appendix c air quality impact assessment

––

Appendix C

Air Quality Impact Assessment

AGL Confidential 2

AGL Note – The West Laydown area has been removed from the Amendment Report (refer p. 30). All references to the West Laydown area within the appendices should be ignored and not considered as part of the proposed amendment.

The business of sustainability

Newcastle Power Station


14 August 2020

Project No.: 0468623/AQIA/R9

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0468623_AGL_NPS_AQIA_20200814_.docx

Document details

Document title Newcastle Power Station

Document subtitle Air Quality Impact Assessment

Project No. 0468623

Date 14 August 2020

Version 12.0

Author James Grieve

Client Name Aurecon Australia Pty Ltd

Document history

Version Revision Author Reviewed by ERM approval to issue

Comments Name Date

Draft D1 James Grieve Damon Roddis Damon

Roddis 04.07.2019

Draft for Client

Review


Roddis 20.08.2019

Revised Draft

incorporating AGL

comments


Roddis 28.08.2019

Revised Draft

incorporating AGL

comments

Final R1 James Grieve Damon Roddis Damon

Roddis 06.09.2019 Finalised


Roddis 03.10.2019 Revised Final





Final R5 James Grieve,

Justine Firth Damon Roddis

Damon

Roddis 11.03.2020

Revised Final

addressing EPA

comments





Final R8

James Grieve

Justine Firth

Tajwar Dar

Damon Roddis Damon



Roddis 14.08.2020

Revised Final

addressing EPA

Request for

Information

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Signature Page

14 August 2020

Newcastle Power Station


James Grieve

Senior Consultant

Damon Roddis

Partner

ERM Australia Pacific Pty Ltd

© Copyright 2020 by ERM Worldwide Group Ltd and / or its affiliates (“ERM”).

All rights reserved. No part of this work may be reproduced or transmitted in any form,

or by any means, without the prior written permission of ERM.

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NEWCASTLE POWER STATION

Air Quality Impact Assessment CONTENTS

CONTENTS

EXECUTIVE SUMMARY ........................................................................................................................ 1

1. INTRODUCTION .......................................................................................................................... 3

1.1 Proposal Location .......................................................................................................................... 3 1.2 Assessment Scope ........................................................................................................................ 3

2. PROPOSAL DESCRIPTION ........................................................................................................ 5

2.1 Overview ........................................................................................................................................ 5 2.2 Power station ................................................................................................................................. 5

2.2.1 Gas Turbine Technology ............................................................................................... 5 2.2.2 Reciprocating Engine Technology ................................................................................ 6 2.2.3 Ancillary Facilities ......................................................................................................... 6

2.3 Construction Activities and Construction Staging .......................................................................... 6 2.4 Emissions to Air ............................................................................................................................. 7

2.4.1 Operational Phase ........................................................................................................ 7 2.4.2 Construction Phase ....................................................................................................... 7 2.4.3 Key Pollutants ............................................................................................................... 9

3. REGULATORY FRAMEWORK ................................................................................................. 10

3.1 Regulatory Emission Limits.......................................................................................................... 10 3.2 Impact Assessment Criteria ......................................................................................................... 11

4. AIR EMISSION CONTROL REVIEW ......................................................................................... 12

4.1 Generator Technology ................................................................................................................. 12 4.2 NOx Emission Control Technologies ............................................................................................ 13

4.2.1 Dry Low NOx (DLN) .................................................................................................... 13 4.2.2 Water / Steam Injection ............................................................................................... 14 4.2.3 Catalytic Combustion .................................................................................................. 14 4.2.4 Selective Catalytic Reduction (SCR) ........................................................................... 14 4.2.5 Selective Non-Catalytic Reduction (SNCR) ................................................................ 15 4.2.6 Non-Selective Catalytic Reduction (NSCR) ................................................................ 15 4.2.7 SCONOx

TM/EMxTM ....................................................................................................... 16

4.3 Technical Feasibility of Identified NOx Emission Control Technologies ....................................... 17 4.4 Emission Control Selection .......................................................................................................... 18

4.4.1 Technical Risk............................................................................................................. 18 4.4.2 Effectiveness............................................................................................................... 19

4.5 Evaluation of selected emission controls against Best Available Techniques (BAT) ................... 24

4.5.1 Gas Turbines .............................................................................................................. 25 4.5.2 Reciprocating Engines ................................................................................................ 25

4.6 Benchmarking .............................................................................................................................. 25

5. EXISTING ENVIRONMENT ....................................................................................................... 27

5.1 Climate and Meteorology ............................................................................................................. 27 5.2 Ambient Air Quality ...................................................................................................................... 34

5.2.1 Nitrogen dioxide .......................................................................................................... 34 5.2.2 Carbon Monoxide ........................................................................................................ 36 5.2.3 Sulfur dioxide .............................................................................................................. 37 5.2.4 Particulate matter less than 2.5 micrometres .............................................................. 39 5.2.5 Particulate matter less than 10 micrometres ............................................................... 41

5.3 Summary ..................................................................................................................................... 42

6. ASSESSMENT METHODOLOGY ............................................................................................. 43

6.1 Model Selection ........................................................................................................................... 43

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6.2 Dispersion Meteorology ............................................................................................................... 43 6.3 Model Receptors .......................................................................................................................... 43 6.4 Emission Parameters ................................................................................................................... 46 6.5 Building Downwash Effects.......................................................................................................... 46 6.6 NO2 Conversion ........................................................................................................................... 47

6.6.1 Ozone Limiting Method ............................................................................................... 48 6.6.2 In-Stack NO2:NOx Ratio .............................................................................................. 48

6.7 Predictions for Sub-hourly Averaging Periods ............................................................................. 49 6.8 Background Air Quality Dataset ................................................................................................... 50

7. EMISSION ESTIMATION ........................................................................................................... 51

7.1 Overview ...................................................................................................................................... 51 7.2 Estimation Methods ..................................................................................................................... 51 7.3 Fuel Consumption ........................................................................................................................ 53 7.4 US EPA AP-42 Emission Factors ................................................................................................ 53 7.5 Sulfur Dioxide Emission Factors .................................................................................................. 54 7.6 Summary of Modelled Emission Rates ........................................................................................ 54 7.7 Annualised Emission Estimates ................................................................................................... 55

8. RESULTS ................................................................................................................................... 56

8.1 Assessment Summary ................................................................................................................. 56 8.2 NO2 .............................................................................................................................................. 59 8.3 PM2.5 ............................................................................................................................................ 65 8.4 Acrolein and Formaldehyde ......................................................................................................... 71

9. OZONE AND INTERREGIONAL TRANSPORT ........................................................................ 76

9.1 Ozone Screening Assessment ..................................................................................................... 76

9.1.1 Classification as ozone attainment or ozone non-attainment area .............................. 77 9.1.2 Emissions Threshold ................................................................................................... 78 9.1.3 Level 1 Ozone Screening Assessment ....................................................................... 79

9.2 Previous Studies Considering Ozone and Interregional Transport .............................................. 80

10. LOCAL CUMULATIVE ASSESSMENT ..................................................................................... 82

11. CONCLUSIONS ......................................................................................................................... 86

12. REFERENCES ........................................................................................................................... 88

APPENDIX A CONSTRUCTION EARTHWORKS SCREENING ASSESSMENT

APPENDIX B METEOROLOGICAL MODELLING

APPENDIX C REVIEW OF EMISSIONS DURING START-UP AND SHUTDOWN

APPENDIX D DETAILED ACROLEIN ASSESSMENT

APPENDIX E METEOROLOGICAL ANALYSIS OF PEAK ACROLEIN PREDICTIONS

List of Tables

Table 1.1: SEARs relevant to air quality ................................................................................................. 3

Table 2.1: Summary of anticipated construction equipment by construction stage................................ 7

Table 2.2: Summary of key pollutants and basis of formation ................................................................ 9

Table 3.1: Summary of Clean Air Regulation emission limits – Gas Turbine Option ........................... 10

Table 3.2: Summary of relevant Clean Air Regulation emission limits – Reciprocating Engine Option10

Table 3.3: Summary of relevant air quality criteria ............................................................................... 11

Table 4.1: Technical feasibility of identified NOx control emission technologies (gas turbine option) .. 17

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Table 4.2: Technical feasibility of identified NOx emission control technologies (reciprocating engine

option) ................................................................................................................................................... 17

Table 4.3: Summary of selected control technologies and associated emission performance ............ 18

Table 4.4: Estimate of Equivalent Annual Cost (EAC) of SCR on gas turbine technology .................. 20

Table 4.5: Estimate of NOx emissions, marginal abatement and marginal abatement cost (MAC) for

SCR ....................................................................................................................................................... 21

Table 4.6: SKM (2010) marginal NOx abatement cost curve data (Greater Metropolitan Region) ....... 22

Table 4.7: Benchmarking of Proposal NOx emissions on a mass per unit output basis ....................... 26

Table 5.1: Summary of climate statistics for Newcastle University weather station (#061390, Period:

1998 - 2018) .......................................................................................................................................... 27

Table 5.2: Summary of nearby AQMS and weather stations with proximity to Proposal ..................... 28

Table 5.3: DPIE Beresfield - Summary of wind monitoring parameters (2013 – 2018) ........................ 29

Table 6.1: Summary of discrete receptors ............................................................................................ 44

Table 6.2: Summary of modelled emission parameters ....................................................................... 46

Table 6.3: Summary of excluded PM events ........................................................................................ 50

Table 6.4: Summary of adopted 2018 pollutant background concentrations. ...................................... 50

Table 7.1: Summary of emission estimation basis by pollutant and technology type........................... 53

Table 7.2: Summary of fuel emission estimates ................................................................................... 53

Table 7.3: Summary of adopted US EPA AP-42 emission factors (lb/MMBTU) .................................. 53

Table 7.4: Derivation of fuel-specific SO2 emission factor for natural gas operation ............................ 54

Table 7.5: Derivation of fuel-specific SO2 emission factor for distillate operation ................................ 54

Table 7.6: Summary of modelled emission rates .................................................................................. 54

Table 7.7: Annualised emission estimates – 100% Operation ............................................................. 55

Table 7.8: Annualised emission estimates – 100% Operation ............................................................. 55

Table 8.1: Assessment Summary – Gas Turbine Option ..................................................................... 57

Table 8.2: Assessment Summary – Reciprocating Engine Option ....................................................... 58

Table 8.3: Summary of model predictions - Maximum 1 hour average NO2 (µg/m³)............................ 59

Table 8.4: Summary of model predictions - Annual average NO2 (µg/m³) ........................................... 60

Table 8.5: Summary of model predictions – Maximum 24 hour average PM2.5 .................................... 65

Table 8.6: Summary of model predictions – Annual average PM2.5 ..................................................... 66

Table 8.7: Summary of model predictions – 99.9th percentile 1 hour average acrolein and

formaldehyde ........................................................................................................................................ 71

Table 9.1: 1 hour and 4 hour maximum ozone concentrations in the Newcastle region (ppm) ........... 78

Table 9.2: Classification of ozone attainment or non-attainment area ................................................. 78

Table 9.3: Emission thresholds for Schedule 1 activities located in non-attainment areas .................. 78

Table 9.4: Estimate of annual NOx emissions at 14% and 100% operating duty ................................. 79

Table 9.5: Summary of daily NOx and CO estimates (tonnes/day) ....................................................... 79

Table 9.6: Summary of Level 1 ozone screening tool results – Incremental ozone concentration (ppb)

.............................................................................................................................................................. 80

Table 9.7: Summary of the emission parameters assessed within CSIRO (2003) ............................... 81

Table 10.1: Annualised air emission quantities for sources near to the Proposal ................................ 82

Table 10.2: Annual maximum 10 minute average SO2 concentrations from TAC monitoring network 83

Table 10.3: Annual maximum 1 hour average SO2 concentrations from TAC monitoring network ...... 84

Table 10.4: Annual maximum 24 hour average SO2 concentrations from TAC monitoring network .... 84

Table 10.5: Screening for potential of the Proposal to produce localised SO2 exceedances............... 85

List of Figures

Figure 1.1: Map showing Proposal location and Proposal area. ............................................................ 4

Figure 4.1: Comparative schematic of conventional and lean pre-mixed burners (NESCAUM, 2000) 13

Figure 4.2: Schematic of SCR equipment for treatment of gas turbine exhaust - adapted from McGinty

(2016). ................................................................................................................................................... 15

Figure 4.3: Schematic representation of the SCONOxTM system (IPPC, 2017) .................................... 16

Figure 4.4: SKM (2010) Marginal NOx abatement cost curves (Greater Metropolitan Region) ............ 23

Figure 4.5: Benchmarking of Proposal NOx emissions on a mass per unit output basis ...................... 26

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Figure 5.1: Location of DPIE AQMS’ within the Newcastle region. ...................................................... 28

Figure 5.2: Annual and seasonal windroses - DPIE Beresfield 2014, 2015 ........................................ 31

Figure 5.3: Annual and seasonal windroses - DPIE Beresfield 2016, 2017 ....................................... 32

Figure 5.4: Annual and seasonal windroses - DPIE Beresfield, 2018 ................................................ 33

Figure 5.5: Time series plot of hourly ambient NO2 measurements within the Newcastle region (2014-

2018) ..................................................................................................................................................... 34

Figure 5.6: Summary statistics for Newcastle region ambient NO2 measurements (2014-2018) ........ 35

Figure 5.7: Time series plot of hourly ambient CO measurements at the Newcastle AQMS (2014-

2018) ..................................................................................................................................................... 36

Figure 5.8: Summary statistics for Newcastle region ambient CO measurements (2014-2018) .......... 36

Figure 5.9: Time series plot of hourly ambient SO2 measurements within the Newcastle region (2014-

2018) ..................................................................................................................................................... 37

Figure 5.10: Summary statistics for Newcastle region ambient SO2 measurements (2014-2018)....... 38

Figure 5.11: Time series plot of 24 hour average ambient PM2.5 measurements within the Newcastle

region (2014-2018) ................................................................................................................................ 39

Figure 5.12: Summary statistics for Newcastle region ambient PM2.5 measurements (2014-2018) .... 40

Figure 5.13: Time series plot of 24 hour average ambient PM10 measurements within the Newcastle

region (2014-2018) ................................................................................................................................ 41

Figure 5.14: Summary statistics for Newcastle region ambient PM10 measurements (2014-2018) ..... 42

Figure 6.1: Aerial image showing discrete receptors, gridded receptor domain extent and Proposal

boundary ............................................................................................................................................... 45

Figure 6.2: Aerial image showing reciprocating engine building representation (blue) and point

sources (red). ........................................................................................................................................ 47

Figure 6.3: ISR vs in-stack NOx concentration from filtered US EPA ISR database ............................. 49

Figure 8.1: Maximum incremental 1 hour average NO2 predictions – Gas Turbine Option (µg/m³) ..... 61

Figure 8.2: Maximum incremental 1 hour average NO2 predictions – Reciprocating Engine Option

(µg/m³) ................................................................................................................................................... 62

Figure 8.3: Annual average incremental NO2 predictions – Gas Turbine Option (µg/m³) .................... 63

Figure 8.4: Annual average incremental NO2 predictions – Reciprocating Engine Option (µg/m³) ...... 64

Figure 8.5: Maximum incremental 24 hour average PM2.5* predictions – Gas Turbine Option (µg/m³) 67

Figure 8.6: Maximum incremental 24 hour average PM2.5 predictions – Reciprocating Engine Option

(µg/m³) ................................................................................................................................................... 68

Figure 8.7: Incremental annual average PM2.5 predictions – Gas Turbine Option (µg/m³) ................... 69

Figure 8.8: Incremental annual average PM2.5 predictions – Reciprocating Engine Option (µg/m³) .... 70

Figure 8.9: 99.9th percentile incremental 1 hour average acrolein predictions – Gas Turbine Option

(µg/m³) ................................................................................................................................................... 72

Figure 8.10: 99.9th percentile incremental 1 hour average acrolein predictions – Reciprocating Engine

Option (µg/m³) ....................................................................................................................................... 73

Figure 8.11: 99.9th percentile incremental 1 hour average formaldehyde predictions – Gas Turbine

Option (µg/m³) ....................................................................................................................................... 74

Figure 8.12: 99.9th percentile incremental 1 hour average formaldehyde predictions – Reciprocating

Engine Option (µg/m³) ........................................................................................................................... 75

Figure 9.1: Ozone impact assessment procedure and current assessment pathway (Environ, 2011) 77

Figure 10.1: Location of TAC SO2 monitoring stations in the local vicinity of the smelter. ................... 83

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ABBREVIATIONS

Abbreviation Meaning

Approved Methods The Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales (EPA, 2016)

AQIA Air Quality Impact Assessment

AQMS Air Quality Monitoring Station

Atm. Atmosphere (unit of pressure)

B(a)P Benzo(a)Pyrene

BACT Best Available Control Technology

CO Carbon Monoxide

CCGT Combined Cycle Gas Turbine

DPIE Department of Planning, Industry and the Environment (formerly OEH)

EAC Equivalent Annual Cost

GJ Gigajoule

GMR Greater Metropolitan Region

g/s grams/second

HAP Hazardous Air Pollutant

HRSG Heat Recovery Steam Generator

ISR In-Stack (NO2:NOx) Ratio

K Degrees Kelvin

kV Kilovolt

LAER Lowest Achievable Emission Rate

MAC Marginal Abatement Cost

MAQS Metropolitan Air Quality Study

mg/Nm³ milligrams per normal cubic metre

MMBTU Million British Thermal Units

MW Megawatt

NGSF Newcastle Gas Storage Facility

Nm³ Normal cubic metre (i.e. 1 cubic metre at conditions of 273K and 1 atm)

NO Nitric oxide

NO2 Nitrogen dioxide

NOx Oxides of nitrogen

OCGT Open Cycle Gas Turbine

O2 Oxygen

OEH Office of Environment and Heritage (now DPIE)

PAH Polycyclic Aromatic Hydrocarbon

PM Particulate Matter (general – inclusive of all size fractions)

PM10 Particulate Matter less than 10 microns in aerodynamic diameter.

PM2.5 Particulate Matter less than 2.5 microns in aerodynamic diameter.

ppb Parts per billion

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ppm Parts per million

RACT Reasonably Available Control Technology

SCR Selective Catalytic Reduction

SO2 Sulfur dioxide

TAPM The Air Pollution Model

µg/m³ Microgram per cubic metre

US EPA United States Environment Protection Agency

VOC Volatile Organic Compound

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NEWCASTLE POWER STATION Air Quality Impact Assessment

EXECUTIVE SUMMARY

EXECUTIVE SUMMARY

ERM Australia Pacific Pty Ltd (ERM) was commissioned by Aurecon Australasia Pty Ltd (Aurecon), on

behalf of AGL, to undertake an Air Quality Impact Assessment (AQIA) for the AGL Newcastle Power

Station (the Proposal), located near Tomago, NSW.

AGL is seeking to construct and operate a peaking power station of approximately 250 MW capacity,

comprising either aeroderivative gas turbine (gas turbine) or reciprocating gas engine (reciprocating

engine) generator technology.

The assessment considered potential air quality impacts associated with construction and operation of

the Proposal. The assessment used a quantitative dispersion modelling analysis to estimate

compliance of operational phase emissions with the New South Wales Environment Protection Authority

(NSW EPA) impact assessment criteria.

The existing environment was characterised in terms of climate, meteorology and ambient air quality,

with identification of key meteorological patterns, and the status of ambient air quality compliance:

Ambient air quality standards for nitrogen dioxide (NO2), carbon monoxide (CO) and sulphur

dioxide (SO2) are currently met at all Department of Planning, Industry and Environment (DPIE)

ambient air quality monitoring locations across the last five years reviewed, with significant margin

between peak measurements and the corresponding standards.

Short term (24 hour average) ambient air quality standards for particulate matter (PM); i.e.

particulate matter less than 2.5 micrometres in aerodynamic diameter (PM2.5) and particulate matter

less than 10 micrometres in aerodynamic diameter (PM10) are exceeded at all locations across the

five years reviewed.

The long term (annual average) PM2.5 ambient air quality standard1 is reached at Wallsend, and

exceeded at all other locations within the five years reviewed. The long term (annual average) PM10

ambient air quality standard is exceeded at Carrington, Stockton and Mayfield, and met at

Wallsend, Beresfield and Newcastle. A review of these exceedances noted the dominance of

extraneous events such as dust storms and bushfire activity.

Emissions from construction operations were reviewed, with subsequent assessment of particulate

matter emissions from earthworks, which possessed the key air emission potential for construction

phase. A quantitative analysis of these emission indicated that peak model predictions were within

relevant impact assessment criteria, thus indicating that the potential for these activities to produce

adverse air quality impacts is low and manageable through routine dust mitigation practices.

Manufacturer data and United States Environmental Protection Agency (US EPA) emission factors were

then used to estimate emissions for representative gas turbine and reciprocating engine technology

options. Both natural gas and distillate fuels have been assessed resulting in a total of 4 assessment

scenarios.

An evaluation of the power station’s emission performance and control technologies concludes that the

technologies currently proposed are consistent with Best Available Technology.

These emissions were applied on a continuous basis in the NSW EPA-approved CALPUFF dispersion

modelling package, in conjunction with regional background air quality and meteorological datasets for

the year 2018. Modelling predictions were processed into the concentration statistics required for

assessment against NSW EPA impact assessment criteria.

Pollutants with a Proposal contribution in excess of 10% of relevant impact assessment criteria are

confined to NO2 and PM (both technology options), as well as acrolein and formaldehyde (reciprocating

engine option only):

1 Annual average standards apply on a calendar year basis.




EXECUTIVE SUMMARY

Cumulative NO2 predictions were estimated using the ozone limiting method, in conjunction with

hourly time varying ozone and NO2 concentrations sourced from the DPIE Beresfield air quality

monitoring station. The maximum 1 hour average cumulative NO2 prediction was 123 µg/m³, equal

to 50% of the criterion.

Peak 24 hour average PM2.5 predictions were approaching criteria, with a peak incremental PM2.5

prediction of 7.6 µg/m³. When added to the peak background concentration of 17.1 µg/m³, this

results in a (maximum + maximum) cumulative concentration of 24.7 µg/m³, which is approaching

the NSW EPA 24 hour criterion of 25 µg/m³. Refinement of the analysis through use of a time

varying background would likely produce predictions well below those presented in this report.

Exceedances of acrolein were predicted for the reciprocating engine option when operational on

natural gas fuel, with the peak prediction across the modelling domain a factor of three times above

the NSW EPA acrolein criterion. This prediction was based on US EPA emission factor-based

estimates of acrolein emissions, for a 4-stroke lean burn gas engine in conjunction with a

conservative estimate of oxidation catalyst control efficiency.

To further investigate the potential for acrolein emissions to produce adverse air quality impacts,

the following analysis was undertaken:

A review of the NSW EPA and international screening criteria was conducted. Based on

assessment against these additional criteria, all predictions were estimated to be within

respective screening criteria, as formulated to be protective of adverse public health

outcomes.

A review of meteorological conditions conducive to acrolein exceedances was undertaken

and identified that predicted exceedances were associated with high wind, moderate

temperature daytime conditions and did not align with times at which the plant is most

likely to operate. In this capacity, the assumption of continuous operation, as adopted

within this assessment, is considered to provide a conservative assessment of peak

acrolein predictions.

Accordingly, the analysis conducted within this assessment indicates that the potential for the Proposal

to generate exceedances is low, and manageable through effective operation of the proposed emission

controls.

Lastly, a review of potential cumulative impacts with other local sources of air emissions was conducted

using the National Pollutant Inventory database. This review identified the Tomago Aluminium Smelter

as the key emission source of interest in terms of potential localised cumulative impacts. Accordingly,

an analysis of the smelter’s local air quality monitoring data was conducted, with assessment of

potential cumulative impacts resulting in no additional exceedances of SO2 impact assessment criteria

as a result of the Proposal.




1. INTRODUCTION

Environmental Resources Management Australia Pacific Pty Ltd (ERM) has been commissioned by

Aurecon Australia Pty Ltd (Aurecon) on behalf of AGL, to undertake an air quality impact assessment

(AQIA) for the Newcastle Power Station (the Proposal). AGL proposes to construct and operate a dual-

fuel (gas/diesel) power station (approximately 250-megawatt (MW)) and associated infrastructure,

including gas supply and electricity transmission connections.

This report provides an assessment of potential air quality impacts associated with the Proposal, in

accordance with the Approved Methods for the Modelling and Assessment of Air Pollutants in New

South Wales (EPA, 2016).

1.1 Proposal Location

The Proposal is proposed to be constructed at Tomago, approximately 14 km north-west of Newcastle

within the Port Stephens Council Local Government Area (Figure 1.1) (the Proposal Area). The

Proposal Area is approximately 96 ha in size and encompasses the following lots:

Lot 2 DP1043561;

Lot 3 DP1043561;

Lot 4 DP1043561 (partial lot);

Lot 202 DP1173564 (partial lot); and

Lot 1203 DP1229590 (partial lot).

The north-west boundaries of Lot 2 DP1043561, Lot 3 DP1043561, and Lot 4 DP1043561 as well as

the western boundary of Lot 1203 DP1229590 abut the Pacific Highway. The southern boundaries of

Lot 2 DP1043561, Lot 3 DP1043561, and Lot 202 DP1173564 adjoin industrial estates. Lot 202

DP1173564 is bounded to the east and north by lots containing dense vegetation.

The power station aspect of the Proposal would be constructed on land within Lot 3, which is located

within the western extent of the Proposal area. In addition, two temporary laydown areas are proposed

within the vicinity of the Proposal –

- The East Laydown Area: is proposed within the existing Newcastle Gas Storage Facility (NGSF), which is located to the east of the NPS (Lot 1203 DP1043561).

- The West Laydown Area: is proposed at the Hexham Metering Station (located approximately 2.5 km to the south of the Proposal Area (Lot 1 DP 813606).

1.2 Assessment Scope

The Secretary’s Environmental Assessment Requirements (SEARs) (Ref: SSI 9837) were issued by

the NSW Department of Planning and Environment (DPE) on 18 February 2019 and form the basis of

the environmental impact assessment for the Proposal.

Table 1.1 outlines the SEARs relevant to air quality, as well as the section of the report within which

they have been addressed.

Table 1.1: SEARs relevant to air quality

Requirement Section Addressed

An assessment of the likely air quality impacts of the project in accordance with the Approved Methods for the Modelling and Assessment of Air Pollutants in NSW (EPA, 2016);

This report

Ability to comply with the relevant regulatory framework, specifically the Protection of the Environment Operations Act 1997 and the Protection of the Environment Operations (Clean Air) Regulation 2010.

Section 3




Figure 1.1: Map showing Proposal location and Proposal area.




2. PROPOSAL DESCRIPTION

2.1 Overview

The Newcastle Power Station would be a dual fuel (gas and diesel) fast-start peaking power station

with a nominal operating capacity of 250MW at Tomago in NSW. The Newcastle Power Station would

supply electricity to the grid at short notice during periods of high electricity demand, and/or low supply,

particularly during periods where intermittent renewable energy supply is low or during supply outages.

This operation is aligned with AGL’s move to a renewable energy mix. While the primary role of the

Newcastle Power Station would be to provide firming or peaking capacity to the National Electricity

Market, to maximise operational flexibility each unit of the power station would be designed for

continuous operation. This impact assessment considers both the peaking load operation and the

continuous operation.

The Proposal would also involve the construction and operation of gas pipelines and an electricity

transmission line. The pipelines would supply the proposed power station with gas from the eastern

Australia gas transmission pipelines via the Jemena network and, as an option, the Newcastle Gas

Storage Facility (NGSF). A new electricity transmission line would transfer the electricity produced by

the proposed power station to the national electricity network via connection to the existing 132kV

TransGrid switchyard. The Proposal has a capital investment value of approximately $400 million and

is anticipated to be operational in the year 2022.

The main elements of the Proposal are as follows:

Power station, necessary supporting ancillary equipment and supporting infrastructure. The power

station would be capable of operating with diesel fuel, if necessary.

132kV electricity transmission line to the existing TransGrid switching yard.

Gas transmission pipelines and receiving station, compressor units, and ancillary infrastructure.

Storage tanks and laydown areas.

Water management infrastructure including pond(s), and a connection to Hunter Water potable

service in line with Hunter Water requirements.

Diesel storage and truck unloading facilities.

Site access road.

Office / administration, amenities, workshop / storage areas and car parking.

2.2 Power station

The power station would be a dual fuel power plant, capable of generating about 250 MW of electricity.

The proposed power station would either consist of large reciprocating engine generators or aero-

derivate gas turbine generators. Generation units would be dual fuel capable, meaning they would be

able to be supplied by natural gas and/or liquid fuel.

The decision to install gas turbines or reciprocating engine technology will be made based on a range

of environmental, social, engineering and economic factors that will be considered as the power station

design progresses.

2.2.1 Gas Turbine Technology

Electricity would be generated by gas turbine technology through the combustion of natural gas and/or

liquid fuel in turbines. With its heritage in the airline industry, aero derivative gas turbine units consist

of a compressor, combustion chamber, turbine and generator. Air is compressed to a high pressure

before being admitted into the combustion chamber. Fuel (natural gas or diesel as required) is injected

into the combustion chamber where combustion occurs at very high temperatures and the gases




expand. The resulting mixture of hot gas is admitted into the turbine causing the turbine to turn,

generating power. In an open cycle configuration, hot exhaust gas is vented to the atmosphere through

an exhaust stack, without heat recovery.

The turbines will be fitted with emission controls as required to meet regulatory emission limits under

both natural gas and distillate oil (‘distillate’) operation.

2.2.2 Reciprocating Engine Technology

With its heritage in the shipping industry and a form of internal combustion engine, reciprocating engines

used for power generation harness the controlled ignition of gas and/or diesel to drive a piston within a

cylinder. A number of pistons move sequentially to rotate a crank shaft which turns the generator.

Manufacturers have identified the requirement for selective catalytic reduction (SCR) and oxidation

catalysts in order to meet regulatory pollution control requirements.

2.2.3 Ancillary Facilities

The power station, regardless of chosen technology, would require supporting ancillary facilities. These

would include:

Natural gas reception yard potentially including gas metering, pressure regulation, compression, heating stations, pigging facilities and provision for flaring.

Generator circuit breakers, generator step-up transformers and switchyard including overhead line support gantry.

Water collection and treatment facilities.

Water storage tanks and ponds.

Truck loading/unloading facilities.

Liquid fuel storage tanks.

Emergency diesel generators with associated fuel storage.

Closed circuit cooling systems.

Control room.

Offices and messing facilities.

Electrical switch rooms.

Occupational health and safety systems including an emergency warning and evacuation system.

Workshop and warehouse.

Firefighting system.

Communication systems.

Security fence, security lighting, stack aviation warning lights (if required) and surveillance system.

Landscaped areas and staff parking areas.

Concrete foundations, bitumen roadways, concrete pads in liquid fuel unloading station and gas turbine or engine unit maintenance areas.

Concrete bund areas with drains for liquid fuel tanks, liquid chemicals store, oil filled transformers (if installed) and other facilities where contaminated liquids could leak.

Level construction and laydown areas.

Engineered batters to support and protect the power plant platform.

Sedimentation pond and associated diversion drain and earth bund.

2.3 Construction Activities and Construction Staging

Key construction activities for the Proposal would include:

Clearing of vegetation at the proposed power station site and as required along the electrical transmission and gas pipeline(s) easements.




Temporary laydown of plant and equipment both within the proposal area, and two areas within the vicinity of the Proposal –

- The Eastern Laydown Area: is proposed within the existing Newcastle Gas Storage Facility

(NGSF), which is located to the east of the NPS.

- The Western Laydown Area: is proposed at the Hexham Metering Station (located

approximately 2.5 km to the south of the Proposal Area.

Demolition of an existing house if not repurposed during construction and operation.

Installation of gas pipeline(s) and electrical transmission line infrastructure.

Earthworks to prepare the power station site and construction areas.

Installation of foundations and underground services.

Installation of aboveground civil, mechanical and electrical plant and equipment.

Commissioning and testing.

2.4 Emissions to Air

2.4.1 Operational Phase

Potential air emission sources associated with operation of the Proposal include:

Main generator plant (comprising either gas turbine or reciprocating technology).

Distillate storage tanks.

Gas reception infrastructure including heating stations, compressors (if not electrically powered) and flaring (if required).

Emergency diesel generators.

The main generator plant forms the critical focus of this assessment. At the time of preparation, limited

detail is available for gas reception and emergency diesel generators. Whilst potential air quality

impacts from these sources are typically minor, consideration should be made as the plant design is

progressed and such detail becomes available.

Emissions from distillate storage tanks would comprise volatile organic compounds. Distillate fuel used

by the Proposal would be of conventional automotive diesel grade, and compliant with the Fuel Quality

Standards (Automotive Diesel) Determination 2019 (AG, 2019). Accordingly, emissions would be

highest during tank filling, and would be similar in nature to those which occur during storage tank filling

operations at a retail service station. Given the large buffer distance surrounding this infrastructure,

potential air quality impacts are likely to be negligible, and have not been considered further within this

assessment.

2.4.2 Construction Phase

During the construction phase, there is the potential for dust to be generated due to the excavation and

handling of soils, site grading activities, and vehicle movements. Table 2.1 provides a summary of

anticipated construction equipment by construction stage.

Table 2.1: Summary of anticipated construction equipment by construction stage

Construction Stage Equipment

S1:

Site Preparation and Earthworks

Excavator

Bulldozer

Grader

Roller

Loader

Dump truck




Construction Stage Equipment

Material screener

Rock crusher

S2:

Concrete Foundation Works

Concrete truck

Concrete mixer

Compactor

Crane

S3:

Building Construction

Crane

Delivery trucks

Pneumatic tools

Electric tools

Power generators

Hammers

S4:

Pre-Pipeline Construction

Excavator

Track trencher

Crushing machine

Truck

Crane

S5:

Pipeline Construction

Welding/Bending machine

Pipe layer

Bulldozer

Padding machine

S6:

Transmission Line Construction

Excavator

Track trencher

Crushing machine

Truck

Crane

Noting the scale of construction and presence of buffers between the plant footprint and the site

boundaries, it is considered appropriate that potential air quality impacts be addressed via the

implementation of conventional management measures for construction operations.

Specifically, the minimisation and control of dust emissions during the construction period should be

detailed within the Construction Environmental Management Plan (CEMP) for the Proposal, through

the implementation of measures that address the management and mitigation of potential air quality

impacts.

Potential adverse air quality impacts associated with off-site laydown areas are considered negligible,

given that operations at these locations will be limited to the laydown and retrieval of plant and

equipment from existing hardstand.

Whilst the specific construction method is yet to be designated, AGL have identified that one method

may involve the screening and crushing of excavated rock material for reuse on site. It is understood

that this operation would occur over a period of approximately 6 weeks, during which approximately

50,000m³ of material would be excavated for screening and crushing prior to reinstatement.




In the context of the range of potential construction processes, this operation has been identified as

possessing higher dust generation potential, and hence has been assessed quantitatively in order to

establish the scale of potential air quality impacts and adequacy of dust management strategies. Details

of this analysis are provided in Appendix A.

2.4.3 Key Pollutants

The operational phase of the Proposal involves the combustion of natural gas and distillate fuels in

either gas turbine or 4-stroke dual-fuel reciprocating engine technologies. Potential air emissions have

been reviewed based on the Chapter 3 of the US EPA AP-42 Compilation of Air Pollutant Emission

Factors (US EPA, 2006), as well as manufacturer information. From this review, the following key air

pollutant emissions have been identified:

Oxides of nitrogen (NOx), inclusive of nitric oxide (NO) and nitrogen dioxide (NO2).

Carbon monoxide (CO)

Sulfur dioxide (SO2)

Particulate matter (PM) including:

- Particulate matter less than 2.5 µm in aerodynamic diameter (PM2.5)

- Particulate matter less than 10 µm in aerodynamic diameter (PM10).

Hazardous air pollutants (HAPs) including:

- Acrolein, benzene, formaldehyde and other volatile organic compounds (VOCs).

- polycyclic aromatic hydrocarbons (PAHs)

- ammonia (residual from SCR).

Table 2.2 provides a summary of these key pollutants and their basis of formation Table 2.2: Summary of key pollutants and basis of formation

Pollutant Formation/Emission Basis

NOx Oxidation of atmospheric nitrogen in high temperature combustion reactions

CO Incomplete oxidation of fuel-bound carbon

SO2 Oxidation of fuel-bound sulfur

PM - Incomplete oxidation of fuel-bound carbon.

- Oxidation of fuel-bound sulfur to sulphate.

- Emission of residual ash material within distillate fuel.

Acrolein - Incomplete oxidation of fuel-bound carbon.

Formaldehyde

Benzene

PAHs

Ammonia* Residual ammonia from SCR operation.

Note: *Applicable to reciprocating engine option for which SCR is proposed.




3. REGULATORY FRAMEWORK

Potential air quality impacts from industrial sources are managed in NSW via a collection of regulatory

instruments, which prescribe operating conditions, plant emission limits and ambient air quality criteria

to be applied in the assessment and management of industrial operations.

These instruments include:

The NSW Protection of the Environment Operations Act (1997) ‘the POEO Act’, which includes

provisions for the minimisation of air pollution and odour, as well as specifying scheduled activities

for which operators must carry an environment protection licence.

The NSW Protection of the Environment Operations (Clean Air) Regulation 2010 ‘the Clean Air

Regulation’ (as amended January 2019), which provides statutory emission limits and operating

requirements for industrial plant and activities.

The Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales

(EPA, 2017), ‘the Approved Methods’, which specify methods for the assessment of air emission

sources and impact assessment criteria.

A summary of these instruments, as relevant to the Proposal, is provided in the following sections.

3.1 Regulatory Emission Limits

The Clean Air Regulation provides emission limits applicable to both the gas turbine and reciprocating

engine plant options being considered for the Proposal. These emission limits apply to gases within

the exhaust stack for operational periods in which the plant is operational, excluding plant start-up and

shutdown.

Table 3.1 and Table 3.2 provide a summary of emission limits relevant to gas turbine and reciprocating

engine options, respectively.

Table 3.1: Summary of Clean Air Regulation emission limits – Gas Turbine Option

Substance Fuel Type

Units / Reference Conditions

Natural Gas Distillate

Solid Particles (Total) - 50 mg/m³,

dry, 273K, 101.3 kPa 15% O2

Nitrogen dioxide (NO2) or Nitric oxide (NO) or both, as NO2 equivalent

70 90

Smoke - Ringelmann 1 or

20% Opacity -

Note: Limits do not apply to start-up and shutdown periods.

Table 3.2: Summary of relevant Clean Air Regulation emission limits – Reciprocating Engine Option

Substance Fuel Type

Units / Reference Conditions


Solid Particles (Total) 50

mg/m³,

dry, 273K, 101.3 kPa 3% O2

Nitrogen dioxide (NO2) or Nitric oxide (NO) or both, as NO2 equivalent

450

Volatile organic compounds (VOCs), as n-propane,

or

Carbon Monoxide (CO)*

40 1,140

125 5,880

Smoke Ringelmann 1 or 20% Opacity -

Notes: These limits do not apply to start-up and shutdown periods.

*The standard for volatile organic compounds or carbon monoxide is satisfied if either of those standards is met.




AGL proposes to procure plant that complies with the requirements of the POEO Act and Clean Air

Regulation, and have sought manufacturer assurances on the capabilities of prospective plant options

to address the requirements outlined in Table 3.1 and Table 3.2.

Within this assessment, the development of emission estimates has been undertaken within these

requirements. Further discussion of this process is provided in Section 6.

3.2 Impact Assessment Criteria

The Approved Methods specify criteria relevant for the assessment of impacts from air pollution. These

criteria form the basis for the quantitative aspect of this assessment.

The criteria are primarily human health-based (i.e. they are set at levels to protect against health effects)

and also protect against adverse amenity and ecological impacts.

Table 3.3 summarises the air quality criteria for relevant to the Proposal.

Table 3.3: Summary of relevant air quality criteria

Pollutant Assessment Statistic Concentration (µg/m³) Assessment Basis

NO2 1 hour maximum 246

Cumulative

(including background) Annual mean 62

CO 15 minute maximum 100,000

1 hour maximum 30,000

8 hour maximum 10,000

SO2 10 minute maximum 712

1 hour maximum 570

24 hour maximum 228

Annual mean 60

PM2.5 24 hour maximum 25

Annual mean 8

PM10 24 hour maximum 50

Annual mean 25

Formaldehyde

99.9th percentile,

1 hour maximum

20

Incremental

(Proposal in isolation) Acrolein 0.42

Benzene 29

PAHs (B[a]P TEQ)* 0.4

Ammonia 330

Note: *PAHs as benzo{a]pyrene equivalent.




4. AIR EMISSION CONTROL REVIEW

This section provides a review of air emission controls selected for the Proposal, with a focus on NOx

controls, as NOx represents the key pollutant of interest for this assessment.

This Section provides:

A definition of the selected power generation technologies and associated technical requirements.

A review of prospective NOx emission control technologies, with identification of those that are

technically feasible for implementation on the Proposal.

Detail of selected emission controls with associated justifications.

Assessment of selected emission controls against best available techniques.

4.1 Generator Technology

A broad range of emission controls are applied to power generation processes. In considering the

applicability of potential controls, it is relevant to define the emission stream that is to be treated. In

addition, it is also relevant to outline the basis for which the proposed power generator technologies

have been selected, especially when excluding a prospective emission control technology on the basis

of compatibility with a given generation technology.

Consistent with the project need, AGL is proposing a fast-start dual fuel peaking plant with a nominal

capacity of 250 MW. It is intended that the Proposal provides firming capacity in support of existing and

planned (intermittent) renewable generation sources, whilst also improving energy security and

reliability within the electricity network.

In this respect, AGL has sought technological solutions that have demonstrated reliability, can operate

under a peaking2 regime, accommodate security of fuel supply, and feature redundancy in design as

per the following requirements:

Are commercially available.

Are demonstrated for peaking operation.

Accommodate both natural gas and distillate fuels.

Have a fast-start capability.

Are available on a scale that permits a nominal (gross) output of 250 MW for a plant comprising a

number of generator units.

AGL has identified the following technologies as being capable of addressing the Proposal

requirements3:

aero-derivative gas turbines.

dual fuel reciprocating engines.

A consideration of the requirements has been included in the consideration of prospective emission

control technologies.

2 Peaking operation includes a higher frequency of plant startups, but a lower frequency of operation overall.

3 Section 2.3 of the EIS contains additional detail on the consideration of alternative generation technologies.




4.2 NOx Emission Control Technologies

A number of different emission control technologies have been developed for power generation

processes. These can be classified into two types:

Primary Emission Controls – which are applied to the combustion process.

Secondary Emission Controls – which are applied to the exhaust stream after combustion is

complete (often referred to as ‘end of pipe’ controls).

Application of these technologies includes technical considerations that are specific to the operation

undertaken and the generation technology employed. This section provides an overview of NOx

emission control technologies that have been reviewed in the selection of emission controls for the

Proposal.

As context to the concentrations presented in this chapter, NOx emissions from uncontrolled gas

turbines are in the vicinity of 200 ppm (~ 400 mg/m³) at a reference of 15% O2. Uncontrolled NOx

emissions from dual fuel reciprocating engines can be significantly higher than this.

4.2.1 Dry Low NOx (DLN)

Dry Low NOx (DLN) is a gas turbine-specific primary combustion control that involves the pre-mixing of

fuel and combustion air to reduce peak flame temperatures, thus suppressing NOx formation. Air and

fuel are pre-mixed in concentrations below the lower flammability limit and introduced into a combustion

zone which is supported by a pilot flame. Figure 4.1 provides a comparative schematic of conventional

and lean pre-mixed burners.

Figure 4.1: Comparative schematic of conventional and lean pre-mixed burners (NESCAUM, 2000)

Relative to uncontrolled (diffusion flame) combustion, this technology is capable of achieving NOx

emission reductions in the vicinity of 90%, with equipment guarantees typically ranging from 9 -25 ppm

(dry at 15% O2), (NESCAUM, 2000).

Since liquid fuels cannot easily be pre-mixed, they are not typically suitable for use in DLN burners

(NESCAUM, 2000). In the case of the Proposal, DLN-equipped turbines have not been able to meet

Clean Air Regulation emission standards when firing liquid fuels. As such, this technology has not been

considered further.




4.2.2 Water / Steam Injection

Water / Steam injection is a primary combustion control that involves the introduction of water or steam

into the combustion zone and was the primary method of NOx reduction prior to the wider uptake of

DLN technology. This technique reduces peak flame temperatures partly through dilution of the

combustion gases, as well as uptake of heat within the combustion zone.

This technology is capable of achieving NOx emissions of 25 ppm on gaseous fuels, and 42 ppm on

liquid fuels (GE, 2020). As noted above, this is relative to uncontrolled concentrations in the vicinity of

200 ppm (dry, 15% O2). The technique does result in increased CO and VOC emissions, as well as a

slight reduction in generator efficiency.

Water injection is the most mature of gas turbine NOx controls, and has been demonstrated to operate

reliably on both gaseous and liquid fuels, whilst also satisfying POEO requirements.

Direct Water Injection (DWI) is also used in some reciprocating engine designs, however limited

information is available as to the applicability of this technology to the dual-fuel engines.

4.2.3 Catalytic Combustion

Catalytic combustion is a gas-turbine specific primary emission control that involves the use of catalyst-

based combustors to oxidise a mixture of natural gas and air at temperatures lower than those

associated with conventional flame-based combustors. This proprietary process was developed

commercially in the 1990s under the XononTM brand, and involves pre-heating the combustion stream

to catalyst operating temperature using a conventional DLN combustor, after which the primary (natural

gas) fuel and air are mixed and contacted with a catalyst, which allows combustion reactions to occur.

(SKM, 2005). Given the lower peak temperatures associated with this process, thermal NOx production

is significantly reduced, resulting in NOx exhaust concentrations below 3 ppm (dry, 15% O2), (ERG,

2009).

As of 2009, there were three commercial applications of this technology in the United States, on turbines

of approximately 1.5 MW capacity. In 2006, Kawasaki purchased the XononTM technology and offered

the technology on a single 1.4 MW turbine with no plans to apply the technology to larger turbines

(ERG, 2009). Since this time, this review has been unable to identify implementation of this technology

on the basis of either scale or generation application, and thus it has not been considered further for

the Proposal.

4.2.4 Selective Catalytic Reduction (SCR)

Selective catalytic reduction (SCR) is a secondary emission control that is applicable to both gas turbine

and reciprocating engine technologies, whereby NOx is converted to nitrogen and water vapour by

injection of a reducing agent (either ammonia or urea) into the exhaust stream. The mixed gases are

then passed through catalyst beds which promote the reduction chemistry. Examples of the chemistry

involved is provided in the following equations for ammonia-based SCR:

4NO + 4NH3 + O2 4N2 +6H2O

2NO2 + 4NH3 + O2 3N2 + 6H2O

Conventional SCR operates at temperature ranges between 200 – 400°C, hence in gas turbine

applications, the infrastructure is typically integrated into the heat recovery steam generator (HRSG) of

combined cycle gas turbine (CCGT) applications, where the exhaust is cooled prior to reaching the

SCR. Given the high exhaust temperatures of open cycle gas turbines, the application of SCR typically

either requires introduction of cooling air, and/or the use of a high temperature zeolite-based catalyst,

along with more careful consideration of overall system design. Figure 4.2 provides a schematic of

SCR equipment for the treatment of gas turbine exhaust.




Figure 4.2: Schematic of SCR equipment for treatment of gas turbine exhaust - adapted from McGinty (2016).

NOx control efficiencies of up to 90% are available in steady-state applications. When combined with

primary control measures such as DLN, NOx emission concentrations as low as 2 ppm (dry @15% O2)

have been achieved on CCGT plants, which has been determined to constitute a Lowest Achievable

Emission Rate (LAER) emission control standard within California. Further consideration of this

technology is provided in Section 4.4.1 and 4.4.2.

4.2.5 Selective Non-Catalytic Reduction (SNCR)

Selective non-catalytic reduction (SNCR) is a secondary emission control that uses reduction chemistry

to convert NOx into nitrogen and water vapour. This process involves injection of a reducing agent

(ammonia or urea) into a high temperature exhaust stream in the post-combustion zone. The reaction

takes place in the absence of a catalyst, and is instead reliant on high temperatures in the range of

approximately 800 – 1,100°C for this conversion to occur. Removal efficiencies are greatest for sources

with the highest pre-treatment NOx concentrations, and ranges of 20% to 65% are common (US EPA,

2017).

SNCR is commonly applied to industrial boilers, however is not compatible with either reciprocating

engine or gas turbine technologies, as both of these technologies are internal combustion processes,

and extract power (with a corresponding drop in pressure and temperature) from the combustion gases

prior to the opportunity to inject a reducing agent. This means that the exhaust stream is in the order

of 400°C below that for which SNCR is effective, and is hence not compatible with the Proposal.

4.2.6 Non-Selective Catalytic Reduction (NSCR)

Non-selective catalytic reduction (NSCR) is a secondary emission control that uses a catalyst without

additional reagents to simultaneously reduce NOx to nitrogen, and oxidise carbon monoxide and

residual hydrocarbons to carbon dioxide and water.

This technology is only effective in a stoichiometric/fuel rich environment, where depleted oxygen

contents allow the reduction reactions to proceed. Commonly referred to as 3-way catalytic converters,

this technology is similar to those found on motor vehicles. The reactions take place at between 430 –

650°C (SKM, 2005), with fuel to air ratios managed carefully to achieve exhaust oxygen contents of <

0.5% (v/v), at which NOx and CO control efficiencies in excess of 90% can be achieved (MECA, 2015).

Gas turbine and dual fuel reciprocating engine technologies rely on lean burn principles, with exhaust

oxygen contents typically in the range of 12 – 16% (v/v). Under these conditions, NSCR is not effective,

and is hence not compatible with the Proposal.




4.2.7 SCONOxTM/EMx

TM

SCONOxTM and its second generation variant EMxTM is a secondary emission control that uses

catalyst/absorption based technology to oxidise both CO to CO2 and NO to NO2, then absorbing NO2

onto potassium carbonate coated media. Unlike SCR, no reagents are added in this process.

Catalyst modules are intermittently isolated from the exhaust flow using a system of baffles, thus

allowing the media to be regenerated using steam, hydrogen and carbon dioxide. Under this process,

the absorbed NO2 is emitted as nitrogen.

The technology is suitable for exhaust streams in the range of 150 – 370°C, and can achieve NOx

emissions as low as 2 ppm, alongside hydrocarbon and CO control efficiencies of 90% (IPPC, 2017).

Figure 4.3 provides a schematic representation of the SCONOxTM system.

Figure 4.3: Schematic representation of the SCONOxTM system (IPPC, 2017)

In 25 years since initial development, successful application of this technology to larger gas turbines

(>5 MW) appears limited to a single combined cycle gas turbine (CCGT) facility in Redding, California

(ERG, 2009; AGPE, 2016).

In reference to the Redding facility, BAAQMD (2010) states “after three years of operation, the Shasta

County AQMD evaluated whether the facility was meeting this demonstration limit with EMx™, and

concluded that ‘Redding Power is not able to reliably and continuously operate while maintaining the NOx

demonstration limit of 2.0 ppmvd @ 15% O2’.” Further detail of operational and reliability experience at

Redding is provided in AGPE (2016)4. Since this time, the Redding SCONOxTM system has been

replaced with SCR.

Given the absence of application on open cycle gas turbines, or at plant scales compatible with the

Proposal, this technology has not been considered further for the Proposal.

4 Page 4.1C-9 https://efiling.energy.ca.gov/GetDocument.aspx?tn=210803-7&DocumentContentId=26423

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4.3 Technical Feasibility of Identified NOx Emission Control Technologies

The technical feasibility of each emission control technology has been assessed as a function of the

following criteria:

Technical Compatibility: Whether the emission control technology is able to be applied to the proposed power generation technologies – which feature lean burn, dual-fuel internal combustion cycles.

Proven Technology: Whether the emission control technology has been implemented and demonstrated to be reliable and effective on the proposed power generation technology at a scale/application that is consistent with the Proposal.

Regulatory Compliance: Whether the design concentration is able to meet the requirements of the Clean Air Regulation.

For an emission control technology to be considered technically feasible, it must be able to meet all of

these criteria.

Table 4.1 and Table 4.2 provide a summary of the technical feasibility of the identified NOx emission

control technologies for gas turbine and reciprocating engine options (respectively).

Table 4.1: Technical feasibility of identified NOx control emission technologies (gas turbine option)

Emission Control Technology

Gas Turbine Option

Technical Compatibility

Proven Technology Regulatory Compliance

Technically Feasible

Primary Emission Controls

DLN ✓ ✓ ✗ ✗

Water Injection ✓ ✓ ✓ ✓

Catalytic Combustion ✗1 ✗1 N/A ✗

Secondary Emission Controls

SCR ✓ ~✓* ✓ ~✓*

SNCR ✗ ✗ N/A ✗

NSCR ✗ ✗ N/A ✗

SCONOxTM / EMx

TM ✓ ✗ ✓ ✗

Notes: 1 Catalytic combustion was not identified as being compatible with liquid fuel operation, nor proven on a scale/application basis for either natural gas or distillate fuel.

“N/A“: Not Applicable - Criterion void due to technical incompatibility. *Limited application observed.

Table 4.2: Technical feasibility of identified NOx emission control technologies (reciprocating engine option)

Emission Control Technology

Reciprocating Engine Option

Technical Compatibility

Proven Technology Regulatory Compliance

Technically Feasible

Primary Emission Controls

DLN ✗ ✗ N/A ✗

Water Injection - ✗ - -

Catalytic Combustion ✗ ✗ N/A ✗

Secondary Emission Controls

SCR ✓ ✓ ✓ ✓

SNCR ✗ ✗ N/A ✗

NSCR ✗ ✗ N/A ✗

SCONOxTM / EMx

TM - ✗ - ✗

Notes: “ – “: Cases of application to dual fuel reciprocating engines were not identified.

“N/A“: Not Applicable: Criterion void due to technical incompatibility.




As shown in the Tables 4.1 and 4.2, the two technically feasible technologies for the Proposal are water

injection and SCR.

4.4 Emission Control Selection

Table 4.3 provides a summary of the selected emission control technologies and associated

performance.

Table 4.3: Summary of selected control technologies and associated emission performance

Power Generation Technology

Gas Turbine Dual Fuel Reciprocating Engine

Technology Water Injection SCR / Catalytic Oxidation

Emission Performance 25 ppm dry @ 15% O2 (gas fuel)

42 ppm dry @ 15% O2 (distillate fuel)

150 mg/Nm³ dry @ 15% O2

(both fuels)

In this process, AGL has identified that SCR is not viable for application on the gas turbine technology

due to a number of factors, as detailed below.

4.4.1 Technical Risk

Open cycle SCR is noted to be an established technology. However, AGL has had difficulty in obtaining

a transparent understanding of the performance of open cycle SCR, as critical to the reliability and

availability requirements of the Proposal5. This is a critical aspect, given that the failure of emission

controls (as validated by continuous emission monitoring) would ultimately impact the ability of the

proposal to support energy security and reliability within the electricity network.

Engineering papers on the successful repair and re-design of open cycle SCR are common, and point

out the capability of the technologies once rectification work has been completed, whilst also covering

key design failures which include (Brattle, 2013; ICAC, 2009; NYISO, 2014a; NYISO 2014b; McGinty,

2016; Linfield, 2017; Muzio, 2018):

Irregular flow distribution

Insufficient quantity and/or mixing tempering air

Irregular ammonia mixing and poor ammonia injection grid design

Catalyst delamination/poisoning

Catalyst module sealing and structural issues.

Thus, from reviewing the material, it is clear that open cycle SCR is not an ‘off the shelf’ technology,

and requires customisation to the specific application. Noting the limited number of manufacturers, the

apparently common nature of equipment failures (relative to the extent of implementation), and the

absence of implementation within Australia, open cycle SCR is considered to present a significant

technical risk to the Proposal, and is thus inconsistent with AGL’s requirements for the implementation

of proven and established technology.

5 Whilst the capabilities of open cycle SCR technology are defined and cases of successful implementation noted, limited

examples of publically available compliance monitoring data have been sighted, and relative to the extent of implementation, a

significant number of instances of plant failures have been referenced. E.g. NYISO (2014a), which states:

“Mr. Ott states that he has “been involved in over 100 simple [i.e. open] cycle SCR systems with non-performance issues, some

of which led to formal warranty claims against the SCR vendors. Some of these non-performance issues involved systems that

include tempering air (cooling air) applications. In those systems, problems I identified involved catalyst failure, ammonia

maldistribution, tempering air maldistribution, seals issues/bypass, high ammonia slip, high inlet NOx and many other issues.”




4.4.2 Effectiveness

An assessment of the effectiveness of SCR has been made using a cost-based method that considers

the abatement cost of SCR on the gas turbine option relative to alternative NOx abatement measures.

The methodology is based on the rationale applied in studies such as:

(OSEC, 1999) Cost Analysis of NOx Control Alternatives for Stationary Gas Turbines, prepared

for the U.S. Department of Energy, Onsite Sycom Energy Corporation, 5 November 1999.

(ACIL Allen, 2014) Load-Based Licence Fee Comparison Study, prepared for NSW Environment

Protection Authority, ACIL Allen Consulting Pty Ltd, September 2014.

The Marginal Abatement Cost (MAC) has been estimated as the Equivalent Annual Cost (EAC)

(inclusive of capital and operating costs) divided by the annual emission reduction.

This relationship is shown in Equation 4.1 (ACIL Allen, 2014):

Equation 4.1

Where: C is the total capital cost

r is the discount rate; and

n is the number of years over which the emission reduction is financed and operational.

O is the annual operating cost.

For an abatement measure to be effective and provide a broader material benefit, it is necessary that it

be aligned with a beneficial environmental outcome whilst also being cost effective against alternative

abatement strategies and providing a material quantity of abatement.

Equivalent Annual Cost (EAC)

OSEC (1999) provides a detailed cost analysis of the application of SCR on gas turbines. Key costs

are noted to comprise a mixture of capital and operating costs inclusive of:

SCR equipment and installation (plant, materials engineering, construction, contractor fees).

Catalyst replacement.

Additional fuel / electricity costs associated with reduced power output and increased parasitic loads.

Other costs include:

Ammonia reagent.

Maintenance costs (beyond catalyst replacement).

Miscellaneous installation costs such as freight and taxes.

To provide a general lower bound MAC analysis, Table 4.3 provides an estimate of the EAC for the

installed SCR system and catalyst only. Items such as taxes, freight, as well as other fixed and variable

operating costs have been excluded.

In addition, given the differing lifetimes of the SCR system and the catalyst, the annualised costs have

been calculated as the sum of separate EACs for the catalyst media and the SCR system.

Catalyst volume has been calculated based on a default value of 30 ft³/MW installed (OSEC, 1999),

with a 70% margin to accommodate transient conditions associated with peaking operation (NYISO,

2014b). SCR capital cost has been estimated using an overnight capital cost estimate of $86/kW

(Brattle, 2013), which is based on a Siemens F class turbine of approximately 250 MW capacity. SCR




for which an allowance for peaking operation has been made, i.e. it is inclusive of a 70% additional

catalyst volume as per NYISO (2014b).

Table 4.4 provides a summary of this estimate.

Table 4.4: Estimate of Equivalent Annual Cost (EAC) of SCR on gas turbine technology

Parameter Value Units Notes

Catalyst Media

Installed capacity 250 MW Nominal capacity of plant

Catalyst requirement 51 ft³/MW (OSEC, 1999), NYISO (2014b)

12,750 ft³ -

Cost of catalyst $227 USD/ft³

US EPA (2019): includes purchase, disposal and changeout labour.

$315 AUD/ft³ Exchange rate: 1 AUD = 0.72 USD

$4.0 M AUD -

Assumed lifespan 5 years Typical value.

Discount rate 7% - -

Catalyst Media EAC $1.0 M $/year -

SCR System (exc. Catalyst Media)

Installed capacity 250,000 kW Nominal capacity of plant

SCR installed cost (inc. catalyst)

$86 USD/kW (Brattle, 2013)

$119 AUD/kW Exchange rate: 1 AUD = 0.72 USD

$29.9 M - -

SCR installed cost (exc. Catalyst).

$25.8 M -

Assumed lifespan 15 years (OSEC, 1999)

Discount rate 7% - Typical value within power generation estimates.

SCR System EAC $2.8 M $/year

SCR System (System)

TOTAL EAC $3.8 M $/year Excludes taxes, duty, freight, and operating costs such as efficiency penalty, auxiliary loads, ammonia, non-

catalyst maintenance etc.

Note: intermediate values may appear non-additive/subtractive due to rounding.

As shown in Table 4.4, the annualised cost of SCR is estimated at approximately $3.8 M.

Marginal Abatement Cost (MAC)

In the context of this analysis, the MAC is the cost associated with achieving the (marginal) NOx

reductions beyond water injection via the use of SCR. Table 4.5 shows the marginal abatement

achieved, as well as the associated MAC. An average SCR-based NOx emission concentration of 5

ppm has been adopted to reflect the average across a peaking cycle, which is inclusive of times when

the SCR is not effective.

These values have been estimated for varying capacity factors, ranging from 1 – 14%, with 1%

representing a lower end of the range typical of NSW-based gas fired peaking plants, and 14% being

representative of the Proposal’s estimate operation.




Table 4.5: Estimate of NOx emissions, marginal abatement and marginal abatement cost (MAC) for SCR

Capacity

Factor

NOx Emissions (tonne NOx/year) SCR Marginal Abatement SCR MAC

25 ppm SCR @ 5 ppm (tonne NOx/year) NOx

1% 9 2 7 $500,000

2% 19 4 15 $250,000

5% 47 9 38 $100,000

10% 95 19 76 $50,000

14% 132 26 106 $40,000

As shown in Table 4.5, this lower-bound MAC ranges between approximately $500,000 and $40,000

per tonne of NOx abated for capacity factors ranging from 1-14%.

This estimate is consistent with alternative estimates for the application of SCR on open cycle gas

turbine peaking plants, for example TCEQ (2015) estimates in excess of $100,000 USD per (imperial)

ton of NOx abated, whilst also noting the importance of low capacity factors in this finding:

“Based on cost evaluations of similar projects with limited annual hours of operation... …the control cost

for SCR with air-cooled exhaust on SGT6 5000F CTs is above $100,000 per annual ton of NOx removed.

It should be noted that the major contributor to the high (poor) cost-effectiveness is due to the limited

operation of electric peaking plants. Most of the cost of SCR is capital cost, and the limited hours result

in a lower potential of annual tons of NOx to spread out that cost. Costs over $100,000/ton of NOx

reduced are considered economically unreasonable by the TCEQ and therefore do not constitute

BACT.”

(TCEQ, 2015)

Given the greater importance of capital costs in low capacity factor estimates, the exclusion of variable

costs in low capacity factor estimates is considered appropriate and conservative.

Noting this, the exclusion of variable operational impairments and costs (such as reduced power output,

and increased parasitic loads) is of greater significance with increasing capacity factors. Given their

reliance on plant output, these variable costs equate to fixed quantities ($/tonne) across all capacity

factors. As an example, inclusion of a 1% increase in gas turbine heat rates, and an additional 4 MW

of parasitic load would result in an additional abatement cost in the vicinity of $10,000 / tonne removed

(across all capacity factors). Whilst these costs are minor relative to the low capacity factor abatement

estimates, they are of increasing significance with increasing capacity factor.

Comparison to Alternative Abatement Options

SKM (2010) provides a set of cost abatement curves for air emission reduction actions within NSW.

This work incorporates 14 initiatives which identify a total of approximately 300,000 tonnes of

prospective NOx abatement. A summary of these initiatives, including MAC and abatement quantities

is provided in Table 4.6, whilst a graphical representation of these data is provided in Figure 4.4.




Table 4.6: SKM (2010) marginal NOx abatement cost curve data (Greater Metropolitan Region)

Rank Initiative MAC ($/tonne) Abatement

Quantity (tonne) Cumulative Abatement

Quantity (tonne) Cumulative

Abatement (%)

1 SmartWay Program -$456,000 712 712 0.2%

2 Shift Transport Mode to Cycling -$271,000 531 1,243 0.4%

3 Coal Fired Power Station Control - Low NOx Burners

$120 83,075 84,318 27.9%

4 Cement Industry NOx Control $290 1,810 86,128 28.5%

5 Coal Fired Power Station SCR $390 176,535 262,663 87.0%

6 Emission Limits for Industry (NOx and PM10)

$610 5,290 267,953 88.8%

7 Gas Engine Electricity Generation - SCR

$760 5,911 273,864 90.8%

8 Tier 4 Standards for Off-Road Vehicles/ Equipment

$1,200 1,502 275,366 91.3%

9 Euro 5/6 Emission for New Passenger Vehicles

$1,700 18,727 294,093 97.5%

10 Locomotive Replacement USEPA Tier 0 to 2 + Retrofit Tier 2 with SCR.

$5,800 4,927 299,020 99.1%

11 Recommission / Electrify Enfield-Port Botany Freight Line

$6,500 106 299,126 99.1%

12 Diesel Locomotive Replacement USEPA Tier 0 ---> Tier 2

$7,500 2,280 301,406 99.9%

13 Port Botany Shore-Side Power $9,500 317 301,723 100.0%

14 Summer-time Petrol Volatility (62 kPA to 60 kPA)

$110,000 32 301,755 100.0%

Total 301,755 - -




Figure 4.4: SKM (2010) Marginal NOx abatement cost curves (Greater Metropolitan Region)




SKM (2010) identifies 302,000 tonnes of NOx abatement opportunities, of which 90% (270,000 tonnes)

are available at less than $1,000 per tonne. In contrast, application of SCR on the proposal would offer

in the vicinity of 100 tonnes per year abatement, at a cost upward of 50 times greater than 90% of

identified abatement initiatives.

Liddell Power Station Closure

relevant to the discussion as to the cost effectiveness of alternative emission reductions, it is also noted

that the justification for the Proposal, is that it is integral to AGL’s Liddell Power Station closure plan. As

such, any increase in NOx emissions from the Proposal would coincide with a significant reduction in

emissions associated with the retirement of AGL’s baseload coal-fired power station at Liddell. In the

2018/2019 NPI reporting year6, the AGL Liddell plant was estimated to produce 21,000 tonnes of NOx,

at an emission intensity of 2.3 kg/MWh. In contrast, under gas fired operation at 14% capacity factor,

a water injection-based plant is estimated to produce approximately 130 tonnes per year, at an emission

intensity approximately 6 times lower than that of Liddell.

As a partial replacement of Liddell’s capacity (of which other replacement components include battery

storage and renewable power generation), the implementation of the Proposal as part of the Liddell

closure plan would result in a significant net reduction of NOx emissions within the NSW Greater

Metropolitan Region.

Summary

In summary, this analysis shows that the application of SCR on gas turbine technology would have

significant cost implications for the Proposal, whilst also providing a limited quantity of emissions

abatement. Such abatement would occur at a marginal abatement cost that is significantly higher than

alternative abatement opportunities identified within the region. In this context, SCR is not considered

cost effective in mitigating NOx emissions from gas turbine operations, nor is it considered to offer a

material quantity of abatement over and above the use of water injection.

4.5 Evaluation of selected emission controls against Best Available Techniques (BAT)

The principal reference in the determination of Best Available Technology for emissions control for the

Proposal has been the European Commission’s Best Available Techniques (BAT) Reference Document

for Large Combustion Plants (“the EU BREF”; IPPC, 2017). This document provides detailed

descriptions of a range of emission control methodologies applied to large combustion processes.

Reference has also been made to the US EPA (RACT/BACT/LAER Clearinghouse (RBLC) database

(US EPA, 2020) which provides individual case-specific New Source Review (NSR) emission control

rulings on the basis of:

RACT, or Reasonably Available Control Technology, is required on existing sources in areas that

are not meeting national ambient air quality standards (i.e., non-attainment areas).

BACT, or Best Available Control Technology, is required on major new or modified sources in

clean areas (i.e., attainment areas).

LAER, or Lowest Achievable Emission Rate, is required on major new or modified sources in

non-attainment areas.

The RBLC database has been searched for BACT cases within the last 5 years (2015 onward).

6 The NPI reporting period is from 1st July to 30th June each year.




4.5.1 Gas Turbines

The EU BREF notes that there are three main techniques that have been used to prevent or reduce

NOx emissions from gas turbines, namely:

Water or steam injection (often retrofitted to existing installations);

Dry Low-NOx Burners (DLN) widely applied for all kinds of gas turbines; and

Catalytic solutions e.g. SCR.

For the current application, the turbine technology providers have elected to use water injection

technology for NOx control. The principal reason for this is the dual fuel (gas and diesel) nature of the

Proposal, which makes the other two techniques unviable. The Proposal’s stated emission performance

through application of the water injection technology is to limit NOx to 25 ppm (51 mg/Nm³) for natural

gas, and 42 ppm (86 mg/Nm³) for distillate (at 15% oxygen).

This performance is comparable to that quoted in Table 10.24 of the EU BREF which states Best

Available Technology Achievable Emission Limits (BAT-AEL) in the range of 25-50 mg/Nm³ (daily

average) for new open cycle gas turbines. This performance is also consistent with the RBLC database

gas turbine BACT values which were observed to range from 9 – 25 ppm (~18 – 51 mg/Nm³)7. A single

BACT ruling of 42 ppm was identified for combustion turbines operating on liquid fuel8.

No values are presented for BAT-AELs for turbines operating on distillate due to an absence of data.

4.5.2 Reciprocating Engines

The EU BREF notes that the most important parameter governing the rate of NOx formation in internal

combustion engines is temperature, where the higher the temperature, the higher the NOx in the

exhaust gas.

While various techniques are noted for lowering combustion temperatures, the EU BREF additionally

notes that “in some applications (e.g. larger plants in sensitive areas in the US), gas engines have been

fitted with SCR for additional NOx reduction”.

For the Proposal, the reciprocating engines would use SCR technology for NOx control, which involves

the reaction of NOx and urea in the presence of a catalyst, to produce nitrogen and carbon dioxide.

The stated emission performance through application of SCR technology is to limit NOx to 150 mg/Nm³

(at 15% oxygen) for both natural gas and distillate fuel operation.

Table 7.6 of the EU BREF notes example NOx emissions for dual fuel engines in the range of 147-

380 mg/Nm³ in gas mode and 1,531-1,751 mg/Nm³ in distillate mode. Equivalent BACT rulings on dual

fuel engines were not identified on the RBLC database.

The Proposal would also use catalytic oxidation technology for VOC control in the reciprocating engines

which is consistent with techniques identified in the BREF.

4.6 Benchmarking

Table 4.1 presents a benchmarking of the Proposal’s NOx emissions on a mass per unit output basis

relative to other power stations in NSW. This information is presented graphically within Figure 4.1.

7 https://cfpub.epa.gov/rblc/index.cfm?action=PermitDetail.ProcessInfo&facility_id=28705&PROCESS_ID=113040

https://cfpub.epa.gov/rblc/index.cfm?action=PermitDetail.ProcessInfo&facility_id=28587&PROCESS_ID=112434




https://cfpub.epa.gov/rblc/index.cfm?action=PermitDetail.ProcessInfo&facility_id=28258&PROCESS_ID=111443 8 https://cfpub.epa.gov/rblc/index.cfm?action=PermitDetail.ProcessInfo&facility_id=28102&PROCESS_ID=110647











Table 4.7: Benchmarking of Proposal NOx emissions on a mass per unit output basis

Reference Plant Option Fuel NOx Emissions

(kg/hr) Output (MW)

NOx Emission Intensity

(kg/MWh)

Proposal

Gas Turbine Natural Gas 108.0 264 0.4

Distillate Oil 182.9 256 0.7

Reciprocating Engine

Natural Gas 255.3 269 0.9

Distillate Oil 276.5 269 1.0

Mt Piper CFPS Existing

Coal

5,120 1,320 3.9

Proposed (2009) 3,745 2,000 1.9

Eraring CFPS Pre-upgrade 12,621 2,640 4.8

Post-upgrade 9,835 3,000 3.3

Bayswater CFPS Proposed (2009) 3,262 2000 1.6

Liddell CFPS Existing 2,3979 1,055

10 2.3

NPI Emission Factor

Gas Turbine

Natural Gas (DLN) - - 0.4

Distillate Oil

(Water Injection) - - 1.0

New Coal Coal - - 1.9

Notes: References as cited within URS (2009), CFPS – Coal Fired Power Station. DLN – Dry Low NOx.

Figure 4.5: Benchmarking of Proposal NOx emissions on a mass per unit output basis

As shown in these data, the NOx emission intensity (kg NOx/MWh) of the Proposal is lower than modern

coal-fired generation technology. In addition, the selected gas turbine technology is also generally

consistent with the corresponding NPI-derived NOx emission intensity.

Also relevant to the consideration of emission quantities is the difference between the NOx emission

intensity of the Proposal relative to the Liddell power station, given that the Project is proposed as part

of a suite of generation projects associated with the closure of Liddell.

9 Hourly average based on NPI 2018/19 value: http://www.npi.gov.au/npidata/action/load/emission-by-individual-facility-result/criteria/state/null/year/2019/jurisdiction-facility/151 (accessed July 2020)

10 Hourly average based on National Greenhouse Energy Reporting (NGER) 2018/19 value:

http://www.cleanenergyregulator.gov.au/NGER/Pages/Published%20information/Electricity%20sector%20emissions%20and%2

0generation%20data/2018-19-greenhouse-and-energy-information-for-designated-generation-facilities---Facility-

details.aspx?ListId=%7B9FA7E23A-8D11-4D83-A481-5EFC36A5873C%7D&ItemID=26 (accessed July 2020).

0.0

1.0

2.0

3.0

4.0

5.0

NaturalGas

DistillateOil

NaturalGas

DistillateOil

Coal Coal Coal Coal Coal Coal NaturalGas - DLN

DistillateOil - WaterInjection

Coal

Gas Turbine Reciprocating Engine Existing Proposed(2009)

Pre-upgrade

Post-upgrade

Proposed(2009)

(2018/2019operation)

Gas Turbine New Coal

Proposal Mt Piper CFPS Eraring CFPS BayswaterCFPS

Liddell NPI Emission Factor

NO

xE

mis

sio

ns (kg/M

Wh)

http://www.npi.gov.au/npidata/action/load/emission-by-individual-facility-result/criteria/state/null/year/2019/jurisdiction-facility/151

http://www.npi.gov.au/npidata/action/load/emission-by-individual-facility-result/criteria/state/null/year/2019/jurisdiction-facility/151

http://www.cleanenergyregulator.gov.au/NGER/Pages/Published%20information/Electricity%20sector%20emissions%20and%20generation%20data/2018-19-greenhouse-and-energy-information-for-designated-generation-facilities---Facility-details.aspx?ListId=%7B9FA7E23A-8D11-4D83-A481-5EFC36A5873C%7D&ItemID=26






5. EXISTING ENVIRONMENT

This report section provides a summary of the existing environment including climate, meteorology and

ambient air quality. These factors are relevant to the consideration of atmospheric dispersion, as well

as the existing condition of the airshed, which forms an important consideration in the prediction of total

pollutant concentrations, for assessment against cumulative air quality criteria.

5.1 Climate and Meteorology

The Newcastle region has a humid sub-tropical climate with warm summers and mild winters.

Precipitation is typically heaviest in the first half of the year when east coast lows can bring very heavy

falls and damaging winds. The region is influenced by land- and seabreeze flows, which have significant

implications for air quality when extended anticyclonic conditions occur (PAE Holmes, 2011a).

Table 5.1 presents a summary of compiled climate statistics for the Bureau of Meteorology (BoM)

Newcastle University Weather Station, which is located approximately 9 km to the south of the Proposal.

Table 5.1: Summary of climate statistics for Newcastle University weather station (#061390, Period: 1998 - 2018)

Parameter

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual

Twice daily temperature observations (°C)

9am mean

23.3 22.6 20.7 18.5 14.8 12.3 11.3 13.0 16.7 19.3 20.2 22.3 17.9

3pm mean

27.3 26.5 25.0 22.1 19.5 17.0 16.6 18.2 21.1 22.7 23.7 26.0 22.1

Twice daily relative humidity observations (%)

9am mean

72 78 78 77 78 79 77 69 65 62 71 70 73

3pm mean

57 62 60 61 59 60 54 48 48 50 58 58 56

Temperature Range (°C)

Mean maximum

29.5 28.5 26.9 24.2 21.2 18.3 18.0 19.7 22.7 24.9 26.0 28.0 24.0

Mean minimum

19.5 19.4 17.6 14.1 10.5 8.8 7.3 8.0 10.7 13.4 15.9 17.9 13.6

Rainfall

Mean Rainfall (mm)

84.5 133.1 124.4 127.3 88.3 131.7 54.8 57.5 66.9 66.2 109.2 69.4 1147.1

Mean rain days

10.2 12.3 12.1 11.8 10.7 12.7 10.7 8.9 8.5 9.5 11.8 11.1 130.3

Sky Condition

Mean clear days

9.3 6.1 8.3 8.1 11.4 10.0 11.5 12.0 12.3 9.9 6.3 6.6 111.8

Mean cloudy days

9.8 10.9 8.9 8.0 7.8 7.9 8.0 5.8 5.4 8.2 11.5 9.5 101.7

Source: http://www.bom.gov.au/climate/averages/tables/cw_061390.shtml (accessed June 2019).

January is the warmest month with an average maximum temperature of 29.5°C. July is the coolest

month with an average minimum temperature of 7.3°C. February through April produces the highest

average monthly rainfall, whilst the number of rain days is relatively consistent across all months of the

year. Winters are generally drier with the highest prevalence of clear conditions.

http://www.bom.gov.au/climate/averages/tables/cw_061390.shtml




The NSW Department of Planning, Industry and the Environment (DPIE) operate 6 air quality monitoring

stations (AQMS), within the Newcastle region, the closest of which is the Beresfield AQMS, located

approximately 4.5 km WNW of the Proposal. These AQMS collect both meteorological and ambient air

quality data. Table 5.2 presents a summary of these AQMS locations, with proximity to the Proposal,

whilst Figure 5.1 shows these locations overlaid on aerial imagery.

Table 5.2: Summary of nearby AQMS and weather stations with proximity to Proposal

AQMS Location Easting (kmE, MGA94) Northing (kmN, MGA94) Distance from Proposal /

Bearing

Beresfield 374.627 6370.449 4.5 km WNW

Stockton 386.306 6358.923 12 km SE

Wallsend 375.623 6359.638 9.5 km WSW

Newcastle 384.038 6355.662 14 km SSE

Mayfield 381.057 6360.752 8.0 km SSE

Carrington 384.350 6358.050 12 km SSE

Figure 5.1: Location of DPIE AQMS’ within the Newcastle region.




Note: Base image sourced from Google Earth Pro.

Table 5.3 presents a summary of wind monitoring parameters for the DPIE Beresfield AQMS over the

most recent six years of monitoring.

Table 5.3: DPIE Beresfield - Summary of wind monitoring parameters (2013 – 2018)

Year Average Wind Speed (m/s) Percent Calms (wind speed < 0.5 m/s) Data Completeness

2014 2.4 4.9% 99.1%

2015 2.5 4.0% 98.9%

2016 2.8 4.2% 98.6%

2017 2.3 4.7% 85.4%

2018 2.4 4.9% 99.7%

All Years (2014 – 2018) 2.5 4.5% 95.6%




Figure 5.2 through 5.4 provide annual and seasonal wind roses for the DPIE Beresfield AQMS across

this period.

As shown in these figures and Table 5.3, winds are generally consistent between years, possessing an

average wind speed of 2.5 m/s with calm conditions occurring approximately 5% of the time. Dominant

winds on the north-westerly / south-easterly axis are consistent with those seen near to the Hunter

River, and show the influence of the Hunter Valley topography. North-westerly winds are dominant

during winter, whilst south-easterly winds are dominant during summer. Winds in autumn and spring

are blended around the valley axis, with strong north-westerly winds present during early spring.




Figure 5.2: Annual and seasonal windroses - DPIE Beresfield 2014, 2015




Figure 5.3: Annual and seasonal windroses - DPIE Beresfield 2016, 2017




Figure 5.4: Annual and seasonal windroses - DPIE Beresfield, 2018




5.2 Ambient Air Quality

An understanding of existing ambient air quality is required to allow an estimate of total pollutant

concentrations (i.e. inclusive of existing background and the Proposal), as required for assessment

against cumulative air quality impact assessment criteria. Air quality within the region is considered

typical of coastal settings, with influences from transport, industrial, domestic and biogenic sources

contributing to total background pollutant levels.

This section provides a brief overview of ambient air quality monitoring data within the Newcastle region.

5.2.1 Nitrogen dioxide

Continuous hourly average ambient NO2 concentrations are measured at six locations within the

Newcastle region (Figure 5.1). Figure 5.5 provides a visual representation of these measurements over

the period 2014 – 2018.

Figure 5.5: Time series plot of hourly ambient NO2 measurements within the Newcastle region (2014-2018)

As shown in Figure 5.5, all measured concentrations are within the EPA 1hr NO2 criterion of 246 µg/m³.

With the exception of two measurements (out of approximately 200,000 measurements), peak

concentrations are below 100 µg/m³, with higher measurements observed during the winter months.

Figure 5.6 provides a summary of NO2 monitoring statistics for Newcastle region ambient NO2

measurements (2014-2018).




Figure 5.6: Summary statistics for Newcastle region ambient NO2 measurements (2014-2018)

As shown in Figure 5.6, trends are generally consistent over the five year period, with peak

concentrations being approximately five times higher than average concentrations. Five year average

concentrations are highest at Mayfield (18.0 µg/m³), closely followed by Beresfield (17.9 µg/m³).

Averages at other locations range from 14.2 µg/m³ (Stockton) to 16.8 µg/m³ (Carrington).

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Wallsend Carrington Stockton Newcastle Mayfield Beresfield




5.2.2 Carbon Monoxide

Continuous hourly average ambient CO concentrations are measured at the DPIE Newcastle AQMS

(Figure 5.1), but not measured at other the other AQMS sites. Figure 5.7 provides a visual

representation of these measurements over the period 2014 – 2018.

Figure 5.7: Time series plot of hourly ambient CO measurements at the Newcastle AQMS (2014-2018)

As shown in Figure 5.7, all measured concentrations are within the EPA 1 hour CO criterion of

30,000 µg/m³, with a maximum measured concentration of 3,250 µg/m³. Annual peak concentrations

are generally below 2,500 µg/m³, with higher concentrations observed during the winter months.

Figure 5.8 shows a summary of CO monitoring statistics for Newcastle AQMS (2014-2018).

Figure 5.8: Summary statistics for Newcastle region ambient CO measurements (2014-2018)

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1,000

1,500

2,000

2,500

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1 hr Maximum 1 hr 99th Percentile 1 hr 90th Percentile 1 hr 75th Percentile Annual Average




As shown in Figure 5.8, trends in peak values possess a slight downward trend over the 5 years, whilst

average values are variable between years.

5.2.3 Sulfur dioxide

Continuous hourly average ambient SO2 concentrations are measured at six locations within the

Newcastle region (Figure 5.1). Figure 5.9 provides a visual representation of these 1 hour average

measurements over the period 2014 – 2018.

Figure 5.9: Time series plot of hourly ambient SO2 measurements within the Newcastle region (2014-2018)

As shown in Figure 5.9, all measured concentrations are within the EPA 1 hour SO2 criterion of

570 µg/m³. With the exception of three measurements (out of approximately 200,000 measurements),

peak concentrations are below 200 µg/m³. The maximum measured 1 hour SO2 concentration is

235 µg/m³.

A clear seasonal or temporal trend is not apparent. Figure 5.10 shows a summary of SO2 monitoring

statistics for Newcastle region (2014-2018).




Figure 5.10: Summary statistics for Newcastle region ambient SO2 measurements (2014-2018)

As shown in Figure 5.10, trends are generally consistent within the five year period, with peak

concentrations being approximately 30 times higher than average concentrations. Five year average

concentrations are highest at Stockton (7.7 µg/m³), followed by Carrington (6.3 µg/m³), which is possibly

due to an influence from shipping emissions. The five year average at Beresfield (4.0 µg/m³) is equal

to that at Newcastle, and slightly higher than that at Wallsend (3.6 µg/m³).

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5.2.4 Particulate matter less than 2.5 micrometres

Continuous hourly average ambient PM2.5 concentrations are measured at six locations within the

Newcastle region (Figure 5.1). Figure 5.11 provides a visual representation of 24 hour average


Figure 5.11: Time series plot of 24 hour average ambient PM2.5 measurements within the Newcastle region (2014-2018)

As shown in Figure 5.11, peak measurements exceed the EPA 24 hour PM2.5 criterion of 25 µg/m³ at

all locations. These measurements primarily relate to interregional dust storms, hazard reduction burns,

and bushfire events. Figure 5.12 shows a corresponding summary of PM2.5 monitoring statistics for

Newcastle region (2014-2018).




Figure 5.12: Summary statistics for Newcastle region ambient PM2.5 measurements (2014-2018)

As shown in Figure 5.12, trends are varied within the five year period, with peak concentrations being

approximately four times higher than average concentrations. Inter-annual variability in peak statistics

is primarily driven by the influence of exceptional events such as dust storms and bushfire activity

In 2016, extensive hazard reduction burns were the major influences on elevated PM2.5 concentrations

throughout NSW. All exceedances of the 24 hour average PM2.5 were linked to hazard reduction burns

(OEH, 2018).

Five year average concentrations are highest at Stockton (9.8 µg/m³), followed by Carrington

(8.3 µg/m³). The five year average at Beresfield (7.7 µg/m³) is near to that at Newcastle and Mayfield

(7.8 µg/m³), and slightly higher than Wallsend (7.3 µg/m³).

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5.2.5 Particulate matter less than 10 micrometres

Continuous hourly average ambient PM10 concentrations are measured at six locations within the

Newcastle region (Figure 5.1). Figure 5.13 provides a visual representation of 24 hour average


Figure 5.13: Time series plot of 24 hour average ambient PM10 measurements within the Newcastle region (2014-2018)

As shown in Figure 5.13, peak measurements exceed the EPA 24 hour PM10 criterion of 50 µg/m³ at all

locations. These measurements primarily relate to interregional dust storms, hazard reduction burns,

and bushfire events.

Of interest, the Office of Environment and Heritage (OEH), (now DPIE) Lower Hunter Particle

Characterisation Study (OEH, 2016) identifies that samples collected at Stockton contained

approximately 12 µg/m³ more annual average PM10 sea salt than Mayfield, with differences most

prevalent during the summer months when onshore winds are present. The effect is less pronounced

in PM2.5 due to the coarser makeup of coastal sea salt.

Figure 5.14 shows a corresponding summary of PM10 monitoring statistics for Newcastle region (2014-

2018).




Figure 5.14: Summary statistics for Newcastle region ambient PM10 measurements (2014-2018)

As shown in Figure 5.14, trends are varied within the five-year period, with peak concentrations being

approximately four times higher than average concentrations. Five year average concentrations are

highest at Stockton (38 µg/m³), followed by Carrington (24 µg/m³), and Mayfield (24 µg/m³). The five

year average at Beresfield (20 µg/m³) is near to that at Newcastle (22 µg/m³), and higher than Wallsend

(17 µg/m³). Inter-annual variability in peak statistics is primarily driven by the influence of exceptional

events such as dust storms and bushfire activity. A detailed review of these events is provided in

Section 5.8.

5.3 Summary

Based on this review the following

Ambient air quality standards for NO2, CO and SO2 are met at all locations across the 5 years

reviewed, with significant margin between peak measurements and the relevant standards.

Short term (24 hour average) ambient air quality standards for PM (PM2.5 and PM10) are exceeded

at all locations across the 5 years reviewed, due to environmental events; such as, dust storms

and bushfires.

The long term (annual average) PM2.5 ambient air quality standard is reached at Wallsend, and

exceeded at all other locations within the 5 years reviewed. The long term (annual average) PM10


Wallsend, Beresfield and Newcastle.

Ambient air quality is generally consistent within the region, with influence of sources such as

shipping and coastal sea salt evident in the data.

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6. ASSESSMENT METHODOLOGY

This section provides an overview of the technical approaches applied within the assessment.

6.1 Model Selection

Given the presence of buoyant air emissions within a coastal region, the use of a non-steady-state

model such as CALPUFF provides a distinct advantage in the treatment of calm conditions over steady-

state models (such as AERMOD or AUSPLUME), and is also able to address changes in meteorology

that occur with changing land use, including coastal fumigation.

The height of the atmospheric boundary layer is driven by turbulence, which is generated either

mechanically via air motion over rough obstacles, or convectively, through heating of the earth’s

surface. Noting the low surface roughness of water, and the ability of water to absorb and distribute

solar radiation, the levels of atmospheric turbulence are lower over water. CALPUFF addresses this

through the incorporation of algorithms that are able to treat these effects.

6.2 Dispersion Meteorology

The regional meteorology has been modelled using CALMET. CALMET is a meteorological pre-

processor that includes a wind field generator containing objective analysis and parameterised

treatments of slope flows, terrain effects and terrain blocking effects. The pre-processor produces fields

of wind components, air temperature, relative humidity, mixing height and other micro-meteorological

variables to produce the three-dimensional meteorological fields that are utilised in the CALPUFF

dispersion model (i.e. the CALPUFF dispersion model requires meteorological data in three

dimensions). CALMET uses the meteorological inputs in combination with land use and geophysical

information for the modelling domain to predict gridded meteorological fields for the region.

A one year meteorological dataset was compiled for CALPUFF for the calendar year 2018. The year

2018 has been selected based on a review of the last 5 years of meteorological data for DPIE Beresfield

AQMS (Section 4). 2018 was noted to be the most consistent with the 5 year average wind speed and

percent calms, whilst also exhibiting data completeness above 90% required for use in dispersion

modelling (99.7% complete). Ambient air quality data for this year is also generally consistent with other

years.

The compiled dataset includes hourly spatially-varying fields of meteorological variables relevant to the

estimation of pollutant dispersion.

CALMET has been run using six surface stations each augmented by corresponding upper air pseudo-

stations from the Commonwealth Scientific and Industrial Research Organisation’s (CSIRO’s) ‘The Air

Pollution Model’ (TAPM). These TAPM runs have incorporated assimilation into the lowest 3 layers in

order to control winds within the surface layer to reflect observed values, whilst providing vertical

blending of the surface observations with the TAPM upper air predictions. TAPM surface observations

have then been discarded within CALPUFF in place of actual observations.

This approach ensures the appropriate weighting of measured data and addresses the spatial variability

in meteorology and boundary layer development across the domain. Most importantly, this approach

also minimises the production of assimilation boundaries that are a critical limitation of a hybrid

approach involving the incorporation of 3-dimensional prognostic wind fields alongside surface

observations. A summary of this meteorological modelling methodology is provided in Appendix B.

6.3 Model Receptors

The model configuration requires designation of the spatial location of model receptors, which are points

at which model concentration outputs are generated. The model has used both gridded and discrete

receptors as per the following:




Gridded receptors have been incorporated on a 30 x 30 km receptor grid equating to a total of

14,641 gridded receptors across 900 square kilometres. This domain extent is considered

adequate for the capture of peak model predictions.

36 discrete receptors have been allocated to localities across the gridded modelling domain.

Table 6.1 lists the discrete receptors with corresponding coordinates. Figure 6.1 shows the gridded

receptor domain extent and corresponding discrete receptor locations.

Table 6.1: Summary of discrete receptors

Receptor Locality Easting (kmE) Northing (kmN)

01 Tomago 379.326 6367.022

02 Hexham 376.901 6367.022

03 Beresfield 374.324 6369.986

04 Heatherbrae 381.323 6371.779

05 Williamtown 392.366 6369.398

06 Fullerton Cove 391.008 6365.382

07 Fern Bay 387.228 6362.173

08 Kooragang 385.102 6360.795

09 Stockton 386.134 6358.129

10 Carrington 384.556 6357.861

11 Mayfield 382.100 6359.338

12 Hamilton 383.027 6356.672

13 Newcastle 385.895 6356.151

14 Merewether 383.491 6354.499

15 Adamstown 381.231 6354.847

16 New Lambton 379.927 6356.614

17 Jesmond 377.725 6358.787

18 Warabrook 380.227 6360.347

19 Sandgate 379.360 6362.211

20 Maryland 374.470 6360.837

21 Cameron Park 370.071 6357.697

22 Cardiff 374.701 6354.655

23 Glendale 372.825 6355.473

24 Black Hill 370.379 6365.841

25 Thornton 372.524 6372.596

26 Ashtonfield 369.596 6372.990

27 East Maitland 367.807 6375.432

28 Millers Rest 379.546 6374.370

29 Raymond Terrace 382.306 6374.446

30 Maitland 364.839 6377.335

31 Morpeth 371.583 6378.304

32 Osterley 378.130 6378.482

33 Medowie 393.082 6376.761

34 Largs 369.012 6380.994

35 Brandy Hill 377.714 6381.904

36 Eagleton 383.569 6380.321




Figure 6.1: Aerial image showing discrete receptors, gridded receptor domain extent and Proposal boundary




6.4 Emission Parameters

Emission parameters have been compiled based on indicative manufacturer information for the

modelled plant options. Indicative stack locations have been estimated for both engine types, by

overlaying selected generic plant layouts onto the centre of the generator yard within the site layout.

Adjustment to stack design and locations will occur with progression of the design due to detailed

consideration of spatial requirements, and/or adoption of alternative vendor options. The influence of

design or location changes within the generator yard area are unlikely to be material when considered

in the context of source-receptor distances of interest.

Table 6.2 presents a summary of modelled emission parameters adopted for each plant option.

Table 6.2: Summary of modelled emission parameters

Emission

Source

Stacks per Cluster1

Stack Height

(mAGL)

Effective Diameter

(m)

Exit Velocity

(m/s)

NG / DO

Exit Temperature

(K)

NG / DO

Easting

(kmE MGA94)

Northing

(kmN MGA94)

Gas Turbine Option

Gas turbine exhaust 1

N/A

20 2.782 60 / 59 679 / 681 378.984 6368.576


20 2.782 60 / 59 679 / 681 378.985 6368.598


20 2.782 60 / 59 679 / 681 378.987 6368.620


20 2.782 60 / 59 679 / 681 378.988 6368.642

Reciprocating Engine Option

Exhaust stack cluster 1

4 32 3.6 26 / 30 593 / 561 378.949 6368.561


4 32 3.6 26 / 30 593 / 561 378.951 6368.597


5 32 4.025 26 / 30 593 / 561 378.956 6368.659

Note: - 1Reciprocating engine stacks merged to a single effective source per stack cluster and modelled with unity emission rate

assumptions corrected to the stack / cluster values (i.e. 4, 4 and 5 g/s for each respective cluster, thus allowing scaling using

individual stack emission rates.

- ‘NG / DO’: Natural Gas / Distillate Oil values (respectively).

- mAGL: metres above ground level.

- All sources modelled at a base elevation of 15 mAHD (m Australian Height Datum).

6.5 Building Downwash Effects

Aerodynamic wakes are produced as air travels over irregular objects such as building structures.

Within these wakes, there is a high level of turbulence and vertical mixing. In instances where exhaust

plumes interact with these wakes, pollutants can be mixed downward to ground level, producing locally

elevated concentrations, and otherwise reducing the scale of plume rise at distances downwind of the

source. Within dispersion modelling, this effect is referred to as building downwash.

For this study, emission sources were screened for potential interaction with building wakes, where

wakes extend:

by a distance of 5 x L from the leeward edge of a wake producing structure, where L is the lesser

of the structure height or the projected structure width.

to a height of 2.5 times the height of the structure.




Based on generic site layouts, the reciprocating engine plant emission stacks (~30 m high) will be

located within the zone of influence of the generator hall, which is approximately 18 m high at its peak.

Figure 6.2 shows the proximity of these structures, as represented within the building downwash model.

Image sourced from Google Earth Pro.

Figure 6.2: Aerial image showing reciprocating engine building representation (blue) and point sources (red).

6.6 NO2 Conversion

Oxides of nitrogen (NOx) are emitted primarily as nitric oxide (NO) and nitrogen dioxide (NO2). At the

point of emission, NOx will primarily comprise NO which has the ability to be progressively oxidised to

NO2 by atmospheric ozone over periods in the time scale of hours. Given that NO2 is the principal

species in terms of potential human health effects, a method for the estimation of NO2 conversion is

required.

Several approaches are available to estimate the transformation of NO to NO2. The Approved Methods

provide the following techniques, in descending order of conservatism:

Method 1: 100% conversion of NO to NO2.

Method 2: NO to NO2 conversion limited by ambient ozone concentration (OLM)

Method 3: NO to NO2 conversion using empirical relationship.

For this assessment, the Ozone Limiting Method (OLM) (Method 2) has been used to estimate NO2

concentrations, as this allows a conservative representation of conversion, whilst also refining

predictions beyond Method 1.




6.6.1 Ozone Limiting Method

In its default form, the OLM assumes that 10% of the NOx emissions occur as NO2, with the remaining

NO being converted over to NO2 until all of the ambient ozone is consumed. In this respect, the

conversion is limited by the availability of ozone. Equation 6.1 provides the basis for the OLM

calculation applied in this assessment:

𝑁𝑂2𝑡𝑜𝑡𝑎𝑙 = {𝐼𝑆𝑅 × 𝑁𝑂𝑥𝑝} + 𝑚𝑖𝑛𝑖𝑚𝑢𝑚{ [(1 − 𝐼𝑆𝑅) × 𝑁𝑂𝑥𝑝] 𝑜𝑟 [(46 48⁄ ) × 𝑂3𝑏𝑔]} + 𝑁𝑂2𝑏𝑔

Equation 6.1

Where: NO2total = total NO2 concentration inclusive of project and background (µg/m³)

ISR = in-stack NO2:NOx ratio

NOxp = predicted NOx concentration (µg/m³)

O3bg = measured background ozone concentration (µg/m³)

NO2bg = background NO2 concentration (µg/m³)

The ozone concentrations applied were based on hourly monitoring data from the Beresfield AQMS.

Ozone and NO2 data were 93% and 94% complete (respectively) for the year 2009. Data gaps of up

to two hours were filled by linear interpolation which brought the data availability to 98%. Remaining

missing values were substituted with data from Wallsend to provide a complete dataset.

The OLM calculations were performed on an hourly basis for each of the 8,760 hours of the model run.

Hourly NO2 predictions were processed using the OLM in conjunction with corresponding hourly ozone

and NO2 background data.

6.6.2 In-Stack NO2:NOx Ratio

As outlined in Section 5.6.1 the default OLM contains the implicit assumption that 10% of NOx emissions

exist as NO2 at the point of release, i.e. the emissions possess an in-stack NO2:NOx ratio (ISR) of 0.1.

This ISR is generally appropriate for combustion sources, which typically feature ISRs of 0.05 to 0.1.

Manufacturer information for the reciprocating engines indicates that this assumption may not be

appropriate for lean burn gas engines using SCR to control NOx emissions to low levels.

To estimate an ISR suitable for application in this assessment, a review of the US EPA In-Stack Ratio

(ISR) database (US EPA, 2017) was undertaken. This database consists of over 2,000 source tests

across a range of combustion plant types, with detail of a range of emission and test parameters. The

database was filtered for the following properties:

Reciprocating internal combustion engines

4-stroke lean burn combustion

Natural gas fuel

Emission concentration less than 150 mg/Nm³ at 15% O2 (equivalent to 450 mg/Nm³ a 3% O2).

Catalytic emission control with exhaust oxygen content > 8%11.

In addition, a range of anomalous results were removed (such as oxygen content greater than 20% or

discrepancies in NOx addition). This results in a dataset of approximately 391 ISR measurements,

which are presented in Figure 6.3.

11

Oxygen criterion applied to remove any inadvertently included rich burn engines with 3-way catalysts, or samples for which

oxygen was not reported.




Figure 6.3: ISR vs in-stack NOx concentration from filtered US EPA ISR database

These data show that for in-stack NOx values within the manufacturer specification of 150 mg/Nm³,

ISRs are generally below 0.2, averaging 0.11 across the filtered dataset. It is noted that the three

highest values (shown in maroon) are from a single set of three consecutive tests performed on the

same unit within one day, and are suspected to be erroneous (with two of three test results reporting

NO of 0.0 ppm). These values have been retained for clarity.

Across the dataset, over 90% of ISR values below this concentration fall within a 30 mg/Nm³ in-stack

NO2 concentration (i.e. the area bounded by the red dashed line). This indicates that the assumption of

emissions occurring at the manufacturer specification with an ISR of 0.2 would accommodate variability

against the average ISR of 0.11, and also higher ISRs that may be present at lower NOx ranges, under

which case a conservative representation of available NO is implied.

Accordingly, an ISR of 0.2 has been adopted for reciprocating engines operating on natural gas, and

the default of 0.1 applied for other sources. Manufacturer information indicates that an ISR of 0.1 is

appropriate for reciprocating engines operating on distillate fuel.

6.7 Predictions for Sub-hourly Averaging Periods

Where required, hourly averaged model predictions and background data have been converted to sub-

hourly averaging periods using the power law conversion provided in the EPA Victoria draft guideline

Guidance notes for using the regulatory air pollution model AERMOD in Victoria (EPAV, 2013). This

conversion accounts for fluctuations in pollutant levels within the larger averaging period, and is

provided in Equation 5.2.

𝐶𝑛 𝑚𝑖𝑛 = 𝐶1 ℎ𝑜𝑢𝑟 × (60

𝑛)

0.2

Equation 6.2

Where: 𝐶1 ℎ𝑜𝑢𝑟 is the 1 hour average prediction.

𝐶𝑛 𝑚𝑖𝑛 is the n minute average prediction.

0

0.2

0.4

0.6

0.8

1

0 25 50 75 100 125 150

In-S

tack N

O2

:NO

x R

atio

In-Stack NOx Concentration (mg/Nm³, dry, corrected to 15% O2)

US EPA ISR Database (4SLB NG w Catalyst, O2 > 8%)

- - - In stack NO2 Concentration < 30 mg/Nm³ (dry, 15%O2) - i.e. adopted ISR x Manufacturer NOx Limit @ 15% O2




6.8 Background Air Quality Dataset

Background data has been sourced from the DPIE Beresfield AQMS based on the data presented in

Section 4. This station has been selected given proximity to the Proposal, and representativeness

within the surrounding modelling domain in terms of surrounding land uses, separation from the coast

and alignment within the Hunter Valley axis.

Particulate matter data have been reviewed to remove exceptional events, based on information

provided in OEH quarterly air quality monitoring summaries for the Newcastle region (OEH, 2018b;

2018c; 2018d; 2018e; 2018f). This allows the assessment of the Proposal excluding extraneous events.

The quarterly reports were reviewed with identification of a total of seven exceptional events relating to

bushfire and dust storm activity. The remaining peak 24 hour PM2.5 concentration was measured on

15 July 2018, at a time when regional dust events were reported. The retention of this data point is

considered conservative to the assessment.Table 6.3 provides a summary of excluded PM events.

Table 6.3: Summary of excluded PM events

Date/s Description Reference

14-16/02/2018 Interregional dust storm, bushfire activity at Wollemi National Park OEH (2018b)

19-20/03/2018 Long range dust transport OEH (2018c)

15/04/2018

18-19/07/2018 Long range dust transport (Victorian Mallee region) OEH (2018d)

04/08/2018 Long range dust transport

6/11/2018 Long-range dust transport from north-western NSW

21-23/11/2018 Long range dust transport (South Australia), Port Stephens bushfire activity. OEH (2018e)

Table 6.4 presents a summary of adopted 2018 pollutant background concentrations, as based on

data from the DPIE Beresfield AQMS.

Table 6.4: Summary of adopted 2018 pollutant background concentrations.

Pollutant Assessment

Statistic

Adopted Background Concentration (µg/m³)

Impact Assessment Criterion (µg/m³)

NO2 1 hour maximum 82* 246

Annual mean 18.1 62

CO 15 minute maximum 1,980** 100,000

1 hour maximum 1,500 30,000

8 hour maximum 1,125 10,000

SO2 10 minute maximum 286 712

1 hour maximum 200 570

24 hour maximum 20 228

Annual mean 4.7 60

PM2.5 24 hour maximum 17.1 25

Annual mean 8.1 8

PM10 24 hour maximum 40.6 50

Annual mean 20.0 25

Note: *Maximum hourly value shown. Time varying background concentration applied in analysis.

**Value converted using power law.

Adopted PM background concentrations exclude 7 exceptional events when interregional dust storms and/or bushfires were present.




7. EMISSION ESTIMATION

7.1 Overview

Proposal emissions have been estimated using manufacturer data supplemented by US EPA AP-42

emission factors (US EPA, 2006) and fuel specifications. For pollutants where manufacturer information

is not available, emission factors allow the estimation of individual pollutant emissions on the basis of

fuel consumption and generator technology.

AGL is proposing to employ either gas turbine or reciprocating engine generation technology for the

Proposal. ERM has been provided with vendor specifications for a range of gas turbine and

reciprocating engine options being considered for the Proposal. ERM has reviewed the technical data

for these options, and progressed detailed modelling of one gas turbine and one reciprocating engine

option, as representative of the proposed generator technologies and the scale of the Proposal output.

In addition, all emission estimates have been scaled upward by 10% to accommodate minor variability

in plant specifications that may exist within each technology option.

7.2 Estimation Methods

Manufacturer data has been used to estimate NOx and CO emissions (both plant options), as well as

formaldehyde and SO2 emissions for reciprocating engines. Where based on manufacturer data, the

modelled emissions reflect control of emissions either to, or within POEO limits, which the plant will be

designed to meet during routine operation.

It is noted that quantitative POEO limits do not apply during start-up or shutdown of the plant. A

discussion of start-up and shutdown emissions is provided in Appendix C. In addition, it is noted that

whilst POEO limits may not be met during part load operation, (e.g. where an individual generator is

run at low loads typically less than 40% - 50% of maximum output), AGL do not propose to operate

generators at part loads.

Manufacturer emission data for PM is limited to filterable particulate. Accordingly, PM emissions for

reciprocating engines have been estimated based on manufacturer’s data for the filterable fraction, and

supplemented by the US EPA AP-42 PM emission factors, (which represent an average of test data),

for the condensable fraction.

The use of oxidation catalysts on the reciprocating engines is anticipated to provide a reduction of

condensable material through oxidation of soluble organic fraction PM (MECA, 2015), thus resulting in

a reduction against the uncontrolled emissions factors featured in the US EPA (2006). As a

conservative measure, this effect has not been incorporated into the emission estimation.

A control efficiency of 40% has been incorporated into the estimation of acrolein emissions for

reciprocating engines under natural gas operation. This is based on a theoretical estimate from the

manufacturer which includes conservatism to reflect uncertainty in measurement of post-control

concentrations near to method detection limits.




Table 7.1 outlines the basis of pollutant emission estimates by technology and pollutant.




Table 7.1: Summary of emission estimation basis by pollutant and technology type

Parameter Technology Type

Gas Turbine Option Reciprocating Engine Option

NOx as NO2 Manufacturer data

CO

SO2 Fuel specification Manufacturer data

PM Manufacturer data (filterable fraction), US EPA AP-42 Emission Factors (condensable fraction)

Acrolein US EPA AP-42 Emission Factors*

Benzene

Formaldehyde US EPA AP-42 Emission Factors Manufacturer data

PAH US EPA AP-42 Emission Factors

Notes: *Vendor estimate of oxidation catalyst efficiency incorporated into reciprocating engine estimate (natural gas fuel).

7.3 Fuel Consumption

Fuel consumption estimates have been provided by Aurecon and are detailed in Table 7.2. These

values have been converted to units of million British thermal units per second (mmBTU/s) on a higher

heating value (HHV) basis, for use in conjunction with the US EPA AP-42 emission factors, which apply

on this basis.

Table 7.2: Summary of fuel emission estimates

Parameter Gas Turbine Reciprocating Engine

Units / Basis Natural Gas Distillate Natural Gas Distillate

Fuel Consumption 2272 2265 2071 2168 GJ/hr (LHV, Plant)

158 157 44 46 MWth (LHV, Unit*)

HHV / LHV Conversion 1.10 1.07 1.10 1.07 -

Fuel Consumption 174 168 49 50 MWth (HHV, Unit*)

0.174 0.157 0.049 0.050 GJ/s (HHV, Unit*)

0.165 0.149 0.046 0.047 mmBTU/s (HHV)

Notes: - LHV: Lower Heating Value,

- HHV: Higher Heating Value,

- GJ: Gigajoules, MWth – megawatt (thermal).

- *Refers to a single generator unit (i.e. an individual turbine/reciprocating engine).

7.4 US EPA AP-42 Emission Factors

The US EPA AP-42 database has been referenced for the emission factors outlined in Table 7.3.

Table 7.3: Summary of adopted US EPA AP-42 emission factors (lb/MMBTU)

Substance Gas Turbine Option (a) Reciprocating Engine Option

Natural Gas Distillate Natural Gas (b) Distillate (c)

PM2.5, PM10 (condensable) 4.70E x 10-03 7.20E x 10-03 9.91E x 10-03 7.70E x 10-03

Acrolein 6.40 x 10-06 6.4 x 10-06 5.14 x 10-03 7.88 x 10-06

Benzene 1.20 x 10-05 5.50 x 10-05 4.40 x 10-04 7.76 x 10-04

Formaldehyde 7.10 x 10-04 2.80 x 10-04 N/A

PAHs (B[a]P TEQ)(d) 9.00 x 10-07 (e) 5.00 x 10-06 (e) 1.67 x 10-07(d) 1.39 x 10-04(d)

Notes: (a) US EPA (2006) – 3.1 Stationary Gas Turbines

(b) US EPA (2006) – 3.2 Natural Gas-Fired Reciprocating Engines (4 stroke lean burn values adopted) in absence of dual-fuel factors.

(c) US EPA (2006) – 3.4 Large Stationary Diesel and All Dual-Fuel Reciprocating Engines.

(d) PAH value converted to B(a)P equivalent using the Potency Equivalent Factors (PEFs) from the Approved Methods (Table 7.2c)

(e) In absence of speciated PAHs or B(a)P TEQ, emission factor estimated as Total PAHs minus naphthalene.

N/A – Not Applicable: Emission estimate based on manufacturer data.




7.5 Sulfur Dioxide Emission Factors

SO2 emission factors have been prepared based on conservation of mass principles, assuming the

complete oxidation of fuel-bound sulfur into SO2. Fuel-bound sulfur content has been defined by the

following relevant fuel specifications:

AEMO 2017, Gas Quality Guidelines, (Network notification threshold adopted).

AG 2019, Fuel Quality Standards (Automotive Diesel) Determination 2019, (Fuel standard

maximum value adopted).

Table 7.4 and Table 7.5 provide detail of the derivation of fuel-specific SO2 emission factors for natural

gas and distillate operation (respectively).

Table 7.4: Derivation of fuel-specific SO2 emission factor for natural gas operation

Parameter Value Units Source / Basis

Sulfur content 50 mg/m³@15°C, 1 atm. AEMO, 2017

Gas density 0.755 kg/m³ AGL, 1995

Sulfur content 66.2 mg/kg Calculated

Energy density 51.4 MJ/kg AGL, 1995

Sulfur content 1.29 mg/MJ Calculated

Sulfur dioxide emissions 2.57 g/GJ

AGL 1995, Natural Gas Technical Data Handbook, AGL 1995.

Table 7.5: Derivation of fuel-specific SO2 emission factor for distillate operation

Parameter Value Units Source / Basis

Energy density 45.6 MJ/kg (HHV) ABARE, 2008

Sulfur content

10.0 mg/kg AG, 2019

0.22 mg/MJ (HHV) Calculated

Sulfur dioxide emissions 0.44 g/GJ (HHV)

7.6 Summary of Modelled Emission Rates

Table 7.6 presents a summary of modelled emission rates by technology, fuel type and pollutant.

Emission rates have been applied on a continuous basis for the 2018 meteorological dataset.

Table 7.6: Summary of modelled emission rates

Substance

Modelled Emission Rate (g/s - stack)


Natural Gas Distillate Natural Gas Distillate

NOx 8.3 14.0 6.0 6.5

CO 15.7 36.3 1.7 1.8

SO2 0.5 0.1 0.49 0.48

PM 1.046 2.626 0.511 0.8998

Acrolein 0.0005 0.0005 0.071 0.0002

Benzene 0.001 0.004 0.010 0.018

Formaldehyde 0.0583 0.0208 0.602 0.652




PAHs (B[a]P TEQ)* 0.00007 0.00037 0.000001 0.000015

Ammonia N/A 0.457 0.476

Note: - N/A – Not applicable as ammonia/urea injection within SCR-based NOx emission controls is limited to reciprocating engine plant.

- Modelled gas turbine plant comprises 4 stacks. Modelled reciprocating engine plant comprises 13 stacks.

7.7 Annualised Emission Estimates

Table 7.7 and Table 7.8 present annualised emission estimates for the Proposal on the basis of 14%

and 100% operation, (respectively). These emission estimates are based on the modelled emission

rates shown in Table 7.6.

Table 7.7: Annualised emission estimates – 100% Operation

Substance

Annualised Emission Estimate (t/annum) – 14% Operation



NOx 146 247 346 374

CO 277 641 98 103

SO2 8.8 1.8 28 28

PM 18 46 29 52

Acrolein 0.01 0.01 4.1 0.01

Benzene 0.02 0.07 0.6 1.0

Formaldehyde 1.0 0.4 35 37

PAHs (B[a]P TEQ)* 0.001 0.007 0.0001 0.001

Ammonia N/A 26 27

Note: N/A – Not applicable as ammonia/urea injection within SCR-based NOx emission controls is limited to reciprocating engine plant.

Table 7.8: Annualised emission estimates – 100% Operation

Substance

Annualised Emission Estimate (t/annum) – 100% Operation



NOx 1,041 1,762 2,469 2,672

CO 1,980 4,579 697 738

SO2 63 13 201 197

PM 132 331 209 369

Acrolein 0.1 0.1 29 0.1

Benzene 0.1 0.5 4.1 7.4

Formaldehyde 7 3 247 267

PAHs (B[a]P TEQ)* 0.009 0.047 0.0004 0.006

Ammonia N/A 187 195

Note: N/A – Not applicable as ammonia/urea injection within SCR-based NOx emission controls is limited to reciprocating engine plant.




8. RESULTS

This section provides a summary of the results of the dispersion modelling, with comparison against

NSW EPA air quality impact assessment criteria. Assessment results have been provided in both

tabulated form, and as contour isopleths for select modelling scenarios.

The dispersion modelling has considered the following operational scenarios:

1. Gas turbine option – Natural Gas Fuel

2. Gas turbine option – Distillate Fuel

3. Reciprocating Engine option – Natural Gas Fuel

4. Reciprocating Engine option – Distillate Fuel.

Modelling predictions for these scenarios have been screened for all pollutants assessed, on the basis

of maximum values at discrete and gridded receptors within an assessment summary.

Based on the scale of these predictions, contour isopleths and receptor lists of modelling results have

been prepared across these four scenarios for the following pollutant and averaging period

combinations:

NO2:

- maximum 1 hour average

- annual average

PM2.5:

- maximum 24 hour average

- annual average

Acrolein: 99.9th percentile 1 hour average

Formaldehyde: 99.9th percentile 1 hour average.

All results have presented in the mass-based units of micrograms per cubic metre (μg/m³). Contour

isopleths have been prepared using geometric spacing (e.g. 1, 2, 5, 10, 20, 50 µg/m³).

Incremental predictions represent the influence of emissions from the Proposal in absence of

background sources. Cumulative predictions represent the combined influence of the Proposal and

existing background concentrations.

8.1 Assessment Summary

Table 8.1 and Table 8.2 present a summary of maximum gridded and discrete receptor predictions for

gas turbine and reciprocating engine options (respectively), for all pollutants and scenarios. All

predictions are compliant with assessment criteria with the exception of the VOC acrolein (reciprocating

engine option under natural gas operation; shown in bold) and annual average PM2.5, due to elevated

background levels.

To further investigate the potential for acrolein emissions to produce adverse air quality impacts, the

following analysis was undertaken:

Additional assessment was conducted incorporating a range of international health risk

screening criteria and is documented in Appendix D. All predictions are estimated to be within

respective screening criteria.

A review of meteorological conditions conducive to acrolein exceedances was undertaken, and is documented in Appendix E. This review identified that predicted exceedances were associated with high wind, moderate temperature daytime conditions and did not align with times at which the plant is more likely to operate. In this capacity, the assumption of continuous operation, as adopted within this assessment, is considered to provide a conservative assessment of peak acrolein predictions.




Table 8.1: Assessment Summary – Gas Turbine Option

Substance Averaging

Period

Prediction at Maximum Impacted Receptor (µg/m³) Maximum Incremental

Prediction

(µg/m³)

Background*

(µg/m³)

Maximum Cumulative Prediction

(µg/m³)

Criterion

(µg/m³)

Natural Gas Fuel Distillate Fuel

Discrete Gridded Discrete Gridded

NO2 1 hour maximum 58 61 63 84 84 82* 100 246

Annual mean 0.2 0.3 0.4 0.4 0.4 18.1 18.5 62

CO 15 minute maximum 139 535 292 1,198 1,198 1,980 3,178 100,000

1 hour maximum 174 669 365 1,498 1,498 1,500 2,998 30,000

8 hour maximum 63 133 139 295 295 1,125 1,420 10,000

SO2 10 minute maximum 8 30 1 4 30 286 316 712

1 hour maximum 5 21 1 3 21 200 221 570

24 hour maximum 0.8 1.5 0.1 0.2 1.5 20 21 228

Annual mean 0.01 0.02 0.002 0.003 0.02 4.7 4.7 60

PM2.5 24 hour maximum 1.6 3.1 3.9 7.6 7.6 17.1 24.7 25

Annual mean 0.03 0.04 0.08 0.10 0.10 8.1* 8.2* 8.0

PM10 24 hour maximum 1.6 3.1 3.9 7.6 7.6 40.6 48.0 50

Annual mean 0.03 0.04 0.08 0.10 0.10 20.0 20.1 25

Acrolein 1 hour 99.9th percentile 0.002 0.003 0.002 0.002 0.003 - 0.003 0.42

Benzene 1 hour 99.9th percentile 0.002 0.005 0.01 0.02 0.02 - 0.02 29

Formaldehyde 1 hour 99.9th percentile 0.2 0.3 0.1 0.1 0.3 - 0.3 20

PAHs 1 hour 99.9th percentile 0.0003 0.0004 0.001 0.002 0.002 - 0.002 0.4

Note: Totals may appear non-additive due to rounding of reported intermediate values.

*Time varying background concentration applied in contemporaneous analysis. Maximum 1 hour background value shown.




Table 8.2: Assessment Summary – Reciprocating Engine Option

Substance Averaging

Period

Prediction at Maximum Impacted Receptor (µg/m³) Maximum Incremental

Prediction

(µg/m³)

Background*

(µg/m³)

Maximum Cumulative Prediction

(µg/m³)

Criterion

(µg/m³)

Natural Gas Fuel Distillate Fuel

Discrete Gridded Discrete Gridded

NO2 1 hour maximum 76 113 71 95 113 821 123 246

Annual mean 0.6 1.0 0.6 1.0 1.0 18.0 19.1 62

CO 15 minute maximum 21 98 26 104 104 1,980 2,084 100,000

1 hour maximum 26 123 32 130 130 1,500 1,630 30,000

8 hour maximum 8 30 11 29 30 1,125 1,155 10,000

SO2 10 minute maximum 11 52 12 50 52 286 338 712

1 hour maximum 8 36 9 35 36 200 236 570

24 hour maximum 1.0 4.3 1.3 3.4 4.3 20 24 228

Annual mean 0.05 0.10 0.05 0.08 0.10 4.7 5 60

PM2.5 24 hour maximum 1.1 4.5 2.5 6.4 6.4 17.1 23 25

Annual mean 0.05 0.10 0.09 0.16 0.16 8.1* 8.3* 8

PM10 24 hour maximum 1.1 4.5 2.5 6.4 6.4 40.6 47.0 50

Annual mean 0.05 0.10 0.09 0.16 0.16 20.0 20 25

Acrolein 1 hour 99.9th percentile 0.68* 1.25* 0.001 0.003 1.25* - 1.25* 0.42

Benzene 1 hour 99.9th percentile 0.1 0.2 0.1 0.3 0.3 - 0.3 29

Formaldehyde 1 hour 99.9th percentile 6 11 5 9 11 - 11 20

PAHs 1 hour 99.9th percentile 0.00001 0.00001 0.0001 0.0002 0.0002 - 0.0002 0.4

Ammonia 1 hour 99.9th percentile 4 9 4 7 9 - 9 330

Notes: Exceedances shown in bold font and marked with an asterisk.

Totals may appear non-additive due to rounding of reported intermediate values.

*Time varying background concentration applied in contemporaneous analysis. Maximum 1 hour background shown.




8.2 NO2

Table 8.3 and Table 8.4 present a summary of maximum 1 hour and annual average NO2 predictions

(respectively). Figure 8.1 through Table 8.4 present contour isopleths for the corresponding incremental

predictions. All NO2 predictions are within relevant impact assessment criteria.

Table 8.3: Summary of model predictions - Maximum 1 hour average NO2 (µg/m³)

Receptor Locality



Incremental

Cumulative

Incremental

Cumulative

Incremental

Cumulative

Incremental

Cumulative

01 Tomago 24 82 37 82 46 82 52 82

02 Hexham 58 82 63 82 76 82 71 82

03 Beresfield 16 82 23 82 28 82 32 82

04 Heatherbrae 24 82 27 82 39 82 32 82

05 Williamtown 5 82 9 82 17 82 19 82

06 Fullerton Cove 7 82 8 82 14 82 16 82

07 Fern Bay 14 82 26 82 37 82 38 82

08 Kooragang 10 82 19 82 27 82 22 82

09 Stockton 11 82 12 82 18 82 18 82

10 Carrington 14 82 16 82 21 82 18 82

11 Mayfield 9 82 16 82 15 82 17 82

12 Hamilton 11 82 15 82 12 82 16 82

13 Newcastle 12 82 14 82 19 82 16 82

14 Merewether 9 82 15 82 12 82 17 82

15 Adamstown 8 82 11 82 17 82 15 82

16 New Lambton 7 82 11 82 16 82 20 82

17 Jesmond 12 82 23 82 15 82 15 82

18 Warabrook 15 82 21 82 43 82 47 82

19 Sandgate 8 82 14 82 20 82 27 82

20 Maryland 28 82 41 82 13 82 28 82

21 Cameron Park 11 82 21 82 25 82 40 82

22 Cardiff 8 82 14 82 12 82 14 82

23 Glendale 15 82 25 82 13 82 14 82

24 Black Hill 9 82 15 82 35 82 36 82

25 Thornton 31 82 59 82 30 82 34 82

26 Ashtonfield 20 82 32 82 70 84 56 82

27 East Maitland 17 82 30 82 38 82 43 82

28 Millers Rest 16 82 28 82 31 82 38 82

29 Raymond Terrace 20 82 22 82 33 82 30 82

30 Maitland 9 82 16 82 24 82 29 82

31 Morpeth 5 82 9 82 30 82 27 82

32 Osterley 8 82 14 82 25 82 25 82

33 Medowie 11 82 14 82 18 82 19 82

34 Largs 8 82 11 82 15 82 18 82

35 Brandy Hill 9 82 16 82 29 82 33 82

36 Eagleton 12 82 14 82 17 82 25 82

Maximum by Receptor Type

Discrete - 58 82 63 82 76 84 71 82

Gridded - 61 82 84 100 113 123 95 119

Criterion - - 246 - 246 - 246 - 246




Table 8.4: Summary of model predictions - Annual average NO2 (µg/m³)

Receptor Locality



Incremental

Cumulative

Incremental

Cumulative

Incremental

Cumulative

Incremental

Cumulative

01 Tomago 0.2 18.2 0.3 18.3 0.5 18.6 0.6 18.6

02 Hexham 0.2 18.3 0.4 18.4 0.6 18.6 0.6 18.7

03 Beresfield 0.1 18.1 0.2 18.2 0.3 18.3 0.3 18.4

04 Heatherbrae 0.1 18.1 0.1 18.2 0.2 18.2 0.2 18.2

05 Williamtown 0.0 18.1 0.1 18.1 0.1 18.2 0.1 18.2

06 Fullerton Cove 0.1 18.1 0.1 18.2 0.2 18.3 0.2 18.3

07 Fern Bay 0.1 18.1 0.2 18.2 0.2 18.3 0.2 18.3

08 Kooragang 0.1 18.1 0.1 18.2 0.2 18.3 0.2 18.3

09 Stockton 0.1 18.1 0.1 18.2 0.2 18.2 0.2 18.2

10 Carrington 0.1 18.1 0.1 18.1 0.2 18.2 0.2 18.2

11 Mayfield 0.1 18.1 0.1 18.1 0.2 18.2 0.2 18.2

12 Hamilton 0.1 18.1 0.1 18.1 0.1 18.2 0.2 18.2

13 Newcastle 0.1 18.1 0.1 18.1 0.1 18.2 0.1 18.2

14 Merewether 0.0 18.1 0.1 18.1 0.1 18.1 0.1 18.2

15 Adamstown 0.0 18.1 0.1 18.1 0.1 18.1 0.1 18.2

16 New Lambton 0.1 18.1 0.1 18.1 0.1 18.2 0.1 18.2

17 Jesmond 0.1 18.1 0.1 18.2 0.2 18.2 0.2 18.2

18 Warabrook 0.1 18.1 0.1 18.2 0.2 18.2 0.2 18.2

19 Sandgate 0.1 18.1 0.1 18.2 0.2 18.2 0.2 18.3

20 Maryland 0.1 18.1 0.2 18.2 0.2 18.3 0.3 18.3

21 Cameron Park 0.1 18.1 0.1 18.1 0.2 18.2 0.2 18.2

22 Cardiff 0.1 18.1 0.1 18.2 0.2 18.2 0.2 18.2

23 Glendale 0.1 18.1 0.1 18.1 0.2 18.2 0.2 18.2

24 Black Hill 0.1 18.1 0.1 18.2 0.2 18.3 0.3 18.3

25 Thornton 0.1 18.1 0.2 18.2 0.3 18.3 0.3 18.3

26 Ashtonfield 0.1 18.1 0.1 18.2 0.2 18.2 0.2 18.3

27 East Maitland 0.1 18.1 0.1 18.2 0.2 18.2 0.2 18.3

28 Millers Rest 0.1 18.1 0.1 18.2 0.2 18.3 0.3 18.3

29 Raymond Terrace 0.1 18.1 0.1 18.2 0.2 18.2 0.2 18.3

30 Maitland 0.1 18.1 0.1 18.1 0.1 18.2 0.2 18.2

31 Morpeth 0.1 18.1 0.1 18.1 0.1 18.2 0.2 18.2

32 Osterley 0.1 18.1 0.1 18.1 0.2 18.2 0.2 18.2

33 Medowie 0.1 18.1 0.1 18.1 0.1 18.2 0.1 18.2

34 Largs 0.0 18.1 0.1 18.1 0.1 18.1 0.1 18.2

35 Brandy Hill 0.0 18.1 0.1 18.1 0.1 18.1 0.1 18.2

36 Eagleton 0.1 18.1 0.1 18.1 0.1 18.2 0.1 18.2


Discrete - 0.2 18.3 0.4 18.4 0.6 18.6 0.6 18.7

Gridded - 0.3 18.3 0.4 19 1.0 19.1 1.0 19.1

Criterion - - 62 - 62 - 62 - 62

Notes: - Predictions based on continuous operation. Annual average predictions at estimated (14%) operating duty would be approx. 7 times

lower than those presented.




Figure 8.1: Maximum incremental 1 hour average NO2 predictions – Gas Turbine Option (µg/m³)


Notes: - Base image sourced from Google Earth Pro.

- Contour Levels: 10, 20, 50, 100 µg/m³.




Figure 8.2: Maximum incremental 1 hour average NO2 predictions – Reciprocating Engine Option (µg/m³)







Figure 8.3: Annual average incremental NO2 predictions – Gas Turbine Option (µg/m³)



- Contour Levels: 0.1, 0.2, 0.5, 1.0 µg/m³.

- Predictions based on continuous operation. Annual average predictions at estimated (14%) operating duty would be approx. 7 times lower than those presented.




Figure 8.4: Annual average incremental NO2 predictions – Reciprocating Engine Option (µg/m³)








8.3 PM2.5

Table 8.5 and Table 8.6 present a summary of maximum 24 hour and annual average PM2.5 predictions

(respectively). Figure 8.5 through Figure 8.8 present corresponding contour isopleths for incremental

PM2.5 predictions.

Table 8.5: Summary of model predictions – Maximum 24 hour average PM2.5

Receptor Locality



Incremental

Cumulative

Incremental

Cumulative

Incremental

Cumulative

Incremental

Cumulative

01 Tomago 0.4 17.8 1.2 18.6 0.8 18.2 1.3 18.7

02 Hexham 1.6 19.0 3.9 21.3 1.1 18.5 2.5 19.9

03 Beresfield 0.3 17.7 0.7 18.1 0.6 18.0 1.0 18.4

04 Heatherbrae 0.5 17.9 1.4 18.8 0.9 18.3 1.6 19.0

05 Williamtown 0.2 17.6 0.4 17.8 0.4 17.8 0.7 18.1

06 Fullerton Cove 0.2 17.6 0.5 17.9 0.5 17.9 0.8 18.2

07 Fern Bay 0.3 17.7 0.7 18.1 0.6 18.0 1.0 18.4

08 Kooragang 0.3 17.7 0.8 18.2 0.5 17.9 0.8 18.2

09 Stockton 0.2 17.6 0.6 18.0 0.3 17.7 0.5 17.9

10 Carrington 0.2 17.6 0.6 18.0 0.3 17.7 0.6 18.0

11 Mayfield 0.1 17.5 0.4 17.8 0.2 17.6 0.3 17.7

12 Hamilton 0.1 17.5 0.4 17.8 0.2 17.6 0.3 17.7

13 Newcastle 0.2 17.6 0.4 17.8 0.3 17.7 0.4 17.8

14 Merewether 0.1 17.5 0.4 17.8 0.2 17.6 0.3 17.7

15 Adamstown 0.1 17.5 0.3 17.7 0.2 17.6 0.3 17.7

16 New Lambton 0.1 17.5 0.2 17.6 0.2 17.6 0.4 17.8

17 Jesmond 0.2 17.6 0.6 18.0 0.2 17.6 0.4 17.8

18 Warabrook 0.1 17.5 0.3 17.7 0.3 17.7 0.5 17.9

19 Sandgate 0.1 17.5 0.4 17.8 0.2 17.6 0.4 17.8

20 Maryland 0.4 17.8 0.8 18.2 0.2 17.6 0.5 17.9

21 Cameron Park 0.2 17.6 0.5 17.9 0.2 17.6 0.4 17.8

22 Cardiff 0.1 17.5 0.3 17.7 0.2 17.6 0.3 17.7

23 Glendale 0.1 17.5 0.3 17.7 0.1 17.5 0.2 17.6

24 Black Hill 0.3 17.7 0.7 18.1 0.3 17.7 0.5 17.9

25 Thornton 0.4 17.8 1.0 18.4 0.5 17.9 0.8 18.2

26 Ashtonfield 0.3 17.7 0.7 18.1 0.3 17.7 0.5 17.9

27 East Maitland 0.3 17.7 0.7 18.1 0.6 18.0 1.0 18.4

28 Millers Rest 0.2 17.6 0.5 17.9 0.3 17.7 0.5 17.9

29 Raymond Terrace 0.5 17.9 1.1 18.5 0.4 17.8 0.7 18.1

30 Maitland 0.2 17.6 0.5 17.9 0.4 17.8 0.7 18.1

31 Morpeth 0.2 17.6 0.4 17.8 0.2 17.6 0.3 17.7

32 Osterley 0.2 17.6 0.4 17.8 0.3 17.7 0.5 17.9

33 Medowie 0.2 17.6 0.6 18.0 0.3 17.7 0.5 17.9

34 Largs 0.1 17.5 0.3 17.7 0.2 17.6 0.3 17.7

35 Brandy Hill 0.1 17.5 0.4 17.8 0.3 17.7 0.5 17.9

36 Eagleton 0.4 17.8 1.1 18.5 0.2 17.6 0.3 17.7


Discrete - 1.6 19.0 3.9 21.3 1.1 18.5 2.5 19.9

Gridded - 3.1 20.5 7.6 25.0 4.5 21.9 6.4 23.8

Criterion - - 25 - 25 - 25 - 25




Table 8.6: Summary of model predictions – Annual average PM2.5

Receptor Locality



Inc. Cum. Inc. Cum. Inc. Cum. Inc. Cum.

01 Tomago 0.02 8.1* 0.06 8.2* 0.05 8.1* 0.08 8.2*

02 Hexham 0.03 8.1* 0.08 8.2* 0.05 8.2* 0.09 8.2*

03 Beresfield 0.01 8.1* 0.03 8.1* 0.03 8.1* 0.04 8.1*

04 Heatherbrae 0.01 8.1* 0.02 8.1* 0.02 8.1* 0.03 8.1*

05 Williamtown 0.01 8.1* 0.01 8.1* 0.01 8.1* 0.02 8.1*

06 Fullerton Cove 0.01 8.1* 0.03 8.1* 0.02 8.1* 0.03 8.1*

07 Fern Bay 0.01 8.1* 0.04 8.1* 0.02 8.1* 0.04 8.1*

08 Kooragang 0.01 8.1* 0.03 8.1* 0.02 8.1* 0.04 8.1*

09 Stockton 0.01 8.1* 0.03 8.1* 0.02 8.1* 0.03 8.1*

10 Carrington 0.01 8.1* 0.02 8.1* 0.02 8.1* 0.03 8.1*

11 Mayfield 0.01 8.1* 0.02 8.1* 0.02 8.1* 0.03 8.1*

12 Hamilton 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*

13 Newcastle 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*

14 Merewether 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*

15 Adamstown 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*

16 New Lambton 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*

17 Jesmond 0.01 8.1* 0.03 8.1* 0.02 8.1* 0.03 8.1*

18 Warabrook 0.01 8.1* 0.03 8.1* 0.02 8.1* 0.03 8.1*

19 Sandgate 0.01 8.1* 0.03 8.1* 0.02 8.1* 0.03 8.1*

20 Maryland 0.01 8.1* 0.03 8.1* 0.02 8.1* 0.03 8.1*

21 Cameron Park 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*

22 Cardiff 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*

23 Glendale 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*

24 Black Hill 0.01 8.1* 0.03 8.1* 0.02 8.1* 0.03 8.1*

25 Thornton 0.02 8.1* 0.04 8.1* 0.02 8.1* 0.04 8.1*

26 Ashtonfield 0.01 8.1* 0.03 8.1* 0.02 8.1* 0.03 8.1*

27 East Maitland 0.01 8.1* 0.03 8.1* 0.02 8.1* 0.03 8.1*

28 Millers Rest 0.01 8.1* 0.03 8.1* 0.02 8.1* 0.03 8.1*

29 Raymond Terrace 0.02 8.1* 0.04 8.1* 0.02 8.1* 0.04 8.1*

30 Maitland 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*

31 Morpeth 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*

32 Osterley 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*

33 Medowie 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*

34 Largs 0.01 8.1* 0.01 8.1* 0.01 8.1* 0.02 8.1*

35 Brandy Hill 0.01 8.1* 0.01 8.1* 0.01 8.1* 0.01 8.1*

36 Eagleton 0.01 8.1* 0.02 8.1* 0.01 8.1* 0.02 8.1*


Discrete - 0.03 8.1* 0.08 8.2* 0.05 8.2* 0.09 8.2*

Gridded - 0.04 8.1* 0.10 8.2* 0.10 8.2* 0.16 8.3*

Criterion - - 8.0 - 8.0 - 8.0 - 8.0

Notes: - Exceedances shown in bold font and marked with an asterisk. Background exceedances result in exceedances for all predictions.

- PM emissions assumed to occur as PM2.5, hence incremental PM2.5 results are equal to incremental PM10 results.

- Predictions based on continuous operation. Annual average predictions at estimated (14%) operating duty would be approx. 7 times

lower than those presented.




Figure 8.5: Maximum incremental 24 hour average PM2.5* predictions – Gas Turbine Option (µg/m³)


.


- Contour Levels: 1, 2, 5 µg/m³.

- Noting that all PM emissions have been assumed to occur as PM2.5, these contour isopleths are also representative of incremental PM10 predictions.




Figure 8.6: Maximum incremental 24 hour average PM2.5 predictions – Reciprocating Engine Option (µg/m³)



- Contour Levels: 1, 2, 5 µg/m³.

- All PM emissions have been assumed to occur as PM2.5, hence these contour isopleths also represent of incremental PM10 predictions.




Figure 8.7: Incremental annual average PM2.5 predictions – Gas Turbine Option (µg/m³)




- All PM emissions have been assumed to occur as PM2.5, hence these contour isopleths also represent of incremental PM10 predictions.





Figure 8.8: Incremental annual average PM2.5 predictions – Reciprocating Engine Option (µg/m³)








8.4 Acrolein and Formaldehyde

Table 8.7 presents a summary of 99.9th percentile 1 hour average acrolein and formaldehyde predictions. Figure 8.9 and Figure 8.10 present contour isopleths of these predictions. Appendix D and Appendix E provide additional assessment and review of potential acrolein impacts.

Table 8.7: Summary of model predictions – 99.9th percentile 1 hour average acrolein and formaldehyde

Receptor Locality

Acrolein Formaldehyde



Natural Gas

Distillate Natural

Gas Distillate

Natural Gas

Distillate Natural

Gas Distillate

01 Tomago 0.001 0.001 0.48* 0.001 0.1 0.0 4.1 4.3

02 Hexham 0.002 0.002 0.68* 0.001 0.2 0.1 5.8 5.2

03 Beresfield 0.001 0.000 0.28 0.001 0.1 0.0 2.4 2.4

04 Heatherbrae 0.001 0.000 0.24 0.001 0.1 0.0 2.0 2.1

05 Williamtown 0.000 0.000 0.13 0.000 0.0 0.0 1.1 1.1

06 Fullerton Cove 0.000 0.000 0.13 0.000 0.0 0.0 1.1 1.1

07 Fern Bay 0.001 0.001 0.25 0.001 0.1 0.0 2.1 2.2

08 Kooragang 0.001 0.000 0.22 0.001 0.1 0.0 1.9 2.0

09 Stockton 0.000 0.000 0.16 0.000 0.0 0.0 1.4 1.6

10 Carrington 0.000 0.000 0.13 0.000 0.0 0.0 1.1 1.1

11 Mayfield 0.000 0.000 0.14 0.000 0.0 0.0 1.2 1.3

12 Hamilton 0.000 0.000 0.11 0.000 0.0 0.0 0.9 1.1

13 Newcastle 0.000 0.000 0.13 0.000 0.0 0.0 1.1 1.1

14 Merewether 0.000 0.000 0.11 0.000 0.0 0.0 0.9 1.0

15 Adamstown 0.000 0.000 0.14 0.000 0.0 0.0 1.2 1.3

16 New Lambton 0.000 0.000 0.15 0.000 0.0 0.0 1.3 1.3

17 Jesmond 0.000 0.000 0.12 0.000 0.0 0.0 1.0 1.1

18 Warabrook 0.000 0.000 0.20 0.000 0.1 0.0 1.7 1.5

19 Sandgate 0.000 0.000 0.15 0.000 0.0 0.0 1.3 1.5

20 Maryland 0.000 0.000 0.11 0.000 0.0 0.0 1.0 1.0

21 Cameron Park 0.000 0.000 0.09 0.000 0.0 0.0 0.7 0.9

22 Cardiff 0.000 0.000 0.09 0.000 0.0 0.0 0.8 0.8

23 Glendale 0.000 0.000 0.09 0.000 0.0 0.0 0.7 0.9

24 Black Hill 0.000 0.000 0.14 0.000 0.0 0.0 1.2 1.3

25 Thornton 0.001 0.000 0.20 0.001 0.1 0.0 1.7 2.0

26 Ashtonfield 0.001 0.001 0.16 0.000 0.1 0.0 1.3 1.7

27 East Maitland 0.000 0.000 0.22 0.001 0.1 0.0 1.9 1.9

28 Millers Rest 0.000 0.000 0.15 0.000 0.0 0.0 1.3 1.4

29 Raymond Terrace 0.001 0.001 0.41 0.001 0.1 0.0 3.4 3.0

30 Maitland 0.000 0.000 0.19 0.000 0.0 0.0 1.6 1.5

31 Morpeth 0.000 0.000 0.10 0.000 0.0 0.0 0.8 0.8

32 Osterley 0.000 0.000 0.13 0.000 0.0 0.0 1.1 0.9

33 Medowie 0.000 0.000 0.17 0.000 0.1 0.0 1.5 1.5

34 Largs 0.000 0.000 0.07 0.000 0.0 0.0 0.6 0.7

35 Brandy Hill 0.000 0.000 0.09 0.000 0.0 0.0 0.7 0.7

36 Eagleton 0.001 0.000 0.13 0.000 0.1 0.0 1.1 0.9


Discrete - 0.002 0.002 0.68* 0.001 0.2 0.1 5.8 5.2

Gridded - 0.003 0.002 1.25* 0.003 0.3 0.1 10.6 9.3

Criterion - 0.42 20

Note: Exceedances shown in bold font and marked with an asterisk.




Figure 8.9: 99.9th percentile incremental 1 hour average acrolein predictions – Gas Turbine Option (µg/m³)



- Contour Levels: 0.001, 0.002, 0.005 µg/m³.




Figure 8.10: 99.9th percentile incremental 1 hour average acrolein predictions – Reciprocating Engine Option (µg/m³)



- Contour Levels: 0.001, 0.002, 0.005, 0.01, 0.02, 0.05, 0.1, 0.2, 0.5, 1 µg/m³.




Figure 8.11: 99.9th percentile incremental 1 hour average formaldehyde predictions – Gas Turbine Option (µg/m³)



- Contour Levels: 0.05, 0.1, 0.2 µg/m³.




Figure 8.12: 99.9th percentile incremental 1 hour average formaldehyde predictions – Reciprocating Engine Option (µg/m³)







9. OZONE AND INTERREGIONAL TRANSPORT

Emissions from combustion sources can interact in the atmosphere to generate photochemical smog

and ozone. The process involves a range of chemical reactions which occur on time scales ranging

from several hours to several days, producing ozone, nitric oxide, peroxyacetyl nitrate and aldehydes.

This phenomenon is typically most prevalent during extended periods of light winds accompanied by

higher temperature and strong sunlight, in places where anthropogenic emissions of precursor

pollutants are significant on a regional basis, and where terrain features and/or meteorological patterns

promote the trapping or recirculation of pollutants.

This section provides a screening level assessment of potential ozone impacts, with consideration of

the potential for interregional transport of air emissions from the Proposal. The approach to undertaking

this assessment has incorporated the outcomes of discussions with NSW EPA.

9.1 Ozone Screening Assessment

This ozone screening assessment has been prepared using the NSW Tiered Procedure for Estimating

Ground-Level Ozone Impacts from Stationary Sources (Environ, 2011), implemented by the NSW EPA

in 2015 in conjunction with an existing investigation of photochemical impacts for the Site.

An overview of the tiered ozone procedure framework is shown in Figure 9.1. The Proposal requires

consideration of ozone impacts as it satisfies all the following:

It is an activity listed under Schedule 1 of the POEO Act.

It will release ozone precursors as part of the Proposal’s proposed operations.

It is located within the NSW Greater Metropolitan Region (GMR) as defined within the Clean Air Regulation.

An assessment of ozone impact that follows the steps outlined in the framework (Figure 9.1) is

discussed in the sections below.




Figure 9.1: Ozone impact assessment procedure and current assessment pathway (Environ, 2011)

9.1.1 Classification as ozone attainment or ozone non-attainment area

The first step in the process is to determine if the project is located within an “attainment area” or “non-

attainment area”. Ozone attainment and non-attainment areas are defined based on comparison with

the ambient air quality (NEPM) goals (NEPC, 1998). The five year average maximum 1 hour and 4

hour ozone concentrations for the region are compared against a screening “acceptance limit” which is

expressed as 82% of the NEPM goal (NEPC, 2007).

The maximum 1 hour and 4 hour ozone concentrations have been summarised for the Newcastle region

for the period 2014-2018, as presented in Table 9.1.

It is noted that whilst available, the 2019 dataset has not yet been fully validated, and has therefore

been excluded from this analysis.




Table 9.1: 1 hour and 4 hour maximum ozone concentrations in the Newcastle region (ppm)

Location Annual maximum

5-year average maximum 2014 2015 2016 2017 2018

1 hour average

Beresfield 0.090 0.077 0.085 0.083 0.107 0.088

Newcastle 0.065 0.074 0.077 0.086 0.067 0.074

Wallsend 0.087 0.071 0.086 0.106 0.086 0.087

4 hour average

Beresfield 0.077 0.067 0.068 0.079 0.089 0.076

Newcastle 0.056 0.066 0.069 0.073 0.058 0.064

Wallsend 0.065 0.062 0.078 0.097 0.068 0.074

Note: The highest five year average maximum value recorded across monitoring stations in the region is shown in bold font.

The classification scheme used to determine if a region is an attainment or non-attainment area is

provided in Table 9.2, as based on the relevant five yearly average annual maximum ozone

concentrations shown in bold font in Table 9.1.

Table 9.2: Classification of ozone attainment or non-attainment area

Regional Airshed Status Five Yearly Average Annual Maximum Ozone Concentration Thresholds

1 hour average 4 hour average

Attainment < 0.082 < 0.0656

Non-attainment >= 0.82 and < 0.130 >= 0.0656 and < 0.110

Non-attainment - Serious >= 0.130 and < 0.150 >= 0.110 and < 0.120

Non-attainment - Severe >= 0.150 and < 0.230 >= 0.120 and < 0.190

Non-attainment - Extreme >= 0.230 >= 0.190

Note: Attainment status highlighted in yellow.

Based on the most recent five years of data, the Newcastle region is classified as an ozone non-

attainment area, hence the right-hand side of the ozone assessment pathway applies (Figure 9.1).

9.1.2 Emissions Threshold

The second step evaluates the total annual NOx and VOC emissions from the project against the

emission thresholds shown in Table 9.3. If the emissions from scheduled activities exceed either of the

thresholds, an ozone impact assessment is required to determine the significance of the incremental

ozone contributions. It is noted that different thresholds apply for ‘serious’, ‘severe’ and ‘extreme’ non-

attainment areas.

Table 9.3: Emission thresholds for Schedule 1 activities located in non-attainment areas

Activity Source type NOx / VOC Emission Threshold (tonnes/year)

Any scheduled activity listed in Schedule 1 of the POEO Act (2007)

New >90

Modified >35

The annual NOx emissions for the Proposal have been estimated for both 14% and 100% (continuous)

operating duty as shown in Table 9.4.




Table 9.4: Estimate of annual NOx emissions at 14% and 100% operating duty

Plant Option Fuel Annual NOx emissions (tonnes/year)

14% Operating Duty 100% Operating Duty

Gas Turbine Natural gas 146 1,041

Diesel oil 247 1,762

Reciprocating Engine Natural gas 346 2,469

Diesel oil 374 2,672

Under both the 14% and 100% operation, the ozone impact assessment is triggered, hence the next

step in the framework is a Level 1 screening assessment.

9.1.3 Level 1 Ozone Screening Assessment

The EPA’s Level 1 screening tool accompanies the NSW Ozone Procedure. This assessment has used

Version 3.0 of the screening tool (Environ, 2015), with inclusion of 2014-2018 ozone data, and user

specified speciated VOC emissions.

The Level 1 screening tool is primarily intended for continuous emission sources. Noting that the

Proposal would operate typically intermittently, but may operate continuously in some circumstances,

this analysis has considered two operating scenarios:

Operation 24 hours per day

Operation 6 hours per day.

Table 9.5 provides a summary of daily NOx and CO inputs as entered into the Level 1 screening tool.

Methane and speciated (i.e. user-specified) VOC emission estimates were also entered into the tool

using US EPA default emission factors (US EPA, 2006).

Table 9.5: Summary of daily NOx and CO estimates (tonnes/day)

Plant Option Fuel 24 hours / day Operation 6 hours / day Operation

NOx CO NOx CO

Gas Turbine Natural gas 2.9 5.4 0.7 1.4

Distillate 4.8 12.5 1.2 3.1

Reciprocating Engine Natural gas 6.8 1.9 1.9 2.0

Distillate 7.3 2.0 3.0* 0.6*

Note: *Includes allowance for elevated emissions during start-up (assuming 1 start-up per 6 hours operation).

The NSW EPA’s ozone assessment framework defines criteria for assessment of increments to ground

level ozone concentrations in the GMR. For non-attainment areas, the NSW Ozone Procedure defines

a screening impact level (SIL) and maximum allowable increment as follows:

Screening impact level (SIL) of 0.5 ppb

Maximum allowable increment of 1 ppb.

Table 9.6 shows the Level 1 screening tool incremental ozone predictions for these scenarios.




Table 9.6: Summary of Level 1 ozone screening tool results – Incremental ozone concentration (ppb)

Plant Option Fuel 24 hours / day Operation 6 hours / day Operation

1 hour 4 hour 1 hour 4 hour

Gas Turbine Natural gas 1.9 1.2 0.5 0.3

Distillate 3.1 2.0 0.8 0.5

Reciprocating Engine Natural gas 4.3 2.7 1.2 0.8

Distillate 4.6 2.8 2.0 1.3

As shown in Table 9.6, the SIL and maximum allowable increment are met for the natural gas-fired gas

turbine option under a 6 hour per day operating scenario, whilst these criteria are exceeded for all other

scenarios.

Ordinarily, if the predicted incremental ozone concentration is above the SIL, the NSW EPA’s ozone

assessment procedure (Figure 9.1) would then require a Level 2 Refined Assessment to be conducted.

However, as discussed below an alternative approach has been adopted in this instance.

9.2 Previous Studies Considering Ozone and Interregional Transport

An independent assessment of photochemical smog generation was undertaken for a previous project

located on the Proposal Area in 2003 (CSIRO, 2003), comprising the staged development of a dual-

fuel gas turbine power plant ranging from 260 MW to 790 MW in capacity.

For this development, CSIRO conducted modelling of potential smog generation using a three-

dimensional modelling system, including a TAPM numerical weather prediction system, the Carnegie

Mellon California Institute of Technology chemical transport model, and the NSW Metropolitan Air

Quality Study (MAQS) emissions inventory.

The modelling featured specific ozone event periods, which were selected on the basis of having high

ozone concentrations, and meteorological conditions suitable for the interregional transport between

the power stations and the Sydney region (CSIRO, 2005).

The results of the modelling indicated that the proposed development would have only had a minor

positive or negative effect on peak 1 hour and 4 hour ozone concentrations, depending on the scenario

considered. Net increases in ozone were predicted to be of the order of 0.2% for all scenarios

considered in the modelling. The assessment recognised that the NEPM ambient air quality standards

for ozone are exceeded on occasion in the Metropolitan Air Quality Study Region, but the development

was found to be very unlikely to cause any exacerbation of this situation (DIPNR, 2003).

The following key comparisons between (CSIRO, 2003) and the Proposal are considered:

Similar NOx emission intensity (kg/MWh) technologies considered for the two projects12.

Assessment of both natural gas and distillate fuels, inclusive of fuel specific VOC emission

quantities.

Smaller scale of the Proposal (~250 MW versus 250 MW (Stage 1) to 790 MW (Stage 3)

capacity.

The presence of occasional ozone exceedances (i.e. non-attainment) noted within the MAQS.

12

CSIRO (2003) assessed a dual-fuel gas turbine-based plant, whilst the Proposal comprises dual fuel gas turbine or

reciprocating engine technologies. Respective NOx emission intensities are presented in Table 4.1.




A summary of the emission parameters assessed within CSIRO (2003) is presented in Table 9.7:

Table 9.7: Summary of the emission parameters assessed within CSIRO (2003)

Daily emissions Plume characteristics

NOx SO2 CO VOC Hs Ds Vs Ts

(g/s) (g/s) (g/s) (g/s) (m) (m) (m s-1) (C)

Stage 2: 2 x OCGT Configuration

Gas-fired

Turbine 1 31.9 1.7 11.7 2.1 35 11 16.5 593

Turbine 2 31.9 1.7 11.7 2.1 35 11 16.5 593

Liquid-fired

Turbine 1 99.2 18.1 58.6 16.0 35 11 17 599

Turbine 2 99.2 18.1 58.6 16.0 35 11 17 599

Stage 3: 2 x CCGT Configuration

Gas-fired

HRSG 1 31.9 1.7 11.7 2.1 35 7 17.4 100

HRSG 2 31.9 1.7 11.7 2.1 35 7 17.4 100

Liquid-fired

HRSG 1 99.2 18.1 58.6 16.0 35 7 20.2 150

HRSG 2 99.2 18.1 58.6 16.0 35 7 20.2 150

In view of the above, it is considered that the conclusions of the previous CSIRO modelling are

anticipated to remain valid for the Proposal. Namely, that net increases in ozone generation as a result

of the Proposal are anticipated to be minor.

Additional support to the above is provided within (CSIRO, 2005); an ozone impact assessment for the

proposed 660 MW Munmorah Power Station on the Central Coast, south of Newcastle.

(CSIRO, 2005) employed similar modelling techniques to that described within CSIRO (2003) and

concludes “emissions from the proposed gas turbine are predicted to result in no exceedances of air

quality goals and standards for NO2 and O3. Emissions from the gas turbine are predicted to have no

adverse effect on concentrations of nitrogen dioxide and ozone in the Sydney basin region”.

In view of the above commentary on both ozone impacts and inter-regional transport associated with

power station assessments in the region, it is not considered that a Level 2 Refined Assessment is

merited for what is a lesser output proposal.




10. LOCAL CUMULATIVE ASSESSMENT

The assessment has addressed potential air quality impacts across a 30 x 30 km region. The

cumulative contribution of regional air pollution sources has been addressed at a broad scale through

the review and incorporation of regional ambient air quality data into the assessment predictions.

To understand potential isolated impacts from the cumulative impact of the Proposal and existing local

emission sources, a review of local air emission sources was conducted. The National Pollutant

Inventory (NPI) air emission database13 was reviewed in order to identify the presence and relative

scale of air emission sources with pollutants common to the Proposal.

Table 10.1 shows a summary of these sources, with proximity to the Proposal, and annualised emission

quantities for relevant pollutants.

Table 10.1: Annualised air emission quantities for sources near to the Proposal

Facility Distance / Bearing from

Proposal

Annualised Air Emissions – NPI 2017/18 Reporting Year (kg)

NOx CO SO2 PM2.5

Hunter Galvanising 1 km SSE 2,500 2,400 27 200

Tomago Aluminium Smelter 1.5 km SE 350,000 47,000,000 11,000,000 53,000

Newcastle Gas Storage Facility 2 km E 2,900 3,200 29 34

Proposal* - 49,000 115,000 2,100 8,100

Note: *Assuming 14% annual average operating duty, maximum of both technology options, 50/50 fuel mix (natural gas/distillate).

These inventories identify the Tomago Aluminium Smelter (‘the smelter’) as a key existing emission

source of interest in terms of potential localised cumulative air quality impacts. The smelter is operated

by Tomago Aluminium Corporation (TAC).

Emissions from the NGSF have been assessed within the Project Approval and subsequent

modifications (PAEH, 2011b), and been shown to be minor including:

Maximum (non-emergency) incremental 1 hour average NO2 sensitive receptor predictions of approximately 2 µg/m³ (assuming a NO2:NOx ratio of 0.2).

Peak 1 hour average SO2 sensitive receptor predictions of approximately 1 µg/m³.

Peak 24 hour average PM2.5 sensitive receptor predictions of approximately 0.1 µg/m³.

These incremental contributions are all less than 1% of their respective criteria, and hence are not

considered material in terms of potential cumulative impacts. Emissions from the Hunter Galvanising

facility are anticipated to be of a similar level of significance.

To gain understanding of potential scale of cumulative impacts with the smelter, ERM has been

provided with ambient monitoring data from the local SO2 monitoring network operated by TAC. These

data include annualised summaries of monitoring data collected at five sites within the network dating

back to 2009, and include the following:

Maximum, 99th, 90th and 75th percentile statistics

10 minute, 1 hour and 24 hour averages

Annual number of exceedances.

Figure 10.1 shows the location of the five continuous real-time ambient air quality monitoring stations

at which SO2 monitoring is currently undertaken, whilst Table 10.2 through Table 10.4 provide the

annual maximum monitoring results for 10 minute, 1 hour and 24 hour averages (respectively).

13

http://www.npi.gov.au/npidata/action/load/map-search (accessed June 2019).

http://www.npi.gov.au/npidata/action/load/map-search




Source: Adapted from TAC provided image.

Figure 10.1: Location of TAC SO2 monitoring stations in the local vicinity of the smelter.

Table 10.2: Annual maximum 10 minute average SO2 concentrations from TAC monitoring network

Year Maximum 10 minute average SO2 Measurement (µg/m³)

Farm Highway Laverick Ave Met Station Site 179

2014 561 314 361 423 364

2015 554 308 304 356 543

2016 448 324 320 344 437

2017 576 280 463 403 402

2018 553 320 365 367 384

Criterion 712




Table 10.3: Annual maximum 1 hour average SO2 concentrations from TAC monitoring network

Year Maximum 1 hour average SO2 Measurement (µg/m³)


2014 454 239 263 320 273

2015 480 299 232 284 349

2016 405 265 241 276 320

2017 433 171 252 296 294

2018 498 248 248 318 295

Criterion 570

Table 10.4: Annual maximum 24 hour average SO2 concentrations from TAC monitoring network

Year Maximum 24 hour average SO2 Measurement (µg/m³)


2014 225 82 76 174 44

2015 217 113 82 126 140

2016 248 (2) 131 84 73 128

2017 237 (1) 52 109 151 96

2018 269 (2)* 97 88 206 99

Criterion 228

Note: Exceedances shown in bold text. Number of exceedances shown in italicised brackets. *Value updated from previous draft based on 2018 monitoring records provided by TAC.

As shown in Table 10.2 through Table 10.4, ambient SO2 concentrations are higher than the

concentrations measured at Beresfield, but within NSW EPA impact assessment criteria, with the

exception of years 2016, 2017 and 2018, which contain a total of five recorded exceedances of the 24

hour average criterion14.

Maximum Cumulative SO2 Concentrations

In order to assess the potential for the Proposal to produce exceedances of SO2 criteria in the local

vicinity of the smelter, a simplistic assessment of potential cumulative impacts has been undertaken.

This has involved addition of peak Proposal model predictions (Reciprocating Engine option, natural

gas operation, continuous operation all hours of the year) to peak measured concentrations within the

TAC monitoring network for the assessment year (2018).

This approach does not necessarily reflect a realistic estimate of potential cumulative concentrations,

given that peak model predictions and peak TAC SO2 data are unlikely to be coincident in either space

or time15 . However this approach is instructive in screening against the NSW EPA SO2 impact

assessment criteria.

Table 10.5 presents this analysis, with comparison of maximum cumulative concentrations against

relevant criteria.

14

2018 value updated from previous draft based on analysis of 2018 monitoring records as provided by TAC in February 2020. 15

The peak 24 hour model prediction in the vicinity of the Farm monitoring site is approximately 1 µg/m³.




Table 10.5: Screening for potential of the Proposal to produce localised SO2 exceedances

Statistic Maximum Measurement

(All TAC Stations, 2018)

Maximum Proposal Increment1

Maximum Cumulative Concentration

Criterion

10 minute 553 52 605 712

1 hour 498 36 534 570

24 hour 269 (205) 4.3 273 (209) 228

Annual 24.3 0.1 24.4 60

Notes: Exceedances shown in bold font and marked with an asterisk.

Highest non-exceedance value shown in italicised font in brackets.

1Reciprocating engine option, natural gas fuel.

When peak 10 minute, 1 hour and annual average model predictions are assessed in conjunction with

peak TAC measurements, the maximum cumulative predictions are within respective criteria. Noting

that the 24 hour average TAC measurements is greater than the criterion, the highest non-exceeding

background concentration has also been presented (value shown in brackets). Adding the highest

predicted 24 hour concentration to this value does not exceed the criterion, thus the Proposal is not

predicted to produce additional exceedances of the 24 hour average criterion.




11. CONCLUSIONS

This assessment has considered potential air quality impacts associated with construction and

operation of the AGL Newcastle Power Station. The assessment has used a quantitative dispersion

modelling analysis to estimate compliance of operational phase emissions with the NSW EPA impact

assessment criteria.

The existing environment has been characterised in terms of climate, meteorology and ambient air

quality, with identification of key meteorological patterns, and the status of ambient air quality

compliance:

Ambient air quality standards for NO2, CO and SO2 are currently met at all DPIE monitoring

locations across the 5 years reviewed, with significant margin between peak measurements and

the corresponding standards.

Short term (24 hour average) ambient air quality standards for PM (i.e. PM2.5 and PM10) are

exceeded at all locations across the 5 years reviewed.

The long term (annual average) PM2.5 ambient air quality standard is met at Wallsend, and

exceeded at all other locations within the 5 years reviewed. The long term (annual average) PM10


Wallsend, Beresfield, and Newcastle. A review of these exceedances noted the dominance of

extraneous events such as dust storms and bushfire activity.

Emissions from construction operations have been reviewed, with subsequent assessment of

particulate matter emissions from earthworks, which possessed the key air emission potential for

construction phase. A quantitative analysis of these emission indicates that peak model predictions

were within relevant impact assessment criteria, indicating that the potential for these activities to

produce adverse air quality impacts is low and manageable through routine dust mitigation practices.

An evaluation of the Proposal’s emission performance and control technologies concludes that the

technologies currently proposed are consistent with Best Available Technology.

Manufacturer data and US EPA emission factors have been used to estimate emissions for

representative gas turbine and reciprocating engine technology options. Both natural gas and distillate

fuels have been assessed resulting in a total of 4 assessment scenarios. These emissions were applied

on a continuous basis in the NSW EPA-approved CALPUFF dispersion modelling package, in

conjunction with regional background air quality and meteorological datasets for the year 2018.

Modelling predictions were processed into the concentration statistics required for assessment against

NSW EPA impact assessment criteria.

Pollutants with a Proposal contribution in excess of 10% of relevant impact assessment criteria are

confined to NO2 and particulate matter (both technology options), as well as acrolein and formaldehyde

(reciprocating engine option only):

Cumulative NO2 predictions were estimated using the ozone limiting method, in conjunction with

hourly time varying ozone and NO2 concentrations sourced from the DPIE Beresfield AQMS. The

maximum 1 hour average cumulative NO2 predictions was 123 µg/m³, equal to 50% of the criterion.

Peak PM2.5 predictions were approaching criteria, with a peak incremental PM2.5 prediction of 7.6

µg/m³. When added to the peak background concentration of 17.1 µg/m³, results in a (maximum +

maximum) cumulative concentration of 24.7 µg/m³, which is approaching the NSW EPA criterion

of 25 µg/m³ Refinement of the analysis through the use of a time varying background would likely

produce predictions well below those presented in this report.

Exceedances of acrolein were predicted for the reciprocating engine option when operational on

natural gas fuel, with the peak prediction across the modelling domain a factor of three times above

the NSW EPA acrolein criterion. This prediction is based on US EPA emission factor-based




estimates of acrolein emissions, for a 4-stroke lean burn gas engine with a conservative estimate

of oxidation catalyst control efficiency.

To further investigate the potential for acrolein emissions to produce adverse air quality impacts,

the following analysis was undertaken:

A review of the NSW EPA and international screening criteria was conducted. Based on

assessment against these additional criteria, all predictions were estimated to be within

respective screening criteria, as formulated to be protective of adverse public health

outcomes.

A review of meteorological conditions conducive to acrolein exceedances was undertaken

and identified that predicted exceedances were associated with high wind, moderate

temperature daytime conditions and did not align with times at which the plant is more likely

to operate. In this capacity, the assumption of continuous operation, as adopted within this

assessment, is considered to provide a conservative assessment of peak acrolein

predictions.

Accordingly, the analysis conducted within this assessment indicates that the potential for the Proposal

to cause exceedances is low, and manageable through effective operation of the proposed emission

controls.

Commentary provided on both ozone impacts and inter-regional transport associated with other power

station assessments in the region indicates that net increases in ozone generation as a result of the

Proposal are anticipated to be minor.

Lastly, a review of potential cumulative impacts with other local sources of air emissions was conducted

using data from the National Pollutant Inventory. This review identified the Tomago Aluminium Smelter

as the key emission source of interest in terms of potential localised cumulative impacts. Accordingly,

an analysis of the smelter’s local air quality monitoring data was conducted, with assessment of

potential cumulative impacts concluding that additional exceedances of SO2 impact assessment criteria

are not predicted to occur as a result of the Proposal.




12. REFERENCES

ABARE 2011, Energy in Australia 2011, Australian Government Department of Resources, Energy

and Tourism, 2008, http://data.daff.gov.au/data/warehouse/pe_abares99001789/Energy_in_Aust_201

1_13f.pdf (accessed June 2019).

ACIL Allen 2014, Load-Based Licence Fee Comparison – Comparison of Load-Based Licence Fees

with Marginal Abatement Costs (MAC) and Marginal External Costs (MEC) for Selected Pollutants,

ACIL Allen Consulting Pty Ltd, September 2014.

AEMO 2017, Gas Quality Guidelines, Australian Energy Market Operator, September 2017,

https://www.aemo.com.au/-/media/Files/Gas/DWGM/2017/Gas-Quality-Guidelines-Version-10.pdf

(accessed May 2019).

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APPENDIX A CONSTRUCTION EARTHWORKS SCREENING ASSESSMENT




A.1 OVERVIEW

During construction, earthworks may generate particulate matter emissions in quantities that are

significant in the context of ambient air quality and amenity in the immediate vicinity of the Proposal

Area.

Whilst the specific construction method is yet to be designated, AGL have identified that one method

may involve the screening and crushing of excavated rock material, for reuse on site. It is understood

that this operation would occur over a period of approximately 40 days, during which approximately

50,000m³ of material would be excavated for screening and crushing prior to reinstatement.

In the context of the range of potential construction processes, this operation has been identified as

possessing higher dust generation potential, and hence has been assessed quantitatively in order to

establish the scale of potential air quality impacts and suitability of dust management strategies.

This Appendix provides a brief overview of this analysis.

A.1 SPATIAL CONTEXT

AGL have indicated that, should it be required, screening and crushing will be undertaken to the west

of the power station area. This location is shown in Figure A.1, along with a selection of near field

sensitive receptors that have been selected for the purpose of this construction dust analysis.




Proposal Boundary

Figure A.1 – Approximate location of earthworks activities inclusive of crushing and screening.

A.2 EMISSION INVENTORY

An emission inventory has been prepared for portion of the earthworks phase that includes the

crushing operations, inclusive of the following process:

Stripping of the excavation area using a bulldozer.

Excavation and loading into a haul truck.

Transport to the crushing and screening area.

Crushing, screening and stockpiling.

It has been assumed that this process occurs at a rate of 50,000 m³ over 40 days, or 1,250 m³/day.

This activity has been assumed to occur during the hours of 7 am to 6 pm. Within the model, these




emissions have been assumed to occur over the full meteorological dataset, which spans the year 2018.

Given that this phase of works is anticipated to occur over 40 days, this approach ensures that worst

case meteorological conditions are adequately represented.

The construction of the Project has been analysed and estimates of dust emissions for the key dust

generating activities have been made. Emission factors developed within NSW, and by the United

States Environmental Protection Agency (US EPA, 1985), have been applied to estimate the amount

of dust produced by each proposed activity.

General assumptions used in the emission estimate include:

Silt content of 10%

Moisture content of 5%

Hours of operation to be between 7am and 6pm, 7 days per week.

The stockpiled material will be approximately 1 ha in area.

Estimates of emissions for each source were developed on an hourly time step taking into account the

activities that would take place. Thus, for each source, for each hour, an emission rate was determined

which depended upon the level of activity and the wind speed. Dust generating activities were

represented by a single volume source situated in the centre of the anticipated construction footprint

(see Figure A.1) and assumed to occur over a horizontal extent of approximately 170 m.

Table A.1 summarises the quantities of TSP, PM10 and PM2.5 estimated to be released during

construction.

Table A.1: Estimated TSP, PM10 and PM2.5 emissions

Activity Annualised Emissions (kg/yr)

TSP PM10 PM2.5

Dozer stripping 5,104 1,125 118

Excavator loading material to trucks 824 390 59

Hauling material to crusher 6,129 1,506 151

Haul trucks unloading material into primary crusher hopper 412 390 59

Transferring material to screen 82 39 6

Crushing of loaded material 1,355 602 25

Screening 6,273 2,158 2,158

Transferring screened material to product stockpile 412 195 29

Front end loader loading material to haul trucks 824 390 59

Wind erosion - footprint construction area 48 24 4

Total 21,464 6,819 2,668

Typically, a high level of control of dust emissions is achievable during construction through dust

management measures. These measures have been incorporated into the dust emissions calculations

provided in Table A-1. These measures are described as follows:

Use of a water cart to control emissions from unsealed haul roads.

Enforcement of speed limits on site.

Minimising drop height of material during truck loading and unloading where possible.

Management of dust generating activities during unfavourable meteorological conditions.

Keeping materials moist including the use of water sprays on stockpiles, crushing and screening.




A.3 ASSESSMENT

Dispersion modelling has been conducted using the CALPUFF dispersion modelling package, in

conjunction with the geographic datasets used for the assessment of operational impacts.

Dispersion model predictions have been made for the worst case construction scenario. Contour plots

of ground level concentrations and dust deposition rates that could potentially be reached, under the

conditions modelled are presented in the following sections. The predicted particulate

concentrations/levels at the surrounding sensitive receivers are also presented in tabular form. At the

sensitive receivers, there are no concentrations predicted to exceed the impact assessment criteria.

As the construction period will be completed over a short period (40 days), only short term impacts of

particulate matter have been assessed and include:

24-hour average PM10

24-hour average PM2.5

Average monthly dust deposition.

The dispersion modelling results for the construction activities in isolation and combined with other

sources are shown in Table A.2. Contour isopleths have been presented in Table A.2.

Table A.2: Summary of dispersion modelling results

Receptor

Maximum 24-hour average PM10 concentration

(µg/m3)

Maximum 24-hour average PM2.5 concentration

(µg/m3)

Average monthly dust deposition

(g/m2/month)

Incremental Cumulative Incremental Cumulative Incremental Cumulative

R1 1 41 1 18 0.01 2.01

R2 2 41 1 18 0.01 2.01

R3 11 43 5 18 0.10 2.10

R4 1 41 1 17 0.01 2.01

R5 6 43 3 18 0.30 2.30

R6 1 41 <1 17 <0.01 2.00

R7 7 41 3 19 0.04 2.04

Maximum 11 43 5 19 0.3 2.3

Criterion - 50 - 19 2 4




Proposal Boundary

Figure A.2: Predicted maximum 24-hour average PM10 concentrations from construction activities - Incremental (µg/m3)




Proposal Boundary

Figure A.3: Predicted maximum 24-hour average PM2.5 concentrations from the construction activities - Incremental (µg/m3)




Proposal Boundary

Figure A.4: Predicted average monthly dust deposition levels from the construction activities - Incremental (g/m2/month)




Proposal Boundary

Figure A.5: Predicted monthly average dust deposition levels from the construction activities – Cumulative (g/m2/month)

A.4 SUMMARY

These dispersion modelling results demonstrate compliance with the 24-hour average PM10 and PM2.5

and monthly dust deposition impact assessment criteria.

Based on these findings, the construction of the Project is not anticipated to adversely impact the local

air environment or nearby sensitive receptors, providing that adequate dust management strategies are

implemented.




APPENDIX B METEOROLOGICAL MODELLING




B.1 TAPM

TAPM is a three dimensional meteorological and air pollution model produced by the CSIRO Division

of Atmospheric Research (Hurley, 2002a, 2002b; Hurley et al., 2002a, 2002b; Hibberd et al., 2003;

Luhar & Hurley, 2003). TAPM solves the fundamental fluid dynamics and scalar transport equations to

predict meteorology and pollutant concentrations. It consists of coupled prognostic meteorological and

air pollution dispersion components.

TAPM has been used to provide upper-air meteorological for the CALMET meteorological pre-

processor. TAPM incorporates the following databases for input to its computations:

Gridded database of terrain heights on a latitude/longitude grid of 30 second grid spacing,

(around one kilometre). This default dataset is supplemented by a finer resolution dataset at

nine second spacing (around 270 metres) for this assessment.

Australian vegetation and soil type data at three minute grid spacing, (around five kilometres).

Rand's global long term monthly mean sea-surface temperatures on a longitude/latitude grid at

one degree grid spacing (around 100 kilometres).

Six-hourly synoptic scale analyses on a latitude/longitude grid at 0.75-degree grid spacing,

(around 75 kilometres), derived from the local analysis and prediction system (LAPS) data from

the Bureau of Meteorology.

TAPM (V4.0.5) was run as per the configuration outlined in Table B.1.

Table B.1: Summary of TAPM model configuration

Parameter Value

Centre of TAPM Analysis 151.7167 °E, 32.825 °S

379 876 mE, 6367 384 mN (MGA94, Zone 56H)

Number of grids 4

Grid spacing 30 km, 10 km, 3 km, 1km

Number of grid points 33 x 33 x 25

Period of analysis 29/12/2017 – 01/01/2019

Terrain information AUSLIG 9 second DEM data

Mode Meteorology

Wind assimilation 6 Sites influencing 3 levels, with a 7,500 m radius of influence:

Beresfield, Williamtown, Stockton, Newcastle, Mayfield, Wallsend.

Data export Data extracted as upper air format (UP.DAT) at all 6 assimilation sites.

A.2 CALMET

CALMET V6.5.0 was configured as detailed below:

Grid dimensions: 121 x 121 points at 250 m resolution (30 x 30 km), with grid origin: 363.875

kmE, 6352.875 kmN (MGA 94).

Cell faces at: 0, 20, 30, 70, 130, 270, 530, 970, 1,530, 2,470, 3,530, 4,970 mAGL.

Terrain information sourced from the 3 arc-second NASA SRTM terrain database.

Land use data manually generated from aerial photography (see Figure A.1).

Temperature from surface and upper air stations.

Diagnostic wind module used with:

- Extrapolation of winds using similarity theory.




- Horizontally and vertically varying winds with divergence minimisation. Froude number adjustment and slope flows incorporated with a radius of influence (TERRAD) of 3 km.

- No calculation of kinematic effects.

- R1 = 3 km, R2 = 40 km.

Figure B.1: Aerial image showing land use codes

Table B.2: Summary of land use types

Land Use Code Description

10 Urban or built up land

30 Rangeland

40 Forest land

51 Streams and canals

54 Bays and estuaries

55 Oceans and seas

61 Forested wetland

70 Barren land




APPENDIX C REVIEW OF EMISSIONS DURING START-UP AND SHUTDOWN




This section provides a brief review of start-up emissions associated with both gas turbine and

reciprocating engine plant options.

C.1 Gas Turbine Option

During operation, gas turbines are designed to oxidise fuel into carbon dioxide and water in an efficient

manner, with effective control of NOx, CO and HAP emissions. This differs from the start-up period,

where generally lower combustion temperatures and transient changes in combustion parameters can

restrict the application of air emission controls (specifically water injection), resulting in short periods

during which oxygen-corrected exhaust pollutant concentrations are higher than those experienced

during operation.

Aeroderivative gas turbines of the scale proposed are capable of progressing from rest to full load on

time scales in the order of 5 - 10 minutes. These durations are inclusive of the period prior to ignition

(e.g. purging of the turbine), and the time during which the turbines are ramping up to full output, i.e.

after which emission controls have become effective. This is in contrast with large industrial (frame)

turbines, for which open cycle start-up durations can be in the vicinity of 15 to 45 minutes (URS, 2011).

Emission estimates for turbine start-up are limited. CH2MHILL (2010) provides start-up and shutdown

pollutant emission estimates for a gas-fired LM6000PC gas turbine, which is a water-injected

aeroderivative turbine of the scale of those being considered for the Proposal.

Over an 8 minute period (from ignition to 100% load), NOx and CO emissions are estimated at 3.5 and

3 pounds (lb) respectively, equating to average emission rates of 3.3 and 2.8 g/s over this period. These

emission rates are similar in scale (slightly lower) to operational NOx and CO emission rates of

approximately 5.4 and 3.3 g/s. Over an 8 minute shutdown period, NOx and CO emission estimates

are 2.7 and 2.4 lb (respectively), which are lower than those during operation, as well as those estimated

over a corresponding 8 minute start-up period, and consequently of lesser significance than operational

emissions.

Emission estimates were not able to be sourced for liquid fuel start-up, however it is anticipated that

these would be similar in scale to operational emissions, especially when weighted into an hourly

average emission rate as relevant to the dispersion modelling interval and the short-term nitrogen

dioxide standard.

Accordingly, given the short duration, reduced exhaust mass flow rates and infrequent nature of start-

up and shutdown conditions (relative to either operation or rest), the potential for these emissions to

produce adverse air quality impacts is considered minor.

C.2 Reciprocating Engine Option

Emissions from reciprocating engines vary during start-up in a similar capacity to those from gas

turbines. Noting this, reciprocating engines employ post-combustion controls (SCR and oxidation

catalysts) which require additional time beyond the engine start-up to reach optimal operating

conditions. Table C.1 provides a summary of manufacturer estimates of NOx emissions for a start-up

hour. As shown in the Table C.1, with the exception of NOx emissions under distillate operation,

emissions during start-up are similar in scale to those under continuous operation.

Table C.1: Comparison of Reciprocating Engine emissions under start-up and operation

Emission Scenario NOx CO

Units NG DO NG DO

Operation (full load) 22 23 6 6 kg/hr

Start-up 23 116 6 14

Proportion: Start-up vs Operation 125% 573% 119% 252% -

In the case of diesel operation, whilst the engines are capable of reaching full operating load in

5 minutes, elevated NOx emissions are estimated to continue for a period of up to 30 minutes after

commencement of start-up. The duration of this condition is dependent on the pre-starting temperature




of the catalyst bed, which in turn is a function of time since the given unit was last operational. Noting

the anticipated infrequent nature of start-up events, and operation on distillate fuel, the combined risk

of adverse air quality impacts resulting from start-up using distillate fuel (under adverse dispersion

conditions) are considered to be low.




APPENDIX D DETAILED ACROLEIN ASSESSMENT




D.1 OVERVIEW

The dispersion modelling has predicted that maximum offsite 1 hour average 99.9th percentile acrolein

predictions would result in a threefold exceedance of the NSW EPA impact assessment criterion. In

order to permit a more refined assessment of potential adverse air quality impacts, additional acrolein

assessment has been undertaken, involving the following tasks:

A review of the background and basis of derivation for the NSW EPA acrolein criterion.

A review of contemporary public health-endpoint based screening criteria.

An expanded assessment of acrolein predictions against alternative screening criteria.

Detail of this analysis is provided in the following sections.

D.2 NSW APPROVED METHODS ACROLEIN CRITERION

The Approved Methods provide a range of air quality impact assessment criteria for application in the

assessment of air emissions from new or modified pollutant sources. The document contains criteria

for ‘principal toxic pollutants’, inclusive of acrolein, which are to be applied against the incremental 99.9th

percentile 1 hour average predictions for the facility of interest, in isolation. These criteria are applicable

at and beyond the boundary of the facility under assessment.

These criteria have been referenced from EPA Victoria “design criteria” for Class 3 indicator pollutants

(GoV, 2001) which in turn, were developed from (current as of 2001) occupational exposure standards

as per the following process:

“Design Criteria… (for Class 2 indicator pollutants) …have been derived from the current

Worksafe Australia Occupational Health and Safety TWA values divided by a safety factor of

30. This safety factor accounts for extrapolation from a healthy adult exposed over their

working life to the general population potentially exposed over a lifetime. This extrapolation

takes into account the protection of sensitive groups including the elderly and children.”

“Design criteria for Class 3 indicators are derived in a similar manner to those for toxicity

based Class 2 indicators. An additional safety factor of 10 is applied due to the seriousness

of the potential health effects arising from exposure to these pollutants”

Table D.1 shows the basis derivation for the NSW EPA acrolein criterion from the corresponding

occupational criterion.

Table D.1: Basis of derivation for NSW EPA acrolein impact assessment criterion

Parameter Value Units Source

Australian 8 hour occupational standard (TWA) – Circa. 2001* 100 ppb (SWA, 2019)

VIC EPA design criterion TWA conversion (safety) factor 300 - (GoV, 2001)

VIC EPA design criterion (3 minute average) 0.33 ppb

Conversion factor (3 minute to 1 hour) 1.82 - (EPAV, 2005)

NSW EPA impact assessment criterion 0.18 ppb

(EPA, 2017) 0.42 µg/m³

Note: *This standard is current, has been in place since 1991 and is understood to be under review (SWA, 2019).




D.3 REVIEW OF ADDITIONAL ACROLEIN SCREENING CRITERIA

A brief review of contemporary public health endpoint-based assessment standards has been

undertaken in order to provide a more consolidated range of criteria for consideration in the assessment

of potential acrolein impacts.

Texas Commission on Environmental Quality (TCEQ) Effects Screening Levels (TCEQ; 2018,

2019)

The Texas Commission on Environmental Quality (TCEQ) provide a diverse range of Effects Screening

Levels (ESLs) for use in dispersion modelling assessment of new and modified sources of air pollution.

TCEQ (2018) provides the following context on the ESLs.

“Effects Screening Level (ESL): Guideline concentrations derived by the Texas Commission

on Environmental Quality (TCEQ) and used to evaluate ambient air concentrations of

constituents. Based on a constituent’s potential to cause adverse health effects, odor

nuisances, vegetation effects, or materials damage. Health-based screening levels are set at

levels lower than those reported to produce adverse health effects, and are set to protect the

general public, including sensitive subgroups such as children, the elderly, or people with

existing respiratory conditions. If an air concentration of a constituent is below the screening

level, adverse effects are not expected. If an air concentration of a constituent is above the

screening level, it is not indicative that an adverse effect will occur, but rather that further

evaluation is warranted.”

TCEQ (2019) also outlines a tiered methodology for the application of the ESL’s. Of these, Tier II

represents an intermediate (screening level) which involves assessment of maximum 1 hour average

sensitive receptor predictions (e.g. a residence) against the ESL, and assessment of maximum 1 hour

average industrial receptor predictions against a level equal to double that of the ESL. The guidance

also outlines a Tier III assessment, which involves more detailed consideration of potential impacts

should exceedances be predicted within the Tier II assessment.

The 1 hour average and annual average acrolein ESLs are 3.2 µg/m³ and 0.82 µg/m³ (respectively).

Ontario Ministry of the Environment and Climate Change Ambient Air Quality Criteria (MoE,

2019)

The Ontario Ambient Air Quality Criteria (AAQCs) comprise air quality criteria intended for use in

environmental assessment and assessment of ambient air quality data, where an AAQC is defined as

“a desirable concentration of a contaminant in air and is used to assess general air quality resulting

from all sources of a contaminant to air” (MoE, 2019).

The 1 hour average and 24 hour average acrolein AAQCs are 4.5 µg/m³ and 0.4 µg/m³ (respectively).

Agency for Toxic Substances and Diseases Registry (ATSDR) Minimal Risk Levels (MRLs),

(ATSDR, 2019)

ATSDR MRLs are provided as a human health risk assessment screening tool for assessing cases

where potential health effects should be considered more closely. They are based on the ‘no observed

adverse effect level/uncertainty factor’ (NOAEL/UF) approach to derivation MRLs for hazardous

substances.

They are set below levels that, based on current information “might cause adverse health effects in the

people most sensitive to such substance-induced effects.” MRLs are derived for acute (1-14 days),

intermediate (>14-364 days), and chronic (365 days and longer) exposure durations, and for both oral

and inhalation exposure routes.

The acute and intermediate MRLs for acrolein are 7.0 µg/m³ and 0.1 µg/m³ (respectively).




California EPA Air Toxics Hot Spots Program – Reference Exposure Levels (OEHHA, 2015)

The Air Toxics Hot Spots Information and Assessment program provides a framework for the

assessment of extent of airborne emissions from stationary sources and the potential public health

impacts of those emissions.

This framework includes an acute, 8 hour and chronic Reference Exposure Levels (RELs) for a range

of substances as per the following (respective) definitions:

“an acute REL is an exposure that is not likely to cause adverse health effects in a human

population, including sensitive subgroups, exposed to that concentration (in units of

micrograms per cubic meter or µg/m3) for the specified exposure duration on an

intermittent basis.”

“an 8 hour REL is an exposure that is not likely to cause adverse health effects in a human

population, including sensitive subgroups, exposed to that concentration (in units of

micrograms per cubic meter or µg/m3) for an 8 hour exposure duration on a regular

(including daily) basis

“A chronic REL is a concentration level (expressed in units of micrograms per cubic meter

(µg/m³) for inhalation exposure… …at or below which no adverse health effects are

anticipated following long-term exposure.”

The acute, 8 hour and chronic acrolein RELs are 2.5 µg/m³, 0.7 µg/m³ and 0.35 µg/m³ (respectively).

Summary of Screening Criteria

Table D.2 presents a summary of acrolein screening criteria identified as relevant to this assessment.

Table D.2: Summary of acrolein criteria

Default Application

Exposure Duration

Criterion Type Value Assessment Statistic Applicability

Dispersion Modelling

Assessment

Acute

NSW EPA IAC 0.42 1 hour (99.9th percentile) At and beyond boundary

TCEQ ESL 3.2 1 hour (maximum)

At sensitive receptors**

Ontario AAQC 4.5 1 hour

Sub-Acute 0.4 24 hour

Chronic TCEQ ESL 0.82 Annual

Human Health Risk Assessment

– Screening*

Acute OEHHA REL

2.5 1 hour

Sub-Acute / Intermediate

0.7 8 hour

ATSDR MRL 7.0 24 hour

0.1 1 – 14 day

Chronic OEHHA REL 0.35 Annual

*For cases where an emission source is not pre-existing, these figures are regularly used in the evaluation of dispersion modelling results.

**In the case of TCEQ-ESLs, Tier II assessment requires application of the ESL at residential receptors, with a doubling of the ESL at off-site industrial receptors (OEHHA, 2019).




D.4 ACROLEIN ASSESSMENT

Table D.3 presents the results of the Proposal dispersion modelling (reciprocating engine, natural gas

option) against the range of criteria identified in Section D.3.

A contour isopleth of the maximum 1 hour average acrolein prediction is also provide in Figure D.1.

Table D.3: Assessment of model predictions against reviewed acrolein criteria

Criterion Type Model Prediction (µg/m³) Criterion (µg/m³) Assessment Statistic Applicable Result

NSW EPA IAC 1.25 0.42 1 hour (99.9th percentile) Grid Maximum

TCEQ ESL

2.0

3.2

1 hour maximum

Maximum Residential Receptor*

Ontario AAQC 4.5

OEHHA REL 2.5

0.5 0.7 8 hour maximum

Ontario AAQC 0.2

0.4 24 hour maximum

ATSDR MRL 7.0 24 hour maximum

0.05 0.1 7 day maximum**

TCEQ ESL 0.01

0.82 Annual

OEHHA REL 0.35

Note: *Maximum residential receptor results interpolated from gridded receptor predictions.

**1 – 14 day MRL treated as applicable to maximum 7 day average prediction.

These results indicate the following:

As shown in Table D.3, with exception of the NSW EPA criterion, all other predictions are within

respective assessment criteria, as formulated to be protective of adverse public health outcomes.

Model predictions are approaching both acute and sub-acute OEHHA RELs.

Annual average model predictions are significantly lower than respective (chronic) criteria.




Figure D.1: Maximum 1 hour average acrolein prediction (µg/m³)




APPENDIX E METEOROLOGICAL ANALYSIS OF PEAK ACROLEIN PREDICTIONS




E.1 Meteorological Analysis

A review of modelling data was undertaken in order to identify meteorological conditions that are

associated with peak acrolein predictions. This involved processing a time series of modelled

meteorological and concentration data at the peak model receptor, which was located immediately to

the south east of the Proposal (MGA coordinates 379 500 mE, 6368 250 mN). Meteorological

conditions and concentration data at this model receptor were analysed and found to indicate the

following:

At the peak 99.9th percentile receptor, concentrations in excess of the 0.42 µg/m³ acrolein criterion

were predicted during a total of 72 hours within the 8,760 hour meteorological dataset16.

Peak predictions are primarily aligned with daytime conditions – 70% of exceedances were

predicted to occur during between the hours of 8 am and 3 pm.

Peak predictions are confined to neutral conditions (C and D class atmospheric stability).

Peak predictions are aligned with strong winds - 97% of exceedances were predicted for wind

speeds greater than 6.5 m/s.

Peak predictions are aligned with moderate temperatures, primarily occurring between 10°C and

30°C.

A visual representation of the data supporting these findings is shown in Figure E.1 (overleaf).

It is noted that the plant is proposed to operate in a peaking capacity, primarily serving periods of peak

demand, or when renewable capacity is limited. It is noted that acrolein exceedances do not align with

the evening peak or temperature extremes (as relevant to peak reverse cycle air conditioning demand),

and are primarily confined to high wind daytime conditions that are typically associated with higher

output from wind and solar generation.

On this basis, it is considered that meteorological conditions conducive to acrolein exceedances do not

align with times at which the plant is more likely to operate. In this capacity, the assumption of

continuous operation, as adopted within this assessment provides a conservative representation of

peak acrolein predictions.

16

The acrolein criterion applies as a 99.9th percentile concentration, and thus applies to the 9th highest modelling result across

an 8,760 hour annual modelling period.




Figure D.1: Review of acrolein exceedances against local wind speed, temperature and hour of day

0

0.5

1

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0 2 4 6 8 10 12

Acro

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Acrolein Criterion = 0.42 µg/m³

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Acro

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Acrolein Criterion = 0.42 µg/m³

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

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