EIS information guideline Air Introduction The generic TOR requires that: The assessment and supporting information should be sufficient for the administering authority to decide whether an approval should be granted. Where applicable, sufficient information should be included to enable approval conditions, such as the existing model EA conditions, to be utilised. The EHP Model mining conditions can be accessed at: Guideline EM944 The EHP Streamlined model conditions for petroleum activities can be accessed at: Guideline EM1274 EHP has drafted guidelines on information needed [s125 (l) (1)] to make an application for an environmental authority. While those guidelines have their primary purpose in relation to project proposals where an EIS has not been triggered; they also provide useful guidance on information requirements for preparation of an EIS. The EHP Application requirements for activities with impacts to air is at: Guideline EM960 EHP Application requirements for petroleum activities is at: Guideline EM705 Information requirements Where required to “Identify and describe the environmental values that must be protected” the EIS should: describe and illustrate the locations of sensitive receptors e.g. existing residences, places of work, schools, etc., agricultural or ecologically significant species and habitats that could be impacted by emissions from the project describe existing development and possible future development that is documented in approved plans assess whether any air quality objectives are needed in addition to those in the EPP (Air). Where a proposal involves the release of a chemical species which is not listed in the EPP (Air) or NEPM, reference can be made to the following: the design criteria prescribed by the Victorian Government State Environment Protection Policy (Air Quality Management, 2001) may be utilised http://www.gazette.vic.gov.au/gazette/Gazettes2001/GG2001S240.pdf NSW modelling guidelines entitled: Approved Methods and Guidance for the Modelling and Assessment of Air Pollutants in NSW (2001) http://www.environment.nsw.gov.au/resources/legislation/ammodelling05361.pdf South Australian EPA Guideline: Air quality impact assessment using design ground level pollutant concentrations (DGLCs) (2006). http://www.epa.sa.gov.au/xstd_files/Air/Guideline/guide_airquality.pdf Where required to “Provide all available baseline information relevant to the environmental risks of the project. Provide details about the quality of the information provided, in particular: the source of the information; how recent the information is; how the reliability of the information was tested; and any uncertainties in the information.” the EIS should: discuss the background levels and sources of air contaminants including suspended particulates, oxides of sulfur or nitrogen, greenhouse gases, odorous compounds and any other relevant constituent, whether major or minor, of the air environment that may be affected by the project provide sufficient data on local meteorology and ambient levels of contaminants to establish a baseline for later studies and for the modelling of air quality environmental impacts within the airshed. Parameters must include air temperature, wind speed and direction, atmospheric stability, mixing depth and other parameters necessary for input to the models. Where required to “Fully describe the characteristics (through an emissions inventory) of the contaminants or materials released when carrying out the activity (point source and fugitive emissions). Emissions (point source and fugitive) during construction, commissioning, upset conditions, operation and closure should be described” the EIS should: describe all the project’s potential sources of emissions (point source and fugitive) to air and expected composition of the emissions. Describe the methods used to quantify emissions (including references). The EIS information guideline Air description should include oxides of sulfur or nitrogen, volatile organic compounds, carbon monoxide and dioxide, particulates (including dust, PM10, and PM2.5), trace metals, odours and any toxic, persistent and/or hazardous substances that would be emitted by the project provide model input data for all air pollutants for both point and fugitive emission sources. For point sources, present concentrations at standard temperature and pressure. Include relevant information on mass emission rates, stack gas exit velocities and temperatures, stack heights, volume flow rates and oxygen content of the flue gases. provide a separate air emission inventory of any off-site activities directly associated with the project, including fugitive emissions such as from rail or road transport of product or waste use estimates of emission rates based on actual measurements from samples taken from similar facilities, preferably full-scale facilities operating elsewhere, or otherwise from experimental or demonstration-scale facilities. Where this is not possible, use published and referenced emission factors and/or data supplied by manufacturers of process and control equipment. State all input parameters, data sets and assumptions used in the modelling in the main text of the EIS or an appendix. Where required to “Predict the impacts of the releases from the activity on environmental values of the receiving environment...” the EIS modelling shall be undertaken in accordance with NSW DECCW (ex NSW EPA) guidelines entitled: Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales (DECCW, 2005). http://www.environment.nsw.gov.au/resources/legislation/ammodelling05361.pdf The model inputs should be as detailed as possible, reflecting any variation of emissions with time and including at least a full year of representative hourly meteorological data. Provide stack parameters such as stack height, diameter, temperature, exit velocity and volume flow rate. If there is no single atmospheric dispersion model that is able to handle the different atmospheric dispersion characteristics exhibited in the project area (such as sea breezes, strong convection, terrain features, temperature inversions and contaminant re-circulation), apply a combination of acceptable models. The most widely used air dispersion models in Australia are AUSPLUME, CALPUFF, TAPM and AERMOD. AUSPLUME model that was originally developed by Victorian Environment Protection Authority will be withdrawn from 1st January 2015. US EPA’s AERMOD regulatory model will be replacing the AUSPLUME model. A combination of TAPM and CALPUFF is the most advanced modelling system currently extensively used in Australia. In Queensland there are many areas where the frequency of very light winds is high and the topography is complex. CALPUFF is technically better formulated for these conditions and it is expected to provide more accurate results than a steady-state Gaussian model. For these locations, dispersion modelling must be conducted using CALPUFF model. Guidance on CALPUFF and CALMET (a pre-processor) modelling system for inclusion into the “Approved Methods for the Modelling and Assessment of Air Pollutants in NSW” was developed NSW EPA/OEH: http://www.epa.nsw.gov.au/resources/air/CALPUFFModelGuidance.pdf. The modelling techniques provided in this guideline should be considered for settings CALMET/CALPUFF configurations. Estimate the maximum ground level concentration (GLC) and provide contour maps of predicted ground level concentrations in the area and frequency distribution for typical and maximum emissions under the expected range of meteorological conditions including the worst case and a summary table comparing air quality guidelines with predicted values at sensitive receptor locations and/or the site boundary. The averaging period for ground-level concentrations of contaminants modelled should be consistent with the relevant averaging periods for air quality indicators and goals in the Environmental Protection (Air) Policy 2008 and the National Environmental Protection (Ambient Air Quality) Measure. For example, the modelling of sulfur dioxide must be conducted for 1-hour, 24hours and annual averaging periods. Predict dust deposition rate at the sensitive receptors 1 using dispersion modelling and provide monthly average dust deposition values. Estimate the cumulative impacts by considering the background dust deposition data from the site. Compare the modelled and measured dust deposition values against any complaint data if available. Compare the predicted ground level concentrations with the air quality objectives, and the point source emissions against best practice national and international source emission standards. For example, the NSW Protection of the Environment Operations (Clean Air) Regulation (http://www.legislation.nsw.gov.au/sessionalview/sessional/sr/2010-428.pdf) can be considered as the source emission standards. Decisions on whether air and noise contaminants will be regulated at ‘sensitive receptors’ or at the property boundary will made by the administering authority with due regard to the nature of the contaminants, the topography, adjacent development etc, and the practicality of monitoring impacts. 1 2 EIS information guideline Air Describe any situations where people, ecosystems or an agricultural use would experience concentrations above an objective. Include a table showing the number of times ground level concentrations are predicted to exceed objectives at sensitive receptor locations. Assess the human health risk associated with emissions from the project for all contaminants whether or not they are covered by the National Environmental Protection (Ambient Air Quality) Measure or the EPP (Air). Assess potential impacts of emissions on ecosystems or agricultural uses of the environment. Assess the potential cumulative impacts or interaction between the emissions from the project and other emissions in the airshed. For example, it may be necessary to evaluate whether nitrogen oxides and volatile organic compounds emissions from the project and other sources within the region would contribute to the generation of photochemical smog, or whether sulfur dioxide emissions would acidify rain or dew. Describe airshed management and the contribution of the project to airshed capacity in view of existing and possible future users of the airshed for assimilation and dispersion of emissions. If odour could be an issue, conduct odour impact assessment according to the EHP guideline Odour Impact Assessment from Developments https://www.ehp.qld.gov.au/licences-permits/business-industry/pdf/guide-odourimpact-assess-developments.pdf. Identify worst case emissions that may occur at start-up, shut-down or during ‘upset’ operating conditions. If these emissions are significantly higher than those for normal operations, evaluate the worst-case impact as a separate exercise to determine whether any planned buffer between the project and neighbouring sensitive receptors or any other mitigation measures would be adequate. Where required to “Describe the proposed mitigation measures and how the proposed activity will be consistent with best practice environmental management. Where a government plan is relevant to the activity or site where the activity is proposed, describe the activity’s consistency with that plan.” The EIS should detail practices and procedures that would be used to avoid or minimise impacts. For a novel or unproven resource extraction process, technology or activity the EIS will need to identify and describe global best practice environmental management. Describe the pollution control equipment and pollution control processes to be employed on the premises and the features of the project designed to suppress or minimise emissions, including dusts and odours. Describe the backup measures to be incorporated that would be activated in the event of failure of primary measures to minimise the likelihood of plant upsets and adverse air impacts. Where required to “Describe how the achievement of the objectives would be monitored, audited and reported, and how corrective actions would be managed.” The EIS should assess how the proposed emission control processes accord with the management hierarchy for air emissions in the EPP (Air). Describe how the air quality objectives would be achieved, monitored and audited, and how corrective action would be taken when needed. Air management plan The proponent may choose to incorporate all of the above findings and the proposed response strategies into a single Air Management Plan. This will aid the administering authority in the setting of approval conditions. The plan would specify how air pollutants emitted by the activity would not adversely affect the welfare and amenity of nearby land uses. The air management plan would demonstrate that appropriate mitigation measures will be implemented to prevent environmental harm. It will make recommendations on continuous improvements. The plan would include, but not necessarily be limited to: identification of air emission sources minimisation of air pollutants at the sources including management and control strategies monitoring and modelling of air emissions as appropriate a detailed complaints-management procedure for nearby land users and residents affected by air pollutants. The elements of air management plan would include: air quality objectives/targets for what is intended to be achieved management strategies for the overall approach to be taken to meet/maintain the stated objectives/targets tasks/actions required to implement the nominated strategies, including any necessary approval applications, consultations and monitoring performance indicators against which the level of achievement of the stated objectives/targets will be measured the frequency/deadline or time frame in which each of the tasks/actions is to be carried out and/or completed the responsible person/organisation for carrying out each task/action reporting and review arrangements (including any auditing) for each task: how often; and to whom 3 EIS information guideline Air corrective actions to be undertaken if the stated objectives/targets are not being met or maintained, including who is responsible for taking required actions. The air management plan would also provide details of the stack and/or ambient air monitoring strategies that will be employed for the mitigation of adverse air impacts. The ambient air monitoring may include dust deposition and PM10 monitoring. The data from this monitoring program can be integrated with the dust mitigation strategies to ensure the protection of environmental values. This monitoring program would address at least the following: sampling practices, procedures and parameters for contaminant testing selection of sampling locations to demonstrate that samples collected will be representative of the air quality of the area frequency of sampling to be undertaken at each location including the number of samples to be taken, sampling period/duration; continuous or semi-continuous sampling meteorological data collection including at least the wind speed and wind direction during the air quality monitoring program at the monitoring locations. Greenhouse gases (GHG) The EIS should provide an inventory of projected annual emissions for each relevant greenhouse gas, with total emissions expressed in ‘Carbon Dioxide equivalent’ terms. Estimate GHG emissions from upstream activities associated with the proposed project, including the fossil fuel based electricity to be used. Briefly describe the methods used to make the estimates. The Australian Department of Climate Change and Energy Efficiency’s National Greenhouse Accounts (NGA) Factors can be used as a reference source for emission estimates and supplemented by other sources where practicable and appropriate. Coal mining projects will include estimates of coal seam methane to be released as well as emissions resulting from such activities as transportation of products and consumables, and energy use by the project. Assess the potential impacts of the project on the state and national greenhouse gas inventories and propose greenhouse gas abatement measures, including: a description of the proposed measures (alternatives and preferred) to avoid and/or minimise greenhouse gas emissions directly resulting from activities of the project, including such activities as transportation of products and consumables, and energy use by the project an assessment of how the preferred measures minimise emissions and achieve energy efficiency a comparison of the preferred measures for emission controls and energy consumption with best practice environmental management in the relevant sector of industry a description of any opportunities for further offsetting GHG emissions through indirect means. Means of reducing greenhouse gas emissions could include such measures as: minimising clearing at the site (which also has imperatives besides reducing GHG emissions) using less carbon-emitting transport modes or fuels integrating transport for the project with other local industries such that GHG emissions from the construction and running of transport infrastructure are minimised maximising the use of renewable energy sources co-locating coal seam methane use for energy production with coal extraction carbon sequestration at nearby or remote locations. Include a specific module to address greenhouse abatement in any appropriate management plan. That module should include: commitments to the abatement of greenhouse gas emissions from the project with details of the intended objectives, measures and performance standards to avoid, minimise and control emissions periodic energy audits with a view to progressively improving energy efficiency a process for regularly reviewing new technologies to identify opportunities to reduce emissions and use energy efficiently, consistent with best practice environmental management any voluntary initiatives such as projects undertaken as a component of the national Greenhouse Challenge Plus program, or research into reducing the lifecycle and embodied energy carbon intensity of the project’s processes or products opportunities for offsetting greenhouse emissions by renewable energy uses commitments to monitor, audit and report on GHG emissions from all relevant activities and the success of offset measures. 4