Licence conditions for pollution studies and reduction program


  

Licence conditions for pollution studies and reduction programs

Summary
 
Licence number: 1698
Title: EIP: Further Investigation of new Chlorine and Sulphuric Acid Mist Limits - LDP 2 - Kiln 6 Stack
Start date: 09 Oct 2023
 
Licence Condition
Background: Prior to the use of non-standard fuels, the LDP2 limit for Chlorine was 200mg/m3 and the limit for Sulphuric Acid Mist was 100 mg/m3. Following The Department of Environment and Planning (DPE) issuing approval for Modification 9 (Mod9) - Use of Waste Derived Fuels in Kiln 6 - the EPA reviewed this licence and modified monitoring, limit and operational requirements to be consistent with the consent and application documents submitted by the licensee. The limits attached to this licence for both Chlorine and Sulphuric Acid mist are 50mg/m3. Based on modelling these limits will achieve appropriate ground level impact assessment criteria. The licensee has stated these limits are achievable, however they were based on a small data set, and it is possible that the licensee will be able to achieve lower limits. The licensee previously undertook an investigation into new Chlorine and Sulphuric Acid Mist limits and collected data over a two-year period. The data supported a lower limit for both Chlorine and Sulphuric Acid Mist. The licensee has now installed and will commission a new Chloride Bypass System, and will investigate through additional monitoring/stack testing achievable and appropriate limits (representing proper and efficient operation) for Chlorine and Sulphuric Acid Mist discharge limits for LDP 2 - Kiln 6 main stack.
Undertaking: The licensee must undertake emissions stack testing as required by the monitoring requirements of this licence over a two-year period, that is four 6-monthly stack tests. The licensee must review the monitoring data obtained during the above period, and the monitoring data obtained during the previous EIP - Investigation of new Chlorine and Sulphuric Acid Mist Limits - LDP 2 - Kiln 6 Stack, and prepare a written report to the EPA recommending feasible and reasonable Chlorine and Sulphuric Acid Mist concentration limits. The recommended limits must consider data obtained from emissions stack testing, and the requirements of S124 of the Protection of the Environment Operations Act (1997), in particular demonstrating Kiln 6 is being operated properly and efficiently. DUE DATE: 3 Months from the date of the fourth stack test (approximately 1st Quarter 2026).