liquid natural gas plantsubmission. a final dpemp was submitted to council with the permit...

ENVIRONMENTAL ASSESSMENT REPORT

Liquid Natural Gas Plant Westbury

BOC Ltd

Report and recommendations of the Environment Division Department of Environment, Parks, Heritage and the Arts to the Board of the Environment Protection Authority June 2009

Environmental Assessment Report – BOC LNG Westbury Plant

I

Environmental Assessment Report

Proponent BOC Ltd

Proposal Construction and operation of a liquid natural gas plant

Location Westbury

NELMS no. 7692

DA number 09/0232

File 110988

Document Class of Assessment

G:\EEO_Enviro_Ops\EAS_Assessments\EAS_Projects\BOC\Assessment\ BOC Ltd EAR 2B

Assessment process milestones

12 August 2008 Notice of Intent submitted

24 Sept 2008 DPEMP Guidelines issued

1 April 2009 Permit application submitted to Council

1 April 2009 Application received by Board

4 April 2009 Start of public consultation period

6 May 2009 End of public consultation period

Acronyms

Board Board of the Environment Protection Authority

DPEMP Development Proposal and Environmental Management Plan

DEPHA Department of Environment, Parks, Heritage and the Arts

DPIW Department of Primary Industries and Water

EIA Environmental impact assessment

EMPC Act Environmental Management and Pollution Control Act 1994

EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (Cth)

LUPA Act Land Use Planning and Approvals Act 1993

SD Sustainable development


II

Report summary This report contains an environmental assessment and recommendations to the Board of the Environment Protection Authority in relation to BOC Ltd’s proposed liquid natural gas (LNG) plant.

The proposal involves the construction of a plant to convert natural gas from the Tasmanian Gas Pipeline to produce approximately 50 tonnes per day of LNG for use as a heavy vehicle fuel. The proposed plant is to be located adjacent to the Tasmanian Alkaloids plant at Westbury.

This report has been prepared by the Environment Division of the Department of Environment, Parks, Heritage and the Arts based on information provided by the proponent in the Development Proposal and Environmental Management Plan (DPEMP). The advice of relevant Government Agencies and the public has also been sought and considered as part of this assessment.

Background to the proposal and details of the assessment process are presented in Section 1 of this report. Section 2 describes the context of this assessment. Details of the proposal are contained in Section 3. Section 4 reviews the need for the proposal and considers the project, site and design alternatives. Section 5 summarises the public and Agency consultation process and the key issues raised in that process. The detailed evaluation of key issues is contained in Section 6. Section 7 identifies other environmental issues and the report conclusions are contained in Section 8.

Appendix 1 contains a tabular evaluation of other environmental issues referred to in Section 7. Appendix 2 contains a summary of issues raised in the consultation process. Appendix 3 contains recommended environmental permit conditions for the proposal. Attachment 2 of the recommended permit conditions contains the table of commitments from the DPEMP.


IV

Table of Contents

1 Approvals process ..................................................................................... 1

2 SD objectives and EIA principles .............................................................. 2

3 The proposal ............................................................................................. 3 4 Need for proposal and alternatives ........................................................... 7

5 Public and agency consultation ................................................................. 8 6 Evaluation of key issues ............................................................................ 9

6.1 Noise ...................................................................................................................... 9 6.2 Atmospheric emissions ......................................................................................... 13

7 Other environmental issues ..................................................................... 17

8 Conclusions ............................................................................................. 17 9 References .............................................................................................. 17 10 Summary of appendices ....................................................................... 18


1

1 Approvals process An application for a permit under the Land Use Planning and Approvals Act 1993 (LUPA Act) in relation to the proposal was submitted to Meander Valley Council on 1 April 2009.

The proposal is defined as a ‘level 2 activity’ under Schedule 2 Subsection (1)(a)(ii) of the Environmental Management and Pollution Control Act 1994 (EMPC Act), being a chemical works (manufacture of organic products). Section 25(1) of the EMPC Act required Council to refer the application to the Board of the Environment Protection Authority (the Board) for assessment under the Act. The application was received by the Board on 1 April 2009.

The Board required that additional information to support the proposal be provided in the form of a Development Proposal and Environmental Management Plan (DPEMP) prepared in accordance with guidelines jointly issued by the Board and Meander Valley Council. The final guidelines were issued to the proponent on 24 September 2008.

One draft of the DPEMP was submitted to the Department for comment prior to its formal submission. A final DPEMP was submitted to Council with the permit application. The DPEMP was released for public inspection for a 28-day period commencing on 4 April 2009. Advertisements were placed in the Advocate, Examiner and Mercury newspapers and on the EPA web site. The DPEMP was also referred at this time to relevant government agencies for comment. No public submissions were received.


2

2 SD objectives and EIA principles The proposal must be considered by the Board in the context of the sustainable development objectives of the Resource Management and Planning System of Tasmania (RMPS), and in the context of the objectives of the Environmental Management and Pollution Control System (EMPCS) established by the EMPC Act. The functions of the Board are to administer and enforce the provisions of the Act, and in particular to use its best endeavours to protect the environment of Tasmania, and to further the RMPS and EMPCS objectives.

The Board must undertake the assessment of the proposal in accordance with the Environmental Impact Assessment Principles defined in Section 74 of the EMPC Act.


3

3 The proposal BOC Ltd proposes to construct a liquid natural gas (LNG) Facility that will produce 50 tonnes of LNG per day from natural gas sourced from the Tasmanian Gas Pipeline at an industrial site near Westbury (Figure 1). The process involves purification of natural gas, drying of the purified gas to remove water, and refrigeration of the dried, purified gas to produce LNG (Figures 2 and 3). The LNG will be stored in two vacuum insulated tanks on site. A ground flare will be used to burn waste gases. A cooling tower will also be required.

The main characteristics of the proposal are summarised in Table 1. A detailed description of the proposal is provided in Section 2 of the DPEMP.

Table 1: Summary of key proposal characteristics Characteristic Description/quantities

Activity description Conversion of natural gas to liquid natural gas (LNG)

Location Lot 7 within the recently created industrial precinct, ‘Trans Central Industrial Precinct’ approximately 1.5 km north of the Westbury town centre off Birralee Road.

Land zoning Industrial

Land tenure BOC Ltd will purchase the land when the subdivision is completed.

Site overview The proposed plant is to be located in the newly established ‘Trans Central Industrial Precinct’, which is adjacent to the Tasmanian Alkaloids plant on Birralee Road, Westbury. The precinct is flat and is crossed by a shallow drainage line from north-east to south-west. The site has previously been used for agricultural land uses and is dominated by exotic pasture species. The Tasmanian Gas Pipeline traverses the precinct.

Surrounding area overview Trans Central Industrial Precinct is located approximately 1.5km north of Westbury (Figure 1). Bass Highway runs in an east-west direction approximately 600m to the south of the site. The township of Westbury is approximately 1km further south of the Bass Highway. The surrounding area is predominantly agricultural with some industry and services (refuelling depots etc).

Major equipment Cold Box and Refrigeration Plant, LNG Storage Tanks (2 x 120 t), Flare System, cooling tower, gas purification equipment.

Inputs

Water 23.2 kL/day

Energy 13,000 MW per year

Other raw materials 19,270 tonnes of natural gas per year

Wastes

Liquid Approximately three kilolitres of wastewater per day to sewer. Approximately 20 kilolitres of water emitted to the atmosphere from the cooling tower.

Atmospheric A flare will burn approximately 475 kg of waste gas per hour. The DPEMP stated that the activity would produce 10.03 kt CO2-e per year based on electricity purchased and on site emissions.

Solid Some construction waste. Several controlled wastes and other solid wastes will be produced during operations.

Noise Major sources are compressor, drive line, motor & gear box; valves, cooling tower, flare and forklift.

Operating hours It is proposed that the plant will operate 24 hours a day, 7 days a week.

Project timetable It is proposed that construction will begin August 2009 and be completed by March 2010. The plant life is expected to be greater than 30 years. A decommissioning plan has not been formulated yet.


4

Figure 1: Proposed location (Modified from Figure 4-1 of the DPEMP)


5

Figure 2 Site Layout Plan (From Figure 2-1 of the DPEMP)


6

Figure 3: Process overview (Figure 2-2 of the DPEMP).


7

4 Need for proposal and alternatives •Project purpose

The proposed plant will produce 50 tonnes of LNG per day. The proposal is being developed in conjunction with several Tasmanian transport companies who plan to convert their trucks from diesel to LNG engines. The LNG will be transported to dedicated refuelling stations around the state.

•Project site alternatives and rationale

The proponent considered Bell Bay and Longford as sites for this proposal. They were rejected because of issues relating to zoning (Longford) and costs associated with pipeline access (Bell Bay).

•Project design alternatives and rationale

The DPEMP provided a range of alternatives to the design chosen (section 2.7 of the DPEMP) and the rationale for the chosen design. These included

• It was initially proposed that sulphur removal would occur in a sacrificial catalyst bed, however the proponent concluded that little additional environmental benefit could be achieved due to the very low quantities in the NG feed and consequently it is proposed that sulphur removal will be sent directly to the flare.

• The plant was originally designed for air cooling to aid the modular design approach; however due to both losses in process efficiency and high capital costs the design reverted to a reticulated cooling water system.

• Consideration was also given to using a gas engine to generate power rather than burning the gas via an enclosed flare. However the gas quantity was not sufficiently large to make an economic case for a gas engine.

• Having two 300,000 litre tanks, instead of five 100,000 litre tanks to minimise the amount of pipe work connecting the tanks together and therefore minimising the potential for leaks.

• The compressor selected is a turbo compressor, and it was chosen for the refrigeration cycle based on better energy efficiency and maintenance requirements.

•Consequences of the project not proceeding.

According to the DPEMP the project will provide an alternative fuel source with lower emissions for heavy vehicles. This therefore has environmental benefits and would be expected to provide price competition to diesel.


8

5 Public and agency consultation A summary of the government agency/body submissions is contained in Appendix 2 of this report.

No public representations were received.

The DPEMP was referred to a number of government agencies/bodies with an interest in the proposal. Responses were received from the following:

• Development and Conservation Assessment Branch (DCAB) of DPIW

• Workplace Standards Tasmania (WST, Dept of Justice)

The following Divisions/Areas of the Department of Environment, Parks, Heritage and the Arts also provided submissions on the DPEMP:

• Aboriginal Heritage Tasmania;

• Noise Specialist Environment Division; and

• Air Specialist Environment Division;

According to the DPEMP, the proponent has also undertaken their own public consultation process involving; Australian Therapeutic Proteins and Tasmanian Alkaloids (industrial neighbours) and three residential neighbours along Birralee road. Groups consulted included members & representatives of: Westbury Working Together, Westbury Business Group, Westbury Hagley Development Association, Great Western Tiers Tourism Association, Meander Valley Enterprise Centre, Deloraine on the Move, Westbury Rotary, Deloraine Rotary, Westbury Apex, Deloraine Apex, Westbury Hagley Independent Service Club. Additional consultation was conducted through public forums at Westbury and Deloraine.


9

6 Evaluation of key issues The DPEMP Project Specific Guidelines required the proponent to respond to five key issues in the DPEMP. These were;

1. Potential noise effects on surrounding residences associated with the operation of the proposal;

2. Potential impacts of air emissions;

3. Potential impacts of fire or explosion within the site, and on offsite premises;

4. Potential impacts of wastewater discharge; and

5. Potential impacts on threatened flora and fauna.

Subsequent to the provision of the DPEMP Project Specific Guidelines, it is now considered that wastewater discharge, flora and fauna, and fire and explosion are not key issues. Wastewater is to be discharged to sewer, the results of a flora and fauna survey indicate minimal potential impact, and the risk associated with fire and explosion will be regulated through assessment under the Dangerous Substances (Safe Handling) Act 2005, which is enforced through Workplace Standards Tasmania (Dept of Justice). An assessment of these three issues is provided in sectiono7.

The key environmental issues relevant to the proposal that were identified for detailed evaluation in this report were:

• Noise; and

• Atmospheric emissions;

These issues are discussed individually in the following Sections. The table of commitments from the DPEMP is included in Attachment 2 of Appendix 3 of this report (proposed permit conditions).

6.1 Noise

Description

Existing environment.

The proposed plant will be located adjacent to the Tasmanian Alkaloids plant on Birralee Road. A noise assessment was conducted, and included noise modelling to determine the potential impact on sensitive receptors. The approach to be used (including establishment of background noise levels) was defined in consultation with the Environment Division Noise Specialist. The noise assessment report was included as Appendix D of the DPEMP, and summarised within the DPEMP.

Eight noise sensitive receptors were identified (Table 2 and Figure 4). Background noise levels were measured using long-term unattended and short term attended monitoring. The background noise levels were calculated based on the results from unattended loggers placed at receptors A, C and H. These locations were chosen because they were considered to be the most representative of the noise results.


10

Table 2: Noise Sensitive Receptors (From Table 2-1 of appendix D, DPEMP)

Receptor Address Approx Distance from Centre of Site (m)

Nearest Site Boundary

A 310 Birralee Road 1300 NW

B 209 Emu Plain Road 1650 E

C 46 Lyttleton Street 1200 SE

D 12 Lyttleton Street 900 SE

E 1 Birralee Road 1100 S

F 52 Deviation Road 1750 SW

G 135 Birralee Road 550 SW

H 139 Birralee Road 400 SW

Figure 4 Sensitive Noise Receptor Locations (From figure 4-1 DPEMP)

Proposed Site

N

Receptor G

Receptor H

Source: Aerial image from Google Earth (URS Copyright, Google Earth 2009)

Receptor A Receptor B

1km from Site

Receptor D Receptor C

Receptor E

Receptor F


11

Table 3: Measured Noise Levels - All Locations (From Table 4-7 of the DPEMP)

Location Rating Background Level (RBL) LA90 dB(A)

Day Evening Night

A: 310 Birralee Road, Westbury 29 28 28

C: 46 Lyttleton Street, Westbury 41 39 35

H: 139 Birralee Road, Westbury 38 33 28 Notes:

• Any 15min periods affected by extraneous noise or adverse weather conditions were excluded from calculations.

• Time of Day — Day: 7.00am – 6.00pm, Monday to Saturday; or 8.00am – 6.00pm on Sundays and public holidays — Evening: 6.00pm – 10.00pm, all days

— Night: 10.00pm – 7.00am, Monday to Saturday; or 10.00pm – 8.00am on Sundays and public holidays

The calculated background noise levels are presented in Table 3. According to the DPEMP, the rating background noise levels (RBL), presented in Table 3, were used to derive noise limits for the identified noise sensitive receptor locations.

Construction Noise Sound power levels of various construction equipment were derived from Australian Standard AS 2436-1981: “Guide to noise control on construction, maintenance and demolition sites” and predicted for each receptor location, as presented in Table 4.

Table 4: Predicted Construction Noise Levels (From Table 4-8 of the DPEMP)

Location Predicted Noise Level

(Enhanced Met Conditions) Leq dB(A)

Noise Criterion

Leq dB(A) Exceedance

A 36 45 No B 30 45 No

C 36 46 No D 37 46 No E 35 45 No F 29 46 No G 44 45 No H 50 45 ~ 5 dB

Note: Properties at Locations G and H will not be used for residential purpose from April 2009.

The modelling predicted that the noise levels under worst case meteorological conditions were within the established construction noise limits at all receptor locations except for Location H (Table 4).


12

Operational Noise

The predicted operational noise levels at each of the receptor locations are outlined in Table 5

Table 5: Predicted Operational Noise Levels (From Table 4-9 of the DPEMP)

Location

Predicted Noise Level (Leq), dB(A) Criterion (Leq) dB(A)

Exceedance Day/Evening Night Day Evening Night

Enhanced Enhanced A < 25 < 25 45 40 35 No B < 25 < 25 46 44 40 No C < 25 < 25 46 44 40 No D < 25 < 25 45 40 35 No E < 25 < 25 46 44 40 No F 28 28 45 40 35 No G 32 32 45 40 35 No H < 25 < 25 45 40 35 No

The modelling predicted that noise criteria for operations would not be exceeded. According to the DPEMP, none of the noise sources would contain characteristics such as prominent tonal component, impulsiveness or dominant low frequency content.

Management measures

Construction

Noise management strategies were outlined in the Noise Impact Assessment and the proponent stated that these could be applied to reduce construction noise if noise levels were exceeding permit conditions. These strategies included scheduling of construction activities, such as the movement of heavy vehicles to standard daytime construction hours (Commitment 1).

Operation

According to the DPEMP, the proponent will install acoustic barriers around noise generating machinery such as the compressor and the letdown valve (Commitment 7).

On commissioning, noise monitoring will be conducted to confirm the conclusions of the Noise assessment (Commitment 11).

Submissions No submissions relating to noise were received. The Division Noise Specialist reviewed both the draft and final DPEMPs.

Evaluation The computer modelling that was used to predict the noise levels due to the construction and operation of the proposed LNG plant assumed a worst-case scenario of noise emissions and atmospheric conditions in relation to the nearest noise sensitive premises.


13

Based on the modelling provided and the potential to further reduce construction noise emissions through simple scheduling controls, the Environment Division’s Noise Specialist recommends that the noise emission limits for the activity should be the same as those suggested by the proponent. Recommended condition N1 imposes the following noise limits:

45dB(A) during daytime (0700-1800), 40 dB(A) for evening (1800-2200), and 35 dB(A) for night-time (2200-0700).

For the construction period; 50dB(A) during daytime 40 dB(A) for evening and 35 dB(A) night-time

These are limits typically set for activities of this nature.

It is recommended that the proponent be required to carry out noise surveys to determine whether noise emission limits are being complied with (N2) and that a report detailing the results of the surveys be provided to the Director (N3).

Recommendations Relevant management commitments outlined in the DPEMP and summarised above should be included in permit.

Standard conditions for the operation of industrial facilities with noise emissions, as routinely issued by the Director, should be included.

N1 Construction and Operation Noise Emission Limits

N2 Noise Survey Requirements

N3 Noise Survey Report Requirements

6.2 Atmospheric emissions

Description

The only emission point source to atmosphere under normal operating conditions will be the ground flare. The flare will be used to burn waste gases including dihydrogen sulphide, and will have an enclosure height of 9.52m above ground and will be refractory lined. The flare is designed to shield people against radiant heat, and to direct emissions vertically into the atmosphere.

To assess potential impacts of the proposed emissions on the Westbury airshed, the proponent undertook atmospheric dispersion modelling. The approach to be used (including establishment of background ambient air quality concentration levels for the chosen contaminants) was defined in consultation with the Environment Division Air Modelling Specialist.

The modelling approach used TAPM (‘The Air Pollution Model’), an atmospheric dispersion model developed by CSIRO Marine and Atmospheric Research to produce input meteorological and terrain data. Air quality impacts from the Facility were predicted using the Ausplume dispersion model.

According to the DPEMP, the modelled substances were chosen based on knowledge of the LNG production process, and estimations of oxidation of flare gas constituents at the ground flare.

Emissions of the following gasses were considered for the assessment:

• Odorous compounds in natural gas: dihydrogen sulphide and methyl mercaptan;

• Hydrocarbons in natural gas: pentane and hexane; and

• Products of combustion: oxides of nitrogen as nitrogen dioxide, carbon dioxide and sulphur dioxide.


14

Three scenarios were used. These were normal operation; normal operation and road tanker depressurisation (venting of LNG from a road tanker to the flare); and Start up.

The modelling results were compared against the relevant Air NEPM standards for populated regions (National Environment Protection (Ambient Air) Measure, 1998), and the Air EPP Environment Protection Policy (Air Quality), 2004. The DPEMP stated that under all modelled scenarios the predicted ground level concentrations, including the addition of background levels, were below the assessment criteria. The results for each modelled substance, under the worst case impact scenario (normal operation and road tanker depressurisation), are summarised as follows:

• The predicted maximum concentration of carbon monoxide was over 100 times lower than its assessment criterion;

• The predicted maximum concentrations (hourly average and annual average) of nitrogen dioxide were over 3 times lower than their respective assessment criteria;

• The predicted maximum concentrations of sulphur dioxide (hourly, daily and annual averages) were over 30 times lower than their respective assessment criteria;

• The predicted maximum concentration of dihydrogen sulphide was over 100 times lower than its assessment criterion;

• The predicted maximum concentration of methyl mercaptan was over 65 times lower than its assessment criterion;

• The predicted maximum concentration of pentane was over 68,000 times lower than its assessment criterion; and

• The predicted maximum concentration of hexane was over 16,000 times lower than its assessment criterion.

Management measures

• Operate the ground flare to thermally destroy waste gasses and excess hydrocarbons vented through pressure relief systems (Commitment 8).

• BOC commits to confirming the assumptions made in the Air Impact Assessment involving monitoring feed gas flare in conjunction with flare flame temperature (infrared) (Commitment 9).

• On commissioning, air quality will be monitored to confirm the conclusions of the air quality impact assessment (Commitment 10).

Submissions

There were no public representations. The Division Air Modelling Specialist reviewed the DPEMP.

Evaluation

The DPEMP stated that the modelling used to assess potential impacts to air quality was very conservative in nature. It used worst-case scenarios with regards to operating and meteorological conditions. It predicted that Tasmanian and national air quality guidelines would not be exceeded during the operation of the proposed LNG plant. In addition, the Division Air Modelling Specialist was consulted through the assessment process and an example Ausplume model output file was provided in Appendix D of the DPEMP to enable the Division Air Modelling Specialist to assess model configuration and output. The specialist has confirmed that the modelling was appropriate.


15

The specialist is of the opinion that the emission concentrations for the parameters used in the modelling could be significantly increased to derive emission limits in most cases. This approach was taken because the modelling indicates that the emissions represent less than 5% of the criterion. Consequently, the recommended emission limits were adjusted as per Table 6.

Table 6: Proposed emission rates from flare.

Parameter Mass Emission Rates, g/s (from

Table 5-3, DPEMP)

Percentage of Criterion (%)

Adjustment Factor

(%)

Proposed Emission Rates (g/s; rounded)

Carbon Monoxide (CO) 1.484 0.9 500 8.9

Nitrogen Dioxide (NO2) 0.256 30.9 10 0.28

Sulphur Dioxide (SO2) 0.036 0.4 500 0.2

Hydrogen Sulphide (H2S) 0.000046 0.9 500 0.0003

Methyl Mercaptan 0.00047 1.4 200 0.0015

Pentane 0.034 0.001 500 0.2

Hexane 0.014 0.01 500 0.1

It is concluded that the activity should not have a deleterious effect on air quality if the emission limits (A1) are not exceeded.

In order to establish that an activity is meeting their requirements under the Air NEPM and Air EPP, a common permit condition requires the proponent to conduct stack testing. Stack testing is not practical for this facility because the flare configuration does not meet the requirements for stack testing under AS 4323.1 – 1995 Stationary Source Emissions – Selection of sampling positions. This standard stipulates the height at which sampling points should be located. This is to ensure that the gases are homogenous. These conditions will not occur in the case of the proposed flare because the flame is close to the tip of the enclosure.

An alternate method to assess the efficiency of the flare would be to measure the flow rate, mass and composition of gases entering the flare and measure the temperature of the flame. In this way, using established destruction rates of gases at particular temperatures, the emission rates and composition of gases can be estimated. The proponent agreed that this would be the most appropriate way to establish emission rates and made commitment in this regard (Commitment 9 and 10).

It is recommended that the proponent be required to submit a sampling plan for measuring the efficiency of the flare (A2) prior to commissioning. This plan should detail how gases will be collected prior to combustion, how flare temperature will be measured and the locations for sampling. Condition A3 would require the proponent to conduct testing within three months of the completion of commissioning, and annually thereafter (unless otherwise approved by the Director) using the methods approved for condition A2 and submit a report to the Director within 60 days of the testing.

Recommendations

It is recommended that the proponent be required to comply with their commitment (G8).


16

The following site-specific atmospheric conditions are recommended for inclusion in the permit: A1 Flare Emission Limits A2 Flare Efficiency Testing A3 Flare Efficiency Testing Frequency


17

7 Other environmental issues In addition to the key issues, the following environmental issues are considered relevant to the proposal and have also been evaluated.

• Aboriginal heritage

• Air pollution (dust)

• Decommissioning/Remediation

• Effluent (wastewater and sewage)

• Erosion and sediment

• Fire and explosion

• Flora and fauna habitat

• Groundwater

• Hazardous materials and dangerous goods

• Public health

• Stormwater

• Waste management

Details of this evaluation, along with recommended permit conditions, are contained in Appendix 1.

8 Conclusions The Environment Division is of the view that:

(i) the RMPS and EMPCS objectives have been duly and properly pursued in the assessment of the proposal; and

(ii) the assessment of the proposal has been undertaken in accordance with the Environmental Impact Assessment Principles; and

(iii) the recommendations set out in this report accord with the Board’s responsibilities in relation to these objectives and principles.

This assessment has been based upon the information provided by the proponent in the DPEMP.

This assessment has incorporated specialist advice provided by Divisions of DEPHA and DPIW in relation to a number of key issues.

It is concluded that the proposal is capable of being managed in an environmentally acceptable manner such that it is unlikely that the RMPS and EMPCS objectives would be compromised, provided that the recommendations made in this report are satisfactorily implemented, including the commitments made by the proponent in the DPEMP.

9 References URS, 1 April 2009, Development Proposal and Environmental Management Plan, Liquid Natural Gas Facility Westbury, Tasmania.

Environmental Assessment Report – BOC Westbury LNG Plant

Appendix 1

10 Summary of appendices Appendix 1 Assessment of other environmental issues

Appendix 2 Summary of issues raised by public and agency submissions

Appendix 3 Proposed permit conditions, includes DPEMP Commitments at Attachment 2

Appendix 1 Assessment of other environmental issues

Issue

Aboriginal Heritage

Description of potential impacts

Impacts on Aboriginal heritage during construction.

Management measures proposed in DPEMP

The DPEMP stated that an Aboriginal Heritage survey was not conducted because previous studies for the Tasmanian Gas Pipeline indicated no likely occurrence of Aboriginal heritage in the vicinity of the site. In the unlikely event that an Aboriginal relic is found, the provisions of the Aboriginal Relics Act 1975 would be followed (Commitment 6).

Public and agency comment

Aboriginal Heritage Tasmania (AHT) reviewed a draft of the DPEMP. AHT stated that there was no need for any Aboriginal heritage surveys for the project area, as it has been covered off in previous surveys /monitoring for the Duke Energy Gas pipeline. There was also no need for an Aboriginal Heritage Officer to be onsite at any stage of construction for monitoring purposes. However, the proponent must comply with the Aboriginal Relics Act 1975

Evaluation

The project is unlikely to impact on cultural heritage. Any relics discovered should be managed in accordance with the Aboriginal Relics Act 1975 (refer Information Schedule LO4).

Recommendation

It is recommended that the proponent be required to comply with DPEMP Commitment 6 (Covered by standard condition G8), and the permit contain the standard information LO4.


Appendix 1

Issue

Air pollution (dust)


Dust is likely to be generated during the construction phase

Management measures proposed in DPEMP • Minimisation of drop heights; • Undertaking of earthworks during periods of when soil moisture content is enough to suppress

dust emissions from earthworks; • Introduction of speed limits to minimise dust generation from unmade roads; • Limitation of the use of non-essential vehicles on site; • Covering of loads of excavated material; • Minimisation of stockpile area to reduce wind erosion; • Periodic watering of exposed land during extended dry periods; • Watering of long term undisturbed stockpiles and stockpiles considered to be causing an

offsite impact; and • Use of vegetation on stockpiles with a static residence time of longer than 3 months.


No public or agency comments were received.

Evaluation

The mitigation measures proposed in the DPEMP are considered adequate.

Recommendation

The Construction Environmental Management Plan should include details of proposed dust reduction measures (CN1).

Issue

Decommissioning/Remediation


Site may not be decommissioned appropriately, leading to ongoing environmental impacts.


The DPEMP stated that the proposed plant would have an operating life of at least 30 years. Therefore, no formal timing or process for decommissioning has been established.



Evaluation

Standard decommissioning conditions requiring a Decommissioning Plan are adequate for this proposal.

Recommendation

Permit conditions to include standard decommissioning/ rehabilitation conditions DC1 (Notification of cessation) DC2 (DRP requirements), and DC3 (Rehabilitation following cessation).


Appendix 1

Issue

Effluent (wastewater and sewage)


Contamination of land and water. The cooling water will be dosed with biocides to control biological growth within the cooling water system. The treatment regime has not yet been finalised, but will incorporate two biocides.


The DPEMP stated that approximately 100 litres per day of domestic wastewater may be produced on site. Process water will consist of the demineralised water plant (reverse osmosis unit) reject stream; and cooling tower blowdown stream. This is expected to be less than 3 kl/d. Both streams will be sent to sewer. Total dissolved solids (TDS) are expected to be approximately 1000 mg/L on average and a maximum of 4000 mg/L. The Meander Valley Council advised the Division that the average TDS was only marginally higher than the discharge from the Westbury wastewater treatment plant (WWTP) and that the volumes represent less than 1% of the inflow to the WWTP. The Council considers that this trade waste is therefore unlikely to adversely affect the operation of the Westbury WWTP. The residual biocide would typically be diluted at least 100 times within the sewerage system and would not therefore be expected to have any impact. The DPEMP stated that once the specific biocide treatment is finalised, details will be provided to Council to confirm that there will be no impact on the treatment plant.



Evaluation

The proposed management measures in regard to TDS appear adequate. While the discharge water containing biocide residue would be diluted within the Westbury WWTP, these biocides could potentially impact on the functioning of the WWTP. Condition EF3 (Biocide management plan) requires the submission of a plan detailing the types of biocide treatments to be used, the concentration and timing of treatments, and an assessment of the potential impact on the Westbury WWTP.

Recommendation

Permit conditions to include non-standard condition EF1 and EF3, and standard condition EF2.


Appendix 1

Issue

Erosion and sediment


Soil erosion and sediment transport off site is possible during the construction phase.


Minimisation of stockpile area to reduce wind erosion (Commitment 1). Stormwater runoff from the site would be discharged into the municipal stormwater drain via a sediment interceptor pit.



Evaluation

Condition CN1 (Construction Environmental Management Plan) would require the proponent to provide details of erosion and sediment management. Compliance with CN1, and management controls outlined in the DPEMP (including commitments), should ensure that impact from erosion and sediment is minimised.

Recommendation

It is recommended that the proponent be required to comply with standard permit conditions CN1, and non-standard permit condition G8 (Commitments).


Appendix 1

Issue

Fire and Explosion


Potential damage to the pollution control equipment used on-site, or by neighbouring activities (eg Tasmanian Alkaloids) and other impacts on life, property and the environment.


The DPEMP included a report of a preliminary hazard assessment (PHA) that was prepared by Lloyd’s Register (Appendix H). It was stated that the PHA was prepared in accordance with the NSW Department of Planning (DOP) in Hazardous Industry Planning Advisory Paper (HIPAP) No 6 – Guidelines for Hazard Analysis. A risk assessment (RA) was also prepared by Lloyd’s Register using the criteria published by DOP in HIPAP No 4 – Risk Criteria for Land Use Planning. The DPEMP stated that these guidelines were chosen because they are the most stringent of all state guidelines. Lloyd’s Register used methods such as workshops to identify credible threats. Risk assessments were conducted for seventeen major accident events (MAEs). The RA included the proposed mitigation methods (such engineering and process controls). The DPEMP stated that the PHA and RA identified that the proposed LNG Facility would comply with all the risk criteria published by the NSW DOP.


Workplace Standards Tasmania (WST) provided advice as to how the activity will be regulated in relation to risk from fire or explosion. The risks associated with the facility will be managed under the new Dangerous Substances (Safe Handling) Act 2005, which will take effect on 1 July 2009. The proposed plant will be designated a Major Hazard Facility. This designation requires the proponent to submit a Safety Report to WST, which is a statement of how risks will be managed. The report must include details of consultation with emergency services, neighbouring activities and the local community. The Report must also clearly demonstrate that the plant design and operating procedures will ensure that the facility presents the lowest risk possible for that particular type of activity. The proponent has held extensive consultations with WST (and other agencies) in relation to preparation of the Safety Report (pers. comm. Danny Dougherty, Compliance Manager, WST).

Evaluation

The proponent has stated that their PHA and RA were conducted using the most stringent criteria and the plant would comply with all the risk criteria. For example, the RA found that the risk of heat radiation or explosion resulting in an injury to a person at the adjacent Tasmanian Alkaloids site was predicted to be 100 times less than the acceptable risk criterion for residential areas. The proponent’s Safety Report must demonstrate to the Secretary of the Department of Justice that the risk at the facility is at an acceptable level, i.e. the risk has been minimised as far as reasonably practicable having regard for the likelihood of harm to a person, property or the environment related to the risk; and the severity of the harm, to be allowed to operate under the Dangerous Substances (Safe Handling) Act 2005. It is therefore the opinion of the Division that the risk to the environment should be acceptable.

Recommendation

No conditions are required in the permit because potential impacts resulting from internal fire or explosion will be managed through another Act (Dangerous Substances (Safe Handling) Act 2005).


Appendix 1

Issue

Flora and Fauna Habitat


A flora and fauna assessment was conducted for the overall Trans Central rezoning and subdivision, which includes the subject site. The site was previously agricultural land, and is not considered to have significant flora and fauna values. A survey of the wider area found that suitable habitat exists for the EPBC listed Green and Gold Frog (Litoria reniformis) on the west side of Birralee Road. Activities on the proposed site (such as construction) could impact on the Green and Gold Frog through the spread of the amphibian Chytrid Fungus. This fungus can be spread through the movement of infected water, tadpoles and frogs.


Ensuring that all machinery and equipment used during construction of the proposed LNG Facility be managed to control the spread of the Amphibian Chytrid Fungus, by adhering to the Tasmanian Washdown Guidelines for Weed and Disease Control: Machinery, Vehicles and Equipment, Edition 1. These Guidelines include instructions on when to Washdown, Equipment for Washdown and Washdown Procedures. Specifically, the following instructions should be adhered to:

All equipment, vehicles and footwear should be dry and clean before entering the site to prevent spread of the Fungus via contaminated soils. The disposal of water and damp or muddy soils at the proposed development site should be minimised or undertaken as far away as possible from waterways, ponds and/or wetlands (Commitment 2).

Under the Weed Management Act 1999, landholders are required to take action to ensure that the declared weeds do not spread onto un-infested areas or neighbouring properties (Commitment 3)


The Development and Conservation Assessment Branch (DCAB) of DPIW supported the management measures to control the spread of amphibian Chytrid Fungus and considered that it is unlikely that construction and operation of the plant would impact natural values in the area. DCAB noted that discharges into waterways could impact the Green and Gold frog and in particular, herbicides should be used appropriately.

Evaluation

DCAB have suggested that the only potential impact of construction and operation on threatened species would relate to the Green and Gold frog and that this impact related to the spread of amphibian Chytrid Fungus and contaminated water impacting on frog habitat. Recommended permit condition FF1 requires the proponent to submit a Weed and Pathogen Management Plan. The plan requires details of the measures to be used to control the spread of weeds and plant and amphibian pathogens, and the spread of weeds on the Land. Measures to control weeds will need to include how potential impacts from herbicides will be managed.

Recommendation

It is recommended that the proponent be required to comply with non standard permit conditions FF1.


Appendix 1

Issue

Groundwater


Contamination of groundwater


According to the DPEMP the only liquid chemicals that could impact on groundwater quality that will be present on the site in any significant quantity will be located in fully concrete lined and bunded areas.



Evaluation

Bunded areas should limit the potential for any contaminant to enter groundwater directly. Bunding should also limit the potential for stormwater to become polluted through contact with these chemicals.

Recommendation

It is recommended that the proponent be required to comply with standard permit conditions H1, H2 and H3 detailed below in Hazardous materials and dangerous goods section.

Issue

Hazardous materials and dangerous goods


Hazardous materials and dangerous goods proposed to be stored and handled on the site (other than natural gas) include refrigerant gas, activated methyldiethanolamine, compressed nitrogen, various oils, and water treatment chemicals.


According to the DPEMP, all materials will be managed in accordance with the appropriate legislation, and standards. Storage will be in bunded areas at least 110% of the maximum inventories



Evaluation

According to the DPEMP, hazardous materials and dangerous goods were included in the risk assessments described in the Fire and Explosion section above. It is therefore considered that appropriate controls are proposed. It is recommended that the permit contain condition H1 (Storage and handling of hazardous materials), H2 (Hazardous materials <250 litres) and H3 (Spill kits).

Recommendation

It is recommended that the proponent be required to comply with standard permit conditions H1, H2 and H3.


Appendix 1

Issue

Public health


Health impacts caused by pathogens such as Legionella being emitted from the cooling tower.


The DPEMP stated that; • A Safety Health and Environment Management Plan will be developed for the proposed

LNG Facility which will consider the potential risk to human health associated with the operation of the cooling tower.

BOC commits to the following actions regarding operations, maintenance and testing of the cooling tower at the proposed LNG Facility: • The cooling tower will be registered with the Meander Valley Council as a regulated system

under the Public Health Act 1997. • Cooling tower to be cleaned and treated with biocides by a water treatment expert prior to

start-up. • Mandatory monthly inspections, at least six monthly cleaning and annual disinfection of the

cooling tower. • Representative sample of water to be taken and tested on a monthly basis for:

— Heterotrophic Colony Count (HCC); — Legionella bacteria.

• If the testing of the representative water sample from the cooling tower reveals the presence legionella bacteria at a level greater than 10 colony forming units/mL; or a HCC greater than or equal to 100,000 colony forming units/mL, BOC will initiate a control strategy in accordance with the relevant Australian Standard (AS/NZ 3666.3 Air Handling and Water Systems of Buildings – Microbial Control, Part 3: Performance Based Maintenance of Cooling Towers.


Public and Environmental Health (DHHS) commented that the controls stated in the DPEMP are considered adequate under the Public Health Act 1997.

Evaluation

The potential health impacts from cooling towers are managed through the Public Health Act 1997.

Recommendation

No conditions are required in the permit because potential impacts will be managed through another Act (Public Health Act 1997).


Appendix 1

Issue

Stormwater


Contamination of surface or groundwater


According to the DPEMP the onsite stormwater collection system will be at surface only (spoon and channel drains and kerbing). Stormwater will be directed though a sediment interceptor pit prior to discharge to the underground municipal stormwater drain pipeline.



Evaluation

The proposed permit contains three standard conditions relating to the storage of hazardous materials (H1 - Storage and handling of hazardous materials, H2 - Hazardous materials <250 litres, and H3 – Spill kits). Condition EF4 (Stormwater) provides the requirements for treatment of potentially polluted stormwater prior to discharge from the Land. Compliance with these three conditions is considered appropriate to minimise the potential for stormwater contamination.

Recommendation

It is recommended that the proponent be required to comply with standard permit conditions H1 H2, H3 and EF4.

Issue

Waste management


A range of solid waste will be generated including controlled wastes (Spent Amine Solution (25% w/w ‘activated’ methyldiethanolamine [aMDEA] solution in demineralised water), and waste oils) and solid wastes (filter cartridges and molecular sieve material).


The proponent acknowledged that wastes must be managed in accordance with the Environmental Management and Pollution Control (Waste Management) Regulations 2000. It is proposed that controlled wastes that can not be disposed of in Tasmanian landfills will be transported to Melbourne. This would be conducted in accordance with the National Environment Protection Measure [NEPM] (Movement of Controlled Waste between States and Territories).



Evaluation

The proposed management measures are considered appropriate. It is recommended that the permit contain condition WM1 (Waste management hierarchy) and WM2 (Controlled waste transport).

Recommendation

It is recommended that the proponent be required to comply with standard permit conditions WM1 and WM2.


Appendix 2

Appendix 2 Summary of issues raised by public and agency submissions

Workplace Standards Tasmania (WST) provided advice as to how the activity will be regulated in relation to risk from fire or explosion.

The risks associated with the facility will be managed under the new Dangerous Substances (Safe Handling) Act 2005, which will take effect 1 July 2009. The proposed plant will be designated a Major Hazard Facility. This designation requires the proponent to submit a Safety Report to WST, which is a statement of how risks will be managed. The report must include details of consultation with emergency services, neighbouring activities and the local community. The Report must also clearly demonstrate that the plant design and operating procedures will ensure that the facility presents the lowest risk possible for that particular type of activity. The proponent has held extensive consultations with WST (and other agencies) in relation to preparation of the Safety Report (pers. comm. Danny Dougherty, Compliance Manager, WST).

Development and Conservation Assessment Branch (DPIW) The information provided in the DPEMP is considered sufficient to establish that the construction and operation of the proposed plant is not likely to impact natural values known to occur in the area. The measures proposed in the DPEMP for the control of the Amphibian Chytrid Fungus (Batrachochytrium dendrobatidis) are supported.

While the drainage line that passes through the site is not considered to provide suitable habitat for the Green and Gold Frog, it does connect with other areas that may provide potential habitat during suitable conditions. Therefore any water discharges that contain sediment or contaminates from the site, that run into the drainage line are likely to have an impact on the downstream habitat and will need to be appropriately managed during construction and operations. In particular any use of herbicides to control weeds on the site will need to be conducted in such a way as to avoid or minimise contamination of the drainage line on the site. Herbicide operations should not be conducted prior to rain events.


Appendix 3

Appendix 3 Proposed permit conditions

Attachment 2

Commitments

(From Table 7-1 of the DPEMP)

Commitment

1 BOC will prepare a Construction Environmental Management Plan that provides for:

• Dust emission mitigation through:

— Minimisation of drop heights;

— Undertaking of earthworks soil moisture is enough to suppress dust emissions;

— Introduction of speed limits to minimise dust generation from unmade roads;

— Limitation of the use of non-essential vehicles on site;

— Covering of loads of excavated material;

— Minimisation of stockpile area to reduce wind erosion;

— Periodic watering of exposed land during extended dry periods;

— Watering of long term undisturbed stockpiles and stockpiles considered to be causing an offsite impact;

and

— Use of vegetation on stockpiles with a static residence time of longer than 3 months.

• Carrying out all construction works during the standard daytime construction hours;

• Scheduling construction to minimise the multiple use of the most noisy equipment or plant items near noise

sensitive receptors;

• Strategic positioning of plant items to reduce the noise emission to noise sensitive receptors, where

possible;

• Ensuring engine covers, maintenance of silencers and mechanical condition. Regular maintenance and

noise testing for major items of construction equipment that are significant contributors to construction

noise levels;

• Awareness training of staff and contractors in environmental noise issues including;

— Minimising the use of horn signals and maintaining to a low volume. Alternative methods of

communication should be considered;

— Avoiding any unnecessary noise when carrying out manual operations and when operating plant; and

— Switching off any equipment not in use for extended periods during construction work;

• Restricting heavy vehicles’ entry to site and departure from site to the nominated construction hours;

• Where noise level exceedances cannot be avoided, consideration should be given to applying time

restrictions and/or providing quiet periods for nearby residents;

• Community consultation with local residents and building owners to assist in the alleviation of community

concerns. Previous experience on similar projects has demonstrated that affected noise sensitive receptors

may be willing to endure higher construction noise levels for a shorter duration if they have been provided

with sufficient warning in the place of intermittent but extended periods of construction noise at lower levels;

• Maintaining a suitable complaint register. Should noise complaints be received, undertake noise monitoring

at the locations concerned. Reasonable and feasible measures would need to be implemented to reduce

noise impacts.

Commitment

2 • Ensuring that all machinery and equipment used during construction of the proposed LNG Facility be

managed to control the spread of the Amphibian Chytrid Fungus, by adhering to the Tasmanian Washdown

Guidelines for Weed and Disease Control: Machinery, Vehicles and Equipment, Edition 1. These

Guidelines include instructions on when to Washdown, Equipment for Washdown and Washdown

Procedures. Specifically, the following instructions should be adhered to:

1. All equipment, vehicles and footwear should be dry and clean before entering the site to prevent

spread of the Fungus via contaminated soils.

2. The disposal of water and damp or muddy soils at the proposed development site should be minimised

or undertaken as far away as possible from waterways, ponds and/or wetlands.

3 Under the Weed Management Act 1999, landholders are required to take action to ensure that the declared

weeds do not spread onto un-infested areas or neighbouring properties.

4 Fugitive emissions from valves and flanges will be monitored on a periodic basis consistent with the health and

safety management at the site

5 During installation and construction, process pipework will be tested to eliminate leaks during this phase.

6 In the unlikely event of the discovery of Aboriginal artefacts during earthworks associated with the proposed LNG

Facility, the provisions of the Aboriginal Relics Act 1975 would be followed.

7 Install and operate the compressor with an acoustic enclosure over the compressor head, and install the letdown

valve and ejector with acoustic cladding to reduce noise emissions from the Facility.

8 Operate the ground flare to thermally destroy waste gasses and excess hydrocarbons vented through pressure

relief systems.

9 BOC commits to confirming the assumptions made in the Air Impact Assessment involving monitoring feed gas

flare in conjunction with flare flame temperature (infrared).

10 On commissioning, air quality will be monitored to confirm the conclusions of the air quality impact assessment.

11 On commissioning, noise monitoring will be conducted to confirm the conclusions of the Noise assessment.

liquid natural gas plantsubmission. a final dpemp was submitted to council with the permit...

Documents