defrost to

remove any water

which may have

entered equipment

0 events/yr

Procedures to ensure water is properly drained prior to defrost operations.

Use N2 sweep where safe to do so during shutdown.

Plan for night, however typically extends to daytime.

Required procedure to remove moisture prior to restart to ensure restart can be conducted without formation of hydrates.

Defrost gas is warm, dry feed gas, expect S = 0 to 1.

Propane re-inventory

(gas displacement to

remove defrost gas)

1 event/yr

30 mins

Use reclaimer as soon as possible following main gas displacement to minimise refrigerant loss and visible smoke.

Keep daytime use < 5 mins where possible (risk of lingering visble smoke from heavies in flare line).


Initial displacement direct to flare, followed by reclaimer operation for residual gas removal. May require multiple valve openings – considered one event per start-up (per 2 hours). High system pressures may require immediate purging to flare (cannot wait for night-time).

Ethylene re-inventory

(gas displacement to

remove defrost gas)

1 event/yr

30 mins

Cooldown and start-

up 0 events/yr

Flash gas rate to be maintained within methane compressor capacity as far as possible.

Flaring expected to be S = 0 to 1 associated with feed gas

Risk of visible smoke expected to be low.

In total, 4 visible smoke events are allowed per major shutdown and start-up, with a total of 180

minutes of visible smoke. These are partly associated with the start-up, when gases introduced into

the refrigerant circuit must be purged to prevent excessive pressures being generated and proper

operation of the refrigerant systems. One event associated with over-run of planned night-time

activity into daytime is also allowed. This is reasonable considering the duration required for 5 purges

of the refrigerant circuits in order to achieve a low concentration of hydrocarbons. One event is also

associated with warm-up or defrost, which is similar to the defrost allowance in planned maintenance

(Table 5.1).


Major shutdowns, particularly if extensive internal work is involved, are typically associated with

higher volumes of gas being flared in order to safely manage the transition from a closed, pressurised

refrigerant system to an open, atmospheric system suitable for safe work and then back again.

Managing these transitions with 4 relatively brief periods of daytime flaring will require careful

planning particularly for the shutdown and de-inventory activities, to avoid the requirement for

daytime flaring. The requirement for systems to be opened to atmosphere should be minimised as far

as possible, using risk based inspection and non-intrusive inspection techniques. Systems which have

been opened to atmosphere should be sealed as soon as work is completed and defrost commenced

with N2 if possible.

An allowance of 4 flaring events is associated with specific events, however it is assumed that this

allowance can be used in any combination of events as requirements are not fully predictable and will

change as the particular requirements for each shutdown / start-up materialise.

There is a risk that two major shutdowns occur in one year, though this would not normally be

planned. A second shutdown may occur in case of equipment failure, or may be opportunistic e.g. in

case of enforced shutdown due to gas supply or demand issues. Work on common equipment such

as common flare headers and flare stack may require simultaneous shutdown of both trains. This is

not currently allowed for, and may need to be negotiated at the time (for example transfer of some

allowance from one year to another).


PLANT UPSET EVENTS

Plant upset events occur from time to time and are generally a result of the programmed actions

taken by control or safety systems, not intentionally caused by an operator. They may result from

instrumentation failure, poor response of the control system to a particular event, inadvertent action

by an operator or by maintenance personnel, etc.

Plant upset events do not include emergency events (excluded from flaring limits – see Section 3.2),

which includes events such as gas releases to atmosphere and PSV lifting.

Plant upset events recorded at the GLNG facility and other potential events are summarised in

Table 7.1. Note that for this table, visible smoke allowance in this case covers all recorded events, day

and night and will be adjusted later.

Table 7.1: Plant Upset Flare Events

Event Visible smoke

allowance1 Mitigations Comments

ESDF (black start) 1 event/yr

15 mins Minimise number of events.

EDP valves not designed to open for ESD upset, except for compressor valves depending on scenario.

ESD initiation does not necessarily directly result in flaring, however may occur due to related events such as EDP valve opening (e.g. compressors), PCV opening for rising pressures – to be minimised by control tuning and setpoint adjustment.

Flaring required for restart.

ESDP 2events/yr

30 mins

SDP 1 event/yr

15 mins

Minimise number of events.

Valves to flare not designed to open on SDP, system designed to contain gas.

Most flaring expected to be S = 0 to 1 from methane system. Sometimes recorded as S = 2

Flaring required for restart

Compressor trip 1 event/yr

15 min


Flaring minimised when trip occurs (< 5 mins).

Trip of refrigerant compressors may result in visible smoke flaring. Compressor restart may also incur flaring.

(Event originally based on BOG compressor trip, with S=3 which is unlikely to be accurate. Scenario expanded to consider other compressors).

Leaking valve /

inadvertent valve

operation - general

0 events/yr

Generally results in non-visible smoke flaring.

Flaring contained to < 5 mins.

Recorded events occurred on feed gas / BOG, with S = 0 to 1. Events on refrigerant circuits are also possible (assume covered elsewhere).

Upset during start-up /

start-up following ESD

/ SDP

2events/yr

30 min

Flaring generally contained to < 5 mins.

Start-up procedure minimises flaring.

Risk of longer duration events, complications during restart.

Includes compressor restart allowance from other events.


Event Visible smoke

allowance1 Mitigations Comments

Emergency

depressurisation /

control valve failure

1 events/yr

20 mins

Flaring contained to < 5 mins (close manual valve if possible).

Position indicators on EDP valves to alert operator.

Valve maintenance program.

Valve failures generally detected and isolated quickly.

PSV failure /

premature lifting

1 events/yr

45 mins

Regular PSV maintenance.

Instrumented protection systems minimise occurrence of PSVs opening.

Spare PSV required to be brought on-line prior to isolating a PSV – may be difficult to achieve quickly (also determination of which PSV is leaking may take some time). Frequency expected to be low (< 1/yr).

Upset during LNG ship

loading e.g. off spec

gas, high tank pressure

0 events/yr

Loading procedures, particularly during ramp-up, minimise flaring

BOG flaring generally S = 0 to 1

Gas turbine upset 1 event/yr

15 mins


Operator response to minimise durations.

Flaring may result from Unit 16 flash vessels due to rising pressures. Generally expect S = 0 to 1 for feed gas flaring, however can be recorded as S = 2 on some occasions. Propane, ethylene gas turbine trips may also result in flaring.

Repairs for fan bank

leaking tubes 0 events/yr

Planned maintenance / inspection.

Flaring at night for purging.

Leak to atmosphere constitutes an emergency situation, and priority is to make the situation safe, not on flare minimisation.

Event relates to flaring due to purging, i.e. after isolations are achieved. This should be a planned night-time event.

NRU off-specification 0 events/yr APC / operator training to minimise upsets

Occurred on numerous occasions, however S = 0 to 1.

Notes:

1. Includes allowance for day and night-time events.

The total allowance is 10 events/yr to a total of 185 minutes. These events are both day and night-

time, and it is estimated that 70% of these events occur during the daytime (related to higher

personnel activity). This results in a daytime visible smoke allowance of 7 events/yr to a total of 130

minutes. Most events are relatively short duration (~ 15 minutes), however in some cases the duration

is extended due to time for detection and potential complications occurring with the event. PSV

failures are expected to be low frequency. A longer allowance is retained as an annual allowance as

this may occur in a given year, and this allowance also provides for other events which may require

additional time to rectify and end flaring.


Plant upset events cannot be mitigated by planning for night-time operation, and a major mitigation

is avoidance of the event in the first place. GLNG have formed a reliability team tasked with event

investigation and mitigations, and this is appropriate to avoid upsets as far as possible. Each trip event

should be properly investigated, and mitigations implemented to avoid/minimise future occurrences.


TOTAL VISIBLE SMOKE FLARING ALLOWANCE AND MANAGEMENT

8.1 Total Visible Smoke Flaring Events

Based on the event allowances in Sections 4 to 7, the total visible flaring allowance is summarised in

Table 8.1.

Table 8.1: Visible Smoke Flaring Allowance Summary



Planned Maintenance 4 160 mins

Major Shutdown / Start-up 4 180 mins

Plant Upsets 7 130 mins

Total 15 470 mins (7.8 hrs)

The total number of flare entries over a one year period (4 May 2019 to 3 May 2020) was 188. Many

of these events were at night, or with a non-visible smoke flare (S = 0 to 1). Remaining entries were

further rationalised by further planning events to be conducted at night and revising procedures to

minimise visible smoke flaring, to achieve a final allowance of 15 events. In order to achieve the

proposed visible smoke limits, careful management of operations will be required.

The actual number of visible smoke flaring events will vary significantly from year to year, depending

on the maintenance and shutdown work planned for that year, actual plant experience with

improperly functioning valves or other equipment, and the number of plant upsets experienced.

These tend to be somewhat random in occurrence, and long periods of no upsets may be followed by

several in short succession. The proposed allowances should therefore be seen as indicative of what

may occur and should be flexible to be used for whatever event actually occurs in any given year. The

overall proposed visible smoke allowance is considered reasonable to allow for what may occur in one

year, considering the plant recent experience, the level of plant equipment and complexity and GLNG

personnel expertise to manage operations.

8.2 Comparison to QGC EA Permit

Visible smoke flaring limits have been established for the neighbouring QCLNG facility in their EA

Permit (Ref. 2), in essence clauses B12 and B13:

(B12) Flaring events, except for those resulting from an emergency, occurring outside of normal

operating conditions must not exceed:

a) 7 hours per annum during daylight hours; and

b) 14 times per annum during daylight hours; and

c) 30 minutes of continuous visible smoke during daylight hours except as authorised under condition

(B13).


(B13) Notwithstanding condition (B12)(c), individual flaring events must not exceed 90 minutes of

continuous visible smoke in the following circumstances:

a) A flaring event associated with a plant maintenance activity that was planned to be completed

outside of daylight hours, but was required to be undertaken during daylight hours to ensure the safe

operation of the plant; or

b) A flaring event associated with a plant maintenance activity that was not planned and was required

to be undertaken during daylight hours to ensure the safe operation of the plant.

The key limitations are a maximum of 7 hours (cumulative) of flaring per annum, and no more than

14 times or events. In most cases an individual flaring event should be less than 30 minutes but could

be up to 90 minutes duration in some cases.

The totals in Table 8.1 slightly exceed the QGC EA limits. It should be noted that the estimated

allowances are not precise, and are based on what may occur in one year. It is expected that in many

years a reduced allowance will be adequate, and careful sustained management of flaring activities

will allow operation within the QGC EA allowances.

8.3 Visible Smoke Flaring Management

In order to stay within any visible smoke flaring allowance, mitigations as noted in Sections 4 to 7

should be considered. Visible smoke flaring management includes:

• Trip reduction campaign, with every trip investigated and mitigations implemented to

prevent/minimise future trips.

• Transfer of refrigerant to an on-line compressor string (including to other train if necessary) rather

than flaring.

• High rate flare purge to minimise lingering visible smoke after release of heavier hydrocarbons to

the flare system.

• Strategies to avoid/minimise requirement for plant defrosting outside of major shutdowns.

• Plan simultaneous flaring where feasible from multiple sources rather than separately.

• Plan for necessary flaring at night.

• Defer unplanned flaring till night-time where possible.

8.4 EA Permit Definition Recommendations

It is recommended that any EA Permit revision for GLNG include the following clarifications for

definition of key terms.

1. ‘Normal operating conditions’ should be clarified to exclude ‘upset’ conditions, and include

LNG ship management.

2. “Plant maintenance activities” should not be restricted to major shutdowns, and include more

minor plant maintenance. It is recommended to not include ‘major’ in the definition in any EA

Permit revision for GLNG.


3. A single visible smoke flaring event should be clarified as potentially including multiple

instances of visible smoke appearance, provided that each instance of visible smoke occurs

due to the same underlying cause, discharges through the same valve or flare source and

occurs within a two hour window.

4. The current EA stipulation of visible smoke flaring for normal operations limited to a

maximum of 5 minutes in any 2 hours should be clarified as applying in daylight hours only.


REFERENCES

1. Permit, Environmental Protection Act 1994, Environmental Authority EPPG00712213, for GLNG,

11 February 2019.

2. Permit, Environmental Protection Act 1994, Environmental Authority EPPG00711513, for QC LNG

Operating Company Pty Ltd, 29 June 2018.

3. Use of standard Ringelmann and Australian Standard miniature smoke charts, Australian Standard

AS 3543:2014

4. Flare Documentation from GLNG Operations, Received via email from R McLaughlin 6 June 2020,

including EA Amendment Proposal.pdf, EA Amendment Table v1.xlsx and supporting

documentation.

5. Queensland Environmental Protection Act 1994

Appendix B – GLNG: Air Quality Assessment of Dry and Wet Flares, prepared by Katestone, dated July 2020


GLNG: Air Quality Assessment of Dry and

Wet Flares

Prepared for:

Santos

August 2020

Final

Prepared by:

Katestone Environmental Pty Ltd

ABN 92 097 270 276

Ground Floor, 16 Marie Street | PO Box 2217

Milton, Brisbane, Queensland, 4064, Australia

www.katestone.global

[email protected]

Ph +61 7 3369 3699

Disclaimer

https://katestone.global/report-disclaimer/

Copyright

This document, electronic files or software are the copyright property of Katestone Environmental Pty. Ltd. and the information contained therein is solely for the use of the authorised recipient and may not be used, copied or reproduced in whole or part for any purpose without the prior written authority of Katestone Environmental Pty. Ltd. Katestone Environmental Pty. Ltd. makes no representation, undertakes no duty and accepts no responsibility to any third party who may use or rely upon this document, electronic files or software or the information contained therein.

© Copyright Katestone Environmental Pty. Ltd.

Document Control

Deliverable #: D19116-3

Title: GLNG: Air Quality Assessment of Dry and Wet Flares

Version: 1.0 (Final)

Client: Santos

Document reference: D19116-3_Santos_GLNG_Flare.docx

Prepared by: Natalie Shaw and Padraig McDowell

Reviewed by: Simon Welchman

Approved by: Simon Welchman

04/08/2020

Katestone Environmental Pty Ltd D19116-3 Santos – GLNG: Air Quality Assessment of Dry and Wet Flares – Final

4 August 2020

Page i

Contents

Executive Summary ........................................................................................................................................ v 1. Introduction ....................................................................................................................................... 1 2. Dry and wet gas flares ..................................................................................................................... 2

2.1 Overview ............................................................................................................................................. 2 2.2 Air pollutants........................................................................................................................................ 2 2.3 Scenarios ............................................................................................................................................. 2 2.4 Emissions .............................................................................................................................................. 4

3. Legislative context............................................................................................................................ 8 4. Assessment methodology .............................................................................................................. 10

4.1 Overview ........................................................................................................................................... 10 4.2 Dispersion modelling ......................................................................................................................... 10

4.2.1 Flares .................................................................................................................................. 10 4.2.2 Other plant equipment .................................................................................................... 11 4.2.3 NOx to NO2 conversion .................................................................................................... 12

4.3 Presentation of results ....................................................................................................................... 12 4.4 Cumulative impacts ......................................................................................................................... 14

5. Dispersion modelling results ........................................................................................................... 15 5.1 Flares in isolation ............................................................................................................................... 15 5.2 Flare including background............................................................................................................. 25

6. Conclusions ..................................................................................................................................... 29 7. References ...................................................................................................................................... 31 Appendix A Shutdown/startup scenarios ............................................................................................ 35

A1 Flared gas quantities, mass rates, and duration of events ............................................................ 35 A2 Emissions summary ............................................................................................................................ 39 A3 Other plant equipment .................................................................................................................... 41

Appendix B Meteorological and dispersion modelling methodology............................................. 43 B1 Development of site-specific meteorology .................................................................................... 43

B1.1 TAPM meteorological simulations .................................................................................... 43 B1.2 CALMET meteorological simulations................................................................................ 44

B2 CALPUFF dispersion modelling methodology ................................................................................. 45 B2.1 Model configuration ......................................................................................................... 45 B2.2 Other plant source characteristics .................................................................................. 45

Appendix C – Dispersion modelling results ................................................................................................. 47

Tables

Table 1 Major shutdown / startup scenarios ...................................................................................................... 3 Table 2 Emission factors and emission rates for the dry and wet gas flare scenarios ..................................... 4 Table 3 Composition of hydrocarbon emissions from the flare based on US EPA AP-42 emission factors .... 4 Table 4 Emission factors for particulate matter based on Equation 1 - McEwen et al. (2012) ....................... 5 Table 5 Emission factors for PAHs ........................................................................................................................ 5 Table 6 Emission rates of NOx, CO, particulates and total hydrocarbons (g/s) .............................................. 6 Table 7 Emission rates of PAHs (g/s) .................................................................................................................... 7 Table 8 Ambient air quality objectives (Air EPP) ................................................................................................ 8 Table 9 Relevant ambient air quality objectives and standards for hydrocarbons ....................................... 9 Table 10 Source characteristics for each dispersion modelling scenario ....................................................... 10 Table 11 Other plant equipment included in the assessment .......................................................................... 11 Table 12 Location of sensitive receptors ............................................................................................................ 12 Table 13 Background concentrations used in modelling assessment ............................................................. 14 Table 14 Predicted ground-level concentrations of NO2, CO, particulates and hydrocarbons due to Scenario

1 (flare in isolation) ................................................................................................................................ 16 Table 15 Predicted ground-level concentrations of PAHs due to Scenario 1 (flare in isolation) ................... 17 Table 16 Predicted ground-level concentrations of NO2, CO, particulates and hydrocarbons due to Scenario

2 (flare in isolation) ................................................................................................................................ 19 Table 17 Predicted ground-level concentrations of PAHs due to Scenario 1 (flare in isolation) ................... 20


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Table 18 Predicted ground-level concentrations of NO2, CO, particulates and hydrocarbons due to Scenario

3 (flare in isolation) ................................................................................................................................ 22 Table 19 Predicted ground-level concentrations of PAHs due to Scenario 1 (flare in isolation) ................... 23 Table 20 Predicted cumulative impacts of NO2, CO, PM10 and PM2.5 for Scenario 1 ..................................... 26 Table 21 Predicted cumulative impacts of NO2, CO, PM10 and PM2.5 for Scenario 2 ..................................... 27 Table 22 Predicted cumulative impacts of NO2, CO, PM10 and PM2.5 for Scenario 3 ..................................... 28

Table A1 Major shutdown/start up and upset scenarios (1) ............................................................................. 35 Table A2 Major shutdown/start up and upset scenarios (2) ............................................................................. 36 Table A3 Major shutdown/start up and upset scenarios (3) ............................................................................. 37 Table A4 Major shutdown/start up and upset scenarios (4) ............................................................................. 38 Table A5 Major shutdown/start up and upset scenarios (5) ............................................................................. 39 Table A6 Summary of other plant equipment .................................................................................................... 41 Table A7 Stack characteristics of GLNG Plant included in the assessment ..................................................... 46

Table C1 Predicted concentrations of NO2, CO and PM10/PM2.5 in isolation, with plant and with plant and

background for Scenario 1 .................................................................................................................. 48 Table C2 Predicted concentrations of NO2, CO and PM10/PM2.5 in isolation, with plant and with plant and

background for Scenario 2 .................................................................................................................. 49 Table C3 Predicted concentrations of NO2, CO and PM10/PM2.5 in isolation, with plant and with plant and

background for Scenario 3 .................................................................................................................. 50

Figures

Figure 1 GLNG and sensitive receptors ............................................................................................................. 13

Figure A1 Summary of emission rates for all flare scenarios considered ........................................................... 40

Contour Plates Plate 1 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 1 – 2019

major shutdown: single train propane system de-inventory for planned maintenance activities (flare

in isolation) ............................................................................................................................................ 32 Plate 2 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 1 – 2019


in isolation) ............................................................................................................................................ 33 Plate 3 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 1 – 2019


in isolation) - all PM10 is assumed to be PM2.5 ...................................................................................... 34

Plate C1 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 1 – 2019


in isolation) ............................................................................................................................................ 52 Plate C2 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 1 – 2019


+ GLNG plant + GAMS background) .................................................................................................. 53 Plate C3 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 1 – 2019


in isolation) ............................................................................................................................................ 54 Plate C4 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 1 – 2019


+ GLNG plant + ambient background) .............................................................................................. 55 Plate C5 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 1 – 2019


in isolation). All PM10 is assumed to be PM2.5. ..................................................................................... 56 Plate C6 Predicted maximum 24-hour average ground level concentrations of PM10 due to Scenario 1 – 2019


+ GLNG plant + ambient background) .............................................................................................. 57


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Plate C7 Predicted maximum 24-hour average ground level concentrations of PM2.5 due to Scenario 1 – 2019


+ GLNG plant + ambient background) .............................................................................................. 58 Plate C8 Predicted maximum 1-hour average ground level concentrations of fluoranthene due to Scenario 1

– 2019 major shutdown: single train propane system de-inventory for planned maintenance activities

(flare in isolation)................................................................................................................................... 59 Plate C9 Predicted maximum 1-hour average ground level concentrations of propylene due to Scenario 1 –

2019 major shutdown: single train propane system de-inventory for planned maintenance activities

(flare in isolation)................................................................................................................................... 60 Plate C10 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 2 – 2016


in isolation) ............................................................................................................................................ 61 Plate C11 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 2 – 2016


+ GLNG plant + GAMS background) .................................................................................................. 62 Plate C12 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 2 – 2016


in isolation) ............................................................................................................................................ 63 Plate C13 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 2 – 2016


+ GLNG plant + ambient background) .............................................................................................. 64 Plate C14 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 2 – 2016


in isolation). All PM10 is assumed to be PM2.5. ...................................................................................... 65 Plate C15 Predicted maximum 24-hour average ground level concentrations of PM10 due to Scenario 2 – 2016


+ GLNG plant + ambient background) .............................................................................................. 66 Plate C16 Predicted maximum 24-hour average ground level concentrations of PM2.5 due to Scenario 2 – 2016


+ GLNG plant + ambient background) .............................................................................................. 67 Plate C17 Predicted maximum 1-hour average ground level concentrations of fluoranthene due to Scenario 2

– 2016 major shutdown: single train propane system de-inventory for planned maintenance activities

(flare in isolation)................................................................................................................................... 68 Plate C18 Predicted maximum 1-hour average ground level concentrations of propylene due to Scenario 2 –


(flare in isolation)................................................................................................................................... 69 Plate C19 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 3 – Upset

event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation) ........................ 70 Plate C20 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 3 – Upset

event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + GAMS

background) ......................................................................................................................................... 71 Plate C21 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 3 – Upset

event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation) ........................ 72 Plate C22 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 3 – Upset

event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + ambient

background) ......................................................................................................................................... 73 Plate C23 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 3 – Upset

Train 1 Propane and Ethylene Valves Open to Flare (flare in isolation). All PM10 is assumed to be PM2.5.

............................................................................................................................................................... 74 Plate C24 Predicted maximum 24-hour average ground level concentrations of PM10 due to Scenario 3 – Upset

event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + ambient

background) ......................................................................................................................................... 75 Plate C25 Predicted maximum 24-hour average ground level concentrations of PM2.5 due to Scenario 3 –

Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + ambient

background) ......................................................................................................................................... 76 Plate C26 Predicted maximum 1-hour average ground level concentrations of fluoranthene due to Scenario 3

– Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation) ........... 77 Plate C27 Predicted maximum 1-hour average ground level concentrations of propylene due to Scenario 3 –

Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation) ............. 78


4 August 2020

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Glossary

Term Definition

µg/m3 micrograms per cubic metre °C degrees Celsius g/s gram per second km kilometre

kg PM/103 m3 kilogram of particulate matter per 1000 cubic metres kg/Sm3 Kilogram per standard cubic metre

m/s metres per second MJ/hour megajoules per hour

MJ/m3 megajoule per cubic metres m3/s cubic metres per second

Sm3/h Standard cubic metre per hour t/h Tons per hour

Nomenclature Definition CO carbon monoxide

CO2 carbon dioxide NO2 nitrogen dioxide NOx oxides of nitrogen

PAHs Polycyclic aromatic hydrocarbons PM10 particulate matter with a diameter less than 10 micrometres PM2.5 particulate matter with a diameter less than 2.5 micrometres

Abbreviations Definition Air EPP Environmental Protection (Air) Policy 2019

DES Department of Environment and Science EDP Emergency depressurisation

ESDP Emergency shutdown process GLNG Gladstone Liquid Natural Gas facility

LNG Liquified natural gas NRU Nitrogen rejection unit SDP Shutdown process


4 August 2020

Page v

EXECUTIVE SUMMARY

Katestone Environmental Pty Ltd (Katestone) was commissioned by Santos to conduct an air quality assessment associated with the operation of flares at its Gladstone LNG facility (GLNG).

GLNG is operated under Environmental Authority Number EPPG00712213. Schedule B details conditions relating to air emissions and conditions B16 to B20 relate to flares.

There is a potential for smoke to occur due to flaring at GLNG during planned and unplanned plant maintenance and emergency situations. Major shutdowns are typically planned to occur once every four years per train.

An air quality assessment was conducted to quantify the emissions associated with the flares when they emit smoke and the potential impact of those emissions on the receiving environment.

The key air pollutants emitted from the dry and wet gas flares at the GLNG facility were found to be:

• Oxides of nitrogen (NOX) • Carbon monoxide (CO) • Hydrocarbons including:

o Methane o Ethane/ethylene o Acetylene o Propane o Propylene

• Particulate matter in the form of PM2.5 and PM10 (flare gases containing propane and ethylene) • Polycyclic Aromatic Hydrocarbons (PAHs) (flare gases containing propane and ethylene).

Katestone considered a range of potential emission scenarios and has identified three key scenarios for further assessment through dispersion modelling. They are as follows:

• Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities


• Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open.

These scenarios were identified for detailed dispersion modelling being the scenarios with maximum potential for impact as:

• Scenario 1 and Scenario 2 represent the worst-case smoking flare scenarios due to the high propane content associated with shutdown of a train.

• Scenario 3 represents the worst-case methane emissions as a result of an upset.

A conservative dispersion modelling assessment was conducted to determine the potential impacts due to flaring operations. The assessment is conservative because it is based on the following assumptions:

• All flaring events have been assumed to occur continuously at their maximum intensity for 24-hours. In reality, a flaring event may occur over a number of minutes or up to 24-hours.

• All other plant and equipment at GLNG operates at the same time as the flaring event. In reality, the smoke events are typically associated with the shutdown of one processing train and, therefore, emissions from other plant and equipment will be reduced.

Dispersion modelling of these scenarios found the following:


4 August 2020

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• Predicted ground-level concentrations NO2, CO, PM10 and PM2.5 as well as hydrocarbons were well below the relevant air quality objectives at all sensitive receptors (including residential receptors and protected areas).

• Predicted ground-level concentrations of PAHs were well below the relevant air quality objectives at all sensitive receptors (including residential receptors and protected areas).


4 August 2020

Page 1

1. INTRODUCTION



There is a potential for smoke to occur due to flaring at GLNG during planned and unplanned plant maintenance and emergency situations. Major shutdowns are typically planned to occur once every four years per train. Santos requires an air quality assessment to quantify the emissions associated with the flares when they emit smoke and the potential impact of those emissions on the receiving environment.

This report details:

• Operation of the dry and wet gas flares and likely emissions (Section 2)

• Legislative context (Section 3)

• Assessment methodology (Section 4)

• Dispersion modelling results (Section 5)

• Conclusions (Section 6).


4 August 2020

Page 2

2. DRY AND WET GAS FLARES

2.1 Overview

The principle function of the wet and dry gas flares is to safely dispose of excess gas from the process. The flare combusts the gases and the products of combustion are emitted to the atmosphere. Flaring occurs in the event of an area blowdown due to plant maintenance, or due to a plant emergency such as a fire or blocked outlet (e.g. inadvertent closure of a valve).

Wet and dry gas flares are provided to support the operational and emergency venting requirements of the process facilities. The wet gas flare system is connected to the front end of the LNG train and typically processes the blowdown of wet, warm hydrocarbon gases and some refrigerants, while the dry gas flare system is connected to the rear end of the LNG train and processes the blowdown of dry, cold hydrocarbon gases. A common structure supports the two flare stacks and a common spare flare stack.

2.2 Air pollutants

The key air pollutants emitted from the dry and wet gas flares at the GLNG facility are as follows:

• Oxides of nitrogen (NOX) • Carbon monoxide (CO) • Total hydrocarbons


• Particulates in the form of PM2.5 and PM10 (flare gases containing propane and ethylene) • Polycyclic Aromatic Hydrocarbons (PAHs) (flare gases containing propane and ethylene).

The flared gases do not include compounds containing sulfur and, therefore, sulfur related compounds (e.g. sulfur dioxide) are not likely to be emitted from the flares.

The amount of each pollutant emitted from the flare depends on the amount of and composition of the gas being flared. A summary of dry and wet gas flare scenarios considered are summarised in Section 2.3.

2.3 Scenarios

Santos conducted a review of the major shutdown/startup and upset scenarios that have occurred over the last four years. A summary of the major shutdowns and upset scenarios is presented in Appendix A. Three scenarios were identified for detailed dispersion modelling assessment being the scenarios with maximum potential for impact. These are summarised in Table 1. The summary includes the mass flow of fuel, expected duration of flaring and energy content for each flare. These scenarios have been chosen as follows:



Whilst the duration of flaring for Scenarios 1, 2 and 3 is shorter than for other scenarios, their short-term emission intensity is greatest. To avoid under-estimation of short-term impact potential, all scenarios have been assumed to occur continuously at their maximum intensity for 24 hours. Therefore, Scenarios 1, 2 and 3 represent worst-case emissions potential (refer to Section 2.4 and Appendix A).


Table 1 Major shutdown / startup scenarios

SANTOS EVENT

Scenario 1 Scenario 2 Scenario 3

EVENT 70 (visible smoke flare event) 2016 - EVENT 1a EVENT 177

2019 major shutdown: single train propane

system de-inventory for planned maintenance

activities

2016 major shutdown: single train propane

system de-inventory for planned maintenance

activities

Upset event: Emergency Depressuring Valve (EDP) valve

failed open

Wet flare Max Flared Rate (t/h) 37 53 5 Max Flared Rate (Sm3/h) 31,053 44,929 4,533 Max Flared Rate (MJ/h) 1,866,285 - - Duration (minutes) 276 46 3 Density (kg/Sm3) 1.19 1.19 1.19

Dry flare

Max Flared Rate (t/h) 144 154 249 Max Flared Rate (Sm3/h) 75,802 81,101 358,122 Max Flared Rate (MJ/h) 7,250,461 7,757,326 13,322,138 Duration (minutes) 302 46 61 Density (kg/Sm3) 1.90 1.90 0.70 Marine flare Max Flared Rate (t/h) - - - Max Flared Rate (Sm3/h) - - - Max Flared Rate (MJ/h) - - - Duration (minutes) - - - Density (kg/Sm3) - - - Total flare Max Flared Rate (t/h) 145 171 249 Max Flared Rate (Sm3/h) 76,309 95,816 358,122 Max Flared Rate (MJ/h) 7,280,942 7,757,326 13,322,138 Duration (minutes) 303 46 63 Density (kg/Sm3) 1.89 1.79 0.70 Waste Gas Max Flared Rate (t/h) 4 - 21 Max Flared Rate (Sm3/h) 2,206 - 11,320 Max Flared Rate (MJ/h) - - - Duration (minutes) 303 - 65 Density (kg/Sm3) 1.87 - 1.87 Propane Max Flared Rate (t/h) 136 149 - Max Flared Rate (Sm3/h) 71,792 78,477 - Max Flared Rate (MJ/h) 6.87E+06 7,506,311 - Duration (minutes) 129 46 - Density (kg/Sm3) 1.9 1.9 - Ethylene Max Flared Rate (t/h) 18 8 - Max Flared Rate (Sm3/h) 15,258 7,020 - Max Flared Rate (MJ/h) 917,006 421,890 - Duration (minutes) 20 46 -

Density (kg/Sm3) 1.19 1.19 -


4 August 2020

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2.4 Emissions

Because of their nature, flares cannot be practically measured in the field. Consequently, emission factors have been employed to estimate emissions. Flare emissions have been based on US EPA AP-42 documents (Chapter 13.5, Industrial Flares), other literature information and information supplied by GLNG. The USEPA AP-42 emission factors for industrial flares and the emission rates used in the assessment of each of the air pollutants: NOX, CO and total hydrocarbons (in methane equivalents) are presented in Table 2.

Table 2 Emission factors and emission rates for the dry and wet gas flare scenarios

Parameter Oxides of nitrogen Carbon monoxide Total hydrocarbons1

Emission factor (g/GJ) 29.24 133.29 60.19

Table note: 1 Measured as methane equivalent

The AP-42 emission factors document for industrial flares (chapter 13.5) provides an average distribution by volume of each hydrocarbon species that contributes to the total hydrocarbon fraction. The speciation of total hydrocarbons is reproduced in Table 3.

Table 3 Composition of hydrocarbon emissions from the flare based on US EPA AP-42 emission factors

Composition Volume (%)

Average Range

Methane 55 14 - 83

Ethane/Ethylene 8 1 - 14

Acetylene 5 0.3 - 23

Propane 7 0 - 16

Propylene 25 1- 65

Note: The composition presented is an average of a number of test results obtained under the following sets of test conditions: steam-assisted flare using high-Btu-content feed; steam-assisted using low-Btu-content feed; and air assisted flare using low-Btu-content feed. In all tests, “waste” gas was a synthetic gas consisting of a mixture of propylene and propane.

Whilst the USEPA AP-42 emission factors for industrial flares also consider particulate emissions for a range of flare types, the data cannot be easily related to a mass emission rate. Recent literature (McEwen J.D.N and Johnson M.R, 2012) has reviewed available particulate matter emission factors for flares and found their accuracy to be questionable “...or based on measurements not directly relevant to open-atmosphere flares”. McEwen et al.

(2012) studied black carbon particulate matter emission factors for gas flares. The study established a relationship between emissions of particulate matter (kg PM/103 m3 fuel) and volumetric heating value of the fuel (MJ/m3) (Equation 1).


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𝑬𝑭 𝒔𝒐𝒐𝒕 = 𝟎. 𝟎𝟓𝟕𝟖 (𝑯𝑽) − 𝟐. 𝟎𝟗 Equation 1

Where: EF is the emission factor (kg PM/103 m3 fuel) HV is volumetric heating value (MJ/m3)

The work of McEwen et al. (2012) shows that fuels with low volumetric heating values, such as methane, produce no particulate matter. Whilst, fuels with higher volumetric heating values, such as propane, can produce higher emission rates of particulate matter. Equation 1 has been used to calculate emission factors for particulate matter for each of the flaring scenarios based on the composition of flared gases (Table 4).

Table 4 Emission factors for particulate matter based on Equation 1 - McEwen et al. (2012)

Scenario Volumetric

heating value (MJ/Sm3)

Particulate matter emission factor

(kg PM/103 m3 fuel)

1 2019 major shutdown: single train Propane system de-inventory for planned maintenance activities

Dry flare 95.65 3.44

Wet flare 60.1 1.38

2 2016 major shutdown: single train Propane system de-inventory for planned maintenance activities

Dry flare 95.65 3.44

3 Upset event: Emergency Depressuring Valve (EDP) valve failed open Dry flare 37.2 0.061

Table note: 1 Methane rich fuel gas such as that to be flared in Scenario 3 is unlikely to produce particulate matter; however, an emission factor has been determined to provide a conservative assessment

Emission rates of PAHs have been derived from the data contained within the Flare Efficiency Study Report, prepared for US EPA (1983) (EPA-600/2-83-052).

A range of PAHs were measured for flares that were not smoking, lightly smoking and heavily smoking. For this study, Katestone has taken the maximum measured value across all smoking flare scenarios and used that emission factor for all flare scenarios. The assessment of PAHs will, therefore, be conservative.

Table 5 presents the emission factors for the individual PAHs that may occur from a flare.

Table 5 Emission factors for PAHs

PAHs Emission factor (µg of pollutant per µg of particulate matter)

Naphthalene 1.0E-05

Acenaphthylene 3.5E-05

Acenaphthene 1.4E-06

Fluorene 3.4E-06

Phenanthrene 6.2E-05

Anthracene 8.5E-06

Pyrene 9.6E-05

Fluoranthene 1.2E-04


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PAHs Emission factor (µg of pollutant per µg of particulate matter)

Benzanthracene 2.7E-05

Chrysene 3.2E-05

Benzo(a)pyrene 6.5E-05

1,12 benzoperylene 3.0E-05 The emission rates of NOx, CO, particulates and total hydrocarbons for each flare scenario are presented in Table 6. The emission rates of PAHs for each flare scenario are presented in Table 7. Appendix A2 presents a summary of emissions for all scenarios considered.

Table 6 Emission rates of NOx, CO, particulates and total hydrocarbons (g/s)

Scenario


2019 major shutdown: single train propane system de-

inventory for planned maintenance activities

2016 major shutdown: single train propane system

de-inventory for planned maintenance activities

Upset event: Emergency

Depressuring Valve (EDP) valve failed open

Dry flare Wet flare Dry flare Dry flare

Carbon monoxide 268 69 218 493

Oxides of nitrogen 59 15 48 108

PM10 72.4 11.9 77.5 6.0

PM2.5 72.4 11.9 77.5 6.0

Total hydrocarbons (as methane)

121 31 98 223

Methane 67 17 54 123

Ethane/ethylene 18 5 15 33

Acetylene 10 3 8 18

Propane 23 6 19 43

Propylene 80 20 65 146

Table note: 1 Methane rich fuel gas such as that to be flared in Scenario 3 is unlikely to produce particulate matter; however, a theoretical emission factor based on an extrapolation of McEwen et al. (2012) has been calculated for PM10 and PM2.5 to provide a conservative assessment 2 Emissions are based on assumption that flare emits continuously for 24-hours


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Table 7 Emission rates of PAHs (g/s)

Scenario



inventory for planned maintenance activities2

2016 major shutdown: single train propane system de-inventory

for planned maintenance activities2

Upset Train 1 EDP Valve Failed Open – No Propane and Ethylene Valves Open

to Flare2

Dry flare Wet flare Dry flare Dry flare

Naphthalene 7.4E-04 1.2E-04 7.9E-04 6.1E-05

Acenaphthylene 2.5E-03 4.2E-04 2.7E-03 2.1E-04

Acenaphthene 1.0E-04 1.7E-05 1.1E-04 8.5E-06

Fluorene 2.5E-04 4.1E-05 2.7E-04 2.1E-05

Phenanthrene 4.5E-03 7.4E-04 4.8E-03 3.7E-04

Anthracene 6.1E-04 1.0E-04 6.6E-04 5.1E-05

Pyrene 7.0E-03 1.1E-03 7.4E-03 5.7E-04

Fluoranthene 8.6E-03 1.4E-03 9.2E-03 7.1E-04

Benzanthracene 1.9E-03 3.2E-04 2.1E-03 1.6E-04

Chrysene 2.3E-03 3.8E-04 2.5E-03 1.9E-04

Benzo(a)pyrene 4.7E-03 7.8E-04 5.0E-03 3.9E-04

1,12 benzoperylene 2.2E-03 3.6E-04 2.3E-03 1.8E-04

Table note: 1 Methane rich fuel gas such as that to be flared in Scenario 3 is unlikely to produce particulate matter and therefore is unlikely to produce PAHs; however, to provide a conservative assessment, the particle emissions estimated for these scenarios in Table 7 have been speciated for PAHs 2 Emissions are based on assumption that flare emits continuously for 24-hours


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3. LEGISLATIVE CONTEXT

The Environmental Protection Act 1994 (EP Act) provides for the management of the air environment in Queensland. The EP Act gives the Department of Environment and Science (DES) the power to create Environmental Protection Policies that identify, and aim to protect, environmental values of the atmosphere that are conducive to the health and well-being of humans and biological integrity. The Environmental Protection (Air)

Policy (Air EPP) was made under the EP Act and gazetted in 1997; the Air EPP was revised and reissued in 2019.

The objective of the Air EPP is to identify the environmental values of the air environment to be enhanced or protected and to achieve the objective of the Environmental Protection Act 1994, i.e. ecologically sustainable development.

The environmental values to be enhanced or protected under the Air EPP are the qualities of the environment that are conducive to:

• protecting health and biodiversity of ecosystems

• human health and wellbeing

• protecting the aesthetics of the environment, including the appearance of building structures and other property

• protecting agricultural use of the environment.

The administering authority must consider the requirements of the Air EPP when it decides an application for an environmental authority, amendment of a licence or approval of a draft environmental management plan. Schedule 1 of the Air EPP specifies air quality indicators and objectives for contaminants that may be present in the air environment.

The Air EPP air quality objectives relevant to the key air pollutants that may be generated from the GLNG flares are presented in Table 8.

Table 8 Ambient air quality objectives (Air EPP)

Pollutant Environmental value Averaging

period

Air quality objective (µg/m³)

Number of days of exceedance

allowed per year

NO2

Health and wellbeing 1-hour 250 1

1-year 62 N/A

Health and biodiversity of ecosystems

1-year 33 N/A

CO Health and wellbeing 8-hour 11,000 N/A

PM10 Health and wellbeing 24-hour 50 N/A

1-year 25 N/A

PM2.5 Health and wellbeing 24-hour 25 N/A

1-year 8 N/A

In addition to the air pollutants detailed above, the combustion of methane, propane or ethylene in the flares is also likely to produce small quantities of hydrocarbons. The hydrocarbon emissions likely to be emitted from the flares are presented in Table 9 with their respective air quality objective. For air quality assessments, it is common practice to consider, and where appropriate adopt, an air quality objective for a specific substance from another jurisdiction if information is not available in the Air EPP. As a result, air quality objectives from the following


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guidelines and standards have been adopted where the Air EPP does not provide any assessment criteria for the hydrocarbons identified in this study:

• National Exposure Standards for Atmospheric Contaminants in the Occupational Environment (NOHSC:1003(1995))

• Texas Commission on Environmental Quality (TCEQ) Effects Screening Levels 2008.

Table 9 Relevant ambient air quality objectives and standards for hydrocarbons

Indicator Environmental

value Averaging

period

Air quality objective or

standard (µg/m³)

Source

Acenaphthylene (as acenaphthene)

Health 1-hour 1 TCEQ

Acetylene Health 1-hour 26,600 TCEQ

Anthracene Health 1-hour 0.5 TCEQ

Benz(a)anthracene Health 1-hour 0.5 TCEQ

Benzo(g,h,i)perylene Health 1-hour 0.5 TCEQ

Chrysene Health 1-hour 0.5 TCEQ

Dibenzo(a,h)anthracene (as acenaphthene)

Health 1-hour 0.5 TCEQ

Ethane Health 1-hour 12,000 TCEQ

Ethylene (Ethene) Health Simple

Asphyxiant 13.9% by volume 3

NOHSC:1003 / TECQ

Fluoranthene (Benzo(j,k)fluorene)

Health 1-hour 0.51 TCEQ

Fluorene Health 1-hour 0.52 TCEQ

Methane Health Simple

Asphyxiant 13.9% by volume 3

NOHSC:1003 / TECQ

Phenanthrene Health 1-hour 0.5 TCEQ

Propane Health 1-hour 18,000 TCEQ

Propylene Health 1-hour 8,750 TCEQ

Pyrene Health 1-hour 0.5 TCEQ 1 Air quality objective not found: Fluoranthene (or Benzo(j, k)fluorene) is a polycyclic aromatic hydrocarbon (PAH) and a structural isomer of the alternant PAH pyrene. Consequently, the same 1-hour average air quality objective of 0.5 μg/m3 has been applied for this assessment. 2 Air quality objective not found: Fluorene is a PAH, and consequently, in line with other PAHs referenced by the TCEQ Effects Screening Levels an air quality objective of 0.5 μg/m3 has been applied for this assessment. 3 To maintain oxygen content in air greater than 18% by volume


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4. ASSESSMENT METHODOLOGY

4.1 Overview

4.2 Dispersion modelling

For each scenario identified for dispersion modelling, the flare was modelled explicitly in the dispersion model CALPUFF. To take into consideration the potential impact from GLNG during each flare scenario, other plant equipment was also included in the dispersion modelling. The flare characteristics incorporated into the dispersion modelling and details of other plant equipment are discussed in the sections below. Details of model configuration are presented in Appendix B.

4.2.1 Flares

Due to the large amount of heat and buoyancy generated by the flare, it cannot be simply modelled as a stack source. To model the flare emissions appropriately, the US EPA Screen 3 methodology was used to generate the pseudo stack characteristics (effective height and diameter) for the flare. The source characteristics used in the dispersion modelling are provided in Table 10.

Table 10 Source characteristics for each dispersion modelling scenario

Parameter Units



2016 major shutdown: single

train propane system de-

inventory for planned

maintenance activities


Depressuring Valve (EDP) valve failed

open

Dry gas flare Wet gas flare Dry gas flare Dry gas flare

value value value value

Peak Energy out GJ hr-1 7,250.5 1,866.3 7,757.3 13,322.1

Energy out GJ/s 2.0 0.5 2.2 3.7

Flare mass rate kg/s 40.0 10.3 42.8 69.1

Gas Density at 0 degrees, 101.3 kPa

kg/m3 1.9 1.2 1.9 0.7

Nominal stack height m 100.0 100 100 100

Nominal flare tip diameter m 1.473 0.965 1.473 1.473

Nominal flare tip radius m 0.737 0.483 0.737 0.737

Exit velocity (modelled) m/s 20 20 20 20

Flare release temperature (modelled)

K 1,273 1,273 1,273 1,273

Effective flare height (modelled)

m 164.5 133.7 166.6 186.2

Effective flare diameter (modelled)

m 14.54 7.38 15.04 19.72

Gross heat released (cal/s) cal/s 481,591,829 123,962,845 515,258,887 884,886,179

Net heat released (cal/s) cal/s 216,716,323 55,783,280 231,866,499 398,198,780


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Parameter Units



2016 major shutdown: single

train propane system de-

inventory for planned



Depressuring Valve (EDP) valve failed

open

Dry gas flare Wet gas flare Dry gas flare Dry gas flare

value value value value

Heat not lost by radiation % 45 45 45 45

4.2.2 Other plant equipment

A conservative assessment has been conducted where it was assumed that the two trains are operating during each flaring scenario, where in reality for the major shutdowns one train will not be in operation (refer to Appendix A for overview of operating plant for the various flare scenarios). A summary of other plant equipment included in the assessment and pollutants emitted from them is summarised in Table 11. The source characteristics and locations and emission rates are based on data supplied by Santos and are summarised in Appendix B.

Table 11 Other plant equipment included in the assessment

Other plant included in cumulative assessment NOx CO PM10/PM2.5

Train 1

A1 Methane Comp. Driver Stack ✓ ✓ ✓

A2 Methane Comp. Driver Stack ✓ ✓ ✓

A3 Ethylene Comp. Driver Stack ✓ ✓ ✓

A4 Ethylene Comp. Driver Stack ✓ ✓ ✓

A5 Propane Comp. Driver Stack ✓ ✓ ✓

A6 Propane Comp. Driver Stack ✓ ✓ ✓

A7 Waste Gas / Acid Gas / Nit Vents

A8 Hot Oil heater ✓ ✓ ✓

A9 GTG Turbine Driver Stack ✓ ✓ ✓




Train 2

B1 Methane Comp. Driver Stack ✓ ✓ ✓

B2 Methane Comp. Driver Stack ✓ ✓ ✓

B3 Ethylene Comp. Driver Stack ✓ ✓ ✓

B4 Ethylene Comp. Driver Stack ✓ ✓ ✓

B5 Propane Comp. Driver Stack ✓ ✓ ✓

B6 Propane Comp. Driver Stack ✓ ✓ ✓

B7 Waste Gas / Acid Gas / Nit Vents

B8 Hot Oil heater ✓ ✓ ✓

B9 GTG Turbine Driver Stack ✓ ✓ ✓

B10 GTG Turbine Driver Stack ✓ ✓ ✓


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4.2.3 NOx to NO2 conversion

Measurements around power stations in Central Queensland show, under worst possible cases, a conversion of 25-40% of the nitric oxide to nitrogen dioxide occurs within the first ten kilometres of plume travel. During days with elevated background levels of hydrocarbons (generally originating from bush-fires, hazard reduction burning or other similar activities), the resulting conversion is usually below 50% in the first thirty kilometres of plume travel (Bofinger et al 1986).

For this assessment, a conservative ratio of 30% conversion of the NOX to NO2 has been assumed.

4.3 Presentation of results

This assessment provides predictions of nitrogen dioxide, particulate matter less than 10 microns (PM10), particulate matter less than 2.5 microns (PM2.5), carbon monoxide and hydrocarbon concentrations at sensitive receptors. Ground-level concentrations are presented for short-term 1-hour and 24-hour averaging periods as the releases from the flares are expected to range from minutes to up to 24-hours. An assessment against longer term averaging periods has therefore not been made.

The locations of these receptors are presented in Table 12 and Figure 1. The assessment has also considered potential impacts at protected areas as shown in Figure 1. The protected areas are as follows:

• Curtis Island National Park

• Curtis Island Conservation Park

• Curtis Island State Forest

• Curtis Island Environmental Management Precinct

• Targinie State Forest.

Table 12 Location of sensitive receptors

Receptor ID Easting (m)a Northing (m)a

Distance (km) and direction from

receptor to facility boundary

Orientation from GLNG Facility

R1 307,206 7371,489 10.0 WNW

R2 307,048 7370,022 9.9 W

R3 307,088 7368,713 9.6 W

R4 307,340 7367,515 9.3 WSW

R5 308,026 7366,635 8.9 WSW

R6 308,162 7365,715 8.9 WSW

R7 311,952 7365,281 5.8 SW

R8 309,092 7361,741 10.2 SW

R9 322,211 7362,744 7.0 SSE

R11 319,653 7366,625 2.4 SSE

R12 320,910 7366,472 3.4 SSE

R13 322,795 7367,791 4.4 SE

R14 323,149 7367,160 5.0 SE

R15 325,103 7366,683 7.0 SE

R16 325,438 7365,648 7.5 SE


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R17 325,396 7373,889 8.2 NE

R18 327,460 7371,898 9.3 ENE

R19 327,781 7371,714 9.5 ENE R20 328,033 7371,495 9.8 ENE

R21 - QCLNG accommodation camp 316,449 7370,786 1.0 NW

R22 - APLNG accommodation camp 316,350 7371,808 2.0 NW

Note a Coordinates in GDA94 MGA55

Contour plots of ground-level concentrations of air contaminants have been used to illustrate the spatial distribution of pollutant levels as a result of GLNG. Contour plots were created from the CALPUFF model output at each grid point in the modelling domain, for each model scenario, using a standard interpolation technique.

Figure 1 GLNG and sensitive receptors


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4.4 Cumulative impacts

For the assessment of impacts to air quality associated with NOX emissions, a two-level approach was adopted to predict the cumulative effect of emissions from the other sources from GLNG and existing, approved and other potential industrial developments in the Gladstone region. This assessment utilised the Gladstone Airshed Modelling System Version 3 (GAMSv3), a regional airshed dispersion modelling tool developed by Katestone for the Department of Infrastructure and Planning for use in planning studies. GAMv3 was used to predict background levels of NOX.

Background concentrations of CO, PM10 and PM2.5 were based on DES monitoring data in the region. No background concentrations were assumed for the assessment of hydrocarbons or PAHs in accordance with conventional practice.

The cumulative impacts for NO2, CO, PM10 and PM2.5 have also been assessed. Table 13 provides a summary of background levels used in the assessment

Table 13 Background concentrations used in modelling assessment

Pollutant Value Source

NO2 GAMS – existing and approved industries in the Gladstone region plus other LNG plants

GAMSv3

CO Modelled GLNG plant plus 250 µg/m3 DES monitoring data from Beacon Avenue, Boyne Island, 2016

PM10 Modelled GLNG plant plus 36 µg/m3 DES monitoring data average 95th percentile 24-hour from South Gladstone, 2019

PM2.5 Modelled GLNG plant plus 17.7 µg/m3 DES monitoring data for South Gladstone, 95th percentile 24-hour average for 2019


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5. DISPERSION MODELLING RESULTS

5.1 Flares in isolation

The results for all flare scenarios modelled are presented in Table 14 to Table 19. The predicted ground-level concentrations are the maximum predicted and are due to the flare in isolation.

The results show predicted ground-level concentrations of pollutants are well below the relevant air quality objectives, as follows:




• Maximum 24-hour average ground-level concentrations of PM2.5 predicted at a receptor less than 9% of the objective

• Maximum 1-hour average ground-level concentrations of hydrocarbons (ethane, ethylene, acetylene, propane and propylene) predicted at a receptor less than 0.4% of the relevant objectives

• Maximum ground-level concentrations of PAHs are well below (less than 0.7% of) the relevant objectives.

Plate 1 presents contours of the maximum 1-hour average concentrations of NO2 predicted due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities in isolation.

Plate 2 presents contours of the maximum 8-hour average concentrations of CO predicted due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities in isolation.

Plate 3 presents contours of the maximum 24-hour average concentrations of particulates (PM10 and PM2.5) predicted due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities in isolation.

Contours of predicted concentrations of NO2, CO, PM10 and PM2.5 for the three scenarios in isolation are presented in Appendix A. Contours of fluoranthene (the PAH with the highest predicted concentrations relative to air quality objectives) is also presented for all dry and wet gas scenarios.


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Table 14 Predicted ground-level concentrations of NO2, CO, particulates and hydrocarbons due to Scenario 1 (flare in isolation)

2019 major shutdown: single train propane system de-inventory for planned maintenance

activities

1-hour NO2

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour methane

1-hour ethane/

ethylene 1-hour

acetylene 1-hour

propane 1-hour

propylene

µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 R1 3.5 12.2 1.0 1.0 13.3 3.6 2.0 4.7 15.8 R2 2.1 15.0 1.3 1.3 8.0 2.2 1.2 2.8 9.5 R3 3.4 9.2 0.8 0.8 13.0 3.5 1.9 4.5 15.5 R4 3.3 8.7 0.7 0.7 12.4 3.4 1.8 4.4 14.9 R5 2.7 9.6 0.8 0.8 10.3 2.8 1.5 3.6 12.3 R6 2.7 11.5 1.0 1.0 10.1 2.8 1.5 3.6 12.1 R7 1.3 6.8 0.5 0.5 4.8 1.3 0.7 1.7 5.8 R8 2.9 6.5 0.5 0.5 10.9 3.0 1.6 3.8 13.1 R9 0.9 4.9 0.4 0.4 3.2 0.9 0.5 1.1 3.9

R11 1.0 3.3 0.3 0.3 3.6 1.0 0.5 1.3 4.3 R12 0.5 3.0 0.3 0.3 2.0 0.5 0.3 0.7 2.3 R13 0.8 3.1 0.3 0.3 3.2 0.9 0.5 1.1 3.8 R14 0.6 2.2 0.2 0.2 2.2 0.6 0.3 0.8 2.6 R15 0.8 3.1 0.3 0.3 3.2 0.9 0.5 1.1 3.8 R16 0.6 2.1 0.2 0.2 2.3 0.6 0.3 0.8 2.7 R17 0.7 2.9 0.3 0.3 2.7 0.7 0.4 0.9 3.2 R18 0.7 3.9 0.3 0.3 2.8 0.8 0.4 1.0 3.4 R19 0.7 3.9 0.3 0.3 2.6 0.7 0.4 0.9 3.1 R20 0.6 3.8 0.3 0.3 2.3 0.6 0.3 0.8 2.8

R21 - QCLNG accommodation camp 0.9 3.4 0.2 0.2 3.5 1.0 0.5 1.2 4.2 R22 - APLNG accommodation camp 1.5 3.6 0.2 0.2 5.7 1.5 0.8 2.0 6.8

Curtis Island National Park 6.5 24.2 2.0 2.0 24.6 6.7 3.6 8.6 29.3 Curtis Island Conservation Park 2.7 9.0 0.8 0.8 10.0 2.7 1.5 3.5 12.0

Curtis Island State Forest 4.5 8.7 0.8 0.8 17.1 4.7 2.5 6.0 20.4 Curtis Island Environmental Management Precinct 7.3 26.2 2.1 2.1 27.6 7.5 4.1 9.7 33.0

Targinie State Forest 3.2 13.3 1.1 1.1 12.2 3.3 1.8 4.3 14.5 Objective 250 11,000 50 25 - 12,000 26,600 18,000 8,750


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Table 15 Predicted ground-level concentrations of PAHs due to Scenario 1 (flare in isolation)


Nap

htha

lene

Ace

naph

thyl

ene

Ace

naph

then

e

Fluo

rene

Phen

anth

rene

Ant

hrac

ene

Pyre

ne

Fluo

rant

hene

Ben

zant

hrac

ene

Chr

ysen

e

Ben

zo(a

)pyr

ene

1,12

be

nzop

eryl

ene

µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 R1 1E-04 4E-04 2E-05 4E-05 8E-04 1E-04 1E-03 2E-03 3E-04 4E-04 8E-04 4E-04 R2 9E-05 3E-04 1E-05 3E-05 6E-04 8E-05 9E-04 1E-03 2E-04 3E-04 6E-04 3E-04 R3 1E-04 5E-04 2E-05 5E-05 8E-04 1E-04 1E-03 2E-03 4E-04 4E-04 9E-04 4E-04 R4 1E-04 4E-04 2E-05 4E-05 8E-04 1E-04 1E-03 1E-03 3E-04 4E-04 8E-04 4E-04 R5 1E-04 4E-04 2E-05 4E-05 7E-04 1E-04 1E-03 1E-03 3E-04 4E-04 8E-04 3E-04 R6 1E-04 4E-04 2E-05 4E-05 7E-04 9E-05 1E-03 1E-03 3E-04 3E-04 7E-04 3E-04 R7 5E-05 2E-04 6E-06 2E-05 3E-04 4E-05 4E-04 5E-04 1E-04 1E-04 3E-04 1E-04 R8 1E-04 4E-04 2E-05 4E-05 7E-04 1E-04 1E-03 1E-03 3E-04 4E-04 8E-04 3E-04 R9 3E-05 1E-04 5E-06 1E-05 2E-04 3E-05 3E-04 4E-04 9E-05 1E-04 2E-04 1E-04

R11 3E-05 1E-04 4E-06 1E-05 2E-04 3E-05 3E-04 4E-04 8E-05 1E-04 2E-04 9E-05 R12 1E-05 5E-05 2E-06 5E-06 9E-05 1E-05 1E-04 2E-04 4E-05 4E-05 9E-05 4E-05 R13 4E-05 1E-04 5E-06 1E-05 2E-04 3E-05 3E-04 4E-04 9E-05 1E-04 2E-04 1E-04 R14 2E-05 8E-05 3E-06 8E-06 1E-04 2E-05 2E-04 3E-04 6E-05 7E-05 2E-04 7E-05 R15 3E-05 1E-04 5E-06 1E-05 2E-04 3E-05 3E-04 4E-04 9E-05 1E-04 2E-04 1E-04 R16 2E-05 8E-05 3E-06 8E-06 1E-04 2E-05 2E-04 3E-04 6E-05 7E-05 1E-04 7E-05 R17 3E-05 1E-04 4E-06 1E-05 2E-04 3E-05 3E-04 4E-04 8E-05 9E-05 2E-04 9E-05 R18 3E-05 1E-04 4E-06 1E-05 2E-04 3E-05 3E-04 4E-04 8E-05 1E-04 2E-04 9E-05 R19 3E-05 1E-04 4E-06 1E-05 2E-04 2E-05 3E-04 3E-04 7E-05 9E-05 2E-04 8E-05 R20 3E-05 9E-05 4E-06 9E-06 2E-04 2E-05 2E-04 3E-04 7E-05 8E-05 2E-04 8E-05

R21 - QCLNG accommodation camp 3E-05 9E-05 4E-06 9E-06 2E-04 2E-05 2E-04 3E-04 7E-05 8E-05 2E-04 7E-05 R22 - APLNG accommodation camp 4E-05 1E-04 6E-06 1E-05 3E-04 4E-05 4E-04 5E-04 1E-04 1E-04 3E-04 1E-04

Curtis Island National Park 3E-04 1E-03 4E-05 1E-04 2E-03 2E-04 3E-03 3E-03 7E-04 9E-04 2E-03 8E-04 Curtis Island Conservation Park 1E-04 4E-04 2E-05 4E-05 7E-04 9E-05 1E-03 1E-03 3E-04 3E-04 7E-04 3E-04

Curtis Island State Forest 2E-04 6E-04 3E-05 6E-05 1E-03 2E-04 2E-03 2E-03 5E-04 6E-04 1E-03 5E-04 Curtis Island Environmental

Management Precinct 3E-04 1E-03 4E-05 1E-04 2E-03 3E-04 3E-03 4E-03 8E-04 9E-04 2E-03 9E-04


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µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 Targinie State Forest 1E-04 5E-04 2E-05 5E-05 9E-04 1E-04 1E-03 2E-03 4E-04 5E-04 9E-04 4E-04

Objective - 1 1 0.52 0.5 0.5 0.5 0.5 0.51 0.5 - 0.5


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activities

1-hour NO2

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour methane

1-hour ethane/

ethylene 1-hour

acetylene 1-hour

propane 1-hour

propylene


R11 0.2 0.8 0.1 0.1 0.9 0.2 0.1 0.3 1.1 R12 0.1 0.8 0.1 0.1 0.5 0.1 0.1 0.2 0.6 R13 0.7 1.8 0.3 0.3 2.5 0.7 0.4 0.9 3.0 R14 0.4 1.1 0.2 0.2 1.7 0.5 0.2 0.6 2.0 R15 0.4 1.1 0.2 0.2 1.6 0.4 0.2 0.6 2.0 R16 0.3 0.6 0.1 0.1 1.0 0.3 0.1 0.4 1.2 R17 0.5 1.8 0.3 0.3 1.7 0.5 0.3 0.6 2.0 R18 0.6 2.8 0.3 0.3 2.4 0.6 0.4 0.8 2.8 R19 0.6 2.5 0.3 0.3 2.1 0.6 0.3 0.7 2.5 R20 0.5 2.3 0.3 0.3 1.8 0.5 0.3 0.6 2.2






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Objective - 1 1 0.52 0.5 0.5 0.5 0.5 0.51 0.5 - 0.5


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Upset event: Emergency Depressuring Valve (EDP) valve failed open

1-hour NO2

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour methane

1-hour ethane/

ethylene 1-hour

acetylene 1-hour

propane 1-hour

propylene


R11 0.4 1.8 0.007 0.007 1.3 0.4 0.2 0.5 1.6 R12 0.2 0.7 0.003 0.003 0.8 0.2 0.1 0.3 0.9 R13 0.3 1.3 0.005 0.005 1.1 0.3 0.2 0.4 1.3 R14 0.3 1.0 0.004 0.004 1.0 0.3 0.1 0.4 1.2 R15 0.3 0.9 0.003 0.003 1.2 0.3 0.2 0.4 1.4 R16 0.2 0.5 0.002 0.002 0.8 0.2 0.1 0.3 0.9 R17 2.2 6.2 0.02 0.02 8.4 2.3 1.2 2.9 10.0 R18 1.5 7.0 0.03 0.03 5.7 1.6 0.8 2.0 6.8 R19 1.4 5.9 0.02 0.02 5.2 1.4 0.8 1.8 6.3 R20 1.3 5.0 0.02 0.02 4.7 1.3 0.7 1.7 5.7






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Objective - 1 1 0.52 0.5 0.5 0.5 0.5 0.51 0.5 - 0.5


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5.2 Flare including background

Table 20 to Table 22 summarise the cumulative maximum concentrations of NO2, CO, PM10 and PM2.5 for all gas flare scenarios. Table C1 to Table C3 in Appendix C present the predicted ground-level concentrations for each modelled dry and wet gas flare scenario as well as a breakdown of predicted concentrations due to flare in isolation, flare with other plant equipment and flare with other plant equipment plus background.

The results show that the predicted ground-level concentrations NO2, CO, PM10 and PM2.5 are well below the relevant air quality objectives for all modelled scenarios, as follows:




• Maximum 24-hour average ground-level concentrations of PM2.5 predicted at a receptor less than 94% of the objective.

Contours of predicted concentrations of NO2, CO, PM10 and PM2.5 including other plant equipment and background are presented in Appendix C.


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Table 20 Predicted cumulative impacts of NO2, CO, PM10 and PM2.5 for Scenario 1


activities

1-hour average

NO2

8-hour average

CO

24-hour average

PM10

24-hour average

PM2.5

µg/m3 µg/m3 µg/m3 µg/m3 R1 43.2 262 37.0 17.7 R2 41.5 265 37.5 17.7 R3 47.5 259 36.8 17.7 R4 48.9 259 36.7 17.7 R5 57.0 260 36.9 17.7 R6 74.5 262 37.0 17.7 R7 67.4 258 36.5 18.2 R8 73.0 257 36.6 18.3 R9 50.9 255 36.4 18.1

R11 40.2 259 36.4 18.1 R12 45.6 256 36.3 18.0 R13 28.5 255 36.3 18.0 R14 30.7 255 36.2 17.9 R15 23.0 255 36.3 18.0 R16 17.5 253 36.2 17.9 R17 27.5 254 36.3 17.9 R18 20.4 255 36.4 18.1 R19 20.0 255 36.4 18.1 R20 20.2 255 36.4 18.1 R21 53.2 271 37.6 19.2 R22 50.6 268 36.9 18.5

Curtis Island National Park 36.0 276 38.0 19.7 Curtis Island Conservation Park 44.8 259 36.8 18.5

Curtis Island State Forest 38.5 260 36.8 18.5 Curtis Island Environmental Management Precinct 75.4 397 42.0 23.6

Targinie State Forest 63.2 264 37.3 19.0 Objective 250 11,000 50 25


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2016 major shutdown: single train propane system de-inventory for planned


1-hour average

NO2

8-hour average

CO

24-hour average

PM10

24-hour average

PM2.5


R11 40.2 259 36.4 18.1 R12 45.6 256 36.3 17.9 R13 28.5 255 36.3 18.0 R14 30.7 255 36.2 17.9 R15 23.0 254 36.3 18.0 R16 17.5 253 36.2 17.9 R17 27.5 254 36.4 18.0 R18 20.4 253 36.4 18.0 R19 20.0 253 36.4 18.0 R20 20.2 253 36.4 18.0 R21 53.2 271 37.6 19.2 R22 50.6 268 36.9 18.5


Curtis Island State Forest 38.4 257 37.0 18.7 Curtis Island Environmental Management

Precinct 75.4 397 41.9 23.6

Targinie State Forest 63.2 262 37.3 19.0

Objective 250 11,000 50 25


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1-hour average

NO2

8-hour average

CO

24-hour average

PM10

24-hour average

PM2.5


R11 40.2 259 36.3 18.0 R12 45.6 256 36.3 17.9 R13 28.5 255 36.2 17.9 R14 30.7 255 36.2 17.9 R15 23.0 254 36.2 17.8 R16 17.5 253 36.1 17.8 R17 27.5 256 36.1 17.8 R18 20.4 257 36.1 17.8 R19 20.0 256 36.1 17.8 R20 20.2 255 36.1 17.8 R21 53.2 271 37.6 19.2 R22 50.6 268 36.9 18.5


Curtis Island State Forest 38.4 264 36.3 18.0 Curtis Island Environmental Management Precinct 75.4 397 41.9 23.6

Targinie State Forest 63.2 265.3 36.4 18.1 Objective 250 11,000 50 25


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6. CONCLUSIONS



There is a potential for smoke to occur due to flaring at GLNG during planned and unplanned plant maintenance and emergency situations. Major shutdowns are typically planned to occur once every four years per train.

An air quality assessment was conducted to quantify the emissions associated with the flares when they emit smoke and the potential impact of those emissions on the receiving environment.

The key air pollutants emitted from the dry and wet gas flares at the GLNG facility were found to be:

• Oxides of nitrogen (NOX) • Carbon monoxide (CO) • Hydrocarbons including:


• Particulate matter in the form of PM2.5 and PM10 (flare gases containing propane and ethylene) • Polycyclic Aromatic Hydrocarbons (PAHs) (flare gases containing propane and ethylene).

Katestone considered a range of potential emission scenarios and has identified three key scenarios for further assessment through dispersion modelling. They are as follows:



• Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open.

These scenarios were identified for detailed dispersion modelling being the scenarios with maximum potential for impact as:



A conservative dispersion modelling assessment was conducted to determine the potential impacts due to flaring operations. The assessment is conservative because it is based on the following assumptions:

• All flaring events have been assumed to occur continuously at their maximum intensity for 24-hours. In reality, a flaring event may occur over a number of minutes or up to 24-hours.

• All other plant and equipment at GLNG operate at the same time as the flaring event. In reality, the smoke events are typically associated with the shutdown of one processing train and, therefore, emissions from other plant and equipment will be reduced.


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Dispersion modelling of these scenarios found the following:

• Predicted ground-level concentrations NO2, CO, PM10 and PM2.5 as well as hydrocarbons were well below the relevant air quality objectives at all sensitive receptors (including residential receptors and protected areas).

• Predicted ground-level concentrations of PAHs were well below the relevant air quality objectives at all sensitive receptors (including residential receptors and protected areas).


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7. REFERENCES

Bofinger ND, Best PR, Cliff DI and Stumer LJ, 1986. “The oxidation of nitric oxide to nitrogen dioxide in power

station plumes”, Proceedings of the Seventh World Clean Air Congress, Sydney, 384-392

McEwan J.D.N and Johnson M.R, 2012, Black Carbon Particulate Matter Emission Factors for Buoyancy Driven Associated Flares, Journal of the Air & Waste Management Association

National Occupational Health and Safety Commission, 1995. Adopted National Exposure Standards for Atmospheric Contaminants in the Occupational Environment (NOHSC:1003(1995))

Texas Commission on Environmental Quality, 2008, Effects Screening Levels, Texas, United States.

United States Environmental Protection Agency (USEPA), 2018, Industrial Flares, AP-42 Chapter 13.5 USEPA Office of Air Quality Planning and Standards


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Plate 1 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


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Plate 2 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


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Plate 3 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation) - all PM10 is assumed to be PM2.5

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

PM10: 50 µg/m³

PM2.5: 25 µg/m³

Prepared by:

P McDowell

Date:

2020


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APPENDIX A SHUTDOWN/STARTUP SCENARIOS

A1 FLARED GAS QUANTITIES, MASS RATES, AND DURATION OF EVENTS

This section presents the major shutdown/startup and upset scenarios that have occurred over the last four years at GLNG. Table A1 to Table A5 summarise the mass flow of fuel, expected duration of flaring and energy content. Information is provided for the dry, wet and marine flares for each scenario.

Table A1 Major shutdown/start up and upset scenarios (1)

GLNG EVENT EVENT 70 (start of

de-inventory) EVENT 70 (visible

smoke) EVENT 82 EVENT 83/84 Train 1 shutdown

2019 Train 1 shutdown



2019

Description

Flaring Train 1 Propane system,

Shutdown activities (start of de-inventory)

Flaring Train 1 Propane system de-inventory, Shutdown

activities

Purging procedure for Propane

system (train1 Start up)

Ethylene vapour re-inventory

Wet flare Max Flared Rate (t/h) 165 37 174 61 Max Flared Rate (Sm3/h) 139,398 31,053 146,594 51,221 Max Flared Rate (MJ/h) - 1,866,285 - 3,078,382 Duration (minutes) 837 276 75 99 Density (kg/Sm3) 1.19 1.19 1.19 1.19 Dry flare Max Flared Rate (t/h) 54 144 97 85 Max Flared Rate (Sm3/h) 77,494 75,802 81,276 121,718 Max Flared Rate (MJ/h) 2,882,777 7,250,461 4,884,688 4,527,910 Duration (minutes) 1,342 302 75 111 Density (kg/Sm3) 0.70 1.90 1.19 0.70 Marine flare Max Flared Rate (t/h) - - - - Max Flared Rate (Sm3/h) - - - - Max Flared Rate (MJ/h) - - - - Duration (minutes) - - - - Density (kg/Sm3) - - - - Total flare Max Flared Rate (t/h) 167 145 247 104 Max Flared Rate (Sm3/h) 141,533 76,309 207,630 121,718 Max Flared Rate (MJ/h) 2,882,777 7,280,942 4,884,688 5,369,158 Duration (minutes) 1,409 303 75 111 Density (kg/Sm3) 1.18 1.89 1.19 0.85 Waste Gas Max Flared Rate (t/h) 11 4 - 2 Max Flared Rate (Sm3/h) 6,003 2,206 - 1,324 Max Flared Rate (MJ/h) - - - - Duration (minutes) 1,413.5 303 - 5 Density (kg/Sm3) 1.873 1.87 - 1.87 Propane Max Flared Rate (t/h) - 136 - 54 Max Flared Rate (Sm3/h) - 71,792 - 28,471 Max Flared Rate (MJ/h) - 6.87E+06 - 2,723,274 Duration (minutes) - 129 - 1.0 Density (kg/Sm3) - 1.9 - 1.9 Ethylene Max Flared Rate (t/h) - 18 30 2 Max Flared Rate (Sm3/h) - 15,258 25,261 1,273 Max Flared Rate (MJ/h) - 917,006 1,518,196 76,536 Duration (minutes) - 20 75 60 Density (kg/Sm3) - 1.19 1.19 1.19


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GLNG event EVENT 85 EVENT 88 2016 - EVENT 1a 2016 - EVENT 1b

Train 1 shutdown 2019

Train 1 shutdown 2019

Train 1 shutdown Propane Peak

Train 1 shutdown Peak Wet Flare

Description

Ethylene vapour re-inventory

Note Event 85 and 88 scenarios overlap

in time

Ethylene vapour re-inventory Note Event 85 and 88 scenarios

overlap in time

Train 1 Unit 15 warm ethylene circuit

defrost, Unit 16 warm methane and NRU

system defrost, depressuring Unit 12

& 13




& 13 Note peak methane event from dry flare

Wet flare Max Flared Rate (t/h) 8 14 53 9

Max Flared Rate (Sm3/h) 6,896 11,567 44,929 7,874 Max Flared Rate (MJ/h) 414,450 695,177 - -

Duration (minutes) 72 43 46 46 Density (kg/Sm3) 1.19 1.19 1.19 1.19

Dry flare Max Flared Rate (t/h) 52 54 154 198

Max Flared Rate (Sm3/h) 75,299 77,661 81,101 284,253 Max Flared Rate (MJ/h) 2,801,123 2,888,989 7,757,326 10,574,212


Marine flare Max Flared Rate (t/h) - - - -

Max Flared Rate (Sm3/h) - - - - Max Flared Rate (MJ/h) - - - -

Duration (minutes) - - - - Density (kg/Sm3) - - - -

Total flared Max Flared Rate (t/h) 59 59 171 198



Waste gas Max Flared Rate (t/h) 3 3 - -

Max Flared Rate (Sm3/h) 1,420 1,517 - - Max Flared Rate (MJ/h) - - - -

Duration (minutes) 37 115 - - Density (kg/Sm3) 1.87 1.87 - -

Propane Max Flared Rate (t/h) - - 149 4

Max Flared Rate (Sm3/h) - - 78,477 2,270 Max Flared Rate (MJ/h) - - 7,506,311 217,097

Duration (minutes) - - 46 1,414 Density (kg/Sm3) - - 1.9 1.9

Ethylene Max Flared Rate (t/h) 3 3 8 5

Max Flared Rate (Sm3/h) 2,612 2,612 7,020 4,003 Max Flared Rate (MJ/h) 156,964 156,964 421,890 240,563



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GLNG event 2016 - EVENT 1c 2017 - EVENT 6 EVENT 60 EVENT 109/110 Train 1 shutdown

Peak Ethylene Train 1 Shutdown Upset Upset

Description




& 13

Propane and Ethylene re-inventory T1 TC-1611 Trip Ethylene flare event

Wet flare Max Flared Rate (t/h) 69 270 23 4

Max Flared Rate (Sm3/h) 57,663 228,031 19,685 3,207 Max Flared Rate (MJ/h) 3,465,576 - - -

Duration (minutes) 541 1,213 38 56 Density (kg/Sm3) 1.19 1.19 1.19 1.19




Marine flare Max Flared Rate (t/h) - - 45.99267216 -

Max Flared Rate (Sm3/h) - - 65,275 - Max Flared Rate (MJ/h) - - 2,345,326 -

Duration (minutes) - - 12 - Density (kg/Sm3) - - 1 -




Waste gas Max Flared Rate (t/h) 3 3 - -

Max Flared Rate (Sm3/h) 1,420 1,517 - - Max Flared Rate (MJ/h) - - - -


Propane Max Flared Rate (t/h) - 7 29 -

Max Flared Rate (Sm3/h) - 3,502 15,665 - Max Flared Rate (MJ/h) - - - -

Duration (minutes) - 1,113 76 - Density (kg/Sm3) - 1.87 1.87 -

Ethylene Max Flared Rate (t/h) 8 64 - -

Max Flared Rate (Sm3/h) 4,103 33,783 - - Max Flared Rate (MJ/h) 392,472 3,231,373 - -



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GLNG event EVENT 125 EVENT 165 EVENT 177 EVENT 180 Upset Upset Upset Upset

Description EDP on 3415-C-1521 tripped open SDP on train 1

Train 1 EDP valve 15075 failed open. Note no propane or

ethylene valves open to flare.

Two Train ESDP - Black Start

Wet flare Max Flared Rate (t/h) 11 - 5 98

Max Flared Rate (Sm3/h) 9,510 - 4,533 82,232 Max Flared Rate (MJ/h) - - - 4,942,143

Duration (minutes) 173 - 3 142 Density (kg/Sm3) 1.19 - 1.19 1.19


Max Flared Rate (Sm3/h) 994 11,478 358,122 16,448 Max Flared Rate (MJ/h) 59,739 426,982 13,322,138 611,866


Marine flare Max Flared Rate (t/h) - - - 16

Max Flared Rate (Sm3/h) - - - 23,503 Max Flared Rate (MJ/h) - - - 844,448

Duration (minutes) - - - 124 Density (kg/Sm3) - - - 1


Max Flared Rate (Sm3/h) 10,188 11,478 358,122 103,497 Max Flared Rate (MJ/h) 59,739 426,982 13,322,138 5,719,505


Waste gas Max Flared Rate (t/h) 19 11 21 7

Max Flared Rate (Sm3/h) 10,150 5,693 11,320 3,692 Max Flared Rate (MJ/h) - - - -


Propane Max Flared Rate (t/h) - - - -

Max Flared Rate (Sm3/h) - - - - Max Flared Rate (MJ/h) - - - -

Duration (minutes) - - - - Density (kg/Sm3) - - - -

Ethylene Max Flared Rate (t/h) 12 - - 24

Max Flared Rate (Sm3/h) 10,188 - - 20,350 Max Flared Rate (MJ/h) 612,299 - - 1,223,035

Duration (minutes) 0 - - 7 Density (kg/Sm3) 1.19 - - 1.19


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GLNG event 2016 - EVENT 3 Upset Event - Power upset

Description Power generation load shedding caused Train 1 and Train 2 SDP

Wet flare Max Flared Rate (t/h) 62

Max Flared Rate (Sm3/h) 89,330 Max Flared Rate (MJ/h) 3,323,076

Duration (minutes) 841 Density (kg/Sm3) 0.70

Dry flare Max Flared Rate (t/h) 107



Marine flare Max Flared Rate (t/h) 20


Duration (minutes) 110 Density (kg/Sm3) 1

Total flared Max Flared Rate (t/h) 181



Waste gas Max Flared Rate (t/h) 38

Max Flared Rate (Sm3/h) 20,236 Max Flared Rate (MJ/h) -


Propane Max Flared Rate (t/h) 130


Duration (minutes) 841 Density (kg/Sm3) 2

Ethylene Max Flared Rate (t/h) 1

Max Flared Rate (Sm3/h) 627 Max Flared Rate (MJ/h) 37,653


A2 EMISSIONS SUMMARY

Figure A1 presents a summary of emissions of particulates (PM10 and PM2.5), NOx, total hydrocarbons and total PAHs for all scenarios considered for the dry and wet flares.


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Figure A1 Summary of emission rates for all flare scenarios considered


A3 OTHER PLANT EQUIPMENT

A summary of other plant equipment operating for each scenario is provided below. Note that all equipment was assumed to be operating for the purposes of dispersion modelling.

Table A6 Summary of other plant equipment

No. Description

Major Shutdown / Start-ups Upset Scenarios

EVEN

T 70

EVEN

T 82

EVEN

T 83

EVEN

T 84

EVEN

T 85

EVEN

T 88

2016

- EV

ENT

1a

2016

- EV

ENT

1b

2016

- EV

ENT

1c

2017

- EV

ENT

6

EVEN

T 60

EVEN

T 10

9

EVEN

T 11

0

EVEN

T 12

5

EVEN

T 16

5

EVEN

T 17

7

EVEN

T 18

0

2016

- EV

ENT

3

Train 1 Air Emission Point Locations

A1 Methane Comp. Driver Stack x x x

A2 Methane Comp. Driver Stack x x x x x x x

A3 Ethylene Comp. Driver Stack x x x x

A4 Ethylene Comp. Driver Stack x x x x x x x

A5 Propane Comp. Driver Stack x x x x x x

A6 Propane Comp. Driver Stack x x x x

A7 Waste Gas / Acid Gas / Nit Vents x x x x x x x x x x x x x x x x x x

A8 Hot Oil heater x x x x x x x x x x x x x x

A9 GTG Turbine Driver Stack x x x x

A10 GTG Turbine Driver Stack x x x x x x x x x x x

A11 GTG Turbine Driver Stack x

A12 GTG Turbine Driver Stack x x x x x

A13 Wet Gas Flare x x x x x x x x x x x x x x x x x


No. Description

Major Shutdown / Start-ups Upset Scenarios

EVEN

T 70

EVEN

T 82

EVEN

T 83

EVEN

T 84

EVEN

T 85

EVEN

T 88

2016

- EV

ENT

1a

2016

- EV

ENT

1b

2016

- EV

ENT

1c

2017

- EV

ENT

6

EVEN

T 60

EVEN

T 10

9

EVEN

T 11

0

EVEN

T 12

5

EVEN

T 16

5

EVEN

T 17

7

EVEN

T 18

0

2016

- EV

ENT

3

A14 Marine Flare x x x

A15 Dry Gas Flare x x x x x x x x x x x x x x x x x x

A16 Backup Wet and Dry Gas Flare

Train 2 Air Emission Point Locations

B1 Methane Comp. Driver Stack x x x x x x x x x x x x x x x x

B2 Methane Comp. Driver Stack x x x x x x x x x x x x x x

B3 Ethylene Comp. Driver Stack x x x x x x x x x x x x x x x x

B4 Ethylene Comp. Driver Stack x x x x x x x x x x x x x x

B5 Propane Comp. Driver Stack x x x x x x x x x x x x x x x x

B6 Propane Comp. Driver Stack x x x x x x x x x x x x x x

B7 Waste Gas / Acid Gas / Nit Vents x x x x x x x x x x x x x x x x x x

B8 Hot Oil heater x x x x x x

B9 GTG Turbine Driver Stack x x x x x x x x x x x x

B10 GTG Turbine Driver Stack x x x x x x x x x x x x x


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APPENDIX B METEOROLOGICAL AND DISPERSION MODELLING

METHODOLOGY

Air dispersion modelling was conducted using a two-stage approach. Firstly, the CSIRO’s meteorological model,

TAPM (The Air Pollution Model) Version 4.0.5 (Hurley 2005), was used to simulate the regional meteorology in the Gladstone region. Further refinement of the wind field was then made through the CALMET Version 6.3 meteorological pre-processor. Secondly, the CALPUFF plume dispersion model was used to predict ground-level concentrations of air pollutants emitted from GLNG.

B1 DEVELOPMENT OF SITE-SPECIFIC METEOROLOGY

B1.1 TAPM meteorological simulations

TAPM was developed by the CSIRO and has been validated by the CSIRO, Katestone Environmental and others for many locations in Australia, Southeast Asia and in North America (see www.dar.csiro.au/TAPM/ for more details on the model and validation results from the CSIRO). Katestone Environmental has used the TAPM model throughout Australia as well as in parts of New Caledonia, the United States of America, Bangladesh and Vietnam. This model generally has performed well for simulating winds in a region.

TAPM required synoptic meteorological information for the Gladstone region. This information was generated by a global model similar to the large-scale models used to forecast the weather. The data are supplied by the BoM on a grid resolution of approximately 75 km, and at elevations of 100 m to five kilometres above the ground. TAPM uses this synoptic information, along with specific details of the location such as surrounding terrain, land-use, soil moisture content and soil type to simulate the meteorology of a region as well as at a specific location.

TAPM solves the fundamental fluid dynamics equations to predict meteorology at a mesoscale (20 kilometre to 200 kilometre) and at a local scale (down to a few hundred metres). TAPM includes parameterisations for cloud/rain micro-physical processes, urban/vegetation canopy and soil, and radiative fluxes. TAPM is skilled at simulating the flows important to regional and local scale meteorology, such as the southeast trade winds and sea breezes.

TAPM was configured as follows:

• Mother domain of 30 km with 3 nested daughter grids of 10 km, 3 km and 1 km

• 40 x 40 grid points for all modelling domains resulting in a 40 x 40 km grid at 1 kilometre resolution

• 25 vertical levels, from the surface up to an altitude of 8000 metres above ground level

• Geosciences Australia 9 second DEM terrain data

• The TAPM defaults for sea surface temperature

• Default options selected for advanced meteorological inputs

• Year modelled: 1 April 2006 to 31 March 2007

• Landuse and coastline data was refined based on high resolution images sourced from Google Earth and vegetation maps obtained from DES

• Local data assimilation using observations from three regionally representative sites.


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The land use for the inner grid required significant modification due to the coarseness of the TAPM dataset. Representative data was derived from vegetation maps obtained from DES and from aerial imaging by Google Earth. The coastline was also re-defined in the database to better represent the complex coastline around Curtis Island. Detailed 9-second arc DEM elevation data (resolution approximately 100 metre) was obtained from Geosciences Australia for this modelling domain.

TAPM was used as the prognostic mesoscale meteorological model to provide three-dimensional hourly meteorological fields to CALMET, a diagnostic meteorological model and wind field pre-processor for the CALPUFF air dispersion model. The CALMET modelling grid was positioned within the TAPM simulation, effectively becoming a fifth nested grid. The three-dimensional meteorological fields generated by TAPM were then input into CALMET model to generate a fine resolution meteorological field.

B1.2 CALMET meteorological simulations

CALMET is an advanced non-steady-state diagnostic three-dimensional meteorological model with micro-meteorological modules for overwater and overland boundary layers. The model is the meteorological pre-processor for the CALPUFF dispersion model. CALMET is capable of assimilating hourly meteorological data from multiple sites within the modelling domain, and can also be initialised with the gridded three-dimensional prognostic output from other meteorological models such as TAPM. This can improve dispersion model output, particularly over complex terrain as the near surface meteorological conditions are calculated for each grid point.

CALMET was used to simulate meteorological conditions around Curtis Island. The modelling domain was setup to be nested within the one kilometre TAPM domain. CALMET treats the prognostic model output as the initial guess field for the diagnostic model wind fields. CALMET then adjusts the initial guess field for the kinematic effects of terrain, slope flows, blocking effects and 3-dimensional divergence minimisation. The coupled approach unites the mesoscale prognostic capabilities of TAPM with the refined terrain and land use capabilities of CALMET.

The use of the three-dimensional wind field provides a complete set of meteorological variables for every grid point and vertical level for each hour of the simulation period. This is a significant improvement in modelling approach to the method of data assimilation from discrete surface stations. No data assimilation was used in CALMET as no local data were available for the Curtis Island site. Regionally representative sites were, however, assimilated into TAPM.

The model was set up with twelve vertical levels with heights at 20 m, 60 m, 100 m, 180 m, 260 m, 360 m, 460 m, 600 m, 800 m, 1600 m, 2600 m and 4600 m at each grid point. The terrain and land use were further refined from those used in the TAPM model to account for the increased resolution. The terrain was generated from the Geosciences Australia 9-second arc DEM dataset at a resolution of 300 m. All default options and factors were selected except where noted below.

Key features of CALMET used to generate the wind fields for the GLNG model are as follows:


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• Domain area of 22.8 by 22.8 km with 300 m grid spacing

• 1 year time scale (1 April 2006 to 31 March 2007), divided into individual months for analysis

• Prognostic wind fields input as MM5/3D.Dat "initial guess" field only (as generated from TAPM)

• Step 1 wind field options include kinematic effects, divergence minimisation, Froude adjustment to a critical Froude number of 1 and slope flows

• Terrain radius of influence set at 2 kilometre

• Cloud cover calculated from prognostic relative humidity.

B2 CALPUFF DISPERSION MODELLING METHODOLOGY

B2.1 Model configuration

Atmospheric dispersion modelling was carried out using the CALPUFF dispersion model. CALPUFF is a non-steady-state puff dispersion model, and is accepted for use by the DERM for application in environments where wind patterns and plume dispersion is strongly influenced by complex terrain and the land-sea interface. The Gladstone region consists of highly complex meteorology, and includes complex terrain, highly variable land uses and a land-sea interface and coastal islands. The CALPUFF dispersion model was used to predict ground-level concentrations of air contaminants downwind of this source. The same grid size and resolution developed for the fine resolution CALMET model was used for the dimensions of the CALPUFF domain.

B2.2 Other plant source characteristics

CALPUFF was configured with default options and parameters, with the following exceptions:

• Modelling period from 1 April 2006 to 31 March 2007

• 94 x 94 grid point domain with 0.3km resolution

• Gridded three-dimensional hourly-varying meteorological conditions generated by CALMET

• No chemical transformation or wet removal modelled

• PDF used for dispersion under convective conditions

• Dispersion coefficients calculated internally from sigma v and sigma w using micrometeorological variables.


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Table A7 Stack characteristics of GLNG Plant included in the assessment

Train Source East Coord (m)

North Coord (m)

Height (m)4

Diameter (m) Temp (oC)

Exit velocity1

(m/s)

Emissions (g/s) NOX2 CO3 PM10/PM2.53

A1 Methane Comp. Driver Stack 317,497 7,369,554 32 3.58 508.5 12 3.6 1.94 0.2 A2 Methane Comp. Driver Stack 317,511 7,369,554 32 3.58 507 12 3.6 1.94 0.2 A3-W Ethylene Comp. Driver Stack 317,525 7,369,554 44 2.5 240.5 8.5 3.6 1.94 0.2 A4-W Ethylene Comp. Driver Stack 317,539 7,369,554 44 2.5 244.5 8.5 3.6 1.94 0.2 A5 Propane Comp. Driver Stack 317,553 7,369,554 32 3.58 494 12 3.6 1.94 0.2 A6 Propane Comp. Driver Stack 317,567 7,369,554 32 3.58 504 12 3.6 1.94 0.2 A8 Hot Oil Heater 317,687 7,369,565 41 2.00 179.33 1.2 0.95 0.99 0.09 A9 GTG Turbine Driver Stack 317,821 7,369,568 30 1.95 546 26 1.74 0.43 0.04 A10 GTG Turbine Driver Stack 317,821 7,369,552 30 1.95 305 26 1.74 0.43 0.04 A11 GTG Turbine Driver Stack 317,821 7,369,536 30 1.8 517.5 19 1.74 0.43 0.04 A12 GTG Turbine Driver Stack 317,821 7,369,519 30 1.83 532 19 1.74 0.43 0.04 B1 Methane Comp. Driver Stack 317,497 7,369,332 32 3.58 498.5 12 3.6 1.94 0.2 B2 Methane Comp. Driver Stack 317,511 7,369,332 32 3.58 481 12 3.6 1.94 0.2 B3-W Ethylene Comp. Driver Stack 317,525 7,369,332 44 2.5 250.5 2.4 3.6 1.94 0.2 B4-W Ethylene Comp. Driver Stack 317,539 7,369,332 44 2.5 265 2.4 3.6 1.94 0.2 B5 Propane Comp. Driver Stack 317,553 7,369,332 32 3.58 490.5 12 3.6 1.94 0.2 B6 Propane Comp. Driver Stack 317,567 7,369,332 32 3.58 504 12 3.6 1.94 0.2 B8 Hot Oil Heater 317,687 7,369,343 41 2 184.25 1.2 0.95 0.99 0.09 B9 GTG Turbine Driver Stack 317,821 7,369,297 30 1.9 374 19 1.74 0.43 0.04 B10 GTG Turbine Driver Stack 317,821 7,369,314 30 1.95 470 19 1.74 0.43 0.04 Table note: 1 Minimum exit velocity as per Schedule B – Table 1 EPPG00712213 2 Maximum mass rate as per Schedule B – Table 2 EPPG00712213’ 3 Emission rates from EIS (Appendix S GLNG Environmental Impact Statement – Air Quality (URS, 2009)) 4 Minimum exit velocity as per Schedule B – Table 1 EPPG00712213


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APPENDIX C – DISPERSION MODELLING RESULTS


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Table C1 Predicted concentrations of NO2, CO and PM10/PM2.5 in isolation, with plant and with plant and background for Scenario 1



Flare in isolation µg/m3 Flare with plant µg/m3 Flare with plant, plus background µg/m3 1-hour

NO2 8-hour

CO 24-hour

PM10 24-hour

PM2.5 1-hour NO21

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour NO21

8-hour CO

24-hour PM10

24-hour PM2.5

R1 3.5 12.2 1.0 1.0 4.9 12.4 1.0 1.0 43.2 262.4 37.0 17.67 R2 2.1 15.0 1.3 1.3 4.4 15.4 1.5 1.5 41.5 265.4 37.5 17.67 R3 3.4 9.2 0.8 0.8 3.8 9.3 0.8 0.8 47.5 259.3 36.8 17.67 R4 3.3 8.7 0.7 0.7 3.9 9.0 0.7 0.7 48.9 259.0 36.7 17.67 R5 2.7 9.6 0.8 0.8 3.8 10.4 0.9 0.9 57.0 260.4 36.9 17.67 R6 2.7 11.5 1.0 1.0 4.9 11.5 1.0 1.0 74.5 261.5 37.0 17.67 R7 1.3 6.8 0.5 0.5 4.6 8.1 0.5 0.5 67.4 258.1 36.5 18.2 R8 2.9 6.5 0.5 0.5 2.8 7.2 0.6 0.6 73.0 257.2 36.6 18.3 R9 0.9 4.9 0.4 0.4 3.3 4.9 0.4 0.4 50.9 254.9 36.4 18.1

R11 1.0 3.3 0.3 0.3 6.1 8.6 0.4 0.4 40.2 258.6 36.4 18.1 R12 0.5 3.0 0.3 0.3 5.2 6.2 0.3 0.3 45.6 256.2 36.3 18.0 R13 0.8 3.1 0.3 0.3 4.7 5.5 0.3 0.3 28.5 255.5 36.3 18.0

R14 0.6 2.2 0.2 0.2 3.9 4.8 0.2 0.2 30.7 254.8 36.2 17.9 R15 0.8 3.1 0.3 0.3 2.9 4.5 0.3 0.3 23.0 254.5 36.3 18.0 R16 0.6 2.1 0.2 0.2 3.2 3.4 0.2 0.2 17.5 253.4 36.2 17.9 R17 0.7 2.9 0.3 0.3 2.5 3.6 0.3 0.3 27.5 253.6 36.3 17.9 R18 0.7 3.9 0.3 0.3 2.9 5.1 0.4 0.4 20.4 255.1 36.4 18.1 R19 0.7 3.9 0.3 0.3 2.8 5.0 0.4 0.4 20.0 255.0 36.4 18.1 R20 0.6 3.8 0.3 0.3 2.4 4.8 0.4 0.4 20.2 254.8 36.4 18.1

R21 - QCLNG accommodation camp 0.9 3.4 0.2 0.2 14.9 21.4 1.6 1.6 53.2 271.4 37.6 19.2

R22 - APLNG accommodation camp 1.5 3.6 0.2 0.2 11.8 17.5 0.9 0.9 50.6 267.5 36.9 18.5

Curtis Island National Park 6.5 24.2 2.0 2.0 6.2 25.7 2.0 2.0 36.0 275.7 38.0 19.7

Curtis Island Conservation Park 2.7 9.0 0.8 0.8 5.7 9.4 0.8 0.8 44.8 259.4 36.8 18.5


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NO2 8-hour

CO 24-hour

PM10 24-hour

PM2.5 1-hour NO21

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour NO21

8-hour CO

24-hour PM10

24-hour PM2.5

Curtis Island State Forest 4.5 8.7 0.8 0.8 5.8 9.9 0.8 0.8 38.5 259.9 36.8 18.5 Curtis Island Environmental

Management Precinct 7.3 26.2 2.1 2.1 58.2 146.9 6.0 6.0 75.4 396.9 42.0 23.6

Targinie State Forest 3.2 13.3 1.1 1.1 13.4 13.8 1.3 1.3 63.2 263.8 37.3 19.0

Objective 250 11,000 50 25 250 11,000 50 25 250 11,000 50 25 Table note: 1 Cumulative NO2 presented as 99.9th highest





NO2 8-hour

CO 24-hour

PM10 24-hour

PM2.5 1-hour NO21

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour NO21

8-hour CO

24-hour PM10

24-hour PM2.5

R1 2.4 6.6 0.8 0.8 4.9 7.2 1.0 1.0 43.2 257 37 18.7 R2 1.5 7.8 0.9 0.9 4.4 8.2 1.4 1.4 41.5 258 37 19.1 R3 2.0 5.8 0.7 0.7 3.8 6.9 0.9 0.9 47.5 257 37 18.6

R4 1.6 5.6 0.7 0.7 3.8 6.3 0.9 0.9 48.9 256 37 18.5 R5 2.2 7.2 0.9 0.9 3.8 8.0 1.1 1.1 57.0 258 37 18.7 R6 1.8 8.9 1.1 1.1 4.9 8.9 1.4 1.4 74.5 259 37 19.0 R7 0.5 2.8 0.3 0.3 4.6 4.5 0.5 0.5 67.4 255 36 18.1 R8 1.9 3.7 0.4 0.4 2.7 4.4 0.6 0.6 73.0 254 37 18.3 R9 0.5 2.2 0.3 0.3 3.3 3.2 0.4 0.4 50.9 253 36 18.1

R11 0.2 0.8 0.1 0.1 6.1 8.6 0.4 0.4 40.2 259 36 18.1 R12 0.1 0.8 0.1 0.1 5.2 5.6 0.3 0.3 45.6 256 36 17.9 R13 0.7 1.8 0.3 0.3 4.7 5.5 0.3 0.3 28.5 255 36 18.0 R14 0.4 1.1 0.2 0.2 3.9 4.6 0.2 0.2 30.7 255 36 17.9 R15 0.4 1.1 0.2 0.2 2.9 3.5 0.3 0.3 23.0 254 36 18.0 R16 0.3 0.6 0.1 0.1 3.2 3.2 0.2 0.2 17.5 253 36 17.9


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NO2 8-hour

CO 24-hour

PM10 24-hour

PM2.5 1-hour NO21

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour NO21

8-hour CO

24-hour PM10

24-hour PM2.5

R17 0.5 1.8 0.3 0.3 2.5 3.5 0.4 0.4 27.5 254 36 18.0 R18 0.6 2.8 0.3 0.3 2.9 2.8 0.4 0.4 20.4 253 36 18.0 R19 0.6 2.5 0.3 0.3 2.8 2.7 0.4 0.4 20.0 253 36 18.0 R20 0.5 2.3 0.3 0.3 2.4 2.6 0.4 0.4 20.2 253 36 18.0

R21 - QCLNG accommodation camp 0.2 0.7 0.2 0.2 14.9 21.4 1.6 1.6 53.2 271 38 19.2

R22 - APLNG accommodation camp 0.2 0.7 0.2 0.2 11.8 17.5 0.9 0.9 50.6 268 37 18.5

Curtis Island National Park 1.8 8.8 1.0 1.0 6.0 9.9 2.2 2.2 36.0 260 38 19.9

Curtis Island Conservation Park 2.1 5.6 0.7 0.7 5.7 5.8 1.0 1.0 44.8 256 37 18.7

Curtis Island State Forest 3.0 6.0 0.7 0.7 5.8 7.2 1.0 1.0 38.4 257 37 18.7 Curtis Island Environmental

Management Precinct 4.3 15.0 1.8 1.8 58.2 146.9 5.9 5.9 75.4 397 42 23.6

Targinie State Forest 2.4 8.2 1.0 1.0 13.4 12.4 1.3 1.3 63.2 262 37 19.0





NO2 8-hour

CO 24-hour

PM10 24-hour

PM2.5 1-hour NO21

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour NO21

8-hour CO

24-hour PM10

24-hour PM2.5

R1 4.3 11.6 0.04 0.04 4.9 11.8 0.4 0.4 43.2 261.8 36.4 17.67 R2 3.5 7.6 0.03 0.03 4.4 7.8 0.2 0.2 41.5 257.8 36.2 17.67 R3 6.7 19.9 0.07 0.07 4.0 19.9 0.2 0.2 47.5 269.9 36.2 17.67 R4 2.6 5.2 0.02 0.02 3.8 5.2 0.2 0.2 49.0 255.2 36.2 17.67 R5 3.5 7.7 0.03 0.03 3.9 7.9 0.1 0.1 57.0 257.9 36.1 17.67 R6 2.4 9.4 0.03 0.03 4.9 10.2 0.1 0.1 74.5 260.2 36.1 17.67


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NO2 8-hour

CO 24-hour

PM10 24-hour

PM2.5 1-hour NO21

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour NO21

8-hour CO

24-hour PM10

24-hour PM2.5

R7 1.0 5.1 0.02 0.02 4.6 6.0 0.2 0.2 67.4 256.0 36.2 17.9 R8 0.9 3.4 0.01 0.01 2.7 4.1 0.1 0.1 73.0 254.1 36.1 17.8 R9 1.1 3.6 0.01 0.01 3.3 3.6 0.1 0.1 50.9 253.6 36.1 17.8

R11 0.4 1.8 0.01 0.01 6.1 8.6 0.3 0.3 40.2 258.6 36.3 18.0 R12 0.2 0.7 0.00 0.00 5.2 5.6 0.3 0.3 45.6 255.6 36.3 17.9

R13 0.3 1.3 0.00 0.00 4.7 5.5 0.2 0.2 28.5 255.5 36.2 17.9 R14 0.3 1.0 0.00 0.00 3.9 4.6 0.2 0.2 30.7 254.6 36.2 17.9 R15 0.3 0.9 0.00 0.00 2.9 3.5 0.2 0.2 23.0 253.5 36.2 17.8 R16 0.2 0.5 0.00 0.00 3.2 3.2 0.1 0.1 17.5 253.2 36.1 17.8 R17 2.2 6.2 0.02 0.02 2.6 6.2 0.1 0.1 27.5 256.2 36.1 17.8 R18 1.5 7.0 0.03 0.03 2.9 7.1 0.1 0.1 20.4 257.1 36.1 17.8 R19 1.4 5.9 0.02 0.02 2.8 6.0 0.1 0.1 20.0 256.0 36.1 17.8 R20 1.3 5.0 0.02 0.02 2.4 5.1 0.1 0.1 20.2 255.1 36.1 17.8

R21 - QCLNG accommodation camp 0.2 0.9 0.00 0.00 14.9 21.4 1.6 1.6 53.2 271.4 37.6 19.2

R22 - APLNG accommodation camp 0.2 0.9 0.00 0.00 11.8 17.5 0.9 0.9 50.6 267.5 36.9 18.5

Curtis Island National Park 5.0 10.0 0.04 0.04 6.0 10.0 0.3 0.3 36.0 260.0 36.3 18.0

Curtis Island Conservation Park 5.1 13.8 0.05 0.05 5.7 13.8 0.3 0.3 44.8 263.8 36.3 18.0

Curtis Island State Forest 4.9 14.2 0.05 0.05 5.8 14.4 0.3 0.3 38.4 264.4 36.3 18.0 Curtis Island Environmental

Management Precinct 5.0 13.8 0.05 0.05 58.2 146.9 5.9 5.9 75.4 396.9 41.9 23.6

Targinie State Forest 4.0 15.2 0.06 0.06 13.5 15.3 0.4 0.4 63.2 265.3 36.4 18.1



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Plate C1 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


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Plate C2 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + GAMS background)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


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Plate C3 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


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Plate C4 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


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Plate C5 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation). All PM10 is assumed to be PM2.5.

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

PM10: 50 µg/m³

PM2.5: 25 µg/m³

Prepared by:

P McDowell

Date:

2020


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Plate C6 Predicted maximum 24-hour average ground level concentrations of PM10 due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

50 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 58

Plate C7 Predicted maximum 24-hour average ground level concentrations of PM2.5 due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

25 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 59

Plate C8 Predicted maximum 1-hour average ground level concentrations of fluoranthene due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

0.5 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 60

Plate C9 Predicted maximum 1-hour average ground level concentrations of propylene due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

8,750 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 61

Plate C10 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 62

Plate C11 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + GAMS background)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 63

Plate C12 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 64

Plate C13 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 65

Plate C14 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation). All PM10 is assumed to be PM2.5.

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

PM10: 50 µg/m³

PM2.5: 25 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 66

Plate C15 Predicted maximum 24-hour average ground level concentrations of PM10 due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

50 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 67

Plate C16 Predicted maximum 24-hour average ground level concentrations of PM2.5 due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

25 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 68

Plate C17 Predicted maximum 1-hour average ground level concentrations of fluoranthene due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

0.5 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 69

Plate C18 Predicted maximum 1-hour average ground level concentrations of propylene due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

8,750 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 70

Plate C19 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 71

Plate C20 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + GAMS background)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 72

Plate C21 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 73

Plate C22 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 74

Plate C23 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 3 – Upset Train 1 Propane and Ethylene Valves Open to Flare (flare in isolation). All PM10 is assumed to be PM2.5.

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

PM10: 50 µg/m³

PM2.5: 25 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 75

Plate C24 Predicted maximum 24-hour average ground level concentrations of PM10 due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

50 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 76

Plate C25 Predicted maximum 24-hour average ground level concentrations of PM2.5 due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

25 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 77

Plate C26 Predicted maximum 1-hour average ground level concentrations of fluoranthene due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

0.5 µg/m³

Prepared by:

P. McDowell

Date:

2020


4 August 2020

Page 78

Plate C27 Predicted maximum 1-hour average ground level concentrations of propylene due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

8,750 µg/m³

Prepared by:

P. McDowell

Date:

2020

Appendix C - Flaring Contingency Management Plan


This document contains confidential information and is not to be disclosed to any third parties without prior written permission from the CEO GLNG Operations Pty Ltd.

UNCONTROLLED IF PRINTED

Flaring Contingency Management Plan

Document Number: 3310-GLNG-5-1.3-0013 Author:

Name Title

Environmental Adviser Checked by:

Name Title

Team Leader LNG Plant Process Engineering Approved by:

Name Title

Plant Manager

Date Rev Reason For Issue Author Checked Approved

0 DH BC 29/04/2019 1 For issue MR RM GJ


Table of Contents

1. PURPOSE ........................................................................................................................ 2 2. SUMMARY OF RESPONSIBILITIES ............................................................................... 2 3. BACKGROUND ................................................................................................................ 3

3.1. Facility Flares ........................................................................................................ 4 3.2. Flare Emissions ..................................................................................................... 6 3.3. Flaring Events ........................................................................................................ 6

Planned Flaring Events ......................................................................... 6 Unplanned/Upset Flaring Events .......................................................... 6

3.4. Flaring Environmental Impacts .............................................................................. 8 4. OBJECTIVES ................................................................................................................... 8 5. PERFORMANCE CRITERIA ............................................................................................ 8

5.1. Legislation and Standards ..................................................................................... 8 5.2. Performance Criteria ............................................................................................. 9

6. MANAGEMENT MEASURES ......................................................................................... 10 7. MONITORING AND REPORTING ................................................................................. 14 8. AUDITING ....................................................................................................................... 14 9. CORRECTIVE ACTIONS ............................................................................................... 14 10. DEFINITIONS ................................................................................................................. 15

UNCONTROLLED IF PRINTED 3310-GLNG-5-1.3-0013

1. PURPOSE

This Plan addresses the objectives and performance criteria, management measures, and monitoring, auditing, and corrective action requirements relating to flaring for the Santos GLNG OPL LNG Facility on Curtis Island. Management measures and reporting and auditing requirements specified are intended to ensure compliance with the requirements of the Environmental Authority (EA) EPPG00712213, and other relevant approvals under applicable Queensland and Commonwealth legislation. This document applies to operation of the LNG Facility. It addresses flaring activity relating to LNG Operations within the bounds of Petroleum Facility Licence (PFL) 10 on Curtis Island, near Gladstone. 2. SUMMARY OF RESPONSIBILITIES

The following, summary of responsibilities apply for personnel undertaking activities covered by this document.

Table 1: Summary of Responsibilities

Role Responsibilities Plant Manager Operate the plant to minimise flaring, achieve optimal

performance and meet the flaring related criteria as stipulated in the EA.

Ensure that key stakeholders, as stipulated in this plan, are provided with timely information regarding planned shutdowns and associated flaring activity to facilitate notifications to stakeholders.

Engage key stakeholders during the shutdown planning process.

Provide key stakeholders with timely, accurate information in relation to unplanned flaring events.

Provide input to MOC assessments to assess the viability of recommended initiatives to reduce flaring activity.

Ensure that process controls identified by Engineering are implemented in order to reduce flaring activity as far as practicable.

Maintenance Manager Maintain the plant to improve reliability and reduce flaring activity as far as practicable.

Manage flare maintenance. Actively participate in planning of shutdowns and execute

all shutdown activities such that flaring is minimised through management of shutdown schedules, purging and isolation of equipment.

Shift Superintendent Ensure logging of planned and unplanned flaring events in the Flaring Register.

Engineering Manager Provide engineering technical input for responses to a complaint or information request from the Administering Authority.


Role Responsibilities Provide technical advice regarding initiatives to reduce

flaring activity. Actively drive all Management of Change on the facility,

with due consideration to potential impacts on Flaring, Principal Environment Advisor Liase with regulatory environmental departments regarding

any flaring issues Communicate flaring related non-compliances with the EA

to the Administering Authority. Oversee the evaluation of compliance with environmental

legislation and regulations, permits, licences and approvals.

Oversee incident investigations and development of corrective actions for operations implementation.

Provide input to Management of Change (MOC) assessments to assess the viability of recommended initiatives to reduce flaring activity.

Environmental Advisor (note this can also be a Senior Environmental Advisor)

Coordinate the collation of information required from Downstream Operations in response to a complaint or information request from the Administering Authority.

Provide the Operations Manager and Maintenance Manager with environmental technical and regulatory compliance support with regard to this management plan.

Participate in flaring related environmental incident investigations as required.

Collate environmental incident reports and associated regulatory notifications

Monitor the implementation of the management measures and identify corrective actions.

Communicate the need for corrective actions to QBU-Environment Team, Site Management and GLNG OPL EHSS&T Manager.

Interact with Administering Authority, as directed. Participate in audits against the SMS. Facilitate site aspects of third party auditing of the EA

conditions. Community Engagement Advisor

Provide timely notifications to key stakeholders on flaring activity.

Provide EQ Assets – Environment and the DSO Environmental Advisor with the details of any flaring related complaints or information requests.

Provide technical advice to External Affairs in relation to any complaints or information requests from the community.

3. BACKGROUND

Santos GLNG OPL processes Coal Seam Gas to produce Liquefied Natural Gas (LNG). The feed gas stream is primarily methane and both propane and ethylene refrigerants are used in the liquefaction process. These three components comprise over 99.9% of materials that


can enter the flares. During normal operations, natural gas and other hydrocarbons flow continuously through the LNG Facility. The flaring system facilitates purging of the Facility during planned shutdowns for routine maintenance activities, unplanned repairs to defective infrastructure or emergency situations. The system includes three separate flare systems and is common for both Train 1 and Train 2. Flaring ensures that hydrocarbons are safely combusted and are not emitted to atmosphere.

3.1. Facility Flares

The Santos GLNG OPL Facility flare system is comprised of the following components:

Wet Process Flare: Designed to handle warm hydrocarbon streams that may be saturated with water vapour and/or contain free liquid hydrocarbons and water;

Dry Process Flare: Designed to handle cryogenic hydrocarbons, both vapour and liquid;

Back-up Wet and Dry Flare; and Marine Flare: Designed to handle LNG vapours from the LNG Storage Tanks in the

event of Boil Off Gas Compressors failure and/or shiploading.

Flare locations are provided in Figure 1 (N.B. On Figure 1 - A13 is Wet Gas Flare, A14 is the Marine Flare, A15 is the Dry Flare and A16 is the back-up Wet and Dry Flare).


Figure 1: Flare Locations (A13 to A16)


3.2. Flare Emissions

Coal seam gas processed at the Facility is comprised of the following:

Approximately 98% Methane; and The remaining 2% is comprised of small quantities of Nitrogen (N2), Carbon

Dioxide (CO2) and Ethane (C2H6) and traces of heavier hydrocarbons.

During normal operating conditions, some gas is combusted in the flares in a pilot flame, designed to provide a continuous ignition source such that any gas sent to the flare as a result of upset conditions is immediately combusted. The pilot flare is a small, smokeless flame which emits small volumes of carbon dioxide, nitrogen oxides and water vapour. The flare purge is a necessary safety requirement to prevent any ingress of air into the flare system. Non-normal operations refer to conditions at the LNG Facility that are outside the general operating parameters of the plant and occur intermittently for a short duration resulting in flaring events. Emission rates for these activities may also be variable and, consequently, do not impact air quality on a continual basis. During non-normal operations, the combustion efficiency of the flare may be reduced by the presence of refrigerants and Nitrogen (used for purging gas lines in the Facility). This results in the emission of Oxides of Nitrogen, Carbon Monoxide (CO), Total Hydrocarbons (Methane, Ethane, Ethylene, Propane), Particulates in the form of PM2.5 and PM10 and trace Polycyclic Aromatic Hydrocarbons (PAH’s).

3.3. Flaring Events

Planned Flaring Events

Planned flaring occurs several times per annum during routine maintenance activities and are normally associated with plant and equipment shut-down and start-up processes. During some shutdowns, de-inventory of the gas process lines and or refrigerant lines will be required to enable safe access whilst the plant is shut down for maintenance/inspection purposes. Refrigerant vapours may need to be sent to the flare during these situations which may result in flaring events. Planned flaring can also occur during shiploading activities. It should however be noted that unplanned events can also occur during shiploading activities. Whilst every attempt is made to eliminate flaring during ship loading at times it may be required in the case of the arrival of a warm ship requiring cool down or in the management of larger volumes of boil off gas.

Unplanned/Upset Flaring Events


Unplanned flaring can occur at any time during upset conditions on either or both LNG Trains. Typical causes of unplanned flaring events include the following:

Regeneration Gas Compressor Trips: The Regeneration Gas Compressor is

used to recover natural gas used for regeneration of the molecular sieve beds. The molecular sieves are used to remove moisture from the gas, which is a requirement prior to liquefaction. Whenever the regeneration gas compressor trips, gas is diverted to the Wet Process Flare. The duration of flaring can vary, and takes place until such time that the regeneration gas compressor is returned to service. Flaring is also required during the compressor restart;

Nitrogen Rejection Unit (NRU) Off Specification: The NRU extracts Nitrogen

from the feed gas, an essential efficiency component of the liquefaction process. When this unit malfunctions, the feed gas to the NRU is typically diverted to the Dry Process Flare;

Gas Turbine Compressor Trips: Gas Turbine Compressors (GTCs) are critical

to the liquefaction process. These units form part of the refrigerant loops which chill feed gas, leading to liquefaction. When GTCs shutdown, they may require depressurisation prior to restarting, which results in flaring activity. Depressurisation of the GTC casings can result in gas or refrigerant vapour being sent to flare, which causes varying degrees of smoke emissions (dependent on which GTC is being depressurised). Re-start of the propane compressors can also require drainage of liquid propane from the compressor casings to the flare. Re-start of gas turbines associated with the refrigerant compressors can also require flaring of fuel gas as part of the start-up operation of the turbines;

Boil Off Gas (BOG) Compressor Failure: The GLNG Facility has three (3) BOG

compressors, which recycle boil off gas from the LNG Storage Tanks and ship loading back into the liquefaction process. This is an energy saving operation which also prevents unnecessary flaring of methane gas. When the BOG compressors malfunction, gas is diverted to the Marine Flare. The volume of gas that is diverted to the Marine Flare varies and is dependent on the number of BOG compressors that are unavailable, as well as, whether or not there is ship loading activity;

Overpressure Release of Hydrocarbon by Pressure Controller or Relief

Valve: During upset conditions, correct functioning of pressure controllers and relief valves will prevent equipment overpressure by releasing hydrocarbons to flare. This is only expected to be for short duration until the process is brought back to normal operating pressure. However, in the event of passing pressure control valves or relief valves, the flaring may continue until the plant can be shutdown for rectification work;

Emergency Shutdown of LNG Train: During emergencies, the LNG train can

be shutdown automatically or manually. Depending on the nature of the


emergency, hydrocarbon may need to be sent to the flare to depressurise the train or pressure controller may open to flare as the train warms up and inventory pressures rise;

Emergency Depressurisation of Gas Process and Refrigeration Circuits:

During emergency depressurisation of the gas process stream and refrigeration circuits and subsequent train shutdown, gas or refrigerants will be sent to the flare to deinventory the train;

Flaring during Shiploading: Unplanned flaring can occur during ship loading

when return vapours exceed the capacity of the plant’s BOG compressors to manage the vapour load. This gas is flared at the marine flare; and,

Emergency Depressurisation of the Gas Transmission Pipeline (GTP): The

LNG facility flare system can be used as part of the process required for emergency depressurisation of the GTP.

3.4. Flaring Environmental Impacts

As part of the performance test of the plant prior to hand over to GLNG, each flare stack was tested on its performance to meet flame stability requirement and designed operation at individual flare design flow rates with feed gas. 4. OBJECTIVES The objectives of this management plan are to:

Reduce flaring activity as far as practicable. Manage social impacts associated with unavoidable flaring by providing timely and

accurate notifications to key stakeholders. Operate in a manner that minimises impacts on ambient air quality. Preserve ambient air quality to the extent that ecological health, public amenity or

safety is maintained.

5. PERFORMANCE CRITERIA

5.1. Legislation and Standards

The performance criteria and implementation strategy has been developed with reference to:

Environmental Protection Act (1994) (EP Act) (Qld). Environmental Protection Regulation (2008) (Qld). Environment Protection (Air) Policy (2008) (EPP (Air)) (Qld). National Environment Protection Measure (Air). Environmental Authority EPPG00712213.


5.2. Performance Criteria The performance criteria for this management plan are as follows:

Visual smoke and particulate emissions will not occur for more than five (5) minutes in any two (2) hour period during normal operating conditions.

Key stakeholders to be notified of planned flaring events a minimum of 24 hours prior to the event.

Key information regarding unplanned flaring events to be captured as per the Proceduire for Recording Flaring Events 3301-GLNG-5-1.3-0023.

Flaring event details shall be reviewed on a regular basis and where appropriate mitigation measures implemented to reduce future flaring activity.

Duration and extent of flaring to be reduced as low as reasonably practicable through implementation of operational controls.

Timely responses to information requests to be provided to all stakeholders. Corrective actions identified will be implemented as soon as practicable following

an unplanned flaring event.


6. MANAGEMENT MEASURES

Management Criteria Management Measure Responsibility 6.1 Competency Based Training Appropriately training personnel

Training and Operations Governance

6.2 Operator Essential Care Operations routine monitoring of flare is included in Operator Essentail Care Tasks. Routine tasks undertaken by Operators to ensure flare is operating satisfactorily.

Operations

6.3 Operating Envelope Management Process alarms in place to advise operators and minimise possibility of operational upsets and train trip.

GLNG Engineering

6.4 Plant process efficiency monitoring (including flare monitoring)

Flaring is reported in monthly operations meetings.

GLNG Engineering

6.5 GE Remote Monitoring and diagnostics

24 hour monitoring of refrigerant compressors and turbines to ensure equipment is operating at optimal performance. RM&D (Remote Monitoring & Diagnostics), AHM (Asset health management), DDE (Dedicated Diagnostic Engineer).

GLNG Engineering

6.6 Reliability and Maintenance Management Standards

Improve reliability reduce trips, reducing flaring events. Focus on defect elimination. GLNG has a robust risk based system for the prioritisation of break in work outside of a disciplined schedule.

GLNG Engineering

6.7 Asset Reliability Improvement Plan (ARIP)

Monitoring of equipment reliability and management of bad actors via TRP (Trip Reduction Program) and PEP (Performance Enhancement Program) to predict and improve equipment efficiency and performance.

GLNG Engineering

6.8 Flaring only to be undertaken from the Process and Marine Flares, as detailed in the EA.

The design of the Plant only facilitates flaring at these locations. Therefore no additional management measures are required.

N/A


Management Criteria Management Measure Responsibility 6.9 Visible smoke (Ringleman >2) and particulate emissions will not occur for more than five (5) minutes in any two (2) hour period during normal operating conditions.

Design of the flares has addressed the requirement that visible smoke and particulate emissions are not to occur for more than five (5) minutes in any two (2) hour period during normal operating conditions. Record events which do not meet this criteria as per the Procedure for Recording Flaring Events” – Document Number 3310-GLNG-5-1.3-0023. Emergency Procedures have been developed and are implemented for non-routine situations to deal with foreseeable risks and hazards including corrective responses to prevent and mitigate environmental harm (Santos GLNG OPL Emergency Response Plan 3301-GLNG-5-1.6-0024).

Operations / GLNG Engineering

6.10 Key stakeholders to be notified of planned flaring events a minimum of 24 hours prior to the event.

Key stakeholders to be engaged during shutdown planning process and provided with a forecast flaring schedule for the event. The forecast is to be updated regularly throughout the event. Key community stakeholders to be notified a minimum of 24 hours ahead of planned flaring events. DES to be notified a minimum of 24 hours ahead of planned significant flaring events. Planned significant flaring events to be entered into the Flaring Register.

Community Relations Officer

6.11 Unplanned flaring events that produce visible smoke and particulate emissions (as per 6.9 above) are to be recorded.

These should be recorded as per the requirements of the “Procedure for Recording Flaring Events” – Document Number 3310-GLNG-5-1.3-0023.

Operations Shift Superintendents

6.12 Duration and extent of flaring to be reduced as low as reasonably practicable through implementation of operational controls.

The following typical upset conditions result in unplanned flaring events. The following mitigation measures are to be implemented where possible to reduce the extent and severity of flaring:

Regeneration Gas Compressor Trips: Whenever practical, pause dehydration sequence;

Nitrogen Rejection Unit (NRU) Off Specification: Limited options available therefore bring NRU back to specification as soon as practicable;

Operations / GLNG Engineering


Management Criteria Management Measure Responsibility Gas Turbine Compressor Trips Limit time taken to restart compressors; and

abide by vendor recommended casing pressure to initiate restart of each GTC; Overpressure Release of Hydrocarbon by Pressure Controller or Relief

Valve: Correct functioning of pressure controller and relief valve would prevent overpressure by releasing hydrocarbon to flare. This is only expected to be for short duration until the process is brought back to normal operating pressure. However, in the event of passing pressure controller valve or relief valve, the flaring may continue until the plant can be shutdown for rectification work.

Emergency Depressurisation of Gas Process and Refrigeration Circuits: Engineering investigation into the process upsets and flare performance.

Emergency Shutdown of LNG Train: During emergency, LNG train can be shutdown either automatically or manually. Depending on the nature of the emergency, hydrocarbon may need to be sent to the flare to depressurise the train or pressure controller may open to flare as the train warms up.

The following planned conditions result in flaring events. The following mitigation measures are to be implemented where possible to reduce the extent and severity of flaring:

De-inventory of refrigerant vapour: Where practical deinventory refrigerant vapour from an offline train into the online train rather than to flare.

Restarting Compressor Turbines: As far as practicable, minimise internal

depressurisation to flare for restarting compressor turbines Ship Loading: Ensure minimum required BOG compressors are online in

advance of shipping operations. Shutdown planning to identify and implement initiatives to reduce flaring activity as far as practicable throughout the shutdown period. These initiatives are to include, but not be limited to those detailed above.

6.13 Timely responses to information requests to be provided by all stakeholders.

Coordinate information request responses. Collation of information for provision to EQ Assets - Environment, to be utilised in the response.

Operations/ GLNG Engineering


Management Criteria Management Measure Responsibility

6.14 Manage complaints Field complaints and seek technical input from key stakeholders, as required. Community Relations 6.15 Corrective actions will be implemented as soon as practicable where required

The cause of the significant flaring events will be identified and where required associated corrective actions implemented in a timely manner.

Operations


7. MONITORING AND REPORTING

Monitoring and reporting is to be undertaken as specified in Schedules B, I and K of the EA and in accordance with the following requirements:

An incident is to be raised in IMS and notification to relevant stakeholders if visible smoke and particulate emissions are observed for more than five (5) minutes in any two (2) hour period during normal operating conditions in accordance with EA condition B19. The environment team must be notified of an event like this within 12 hours of occurrence.

DES and other key stakeholders to be notified a minimum of 24 hours ahead of significant planned flaring events.

Where required reporting on monitoring undertaken in response to complaints or specific direction of the Administering Authority will be provided within ten (10) days of completion of the investigation or receipt of monitoring results, whichever is the latter, in accordance with EA condition K5.

Monitoring outcomes and corrective actions (if required) will be reported in the Annual Monitoring Report.

8. AUDITING

The SMS must be regularly audited to ensure its continuing suitability, adequacy and effectiveness and meet Santos GLNG OPL commitment to continual improvement. Regular internal audits of the SMS are conducted, covering all activities within the scope of the SMS. Santos GLNG OPL will also ensure that a qualified third party auditor (accepted by the Administering Authority) undertakes compliance monitoring against the EA conditions as required by the EA. 9. CORRECTIVE ACTIONS

Description Responsibility Should visible smoke and particulate emissions occur for more than five (5) minutes in any two (2) hour period during normal operating conditions the Operations Shift Superintendent will: 1. Consult with engineering to identify possible causes. 2. Investigate mitigation measures. 3. Implement appropriate mitigations if possible.

Operations Shift Superintendents

Investigate complaints and advise the Administering Authority in writing (within 14 days of completion of the investigation) of the proposed or undertaken action in relation to the complaint.

Senior Community Relations Advisor / Environmental Advisor

Undertake monitoring specified by the Administering Authority to investigate any complaint of environmental harm. Report results of the investigation and monitoring within 14 days of completion of the investigation or receipt of the monitoring results, whichever is the latter.

Environmental Advisor

Implement corrective actions if the monitoring indicates an exceedance of emission limits in the EA.

Operations and GLNG Engineering


Description Responsibility Record the following details for all complaints received and provide the information to the Administering Authority:

Name, address and contact details of complainant. Time and date of complaint. Reasons for the complaint. Investigations undertaken. Conclusions formed. Actions taken to resolve complaint. Any abatement measures implemented. Person responsible for resolving the complaint.

Senior Community Relations Advisor / Environmental Advisor

10. DEFINITIONS

Term Meaning Administering Authority Department of Environment and Heritage Protection. The

Queensland Government Department that administers the Environmental Authority under the Environmental Protection Act 1994.

CG Coordinator General CH4 Methane CO Carbon Monoxide CO2 Carbon Dioxide DCS Distributed Control System EA Environmental Authority, specifically Environmental

Authority EPPG00712213 EHP Department of Environment and Heritage Protection EP Act Environmental Protection Act 1994 (Qld) EPP (Air) Environmental Protection (Air) Policy 2008 (Qld) GTC Gas Turbine Compressor GTP Gas Transmission Pipeline LNG Liquefied Natural Gas N2 Nitrogen Gas Normal operating conditions

Normal operating conditions are defined as the ongoing operation of the LNG plant following commissioning and excludes non-normal operating conditions such as start-up, shutdown, maintenance, calibration of emissions monitoring devices.

NOx Nitrogen Oxides NRU Nitrogen Rejection Unit PFL Petroleum Facility Licence PM10 Particulate Matter in the order of 10 micrometres or less SMS Santos Management System


APPENDIX A - EA COMPLAINT MONITORING REQUIREMENTS In the event of a complaint or request from the Administering Authority, GLNG OPL is required to undertake monitoring specified by the Administering Authority, within a reasonable and practicable time frame nominated by the Administering Authority, to investigate any complaint of environmental harm at any sensitive or commercial place, in accordance with EA EPPG00712213 Schedule J. The results of the investigation (including an analysis and interpretation of the monitoring results) and abatement measures implemented must be provided to the Administering Authority within ten (10) days of completion of the investigation, or receipt of monitoring results, whichever is the latter, in accordance with EA EPPG00712213 Schedule K.

Appendix D – Procedure for Recording Flaring Events


This document contains confidential information and is not to be disclosed to any third parties without prior written permission from the CEO GLNG Operations Pty Ltd.


Procedure for Recording Flaring Events Document Number: 3301-GLNG-5-1.3-0023 Author:

Title Name

Senior Environmental Advisor Reviewed by:

Title Name

Principal Environment Adviser Team Leader LNG Plant Process Engineering

Approved by:

Title Name

Plant Manager

Date Rev Reason For Issue Author Checked Approved

0 BC DH 17/01/02019 0.1 For Review MR JC 27/06/2019 1.0 For Use MR JC/ RM GJ


Table of Contents 1. Purpose ............................................................................................................................ 1 2. Scope ................................................................................................................................ 1 3. Definitions ......................................................................................................................... 1 4. Responsibilities ................................................................................................................. 1 5. Procedure ......................................................................................................................... 2

5.1. Monitoring Flares ................................................................................................... 2 5.2. Recording of Flaring Events .................................................................................. 2

6. Monitoring and Reporting ................................................................................................. 2 APPENDIX A - Flaring Event Register Template ................................................................... 3 APPENDIX B – Ringelmann Smoke Chart .............................................................................. 4

of 4 UNCONTROLLED IF PRINTED 3301-GLNG-5-1.3-0023

1. PURPOSE The Flaring Event Register Procedure defines the requirements for the recording of flaring events at the LNG facility. Management of flaring events is required to ensure compliance with Environmental Authority (EA) EPPG00712213 conditions with respect to flaring and to minimise the potential for community complaints relating to visible smoke. 2. SCOPE The scope of this Procedure encompasses the flaring system at the LNG Facility (wet flare, dry flare, back-up flare and marine flare). The EA stipulates that flaring events associated with visible smoke cannot occur for longer than 5 minutes in any 2 hour period during normal operations. The recording of flaring events in a Flaring Event Register is a requirement of the Flaring Contingency Management Plan (3310-GLNG-5-1.3-0013) whether the flaring event is planned (normal operations or planned shut-down/ start-up) or unplanned (i.e. upset). All flaring events should be noted and recorded in the Flaring Register. 3. DEFINITIONS EA Environmental Authority EPPG00712213

DES Department of Environment and Science, the administering authority for the EA

Flaring Event A flaring event which is associated with visible smoke (Ringelmann number greater than 2) and occurs for a minimum of 5 minutes in any 2 hour period during normal operating conditions.

4. RESPONSIBILITIES

Role Responsibilities Operations Superintendent / Team Leaders • Ensure all Operations Teams are aware of the

Procedure for Recording Flaring Events • Ensure that a Flaring Event Register entry is

completed for each Flaring Event • Resource allocation

Operations Team Members • Be aware of the Flaring Event Register Procedure • Log Flaring Events in the Flaring Event Register

with complete and accurate details


Role Responsibilities Senior Environmental Advisor • Participate in flaring related environmental incident

investigations • Collate environmental incident reports and

associated regulatory notifications

5. PROCEDURE

5.1. Monitoring Flares The main flare stack and the marine flare shall be monitored by CCTV camera and visual observations. 5.2. Recording of Flaring Events When a flaring event has been identified, the following information shall be recorded in the Flaring Register:

Time flaring commenced; Nature of operations at the time of flaring; Specific cause of flaring; Ringlemann Score (1-5); Actions taken to minimise flaring intensity and duration; and Time flaring stopped.

An example format of the Flaring Register is shown in Appendix A. An example Ringleman score chart is stored in Appendix B. This should be used in accordance with the instructions with the chart in Appendix B. Notifications are to be issued prior to the end of each shift during which the event occurred. Records of all unplanned flaring events to be maintained in Flaring Register.

6. REPORTING Monitoring and reporting is to be undertaken as specified in Schedules B, I and K of the EA.


APPENDIX A - Flaring Event Register Template

EVENT NO.

DATE START TIME

PLANT OPERATING CONDITIONS

CAUSE(S) Ringelmann Score

(1-5) ACTIONS TAKEN TO MINIMISE

TIME FLARING

EVENT STOPPED

Normal Shut-down / Start-up

Upset

(5 min trigger)


APPENDIX B – Ringelmann Smoke Chart

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Appendix E – QCLNG EA EPPG00711513, Schedule B – Air Emissions


Permit

Environmental Authority EPPG00711513

Date Granted: 29 June 2018 Page 5 of 34

SCHEDULE B — AIR EMISSIONS Nuisance (B1) The release of noxious or offensive odours or any other noxious or offensive airborne contaminants

resulting from the activities must not cause an environmental nuisance at any nuisance sensitive or commercial place.

(B2) The release of dust and/or particulate matter resulting from the activities must not cause an environmental nuisance at any nuisance sensitive or commercial place.

(B3) Dust and particulate matter must not exceed any of the following levels when measured at any

nuisance sensitive or commercial place: a) dust deposition of 120 milligrams per square metre per day over a 30-days averaging period,

when monitored in accordance with Australian Standard AS 3580.10.1 of 2003 (or more recent editions); or

b) a concentration of particulate matter with an aerodynamic diameter of less than 2.5 micrometres (PM2.5) suspended in the atmosphere of 25 micrograms per cubic metre over a 24-hour averaging time, at a dust sensitive place downwind of the licensed place, when monitored in accordance with the most recent version of: i) Australian Standard AS AS/NZS3580.9.10 Methods for sampling and analysis of ambient

air—Determination of suspended particulate matter—PM (sub)2.5(/sub) low volume sampler—Gravimetric method; or

ii) any alternative method of monitoring PM2.5 which may be permitted by the ‘Air Quality

Sampling Manual’ as published from time to time by the administering authority.

c) a concentration of particulate matter with an aerodynamic diameter of less than 10 micrometre (µm) (PM10) suspended in the atmosphere of 50 micrograms per cubic metre (with five one day exceedances allowed in any one year period); and over a 24 hour averaging time, at a dust sensitive place downwind of the licensed place, when monitored in accordance with: i) Australian Standard AS 3580.9.6 of 2003 (or more recent editions) 'Ambient air -

Particulate matter - Determination of suspended particulate PM10 high-volume sampler with size-selective inlet - Gravimetric method'; or

ii) any alternative method of monitoring PM10 which may be permitted by the 'Air Quality

Sampling Manual' as published from time to time by the administering authority. Note: The above 5 days exceedances per year are based on the expected exceedances from the

natural events such as bushfires and dust storm.

The Release of Contaminants to the Atmosphere (B4) The release of contaminants to the atmosphere from a point source must only occur from those

release points identified in Schedule B, Table 1 – Contaminant Release Points and must be directed vertically upwards without any impedance or hindrance.

(B5) Contaminants requiring on-going monitoring must be released to the atmosphere from a release point at a height and a flow rate not less than the corresponding height and velocity stated for that release point in Schedule B, Table 2 – Contaminant Release Limits to Air.

(B6) Contaminants must not be released to the atmosphere from a release point at a mass emission

rate/concentration, as measured at a monitoring point, in excess of that stated in Schedule B, Table 2 – Contaminant Release Limits to Air.

Permit



(B7) Contaminants must be monitored not less frequently than specified in Schedule B, Table 2 – Contaminant Release Limits to Air.

(B8) Monitoring of any releases to the atmosphere required by a condition of this approval must be

carried out in accordance with the following requirements: a) monitoring provisions for the emission sources listed in Schedule B, Table 2 – Contaminant

Release Limits to Air must comply with the Australian Standard AS 4323.1 - 1995 'Stationary source emissions, Method 1: Selection of sampling positions' (or more recent editions).

b) the following tests must be performed for each determination specified in Schedule B, Table 2 – Contaminant Release Limits to Air: i) gas velocity and volume flow rate; ii) temperature; iii) water vapour concentration (moisture content).

c) samples must be taken when emissions are expected to be at maximum rates. d) during the sampling period the following additional information must be gathered:

i) production rate at the time of sampling; ii) raw materials and fuel used; iii) number of plant or equipment and operating units operating; iv) reference to the actual test methods and accuracy of the methods.

(B9) All emission sources requiring monitoring must be conspicuously marked with the corresponding release point number and equipment number as identified in Schedule B, Table 2 – Contaminant

Release Limits to Air.

Schedule B, Table 1 – Contaminant Release Points Emission Source

Train 1 Emission Sources Train 1 Compressor Gas Turbines (x8)

Acid Gas Removal Unit 1 Nitrogen Rejection Unit 1





Other LNG Facility Emission Sources

Gas Turbine Power Generators (x4) Marine Flare

Process Flares (Wet and Dry Gas) Regeneration Gas Heaters 1 & 2

Hot Oil Heaters 1 & 2 Fire Water Pumps (diesel x3)

Back-Up Power Generators (diesel x6) Emergency Air Compressor (diesel x2)

Standby Generator at Marine Terminal Building (diesel x1)

Permit



Schedule B, Table 2 – Contaminant Release Limits to Air

Emission Sources Equipment Number Contaminant

Release

Release Height Above

Grade (m)

Emission Velocity

(m/s)

Maximum Release

Limit

Monitoring Frequency

Train 1 Gas Compressor Turbines Propane

Compressors 1TC-1411 1TC-1421 NOx 34 25

61 mg/Nm3 (dry) @ 15% O2 and 4.0

g/s Note 2

One stack per year on a

rotational basis Note 1

Ethylene Compressors

1TC-1511 1TC-1521 NOx 34 25

Methane Compressors

WHR* Unit Stacks 1TC-1611 (1H-3411) 1TC-1621 (1H-3421) NOx

49.2

8.2

Bypass Stacks 1TC-1611 (1H-3411-K01) 1TC-1621 (1H-3421-K01)

N/A



61 mg/Nm3 (dry) @ 15% O2 and 4.0 g/s Note 2

One stack per year on a

rotational basis Note 1


2TC-1511 2TC-1521 NOx 34 25

Methane Compressors


49.2

8.2


N/A



61 mg/Nm3 (dry) @ 15% O2 and 4.0

g/s Note 2

All stacks during commissioning (see Note 1) of the facility and one stack per year thereafter on rotational

basis


3TC-1511 3TC-1521 NOx 34 25

Methane Compressors


49.2

8.2


N/A

Power Generation Turbines

Gas Turbine Power

Generators

1TG-3101 1TG-3102 1TG-3103 1TG-3104

NOx 25 8.2

61 mg/Nm3 (dry) @ 15% O2 and 4.0

g/s

All stacks during commissioning (see Note 1) of the facility and one stack per year thereafter on rotational

basis * WHR = Waste Heat Recovery

Note 1: The above NOx release limits are applicable during all timings except start-up, shut-down and calibration of

emission monitoring devices. The start-up duration is allowed up to 30 minutes.

Note 2: The total mass emission rate from the WHR Unit and bypass stack from each methane gas turbine compressor

must not exceed 4.0 g/s NOx.

Permit



(B10) Within 3 months of commissioning the facility, the holder of this environmental authority must conduct air emission monitoring to demonstrate compliance with air emission limits listed in Schedule B, Table 2 – Contaminant Release Limits to Air and submit report to the administering authority.

Flare (B11) Visible smoke must not be produced from the flares except for a total of 5 minutes in any two hour

period during normal operating conditions.

(B12) Flaring events, except for those resulting from an emergency, occurring outside of normal operating conditions must not exceed:

a) 7 hours per annum during daylight hours; and b) 14 times per annum during daylight hours; and c) 30 minutes of continuous visible smoke during daylight hours except as authorised

under condition (B13).

(B13) Notwithstanding condition (B12)(c), individual flaring events must not exceed 90 minutes of continuous visible smoke in the following circumstances:

a) A flaring event associated with a plant maintenance activity that was planned to be completed outside of daylight hours, but was required to be undertaken during daylight hours to ensure the safe operation of the plant; or

b) A flaring event associated with a plant maintenance activity that was not planned and was required to be undertaken during daylight hours to ensure the safe operation of the plant.

(B14) The holder of this authority must keep records of each flaring event to determine compliance with

condition (B12) and (B13) and provide these records to the administering authority on request. Records must include, but not be limited to:

a) The duration of each flaring event; and b) The operational planning that was implemented to minimise flaring; and c) The operational controls that were implemented during flaring; and d) If the flaring event exceeds 30 minutes, the circumstance under condition (B13) which

caused this exceedance. (B15) The holder of this authority must monitor and record all flaring events in accordance with Schedule

B, Table 3 – Recording during flaring events and Condition (I3).

Schedule B – Table 3 – Recording during flaring events Table 3 – Monitoring of point source emissions to air

Emission point

references

Parameter Units Frequency Method Commencement of Recording

Process Flares (Wet and Dry Gas) and Marine Flare

Visual recording seconds Continuously during a flaring event

Digital Video Recorder

Commencing 29 January 2016

Temperature °C Continuously during a flaring event

CEMS

Vent gas flow rate m/s Continuously during a flaring event

CEMS

Vent gas composition

Multiple Continuously during a flaring event

CEMS Within 18 months of 29 January 2016

(B16) Contingency plans and emergency procedures must be developed and implemented for non-routine situations to deal with foreseeable risks and hazards including corrective responses to prevent and

Permit



mitigate environmental harm (including a contingency plan when plant shuts down for maintenance or other reasons).

Fugitive Emissions

(B17) The holder of this environmental authority must ensure that all reasonable and practicable measures

are taken in the design and operation of the plant to minimise fugitive VOC emissions. Reasonable and practicable measures include but are not limited to: a) implementation of a monitoring program to regularly leak test all units/components including

pumps, piping and controls, vessels and tanks; and b) operating, maintenance and management practices to be implemented to mitigate fugitive VOC

sources.

(B18) The ducting and extraction systems that transfer effluent gases from one location to another must be constructed, operated and maintained so as to minimise any leakage of VOCs and vapours to the atmosphere occurring from these sources.

(B19) In the event of emissions of contaminants occurring from industrial plant or ducting systems that transfer effluent gases from one location to another, the fault or omission that resulted in that emission must be corrected as soon as practicable.

Fuel Burning (B20) This authority only permits the burning of natural gas and diesel fuel in the fuel burning equipment

under normal operating conditions at the rate of the design capacity of the equipment. (B21) For commissioning and operation of the LNG Plant diesel fuel must only be used in the specified

diesel fuel burning equipment in Schedule B, Table 1 – Contaminant Release Points, under backup, standby, start up and/or emergency situations.

(B22) The sulphur content of fuel burned in the power generators must not exceed 0.5 percent by weight. Greenhouse Gas Emissions (B23) The holder of this authority must develop and implement a greenhouse gas reduction strategy for the

LNG Facility. The strategy must include, but not limited to, the company’s policy on greenhouse gas

emissions, an energy efficiency program, a continuous improvement program, better control systems and a CO2 recovery plan.

Appendix F – Proposed Amendment to the Environmental Authority (EPPG00712213)


Condition Number

Existing Condition Proposed Condition Justification

SCHEDULE B – AIR EMISSIONS

B2 The release of dust and/or particulate matter resulting from the activities must not cause an environmental nuisance at any sensitive or commercial place.

The release of dust and/or particulate matter resulting from the activities must not cause an environmental nuisance at any nuisance sensitive or commercial place unless the release occurs as a result of an emergency, or is authorised by this environmental authority or the EP Act.

Refer to section 2.5.3.1

B20 N/A Flaring events, except for those resulting from an emergency, occurring outside of normal operating conditions must not exceed: a) 7 hours per annum during daylight hours;

and b) 14 times per annum during daylight hours;

and c) 30 minutes of continuous visible smoke

during daylight hours except as authorised under condition (B21).

Refer to section 2.5

B21 N/A Notwithstanding condition (B20)(c), flaring events must not exceed 90 minutes of continuous visible smoke at any one time in the following circumstances: a) A flaring event associated with a plant

maintenance activity that was planned to be completed outside of daylight hours, but was required to be undertaken during daylight hours to ensure the safe operation of the plant; or

b) A flaring event associated with a plant maintenance activity that was not planned and was required to be undertaken during daylight hours to ensure the safe operation of the plant.



Condition Number


B22 N/A The holder of this authority must keep records of each flaring event to determine compliance with condition (B20) and (B21) and provide these records to the administering authority on request. Records must include, but not be limited to: a) The duration of each flaring event; and b) The operational planning that was implemented to minimise flaring; and c) The operational controls that were implemented during flaring; and d) If the flaring event exceeds 30 minutes, the circumstance under condition (B21) which caused this exceedance.


APPENDIX 1 - DEFINITIONS

N/A “daylight hours” means those between sunrise and sunset times as shown on the Australian Government Geoscience Australia webpage < http://www.ga.gov.au/geodesy/astro/sunrise.jsp>.


N/A “emergency” means (a) either— (i) human health or safety is threatened; or (ii) serious or material environmental harm has been or is likely to be caused; and (b) urgent action is necessary to— (i) protect the health or safety of persons; or (ii) prevent or minimise the harm; or (iii) rehabilitate or restore the environment because of the harm.

Refer to section 2.5 and 2.5.3.1

N/A “flaring event” means an event where flammable gas is combusted through a flare and produces visible smoke either (i) continuously for more than 5 minutes or (ii) multiple instances of visible smoke occurring consecutively with a total duration of more than 5 minutes, provided

Refer to section 2.5.3.1



Condition Number


that the consecutive instances of visible smoke occur due to the same underlying cause, discharges through the same valve or flare source and occurs within a two hour period.

“normal operating conditions” means the ongoing operation of the LNG plant following commissioning and excludes start-up, shutdown, maintenance or calibration of emission monitoring devices.

“normal operating conditions” means the ongoing operation of the LNG plant following commissioning and excludes, excluding start-up, shutdown, maintenance or calibration of emission monitoring devices and upset conditions, an emergency and LNG ship management.


N/A “plant maintenance activities” means the maintenance shutdowns (and subsequent start-ups) where equipment at the plant is inspected and, if needed, repaired or replaced to ensure the ongoing safe operation of the plant.


N/A “Ringelmann number” means a visually comparative scale used to define levels of opacity, where clear is 0, black is 5 and 1 through 4 are increasing levels of grey as used in describing smoke from combustion of hydrocarbons.


N/A “visible smoke” means a visible suspension of carbon or other particles in air measured by a Ringelmann number greater than 2.



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