Air Quality Management Plan

Operations Environmental Management Plan – LNG Operations
Title: LNG Operations – Air Quality Management Plan Issue date: September 2013
LNGOP-QL00-ENV-PLN-000004 Review due: September 2014
LNG OPERATIONS - ENVIRONMENT
AIR QUALITY MANAGEMENT PLAN
Scope and application

This Plan addresses the objectives and performance criteria, management measures, and monitoring, auditing,
and corrective action requirements relating to air quality for the Queensland Curtis LNG Facility on Curtis Island
during operations.
Management measures and reporting and auditing requirements specified, are intended to ensure compliance
with the requirements of the Environmental Authority (EA) for Petroleum Facility Licence (PFL) 11 (Permit
Number EPPG00711513), and other relevant approvals under applicable Queensland and Commonwealth
legislation.
This document applies to operation of the LNG Facility following handover of the site from Bechtel to QGC. It
addresses emissions relating to LNG Operations within the bounds of PFL11 on Curtis Island. Emissions associated
with shipping activities are not addressed except to the extent the emissions from shipping are transferred into
the LNG Facility, either through boil-off gas return to the LNG process or to the LNG Facility marine facility.
Contents
1.0 Summary of Responsibilities ........................................................................................................... 3
2.0 Structure ......................................................................................................................................... 4
3.0 Aspect ............................................................................................................................................. 5
4.0 Objective ......................................................................................................................................... 9
5.0 Performance Criteria....................................................................................................................... 9
5.1 Legislation and Standards ............................................................................................................... 9
5.2 Performance Criteria....................................................................................................................... 9
6.0 Management Measures ................................................................................................................ 10
6.1 Greenhouse Gas Emissions ........................................................................................................... 11
6.2 Dust and Odour ............................................................................................................................. 11
6.3 Fugitive Emissions ......................................................................................................................... 11
6.4 Flares ............................................................................................................................................. 12
6.5 Fuel Burning .................................................................................................................................. 12
6.6 Point Source Emissions ................................................................................................................. 13
7.0 Monitoring and Reporting ............................................................................................................ 14
7.1 Greenhouse Gas Emissions ........................................................................................................... 15
7.2 Dust and Odour ............................................................................................................................. 15
8.0 Auditing ......................................................................................................................................... 17
UNCONTROLLED WHEN PRINTED Revision: B
© QGC 2013 Page 1 of 22

9.0 Corrective Action .......................................................................................................................... 17

9.1 Dust ............................................................................................................................................... 18
9.2 Fugitive Emissions ......................................................................................................................... 18
9.3 Flares ............................................................................................................................................. 18
9.4 Fuel Burning .................................................................................................................................. 18
9.6 General.......................................................................................................................................... 19
Definitions ..................................................................................................................................... 20
Acronyms and Abbreviations ........................................................................................................ 20
Appendix A EA Complaint Monitoring Requirements ...................................................................................... 21
Tables
Table 1: Summary of Responsibilities 3
Table 2: Structure 4
Table 3: Key Emissions Sources 8
Table 4: Management Measures 11
Table 5: Monitoring and Reporting Requirements 15
Table 6: Static Emissions Monitoring 16
Table 7: Correction Actions 18
Figures
Figure 1: Locations of QCLNG Static Emissions Sources 6
Figure 2: Static Emissions Monitoring Locations 7
© QGC 2013 Page 2 of 22

1.0 Summary of Responsibilities

The following summary of responsibilities apply for personnel undertaking
activities covered by this document.
Table 1: Summary of Responsibilities
Position Management Responsibilities
QGC Central  Manage dust and particulate monitoring in response to a
Environment complaint or request from the Administering Authority.
Team/ QGC  Coordinate and undertake routine air quality sampling and
Central monitoring and manage field and laboratory analytical data
Compliance results.
Team  Undertake any required reporting associated with air quality
monitoring programs.
 Manage contracts with Laboratory Analysing Service Providers.
 Undertake Greenhouse Gas Emission reporting
 Undertake audits against the QGC Environmental Management
System (EMS).
 Manage third party auditing of the Environmental Authority (EA)
and Coordinator General (CG) Conditions.
 Coordinate preparation and submission of Statutory Reporting
including Annual Environmental Return and Annual Monitoring
Report.
 Communicate non-compliance with the EA to the Administering
Authority.
LNG Operations  Oversee the evaluation of compliance with environmental
HSSE Manager legislation and regulations, permits, licences and approvals.
 Oversee the evaluation of compliance with environmental
legislation and regulations, permits, licences and approvals.
 Ensure this Management Plan is implemented and updated.
 Oversee incident investigations and implementation of corrective
actions.
Lead  Provide input into the Environmental Site Induction provided to
Environmental all site staff and visitors.
Advisor (LEA) /  Act as primary point of contact for site personnel for air quality
Superintendent matters and any associated environmental incidents.
Environment  Provide the Production Manager and Maintenance Manager with
(title TBC for environmental technical and regulatory compliance support with
Ops) regard to this management plan.
 Assist with dust and particulate monitoring in response to a
complaint or request from the Administering Authority under
direction of the QGC Central Environment Team/ QGC Central
Compliance Team.
 Initiate and participate in environmental incident investigations in
conjunction with and as directed by the LNG Operations HSSE
Manager.
 Communicate incidences and non-compliance to the QGC Central
Environment Team/ QGC Central Compliance Team.
 Collate environmental incident reports and associated regulatory
notifications for submission to the QGC Central Environment
Team/QGC Central Compliance Team for review and transmission
to the administering authority.
 Monitor the implementation of the management measures and
© QGC 2013 Page 3 of 22

identify corrective actions.

 Coordinate with QGC Central Environment Team/ QGC Central
Compliance Team, Site Management and LNG Operations HSSE
Manager on air quality compliance issues.
 Communicate the need for corrective actions to the QGC Central
Compliance Team/ QGC Central Compliance Team, Production
Manager and LNG Operations HSSE Manager.
 Interact with Administering Authority as directed by the QGC
Central Environment Team/ QGC Central Compliance Team.
 Participate in audits against the QGC EMS.
 Facilitate site aspects of third party auditing of the EA and CG
Conditions.
Business  Manage contract processes including incorporation of safety
Services requirements into contracts.
Manager
Production  Operate the plant to meet specifications, achieve optimal
Manager performance and meet the stack emission discharge criteria as
stipulated in the EA.
Maintenance  Maintain the plant to prevent leakage of fugitive emissions.
Manager
2.0 Structure
The body of this management plan follows the structure outlined below:
Table 2: Structure
Section Heading Description
1.0 Summary of Summary of responsibilities for all personnel undertaking
Responsibilities activities covered by this document.
2.0 Structure This section, summarising document structure.
3.0 Aspect How aspects of the activity phases are to be managed (as
it affects environmental and social values).
4.0 Objective The Activity policy or management objective that applies
to each element.
5.0 Performance Measurable performance criteria (outcomes) for each
Criteria element of each Activity phase.
6.0 Management The strategies, tasks or action program (to nominated
Measures operational design standards) that will be implemented to
achieve the performance criteria.
7.0 Monitoring and The monitoring requirements to measure actual
Reporting performance (i.e. specified limits to pre-selected indicators
of change).
Format, timing and responsibility for reporting and
auditing of monitoring results.
8.0 Auditing The auditing requirements to demonstrate
implementation of agreed environmental management
strategies and compliance with agreed performance
criteria.
9.0 Corrective The action (options) to be implemented in case a
Actions performance requirement is not reached and the person
responsible for that action (including staff authority,
responsibility and management structure).
© QGC 2013 Page 4 of 22

3.0 Aspect
A brief description of emission sources and key emissions are included in Table 3
below. Locations of key point source emissions are provided in Figure 1 and
locations for monitoring are included in Figure 2.
Emissions sources addressed include the following:
1. Point Sources under Normal Operations
Sources with continuous emissions under normal operations, including
emissions generated by the combustion of coal seam gas (CSG) and the
processing of feed gas for liquefaction. These emissions will tend to be
constant within certain bounds.
2. Point Sources under Start-up, Shutdown or Upset Conditions
Non-normal operations refer to conditions at the LNG Facility that are
outside the general operating parameters of the plant and occur
intermittently for a short duration. Emission rates for these activities
may also be variable and, consequently, do not impact air quality on a
continual basis.
3. Fugitive Emissions and Other Sources
There may also be minor emissions from vehicles and occasional use of
mobile plant and equipment (for example, mobile pumps to manage
stormwater, mobile generators for maintenance works, etc).These
emissions will be transient, intermittent and spatially variable. Vehicles
may also generate dust if driven on unsurfaced roadways.
Fugitive emissions may arise due to trace leakage of gas through
flanges, valves or other equipment, and from vents and pressure safety
valves (PSVs). PSVs and vents are installed on a range of equipment
across the site. While emissions from many of these will be only
pressurised air or inert gas (nitrogen), emissions to atmosphere with
potential air quality impact or greenhouse gas impact may arise from
the sources identified in Table 3.
© QGC 2013 Page 5 of 22

Figure 1.
Static Emission Sources
Nitrogen Rejection Unit
Train 2
Acid Gas Removal Unit
(
! Static Emission Source
(
! !
(
Regeneration Gas Heater
(
!
(
! Static Emission Source
Compressor Gas Turbines (x6) Hot Oil Heater Export Pipeline
Gas Turbine Generator (x3) Wet Lease Boundary
QCLNG Site Boundary (PFL11)

Train 1
Acid Gas Removal Unit
Nitrogen Rejection Unit
(
! (
!
Compressor Gas Turbines (x6) Emergency & Back-Up

Fire Water Pumps (x3) Diesel Generators
Process Flares (Wet and Dry Gas)
(
!
Marine Flare
(
!
DATE: 16/08/2013 CREATED BY: hibberde

MAP NO: M_25547_01d
Standby Diesel Generator

(Marine Terminal Building)
0 50 100
± 150 200 250
Meters
Map Projection: GDA 94 SCALE: 1:7,500 (A4)
DATA SOURCE: Site Layout - Bechtel

Site Boundary - DME
Aerial Imagery - NearMap
Note: Every effort has been made to ensure this information is spatially accurate.
The location of this information should not be relied on as the exact field location
"Based on or contains data provided by the State of Queensland (Department of
Environment and Resources Management) 2011. In consideration of the State permitting
use of this data you acknowledge and agree that the State gives no warranty in relation to
the data (including accuracy, reliability, completeness, currency or suitability) and accepts
no liability (including without limitation, liability in negligence) for any loss, damage or
costs (including consequential damage) relating to any use of the data. Data must not
be used for direct marketing or be used in breach of the privacy laws."
Figure 2.
Train 2
Static Emission
Monitoring Locations
Legend
!
( Static Emission Source
RP8
RP10 QCLNG Site Boundary (PFL11)
!
( !((
! ( Wet Lease Boundary
RP7 !(! ! RP12
RP9 ( Export Pipeline
RP11
RP13
RP14
!
( RP15
!
(
Train 1 !
(
RP1
RP2
RP4
!
( (! (
! ( RP6
!(! !
RP3 (
RP5
DATE: 15/08/2013 CREATED BY: hibberde

MAP NO: M_25547_02c
Release Equipment
±
Location Emission Source 0 25 50 75 100
Point Number
Meters
Propane Compressor Gas Turbine RP1 1TC-1411
Propane Compressor Gas Turbine RP2 1TC-1421 Map Projection: GDA 94 SCALE: 1:3,000 (A4)
DATA SOURCE:
Ethylene Compressor Gas Turbine RP3 1TC-1511
Train 1 <INSERT DATA SOURCE>
Methane Compressor Gas Turbine (with WHR) RP5 1TC-1611
Note: Every effort has been made to ensure this information is spatially accurate.
The location of this information should not be relied on as the exact field location

"Based on or contains data provided by the State of Queensland (Department of
Environment and Resources Management) 2011. In consideration of the State permitting
use of this data you acknowledge and agree that the State gives no warranty in relation to
Propane Compressor Gas Turbine RP7 2TC-1411 the data (including accuracy, reliability, completeness, currency or suitability) and accepts
no liability (including without limitation, liability in negligence) for any loss, damage or
Propane Compressor Gas Turbine RP8 2TC-1421 costs (including consequential damage) relating to any use of the data. Data must not
be used for direct marketing or be used in breach of the privacy laws."
Train 2
Gas Turbine Generator RP13 1TG-3101
Power
Generation
Table 3: Key Emissions Sources

Aspect Location Emission Source Number Key Emissions Comments
Compressor Gas Turbines 12 (6 per train) NOx (minor / trace CO, PM10, CO2, CH4)
Trains 1 and 2 Acid Gas Removal Unit (CO2 vent) 2 (1 per train) CO2 (minor CH4)
Point Sources Nitrogen Rejection Unit (NRU vent) 2 (1 per train) N2 (minor CH4)
- Normal
Operations Power Generation Gas Turbine Generators 3 NOx (minor / trace CO, PM10, CO2, CH4) 2 operational, 1 standby
Wet & Dry Gas Flares NOx, CO (minor/trace PM10, CO2) Pilot light only during normal ops
Flares
Marine Flares Dependent upon vessel Pilot light
NOx, CO, (minor / trace PM10, Flaring due to purging, dryout, cooldown,
Wet and dry gas flares
hydrocarbons) trips or upset
Flares
NOx, CO, (minor / trace PM10, Trips or upset
Marine flare
Point Sources hydrocarbons)
- Start-up, Hot Oil Heater 1 NOx (minor / trace CO, PM10, CO2, CH4) Start-up only (not monitored)
Shutdown or Regeneration Gas Heater 1 NOx (minor / trace CO, PM10, CO2, CH4) Start-up only (not monitored)
Upset
Conditions Utilities and Back- Power generation (diesel) 3 Diesel emissions Start-up / back-up only (not monitored)
up Fire Water Pumps (diesel) 3 Diesel emissions Intermittent – emergency (not monitored)
Standby Diesel Generator Marine Terminal Bldg 1 Diesel emissions Intermittent – (not monitored)
Emergency air compressor – (diesel) 2 Diesel emissions Intermittent –back-up (not monitored)
Vehicles Diesel emissions
Mobile
Mobile Plant and Equipment Diesel emissions
PSVs - Amine Units and Tanks N2 Blanket
PSVs - LNG Tanks CH4
Vent - Hot Oil Storage Tank N2 Blanket
Fugitive
Emissions and Miscellaneous Atmospheric Vents (e.g. water
Air
Other Sources tanks, plant and instrument air receivers)
PSVs and vents Intermittent for pressure relief
Demineralised Water Storage Tanks N2 Blanket
Nitrogen Receivers N2 Service
Gas Analysers CH4
PSVs on Hydrocarbon Absorbers Air, N2
PSVs - Refrigerant Isotainers Ethylene, propane
© QGC 2013 Page 8 of 22

4.0 Objective
The Project environmental objectives for air quality are:
 To operate in a manner that minimises impacts on ambient air quality.
 To preserve ambient air quality to the extent that ecological health,
public amenity or safety is maintained.
 To actively manage emissions of greenhouse gases and to minimise the
emission of greenhouse gases in terms of carbon dioxide equivalent
(CO2eq) per unit of hydrocarbon produced/transmitted (Greenhouse Gas
(GHG) efficiency).
 To manage the physical risks to facilities resulting from climate change.
 To eliminate the emission of ozone depleting substances.
5.0 Performance Criteria
5.1 Legislation and Standards

The performance criteria and implementation strategy has been developed with
reference to:
 Environmental Protection Act 1994 (EP Act) (Qld).
 Environmental Protection Regulation 2008 (Qld).
 Environment Protection (Air) Policy 2008 (EPP (Air)) (Qld).
 National Environment Protection Measure (Air).
 Environmental Authority No. EPPG00711513
5.2 Performance Criteria

The performance criteria and objectives for this management plan are as follows:
Greenhouse Gas Emissions
 Manage emissions of greenhouse gases in accordance with the QCLNG 
Greenhouse Gas Emissions Strategy
Nuisance (Dust and Odour)

 No environmental nuisance from the release of dust or particulate
matter at any nuisance sensitive or commercial place.
 No environmental nuisance from the release of noxious or offensive
airborne contaminants at any nuisance sensitive or commercial place.
Releases to Atmosphere
 Release of contaminants to the atmosphere from point sources only at
flow and emission rates in accordance with Schedule B, Table 1 and
Schedule B, Table 2 of the EA.
 Monitoring of contaminants to the atmosphere from Point Sources in
accordance with Schedule B, Table 2 of the EA.
 No emission to air of ozone depleting substances.
© QGC 2013 Page 9 of 22

Flaring
 Visual smoke and particulate emissions will not occur for more than five
(5) minutes in any two (2) hour period during normal operating
conditions, other than during LNG train start-up.
Fugitive Emissions
 Take all reasonable and practicable measures to minimise fugitive
emissions.
Fuel Burning
 No burning of waste or fuel, other than as permitted by the EA.
 The sulphur content of fuel burned in the power generators will not
exceed 0.5 percent by weight.
General
 Manage complaints in accordance with the Gladstone Stakeholder
Engagement Plan.
 Corrective actions will be implemented promptly where fault of omission
has resulted in emission of contaminants from industrial plant or ducting
systems.
6.0 Management Measures

Table 4 presents management measures to be adopted during operation to meet
the performance objectives and criteria for air quality.
© QGC 2013 Page 10 of 22

Table 4: Management Measures

Performance Criteria Management Measure Responsibility
6.1 Greenhouse Gas Emissions
Manage emissions of greenhouse gases in accordance with the QCLNG Greenhouse Gas Emissions Strategy. QGC Central
. Environment Team/
QGC Central
Compliance Team
6.2 Dust and Odour
No environmental nuisance from the All vehicles travelling within the LNG Facility will use the permanent site roads All Staff
release of dust or particulate matter provided.
at any nuisance sensitive or
commercial place. Roads within the LNG Facility in regular use during normal operations will be sealed Maintenance
and maintained. Manager
Manage complaints about air quality The security permiter road around the exterior of the LNG Facility is only to be utilised LEA
in accordance and within timeframes for maintenance of regeneration works and access to the GAWB Pipeline. Traffic
stipulated in the Gladstone speeds are less than 20 km/hour to minimise dust generation.
Stakeholder Engagement Plan. The Spoil Pile Access Road is only to be utilised for weed management and
regenerations works and traffic speeds are less than 20 km/hour to minimise dust
generation.
Undertake dust and particulate monitoring in response to a complaint or request QGC Central  Refer to EA Schedule B Condition B3
from the Administering Authority. Environment Team (Appendix A)
Dust and particulate monitoring undertaken to meet EA requirements as provided in / QGC Central
Appendix A. Compliance Team
Staff that will be responsible for receiving and responding to complaints will be (LEA to assist
trained in Gladstone Stakeholder Engagement Plan. onsite)
6.3 Fugitive Emissions
Fugitive emissions will be minimised Implementation of the Integrated Control and Safety System (ICSS), which is Production
by taking all reasonable and integrated by three components; the Fire and Gas System (FGS), the Distributed Manager
practicable measures during design Control System (DCS), and the Safety Instrument System (SIS).
and operation. Line-of site, Infra-red (IR) and Point Gas Detector high-level gas/leak alarms and
© QGC 2013 Page 11 of 22


Ultrasonic leak detection alarms will be observed at local control points and
permanently manned control points.
Regular surveillance to detect fugitive emissions will be undertaken of control valves,
glands on control valves and vents on cold boxes.
Performance Standards have been developed to address hydrocarbon containment.
Regular maintenance of the Plant will be undertaken by the Maintenance Team. Maintenance
Manager
Routine Baseline Inspection will be undertaken pre-operation.
Leak detection of the flanges will be undertaken at start up or if the flanges are
disturbed.
6.4 Flares
Visible smoke and particulate Design of the flares has addressed the requirement that visible smoke and particulate Engineering
emissions will not occur for more emissions are not to occur for more than five (5) minutes in any two (2) hour period Manager
than five (5) minutes in any two (2) during normal operating conditions, other than during LNG train start-up.
hour period during normal operating Emergency Procedures have been developed and are implemented for non-routine Production
conditions, other than during LNG situations to deal with foreseeable risks and hazards including corrective responses to Manager
train start-up prevent and mitigate environmental harm.
6.5 Fuel Burning
No burning of waste or fuel, other There will be no burning of waste, fuel (other than natural gas in the fuel burning LEA
than as permitted by the EA. equipment under normal operating conditions) or chemicals at the LNG Facility.
The sulphur content of fuel burned in Fuel supply contracts will specify the supply of low sulphur fuel. Business Services
the power generators will not exceed Manager
0.5 percent by weight.
© QGC 2013 Page 12 of 22

6.6 Point Source Emissions
Release of contaminants to the The exhaust stacks have been designed to achieve the minimum release heights Engineering
atmosphere will only occur from (above grade) stipulated in the EA. Manager
Point Sources at flow and emission Operate the plant to achieve the minimum release velocity stipulated in the EA. Production
rates in accordance with Schedule B, Manager
Table 1 and Schedule B, Table 2 of
Assist the contractor in obtaining additional information as required on the Plant QGC Central
the EA.
operation. Environment Team/
QGC Central
Compliance Team
Monitoring of contaminants to the The following testing on equipment will be undertaken which will confirm equipment Production
atmosphere from Point Sources will is running to specifications and meeting design criteria: Manager
occur in accordance with Schedule B,  Factory Acceptance Tests (FATs) for the ICSS systems will occur at supplier’s Maintenance
Table 2 of the EA. staging facilities. Manager
 Commissioning Demonstration Tests are intended to demonstrate performance
of the subject system meets the design intent as shown in technical
specifications.
 Plant Performance Test, which measures the rate of increase of LNG in storage
(Net LNG Production).
 Fuel Gas Consumption Performance Test.
 Remote Monitoring and Diagnostics, 24/7.
 Performance Maintenance will be undertaken at 4,000, 25,000 and 50,000 hour
intervals. Exhaust Emissions Mapping will therefore occur approximately every 3
years.
© QGC 2013 Page 13 of 22

7.0 Monitoring and Reporting

Monitoring and reporting is to be undertaken as specified in Schedule B (as per
the tables below) and in accordance with the following requirements:
 Undertake the monitoring in accordance with the Australian Standard AS
4323.1 – 1995 ‘ Stationary source emissions, Method 1: Selection of
sampling positions’ (or more recent editions).
 The following tests must be performed for each determination specified
in the EA:
- Gas velocity and volume flow rate.
- Temperature.
- Water vapour concentration (moisture content).
 During the sampling period, the following additional information must be
gathered:
- Production rate at the time of sampling.
- Raw materials and fuel used.
- Number of plant or equipment and operator units operating.
The QGC Central Environmental Team will oversee monitoring in response to

incident or complaint monitoring at the direction of the Administering Authority.
Reporting on monitoring undertaken in response to complaints or specific
direction of the Administering Authority will be provided within fourteen (14)
days of completion of the investigation or receipt of monitoring results,
whichever is the latter, in accordance with Schedule J of the EA.
Monitoring outcomes and corrective actions (if required) will be reported in the
Annual Monitoring Report prepared by QGC Central Environment Team/ QGC
Central Compliance Team and submitted to the Administering Authority.
© QGC 2013 Page 14 of 22

Table 5: Monitoring and Reporting Requirements

Monitoring Action Reporting Action Responsibility
7.1 Greenhouse Gas Emissions
Monitor the Greenhouse Gas Emissions in accordance with the Report Greenhouse Gas Emissions as required, QGC Central Environment
Greenhouse Gas Emission Strategy. including preparation of the Annual Environmental Team /
Return QGC Central Compliance
Team
7.2 Dust and Odour
In the event of a complaint or request from the Administering Gladstone Stakeholder Engagement Plan QGC Central Environment  Refer to EA Schedule B Condition B3
Authority, dust and particulate monitoring must be undertaken Annual Environmental Return Team / (Appendix A)
to meet EA requirements as provided in Appendix A. QGC Central Compliance
Team (LEA to assist onsite)
Monitoring of the point sources is to occur annually, on a Annual Environmental Return QGC Central Environment
rotational basis. Table 6 outlines the release points to be Team /
monitored, the frequency of monitoring and the contaminant QGC Central Compliance
release limits. Figure 2 shows the monitoring locations. Team
Analysis of samples to be undertaken by a NATA certified
laboratory.
Samples must be taken when emissions are expected to be at
maximum rates.
© QGC 2013 Page 15 of 22

Table 6: Static Emissions Monitoring

Emission Source Release Equipment Monitoring Frequency Minimum Parameter Maximum Release Limit
Point Number Veolcity Measured
(m/sec)
Train 1
Propane Compressor Gas Turbine RP1 1TC-1411 25 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec
Ethylene Compressor Gas Turbine RP3 1TC-1511 One (1) Train 1 Emission Source per 25 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec
Ethylene Compressor Gas Turbine RP4 1TC-1521 year, on a rotational basis 25 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec
Methane Compressor Gas Turbine (with WHR) RP5 1TC-1611 22 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec
Train 2
Ethylene Compressor Gas Turbine RP9 2TC-1511 One (1) Train 2 Emission Source per 25 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec
Ethylene Compressor Gas Turbine RP10 2TC-1521 year, on a rotational basis 25 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec
Power Generation
Gas Turbine Generator RP13 1TG-3101 25 NOx 61 mg/Nm3 (dry) @ 15%O2 and 3.4 g/sec
1 Power Generation Emission Source
per year, on a rotational basis
© QGC 2013 Page 16 of 22

8.0 Auditing
QGC maintains an EMS in accordance with the international standard AS/NZS ISO  Auditing against relevant
14001. The EMS must be regularly audited to ensure its continuing suitability, environmental legislation and
adequacy and effectiveness and meet QGC’s commitment to continual regulations, environmental
improvement. licences and permits
Regular internal audits of the EMS are conducted, covering all activities within the
scope of the QGC Asset EMS.
QGC will also ensure that a qualified third party auditor (accepted by the
Administering Authority) undertakes compliance monitoring against the EA
conditions within one (1) year of the completion of commissioning of the LNG
Facility and every three years thereafter.
9.0 Corrective Action

Table 7 outlines the corrective actions that have been identified for the potential
impacts on air quality should the management measures be inadequate.
© QGC 2013 Page 17 of 22

Table 7: Correction Actions

Corrective Actions Responsibility
9.1 Dust
In the event of a complaint, undertake dust and particulate monitoring. QGC Central Environment Team /
QGC Central Compliance Team (LEA to  Refer to EA Schedule B Condition B3
assist onsite) (Appendix A)
9.2 Fugitive Emissions
Fugitive emissions from the Plant will be identified by the Production Team via a leak detection Production Manager (leak detection)
program and responded to by the Maintenance Team. Maintenance Manager (required
maintenance)
9.3 Flares
Should visible smoke and particulate emissions occur for more than five (5) minutes in any two (2) hour Production Manager
period during normal operating conditions, other than during LNG train start-up the Production
Manager will:
1. Consult with engineering to identify possible causes.
2. Investigate mitigation measures.
3. Implement appropriate mitigations if possible.
9.4 Fuel Burning
Should the fuel received from suppliers for burning in the power generators exceed 0.5 percent sulphur Business Services Manager
by weight the Business Services Manager will contact the suppliers and investigate.

Should monitoring indicate a breach of the discharge criteria set out in Schedule B, Table 2 of the EA, QGC Central Environment Team /
the following process will be followed: QGC Central Compliance Team
1. Immediate retest to ensure accurate results.
2. Consultation with engineering to identify possible causes.
3. Investigation of implications via dispersion modelling studies.
4. Investigation of mitigation measures.
5. Implementation of appropriate mitigations if possible.
© QGC 2013 Page 18 of 22

Corrective Actions Responsibility
9.6 General
Investigate complaints and advise the Administering Authority in writing (within 14 days of completion QGC Central Environment Team /
of the investigation) of the proposed or undertaken action in relation to the complaint. QGC Central Compliance Team
and LEA
Undertake monitoring specified by the Administering Authority to investigate any complaint of
environmental harm. Report results of the investigation and monitoring within 14 days of completion
of the investigation or receipt of the monitoring results, whichever is the latter.
Implement corrective actions if the monitoring indicates an exceedence of discharge limits in the EA.
Record the following details for all complaints received and provide the information to the
Administering Authority:
 Name, address and contact details of complainant.
 Time and date of complaint.
 Reasons for the complaint.
 Investigations undertaken.
 Conclusions formed.
 Actions taken to resolve complaint.
 Any abatement measures implemented.
 Person responsible for resolving the complaint.
© QGC 2013 Page 19 of 22

Operations Environmental Management Plan – LNG
Operations Title: LNG Operations – Air Quality Management
Plan Issue Date: September 2013
LNGOP-QL00-ENV-PLN-000004 Review Date: September 2014
Definitions
Term Meaning
Administering Authority Department of Environment and Heritage Protection (formerly Department of
Environment and Resource Management). The Queensland Government
Department that administers the Environmental Authority under the Environmental
Protection Act 1994.
Acronyms and Abbreviations

Acronym Meaning
CG Coordinator General
CH4 Methane
CO Carbon Monoxide
CO2 Carbon Dioxide
DCS Distributed Control System
EA Environmental Authority, and specifically the Environmental Authority for Petroleum Facility Licence
PFL 11 (EPPG00711513)
EHP Department of Environment and Heritage Protection
EMS Environmental Management System
EP Act Environmental Protection Act 1994 (Qld)
EPP (Air) Environmental Protection (Air) Policy 2008 (Qld)
FGS Fire and Gas System
LEA Lead Environmental Advisor
GHG Greenhouse Gas
g/sec Grams per second
ICSS Integrated Control and Safety System
LNG Liquefied Natural Gas
3
mg/Nm Milligrams per Normal cubic metre
NATA National Association of Testing Authorities, Australia
NEPM National Environment Protection Measure
N2 Nitrogen Gas
NOx Nitrogen Oxides
NRU Nitrogen Rejection Unit
O2 Oxygen
PFL Petroleum Facility Licence
PM10 Particulate Matter in the order of 10 micrometres or less
PSV Pressure Safety Valve
QGC QGC – A BG Group business
QCLNG Queensland Curtis LNG
SIS Safety Instrument System
© QGC 2013 Page 20 of 22

Appendix A EA Complaint Monitoring Requirements
In the event of a complaint or request from the Administering Authority, dust and particulate monitoring must be
undertaken to meet EA requirements. The following criteria must be achieved:
 Dust deposition of 120 mg/m2 per day over a 30-days averaging period, when monitored in accordance
with Australian Standard AS 3580.10.1 of 2003 (or more recent editions); or
 A concentration of particulate matter with an aerodynamic diameter of less than 10 µm (PM10) suspended
in the atmosphere of 50 µg/m3 (with five one day exceedances allowed in any one year period1); and over
a 24 hour averaging time, at a dust sensitive place downwind of the licensed place, when monitored in
accordance with:
- Australian Standard AS3580.9.6 of 2003 (or more recent editions) ‘Ambient air – Particulate matter
– Determination of suspended particulate PM10 high-volume sampler with size-selective inlet –
Gravimetric method’; or
- Any alternative method of monitoring PM10 which may be permitted by the ‘Air Quality Sampling
Manual´ as published from time to time by the Administering Authority.
1
The 5 days exceedances per year are based on the expected exceedances from the natural events such as bushfires and dust storm.
© QGC 2013 Page 21 of 22

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Operations Environmental Management Plan – LNG Operations

LNG OPERATIONS - ENVIRONMENT

AIR QUALITY MANAGEMENT PLAN

Scope and application

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9.0 Corrective Action .......................................................................................................................... 17

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1.0 Summary of Responsibilities

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identify corrective actions.

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Compressor Gas Turbines (x6) Hot Oil Heater Export Pipeline

Gas Turbine Generator (x3) Wet Lease Boundary

QCLNG Site Boundary (PFL11)

Compressor Gas Turbines (x6) Emergency & Back-Up

Process Flares (Wet and Dry Gas)

DATE: 16/08/2013 CREATED BY: hibberde

Standby Diesel Generator

Map Projection: GDA 94 SCALE: 1:7,500 (A4)

DATA SOURCE: Site Layout - Bechtel

DATE: 15/08/2013 CREATED BY: hibberde

Methane Compressor Gas Turbine (with WHR) RP6 1TC-1621

Table 3: Key Emissions Sources

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5.0 Performance Criteria

5.1 Legislation and Standards

5.2 Performance Criteria

Nuisance (Dust and Odour)

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6.0 Management Measures

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Table 4: Management Measures

6.1 Greenhouse Gas Emissions

6.2 Dust and Odour

6.3 Fugitive Emissions

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Performance Criteria Management Measure Responsibility

6.5 Fuel Burning

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Performance Criteria Management Measure Responsibility

6.6 Point Source Emissions

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7.0 Monitoring and Reporting

The QGC Central Environmental Team will oversee monitoring in response to

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Table 5: Monitoring and Reporting Requirements