Stephenson ANNUAL EMISSION SURVEY SCRUBBER STACK (EPA ID 2) BITUMINOUS PRODUCTS PTY LTD REVESBY, NSW PROJECT NO.

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1 Stephenson Environmental Management Australia ANNUAL EMISSION SURVEY SCRUBBER STACK (EPA ID 2) REVESBY, NSW PROJECT NO.: 5997/S/S25146/18 DATE OF SURVEY: 11 SEPTEMBER 2018 DATE OF ISSUE: 2 OCTOBER 2018

2 Stephenson Environmental Management Australia Peter W Stephenson & Associates Pty Ltd ACN (Incorporated in NSW) ABN A Hampstead Road Auburn NSW 2144 Australia Tel: (02) info@stephensonenv.com.au ANNUAL EMISSION SURVEY SCRUBBER STACK (EPA ID 2) REVESBY, NSW PROJECT NO.: 5997/S/S25146/18 DATE OF SURVEY: 11 SEPTEMBER 2018 DATE OF ISSUE: 2 OCTOBER 2018 P W STEPHENSON J WEBER M KIMBER

3 TABLE OF CONTENTS 1 INTRODUCTION LICENCE AND REGULATORY LIMITS PRODUCTION CONDITIONS EMISSION TEST RESULTS INTRODUCTION TOTAL SOLID PARTICULATE MATTER (TSP) ODOUR VOLATILE ORGANIC COMPOUNDS (VOCS) CONCLUSIONS TEST METHODS EXHAUST GAS VELOCITY AND TEMPERATURE CONTINUOUS GASEOUS ANALYSIS ODOUR ODOUR MEASUREMENT/DYNAMIC OLFACTOMETRY TOTAL SOLID PARTICULATES (TSP) VOLATILE ORGANIC COMPOUNDS (VOCS) ACCURACY... 9 APPENDIX A EMISSION TEST RESULTS... I APPENDIX B - NATA EMISSION TEST REPORT INCLUDING CERTIFICATES OF ANALYSIS... I APPENDIX C CALIBRATION DETAILS... I APPENDIX D SAMPLE LOCATIONS... I TABLE OF TABLES TABLE 2-1 EPA ID POINT 2: MONITORING REQUIREMENTS AND EMISSION CONCENTRATION LIMITS... 2 TABLE 4-1 AVERAGE EMISSION CONCENTRATIONS TEST RESULTS SCRUBBER STACK EPA ID TABLE 4-2 SUMMARY OF DETECTED VOCS SCRUBBER STACK-EPA ID TABLE 6-1 ESTIMATION OF MEASUREMENT UNCERTAINTY TABLE OF TABLES APPENDICES TABLE A- 1 DETAILED EMISSION TEST RESULTS SCRUBBER STACK - TSP... II TABLE C-1 INSTRUMENT CALIBRATION INFORMATION... II TABLE OF FIGURES APPENDICES FIGURE D-1 SAMPLE LOCATION EPA ID POINT 2... II STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA TOC I 5997/S/S25146/18

4 1 INTRODUCTION Stephenson Environmental Management Australia (SEMA) was requested by Bituminous Products Pty Ltd to assess the emission from the Scrubber discharge stack at their Bituminous Products facility in Revesby, New South Wales (NSW). The facility is licensed by the Office of Environment and Heritage (OEH) under Environment Protection Licence (EPL) No The objectives of the tests were: To monitor the emissions from EPA ID Point 2 (Scrubber Stack) in accordance with Condition M2.1 in EPL 5267, Determine compliance of the emission with the concentration limits as outlined in Condition L3.3, Report the findings of the survey in a report. Refer to Section 2 for further details on the monitoring requirements and concentration limits under the EPL. The stack emission was assessed for the following components: Exhaust Gas Velocity, Volume and Temperature Total Solid Particulate Matter (TSP) Odour Volatile Organic Compounds (VOCs). The emission tests were undertaken on 11 September 2018 on the discharge stack serving the EPA ID Point 2. STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA PAGE /S/S25146/18

5 2 LICENCE AND REGULATORY LIMITS The stacks at Bituminous Products Pty Ltd are licensed by the NSW OEH under EPL No which specifies the monitoring requirements and concentration limits from these stacks. Table 2-1 summarises the EPL monitoring requirements and the concentration limits for EPA ID Point 2. The reference conditions pertaining to the concentration limits are specified in Condition L3.3 of the EPL and are outlined under the respective concentration limit tables. TABLE 2-1 EPA ID POINT 2: MONITORING REQUIREMENTS AND EMISSION CONCENTRATION LIMITS Units Frequency Sampling Method EPL 100 Percentile Concentration Limit (ID 2) Odour ou Annual OM-7 -- Solid Particles mg/m 3 Annual TM Volatile Organic Compounds mg/m 3 Annual TM Dry gas density kg/m 3 Annual TM-4 -- Moisture % Annual TM Molecular weight of stack gases g/g.mole Annual TM Temperature o C Annual TM-2 -- Velocity m/s Annual TM-2 -- Volumetric Flow rate m 3 /s Annual TM-2 -- Reference Conditions VOC and Solid Particles: Dry 273 o K, kpa Key: ou = odour units mg/m 3 = milligrams per cubic 0 o C and 1 atmosphere kg/m 3 = kilograms per cubic metre % = percent g/g.mole = grams per gram mole oc = degrees Celsius m/s = metres per second m 3 /s = cubic metres per second -- = no limit in EPL TM = Test method VOC = Volatile Organic Compounds kpa = kilopascals K = Kelvin STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA PAGE /S/S25146/18

6 3 PRODUCTION CONDITIONS Bituminous Products Pty Ltd personnel considered the facility was operating under typical conditions on the day of testing. The production data supplied to SEMA for the day of testing on 11 September 2018 was: Production was normal activities, with Polymer Modified Bitumen (PMB) in Mixing Tank 1 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA PAGE /S/S25146/18

7 4 EMISSION TEST RESULTS 4.1 INTRODUCTION SEMA completed the sampling for all parameters tested including odour and VOCs; and, analysis of flow, temperature, moisture and TSP. SEMA is NATA accredited for this sampling and analysis, Accreditation No Refer to SEMA s Emission Test Report No. 5997/S, Appendix B, which includes a summary of results and the associated certificates of analysis including SEMA NATA Particle Test Report No Analysis for VOCs was performed by the NATA accredited (NATA No. 3726) TestSafe Laboratories, Report No Odour Research Laboratories Australia (ORLA) completed the odour analysis, report number ORLA 5997/ORLA/01. ORLA is a division of Peter W Stephenson & Associates Pty Ltd and is NATA accredited for odour analysis, accreditation number The stack emission test results are summarised in Tables 4-1 and 4-2 and detailed in Appendix A. Appendix C details the calibration of measurement instruments. Refer Appendix D for sample locations. 4.2 TOTAL SOLID PARTICULATE MATTER (TSP) The Scrubber Stack TSP emission concentrations measured at stack oxygen (O 2), were 0.8 milligrams per cubic metre (mg/m 3 ) for Run 1 and 5.6 mg/m 3 for Run 2. The average TSP emission concentration was 3.2 mg/m 3. Refer to Table 4-1 and Appendix A for detailed results. 4.3 ODOUR The Scrubber Stack measured odour emission concentration was 820 odour units (ou) for Run 1 and 1,800 ou for Run 2 with an average odour emission concentration of 1,310 ou when corrected for equal volumetric exhaust gas flow rates. 4.4 VOLATILE ORGANIC COMPOUNDS (VOCS) The Scrubber Stack average total VOCs emission concentration* measured at stack O 2 was 20.9 mg/m 3. Refer to Table 4-2 for the VOC results. * Note: The POEO (Clean Air) Regulation requires VOCs to be reported as n-propane equivalent. Hence all measured VOC emissions are reported as n-propane equivalent unless otherwise stated. STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA PAGE /S/S25146/18

8 TABLE 4-1 AVERAGE EMISSION CONCENTRATIONS TEST RESULTS SCRUBBER STACK EPA ID 2 Parameter Units of Measure Average Emission Conc. EPA ID 2 11 September 2018 EPL Conc. Limit Odour ou 1, Solid Particles mg/m Volatile Organic Compounds * mg/m Dry gas density kg/m Moisture % Molecular weight of stack gases g/g.mole Temperature o C Velocity m/s Volumetric Flowrate m 3 /s TABLE 4-2 SUMMARY OF DETECTED VOCS SCRUBBER STACK-EPA ID 2 VOCs EPA ID 2 (n-propane equivalent) (Average mg/m 3 ) 11 September 2018 EPL Conc. Limit Key to abbreviations in tables overleaf Aliphatic Hydrocarbons n-octane n-nonane n-decane n-undecane n-dodecane n-tridecane Aromatic Hydrocarbons Ethylbenzene ,2,3-Trimethylbenzene ,2,4-Trimethylbenzene ,3,5-Trimethylbenzene p-xylene &/or m-xylene o-xylene Sum of VOCs (73 Suite) (as n-propane equiv.) STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA PAGE /S/S25146/18

9 Key to Tables 4-1 and 4-2: EPL = Environment Protection Licence Conc. = concentration -- = No limit ou = odour units mg/m 3 = milligrams per cubic 0 o C and 1 atmosphere kg/m 3 = kilograms per cubic metre % = percent g/g.mole = grams per gram mole oc = degrees Celsius m/s = metres per second m 3 /s = cubic metres per second < = Less than VOC = volatile organic compound * = VOCs reported as n-propane equivalent as required by POEO regulation Note: All VOC concentrations reported as n-propane equivalent as required by the POEO (Clean Air) Regulation. STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA PAGE /S/S25146/18

10 5 CONCLUSIONS From the data presented and test work conducted during typical production cycles, the following conclusions can be drawn: SCRUBBER STACK EPA ID POINT 2 Particulate matter emission concentration (TSP) averaged 3.2 mg/m 3 which was in compliance with the EPL 5267 emission limit of 50 mg/m 3. The average VOC emission concentration was 20.9 mg/m 3 which was in compliance with the EPL 5267 emission limit of 40 mg/m 3 (expressed as n-propane). The odour emission concentration averaged 1,310 ou. There is no EPL stack emission limit for odour. STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA PAGE /S/S25146/18

11 6 TEST METHODS 6.1 EXHAUST GAS VELOCITY AND TEMPERATURE (OEH NSW TM-1 & 2) Velocity profiles were obtained across the stack utilising an Airflow Developments Ltd. S-type pitot tube and inclined manometer. The exhaust gas temperature was measured using a Digital thermometer ( o C) connected to a chromel/alumel (K-type) thermocouple probe. 6.2 CONTINUOUS GASEOUS ANALYSIS (OEH NSW TM- 4 & 11) Sampling and analysis of exhaust gas were performed using a Stephenson Environmental Management Australia mobile combustion and environmental monitoring laboratory. Emission gases were distributed to the analysers via a manifold. Flue gas from the stack was pumped continuously. The following components of the laboratory were relevant to this work: Oxygen Calibration QA/QC Testo 350XL BOC Special Gas Mixtures relevant for each analyser. Instrument calibrations were performed at the start and finish of sampling at each location. Calibration (Zero/Span) checks. Sample line integrity calibration check 6.3 ODOUR ODOUR MEASUREMENT/DYNAMIC OLFACTOMETRY (AS ; OEH NSW OM-7) Samples were collected in Nalophane sampling bags which are enclosed in airtight plastic containers. Sampling and dilution lines are constructed from teflon, stainless or glass to prevent contamination of the sample. The sampling and dilution procedures used were in accordance with AS Odorous gas for analysis was drawn through a 316 stainless steel sampling probe. The gas then passes through a Teflon (PTFE) tube connected to the Nalophane sampling bag. The sampling pump is connected to the airtight plastic container to provide a sample gas flow-rate of approximately 1.5 to 4.0 litres per minute. After the required volume has been sampled, the pump is stopped and the bag sealed with a stainless steel valve. Using a forced choice olfactometer, the Nalophane bag of odour sample was dynamically diluted to various concentrations with dry odour free air. The diluted sample was then presented to a panel of screened panellists as one of these airflows. The panellists then recorded if they could detect any odour and from which flow. The other flow was discharging odour free air. STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA PAGE /S/S25146/18

12 The odour is always presented to the panellists in ascending concentration; that is, from lower to higher concentration. The panellists are required at each dilution level to nominate a response to what they smell from the flows (forced choice methodology). The panellists response options are: Guess Inkle Detect or Certain Recognise Unable to determine which air flow contains the diluted odours Thinks that one of the flows may be different from the other flow Is confident that one of the airflows smells different from the other flow. Not necessarily able to say what the smell is. Is confident that one of the flows smells different from the other flow and is able to: Assign a hedonic tone (pleasantness scale number) to the odour ranging from 10 to 10 and/or Able to assign a character to the colour, as in it smells like Note: 1. The Recognise level concentration and Hedonic Tone and odour descriptors are obtained with the diluted odour, panellists are not exposed to the full strength odour. Note 2. The Recognised response, hedonic tone and odour descriptors are not part of AS The panel responses and dilution levels used were then entered into a computer programme to determine the 50% panel response. This dilution level corresponds to the odour concentration of the sample. 6.4 TOTAL SOLID PARTICULATES (TSP) (OEH NSW TM- 15) The isokinetic particle collection filtration method utilising filtration equipment manufactured by Gelman Scientific and Western Precipitation Division of Joy Manufacturing was used for the particulate matter sampling. Samples were collected at isokinetic rates from multipoint traverses across the discharge stack, in accordance with Australian Standard (AS) 4323, 1995 Parts 1 & 2 and OEH NSW Test Method VOLATILE ORGANIC COMPOUNDS (VOCS) (OEH NSW TM-34) A sample of stack air is drawn onto a proprietary manufactured activated carbon tube and the analysis using Gas Chromatography/Mass Spectrometry (GC/MS) was performed by the NATA accredited laboratory, TestSafe Australia, accreditation number, ACCURACY All results are quoted on a dry basis. SEMA has adopted the following (Table 6-1) uncertainties for various stack testing methods. STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA PAGE /S/S25146/18

13 TABLE 6-1 ESTIMATION OF MEASUREMENT UNCERTAINTY Pollutant Methods Uncertainty Moisture AS4323.2, TM-22, USEPA 4 25% Oxygen TM-25, USEPA 3A 1% actual Particulate > 20 mg/m 3 TM-15, AS4323.2, USEPA 5 & 17 15% Particulate < 20 mg/m 3 TM-15, AS4323.2, USEPA 5 & 17 50% Velocity AS4323.1, TM-2, USEPA 2 5% Volatile Organic Compounds (adsorption tube) TM-34, USEPA 18 25% Odour AS4323.3, OM-7 50% Key: Unless otherwise indicated the uncertainties quoted have been 95% level of Confidence level (i.e. by multiplying the repeatability standard deviation by a co-efficient equal to 1.96) (Source Measurement Uncertainty) Sources: Measurement Uncertainty implications for the enforcement of emission limits by Maciek Lewandowski (Environment Agency) & Michael Woodfield (AEAT) UK Technical Guidance Note (Monitoring) M2 Monitoring of stack emissions to air Environment Agency Version 3.1 June Note: ISO 9096 is for mg/m 3- which AS is based on. Note DSEN testing for < 5 mg/m 3 correlates to 5 mg/m 3 with most quoted uncertainties of mg/m 6.4 mg/m 3. From Clean Air Engineering in the United States the lowest practical limit of USEPA M5 is 5 mg/m 3 under lab conditions. STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA PAGE /S/S25146/18

14 APPENDIX A EMISSION TEST RESULTS Glossary: % = percent oc = Degrees Celsius am³/min = cubic metre of gas at actual conditions per minute Normal Volume (m³) = cubic metre at 0 C and 760 mm pressure and 1 atmosphere am³ = cubic metre of gas at actual conditions g/g mole = grams per gram mole g/s = grams per second hrs = hours kg/m 3 = kilograms per cubic metre kpa = kilo Pascals m 2 = square metre m/s = metre per second m³/sec = cubic metre per second at 0 0 C and 1 atmosphere mg = milligrams mg/ m³ = milligrams per cubic metre at 0ºC and 1 atmosphere O 2 = Oxygen Abbreviations of Parameters PM 10 = Particulate Matter less than 10 microns TSP = Total Solid Particulates Abbreviations of Personnel PWS = Peter W Stephenson JW = Jay Weber STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX A-I 5997/S/S25146/18

15 TABLE A- 1 DETAILED EMISSION TEST RESULTS SCRUBBER STACK - TSP Emission Test Results TSP TSP Project Number Project Name Bituminous Products Bituminous Products Test Location Scrubber Scrubber Date 11-Sep Sep-18 RUN 1 2 Sample Start Time (hrs) 8:11 9:15 Sample Finish Time (hrs) 9:11 10:15 Sample Location (Inlet/Exhaust) Exhaust Exhaust Stack Temperature ( o C) Stack Cross-Sectional area (m 2 ) Average Stack Gas Velocity (m/s) Actual Gas Flow Volume (am 3 /min) Total Normal Gas Flow Volume (m 3 /min) Total Normal Gas Flow Volume (m 3 /sec) Total Stack Pressure (kpa) Analysis TSP TSP Method TM-15 TM-15 SEMA Lab Number Mass In Sample (mg) Air Volume Sampled (am 3 ) Normal Sample Volume (m 3 ) Concentration at Stack O 2 (mg/m 3 ) Mass Emission Rate (g/s) Moisture Content (% by volume) Molecular Weight Dry Stack Gas (g/g-mole) Dry Gas Density (kg/m 3 ) EPL Limit (mg/m 3 ) Isokinetic Sampling Rate (%) Sample Storage Period 3 months 3 months Sampling Performed by PWS, JW PWS, JW Sample Analysed by (Laboratory) SEMA SEMA Calculations Entered by JW JW Calculations Checked by PWS PWS STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX A-II 5997/S/S25146/18

16 APPENDIX B - NATA EMISSION TEST REPORT INCLUDING CERTIFICATES OF ANALYSIS STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-I 5997/S/S25146/18

17 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-II 5997/S/S25146/18

18 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-III 5997/S/S25146/18

19 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-IV 5997/S/S25146/18

20 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-V 5997/S/S25146/18

21 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-VI 5997/S/S25146/18

22 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-VII 5997/S/S25146/18

23 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-VIII 5997/S/S25146/18

24 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-IX 5997/S/S25146/18

25 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-X 5997/S/S25146/18

26 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-XI 5997/S/S25146/18

27 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-XII 5997/S/S25146/18

28 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-XIII 5997/S/S25146/18

29 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-XIV 5997/S/S25146/18

30 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-XV 5997/S/S25146/18

31 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-XVI 5997/S/S25146/18

32 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX B-XVII 5997/S/S25146/18

33 APPENDIX C CALIBRATION DETAILS STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX C-I 5997/S/S25146/18

34 TABLE C-1 INSTRUMENT CALIBRATION INFORMATION SEMA Asset No. Equipment Description Date Last Calibrated Calibration Due Date 704 Stopwatch 16-Jul Jan Gas Meter 13-Jul Jul Digital Temperature Reader 21-Mar Jan Thermocouple 13-Jul Jan Nozzle TSP Swagelok 3 06-Mar Mar Digital Manometer 07-Feb Feb Barometer 05-Feb Feb Pitot 24-May Balance 24-May-2019 Visually inspected On-Site before use Response Check with SEMA Site Mass 929 Calibrated Site Mass 21-Mar Mar Balance Response Check with SEMA Site Mass 946 Combustion analyzer 24-Jul Jan Personal Sampler 28-Sep Sep TSI Thermal Mass Flowmeter 07-May Nov Personal Sampler 21-Mar Mar-19 Gas Mixtures used for Analyser Span Response Conc. Mixture Cylinder No. Expiry Date 0.099% 9.8% 10.1% Carbon Monoxide Carbon Dioxide Oxygen In Nitrogen ALWB Jul-21 STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX C-II 5997/S/S25146/18

35 APPENDIX D SAMPLE LOCATIONS STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX D-I 5997/S/S25146/18

36 FIGURE D-1 SAMPLE LOCATION EPA ID POINT 2 Disturbance is the Stack Exit/Exhaust Duct Diameter 0.25m Sample Plane Upstream of Disturbance is 10.2m which is 2 Duct Diameters Total Number of Sampling Points is 4 Sampling Plane Sample Plane Downstream of Disturbance is 1.6m which is 6 Duct Diameters Flow Disturbance is a Bend (Expansion) In the absence of cyclonic flow activity ideal sampling plane conditions will be found to exist at 6-8 duct diameters downstream and 2-3 duct diameters upstream from a flow disturbance. The sampling plane does meet this criterion. The sampling plane does not comply with the minimum number of access points required. The minimum requirement for the above stack diameter is two four (4) inch access points at 90 degrees to each along the same sampling plane. Additional sample points were used in compliance with AS as the sampling plane was non-ideal. The location of the sampling plane complies with AS criteria for temperature, velocity and gas flow profile. STEPHENSON ENVIRONMENTAL MANAGEMENT AUSTRALIA APPENDIX D-II 5997/S/S25146/18