Licence conditions for pollution studies and reduction program


  

Licence conditions for pollution studies and reduction programs

Summary
 
Licence number: 1552
Title: Wagon Monitoring and Reporting Environmental Improvement Program
Start date: 01 Feb 2016
 
Licence Condition
Background   The licensee is to implement a program of monitoring and reporting on the condition of loaded coal wagons received at the premises. All trains entering the dump station will be assessed against criteria relating to the likelihood that coal may have been spilt within the rail corridor during the train’s most recent journey. Reporting of the recorded train assessments will be undertaken on a 24 hour, weekly and monthly process. The program is to include a review and audit process to ensure assessment consistency and program effectiveness. The program will commence on 1 February 2016 with a formal review to be undertaken with the EPA on 1 September 2016 prior to closure, or otherwise agreed by the EPA in writing.   This program has been included on the Environment Protection Licences of the  four main coal shipping terminals in New South Wales, which includes the following (subsequently referred to as “the Coal Terminals”). (i)           The Carrington Coal Terminal, for which Port Waratah Coal Services Ltd (PWCS) holds Environment Protection Licence 601; (ii)         The Kooragang Coal Terminal, for which Port Waratah Coal Services Ltd (PWCS) holds Environment Protection Licence 1552; (iii)        The NCIG Coal Terminal, for which Newcastle Coal Infrastructure Group Pty Ltd (NCIG) holds Environment Protection Licence 12693; and (iv)        The Port Kembla Coal Terminal, for which Port Kembla Coal Terminal Limited (PKCT) holds Environment Protection Licence 1625.
Program   The assessment of wagon condition will be based on operator observations from the dump station control room, via a real time Closed Circuit Television System (CCTV). The operators will focus on:   ·      The presence of coal on a wagon sill – as the manifestation of an unbalanced or overloaded wagon and would indicate if parasitic coal is likely to be present on other external surfaces. ·      The height of a load – as an indicator of increased potential risk of coal loss from a wagon during a journey. Each train will be classified as either Satisfactory or Unsatisfactory, where an unsatisfactory classification will be based on the following criteria: o         Coal evident on the sill of wagons – coal observed on at least 50% of the sill length of a wagon. A systemic loading issue will also likely present on multiple wagons. o         Load height above wagon sill or gunwale of wagon – coal loaded in a wagon observed at a height greater than 150mm above the wagon sill over at least 50% of the length of a wagon. A systemic loading issue will also likely present on multiple wagons.
Reporting  The recorded assessment of the conditions of all trains will be reported. The information that will be recorded against each assessed train will include: • Date entered dump station • Time entered dump station • Load point • Train identifier • Overall assessed condition (i.e. satisfactory or unsatisfactory) • If unsatisfactory:         o Unsatisfactory criteria (i.e. coal on sill and/or over height)         o Photo of unsatisfactory conditions identified Reporting will be undertaken in accordance with the following criteria: (a) Within 24 hours • The identification of an unsatisfactory train will be reported to the load point. • Information recorded for a train classified as unsatisfactory will be provided to the load point. This timely reporting will enable the load point to investigate the associated loading event and take appropriate remedial action. (b) Weekly • A report will be provided to the EPA outlining the recorded detail for all assessed trains. • The report will incorporate data of the assessments undertaken and an overview of all unsatisfactory trains recorded, together with the recorded detail of all trains. • This report will be provided to the EPA’s Regional Manager – Illawarra, by email to epa.illawarra@epa.nsw.gov.au, every Wednesday for information recorded for the previous week (Sunday – Sunday). • The information provided in relation to the unsatisfactory trains will enable the EPA to follow-up with a load point the results of their associated investigation and any remedial action undertaken. (c) Monthly • A statistical summary report will be provided to the EPA detailing recorded train information in total and by load point. • This report will be provided to the EPA’s Regional Manager – Illawarra, by email to epa.illawarra@epa.nsw.gov.au, by the 15th of each month for information recorded for the previous month.
Review and Audit   The licensee will undertake a review of the program, as implemented, to ensure that the desired outcomes are being achieved.   The review and audit program will include:   ·               Monthly review meeting of all information collected by the licensees of the Coal Terminals (EPA optional) to consider assessments completed on all trains and any feedback received from either load points or the EPA. Any modification to the implemented program would be agreed at this meeting and undertaken through consultation with the EPA. ·               Monthly audit of trains classified as unsatisfactory across the Coal Terminals to ensure consistency of assessment. The requirement for further clarification, training or modification of the assessment criteria will be defined by this audit process. The audit will be collaboratively undertaken by a member of each of the Coal Terminals. ·               Upon completion of the monitoring / reporting program, a review meeting between the licensees of the Coal Terminals and the EPA will be undertaken to discuss the effectiveness of the implemented program.
Implementation   The following milestones apply to the establishment and delivery of the wagon monitoring and reporting program:   ·               The licensee will establish technology and systems to enable monitoring and reporting (e.g. cameras installed, employee training, reports developed) in respect of the No. 3 Dump Station – 31 January 2016. ·               Initial implementation of program with reporting to load points only in respect of the No. 3 Dump Station  – 1 February 2016. ·               Full implementation of program including weekly reporting to the EPA in respect of the No. 3 Dump Station– 1 March 2016. ·               The licensee will establish technology and systems to enable monitoring and reporting (e.g. cameras installed, employee training, reports developed) in respect of the No. 1, 2 and 4 Dump Stations – 31 March 2016. ·                Full implementation of program with reporting to load points and weekly reporting to the EPA in respect of the No. 1, 2 and 4 Dump Stations  – 1 April 2016. ·                Formal review and closure after six months of program implementation or otherwise as agreed – 30 September 2016.