Licence conditions for pollution studies and reduction program


  

Licence conditions for pollution studies and reduction programs

Summary
 
Licence number: 761
Title: Trigger, Action and Response Plan (TARP) - NOx
Start date: 01 Jan 2022
 
Licence Condition
The licensee must engage a suitably qualified and independent consultant to review a Trigger, Action and Response Plan (TARP) prepared by the licensee that: a) minimises the risk of any NOx concentration limit exceedances at the Premises; b) continually improves the licensee’s response to occasional and/or abnormal combustion conditions that may lead to a NOx concentration limit exceedance; c) provide recommendations for implementation of the TARP at the Premises; d) is used in combination with the Continuous Emissions Monitoring System CEMS.
The TARP prepared under condition U1.1 must include as a minimum the following: a) A description of normal operating conditions. A range of metrics should be included to identify if the unit is operating in a proper and efficient manner. Such metrics may include:         (i) Boiler load (upper and lower bounds which are considered within normal operating range);         (ii) Stability of the units;         (iii) Process inputs (fuel type, fuel usage rate, temperatures, flow rates). b) A description of proactive measures that can be implemented to minimise the risk of any NOx concentration limit exceedances at the Premises; c) Specify:         (i) Parameters that can be monitored and recorded for the purposes of ensuring the units are         operating in a way to minimise the risk of any NOx concentration limit exceedances at the         Premises;         (ii) quantitative threshold levels that once exceeded require the licensee to undertake investigative works and corrective actions to prevent the NOx concentration emissions limits in condition L3.4 and L3.5 being exceeded;    d) A detailed description of the measures or actions to be taken once thresholds are triggered to prevent NOx concentration limits from being exceeded. e) Specify clear reporting requirements for detailing the process operating conditions. Those process operating conditions must be reported in accordance with those requirements if the threshold under condition U1.2(c)(ii) is exceeded.   f) Specify reporting requirements for detailing the investigative and corrective works undertaken under condition U1.2(C)(ii) if that threshold is exceeded. g) Identify:         (i) persons responsible for undertaking the actions detailed in U1.2(d);         (ii) methods for tracking the effectiveness of the applied reactive measures.
The TARP prepared under condition U1.1 must include a detailed description of quality assurance and quality control (QA/QC) procedures used for collecting, verifying, and reporting data
The TARP must be informed by the results and conclusions of the following documents: Katestone Environmental Pty Ltd, Vales Point Power Station Air Quality Assessment for Group Exemption Extension (8 October 2021); Jacobs Group (Australia) Pty Ltd, NOx Pollution Reduction Study, Vales Point – Evaluation of Potential NOx Emission Controls (6 October 2021); Katestone Environmental Pty Ltd, Revised NOx Emission Limits for Vales Point Power Station (26 November 2021).
The TARP prepared in accordance with condition U1.1 must be submitted to the EPA for review by 1 July 2022.