Attachment 3A PEG Power Station Commissioning Plan

100-TE-DC-0003_5

Report

Attachment 3A PEG Power Station Commissioning Plan

Pilbara Energy Generation Project

January 2021 540PG-0000-RP-EN-0002.002 Rev 2

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Attachment 3A PEG Power Station Commissioning Plan

Document & Revision Number 540PG-0000-RP-EN-0002.002 Rev 2

14/01/2021

Status IFU - Issued for Use

Summary of Changes N/A

Author K Fox

Checked or Squad Review# (if applicable)

S Turner

Approved S McGunnigle

Access to this document: Public Use (Access to all) Next Review Date

(if applicable) N/A

Revision History

Author Checker Approver Rev No. Status Issued Date

D Thompson Squad Review S McGunnigle 1 IFU 28/04/2020

This page has been left blank intentionally

TABLE OF CONTENTS

1. INTRODUCTION .......................................................................................................... 6

1.1 Project Background ...................................................................................... 6

2. SCHEDULE .................................................................................................................. 7

2.1 Commissioning Timeframe Summary ......................................................... 7

2.2 Project Schedule ........................................................................................... 7

2.3 Staged Commissioning Schedule ................................................................ 7

2.3.1 Phase 1 – Construction and Construction Verification ..................................... 7

2.3.2 Phase 2 – Function Testing (Pre-Commissioning)........................................... 8

2.3.3 Phase 3 – No Load Commissioning ................................................................ 8

2.3.4 Phase 4 – Load Commissioning ...................................................................... 8

2.3.5 Phase 5 - Performance Testing ....................................................................... 8

2.3.6 Phase 6 – Time-Limited Operations ................................................................ 8

3. INPUTS AND OUTPUTS .............................................................................................. 9

3.1 Inputs ............................................................................................................. 9

3.2 Outputs .......................................................................................................... 9

3.3 Expected Emissions During Commissioning ........................................... 10

3.3.1 Oxides of Nitrogen (NOx) ............................................................................... 10

3.3.2 Sulphur Dioxide (SO2) ................................................................................... 10

3.3.3 Particulate Matter (PM) ................................................................................. 10

3.3.4 Carbon Monoxide (CO) ................................................................................. 10

3.4 Greenhouse Gas Emissions ....................................................................... 11

3.5 Commissioning Emissions Testing ........................................................... 11

4. RISK MANGAGEMENT AND CONTINGENCY PLANNING ...................................... 12

4.1 Incident Management and Compliance ..................................................... 12

4.2 Chemical and Hydrocarbon Management ................................................. 12

4.3 Surface water and drainage ....................................................................... 12

4.4 Complaints .................................................................................................. 12

4.5 Unplanned Emissions or Emission Exceedances .................................... 13

5. DEVIATION FROM NORMAL OPERATIONS ............................................................ 13

5.1 Inputs and Outputs ..................................................................................... 13

5.1.1 Inputs ............................................................................................................ 13

5.1.2 Outputs ......................................................................................................... 13

5.2 Risk Management and Contingency Planning .......................................... 14

6. REFERENCES ........................................................................................................... 15

List of Tables Table 1. Upper level of emissions during normal operation ...................................................... 10 Table 2. Expected emissions during commissioning performance testing ................................ 11 List of Figures No table of figures entries found. List of Appendices No table of figures entries found.

1. INTRODUCTION

The purpose of this document is to detail a plan for commissioning and testing of the proposed PEG Power Station. Under s 54 and s 57 of the Environmental Protection Act 1986, an application for works approval or for a licence must be made in a form and in the manner approved by the Chief Executive Officer (CEO). The Department of Water and Environmental Regulation (DWER) provide an application form to facilitate this process. The new version of the application form (DWER, 2020) stipulates:

If applying to construct works or install equipment, and environmental commissioning of the works or equipment is planned, an environmental commissioning plan has been included in Attachment 3A.

The environmental commissioning plan is expected to include, at minimum, identification of:

• the sequence of commissioning activities to be undertaken, including details on whether they will be done in stages;

• a summary of the timeframes associated with the identified sequence of commissioning activities;

• the inputs and outputs that will be used in the commissioning process;

• the emissions and/or discharges expected to occur during commissioning;

• the emissions and/or discharges that will be monitored and/or confirmed to establish or test a steady-state operation (e.g. identifying emissions surrogates, etc.), including a detailed emissions monitoring program for the measurement of those emissions and/or discharges;

• the controls (including management actions) that will be put in place to address the expected emissions and/or discharges;

• any contingency plans for if emissions exceedances or unplanned emissions and/or discharges occur; and

• how any of the above would differ from standard operations once commissioning is complete.

1.1 Project Background

Pilbara Energy Generation Pty Ltd (PEG); a wholly owned subsidiary of Fortescue Metals Group (Fortescue) proposes to develop the Pilbara Energy Generation Project which consists of a combination of solar and gas-fired power generation across several locations in the Pilbara Region of Western Australia. This Project involves the development of two photovoltaic solar arrays, with a combined capacity of approximately 150 MW, in addition to the proposed PEG

Power Station. The energy generated by the PEG Project will be used to provide power to a range of Fortescue and Fortescue Joint Venture Projects.

2. SCHEDULE

The schedule of both commissioning and the overall schedule (giving indicative timeframes for approval requirements) are detailed below.

2.1 Commissioning Timeframe Summary

The April 2020 update of the DWER Application Form calls for the commissioning plan to include

• the sequence of commissioning activities to be undertaken, including details on whether they will be done in stages and

• a summary of the timeframes associated with the identified sequence of commissioning activities

2.2 Project Schedule

As discussed in Attachment 3B, the scheduling of the project is as follows.

Subject to the receipt of approvals, the following schedule has been developed for the PEG Power Station:

Preliminary Site Earthworks March – April 2021

Construction April 2021 – December 2021

Commissioning December 2021 – July 2022

Operation July 2022

This schedule allows for power supply delivery for the commencement of operation of the Iron Bridge Project ore processing facility.

2.3 Staged Commissioning Schedule

The commissioning process can be summarised by the time-based sequence of activities defined as Phases of Completion. The dates and durations are estimated as per the Construction Schedule Baseline and may vary depending on the date of approval and site conditions.

2.3.1 Phase 1 – Construction and Construction Verification

Construction of the PEG Power Station and verification and testing (de-energised) of fabrication, construction and installation works to confirm that the applicable rules, standards and specifications have been met, and the projects requirements are fulfilled. The completion of Phase 1 would ensure that equipment is safe to be energised. Phase 1 is estimated to take approximately 60 weeks to complete and is expected to be completed in December 2021.

2.3.2 Phase 2 – Function Testing (Pre-Commissioning)

During this phase, specific items of equipment will undergo energisation, direction and uncoupled testing to ensure tolerances and testing procedures comply with vendor manuals and recommendations. In addition, safety devices and instrumentations will be fully tested and operational in remote and local operations. Phase 2 is estimated to take approximately 4 weeks to complete and is expected to occur during January 2022.

2.3.3 Phase 3 – No Load Commissioning

The process control system is tested as far is practical, to ensure correct operation and interaction between plant areas using benign fluids, usually water and air. Phase 3 is estimated to take approximately two weeks to complete and is expected to occur during January 2022.

Within 60 days of completion of Phase 1, an Environmental Compliance Report will be submitted to DWER, confirming that the key infrastructure has been constructed in accordance with the specific requirements of the Works Approval.

2.3.4 Phase 4 – Load Commissioning

Covers the introduction of gas to the plant and build up to nominal operating conditions and steady state operation. Phase 4 is estimated to take approximately eight weeks to complete and is expected to occur during February 2022.

2.3.5 Phase 5 - Performance Testing

Gas supply is gradually increased into the facility and the performance of the Plant is optimised and assessed building to full operational throughput. Phase 5 is estimated to take approximately four weeks to complete and is expected to occur during July 2022.

Commissioning emissions testing will take place during this phase. An Environmental Commissioning Report will be submitted to DWER within 60 days of completion of Phase 5, confirming that the key infrastructure is capable of operating in accordance with the specific requirements of the Works Approval.

2.3.6 Phase 6 – Time-Limited Operations

Following submission of the Environmental Commissioning Report, PEG requests a period of up to 120 days of time-limited operations, whereby the PEG Power Station could commence operations while a Licence Application is in the process of assessment and approval by DWER.

3. INPUTS AND OUTPUTS

The April 2020 update of the DWER Application Form calls for the commissioning plan to include:

• the inputs and outputs that will be used in the commissioning process;

• the emissions and/or discharges expected to occur during commissioning;

• the emissions and/or discharges that will be monitored and/or confirmed to establish or test a steady-state operation (e.g. identifying emissions surrogates, etc.), including a detailed emissions monitoring program for the measurement of those emissions and/or discharges;

3.1 Inputs

Inputs for the PEG Power Station include:

• natural gas

• engine oil

• diesel (for black start genset)

• water (for fire systems).

3.2 Outputs

The key output of the PEG Power Station will be power supply of 150 MW. Power will be generated at 11 kV and converted to 220 kV using on-site transformers. Power will be generated on an N+1 dispatch programme, based on 150 MW exported power with one engine in reserve. This results in a fully installed capacity of 165 MW.

Additional outputs of the proposed PEG Power Station include the following emissions and discharges:

• Exhaust gases as detailed in Table 1 • Waste oil (from engines and as separated by oily water treatment infrastructure) as detailed

in Section 4.3 of attachment 3B • Minor quantities of treated water from oily water treatment infrastructure as detailed in

Section 4.3 of attachment 3B

Table 1. Upper level of emissions during normal operation

Emission Emission Rate (g/s)

75% Load 100% Load Start-up

NOx, Nitrogen oxides (Calculated as NO2) 2.85 3.8 7.6

CO, Carbon monoxide 2.3 3.1 6.2

SO2, Sulphur dioxide 0.02 0.03 0.06

PM, Particulate matter (as dry dust) 0.15 0.2 0.4

3.3 Expected Emissions During Commissioning

As discussed in 4.1 of Attachment 3B, key emissions during commissioning are as follows.

3.3.1 Oxides of Nitrogen (NOx)

Emissions of Oxides of Nitrogen result from the combustion of hydrocarbons, especially at high temperatures. Commissioning activities, including tuning, will help to keep NOx emissions to a minimum during future normal operations.

3.3.2 Sulphur Dioxide (SO2)

SO2 emissions from power generation are largely a result of the sulphur content in the fuel consumed. Western Australian natural gas contains low levels of sulphur (Department of Environment, 2004; Kwinana Industries Council, 2015), thus the emission of SO2 resulting from natural gas combustion is very low. Due to the high efficiency of these units, the fuel consumed per unit of energy produced is also lower, meaning lower SO2 emission intensity than less efficient gas fired generators.

3.3.3 Particulate Matter (PM)

Particulate emissions result from the carryover of non-combustible trace compounds in the fuel and lubricating our as well as from incomplete combustion. Generally, gas fired reciprocating engines emit very low quantities of particulates (United States Environmental Protection Agency, 2000)

3.3.4 Carbon Monoxide (CO)

Carbon monoxide emissions generally result from incomplete combustion, the expected emissions of CO during commissioning are extremely low.

3.4 Greenhouse Gas Emissions

As discussed in 4.2 of Attachment 3B, Fortescue manages Greenhouse Gases under the Greenhouse Gas Emissions and Energy Reporting Management Plan (100-PR-GH-0001) for the PEG Power Station. In addition to any reporting requirements applied under Part V of the EP Act, greenhouse gas emissions and associated energy data will be reported as per the requirements of the National Greenhouse and Energy Reporting Act 2007 (NGER Act).

3.5 Commissioning Emissions Testing

During Phase 5 of Commissioning (Performance Testing), detailed in 2.3 of this document, qualified and NATA accredited air monitoring technicians will be on site to monitor point source emissions to air from each of the exhaust stacks.

Analytes in exhaust emissions that will be tested during commissioning include those outlined below in Table 2.

Emission testing will be carried out against manufacturer guarantees (Table 2), which are calculated by the manufacturer using conservative methodology (highest emission scenarios). Testing will be carried out in compliance with WA Continuous Emission Monitoring System (CEMS) Code for Stationary Source Air Emissions (Department of Environment Regulation, 2016). All emissions will be monitored/sampled in accordance with USEPA standards. All results will be reported on a dry basis to standard temperature and pressure and corrected to 15% oxygen.

Table 2. Expected emissions during commissioning performance testing

Emission Activity Mitigation Measures (If Required)

Guaranteed Emission Rate (g/s)

75% Load

100% Load

Start-up

NOx, Nitrogen oxides (Calculated as NO2)

During performance test Optimise Tuning and or Load to Reduce Emissions

2.85 3.8 7.6

CO, Carbon monoxide


2.3 3.1 6.2

SO2, Sulphur dioxide


0.02 0.03 0.06

PM, Particulate matter (as dry dust)


0.15 0.2 0.4

4. RISK MANGAGEMENT AND CONTINGENCY PLANNING

The April 2020 update of the DWER Application Form calls for the commissioning plan to include: • the controls (including management actions) that will be put in place to address the

expected emissions and/or discharges and • to include any contingency plans for if emissions exceedances or unplanned emissions

and/or discharges occur

4.1 Incident Management and Compliance

Incidents that occur during commissioning will be managed under the Incident and Event Management Procedure (100-PR-SA-0011). Details of any environmental incident that takes place during commissioning will be reported in the Environmental Commissioning Report that will be submitted to DWER within 60 days of completion of Phase 5. Conditions of the anticipated works approval and any subsequent licences will be managed under the Environmental Compliance Obligation Management Procedure (100-PR-EN-1046).

4.2 Chemical and Hydrocarbon Management

Chemicals and hydrocarbons utilised will be managed in accordance with the Chemical and Hydrocarbon Management Plan (100-PL-EN-0011). Spills will be managed under Chemical and Hydrocarbon Spills Procedure (45-PL-EN-0014). Ongoing storage of chemicals and hydrocarbons will be managed by conducting periodic inspections of chemical and hydrocarbon storage areas to confirm compliance with future Licence conditions and applicable Australian Standards as outlined in the Hazardous Materials Management Procedure (45-PR-SA-0051). When diesel storage areas are required to be licensed under the EP Act and/or the Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007, facilities will be designed and constructed in accordance with the Standard Engineering Specification Diesel Storage and Handling (100-SP-ME- 0044).

4.3 Surface water and drainage

Risks to surface water are managed under the following plans: • Surface Water Management Plan (100-PL-EN-1015)

• Standard Engineering Specification for Drainage and Flood Protection (100-SP-CI-0004).

4.4 Complaints

Complaints will be managed under the Community Incident Procedure (100-PR-HE-0007)

4.5 Unplanned Emissions or Emission Exceedances

Unplanned emissions or emission exceedances (if applicable) will be managed by adjusting the load of the engine where necessary. If higher than expected emissions are discovered during testing, engines will be re-retuned until satisfactory readings are reached.

5. DEVIATION FROM NORMAL OPERATIONS

The April 2020 update of the DWER Application Form calls for the commissioning plan to include how any of the above would differ from standard operations once commissioning is complete.

5.1 Inputs and Outputs

The ways the normal inputs and outputs would differ from the emissions during commissioning are as follows.

5.1.1 Inputs

• Natural gas will be drawn from the same source during commissioning and normal operations.

• Engine oil use is not likely to differ between commissioning and normal operations

• Diesel (for black start genset) – during commissioning diesel will be used to test the black start generator, under normal operations it will only be consumed during testing and black start scenarios.

• Water (for fire systems) will be used to test the fire systems, under normal operations this water will only be consumed during testing and emergency scenarios.

5.1.2 Outputs

Although the PEG Power Station will have a nameplate capacity of 165MW the dispatch arrangement will mean the PEG Power Station is intended to maintain a power supply of 150 MW power, generated at 11 kV and converted to 220, this will not always be the case during commissioning.

Commissioning activities, including combustor mapping or tuning, are not considered normal operations. Emissions are likely to fluctuate during these activities. As a result of this, emissions likely to be low, consistent and predictable in comparison with certain commissioning activities.

The emissions from individual exhausts during commissioning are likely to vary significantly for very short periods. due to tuning, and testing of the machines over a range of loads, as part of the process of optimising performance and efficiency.

Normal operations will be in line with manufacturer specifications, and instead of units ramping up and down, they will be operated at ≥75% capacity, more units will be dispatched or removed from dispatch to meet energy demands. This dispatch strategy will ensure efficient fuel use and minimisation of emission intensity (including greenhouse gas emission intensity). The dispersion of emissions and comparison of these figures against relevant criteria can be found in the Air Emission Assessment conducted by SLR, which is appended to attachment 3B of this application.

5.2 Risk Management and Contingency Planning

The approach to management of incidents, chemicals and hydrocarbons, surface water and drainage, complaints, unplanned emissions or emission exceedances and unplanned discharges during normal operations will not differ from what is detailed in section 3 of this document.

6. REFERENCES

Department of Water and Environmental Regulation (2020) Application form V13: Works Approval / Licence / Renewal /Amendment / Registration Part V, Division 3, Environmental Protection Act 1986, Environmental Protection Regulations 1987

Department of Environment Regulation, (2016) Continuous Emission Monitoring System (CEMS) Code for Stationary Source Air Emissions

Kwinana Industries Council (2015) KIC Fact Sheet, Sulphur Dioxide

Department of Environment (2004) Pilbara Air Quality Study Summary Report, Technical Series Report 120

United States Environmental Protection Agency (2000) AP 42, Fifth Edition, Volume I, Chapter 3: Stationary Internal Combustion Sources

Documents

Attachment 3A PEG Power Station Commissioning Plan