AIR QUALITY MANAGEMENT PLAN - s08.static-shell.com

Operations Environmental Management Plan – LNG Operations Title: LNG Operations – Air Quality Management Plan Issue date: September 2013

LNGOP-QL00-ENV-PLN-000004 Review due: September 2014

UNCONTROLLED WHEN PRINTED Revision: B

© QGC 2013 Page 1 of 22

LNG OPERATIONS - ENVIRONMENT

AIR QUALITY MANAGEMENT PLAN

Scope and application

This Plan addresses the objectives and performance criteria, management measures, and monitoring, auditing, and corrective action requirements relating to air quality for the Queensland Curtis LNG Facility on Curtis Island during operations.

Management measures and reporting and auditing requirements specified, are intended to ensure compliance with the requirements of the Environmental Authority (EA) for Petroleum Facility Licence (PFL) 11 (Permit Number EPPG00711513), and other relevant approvals under applicable Queensland and Commonwealth legislation.

This document applies to operation of the LNG Facility following handover of the site from Bechtel to QGC. It addresses emissions relating to LNG Operations within the bounds of PFL11 on Curtis Island. Emissions associated with shipping activities are not addressed except to the extent the emissions from shipping are transferred into the LNG Facility, either through boil-off gas return to the LNG process or to the LNG Facility marine facility.

Contents

1.0 Summary of Responsibilities ........................................................................................................... 3

2.0 Structure ......................................................................................................................................... 4

3.0 Aspect ............................................................................................................................................. 5

4.0 Objective ......................................................................................................................................... 9

5.0 Performance Criteria ....................................................................................................................... 9

5.1 Legislation and Standards ............................................................................................................... 9

5.2 Performance Criteria ....................................................................................................................... 9

6.0 Management Measures ................................................................................................................ 10

6.1 Greenhouse Gas Emissions ........................................................................................................... 11

6.2 Dust and Odour ............................................................................................................................. 11

6.3 Fugitive Emissions ......................................................................................................................... 11

6.4 Flares ............................................................................................................................................. 12

6.5 Fuel Burning .................................................................................................................................. 12

6.6 Point Source Emissions ................................................................................................................. 13

7.0 Monitoring and Reporting ............................................................................................................ 14

7.1 Greenhouse Gas Emissions ........................................................................................................... 15

7.2 Dust and Odour ............................................................................................................................. 15


8.0 Auditing ......................................................................................................................................... 17




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9.0 Corrective Action .......................................................................................................................... 17

9.1 Dust ............................................................................................................................................... 18

9.2 Fugitive Emissions ......................................................................................................................... 18

9.3 Flares ............................................................................................................................................. 18

9.4 Fuel Burning .................................................................................................................................. 18


9.6 General .......................................................................................................................................... 19

Definitions ..................................................................................................................................... 20

Acronyms and Abbreviations ........................................................................................................ 20

Appendix A EA Complaint Monitoring Requirements ...................................................................................... 21

Tables

Table 1: Summary of Responsibilities 3

Table 2: Structure 4

Table 3: Key Emissions Sources 8

Table 4: Management Measures 11

Table 5: Monitoring and Reporting Requirements 15

Table 6: Static Emissions Monitoring 16

Table 7: Correction Actions 18

Figures

Figure 1: Locations of QCLNG Static Emissions Sources 6

Figure 2: Static Emissions Monitoring Locations 7




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1.0 Summary of Responsibilities

The following summary of responsibilities apply for personnel undertaking activities covered by this document.

Table 1: Summary of Responsibilities

Position Management Responsibilities

QGC Central Environment Team/ QGC Central Compliance Team

Manage dust and particulate monitoring in response to a complaint or request from the Administering Authority.

Coordinate and undertake routine air quality sampling and monitoring and manage field and laboratory analytical data results.

Undertake any required reporting associated with air quality monitoring programs.

Manage contracts with Laboratory Analysing Service Providers.

Undertake Greenhouse Gas Emission reporting

Undertake audits against the QGC Environmental Management System (EMS).

Manage third party auditing of the Environmental Authority (EA) and Coordinator General (CG) Conditions.

Coordinate preparation and submission of Statutory Reporting including Annual Environmental Return and Annual Monitoring Report.

Communicate non-compliance with the EA to the Administering Authority.

LNG Operations HSSE Manager

Oversee the evaluation of compliance with environmental legislation and regulations, permits, licences and approvals.

Oversee the evaluation of compliance with environmental legislation and regulations, permits, licences and approvals.

Ensure this Management Plan is implemented and updated.

Oversee incident investigations and implementation of corrective actions.

Lead Environmental Advisor (LEA) / Superintendent Environment (title TBC for Ops)

Provide input into the Environmental Site Induction provided to all site staff and visitors.

Act as primary point of contact for site personnel for air quality matters and any associated environmental incidents.

Provide the Production Manager and Maintenance Manager with environmental technical and regulatory compliance support with regard to this management plan.

Assist with dust and particulate monitoring in response to a complaint or request from the Administering Authority under direction of the QGC Central Environment Team/ QGC Central Compliance Team.

Initiate and participate in environmental incident investigations in conjunction with and as directed by the LNG Operations HSSE Manager.

Communicate incidences and non-compliance to the QGC Central Environment Team/ QGC Central Compliance Team.

Collate environmental incident reports and associated regulatory notifications for submission to the QGC Central Environment Team/QGC Central Compliance Team for review and transmission to the administering authority.

Monitor the implementation of the management measures and




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identify corrective actions.

Coordinate with QGC Central Environment Team/ QGC Central Compliance Team, Site Management and LNG Operations HSSE Manager on air quality compliance issues.

Communicate the need for corrective actions to the QGC Central Compliance Team/ QGC Central Compliance Team, Production Manager and LNG Operations HSSE Manager.

Interact with Administering Authority as directed by the QGC Central Environment Team/ QGC Central Compliance Team.

Participate in audits against the QGC EMS.

Facilitate site aspects of third party auditing of the EA and CG Conditions.

Business Services Manager

Manage contract processes including incorporation of safety requirements into contracts.

Production Manager

Operate the plant to meet specifications, achieve optimal performance and meet the stack emission discharge criteria as stipulated in the EA.

Maintenance Manager

Maintain the plant to prevent leakage of fugitive emissions.

2.0 Structure

The body of this management plan follows the structure outlined below:

Table 2: Structure

Section Heading Description

1.0 Summary of Responsibilities

Summary of responsibilities for all personnel undertaking activities covered by this document.

2.0 Structure This section, summarising document structure.

3.0 Aspect How aspects of the activity phases are to be managed (as it affects environmental and social values).

4.0 Objective The Activity policy or management objective that applies to each element.

5.0 Performance Criteria

Measurable performance criteria (outcomes) for each element of each Activity phase.

6.0 Management Measures

The strategies, tasks or action program (to nominated operational design standards) that will be implemented to achieve the performance criteria.

7.0 Monitoring and Reporting

The monitoring requirements to measure actual performance (i.e. specified limits to pre-selected indicators of change).

Format, timing and responsibility for reporting and auditing of monitoring results.

8.0 Auditing The auditing requirements to demonstrate implementation of agreed environmental management strategies and compliance with agreed performance criteria.

9.0 Corrective Actions

The action (options) to be implemented in case a performance requirement is not reached and the person responsible for that action (including staff authority, responsibility and management structure).




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3.0 Aspect

A brief description of emission sources and key emissions are included in Table 3 below. Locations of key point source emissions are provided in Figure 1 and locations for monitoring are included in Figure 2.

Emissions sources addressed include the following:

1. Point Sources under Normal Operations

Sources with continuous emissions under normal operations, including emissions generated by the combustion of coal seam gas (CSG) and the processing of feed gas for liquefaction. These emissions will tend to be constant within certain bounds.

2. Point Sources under Start-up, Shutdown or Upset Conditions

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. Emission rates for these activities may also be variable and, consequently, do not impact air quality on a continual basis.

3. Fugitive Emissions and Other Sources

There may also be minor emissions from vehicles and occasional use of mobile plant and equipment (for example, mobile pumps to manage stormwater, mobile generators for maintenance works, etc).These emissions will be transient, intermittent and spatially variable. Vehicles may also generate dust if driven on unsurfaced roadways.

Fugitive emissions may arise due to trace leakage of gas through flanges, valves or other equipment, and from vents and pressure safety valves (PSVs). PSVs and vents are installed on a range of equipment across the site. While emissions from many of these will be only pressurised air or inert gas (nitrogen), emissions to atmosphere with potential air quality impact or greenhouse gas impact may arise from the sources identified in Table 3.

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Process Flares (Wet and Dry Gas)

Acid Gas Removal UnitRegeneration Gas HeaterHot Oil Heater

Marine Flare

Nitrogen Rejection Unit

Emergency & Back-Up Diesel Generators

Gas Turbine Generator (x3)Compressor Gas Turbines (x6)

Train 1

Train 2

Fire Water Pumps (x3)

Standby Diesel Generator(Marine Terminal Building)

Acid Gas Removal Unit

Compressor Gas Turbines (x6)

Nitrogen Rejection Unit

Figure 1.Static Emission Sources

0 50 100 150 200 250

Meters

!( Static Emission SourceStatic Emission SourceExport PipelineWet Lease BoundaryQCLNG Site Boundary (PFL11)

DATA SOURCE: Site Layout - BechtelSite Boundary - DME

Aerial Imagery - NearMap

Map Projection: GDA 94

M_25547_01d16/08/2013 hibberde DATE: CREATED BY:

MAP NO:

SCALE: 1:7,500 (A4)

"Based on or contains data provided by the State of Queensland (Department ofEnvironment and Resources Management) 2011. In consideration of the State permittinguse of this data you acknowledge and agree that the State gives no warranty in relation tothe data (including accuracy, reliability, completeness, currency or suitability) and accepts

no liability (including without limitation, liability in negligence) for any loss, damage orcosts (including consequential damage) relating to any use of the data. Data must not

be used for direct marketing or be used in breach of the privacy laws."

Note: Every effort has been made to ensure this information is spatially accurate. The location of this information should not be relied on as the exact field location

±

!( !( !( !( !( !(

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!(Train 1

Train 2

RP1 RP2

RP3

RP4

RP5

RP6

RP7

RP8RP10

RP11RP12RP9

RP13 RP14RP15

Figure 2.Static Emission

Monitoring Locations

0 25 50 75 100

Meters

Legend!( Static Emission Source

QCLNG Site Boundary (PFL11)Wet Lease BoundaryExport Pipeline

DATA SOURCE:<INSERT DATA SOURCE>

Map Projection: GDA 94

M_25547_02c15/08/2013 hibberde DATE: CREATED BY:

MAP NO:

SCALE: 1:3,000 (A4)

"Based on or contains data provided by the State of Queensland (Department ofEnvironment and Resources Management) 2011. In consideration of the State permittinguse of this data you acknowledge and agree that the State gives no warranty in relation tothe data (including accuracy, reliability, completeness, currency or suitability) and accepts

no liability (including without limitation, liability in negligence) for any loss, damage orcosts (including consequential damage) relating to any use of the data. Data must not

be used for direct marketing or be used in breach of the privacy laws."

Note: Every effort has been made to ensure this information is spatially accurate. The location of this information should not be relied on as the exact field location

±Location Emission Source Release

PointEquipment

NumberPropane Compressor Gas Turbine RP1 1TC-1411Propane Compressor Gas Turbine RP2 1TC-1421Ethylene Compressor Gas Turbine RP3 1TC-1511Ethylene Compressor Gas Turbine RP4 1TC-1521Methane Compressor Gas Turbine (with WHR) RP5 1TC-1611Methane Compressor Gas Turbine (with WHR) RP6 1TC-1621Propane Compressor Gas Turbine RP7 2TC-1411Propane Compressor Gas Turbine RP8 2TC-1421Ethylene Compressor Gas Turbine RP9 2TC-1511Ethylene Compressor Gas Turbine RP10 2TC-1521Methane Compressor Gas Turbine (with WHR) RP11 2TC-1611Methane Compressor Gas Turbine (with WHR) RP12 2TC-1621Gas Turbine Generator RP13 1TG-3101Gas Turbine Generator RP14 1TG-3102Gas Turbine Generator RP15 1TG-3103

Train 1

Train 2

Power Generation




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Table 3: Key Emissions Sources

Aspect Location Emission Source Number Key Emissions Comments

Point Sources - Normal

Operations

Trains 1 and 2

Compressor Gas Turbines 12 (6 per train) NOx (minor / trace CO, PM10, CO2, CH4)

Acid Gas Removal Unit (CO2 vent) 2 (1 per train) CO2 (minor CH4)

Nitrogen Rejection Unit (NRU vent) 2 (1 per train) N2 (minor CH4)

Power Generation Gas Turbine Generators 3 NOx (minor / trace CO, PM10, CO2, CH4) 2 operational, 1 standby

Flares Wet & Dry Gas Flares NOx, CO (minor/trace PM10, CO2) Pilot light only during normal ops

Marine Flares Dependent upon vessel Pilot light

Point Sources - Start-up,

Shutdown or Upset

Conditions

Flares

Wet and dry gas flares NOx, CO, (minor / trace PM10,

hydrocarbons) Flaring due to purging, dryout, cooldown,

trips or upset

Marine flare NOx, CO, (minor / trace PM10,

hydrocarbons) Trips or upset

Utilities and Back-up

Hot Oil Heater 1 NOx (minor / trace CO, PM10, CO2, CH4) Start-up only (not monitored)

Regeneration Gas Heater 1 NOx (minor / trace CO, PM10, CO2, CH4) Start-up only (not monitored)

Power generation (diesel) 3 Diesel emissions Start-up / back-up only (not monitored)

Fire Water Pumps (diesel) 3 Diesel emissions Intermittent – emergency (not monitored)

Standby Diesel Generator Marine Terminal Bldg 1 Diesel emissions Intermittent – (not monitored)

Emergency air compressor – (diesel) 2 Diesel emissions Intermittent –back-up (not monitored)

Fugitive Emissions and Other Sources

Mobile Vehicles Diesel emissions

Mobile Plant and Equipment Diesel emissions

PSVs and vents

PSVs - Amine Units and Tanks N2 Blanket

Intermittent for pressure relief

PSVs - LNG Tanks CH4

Vent - Hot Oil Storage Tank N2 Blanket

Miscellaneous Atmospheric Vents (e.g. water tanks, plant and instrument air receivers)

Air

Demineralised Water Storage Tanks N2 Blanket

Nitrogen Receivers N2 Service

Gas Analysers CH4

PSVs on Hydrocarbon Absorbers Air, N2

PSVs - Refrigerant Isotainers Ethylene, propane




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4.0 Objective

The Project environmental objectives for air quality are:

To operate in a manner that minimises impacts on ambient air quality.

To preserve ambient air quality to the extent that ecological health, public amenity or safety is maintained.

To actively manage emissions of greenhouse gases and to minimise the emission of greenhouse gases in terms of carbon dioxide equivalent (CO2eq) per unit of hydrocarbon produced/transmitted (Greenhouse Gas (GHG) efficiency).

To manage the physical risks to facilities resulting from climate change.

To eliminate the emission of ozone depleting substances.


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 No. EPPG00711513


The performance criteria and objectives for this management plan are as follows:

Greenhouse Gas Emissions

Manage emissions of greenhouse gases in accordance with the QCLNG Greenhouse Gas Emissions Strategy

Nuisance (Dust and Odour)

No environmental nuisance from the release of dust or particulate matter at any nuisance sensitive or commercial place.

No environmental nuisance from the release of noxious or offensive airborne contaminants at any nuisance sensitive or commercial place.

Releases to Atmosphere

Release of contaminants to the atmosphere from point sources only at flow and emission rates in accordance with Schedule B, Table 1 and Schedule B, Table 2 of the EA.

Monitoring of contaminants to the atmosphere from Point Sources in accordance with Schedule B, Table 2 of the EA.

No emission to air of ozone depleting substances.




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Flaring

Visual smoke and particulate emissions will not occur for more than five (5) minutes in any two (2) hour period during normal operating conditions, other than during LNG train start-up.

Fugitive Emissions

Take all reasonable and practicable measures to minimise fugitive emissions.

Fuel Burning

No burning of waste or fuel, other than as permitted by the EA.

The sulphur content of fuel burned in the power generators will not exceed 0.5 percent by weight.

General

Manage complaints in accordance with the Gladstone Stakeholder Engagement Plan.

Corrective actions will be implemented promptly where fault of omission has resulted in emission of contaminants from industrial plant or ducting systems.

6.0 Management Measures

Table 4 presents management measures to be adopted during operation to meet the performance objectives and criteria for air quality.




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Table 4: Management Measures

Performance Criteria Management Measure Responsibility

6.1 Greenhouse Gas Emissions

Manage emissions of greenhouse gases in accordance with the QCLNG Greenhouse Gas Emissions Strategy.

.


6.2 Dust and Odour

No environmental nuisance from the release of dust or particulate matter at any nuisance sensitive or commercial place.

Manage complaints about air quality in accordance and within timeframes stipulated in the Gladstone Stakeholder Engagement Plan.

All vehicles travelling within the LNG Facility will use the permanent site roads provided.

All Staff

Roads within the LNG Facility in regular use during normal operations will be sealed and maintained.

Maintenance Manager

The security permiter road around the exterior of the LNG Facility is only to be utilised for maintenance of regeneration works and access to the GAWB Pipeline. Traffic speeds are less than 20 km/hour to minimise dust generation.

LEA

The Spoil Pile Access Road is only to be utilised for weed management and regenerations works and traffic speeds are less than 20 km/hour to minimise dust generation.

Undertake dust and particulate monitoring in response to a complaint or request from the Administering Authority.

Dust and particulate monitoring undertaken to meet EA requirements as provided in Appendix A.

QGC Central Environment Team / QGC Central Compliance Team (LEA to assist onsite)

Refer to EA Schedule B Condition B3 (Appendix A)

Staff that will be responsible for receiving and responding to complaints will be trained in Gladstone Stakeholder Engagement Plan.

6.3 Fugitive Emissions

Fugitive emissions will be minimised by taking all reasonable and practicable measures during design and operation.

Implementation of the Integrated Control and Safety System (ICSS), which is integrated by three components; the Fire and Gas System (FGS), the Distributed Control System (DCS), and the Safety Instrument System (SIS).

Line-of site, Infra-red (IR) and Point Gas Detector high-level gas/leak alarms and

Production Manager




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Ultrasonic leak detection alarms will be observed at local control points and permanently manned control points.

Regular surveillance to detect fugitive emissions will be undertaken of control valves, glands on control valves and vents on cold boxes.

Performance Standards have been developed to address hydrocarbon containment.

Regular maintenance of the Plant will be undertaken by the Maintenance Team. Maintenance Manager

Routine Baseline Inspection will be undertaken pre-operation.

Leak detection of the flanges will be undertaken at start up or if the flanges are disturbed.

6.4 Flares

Visible smoke and particulate emissions will not occur for more than five (5) minutes in any two (2) hour period during normal operating conditions, other than during LNG train start-up

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, other than during LNG train start-up.

Engineering Manager

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.

Production Manager

6.5 Fuel Burning

No burning of waste or fuel, other than as permitted by the EA.

There will be no burning of waste, fuel (other than natural gas in the fuel burning equipment under normal operating conditions) or chemicals at the LNG Facility.

LEA

The sulphur content of fuel burned in the power generators will not exceed 0.5 percent by weight.

Fuel supply contracts will specify the supply of low sulphur fuel. Business Services Manager




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6.6 Point Source Emissions

Release of contaminants to the atmosphere will only occur from Point Sources at flow and emission rates in accordance with Schedule B, Table 1 and Schedule B, Table 2 of the EA.

The exhaust stacks have been designed to achieve the minimum release heights (above grade) stipulated in the EA.

Engineering Manager

Operate the plant to achieve the minimum release velocity stipulated in the EA. Production Manager

Assist the contractor in obtaining additional information as required on the Plant operation.


Monitoring of contaminants to the atmosphere from Point Sources will occur in accordance with Schedule B, Table 2 of the EA.

The following testing on equipment will be undertaken which will confirm equipment is running to specifications and meeting design criteria:

Factory Acceptance Tests (FATs) for the ICSS systems will occur at supplier’s staging facilities.

Commissioning Demonstration Tests are intended to demonstrate performance of the subject system meets the design intent as shown in technical specifications.

Plant Performance Test, which measures the rate of increase of LNG in storage (Net LNG Production).

Fuel Gas Consumption Performance Test.

Remote Monitoring and Diagnostics, 24/7.

Performance Maintenance will be undertaken at 4,000, 25,000 and 50,000 hour intervals. Exhaust Emissions Mapping will therefore occur approximately every 3 years.

Production Manager

Maintenance Manager




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7.0 Monitoring and Reporting

Monitoring and reporting is to be undertaken as specified in Schedule B (as per the tables below) and in accordance with the following requirements:

Undertake the monitoring in accordance with the Australian Standard AS 4323.1 – 1995 ‘ Stationary source emissions, Method 1: Selection of sampling positions’ (or more recent editions).

The following tests must be performed for each determination specified in the EA:

- Gas velocity and volume flow rate.

- Temperature.

- Water vapour concentration (moisture content).

During the sampling period, the following additional information must be gathered:

- Production rate at the time of sampling.

- Raw materials and fuel used.

- Number of plant or equipment and operator units operating.

The QGC Central Environmental Team will oversee monitoring in response to incident or complaint monitoring at the direction of the Administering Authority.

Reporting on monitoring undertaken in response to complaints or specific direction of the Administering Authority will be provided within fourteen (14) days of completion of the investigation or receipt of monitoring results, whichever is the latter, in accordance with Schedule J of the EA.

Monitoring outcomes and corrective actions (if required) will be reported in the Annual Monitoring Report prepared by QGC Central Environment Team/ QGC Central Compliance Team and submitted to the Administering Authority.




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Table 5: Monitoring and Reporting Requirements

Monitoring Action Reporting Action Responsibility

7.1 Greenhouse Gas Emissions

Monitor the Greenhouse Gas Emissions in accordance with the Greenhouse Gas Emission Strategy.

Report Greenhouse Gas Emissions as required, including preparation of the Annual Environmental Return

QGC Central Environment Team / QGC Central Compliance Team

7.2 Dust and Odour

In the event of a complaint or request from the Administering Authority, dust and particulate monitoring must be undertaken to meet EA requirements as provided in Appendix A.

Gladstone Stakeholder Engagement Plan

Annual Environmental Return QGC Central Environment Team / QGC Central Compliance Team (LEA to assist onsite)



Monitoring of the point sources is to occur annually, on a rotational basis. Table 6 outlines the release points to be monitored, the frequency of monitoring and the contaminant release limits. Figure 2 shows the monitoring locations.

Analysis of samples to be undertaken by a NATA certified laboratory.

Samples must be taken when emissions are expected to be at maximum rates.

Annual Environmental Return QGC Central Environment Team / QGC Central Compliance Team




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Table 6: Static Emissions Monitoring

Emission Source Release Point

Equipment Number

Monitoring Frequency Minimum Veolcity (m/sec)

Parameter Measured

Maximum Release Limit

Train 1

Propane Compressor Gas Turbine RP1 1TC-1411

One (1) Train 1 Emission Source per year, on a rotational basis

25 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec

Propane Compressor Gas Turbine RP2 1TC-1421 25 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec

Ethylene Compressor Gas Turbine RP3 1TC-1511 25 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec


Methane Compressor Gas Turbine (with WHR) RP5 1TC-1611 22 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec


Train 2

Propane Compressor Gas Turbine RP7 2TC-1411

One (1) Train 2 Emission Source per year, on a rotational basis


Propane Compressor Gas Turbine RP8 2TC-1421 25 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec





Power Generation

Gas Turbine Generator RP13 1TG-3101 1 Power Generation Emission Source

per year, on a rotational basis


Gas Turbine Generator RP14 1TG-3102 25 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec

Gas Turbine Generator RP15 1TG-3103 25 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec




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8.0 Auditing

QGC maintains an EMS in accordance with the international standard AS/NZS ISO 14001. The EMS must be regularly audited to ensure its continuing suitability, adequacy and effectiveness and meet QGC’s commitment to continual improvement.

Regular internal audits of the EMS are conducted, covering all activities within the scope of the QGC Asset EMS.

QGC will also ensure that a qualified third party auditor (accepted by the Administering Authority) undertakes compliance monitoring against the EA conditions within one (1) year of the completion of commissioning of the LNG Facility and every three years thereafter.

Auditing against relevant environmental legislation and regulations, environmental licences and permits

9.0 Corrective Action

Table 7 outlines the corrective actions that have been identified for the potential impacts on air quality should the management measures be inadequate.




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Table 7: Correction Actions

Corrective Actions Responsibility

9.1 Dust


In the event of a complaint, undertake dust and particulate monitoring.

QGC Central Environment Team / QGC Central Compliance Team (LEA to assist onsite)

9.2 Fugitive Emissions

Fugitive emissions from the Plant will be identified by the Production Team via a leak detection program and responded to by the Maintenance Team.

Production Manager (leak detection)

Maintenance Manager (required maintenance)

9.3 Flares

Should visible smoke and particulate emissions occur for more than five (5) minutes in any two (2) hour period during normal operating conditions, other than during LNG train start-up the Production Manager will:

1. Consult with engineering to identify possible causes.

2. Investigate mitigation measures.

3. Implement appropriate mitigations if possible.

Production Manager

9.4 Fuel Burning

Should the fuel received from suppliers for burning in the power generators exceed 0.5 percent sulphur by weight the Business Services Manager will contact the suppliers and investigate.

Business Services Manager


Should monitoring indicate a breach of the discharge criteria set out in Schedule B, Table 2 of the EA, the following process will be followed:

1. Immediate retest to ensure accurate results.

2. Consultation with engineering to identify possible causes.

3. Investigation of implications via dispersion modelling studies.

4. Investigation of mitigation measures.

5. Implementation of appropriate mitigations if possible.





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Corrective Actions Responsibility

9.6 General

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.


and LEA

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.

Implement corrective actions if the monitoring indicates an exceedence of discharge limits in the EA.

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.

Operations Environmental Management Plan – LNG Operations Title: LNG Operations – Air Quality Management Plan Issue Date: September 2013

LNGOP-QL00-ENV-PLN-000004 Review Date: September 2014


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Definitions

Term Meaning

Administering Authority Department of Environment and Heritage Protection (formerly Department of Environment and Resource Management). The Queensland Government Department that administers the Environmental Authority under the Environmental Protection Act 1994.

Acronyms and Abbreviations

Acronym Meaning

CG Coordinator General

CH4 Methane

CO Carbon Monoxide

CO2 Carbon Dioxide

DCS Distributed Control System

EA Environmental Authority, and specifically the Environmental Authority for Petroleum Facility Licence PFL 11 (EPPG00711513)

EHP Department of Environment and Heritage Protection

EMS Environmental Management System

EP Act Environmental Protection Act 1994 (Qld)

EPP (Air) Environmental Protection (Air) Policy 2008 (Qld)

FGS Fire and Gas System

LEA Lead Environmental Advisor

GHG Greenhouse Gas

g/sec Grams per second

ICSS Integrated Control and Safety System

LNG Liquefied Natural Gas

mg/Nm3 Milligrams per Normal cubic metre

NATA National Association of Testing Authorities, Australia

NEPM National Environment Protection Measure

N2 Nitrogen Gas

NOx Nitrogen Oxides

NRU Nitrogen Rejection Unit

O2 Oxygen

PFL Petroleum Facility Licence

PM10 Particulate Matter in the order of 10 micrometres or less

PSV Pressure Safety Valve

QGC QGC – A BG Group business

QCLNG Queensland Curtis LNG

SIS Safety Instrument System




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Appendix A EA Complaint Monitoring Requirements

In the event of a complaint or request from the Administering Authority, dust and particulate monitoring must be undertaken to meet EA requirements. The following criteria must be achieved:

Dust deposition of 120 mg/m2 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

A concentration of particulate matter with an aerodynamic diameter of less than 10 µm (PM10) suspended

in the atmosphere of 50 µg/m3 (with five one day exceedances allowed in any one year period1); and over

a 24 hour averaging time, at a dust sensitive place downwind of the licensed place, when monitored in accordance with:

- Australian Standard AS3580.9.6 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

- 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.

1 The 5 days exceedances per year are based on the expected exceedances from the natural events such as bushfires and dust storm.




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