Licence conditions for pollution studies and reduction program


  

Licence conditions for pollution studies and reduction programs

Summary
 
Licence number: 12003
Title: PRP 6 - Predictive Emissions Monitoring System
Start date: 01 Jan 2014
 
Licence Condition
AIM The aim of this Pollution Reduction Program (PRP) is to allow the licensee to trial a Predictive Emissions Monitoring System (PEMS) on its Compressor Engine 2 and 3 (Licensed Discharge Points 2 and 3 respectively on EPL12003). The trial will be undertaken for a period of six months to determine suitability of PEMS as a replacement to continuous emissions monitoring for nitrogen oxides (NOx). BACKGROUND Clause 2.2 of the Enforceable Undertaking approved by the EPA on 8 August 2013 provides that: Within one month of the date of signing of this undertaking AGL must submit in writing to the EPA a proposal to trial a PEMS on Compressor Engines 2 and 3 for an agreed period.Subject to the EPA’s approval in writing, AGL will implement the trial. Upon completion of the trial the EPA may approve PEMS as the monitoring system for Compressor Engines 2 and 3 subject to conditions of the EPL. The PEMS is proposed as a suitable alternative to continuous emissions monitoring to predict Nitrogen Oxides (NOx) in-stack concentrations specifically for Compressor Engines 2 and 3. THE TRIAL The PEMS proposal is outlined in the document Environment Protection Licence 12003 Enforceable Undertaking Clause 2.2: Proposal to trial Predictive Emissions Monitoring System (PEMS) (AGL, 2 September 2013). The PEMS for engines 2 and 3 will utilise monitoring data from the engine compressors (load and speed) and differential catalyst temperature (pre and post catalyst). This data will be compared against engine emission and catalyst destruction efficiency specifications that have been conservatively derived to ensure predicted emission concentrations are less than actual emission concentrations. The Licensee must: • continue monitoring emissions with the current TESTO CEMS units on compressor engines 2 and 3 for the duration of the trial. • continue monthly independent air emission monitoring for the duration of the trial on compressor engines 2 and 3. • engage independent air emission monitoring consultants to undertake a full relative accuracy test audit (RATA) analysis of the PEMS. • ensure the PEMS is consistent with the abovementioned PEMS proposal, including US EPA Performance Specification 16 requirements. POST TRIAL REPORT By the Completion Date, the licensee must submit a final Report to the EPA in writing. The report must include, but not be limited to, the following information: 1. Operating conditions during the trial period, including compressor engine operational hours. 2. The results of all stack emissions testing conducted for each compressor engine during the trial. 3. The results of all reference method tests. 4. All test reports and raw data. 5. How ongoing operations will be managed to ensure compliance with EPL NOx concentration limits. 6. Any conclusions reached by AGL as a result of the trial. Note: Upon completion of the trial the EPA may approve PEMS as the monitoring system for Compressor Engines 2 and 3 subject to conditions of the EPL. COMPLETION DATE:31 August 2014 COMPLETED: 31 AUGUST 2014