Licence conditions for pollution studies and reduction program


  

Licence conditions for pollution studies and reduction programs

Summary
 
Licence number: 10893
Title: Air Quality Risk Assessment
Start date: 02 Jul 2021
 
Licence Condition
The licensee must engage an independent and appropriately qualified consultant to undertake an Air Quality Risk Assessment. The Assessment must; 1. Include a detailed description of all activities occurring on the site and include:         a) A process flow diagram clearly showing all activities/ operations carried out on the premises including, but not limited to;             i. vessel spray painting             ii. welding, and             iii. surface preparation activities         b) A detailed discussion of all activities carried out on the site, including frequency of occurrence and variability (i.e. seasonal, ad-hoc, routine)         c) A comprehensive inventory of all materials/ products used for performing the identified activities such as paints, thinners, solvents, adhesives and surface coating materials. For each material/ product identified, the following must be included;             i. details regarding the frequency of use and typical application rates             ii. details of the volumes used (litre’s per annum)             iii. material Safety Data Sheet 2. Identify all potential sources of air pollutants (including dust, VOC’s and odour) arising from activities undertaken and materials used on the site. Sources must be identified as point sources or fugitive sources. 3. Include a detailed site plan clearly showing the layout of the site and;         a) locations where all activities/ operations occur         b) all emission sources clearly identified         c) plant boundary         d) sensitive receptors (e.g. nearest residences)         e) topography 4. Include a risk evaluation and assessment of each emission source and their potential impact on air quality. Methods for developing the risk classification must give consideration to, but not necessarily be limited to the:         a) type of material and specific material properties which may contribute to odour generation;         b) quantity of individual material types used by the Premises;         c) specific activities undertaken which utilise the material         d) odour emission intensity, including the results of any odour sampling where considered reasonable and practical to collect as part of the risk classification process 5. Identify and describe all currently installed emission controls including;         a) plans, process flow diagrams and descriptions that clearly identify and explain all pollution control equipment and control techniques for all activities occurring on the premises         b) a description of all aspects of the air emission control systems, with particular regard to any fugitive emission capture systems (e.g. hooding, ducting), treatment systems (e.g. scrubbers, bag filters) and discharge systems (e.g. stacks)         c) the operational parameters of all emission sources, including all operational variability, i.e. location, release type (stack, volume or area) and release parameters (e.g. stack height, stack diameter, exhaust velocity, temperature, emission concentration and rate)         d) emission concentrations and rates must be determined;            i. from all point sources during activities with high potential to cause air impacts            ii. during peak operations, or at times representing worst case conditions            iii. for pollutants including particles, odour and volatile organic compounds (VOC’s)            iv. in accordance with the approved methods for the sampling and analysis of air pollutants in NSW 6. Evaluate the effectiveness of currently installed controls at controlling pollutant emissions from all activities with a high potential to cause air quality impacts;         a) the effectiveness must be determined based on the achieved emission performance and removal efficiency of the installed controls, and         b) must be determined based on the results of emission testing for pollutants including particles, odour and VOC’s 7. Identify, evaluate and recommend options to reduce air quality impacts (including odour) from the premises. The proposal must specify:         a) how pollutant emissions will be mitigated for each material and activity identified and classified as having high emission potential         b) how emission performance improvements will be implemented for each material and activity identified as having high emission potential         c) a timeline for implementation of each odour performance improvement identified.         d) each mitigation and improvement measure identified must:           i. be tailored to the odour risk for each material and activity, and           ii. include performance targets that are measurable, auditable and consistent with the Objective* of the pollution reduction study.
The works required by this Pollution Reduction Study must make reference to methodologies set out in the following documents:
The works required by this Pollution Reduction Study must make reference to methodologies set out in the following documents:         - Technical Framework: Assessment and management of odour from stationary sources in NSW (NSW DEC, 2006);         - Technical Notes: Assessment and management of odour from stationary sources in NSW (NSW DEC, 2006);         - Approved Methods for the Modelling and Assessment of Air Pollutants in NSW (NSW DEC, 2005); and         - Approved Methods for Sampling and Analysis of Air Pollutants in NSW (NSW DEC, 2006).
The licensee must submit a report electronically to the Director, Regulatory Operations Metropolitan, by 22 November 2021 at RegOps.MetroWest@epa.nsw.gov.au outlining the findings of the Air Quality Risk Assessment described under condition U2.1 of this licence.
* The objective of this pollution reduction study is to:  understand the risk of air quality impacts from site activities; determine if currently installed pollution controls remain fit-for-purpose; and identify measures to minimise air quality impacts and ensure compliance with section 128 and section 129 of the Protection of the Environment Operations Act 1997 and Conditions O1-O4 and Condition L4 of this licence.