Licence conditions for pollution studies and reduction program


Licence conditions for pollution studies and reduction programs

Licence number: 2094
Title: Particulate matter Control Best Practice - Wheel Generated Dust
Start date: 21 Dec 2012
Licence Condition
The Licensee must achieve and maintain a dust control efficiency of 80% or more on all active haul roads by 22 March 2013.   Control efficiency is calculated as:   CE =    E (uncontrolled) - E (controlled)       x 100               E (uncontrolled)      Where E =   the emission rate of the activity
To assess compliance with Condition U2.1, the Licensee must: measure uncontrolled and controlled haul road emissions on at least 3 occasions using a mobile dust monitoring system; continuously measure and record ‘additional site data’ including:         -        vehicle kilometres travelled (VKT),         -        material movements around the site,         -        total and rate of rainfall,frequency, duration, rate and quantity of water applied to the haul roads, and         -        frequency, duration, rate and quantity of suppressant applied to haul roads in comparison to manufacturers specifications, undertake silt content and soil moisture sampling during each mobile dust sampling occasion; and determine if a site specific relationship can be derived between the measured control efficiency, additional site data and the soil moisture and silt content levels. The measurement of uncontrolled and controlled haul road PM10 emissions must not be undertaken at times when greater than 5mm of rain has been received in the last 24 hours or 20mm of rain has been received within the previous 7 days prior to sampling.
The Licensee must submit a report to the EPA which documents the results of the assessment undertaken in accordance with Condition U2.1.  The report must include an assessment of: the dust control effectiveness, the dust levels recorded, and any relationship established between control effectiveness and the additional site data. The report must be submitted by the Licensee to the Environment Protection Authority Regional Manager Hunter, at PO Box 488G, NEWCASTLE by 15 August 2014.
The report required by condition U2.3 must be made publicly available by the Licensee on the Licensee’s website by 29 August 2014. 
The EPA acknowledges that in order to determine uncontrolled PM10 emissions, the section of haul road to be sampled will need to be left untreated for a period of up to 48 hours prior to the sampling taking place.
Timely Public Access to Air Quality Data The licensee must operate a web based service to ensure the community has access to timely, relevant and meaningful continuous emission monitoring data for the Sinter Machine Short Term Operational Arrangements. This must include but not be limited to continuous particle monitoring at the following locations: (a)  In stack at point 151. (b)  Ambient air quality. This service must be developed in consultation with the EPA.
The following points referred to in the table below are identified in this licence for the purposes of monitoring and/or the setting of limits for the emission of pollutants to the air from the point.
For each monitoring/discharge point or utilisation area specified in the table\s below (by a point number), the concentration of a pollutant discharged at that point, or applied to that area, must not exceed the concentration limits specified for that pollutant in the table. POINT 151
For each monitoring/discharge point or utilisation area specified below (by a point number), the licensee must monitor (by sampling and obtaining results by analysis) the concentration of each pollutant specified in Column 1. The licensee must use the sampling method, units of measure, and sample at the frequency, specified opposite in the other columns: POINT 151
1. Special Frequency 12 means "Daily at the commencement of the bypass and one sample every 2 days following confirmation that the first 3 daily sample results are less than the licence limit." 2. Due to the increased Dioxin and Furan monitoring frequency, non-isokinetic testing of the following gases using the specified methods is approved for the June 2021 bypass: a) Hydrogen Chloride and Hydrogen Fluoride - USEPA Method 26 or equivalent. b) Sulfur Dioxide and Sulfuric Acid Mist and Sulfur Trioxide (as SO3) - USEPA Conditional Test Method 13 (USEPA Method 8A) or 13A or equivalent. 3. Continuous monitoring of Solid Particles is required under this licence as listed in the table above.  The results of this monitoring are not required for compliance assessment purposes.  The results of this monitoring are used by the licensee for operational control purposes.  4. Type 1 substance means the elements antimony, arsenic, cadmium, lead or mercury or any compound containing one or more of those elements. 5. Type 2 substance means the elements beryllium, chromium, cobalt, manganese,  nickel, selenium, tin or vanadium or any compound containing one or more of those elements. 6. Limits for Type 1 and Type 2 substances are specified in the Protection of the Environment Operations (Clean Air) Regulation 2021.
Duty to Minimise or Prevent Air Pollution During any bypass the licensee must carry on any activity or operate any plant by such practicable means as may be necessary to prevent or minimise air pollution.  These practicable means may include, but not necessarily be limited to: a)  Dealing with materials in a proper and efficient manner at all times. b)  Maintaining and operating plant and equipment in a proper and efficient manner. c)  Reductions in the nature and quantity of materials processed that could result in the discharge of substances likely to cause harm to the environment. d)  Restrictions on the throughput (tonnes/per hour) of materials processed by the Sinter Plant.
Concentration limits
Location of monitoring/discharge points and areas
Requirement to monitor concentration of pollutants discharged
Background To facilitate the ongoing safe and effective operation of the Waste Gas Cleaning Plant (WGCP) serving the Sinter Plant, the following conditions permit emissions from the Sinter Plant to bypass the WGCP following treatment in the electrostatic precipitators. The bypass would occur for limited periods of time in the following circumstances: (a)  for a proactive response to plant control data/indicators or emergency shutdown; or (b) for preventative maintenance.
Requirements Unless otherwise agreed in writing by the EPA, the licensee must comply with the following conditions whenever the bypass occurs.
Notification and Approval 1. Immediately after the licensee becomes aware of any WGCP bypass, which is not approved for preventative maintenance, the licensee must notify the EPA and provide all relevant information about it. 2. The licensee must provide written details of the notification to the EPA within 7 days of the date on which the WGCP bypass occurred. 3. The licensee must obtain approval in writing from the EPA prior to any preventative maintenance activities that require WGCP bypass.
Operation 1. The duration of the WGCP bypass must be minimised as far as practicable. 2. The licensee must notify the EPA in writing as soon as practicable if the duration of the bypass is likely to exceed: a) 28 days for a proactive response or emergency shutdown; and b) 10 weeks for any preventative maintenance.
Requirement to record bypasses of the WGCP The licensee must record the following details in relation to each bypass of the WGCP and provide the information to the EPA upon request: a) The reason for the bypass; b) The start time and date; and c) The finish time and date.
Review of Air Emissions Model Background The current site emissions model was developed by ENVIRON over the period from 2008 to 2011. The model, methods and consultants were approved by the EPA and the work undertaken successfully as part of PRP 131. Having a standard approved model has allowed consistent assessment over time of changes in air emissions and impacts associated with operational changes and incidents.  The current model allows any combination of plant to be modelled, including 6 Blast Furnace and other plant that has been shut down. New plant can simply be added. Following the recent use of the model during the 2020 Sinter Plant Bypass, the EPA has highlighted the possible need for some updates, including current plant configuration, supporting data, and generation of model outputs consistent with contemporary guidelines and criteria.  Aim To review the existing BSL Air Emissions Site Wide Model.   Requirements 1  The licensee must undertake a review of the Air Emissions Site Wide Model and identify all updates required to be made to the model to ensure; a)  all point and fugitive emission sources are reflective of the current operations b)  the emissions inventory is reflective of contemporary emissions data c)  any adopted emission factors are current and consistent with industry standard the background air quality data is based on contemporary ambient air monitoring data d)  the simulated production scenarios are reflective of current and likely future operations e)  the adopted meteorologic data is both spatially and temporally representative f)  all nearby sensitive receivers have been considered The report must incorporate a peer review by a suitably qualified and experienced professional that has been approved by the EPA. Following submission of this report, the EPA will discuss the model update timing with the licensee All assessment procedures and must be consistent with the EPA’s Approved Method for the Modelling and Assessment of Air Pollutants in NSW (2017) Due Date:  26 February 2021 Note: BlueScope plans to update the air emissions model as part of the No 6 Reline project.  This update is currently expected to occur in late 2021.
Feasibility Assessment for Continuous Emissions Monitoring System (CEMS) (Sulfur Dioxide) Background In spite of ongoing efforts by BSL, the Sulfur Rich Gas (SRG) plant experiences periodic outages which can lead to extended down times.  SRG availability was around 80% in 2018 and 60% for 2019.  While this has not presented an emissions limit compliance issue, it does increase emissions of sulfur oxides.  The current licence quarterly stack testing provides limited information on emissions rates, particularly on any short term changes in SO2 emissions when the SRG plant is on or off line.  Other real time monitoring systems installed following the fire in 2014 have proven useful in tracking plant performance and adjusting operating parameters.  Additionally if the WGCP regenerator is off line, real time sulfur dioxide (SO2) monitoring may provide additional, real time information on the condition of the WGCP char.  An SO2 CEMS system was investigated and trialled at the sinter plant some time ago.  EPA believes there is value in reassessing the feasibility of implementing continuous emissions SO2 monitoring to account for these changes in emissions in real time, and thus will require a feasibility assessment. As part of this assessment process, in late 2021 the licensee proposed to also undertake a continuous monitoring program to assess the effect on SO2 emissions to changing plant conditions.  This proposed assessment program component has been added as Part 3 of this condition. Aim To undertake a feasibility assessment for implementing a continuous method for measuring sulfur dioxide (SO2) emissions from the Sinter Plant Waste Gas Cleaning Plant Stack. Requirements The licensee must prepare and submit a feasibility study report which assesses the feasibility of installing and operating a monitoring system capable of measuring sulfur dioxide (SO2) emissions on the outlet of the Sinter Plant Waste Gas Cleaning Plant Stack on a continuous basis. The proposed system must be capable of being correlated against a reference method in accordance with US EPA Performance Specification 2. As a minimum, the report must: a)  be prepared in consultation with a suitably qualified and experienced air monitoring practitioner who has demonstrated experience in the installation and operation of SO2 monitoring systems at large industrial plant; b)  include a statement about the general feasibility of installing a SO2 CEMS; c)  evaluate potential monitoring options based on site specific factors including, but not limited to:   i.  process and stack conditions,   ii.  sulfur dioxide concentration range, and   iii.  reliability and life cycle cost. d)  evaluate potential installation locations capable of achieving a representative measurement. Part 1.  By 30 October 2021 the licensee must submit to the EPA a proposed methodology for undertaking the feasibility assessment of continuous SO2 monitoring at EPL Point 107 as required under 1 above.  The proposed methodology must generate a prioritised feasibility ranking of the measurement options. Due Date: 30 October 2021 (Complete DOC21/951274)
Part 3.  The licensee must undertake the feasibility assessment  per the approved methodology and submit a report of the assessment findings to the EPA by the due date below. Where it is considered not feasible to install a SO2 CEMS, the Report must: a)  provide a detailed explanation and robust justification of why installation and operation of an SO2 CEMS is not feasible; and b)  detail proposed alternative monitoring and reporting options that ensure ongoing representativeness of SO2 emission monitoring and reporting at the premises. Alternative options must have suitable temporal resolution to ensure all significant emission variability is accounted for. Note: Following submission of the report EPA will meet with the licensee to discuss the findings and possible installation of a monitor or monitoring system. Due Date: on hold pending consideration of Part 2 (above) results
1.  The combined emissions of air impurities from point 151 must be determined in accordance with TM-38, calculated using data collected concurrently at sampling locations 3A and 3B. 2.  The Dioxins and Furans sampling time must be the longer of either 2 hours or the time required to achieve a method detection limit of 0.02 ng/m3
Part 2. The licensee must submit the results of a continuous monitoring program which: 1.  Includes 6 months of monitoring. Gaps for gases van usage elsewhere on site are acceptable but must be clearly explained in the final report; 2.  Lists monitoring parameters.  Parameters must include temperature and oxygen monitored concurrently with SO2; 3.  Accounts for a range of process and stack conditions including variations in Sinter Plant and WGCP operation e.g. SRG outages, line stops, restarts, regenerator outages; 4.  Result in the inclusion of the monitoring results in the final report.  The continuous monitoring program results must include or be supported by a: a)  comparison of SO2 levels (and other parameters) accounting for 1 and 3 above and a discussion on changes in processes and subsequent emissions b)  presentation of an SO2 emissions range (for normal and other operations) c)  narrative on any operational changes to minimise SO2 emissions d)  discussion on operational control based on SO2 monitoring data. e)  description of the procedure to estimate stack moisture in the absence of CEMS monitor f)  discussion on the variability of iso-kinetic moisture results including consideration of the historic data set.   Due Date: 31 March 2023