Appendix A – GLNG Environmental authority visible smoke

Appendix A – GLNG Environmental authority visible smoke

allowance review, prepared by KBR, dated July 2020

Santos GLNG l PFL 10 EPPG00712213 - Amendment Application l 26 August 2020

KBR Energy Solutions, Consulting

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The future, designed and delivered

GLNG OPERATIONS PTY LTD

GLNG ENVIRONMENTAL AUTHORITY

VISIBLE SMOKE ALLOWANCE REVIEW

THIRD-PARTY REVIEW

July 2020

92201-SAN-RT-A-00001

Revision: 0

REV DATE DESCRIPTION PREPARED CHECKED APPROVED QA

A 26/06/2020 Issued for GLNG Review F den Boer M McLean

B 10/07/2020 Re-issued for GLNG Review F den Boer M McLean

0 15/07/2020 Issued for Use F den Boer M McLean M McLean M McLean

RELIANCE NOTICE

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92201-SAN-RT-A-00001 Page 2 of 26 Revision: 0

July 2020

CONTENTS

ABBREVIATIONS 3

EXECUTIVE SUMMARY 4

INTRODUCTION 6

BASIS AND ASSUMPTIONS 7

3.1 Plant Flare Facilities 7

3.2 Definitions 7

3.3 LNG Plant Terminology 8

3.4 EA Flare Permit 9

3.5 Flare Ringelmann Readings 10

3.6 Measured Plant Data 10

NORMAL OPERATIONS 12

PLANNED MAINTENANCE 14

MAJOR SHUTDOWN / START-UP 17

PLANT UPSET EVENTS 20

TOTAL VISIBLE SMOKE FLARING ALLOWANCE AND MANAGEMENT 23

8.1 Total Visible Smoke Flaring Events 23

8.2 Comparison to QGC EA Permit 23

8.3 Visible Smoke Flaring Management 24

8.4 EA Permit Definition Recommendations 24

REFERENCES 26


July 2020

ABBREVIATIONS

APC Advanced Process Control

AS Australian Standard

BOG Boil-Off Gas

DES Department of Environment and Science

EA Environmental Authority

EDP Emergency Depressurisation

ESD Emergency Shutdown

ESDF Emergency Shutdown Inlet Feed

ESDP Emergency Shutdown Process

FG Fuel Gas

GLNG Gladstone Liquified Natural Gas

LNG Liquified Natural Gas

mtpa Millions of tonnes per annum

N2 Nitrogen

NRU Nitrogen Rejection Unit

PCV Pressure Control Valve

PSV Pressure Safety Valve

QCLNG Queensland Curtis Liquified Natural Gas

QGC Queensland Gas Company, operator for QCLNG facility

S Ringelmann Number

SDP Shutdown Process

TIAC Turbine Inlet Air Chilling System

XV Shutdown (Solenoid) Valve


July 2020

EXECUTIVE SUMMARY

The GLNG facility is equipped with an elevated pipe type flare and from time to time visible smoke is

produced, as a result of maintenance or plant upset operations. GLNG’s EA currently includes provisions for “visible smoke and particulate emissions” (black smoke) during normal operating

conditions, limited to no more than five minutes in any two hour period. However, no quantified

flaring limits have been specified for abnormal operating conditions e.g. planned maintenance, upset

conditions or shutdown / start-up. An allowance for visible smoke emissions during abnormal

operating conditions is required to reflect operating requirements at the LNG plant.

GLNG has undergone an internal exercise to identify operational scenarios which have historically

produced visible smoke emissions from the flare. This has included quantification of the expected

duration and frequency of each event with consideration of mitigation methods already employed at

the LNG plant. GLNG have requested KBR to perform a third-party review and endorsement of the

visible smoke scenarios and mitigations, which is the subject of this report.

GLNG have analysed flaring events from 4 May 2019 to 3 May 2020, as a typical year of operation,

including a major train shutdown and start-up. Events were categorised and visible smoke allowances

given for each type of event. ‘Visible’ smoke for the purposes of this review is smoke with a Ringelmann number greater than 2 occurring in daylight hours, with night-time events excluded. As

part of this review, the events and allowances were reviewed, considering other events which may

occur based on the plant configuration and experience with other plants. Reasonable visible smoke

allowances were given to each type of event, in order to allow safe and efficient plant operation

considering the installed facilities.

The proposed allowances per category of event are summarised in Table 1.1. Most events are of a

duration less than 30 minutes, however an allowance of up to 90 minutes is required in some

instances.

Table 1.1: Visible Smoke Flaring Allowance Summary

Category Events/yr Duration/yr

Normal Operations 0 0

Planned Maintenance 4 160 mins

Major Shutdown / Start-up 4 180 mins

Plant Upsets 7 130 mins

Total 15 470 mins (7.8 hrs)

These allowances are considered reasonable and reflect a balance between enabling safe and efficient

operation of the LNG plant and a strong drive to minimise visible smoke emissions affecting public

visual amenity.


July 2020

The actual number of visible smoke flaring events will vary significantly from year to year, depending

on the maintenance and shutdown work planned for that year, actual plant experience with

improperly functioning valves or other equipment, and the number of plant upsets experienced.

These tend to be somewhat random in occurrence, and long periods of no upsets may be followed by

several in short succession. The overall proposed visible smoke allowance is considered reasonable to

allow for what may occur in one year, based on the plant recent experience, the level of plant

equipment and complexity and GLNG personnel expertise to manage operations. It is expected that

in many years the actual number and duration of visible smoke events will be less than the total in

Table 1.1, however this may not always be the case.

The neighbouring QGC LNG plant has an amended EA Permit which allows up to 14 events and 7 hours

of visible smoke per year. The totals in Table 1.1 slightly exceed the QGC EA limits. It should be noted

that the estimated allowances are not precise, and are based on what may occur in one year. It is

expected that in many years a reduced allowance will be adequate, and careful sustained

management of flaring activities will allow operation within the QGC EA allowances.

Visible smoke flaring management includes:

• Trip reduction campaign, with every trip investigated and mitigations implemented to

prevent/minimise future trips.

• Transfer of refrigerant to an on-line compressor string (including to the other train if necessary),

rather than flaring.

• High rate flare purge to minimise lingering visible smoke after release of heavier hydrocarbons to

the flare system.

• Strategies to avoid/minimise requirement for plant defrosting outside of major shutdowns.

• Plan simultaneous flaring where feasible from multiple sources rather than separately.

• Plan for necessary flaring at night.

• Defer unplanned flaring till night-time where possible.


July 2020

INTRODUCTION

The Gladstone LNG (GLNG) plant is located at Curtis Island near Gladstone in Queensland, Australia

and is operated by GLNG Operations Pty Ltd on behalf of Joint Venture Participants including Santos,

PETRONAS, Total and KOGAS. The plant takes gas delivered from onshore gas fields and converts it

into LNG for sale. The plant commenced operation in 2015 and has a nameplate capacity of 7.8 mtpa

in two trains.

GLNG’s EA currently includes provisions for “visible smoke and particulate emissions” (black smoke) during normal operating conditions. However, no time or event flaring limits have been specified for

abnormal operating conditions e.g. planned maintenance, upset conditions, shutdown / start-up, etc.

An allowance for visible smoke emissions during abnormal operating conditions is required to reflect

operating requirements at the LNG plant.

GLNG has undergone an internal exercise to identify operational scenarios which have historically

produced visible smoke emissions from the flare. This has included identification of the expected

duration and frequency of each event with consideration of mitigation methods already employed at

the LNG plant.

GLNG have commissioned KBR to perform an independent third-party review of the visble smoke

events associated with operation of the LNG plant. The scope of the review includes:

• Review of the operating scenarios identified by GLNG and verification to GLNG historical flaring

events;

• Review of the frequency and duration of events; and

• Review of mitigation methods for reduction of visible smoke events.

The scope of the review is limited to visibility aspects of smoke (for public visual amenity impact) and

does not address health or safety aspects.

The purpose of this report is to document the findings of this review.


July 2020

BASIS AND ASSUMPTIONS

3.1 Plant Flare Facilities

The GLNG plant generally operates with no flaring apart from very minor flare pilots and flare purge

gas. Flaring is required from time to time, in order to safely perform maintenance activities and to

effectively manage plant upset scenarios including start-up, shutdown, trip events, etc.

The GLNG facility is serviced with 4 elevated flares:

• B-1901 Wet flare

• B-1902 Dry flare

• B-1903 Marine / Storage flare

• B-1906 Wet / Dry flare

The Wet, Dry and Wet / Dry flares share a common support structure and ancillaries. The Wet / Dry

flare is a common spare for the Wet and Dry flares and is not normally in use. These flares are elevated

and are subject to generate visible smoke when heavier hydrocarbons are combusted. Visible smoke

results from incomplete oxidation of heavier hydrocarbons, with some generation of carbon

particulates in addition to other combustion products. When flaring feed gas (or methane refrigerant

gas), negligible visible smoke generation is expected, as the feed gas is devoid of heavier hydrocarbons

for the GLNG facility (in contrast to many other LNG facilities). Flaring from the propane or ethylene

refrigerant circuits is expected to result in visible smoke, with some generation of carbon particulates

from these molecules.

The Marine / Storage flare is dedicated to boil-off gas from the LNG storage tanks and from LNG

tankers and associated equipment. This gas is normally essentially all methane, with a small amount

of nitrogen, and burns with a clean flame (Ringelmann number of 0 to 1).

3.2 Definitions

The review is based on Environmental Authority definitions (from Ref. 1 and 2) as follows.

“Normal operating conditions” means the ongoing operation of the LNG plant following commissioning and excludes start-up, shut-down, maintenance or calibration of emission monitoring

devices.

This definition is assumed to exclude ‘upset’ conditions, and LNG ship management is included in

‘normal operating conditions’ (from Ref. 2).

“Flaring event” means an event where flammable gas is combusted through a flare and produces

visible smoke continuously for more than 5 minutes. (Ref. 2).

“Visible smoke” means a visible suspension of carbon or other particles in air measured by a Ringelmann number greater than 2. (Ref. 2)


July 2020

Ringelmann scores are generally given in whole numbers from 0 (clear) to 5 (black), and therefore by

this definition visible smoke is a smoke intensity of Ringelmann score of 3, 4 or 5. However, quarter

numbers are allowed according to AS 3543 (see Section 3.5), and therefore “greater than 2” can be considered 2.25 or higher.

“Plant maintenance activities” means the maintenance shutdowns (and subsequent start-ups) where

equipment at the plant is inspected and, if needed, repaired or replaced to ensure the ongoing safe

operation of the plant (adapted from Ref. 2).

Based on Ref. 2 EA, flaring events are to be restricted if they occur in daylight hours, with night-time

flaring events being unrestricted. “Daylight hours” means those between sunrise and sunset times as

shown on the Australian Government Geoscience Australia webpage

<http://www.ga.gov.au/geodesy/astro/sunrise.jsp>. (Ref. 2).

From the EA Permit, flaring limits do not apply in the event of an emergency. An “emergency” is defined in Ref. 5, clause 466B as:

An emergency exists if—

(a) either—

(i) human health or safety is threatened; or

(ii) serious or material environmental harm has been or is likely to be caused; and

(b) urgent action is necessary to—

(i) protect the health or safety of persons; or

(ii) prevent or minimise the harm; or

(iii) rehabilitate or restore the environment because of the harm.

Specifically for the purposes of this review, an emergency event is considered to have occurred and

resulted in flaring in situations where the pressure in a system has reached PSV set pressure resulting

in a PSV lifting, or where a hydrocarbon release to atmosphere has occurred from an item of piping

or equipment, and depressurisation to flare is initiated in order to minimise and limit the release to

atmosphere. Events of this nature are not considered as subject to flaring limits.

3.3 LNG Plant Terminology

The GLNG LNG plant consists of two independent parallel processing facilities called trains. Each train

contains the gas processing and liquefaction facilities in order to produce LNG, using three

refrigeration cycles (based on propane, ethylene and methane). Refrigeration cycles are driven by gas

turbine powered compressors, arranged in two strings for each LNG train, with each string consisting

of three gas turbine driven compressors (one each for propane, ethylene and methane). An LNG train

may operate with either one or both strings operational. Each refrigerant compressor contains

multiple stages, operating at distinct pressure levels, in order to maximise plant efficiency.

http://www.ga.gov.au/geodesy/astro/sunrise.jsp


July 2020

At natural gas liquefaction temperatures, substances such as water or heavier hydrocarbons will

freeze and will tend to cause blockages within the liquefaction facilities. These substances may

potentially be introduced from the feed gas or when facilities are open to the atmosphere during

maintenance activities, and must be removed to ensure proper operation of the facilities. This is

achieved in a process called defrost (or dry out following maintenance), where warm dry feed gas is

used to vaporise these substances and remove them from the facilities. Defrost gas must be directed

to flare for safe disposal. The defrost procedure may also be used in order to warm up cold sections

of the plant in order to achieve a safe working temperature prior to maintenance activities.

In order to safely conduct intrusive maintenance activities on the LNG train facilities, hydrocarbons

must first be removed. Propane and ethylene refrigerants are transferred as far as practicable to

storage, another train or another compressor string. Remaining vapours need to be flared. Residual

vapour at atmospheric pressure is still hazardous and is purged from the facilities using nitrogen

vapour. Multiple purging steps are required to ensure all affected areas have a safe very low level of

hydrocarbons prior to intrusive maintenance work being conducted. Purged vapours (a mixture of

hydrocarbons and nitrogen) are safely disposed of to the plant flare.

Following completion of intrusive maintenance work, any oxygen which has entered the processing

facilities must be removed, and this is also achieved using a nitrogen purge. When oxygen content is

reduced to a very low level, hydrocarbons may be safely introduced. The first hydrocarbons

introduced may be defrost gas (warm dry feed gas), following which the defrost gas is displaced by

refrigerant in the propane and ethylene circuits.

3.4 EA Flare Permit

3.4.1 Current Regulations

The current EA Permit (Ref. 1) limits visible smoke according to clause B19:

(B19) Visible smoke and particulate emissions must not be permitted for more than five minutes in

any two hour period during normal operating conditions.

This clause is specifically applicable to normal operating conditions, and no specific guidance is given

for limitations associated with maintenance, start-up and shutdown operations. Due to the public

visibility of the flare however, public visual amenity may be affected by visible smoke events, and this

could be limited according to clause J1:

(J1) When the administering authority advises the holder of a complaint alleging environmental

nuisance, the holder must investigate the complaint and advise the administering authority in writing

of the action proposed or undertaken in relation to the complaint.

3.4.2 Visible Smoke Flaring Event

Visible smoke is not currently defined in the GLNG EA Permit. This review is premised on visible smoke

being defined as smoke of intensity greater than Ringelmann number 2, occurring in daylight hours

(from Ref. 2). Flare smoke events occurring at night are not quantified in this report.


July 2020

The definition of what constitutes ‘an event’ is important to properly quantify visible smoke

occurrences. Some events may result in sporadic flaring, with a valve to flare cycling through open

and closed positions. This should properly be considered as a single event, from a single initiating

cause. This should be clarified in the definitions, such that any allowance is not prematurely and

unreasonably exhausted. A proposed guideline is that: a single event may include multiple instances

of visible smoke appearance, provided that each instance of visible smoke occurs due to the same

underlying cause, discharges through the same valve or flare source and occurs within a two hour

window. (The two hour limit is derived from the criteria used for visible smoke allowance in normal

operations, and is considered a reasonable guideline without being overly restrictive or unlimited).

3.4.3 Visible Smoke in Normal Operations

Note that the current stipulation of EA clause B19 (Visible smoke and particulate emissions must not

be permitted for more than five minutes in any two hour period during normal operating conditions)

is assumed to remain with any revised EA Permit. This clause is not specific to daylight hours, and

therefore could be interpreted to also apply at night-time. Considering visible smoke affecting public

amenity is essentially a daytime issue, it would be reasonable to conclude that night-time flaring from

normal operations is acceptable, and has been assumed for this report.

3.5 Flare Ringelmann Readings

Visible smoke is defined in terms of a Ringelmann number, which is a method commonly used to

assess the opacity of flares and exhausts. The method requires a trained operator and is somewhat

subjective. To obtain consistent results as far as possible, the guidelines in Australian Standard AS

3543 (Ref. 3) should be followed.

The flare should be observed from a location:

• perpendicular to the direction of the plume (wind direction).

• at least 3 stack heights away from the flare base.

• have good lighting (sun at right angles to line of observation).

A video record allows later viewing and assessment of Ringelmann number and durations, which may

not be practicable for an operator required to perform other tasks at the time of flaring. The zoom on

the camera should be such as to obtain a similar reading as a manual standard reading under AS 3543

conditions.

Ringelmann (S) numbers are generally noted in whole numbers, though AS 3543 does allow estimation

to the nearest quarter number in favourable conditions.

3.6 Measured Plant Data

The GLNG plant has been operating for approximately 5 years, and can be considered to be in a stable,

mature operating phase, focused on continuous and incremental improvement and optimisation.

Operations are focused on minimising flaring due to the economic impact (particularly refrigerant is

expensive and main cause of visible smoke flaring) as well as the environmental and societal impact.


July 2020

Plant flaring data over a period of 1 year from 4 May 2019 to 3 May 2020 has been assessed by GLNG.

This data records the time, duration, intensity (Ringelmann number, S) and cause of the flaring that

occurred. In total, 188 flare entries were recorded. These entries were categorised into the following

categories:

• Normal operations;

• Planned maintenance;

• Major shutdown / start-up; and

• Plant upset events.

For this third-party review, the same categorisation was used, and mostly events were kept in the

same category, with some modifications to stay in line with definitions. Proposed allowances were

reviewed to determine if these were reasonable considering plant experience, possible mitigations

and controls, as well as experience on other plants. Allowances were adjusted in some instances to

better reflect plant requirements in the future. Events which were not experienced by GLNG over the

one year of recorded data, but which have occurred on other LNG plants and could reasonably occur

at GLNG based on the plant configuration, were also noted and added to the listing of possible events.

Note that historical data was assessed by GLNG based on S = 2 or greater. This provides a conservative

basis, as visible smoke is defined as S > 2, and therefore would not include readings of 2. This

conservatism is appropriate considering the subjective nature of smoke intensity readings, and the

possibility of intermediate Ringelmann number readings.

Visible smoke flaring mitigations have been considered for each flaring event according to the

following hierarchy:

1. Avoid /eliminate event occurring.

2. Minimise flaring amount and duration.

3. Perform flaring during night hours.

4. Perform flaring during daylight hours if essential.

This follows the premise that night-time flaring, while undesirable from an operational perspective,

will not be regulated and will not be subject to allowances. Activities resulting in visible smoke flaring

that can reasonably be conducted at night are therefore not given an allowance in the following

sections.

Visible smoke flare mitigation by major plant modifications and capital works is outside the scope of

this review.


July 2020

NORMAL OPERATIONS

As noted in Section 3.1, visible smoke flaring is generally not expected at the GLNG facility in normal

operations. The events recorded in Table 4.1 have been identified as occurring during normal

operations which may potentially result in visible smoke flaring. Note that short duration flaring (less

than 5 minutes per 2 hours) is not considered to constitute a flaring event (Section 3.4). As per Section

3.4, visible smoke is not permitted in normal operations, and therefore no allowances have been

made, with mitigations required to avoid this occurring. One of the mitigations is to perform flaring

activities at night, and this should be included as an allowable exception in any EA revision.

In the following tables, S is used as abbreviation for Ringlemann number (per Ref. 3.).

Table 4.1: Normal Operation Flare Events

Event Visible Smoke

Allowance Mitigation Comment

Propane Compressor

Start (compressor

casing drain)

0 events/yr Transfer to on-line

compressor string

(depressurise off-line

string).

Minor drainage (after

pressure reduction) will

generally not result in S

> 2.

Start-up at night.

Compressor start would generally be

associated with an upset or major

maintenance operation, however may

be classified as normal operation if

shutdown and start-up for production

planning reasons or minor

maintenance.

Procedure has been developed to

minimise flaring, though total

elimination is not possible.

Ethylene Compressor

Start (pressure

reduction maybe

required)

0 events/yr

Propane reclaimer

operation

0 events/yr

Efficient reclaimer

column operation will

minimise refrigerant

losses and visible smoke

generation. Most light

ends can be removed

with S < 2.

Operated at night

where possible.

Removing non-condensables

associated with a major shutdown

should be considered as part of

shutdown event. Reclaimer operation

for built up non-condensables e.g. N2

from seals or from refrigerant supply

can be considered normal operations.

This is a relatively rare event and can

be planned for night operation.

A leaking exchanger may cause a

significant increase in requirement for

reclaimer operation. This should still

be able to be managed nightly. Other

options e.g. piping to methane loop

could be considered.

Ethylene reclaimer

operation

0 events/yr

Propane refrigerant

delivery via tanker

0 events/yr Frequency of tanker

delivery has been

reduced with

implementation of seal

gas recovery.

Transfer hoses gravity

drained as far as

possible.

Flaring involved to purge transfer

hoses. Propane tankers are required

to be a day activity. Minor (low rate,

short duration) flare smoking as

propane progresses through flare

header, generally S < 2.


July 2020

Event Visible Smoke

Allowance Mitigation Comment

Ethylene refrigerant

delivery

0 events/yr Requirement minimised

with seal gas recovery.

Night activity.

Fuel Gas (FG) purge to

flare for compressor

restart (where FG

temperature less than

agreed limit)

0 events/yr

Duration expected to be

< 5 minutes Fuel gas purge should be S = 0 to 1

Vapour return line

maintain <0°C (BOG

control valve opening)

0 events/yr Duration expected to be

< 5 minutes BOG flaring should be S = 0 to 1

Gas up / cool down

(warm LNG ship) 0 events/yr

Generally non-visible (S

= 0 to 1)

Flaring of return vapour from the ship

is required until the dewpoint is less

than -90°C.

Generally project ships are used, with

residual LNG essentially methane.

Risk of occasional non-project ships

with significant heavies content in

future, which would result in

significant visible smoke flaring. This

has not occurred at GLNG to date.

This is a risk to be managed with ships

in this condition to be minimised.

Flaring to be conducted at night as far

as possible.

Heavies purge from

propane, ethylene

circuits

0 events/yr Make up refrigerant

specification to

minimise heavies

content.

Plan as night activity.

Possible requirement in future

(reduced purge with seal gas

recovery).

Bleed down pressure

in compressors when

shutdown (for

pressure control, not

part of re-start)

0 events/yr Generally not required

if pressures can be

contained.

Bleed to on-line

compressor string if

possible.

Plan as night activity if

required.

Can be required in some cases where

pressure is building up in compressor

circuit.

As summarised in Table 4.1, normal operation is generally conducted without visible smoke flaring.

Some events as noted in the table may result in minor flaring. Minor daytime visible smoke flaring is

consistent with the GLNG EA Permit clause B19 which allows visible smoke not exceeding 5 minutes

in a 2 hour period for normal operations. Flaring events will be planned to be conducted at night as

far as possible, though there is some risk that longer events will be required in daytime in order to

maintain safe and efficient operations (non-normal operation). This will be considered as a plant upset

event (allowances in Section 7).


July 2020

PLANNED MAINTENANCE

Planned maintenance includes all ongoing maintenance activities conducted on the LNG facilities to

ensure facilities are kept in a safe, efficient and proper operating state, outside of major shutdown

maintenance periods. These maintenance activities tend to be based on short to medium term

planning resulting from plant condition monitoring, and not from long term planning.

Planned maintenance events will involve visible smoke flaring in order to create a safe working

environment, and events and proposed allowances are summarised in Table 5.1.

Table 5.1: Planned Maintenance Flare Events

Event Visible Smoke

Allowance Mitigations Comments

Project based

maintenance

activities.

Flaring from

depressurisation

where required to

break containment.

0 events/yr

Project work to be

conducted in major

shutdown as far as

practicable (unless part

of a compressor string).

Conduct at night as far

as possible.

Minor project work is planned, and

associated flaring is conducted at

night.

Some risk of carryover work into day

hours.

Valve testing /

stroking / repair.

Flaring from

depressurisation

around valve.

2 events/yr,

40 mins

Valve maintenance

program during major

shutdowns to minimise

work between

shutdowns.

Valve stroking/testing

to be with blocked in

valve as far as possible

to avoid flaring.

Conduct activities at

night (not always

feasible).

Valve testing for the identification of a

passing valve, valve stroking to ensure

valves can act when required (i.e.

does not get stuck) and the planned

repair of known problematic valves.

Multiple valve stroking /

depressurisation to flare may be

required in some instances – should

be classified as 1 flare event.

Ethylene fan bank

internal inspection 0 events/yr

Depressurise to other

compression string.

Coincide with other

compressor

maintenance program

or major shutdown.

Conduct flaring at night.

Ethylene coolers included in

compressor isolations, may require

scheduled or unscheduled inspection

/ repair. To be included with other

compressor activity.

Propane fan bank

internal inspection 0 events/yr

Bank operated warm

prior to isolation to

minimise inventory.

Conduct flaring at night.

Configuration of propane condenser

does not allow each bank to be lined

up to flare, however temporary hoses

may be used for purging. This

requirement can be minimised by

operating bank warm and eliminating

condensed liquid prior to purging.


July 2020

Event Visible Smoke

Allowance Mitigations Comments

Turbine Inlet Air

Chilling System (TIAC)

maintenance

Flaring where

required to break

containment. For

purging non-

condensables and

potentially for

compressor start-up

0 events/yr

Transfer propane to on-

line machines.

Conduct at night as far

as possible.

TIACs provide additional capacity /

efficiency for the main refrigerant

drivers, and planned shutdowns are

possible whilst maintaining

production.

Some risk of carryover work into day

hours.

General maintenance

for refrigeration units

- XV repair,

inspections, strainer

cleaning, etc. Flaring

to depressurise

equipment to be

worked on.

1 event/yr, 90

mins

Train maintenance

generally planned for

major shutdown.

Conducted at night as

far as practicable.

XV repair may be covered by valve

repair above.

Allows for train shutdowns, with

partial train purging, defrosting.

Only 1 event allowed for, for

carryover from planned night-time

work into the day. Max duration of 90

minutes is reasonable to achieve full

purging (e.g. propane circuit).

P1601 defrost recorded S = 2, cold gas

can sometimes result in higher S

scores, possibly due to residual

refrigerant or accumulated heavies in

the process.

Defrosting as required

for hydrate / heavies

removal

1 event/yr, 30

mins

(One event

also allowed

for in major

shutdown)

Proper operation of mol

sieve beds to minimise

risk of water

accumulation.

Coincide with other

maintenance activity.

Operation at night (risk

of carryover into day).

Accumulation of heavies may be able

to be avoided using a dedicated layer

in the mol sieve beds – could be

considered in future if this is an

ongoing issue.

Operation should be S < 2 for the

main part of the flaring, however will

be higher when heavies are released.

Compressor start-up

after maintenance

activity. Flaring from

casing drains etc..

0 events/yr

Transfer to other string

or train if possible.

Start-up at night.

Similar to compressor start-up in

normal operations.

Can take ~35 mins.

Reclaimer operation

following

maintenance

0 events/yr

(Allowance for

displacement

given in major

shutdown)

Minimise volume of N2

ingress.

Efficient reclaimer

operation.

Operate at night.

May not always be practicable to

restrict to night operation. With

reclaimer properly running, low rate

venting from reclaimer can be

achieved with S < 2.

The total allowance is 4 events per year, with a total duration of 160 minutes.


July 2020

As in normal operations, no allowance is given for compressor start-up. The main mitigation should

be to transfer fluids from casings drains or excess pressure (if applicable) to another compressor

string. Procedures and minor modifications (e.g. bypass of check valves if required) to allow this

operation should be developed as required. Similarly an allowance is not given for reclaimer operation

as visible smoke should not be produced when this is operated efficiently.

The main mitigation for planned maintenance is to conduct essential flaring events at night as far as

possible. This may become overly restrictive in some cases, e.g. additional requirements are identified

during the day and need to be actioned to ensure safe work can continue. This is addressed under

valve testing / repair.

Historically GLNG have conducted flaring for defrost activities to manage accumulation of

components which may freeze inside equipment, and this requirement can be expected in the future.

It may not always be feasible to conduct this at night, and further work on feed gas treatment

processing to minimise the requirement for this activity may be considered.

Plant equipment in feed gas, LNG storage & loading and methane circuit are generally excluded –

flaring from these areas should be S = 0 to 1. Flaring from these areas may result in S = 2 to 3 in some

cases, as a result of residual heavies in the gas or associated with residual propane (or ethylene) in

the flare lines. At times this can result in visible smoke flaring in excess of 5 minutes and will need to

be carefully monitored. A mitigation method used by the plant is to temporarily increase the flare

purge rate following release of heavier gas / liquids into the flare line. In order to avoid additional

flaring (to reduce visible smoke), nitrogen sweep should be used where possible.


July 2020

MAJOR SHUTDOWN / START-UP

Major shutdown maintenance is conducted on each LNG train once every 4 years. This involves

complete shutdown of the train, gas freeing of the entire train and internal inspection / maintenance.

This is required for safety mandated inspections, to ensure the plant remains safe, efficient and

operable. As far as possible, preventative maintenance will be conducted during this shutdown, to

minimise the risk of train shutdowns in intervening periods. Flaring is reduced by minimising the

number of shutdowns as far as practicable. This shutdown will typically be over a period of weeks and

is followed by removal of air and moisture which may have entered piping and equipment using

nitrogen followed by defrost gas (dry, warm feed gas). Refrigerants can then be introduced and the

train restarted.

Visible smoke events and allowances are summarised in Table 6.1. Allowances are on a per year basis,

(similar to the QGC EA Permit allowances which are on an annual basis). A major shutdown is not

required every year (typically every second year), and this will result in a greater allowance for

planned maintenance and other events in non-shutdown years.

Table 6.1: Major Shutdown / Start-up Flare Events

Event

Visible smoke

allowance

GLNG request

Mitigations Comments

Propane de-inventory

for a train 0 events

Recovery to online train

minimises flaring

required.

Planned night activity

Ensure all liquid is drained from all

points prior to flaring.

Consider possibility to line up to low

stage in on-line train to allow recovery

of propane vapour.

Propane de-inventory

for a train - purges

1 event/yr

90 minutes


(risk of carryover to day-

time)

Risk of carryover into day, e.g. if

effective isolation has not been

achieved at all points.

Flare allowance for carryover into day

(share allowance with ethylene). Later

purges with high N2 concentration

should have S < 2. An allowance of 90

minutes for purging of an entire

system is appropriate.

Note that each purge is considered a

separate flaring event due to the time

interval between purges.

Ethylene de-inventory

for a train 0 events

Recovery to online train

minimises flaring

required.


Consider possibility to line up to low

stage in on-line train.

Ethylene de-inventory

for a train - purges

(incl. in

propane

purge

allowance)


Risk of carryover into day, e.g. if

effective isolation has not been

achieved at all points. Purging should

be able to be simultaneous with

propane system if planned.


July 2020

Event

Visible smoke

allowance

GLNG request

Mitigations Comments

Warm up/ defrost (to

allow safe working on

cold equipment)

1 event/yr

30 mins

Mostly at night and with

S = 0 to 1, however may

be periods with S > 2

when accumulated

heavies are displaced.

Not always required (e.g. 2018). Total

expected duration is 18 hours.

Potential to partially warm up using

compressor circulation can be

considered.

Dry out/ defrost to

remove any water

which may have

entered equipment

0 events/yr

Procedures to ensure

water is properly

drained prior to defrost

operations.

Use N2 sweep where

safe to do so during

shutdown.

Plan for night, however

typically extends to

daytime.

Required procedure to remove

moisture prior to restart to ensure

restart can be conducted without

formation of hydrates.

Defrost gas is warm, dry feed gas,

expect S = 0 to 1.

Propane re-inventory

(gas displacement to

remove defrost gas)

1 event/yr

30 mins

Use reclaimer as soon

as possible following

main gas displacement

to minimise refrigerant

loss and visible smoke.

Keep daytime use < 5

mins where possible

(risk of lingering visble

smoke from heavies in

flare line).


Initial displacement direct to flare,

followed by reclaimer operation for

residual gas removal. May require

multiple valve openings – considered

one event per start-up (per 2 hours).

High system pressures may require

immediate purging to flare (cannot

wait for night-time).

Ethylene re-inventory

(gas displacement to

remove defrost gas)

1 event/yr

30 mins

Cooldown and start-

up 0 events/yr

Flash gas rate to be

maintained within

methane compressor

capacity as far as

possible.

Flaring expected to be S

= 0 to 1 associated with

feed gas

Risk of visible smoke expected to be

low.

In total, 4 visible smoke events are allowed per major shutdown and start-up, with a total of 180

minutes of visible smoke. These are partly associated with the start-up, when gases introduced into

the refrigerant circuit must be purged to prevent excessive pressures being generated and proper

operation of the refrigerant systems. One event associated with over-run of planned night-time

activity into daytime is also allowed. This is reasonable considering the duration required for 5 purges

of the refrigerant circuits in order to achieve a low concentration of hydrocarbons. One event is also

associated with warm-up or defrost, which is similar to the defrost allowance in planned maintenance

(Table 5.1).


July 2020

Major shutdowns, particularly if extensive internal work is involved, are typically associated with

higher volumes of gas being flared in order to safely manage the transition from a closed, pressurised

refrigerant system to an open, atmospheric system suitable for safe work and then back again.

Managing these transitions with 4 relatively brief periods of daytime flaring will require careful

planning particularly for the shutdown and de-inventory activities, to avoid the requirement for

daytime flaring. The requirement for systems to be opened to atmosphere should be minimised as far

as possible, using risk based inspection and non-intrusive inspection techniques. Systems which have

been opened to atmosphere should be sealed as soon as work is completed and defrost commenced

with N2 if possible.

An allowance of 4 flaring events is associated with specific events, however it is assumed that this

allowance can be used in any combination of events as requirements are not fully predictable and will

change as the particular requirements for each shutdown / start-up materialise.

There is a risk that two major shutdowns occur in one year, though this would not normally be

planned. A second shutdown may occur in case of equipment failure, or may be opportunistic e.g. in

case of enforced shutdown due to gas supply or demand issues. Work on common equipment such

as common flare headers and flare stack may require simultaneous shutdown of both trains. This is

not currently allowed for, and may need to be negotiated at the time (for example transfer of some

allowance from one year to another).


July 2020

PLANT UPSET EVENTS

Plant upset events occur from time to time and are generally a result of the programmed actions

taken by control or safety systems, not intentionally caused by an operator. They may result from

instrumentation failure, poor response of the control system to a particular event, inadvertent action

by an operator or by maintenance personnel, etc.

Plant upset events do not include emergency events (excluded from flaring limits – see Section 3.2),

which includes events such as gas releases to atmosphere and PSV lifting.

Plant upset events recorded at the GLNG facility and other potential events are summarised in

Table 7.1. Note that for this table, visible smoke allowance in this case covers all recorded events, day

and night and will be adjusted later.

Table 7.1: Plant Upset Flare Events

Event Visible smoke

allowance1 Mitigations Comments

ESDF (black start) 1 event/yr

15 mins Minimise number of

events.

EDP valves not designed

to open for ESD upset,

except for compressor

valves depending on

scenario.

ESD initiation does not necessarily

directly result in flaring, however may

occur due to related events such as

EDP valve opening (e.g. compressors),

PCV opening for rising pressures – to

be minimised by control tuning and

setpoint adjustment.

Flaring required for restart.

ESDP 2events/yr

30 mins

SDP 1 event/yr

15 mins

Minimise number of

events.

Valves to flare not

designed to open on

SDP, system designed to

contain gas.

Most flaring expected to be S = 0 to 1

from methane system. Sometimes

recorded as S = 2

Flaring required for restart

Compressor trip 1 event/yr

15 min

Minimise number of

events.

Flaring minimised when

trip occurs (< 5 mins).

Trip of refrigerant compressors may

result in visible smoke flaring.

Compressor restart may also incur

flaring.

(Event originally based on BOG

compressor trip, with S=3 which is

unlikely to be accurate. Scenario

expanded to consider other

compressors).

Leaking valve /

inadvertent valve

operation - general

0 events/yr

Generally results in non-

visible smoke flaring.

Flaring contained to < 5

mins.

Recorded events occurred on feed gas

/ BOG, with S = 0 to 1. Events on

refrigerant circuits are also possible

(assume covered elsewhere).

Upset during start-up /

start-up following ESD

/ SDP

2events/yr

30 min

Flaring generally

contained to < 5 mins.

Start-up procedure

minimises flaring.

Risk of longer duration events,

complications during restart.

Includes compressor restart allowance

from other events.


July 2020

Event Visible smoke

allowance1 Mitigations Comments

Emergency

depressurisation /

control valve failure

1 events/yr

20 mins

Flaring contained to < 5

mins (close manual

valve if possible).

Position indicators on

EDP valves to alert

operator.

Valve maintenance

program.

Valve failures generally detected and

isolated quickly.

PSV failure /

premature lifting

1 events/yr

45 mins

Regular PSV

maintenance.

Instrumented

protection systems

minimise occurrence of

PSVs opening.

Spare PSV required to be brought on-

line prior to isolating a PSV – may be

difficult to achieve quickly (also

determination of which PSV is leaking

may take some time). Frequency

expected to be low (< 1/yr).

Upset during LNG ship

loading e.g. off spec

gas, high tank pressure

0 events/yr

Loading procedures,

particularly during

ramp-up, minimise

flaring

BOG flaring generally S = 0 to 1

Gas turbine upset 1 event/yr

15 mins

Minimise number of

events.

Operator response to

minimise durations.

Flaring may result from Unit 16 flash

vessels due to rising pressures.

Generally expect S = 0 to 1 for feed

gas flaring, however can be recorded

as S = 2 on some occasions. Propane,

ethylene gas turbine trips may also

result in flaring.

Repairs for fan bank

leaking tubes 0 events/yr

Planned maintenance /

inspection.

Flaring at night for

purging.

Leak to atmosphere constitutes an

emergency situation, and priority is to

make the situation safe, not on flare

minimisation.

Event relates to flaring due to purging,

i.e. after isolations are achieved. This

should be a planned night-time event.

NRU off-specification 0 events/yr APC / operator training

to minimise upsets

Occurred on numerous occasions,

however S = 0 to 1.

Notes:

1. Includes allowance for day and night-time events.

The total allowance is 10 events/yr to a total of 185 minutes. These events are both day and night-

time, and it is estimated that 70% of these events occur during the daytime (related to higher

personnel activity). This results in a daytime visible smoke allowance of 7 events/yr to a total of 130

minutes. Most events are relatively short duration (~ 15 minutes), however in some cases the duration

is extended due to time for detection and potential complications occurring with the event. PSV

failures are expected to be low frequency. A longer allowance is retained as an annual allowance as

this may occur in a given year, and this allowance also provides for other events which may require

additional time to rectify and end flaring.


July 2020

Plant upset events cannot be mitigated by planning for night-time operation, and a major mitigation

is avoidance of the event in the first place. GLNG have formed a reliability team tasked with event

investigation and mitigations, and this is appropriate to avoid upsets as far as possible. Each trip event

should be properly investigated, and mitigations implemented to avoid/minimise future occurrences.


July 2020

TOTAL VISIBLE SMOKE FLARING ALLOWANCE AND MANAGEMENT

8.1 Total Visible Smoke Flaring Events

Based on the event allowances in Sections 4 to 7, the total visible flaring allowance is summarised in

Table 8.1.

Table 8.1: Visible Smoke Flaring Allowance Summary

Category Events/yr Duration/yr

Normal Operations 0 0

Planned Maintenance 4 160 mins

Major Shutdown / Start-up 4 180 mins

Plant Upsets 7 130 mins

Total 15 470 mins (7.8 hrs)

The total number of flare entries over a one year period (4 May 2019 to 3 May 2020) was 188. Many

of these events were at night, or with a non-visible smoke flare (S = 0 to 1). Remaining entries were

further rationalised by further planning events to be conducted at night and revising procedures to

minimise visible smoke flaring, to achieve a final allowance of 15 events. In order to achieve the

proposed visible smoke limits, careful management of operations will be required.

The actual number of visible smoke flaring events will vary significantly from year to year, depending

on the maintenance and shutdown work planned for that year, actual plant experience with

improperly functioning valves or other equipment, and the number of plant upsets experienced.

These tend to be somewhat random in occurrence, and long periods of no upsets may be followed by

several in short succession. The proposed allowances should therefore be seen as indicative of what

may occur and should be flexible to be used for whatever event actually occurs in any given year. The

overall proposed visible smoke allowance is considered reasonable to allow for what may occur in one

year, considering the plant recent experience, the level of plant equipment and complexity and GLNG

personnel expertise to manage operations.

8.2 Comparison to QGC EA Permit

Visible smoke flaring limits have been established for the neighbouring QCLNG facility in their EA

Permit (Ref. 2), in essence clauses B12 and B13:

(B12) Flaring events, except for those resulting from an emergency, occurring outside of normal

operating conditions must not exceed:

a) 7 hours per annum during daylight hours; and

b) 14 times per annum during daylight hours; and

c) 30 minutes of continuous visible smoke during daylight hours except as authorised under condition

(B13).


July 2020

(B13) Notwithstanding condition (B12)(c), individual flaring events must not exceed 90 minutes of

continuous visible smoke in the following circumstances:

a) A flaring event associated with a plant maintenance activity that was planned to be completed

outside of daylight hours, but was required to be undertaken during daylight hours to ensure the safe

operation of the plant; or

b) A flaring event associated with a plant maintenance activity that was not planned and was required

to be undertaken during daylight hours to ensure the safe operation of the plant.

The key limitations are a maximum of 7 hours (cumulative) of flaring per annum, and no more than

14 times or events. In most cases an individual flaring event should be less than 30 minutes but could

be up to 90 minutes duration in some cases.

The totals in Table 8.1 slightly exceed the QGC EA limits. It should be noted that the estimated

allowances are not precise, and are based on what may occur in one year. It is expected that in many

years a reduced allowance will be adequate, and careful sustained management of flaring activities

will allow operation within the QGC EA allowances.

8.3 Visible Smoke Flaring Management

In order to stay within any visible smoke flaring allowance, mitigations as noted in Sections 4 to 7

should be considered. Visible smoke flaring management includes:

• Trip reduction campaign, with every trip investigated and mitigations implemented to

prevent/minimise future trips.

• Transfer of refrigerant to an on-line compressor string (including to other train if necessary) rather

than flaring.

• High rate flare purge to minimise lingering visible smoke after release of heavier hydrocarbons to

the flare system.

• Strategies to avoid/minimise requirement for plant defrosting outside of major shutdowns.

• Plan simultaneous flaring where feasible from multiple sources rather than separately.

• Plan for necessary flaring at night.

• Defer unplanned flaring till night-time where possible.

8.4 EA Permit Definition Recommendations

It is recommended that any EA Permit revision for GLNG include the following clarifications for

definition of key terms.

1. ‘Normal operating conditions’ should be clarified to exclude ‘upset’ conditions, and include LNG ship management.

2. “Plant maintenance activities” should not be restricted to major shutdowns, and include more

minor plant maintenance. It is recommended to not include ‘major’ in the definition in any EA

Permit revision for GLNG.


July 2020

3. A single visible smoke flaring event should be clarified as potentially including multiple

instances of visible smoke appearance, provided that each instance of visible smoke occurs

due to the same underlying cause, discharges through the same valve or flare source and

occurs within a two hour window.

4. The current EA stipulation of visible smoke flaring for normal operations limited to a

maximum of 5 minutes in any 2 hours should be clarified as applying in daylight hours only.


July 2020

REFERENCES

1. Permit, Environmental Protection Act 1994, Environmental Authority EPPG00712213, for GLNG,

11 February 2019.

2. Permit, Environmental Protection Act 1994, Environmental Authority EPPG00711513, for QC LNG

Operating Company Pty Ltd, 29 June 2018.

3. Use of standard Ringelmann and Australian Standard miniature smoke charts, Australian Standard

AS 3543:2014

4. Flare Documentation from GLNG Operations, Received via email from R McLaughlin 6 June 2020,

including EA Amendment Proposal.pdf, EA Amendment Table v1.xlsx and supporting

documentation.

5. Queensland Environmental Protection Act 1994

Appendix B – GLNG: Air Quality Assessment of Dry and Wet

Flares, prepared by Katestone, dated July 2020


GLNG: Air Quality Assessment of Dry and

Wet Flares

Prepared for:

Santos

August 2020

Final

Prepared by:

Katestone Environmental Pty Ltd

ABN 92 097 270 276

Ground Floor, 16 Marie Street | PO Box 2217

Milton, Brisbane, Queensland, 4064, Australia

www.katestone.global

[email protected]

Ph +61 7 3369 3699

Disclaimer

https://katestone.global/report-disclaimer/

Copyright

This document, electronic files or software are the copyright property of Katestone Environmental Pty. Ltd. and the information contained therein is solely for the use of the authorised recipient and may not be used, copied or reproduced in whole or part for any purpose without the prior written authority of Katestone Environmental Pty. Ltd. Katestone Environmental Pty. Ltd. makes no representation, undertakes no duty and accepts no responsibility to any third party who may use or rely upon this document, electronic files or software or the information contained therein.

© Copyright Katestone Environmental Pty. Ltd.

Document Control

Deliverable #: D19116-3

Title: GLNG: Air Quality Assessment of Dry and Wet Flares

Version: 1.0 (Final)

Client: Santos

Document reference: D19116-3_Santos_GLNG_Flare.docx

Prepared by:

Reviewed by:

Approved by:

04/08/2020

Katestone Environmental Pty Ltd D19116-3 Santos – GLNG: Air Quality Assessment of Dry and Wet Flares – Final

4 August 2020

Page i

Contents

Executive Summary ........................................................................................................................................ v 1. Introduction ....................................................................................................................................... 1 2. Dry and wet gas flares ..................................................................................................................... 2

2.1 Overview ............................................................................................................................................. 2

2.2 Air pollutants........................................................................................................................................ 2

2.3 Scenarios ............................................................................................................................................. 2

2.4 Emissions .............................................................................................................................................. 4

3. Legislative context............................................................................................................................ 8 4. Assessment methodology .............................................................................................................. 10

4.1 Overview ........................................................................................................................................... 10

4.2 Dispersion modelling ......................................................................................................................... 10

4.2.1 Flares .................................................................................................................................. 10

4.2.2 Other plant equipment .................................................................................................... 11

4.2.3 NOx to NO2 conversion .................................................................................................... 12

4.3 Presentation of results ....................................................................................................................... 12

4.4 Cumulative impacts ......................................................................................................................... 14

5. Dispersion modelling results ........................................................................................................... 15 5.1 Flares in isolation ............................................................................................................................... 15

5.2 Flare including background............................................................................................................. 25

6. Conclusions ..................................................................................................................................... 29 7. References ...................................................................................................................................... 31 Appendix A Shutdown/startup scenarios ............................................................................................ 35

A1 Flared gas quantities, mass rates, and duration of events ............................................................ 35

A2 Emissions summary ............................................................................................................................ 39

A3 Other plant equipment .................................................................................................................... 41

Appendix B Meteorological and dispersion modelling methodology............................................. 43 B1 Development of site-specific meteorology .................................................................................... 43

B1.1 TAPM meteorological simulations .................................................................................... 43

B1.2 CALMET meteorological simulations................................................................................ 44

B2 CALPUFF dispersion modelling methodology ................................................................................. 45

B2.1 Model configuration ......................................................................................................... 45

B2.2 Other plant source characteristics .................................................................................. 45

Appendix C – Dispersion modelling results ................................................................................................. 47

Tables

Table 1 Major shutdown / startup scenarios ...................................................................................................... 3

Table 2 Emission factors and emission rates for the dry and wet gas flare scenarios ..................................... 4

Table 3 Composition of hydrocarbon emissions from the flare based on US EPA AP-42 emission factors .... 4

Table 4 Emission factors for particulate matter based on Equation 1 - McEwen et al. (2012) ....................... 5

Table 5 Emission factors for PAHs ........................................................................................................................ 5

Table 6 Emission rates of NOx, CO, particulates and total hydrocarbons (g/s) .............................................. 6

Table 7 Emission rates of PAHs (g/s) .................................................................................................................... 7

Table 8 Ambient air quality objectives (Air EPP) ................................................................................................ 8

Table 9 Relevant ambient air quality objectives and standards for hydrocarbons ....................................... 9

Table 10 Source characteristics for each dispersion modelling scenario ....................................................... 10

Table 11 Other plant equipment included in the assessment .......................................................................... 11

Table 12 Location of sensitive receptors ............................................................................................................ 12

Table 13 Background concentrations used in modelling assessment ............................................................. 14

Table 14 Predicted ground-level concentrations of NO2, CO, particulates and hydrocarbons due to Scenario

1 (flare in isolation) ................................................................................................................................ 16

Table 15 Predicted ground-level concentrations of PAHs due to Scenario 1 (flare in isolation) ................... 17


2 (flare in isolation) ................................................................................................................................ 19

Table 17 Predicted ground-level concentrations of PAHs due to Scenario 1 (flare in isolation) ................... 20


4 August 2020

Page ii


3 (flare in isolation) ................................................................................................................................ 22 Table 19 Predicted ground-level concentrations of PAHs due to Scenario 1 (flare in isolation) ................... 23 Table 20 Predicted cumulative impacts of NO2, CO, PM10 and PM2.5 for Scenario 1 ..................................... 26 Table 21 Predicted cumulative impacts of NO2, CO, PM10 and PM2.5 for Scenario 2 ..................................... 27 Table 22 Predicted cumulative impacts of NO2, CO, PM10 and PM2.5 for Scenario 3 ..................................... 28

Table A1 Major shutdown/start up and upset scenarios (1) ............................................................................. 35 Table A2 Major shutdown/start up and upset scenarios (2) ............................................................................. 36 Table A3 Major shutdown/start up and upset scenarios (3) ............................................................................. 37 Table A4 Major shutdown/start up and upset scenarios (4) ............................................................................. 38 Table A5 Major shutdown/start up and upset scenarios (5) ............................................................................. 39 Table A6 Summary of other plant equipment .................................................................................................... 41 Table A7 Stack characteristics of GLNG Plant included in the assessment ..................................................... 46

Table C1 Predicted concentrations of NO2, CO and PM10/PM2.5 in isolation, with plant and with plant and

background for Scenario 1 .................................................................................................................. 48 Table C2 Predicted concentrations of NO2, CO and PM10/PM2.5 in isolation, with plant and with plant and

background for Scenario 2 .................................................................................................................. 49 Table C3 Predicted concentrations of NO2, CO and PM10/PM2.5 in isolation, with plant and with plant and

background for Scenario 3 .................................................................................................................. 50

Figures

Figure 1 GLNG and sensitive receptors ............................................................................................................. 13

Figure A1 Summary of emission rates for all flare scenarios considered ........................................................... 40

Contour Plates

Plate 1 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 1 – 2019

major shutdown: single train propane system de-inventory for planned maintenance activities (flare

in isolation) ............................................................................................................................................ 32 Plate 2 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 1 – 2019


in isolation) ............................................................................................................................................ 33 Plate 3 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 1 – 2019


in isolation) - all PM10 is assumed to be PM2.5 ...................................................................................... 34

Plate C1 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 1 – 2019


in isolation) ............................................................................................................................................ 52 Plate C2 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 1 – 2019


+ GLNG plant + GAMS background) .................................................................................................. 53 Plate C3 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 1 – 2019


in isolation) ............................................................................................................................................ 54 Plate C4 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 1 – 2019


+ GLNG plant + ambient background) .............................................................................................. 55 Plate C5 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 1 – 2019


in isolation). All PM10 is assumed to be PM2.5. ..................................................................................... 56 Plate C6 Predicted maximum 24-hour average ground level concentrations of PM10 due to Scenario 1 – 2019


+ GLNG plant + ambient background) .............................................................................................. 57


4 August 2020

Page iii

Plate C7 Predicted maximum 24-hour average ground level concentrations of PM2.5 due to Scenario 1 – 2019


+ GLNG plant + ambient background) .............................................................................................. 58 Plate C8 Predicted maximum 1-hour average ground level concentrations of fluoranthene due to Scenario 1

– 2019 major shutdown: single train propane system de-inventory for planned maintenance activities

(flare in isolation)................................................................................................................................... 59 Plate C9 Predicted maximum 1-hour average ground level concentrations of propylene due to Scenario 1 –

2019 major shutdown: single train propane system de-inventory for planned maintenance activities

(flare in isolation)................................................................................................................................... 60 Plate C10 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 2 – 2016


in isolation) ............................................................................................................................................ 61 Plate C11 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 2 – 2016


+ GLNG plant + GAMS background) .................................................................................................. 62 Plate C12 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 2 – 2016


in isolation) ............................................................................................................................................ 63 Plate C13 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 2 – 2016


+ GLNG plant + ambient background) .............................................................................................. 64 Plate C14 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 2 – 2016


in isolation). All PM10 is assumed to be PM2.5. ...................................................................................... 65 Plate C15 Predicted maximum 24-hour average ground level concentrations of PM10 due to Scenario 2 – 2016


+ GLNG plant + ambient background) .............................................................................................. 66 Plate C16 Predicted maximum 24-hour average ground level concentrations of PM2.5 due to Scenario 2 – 2016


+ GLNG plant + ambient background) .............................................................................................. 67 Plate C17 Predicted maximum 1-hour average ground level concentrations of fluoranthene due to Scenario 2

– 2016 major shutdown: single train propane system de-inventory for planned maintenance activities

(flare in isolation)................................................................................................................................... 68 Plate C18 Predicted maximum 1-hour average ground level concentrations of propylene due to Scenario 2 –


(flare in isolation)................................................................................................................................... 69 Plate C19 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 3 – Upset

event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation) ........................ 70 Plate C20 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 3 – Upset

event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + GAMS

background) ......................................................................................................................................... 71 Plate C21 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 3 – Upset

event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation) ........................ 72 Plate C22 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 3 – Upset

event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + ambient

background) ......................................................................................................................................... 73 Plate C23 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 3 – Upset

Train 1 Propane and Ethylene Valves Open to Flare (flare in isolation). All PM10 is assumed to be PM2.5.

............................................................................................................................................................... 74 Plate C24 Predicted maximum 24-hour average ground level concentrations of PM10 due to Scenario 3 – Upset

event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + ambient

background) ......................................................................................................................................... 75 Plate C25 Predicted maximum 24-hour average ground level concentrations of PM2.5 due to Scenario 3 –

Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + ambient

background) ......................................................................................................................................... 76 Plate C26 Predicted maximum 1-hour average ground level concentrations of fluoranthene due to Scenario 3

– Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation) ........... 77 Plate C27 Predicted maximum 1-hour average ground level concentrations of propylene due to Scenario 3 –

Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation) ............. 78


4 August 2020

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Glossary

Term Definition

µg/m3 micrograms per cubic metre

°C degrees Celsius

g/s gram per second

km kilometre

kg PM/103 m3 kilogram of particulate matter per 1000 cubic metres

kg/Sm3 Kilogram per standard cubic metre

m/s metres per second

MJ/hour megajoules per hour

MJ/m3 megajoule per cubic metres

m3/s cubic metres per second

Sm3/h Standard cubic metre per hour

t/h Tons per hour

Nomenclature Definition

CO carbon monoxide

CO2 carbon dioxide

NO2 nitrogen dioxide

NOx oxides of nitrogen

PAHs Polycyclic aromatic hydrocarbons

PM10 particulate matter with a diameter less than 10 micrometres

PM2.5 particulate matter with a diameter less than 2.5 micrometres

Abbreviations Definition

Air EPP Environmental Protection (Air) Policy 2019

DES Department of Environment and Science

EDP Emergency depressurisation

ESDP Emergency shutdown process

GLNG Gladstone Liquid Natural Gas facility

LNG Liquified natural gas

NRU Nitrogen rejection unit

SDP Shutdown process


4 August 2020

Page v

EXECUTIVE SUMMARY

Katestone Environmental Pty Ltd (Katestone) was commissioned by Santos to conduct an air quality

assessment associated with the operation of flares at its Gladstone LNG facility (GLNG).

GLNG is operated under Environmental Authority Number EPPG00712213. Schedule B details conditions

relating to air emissions and conditions B16 to B20 relate to flares.

There is a potential for smoke to occur due to flaring at GLNG during planned and unplanned plant maintenance

and emergency situations. Major shutdowns are typically planned to occur once every four years per train.

An air quality assessment was conducted to quantify the emissions associated with the flares when they emit

smoke and the potential impact of those emissions on the receiving environment.

The key air pollutants emitted from the dry and wet gas flares at the GLNG facility were found to be:

• Oxides of nitrogen (NOX)

• Carbon monoxide (CO)

• Hydrocarbons including:

o Methane

o Ethane/ethylene

o Acetylene

o Propane

o Propylene

• Particulate matter in the form of PM2.5 and PM10 (flare gases containing propane and ethylene)

• Polycyclic Aromatic Hydrocarbons (PAHs) (flare gases containing propane and ethylene).

Katestone considered a range of potential emission scenarios and has identified three key scenarios for further

assessment through dispersion modelling. They are as follows:

• Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance

activities


activities

• Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open.

These scenarios were identified for detailed dispersion modelling being the scenarios with maximum potential

for impact as:

• Scenario 1 and Scenario 2 represent the worst-case smoking flare scenarios due to the high propane

content associated with shutdown of a train.

• Scenario 3 represents the worst-case methane emissions as a result of an upset.

A conservative dispersion modelling assessment was conducted to determine the potential impacts due to

flaring operations. The assessment is conservative because it is based on the following assumptions:

• All flaring events have been assumed to occur continuously at their maximum intensity for 24-hours.

In reality, a flaring event may occur over a number of minutes or up to 24-hours.

• All other plant and equipment at GLNG operates at the same time as the flaring event. In reality, the

smoke events are typically associated with the shutdown of one processing train and, therefore,

emissions from other plant and equipment will be reduced.

Dispersion modelling of these scenarios found the following:


4 August 2020

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• Predicted ground-level concentrations NO2, CO, PM10 and PM2.5 as well as hydrocarbons were well

below the relevant air quality objectives at all sensitive receptors (including residential receptors and

protected areas).

• Predicted ground-level concentrations of PAHs were well below the relevant air quality objectives at all

sensitive receptors (including residential receptors and protected areas).


4 August 2020

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1. INTRODUCTION

Katestone Environmental Pty Ltd (Katestone) was commissioned by Santos to conduct an air quality assessment

associated with the operation of flares at its Gladstone LNG facility (GLNG).

GLNG is operated under Environmental Authority Number EPPG00712213. Schedule B details conditions relating

to air emissions and conditions B16 to B20 relate to flares.


and emergency situations. Major shutdowns are typically planned to occur once every four years per train. Santos

requires an air quality assessment to quantify the emissions associated with the flares when they emit smoke and

the potential impact of those emissions on the receiving environment.

This report details:

• Operation of the dry and wet gas flares and likely emissions (Section 2)

• Legislative context (Section 3)

• Assessment methodology (Section 4)

• Dispersion modelling results (Section 5)

• Conclusions (Section 6).


4 August 2020

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2. DRY AND WET GAS FLARES

2.1 Overview

The principle function of the wet and dry gas flares is to safely dispose of excess gas from the process. The flare

combusts the gases and the products of combustion are emitted to the atmosphere. Flaring occurs in the event of

an area blowdown due to plant maintenance, or due to a plant emergency such as a fire or blocked outlet (e.g.

inadvertent closure of a valve).

Wet and dry gas flares are provided to support the operational and emergency venting requirements of the process

facilities. The wet gas flare system is connected to the front end of the LNG train and typically processes the

blowdown of wet, warm hydrocarbon gases and some refrigerants, while the dry gas flare system is connected to

the rear end of the LNG train and processes the blowdown of dry, cold hydrocarbon gases. A common structure

supports the two flare stacks and a common spare flare stack.

2.2 Air pollutants

The key air pollutants emitted from the dry and wet gas flares at the GLNG facility are as follows:



• Total hydrocarbons

o Methane

o Ethane/ethylene

o Acetylene

o Propane

o Propylene

• Particulates in the form of PM2.5 and PM10 (flare gases containing propane and ethylene)


The flared gases do not include compounds containing sulfur and, therefore, sulfur related compounds (e.g. sulfur

dioxide) are not likely to be emitted from the flares.

The amount of each pollutant emitted from the flare depends on the amount of and composition of the gas being

flared. A summary of dry and wet gas flare scenarios considered are summarised in Section 2.3.

2.3 Scenarios

Santos conducted a review of the major shutdown/startup and upset scenarios that have occurred over the last

four years. A summary of the major shutdowns and upset scenarios is presented in Appendix A. Three scenarios

were identified for detailed dispersion modelling assessment being the scenarios with maximum potential for

impact. These are summarised in Table 1. The summary includes the mass flow of fuel, expected duration of

flaring and energy content for each flare. These scenarios have been chosen as follows:




Whilst the duration of flaring for Scenarios 1, 2 and 3 is shorter than for other scenarios, their short-term emission

intensity is greatest. To avoid under-estimation of short-term impact potential, all scenarios have been assumed

to occur continuously at their maximum intensity for 24 hours. Therefore, Scenarios 1, 2 and 3 represent worst-

case emissions potential (refer to Section 2.4 and Appendix A).


Table 1 Major shutdown / startup scenarios

SANTOS EVENT

Scenario 1 Scenario 2 Scenario 3

EVENT 70 (visible smoke flare event)

2016 - EVENT 1a EVENT 177

2019 major shutdown: single train propane

system de-inventory for planned maintenance

activities



activities

Upset event: Emergency Depressuring Valve (EDP) valve

failed open

Wet flare

Max Flared Rate (t/h) 37 53 5

Max Flared Rate (Sm3/h) 31,053 44,929 4,533

Max Flared Rate (MJ/h) 1,866,285 - -

Duration (minutes) 276 46 3

Density (kg/Sm3) 1.19 1.19 1.19

Dry flare



Max Flared Rate (MJ/h) 7,250,461 7,757,326 13,322,138


Density (kg/Sm3) 1.90 1.90 0.70

Marine flare

Max Flared Rate (t/h) - - -

Max Flared Rate (Sm3/h) - - -

Max Flared Rate (MJ/h) - - -

Duration (minutes) - - -

Density (kg/Sm3) - - -

Total flare



Max Flared Rate (MJ/h) 7,280,942 7,757,326 13,322,138


Density (kg/Sm3) 1.89 1.79 0.70

Waste Gas

Max Flared Rate (t/h) 4 - 21

Max Flared Rate (Sm3/h) 2,206 - 11,320

Max Flared Rate (MJ/h) - - -

Duration (minutes) 303 - 65

Density (kg/Sm3) 1.87 - 1.87

Propane

Max Flared Rate (t/h) 136 149 -

Max Flared Rate (Sm3/h) 71,792 78,477 -

Max Flared Rate (MJ/h) 6.87E+06 7,506,311 -

Duration (minutes) 129 46 -

Density (kg/Sm3) 1.9 1.9 -

Ethylene

Max Flared Rate (t/h) 18 8 -

Max Flared Rate (Sm3/h) 15,258 7,020 -

Max Flared Rate (MJ/h) 917,006 421,890 -

Duration (minutes) 20 46 -

Density (kg/Sm3) 1.19 1.19 -


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2.4 Emissions

Because of their nature, flares cannot be practically measured in the field. Consequently, emission factors have

been employed to estimate emissions. Flare emissions have been based on US EPA AP-42 documents (Chapter

13.5, Industrial Flares), other literature information and information supplied by GLNG. The USEPA AP-42 emission

factors for industrial flares and the emission rates used in the assessment of each of the air pollutants: NOX, CO

and total hydrocarbons (in methane equivalents) are presented in Table 2.

Table 2 Emission factors and emission rates for the dry and wet gas flare scenarios

Parameter Oxides of nitrogen Carbon monoxide Total hydrocarbons1

Emission factor (g/GJ) 29.24 133.29 60.19

Table note:

1 Measured as methane equivalent

The AP-42 emission factors document for industrial flares (chapter 13.5) provides an average distribution by volume

of each hydrocarbon species that contributes to the total hydrocarbon fraction. The speciation of total hydrocarbons

is reproduced in Table 3.

Table 3 Composition of hydrocarbon emissions from the flare based on US EPA AP-42 emission factors

Composition Volume (%)

Average Range

Methane 55 14 - 83

Ethane/Ethylene 8 1 - 14

Acetylene 5 0.3 - 23

Propane 7 0 - 16

Propylene 25 1- 65

Note: The composition presented is an average of a number of test results obtained under the following sets of test conditions: steam-assisted flare using high-Btu-content feed; steam-assisted using low-Btu-content feed; and air assisted flare using low-Btu-content feed. In all tests, “waste” gas was a synthetic gas consisting of a mixture of propylene and propane.

Whilst the USEPA AP-42 emission factors for industrial flares also consider particulate emissions for a range of

flare types, the data cannot be easily related to a mass emission rate. Recent literature (McEwen J.D.N and

Johnson M.R, 2012) has reviewed available particulate matter emission factors for flares and found their accuracy

to be questionable “...or based on measurements not directly relevant to open-atmosphere flares”. McEwen et al. (2012) studied black carbon particulate matter emission factors for gas flares. The study established a relationship

between emissions of particulate matter (kg PM/103 m3 fuel) and volumetric heating value of the fuel (MJ/m3)

(Equation 1).


4 August 2020

Page 5

𝑬𝑭 𝒔𝒐𝒐𝒕 = 𝟎. 𝟎𝟓𝟕𝟖 (𝑯𝑽) − 𝟐. 𝟎𝟗 Equation 1

Where:

EF is the emission factor (kg PM/103 m3 fuel)

HV is volumetric heating value (MJ/m3)

The work of McEwen et al. (2012) shows that fuels with low volumetric heating values, such as methane, produce

no particulate matter. Whilst, fuels with higher volumetric heating values, such as propane, can produce higher

emission rates of particulate matter. Equation 1 has been used to calculate emission factors for particulate matter

for each of the flaring scenarios based on the composition of flared gases (Table 4).

Table 4 Emission factors for particulate matter based on Equation 1 - McEwen et al. (2012)

Scenario

Volumetric heating value

(MJ/Sm3)

Particulate matter emission factor

(kg PM/103 m3 fuel)

1 2019 major shutdown: single train Propane system de-inventory for planned maintenance activities

Dry flare 95.65 3.44

Wet flare 60.1 1.38

2 2016 major shutdown: single train Propane system de-inventory for planned maintenance activities


3 Upset event: Emergency Depressuring Valve (EDP) valve failed open


Table note:

1 Methane rich fuel gas such as that to be flared in Scenario 3 is unlikely to produce particulate matter; however, an emission factor has been determined to provide a conservative assessment

Emission rates of PAHs have been derived from the data contained within the Flare Efficiency Study Report,

prepared for US EPA (1983) (EPA-600/2-83-052).

A range of PAHs were measured for flares that were not smoking, lightly smoking and heavily smoking. For this

study, Katestone has taken the maximum measured value across all smoking flare scenarios and used that

emission factor for all flare scenarios. The assessment of PAHs will, therefore, be conservative.

Table 5 presents the emission factors for the individual PAHs that may occur from a flare.

Table 5 Emission factors for PAHs

PAHs Emission factor (µg of pollutant per µg of particulate

matter)

Naphthalene 1.0E-05

Acenaphthylene 3.5E-05

Acenaphthene 1.4E-06

Fluorene 3.4E-06

Phenanthrene 6.2E-05

Anthracene 8.5E-06

Pyrene 9.6E-05

Fluoranthene 1.2E-04


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Page 6

PAHs Emission factor (µg of pollutant per µg of particulate

matter)

Benzanthracene 2.7E-05

Chrysene 3.2E-05

Benzo(a)pyrene 6.5E-05

1,12 benzoperylene 3.0E-05

The emission rates of NOx, CO, particulates and total hydrocarbons for each flare scenario are presented in Table

6. The emission rates of PAHs for each flare scenario are presented in Table 7. Appendix A2 presents a summary

of emissions for all scenarios considered.

Table 6 Emission rates of NOx, CO, particulates and total hydrocarbons (g/s)

Scenario


2019 major shutdown: single

train propane system de-

inventory for planned

maintenance activities

2016 major shutdown:

single train propane system

de-inventory for planned


Upset event:

Emergency

Depressuring Valve

(EDP) valve failed open

Dry flare Wet flare Dry flare Dry flare

Carbon monoxide 268 69 218 493

Oxides of nitrogen 59 15 48 108

PM10 72.4 11.9 77.5 6.0

PM2.5 72.4 11.9 77.5 6.0

Total hydrocarbons (as

methane) 121 31 98 223

Methane 67 17 54 123

Ethane/ethylene 18 5 15 33

Acetylene 10 3 8 18

Propane 23 6 19 43

Propylene 80 20 65 146

Table note:

1 Methane rich fuel gas such as that to be flared in Scenario 3 is unlikely to produce particulate matter; however, a

theoretical emission factor based on an extrapolation of McEwen et al. (2012) has been calculated for PM10 and PM2.5 to

provide a conservative assessment

2 Emissions are based on assumption that flare emits continuously for 24-hours


4 August 2020

Page 7

Table 7 Emission rates of PAHs (g/s)

Scenario


2019 major shutdown: single train propane system de-

inventory for planned maintenance activities2

2016 major shutdown: single train propane system de-inventory

for planned maintenance activities2

Upset Train 1 EDP Valve Failed Open – No Propane and Ethylene Valves Open

to Flare2

Dry flare Wet flare Dry flare Dry flare

Naphthalene 7.4E-04 1.2E-04 7.9E-04 6.1E-05

Acenaphthylene 2.5E-03 4.2E-04 2.7E-03 2.1E-04

Acenaphthene 1.0E-04 1.7E-05 1.1E-04 8.5E-06

Fluorene 2.5E-04 4.1E-05 2.7E-04 2.1E-05

Phenanthrene 4.5E-03 7.4E-04 4.8E-03 3.7E-04

Anthracene 6.1E-04 1.0E-04 6.6E-04 5.1E-05

Pyrene 7.0E-03 1.1E-03 7.4E-03 5.7E-04

Fluoranthene 8.6E-03 1.4E-03 9.2E-03 7.1E-04

Benzanthracene 1.9E-03 3.2E-04 2.1E-03 1.6E-04

Chrysene 2.3E-03 3.8E-04 2.5E-03 1.9E-04

Benzo(a)pyrene 4.7E-03 7.8E-04 5.0E-03 3.9E-04

1,12 benzoperylene 2.2E-03 3.6E-04 2.3E-03 1.8E-04

Table note:

1 Methane rich fuel gas such as that to be flared in Scenario 3 is unlikely to produce particulate matter and therefore is unlikely to produce PAHs; however, to provide a conservative assessment, the particle emissions estimated for these scenarios in Table 7 have been speciated for PAHs

2 Emissions are based on assumption that flare emits continuously for 24-hours


4 August 2020

Page 8

3. LEGISLATIVE CONTEXT

The Environmental Protection Act 1994 (EP Act) provides for the management of the air environment in

Queensland. The EP Act gives the Department of Environment and Science (DES) the power to create

Environmental Protection Policies that identify, and aim to protect, environmental values of the atmosphere that

are conducive to the health and well-being of humans and biological integrity. The Environmental Protection (Air)

Policy (Air EPP) was made under the EP Act and gazetted in 1997; the Air EPP was revised and reissued in 2019.

The objective of the Air EPP is to identify the environmental values of the air environment to be enhanced or

protected and to achieve the objective of the Environmental Protection Act 1994, i.e. ecologically sustainable

development.

The environmental values to be enhanced or protected under the Air EPP are the qualities of the environment that

are conducive to:

• protecting health and biodiversity of ecosystems

• human health and wellbeing

• protecting the aesthetics of the environment, including the appearance of building structures and other

property

• protecting agricultural use of the environment.

The administering authority must consider the requirements of the Air EPP when it decides an application for an

environmental authority, amendment of a licence or approval of a draft environmental management plan. Schedule

1 of the Air EPP specifies air quality indicators and objectives for contaminants that may be present in the air

environment.

The Air EPP air quality objectives relevant to the key air pollutants that may be generated from the GLNG flares

are presented in Table 8.

Table 8 Ambient air quality objectives (Air EPP)

Pollutant Environmental value Averaging

period

Air quality

objective

(µg/m³)

Number of days

of exceedance

allowed per year

NO2

Health and wellbeing 1-hour 250 1

1-year 62 N/A

Health and biodiversity of

ecosystems 1-year 33 N/A

CO Health and wellbeing 8-hour 11,000 N/A

PM10 Health and wellbeing 24-hour 50 N/A

1-year 25 N/A

PM2.5 Health and wellbeing 24-hour 25 N/A

1-year 8 N/A

In addition to the air pollutants detailed above, the combustion of methane, propane or ethylene in the flares is also

likely to produce small quantities of hydrocarbons. The hydrocarbon emissions likely to be emitted from the flares

are presented in Table 9 with their respective air quality objective. For air quality assessments, it is common

practice to consider, and where appropriate adopt, an air quality objective for a specific substance from another

jurisdiction if information is not available in the Air EPP. As a result, air quality objectives from the following


4 August 2020

Page 9

guidelines and standards have been adopted where the Air EPP does not provide any assessment criteria for the

hydrocarbons identified in this study:

• National Exposure Standards for Atmospheric Contaminants in the Occupational Environment

(NOHSC:1003(1995))

• Texas Commission on Environmental Quality (TCEQ) Effects Screening Levels 2008.

Table 9 Relevant ambient air quality objectives and standards for hydrocarbons

Indicator Environmental

value

Averaging

period

Air quality

objective or

standard

(µg/m³)

Source

Acenaphthylene

(as acenaphthene) Health 1-hour 1 TCEQ

Acetylene Health 1-hour 26,600 TCEQ

Anthracene Health 1-hour 0.5 TCEQ

Benz(a)anthracene Health 1-hour 0.5 TCEQ

Benzo(g,h,i)perylene Health 1-hour 0.5 TCEQ

Chrysene Health 1-hour 0.5 TCEQ

Dibenzo(a,h)anthracene

(as acenaphthene) Health 1-hour 0.5 TCEQ

Ethane Health 1-hour 12,000 TCEQ

Ethylene (Ethene) Health Simple

Asphyxiant

13.9% by

volume 3

NOHSC:1003 /

TECQ

Fluoranthene

(Benzo(j,k)fluorene) Health 1-hour 0.51 TCEQ

Fluorene Health 1-hour 0.52 TCEQ

Methane Health Simple

Asphyxiant

13.9% by

volume 3

NOHSC:1003 /

TECQ

Phenanthrene Health 1-hour 0.5 TCEQ

Propane Health 1-hour 18,000 TCEQ

Propylene Health 1-hour 8,750 TCEQ

Pyrene Health 1-hour 0.5 TCEQ

1 Air quality objective not found: Fluoranthene (or Benzo(j, k)fluorene) is a polycyclic aromatic hydrocarbon

(PAH) and a structural isomer of the alternant PAH pyrene. Consequently, the same 1-hour average air

quality objective of 0.5 μg/m3 has been applied for this assessment.

2 Air quality objective not found: Fluorene is a PAH, and consequently, in line with other PAHs referenced by

the TCEQ Effects Screening Levels an air quality objective of 0.5 μg/m3 has been applied for this assessment.

3 To maintain oxygen content in air greater than 18% by volume


4 August 2020

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4. ASSESSMENT METHODOLOGY

4.1 Overview

4.2 Dispersion modelling

For each scenario identified for dispersion modelling, the flare was modelled explicitly in the dispersion model

CALPUFF. To take into consideration the potential impact from GLNG during each flare scenario, other plant

equipment was also included in the dispersion modelling. The flare characteristics incorporated into the dispersion

modelling and details of other plant equipment are discussed in the sections below. Details of model configuration

are presented in Appendix B.

4.2.1 Flares

Due to the large amount of heat and buoyancy generated by the flare, it cannot be simply modelled as a stack

source. To model the flare emissions appropriately, the US EPA Screen 3 methodology was used to generate the

pseudo stack characteristics (effective height and diameter) for the flare. The source characteristics used in the

dispersion modelling are provided in Table 10.

Table 10 Source characteristics for each dispersion modelling scenario

Parameter Units


2019 major shutdown: single train

propane system de-inventory for

planned maintenance activities

2016 major

shutdown: single

train propane

system de-

inventory for

planned

maintenance

activities

Upset event:

Emergency

Depressuring

Valve (EDP)

valve failed

open

Dry gas flare Wet gas flare Dry gas flare Dry gas flare

value value value value

Peak Energy out GJ hr-1 7,250.5 1,866.3 7,757.3 13,322.1

Energy out GJ/s 2.0 0.5 2.2 3.7

Flare mass rate kg/s 40.0 10.3 42.8 69.1

Gas Density at 0 degrees,

101.3 kPa kg/m3 1.9 1.2 1.9 0.7

Nominal stack height m 100.0 100 100 100

Nominal flare tip diameter m 1.473 0.965 1.473 1.473

Nominal flare tip radius m 0.737 0.483 0.737 0.737

Exit velocity (modelled) m/s 20 20 20 20

Flare release temperature

(modelled) K 1,273 1,273 1,273 1,273

Effective flare height

(modelled) m 164.5 133.7 166.6 186.2

Effective flare diameter

(modelled) m 14.54 7.38 15.04 19.72

Gross heat released (cal/s) cal/s 481,591,829 123,962,845 515,258,887 884,886,179

Net heat released (cal/s) cal/s 216,716,323 55,783,280 231,866,499 398,198,780


4 August 2020

Page 11

Parameter Units


2019 major shutdown: single train

propane system de-inventory for

planned maintenance activities

2016 major

shutdown: single

train propane

system de-

inventory for

planned

maintenance

activities

Upset event:

Emergency

Depressuring

Valve (EDP)

valve failed

open

Dry gas flare Wet gas flare Dry gas flare Dry gas flare

value value value value

Heat not lost by radiation % 45 45 45 45

4.2.2 Other plant equipment

A conservative assessment has been conducted where it was assumed that the two trains are operating during

each flaring scenario, where in reality for the major shutdowns one train will not be in operation (refer to Appendix

A for overview of operating plant for the various flare scenarios). A summary of other plant equipment included in

the assessment and pollutants emitted from them is summarised in Table 11. The source characteristics and

locations and emission rates are based on data supplied by Santos and are summarised in Appendix B.

Table 11 Other plant equipment included in the assessment

Other plant included in cumulative assessment NOx CO PM10/PM2.5

Train 1

A1 Methane Comp. Driver Stack ✓ ✓ ✓

A2 Methane Comp. Driver Stack ✓ ✓ ✓

A3 Ethylene Comp. Driver Stack ✓ ✓ ✓

A4 Ethylene Comp. Driver Stack ✓ ✓ ✓

A5 Propane Comp. Driver Stack ✓ ✓ ✓

A6 Propane Comp. Driver Stack ✓ ✓ ✓

A7 Waste Gas / Acid Gas / Nit Vents

A8 Hot Oil heater ✓ ✓ ✓

A9 GTG Turbine Driver Stack ✓ ✓ ✓




Train 2

B1 Methane Comp. Driver Stack ✓ ✓ ✓

B2 Methane Comp. Driver Stack ✓ ✓ ✓

B3 Ethylene Comp. Driver Stack ✓ ✓ ✓

B4 Ethylene Comp. Driver Stack ✓ ✓ ✓

B5 Propane Comp. Driver Stack ✓ ✓ ✓

B6 Propane Comp. Driver Stack ✓ ✓ ✓

B7 Waste Gas / Acid Gas / Nit Vents

B8 Hot Oil heater ✓ ✓ ✓

B9 GTG Turbine Driver Stack ✓ ✓ ✓

B10 GTG Turbine Driver Stack ✓ ✓ ✓


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Page 12

4.2.3 NOx to NO2 conversion

Measurements around power stations in Central Queensland show, under worst possible cases, a conversion of

25-40% of the nitric oxide to nitrogen dioxide occurs within the first ten kilometres of plume travel. During days

with elevated background levels of hydrocarbons (generally originating from bush-fires, hazard reduction burning

or other similar activities), the resulting conversion is usually below 50% in the first thirty kilometres of plume travel

(Bofinger et al 1986).

For this assessment, a conservative ratio of 30% conversion of the NOX to NO2 has been assumed.

4.3 Presentation of results

This assessment provides predictions of nitrogen dioxide, particulate matter less than 10 microns (PM10),

particulate matter less than 2.5 microns (PM2.5), carbon monoxide and hydrocarbon concentrations at sensitive

receptors. Ground-level concentrations are presented for short-term 1-hour and 24-hour averaging periods as the

releases from the flares are expected to range from minutes to up to 24-hours. An assessment against longer term

averaging periods has therefore not been made.

The locations of these receptors are presented in Table 12 and Figure 1. The assessment has also considered

potential impacts at protected areas as shown in Figure 1. The protected areas are as follows:

• Curtis Island National Park

• Curtis Island Conservation Park

• Curtis Island State Forest

• Curtis Island Environmental Management Precinct

• Targinie State Forest.

Table 12 Location of sensitive receptors

Receptor ID Easting (m)a Northing (m)a

Distance (km) and

direction from

receptor to facility

boundary

Orientation from

GLNG Facility

R1 307,206 7371,489 10.0 WNW

R2 307,048 7370,022 9.9 W

R3 307,088 7368,713 9.6 W

R4 307,340 7367,515 9.3 WSW

R5 308,026 7366,635 8.9 WSW

R6 308,162 7365,715 8.9 WSW

R7 311,952 7365,281 5.8 SW

R8 309,092 7361,741 10.2 SW

R9 322,211 7362,744 7.0 SSE

R11 319,653 7366,625 2.4 SSE

R12 320,910 7366,472 3.4 SSE

R13 322,795 7367,791 4.4 SE

R14 323,149 7367,160 5.0 SE

R15 325,103 7366,683 7.0 SE

R16 325,438 7365,648 7.5 SE


4 August 2020

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R17 325,396 7373,889 8.2 NE

R18 327,460 7371,898 9.3 ENE

R19 327,781 7371,714 9.5 ENE

R20 328,033 7371,495 9.8 ENE

R21 - QCLNG

accommodation camp 316,449 7370,786 1.0 NW

R22 - APLNG

accommodation camp 316,350 7371,808 2.0 NW

Note a Coordinates in GDA94 MGA55

Contour plots of ground-level concentrations of air contaminants have been used to illustrate the spatial distribution

of pollutant levels as a result of GLNG. Contour plots were created from the CALPUFF model output at each grid

point in the modelling domain, for each model scenario, using a standard interpolation technique.

Figure 1 GLNG and sensitive receptors


4 August 2020

Page 14

4.4 Cumulative impacts

For the assessment of impacts to air quality associated with NOX emissions, a two-level approach was adopted to

predict the cumulative effect of emissions from the other sources from GLNG and existing, approved and other

potential industrial developments in the Gladstone region. This assessment utilised the Gladstone Airshed

Modelling System Version 3 (GAMSv3), a regional airshed dispersion modelling tool developed by Katestone for

the Department of Infrastructure and Planning for use in planning studies. GAMv3 was used to predict background

levels of NOX.

Background concentrations of CO, PM10 and PM2.5 were based on DES monitoring data in the region. No

background concentrations were assumed for the assessment of hydrocarbons or PAHs in accordance with

conventional practice.

The cumulative impacts for NO2, CO, PM10 and PM2.5 have also been assessed. Table 13 provides a summary of

background levels used in the assessment

Table 13 Background concentrations used in modelling assessment

Pollutant Value Source

NO2

GAMS – existing and approved

industries in the Gladstone region plus

other LNG plants

GAMSv3

CO Modelled GLNG plant plus 250 µg/m3 DES monitoring data from Beacon Avenue, Boyne

Island, 2016

PM10 Modelled GLNG plant plus 36 µg/m3 DES monitoring data average 95th percentile 24-hour

from South Gladstone, 2019

PM2.5 Modelled GLNG plant plus 17.7 µg/m3 DES monitoring data for South Gladstone, 95th

percentile 24-hour average for 2019


4 August 2020

Page 15

5. DISPERSION MODELLING RESULTS

5.1 Flares in isolation

The results for all flare scenarios modelled are presented in Table 14 to Table 19. The predicted ground-level

concentrations are the maximum predicted and are due to the flare in isolation.

The results show predicted ground-level concentrations of pollutants are well below the relevant air quality

objectives, as follows:

• Maximum 1-hour average ground-level concentrations of NO2 predicted at a receptor less than 3% of the

objective

• Maximum 8-hour average ground-level concentration of CO predicted at a receptor less than 1% of the

objective

• Maximum 24-hour average ground-level concentrations of PM10 predicted at a receptor less than 5% of

the objective

• Maximum 24-hour average ground-level concentrations of PM2.5 predicted at a receptor less than 9% of

the objective

• Maximum 1-hour average ground-level concentrations of hydrocarbons (ethane, ethylene, acetylene,

propane and propylene) predicted at a receptor less than 0.4% of the relevant objectives

• Maximum ground-level concentrations of PAHs are well below (less than 0.7% of) the relevant objectives.

Plate 1 presents contours of the maximum 1-hour average concentrations of NO2 predicted due to Scenario 1 –

2019 major shutdown: single train propane system de-inventory for planned maintenance activities in isolation.

Plate 2 presents contours of the maximum 8-hour average concentrations of CO predicted due to Scenario 1 –

2019 major shutdown: single train propane system de-inventory for planned maintenance activities in isolation.

Plate 3 presents contours of the maximum 24-hour average concentrations of particulates (PM10 and PM2.5)

predicted due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned

maintenance activities in isolation.

Contours of predicted concentrations of NO2, CO, PM10 and PM2.5 for the three scenarios in isolation are presented

in Appendix A. Contours of fluoranthene (the PAH with the highest predicted concentrations relative to air quality

objectives) is also presented for all dry and wet gas scenarios.


4 August 2020

Page 16

Table 14 Predicted ground-level concentrations of NO2, CO, particulates and hydrocarbons due to Scenario 1 (flare in isolation)

2019 major shutdown: single train propane system de-inventory for planned maintenance

activities

1-hour NO2

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour methane

1-hour ethane/

ethylene

1-hour acetylene

1-hour propane

1-hour propylene

µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3

R1 3.5 12.2 1.0 1.0 13.3 3.6 2.0 4.7 15.8

R2 2.1 15.0 1.3 1.3 8.0 2.2 1.2 2.8 9.5

R3 3.4 9.2 0.8 0.8 13.0 3.5 1.9 4.5 15.5

R4 3.3 8.7 0.7 0.7 12.4 3.4 1.8 4.4 14.9

R5 2.7 9.6 0.8 0.8 10.3 2.8 1.5 3.6 12.3

R6 2.7 11.5 1.0 1.0 10.1 2.8 1.5 3.6 12.1

R7 1.3 6.8 0.5 0.5 4.8 1.3 0.7 1.7 5.8

R8 2.9 6.5 0.5 0.5 10.9 3.0 1.6 3.8 13.1

R9 0.9 4.9 0.4 0.4 3.2 0.9 0.5 1.1 3.9

R11 1.0 3.3 0.3 0.3 3.6 1.0 0.5 1.3 4.3

R12 0.5 3.0 0.3 0.3 2.0 0.5 0.3 0.7 2.3

R13 0.8 3.1 0.3 0.3 3.2 0.9 0.5 1.1 3.8

R14 0.6 2.2 0.2 0.2 2.2 0.6 0.3 0.8 2.6

R15 0.8 3.1 0.3 0.3 3.2 0.9 0.5 1.1 3.8

R16 0.6 2.1 0.2 0.2 2.3 0.6 0.3 0.8 2.7

R17 0.7 2.9 0.3 0.3 2.7 0.7 0.4 0.9 3.2

R18 0.7 3.9 0.3 0.3 2.8 0.8 0.4 1.0 3.4

R19 0.7 3.9 0.3 0.3 2.6 0.7 0.4 0.9 3.1

R20 0.6 3.8 0.3 0.3 2.3 0.6 0.3 0.8 2.8

R21 - QCLNG accommodation camp 0.9 3.4 0.2 0.2 3.5 1.0 0.5 1.2 4.2

R22 - APLNG accommodation camp 1.5 3.6 0.2 0.2 5.7 1.5 0.8 2.0 6.8

Curtis Island National Park 6.5 24.2 2.0 2.0 24.6 6.7 3.6 8.6 29.3

Curtis Island Conservation Park 2.7 9.0 0.8 0.8 10.0 2.7 1.5 3.5 12.0

Curtis Island State Forest 4.5 8.7 0.8 0.8 17.1 4.7 2.5 6.0 20.4

Curtis Island Environmental Management Precinct 7.3 26.2 2.1 2.1 27.6 7.5 4.1 9.7 33.0

Targinie State Forest 3.2 13.3 1.1 1.1 12.2 3.3 1.8 4.3 14.5

Objective 250 11,000 50 25 - 12,000 26,600 18,000 8,750


4 August 2020

Page 17

Table 15 Predicted ground-level concentrations of PAHs due to Scenario 1 (flare in isolation)


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µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3

R1 1E-04 4E-04 2E-05 4E-05 8E-04 1E-04 1E-03 2E-03 3E-04 4E-04 8E-04 4E-04

R2 9E-05 3E-04 1E-05 3E-05 6E-04 8E-05 9E-04 1E-03 2E-04 3E-04 6E-04 3E-04

R3 1E-04 5E-04 2E-05 5E-05 8E-04 1E-04 1E-03 2E-03 4E-04 4E-04 9E-04 4E-04

R4 1E-04 4E-04 2E-05 4E-05 8E-04 1E-04 1E-03 1E-03 3E-04 4E-04 8E-04 4E-04

R5 1E-04 4E-04 2E-05 4E-05 7E-04 1E-04 1E-03 1E-03 3E-04 4E-04 8E-04 3E-04

R6 1E-04 4E-04 2E-05 4E-05 7E-04 9E-05 1E-03 1E-03 3E-04 3E-04 7E-04 3E-04

R7 5E-05 2E-04 6E-06 2E-05 3E-04 4E-05 4E-04 5E-04 1E-04 1E-04 3E-04 1E-04

R8 1E-04 4E-04 2E-05 4E-05 7E-04 1E-04 1E-03 1E-03 3E-04 4E-04 8E-04 3E-04

R9 3E-05 1E-04 5E-06 1E-05 2E-04 3E-05 3E-04 4E-04 9E-05 1E-04 2E-04 1E-04

R11 3E-05 1E-04 4E-06 1E-05 2E-04 3E-05 3E-04 4E-04 8E-05 1E-04 2E-04 9E-05

R12 1E-05 5E-05 2E-06 5E-06 9E-05 1E-05 1E-04 2E-04 4E-05 4E-05 9E-05 4E-05

R13 4E-05 1E-04 5E-06 1E-05 2E-04 3E-05 3E-04 4E-04 9E-05 1E-04 2E-04 1E-04

R14 2E-05 8E-05 3E-06 8E-06 1E-04 2E-05 2E-04 3E-04 6E-05 7E-05 2E-04 7E-05

R15 3E-05 1E-04 5E-06 1E-05 2E-04 3E-05 3E-04 4E-04 9E-05 1E-04 2E-04 1E-04

R16 2E-05 8E-05 3E-06 8E-06 1E-04 2E-05 2E-04 3E-04 6E-05 7E-05 1E-04 7E-05

R17 3E-05 1E-04 4E-06 1E-05 2E-04 3E-05 3E-04 4E-04 8E-05 9E-05 2E-04 9E-05

R18 3E-05 1E-04 4E-06 1E-05 2E-04 3E-05 3E-04 4E-04 8E-05 1E-04 2E-04 9E-05

R19 3E-05 1E-04 4E-06 1E-05 2E-04 2E-05 3E-04 3E-04 7E-05 9E-05 2E-04 8E-05

R20 3E-05 9E-05 4E-06 9E-06 2E-04 2E-05 2E-04 3E-04 7E-05 8E-05 2E-04 8E-05

R21 - QCLNG accommodation camp 3E-05 9E-05 4E-06 9E-06 2E-04 2E-05 2E-04 3E-04 7E-05 8E-05 2E-04 7E-05

R22 - APLNG accommodation camp 4E-05 1E-04 6E-06 1E-05 3E-04 4E-05 4E-04 5E-04 1E-04 1E-04 3E-04 1E-04

Curtis Island National Park 3E-04 1E-03 4E-05 1E-04 2E-03 2E-04 3E-03 3E-03 7E-04 9E-04 2E-03 8E-04

Curtis Island Conservation Park 1E-04 4E-04 2E-05 4E-05 7E-04 9E-05 1E-03 1E-03 3E-04 3E-04 7E-04 3E-04

Curtis Island State Forest 2E-04 6E-04 3E-05 6E-05 1E-03 2E-04 2E-03 2E-03 5E-04 6E-04 1E-03 5E-04

Curtis Island Environmental Management Precinct

3E-04 1E-03 4E-05 1E-04 2E-03 3E-04 3E-03 4E-03 8E-04 9E-04 2E-03 9E-04


4 August 2020

Page 18


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Targinie State Forest 1E-04 5E-04 2E-05 5E-05 9E-04 1E-04 1E-03 2E-03 4E-04 5E-04 9E-04 4E-04

Objective - 1 1 0.52 0.5 0.5 0.5 0.5 0.51 0.5 - 0.5


4 August 2020

Page 19


2016 major shutdown: single train propane system de-inventory for planned maintenance

activities

1-hour NO2

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour methane

1-hour ethane/

ethylene

1-hour acetylene

1-hour propane

1-hour propylene


R1 2.4 6.6 0.8 0.8 9.0 2.5 1.3 3.2 10.7

R2 1.5 7.8 0.9 0.9 5.7 1.6 0.8 2.0 6.8

R3 2.0 5.8 0.7 0.7 7.6 2.1 1.1 2.7 9.0

R4 1.6 5.6 0.7 0.7 6.0 1.6 0.9 2.1 7.2

R5 2.2 7.2 0.9 0.9 8.5 2.3 1.3 3.0 10.1

R6 1.8 8.9 1.1 1.1 6.6 1.8 1.0 2.3 7.9

R7 0.5 2.8 0.3 0.3 1.8 0.5 0.3 0.6 2.2

R8 1.9 3.7 0.4 0.4 7.2 2.0 1.1 2.5 8.6

R9 0.5 2.2 0.3 0.3 2.1 0.6 0.3 0.7 2.5

R11 0.2 0.8 0.1 0.1 0.9 0.2 0.1 0.3 1.1

R12 0.1 0.8 0.1 0.1 0.5 0.1 0.1 0.2 0.6

R13 0.7 1.8 0.3 0.3 2.5 0.7 0.4 0.9 3.0

R14 0.4 1.1 0.2 0.2 1.7 0.5 0.2 0.6 2.0

R15 0.4 1.1 0.2 0.2 1.6 0.4 0.2 0.6 2.0

R16 0.3 0.6 0.1 0.1 1.0 0.3 0.1 0.4 1.2

R17 0.5 1.8 0.3 0.3 1.7 0.5 0.3 0.6 2.0

R18 0.6 2.8 0.3 0.3 2.4 0.6 0.4 0.8 2.8

R19 0.6 2.5 0.3 0.3 2.1 0.6 0.3 0.7 2.5

R20 0.5 2.3 0.3 0.3 1.8 0.5 0.3 0.6 2.2








Objective 250 11,000 50 25 - 12,000 26,600 18,000 8,750


4 August 2020

Page 20



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R1 1E-04 5E-04 2E-05 4E-05 8E-04 1E-04 1E-03 2E-03 3E-04 4E-04 8E-04 4E-04

R2 8E-05 3E-04 1E-05 3E-05 5E-04 7E-05 8E-04 1E-03 2E-04 3E-04 5E-04 2E-04

R3 1E-04 4E-04 2E-05 4E-05 7E-04 9E-05 1E-03 1E-03 3E-04 3E-04 7E-04 3E-04

R4 9E-05 3E-04 1E-05 3E-05 5E-04 7E-05 8E-04 1E-03 2E-04 3E-04 6E-04 3E-04

R5 1E-04 4E-04 2E-05 4E-05 8E-04 1E-04 1E-03 1E-03 3E-04 4E-04 8E-04 4E-04

R6 1E-04 3E-04 1E-05 3E-05 6E-04 8E-05 9E-04 1E-03 3E-04 3E-04 6E-04 3E-04

R7 3E-05 9E-05 4E-06 9E-06 2E-04 2E-05 3E-04 3E-04 7E-05 8E-05 2E-04 8E-05

R8 1E-04 4E-04 1E-05 4E-05 6E-04 9E-05 1E-03 1E-03 3E-04 3E-04 7E-04 3E-04

R9 3E-05 1E-04 4E-06 1E-05 2E-04 3E-05 3E-04 4E-04 8E-05 9E-05 2E-04 9E-05

R11 1E-05 5E-05 2E-06 4E-06 8E-05 1E-05 1E-04 2E-04 3E-05 4E-05 8E-05 4E-05

R12 7E-06 2E-05 1E-06 2E-06 4E-05 6E-06 7E-05 8E-05 2E-05 2E-05 5E-05 2E-05

R13 4E-05 1E-04 5E-06 1E-05 2E-04 3E-05 3E-04 4E-04 9E-05 1E-04 2E-04 1E-04

R14 2E-05 8E-05 3E-06 8E-06 1E-04 2E-05 2E-04 3E-04 6E-05 8E-05 2E-04 7E-05

R15 2E-05 8E-05 3E-06 8E-06 1E-04 2E-05 2E-04 3E-04 6E-05 7E-05 2E-04 7E-05

R16 1E-05 5E-05 2E-06 5E-06 9E-05 1E-05 1E-04 2E-04 4E-05 5E-05 9E-05 4E-05

R17 2E-05 9E-05 3E-06 8E-06 2E-04 2E-05 2E-04 3E-04 6E-05 8E-05 2E-04 7E-05

R18 3E-05 1E-04 5E-06 1E-05 2E-04 3E-05 3E-04 4E-04 9E-05 1E-04 2E-04 1E-04

R19 3E-05 1E-04 4E-06 1E-05 2E-04 3E-05 3E-04 4E-04 8E-05 1E-04 2E-04 9E-05

R20 3E-05 9E-05 4E-06 9E-06 2E-04 2E-05 3E-04 3E-04 7E-05 8E-05 2E-04 8E-05







2E-04 8E-04 3E-05 8E-05 1E-03 2E-04 2E-03 3E-03 6E-04 7E-04 2E-03 7E-04


4 August 2020

Page 21


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Objective - 1 1 0.52 0.5 0.5 0.5 0.5 0.51 0.5 - 0.5


4 August 2020

Page 22


Upset event: Emergency Depressuring Valve (EDP) valve failed open

1-hour NO2

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour methane

1-hour ethane/

ethylene

1-hour acetylene

1-hour propane

1-hour propylene


R1 4.3 11.6 0.04 0.04 16.2 4.4 2.4 5.7 19.4

R2 3.5 7.6 0.03 0.03 13.0 3.6 1.9 4.6 15.6

R3 6.7 19.9 0.07 0.07 25.1 6.9 3.7 8.8 30.0

R4 2.6 5.2 0.02 0.02 9.7 2.7 1.4 3.4 11.6

R5 3.5 7.7 0.03 0.03 13.0 3.6 1.9 4.6 15.6

R6 2.4 9.4 0.03 0.03 8.9 2.4 1.3 3.1 10.7

R7 1.0 5.1 0.02 0.02 3.8 1.0 0.6 1.3 4.6

R8 0.9 3.4 0.01 0.01 3.3 0.9 0.5 1.2 4.0

R9 1.1 3.6 0.01 0.01 4.0 1.1 0.6 1.4 4.7

R11 0.4 1.8 0.007 0.007 1.3 0.4 0.2 0.5 1.6

R12 0.2 0.7 0.003 0.003 0.8 0.2 0.1 0.3 0.9

R13 0.3 1.3 0.005 0.005 1.1 0.3 0.2 0.4 1.3

R14 0.3 1.0 0.004 0.004 1.0 0.3 0.1 0.4 1.2

R15 0.3 0.9 0.003 0.003 1.2 0.3 0.2 0.4 1.4

R16 0.2 0.5 0.002 0.002 0.8 0.2 0.1 0.3 0.9

R17 2.2 6.2 0.02 0.02 8.4 2.3 1.2 2.9 10.0

R18 1.5 7.0 0.03 0.03 5.7 1.6 0.8 2.0 6.8

R19 1.4 5.9 0.02 0.02 5.2 1.4 0.8 1.8 6.3

R20 1.3 5.0 0.02 0.02 4.7 1.3 0.7 1.7 5.7








Objective 250 11,000 50 25 - 12,000 26,600 18,000 8,750


4 August 2020

Page 23



failed open

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R1 8E-06 3E-05 1E-06 3E-06 5E-05 7E-06 8E-05 9E-05 2E-05 3E-05 5E-05 2E-05

R2 6E-06 2E-05 9E-07 2E-06 4E-05 5E-06 6E-05 8E-05 2E-05 2E-05 4E-05 2E-05

R3 1E-05 4E-05 2E-06 4E-06 8E-05 1E-05 1E-04 1E-04 3E-05 4E-05 8E-05 4E-05

R4 5E-06 2E-05 7E-07 2E-06 3E-05 4E-06 5E-05 6E-05 1E-05 2E-05 3E-05 1E-05

R5 6E-06 2E-05 9E-07 2E-06 4E-05 5E-06 6E-05 8E-05 2E-05 2E-05 4E-05 2E-05

R6 4E-06 2E-05 6E-07 2E-06 3E-05 4E-06 4E-05 5E-05 1E-05 1E-05 3E-05 1E-05

R7 2E-06 7E-06 3E-07 6E-07 1E-05 2E-06 2E-05 2E-05 5E-06 6E-06 1E-05 6E-06

R8 2E-06 6E-06 2E-07 6E-07 1E-05 1E-06 2E-05 2E-05 4E-06 5E-06 1E-05 5E-06

R9 2E-06 7E-06 3E-07 7E-07 1E-05 2E-06 2E-05 2E-05 5E-06 6E-06 1E-05 6E-06

R11 7E-07 2E-06 9E-08 2E-07 4E-06 6E-07 6E-06 8E-06 2E-06 2E-06 4E-06 2E-06

R12 4E-07 1E-06 5E-08 1E-07 2E-06 3E-07 4E-06 5E-06 1E-06 1E-06 2E-06 1E-06

R13 5E-07 2E-06 8E-08 2E-07 3E-06 5E-07 5E-06 6E-06 1E-06 2E-06 3E-06 2E-06

R14 5E-07 2E-06 7E-08 2E-07 3E-06 4E-07 5E-06 6E-06 1E-06 2E-06 3E-06 1E-06

R15 6E-07 2E-06 8E-08 2E-07 4E-06 5E-07 6E-06 7E-06 2E-06 2E-06 4E-06 2E-06

R16 4E-07 1E-06 5E-08 1E-07 2E-06 3E-07 4E-06 4E-06 1E-06 1E-06 2E-06 1E-06

R17 4E-06 1E-05 6E-07 1E-06 3E-05 3E-06 4E-05 5E-05 1E-05 1E-05 3E-05 1E-05

R18 3E-06 1E-05 4E-07 1E-06 2E-05 2E-06 3E-05 3E-05 7E-06 9E-06 2E-05 8E-06

R19 3E-06 9E-06 4E-07 9E-07 2E-05 2E-06 2E-05 3E-05 7E-06 8E-06 2E-05 8E-06

R20 2E-06 8E-06 3E-07 8E-07 1E-05 2E-06 2E-05 3E-05 6E-06 7E-06 2E-05 7E-06







9E-06 3E-05 1E-06 3E-06 6E-05 8E-06 9E-05 1E-04 2E-05 3E-05 6E-05 3E-05


4 August 2020

Page 24


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zo

(a)p

yre

ne

1,1

2

be

nzo

pe

ryle

ne



Objective - 1 1 0.52 0.5 0.5 0.5 0.5 0.51 0.5 - 0.5


4 August 2020

Page 25

5.2 Flare including background

Table 20 to Table 22 summarise the cumulative maximum concentrations of NO2, CO, PM10 and PM2.5 for all gas

flare scenarios. Table C1 to Table C3 in Appendix C present the predicted ground-level concentrations for each

modelled dry and wet gas flare scenario as well as a breakdown of predicted concentrations due to flare in isolation,

flare with other plant equipment and flare with other plant equipment plus background.

The results show that the predicted ground-level concentrations NO2, CO, PM10 and PM2.5 are well below the

relevant air quality objectives for all modelled scenarios, as follows:

• Maximum 1-hour average ground-level concentrations of NO2 predicted at a receptor less than 30% of

the objective

• Maximum 8-hour average ground-level concentration of CO predicted at a receptor less than 4% of the

objective

• Maximum 24-hour average ground-level concentrations of PM10 predicted at a receptor less than 84% of

the objective

• Maximum 24-hour average ground-level concentrations of PM2.5 predicted at a receptor less than 94% of

the objective.

Contours of predicted concentrations of NO2, CO, PM10 and PM2.5 including other plant equipment and background

are presented in Appendix C.


4 August 2020

Page 26

Table 20 Predicted cumulative impacts of NO2, CO, PM10 and PM2.5 for Scenario 1



activities

1-hour

average

NO2

8-hour

average

CO

24-hour

average

PM10

24-hour

average

PM2.5

µg/m3 µg/m3 µg/m3 µg/m3

R1 43.2 262 37.0 17.7

R2 41.5 265 37.5 17.7

R3 47.5 259 36.8 17.7

R4 48.9 259 36.7 17.7

R5 57.0 260 36.9 17.7

R6 74.5 262 37.0 17.7

R7 67.4 258 36.5 18.2

R8 73.0 257 36.6 18.3

R9 50.9 255 36.4 18.1

R11 40.2 259 36.4 18.1

R12 45.6 256 36.3 18.0

R13 28.5 255 36.3 18.0

R14 30.7 255 36.2 17.9

R15 23.0 255 36.3 18.0

R16 17.5 253 36.2 17.9

R17 27.5 254 36.3 17.9

R18 20.4 255 36.4 18.1

R19 20.0 255 36.4 18.1

R20 20.2 255 36.4 18.1

R21 53.2 271 37.6 19.2

R22 50.6 268 36.9 18.5

Curtis Island National Park 36.0 276 38.0 19.7

Curtis Island Conservation Park 44.8 259 36.8 18.5

Curtis Island State Forest 38.5 260 36.8 18.5

Curtis Island Environmental Management Precinct 75.4 397 42.0 23.6

Targinie State Forest 63.2 264 37.3 19.0

Objective 250 11,000 50 25


4 August 2020

Page 27



system de-inventory for planned


1-hour

average

NO2

8-hour

average

CO

24-hour

average

PM10

24-hour

average

PM2.5


R1 43.2 257 37.0 18.7

R2 41.5 258 37.4 19.1

R3 47.5 257 36.9 18.6

R4 48.9 256 36.9 18.5

R5 57.0 258 37.1 18.7

R6 74.5 259 37.4 19.0

R7 67.4 255 36.5 18.1

R8 73.0 254 36.6 18.3

R9 50.9 253 36.4 18.1

R11 40.2 259 36.4 18.1

R12 45.6 256 36.3 17.9

R13 28.5 255 36.3 18.0

R14 30.7 255 36.2 17.9

R15 23.0 254 36.3 18.0

R16 17.5 253 36.2 17.9

R17 27.5 254 36.4 18.0

R18 20.4 253 36.4 18.0

R19 20.0 253 36.4 18.0

R20 20.2 253 36.4 18.0

R21 53.2 271 37.6 19.2

R22 50.6 268 36.9 18.5




Curtis Island Environmental Management

Precinct 75.4 397 41.9 23.6

Targinie State Forest 63.2 262 37.3 19.0

Objective 250 11,000 50 25


4 August 2020

Page 28


Upset event: Emergency Depressuring Valve

(EDP) valve failed open

1-hour

average

NO2

8-hour

average

CO

24-hour

average

PM10

24-hour

average

PM2.5


R1 43.2 262 36.4 17.7

R2 41.5 258 36.2 17.7

R3 47.5 270 36.2 17.7

R4 49.0 255 36.2 17.7

R5 57.0 258 36.1 17.7

R6 74.5 260 36.1 17.7

R7 67.4 256 36.2 17.9

R8 73.0 254 36.1 17.8

R9 50.9 254 36.1 17.8

R11 40.2 259 36.3 18.0

R12 45.6 256 36.3 17.9

R13 28.5 255 36.2 17.9

R14 30.7 255 36.2 17.9

R15 23.0 254 36.2 17.8

R16 17.5 253 36.1 17.8

R17 27.5 256 36.1 17.8

R18 20.4 257 36.1 17.8

R19 20.0 256 36.1 17.8

R20 20.2 255 36.1 17.8

R21 53.2 271 37.6 19.2

R22 50.6 268 36.9 18.5




Curtis Island Environmental Management Precinct 75.4 397 41.9 23.6

Targinie State Forest 63.2 265.3 36.4 18.1

Objective 250 11,000 50 25


4 August 2020

Page 29

6. CONCLUSIONS

Katestone Environmental Pty Ltd (Katestone) was commissioned by Santos to conduct an air quality assessment

associated with the operation of flares at its Gladstone LNG facility (GLNG).

GLNG is operated under Environmental Authority Number EPPG00712213. Schedule B details conditions relating

to air emissions and conditions B16 to B20 relate to flares.


and emergency situations. Major shutdowns are typically planned to occur once every four years per train.

An air quality assessment was conducted to quantify the emissions associated with the flares when they emit

smoke and the potential impact of those emissions on the receiving environment.

The key air pollutants emitted from the dry and wet gas flares at the GLNG facility were found to be:



• Hydrocarbons including:

o Methane

o Ethane/ethylene

o Acetylene

o Propane

o Propylene

• Particulate matter in the form of PM2.5 and PM10 (flare gases containing propane and ethylene)


Katestone considered a range of potential emission scenarios and has identified three key scenarios for further

assessment through dispersion modelling. They are as follows:


activities


activities

• Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open.

These scenarios were identified for detailed dispersion modelling being the scenarios with maximum potential for

impact as:




A conservative dispersion modelling assessment was conducted to determine the potential impacts due to flaring

operations. The assessment is conservative because it is based on the following assumptions:

• All flaring events have been assumed to occur continuously at their maximum intensity for 24-hours. In

reality, a flaring event may occur over a number of minutes or up to 24-hours.

• All other plant and equipment at GLNG operate at the same time as the flaring event. In reality, the smoke

events are typically associated with the shutdown of one processing train and, therefore, emissions from

other plant and equipment will be reduced.


4 August 2020

Page 30

Dispersion modelling of these scenarios found the following:

• Predicted ground-level concentrations NO2, CO, PM10 and PM2.5 as well as hydrocarbons were well below

the relevant air quality objectives at all sensitive receptors (including residential receptors and protected

areas).

• Predicted ground-level concentrations of PAHs were well below the relevant air quality objectives at all

sensitive receptors (including residential receptors and protected areas).


4 August 2020

Page 31

7. REFERENCES

Bofinger ND, Best PR, Cliff DI and Stumer LJ, 1986. “The oxidation of nitric oxide to nitrogen dioxide in power station plumes”, Proceedings of the Seventh World Clean Air Congress, Sydney, 384-392

McEwan J.D.N and Johnson M.R, 2012, Black Carbon Particulate Matter Emission Factors for Buoyancy Driven

Associated Flares, Journal of the Air & Waste Management Association

National Occupational Health and Safety Commission, 1995. Adopted National Exposure Standards for

Atmospheric Contaminants in the Occupational Environment (NOHSC:1003(1995))

Texas Commission on Environmental Quality, 2008, Effects Screening Levels, Texas, United States.

United States Environmental Protection Agency (USEPA), 2018, Industrial Flares, AP-42 Chapter 13.5 USEPA

Office of Air Quality Planning and Standards


4 August 2020

Page 32

Plate 1 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 33

Plate 2 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 34

Plate 3 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation) - all PM10 is assumed to be PM2.5

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

PM10: 50 µg/m³

PM2.5: 25 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 35

APPENDIX A SHUTDOWN/STARTUP SCENARIOS

A1 FLARED GAS QUANTITIES, MASS RATES, AND DURATION OF EVENTS

This section presents the major shutdown/startup and upset scenarios that have occurred over the last four years

at GLNG. Table A1 to Table A5 summarise the mass flow of fuel, expected duration of flaring and energy content.

Information is provided for the dry, wet and marine flares for each scenario.

Table A1 Major shutdown/start up and upset scenarios (1)

GLNG EVENT

EVENT 70 (start of de-inventory)

EVENT 70 (visible smoke)

EVENT 82 EVENT 83/84

Train 1 shutdown 2019




Description

Flaring Train 1 Propane system,

Shutdown activities (start of de-inventory)

Flaring Train 1 Propane system de-inventory, Shutdown

activities

Purging procedure for Propane

system (train1 Start up)

Ethylene vapour re-inventory

Wet flare

Max Flared Rate (t/h) 165 37 174 61

Max Flared Rate (Sm3/h) 139,398 31,053 146,594 51,221 Max Flared Rate (MJ/h) - 1,866,285 - 3,078,382

Duration (minutes) 837 276 75 99

Density (kg/Sm3) 1.19 1.19 1.19 1.19

Dry flare


Max Flared Rate (Sm3/h) 77,494 75,802 81,276 121,718 Max Flared Rate (MJ/h) 2,882,777 7,250,461 4,884,688 4,527,910

Duration (minutes) 1,342 302 75 111

Density (kg/Sm3) 0.70 1.90 1.19 0.70

Marine flare

Max Flared Rate (t/h) - - - -

Max Flared Rate (Sm3/h) - - - - Max Flared Rate (MJ/h) - - - -

Duration (minutes) - - - -

Density (kg/Sm3) - - - -

Total flare



Duration (minutes) 1,409 303 75 111

Density (kg/Sm3) 1.18 1.89 1.19 0.85

Waste Gas

Max Flared Rate (t/h) 11 4 - 2 Max Flared Rate (Sm3/h) 6,003 2,206 - 1,324

Max Flared Rate (MJ/h) - - - -

Duration (minutes) 1,413.5 303 - 5

Density (kg/Sm3) 1.873 1.87 - 1.87

Propane

Max Flared Rate (t/h) - 136 - 54 Max Flared Rate (Sm3/h) - 71,792 - 28,471

Max Flared Rate (MJ/h) - 6.87E+06 - 2,723,274

Duration (minutes) - 129 - 1.0

Density (kg/Sm3) - 1.9 - 1.9

Ethylene

Max Flared Rate (t/h) - 18 30 2 Max Flared Rate (Sm3/h) - 15,258 25,261 1,273

Max Flared Rate (MJ/h) - 917,006 1,518,196 76,536

Duration (minutes) - 20 75 60

Density (kg/Sm3) - 1.19 1.19 1.19


4 August 2020

Page 36


GLNG event EVENT 85 EVENT 88 2016 - EVENT 1a 2016 - EVENT 1b



Train 1 shutdown Propane Peak

Train 1 shutdown Peak Wet Flare

Description

Ethylene vapour re-inventory

Note Event 85 and 88 scenarios overlap

in time

Ethylene vapour re-inventory Note Event 85 and 88 scenarios

overlap in time

Train 1 Unit 15 warm ethylene circuit

defrost, Unit 16 warm methane and NRU

system defrost, depressuring Unit 12

& 13




& 13 Note peak methane event from dry flare

Wet flare


Max Flared Rate (Sm3/h) 6,896 11,567 44,929 7,874

Max Flared Rate (MJ/h) 414,450 695,177 - -

Duration (minutes) 72 43 46 46 Density (kg/Sm3) 1.19 1.19 1.19 1.19

Dry flare



Max Flared Rate (MJ/h) 2,801,123 2,888,989 7,757,326 10,574,212

Duration (minutes) 94 138 46 46 Density (kg/Sm3) 0.70 0.70 1.90 0.70

Marine flare

Max Flared Rate (t/h) - - - -

Max Flared Rate (Sm3/h) - - - -


Duration (minutes) - - - - Density (kg/Sm3) - - - -

Total flared



Max Flared Rate (MJ/h) 3,144,005 3,144,005 7,757,326 10,574,212 Duration (minutes) 94 138 46 46

Density (kg/Sm3) 0.73 0.73 1.79 0.70

Waste gas

Max Flared Rate (t/h) 3 3 - -

Max Flared Rate (Sm3/h) 1,420 1,517 - -

Max Flared Rate (MJ/h) - - - - Duration (minutes) 37 115 - -

Density (kg/Sm3) 1.87 1.87 - -

Propane

Max Flared Rate (t/h) - - 149 4

Max Flared Rate (Sm3/h) - - 78,477 2,270

Max Flared Rate (MJ/h) - - 7,506,311 217,097 Duration (minutes) - - 46 1,414

Density (kg/Sm3) - - 1.9 1.9

Ethylene



Max Flared Rate (MJ/h) 156,964 156,964 421,890 240,563 Duration (minutes) 59 99 46 35

Density (kg/Sm3) 1.19 1.19 1.19 1.19


4 August 2020

Page 37


GLNG event 2016 - EVENT 1c 2017 - EVENT 6 EVENT 60 EVENT 109/110

Train 1 shutdown Peak Ethylene

Train 1 Shutdown Upset Upset

Description




& 13

Propane and Ethylene re-inventory

T1 TC-1611 Trip Ethylene flare event

Wet flare


Max Flared Rate (Sm3/h) 57,663 228,031 19,685 3,207 Max Flared Rate (MJ/h) 3,465,576 - - -

Duration (minutes) 541 1,213 38 56

Density (kg/Sm3) 1.19 1.19 1.19 1.19

Dry flare




Density (kg/Sm3) 1.19 0.70 0.70 1.19

Marine flare

Max Flared Rate (t/h) - - 45.99267216 -

Max Flared Rate (Sm3/h) - - 65,275 - Max Flared Rate (MJ/h) - - 2,345,326 -

Duration (minutes) - - 12 -

Density (kg/Sm3) - - 1 -

Total flared

Max Flared Rate (t/h) 138 272 52 102 Max Flared Rate (Sm3/h) 115,769 230,548 74,590 85,490

Max Flared Rate (MJ/h) 6,957,723 1,525,795 2,691,844 5,073,462


Density (kg/Sm3) 1.19 1.18 0.70 1.19

Waste gas

Max Flared Rate (t/h) 3 3 - - Max Flared Rate (Sm3/h) 1,420 1,517 - -


Duration (minutes) 37 115 - -

Density (kg/Sm3) 1.87 1.87 - -

Propane

Max Flared Rate (t/h) - 7 29 - Max Flared Rate (Sm3/h) - 3,502 15,665 -


Duration (minutes) - 1,113 76 -

Density (kg/Sm3) - 1.87 1.87 -

Ethylene

Max Flared Rate (t/h) 8 64 - - Max Flared Rate (Sm3/h) 4,103 33,783 - -

Max Flared Rate (MJ/h) 392,472 3,231,373 - -

Duration (minutes) 1 38 - -

Density (kg/Sm3) 1.9 1.9 - -


4 August 2020

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GLNG event EVENT 125 EVENT 165 EVENT 177 EVENT 180

Upset Upset Upset Upset

Description EDP on 3415-C-1521

tripped open SDP on train 1

Train 1 EDP valve 15075 failed open. Note no propane or

ethylene valves open to flare.

Two Train ESDP - Black Start

Wet flare

Max Flared Rate (t/h) 11 - 5 98

Max Flared Rate (Sm3/h) 9,510 - 4,533 82,232 Max Flared Rate (MJ/h) - - - 4,942,143

Duration (minutes) 173 - 3 142

Density (kg/Sm3) 1.19 - 1.19 1.19

Dry flare


Max Flared Rate (Sm3/h) 994 11,478 358,122 16,448 Max Flared Rate (MJ/h) 59,739 426,982 13,322,138 611,866


Density (kg/Sm3) 1.19 0.70 0.70 0.70

Marine flare

Max Flared Rate (t/h) - - - 16

Max Flared Rate (Sm3/h) - - - 23,503 Max Flared Rate (MJ/h) - - - 844,448

Duration (minutes) - - - 124

Density (kg/Sm3) - - - 1

Total flared


Max Flared Rate (Sm3/h) 10,188 11,478 358,122 103,497 Max Flared Rate (MJ/h) 59,739 426,982 13,322,138 5,719,505


Density (kg/Sm3) 1.19 0.70 0.70 1.09

Waste gas

Max Flared Rate (t/h) 19 11 21 7 Max Flared Rate (Sm3/h) 10,150 5,693 11,320 3,692



Density (kg/Sm3) 1.87 1.87 1.87 1.87

Propane

Max Flared Rate (t/h) - - - - Max Flared Rate (Sm3/h) - - - -


Duration (minutes) - - - -

Density (kg/Sm3) - - - -

Ethylene

Max Flared Rate (t/h) 12 - - 24 Max Flared Rate (Sm3/h) 10,188 - - 20,350

Max Flared Rate (MJ/h) 612,299 - - 1,223,035

Duration (minutes) 0 - - 7

Density (kg/Sm3) 1.19 - - 1.19


4 August 2020

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GLNG event 2016 - EVENT 3

Upset Event - Power upset

Description Power generation load shedding caused Train 1 and

Train 2 SDP

Wet flare

Max Flared Rate (t/h) 62

Max Flared Rate (Sm3/h) 89,330 Max Flared Rate (MJ/h) 3,323,076

Duration (minutes) 841

Density (kg/Sm3) 0.70

Dry flare





Marine flare




Density (kg/Sm3) 1

Total flared





Waste gas

Max Flared Rate (t/h) 38 Max Flared Rate (Sm3/h) 20,236

Max Flared Rate (MJ/h) -



Propane

Max Flared Rate (t/h) 130 Max Flared Rate (Sm3/h) 68,330

Max Flared Rate (MJ/h) 6,535,743


Density (kg/Sm3) 2

Ethylene

Max Flared Rate (t/h) 1 Max Flared Rate (Sm3/h) 627

Max Flared Rate (MJ/h) 37,653



A2 EMISSIONS SUMMARY

Figure A1 presents a summary of emissions of particulates (PM10 and PM2.5), NOx, total hydrocarbons and total

PAHs for all scenarios considered for the dry and wet flares.


4 August 2020

Page 40

Figure A1 Summary of emission rates for all flare scenarios considered


A3 OTHER PLANT EQUIPMENT

A summary of other plant equipment operating for each scenario is provided below. Note that all equipment was assumed to be operating for the purposes of dispersion modelling.

Table A6 Summary of other plant equipment

No. Description

Major Shutdown / Start-ups Upset Scenarios

EV

EN

T 7

0

EV

EN

T 8

2

EV

EN

T 8

3

EV

EN

T 8

4

EV

EN

T 8

5

EV

EN

T 8

8

20

16

-

EV

EN

T 1

a

20

16

-

EV

EN

T 1

b

20

16

-

EV

EN

T 1

c

20

17

-

EV

EN

T 6

EV

EN

T 6

0

EV

EN

T

10

9

EV

EN

T

11

0

EV

EN

T

12

5

EV

EN

T

16

5

EV

EN

T

17

7

EV

EN

T

18

0

20

16

-

EV

EN

T 3

Train 1 Air Emission Point Locations

A1 Methane Comp. Driver Stack

x x x

A2 Methane Comp. Driver Stack

x x x x x x x

A3 Ethylene Comp. Driver Stack

x x x x

A4 Ethylene Comp. Driver Stack

x x x x x x x

A5 Propane Comp. Driver Stack

x x x x x x

A6 Propane Comp. Driver Stack

x x x x

A7 Waste Gas / Acid Gas / Nit Vents

x x x x x x x x x x x x x x x x x x

A8 Hot Oil heater x x x x x x x x x x x x x x

A9 GTG Turbine Driver Stack

x x x x


x x x x x x x x x x x


x


x x x x x

A13 Wet Gas Flare x x x x x x x x x x x x x x x x x


No. Description

Major Shutdown / Start-ups Upset Scenarios

EV

EN

T 7

0

EV

EN

T 8

2

EV

EN

T 8

3

EV

EN

T 8

4

EV

EN

T 8

5

EV

EN

T 8

8

20

16

-

EV

EN

T 1

a

20

16

-

EV

EN

T 1

b

20

16

-

EV

EN

T 1

c

20

17

-

EV

EN

T 6

EV

EN

T 6

0

EV

EN

T

10

9

EV

EN

T

11

0

EV

EN

T

12

5

EV

EN

T

16

5

EV

EN

T

17

7

EV

EN

T

18

0

20

16

-

EV

EN

T 3

A14 Marine Flare x x x

A15 Dry Gas Flare x x x x x x x x x x x x x x x x x x

A16 Backup Wet and Dry Gas Flare

Train 2 Air Emission Point Locations

B1 Methane Comp. Driver Stack

x x x x x x x x x x x x x x x x

B2 Methane Comp. Driver Stack

x x x x x x x x x x x x x x

B3 Ethylene Comp. Driver Stack


B4 Ethylene Comp. Driver Stack


B5 Propane Comp. Driver Stack


B6 Propane Comp. Driver Stack


B7 Waste Gas / Acid Gas / Nit Vents

x x x x x x x x x x x x x x x x x x

B8 Hot Oil heater x x x x x x

B9 GTG Turbine Driver Stack

x x x x x x x x x x x x

B10 GTG Turbine Driver Stack

x x x x x x x x x x x x x


4 August 2020

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APPENDIX B METEOROLOGICAL AND DISPERSION MODELLING

METHODOLOGY

Air dispersion modelling was conducted using a two-stage approach. Firstly, the CSIRO’s meteorological model,TAPM (The Air Pollution Model) Version 4.0.5 (Hurley 2005), was used to simulate the regional meteorology in the

Gladstone region. Further refinement of the wind field was then made through the CALMET Version 6.3

meteorological pre-processor. Secondly, the CALPUFF plume dispersion model was used to predict ground-level

concentrations of air pollutants emitted from GLNG.

B1 DEVELOPMENT OF SITE-SPECIFIC METEOROLOGY

B1.1 TAPM meteorological simulations

TAPM was developed by the CSIRO and has been validated by the CSIRO, Katestone Environmental and others

for many locations in Australia, Southeast Asia and in North America (see www.dar.csiro.au/TAPM/ for more details

on the model and validation results from the CSIRO). Katestone Environmental has used the TAPM model

throughout Australia as well as in parts of New Caledonia, the United States of America, Bangladesh and Vietnam.

This model generally has performed well for simulating winds in a region.

TAPM required synoptic meteorological information for the Gladstone region. This information was generated by a

global model similar to the large-scale models used to forecast the weather. The data are supplied by the BoM on

a grid resolution of approximately 75 km, and at elevations of 100 m to five kilometres above the ground. TAPM

uses this synoptic information, along with specific details of the location such as surrounding terrain, land-use, soil

moisture content and soil type to simulate the meteorology of a region as well as at a specific location.

TAPM solves the fundamental fluid dynamics equations to predict meteorology at a mesoscale (20 kilometre to

200 kilometre) and at a local scale (down to a few hundred metres). TAPM includes parameterisations for

cloud/rain micro-physical processes, urban/vegetation canopy and soil, and radiative fluxes. TAPM is skilled at

simulating the flows important to regional and local scale meteorology, such as the southeast trade winds and sea

breezes.

TAPM was configured as follows:

• Mother domain of 30 km with 3 nested daughter grids of 10 km, 3 km and 1 km

• 40 x 40 grid points for all modelling domains resulting in a 40 x 40 km grid at 1 kilometre resolution

• 25 vertical levels, from the surface up to an altitude of 8000 metres above ground level

• Geosciences Australia 9 second DEM terrain data

• The TAPM defaults for sea surface temperature

• Default options selected for advanced meteorological inputs

• Year modelled: 1 April 2006 to 31 March 2007

• Landuse and coastline data was refined based on high resolution images sourced from Google Earth and

vegetation maps obtained from DES

• Local data assimilation using observations from three regionally representative sites.


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The land use for the inner grid required significant modification due to the coarseness of the TAPM dataset.

Representative data was derived from vegetation maps obtained from DES and from aerial imaging by Google

Earth. The coastline was also re-defined in the database to better represent the complex coastline around Curtis

Island. Detailed 9-second arc DEM elevation data (resolution approximately 100 metre) was obtained from

Geosciences Australia for this modelling domain.

TAPM was used as the prognostic mesoscale meteorological model to provide three-dimensional hourly

meteorological fields to CALMET, a diagnostic meteorological model and wind field pre-processor for the CALPUFF

air dispersion model. The CALMET modelling grid was positioned within the TAPM simulation, effectively becoming

a fifth nested grid. The three-dimensional meteorological fields generated by TAPM were then input into CALMET

model to generate a fine resolution meteorological field.

B1.2 CALMET meteorological simulations

CALMET is an advanced non-steady-state diagnostic three-dimensional meteorological model with micro-

meteorological modules for overwater and overland boundary layers. The model is the meteorological pre-

processor for the CALPUFF dispersion model. CALMET is capable of assimilating hourly meteorological data from

multiple sites within the modelling domain, and can also be initialised with the gridded three-dimensional prognostic

output from other meteorological models such as TAPM. This can improve dispersion model output, particularly

over complex terrain as the near surface meteorological conditions are calculated for each grid point.

CALMET was used to simulate meteorological conditions around Curtis Island. The modelling domain was setup

to be nested within the one kilometre TAPM domain. CALMET treats the prognostic model output as the initial

guess field for the diagnostic model wind fields. CALMET then adjusts the initial guess field for the kinematic

effects of terrain, slope flows, blocking effects and 3-dimensional divergence minimisation. The coupled approach

unites the mesoscale prognostic capabilities of TAPM with the refined terrain and land use capabilities of CALMET.

The use of the three-dimensional wind field provides a complete set of meteorological variables for every grid point

and vertical level for each hour of the simulation period. This is a significant improvement in modelling approach

to the method of data assimilation from discrete surface stations. No data assimilation was used in CALMET as

no local data were available for the Curtis Island site. Regionally representative sites were, however, assimilated

into TAPM.

The model was set up with twelve vertical levels with heights at 20 m, 60 m, 100 m, 180 m, 260 m, 360 m, 460 m,

600 m, 800 m, 1600 m, 2600 m and 4600 m at each grid point. The terrain and land use were further refined from

those used in the TAPM model to account for the increased resolution. The terrain was generated from the

Geosciences Australia 9-second arc DEM dataset at a resolution of 300 m. All default options and factors were

selected except where noted below.

Key features of CALMET used to generate the wind fields for the GLNG model are as follows:


4 August 2020

Page 45

• Domain area of 22.8 by 22.8 km with 300 m grid spacing

• 1 year time scale (1 April 2006 to 31 March 2007), divided into individual months for analysis

• Prognostic wind fields input as MM5/3D.Dat "initial guess" field only (as generated from TAPM)

• Step 1 wind field options include kinematic effects, divergence minimisation, Froude adjustment to a

critical Froude number of 1 and slope flows

• Terrain radius of influence set at 2 kilometre

• Cloud cover calculated from prognostic relative humidity.

B2 CALPUFF DISPERSION MODELLING METHODOLOGY

B2.1 Model configuration

Atmospheric dispersion modelling was carried out using the CALPUFF dispersion model. CALPUFF is a non-

steady-state puff dispersion model, and is accepted for use by the DERM for application in environments where

wind patterns and plume dispersion is strongly influenced by complex terrain and the land-sea interface. The

Gladstone region consists of highly complex meteorology, and includes complex terrain, highly variable land uses

and a land-sea interface and coastal islands. The CALPUFF dispersion model was used to predict ground-level

concentrations of air contaminants downwind of this source. The same grid size and resolution developed for the

fine resolution CALMET model was used for the dimensions of the CALPUFF domain.

B2.2 Other plant source characteristics

CALPUFF was configured with default options and parameters, with the following exceptions:

• Modelling period from 1 April 2006 to 31 March 2007

• 94 x 94 grid point domain with 0.3km resolution

• Gridded three-dimensional hourly-varying meteorological conditions generated by CALMET

• No chemical transformation or wet removal modelled

• PDF used for dispersion under convective conditions

• Dispersion coefficients calculated internally from sigma v and sigma w using micrometeorological

variables.


4 August 2020

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Table A7 Stack characteristics of GLNG Plant included in the assessment

Train Source East

Coord (m) North

Coord (m) Height

(m)4

Diameter (m)

Temp (oC) Exit

velocity1

(m/s)

Emissions (g/s)

NOX2 CO3 PM10/PM2.53

A1 Methane Comp. Driver Stack 317,497 7,369,554 32 3.58 508.5 12 3.6 1.94 0.2

A2 Methane Comp. Driver Stack 317,511 7,369,554 32 3.58 507 12 3.6 1.94 0.2

A3-W Ethylene Comp. Driver Stack 317,525 7,369,554 44 2.5 240.5 8.5 3.6 1.94 0.2

A4-W Ethylene Comp. Driver Stack 317,539 7,369,554 44 2.5 244.5 8.5 3.6 1.94 0.2

A5 Propane Comp. Driver Stack 317,553 7,369,554 32 3.58 494 12 3.6 1.94 0.2

A6 Propane Comp. Driver Stack 317,567 7,369,554 32 3.58 504 12 3.6 1.94 0.2

A8 Hot Oil Heater 317,687 7,369,565 41 2.00 179.33 1.2 0.95 0.99 0.09

A9 GTG Turbine Driver Stack 317,821 7,369,568 30 1.95 546 26 1.74 0.43 0.04


A11 GTG Turbine Driver Stack 317,821 7,369,536 30 1.8 517.5 19 1.74 0.43 0.04


B1 Methane Comp. Driver Stack 317,497 7,369,332 32 3.58 498.5 12 3.6 1.94 0.2

B2 Methane Comp. Driver Stack 317,511 7,369,332 32 3.58 481 12 3.6 1.94 0.2

B3-W Ethylene Comp. Driver Stack 317,525 7,369,332 44 2.5 250.5 2.4 3.6 1.94 0.2

B4-W Ethylene Comp. Driver Stack 317,539 7,369,332 44 2.5 265 2.4 3.6 1.94 0.2

B5 Propane Comp. Driver Stack 317,553 7,369,332 32 3.58 490.5 12 3.6 1.94 0.2

B6 Propane Comp. Driver Stack 317,567 7,369,332 32 3.58 504 12 3.6 1.94 0.2

B8 Hot Oil Heater 317,687 7,369,343 41 2 184.25 1.2 0.95 0.99 0.09

B9 GTG Turbine Driver Stack 317,821 7,369,297 30 1.9 374 19 1.74 0.43 0.04

B10 GTG Turbine Driver Stack 317,821 7,369,314 30 1.95 470 19 1.74 0.43 0.04

Table note: 1 Minimum exit velocity as per Schedule B – Table 1 EPPG00712213 2 Maximum mass rate as per Schedule B – Table 2 EPPG00712213’ 3 Emission rates from EIS (Appendix S GLNG Environmental Impact Statement – Air Quality (URS, 2009)) 4 Minimum exit velocity as per Schedule B – Table 1 EPPG00712213


4 August 2020

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APPENDIX C – DISPERSION MODELLING RESULTS


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Table C1 Predicted concentrations of NO2, CO and PM10/PM2.5 in isolation, with plant and with plant and background for Scenario 1


inventory for planned maintenance activities

Flare in isolation µg/m3 Flare with plant µg/m3 Flare with plant, plus background µg/m3

1-hourNO2

8-hourCO

24-hourPM10

24-hourPM2.5

1-hourNO2

1

8-hourCO

24-hourPM10

24-hourPM2.5

1-hourNO2

1

8-hourCO

24-hourPM10

24-hourPM2.5

R1 3.5 12.2 1.0 1.0 4.9 12.4 1.0 1.0 43.2 262.4 37.0 17.67

R2 2.1 15.0 1.3 1.3 4.4 15.4 1.5 1.5 41.5 265.4 37.5 17.67

R3 3.4 9.2 0.8 0.8 3.8 9.3 0.8 0.8 47.5 259.3 36.8 17.67

R4 3.3 8.7 0.7 0.7 3.9 9.0 0.7 0.7 48.9 259.0 36.7 17.67

R5 2.7 9.6 0.8 0.8 3.8 10.4 0.9 0.9 57.0 260.4 36.9 17.67

R6 2.7 11.5 1.0 1.0 4.9 11.5 1.0 1.0 74.5 261.5 37.0 17.67

R7 1.3 6.8 0.5 0.5 4.6 8.1 0.5 0.5 67.4 258.1 36.5 18.2

R8 2.9 6.5 0.5 0.5 2.8 7.2 0.6 0.6 73.0 257.2 36.6 18.3

R9 0.9 4.9 0.4 0.4 3.3 4.9 0.4 0.4 50.9 254.9 36.4 18.1

R11 1.0 3.3 0.3 0.3 6.1 8.6 0.4 0.4 40.2 258.6 36.4 18.1

R12 0.5 3.0 0.3 0.3 5.2 6.2 0.3 0.3 45.6 256.2 36.3 18.0

R13 0.8 3.1 0.3 0.3 4.7 5.5 0.3 0.3 28.5 255.5 36.3 18.0

R14 0.6 2.2 0.2 0.2 3.9 4.8 0.2 0.2 30.7 254.8 36.2 17.9

R15 0.8 3.1 0.3 0.3 2.9 4.5 0.3 0.3 23.0 254.5 36.3 18.0

R16 0.6 2.1 0.2 0.2 3.2 3.4 0.2 0.2 17.5 253.4 36.2 17.9

R17 0.7 2.9 0.3 0.3 2.5 3.6 0.3 0.3 27.5 253.6 36.3 17.9

R18 0.7 3.9 0.3 0.3 2.9 5.1 0.4 0.4 20.4 255.1 36.4 18.1

R19 0.7 3.9 0.3 0.3 2.8 5.0 0.4 0.4 20.0 255.0 36.4 18.1

R20 0.6 3.8 0.3 0.3 2.4 4.8 0.4 0.4 20.2 254.8 36.4 18.1

R21 - QCLNG accommodation camp

0.9 3.4 0.2 0.2 14.9 21.4 1.6 1.6 53.2 271.4 37.6 19.2

R22 - APLNG accommodation camp

1.5 3.6 0.2 0.2 11.8 17.5 0.9 0.9 50.6 267.5 36.9 18.5

Curtis Island National Park 6.5 24.2 2.0 2.0 6.2 25.7 2.0 2.0 36.0 275.7 38.0 19.7

Curtis Island Conservation Park 2.7 9.0 0.8 0.8 5.7 9.4 0.8 0.8 44.8 259.4 36.8 18.5


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1-hourNO2

8-hourCO

24-hourPM10

24-hourPM2.5

1-hourNO2

1

8-hourCO

24-hourPM10

24-hourPM2.5

1-hourNO2

1

8-hourCO

24-hourPM10

24-hourPM2.5

Curtis Island State Forest 4.5 8.7 0.8 0.8 5.8 9.9 0.8 0.8 38.5 259.9 36.8 18.5


7.3 26.2 2.1 2.1 58.2 146.9 6.0 6.0 75.4 396.9 42.0 23.6

Targinie State Forest 3.2 13.3 1.1 1.1 13.4 13.8 1.3 1.3 63.2 263.8 37.3 19.0

Objective 250 11,000 50 25 250 11,000 50 25 250 11,000 50 25

Table note: 1 Cumulative NO2 presented as 99.9th highest





1-hourNO2

8-hourCO

24-hourPM10

24-hourPM2.5

1-hourNO2

1

8-hourCO

24-hourPM10

24-hourPM2.5

1-hourNO2

1

8-hourCO

24-hourPM10

24-hourPM2.5

R1 2.4 6.6 0.8 0.8 4.9 7.2 1.0 1.0 43.2 257 37 18.7

R2 1.5 7.8 0.9 0.9 4.4 8.2 1.4 1.4 41.5 258 37 19.1

R3 2.0 5.8 0.7 0.7 3.8 6.9 0.9 0.9 47.5 257 37 18.6

R4 1.6 5.6 0.7 0.7 3.8 6.3 0.9 0.9 48.9 256 37 18.5

R5 2.2 7.2 0.9 0.9 3.8 8.0 1.1 1.1 57.0 258 37 18.7

R6 1.8 8.9 1.1 1.1 4.9 8.9 1.4 1.4 74.5 259 37 19.0

R7 0.5 2.8 0.3 0.3 4.6 4.5 0.5 0.5 67.4 255 36 18.1

R8 1.9 3.7 0.4 0.4 2.7 4.4 0.6 0.6 73.0 254 37 18.3

R9 0.5 2.2 0.3 0.3 3.3 3.2 0.4 0.4 50.9 253 36 18.1

R11 0.2 0.8 0.1 0.1 6.1 8.6 0.4 0.4 40.2 259 36 18.1

R12 0.1 0.8 0.1 0.1 5.2 5.6 0.3 0.3 45.6 256 36 17.9

R13 0.7 1.8 0.3 0.3 4.7 5.5 0.3 0.3 28.5 255 36 18.0

R14 0.4 1.1 0.2 0.2 3.9 4.6 0.2 0.2 30.7 255 36 17.9

R15 0.4 1.1 0.2 0.2 2.9 3.5 0.3 0.3 23.0 254 36 18.0

R16 0.3 0.6 0.1 0.1 3.2 3.2 0.2 0.2 17.5 253 36 17.9


4 August 2020

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1-hourNO2

8-hourCO

24-hourPM10

24-hourPM2.5

1-hourNO2

1

8-hourCO

24-hourPM10

24-hourPM2.5

1-hourNO2

1

8-hourCO

24-hourPM10

24-hourPM2.5

R17 0.5 1.8 0.3 0.3 2.5 3.5 0.4 0.4 27.5 254 36 18.0

R18 0.6 2.8 0.3 0.3 2.9 2.8 0.4 0.4 20.4 253 36 18.0

R19 0.6 2.5 0.3 0.3 2.8 2.7 0.4 0.4 20.0 253 36 18.0

R20 0.5 2.3 0.3 0.3 2.4 2.6 0.4 0.4 20.2 253 36 18.0


0.2 0.7 0.2 0.2 14.9 21.4 1.6 1.6 53.2 271 38 19.2


0.2 0.7 0.2 0.2 11.8 17.5 0.9 0.9 50.6 268 37 18.5

Curtis Island National Park 1.8 8.8 1.0 1.0 6.0 9.9 2.2 2.2 36.0 260 38 19.9

Curtis Island Conservation Park 2.1 5.6 0.7 0.7 5.7 5.8 1.0 1.0 44.8 256 37 18.7

Curtis Island State Forest 3.0 6.0 0.7 0.7 5.8 7.2 1.0 1.0 38.4 257 37 18.7


4.3 15.0 1.8 1.8 58.2 146.9 5.9 5.9 75.4 397 42 23.6

Targinie State Forest 2.4 8.2 1.0 1.0 13.4 12.4 1.3 1.3 63.2 262 37 19.0

Objective 250 11,000 50 25 250 11,000 50 25 250 11,000 50 25





1-hourNO2

8-hourCO

24-hourPM10

24-hourPM2.5

1-hourNO2

1

8-hourCO

24-hourPM10

24-hourPM2.5

1-hourNO2

1

8-hourCO

24-hourPM10

24-hourPM2.5

R1 4.3 11.6 0.04 0.04 4.9 11.8 0.4 0.4 43.2 261.8 36.4 17.67

R2 3.5 7.6 0.03 0.03 4.4 7.8 0.2 0.2 41.5 257.8 36.2 17.67

R3 6.7 19.9 0.07 0.07 4.0 19.9 0.2 0.2 47.5 269.9 36.2 17.67

R4 2.6 5.2 0.02 0.02 3.8 5.2 0.2 0.2 49.0 255.2 36.2 17.67

R5 3.5 7.7 0.03 0.03 3.9 7.9 0.1 0.1 57.0 257.9 36.1 17.67

R6 2.4 9.4 0.03 0.03 4.9 10.2 0.1 0.1 74.5 260.2 36.1 17.67


4 August 2020

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1-hour NO2

8-hour CO

24-hour PM10

24-hour PM2.5

1-hour NO2

1 8-hour

CO 24-hour

PM10 24-hour

PM2.5 1-hour NO2

1 8-hour

CO 24-hour

PM10 24-hour

PM2.5

R7 1.0 5.1 0.02 0.02 4.6 6.0 0.2 0.2 67.4 256.0 36.2 17.9

R8 0.9 3.4 0.01 0.01 2.7 4.1 0.1 0.1 73.0 254.1 36.1 17.8

R9 1.1 3.6 0.01 0.01 3.3 3.6 0.1 0.1 50.9 253.6 36.1 17.8

R11 0.4 1.8 0.01 0.01 6.1 8.6 0.3 0.3 40.2 258.6 36.3 18.0

R12 0.2 0.7 0.00 0.00 5.2 5.6 0.3 0.3 45.6 255.6 36.3 17.9

R13 0.3 1.3 0.00 0.00 4.7 5.5 0.2 0.2 28.5 255.5 36.2 17.9

R14 0.3 1.0 0.00 0.00 3.9 4.6 0.2 0.2 30.7 254.6 36.2 17.9

R15 0.3 0.9 0.00 0.00 2.9 3.5 0.2 0.2 23.0 253.5 36.2 17.8

R16 0.2 0.5 0.00 0.00 3.2 3.2 0.1 0.1 17.5 253.2 36.1 17.8

R17 2.2 6.2 0.02 0.02 2.6 6.2 0.1 0.1 27.5 256.2 36.1 17.8

R18 1.5 7.0 0.03 0.03 2.9 7.1 0.1 0.1 20.4 257.1 36.1 17.8

R19 1.4 5.9 0.02 0.02 2.8 6.0 0.1 0.1 20.0 256.0 36.1 17.8

R20 1.3 5.0 0.02 0.02 2.4 5.1 0.1 0.1 20.2 255.1 36.1 17.8


0.2 0.9 0.00 0.00 14.9 21.4 1.6 1.6 53.2 271.4 37.6 19.2


0.2 0.9 0.00 0.00 11.8 17.5 0.9 0.9 50.6 267.5 36.9 18.5

Curtis Island National Park 5.0 10.0 0.04 0.04 6.0 10.0 0.3 0.3 36.0 260.0 36.3 18.0

Curtis Island Conservation Park 5.1 13.8 0.05 0.05 5.7 13.8 0.3 0.3 44.8 263.8 36.3 18.0

Curtis Island State Forest 4.9 14.2 0.05 0.05 5.8 14.4 0.3 0.3 38.4 264.4 36.3 18.0


5.0 13.8 0.05 0.05 58.2 146.9 5.9 5.9 75.4 396.9 41.9 23.6

Targinie State Forest 4.0 15.2 0.06 0.06 13.5 15.3 0.4 0.4 63.2 265.3 36.4 18.1

Objective 250 11,000 50 25 250 11,000 50 25 250 11,000 50 25



4 August 2020

Page 52

Plate C1 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 53

Plate C2 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + GAMS background)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 54

Plate C3 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 55

Plate C4 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 56

Plate C5 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation). All PM10 is assumed to be PM2.5.

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

PM10: 50 µg/m³

PM2.5: 25 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 57

Plate C6 Predicted maximum 24-hour average ground level concentrations of PM10 due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

50 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 58

Plate C7 Predicted maximum 24-hour average ground level concentrations of PM2.5 due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

25 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 59

Plate C8 Predicted maximum 1-hour average ground level concentrations of fluoranthene due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

0.5 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 60

Plate C9 Predicted maximum 1-hour average ground level concentrations of propylene due to Scenario 1 – 2019 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

8,750 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 61

Plate C10 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 62

Plate C11 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + GAMS background)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 63

Plate C12 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 64

Plate C13 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 65

Plate C14 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation). All PM10 is assumed to be PM2.5.

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

PM10: 50 µg/m³

PM2.5: 25 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 66

Plate C15 Predicted maximum 24-hour average ground level concentrations of PM10 due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

50 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 67

Plate C16 Predicted maximum 24-hour average ground level concentrations of PM2.5 due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

25 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 68

Plate C17 Predicted maximum 1-hour average ground level concentrations of fluoranthene due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

0.5 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 69

Plate C18 Predicted maximum 1-hour average ground level concentrations of propylene due to Scenario 2 – 2016 major shutdown: single train propane system de-inventory for planned maintenance activities (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

8,750 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 70

Plate C19 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 71

Plate C20 Predicted maximum 1-hour average ground level concentrations of NO2 due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + GAMS background)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

250 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 72

Plate C21 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 73

Plate C22 Predicted maximum 8-hour average ground level concentrations of CO due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

8-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

11,000 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 74

Plate C23 Predicted maximum 24-hour average ground level concentrations of PM due to Scenario 3 – Upset Train 1 Propane and Ethylene Valves Open to Flare (flare in isolation). All PM10 is assumed to be PM2.5.

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

PM10: 50 µg/m³

PM2.5: 25 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 75

Plate C24 Predicted maximum 24-hour average ground level concentrations of PM10 due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

50 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 76

Plate C25 Predicted maximum 24-hour average ground level concentrations of PM2.5 due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare + GLNG plant + ambient background)

Location:

Gladstone

Averaging period:

24-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

25 µg/m³

Prepared by:

P McDowell

Date:

2020


4 August 2020

Page 77

Plate C26 Predicted maximum 1-hour average ground level concentrations of fluoranthene due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

0.5 µg/m³

Prepared by:

P. McDowell

Date:

2020


4 August 2020

Page 78

Plate C27 Predicted maximum 1-hour average ground level concentrations of propylene due to Scenario 3 – Upset event: Emergency Depressuring Valve (EDP) valve failed open (flare in isolation)

Location:

Gladstone

Averaging period:

1-hour

Data source:

CALPUFF

Units:

µg/m³

Type:

Maximum contours

Objective:

8,750 µg/m³

Prepared by:

P. McDowell

Date:

2020

Appendix C - Flaring Contingency Management Plan


This document contains confidential information and is not to be disclosed to any third parties without prior written permission from the CEO GLNG Operations Pty Ltd.

UNCONTROLLED IF PRINTED

Flaring Contingency Management Plan Document Number: 3310-GLNG-5-1.3-0013

Author: Name Title

Environmental Adviser

Checked by: Name Title

Team Leader LNG Plant Process Engineering

Approved by: Name Title

Plant Manager

Date Rev Reason For Issue Author Checked Approved0 DH BC

29/04/2019 1 For issue MR RM GJ


Table of Contents

1. PURPOSE ........................................................................................................................ 2 2. SUMMARY OF RESPONSIBILITIES ............................................................................... 2 3. BACKGROUND ................................................................................................................ 3

3.1. Facility Flares ........................................................................................................ 4 3.2. Flare Emissions ..................................................................................................... 6 3.3. Flaring Events ........................................................................................................ 6

Planned Flaring Events ......................................................................... 6 Unplanned/Upset Flaring Events .......................................................... 6

3.4. Flaring Environmental Impacts .............................................................................. 8 4. OBJECTIVES ................................................................................................................... 8 5. PERFORMANCE CRITERIA ............................................................................................ 8

5.1. Legislation and Standards ..................................................................................... 8 5.2. Performance Criteria ............................................................................................. 9

6. MANAGEMENT MEASURES ......................................................................................... 10 7. MONITORING AND REPORTING ................................................................................. 14 8. AUDITING ....................................................................................................................... 14 9. CORRECTIVE ACTIONS ............................................................................................... 14 10. DEFINITIONS ................................................................................................................. 15

Page 2 UNCONTROLLED IF PRINTED 3310-GLNG-5-1.3-0013

1. PURPOSEThis Plan addresses the objectives and performance criteria, management measures, and monitoring, auditing, and corrective action requirements relating to flaring for the Santos GLNG OPL LNG Facility on Curtis Island.

Management measures and reporting and auditing requirements specified are intended to ensure compliance with the requirements of the Environmental Authority (EA) EPPG00712213, and other relevant approvals under applicable Queensland and Commonwealth legislation.

This document applies to operation of the LNG Facility. It addresses flaring activity relating to LNG Operations within the bounds of Petroleum Facility Licence (PFL) 10 on Curtis Island, near Gladstone.

2. SUMMARY OF RESPONSIBILITIESThe following, summary of responsibilities apply for personnel undertaking activities covered by this document.

Table 1: Summary of Responsibilities Role Responsibilities

Plant Manager Operate the plant to minimise flaring, achieve optimalperformance and meet the flaring related criteria asstipulated in the EA.

Ensure that key stakeholders, as stipulated in this plan,are provided with timely information regarding plannedshutdowns and associated flaring activity to facilitatenotifications to stakeholders.

Engage key stakeholders during the shutdown planningprocess.

Provide key stakeholders with timely, accurate informationin relation to unplanned flaring events.

Provide input to MOC assessments to assess the viabilityof recommended initiatives to reduce flaring activity.

Ensure that process controls identified by Engineering areimplemented in order to reduce flaring activity as far aspracticable.

Maintenance Manager Maintain the plant to improve reliability and reduce flaringactivity as far as practicable.

Manage flare maintenance. Actively participate in planning of shutdowns and execute

all shutdown activities such that flaring is minimisedthrough management of shutdown schedules, purging andisolation of equipment.

Shift Superintendent Ensure logging of planned and unplanned flaring events inthe Flaring Register.

Engineering Manager Provide engineering technical input for responses to acomplaint or information request from the AdministeringAuthority.


Role Responsibilities Provide technical advice regarding initiatives to reduce

flaring activity. Actively drive all Management of Change on the facility,

with due consideration to potential impacts on Flaring,Principal Environment Advisor Liase with regulatory environmental departments regarding

any flaring issues Communicate flaring related non-compliances with the EA

to the Administering Authority. Oversee the evaluation of compliance with environmental

legislation and regulations, permits, licences andapprovals.

Oversee incident investigations and development ofcorrective actions for operations implementation.

Provide input to Management of Change (MOC)assessments to assess the viability of recommendedinitiatives to reduce flaring activity.

Environmental Advisor (note this can also be a Senior Environmental Advisor)

Coordinate the collation of information required fromDownstream Operations in response to a complaint orinformation request from the Administering Authority.

Provide the Operations Manager and MaintenanceManager with environmental technical and regulatorycompliance support with regard to this management plan.

Participate in flaring related environmental incidentinvestigations as required.

Collate environmental incident reports and associatedregulatory notifications

Monitor the implementation of the management measuresand identify corrective actions.

Communicate the need for corrective actions to QBU-Environment Team, Site Management and GLNG OPLEHSS&T Manager.

Interact with Administering Authority, as directed. Participate in audits against the SMS. Facilitate site aspects of third party auditing of the EA

conditions.Community Engagement Advisor

Provide timely notifications to key stakeholders on flaringactivity.

Provide EQ Assets – Environment and the DSOEnvironmental Advisor with the details of any flaringrelated complaints or information requests.

Provide technical advice to External Affairs in relation toany complaints or information requests from thecommunity.

3. BACKGROUNDSantos GLNG OPL processes Coal Seam Gas to produce Liquefied Natural Gas (LNG). The feed gas stream is primarily methane and both propane and ethylene refrigerants are used in the liquefaction process. These three components comprise over 99.9% of materials that


can enter the flares. During normal operations, natural gas and other hydrocarbons flow continuously through the LNG Facility. The flaring system facilitates purging of the Facility during planned shutdowns for routine maintenance activities, unplanned repairs to defective infrastructure or emergency situations. The system includes three separate flare systems and is common for both Train 1 and Train 2. Flaring ensures that hydrocarbons are safely combusted and are not emitted to atmosphere.

3.1. Facility Flares

The Santos GLNG OPL Facility flare system is comprised of the following components:

Wet Process Flare: Designed to handle warm hydrocarbon streams that may besaturated with water vapour and/or contain free liquid hydrocarbons and water;

Dry Process Flare: Designed to handle cryogenic hydrocarbons, both vapour andliquid;

Back-up Wet and Dry Flare; and Marine Flare: Designed to handle LNG vapours from the LNG Storage Tanks in the

event of Boil Off Gas Compressors failure and/or shiploading.

Flare locations are provided in Figure 1 (N.B. On Figure 1 - A13 is Wet Gas Flare, A14 is the Marine Flare, A15 is the Dry Flare and A16 is the back-up Wet and Dry Flare).


Figure 1: Flare Locations (A13 to A16)


3.2. Flare Emissions

Coal seam gas processed at the Facility is comprised of the following:

Approximately 98% Methane; and The remaining 2% is comprised of small quantities of Nitrogen (N2), Carbon

Dioxide (CO2) and Ethane (C2H6) and traces of heavier hydrocarbons.

During normal operating conditions, some gas is combusted in the flares in a pilot flame, designed to provide a continuous ignition source such that any gas sent to the flare as a result of upset conditions is immediately combusted. The pilot flare is a small, smokeless flame which emits small volumes of carbon dioxide, nitrogen oxides and water vapour. The flare purge is a necessary safety requirement to prevent any ingress of air into the flare system.

Non-normal operations refer to conditions at the LNG Facility that are outside the general operating parameters of the plant and occur intermittently for a short duration resulting in flaring events. Emission rates for these activities may also be variable and, consequently, do not impact air quality on a continual basis. During non-normal operations, the combustion efficiency of the flare may be reduced by the presence of refrigerants and Nitrogen (used for purging gas lines in the Facility). This results in the emission of Oxides of Nitrogen, Carbon Monoxide (CO), Total Hydrocarbons (Methane, Ethane, Ethylene, Propane), Particulates in the form of PM2.5 and PM10 and trace Polycyclic Aromatic Hydrocarbons (PAH’s).

3.3. Flaring Events

Planned Flaring Events

Planned flaring occurs several times per annum during routine maintenance activities and are normally associated with plant and equipment shut-down and start-up processes.

During some shutdowns, de-inventory of the gas process lines and or refrigerant lines will be required to enable safe access whilst the plant is shut down for maintenance/inspection purposes. Refrigerant vapours may need to be sent to the flare during these situations which may result in flaring events.

Planned flaring can also occur during shiploading activities. It should however be noted that unplanned events can also occur during shiploading activities. Whilst every attempt is made to eliminate flaring during ship loading at times it may be required in the case of the arrival of a warm ship requiring cool down or in the management of larger volumes of boil off gas.

Unplanned/Upset Flaring Events


Unplanned flaring can occur at any time during upset conditions on either or both LNG Trains.

Typical causes of unplanned flaring events include the following:

Regeneration Gas Compressor Trips: The Regeneration Gas Compressor isused to recover natural gas used for regeneration of the molecular sieve beds.The molecular sieves are used to remove moisture from the gas, which is arequirement prior to liquefaction. Whenever the regeneration gas compressortrips, gas is diverted to the Wet Process Flare. The duration of flaring can vary,and takes place until such time that the regeneration gas compressor is returnedto service. Flaring is also required during the compressor restart;

Nitrogen Rejection Unit (NRU) Off Specification: The NRU extracts Nitrogenfrom the feed gas, an essential efficiency component of the liquefaction process.When this unit malfunctions, the feed gas to the NRU is typically diverted to theDry Process Flare;

Gas Turbine Compressor Trips: Gas Turbine Compressors (GTCs) are criticalto the liquefaction process. These units form part of the refrigerant loops whichchill feed gas, leading to liquefaction. When GTCs shutdown, they may requiredepressurisation prior to restarting, which results in flaring activity.Depressurisation of the GTC casings can result in gas or refrigerant vapour beingsent to flare, which causes varying degrees of smoke emissions (dependent onwhich GTC is being depressurised). Re-start of the propane compressors canalso require drainage of liquid propane from the compressor casings to the flare.Re-start of gas turbines associated with the refrigerant compressors can alsorequire flaring of fuel gas as part of the start-up operation of the turbines;

Boil Off Gas (BOG) Compressor Failure: The GLNG Facility has three (3) BOGcompressors, which recycle boil off gas from the LNG Storage Tanks and shiploading back into the liquefaction process. This is an energy saving operationwhich also prevents unnecessary flaring of methane gas. When the BOGcompressors malfunction, gas is diverted to the Marine Flare. The volume of gasthat is diverted to the Marine Flare varies and is dependent on the number ofBOG compressors that are unavailable, as well as, whether or not there is shiploading activity;

Overpressure Release of Hydrocarbon by Pressure Controller or ReliefValve: During upset conditions, correct functioning of pressure controllers andrelief valves will prevent equipment overpressure by releasing hydrocarbons toflare. This is only expected to be for short duration until the process is broughtback to normal operating pressure. However, in the event of passing pressurecontrol valves or relief valves, the flaring may continue until the plant can beshutdown for rectification work;

Emergency Shutdown of LNG Train: During emergencies, the LNG train canbe shutdown automatically or manually. Depending on the nature of the


emergency, hydrocarbon may need to be sent to the flare to depressurise the train or pressure controller may open to flare as the train warms up and inventory pressures rise;

Emergency Depressurisation of Gas Process and Refrigeration Circuits:During emergency depressurisation of the gas process stream and refrigerationcircuits and subsequent train shutdown, gas or refrigerants will be sent to theflare to deinventory the train;

Flaring during Shiploading: Unplanned flaring can occur during ship loadingwhen return vapours exceed the capacity of the plant’s BOG compressors tomanage the vapour load. This gas is flared at the marine flare; and,

Emergency Depressurisation of the Gas Transmission Pipeline (GTP): TheLNG facility flare system can be used as part of the process required foremergency depressurisation of the GTP.

3.4. Flaring Environmental Impacts

As part of the performance test of the plant prior to hand over to GLNG, each flare stack was tested on its performance to meet flame stability requirement and designed operation at individual flare design flow rates with feed gas.

4. OBJECTIVESThe objectives of this management plan are to:

Reduce flaring activity as far as practicable. Manage social impacts associated with unavoidable flaring by providing timely and

accurate notifications to key stakeholders. Operate in a manner that minimises impacts on ambient air quality. Preserve ambient air quality to the extent that ecological health, public amenity or

safety is maintained.

5. PERFORMANCE CRITERIA

5.1. Legislation and Standards

The performance criteria and implementation strategy has been developed withreference to:

Environmental Protection Act (1994) (EP Act) (Qld). Environmental Protection Regulation (2008) (Qld). Environment Protection (Air) Policy (2008) (EPP (Air)) (Qld). National Environment Protection Measure (Air). Environmental Authority EPPG00712213.


5.2. Performance Criteria

The performance criteria for this management plan are as follows:

Visual smoke and particulate emissions will not occur for more than five (5)minutes in any two (2) hour period during normal operating conditions.

Key stakeholders to be notified of planned flaring events a minimum of 24 hoursprior to the event.

Key information regarding unplanned flaring events to be captured as per theProceduire for Recording Flaring Events 3301-GLNG-5-1.3-0023.

Flaring event details shall be reviewed on a regular basis and where appropriatemitigation measures implemented to reduce future flaring activity.

Duration and extent of flaring to be reduced as low as reasonably practicablethrough implementation of operational controls.

Timely responses to information requests to be provided to all stakeholders. Corrective actions identified will be implemented as soon as practicable following

an unplanned flaring event.


6. MANAGEMENT MEASURES

Management Criteria Management Measure Responsibility 6.1 Competency Based Training Appropriately training personnel Training and Operations

Governance 6.2 Operator Essential Care Operations routine monitoring of flare is included in Operator Essentail Care Tasks.

Routine tasks undertaken by Operators to ensure flare is operating satisfactorily. Operations

6.3 Operating Envelope Management Process alarms in place to advise operators and minimise possibility of operational upsets and train trip.

GLNG Engineering

6.4 Plant process efficiency monitoring (including flare monitoring)

Flaring is reported in monthly operations meetings. GLNG Engineering

6.5 GE Remote Monitoring and diagnostics

24 hour monitoring of refrigerant compressors and turbines to ensure equipment is operating at optimal performance. RM&D (Remote Monitoring & Diagnostics), AHM (Asset health management), DDE (Dedicated Diagnostic Engineer).

GLNG Engineering

6.6 Reliability and Maintenance Management Standards

Improve reliability reduce trips, reducing flaring events. Focus on defect elimination. GLNG has a robust risk based system for the prioritisation of break in work outside of a disciplined schedule.

GLNG Engineering

6.7 Asset Reliability Improvement Plan (ARIP)

Monitoring of equipment reliability and management of bad actors via TRP (Trip Reduction Program) and PEP (Performance Enhancement Program) to predict and improve equipment efficiency and performance.

GLNG Engineering

6.8 Flaring only to be undertaken from the Process and Marine Flares, as detailed in the EA.

The design of the Plant only facilitates flaring at these locations. Therefore no additional management measures are required.

N/A


Management Criteria Management Measure Responsibility 6.9 Visible smoke (Ringleman >2) and particulate emissions will not occur for more than five (5) minutes in any two (2) hour period during normal operatingconditions.

Design of the flares has addressed the requirement that visible smoke and particulate emissions are not to occur for more than five (5) minutes in any two (2) hour period during normal operating conditions.

Record events which do not meet this criteria as per the Procedure for Recording Flaring Events” – Document Number 3310-GLNG-5-1.3-0023.

Emergency Procedures have been developed and are implemented for non-routine situations to deal with foreseeable risks and hazards including corrective responses to prevent and mitigate environmental harm (Santos GLNG OPL Emergency Response Plan 3301-GLNG-5-1.6-0024).

Operations / GLNG Engineering

6.10 Key stakeholders to be notified of planned flaring events a minimum of 24 hours prior to the event.

Key stakeholders to be engaged during shutdown planning process and provided with a forecast flaring schedule for the event. The forecast is to be updated regularly throughout the event.

Key community stakeholders to be notified a minimum of 24 hours ahead of planned flaring events.

DES to be notified a minimum of 24 hours ahead of planned significant flaring events. Planned significant flaring events to be entered into the Flaring Register.

Community Relations Officer

6.11 Unplanned flaring events that produce visible smoke and particulate emissions (as per 6.9 above) are to be recorded.

These should be recorded as per the requirements of the “Procedure for Recording Flaring Events” – Document Number 3310-GLNG-5-1.3-0023.

Operations Shift Superintendents

6.12 Duration and extent of flaring to be reduced as low as reasonably practicable through implementation of operational controls.

The following typical upset conditions result in unplanned flaring events. The following mitigation measures are to be implemented where possible to reduce the extent and severity of flaring:

Regeneration Gas Compressor Trips: Whenever practical, pause dehydrationsequence;

Nitrogen Rejection Unit (NRU) Off Specification: Limited options availabletherefore bring NRU back to specification as soon as practicable;

Operations / GLNG Engineering


Management Criteria Management Measure Responsibility Gas Turbine Compressor Trips Limit time taken to restart compressors; and

abide by vendor recommended casing pressure to initiate restart of each GTC; Overpressure Release of Hydrocarbon by Pressure Controller or Relief

Valve: Correct functioning of pressure controller and relief valve would preventoverpressure by releasing hydrocarbon to flare. This is only expected to be forshort duration until the process is brought back to normal operating pressure.However, in the event of passing pressure controller valve or relief valve, theflaring may continue until the plant can be shutdown for rectification work.

Emergency Depressurisation of Gas Process and Refrigeration Circuits:Engineering investigation into the process upsets and flare performance.

Emergency Shutdown of LNG Train: During emergency, LNG train can beshutdown either automatically or manually. Depending on the nature of theemergency, hydrocarbon may need to be sent to the flare to depressurise thetrain or pressure controller may open to flare as the train warms up.

The following planned conditions result in flaring events. The following mitigation measures are to be implemented where possible to reduce the extent and severity of flaring:

De-inventory of refrigerant vapour: Where practical deinventory refrigerantvapour from an offline train into the online train rather than to flare.

Restarting Compressor Turbines: As far as practicable, minimise internaldepressurisation to flare for restarting compressor turbines

Ship Loading: Ensure minimum required BOG compressors are online inadvance of shipping operations.

Shutdown planning to identify and implement initiatives to reduce flaring activity as far as practicable throughout the shutdown period. These initiatives are to include, but not be limited to those detailed above.

6.13 Timely responses to information requests to be provided by all stakeholders.

Coordinate information request responses.

Collation of information for provision to EQ Assets - Environment, to be utilised in the response.

Operations/ GLNG Engineering


Management Criteria Management Measure Responsibility

6.14 Manage complaints Field complaints and seek technical input from key stakeholders, as required. Community Relations 6.15 Corrective actions will be implemented as soon as practicable where required

The cause of the significant flaring events will be identified and where required associated corrective actions implemented in a timely manner.

Operations


7. MONITORING AND REPORTINGMonitoring and reporting is to be undertaken as specified in Schedules B, I and K of the EA and in accordance with the following requirements:

An incident is to be raised in IMS and notification to relevant stakeholders if visiblesmoke and particulate emissions are observed for more than five (5) minutes in anytwo (2) hour period during normal operating conditions in accordance with EAcondition B19. The environment team must be notified of an event like this within 12hours of occurrence.

DES and other key stakeholders to be notified a minimum of 24 hours ahead ofsignificant planned flaring events.

Where required reporting on monitoring undertaken in response to complaints orspecific direction of the Administering Authority will be provided within ten (10) daysof completion of the investigation or receipt of monitoring results, whichever is thelatter, in accordance with EA condition K5.

Monitoring outcomes and corrective actions (if required) will be reported in the AnnualMonitoring Report.

8. AUDITINGThe SMS must be regularly audited to ensure its continuing suitability, adequacy and effectiveness and meet Santos GLNG OPL commitment to continual improvement. Regular internal audits of the SMS are conducted, covering all activities within the scope of the SMS. Santos GLNG OPL will also ensure that a qualified third party auditor (accepted by the Administering Authority) undertakes compliance monitoring against the EA conditions as required by the EA.

9. CORRECTIVE ACTIONS

Description Responsibility Should visible smoke and particulate emissions occur for more than five (5) minutes in any two (2) hour period during normal operating conditions the Operations Shift Superintendent will: 1. Consult with engineering to identify possible causes.2. Investigate mitigation measures.3. Implement appropriate mitigations if possible.

Operations Shift Superintendents

Investigate complaints and advise the Administering Authority in writing (within 14 days of completion of the investigation) of the proposed or undertaken action in relation to the complaint.

Senior Community Relations Advisor / Environmental Advisor

Undertake monitoring specified by the Administering Authority to investigate any complaint of environmental harm. Report results of the investigation and monitoring within 14 days of completion of the investigation or receipt of the monitoring results, whichever is the latter.

Environmental Advisor

Implement corrective actions if the monitoring indicates an exceedance of emission limits in the EA.

Operations and GLNG Engineering


Description Responsibility Record the following details for all complaints received and provide the information to the Administering Authority:

Name, address and contact details of complainant. Time and date of complaint. Reasons for the complaint. Investigations undertaken. Conclusions formed. Actions taken to resolve complaint. Any abatement measures implemented. Person responsible for resolving the complaint.

Senior Community Relations Advisor / Environmental Advisor

10. DEFINITIONSTerm Meaning

Administering Authority Department of Environment and Heritage Protection. The Queensland Government Department that administers the Environmental Authority under the Environmental Protection Act 1994.

CG Coordinator General CH4 Methane CO Carbon Monoxide CO2 Carbon Dioxide DCS Distributed Control System EA Environmental Authority, specifically Environmental

Authority EPPG00712213 EHP Department of Environment and Heritage Protection EP Act Environmental Protection Act 1994 (Qld) EPP (Air) Environmental Protection (Air) Policy 2008 (Qld)

GTC Gas Turbine Compressor GTP Gas Transmission Pipeline LNG Liquefied Natural Gas N2 Nitrogen Gas Normal operating conditions

Normal operating conditions are defined as the ongoing operation of the LNG plant following commissioning and excludes non-normal operating conditions such as start-up, shutdown, maintenance, calibration of emissions monitoring devices.

NOx Nitrogen Oxides NRU Nitrogen Rejection Unit PFL Petroleum Facility Licence PM10 Particulate Matter in the order of 10 micrometres or less SMS Santos Management System


APPENDIX A - EA COMPLAINT MONITORING REQUIREMENTS

In the event of a complaint or request from the Administering Authority, GLNG OPL is required to undertake monitoring specified by the Administering Authority, within a reasonable and practicable time frame nominated by the Administering Authority, to investigate any complaint of environmental harm at any sensitive or commercial place, in accordance with EA EPPG00712213 Schedule J.

The results of the investigation (including an analysis and interpretation of the monitoring results) and abatement measures implemented must be provided to the Administering Authority within ten (10) days of completion of the investigation, or receipt of monitoring results, whichever is the latter, in accordance with EA EPPG00712213 Schedule K.

Appendix D – Procedure for Recording Flaring Events


This document contains confidential information and is not to be disclosed to any third parties without prior written permission from the CEO GLNG Operations Pty Ltd.


Pro ce dure fo r Re co rdin g Flarin g Eve n ts

Document Number: 3301-GLNG-5-1.3-0023

Author: Title Name Senior Environmental Advisor

Reviewed by: Title Name Principal Environment Adviser Team Leader LNG Plant Process Engineering

Approved by: Title Name Plant Manager

Date Rev Reason For Issue Author Checked Approved0 BC DH

17/01/02019 0.1 For Review MR JC 27/06/2019 1.0 For Use MR JC/ RM GJ


Table o f Co n te n ts

1. Purpose ............................................................................................................................ 1 2. Scope ................................................................................................................................ 1 3. Definitions ......................................................................................................................... 1 4. Responsibilities ................................................................................................................. 1 5. Procedure ......................................................................................................................... 2

5.1. Monitoring Flares ................................................................................................... 2 5.2. Recording of Flaring Events .................................................................................. 2

6. Monitoring and Reporting ................................................................................................. 2 APPENDIX A - Flaring Event Register Template ................................................................... 3 APPENDIX B – Ringelmann Smoke Chart .............................................................................. 4

Page 1 of 4 UNCONTROLLED IF PRINTED 3301-GLNG-5-1.3-0023

1. PURPOSE

The Flaring Event Register Procedure defines the requirements for the recording of flaring events at the LNG facility.

Management of flaring events is required to ensure compliance with Environmental Authority (EA) EPPG00712213 conditions with respect to flaring and to minimise the potential for community complaints relating to visible smoke.

2. SCOPE

The scope of this Procedure encompasses the flaring system at the LNG Facility (wet flare, dry flare, back-up flare and marine flare).

The EA stipulates that flaring events associated with visible smoke cannot occur for longer than 5 minutes in any 2 hour period during normal operations.

The recording of flaring events in a Flaring Event Register is a requirement of the Flaring Contingency Management Plan (3310-GLNG-5-1.3-0013) whether the flaring event is planned (normal operations or planned shut-down/ start-up) or unplanned (i.e. upset).

All flaring events should be noted and recorded in the Flaring Register.

3. DEFINITIONS

EA Environmental Authority EPPG00712213

DES Department of Environment and Science, the administering authority for the EA

Flaring Event A flaring event which is associated with visible smoke (Ringelmann number greater than 2) and occurs for a minimum of 5 minutes in any 2 hour period during normal operating conditions.

4. RESPONSIBILITIES

Role Responsibilities Operations Superintendent / Team Leaders • Ensure all Operations Teams are aware of the

Procedure for Recording Flaring Events• Ensure that a Flaring Event Register entry is

completed for each Flaring Event• Resource allocation

Operations Team Members • Be aware of the Flaring Event Register Procedure• Log Flaring Events in the Flaring Event Register

with complete and accurate details


Role Responsibilities Senior Environmental Advisor • Participate in flaring related environmental incident

investigations• Collate environmental incident reports and

associated regulatory notifications

5. PROCEDURE5.1. Monitoring Flares

The main flare stack and the marine flare shall be monitored by CCTV camera and visualobservations.

5.2. Recording of Flaring Events

When a flaring event has been identified, the following information shall be recorded in theFlaring Register:

Time flaring commenced; Nature of operations at the time of flaring; Specific cause of flaring; Ringlemann Score (1-5); Actions taken to minimise flaring intensity and duration; and Time flaring stopped.

An example format of the Flaring Register is shown in Appendix A.

An example Ringleman score chart is stored in Appendix B. This should be used in accordance with the instructions with the chart in Appendix B.

Notifications are to be issued prior to the end of each shift during which the event occurred. Records of all unplanned flaring events to be maintained in Flaring Register.

6. REPORTING

Monitoring and reporting is to be undertaken as specified in Schedules B, I and K of the EA.


APPENDIX A - Flaring Event Register Template

EVENT NO. DATE START

TIME

PLANT OPERATING CONDITIONS

CAUSE(S) Ringelmann Score (1-5) ACTIONS TAKEN TO MINIMISE

TIME FLARING

EVENT STOPPED

Normal Shut-down / Start-up Upset

(5 min trigger)


APPENDIX B – Ringelmann Smoke Chart

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Appendix E – QCLNG EA EPPG00711513, Schedule B – Air

Emissions


Permit

Environmental Authority EPPG00711513

Date Granted: 29 June 2018 Page 5 of 34

SCHEDULE B — AIR EMISSIONS

Nuisance

(B1) The release of noxious or offensive odours or any other noxious or offensive airborne contaminants

resulting from the activities must not cause an environmental nuisance at any nuisance sensitive or

commercial place.

(B2) The release of dust and/or particulate matter resulting from the activities must not cause an

environmental nuisance at any nuisance sensitive or commercial place.

(B3) Dust and particulate matter must not exceed any of the following levels when measured at any

nuisance sensitive or commercial place:

a) dust deposition of 120 milligrams per square metre per day over a 30-days averaging period,

when monitored in accordance with Australian Standard AS 3580.10.1 of 2003 (or more recent

editions); or

b) a concentration of particulate matter with an aerodynamic diameter of less than 2.5 micrometres

(PM2.5) suspended in the atmosphere of 25 micrograms per cubic metre over a 24-hour

averaging time, at a dust sensitive place downwind of the licensed place, when monitored in

accordance with the most recent version of:

i) Australian Standard AS AS/NZS3580.9.10 Methods for sampling and analysis of ambient

air—Determination of suspended particulate matter—PM (sub)2.5(/sub) low volume

sampler—Gravimetric method; or

ii) any alternative method of monitoring PM2.5 which may be permitted by the ‘Air QualitySampling Manual’ as published from time to time by the administering authority.

c) a concentration of particulate matter with an aerodynamic diameter of less than 10 micrometre

(µm) (PM10) suspended in the atmosphere of 50 micrograms per cubic metre (with five one day

exceedances allowed in any one year period); and over a 24 hour averaging time, at a dust

sensitive place downwind of the licensed place, when monitored in accordance with:

i) Australian Standard AS 3580.9.6 of 2003 (or more recent editions) 'Ambient air -

Particulate matter - Determination of suspended particulate PM10 high-volume sampler

with size-selective inlet - Gravimetric method'; or

ii) any alternative method of monitoring PM10 which may be permitted by the 'Air Quality

Sampling Manual' as published from time to time by the administering authority.

Note: The above 5 days exceedances per year are based on the expected exceedances from the

natural events such as bushfires and dust storm.

The Release of Contaminants to the Atmosphere

(B4) The release of contaminants to the atmosphere from a point source must only occur from those

release points identified in Schedule B, Table 1 – Contaminant Release Points and must be directed

vertically upwards without any impedance or hindrance.

(B5) Contaminants requiring on-going monitoring must be released to the atmosphere from a release

point at a height and a flow rate not less than the corresponding height and velocity stated for that

release point in Schedule B, Table 2 – Contaminant Release Limits to Air.

(B6) Contaminants must not be released to the atmosphere from a release point at a mass emission

rate/concentration, as measured at a monitoring point, in excess of that stated in Schedule B, Table

2 – Contaminant Release Limits to Air.

Permit



(B7) Contaminants must be monitored not less frequently than specified in Schedule B, Table 2 –

Contaminant Release Limits to Air.

(B8) Monitoring of any releases to the atmosphere required by a condition of this approval must be

carried out in accordance with the following requirements:

a) monitoring provisions for the emission sources listed in Schedule B, Table 2 – Contaminant

Release Limits to Air must comply with the Australian Standard AS 4323.1 - 1995 'Stationary

source emissions, Method 1: Selection of sampling positions' (or more recent editions).

b) the following tests must be performed for each determination specified in Schedule B, Table 2 –Contaminant Release Limits to Air:

i) gas velocity and volume flow rate;

ii) temperature;

iii) water vapour concentration (moisture content).

c) samples must be taken when emissions are expected to be at maximum rates.

d) during the sampling period the following additional information must be gathered:

i) production rate at the time of sampling;

ii) raw materials and fuel used;

iii) number of plant or equipment and operating units operating;

iv) reference to the actual test methods and accuracy of the methods.

(B9) All emission sources requiring monitoring must be conspicuously marked with the corresponding

release point number and equipment number as identified in Schedule B, Table 2 – Contaminant

Release Limits to Air.

Schedule B, Table 1 – Contaminant Release Points

Emission Source

Train 1 Emission Sources

Train 1 Compressor Gas Turbines (x8)

Acid Gas Removal Unit 1

Nitrogen Rejection Unit 1









Other LNG Facility Emission Sources

Gas Turbine Power Generators (x4)

Marine Flare

Process Flares (Wet and Dry Gas)

Regeneration Gas Heaters 1 & 2

Hot Oil Heaters 1 & 2

Fire Water Pumps (diesel x3)

Back-Up Power Generators (diesel x6)

Emergency Air Compressor (diesel x2)

Standby Generator at Marine Terminal Building (diesel x1)

Permit



Schedule B, Table 2 – Contaminant Release Limits to Air

Emission

Sources Equipment Number

Contaminant

Release

Release

Height

Above

Grade (m)

Emission

Velocity

(m/s)

Maximum

Release

Limit

Monitoring

Frequency

Train 1 Gas Compressor Turbines

Propane

Compressors

1TC-1411

1TC-1421 NOx 34 25

61 mg/Nm3

(dry) @ 15%

O2 and 4.0

g/s Note 2

One stack per

year on a

rotational basis Note 1

Ethylene

Compressors

1TC-1511

1TC-1521 NOx 34 25

Methane

Compressors

WHR* Unit Stacks

1TC-1611 (1H-3411)

1TC-1621 (1H-3421) NOx 49.2

8.2

Bypass Stacks

1TC-1611 (1H-3411-K01)

1TC-1621 (1H-3421-K01)

N/A


Propane

Compressors

2TC-1411

2TC-1421 NOx 34 25

61 mg/Nm3

(dry) @ 15%

O2 and 4.0

g/s Note 2

One stack per

year on a

rotational basis Note 1

Ethylene

Compressors

2TC-1511

2TC-1521 NOx 34 25

Methane

Compressors

WHR* Unit Stacks

2TC-1611 (2H-3411)

2TC-1621 (2H-3421) NOx 49.2

8.2

Bypass Stacks

2TC-1611 (2H-3411-K01)

2TC-1621 (2H-3421-K01)

N/A


Propane

Compressors

3TC-1411

3TC-1421 NOx 34 25

61 mg/Nm3

(dry) @ 15%

O2 and 4.0

g/s Note 2

All stacks during

commissioning

(see Note 1) of

the facility and

one stack per

year thereafter

on rotational

basis

Ethylene

Compressors

3TC-1511

3TC-1521 NOx 34 25

Methane

Compressors

WHR* Unit Stacks

3TC-1611 (3H-3411)

3TC-1621 (3H-3421) NOx 49.2

8.2

Bypass Stacks

3TC-1611 (3H-3411-K01)

3TC-1621 (3H-3421-K01)

N/A

Power Generation Turbines

Gas Turbine

Power

Generators

1TG-3101

1TG-3102

1TG-3103

1TG-3104

NOx 25 8.2

61 mg/Nm3

(dry) @ 15%

O2 and 4.0

g/s

All stacks during

commissioning

(see Note 1) of

the facility and

one stack per

year thereafter

on rotational

basis

* WHR = Waste Heat Recovery

Note 1: The above NOx release limits are applicable during all timings except start-up, shut-down and calibration of

emission monitoring devices. The start-up duration is allowed up to 30 minutes.

Note 2: The total mass emission rate from the WHR Unit and bypass stack from each methane gas turbine compressor

must not exceed 4.0 g/s NOx.

Permit



(B10) Within 3 months of commissioning the facility, the holder of this environmental authority must

conduct air emission monitoring to demonstrate compliance with air emission limits listed in

Schedule B, Table 2 – Contaminant Release Limits to Air and submit report to the administering

authority.

Flare

(B11) Visible smoke must not be produced from the flares except for a total of 5 minutes in any two hour period during normal operating conditions.

(B12) Flaring events, except for those resulting from an emergency, occurring outside of normal

operating conditions must not exceed:

a) 7 hours per annum during daylight hours; and

b) 14 times per annum during daylight hours; and

c) 30 minutes of continuous visible smoke during daylight hours except as authorised

under condition (B13).

(B13) Notwithstanding condition (B12)(c), individual flaring events must not exceed 90 minutes of

continuous visible smoke in the following circumstances:

a) A flaring event associated with a plant maintenance activity that was planned to be

completed outside of daylight hours, but was required to be undertaken during daylight

hours to ensure the safe operation of the plant; or

b) A flaring event associated with a plant maintenance activity that was not planned and was

required to be undertaken during daylight hours to ensure the safe operation of the plant.

(B14) The holder of this authority must keep records of each flaring event to determine compliance with condition (B12) and (B13) and provide these records to the administering authority on request. Records must include, but not be limited to:

a) The duration of each flaring event; andb) The operational planning that was implemented to minimise flaring; andc) The operational controls that were implemented during flaring; andd) If the flaring event exceeds 30 minutes, the circumstance under condition (B13) which

caused this exceedance.

(B15) The holder of this authority must monitor and record all flaring events in accordance with Schedule

B, Table 3 – Recording during flaring events and Condition (I3).

Schedule B – Table 3 – Recording during flaring events

Table 3 – Monitoring of point source emissions to air

Emission point

references

Parameter Units Frequency Method Commencement of Recording

Process Flares (Wet and Dry Gas) and Marine Flare

Visual recording seconds Continuously during a flaring event

Digital Video Recorder

Commencing 29 January 2016

Temperature °C Continuously during a flaring event

CEMS

Vent gas flow rate m/s Continuously during a flaring event

CEMS

Vent gas composition

Multiple Continuously during a flaring event

CEMS Within 18 months of 29 January 2016

(B16) Contingency plans and emergency procedures must be developed and implemented for non-routine

situations to deal with foreseeable risks and hazards including corrective responses to prevent and

Permit



mitigate environmental harm (including a contingency plan when plant shuts down for maintenance

or other reasons).

Fugitive Emissions

(B17) The holder of this environmental authority must ensure that all reasonable and practicable measures

are taken in the design and operation of the plant to minimise fugitive VOC emissions. Reasonable

and practicable measures include but are not limited to:

a) implementation of a monitoring program to regularly leak test all units/components including

pumps, piping and controls, vessels and tanks; and

b) operating, maintenance and management practices to be implemented to mitigate fugitive VOC

sources.

(B18) The ducting and extraction systems that transfer effluent gases from one location to another must be

constructed, operated and maintained so as to minimise any leakage of VOCs and vapours to the

atmosphere occurring from these sources.

(B19) In the event of emissions of contaminants occurring from industrial plant or ducting systems that

transfer effluent gases from one location to another, the fault or omission that resulted in that

emission must be corrected as soon as practicable.

Fuel Burning

(B20) This authority only permits the burning of natural gas and diesel fuel in the fuel burning equipment

under normal operating conditions at the rate of the design capacity of the equipment.

(B21) For commissioning and operation of the LNG Plant diesel fuel must only be used in the specified

diesel fuel burning equipment in Schedule B, Table 1 – Contaminant Release Points, under backup,

standby, start up and/or emergency situations.

(B22) The sulphur content of fuel burned in the power generators must not exceed 0.5 percent by weight.

Greenhouse Gas Emissions

(B23) The holder of this authority must develop and implement a greenhouse gas reduction strategy for the

LNG Facility. The strategy must include, but not limited to, the company’s policy on greenhouse gas emissions, an energy efficiency program, a continuous improvement program, better control systems

and a CO2 recovery plan.

Appendix F – Proposed Amendment to the Environmental

Authority (EPPG00712213)


Condition Number

Existing Condition Proposed Condition Justification

SCHEDULE B – AIR EMISSIONS

B2 The release of dust and/or particulate matter resulting from the activities must not cause an environmental nuisance at any sensitive or commercial place.

The release of dust and/or particulate matter resulting from the activities must not cause an environmental nuisance at any nuisance sensitive or commercial place unless the release occurs as a result of an emergency, or is authorised by this environmental authority or the EP Act.

Refer to section 2.5.3.1

B20 N/A Flaring events, except for those resulting from an emergency, occurring outside of normal operating conditions must not exceed:

a) 7 hours per annum during daylight hours;and

b) 14 times per annum during daylight hours;and

c) 30 minutes of continuous visible smokeduring daylight hours except as authorisedunder condition (B21).

Refer to section 2.5

B21 N/A Notwithstanding condition (B20)(c), flaring events must not exceed 90 minutes of continuous visible smoke at any one time in the following circumstances:

a) A flaring event associated with a plantmaintenance activity that was planned to becompleted outside of daylight hours, but wasrequired to be undertaken during daylighthours to ensure the safe operation of theplant; or

b) A flaring event associated with a plantmaintenance activity that was not plannedand was required to be undertaken duringdaylight hours to ensure the safe operationof the plant.



Condition Number


B22 N/A The holder of this authority must keep records of each flaring event to determine compliance with condition (B20) and (B21) and provide these records to the administering authority on request.

Records must include, but not be limited to:

a) The duration of each flaring event; and

b) The operational planning that wasimplemented to minimise flaring; and

c) The operational controls that wereimplemented during flaring; and

d) If the flaring event exceeds 30 minutes, thecircumstance under condition (B21) whichcaused this exceedance.


APPENDIX 1 - DEFINITIONS

N/A “daylight hours” means those between sunrise and sunset times as shown on the Australian Government Geoscience Australia webpage < http://www.ga.gov.au/geodesy/astro/sunrise.jsp>.


N/A “emergency” means (a) either— (i) human health or safety is threatened; or (ii) serious or material environmental harm has been or is likely to be caused; and (b) urgent action is necessary to— (i) protect the health or safety of persons; or (ii) prevent or minimise the harm; or (iii)rehabilitate or restore the environment becauseof the harm.

Refer to section 2.5 and 2.5.3.1

N/A “flaring event” means an event where flammable gas is combusted through a flare and produces visible smoke either (i) continuously for more than 5 minutes or (ii) multiple instances of visible smoke occurring consecutively with a total duration of more than 5 minutes, provided

Refer to section 2.5.3.1


http://www.ga.gov.au/geodesy/astro/sunrise.jsp

Condition Number


that the consecutive instances of visible smoke occur due to the same underlying cause, discharges through the same valve or flare source and occurs within a two hour period.

“normal operating conditions” means the ongoing operation of the LNG plant following commissioning and excludes start-up, shutdown, maintenance or calibration of emission monitoring devices.

“normal operating conditions” means the ongoing operation of the LNG plant following commissioning and excludes, excluding start-up, shutdown, maintenance or calibration of emission monitoring devices and upset conditions, an emergency and LNG ship management.


N/A “plant maintenance activities” means the maintenance shutdowns (and subsequent start-ups) where equipment at the plant is inspected and, if needed, repaired or replaced to ensure the ongoing safe operation of the plant.


N/A “Ringelmann number” means a visually comparative scale used to define levels of opacity, where clear is 0, black is 5 and 1 through 4 are increasing levels of grey as used in describing smoke from combustion of hydrocarbons.


N/A “visible smoke” means a visible suspension of carbon or other particles in air measured by a Ringelmann number greater than 2.



Documents

Appendix A – GLNG Environmental authority visible smoke