Licence conditions for pollution studies and reduction program


  

Licence conditions for pollution studies and reduction programs

Summary
 
Licence number: 12003
Title: PRP 7 - Predictive Emissions Monitoring System (Stage 2)
Start date: 11 Dec 2014
 
Licence Condition
AIM The aim of this Pollution Reduction Program (PRP) is for the licensee to refine the Predictive Emissions Monitoring System (PEMS) on its Compressor Engine 2 and 3 (Licensed Discharge Points 2 and 3 respectively on EPL 12003).   BACKGROUND The Trial PEMS Program (PRP 6) was undertaken in accordance with Clause 2.2 of the Enforceable Undertaking signed by the Environment Protection Authority (EPA) and AGL on 8 August 2013. 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 Licensee provided its report ‘PRP 6 – Predictive Emissions Monitoring System Post Trial Report’ to EPA on 29 August 2014. The report identified that while the Trial generally provided information consistent with the proposal it identified that additional and more sensitive monitoring of deviations from normal compressor engine operations and catalyst performance is required. The Licensee has therefore proposed a Stage 2 PRP to investigate PEMS improvements.  
STAGE 2 - PROGRAM The Stage 2 PEMS Program is outlined in the document Environment Protection Licence 12003 PRP 6 – Predictive Emissions Monitoring System Post Trial Report (AGL, 29 August 2014). The Stage 2 Program will be undertaken for a period of six (6) months.   The PEMS for Engines 2 and 3 will continue to 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. In addition, the following works will be carried out: ·               Installation of secondary sacrificial catalyst upstream of existing primary catalyst ·               Installation of differential pressure transmitter across the catalyst ·               Replacement of the existing exhaust thermocouples ·               Collect additional information from engine controller for deviation monitoring; and ·               Tune the Catalyst destruction efficiency.   The Licensee has indicated the proposed sacrificial catalyst will also serve to reduce the NOx levels; however, its primary function is to protect the downstream primary catalyst from contamination.   The Licensee must: ·              continue monitoring emissions with the current TESTO CEMS units on Compressor Engines 2 and 3 for the duration of the revised Trial ·              continue monthly independent air emission monitoring for the duration of the Trial on Compressor Engines 2 and 3 ·              ensure the PEMS is consistent with the abovementioned PEMS proposal, including consistency with US EPA Performance Specification 16 requirements as far as practicable.
STAGE 2 REPORT Within 30 days of completion of the Stage 2 Program, the licensee must submit a written report to the EPA. 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:                                          1.        Upon completion of the Stage 2 Program, the EPA may approve PEMS as the monitoring system for Compressor Engines 2 and 3 subject to conditions of the EPL.   COMPLETION DATE:   14 APRIL 2016