Released by EHP under the

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1 Queensland Health Tara Air Emission Data Collation Report drafted by the Energy Assessments Unit Department of Environment and Heritage Protection File C Page 1 of 185

2 Contents Comment [DN1]: Update page numbers as required. 1. Introduction Methodology Contaminants Action Plan Objectives 4 3. Review of Existing Reports, Monitoring Conditions and Limitations Description of Air Monitoring EA Conditions QGC Kenya APLNG Talinga Results and Discussion QGC Kenya APLNG Talinga External response Other EHP Units Department of Health (Queensland Health) Coal Seam Gas Compliance Unit GasFields Commission Queensland Department of Science, Information Technology, Innovation and Arts Site Inspections Review of Talinga Gas Processing Facility Ambient Air Monitoring Program Review.? 8. Conclusion.? 9. Recommendations..? Attachment A File C Page 2 of 185

3 Queensland Health Tara Air Emission Data Collation 1. Introduction Residents of the Wieambilla Estate have raised concerns about the impacts of air emissions from the local coal seam gas fields on their health and well-being and that of the surrounding community. These concerns have primarily focused on odours and the potential health implications from those odours. The Wieambilla Estate is located half-way between Chinchilla to the north and Tara to the south of the estate. Refer to Attachment A for a map showing the Wieambilla Estate complainants in relation to the indicative locations of fuel burning equipment on the Talinga Project Area and Kenya Project Area. The location of all fuel burning equipment is not available to Department of Environment and Heritage Protection (EHP), as such only compression stations and gas plants have been identified in Attachment A. The Wieambilla Estate is surrounded by petroleum tenure both in exploration/appraisal phase or production phase. The two primary production gas fields in the vicinity of the Wieambilla Estate are Australia Pacific LNG Pty Limited s (APLNG) Talinga Project Area (Environmental Authority (EA) EPPG ) and QGC Pty Limited (QGC) s Kenya Project Area (EA EPPG ). The other petroleum tenures surrounding these project areas have not been included in this report as they are primarily exploration or in the initial development phase. Both APLNG and QGC have fuel burning equipment that has been in operation for at least five years. APLNG s Talinga has been operating since February 2004 and QGC s Kenya has been operating since July In response to residents concerns raised about the health impact of odour emissions from the local coal seam gas fields on surrounding residential areas, the Department of Health undertook an investigation which resulted in the Department of Health report Coal seam gas in the Tara region: Summary risk assessment of health complaints and environmental monitoring data, March Several recommendations were made in the report and an action plan in response to the recommendations was drafted. One of these recommendations was for EHP to undertake a desktop review of existing air monitoring undertaken by EHP and industry to identify any gaps in available data. This report presents the results of the Action Plan and resulting review. 2. Methodology A desktop review was undertaken by the Energy Assessments Unit (EAU) to gather information and data regarding air emissions in the Tara region, coincidentally APLNG s Talinga project area and QGC s Kenya project area. Firstly an information request was sent out to both companies over the course of The southern region (Toowoomba), Department of Science, Information Technology, Innovation and the Arts (DSITIA), and Queensland Health were contacted for any relevant information. An air specialist from within EHP was also included in the review process to analyse technical data and provide advice on air emissions. The report has been broken up into EA conditions (all amendments), data, discussion, other reports, conclusion and recommendations File C Page 3 of 185

4 Timeline of Energy Assessment process: 18 December 2012 EHP issued letters to QGC (for the Kenya Project Area) and APLNG (for the Talinga Project Area) requesting all documents, information and data that is required to be developed in the Environmental Authority conditions, to be provide to EHP for a comprehensive desktop (Level C) audit. This included a request for air monitoring data to be submitted to EHP. 8 February 2013 and 11 February 2013 Received information from APLNG and QGC respectively. 24 April 2013 EHP issued a second request for information to QGC and APLNG as all the required information had not been provided. 7 May 2013 APLNG provided additional information in response to EHP letter. 17 May 2013 QGC provided additional information in response to EHP letter. 5 June 2013 Energy Assessment, EHP was tasked with collating air data, which had been received by EHP as part of the EIS process and EA applications for the QGC Kenya Project Area and APLNG Talinga Project Area. 9 August 2013 EHP requested air modelling and monitoring from QGC, originally requested as part of the desktop audit on 18 December August 2013 QGC responded to letter and provided reasons why air modelling and monitoring could not be provided. No air modelling or monitoring was provided to EHP. 30 August 2013 Energy Assessment finalised its report on its findings, titled Queensland Health Tara Air Emissions Data Collation. 5 February Energy Assessment was requested to finalise report which included the following data provided to EHP since 30 August 2013: o APLNG Third Party Audit, provided 24 October 2013; o QGC monitoring data for the Kenya Water Treatment Plant, provided 28 November 2013; 12 February 2014 Energy Assessment, EHP forwarded revised report Contaminants The chosen contaminants for this report are Nitrogen nitrogen dioxide(no₂) and Carbon carbon monoxide (CO). These contaminants are the major by-products of burning coal seam gas (CSG) methane. The Coordinator General s report for both the QGC and APLNG on the EIS highlighted monitoring of oxides of Nitrogen nitrogen. Thus the air quality objectives for NO₂ and CO as specified limits in the Environmental Protection (Air) Policy 2008 (EPP (Air)) have been chosen for the EA conditions to regulate and monitor contaminant releases. The Queensland Health report lists other contaminants which are primarily in context to odour issues. Due to the composition of the fuel gas (CSG) it is unlikely that these other contaminants would be of concern to human health at any concentrations generated by the combustion of the fuel gas. Concentrations of these other contaminants are likely to be very low. Comment [M2]: Which EIS? Reference this Fugitive emissions are addressed in the DSITIA report and in the EPP (Air) limits, however the EA does not monitor for these as they are unlikely to occur in high concentrations. The APLNG Talinga EA has measures to reduce fugitive emissions with conditions to ensure that all reasonable and File C Page 4 of 185

5 practical measures are taken in the design and operation of the plant to minimise fugitive VOC emissions (Condition F14) Action Plan Objectives The Action Plan was created after a meeting between various EHP and government agencies, Queensland Health and the GasFields Commission in June The plan comprises of four main objectives; the first two allocated to EAU, the last two allocated to Southern region. The action plan is listed as follows: 1. Collate and review existing air monitoring and modelling data available from government agencies and industry sources to identify if gaps exist in the available data. 2. Evaluate need for a plan to address any gaps identified and consider need for additional strategic monitoring of ambient air quality or air modelling. 3. Should this evaluation recommend additional air monitoring consider funding options, including industry funded solutions, to implement the plan. 4. Provide the air monitoring and modelling results to Department of Health for undertaking he health risk assessments. This report represents as the response to the first two objectives of the action plan and provides recommendations in relation to the third objective. 3. Review of Existing Reports, Monitoring Conditions and Limitations The Department of Science, Information Technology, Innovation and the Arts (DSITIA) commenced a community sampling program for volatile organic compounds (VOCs) in the Wieambilla Estate in response to community concerns about the impacts of air emissions from the local coal seam gas fields on the health and well-being of the surrounding community. The report, Wieambilla Estates Odour Investigation Results, July December 2012 outlines the results of the community sampling program conducted between July and December 2012 and is included in Attachment B. It indicated that a number of volatile organic compounds (VOCs) were detected in the ambient air at levels generally well below relevant guidelines and criteria used to assess VOC concentrations. Monitoring data for this review was collected from the APLNG Talinga EA and the QGC Kenya EA. The relevant EA conditions are described below in Section Description of Air Monitoring EA Conditions The following is a compliance assessment of EA conditions in relation to air emissions. The EA conditions proceed from the most recently dated to the oldest available File C Page 5 of 185

6 QGC Kenya July 2011 present Fuel burning and combustion equipment register It is a requirement under QGC Kenya EA condition (G3) that a fuel burning register of equipment capable of burning more than 500kg/hr is maintained. There is no individual fuel burning equipment which burns more than 500kg/hr of fuel in the Kenya Project Area and as such no equipment has been included in the register. Ground level concentrations Table 1: Maximum Ground Level Concentration Criteria outlines the maximum concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located more than 5km outside of a hub or populated area as specified in EA condition (G7) for the Kenya Project Area. Table 1: Maximum Ground Level Concentration Criteria (as per EA Condition G7) Contaminant Concentration at Units Averaging time 0⁰ Celsius NOx as Nitrogen 250 μg/m³ 1 hour nitrogen dioxide NOx as Nitrogen 33 μg/m³ 1 year nitrogen dioxide Carbon monoxide 11 mg/m³ 8 hour The following condition (G10) applies to any fuel burning and combustion equipment located inside 5km of a hub and/or populated area. Table 2 documents the only equipment allowed to burn more than 500kg/hr of fuel and their limits. Note: Although this condition existed in July 2011, the table was not completed and included in the EA until July 2012, rendering the condition unenforceable until that date File C Page 6 of 185

7 Table 2: Releases of contaminants to air (as per EA Condition G10) Resource Authority Field Facility Release point PL180 Kenya Kenya Field Compressor Station PL180 Kenya Kenya Central Processing Plant PL228 Kenya Kenya Relocatable Water Treatment Plant (RWTP) PL228 Kenya Kenya RWTP PL228 Kenya Kenya Water Treatment Plant Power Generators FCS 1 - FCS 8 CPP 1 - CPP 10 DGA 1 DGB 1 DGB 2 PG 1- PG 7 Unit Description Gas Screw Compressor Gas Reciprocating Engines Diesel Generators Diesel Generators Gas Reciprocating Engines Min Stack Minimum NOx as Nitrogen dioxide Carbon monoxide Release Height (m) diameter (m) efflux velocity (m/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) PL228 Kenya PB 1 - Auxiliary PB 3 boiler PL228 Kenya BC 1 - BC 3 Gas Reciprocating Engines *Minimum efflux velocity, maximum concentration and maximum mass emission are to be measured at the Maximum Continuous Rating File C Page 7 of 185

8 Point source air monitoring Point source air monitoring is required for both NOx as nitrogen dioxide and carbon monoxide at Kenya (Condition G15). It requires monitoring 3 months after commissioning any fuel equipment and biennially thereafter. May 2009 March 2010 Contaminant release points Condition (O1): The release of contaminants to the atmosphere from a point source can only occur at the release points specified below. Table 3: Compressor Station Release Points (as per EA Condition O1) Release Source Minimum release height (meters) Kenya Field Compression Station Natural Gas Engines Kenya 1 to Kenya 4 Natural Gas Engines Kenya 5 to Kenya 8 Start and blow down vents Minimum velocity (m/sec) Contaminant release 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr 3m Approx 30m³ coal seam gas (>97% CH4, 2.6% N, 0.1% CO2, <0.15% C2H6) Codie Field Compression Station Natural Gas Engines Codie 1 to Codie 8 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr Kenya Processing Plant Natural Gas Engines Kenya Sales 1 to Kenya Sales 10 Type of fuel to be used 3.5 meters above ground level 42 m/s At 100% load and speed: NOx ton/year CO ton/year Hydrocarbons 9.15 ton/year Condition (O3): The only type of fuel to be burnt in the compressors, under normal operating conditions, is coal seam gas. Monitoring of contaminant releases Condition (O4): Only when the administering authority requests contaminant monitoring File C Page 8 of 185

9 July 2007 November The older conditions regarding air were focused on dust suppression and particulate matter. The following condition is the only condition regarding fuel burning: Condition (K1): This environmental authority only permits the burning of hydrocarbon based fuels in fuel burning equipment APLNG Talinga September 2012 present Fuel burning and combustion equipment register It is a requirement under APLNG Talinga EA condition (F7) that a fuel burning register of equipment capable of burning more than 500kg/hr is maintained. APLNG provided a fuel burning and combustion equipment register for all fuel burning equipment located on the Talinga Project Area, however only the Reciprocating Compressors at the Talinga Gas Processing Facility burn more than 500kg/hr of fuel. Ground level concentrations Table 4 Maximum Ground Level Concentration Criteria outlines the maximum concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located outside of a hub or populated area as specified in EA condition (F4) for the Talinga Project Area. Table 4: Maximum Ground Level Concentration Criteria (as per EA Condition F4) Contaminant Concentration at Units Averaging time 0⁰ Celsius NOx as Nitrogen 250 μg/m³ 1 hour dioxide NOx as Nitrogen 33 μg/m³ 1 year dioxide Carbon monoxide 11 mg/m³ 8 hour May March 2012 Fuel burning facility details Condition (O1) requires APLNG to submit fuel burning details to EHP within 3 months of grant of authority, for assessment to ensure emissions are not causing nuisance/environmental harm. Contaminant Limits Table 5 demonstrates the contaminant limits of each piece of equipment as instructed in condition (O4). QGC has supplied no data to determine compliance File C Page 9 of 185

10 Table 5: Fuel Burning Facility Release Points and Contaminant Limits (as per EA Condition O4) Release Source Minimum release height (meters) Minimum velocity (m/sec) Contaminant release Maximum release limit¹ Talinga Gas Plant Screw NOx 6.6 Compressors Reciprocating NOx 0.39 Compressors Generators NOx 2.2 TEG Reboiler Burner NOx 0.7 Rockwood Compressor Station Screw NOx 0.13 Compressors Talinga Water Treatment Facility Power Station NOx 0.11 Talinga Field Well Head Pump Microprocessors NOx Note 1: The above NOx limits are applicable at all times except start-up, shut down and calibration of emission monitoring devices. The maximum start-up allowed is 30 mins. Type of fuel to be used Condition (O5): The only fuel to be burnt under normal operating conditions is methane. Monitoring of contaminant releases to the atmosphere Condition (O12): QGC must conduct and keep records of a monitoring program of contaminant release to the atmosphere at the release points, frequency and parameters in the table below. Table 6: Required air monitoring (as per EA Condition O12) Determination Required Release points Frequency Mass emission rate and concentration of oxides of nitrogen (NOx) in the flue gas at the specified oxygen reference level. Talinga WTF E S E S E S E S Talinga GP and flares E S E S E S E S Rockwood Compressor Station E S E S E S E S During commissioning of the plant, twice a year for the first two years of operation and then annually thereafter File C Page 10 of 185

11 March The older conditions regarding air were focused on dust suppression and particulate matter. The following condition is the only condition regarding fuel burning: Condition (K1): This environmental authority only permits the burning of hydrocarbon based fuels in fuel burning equipment Air quality objectives from EPP (Air) Limits Environmental Protection (Air) Policy 2008 Table 7 lists the air quality objectives for carbon monoxide and nitrogen dioxide as specified in the EPP (Air). Table 7: Air quality objectives from EPP (Air) Indicator Carbon monoxide Nitrogen dioxide Environmental value Health and wellbeing Health and wellbeing Health and biodiversity of ecosystems 4. Results and Discussion 4.1. QGC Kenya Air quality objectives Period Days μg/m³ at 0 degrees C (except where noted) ppm (volume/ volume) 11mg/m³ 9 8 hours 1 day each year hour 1 day each year year year No data for ground level concentrations is available for the Kenya Project Area. The EA conditions only require monitoring of fuel burning or combustion equipment burning more than 500kg/hr and no equipment of this size is on site. Therefore, no data has been provided to EHP. Stack (point source) monitoring Access deferred File C Page 11 of 185

12 Access deferred Table 8: Kenya Water Treatment Plant Power Generators for October (Data sourced from QGC through the report Air monitoring (point source) by Veolia water November 2013) Release Average NOx as Nitrogen dioxide Carbon monoxide point stack gas velocity (m/sec) Maximum concentration * (mg / dscm) Mass emission rate* (kg/hour) Maximum concentration * (mg / dscm) Mass emission rate* (kg/hour) PG PG PG PG PG PG6* N/A PG *PG6 was not tested as it was offline during the sampling program. Kenya WTP power generator stack test report (Table 8) The ECS stack testing report provides results or emissions testing carried out at the Kenya WTP gasfired power generators in October this year. One of the seven generators was not operating at the time, and so was not tested. The ECS report notes that the sampling planes for the six generators was non-ideal for flow rate determinations, however additional sampling traverses were undertaken in accordance with AS to compensate for the non-ideal location. Hence flow rate determinations can be regarded as reliable. Results for concentration (mg/m3) and mass (g/s) for NOx expressed as NO2 and for CO were all less than the relevant EA release limits. Measured efflux velocities were all greater than the EA minimum efflux velocity. The EA requires that measurements of efflux velocity, pollutant concentration and pollutant mass be made at maximum continuous rating (load) (MCR). In this case engine load was set at 90% to allow for the engine to be able to handle a sudden increase in extra load without causing a complete plant shutdown. (Executive summary, page 5). This would satisfy the MCR requirement. As such, the testing showed that the power generators were compliant with the EA release limits. Table 9: Stack and emission data provided by QGC, which are based on stack monitoring programs performed at a number of sites. (Data sourced from QGC through the report Central Project Area Air Dispersion Modelling Study by SLR global environmental solutions December Comment [DN3]: Not sure if data, may be modelled File C Page 12 of 185

13 Facility Kenya Field Compressor Station Kenya Central Processing Plant Kenya Water Treatment Plant Power Generators Release point FCS 1 - FCS 8 CPP 1 - CPP 10 PG 1- PG 7 PB 1 - PB 3 BC 1 - BC 3 Modelling studies (Table 9) Unit Description Gas Screw Compressor Gas Reciprocating Engines Stack height (m) Stack diameter (m) Exit velocity (m/sec) CO emission rate (g/sec) NOx emissio n rate (g/sec) Gas Reciprocating Engines Auxiliary boiler Gas Reciprocating Engines Two modelling studies prepared to assess the potential impacts in air quality from the QGC Kenya area used a number of NOx emission factors for the WTP generators that were provided by QGC. These were compared against the measured NOX emissions. The measured emissions were all below the modelled factors. In addition, measured efflux velocities and temperatures were higher than those modelled. If the assessment was undertaken using the measured NOX emissions, efflux velocities, and temperatures, it is feasible the predicted ground-level concentrations would be lower than those modelled in the previous studies File C Page 13 of 185

14 4.2. APLNG Talinga APLNG has alleged no air emission data exists for 2007 to Only the Reciprocating Compressors at the Talinga Gas Processing Facility burn more than 500kg/hr of fuel, due to this the majority of the following data is for this equipment and surrounding facility. Emissions monitoring There are two tables to represent air emission data for the Talinga Gas Processing Facility. Table 8 10 displays data for 2013, whilst Table 9 11 displays data for File C Page 14 of 185

15 Table 10: Monitored Talinga Gas Processing Plant air emission data 2013 (Data sourced from APLNG through the report Emissions Monitoring: Talinga Gas Processing Facility July 2013) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressors Screw Compressor Power Generator NOx mass emission rate (g/sec) NOx maximum concentration (mg/nm³) CO mass emission rates (g/sec) K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K NA - Breakdown K /06/ K /06/ K /06/ K /06/ G /06/ G /06/ G /06/ CO maximum concentration (mb/nm³) File C Page 15 of 185 Release

16 Table 11: Monitored Talinga Gas Processing Facility air emission data 2012 (Data sourced from APLNG though the report Emissions Monitoring: Talinga Gas Processing Facility October 2012) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressor Screw Compressor NOx mass emission rate (g/sec) K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ NOx maximum concentration (mg/nm³) File C Page 16 of 185 Release

17 Annual Environmental Monitoring Report March APLNG have submitted an annual environmental monitoring report for which provides a summary of the past 12 months monitoring data and results. Table 10 shows data for one of each compressor type. Table 12: Annual environmental monitoring air emission data comparison Facility Measure EA Condition Monitored Reciprocating Velocity (m/s) Compressor 5 Nitrogen Oxides (NO₂) (g/s) Screw Compressor Velocity (m/s) Nitrogen Oxides (NO₂) (g/s) APLNG have the following comment regarding the non-compliance of velocity: The monitoring indicated that the emission velocity on one of the engines was below the minimum licence limit. An investigation into the incident concluded that the engine emission specification originally supplied to the department as part of the proposed development application was incorrect. The emission velocity calculation failed to factor in temperature losses in the exhaust stack and the operating set up of the engine. Note: Only the last of each of the compressors has been included, Reciprocating Compressor 5 of 5, Screw Compressor 12 of 12. Also the EA limits above come from the March 2012 EA conditions. There has been no comparison to previous year s results. 5. External Response Throughout the report process there were updates from sources internally at other EHP units, from the Coal Seam Gas Compliance Unit, the GasFields Commission Queensland, DSITIA and Queensland Health Other EHP Units Access deferred File C Page 17 of 185

18 5.2. Department of Health (Queensland Health) The response from Queensland Health 5.3. Coal Seam Gas Compliance Unit (CSGCU) The Coal Seam Gas Compliance Unit of the Department of Natural Resources and Mines confirmed on 7 February 2014 that no air modelling or monitoring data has been undertaken or received by this unit. has been working with landholders that have complained about air quality and odour in the Wieambilla Estate for a number of years now. All of the government sampling that they are aware of has been done by EHP South (Toowoomba) and all that was available at the time was included in a report and was reviewed as part of the Tara Health report. They are also aware that QGC engaged a contractor to do a wide range of sampling for a number of properties on the Estate and these are included in the Health report. The CSGCU has not received any other information GasFields Commission Queensland The GasFields Commission confirmed on 10 February 2014 that no has not undertaken any air modelling or monitoring or modelling or has been undertaken or received any data on thisby the GasFields Commission. They have encouraged the companies and the relevant government agencies to undertake this work and provide the information to the relevant people Department of Science, Information Technology, Innovation and Arts (DSITIA) David Wainwright (Director Air Quality Sciences of ) has confirmed that DSITIA confirmed on 7 February 2014 that no do not have any more air modelling or monitoring data has been provided to DSITIA since other than what was collected in the 2012 report, which has already been included in this report. 6. Site Inspections (To insert from known information / from Southern) Comment [PM4]: Need Danielle or Hamish to confirm this date 7. Review of Talinga Gas Processing Facility Ambient Air Monitoring Program Review APLNG implemented an ambient air quality monitoring program approximately 3km southeast of the Talinga Gas Processing Facility (GPF) in response to stack testing that showed some aspects of the operational emissions did not conform to the existing approval conditions; in particular the File C Page 18 of 185

19 exhaust velocity was found to be below the minimum specified. (Page 1 ). The monitoring program was designed to measure ambient ground-level concentrations of nitric oxide (NO), nitrogen dioxide (NO₂), oxides of nitrogen (NOx), carbon monoxide (CO), and meteorological observations including wind speed and wind direction. Among other things, the purpose of the program was to understand the potential environmental or health impacts of emission from the GPF. Only NO₂ and CO are scheduled in the EPP (Air) and EA limits. Validated data for the 7 month period between 20 June 2012 and 31 January 2013 was reviewed by Katestone Environmental (Katestone Environmental document reference D _Origin_Talinga_Ambient_Monitoring_Report_v1.10.docx). The review assessed ground-level concentrations against wind direction and showed that: - The highest NO₂ concentrations were associated with winds blowing from the direction of the GPF towards the monitoring point; NO₂ - Some elevated NO₂ concentrations were associated with a second GPF in the area (the report did not identify the location other than upwind of the monitoring point ); and - NO₂ concentrations were near background levels when the wind blew from all other directions (page 28, Figure 9). The review correctly concluded that measured concentrations for 1-hour and annual ground-level NO₂, and for 8-hour CO were below the respective EPP (Air) goals. Katestone Environmental also undertook new air quality dispersion modelling using stack testing emissions data provided by APLNG. 1-hour concentrations of NO₂ were predicted to exceed the EPP (Air) goal up 15km to the south-southwest of the GFC and monitoring station (Page 13, Page 34, Figure 15; and Page 36, Figure 17). No sensitive receptors were identified within the exceedance zone (which suggests no non-compliances). Modelled pollutant concentrations were compared with measured concentrations. Comparisons showed some differences, however on balance, the differences can be regarded to be within the sensitivity bounds of the modelling system. Note that (a) the monitoring station is outside the modelled exceedance zones, and (b), the extent to which the non-compliant exhaust velocity(ies) contributed to the modelled exceedances was not investigated. 8. Conclusion The Queensland Health report found no clear link between the health complaints by some residents in the Tara region and impacts of the local CSG industry on air, water or soil. The DSITIA report on VOCs in the Wieambilla Estate detected VOCs in ambient air; however the levels detected were below relevant guidelines and criteria used to assess the potential health effects from VOC s. Access deferred File C Page 19 of 185

20 Access deferred Of the information available there are only individual results which do not represent the Wieambilla Estate. There is insufficient data to be able to calibrate and validate an appropriate air shed model for the Tara region. For this to occur there needs to be more data, both point source at the stack and ground level concentrations to cover all equipment capable of significant air emissions. However, the data did reveal some information for the Talinga Project Area as APLNG undertook an ambient air monitoring program monitoring CO, NO, NO₂ and NOx which demonstrated that concentrations of NO₂ and CO were below EPP (Air) objectives. QGC have also demonstrated that the Kenya Water Treatment Plant is complying with EA limits. EHP does not have access to information on other contaminants listed in the Queensland Health report. However, as mentioned it is unlikely that there would be other contaminants of concern based on the composition of the fuel gas (CSG). 9. Recommendations 1. EHP will undertake compliance of the Talinga Gas Field and Kenya Gas Field through the Level C inspections to determine the level of non-compliance with regards to the conditions relating to air emissions in the EAs. 2. EHP will undertake a review of current EA conditions to identify improvements to ensure EHP is able to determine industry compliance with EPP (Air). It is suggested that the focus on equipment capable of burning more than 500kg/hr of fuel be removed/adjusted to ensure all infrastructure emitting contaminants that have the potential for environmental harm are accounted for. 3. EHP will monitor the current situation until outcomes from the Level C inspections and EA condition review informs required actions. 4. This report and reviewing process should be audited within 2 years to ensure that the issues identified in the report have been rectified File C Page 20 of 185

21 Attachment A: Air emissions gap analysis indicative locations of fuel burning equipment surrounding the Wieambilla Estate complainants 49-Sch File C Page 21 of 185

22 Queensland Health Tara Air Emission Data Collation Report drafted by the Energy Assessments Unit Department of Environment and Heritage Protection File C Page 22 of 185

23 Contents Comment [DN1]: Update page numbers as required. 1. Introduction Methodology Contaminants Action Plan Objectives 4 3. Review of Existing Reports, Monitoring Conditions and Limitations Description of Air Monitoring EA Conditions QGC Kenya APLNG Talinga Results and Discussion QGC Kenya APLNG Talinga External response Other EHP Units Department of Health (Queensland Health) Coal Seam Gas Compliance Unit GasFields Commission Queensland Department of Science, Information Technology, Innovation and Arts Site Inspections Review of Talinga Gas Processing Facility Ambient Air Monitoring Program Review.? 8. Conclusion.? 9. Recommendations..? Attachment A? File C Page 23 of 185

24 Queensland Health Tara Air Emission Data Collation 1. Introduction Residents of the Wieambilla Estate have raised concerns about the impacts of air emissions from the local coal seam gas fields on their health and well-being and that of the surrounding community. These concerns have primarily focused on odours and the potential health implications from those odours. The Wieambilla Estate is located half-way between Chinchilla to the north and Tara to the south of the estate. Refer to Attachment A for a map showing the Wieambilla Estate complainants in relation to the indicative locations of fuel burning equipment on the Talinga Project Area and Kenya Project Area. The location of all fuel burning equipment is not available to Department of Environment and Heritage Protection (EHP), as such only compression stations and gas plants have been identified in Attachment A. The Wieambilla Estate is surrounded by petroleum tenure both in exploration/appraisal phase or production phase. The two primary production gas fields in the vicinity of the Wieambilla Estate are Australia Pacific LNG s (APLNG) Talinga Project Area (Environmental Authority (EA) EPPG ) and QGC s Kenya Project Area (EA EPPG ). The other petroleum tenures surrounding these project areas have not been included in this report as they are primarily exploration or in the initial development phase. Both APLNG and QGC have fuel burning equipment that has been in operation for at least five years. APLNG s Talinga has been operating since February 2004 and QGC s Kenya has been operating since July In response to residents concerns raised about the health impact of odour emissions from the local coal seam gas fields on surrounding residential areas, the Department of Health undertook an investigation which resulted in the Department of Health report Coal seam gas in the Tara region: Summary risk assessment of health complaints and environmental monitoring data, March Several recommendations were made in the report and an action plan in response to the recommendations was drafted. One of these recommendations was for EHP to undertake a desktop review of existing air monitoring undertaken by EHP and industry to identify any gaps in available data. This report presents the results of the Action Plan and resulting review. 2. Methodology A desktop review was undertaken by the Energy Assessments Unit (EAU) to gather information and data regarding air emissions in the Tara region, coincidentally APLNG s Talinga project area and QGC s Kenya project area. Firstly an information request was sent out to both companies over the course of The southern region (Toowoomba), Department of Science, Information Technology, Innovation and the Arts (DSITIA), and Queensland Health were contacted for any relevant information. An air specialist from within EHP was also included in the review process to analyse technical data and provide advice on air emissions. Comment [M2]: Write in full for the first time The report has been broken up into EA conditions (all amendments), data, discussion, other reports, conclusion and recommendations File C Page 24 of 185

25 Timeline of Energy Assessment process: 18 December 2012 EHP issued letters to QGC (for the Kenya Project Area) and APLNG (for the Talinga Project Area) requesting all documents, information and data that is required to be developed in the Environmental Authority conditions, to be provide to EHP for a comprehensive desktop (Level C) audit. This included a request for air monitoring data to be submitted to EHP. 8 February 2013 and 11 February 2013 Received information from APLNG and QGC respectively. 24 April 2013 EHP issued a second request for information to QGC and APLNG as all the required information had not been provided. 7 May 2013 APLNG provided additional information in response to EHP letter. 17 May 2013 QGC provided additional information in response to EHP letter. 5 June 2013 Energy Assessment, EHP was tasked with collating air data, which had been received by EHP as part of the EIS process and EA applications for the QGC Kenya Project Area and APLNG Talinga Project Area. 9 August 2013 EHP requested air modelling and monitoring from QGC, originally requested as part of the desktop audit on 18 December August 2013 QGC responded to letter and provided reasons why air modelling and monitoring could not be provided. No air modelling or monitoring was provided to EHP. 30 August 2013 Energy Assessment finalised its report on its findings, titled Queensland Health Tara Air Emissions Data Collation. 5 February Energy Assessment was requested to finalise report which included the following data provided to EHP since 30 August 2013: o APLNG Third Party Audit, provided 24 October 2013; o QGC monitoring data for the Kenya Water Treatment Plant, provided 28 November 2013; 12 February 2014 Energy Assessment, EHP forwarded revised report Contaminants The chosen contaminants for this report are Nitrogen dioxide(no₂) and Carbon monoxide (CO). These contaminants are the major by-products of burning coal seam gas (CSG) methane. The Coordinator General s report on the EIS highlighted monitoring of oxides of Nitrogen. Thus the NO₂ and CO limits in EPP Air have been chosen for the EA conditions to regulate and monitor contaminant releases. The Queensland Health report lists other contaminants which are primarily in context to odour issues. Due to the composition of the fuel gas (CSG) it is unlikely that these other contaminants would be of concern to human health at any concentrations generated by the combustion of the fuel gas. Concentrations of these other contaminants are likely to be very low. Comment [M3]: Which EIS? Reference this Comment [M4]: Write in full for the 1 st time Fugitive emissions are addressed in the DSITIA report and in the EPP Air limits, however the EA does not monitor for these as they are unlikely to occur in high concentrations. The APLNG Talinga EA has measures to reduce fugitive emissions with conditions to ensure that all reasonable and practical measures are taken in the design and operation of the plant to minimise fugitive VOC emissions (Condition F14) File C Page 25 of 185

26 2.2. Action Plan Objectives The Action Plan was created after a meeting between various EHP and government agencies, Queensland Health and the GasFields Commission in June The plan comprises of four main objectives; the first two allocated to EAU, the last two allocated to Southern region. The action plan is listed as follows: 1. Collate and review existing air monitoring and modelling data available from government agencies and industry sources to identify if gaps exist in the available data. 2. Evaluate need for a plan to address any gaps identified and consider need for additional strategic monitoring of ambient air quality or air modelling. 3. Should this evaluation recommend additional air monitoring consider funding options, including industry funded solutions, to implement the plan. 4. Provide the air monitoring and modelling results to Department of Health for undertaking he health risk assessments. This report represents as the response to the first two objectives of the action plan and provides recommendations in relation to the third objective. 3. Review of Existing Reports, Monitoring Conditions and Limitations The Department of Science, Information Technology, Innovation and the Arts (DSITIA) commenced a community sampling program for volatile organic compounds (VOCs) in the Wieambilla Estate in response to community concerns about the impacts of air emissions from the local coal seam gas fields on the health and well-being of the surrounding community. The report, Wieambilla Estates Odour Investigation Results, July December 2012 outlines the results of the community sampling program conducted between July and December 2012 and is included in Attachment B. It indicated that a number of volatile organic compounds (VOCs) were detected in the ambient air at levels generally well below relevant guidelines and criteria used to assess VOC concentrations. Monitoring data for this review was collected from the APLNG Talinga EA and the QGC Kenya EA. The relevant EA conditions are described below in Section Description of Air Monitoring EA Conditions The following is a compliance assessment of EA conditions in relation to air emissions. The EA conditions proceed from the most recently dated to the oldest available QGC Kenya July 2011 present File C Page 26 of 185

27 Fuel burning and combustion equipment register It is a requirement under QGC Kenya EA condition (G3) that a fuel burning register of equipment capable of burning more than 500kg/hr is maintained. There is no individual fuel burning equipment which burns more than 500kg/hr of fuel in the Kenya Project Area and as such no equipment has been included in the register. Ground level concentrations Table 1: Maximum Ground Level Concentration Criteria outlines the maximum concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located more than 5km outside of a hub or populated area as specified in EA condition (G7) for the Kenya Project Area. Table 1: Maximum Ground Level Concentration Criteria (as per EA Condition G7) Contaminant Concentration at Units Averaging time 0⁰ Celsius NOx as Nitrogen 250 μg/m³ 1 hour dioxide NOx as Nitrogen 33 μg/m³ 1 year dioxide Carbon monoxide 11 mg/m³ 8 hour The following condition (G10) applies to any fuel burning and combustion equipment located inside 5km of a hub and/or populated area. Table 2 documents the only equipment allowed to burn more than 500kg/hr of fuel and their limits. Note: Although this condition existed in July 2011, the table was not completed and included in the EA until July 2012, rendering the condition unenforceable until that date File C Page 27 of 185

28 Table 2: Releases of contaminants to air (as per EA Condition G10) Resource Authority Field Facility Release point PL180 Kenya Kenya Field Compressor Station PL180 Kenya Kenya Central Processing Plant PL228 Kenya Kenya Relocatable Water Treatment Plant (RWTP) PL228 Kenya Kenya RWTP PL228 Kenya Kenya Water Treatment Plant Power Generators FCS 1 - FCS 8 CPP 1 - CPP 10 DGA 1 DGB 1 DGB 2 PG 1- PG 7 Unit Description Gas Screw Compressor Gas Reciprocating Engines Diesel Generators Diesel Generators Gas Reciprocating Engines Min Stack Minimum NOx as Nitrogen dioxide Carbon monoxide Release Height (m) diameter (m) efflux velocity (m/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) PL228 Kenya PB 1 - Auxiliary PB 3 boiler PL228 Kenya BC 1 - BC 3 Gas Reciprocating Engines *Minimum efflux velocity, maximum concentration and maximum mass emission are to be measured at the Maximum Continuous Rating File C Page 28 of 185 Release

29 Point source air monitoring Point source air monitoring is required for both NOx as nitrogen dioxide and carbon monoxide at Kenya (Condition G15). It requires monitoring 3 months after commissioning any fuel equipment and biennially thereafter. May 2009 March 2010 Contaminant release points Condition (O1): The release of contaminants to the atmosphere from a point source can only occur at the release points specified below. Table 3: Compressor Station Release Points (as per EA Condition O1) Release Source Minimum release height (meters) Kenya Field Compression Station Natural Gas Engines Kenya 1 to Kenya 4 Natural Gas Engines Kenya 5 to Kenya 8 Start and blow down vents Minimum velocity (m/sec) Contaminant release 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr 3m Approx 30m³ coal seam gas (>97% CH4, 2.6% N, 0.1% CO2, <0.15% C2H6) Codie Field Compression Station Natural Gas Engines Codie 1 to Codie 8 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr Kenya Processing Plant Natural Gas Engines Kenya Sales 1 to Kenya Sales 10 Type of fuel to be used 3.5 meters above ground level 42 m/s At 100% load and speed: NOx ton/year CO ton/year Hydrocarbons 9.15 ton/year Condition (O3): The only type of fuel to be burnt in the compressors, under normal operating conditions, is coal seam gas. Monitoring of contaminant releases Condition (O4): Only when the administering authority requests contaminant monitoring. July 2007 November File C Page 29 of 185

30 The older conditions regarding air were focused on dust suppression and particulate matter. The following condition is the only condition regarding fuel burning: Condition (K1): This environmental authority only permits the burning of hydrocarbon based fuels in fuel burning equipment APLNG Talinga September 2012 present Fuel burning and combustion equipment register It is a requirement under APLNG Talinga EA condition (F7) that a fuel burning register of equipment capable of burning more than 500kg/hr is maintained. APLNG provided a fuel burning and combustion equipment register for all fuel burning equipment located on the Talinga Project Area, however only the Reciprocating Compressors at the Talinga Gas Processing Facility burn more than 500kg/hr of fuel. Ground level concentrations Table 4 Maximum Ground Level Concentration Criteria outlines the maximum concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located outside of a hub or populated area as specified in EA condition (F4) for the Talinga Project Area. Table 4: Maximum Ground Level Concentration Criteria (as per EA Condition F4) Contaminant Concentration at Units Averaging time 0⁰ Celsius NOx as Nitrogen 250 μg/m³ 1 hour dioxide NOx as Nitrogen 33 μg/m³ 1 year dioxide Carbon monoxide 11 mg/m³ 8 hour May March 2012 Fuel burning facility details Condition (O1) requires APLNG to submit fuel burning details to EHP within 3 months of grant of authority, for assessment to ensure emissions are not causing nuisance/environmental harm. Contaminant Limits Table 5 demonstrates the contaminant limits of each piece of equipment as instructed in condition (O4). QGC has supplied no data to determine compliance. Table 5: Fuel Burning Facility Release Points and Contaminant Limits (as per EA Condition O4) File C Page 30 of 185

31 Release Source Minimum release height (meters) Minimum velocity (m/sec) Contaminant release Maximum release limit¹ Talinga Gas Plant Screw NOx 6.6 Compressors Reciprocating NOx 0.39 Compressors Generators NOx 2.2 TEG Reboiler Burner NOx 0.7 Rockwood Compressor Station Screw NOx 0.13 Compressors Talinga Water Treatment Facility Power Station NOx 0.11 Talinga Field Well Head Pump Microprocessors NOx Note 1: The above NOx limits are applicable at all times except start-up, shut down and calibration of emission monitoring devices. The maximum start-up allowed is 30 mins. Type of fuel to be used Condition (O5): The only fuel to be burnt under normal operating conditions is methane. Monitoring of contaminant releases to the atmosphere Condition (O12): QGC must conduct and keep records of a monitoring program of contaminant release to the atmosphere at the release points, frequency and parameters in the table below. Table 6: Required air monitoring (as per EA Condition O12) Determination Required Release points Frequency Mass emission rate and concentration of oxides of nitrogen (NOx) in the flue gas at the specified oxygen reference level. Talinga WTF E S E S E S E S Talinga GP and flares E S E S E S E S Rockwood Compressor Station E S E S E S E S During commissioning of the plant, twice a year for the first two years of operation and then annually thereafter File C Page 31 of 185

32 March The older conditions regarding air were focused on dust suppression and particulate matter. The following condition is the only condition regarding fuel burning: Condition (K1): This environmental authority only permits the burning of hydrocarbon based fuels in fuel burning equipment EPP Air Limits Environmental Protection (Air) Policy 2008 Table 7: Air quality objectives from EPP Air Indicator Carbon monoxide Nitrogen dioxide Environmental value Health and wellbeing Health and wellbeing Health and biodiversity of ecosystems 4. Results and Discussion 4.1. QGC Kenya Air quality objectives Period Days μg/m³ at 0 degrees C (except where noted) ppm (volume/ volume) 11mg/m³ 9 8 hours 1 day each year hour 1 day each year year year No data for ground level concentrations is available for the Kenya Project Area. The EA conditions only require monitoring of fuel burning or combustion equipment burning more than 500kg/hr and no equipment of this size is on site. Therefore, no data has been provided to EHP. Stack (point source) monitoring Comment [M5]: Insert discussion re EPP Air Access deferred Table 8: Kenya Water Treatment Plant Power Generators for October File C Page 32 of 185

33 (Data sourced from QGC through the report Air monitoring (point source) by Veolia water November 2013) Release point Average stack gas velocity (m/sec) NOx as Nitrogen dioxide Maximum Mass concentration emission * (mg / dscm) rate* (kg/hour) Carbon monoxide Maximum Mass concentration emission * (mg / dscm) rate* (kg/hour) PG PG PG PG PG PG6* N/A PG *PG6 was not tested as it was offline during the sampling program. Table 9: Stack and emission data provided by QGC, which are based on stack monitoring programs performed at a number of sites. (Data sourced from QGC through the report Central Project Area Air Dispersion Modelling Study by SLR global environmental solutions December Facility Kenya Field Compressor Station Kenya Central Processing Plant Kenya Water Treatment Plant Power Generators Release point FCS 1 - FCS 8 CPP 1 - CPP 10 PG 1- PG 7 PB 1 - PB 3 BC 1 - BC 3 Unit Description Gas Screw Compressor Gas Reciprocating Engines Stack height (m) Stack diameter (m) Exit velocity (m/sec) CO emission rate (g/sec) NOx emissio n rate (g/sec) Gas Reciprocating Engines Auxiliary boiler Gas Reciprocating Engines Comment [DN6]: Not sure if data, may be modelled File C Page 33 of 185

34 Kenya WTP power generator stack test report (Table 8) The ECS stack testing report provides results or emissions testing carried out at the Kenya WTP gasfired power generators in October this year. One of the seven generators was not operating at the time, and so was not tested. The ECS report notes that the sampling planes for the six generators was non-ideal for flow rate determinations, however additional sampling traverses were undertaken in accordance with AS to compensate for the non-ideal location. Hence flow rate determinations can be regarded as reliable. Results for concentration (mg/m3) and mass (g/s) for NOx expressed as NO2 and for CO were all less than the relevant EA release limits. Measured efflux velocities were all greater than the EA minimum efflux velocity. The EA requires that measurements of efflux velocity, pollutant concentration and pollutant mass be made at maximum continuous rating (load) (MCR). In this case engine load was set at 90% to allow for the engine to be able to handle a sudden increase in extra load without causing a complete plant shutdown. (Executive summary, page 5). This would satisfy the MCR requirement. As such, the testing showed that the power generators were compliant with the EA release limits. Modelling studies (Table 9) Two modelling studies prepared to assess the potential impacts in air quality from the QGC Kenya area used a number of NOx emission factors for the WTP generators that were provided by QGC. These were compared against the measured NOX emissions. The measured emissions were all below the modelled factors. In addition, measured efflux velocities and temperatures were higher than those modelled. If the assessment was undertaken using the measured NOX emissions, efflux velocities, and temperatures, it is feasible the predicted ground-level concentrations would be lower than those modelled in the previous studies APLNG Talinga APLNG has alleged no air emission data exists for 2007 to Only the Reciprocating Compressors at the Talinga Gas Processing Facility burn more than 500kg/hr of fuel, due to this the majority of the following data is for this equipment and surrounding facility. Emissions monitoring There are two tables to represent air emission data for the Talinga Gas Processing Facility. Table 8 displays data for 2013, whilst Table 9 displays data for File C Page 34 of 185

35 Table 10: Monitored Talinga Gas Processing Plant air emission data 2013 (Data sourced from APLNG through the report Emissions Monitoring: Talinga Gas Processing Facility July 2013) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressors Screw Compressor Power Generator NOx mass emission rate (g/sec) NOx maximum concentration (mg/nm³) CO mass emission rates (g/sec) K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K NA - Breakdown K /06/ K /06/ K /06/ K /06/ G /06/ G /06/ G /06/ CO maximum concentration (mb/nm³) File C Page 35 of 185

36 Table 11: Monitored Talinga Gas Processing Facility air emission data 2012 (Data sourced from APLNG though the report Emissions Monitoring: Talinga Gas Processing Facility October 2012) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressor Screw Compressor NOx mass emission rate (g/sec) K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ NOx maximum concentration (mg/nm³) File C Page 36 of 185

37 Annual Environmental Monitoring Report March APLNG have submitted an annual environmental monitoring report for which provides a summary of the past 12 months monitoring data and results. Table 10 shows data for one of each compressor type. Table 12: Annual environmental monitoring air emission data comparison Facility Measure EA Condition Monitored Reciprocating Velocity (m/s) Compressor 5 Nitrogen Oxides (NO₂) (g/s) Screw Compressor Velocity (m/s) Nitrogen Oxides (NO₂) (g/s) APLNG have the following comment regarding the non-compliance of velocity: The monitoring indicated that the emission velocity on one of the engines was below the minimum licence limit. An investigation into the incident concluded that the engine emission specification originally supplied to the department as part of the proposed development application was incorrect. The emission velocity calculation failed to factor in temperature losses in the exhaust stack and the operating set up of the engine. Note: Only the last of each of the compressors has been included, Reciprocating Compressor 5 of 5, Screw Compressor 12 of 12. Also the EA limits above come from the March 2012 EA conditions. There has been no comparison to previous year s results. 5. External Response Throughout the report process there were updates from sources internally at other EHP units, from the Coal Seam Gas Compliance Unit, the GasFields Commission Queensland, DSITIA and Queensland Health Other EHP Units Access deferred 5.2. Department of Health (Queensland Health) File C Page 37 of 185

38 The response from Queensland Health 5.3. Coal Seam Gas Compliance Unit (CSGCU) The Coal Seam Gas Compliance Unit has been working with landholders that have complained about air quality and odour in the Wieambilla Estate for a number of years now. All of the government sampling that they are aware of has been done by EHP South (Toowoomba) and all that was available at the time was included in a report and was reviewed as part of the Tara Health report. They are also aware that QGC engaged a contractor to do a wide range of sampling for a number of properties on the Estate and these are included in the Health report. The CSGCU has not received any other information GasFields Commission Queensland The GasFields Commission has not undertaken any air monitoring or modelling or received any data on this. They have encouraged the companies and the relevant government agencies to undertake this work and provide the information to the relevant people Department of Science, Information Technology, Innovation and Arts (DSITIA) David Wainwright (Director Air Quality Sciences) has confirmed that DSITIA do not have any more monitoring data other than what was collected in the 2012 report, which has already been included in this report. 6. Site Inspections (To insert from known information / from Southern) 7. Review of Talinga Gas Processing Facility Ambient Air Monitoring Program Review APLNG implemented an ambient air quality monitoring program approximately 3km southeast of the Talinga Gas Processing Facility (GPF) in response to stack testing that showed some aspects of the operational emissions did not conform to the existing approval conditions; in particular the exhaust velocity was found to be below the minimum specified. (Page 1 ). The monitoring program was designed to measure ambient ground-level concentrations of nitric oxide (NO), nitrogen dioxide (NO₂), oxides of nitrogen (NOx), carbon monoxide (CO), and meteorological observations including wind speed and wind direction. Among other things, the purpose of the program was to understand File C Page 38 of 185

39 the potential environmental or health impacts of emission from the GPF. Only NO₂ and CO are scheduled in the EPP (Air) and EA limits. Validated data for the 7 month period between 20 June 2012 and 31 January 2013 was reviewed by Katestone Environmental (Katestone Environmental document reference D _Origin_Talinga_Ambient_Monitoring_Report_v1.10.docx). The review assessed ground-level concentrations against wind direction and showed that: - The highest NO₂ concentrations were associated with winds blowing from the direction of the GPF towards the monitoring point; NO₂ - Some elevated NO₂ concentrations were associated with a second GPF in the area (the report did not identify the location other than upwind of the monitoring point ); and - NO₂ concentrations were near background levels when the wind blew from all other directions (page 28, Figure 9). The review correctly concluded that measured concentrations for 1-hour and annual ground-level NO₂, and for 8-hour CO were below the respective EPP (Air) goals. Katestone Environmental also undertook new air quality dispersion modelling using stack testing emissions data provided by APLNG. 1-hour concentrations of NO₂ were predicted to exceed the EPP (Air) goal up 15km to the south-southwest of the GFC and monitoring station (Page 13, Page 34, Figure 15; and Page 36, Figure 17). No sensitive receptors were identified within the exceedance zone (which suggests no non-compliances). Modelled pollutant concentrations were compared with measured concentrations. Comparisons showed some differences, however on balance, the differences can be regarded to be within the sensitivity bounds of the modelling system. Note that (a) the monitoring station is outside the modelled exceedance zones, and (b), the extent to which the non-compliant exhaust velocity(ies) contributed to the modelled exceedances was not investigated. 8. Conclusion The Queensland Health report found no clear link between the health complaints by some residents in the Tara region and impacts of the local CSG industry on air, water or soil. The DSITIA report on VOCs in the Wieambilla Estate detected VOCs in ambient air; however the levels detected were below relevant guidelines and criteria used to assess the potential health effects from VOC s. Access deferred Released by EHP File C Page 39 of 185

40 Of the information available there are only individual results which do not represent the Wieambilla Estate. There is insufficient data to be able to calibrate and validate an appropriate air shed model for the Tara region. For this to occur there needs to be more data, both point source at the stack and ground level concentrations to cover all equipment capable of significant air emissions. However, the data did reveal some information for the Talinga Project Area as APLNG undertook an ambient air monitoring program monitoring CO, NO, NO₂ and NOx which demonstrated that concentrations of NO₂ and CO were below EPP (Air) objectives. QGC have also demonstrated that the Kenya Water Treatment Plant is complying with EA limits. EHP does not have access to information on other contaminants listed in the Queensland Health report. However, as mentioned it is unlikely that there would be other contaminants of concern based on the composition of the fuel gas (CSG). 9. Recommendations 1. EHP will undertake compliance of the Talinga Gas Field and Kenya Gas Field through the Level C inspections to determine the level of non-compliance with regards to the conditions relating to air emissions in the EAs. 2. EHP will undertake a review of current EA conditions to identify improvements to ensure EHP is able to determine industry compliance with EPP (Air). It is suggested that the focus on equipment capable of burning more than 500kg/hr of fuel be removed/adjusted to ensure all infrastructure emitting contaminants that have the potential for environmental harm are accounted for. 3. EHP will monitor the current situation until outcomes from the Level C inspections and EA condition review informs required actions. 4. This report and reviewing process should be audited within 2 years to ensure that the issues identified in the report have been rectified File C Page 40 of 185

41 Attachment A: Air emissions gap analysis indicative locations of fuel burning equipment surrounding the Wieambilla Estate complainants File C Page 41 of 185

42 49-Sch File C Page 42 of 185

43 Queensland Health Tara Air Emission Data Collation Report drafted by the Energy Assessments Unit Department of Environment and Heritage Protection File C Page 43 of 185

44 Contents Comment [DN1]: Update page numbers as required. 1. Introduction Methodology Contaminants Action Plan Objectives 4 3. Review of Existing Reports, Monitoring Conditions and Limitations Description of Air Monitoring EA Conditions QGC Kenya APLNG Talinga Results and Discussion QGC Kenya APLNG Talinga External response Other EHP Units Department of Health (Queensland Health) Coal Seam Gas Compliance Unit GasFields Commission Queensland Department of Science, Information Technology, Innovation and Arts Site Inspections Review of Talinga Gas Processing Facility Ambient Air Monitoring Program Review.? 8. Conclusion.? 9. Recommendations..? Attachment A? File C Page 44 of 185

45 Queensland Health Tara Air Emission Data Collation 1. Introduction Residents of the Wieambilla Estate have raised concerns about the impacts of air emissions from the local coal seam gas fields on their health and well-being and that of the surrounding community. These concerns have primarily focused on odours and the potential health implications from those odours. The Wieambilla Estate is located half-way between Chinchilla to the north and Tara to the south of the estate. Refer to Attachment A for a map showing the Wieambilla Estate complainants in relation to the indicative locations of fuel burning equipment on the Talinga Project Area and Kenya Project Area. The location of all fuel burning equipment is not available to Department of Environment and Heritage Protection (EHP), as such only compression stations and gas plants have been identified in Attachment A. In response to residents concerns raised about the health impact of odour emissions from the local coal seam gas fields on surrounding residential areas, the Department of Health undertook an investigation which resulted in the Department of Health report Coal seam gas in the Tara region: Summary risk assessment of health complaints and environmental monitoring data, March Several recommendations were made in the report and an action plan in response to the recommendations was drafted. One of these recommendations was for EHP to undertake a desktop review of existing air monitoring undertaken by EHP and industry to identify any gaps in available data. This report presents the results of the Action Plan and resulting review. The Wieambilla Estate is surrounded by petroleum tenure both in exploration/appraisal phase or production phase. The two primary production gas fields in the vicinity of the Wieambilla Estate are Australia Pacific LNG s (APLNG) Talinga Project Area (Environmental Authority (EA) EPPG ) and QGC s Kenya Project Area (EA EPPG ). The other petroleum tenures surrounding these project areas have not been included in this report as they are primarily exploration or in the initial development phase. Both APLNG and QGC have fuel burning equipment that has been in operation for at least five years. APLNG s Talinga has been operating since February 2004 and QGC s Kenya has been operating since July Methodology A desktop review was undertaken by the Energy Assessments Unit (EAU) to gather information and data regarding air emissions in the Tara region, coincidentally APLNG s Talinga project area and QGC s Kenya project area. Firstly an information request was sent out to both companies over the course of The southern region (Toowoomba), Department of Science, Information Technology, Innovation and the Arts (DSITIA), and Queensland Health were contacted for any relevant information. An air specialist from within EHP was also included in the review process to analyse technical data and provide advice on air emissions. The report has been broken up into EA conditions (all amendments), data, discussion, other reports, conclusion and recommendations File C Page 45 of 185

46 Timeline of Energy Assessment process: 18 December 2012 EHP issued letters to QGC (for the Kenya Project Area) and APLNG (for the Talinga Project Area) requesting all documents, information and data that is required to be developed in the Environmental Authority conditions, to be provide to EHP for a comprehensive desktop (Level C) audit. This included a request for air monitoring data to be submitted to EHP. 8 February 2013 and 11 February 2013 Received information from APLNG and QGC respectively. 24 April 2013 EHP issued a second request for information to QGC and APLNG as all the required information had not been provided. 7 May 2013 APLNG provided additional information in response to EHP letter. 17 May 2013 QGC provided additional information in response to EHP letter. 5 June 2013 Energy Assessment, EHP was tasked with collating air data, which had been received by EHP as part of the EIS process and EA applications for the QGC Kenya Project Area and APLNG Talinga Project Area. 9 August 2013 EHP requested air modelling and monitoring from QGC, originally requested as part of the desktop audit on 18 December August 2013 QGC responded to letter and provided reasons why air modelling and monitoring could not be provided. No air modelling or monitoring was provided to EHP. 30 August 2013 Energy Assessment finalised its report on its findings, titled Queensland Health Tara Air Emissions Data Collation and was sent to Mark Venz (director of Energy Assessment, EHP) 5 February Energy Assessment was requested to revise report to include the following data provided to EHP since 30 August 2013: o APLNG Third Party Audit, provided 24 October 2013; o QGC monitoring data for the Kenya Water Treatment Plant, provided 28 November 2013 ; 12 February 2014 Energy Assessment, EHP forwarded revised report to xxxxxx for review and comment Contaminants The chosen contaminants for this report are Nitrogen dioxide(no₂) and Carbon monoxide (CO). These contaminants are the major by-products of burning coal seam gas (CSG) methane. Thus the NO₂ and CO limits in EPP Air have been chosen for the EA conditions to regulate and monitor contaminant releases. The Coordinator General s report on the EIS has only highlighted monitoring of oxides of Nitrogen which is the only gas in volumes likely to cause significant health effects. The Queensland Health report lists other contaminants which are primarily in context to odour issues. Due to the composition of the fuel gas (CSG) it is unlikely that these other contaminants would be of concern to human health at any concentrations generated by the combustion of the fuel gas. Concentrations of these other contaminants are likely to be very low therefore EHP does not monitor for them File C Page 46 of 185

47 Fugitive emissions are addressed in the DSITIA report and in the EPP Air limits, however the EA does not monitor for these as they are unlikely to occur in high concentrations. The APLNG Talinga EA has measures to reduce fugitive emissions with conditions to ensure that all reasonable and practical measures are taken in the design and operation of the plant to minimise fugitive VOC emissions (Condition F14) Action Plan Objectives The Action Plan was created after a meeting between various EHP and government agencies, Queensland Health and the GasFields Comission in June The plan comprises of four main objectives; the first two allocated to EAU, the last two allocated to Southern region. The action plan is listed as follows: 1. Collate and review existing air monitoring and modelling data available from government agencies and industry sources to identify if gaps exist in the available data. 2. Evaluate need for a plan to address any gaps identified and consider need for additional strategic monitoring of ambient air quality or air modelling. 3. Should this evaluation recommend additional air monitoring consider funding options, including industry funded solutions, to implement the plan. 4. Provide the air monitoring and modelling results to Department of Health for undertaking he health risk assessments. This report represents as the response to the first two objectives of the action plan. 3. Review of Existing Reports, Monitoring Conditions and Limitations The Department of Science, Information Technology, Innovation and the Arts (DSITIA) commenced a community sampling program for volatile organic compounds (VOCs) in the Wieambilla Estate in response to community concerns about the impacts of air emissions from the local coal seam gas fields on the health and well-being of the surrounding community. The report, Wieambilla Estates Odour Investigation Results, July December 2012 outlines the results of the community sampling program conducted between July and December 2012 and is included in Attachment B. It indicated that a number of volatile organic compounds (VOCs) were detected in the ambient air at levels generally well below relevant guidelines and criteria used to assess VOC concentrations. Monitoring data for this review was collected from the APLNG Talinga EA and the QGC Kenya EA. The relevant EA conditions are described below in Section File C Page 47 of 185

48 3.1. Description of Air Monitoring EA Conditions The following is a compliance assessment of EA conditions in relation to air emissions. The EA conditions proceed from the most recently dated to the oldest available QGC Kenya July 2011 present Fuel burning and combustion equipment register It is a requirement under QGC Kenya EA condition (G3) that a fuel burning register of equipment capable of burning more than 500kg/hr is maintained. There is no individual fuel burning equipment which burns more than 500kg/hr of fuel in the Kenya Project Area and as such no equipment has been included in the register. Ground level concentrations Table 1: Maximum Ground Level Concentration Criteria outlines the maximum concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located more than 5km outside of a hub or populated area as specified in EA condition (G7) for the Kenya Project Area. Table 1: Maximum Ground Level Concentration Criteria (as per EA Condition G7) Contaminant Concentration at Units Averaging time 0⁰ Celsius NOx as Nitrogen 250 μg/m³ 1 hour dioxide NOx as Nitrogen 33 μg/m³ 1 year dioxide Carbon monoxide 11 mg/m³ 8 hour The following condition (G10) applies to any fuel burning and combustion equipment located inside 5km of a hub and/or populated area. Table 2 documents the only equipment allowed to burn more than 500kg/hr of fuel and their limits. Note: Although this condition existed in July 2011, the table was not completed and included in the EA until July 2012, rendering the condition unenforceable until that date File C Page 48 of 185

49 Table 2: Releases of contaminants to air (as per EA Condition G10) Resource Authority Field Facility Release point PL180 Kenya Kenya Field Compressor Station PL180 Kenya Kenya Central Processing Plant PL228 Kenya Kenya Relocatable Water Treatment Plant (RWTP) PL228 Kenya Kenya RWTP PL228 Kenya Kenya Water Treatment Plant Power Generators FCS 1 - FCS 8 CPP 1 - CPP 10 DGA 1 DGB 1 DGB 2 PG 1- PG 7 Unit Description Gas Screw Compressor Gas Reciprocating Engines Diesel Generators Diesel Generators Gas Reciprocating Engines Min Stack Minimum NOx as Nitrogen dioxide Carbon monoxide Release Height (m) diameter (m) efflux velocity (m/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) PL228 Kenya PB 1 - Auxiliary PB 3 boiler PL228 Kenya BC 1 - BC 3 Gas Reciprocating Engines *Minimum efflux velocity, maximum concentration and maximum mass emission are to be measured at the Maximum Continuous Rating File C Page 49 of 185

50 Point source air monitoring Point source air monitoring is required for both NOx as nitrogen dioxide and carbon monoxide at Kenya (Condition G15). It requires monitoring 3 months after commissioning any fuel equipment and biennially thereafter. May 2009 March 2010 Contaminant release points Condition (O1): The release of contaminants to the atmosphere from a point source can only occur at the release points specified below. Table 3: Compressor Station Release Points (as per EA Condition O1) Release Source Minimum release height (meters) Kenya Field Compression Station Natural Gas Engines Kenya 1 to Kenya 4 Natural Gas Engines Kenya 5 to Kenya 8 Start and blow down vents Minimum velocity (m/sec) Contaminant release 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr 3m Approx 30m³ coal seam gas (>97% CH4, 2.6% N, 0.1% CO2, <0.15% C2H6) Codie Field Compression Station Natural Gas Engines Codie 1 to Codie 8 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr Kenya Processing Plant Natural Gas Engines Kenya Sales 1 to Kenya Sales 10 Type of fuel to be used 3.5 meters above ground level 42 m/s At 100% load and speed: NOx ton/year CO ton/year Hydrocarbons 9.15 ton/year Condition (O3): The only type of fuel to be burnt in the compressors, under normal operating conditions, is coal seam gas. Monitoring of contaminant releases Condition (O4): Only when the administering authority requests contaminant monitoring. July 2007 November File C Page 50 of 185

51 The older conditions regarding air were focused on dust suppression and particulate matter. The following condition is the only condition regarding fuel burning: Condition (K1): This environmental authority only permits the burning of hydrocarbon based fuels in fuel burning equipment APLNG Talinga September 2012 present Fuel burning and combustion equipment register It is a requirement under APLNG Talinga EA condition (F7) that a fuel burning register of equipment capable of burning more than 500kg/hr is maintained. APLNG provided a fuel burning and combustion equipment register for all fuel burning equipment located on the Talinga Project Area, however only the Reciprocating Compressors at the Talinga Gas Processing Facility burn more than 500kg/hr of fuel. Ground level concentrations Table 4 Maximum Ground Level Concentration Criteria outlines the maximum concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located outside of a hub or populated area as specified in EA condition (F4) for the Talinga Project Area. Table 4: Maximum Ground Level Concentration Criteria (as per EA Condition F4) Contaminant Concentration at Units Averaging time 0⁰ Celsius NOx as Nitrogen 250 μg/m³ 1 hour dioxide NOx as Nitrogen 33 μg/m³ 1 year dioxide Carbon monoxide 11 mg/m³ 8 hour May March 2012 Fuel burning facility details Condition (O1) requires APLNG to submit fuel burning details to EHP within 3 months of grant of authority, for assessment to ensure emissions are not causing nuisance/environmental harm. Contaminant Limits Table 5 demonstrates the contaminant limits of each piece of equipment as instructed in condition (O4). QGC has supplied no data to determine compliance File C Page 51 of 185

52 Table 5: Fuel Burning Facility Release Points and Contaminant Limits (as per EA Condition O4) Release Source Minimum release height (meters) Minimum velocity (m/sec) Contaminant release Maximum release limit¹ Talinga Gas Plant Screw NOx 6.6 Compressors Reciprocating NOx 0.39 Compressors Generators NOx 2.2 TEG Reboiler Burner NOx 0.7 Rockwood Compressor Station Screw NOx 0.13 Compressors Talinga Water Treatment Facility Power Station NOx 0.11 Talinga Field Well Head Pump Microprocessors NOx Note 1: The above NOx limits are applicable at all times except start-up, shut down and calibration of emission monitoring devices. The maximum start-up allowed is 30 mins. Type of fuel to be used Condition (O5): The only fuel to be burnt under normal operating conditions is methane. Monitoring of contaminant releases to the atmosphere Condition (O12): QGC must conduct and keep records of a monitoring program of contaminant release to the atmosphere at the release points, frequency and parameters in the table below. Table 6: Required air monitoring (as per EA Condition O12) Determination Required Release points Frequency Mass emission rate and concentration of oxides of nitrogen (NOx) in the flue gas at the specified oxygen reference level. Talinga WTF E S E S E S E S Talinga GP and flares E S E S E S E S Rockwood Compressor Station E S E S E S E S During commissioning of the plant, twice a year for the first two years of operation and then annually thereafter File C Page 52 of 185

53 March The older conditions regarding air were focused on dust suppression and particulate matter. The following condition is the only condition regarding fuel burning: Condition (K1): This environmental authority only permits the burning of hydrocarbon based fuels in fuel burning equipment EPP Air Limits Environmental Protection (Air) Policy 2008 Table 7: Air quality objectives from EPP Air Indicator Carbon monoxide Nitrogen dioxide Environmental value Health and wellbeing Health and wellbeing Health and biodiversity of ecosystems 4. Results and Discussion 4.1. QGC Kenya Air quality objectives Period Days μg/m³ at 0 degrees C (except where noted) ppm (volume/ volume) 11mg/m³ 9 8 hours 1 day each year hour 1 day each year year year No data for ground level concentrations is available for the Kenya Project Area. The EA conditions only require monitoring of fuel burning or combustion equipment burning more than 500kg/hr and no equipment of this size is on site. Therefore, no data has been provided to EHP. Stack (point source) monitoring Access deferred Table 8: Kenya Water Treatment Plant Power Generators for October File C Page 53 of 185

54 (Data sourced from QGC through the report Air monitoring (point source) by Veolia water November 2013) Release point Average stack gas velocity (m/sec) NOx as Nitrogen dioxide Maximum Mass concentration emission * (mg / dscm) rate* (kg/hour) Carbon monoxide Maximum Mass concentration emission * (mg / dscm) rate* (kg/hour) PG PG PG PG PG PG6* N/A PG *PG6 was not tested as it was offline during the sampling program. Table 9: Stack and emission data provided by QGC, which are based on stack monitoring programs performed at a number of sites. (Data sourced from QGC through the report Central Project Area Air Dispersion Modelling Study by SLR global environmental solutions December Facility Kenya Field Compressor Station Kenya Central Processing Plant Kenya Water Treatment Plant Power Generators Release point FCS 1 - FCS 8 CPP 1 - CPP 10 PG 1- PG 7 PB 1 - PB 3 BC 1 - BC 3 Unit Description Gas Screw Compressor Gas Reciprocating Engines Stack height (m) Stack diameter (m) Exit velocity (m/sec) CO emission rate (g/sec) NOx emissio n rate (g/sec) Gas Reciprocating Engines Auxiliary boiler Gas Reciprocating Engines Comment [DN2]: Not sure if data, may be modelled File C Page 54 of 185

55 Kenya WTP power generator stack test report (Table 8) The ECS stack testing report provides results or emissions testing carried out at the Kenya WTP gasfired power generators in October this year. One of the seven generators was not operating at the time, and so was not tested. The ECS report notes that the sampling planes for the six generators was non-ideal for flow rate determinations, however additional sampling traverses were undertaken in accordance with AS to compensate for the non-ideal location. Hence flow rate determinations can be regarded as reliable. Results for concentration (mg/m3) and mass (g/s) for NOx expressed as NO2 and for CO were all less than the relevant EA release limits. Measured efflux velocities were all greater than the EA minimum efflux velocity. The EA requires that measurements of efflux velocity, pollutant concentration and pollutant mass be made at maximum continuous rating (load) (MCR). In this case engine load was set at 90% to allow for the engine to be able to handle a sudden increase in extra load without causing a complete plant shutdown. (Executive summary, page 5). This would satisfy the MCR requirement. As such, the testing showed that the power generators were compliant with the EA release limits. Modelling studies (Table 9) Two modelling studies prepared to assess the potential impacts in air quality from the QGC Kenya area used a number of NOx emission factors for the WTP generators that were provided by QGC. These were compared against the measured NOX emissions. The measured emissions were all below the modelled factors. In addition, measured efflux velocities and temperatures were higher than those modelled. If the assessment was undertaken using the measured NOX emissions, efflux velocities, and temperatures, it is feasible the predicted ground-level concentrations would be lower than those modelled in the previous studies APLNG Talinga APLNG has alleged no air emission data exists for 2007 to Only the Reciprocating Compressors at the Talinga Gas Processing Facility burn more than 500kg/hr of fuel, due to this the majority of the following data is for this equipment and surrounding facility. Emissions monitoring There are two tables to represent air emission data for the Talinga Gas Processing Facility. Table 8 displays data for 2013, whilst Table 9 displays data for File C Page 55 of 185

56 Table 10: Monitored Talinga Gas Processing Plant air emission data 2013 (Data sourced from APLNG through the report Emissions Monitoring: Talinga Gas Processing Facility July 2013) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressors Screw Compressor Power Generator NOx mass emission rate (g/sec) NOx maximum concentration (mg/nm³) CO mass emission rates (g/sec) K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K NA - Breakdown K /06/ K /06/ K /06/ K /06/ G /06/ G /06/ G /06/ CO maximum concentration (mb/nm³) File C Page 56 of 185

57 Table 11: Monitored Talinga Gas Processing Facility air emission data 2012 (Data sourced from APLNG though the report Emissions Monitoring: Talinga Gas Processing Facility October 2012) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressor Screw Compressor NOx mass emission rate (g/sec) K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ NOx maximum concentration (mg/nm³) File C Page 57 of 185

58 Annual Environmental Monitoring Report March APLNG have submitted an annual environmental monitoring report for which provides a summary of the past 12 months monitoring data and results. Table 10 shows data for one of each compressor type. Table 12: Annual environmental monitoring air emission data comparison Facility Measure EA Condition Monitored Reciprocating Velocity (m/s) Compressor 5 Nitrogen Oxides (NO₂) (g/s) Screw Compressor Velocity (m/s) Nitrogen Oxides (NO₂) (g/s) APLNG have the following comment regarding the non-compliance of velocity: The monitoring indicated that the emission velocity on one of the engines was below the minimum licence limit. An investigation into the incident concluded that the engine emission specification originally supplied to the department as part of the proposed development application was incorrect. The emission velocity calculation failed to factor in temperature losses in the exhaust stack and the operating set up of the engine. Note: Only the last of each of the compressors has been included, Reciprocating Compressor 5 of 5, Screw Compressor 12 of 12. Also the EA limits above come from the March 2012 EA conditions. There has been no comparison to previous year s results. 5. External Response Throughout the report process there were updates from sources internally at other EHP units, from the Coal Seam Gas Compliance Unit, the GasFields Commission Queensland and Queensland Health Other EHP Units Access deferred 5.2. Department of Health (Queensland Health) The response from Queensland Health File C Page 58 of 185

59 5.3. Coal Seam Gas Compliance Unit (CSGCU) The Coal Seam Gas Compliance Unit has been working with landholders that have complained about air quality and odour in the Wieambilla Estate for a number of years now. All of the government sampling that they are aware of has been done by EHP South (Toowoomba) and all that was available at the time was included in a report and was reviewed as part of the Tara Health report. They are also aware that QGC engaged a contractor to do a wide range of sampling for a number of properties on the Estate and these are included in the Health report. The CSGCU has not received any other information GasFields Commission Queensland The GasFields Commission has not undertaken any air monitoring or modelling or received any data on this. They have encouraged the companies and the relevant government agencies to undertake this work and provide the information to the relevant people Department of Science, Information Technology, Innovation and Arts (DSITIA) David Wainwright (Director Air Quality Sciences) has confirmed that DSITIA do not have any more monitoring data other than what was collected in the 2012 report, which has already been included in this report. 6. Site Inspections (To insert from known information / from Southern) 7. Review of Talinga Gas Processing Facility Ambient Air Monitoring Program Review APLNG implemented an ambient air quality monitoring program approximately 3km southeast of the Talinga Gas Processing Facility (GPF) in response to stack testing that showed some aspects of the operational emissions did not conform to the existing approval conditions; in particular the exhaust velocity was found to be below the minimum specified. (Page 1 ). The monitoring program was designed to measure ambient ground-level concentrations of nitric oxide (NO), nitrogen dioxide (NO₂), oxides of nitrogen (NOx), carbon monoxide (CO), and meteorological observations including wind speed and wind direction. Among other things, the purpose of the program was to understand the potential environmental or health impacts of emission from the GPF. Only NO₂ and CO are scheduled in the EPP (Air) and EA limits File C Page 59 of 185

60 Validated data for the 7 month period between 20 June 2012 and 31 January 2013 was reviewed by Katestone Environmental (Katestone Environmental document reference D _Origin_Talinga_Ambient_Monitoring_Report_v1.10.docx). The review assessed ground-level concentrations against wind direction and showed that: - The highest NO₂ concentrations were associated with winds blowing from the direction of the GPF towards the monitoring point; NO₂ - Some elevated NO₂ concentrations were associated with a second GPF in the area (the report did not identify the location other than upwind of the monitoring point ); and - NO₂ concentrations were near background levels when the wind blew from all other directions (page 28, Figure 9). The review correctly concluded that measured concentrations for 1-hour and annual ground-level NO₂, and for 8-hour CO were below the respective EPP (Air) goals. Katestone Environmental also undertook new air quality dispersion modelling using stack testing emissions data provided by APLNG. 1-hour concentrations of NO₂ were predicted to exceed the EPP (Air) goal up 15km to the south-southwest of the GFC and monitoring station (Page 13, Page 34, Figure 15; and Page 36, Figure 17). No sensitive receptors were identified within the exceedance zone (which suggests no non-compliances). Modelled pollutant concentrations were compared with measured concentrations. Comparisons showed some differences, however on balance, the differences can be regarded to be within the sensitivity bounds of the modelling system. Note that (a) the monitoring station is outside the modelled exceedance zones, and (b), the extent to which the non-compliant exhaust velocity(ies) contributed to the modelled exceedances was not investigated. 8. Conclusion The Queensland Health report found no clear link between the health complaints by some residents in the Tara region and impacts of the local CSG industry on air, water or soil. The DSITIA report on VOCs in the Wieambilla Estate detected VOCs in ambient air; however the levels detected were below relevant guidelines and criteria used to assess the potential health effects from VOC s. Access deferred Released by EHP Of the information available there are only individual results which do not represent the Wieambilla Estate. There is insufficient data to be able to calibrate and validate an appropriate air shed model for the Tara region. For this to occur there needs to be more data, both point source at the stack and ground level concentrations to cover all equipment capable of significant air emissions File C Page 60 of 185

61 However, the data did reveal some information for the Talinga Project Area as APLNG undertook an ambient air monitoring program monitoring CO, NO, NO₂ and NOx which demonstrated that concentrations of NO₂ and CO were below EPP (Air) objectives. QGC have also demonstrated that the Kenya Water Treatment Plant is complying with EA limits. EHP does not have access to information on other contaminants listed in the Queensland Health report. However, as mentioned it is unlikely that there would be other contaminants of concern based on the composition of the fuel gas (CSG). 9. Recommendations 1. EHP will undertake compliance of the Talinga Gas Field and Kenya Gas Field through the Level C inspections to determine the level of non-compliance with regards to the conditions relating to air emissions in the EAs. 2. EHP will undertake a review of current EA conditions to identify improvements to ensure EHP is able to determine industry compliance with EPP (Air). It is suggested that the focus on equipment capable of burning more than 500kg/hr of fuel be removed/adjusted to ensure all infrastructure emitting contaminants that have the potential for environmental harm are accounted for. 3. EHP will monitor the current situation until outcomes from the Level C inspections and EA condition review informs required actions This report and reviewing process should be audited within 2 years to ensure that the issues identified in the report have been rectified File C Page 61 of 185

62 Attachment A: Air emissions gap analysis indicative locations of fuel burning equipment surrounding the Wieambilla Estate complainants File C Page 62 of 185

63 49-Sch File C Page 63 of 185

64 Queensland Health Tara Air Emission Data Collation Report drafted by the Energy Assessments Unit Department of Environment and Heritage Protection File C Page 64 of 185

65 Contents Comment [DN1]: Update page numbers as required. 1. Introduction Methodology Contaminants Action Plan Objectives 4 3. Review of Existing Reports, Monitoring Conditions and Limitations Description of Air Monitoring EA Conditions QGC Kenya APLNG Talinga Results and Discussion QGC Kenya APLNG Talinga External response Other EHP Units Department of Health (Queensland Health) Coal Seam Gas Compliance Unit GasFields Commission Queensland Department of Science, Information Technology, Innovation and Arts Site Inspections Review of Talinga Gas Processing Facility Ambient Air Monitoring Program Review.? 8. Conclusion.? 9. Recommendations..? Attachment A? File C Page 65 of 185

66 Queensland Health Tara Air Emission Data Collation 1. Introduction Residents of the Wieambilla Estate have raised concerns about the impacts of air emissions from the local coal seam gas fields on their health and well-being and that of the surrounding community. These concerns have primarily focused on odours and the potential health implications from those odours. The Wieambilla Estate is located half-way between Chinchilla to the north and Tara to the south of the estate. Refer to Attachment A for a map showing the Wieambilla Estate complainants in relation to the indicative locations of fuel burning equipment on the Talinga Project Area and Kenya Project Area. The location of all fuel burning equipment is not available to Department of Environment and Heritage Protection (EHP), as such only compression stations and gas plants have been identified in Attachment A. The Wieambilla Estate is surrounded by petroleum tenure both in exploration/appraisal phase or production phase. The two primary production gas fields in the vicinity of the Wieambilla Estate are Australia Pacific LNG s (APLNG) Talinga Project Area (Environmental Authority (EA) EPPG ) and QGC s Kenya Project Area (EA EPPG ). The other petroleum tenures surrounding these project areas have not been included in this report as they are primarily exploration or in the initial development phase. Both APLNG and QGC have fuel burning equipment that has been in operation for at least five years. APLNG s Talinga has been operating since February 2004 and QGC s Kenya has been operating since July In response to residents concerns raised about the health impact of odour emissions from the local coal seam gas fields on surrounding residential areas, the Department of Health undertook an investigation which resulted in the Department of Health report Coal seam gas in the Tara region: Summary risk assessment of health complaints and environmental monitoring data, March Several recommendations were made in the report and an action plan in response to the recommendations was drafted. One of these recommendations was for EHP to undertake a desktop review of existing air monitoring undertaken by EHP and industry to identify any gaps in available data. This report presents the results of the Action Plan and resulting review. 2. Methodology A desktop review was undertaken by the Energy Assessments Unit (EAU) to gather information and data regarding air emissions in the Tara region, coincidentally APLNG s Talinga project area and QGC s Kenya project area. Firstly an information request was sent out to both companies over the course of The southern region (Toowoomba), Department of Science, Information Technology, Innovation and the Arts (DSITIA), and Queensland Health were contacted for any relevant information. An air specialist from within EHP was also included in the review process to analyse technical data and provide advice on air emissions. Comment [M2]: Write in full for the first time The report has been broken up into EA conditions (all amendments), data, discussion, other reports, conclusion and recommendations File C Page 66 of 185

67 Timeline of Energy Assessment process: 18 December 2012 EHP issued letters to QGC (for the Kenya Project Area) and APLNG (for the Talinga Project Area) requesting all documents, information and data that is required to be developed in the Environmental Authority conditions, to be provide to EHP for a comprehensive desktop (Level C) audit. This included a request for air monitoring data to be submitted to EHP. 8 February 2013 and 11 February 2013 Received information from APLNG and QGC respectively. 24 April 2013 EHP issued a second request for information to QGC and APLNG as all the required information had not been provided. 7 May 2013 APLNG provided additional information in response to EHP letter. 17 May 2013 QGC provided additional information in response to EHP letter. 5 June 2013 Energy Assessment, EHP was tasked with collating air data, which had been received by EHP as part of the EIS process and EA applications for the QGC Kenya Project Area and APLNG Talinga Project Area. 9 August 2013 EHP requested air modelling and monitoring from QGC, originally requested as part of the desktop audit on 18 December August 2013 QGC responded to letter and provided reasons why air modelling and monitoring could not be provided. No air modelling or monitoring was provided to EHP. 30 August 2013 Energy Assessment finalised its report on its findings, titled Queensland Health Tara Air Emissions Data Collation. 5 February Energy Assessment was requested to finalise report which included the following data provided to EHP since 30 August 2013: o APLNG Third Party Audit, provided 24 October 2013; o QGC monitoring data for the Kenya Water Treatment Plant, provided 28 November 2013; 12 February 2014 Energy Assessment, EHP forwarded revised report Contaminants The chosen contaminants for this report are Nitrogen dioxide(no₂) and Carbon monoxide (CO). These contaminants are the major by-products of burning coal seam gas (CSG) methane. The Coordinator General s report on the EIS highlighted monitoring of oxides of Nitrogen. Thus the NO₂ and CO limits in EPP Air have been chosen for the EA conditions to regulate and monitor contaminant releases. The Queensland Health report lists other contaminants which are primarily in context to odour issues. Due to the composition of the fuel gas (CSG) it is unlikely that these other contaminants would be of concern to human health at any concentrations generated by the combustion of the fuel gas. Concentrations of these other contaminants are likely to be very low. Comment [M3]: Which EIS? Reference this Comment [M4]: Write in full for the 1 st time Fugitive emissions are addressed in the DSITIA report and in the EPP Air limits, however the EA does not monitor for these as they are unlikely to occur in high concentrations. The APLNG Talinga EA has measures to reduce fugitive emissions with conditions to ensure that all reasonable and practical measures are taken in the design and operation of the plant to minimise fugitive VOC emissions (Condition F14) File C Page 67 of 185

68 2.2. Action Plan Objectives The Action Plan was created after a meeting between various EHP and government agencies, Queensland Health and the GasFields Commission in June The plan comprises of four main objectives; the first two allocated to EAU, the last two allocated to Southern region. The action plan is listed as follows: 1. Collate and review existing air monitoring and modelling data available from government agencies and industry sources to identify if gaps exist in the available data. 2. Evaluate need for a plan to address any gaps identified and consider need for additional strategic monitoring of ambient air quality or air modelling. 3. Should this evaluation recommend additional air monitoring consider funding options, including industry funded solutions, to implement the plan. 4. Provide the air monitoring and modelling results to Department of Health for undertaking he health risk assessments. This report represents as the response to the first two objectives of the action plan and provides recommendations in relation to the third objective. 3. Review of Existing Reports, Monitoring Conditions and Limitations The Department of Science, Information Technology, Innovation and the Arts (DSITIA) commenced a community sampling program for volatile organic compounds (VOCs) in the Wieambilla Estate in response to community concerns about the impacts of air emissions from the local coal seam gas fields on the health and well-being of the surrounding community. The report, Wieambilla Estates Odour Investigation Results, July December 2012 outlines the results of the community sampling program conducted between July and December 2012 and is included in Attachment B. It indicated that a number of volatile organic compounds (VOCs) were detected in the ambient air at levels generally well below relevant guidelines and criteria used to assess VOC concentrations. Monitoring data for this review was collected from the APLNG Talinga EA and the QGC Kenya EA. The relevant EA conditions are described below in Section Description of Air Monitoring EA Conditions The following is a compliance assessment of EA conditions in relation to air emissions. The EA conditions proceed from the most recently dated to the oldest available QGC Kenya July 2011 present File C Page 68 of 185

69 Fuel burning and combustion equipment register It is a requirement under QGC Kenya EA condition (G3) that a fuel burning register of equipment capable of burning more than 500kg/hr is maintained. There is no individual fuel burning equipment which burns more than 500kg/hr of fuel in the Kenya Project Area and as such no equipment has been included in the register. Ground level concentrations Table 1: Maximum Ground Level Concentration Criteria outlines the maximum concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located more than 5km outside of a hub or populated area as specified in EA condition (G7) for the Kenya Project Area. Table 1: Maximum Ground Level Concentration Criteria (as per EA Condition G7) Contaminant Concentration at Units Averaging time 0⁰ Celsius NOx as Nitrogen 250 μg/m³ 1 hour dioxide NOx as Nitrogen 33 μg/m³ 1 year dioxide Carbon monoxide 11 mg/m³ 8 hour The following condition (G10) applies to any fuel burning and combustion equipment located inside 5km of a hub and/or populated area. Table 2 documents the only equipment allowed to burn more than 500kg/hr of fuel and their limits. Note: Although this condition existed in July 2011, the table was not completed and included in the EA until July 2012, rendering the condition unenforceable until that date File C Page 69 of 185

70 Table 2: Releases of contaminants to air (as per EA Condition G10) Resource Authority Field Facility Release point PL180 Kenya Kenya Field Compressor Station PL180 Kenya Kenya Central Processing Plant PL228 Kenya Kenya Relocatable Water Treatment Plant (RWTP) PL228 Kenya Kenya RWTP PL228 Kenya Kenya Water Treatment Plant Power Generators FCS 1 - FCS 8 CPP 1 - CPP 10 DGA 1 DGB 1 DGB 2 PG 1- PG 7 Unit Description Gas Screw Compressor Gas Reciprocating Engines Diesel Generators Diesel Generators Gas Reciprocating Engines Min Stack Minimum NOx as Nitrogen dioxide Carbon monoxide Release Height (m) diameter (m) efflux velocity (m/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) PL228 Kenya PB 1 - Auxiliary PB 3 boiler PL228 Kenya BC 1 - BC 3 Gas Reciprocating Engines *Minimum efflux velocity, maximum concentration and maximum mass emission are to be measured at the Maximum Continuous Rating File C Page 70 of 185

71 Point source air monitoring Point source air monitoring is required for both NOx as nitrogen dioxide and carbon monoxide at Kenya (Condition G15). It requires monitoring 3 months after commissioning any fuel equipment and biennially thereafter. May 2009 March 2010 Contaminant release points Condition (O1): The release of contaminants to the atmosphere from a point source can only occur at the release points specified below. Table 3: Compressor Station Release Points (as per EA Condition O1) Release Source Minimum release height (meters) Kenya Field Compression Station Natural Gas Engines Kenya 1 to Kenya 4 Natural Gas Engines Kenya 5 to Kenya 8 Start and blow down vents Minimum velocity (m/sec) Contaminant release 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr 3m Approx 30m³ coal seam gas (>97% CH4, 2.6% N, 0.1% CO2, <0.15% C2H6) Codie Field Compression Station Natural Gas Engines Codie 1 to Codie 8 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr Kenya Processing Plant Natural Gas Engines Kenya Sales 1 to Kenya Sales 10 Type of fuel to be used 3.5 meters above ground level 42 m/s At 100% load and speed: NOx ton/year CO ton/year Hydrocarbons 9.15 ton/year Condition (O3): The only type of fuel to be burnt in the compressors, under normal operating conditions, is coal seam gas. Monitoring of contaminant releases Condition (O4): Only when the administering authority requests contaminant monitoring. July 2007 November File C Page 71 of 185

72 The older conditions regarding air were focused on dust suppression and particulate matter. The following condition is the only condition regarding fuel burning: Condition (K1): This environmental authority only permits the burning of hydrocarbon based fuels in fuel burning equipment APLNG Talinga September 2012 present Fuel burning and combustion equipment register It is a requirement under APLNG Talinga EA condition (F7) that a fuel burning register of equipment capable of burning more than 500kg/hr is maintained. APLNG provided a fuel burning and combustion equipment register for all fuel burning equipment located on the Talinga Project Area, however only the Reciprocating Compressors at the Talinga Gas Processing Facility burn more than 500kg/hr of fuel. Ground level concentrations Table 4 Maximum Ground Level Concentration Criteria outlines the maximum concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located outside of a hub or populated area as specified in EA condition (F4) for the Talinga Project Area. Table 4: Maximum Ground Level Concentration Criteria (as per EA Condition F4) Contaminant Concentration at Units Averaging time 0⁰ Celsius NOx as Nitrogen 250 μg/m³ 1 hour dioxide NOx as Nitrogen 33 μg/m³ 1 year dioxide Carbon monoxide 11 mg/m³ 8 hour May March 2012 Fuel burning facility details Condition (O1) requires APLNG to submit fuel burning details to EHP within 3 months of grant of authority, for assessment to ensure emissions are not causing nuisance/environmental harm. Contaminant Limits Table 5 demonstrates the contaminant limits of each piece of equipment as instructed in condition (O4). QGC has supplied no data to determine compliance. Table 5: Fuel Burning Facility Release Points and Contaminant Limits (as per EA Condition O4) File C Page 72 of 185

73 Release Source Minimum release height (meters) Minimum velocity (m/sec) Contaminant release Maximum release limit¹ Talinga Gas Plant Screw NOx 6.6 Compressors Reciprocating NOx 0.39 Compressors Generators NOx 2.2 TEG Reboiler Burner NOx 0.7 Rockwood Compressor Station Screw NOx 0.13 Compressors Talinga Water Treatment Facility Power Station NOx 0.11 Talinga Field Well Head Pump Microprocessors NOx Note 1: The above NOx limits are applicable at all times except start-up, shut down and calibration of emission monitoring devices. The maximum start-up allowed is 30 mins. Type of fuel to be used Condition (O5): The only fuel to be burnt under normal operating conditions is methane. Monitoring of contaminant releases to the atmosphere Condition (O12): QGC must conduct and keep records of a monitoring program of contaminant release to the atmosphere at the release points, frequency and parameters in the table below. Table 6: Required air monitoring (as per EA Condition O12) Determination Required Release points Frequency Mass emission rate and concentration of oxides of nitrogen (NOx) in the flue gas at the specified oxygen reference level. Talinga WTF E S E S E S E S Talinga GP and flares E S E S E S E S Rockwood Compressor Station E S E S E S E S During commissioning of the plant, twice a year for the first two years of operation and then annually thereafter File C Page 73 of 185

74 March The older conditions regarding air were focused on dust suppression and particulate matter. The following condition is the only condition regarding fuel burning: Condition (K1): This environmental authority only permits the burning of hydrocarbon based fuels in fuel burning equipment EPP Air Limits Environmental Protection (Air) Policy 2008 Table 7: Air quality objectives from EPP Air Indicator Carbon monoxide Nitrogen dioxide Environmental value Health and wellbeing Health and wellbeing Health and biodiversity of ecosystems 4. Results and Discussion 4.1. QGC Kenya Air quality objectives Period Days μg/m³ at 0 degrees C (except where noted) ppm (volume/ volume) 11mg/m³ 9 8 hours 1 day each year hour 1 day each year year year No data for ground level concentrations is available for the Kenya Project Area. The EA conditions only require monitoring of fuel burning or combustion equipment burning more than 500kg/hr and no equipment of this size is on site. Therefore, no data has been provided to EHP. Stack (point source) monitoring by EHP Comment [M5]: Insert discussion re EPP Air Access deferred Released Table 8: Kenya Water Treatment Plant Power Generators for October File C Page 74 of 185

75 (Data sourced from QGC through the report Air monitoring (point source) by Veolia water November 2013) Release point Average stack gas velocity (m/sec) NOx as Nitrogen dioxide Maximum Mass concentration emission * (mg / dscm) rate* (kg/hour) Carbon monoxide Maximum Mass concentration emission * (mg / dscm) rate* (kg/hour) PG PG PG PG PG PG6* N/A PG *PG6 was not tested as it was offline during the sampling program. Table 9: Stack and emission data provided by QGC, which are based on stack monitoring programs performed at a number of sites. (Data sourced from QGC through the report Central Project Area Air Dispersion Modelling Study by SLR global environmental solutions December Facility Kenya Field Compressor Station Kenya Central Processing Plant Kenya Water Treatment Plant Power Generators Release point FCS 1 - FCS 8 CPP 1 - CPP 10 PG 1- PG 7 PB 1 - PB 3 BC 1 - BC 3 Unit Description Gas Screw Compressor Gas Reciprocating Engines Stack height (m) Stack diameter (m) Exit velocity (m/sec) CO emission rate (g/sec) NOx emissio n rate (g/sec) Gas Reciprocating Engines Auxiliary boiler Gas Reciprocating Engines Comment [DN6]: Not sure if data, may be modelled File C Page 75 of 185

76 Kenya WTP power generator stack test report (Table 8) The ECS stack testing report provides results or emissions testing carried out at the Kenya WTP gasfired power generators in October this year. One of the seven generators was not operating at the time, and so was not tested. The ECS report notes that the sampling planes for the six generators was non-ideal for flow rate determinations, however additional sampling traverses were undertaken in accordance with AS to compensate for the non-ideal location. Hence flow rate determinations can be regarded as reliable. Results for concentration (mg/m3) and mass (g/s) for NOx expressed as NO2 and for CO were all less than the relevant EA release limits. Measured efflux velocities were all greater than the EA minimum efflux velocity. The EA requires that measurements of efflux velocity, pollutant concentration and pollutant mass be made at maximum continuous rating (load) (MCR). In this case engine load was set at 90% to allow for the engine to be able to handle a sudden increase in extra load without causing a complete plant shutdown. (Executive summary, page 5). This would satisfy the MCR requirement. As such, the testing showed that the power generators were compliant with the EA release limits. Modelling studies (Table 9) Two modelling studies prepared to assess the potential impacts in air quality from the QGC Kenya area used a number of NOx emission factors for the WTP generators that were provided by QGC. These were compared against the measured NOX emissions. The measured emissions were all below the modelled factors. In addition, measured efflux velocities and temperatures were higher than those modelled. If the assessment was undertaken using the measured NOX emissions, efflux velocities, and temperatures, it is feasible the predicted ground-level concentrations would be lower than those modelled in the previous studies APLNG Talinga APLNG has alleged no air emission data exists for 2007 to Only the Reciprocating Compressors at the Talinga Gas Processing Facility burn more than 500kg/hr of fuel, due to this the majority of the following data is for this equipment and surrounding facility. Emissions monitoring There are two tables to represent air emission data for the Talinga Gas Processing Facility. Table 8 displays data for 2013, whilst Table 9 displays data for File C Page 76 of 185

77 Table 10: Monitored Talinga Gas Processing Plant air emission data 2013 (Data sourced from APLNG through the report Emissions Monitoring: Talinga Gas Processing Facility July 2013) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressors Screw Compressor Power Generator NOx mass emission rate (g/sec) NOx maximum concentration (mg/nm³) CO mass emission rates (g/sec) K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K NA - Breakdown K /06/ K /06/ K /06/ K /06/ G /06/ G /06/ G /06/ CO maximum concentration (mb/nm³) File C Page 77 of 185

78 Table 11: Monitored Talinga Gas Processing Facility air emission data 2012 (Data sourced from APLNG though the report Emissions Monitoring: Talinga Gas Processing Facility October 2012) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressor Screw Compressor NOx mass emission rate (g/sec) K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ NOx maximum concentration (mg/nm³) File C Page 78 of 185

79 Annual Environmental Monitoring Report March APLNG have submitted an annual environmental monitoring report for which provides a summary of the past 12 months monitoring data and results. Table 10 shows data for one of each compressor type. Table 12: Annual environmental monitoring air emission data comparison Facility Measure EA Condition Monitored Reciprocating Velocity (m/s) Compressor 5 Nitrogen Oxides (NO₂) (g/s) Screw Compressor Velocity (m/s) Nitrogen Oxides (NO₂) (g/s) APLNG have the following comment regarding the non-compliance of velocity: The monitoring indicated that the emission velocity on one of the engines was below the minimum licence limit. An investigation into the incident concluded that the engine emission specification originally supplied to the department as part of the proposed development application was incorrect. The emission velocity calculation failed to factor in temperature losses in the exhaust stack and the operating set up of the engine. Note: Only the last of each of the compressors has been included, Reciprocating Compressor 5 of 5, Screw Compressor 12 of 12. Also the EA limits above come from the March 2012 EA conditions. There has been no comparison to previous year s results. 5. External Response Throughout the report process there were updates from sources internally at other EHP units, from the Coal Seam Gas Compliance Unit, the GasFields Commission Queensland, DSITIA and Queensland Health Other EHP Units Access deferred 5.2. Department of Health (Queensland Health) File C Page 79 of 185

80 The response from Queensland Health 5.3. Coal Seam Gas Compliance Unit (CSGCU) The Coal Seam Gas Compliance Unit has been working with landholders that have complained about air quality and odour in the Wieambilla Estate for a number of years now. All of the government sampling that they are aware of has been done by EHP South (Toowoomba) and all that was available at the time was included in a report and was reviewed as part of the Tara Health report. They are also aware that QGC engaged a contractor to do a wide range of sampling for a number of properties on the Estate and these are included in the Health report. The CSGCU has not received any other information GasFields Commission Queensland The GasFields Commission has not undertaken any air monitoring or modelling or received any data on this. They have encouraged the companies and the relevant government agencies to undertake this work and provide the information to the relevant people Department of Science, Information Technology, Innovation and Arts (DSITIA) David Wainwright (Director Air Quality Sciences) has confirmed that DSITIA do not have any more monitoring data other than what was collected in the 2012 report, which has already been included in this report. 6. Site Inspections (To insert from known information / from Southern) 7. Review of Talinga Gas Processing Facility Ambient Air Monitoring Program Review APLNG implemented an ambient air quality monitoring program approximately 3km southeast of the Talinga Gas Processing Facility (GPF) in response to stack testing that showed some aspects of the operational emissions did not conform to the existing approval conditions; in particular the exhaust velocity was found to be below the minimum specified. (Page 1 ). The monitoring program was designed to measure ambient ground-level concentrations of nitric oxide (NO), nitrogen dioxide (NO₂), oxides of nitrogen (NOx), carbon monoxide (CO), and meteorological observations including wind speed and wind direction. Among other things, the purpose of the program was to understand File C Page 80 of 185

81 the potential environmental or health impacts of emission from the GPF. Only NO₂ and CO are scheduled in the EPP (Air) and EA limits. Validated data for the 7 month period between 20 June 2012 and 31 January 2013 was reviewed by Katestone Environmental (Katestone Environmental document reference D _Origin_Talinga_Ambient_Monitoring_Report_v1.10.docx). The review assessed ground-level concentrations against wind direction and showed that: - The highest NO₂ concentrations were associated with winds blowing from the direction of the GPF towards the monitoring point; NO₂ - Some elevated NO₂ concentrations were associated with a second GPF in the area (the report did not identify the location other than upwind of the monitoring point ); and - NO₂ concentrations were near background levels when the wind blew from all other directions (page 28, Figure 9). The review correctly concluded that measured concentrations for 1-hour and annual ground-level NO₂, and for 8-hour CO were below the respective EPP (Air) goals. Katestone Environmental also undertook new air quality dispersion modelling using stack testing emissions data provided by APLNG. 1-hour concentrations of NO₂ were predicted to exceed the EPP (Air) goal up 15km to the south-southwest of the GFC and monitoring station (Page 13, Page 34, Figure 15; and Page 36, Figure 17). No sensitive receptors were identified within the exceedance zone (which suggests no non-compliances). Modelled pollutant concentrations were compared with measured concentrations. Comparisons showed some differences, however on balance, the differences can be regarded to be within the sensitivity bounds of the modelling system. Note that (a) the monitoring station is outside the modelled exceedance zones, and (b), the extent to which the non-compliant exhaust velocity(ies) contributed to the modelled exceedances was not investigated. 8. Conclusion The Queensland Health report found no clear link between the health complaints by some residents in the Tara region and impacts of the local CSG industry on air, water or soil. The DSITIA report on VOCs in the Wieambilla Estate detected VOCs in ambient air; however the levels detected were below relevant guidelines and criteria used to assess the potential health effects from VOC s. Access deferred Released by EHP File C Page 81 of 185

82 Of the information available there are only individual results which do not represent the Wieambilla Estate. There is insufficient data to be able to calibrate and validate an appropriate air shed model for the Tara region. For this to occur there needs to be more data, both point source at the stack and ground level concentrations to cover all equipment capable of significant air emissions. However, the data did reveal some information for the Talinga Project Area as APLNG undertook an ambient air monitoring program monitoring CO, NO, NO₂ and NOx which demonstrated that concentrations of NO₂ and CO were below EPP (Air) objectives. QGC have also demonstrated that the Kenya Water Treatment Plant is complying with EA limits. EHP does not have access to information on other contaminants listed in the Queensland Health report. However, as mentioned it is unlikely that there would be other contaminants of concern based on the composition of the fuel gas (CSG). 9. Recommendations 1. EHP will undertake compliance of the Talinga Gas Field and Kenya Gas Field through the Level C inspections to determine the level of non-compliance with regards to the conditions relating to air emissions in the EAs. 2. EHP will undertake a review of current EA conditions to identify improvements to ensure EHP is able to determine industry compliance with EPP (Air). It is suggested that the focus on equipment capable of burning more than 500kg/hr of fuel be removed/adjusted to ensure all infrastructure emitting contaminants that have the potential for environmental harm are accounted for. 3. EHP will monitor the current situation until outcomes from the Level C inspections and EA condition review informs required actions. 4. This report and reviewing process should be audited within 2 years to ensure that the issues identified in the report have been rectified File C Page 82 of 185

83 Attachment A: Air emissions gap analysis indicative locations of fuel burning equipment surrounding the Wieambilla Estate complainants File C Page 83 of 185

84 49-Sch File C Page 84 of 185

85 Queensland Health Tara Air emission data collection 1. Introduction Residents of the Wieambilla Estate have raised concerns about the impacts of air emissions from the local coal seam gas fields on their health and well-being and that of the surrounding community. These concerns have primarily focused on odours and the potential health implications from those odours. The Wieambilla Estate is located half-way between Chinchilla to the north and Tara to the south of the estate. Refer to Attachment A for a map showing the Wieambilla Estate complainants in relation to the indicative locations of fuel burning equipment on the Talinga Project Area and Kenya Project Area. The location of all fuel burning equipment is not available to Department of Environment and Heritage Protection (EHP), as such only compression stations and gas plants have been identified in Attachment A. In response to residents concerns raised about the health impact of odour emissions from the local coal seam gas fields on surrounding residential areas, the Department of Health undertook an investigation which resulted in the Department of Health report Coal seam gas in the Tara region: Summary risk assessment of health complaints and environmental monitoring data, March Several recommendations were made in the report and an action plan in response to the recommendations was drafted. One of these recommendations was for EHP to undertake a desktop review of existing air monitoring undertaken by EHP and industry to identify any gaps in available data. This report presents the results of that review. The Wieambilla Estate is surrounded by petroleum tenure both in exploration/appraisal phase or production phase. The two primary production gas fields in the vicinity of the Wieambilla Estate are Australia Pacific LNG s (APLNG) Talinga Project Area (Environmental Authority (EA) EPPG ) and QGC s Kenya Project Area (EA EPPG ). The other petroleum tenures surrounding these project areas have not been included in this report as they are primarily exploration or in the initial development phase. Both APLNG and QGC has fuel burning equipment that has been in operation for at least five years. APLNG s Talinga has been operating since February 2004 and QGC s Kenya has been operating since July Review of existing monitoring data The Department of Science, Information Technology, Innovation and the Arts (DSITIA) commenced a community sampling program for volatile organic compounds (VOCs) in the Wieambilla Estate in response to community concerns about the impacts of air emissions from the local coal seam gas fields on the health and well-being of the surrounding community. The report, Wieambilla Estates Odour Investigation Results, July December 2012 outlines the results of the community sampling program conducted between July and December 2012 and is included in Attachment B. It indicated File C Page 85 of 185

86 that a number of volatile organic compounds (VOCs) were detected in the ambient air at levels generally well below relevant guidelines and criteria used to assess VOC concentrations. Monitoring data for this review was collected from the APLNG Talinga EA and the QGC Kenya EA. The relevant EA conditions are described below in section Description of Air Monitoring EA conditions The following is a compliance assessment of EA conditions in relation to air emissions. The EA conditions proceed from the most recently dated to the oldest available QGC Kenya July 2011 present Fuel burning and combustion equipment register It is a requirement under QGC Kenya EA condition (G3) that a fuel burning register of equipment capable of burning more than 500kg/hr is maintained. There is no individual fuel burning equipment which burns more than 500kg/hr of fuel in the Kenya Project Area and as such no equipment has been included in the register. Ground level concentrations The following table Maximum Ground Level Concentration Criteria outlines the maximum concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located more than 5km outside of a hub or populated area as specified in EA condition (G7) for the Kenya Project Area. Table 1: Maximum Ground Level Concentration Criteria Contaminant Concentration at Units Averaging time 0⁰ Celsius NOx as Nitrogen 250 μg/m³ 1 hour dioxide NOx as Nitrogen 33 μg/m³ 1 year dioxide Carbon monoxide 11 mg/m³ 8 hour The following condition (G10) applies to any fuel burning and combustion equipment located inside 5km of a hub and/or populated area. The following table documents the only equipment allowed to burn more than 500kg/hr of fuel and their limits File C Page 86 of 185

87 Note: Although this condition existed in July 2011, the table was not completed and included in the EA until July 2012, rendering the condition unenforceable until that date File C Page 87 of 185

88 Table 2: Releases of contaminants to air Resource Authority Field Facility Release point PL180 Kenya Kenya Field Compressor Station FCS 1 - FCS 8 PL180 Kenya Kenya CPP 1 - Central CPP 10 Processing Plant PL228 Kenya Kenya DGA 1 Relocatable Water Treatment Plant (RWTP) PL228 Kenya Kenya DGB 1 RWTP DGB 2 PL228 Kenya Kenya PG 1- Water PG 7 Treatment Plant Power Generators PL228 Kenya PB 1 - PB 3 PL228 Kenya BC 1 - BC 3 Unit Description Gas Screw Compressor Gas Reciprocating Engines Diesel Generators Diesel Generators Gas Reciprocating Engines Min Release Height (m) Stack diameter (m) Minimum efflux velocity (m/sec) NOx as Nitrogen dioxide Maximum Mass concentration* emission (mg / Nm³) rate* (g/sec) Carbon monoxide Maximum Mass concentration* emission (mg / Nm³) rate* (g/sec) Auxiliary boiler Gas Reciprocating Engines *Minimum efflux velocity, maximum concentration and maximum mass emission are to be measured at the Maximum Continuous Rating File C Page 88 of 185

89 Point source air monitoring Point source air monitoring is required for both NOx as nitrogen dioxide and carbon monoxide at Kenya (G15). It requires monitoring 3 months after commissioning any fuel equipment and biennially thereafter. May 2009 March 2010 Contaminant release points Condition (O1) The release of contaminants to the atmosphere from a point source can only occur at the release points specified below. Table 3: Compressor Station Release Points Release Source Minimum release height (meters) Kenya Field Compression Station Natural Gas Engines Kenya 1 to Kenya 4 Natural Gas Engines Kenya 5 to Kenya 8 Start and blow down vents Minimum velocity (m/sec) Contaminant release 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr 3m Approx 30m³ coal seam gas (>97% CH4, 2.6% N, 0.1% CO2, <0.15% C2H6) Codie Field Compression Station Natural Gas Engines Codie 1 to Codie 8 7m 59 m/s At 100% load and speed: NOx 1.91 kg/hr CO 1.5kg/hr Hydrocarbons 3.3kg/hr Kenya Processing Plant Natural Gas Engines Kenya Sales 1 to Kenya Sales meters above ground level 42 m/s At 100% load and speed: NOx ton/year CO ton/year Hydrocarbons 9.15 ton/year Type of fuel to be used Condition (O3) The only type of fuel to be burnt in the compressors, under normal operating conditions, is coal seam gas. Monitoring of contaminant releases Condition (O4) Only when the administering authority requests contaminant monitoring. July 2007 November File C Page 89 of 185

90 The older conditions regarding air were focused on dust suppression and particulate matter. The following condition is the only condition regarding fuel burning: (K1) This environmental authority only permits the burning of hydrocarbon based fuels in fuel burning equipment APLNG Talinga September 2012 present Fuel burning and combustion equipment register It is a requirement under APLNG Talinga EA condition (F7) that a fuel burning register of equipment capable of burning more than 500kg/hr is maintained. APLNG provided a fuel burning and combustion equipment register for all fuel burning equipment located on the Talinga Project Area, however only the Reciprocating Compressors at the Talinga Gas Processing Facility burn more than 500kg/hr of fuel. Ground level concentrations The following table Maximum Ground Level Concentration Criteria outlines the maximum concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located outside of a hub or populated area as specified in EA condition (F4) for the Talinga Project Area. Table 4: Maximum Ground Level Concentration Criteria Contaminant Concentration at Units Averaging time 0⁰ Celsius NOx as Nitrogen 250 μg/m³ 1 hour dioxide NOx as Nitrogen 33 μg/m³ 1 year dioxide Carbon monoxide 11 mg/m³ 8 hour May March 2012 Fuel burning facility details Condition (O1) requires APLNG to submit fuel burning details to EHP within 3 months of grant of authority, for assessment to ensure emissions are not causing nuisance/environmental harm. Contaminant Limits File C Page 90 of 185

91 The following table demonstrates the contaminant limits of each piece of equipment as instructed in condition (O4). QGC has supplied no data to determine compliance. Table 5: Fuel Burning Facility Release Points and Contaminant Limits Release Source Minimum release height (meters) Minimum velocity (m/sec) Contaminant release Maximum release limit¹ Talinga Gas Plant Screw NOx 6.6 Compressors Reciprocating NOx 0.39 Compressors Generators NOx 2.2 TEG Reboiler Burner NOx 0.7 Screw Compressors Rockwood Compressor Station NOx 0.13 Talinga Water Treatment Facility Power Station NOx 0.11 Talinga Field Well Head Pump Microprocessors NOx Note 1: The above NOx limits are applicable at all times except start-up, shut down and calibration of emission monitoring devices. The maximum start-up allowed is 30 mins. Type of fuel to be used Condition (O5) The only fuel to be burnt under normal operating conditions is methane. Monitoring of contaminant releases to the atmosphere Condition (O12) QGC must conduct and keep records of a monitoring program of contaminant release to the atmosphere at the release points, frequency and parameters in the table below. Table 6: Required air monitoring Determination Required Release points Frequency Mass emission rate and concentration of oxides of nitrogen (NOx) in the flue gas at the specified oxygen reference level. Talinga WTF E S E S E S E S Talinga GP and flares E S E S E S E S Rockwood Compressor Station E S E S E S During commissioning of the plant, twice a year for the first two years of operation and then annually thereafter File C Page 91 of 185

92 E S March The older conditions regarding air were focused on dust suppression and particulate matter. The following condition is the only condition regarding fuel burning: (K1) This environmental authority only permits the burning of hydrocarbon based fuels in fuel burning equipment. 2.2 EPP Air Limits Environmental Protection (Air) Policy 2008 Table 7: Air quality objectives from EPP Air Indicator Carbon monoxide Nitrogen dioxide Environmental value Health and wellbeing Health and wellbeing Health and biodiversity of ecosystems 3. Results and Discussion 3.1. Kenya Air quality objectives Period Days μg/m³ at 0 degrees C (except where noted) ppm (volume/ volume) 11mg/m³ 9 8 hours 1 day each year hour 1 day each year year year No data for ground level concentrations is available for the Kenya Project Area. The EA conditions only require monitoring of fuel burning or combustion equipment burning more than 500kg/hr and no equipment of this size is on site. Therefore, no data has been provided to EHP. Access deferred File C Page 92 of 185

93 3.2. Talinga APLNG has alleged no air emission data exists for 2007 to Only the Reciprocating Compressors at the Talinga Gas Processing Facility burn more than 500kg/hr of fuel, due to this the majority of the following data is for this equipment and surrounding facility. Emissions monitoring There are two tables to represent data for the Talinga Gas Processing Facility. The data limits for comparison are from the Talinga fuel burning and combustion equipment register which are engineered limits Other contaminants The Queensland Health report lists other contaminants which are primarily in context to odour issues. Under the EA conditions for Kenya and Talinga EHP does not have the ability to request information on these contaminants. However, due to the composition of the fuel gas (CSG) it is unlikely that these contaminants would be of concern to human health at any concentrations generated by the combustion of the fuel gas. Concentrations of these other contaminants is likely to be very low therefore EHP does not monitor for them. The EA monitors for CO and NOx as these are the major combustions of air when burning methane. Fugitive emissions are addressed in the DSITIA report and in the EPP Air limits, however the EA does not monitor for these as they are unlikely to occur in high concentrations. The APLNG Talinga EA does have measures to reduce fugitive emissions with conditions to ensure that all reasonable and practical measures are taken in the design and operation of the plant to minimise fugitive VOC emissions (Condition F14) File C Page 93 of 185

94 Table 8: Monitored Talinga Gas Processing Plant air emission data 2013 Equipment Reciprocating Compressors Screw Compressor Power Generator Release point Date Minimum efflux velocity (m/sec) NOx mass emission rate (g/sec) NOx maximum concentration (mg/nm³) CO mass emission rates (g/sec) K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K NA - Breakdown K /06/ K /06/ K /06/ K /06/ G /06/ G /06/ G /06/ CO maximum concentration (mb/nm³) File C Page 94 of 185

95 Table 9: Monitored Talinga Gas Processing Facility air emission data 2012 Equipment Reciprocating Compressor Screw Compressor Release point Date Minimum efflux velocity (m/sec) NOx mass emission rate (g/sec) K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ NOx maximum concentration (mg/nm³) File C Page 95 of 185

96 Annual Environmental Monitoring Report March APLNG have submitted an annual environmental monitoring report for which provides a summary of the past 12 months monitoring data and results. The following table shows data for one of each compressor type. Table 10: Annual environmental monitoring air emission data comparison Facility Measure EA Condition Monitored Reciprocating Velocity (m/s) Compressor 5 Nitrogen Oxides (NO₂) (g/s) Screw Compressor Velocity (m/s) Nitrogen Oxides (NO₂) (g/s) APLNG have the following comment regarding the non-compliance of velocity: The monitoring indicated that the emission velocity on one of the engines was below the minimum licence limit. An investigation into the incident concluded that the engine emission specification originally supplied to the department as part of the proposed development application was incorrect. The emission velocity calculation failed to factor in temperature losses in the exhaust stack and the operating set up of the engine. Note: Only the last of each of the compressors has been included, Reciprocating Compressor 5 of 5, Screw Compressor 12 of 12. Also the EA limits above come from the March 2012 EA conditions. 4. Review of Talinga Gas Processing Facility Ambient Air Monitoring Program Review APLNG implemented an ambient air quality monitoring program approximately 3km southeast of the Talinga Gas Processing Facility (GPF) in response to stack testing that showed some aspects of the operational emissions did not conform to the existing approval conditions; in particular the exhaust velocity was found to be below the minimum specified. (Page 1 ). The monitoring program was designed to measure ambient ground-level concentrations of nitric oxide (NO), nitrogen dioxide (NO2), oxides of nitrogen (NOx), carbon monoxide (CO), and meteorological observations including wind speed and wind direction. Among other things, the purpose of the program was to understand the potential environmental or health impacts of emission from the GPF. Only NO2 and CO are scheduled in the EPP (Air) and EA limits. Validated data for the 7 month period between 20 June 2012 and 31 January 2013 was reviewed by Katestone Environmental (Katestone Environmental document reference D _Origin_Talinga_Ambient_Monitoring_Report_v1.10.docx). The review assessed ground-level concentrations against wind direction and showed that: - The highest NO2 concentrations were associated with winds blowing from the direction of the GPF towards the monitoring point; File C Page 96 of 185

97 - Some elevated NO2 concentrations were associated with a second GPF in the area (the report did not identify the location other than upwind of the monitoring point ); and - NO2 concentrations were near background levels when the wind blew from all other directions (page 28, Figure 9). The review correctly concluded that measured concentrations for 1-hour and annual ground-level NO2, and for 8-hour CO were below the respective EPP (Air) goals. Katestone Environmental also undertook new air quality dispersion modelling using stack testing emissions data provided by APLNG. 1-hour concentrations of NO2 were predicted to exceed the EPP (Air) goal up 15km to the south-southwest of the GFC and monitoring station (Page 13, Page 34, Figure 15; and Page 36, Figure 17). No sensitive receptors were identified within the exceedance zone (which suggests no non-compliances). Modelled pollutant concentrations were compared with measured concentrations. Comparisons showed some differences, however on balance, the differences can be regarded to be within the sensitivity bounds of the modelling system. Note that (a) the monitoring station is outside the modelled exceedance zones, and (b), the extent to which the non-compliant exhaust velocity(ies) contributed to the modelled exceedances was not investigated. 5. Conclusion The Queensland Health report found no clear link between the health complaints by some residents in the Tara region and impacts of the local CSG industry on air, water or soil. The DSITIA report on VOCs in the Wieambilla Estate detected VOCs in ambient air; however the levels detected were below relevant guidelines and criteria used to assess the potential health effects from VOC s. Access deferred Released by EHP However some information is available for the Talinga Project Area as APLNG undertook an ambient air monitoring program monitoring CO, NO, NO2 and NOx which demonstrated that concentrations of NO2 and CO were below EPP (Air) objectives. EHP does not have access to information on other contaminants listed in the Queensland Health report. However, as mentioned it is unlikely that there would be other contaminants of concern based on the composition of the fuel gas (CSG) File C Page 97 of 185

98 6. Recommendations 1. EHP will undertake compliance of the Talinga Gas Field and Kenya Gas Field through the Level C inspections to determine the level of non-compliance with regards to the conditions relating to air emissions in the EAs. 2. EHP will undertake a review of current EA conditions to identify improvements to ensure EHP is able to determine industry compliance with EPP (Air). 3. EHP will monitor the current situation until outcomes from the Level C inspections and EA condition review informs required actions File C Page 98 of 185

99 Attachment A: Air emissions gap analysis indicative locations of fuel burning equipment surrounding the Wieambilla Estate complainants File C Page 99 of 185

100 File C Page 100 of 185

101 Tara Air Emission Data Collation Response to the Queensland Health Action Plan Report drafted by the Department of Environment and Heritage Protection Page File C Page 101 of 185

102 Contents 1. Introduction Action Plan Objectives Collation of existing data Air quality objectives from EPP (Air) QGC Kenya QGC Requirements QGC Results APLNG Talinga APLNG Requirements APLNG Results Southern Region Investigations Evaluation of gaps in the data Part C of the Action Plan Part D of the Action Plan Attachment A: Air emissions gap analysis indicative locations of fuel burning equipment surrounding the Wieambilla Estate complainants Page i File C Page 102 of 185

103 1. Introduction Residents of the Wieambilla Estate have raised concerns about the impacts of air emissions from the local coal seam gas fields on their health and well-being and that of the surrounding community. These concerns have primarily focused on odours and the potential health implications from those odours. The Wieambilla Estate is located half-way between Chinchilla to the north and Tara to the south of the estate. It is surrounded by petroleum tenure both in exploration/appraisal phase or production phase. The two primary production gas fields in the vicinity of the Wieambilla Estate are Australia Pacific LNG Pty Limited s (APLNG) Talinga Project Area (Environmental Authority (EA) EPPG ) and Queensland Gas Company Pty Limited (QGC) Kenya Project Area (EA EPPG ). Refer to Attachment A for a map indicating the locations of compression stations and gas plants for these project areas. The other petroleum tenures surrounding these project areas have not been included in this report as they are primarily exploration or in the initial development phase. Both APLNG and QGC have fuel burning equipment that has been in operation for at least five years. APLNG s Talinga has been operating since February 2004 and QGC s Kenya has been operating since July In response to residents concerns raised about the health impact of odour emissions from the local coal seam gas fields on surrounding residential areas, the Department of Health (Queensland Health) undertook an investigation which resulted in the Department of Health report Coal seam gas in the Tara region: Summary risk assessment of health complaints and environmental monitoring data, March Several recommendations were made in the report and an action plan in response to the recommendations was drafted. One of these recommendations was for EHP to undertake a desktop review of existing air monitoring undertaken by EHP and industry to identify any gaps in available data. This report presents the results of the Action Plan and resulting review. The Department of Science, Information Technology, Innovation and the Arts (DSITIA) commenced a community sampling program for volatile organic compounds (VOCs) in the Wieambilla Estate in response to community concerns about the impacts of air emissions from the local coal seam gas fields on the health and well-being of the surrounding community. The report, Wieambilla Estates Odour Investigation Results, July December 2012 outlines the results of the community sampling program conducted between July and December It indicated that a number of VOCs were detected in the ambient air at levels generally well below relevant guidelines and criteria used to assess VOC concentrations. The chosen contaminants for this report are nitrogen dioxide (NO₂) and carbon monoxide (CO). These contaminants are the major by-products of burning coal seam gas (CSG) methane. The Coordinator General s report for both the QGC and APLNG Environmental Impact Statement (EIS) highlighted monitoring of oxides of nitrogen (NOx). Thus the air quality objectives for NO₂ and CO as specified in the Environmental Protection (Air) Policy 2008 (EPP (Air)) have been chosen for the EA conditions to regulate and monitor contaminant releases. The Queensland Health report lists other contaminants which are primarily in context to odour issues. Due to the composition of the fuel gas (CSG) it is unlikely that these other contaminants would be of concern to human health at any concentrations generated by the combustion of the fuel gas. Concentrations of these other contaminants are likely to be very low. Page File C Page 103 of 185

104 Fugitive emissions are addressed in the DSITIA report and in the EPP (Air) limits, however the EAs do not monitor for these as they are unlikely to occur in high concentrations. However, the EAs take measures to ensure that all reasonable and practical measures are taken in the design and operation of the plant to minimise fugitive VOC emissions. 1.1 Action Plan Objectives The focus of this report is on task 4 of the Action Plan which was created after a meeting between various EHP and government agencies, Queensland Health and the GasFields Commission in June Task 4 of the plan comprises of four main objectives (current as of September 2013): a) Collate and review existing air monitoring and modelling data available from government agencies and industry sources to identify if gaps exist in the available data. (Refer to Section 2). b) Evaluate need for a plan to address any gaps identified and consider need for additional strategic monitoring of ambient air quality or air modelling. (Refer to Section 3). c) Should this evaluation recommend additional air monitoring consider funding options, including industry funded solutions, to implement the plan. (Refer to Section 4). d) Provide the air monitoring and modelling results to Department of Health for undertaking the health risk assessments. (Refer to Section 5). This report represents as the response to the first two objectives of the action plan and provides recommendations in relation to the third objective. 2. Collation of existing data This section is dedicated to part A of the Action plan; the collation and review of existing monitoring and modelling data. EHP has liaised with the Queensland Health, the Coal Seam Gas Compliance Unit (CSGCU), the GasFields Commission Queensland and DSITIA. These agencies have concluded that no additional monitoring or modelling has occurred or been provided to them since the commencement of this report in August. The Toowoomba office (Southern region) will provide an account of their surveying and results in Section Air quality objectives from EPP (Air) Page File C Page 104 of 185

105 Table 1: Air quality objectives for carbon monoxide and nitrogen dioxide as specified in the EPP (Air). (Current as of November 2012) Indicator Carbon monoxide Nitrogen dioxide 2.2 QGC Kenya Environmental value Health and wellbeing Health and wellbeing Health and biodiversity of ecosystems Air quality objectives Period Days μg/m³ at 0 degrees C (except where noted) ppm (volume/ volume) 11mg/m³ 9 8 hours 1 day each year hour 1 day each year year year Under EA EPPG QGC are required to maintain a fuel burning register of equipment, comply with air emission release limits, and monitor for ground level concentrations and stack emissions. QGC has provided EHP with monitoring data and modelling for the Kenya Water Treatment Plant (Kenya WTF) QGC Requirements Most of the requirements for air monitoring are triggered by fuel burning equipment that is capable of burning at least 500kg of fuel in an hour. This is because Environmental Protection Regulation 2008, fuel burning is listed as an Environmentally Relevant Activity (ERA) if it reaches the 500kg/hr of fuel threshold. QGC are required to keep and maintain a fuel burning register of equipment capable of burning more than 500kg/hr. QGC must undertake ground level concentration monitoring for all fuel burning and combustion equipment capable of burning more that 500kg/hr located more than 5km outside of a hub or populated area. Maximum ground level concentrations for the Kenya Project Area are the same as the EPP (Air) limits listed in Section 2.1, Table 1. QGC must undertake point source air monitoring for the equipment specified in Table 2 at a frequency of 3 months after commissioning of any fuel equipment and biennially thereafter. This monitoring must include: 1. Gas velocity, volume and mass flow rate; 2. Contaminant (NO₂ and CO) concentration and mass emission rate; 3. Temperature; and 4. Water vapour concentration (for non-continuous sampling). Page File C Page 105 of 185

106 Table 2 states the limits which apply to any fuel burning and combustion equipment located inside 5km of a hub and/or populated area. Resource Authority Field Facility Release point PL180 Kenya Kenya Field Compressor Station PL180 Kenya Kenya Central Processing Plant PL228 Kenya Kenya Relocatable Water Treatment Plant (RWTP) PL228 Kenya Kenya RWTP PL228 Kenya Kenya Water Treatment Plant Power Generators FCS 1 - FCS 8 CPP 1 - CPP 10 DGA 1 DGB 1 DGB 2 PG 1- PG 7 Unit Description Gas Screw Compressor Gas Reciprocating Engines Diesel Generators Diesel Generators Gas Reciprocating Engines Min Stack Minimum NOx as Nitrogen dioxide Carbon monoxide Release Height (m) diameter (m) efflux velocity (m/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) PL228 Kenya PB 1 - Auxiliary PB 3 boiler PL228 Kenya BC 1 - Gas BC 3 Reciprocating Engines *Minimum efflux velocity, maximum concentration and maximum mass emission are to be measured at the Maximum Continuous Rating. Page File C Page 106 of 185

107 2.2.2 QGC Results QGC has identified that there is no equipment on the Kenya Project Area that is capable of burning more than 500kg/hr of fuel. For this reason there is no fuel burning register or ground level concentration monitoring. Monitored point source emission data has been supplied for the Kenya WTP, which was commissioned on INSERT DATE, with results available in Table 3. There is currently no data available for the other equipment. The ECS stack testing report provides results or emissions testing carried out at the Kenya WTP gasfired power generators in October One of the seven generators was not operating at the time, and therefor was not tested. The ECS report notes that the sampling planes for the six generators was non-ideal for flow rate determinations, however additional sampling traverses were undertaken in accordance with AS to compensate for the non-ideal location. Hence flow rate determinations can be regarded as reliable. Results for concentration (mg/m3) and mass (g/s) for NOx expressed as NO2 and for CO were all less than the relevant EA release limits. Measured efflux velocities were all greater than the EA minimum efflux velocity. The EA requires that measurements of efflux velocity, pollutant concentration and pollutant mass be made at maximum continuous rating (load) (MCR). In this case engine load was set at 90% to allow for the engine to be able to handle a sudden increase in extra load without causing a complete plant shutdown. (Executive summary, page 5). This would satisfy the MCR requirement. As such, the testing showed that the power generators were compliant with the EA release limits. Table 3: Kenya Water Treatment Plant Power Generators for October (Data sourced from QGC through the report Air monitoring (point source) by Veolia water November 2013). Release Average NOx as Nitrogen dioxide Carbon monoxide point stack gas velocity (m/sec) Maximum concentration * (mg / dscm) Mass emission rate* (kg/hour) Maximum concentration * (mg / dscm) Mass emission rate* (kg/hour) PG PG PG PG PG PG6* N/A PG *PG6 was not tested as it was offline during the sampling program. Comment [DN1]: Find. Comment [DN2]: Awaiting comment from Ralph. Two modelling were studies prepared to assess the potential impacts of air quality from the Kenya Project area used a number of NOx emission factors for the WTP generators that were provided by QGC. These were compared against the measured NOX emissions. The measured emissions were all below the modelled factors. In addition, measured efflux velocities and temperatures were higher Page File C Page 107 of 185

108 than those modelled. If the assessment was undertaken using the measured NOX emissions, efflux velocities, and temperatures, it is feasible the predicted ground-level concentrations would be lower than those modelled in the previous studies. Table 4: Modelled stack and emission data provided by QGC, which are based on stack monitoring programs performed at a number of sites. (Data sourced from QGC through the report Central Project Area Air Dispersion Modelling Study by SLR global environmental solutions December 2012). Facility Kenya Field Compressor Station Kenya Central Processing Plant Kenya Water Treatment Plant Power Generators Release point FCS 1 - FCS 8 CPP 1 - CPP 10 PG 1- PG 7 PB 1 - PB 3 BC 1 - BC APLNG Talinga Unit Description Gas Screw Compressor Gas Reciprocating Engines Gas Reciprocating Engines Auxiliary boiler Gas Reciprocating Engines Stack height (m) Stack diameter (m) Exit velocity (m/sec) CO emission rate (g/sec) NOx emission rate (g/sec) Under EA EPPG APLNG are required to maintain a fuel burning register of equipment, comply with air emission release limits, and monitor for ground level concentrations and stack emissions. APLNG has provided EHP with monitoring data and modelling for the Talinga Gas Processing Facility (Talinga GPF) APLNG Requirements Most of the requirements for air monitoring are triggered by fuel burning equipment that is capable of burning at least 500kg of fuel in an hour. This is because Environmental Protection Regulation 2008, fuel burning is listed as an Environmentally Relevant Activity (ERA) if it reaches the 500kg/hr of fuel threshold. APLNG are required to keep and maintain a fuel burning register of equipment capable of burning more than 500kg/hr. Page File C Page 108 of 185

109 APLNG are required to monitor the ground level concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located outside of a hub or populated area. Maximum ground level concentrations for the Talinga Project Area are the same as the EPP (Air) limits listed in Section 2.1, Table 1. APLNG must undertake point source air monitoring for equipment capable of burning more than 500kg/hr of fuel. This monitoring must be completed at an annual frequency and must include: 1. Gas velocity, volume and mass flow rate; 2. Contaminant (NO₂ and CO) concentration and mass emission rate; 3. Temperature; and 4. Water vapour concentration (for non-continuous sampling) APLNG Results APLNG provided a fuel burning and combustion equipment register for all fuel burning equipment located on the Talinga Project Area, however only the Reciprocating Compressors at the Talinga GPF burn more than 500kg/hr of fuel. For this reason there is no ground level concentration monitoring. There are two tables to represent air emission data for the Talinga Gas Processing Facility; Table 5 which displays data for 2013, and Table 6 which displays data for Page File C Page 109 of 185

110 Table 5: Monitored Talinga Gas Processing Plant air emission data (Data sourced from APLNG through the report Emissions Monitoring: Talinga Gas Processing Facility July 2013) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressors Screw Compressor Power Generator NOx mass emission rate (g/sec) NOx maximum concentration (mg/nm³) CO mass emission rates (g/sec) K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K NA - Breakdown K /06/ K /06/ K /06/ K /06/ G /06/ G /06/ G /06/ CO maximum concentration (mb/nm³) Page File C Page 110 of 185

111 Table 6: Monitored Talinga Gas Processing Facility air emission data (Data sourced from APLNG though the report Emissions Monitoring: Talinga Gas Processing Facility October 2012) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressor Screw Compressor NOx mass emission rate (g/sec) K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ NOx maximum concentration (mg/nm³) Page File C Page 111 of 185

112 APLNG implemented an ambient air quality monitoring program approximately 3km southeast of the Talinga Gas Processing Facility (GPF) in response to stack testing that showed some aspects of the operational emissions did not conform to the existing approval conditions; in particular the exhaust velocity was found to be below the minimum specified. (Page 1). The monitoring program was designed to measure ambient ground-level concentrations of nitric oxide (NO), NO₂, NOx, CO, and meteorological observations including wind speed and wind direction. Among other things, the purpose of the program was to understand the potential environmental or health impacts of emission from the GPF. Only NO₂ and CO are scheduled in the EPP (Air) and EA limits. Validated data for the 7 month period between 20 June 2012 and 31 January 2013 was reviewed by Katestone Environmental (Katestone Environmental document reference D _Origin_Talinga_Ambient_Monitoring_Report_v1.10.docx). The review assessed ground-level concentrations against wind direction and showed that: - The highest NO₂ concentrations were associated with winds blowing from the direction of the GPF towards the monitoring point; NO₂ - Some elevated NO₂ concentrations were associated with a second GPF in the area (the report did not identify the location other than upwind of the monitoring point ); and - NO₂ concentrations were near background levels when the wind blew from all other directions (page 28, Figure 9). The review correctly concluded that measured concentrations for 1-hour and annual ground-level NO₂, and for 8-hour CO were below the respective EPP (Air) goals. Katestone Environmental also undertook new air quality dispersion modelling using stack testing emissions data provided by APLNG. 1-hour concentrations of NO₂ were predicted to exceed the EPP (Air) goal up 15km to the south-southwest of the GFC and monitoring station (Page 13, Page 34, Figure 15 (Figure 1 below); and Page 36, Figure 17 (Figure 2 below)). No sensitive receptors were identified within the exceedance zone (which suggests no non-compliances). Modelled pollutant concentrations were compared with measured concentrations. Comparisons showed some differences, however on balance, the differences can be regarded to be within the sensitivity bounds of the modelling system. Note that (a) the monitoring station is outside the modelled exceedance zones, and (b), the extent to which the non-compliant exhaust velocity(ies) contributed to the modelled exceedances was not investigated. Page File C Page 112 of 185

113 Figure 1: APLNG Talinga modelled ground level concentrations of nitrogen dioxide (operating at maximum load). Page File C Page 113 of 185

114 Figure 2: APLNG Talinga modelled ground level concentrations of nitrogen dioxide (operating at normal load). Page File C Page 114 of 185

115 2.4 Southern Region Investigations Southern Region has conducted approximately 25 separate tests for VOCs in the area of concern using a variety of testing apparatus. Levels detected were below relevant guidelines and criteria used to assess the potential health effects from VOC s. Since July 2012 Southern Region has conducted a variety of tests focussing on air quality in the Tara Estates in response to concerns raised by the local community. EHP focussed on testing for VOCs, in particular due to a number of odour complaints which had been received. Two methods were used to test for VOCs: evacuated canisters to test for acute events and passive tubes to test ambient levels of VOCs. Evacuated canisters were placed with local residents, to be opened when they believed there was an unusual odour event. In addition EHP officers took canister samples immediately above a high point vent within QGCs Kenya gas field gathering system, to test for direct VOC emissions from CSG gathering systems. The results of tests undertaken between July and December 2012 were assessed and collated in a report by DSITIA: Wieambilla Estates Odour Investigation Results. The report concluded that a number of VOCs were detected in the ambient air, generally at levels well below relevant guidelines and criteria. The use of evacuated canisters in the Tara Estates has continued through 2013, though community members are opening the canisters less frequently. Results from 2013 are not markedly different to In December 2013 EHP elected to trial dinitrophenylhydrazine (DNPH) tube samplers, which can test for different odorous substances (carbonyls) to the evacuated canisters. One sampler was opened by a resident in December, and analysis of the sample indicates no significant carbonyl contamination. A second sampler has been deployed and remains in the field, as yet unopened by the resident. During September and October 2013 EHP investigated reports of black oily fallout in proximity to the APLNG Ironbark field within the Talinga project area. EHP has analysed samples taken by swabbing vehicles and direct deposition sampling. The results appear to be consistent with the composition of mineral dust (essentially road dust), that is, not industrial fallout. The source of oily fallout is likely to be seasonal and natural (supported by a GHD report commissioned by Origin that identifies insects lerps as the probable cause). Comment [DN3]: Awaiting comment from Southern region. 3. Evaluation of gaps in the data This section of the report is dedicated to part B of the Action Plan; address any gaps identified in the data collection and review. It is known that nno air shed monitoring modelling exists for the region in and around Wieambilla Estate. It would be beneficial to map the air emission situation from a whole perspective instead of Page File C Page 115 of 185

116 individual pieces of equipmentair shed modelling would be able to inform whether the Air Quality Objective of the EPP (Air) has been met across the two EAs. However in order to undertake such modelling This requires both stack monitoring, ground concentration sampling and sensitive receptor data is required. Currently, of the data available, there is only information on stack testing is available. This review has also identified that there are gaps in the information that can be obtained through the It has been identified through this data collection and review that the monitoring requirements in the EAs have set back potential results. Most of tthe requirements for monitoring and data collection requirements for monitoring and data collection are only forsurround individual fuel burning equipment that is capable of burning more than 500kg/hr of fuel. As acknowledged by both APLNG and QGC there is are only a few pieces of equipment which exceed this limit. More importantly data from equipment that burn less than 500kg/hr of fuel but cumulatively burn greater than 500 kg/hr of fuel is omitted due to the current wording of the conditions. Whilst this can be considered as a gap and an argument be made that EHP should amend the conditions so that data from all fuel burning equipment can be obtained for the purpose of determining air quality in the Wieambilla, such action may not be required. Another CSG company operating in the Surat basin performed a review of the air quality related conditions in the respective EA and completed an Air Quality Modelling Study for existing and proposed activities in the project area. The modelling of CO and NO 2 emissions from combustion sources associated with project infrastructure demonstrated that these emissions have no potential to give rise to ground exceedances of ambient air quality criteria in the EPP (Air). As such, it is highly likely that activities undertaken on the APLNG and QGC EAs are also resulting in emissions that are significantly lower than the ambient air quality criteria in the EPP (Air). However, APLNG and QGC would need to undertake similar modelling in order to demonstrate that this is the case so as to account for any project specific variability. It could be understood that the 500kg/hr requirement could be altered but, with the inclusion of streamlined conditions from the Greentape Reduction legislation, it would be redundant. The Environmental Protection (Greentape Reduction) and Other Legislation Amendment Act 2012 has been created to put the responsibility back onto the CSG industries by creating their own monitoring and management plans whilst upholding EHP standards. It also means stricter enforcement when EHP standards are not met. 4. Part C of the Action Plan 1. EHP will undertake compliance of the Talinga Gas Field and Kenya Gas Field through the Annual Compliance Plans (ACP) inspections to determine the level of non-compliance with regards to the monitoring provisions. Formatted: Subscript Comment [DN4]: Hamish input please. 2. EHP will undertake a review of current monitoring requirements to identify improvements to ensure EHP is able to determine industry compliance with EPP (Air). It is suggested that the focus on equipment capable of burning more than 500kg/hr of fuel be removed/adjusted to ensure all infrastructure emitting contaminants that have the potential for environmental harm are accounted for. Page File C Page 116 of 185

117 3. EHP will monitor the current situation until outcomes from the ACP and monitoring requirement review informs required actions. 5. Part D of the Action Plan This report completes Part D of the Action Plan. Page File C Page 117 of 185

118 Attachment A: Air emissions gap analysis indicative locations of fuel burning equipment surrounding the Wieambilla Estate complainants 49-Sch4 Page File C Page 118 of 185

119 Tara Air Emission Data Collation Response to the Queensland Health Action Plan Report drafted by the Department of Environment and Heritage Protection 11 P age File C Page 119 of 185

120 Contents 1. Introduction Action Plan Objectives Collation of existing data Air quality objectives from EPP (Air) QGC Kenya QGC Requirements QGC Results APLNG Talinga APLNG Requirements APLNG Results Southern Region Investigation Evaluation of gaps in the data EHP Gap Analysis... Error! Bookmark not defined. 3.2 Southern Gap Analysis... Error! Bookmark not defined. 4. Part C of the Action Plan Part D of the Action Plan... 4 Attachment A: Air emissions gap analysis indicative locations of fuel burning equipment surrounding the Wieambilla Estate complainants P age File C Page 120 of 185

121 1. Introduction Residents of the Wieambilla Estate have raised concerns about the impacts of air emissions from the local coal seam gas fields on their health and well being and that of the surrounding community. These concerns have primarily focused on odours and the potential health implications from those odours. The Wieambilla Estate is located half way between Chinchilla to the north and Tara to the south of the estate. It is surrounded by petroleum tenure both in exploration/appraisal phase or production phase. The two primary production gas fields in the vicinity of the Wieambilla Estate are Australia Pacific LNG Pty Limited s (APLNG) Talinga Project Area (Environmental Authority (EA) EPPG ) and Queensland Gas Company Pty Limited (QGC) Kenya Project Area (EA EPPG ). Refer to Attachment A for a map indicating the locations of compression stations and gas plants for these project areas. The other petroleum tenures surrounding these project areas have not been included in this report as they are primarily exploration or in the initial development phase. Both APLNG and QGC have fuel burning equipment that has been in operation for at least five years. APLNG s Talinga has been operating since February 2004 and QGC s Kenya has been operating since July In response to residents concerns raised about the health impact of odour emissions from the local coal seam gas fields on surrounding residential areas, the Department of Health (Queensland Health) undertook an investigation which resulted in the Department of Health report Coal seam gas in the Tara region: Summary risk assessment of health complaints and environmental monitoring data, March Several recommendations were made in the report and an action plan in response to the recommendations was drafted. One of these recommendations was for EHP to undertake a desktop review of existing air monitoring undertaken by EHP and industry to identify any gaps in available data. This report presents the results of the Action Plan and resulting review. The Department of Science, Information Technology, Innovation and the Arts (DSITIA) commenced a community sampling program for volatile organic compounds (VOCs) in the Wieambilla Estate in response to community concerns about the impacts of air emissions from the local coal seam gas fields on the health and well being of the surrounding community. The report, Wieambilla Estates Odour Investigation Results, July December 2012 outlines the results of the community sampling program conducted between July and December It indicated that a number of volatile organic compounds (VOCs) were detected in the ambient air at levels generally well below relevant guidelines and criteria used to assess VOC concentrations. The chosen contaminants for this report are nitrogen dioxide (NO₂) and carbon monoxide (CO). These contaminants are the major by products of burning coal seam gas (CSG) methane. The Coordinator General s report for both the QGC and APLNG Environmental Impact Statement (EIS) highlighted monitoring of oxides of nitrogen (NOx). Thus the air quality objectives for NO₂ and CO as specified in the Environmental Protection (Air) Policy 2008 (EPP (Air)) have been chosen for the EA conditions to regulate and monitor contaminant releases. The Queensland Health report lists other contaminants which are primarily in context to odour issues. Due to the composition of the fuel gas (CSG) it is unlikely that these other contaminants would be of concern to human health at any concentrations generated by the combustion of the fuel gas. Concentrations of these other contaminants are likely to be very low. 2 P age File C Page 121 of 185

122 Fugitive emissions are addressed in the DSITIA report and in the EPP (Air) limits, however the EAs do not monitor for these as they are unlikely to occur in high concentrations. However, the EAs take measures to ensure that all reasonable and practical measures are taken in the design and operation of the plant to minimise fugitive VOC emissions. 1.1 Action Plan Objectives The focus of this report is on task 4 of the Action Plan which was created after a meeting between various EHP and government agencies, Queensland Health and the GasFields Commission in June Task 4 of the plan comprises of four main objectives (current as of September 2013): a) Collate and review existing air monitoring and modelling data available from government agencies and industry sources to identify if gaps exist in the available data. (Refer to Section 2). b) Evaluate need for a plan to address any gaps identified and consider need for additional strategic monitoring of ambient air quality or air modelling. (Refer to Section 3). c) Should this evaluation recommend additional air monitoring consider funding options, including industry funded solutions, to implement the plan. (Refer to Section 4). d) Provide the air monitoring and modelling results to Department of Health for undertaking the health risk assessments. (Refer to Section 5). This report represents as the response to the first two objectives of the action plan and provides recommendations in relation to the third objective. 2. Collation of existing data This section is dedicated to part A of the Action plan; the collation and review of existing monitoring and modelling data. EHP has liaised with the Queensland Health, the Coal Seam Gas Compliance Unit (CSGCU), the GasFields Commission Queensland and DSITIA. These agencies have concluded that no additional monitoring or modelling has occurred or been provided to them since the commencement of this report in August. The Toowoomba office (Southern region) will provide an account of their surveying and results in Section Air quality objectives from EPP (Air) Comment [DN1]: Update as necessary 3 P age File C Page 122 of 185

123 Table 1: Air quality objectives for carbon monoxide and nitrogen dioxide as specified in the EPP (Air). (Current as of November 2012) Indicator Carbon monoxide Nitrogen dioxide 2.2 QGC Kenya Environmental value Health and wellbeing Health and wellbeing Health and biodiversity of ecosystems Air quality objectives Period Days μg/m³ at 0 degrees C (except where noted) ppm (volume/ volume) 11mg/m³ 9 8 hours 1 day each year hour 1 day each year year year Under EA EPPG QGC are required to maintain a fuel burning register of equipment, comply with air emission release limits, and monitor for ground level concentrations and stack emissions. QGC has provided EHP with monitoring data and modelling for the Kenya Water Treatment Plant (Kenya WTF) QGC Requirements QGC are required to keep and maintain a fuel burning register of equipment capable of burning more than 500kg/hr. ERA 500kg/hr of fuel QGC must undertake ground level concentration monitoring for all fuel burning and combustion equipment capable of burning more that 500kg/hr located more than 5km outside of a hub or populated area. Maximum ground level concentrations for the Kenya Project Area are the same as the EPP (Air) limits listed in Section 2.1, Table 1. QGC must undertake point source air monitoring for the equipment specified in Table 2 at a frequency of 3 months after commissioning of any fuel equipment and biennially thereafter. This monitoring must include: 1. Gas velocity, volume and mass flow rate; 2. Contaminant (NO₂ and CO) concentration and mass emission rate; 3. Temperature; and 4. Water vapour concentration (for non continuous sampling). Comment [DN2]: Explain why this has been chosen link to ERAs. 4 P age File C Page 123 of 185

124 Table 2 states the limits which apply to any fuel burning and combustion equipment located inside 5km of a hub and/or populated area. Resource Authority Field Facility Release point PL180 Kenya Kenya Field Compressor Station PL180 Kenya Kenya Central Processing Plant PL228 Kenya Kenya Relocatable Water Treatment Plant (RWTP) PL228 Kenya Kenya RWTP PL228 Kenya Kenya Water Treatment Plant Power Generators FCS 1 FCS 8 CPP 1 CPP 10 DGA 1 DGB 1 DGB 2 PG 1 PG 7 Unit Description Gas Screw Compressor Gas Reciprocating Engines Diesel Generators Diesel Generators Gas Reciprocating Engines Min Stack Minimum NOx as Nitrogen dioxide Carbon monoxide Release Height (m) diameter (m) efflux velocity (m/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) PL228 Kenya PB 1 Auxiliary PB 3 boiler PL228 Kenya BC 1 Gas BC 3 Reciprocating Engines *Minimum efflux velocity, maximum concentration and maximum mass emission are to be measured at the Maximum Continuous Rating. 13 P age File C Page 124 of 185

125 2.2.2 QGC Results QGC has identified that there is no equipment on the Kenya Project Area that is capable of burning more than 500kg/hr of fuel. For this reason there is no fuel burning register or ground level concentration monitoring. Monitored point source emission data has been supplied for the Kenya WTP, which was commissioned on INSERT DATE, with results available in Table 3. There is currently no data available for the other equipment. The ECS stack testing report provides results or emissions testing carried out at the Kenya WTP gasfired power generators in October One of the seven generators was not operating at the time, and therefor was not tested. The ECS report notes that the sampling planes for the six generators was non ideal for flow rate determinations, however additional sampling traverses were undertaken in accordance with AS to compensate for the non ideal location. Hence flow rate determinations can be regarded as reliable. Results for concentration (mg/m3) and mass (g/s) for NOx expressed as NO2 and for CO were all less than the relevant EA release limits. Measured efflux velocities were all greater than the EA minimum efflux velocity. The EA requires that measurements of efflux velocity, pollutant concentration and pollutant mass be made at maximum continuous rating (load) (MCR). In this case engine load was set at 90% to allow for the engine to be able to handle a sudden increase in extra load without causing a complete plant shutdown. (Executive summary, page 5). This would satisfy the MCR requirement. As such, the testing showed that the power generators were compliant with the EA release limits. Table 3: Kenya Water Treatment Plant Power Generators for October (Data sourced from QGC through the report Air monitoring (point source) by Veolia water November 2013). Release Average NOx as Nitrogen dioxide Carbon monoxide point stack gas velocity (m/sec) Maximum concentration * (mg / dscm) Mass emission rate* (kg/hour) Maximum concentration * (mg / dscm) Mass emission rate* (kg/hour) PG PG PG PG PG PG6* N/A PG *PG6 was not tested as it was offline during the sampling program. Comment [DN3]: Find. Comment [DN4]: What is this? Phone Ralph. Two modelling were studies prepared to assess the potential impacts of air quality from the Kenya Project area used a number of NOx emission factors for the WTP generators that were provided by QGC. These were compared against the measured NOX emissions. The measured emissions were all below the modelled factors. In addition, measured efflux velocities and temperatures were higher 11 P age File C Page 125 of 185

126 than those modelled. If the assessment was undertaken using the measured NOX emissions, efflux velocities, and temperatures, it is feasible the predicted ground level concentrations would be lower than those modelled in the previous studies. Table 4: Modelled stack and emission data provided by QGC, which are based on stack monitoring programs performed at a number of sites. (Data sourced from QGC through the report Central Project Area Air Dispersion Modelling Study by SLR global environmental solutions December Facility Kenya Field Compressor Station Kenya Central Processing Plant Kenya Water Treatment Plant Power Generators Release point FCS 1 FCS 8 CPP 1 CPP 10 PG 1 PG 7 PB 1 PB 3 BC 1 BC APLNG Talinga Unit Description Gas Screw Compressor Gas Reciprocating Engines Gas Reciprocating Engines Auxiliary boiler Gas Reciprocating Engines Stack height (m) Stack diameter (m) Exit velocity (m/sec) CO emission rate (g/sec) NOx emission rate (g/sec) APLNG have various requirements for Talinga to provide a fuel burning register of equipment, uphold release limits, and monitor for ground level concentrations and stack emissions. QGC has provided monitoring data and modelling for the Talinga Gas Processing Facility (Talinga GPF) APLNG Requirements APLNG are required to keep and maintain a fuel burning register of equipment capable of burning more than 500kg/hr. APLNG are required to monitor the ground level concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located outside of a hub or populated area. Maximum ground level concentrations for the Talinga Project Area are the same as the EPP (Air) limits listed in Section 2.1, Table 1. APLNG must undertake point source air monitoring for equipment capable of burning more than 500kg/hr of fuel. This monitoring must be completed at an annual frequency and must include: 13 P age File C Page 126 of 185

127 1. Gas velocity, volume and mass flow rate; 2. Contaminant (NO₂ and CO) concentration and mass emission rate; 3. Temperature; and 4. Water vapour concentration (for non continuous sampling) APLNG Results APLNG provided a fuel burning and combustion equipment register for all fuel burning equipment located on the Talinga Project Area, however only the Reciprocating Compressors at the Talinga GPF burn more than 500kg/hr of fuel. For this reason there is no ground level concentration monitoring. There are two tables to represent air emission data for the Talinga Gas Processing Facility; Table 5 which displays data for 2013, and Table 6 which displays data for P age File C Page 127 of 185

128 Table 5: Monitored Talinga Gas Processing Plant air emission data (Data sourced from APLNG through the report Emissions Monitoring: Talinga Gas Processing Facility July 2013) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressors Screw Compressor Power Generator CO mass emission rates (g/sec) NOx mass emission rate (g/sec) NOx maximum concentration (mg/nm³) K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K NA Breakdown K /06/ K /06/ K /06/ K /06/ G /06/ G /06/ G /06/ CO maximum concentration (mb/nm³) 11 P age File C Page 128 of 185

129 Table 6: Monitored Talinga Gas Processing Facility air emission data (Data sourced from APLNG though the report Emissions Monitoring: Talinga Gas Processing Facility October 2012) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressor Screw Compressor NOx mass emission rate (g/sec) K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ NOx maximum concentration (mg/nm³) 13 P age File C Page 129 of 185

130 APLNG implemented an ambient air quality monitoring program approximately 3km southeast of the Talinga Gas Processing Facility (GPF) in response to stack testing that showed some aspects of the operational emissions did not conform to the existing approval conditions; in particular the exhaust velocity was found to be below the minimum specified. (Page 1). The monitoring program was designed to measure ambient ground level concentrations of nitric oxide (NO), NO₂, NOx, CO, and meteorological observations including wind speed and wind direction. Among other things, the purpose of the program was to understand the potential environmental or health impacts of emission from the GPF. Only NO₂ and CO are scheduled in the EPP (Air) and EA limits. Validated data for the 7 month period between 20 June 2012 and 31 January 2013 was reviewed by Katestone Environmental (Katestone Environmental document reference D _Origin_Talinga_Ambient_Monitoring_Report_v1.10.docx). The review assessed ground level concentrations against wind direction and showed that: The highest NO₂ concentrations were associated with winds blowing from the direction of the GPF towards the monitoring point; NO₂ Some elevated NO₂ concentrations were associated with a second GPF in the area (the report did not identify the location other than upwind of the monitoring point ); and NO₂ concentrations were near background levels when the wind blew from all other directions (page 28, Figure 9). The review correctly concluded that measured concentrations for 1 hour and annual ground level NO₂, and for 8 hour CO were below the respective EPP (Air) goals. Katestone Environmental also undertook new air quality dispersion modelling using stack testing emissions data provided by APLNG. 1 hour concentrations of NO₂ were predicted to exceed the EPP (Air) goal up 15km to the south southwest of the GFC and monitoring station (Page 13, Page 34, Figure 15 (Figure 1 below); and Page 36, Figure 17 (Figure 2 below)). No sensitive receptors were identified within the exceedance zone (which suggests no non compliances). Modelled pollutant concentrations were compared with measured concentrations. Comparisons showed some differences, however on balance, the differences can be regarded to be within the sensitivity bounds of the modelling system. Note that (a) the monitoring station is outside the modelled exceedance zones, and (b), the extent to which the non compliant exhaust velocity(ies) contributed to the modelled exceedances was not investigated. 11 P age File C Page 130 of 185

131 Figure 1: APLNG Talinga modelled ground level concentrations of nitrogen dioxide (operating at maximum load). 13 P age File C Page 131 of 185

132 Figure 2: APLNG Talinga modelled ground level concentrations of nitrogen dioxide (operating at normal load). 13 P age File C Page 132 of 185

133 2.4 Southern Region Investigations Southern Region has conducted approximately 25 separate tests for VOCs in the area of concern using a variety of testing apparatus. Levels detected were below relevant guidelines and criteria used to assess the potential health effects from VOC s. Since July 2012 Southern Region has conducted a variety of tests focussing on air quality in the Tara Estates in response to concerns raised by the local community. EHP focussed on testing for Volatile Organic Compounds, in particular due to a number of odour complaints which had been received. Two methods were used to test for VOCs: evacuated canisters to test for acute events and passive tubes to test ambient levels of VOCs. Evacuated canisters were placed with local residents, to be opened when they believed there was an unusual odour event. In addition EHP officers took canister samples immediately above a high point vent within QGCs Kenya gas field gathering system, to test for direct VOC emissions from CSG gathering systems. The results of tests undertaken between July and December 2012 were assessed and collated in a report by DSITIA: Wieambilla Estates Odour Investigation Results. The report concluded that a number of VOCs were detected in the ambient air, generally at levels well below relevant guidelines and criteria. The use of evacuated canisters in the Tara Estates has continued through 2013, though community members are opening the canisters less frequently. Results from 2013 are not markedly different to In December 2013 EHP elected to trial DNPH tube samplers, which can test for different odorous substances (carbonyls) to the evacuated canisters. One sampler was opened by a resident in December, and analysis of the sample indicates no significant carbonyl contamination. A second sampler has been deployed and remains in the field, as yet unopened by the resident. During September and October 2013 EHP investigated reports of black oily fallout in proximity to the APLNG Ironbark field within the Talinga project area. EHP has analysed samples taken by swabbing vehicles and direct deposition sampling. The results appear to be consistent with the composition of mineral dust (essentially road dust), that is, not industrial fallout. The source of oily fallout is likely to be seasonal and natural (supported by a GHD report commissioned by Origin that identifies insects lerps as the probable cause). Comment [DN5]: Find. southern? Comment [DN6]:? 3. Evaluation of gaps in the data This section of the report is dedicated to part B of the Action Plan; address any gaps identified in the data collection and review. It is known that no air shed monitoring exists for the Wieambilla Estate. It would be beneficial to map the air emission situation from a whole perspective instead of individual pieces of equipment. This requires both stack monitoring, ground concentration sampling and sensitive receptor data. 13 P age File C Page 133 of 185

134 Currently, of the data available, there is only information on stack testing. It has been identified through this data collection and review that the monitoring requirements in the EA have set back potential results. Most of the requirements for monitoring and data collection surround fuel burning equipment that is capable of burning more than 500kg/hr of fuel. As acknowledged by both APLNG and QGC there is only a few pieces of equipment which exceed this limit. It could be understood that the 500kg/hr requirement could be altered but, with the inclusion of streamlined conditions from the Greentape Reduction legislation, it would be redundant. The Environmental Protection (Greentape Reduction) and Other Legislation Amendment Act 2012 has been created to put the responsibility back onto the CSG industries by creating their own monitoring and management plans whilst upholding EHP standards. It also means stricter enforcement when EHP standards are not met. 4. Part C of the Action Plan 1. EHP will undertake compliance of the Talinga Gas Field and Kenya Gas Field through the Annual Compliance Plans (ACP) inspections to determine the level of non compliance with regards to the monitoring provisions. 2. EHP will undertake a review of current monitoring requirements to identify improvements to ensure EHP is able to determine industry compliance with EPP (Air). It is suggested that the focus on equipment capable of burning more than 500kg/hr of fuel be removed/adjusted to ensure all infrastructure emitting contaminants that have the potential for environmental harm are accounted for. 3. EHP will monitor the current situation until outcomes from the ACP and monitoring requirement review informs required actions. 5. Part D of the Action Plan This report completes Part D of the Action Plan. 13 P age File C Page 134 of 185

135 Attachment A: Air emissions gap analysis indicative locations of fuel burning equipment surrounding the Wieambilla Estate complainants 49-Sch4 13 P age File C Page 135 of 185

136 Tara Air Emission Data Collation Response to the Queensland Health Action Plan Report drafted by the Department of Environment and Heritage Protection Page File C Page 136 of 185

137 Contents 1. Introduction Action Plan Objectives Collation of existing data Air quality objectives from EPP (Air) QGC Kenya QGC Requirements QGC Results APLNG Talinga APLNG Requirements APLNG Results Southern Region Investigations Evaluation of gaps in the data Part C of the Action Plan Part D of the Action Plan Attachment A: Air emissions gap analysis indicative locations of fuel burning equipment surrounding the Wieambilla Estate complainants Page i File C Page 137 of 185

138 1. Introduction Residents of the Wieambilla Estate have raised concerns about the impacts of air emissions from the local coal seam gas fields on their health and well being and that of the surrounding community. These concerns have primarily focused on odours and the potential health implications from those odours. The Wieambilla Estate is located half way between Chinchilla to the north and Tara to the south of the estate. It is surrounded by petroleum tenure both in exploration/appraisal phase or production phase. The two primary production gas fields in the vicinity of the Wieambilla Estate are Australia Pacific LNG Pty Limited s (APLNG) Talinga Project Area (Environmental Authority (EA) EPPG ) and Queensland Gas Company Pty Limited (QGC) Kenya Project Area (EA EPPG ). Both APLNG and QGC have fuel burning equipment that has been in operation for at least five years. APLNG s Talinga has been operating since February 2004 and QGC s Kenya has been operating since July Refer to Attachment A for a map indicating the locations of compression stations and gas plants for these project areas. The other petroleum tenures surrounding these project areas have not been included in this report as they are primarily exploration or in the initial development phase. In response to residents concerns raised about the health impact of odour emissions from the local coal seam gas fields on surrounding residential areas, the Department of Health (Queensland Health) undertook an investigation which resulted in the Department of Health report Coal seam gas in the Tara region: Summary risk assessment of health complaints and environmental monitoring data, March Several recommendations were made in the report and an action plan in response to the recommendations was drafted. One of these recommendations was for EHP to undertake a desktop review of existing air monitoring undertaken by EHP and industry to identify any gaps in available data. This report presents the results of the Action Plan and resulting review. The Department of Science, Information Technology, Innovation and the Arts (DSITIA) commenced a community sampling program for volatile organic compounds (VOCs) in the Wieambilla Estate in response to community concerns about the impacts of air emissions from the local coal seam gas fields on the health and well being of the surrounding community. The report, Wieambilla Estates Odour Investigation Results, July December 2012 outlines the results of the community sampling program conducted between July and December It indicated that a number of VOCs were detected in the ambient air, at levels generally well below relevant guidelines and criteria used to assess VOC concentrations. The chosen contaminants for this report are nitrogen dioxide (NO₂) and carbon monoxide (CO). These contaminants are the major by products of burning coal seam gas (CSG) methane. The Coordinator General s report for both the QGC and APLNG Environmental Impact Statement (EIS) highlighted monitoring of oxides of nitrogen (NOx). Thus the air quality objectives for NO₂ and CO as specified in the Environmental Protection (Air) Policy 2008 (EPP (Air)) have been chosenare included for in the EA conditions to regulate and monitor contaminant releases. The Queensland Health report lists other contaminants which are primarily in context to odour issues. Due to the composition of the fuel gas (CSG) it is unlikely that these other contaminants would be of concern to human health at any concentrations generated by the combustion of the fuel gas. Cconcentrations of these other contaminants are likely to be very low. Page File C Page 138 of 185

139 Fugitive emissions are addressed in the DSITIA report and in the EPP (Air) limits, however the EAs do not condition monitoring for these. as they are unlikely to occur in high concentrations. However, the EAs take measures to ensure that all reasonable and practical measures are taken in the design and operation of the plant to minimise fugitive VOC emissions. 1.1 Action Plan Objectives The focus of this report is on Ttask 4 of the Draft Action Plan which was created after a meeting between various EHP and government agencies, Queensland Health and the GasFields Commission in June Task 4 of the plan comprises of four main objectives (current as of September 2013): a) Collate and review existing air monitoring and modelling data available from government agencies and industry sources to identify if gaps exist in the available data. (Refer to Section 2). b) Evaluate need for a plan to address any gaps identified and consider need for additional strategic monitoring of ambient air quality or air modelling. (Refer to Section 3). c) Should this evaluation recommend additional air monitoring consider funding options, including industry funded solutions, to implement the plan. (Refer to Section 4). d) Provide the air monitoring and modelling results to Department of Health for undertaking the health risk assessments. (Refer to Section 5). This report represents as the response to the first two objectives of the action plan and provides recommendations in relation to the third objective. 2. Collation of existing data This section is dedicated to Task 4 Ppart A of the Draft Action Pplan; the collation and review of existing monitoring and modelling data. EHP has liaised with the Queensland Health, the Coal Seam Gas Compliance Unit (CSGCU), the GasFields Commission Queensland and DSITIA. These agencies have concluded that no additional monitoring or modelling has occurred or been provided to them since the commencement of this report in August. The Toowoomba office (Southern region) will provide an account of their surveying and results in Section 2.4. Page File C Page 139 of 185

140 2.1 Air quality objectives from EPP (Air) Table 1: Air quality objectives for carbon monoxide and nitrogen dioxide as specified in the EPP (Air). (Current as of November 2012) Indicator Carbon monoxide Nitrogen dioxide 2.2 QGC Kenya Environmental value Health and wellbeing Health and wellbeing Health and biodiversity of ecosystems Air quality objectives Period Days μg/m³ at 0 degrees C (except where noted) ppm (volume/ volume) 11mg/m³ 9 8 hours 1 day each year hour 1 day each year year year Under EA EPPG QGC are required to maintain a fuel burning register of equipment, comply with air emission release limits, and monitor for ground level concentrations and stack emissions. QGC has provided EHP with monitoring data and modelling for the Kenya Water Treatment Plant (Kenya WTF) QGC Requirements Most of the requirements for air monitoring are triggered by fuel burning equipment that is capable of burning at least 500kg of fuel in an hour (. This is because Environmental Protection Regulation 2008, fuel burning is listed as an Environmentally Relevant Activity (ERA) if it reaches the 500kg/hr of fuel threshold). QGC are required to keep and maintain a fuel burning register of equipment capable of burning more than 500kg/hr. QGC must undertake ground level concentration monitoring for all fuel burning and combustion equipment capable of burning more that 500kg/hr located more than 5km outside of a hub or populated area. Maximum ground level concentrations for the Kenya Project Area are the same as the EPP (Air) limits listed in Section 2.1, Table 1. QGC must undertake point source air monitoring for the equipment specified in Table 2 at a frequency of 3 months after commissioning of any fuel equipment and biennially thereafter. This monitoring must include: 1. Gas velocity, volume and mass flow rate; 2. Contaminant (NO₂ and CO) concentration and mass emission rate; 3. Temperature; and 4. Water vapour concentration (for non continuous sampling). Page File C Page 140 of 185

141 Table 2 states the limits which apply to any fuel burning and combustion equipment located inside 5km of a hub and/or populated area. Resource Authority Field Facility Release point PL180 Kenya Kenya Field Compressor Station PL180 Kenya Kenya Central Processing Plant PL228 Kenya Kenya Relocatable Water Treatment Plant (RWTP) PL228 Kenya Kenya RWTP PL228 Kenya Kenya Water Treatment Plant Power Generators FCS 1 FCS 8 CPP 1 CPP 10 DGA 1 DGB 1 DGB 2 PG 1 PG 7 Unit Description Gas Screw Compressor Gas Reciprocating Engines Diesel Generators Diesel Generators Gas Reciprocating Engines Min Stack Minimum NOx as Nitrogen dioxide Carbon monoxide Release Height (m) diameter (m) efflux velocity (m/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) Maximum concentration* (mg / Nm³) Mass emission rate* (g/sec) PL228 Kenya PB 1 Auxiliary PB 3 boiler PL228 Kenya BC 1 Gas BC 3 Reciprocating Engines *Minimum efflux velocity, maximum concentration and maximum mass emission are to be measured at the Maximum Continuous Rating. Page File C Page 141 of 185

142 2.2.2 QGC Results QGC has identified that there is no equipment on the Kenya Project Area that is capable of burning more than 500kg/hr of fuel. For this reason there is no fuel burning register or ground level concentration monitoring. Monitored point source emission data has been supplied for the Kenya WTP, which was commissioned in July 2013 with results available in Table 3. There is currently no data available for the other equipment. The Air Monitoring (point source) report conducted by Veolia water dated November 2013 (ECSstack testing report) provides results or emissions testing carried out at the Kenya WTP gas fired power generators in October One of the seven generators was not operating at the time, and therefore was not tested. The ECS report notes that the sampling planes for the six generators was non ideal for flow rate determinations, however additional sampling traverses were undertaken in accordance with AS to compensate for the non ideal location. Hence flow rate determinations can be regarded as reliable. Results for concentration (mg/m3) and mass (g/s) for NOx expressed as NO₂2 and for CO were all less than the relevant EA release limits. Measured efflux velocities were all greater than the EA minimum efflux velocity. The EA requires that measurements of efflux velocity, pollutant concentration and pollutant mass be made at maximum continuous rating (load) (MCR). In this case engine load was set at 90% to allow for the engine to be able to handle a sudden increase in extra load without causing a complete plant shutdown. (Executive summary, page 5). This would satisfy the MCR requirement. As such, the testing showed that the power generators were compliant with the EA release limits. Table 3: Kenya Water Treatment Plant Power Generators for October (Data sourced from QGC through the ECS report Air monitoring (point source) by Veolia water November 2013). Release Average NOx as Nitrogen dioxide Carbon monoxide point stack gas velocity (m/sec) Maximum concentration * (mg / dscm) Mass emission rate* (kg/hour) Maximum concentration * (mg / dscm) Mass emission rate* (kg/hour) PG PG PG PG PG PG6* N/A PG *PG6 was not tested as it was offline during the sampling program. Two modelling were studies were prepared to assess the potential impacts of air quality from the Kenya Project area which used a number of NOx emission factors for the WTP generators that were provided by QGC. These were compared against the measured NOxX emissions. The measured Page File C Page 142 of 185

143 emissions were all below the modelled factors. In addition, the measured efflux velocities and temperatures were also better higher than those modelled ( being higher than the minimum standard). If the assessment was undertaken using the measured NOxX emissions, efflux velocities, and temperatures, it is feasible the predicted ground level concentrations would be lower than those modelled in the previous studies. Table 4: Modelled stack and emission data provided by QGC, which are based on stack monitoring programs performed at a number of sites. (Data sourced from QGC through the report Central Project Area Air Dispersion Modelling Study by SLR global environmental solutions December 2012). Facility Kenya Field Compressor Station Kenya Central Processing Plant Kenya Water Treatment Plant Power Generators Release point FCS 1 FCS 8 CPP 1 CPP 10 PG 1 PG 7 PB 1 PB 3 BC 1 BC APLNG Talinga Unit Description Gas Screw Compressor Gas Reciprocating Engines Gas Reciprocating Engines Auxiliary boiler Gas Reciprocating Engines Stack height (m) Stack diameter (m) Exit velocity (m/sec) CO emission rate (g/sec) NOx emission rate (g/sec) Under EA EPPG APLNG are required to maintain a fuel burning register of equipment, comply with air emission release limits, and monitor for ground level concentrations and stack emissions. APLNG has provided EHP with monitoring data and modelling for the Talinga Gas Processing Facility (Talinga GPF) APLNG Requirements Most of the requirements for air monitoring are triggered by fuel burning equipment that is capable of burning at least 500kg of fuel in an hour. This is because Environmental Protection Regulation 2008, fuel burning is listed as an Environmentally Relevant Activity (ERA) if it reaches the 500kg/hr of fuel threshold. APLNG are required to keep and maintain a fuel burning register of equipment capable of burning more than 500kg/hr. Page File C Page 143 of 185

144 APLNG are required to monitor the ground level concentrations for all fuel burning and combustion equipment capable of burning more that 500kg/hr located outside of a hub or populated area. Maximum ground level concentrations for the Talinga Project Area are the same as the EPP (Air) limits listed in Section 2.1, Table 1. APLNG must undertake point source air monitoring for equipment capable of burning more than 500kg/hr of fuel. This monitoring must be completed at an annual frequency and must include: 1. Gas velocity, volume and mass flow rate; 2. Contaminant (NO₂ and CO) concentration and mass emission rate; 3. Temperature; and 4. Water vapour concentration (for non continuous sampling) APLNG Results APLNG provided a fuel burning and combustion equipment register for all fuel burning equipment located on the Talinga Project Area, however only the Reciprocating Compressors at the Talinga GPF burn more than 500kg/hr of fuel. For this reason there is no ground level concentration monitoring. There are two tables to represent air emission data for the Talinga Gas Processing Facility; Table 5 which displays data for 2013, and Table 6 which displays data for Page File C Page 144 of 185

145 Table 5: Monitored Talinga Gas Processing Plant air emission data (Data sourced from APLNG through the report Emissions Monitoring: Talinga Gas Processing Facility July 2013) Equipment Release point Date Minimum efflux velocity (m/sec) Reciprocating Compressors Screw Compressor Power Generator NOx mass emission rate (g/sec) NOx maximum concentration (mg/nm³) CO mass emission rates (g/sec) K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K /06/ K NA Breakdown K /06/ K /06/ K /06/ K /06/ G /06/ G /06/ G /06/ CO maximum concentration (mb/nm³) Page File C Page 145 of 185

146 Table 6: Monitored Talinga Gas Processing Facility air emission data (Data sourced from APLNG though the report Emissions Monitoring: Talinga Gas Processing Facility October 2012) Equipment Release point Date Minimum efflux velocity (m/sec) NOx mass emission rate (g/sec) NOx maximum concentration (mg/nm³) Reciprocating K /10/ Compressor K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ Screw K /10/ Compressor K /10/ K /10/ K /10/ K /10/ K /10/ K /10/ Page File C Page 146 of 185

147 APLNG implemented an ambient air quality monitoring program approximately 3km southeast of the Talinga Gas Processing Facility (GPF) in response to stack testing that showed some aspects of the operational emissions did not conform to the existing approval conditions; in particular the exhaust velocity was found to be below the minimum specified. (Page 1). The monitoring program was designed to measure ambient ground level concentrations of nitric oxide (NO), NO₂, NOx, CO, and meteorological observations including wind speed and wind direction. Among other things, the purpose of the program was to understand the potential environmental or health impacts of emission from the GPF. Only NO₂ and CO are scheduled in the EPP (Air) and EA limits. Validated data for the 7 month period between 20 June 2012 and 31 January 2013 was reviewed by Katestone Environmental (Katestone Environmental document reference D _Origin_Talinga_Ambient_Monitoring_Report_v1.10.docx). The review assessed ground level concentrations against wind direction and showed that: The highest NO₂ concentrations were associated with winds blowing from the direction of the GPF towards the monitoring point; NO₂ Some elevated NO₂ concentrations were associated with a second GPF in the area (the report did not identify the location other than upwind of the monitoring point ); and NO₂ concentrations were near background levels when the wind blew from all other directions (page 28, Figure 9). The review correctly concluded that measured concentrations for 1 hour and annual ground level NO₂, and for 8 hour CO were below the respective EPP (Air) goals. Katestone Environmental also undertook new air quality dispersion modelling using stack testing emissions data provided by APLNG. 1 hour concentrations of NO₂ were predicted to exceed the EPP (Air) goal up 15km to the south southwest of the GFC and monitoring station (Page 13, Page 34, Figure 15 (Figure 1 below); and Page 36, Figure 17 (Figure 2 below)). No sensitive receptors were identified within the exceedance zone (which suggests no non compliances). Modelled pollutant concentrations were compared with measured concentrations. Comparisons showed some differences, however on balance, the differences can be regarded to be within the sensitivity bounds of the modelling system. Note that (a) the monitoring station is outside the modelled exceedance zones, and (b), the extent to which the non compliant exhaust velocity(ies) contributed to the modelled exceedances was not investigated. Page File C Page 147 of 185

148 Figure 1: APLNG Talinga modelled ground level concentrations of nitrogen dioxide (operating at maximum load). Page File C Page 148 of 185

149 Figure 2: APLNG Talinga modelled ground level concentrations of nitrogen dioxide (operating at normal load). Page File C Page 149 of 185

150 2.4 Southern Region Investigations Southern Region has conducted approximately 25 separate tests for VOCs in the area of concern using a variety of testing apparatus. Levels detected were below relevant guidelines and criteria used to assess the potential health effects from VOC s. Since July 2012 Southern Region has conducted a variety of tests focussing on air quality in the Tara Estates in response to concerns raised by the local community. EHP focussed on testing for VOCs, in particular due to a number of odour complaints which had been received. Two methods were used to test for VOCs: evacuated canisters to test for acute events and passive tubes to test ambient levels of VOCs. Evacuated canisters were placed with local residents, to be opened when they believed there was an unusual odour event. In addition, EHP officers took canister samples immediately above a high point vent within QGCs Kenya gas field gathering system, to test for direct VOC emissions from CSG gathering systems. The results of tests undertaken between July and December 2012 were assessed and collated in a report by DSITIA: Wieambilla Estates Odour Investigation Results. The report concluded that a number of VOCs were detected in the ambient air, generally at levels well below relevant guidelines and criteria. The use of evacuated canisters in the Tara Estates has continued through 2013, though community members are opening the canisters less frequently. Results from 2013 are not markedly different to In December 2013, EHP elected to trial dinitrophenylhydrazine (DNPH) tube samplers, which can test for different odorous substances (carbonyls) to the evacuated canisters. One sampler was opened by a resident in December, and analysis of the sample indicates no significant carbonyl contamination. A second sampler has been deployed and remains in the field, as yet unopened by the resident. During September and October 2013 EHP investigated reports of black oily fallout in proximity to the APLNG Ironbark field within the Talinga project area. EHP has analysed samples taken by swabbing vehicles and direct deposition sampling. The results appear to be consistent with the composition of mineral dust (essentially road dust), that is, not industrial fallout. The source of oily fallout is likely to be seasonal and natural. 3. Evaluation of gaps in the data This section of the report is dedicated to Task 4 Ppart B of the Draft Action Plan; address any gaps identified in the data collection and review. No air shed modelling exists for the region in and around Wieambilla Estate. Air shed modelling would be able to inform whether the Air Quality Objective of the EPP (Air) has been met across the two EAs. However in order to undertake such modelling stack monitoring, ground concentration Page File C Page 150 of 185

151 sampling and sensitive receptor data is required. Currently only information on stack testing is available. This review has also identified that there are gaps in the information that can be obtained through the monitoring requirements in the EAs. The requirements for monitoring and data collection are only for individual fuel burning equipment capable of burning more than 500kg/hr of fuel. As acknowledged by both APLNG and QGC there are only a few pieces of equipment which exceed this limit. More importantly data from equipment that burn less than 500kg/hr of fuel but cumulatively burn greater than 500 kg/hr of fuel is omitted due to the current wording of the conditions. Whilst this can be considered as a gap and an argument be made that EHP should amend the conditions so that data from all fuel burning equipment can be obtained for the purpose of determining air quality in the Wieambilla Estate, such action may not be required. Some gaps in relation to EAs have been identified and are currently being addressed through the preparation of streamlined model conditions. Recently developed streamlined conditions address the issue of fuel burning equipment and the 500kg/hr limit by defining fuel burning or combustion facility as being defined as a permanent fuel burning or combustion equipment which in isolation, or combined in operation, or which are interconnected, is, or are capable of burning more than 500 kg of fuel in an hour. Point source air monitoring for any fuel burning or combustion facility must be undertaken to demonstrate compliance with the limits set in the EA. The streamlined conditions ensure fuel burning or combustion facilities meet EPP Air Quality Objectives and an air receiving environment program is prescribed to demonstrate compliance with the Air Quality Objectives. Another CSG company operating in the Surat Bbasin performed a review of the air quality related conditions in the respective EA and completed an Air Quality Modelling Study for existing and proposed activities in the project area. The modelling of CO and NO 2 emissions from combustion sources associated with project infrastructure demonstrated that although there may be exceedances of stack emission heights, direction of venting and minimum efflux velocities, the resulting these emissions have no potential to give rise to ground exceedances of ambient air quality criteria in the EPP (Air). The result of this report was an amendment application to implement less stringent air monitoring in line with streamline conditions. As such, iit is highly likely that activities undertaken on the APLNG and QGC EAs are also resulting in emissions that are significantly lower than the ambient air quality criteria in the EPP (Air). However, APLNG and QGC would need to undertake similar modelling in order to demonstrate that this is the case so as to account for any project specific variability. Both project areas have been targeted for Level C inspections in the 2013/2014 Annual Compliance Plan. Level C inspections are the highest and most detailed level of compliance assessment that the department undertakes. The Level C inspection of the QGC Kenya site was undertaken in September 2013 whilst the Level C inspection of the APLNG Talinga site will be undertaken in the first half of It is expected that the results from both inspections will determine QGC/APLNG compliance with the conditions of the air schedule as well as identify gaps in the department s ability to determine compliance of the project areas with the EPP (Air). EHP has reviewed and evaluated air monitoring and modelling data for the Wiembella Estates and has determined that there is no need to expand on current levels of monitoring in the area. Page File C Page 151 of 185

152 4. Part C of the Action PlanRecommendations to implement plan This section is dedicated to Task 4 Part C of the Draft Action Plan; should theis evaluation recommend additional air monitoring consider funding options, including industry funded solutions, to implement the plan. Insert sentencethis report does not recommend any expansion of current levels of strategic monitoring of ambient air quality. As such, there has been no consideration of funding options for such a program. However in order to ensure that best practice is being implemented in the project areas with respect to air monitoring EHP proposes the following recommendations: It is recommended that: 1. EHP will undertake compliance of the Talinga Gas Field and Kenya Gas Field through the Annual Compliance Plans (ACP) inspections to determine the level of non compliance with regards to the monitoring provisions. 2. EHP will undertake a review of current monitoring requirements to identify improvements to ensure EHP is able to determine industry compliance with EPP (Air). It is suggested that the focus on equipment capable of burning more than 500kg/hr of fuel be removed/adjusted to ensure all infrastructure emitting contaminants that have the potential for environmental harm are accounted for. 3. EHP will monitor the current situation until outcomes from the ACP and monitoring requirement review informs required actions. 5. Part D of the Action PlanProvide air monitoring and modelling results to DoH This report completes Task 4 Part D of the Draft Action Plan. Formatted: Highlight Formatted: Highlight Page File C Page 152 of 185

153 Attachment A: Air emissions gap analysis indicative locations of fuel burning equipment surrounding the Wieambilla Estate complainants 49-Sch4 Page File C Page 153 of 185