Neerabup Stack Emissions Management Plan (SEMP) Annual ... · Neerabup Stack Emissions Management Plan (SEMP) Annual Compliance Report 2016-2017 Author: Bruno Lanciano

Neerabup Stack Emissions Management Plan (SEMP) Annual Compliance Report

2016-2017 Author: Bruno Lanciano

17 November 2017

SEMP Annual Compliance Report 2016-2017 Page 2 of 17

Title: 2016-2017 SEMP Annual Compliance Report Author: NewGen Neerabup Partnership – Bruno Lanciano PowerStation Manager: Bruno Lanciano Name of document: 2016-2017 SEMP Annual Compliance Report Document version: 0

Document version control

Revision Date Issued Reviewed by Approved by Date Approved Revision Type A 01//11/2017 B Lanciano Draft 0 17/11/2017 B Lanciano

B Lanciano P MacMahon

17/11/2017 Approved/Issued

Distribution of copies

Revision Copy no Quantity Issued to 0 1 1 Bruno Lanciano

ERM Power - Neerabup Office 0 2

1 Phil MacMahon / Derek McKay

ERM Power Brisbane Office 0 3 1 DWER 0 4 1 OEPA


CONTENTS CONTENTS 3

1.0 EXECUTIVE SUMMARY 4

2.0 KEY RECOMMENDATIONS / FUTURE WORK 4

3.0 SEMP CONDITIONS 5

3.1 DESIGN/CONSTRUCT 6

3.2 OPERATION 7

3.3 ROLES AND RESPONSIL BITIES 8

3.4 ATOMOSPHERIC EMISSIONS 9

3.5 COMPLAINTS 9

3.6 CONTINGENCIES 10

3.7 STAKEHOLDER CONSULTAITON 11

3.8 AUDITING 11

3.9 REVIEW AND REVISION 12

4.0 ANNUAL REPORT 12

4.1 RECORD KEEPING 13

4.2 CERTIFICATION OF RESULTS 13

APPENDIX 1 – STACK EMISSIONS SAMPLING REPORT (BOTH UNITS – OCT 2016) 14

APPENDIX 2 – INCIDENT REPORTS 15

APPENDIX 3 – EXTERNAL COMPLAINTS REGISTER 16

APPENDIX 4 – INSPECTION PLAN SCHEDULE 17


1.0 EXECUTIVE SUMMARY This annual Stack Emissions Management Plan (SEMP) Compliance Report is produced internally by NewGen Neerabup and covers the period from 1st July 2016 to 30th June 2017. The following is a summary of the key points in this report;

• This report is an internal audit or the SEMP for the period 1 July 2015 to 30 June 2016.

• This annual report identifies compliance with the SEMP.

• NewGen Neerabup submitted a revision 2 of the SEMP to OEPA for approval in May 2013, OEPA approved the revision to the SEMP on the 15th August 2013. This report evaluates compliance with the requirements of the Stack Emissions Management Plan, June 2013 Rev 2.

• As required by the environmental l icence, annual stack emissions testing was conducted by SLR Consulting Australia Pty Ltd on the following dates;

o Unit 11 – 24th October 2016 o Unit 12 – 31st October 2016

The results of these tests were within the defined l imits.

• An external compliance audit of the SEMP was conducted on 17 November 2016, for the audit period 1st July 2015 to 30th June 2016 for the Ministerial Statement and also for the Bankers Audit. This external audit included a review of the SEMP and found compliance with the SEMP.

• The next external compliance audit for the 2016-2017 period (1st July 2016 – 30th June 2017) is currently scheduled to occur on the mid to late November 2017 that will be conducted by Strategen Environmental Consultants Pty Ltd. Strategen’s external audit report to follow a few months later and will be subsequently reported in 2016-2017 SEMP reporting period.

• Complaints procedures and register have been developed; no complaints have been received to date. NewGen Neerabup also regularly completes (annually) pipeline landowner and other relevant third parties that are located within 500meters of the pipeline easement and power station (eg; all close neighbouring residences and business), no complaints have been received via this consultation process.

• This annual report is due for submission by the 30th September annually. A longer lead-time (increased from 30 to 90 days) has been added to the work order scheduling to prompt/remind of required timeframe. No further action deemed necessary.

2.0 KEY RECOMMENDATIONS / FUTURE WORK

• Complete the next external audit for the 2016-2017 period. This external audit is currently scheduled to occur late November 2017, with the audit report scheduled to be submitted to OEPA early in 2018. Currently scheduled in MEX Work Order number 7195.


3.0 SEMP CONDITIONS As defined by the section 13.0 of the stack emissions management plan, this report evaluates compliance with the requirements of the Stack Emissions Management Plan, June 2013 Rev 2.0 (SEMP) as agreed with by the Office of Environmental Protection Authority (OEPA) and NewGen Neerabup. Section 13/table 5 of the stack emissions management plant defines the key management actions/compliance requirements of the SEMP annual compliance report and comments on the status of these requirements are summarised in table 1.

Table 1 - Key management actions

Ref # Timing / Phase Key Management Action DWER Reporting/Evidence

Reviewed comments/status

SEMP1 Post-

commissioning

Monitor emissions from the exhaust stack as specified in Section 7.1 Table 4

Results submitted to DWER

As per • Section 3.1 • Section 3.2 • Section 3.4 • Section 3.5 • Section 4.0 / This annual compliance report

SEMP2 Ongoing Monitor NOx emissions from the exhaust stack as specified in Section 7.1 Table 4

Notification letter sent to DWER in the event of an exceedance, summarise performance in annual report, logged data available on request.

As per • Section 3.1 • Section 3.2 • Section 3.4 • Section 3.5 • Nil Incident reports / Appendix 2 • Section 4.0 / This annual compliance report

SEMP3 Ongoing Monitor and respond to community complaints, record actions as specified in Section 7.2

Summarise performance in annual report, logged data available on request.

As per • Section 3.5 • Nil external complaints / Appendix 3 • Section 4.0 / This annual compliance report

SEMP4 Annual Monitor carbon monoxide, and other stack parameters as specified in Section 7.1 Table 4

Summarise performance in annual report, logged data available on request.

As per • Section 3.1 • Section 3.2 • Section 3.4 • Section 3.5 • Annual stack test reports / Appendix 1 • Section 4.0 / This annual compliance report

SEMP5 Annual Prepare annual compliance report

Analyse monitoring results, submit to DWER with annual report

As per • Section 3.4 • Section 3.5 • Section 3.6 • Section 3.7 • Section 3.8 • Section 3.9 • Section 4.0 / This annual compliance report


3.1 DESIGN/CONSTRUCT As defined by the section 6.1 of the stack emissions management plan, the power station shall be designed and constructed to comply with the emission concentration targets specified in section 5.1 of the stack emissions management plan. The power station will uti l ise low NOx burners to ensure that emissions of oxides of nitrogen are minimised as far as is practicable.

Evidence: Emission concentration targets are specified in section 5.1 of the SEMP and as summarised in table 2 below; Table 2 – SEMP atmospheric emission concentration targets

Gas-turbine Air pollutant Operational Condition-1

Emission concentration Target -2, 3

Averaging period

Unit 1 and 2 Oxides of nitrogen All 25 ppmv or

51 mg/Nm3

1-hour

Unit 1 and 2 Carbon monoxide All 10 ppmv or

12.6 mg/Nm3

1-hour

Table Note 1Excluding start-up, shutdown, initial commissioning and other times when the units are operating below 60% maximum

load. 2Corrected to 15% O2 basis.

3mg/Nm

3, corrected to 101.3 KPa, 273 K.

The design criteria in “General Turnkey Specifications, NEERABUP POWER STATION, March 2007, Commercial-In-Confidence, ERM Power”, which was supplied to prospective plant providers, includes NOx emission target of 25ppmv. Note: the design specifications precede the SEMP by over two years.

• Low NOx burners were included in the design and have been installed on the commissioned units in 2009. • Refer to section 3.2 Operations and section 3.4 Atmospheric Emissions • Refer to Annual stack test reports / Appendix 1 • All emissions testing performed to date has verified that emissions measured are below the targets in table 2 of

section 5.1 of the SEMP.

Comments: Remains compliant.

SEMP6 Ongoing Preventative maintenance

Complete maintenance log, logged data available on request

As per • Section 3.1 • Section 3.2 • Section 3.3 • Section 3.4 • Section 3.5 • Section 3.6 • Section 3.7 • Section 3.8 • Maintenance management system

database • Inspection Plan Schedule/ Appendix 4 • This annual compliance report


3.2 OPERATION As defined by the section 6.2 of the stack emissions management plan, the power station shall be maintained and operated in a proper and efficient manner and in accordance with the manufacturer’s operation and maintenance manual to ensure compliance is achieved with the emission concentration targets specified within section 5.1 of the stack emissions management plan.

Evidence: Maintenance: Maintenance planning schedules are in accordance with the manufacturer’s requirements (refer to attached Inspection Plan Schedule in Appendix 5).

Maintenance on the Neerabup gas turbines are triggered by the number of starts rather than the equivalent operating hours (EOH) due to the peaking nature of Neerabup Operations. (Short runs with frequent starts).

The Siemens OEM schedules minor inspections at 250 starts (+/- 10%) or 8,000EOH whichever is earlier. The Second minor inspections were completed in November 2017. (outside this reporting period)

The hardware component affecting gas emission i.e. fuel gas burners and combustion chamber hot gas path items are inspected during every minor inspection at 250 starts (+/- 10%) or 8,000EOH whichever is earlier. The first and second minor inspections were performed by Siemens Nov 2014 and Nov 2017 with no issues detected. The burners and turbine in good working condition fit for service until the next minor inspection. Based on current operating regime of Neerabup Power Station the 3rd minor inspections for both GT units will be due approximately April 2021. A more extensive inspection involving repair / replacement of some components of fuel gas burners and hot gas path items will be performed during a major inspection which is scheduled at every 1250 starts (+/- 10%) or 41,000EOH or 12 year time period whichever is earlier. Based on current operating regime of Neerabup Power Station the first major inspection will be due in 2032. A yearly maintenance programme is in place for checking and testing flame monitoring and protection circuitry. Running parameters of fuel gas combustion performance e.g. combustion chamber differential pressure, combustion chamber noise level, combustion flame intensity and gas turbine fuel gas inlet temperature are being regularly monitored online during gas turbine operation. These all provide normal operating parameters and deviation from these normal parameters are alarmed by the Turbine control SCADA system. Operation:

Evidence: The power station has conducted operations in compliance with the SEMP emission targets. Results from sampling and analysis of air pollutants, undertaken by SLR Consulting Australia are summarised below in table 3 below.

1st minor inspection

Starts count @ 1st minor

EOH @ 1st minor

2nd minor inspection

Starts count @2nd minor

EOH @ 2nd minor

Unit 11 19-Nov-14 273 6,159 10-Nov-17 523 10,991 250Unit 12 21-Nov-14 272 5,851 7-Nov-17 523 10,623 251

1st Minor inspection (Starts Based) 2nd Minor inspection (Starts Based) Total Starts from 1st to 2nd minor


Table 3 – Summary of stack emissions test results

Annual exhaust stack monitoring was performed by SLR Consulting Australia Pty Ltd (NATA Accreditation Number 3130) as per summary of stack emissions test results – table 3.

• The full results of the monitoring are included Appendix 1. • Appendix 2 – Nil notifiable incidents detected or reported to Department of Environment Regulation

o Annual stack test results refer SEMP4 and

o Section 3.1

o Section 3.2

o Section 3.4

o Section 3.5 o Annual stack test reports / Appendix 1.

• Maintenance planning schedules show compliance with the manufacturer’s requirements. Monitoring results for

emissions are below specified concentration targets.

• The first and second minor inspections outages were completed prior to the OEM Schedule of 250 starts (+/- 10%) or 8,000EOH (whichever is earlier). Please refer to appendix 4.

• Refer to section 3.4 atmospheric emissions

• Refer to Annual stack test reports / Appendix 1

• Available on request “2016-2017 NewGen Neerabup DER Annual Monitoring & Compliance Report”


3.3 ROLES AND RESPONSILBITIES As defined by the section 6.3 of the stack emissions management plan.

Evidence: Personal or roles or responsibilities have not changed within the last 12 months.


Machine output Concentration 1 hr avg Criteria Compliance Concentration 1 hr avg Criteria ComplianceMW ppmv @ 15% O2 ppmv @ 15% O2 Yes / No ppmv ppmv @ 15% O2 Yes / No

24-Oct-16 17:35 to 18:35 137.36, 2 19.2 < 25 Yes <1 < 10 YesNote 1 - Water Injection (or Power Augmentation {PAG}) mode WAS NOT operating at the time of the stack test. [Future emissions tests will be performed with this worse case emission scenario where possible]Note 2 - Turbines operated @83% of nominal Maximum rated capacity of 165MWe, and was operating no more than +/-5% variation

Machine output Concentration 1 hr avg Criteria Compliance Concentration 1 hr avg Criteria ComplianceMW ppmv @ 15% O2 ppmv @ 15% O2 Yes / No ppmv ppmv @ 15% O2 Yes / No

31-Oct-17 11:40 to 12:40 156.56, 2 16.3 < 25 Yes <1 < 10 YesNote 1 - Water Injection (or Power Augmentation {PAG}) mode WAS NOT operating at the time of the stack test. [Future emissions tests will be performed with this worse case emission scenario where possible]Note 2 - Turbines operated @95% of nominal Maximum rated capacity of 165MWe, and was operating no more than +/-5% variation

Neerabup Unit 11Parameter Nitrogen Oxides (as NO2) Corrected to 15% Oxygen Carbon Monoxide

Date of Emissions Testing

Time of Emissions Testing

Neerabup Unit 12Parameter Nitrogen Oxides (as NO2) Corrected to 15% Oxygen Carbon Monoxide

Date of Emissions Testing

Time of Emissions Testing


3.4 ATOMOSPHERIC EMISSIONS As defined by the section 7.1 of the stack emissions management plan, Sampling and analysis of air pollutants shall be undertaken and reported as specified in section 7 of the SEMP and as summarised in table 4 below; TABLE 4 – Emission monitoring parameters, Units 1 and 2 Pollutant/parameter Units of measure

Method Frequency

Oxides of nitrogen ppmvd@15% O2 or mg/Nm3 USEPA Method 7E Annually

Carbon monoxide ppmvd@15% O2 or mg/Nm3 USEPA Method 10 Annually

Stack Gas Velocity m/s USEPA Method 2 or 2C Annually

Stack Gas Temperature ºC USEPA Method 2 or 2C Annually

Stack volumetric flow rate m3/s USEPA Method 2 or 2C Annually

Moisture content % USEPA Method 4

Annually

Dry gas density or molecular weight

Kkg/m3 g/gmol

USEPA Method 3 Annually

Oxygen % USEPA Method 3A Annually

Evidence: Sampling and analysis of air pollutants, as shown in Table 4, was undertaken during the period by SLR Consulting Australia Pty Ltd (NATA Accreditation Number 3130) on the following dates and the report provided by SLR Consulting Australia have been attached to this report in Appendix 1;

• Unit 11 – 24th October 2016 (17:35-18:35) • Unit 12 – 31st October 2016 (11:40-12:40) • Refer to section 3.2 & 3.4 • Refer to Annual stack test reports / Appendix 1 • Please also refer to “2016-2017 NewGen Neerabup DER Annual Monitoring & Compliance Report” for the AR1

forms and also copies of the external consultant stack testing reports submitted to DER. Report is available on request.

Comments: Remains Compliant.

3.5 COMPLAINTS As defined by the section 7.2 of the stack emissions management plan, A complaints procedure shall be established to receive complaints from the community associated with air emissions from the power station.


The power station operator shall investigate all complaints and, where the power station is found to be the cause of the incident, the operator shall take actions to ensure that the cause is rectified and implement measures to ensure that there is minimal risk of the incident recurring.

Evidence: NewGen Neerabup has a complaints procedure and complaints register to meet the requirements of the SEMP- External Complaints Procedure [NPS-OPS-EXT-COMP]; External Complaints Register [NPS-REG-EXT-COMP]. NewGen Neerabup also performs annual Stakeholder consultations to meet the requirements of the Pipeline Licence (PL75) for the Department of Minerals and Petroleum as per Stakeholder Management Guidelines procedure [NPS-PL-ROW-14]. This procedure regularly (annually) prompts pipeline landowner and other relevant third party consultations that are located within 500 meters of the power station and pipeline easement (eg; all close neighbouring residences and business). During the reporting period no complaints have been received by the above processes as both require the complaints to be entered into the complaints register. Refer to appendix 3 for the complaints register for the reporting period (Nil or blank). Procedure and register established. No complaints or investigations recorded. No complaints or investigations recorded via the Pipeline easement stakeholder management procedures


3.6 CONTINGENCIES As defined by the section 8.0 of the stack emissions management plan, the following mechanisms will be established to identify actual and apparent non-conformance with the SEMP: (a) Routine preventative maintenance will be undertaken in accordance with the manufacturer’s operation and

maintenance manual. (b) Sampling and analysis of carbon monoxide, oxides of nitrogen (and other exhaust parameters) on an annual

campaign basis in accordance with the requirements specified in Section 7.1 to support this SEMP and provide a secondary check on operations and maintenance.

(c) Implementation and ongoing maintenance of complaints reporting, management system and investigation system.

Evidence: (a) Routine preventative maintenance program as contained in the Maintenance Management System (MEX), and also

as depicted by the Turbine OEM (Siemens), every 250 Starts (+/- 10%) and/or every 8,000 EOH. The first and second minor inspections outages were completed prior to the OEM Schedule of 250 starts (+ 10%). Please refer to appendix 4.

(b) Annual stack testing program as defined in section 3.4.

(c) Complaints reporting, investigation and management system as defined by section 3.5.



3.7 STAKEHOLDER CONSULTAITON As defined by the section 9.0 of the stack emissions management plan, In accordance with OEPA correspondence dated 15 February 2011 (Ref: OEPA2010/001038-1) ERM Power will:

1) Post a copy of the revised SEMP on the ERM Power website for the l ife of the project: www.ermpower.com.au/generation-regulatory

2) Make all historical documents required to be made publicly available obtainable upon request to ERM Power.

3) Within fourteen days from the date of making documents publically available, provide evidence to the Proposal Implementation Monitoring Branch (PIMB) to confirm that the document has been posted on the ERM website.

Evidence: 1) The currently approved copy of the SEMP (Rev 2) is posted on the ERM Power Website

www.ermpower.com.au/generation-regulatory

2) Historical documents are available upon request.

3) Revision 2 of the SEMP was submitted to OEPA & DER on the 21st June 2013 and approved by OEPA on the 15th August 2013. Revision 2 was made publically available on the ERM power website on the 30th August 2013

4) As at 15th November 2017 – a check on last year’s 2015-2016 SEMP Annual Compliance report that was submitted to the OEPA & DWER on the 7th October 2016 is currently sti l l available on the ERM Power website (www.ermpower.com.au/generation-regulatory).

5) This report will replace this previous years report within days of submission of this report to the OEPA.


3.8 AUDITING As defined by the section 10.0 of the stack emissions management plan, Annual internal audits and annual external audits will be conducted as specified in the Operational Environmental Management Plan. These audits will assess compliance with the SEMP.

Evidence: Operational Environmental Management Plan states auditing is to be done in accordance with requirements of MS759 and other approvals. Internal and external audits conducted found compliance with the SEMP;

• Internal Compliance audit of the SEMP by the Operator ERM Power Limited for period 1 July 2016 to 30 June 2017 has been completion by the review and the issue of this annual compliance report.

• An external compliance audit of the SEMP was conducted on 17 November 2016, for the audit period 1st July 2015 to 30th June 2016 for the Ministerial Statement and also for the Bankers Audit; the external audit was conducted by Strategen Environmental Consultants Pty Ltd. Filename reference: 2015-2016 Neerabup Environmental Compliance Report (EPO16160_01 R001 Rev 0 - 9 December 2016)

• The next external compliance audit for the 2016-2017 period (1st July 2016 – 30th June 2017) is currently scheduled to occur on the mid to late November 2017 that will be conducted by Strategen Environmental Consultants Pty Ltd. Strategen’s external audit report to follow a few months later and will be subsequently reported in 2017-2018 SEMP reporting period.

• Internal / External Audit reports available on request.

• Internal /External compliance audits found compliance with SEMP.

http://www.ermpower.com.au/generation-regulatory





3.9 REVIEW AND REVISION As defined by the section 11.0 of the stack emissions management plan, This SEMP will be reviewed on an annual basis to ensure that all aspects of operation management and maintenance comply with Government requirements and current best practice.

Evidence: During compilation of this report, the currently approved Stack Emissions Management Plan (SEMP) Rev 2.0 was reviewed for appropriateness, It was concluded that it is sti l l current and no further amendments are required, hence no action taken.


4.0 ANNUAL REPORT As defined by the section 12.1 of the stack emissions management plan, an annual report will be submitted within three months of completion of the financial year (30th Sept annually), that:

• Summarises compliance with SEMP conditions

• Provides details of any incidents of non-compliance with SEMP conditions

• Summarises air pollution monitoring data collected as part of this SEMP

• Summarises complaints

• Summarises outcomes of auditing.

This report was prepared in accordance with Department of Environment guidelines for performance and compliance reporting. The annual report will be made publicly available through posting on the ERM Power website shortly after lodgement to OEPA.

Evidence: • This SEMP annual compliance report summarises compliance with SEMP conditions and other items indicated in

Section 4.0.

• This SEMP annual compliance report was approved internally on the 17th November 2017 and was submitted to OEPA prior on the 17th November 2017.

• This SEMP annual compliance report will be made publically available on the ERM Power website in the next 7 days.

Comments: Remains compliant. Reporting time frame was sl ightly late as report was due according to the SEMP by 30th September. A longer lead-time (increased from 30 to 90 days) has been added to the work order scheduling to prompt/remind of required timeframe. No further action deemed necessary.


4.1 RECORD KEEPING As defined by the section 12.2 of the stack emissions management plan, the following records are to be kept on site and made available to any DWER, EPA or OEPA representative on request.

• Emissions monitoring reports and data

• All environmental complaints – maintain complaints register

• External reporting to OEPA, including annual reports

• Daily checklists.

Evidence:

• All available upon request.


4.2 CERTIFICATION OF RESULTS The annual auditing and annual monitoring results supplied in this report are a correct representation of the plant as required by the SEMP. Signed: Name: Bruno Lanciano Position: Power Station Manager Date: 17/11/2017


APPENDIX 1 – STACK EMISSIONS SAMPLING REPORT (BOTH UNITS – OCT 2016)

SLR CONSULTING AUSTRALIA PTY LTD UNIT 5, 31 CENTURY ROAD, MALAGA WA 6090

TELEPHONE: 08 9422 5900

Test Report 675.11102.00000-TR1R1

Emission Test Report 675.11145.00000 TR1R0.docx Page 1 of 8

1 CLIENT DETAILS

Organisation: ERM Power Pty Ltd

Company Contact: Bruno Lanciano

Site Address: Trandos Road NEERABUP WA 6031

Postal Address: PO Box 323 WANNEROO WA 6946

Telephone Number: 9206 8005 or 0409 231 741

2 PROJECT DETAILS & SCOPE OF WORK REQUESTED

Project Number: 675.11002.00000

Project Name: Newgen Neerabup Power Station

Project Manager: Paul Cimbaly

Reason(s) for Work: Licence No. L8356/2009/2 – Condition 3.2

– Annual Compliance Programme

Monitoring Date(s): 24 October and 31 October 2016

Production/Operational Conditions: Normal

Parameters requested: Oxygen, Oxides of Nitrogen, Carbon monoxide, stack gas velocity

Sample Locations: EPL Authorised Emission Point References – A1, A2

Sample Identification Numbers: Not Applicable

Signatory

Paul Cimbaly

Issue Date: 22 December 2016 Accredited for Compliance with ISO/IEC 17025. The results of the tests, calibration and/or

measurements included in this document are traceable to Australian/national standards.

This report cannot be reproduced except in full.


TELEPHONE: 08 9422 5900

Test Report 675.11102.00000-TR1R1


3 NOMENCLATURE

* Not part of SLR scope of accreditation o degrees

> greater than

≥ greater than or equal to

< less than

≤ less than or equal to

% percentage oC degrees Celsius

± Plus or Minus

AESTD Australian Eastern Standard Time Daylight Savings

AEST Australian Eastern Standard Time

ALS Australian Laboratory Services

Avg Average

AS Australian Standard

AS/NZS Australian Standards/New Zealand Standards

CEMS Continuous Emission Monitoring System

CFR Code of Federal Regulations

CH4 Methane

CO2 Carbon dioxide

CO Carbon monoxide

Conc. Concentration

CSC Certified Span Concentration

CST Central Standard Time

CTM Conditional Test Method

D Duct Diameters

DER Department of Environment Regulation

EPA Environment Protection Agency

EPL Environment Protection Licence

g/g mole grams per gram mole

g/kW.h grams per kilowatt hour

g/m3 grams per cubic metre

H2S Hydrogen sulfide

hr hour

ID Identification

ISO International Standards Organisation

kg/hr kilograms per hour

kg/m3 kilograms per cubic metre of air

kPa kilopascals

kW kilowatt

LOR Limit of Reporting

m metre

m2 metres square

m3 cubic metres

m/s metres per second

m3/hr cubic metre of air per hour

m3/s cubic metre of air per second

Max Maximum

mg/m3 milligrams per cubic metre of air

Min Minimum

min minutes

µg/m3 micrograms per cubic metre of air

MRC Maximum Rated Capacity

MU Measurement Uncertainty

MW Megawatts

N.m3/hr Normal Cubic Metres Per Hour

NA Not Applicable

NATA National Association of Testing Authorities

NIOSH National Association of Testing Authorities

NDIR Non-dispersive Infra-red Spectrometry

NSW New South Wales

NM Not Measured

No. Number

NO Nitric oxide

NO2 Nitrogen Dioxide

NOx Oxides of nitrogen

O2 Oxygen

OEH Office of Environment and Heritage

OM Other Method

POEO Protection of the Environment and Operations (Clean Air) Regulations 2010

PM10 Particulate matter less than 10 microns

PM2.5 Particulate matter less than 2.5 microns

ppb parts per billion

ppm parts per million

ppmv parts per million by volume

QA/QC Quality Assurance / Quality Control

Qld Queensland

S.m3/hr Standard Cubic Metres Per Hour

SLR SLR Consulting Australia Pty Ltd

SO2 Sulphur dioxide

SO3/H2SO4 Sulphur trioxide / sulphuric acid mist

STP Standard Temperature and Pressure

TM Test Method

TPH Tonnes per Hour

TPY Tonnes per Year

TSP Total suspended particulate

USEPA M United States Environment Protection Agency Method

UTM Universal Transverse Mercator

v/v volume per volume

WST Western Standard Time

Normal (N) dry, 0oC and 101.3 kPa

Standard (S) dry, 15oC and 101.3 kPa


TELEPHONE: 08 9422 5900

Test Report 675.11102.00000-TR1R1


4 PROCESS EMISSIONS MONITORING - PARAMETER, SAMPLING AND ANALYSIS METHOD AND ANALYSIS LABORATORY

4.1 Test Methods and Analysis References

All sampling and monitoring was performed by SLR unless otherwise specified. The following table outlines for each parameter requested to be tested, the relevant test method for sampling and analysis and the NATA Accredited Laboratory that completed the analysis.

4.1.1 Point Source Emissions

Parameter Test Method Number for Sampling and Analysis

NATA Laboratory Analysis By: NATA Accreditation No. & Report No.

Sampling location AS4323.1

USEPA M1

SLR Consulting Australia Pty Ltd

NATA No.3130

Report No. 675.11145.00000-TR1R0

Carbon monoxide USEPA M10


NATA No.3130

Report No. 675.11145.00000-TR1R0

Dry gas composition and dry molecular weight

USEPA M3A


NATA No.3130

Report No. 675.11145.00000-TR1R0

Volumetric flow rate and stack gas velocity

USEPA M2

Combustion Stoichiometry


NATA No.3130

Report No. 675.11145.00000-TR1R0

Oxygen USEPA M3A


NATA No.3130

Report No. 675.11145.00000-TR1R0

Oxides of nitrogen USEPA M7E


NATA No.3130

Report No. 675.11145.00000-TR1R0

4.2 Deviations from Test Methods

No deviations from the Test Methods.

4.3 Sampling Times

As per Environmental Licence L8356/2009/2

4.4 Reference Conditions

As per Environmental Licence L8356/2009/2

4.5 Identification

All samples are individual labelled with reference number, location, sampling date and times.


TELEPHONE: 08 9422 5900

Test Report 675.11102.00000-TR1R1


4.6 Sample Plane Requirements

From engineering drawings supplied by ERM it was concluded that the stack sample planes on Units 11 and 12 did not meet the minimum distance criteria of AS4323.1 for a velocity traverse in accordance with USEPA Method 2, using an S-type pitot and manometer and a K-type thermocouple and meter.

Sampling planes on Units 11 and 12, which are identical, are non-compliant with AS4323.1 in terms of both distance and velocity profile non-uniformity. USEPA Method 2, Section 1.2 has been employed to determine volumetric flow rate, which states: “When unacceptable conditions exist, alternative procedures …must be employed to produce accurate flow rate determinations such as … (2) to calculate the total volumetric flow rate stoichiometrically”.

SLR has a proprietary NATA-accredited procedure and computer algorithm which enables a stoichiometric calculation of the airflow based on natural gas combustion, as per the option outlined in USEPA Method 2.

DER correspondence (DER reference 2010/007483) has confirmed that this approach is acceptable to the DER.

4.7 Operating Conditions

EPL Emission Point Reference A1 (Unit 11) was operating at 137MWe over the sixty minute test period.

EPL Emission Point Reference A2 (Unit 12) was operating at 156MWe over the sixty minute test period.

Both Units were operating at above the minimum output of 100MWe and within ±5% of the mean MWe as required under Section 3.2 of the EPL

4.8 Licence No. L8356/2009/2 – Section 3.2 Details

4.8.1 Condition 3.2.1

The licensee shall undertake the monitoring in Table 3.2.1 according to the specifications in that table.


TELEPHONE: 08 9422 5900

Test Report 675.11102.00000-TR1R1


Table 1 Summary of Licence L8356/2009/2 Table 3.2.1 Monitoring of Point Source Emissions to Air

Emission Point Reference

Parameter Units1 Averaging

Period Frequency Method

A1, A2 Nitrogen oxides mg/m3

g/s

60 min Annually USEPA Method 7E

Carbon monoxide

mg/m3

g/s

60 min Annually USEPA Method 10

Stack gas velocity

m/s Annually USEPA Method 2

1. All units are referenced to STP dry

2. Monitoring shall be undertaken to reflect normal operating conditions and any limits or conditions on inputs or production such that minimum output per gas turbines at all tiems during the testing is maintained at 100MWe and variation of no more than ±5% is observed during the testing

3. All units are reference to 15% O2

4.8.2 Condition 3.2.2

The Licensee shall ensure that all non-continuous sampling and analysis undertaken pursuant to condition 3.2.1 is undertaken by a holder of NATA accreditation for the relevant methods of sampling and analysis.


TELEPHONE: 08 9422 5900

Test Report 675.11102.00000-TR1R1


5 SAMPLING PLANE RECORDS

The sample location for the turbines did not meet ideal or the minimum requirements for upstream and downstream sample position as detailed in AS 4323.1. Refer to Table 1 for detailed summary of the sample location recordings and illustrative representation of one location.

Refer to Section 4.6 for additional details regarding the sample location and its suitability to conduct representative measurements in accordance with AS 4323.1.

Table 1 Summary of Sample Location Recordings

Location Location A1 and A2

Photograph 1 View of Location A2

Photograph 2 Sample port

gffg

Duct Diameter (m) 6.2

Upstream Requirements

Type of Disturbance Exit

Distance to Disturbance (m) 2.3

No. of Duct Diameters 0.3

Ideal Minimum Distance Criteria 2D

Diameters less than Ideal Criteria 1.7

Sampling Factor 1.1

Downstream Requirements

Type of Disturbance Connection

Distance to Disturbance (m) 7.7

No. of Duct Diameters 1.2

Ideal Minimum Distance Criteria 6D

Diameters less than Ideal Criteria 4.8

Sampling Factor 1.15

Number of sampling points for manual isokinetic sampling

Minimum No. of Sampling Traverses

6

Minimum No. of Access Holes 6

Minimum No. of Sampling Points 6

Combined Sampling Factor 1.05 * 1.00 = 1.05

Total No. of Sampling Points required

48 (8 points per traverse)

Emission Point Height 35m

Comments Both Locations are identical


TELEPHONE: 08 9422 5900

Test Report 675.11102.00000-TR1R1


5.1 Additional Details of Sample Location

5.1.1 Design

The Neerabup Power Station is classified as a peaking power station.

Tests were conducted on two Siemens V94.2 natural gas-fired turbines (designated as Unit 11 and Unit 12).

Each unit is nominally rated to 165 megawatts electric (MWe) in open cycle mode, and the units have low oxides of nitrogen (NOx) burners.

6 RESULTS

SLR Consulting Australia Pty Ltd (SLR) conducted the annual emissions monitoring programme at Newgen Neerabup Power Station in accordance with the requirements of the plant operating licence issued by the Department of Environment Regulation (Licence number L8356/2009/2

The monitoring programme performed on emission point A1 on 24 October 2016 and A2 on 31 October 2016 represents the 2016 annual reporting period. The monitoring was carried out as per Condition 3.2 of licence, L8356/2009/2

SLR is NATA accredited for all the parameters required to be tested and hence compliance achieved with Condition 3.2.3.

Table 3 Summary of Average Results – Units 11 and 12

Test Parameter Units of Measurement

Unit 11 Unit 12 Licence Emission Limit

Test Date -- 24/10/16 31/10/16 --

Sampling Period 24 hour WST 17:35-18:35 11:40-12:40 --

NOx ppmvd

mg/Nm3

19.2

40.3

16.3

34.0

25

51

CO ppmvd

mg/Nm3

<1

<1

<1

<1

No Limits

O2 % v/v dry 15.13 15.06 N/A

Stack Gas Velocity m/s No Limits

Stack Gas Volumetric Flowrate

m3/s

m3/hr

342.0

1,231,271

370.9

1,335,592

No Limits

Compliance Status -- Compliant Compliant --


TELEPHONE: 08 9422 5900

Test Report 675.11102.00000-TR1R1

Emission Test Report Page 8 of 8

6.1 Instrument Calibration Details

Asset No. Instrument Description Date Last Calibrated Calibration Due Date

2388 Gas Analyser 30/08/2016 30/03/2017

1910 Timepiece 01/09/2016 01/12/2016

6.2 Certified Span Calibration Gases Information

Special Gas Mixtures Certified Concentration Cylinder No. Expiry Date

NO, NOx 45 ppm, 45 ppm ALQW3400 19/02/2019

NO2 96 ppm ALYC2112 12/03/2019

CO 841 ppm ALQY7450 15/03/2018

O2 10.0% ALSK4433 10/01/2021

6.3 Measurement Uncertainty

Parameter Associated Test Method Uncertainty

Velocity USEPA M2A, 2C ± 5%

Temperature USEPA M2C +2oC

Moisture USEPA M4 ± 25%

Oxygen USEPA M3 ± 15%

Carbon dioxide USEPA M3 ± 15%

Nitrogen oxides USEPA 7E ± 15%

Please note that the MU can only relate to the gas concentrations reported and not to the calculated emission rates. This is because the source volumetric flowrates rely to some extent on data supplied by Neerabup such as the fuel gas feed rates, and which fall outside SLR’s accreditation/QA controls.

In considering an MU for the emission rate data (in kg/hour) it is generally considered that a gas compositional analysis, conducted to an ISO standard, on a calibrated gas chromatograph would attract an uncertainty of only one or two percent as a maximum. Fuel gas feed rate data would also be expected to accrue about 1 to 2% of uncertainty when measured with modern, state of the art instrumentation. In combining all errors a total MU of ±10% would not be an unreasonable expectation of this particular programme for the reported emission rates.


APPENDIX 2 – INCIDENT REPORTS No incidents were reported to DWER during this period.


APPENDIX 3 – EXTERNAL COMPLAINTS REGISTER No external complaints have occurred during this reporting period.

O:\Operations\Neerabup\09 - Registers\External Complaints Register\NPS-REG-EXT-COMP External Complaints Register.xlsx\Power Station Incidents

MEX WO#

No complaints received to date. 29/08/2017









Complaint No Date Received Description (abbreviated) Actions Closed Date


STANDARD OPERATING PROCEDURE

External Complaints Register - Power Station

REV NO: 0 REV DATE:

NPS-REG-EXT-COMP

22/12/2010

Date Notification Completed

http://www.ermpower.com.au/

O:\Operations\Neerabup\09 - Registers\External Complaints Register\NPS-REG-EXT-COMP External Complaints Register.xlsx\PL75 - Ext Complaints











Complaint No Date Received Description (abbreviated) Actions Closed Date

Date Notification Completed

MEX WO#

STANDARD OPERATING PROCEDURE

External Complaints Register - Pipeline PL75

NPS-REG-EXT-COMP

REV NO: 0 REV DATE: 22/12/2010

http://www.ermpower.com.au/


APPENDIX 4 – INSPECTION PLAN SCHEDULE

NEEARBUP Forecasted Inspection Plan 2009 - 20321st Minor Insp 2nd Minor Insp. Current 3rd Minor Inp.

GT11 - Date 19/11/2014 10/11/2017 14/11/2017 April 2021 (forecast)Dynamic Hours 371 404 4004 N/ABaseload OH 937 1631 1634 N/APeakload OH 2032 3626 3639 N/ANormal Start 273 523 524 767Emergency Start 9 10 10 N/AEOH 6160 10991 11017 18555

GT12 - Date 28/11/2014 7/11/2017 14/11/2017 April 2021 (forecast)Dynamic Hours 441 441 441 N/ABaseload OH 676 1321 1330 N/APeakload OH 2007 3602 3626 N/ANormal Start 274 523 528 768Emergency Start 3 3 3 N/AEOH 5893 10623 10706 18197

GT Inspection Interval EOH Start Years

8000 250 n/a41000 1250 upto 12

123000 3000 n/a

Inspection scopeMinor - entry to accessible regions for visual inspection on followings:-

compressor inlet including air intakeburners and flame cylinder end plateceramic tile lining of flame cylinders, hot gas path of mixing and inner casingsturbine stage 1 and 4exhaust casing and diffuser liner

Major - extensive dismantling, detail visual inspection and non-destructive evaluation;refurbishment of coated airfoils in turbine and compressor sections;scheduled and condition-based repair measuresimplementation of LTE measures

GT Generator Inspection IntervalYears

Min Max10000 20000 n/a8000 10000 upto 3

16000 20000 upto 640000 60000 upto 12

Initial - maximal as Main inspection, removal of rotor

Short - checks and measures required based on observation during operation and checks;

Intermediate - similar to Short Inspection including partial disassembly but without rotor removal

Main - similar to Intermediate Inspection but with rotor removal

UpdatedForecast EOH (accumulative)

31-A

ug-0

9

30-S

ep-0

9

31-O

ct-0

9

31-A

ug-1

1

30-S

ep-1

1

31-O

ct-1

1

30-N

ov-1

4

30-N

ov-1

7

30-A

pr-2

1

30-S

ep-2

5

30-S

ep-2

8

31-M

ay-3

2

30-N

ov-3

2

5 5 5 5 5 5 5 5 5 5 5 5 8Starts no. GT11 3 23 37 98 103 115 275 528 767 1076 1286 1543 1578EOH GT11 40 572 975 2373 2346 2752 6203 11159 18471 27923 34343 42189 43259EOH Generator GT11 40 572 975 2373 2346 2752 6203 11161 18555 28113 34605 42539 43621

Starts no. GT12 5 25 33 94 98 121 274 529 768 1077 1287 1544 1579EOH GT12 59 404 539 2058 2110 2749 5893 10801 18113 27565 33985 41831 42901EOH Generator GT12 59 404 539 2058 2110 2749 5893 10803 18197 27755 34247 42181 43263

Click to expand hidden cellsOthers Senarios

1) The forecast results for Neerabup are based on two likely scenarios i.e. a) Operating Regime No.5 (70 starts / yr) yeilding 2140 EOH / yearb) Combination of Operating Regime No. 7 (no starts for 9 months) and No.8 (3 start / week for 3 summer months) yeilding about 26starts & 1000 EOH / yearc) Combination of Operating Regime No. 7 (no starts for 7 months); No.9 (3 start / mth for 3 summer months) and No.10 (1 start / mth for 2 summer shoulder months) yeilding about 11 starts & 132 EOH / yeard) Combination of Operating Regime No. 7 (no starts for 9 months) and No.11 (5 start / week for 3 summer months) yeilding about 63 starts & 1584 EOH / year

2) For all scenarios, most inspection intervals are pre-dominated by time factor rather than EOH factor3) With a lower starting EOH, and to achieve a staggerred outage, inspection intervals for GT12 lags GT11 by a few moths to a year (Major Inspection) 4) EOH criteria for Generator is different from GT .

Inspections for Generator are scheduled to coincide with those for GT as far as possible to minimise number of outages.

Operating Regime No.5 - 70 starts / year

Scenario a)

Short Inspection (3 days)Intermediate Inspection (2 weeks)

Main Inspection (4 weeks)

DescriptionMinor inspection (3 days)

Major inspection (25 days)

EOH Description

Life Extention inspection (35 days)

Initial Inspection (4 weeks)

GT11/12 5th Minor Inspection

GT11/12 Commercial Operation 19 Oct 2009

GT12 End of Warranty Inspection 29-31Aug 2011

GT11 End of Warranty Inspection 1-2 Sept 2011

GT11/12 End of Warranty19 Oct 2011

1st Minor Inspections CompletedUnit 11 - 19/11/2014 (@273 starts, 6,159 EOH)Unit 12 - 21/11/2014 (@272 starts, 5,851 EOH)

GT11/12 4th Minor Inspection

GT11 1st Major Overhaul1500 starts

GT12 1st Major Overhaul1500 starts

2nd Minor Inspections CompletedUnit 11 - 10/11/2017 (@ 523 starts, 10,991 EOH)Unit 12 - 07/11/2017 (@ 523 starts,10,623 EOH )

Kho Su Chuan:GT11/12 3rd Minor Inspection

Documents

Neerabup Stack Emissions Management Plan (SEMP) Annual ... · Neerabup Stack Emissions Management Plan (SEMP) Annual Compliance Report 2016-2017 Author: Bruno Lanciano