1

AGL and APA Gas Import and Pipeline Project

Peer Review of AECOM Air Quality Impact

Assessment Report

Expert Witness Statement – Dr Graeme Ross

Inquiry and Advisory Committee

(IAC)

Consulting Air pollution Modelling and Meteorology

October 2020

2

Presentation Overview

• Peer review of EES Technical Report G - Air

Impact Assessment:

– Process

– Opinions - Review Outcomes

• Construction Impact Assessment

• Operational Impact Assessment

• Additional Opinions: – TRG Comments Register

– Public Submissions

– EPA Submission

– Technical Advice #2 – Colin McIntosh

• Conclusions

3

Peer Review

4

Peer Review - Process

Current Peer Review based on:

o Air quality impact assessment – EES Technical Report G

o Suite of AERMOD input files used to produce the results in the Technical

Report - Gas-fuelled FSRU modelling

Iterative Approach based on previous report versions with updates re:

o Sensitivity test re influence of the LNG carrier

o Inclusion of a ‘Normal’ operating scenario

o Addition of a preliminary HHRA - Formaldehyde

5

Construction Impact Assessment

6

Construction Impact Assessment

Pipeline Works – Dust Impact Assessment

I consider that:

• The adoption of the IAQM methodology + industry standard

practice is appropriate

• The methodology has been applied in accordance with the

guideline document

7

Conclusions – Construction Impact Assessment

Dust emissions

I confirm the following key conclusions and outcomes:

Mitigation

• Residual risk – low or very low

• I recommend that MM-AQ07 be extended to include

monitoring of fine particulates

8

Operational Impact Assessment

9

Operational Impact Assessment

OVERVIEW

I consider that:

• The operational impact assessment has been

conducted in accordance with SEPP (AQM)

• The modelling assessment follows the requirement of

Schedule C – SEPP (AQM)

• The following 10 slides provide details of the modelling

approach

10

Modelling Concept

Inputs

Emissions data

Meteorology

Geophysical

conditions

Concentration

of

pollutant

in

space and time

Air Quality

Objective

Atmospheric

Dispersion

Model

Mathematical Model Outputs

11

Modelling Concept cont’d

12

Impact Assessment Criteria

• Design criterion

– State Environment Protection Policy (Air Quality

Management) – SEPP(AQM)

13

Model Choice & Configuration

• Choice of Model

I consider AERMOD appropriate: • Current regulatory model

• Local scale impacts

• Consistent with best available meteorology

• Model configuration

I consider:

• General configuration/options - ‘accepted industry practice’

• LOW_WIND option - appropriate

• NOX to NO2 conversion – appropriate & conservative

14

Modelling Domain and Sensitive Receptors

Inner Grid – 4 km x 4 km @ 100 m resolution

38 Sensitive/Discrete receptors

15

Model Inputs – Meteorology & ‘Building/Structure Influences

Meteorology:

– Source & creation of meteorological files for 2014 - 2018:

• Based on best available data & representative of local conditions

• Created in accordance with EPAV guidance document

• See also further comments later re EPA Submission

Building/Structure Influences - FSRU:

Treatment of FSRU wake effects on emission plumes:

• I consider that BPIP/PRIME approach and key input dimensions

– appropriate & represent ‘accepted industry practice’

• I have conducted an independent check of the approach & outcomes

16

Model Inputs – Sources & Emissions

• I have reviewed the suite of modelling input files covering Scenario’s 1, 2 & 3 & consider:

– Representation of sources and emission characteristics

in input files are consistent with Report for all three scenarios.

• A full review of the following were beyond my brief

– The selection of emission scenarios

– The emissions inventories and their basis

– Scenario 4 – Liquid fuelled

17

Model Inputs – Background Concentrations

• I consider:

– Adopted background concentrations to be ‘ultra-

conservative’ due to:

• Choice of 70th percentile

• Correction methodology from 24-hour values to 1-hour values –

e.g.

– adopted NO2 background of 54.7 ug/m3

– cf.

– preferred background of approx. 27 ug/m3

Assessment Results - Operational Impacts

18

Assessment Results - Maximum GLC - sensitive

receptor predictions – Scenarios 2 &3

Compliance – all pollutants

19

Independent verification

• Conducted independent check/verification of

modelling result for:

– NO2 & Formaldehyde emissions

– Scenario’s 1, 2 & 3 – Gas-fuelled FSRU

– Year 2014 meteorology

• Results checked/verified for:

– Predictions at sensitive receptor with highest

impact (Receptor #33)

– Predicted contour plots

20

21

Independent Model Predictions

Next 2 slides illustrate the following examples:

NO2

Scenario 3 - Contour plots

Formaldehyde

Scenario 3 - Contour plots

22

Scenario 3 – NO2

(Sensitive Receptor #33 -75.4 ug/m3, 39.7% design criterion)

23

Scenario 3 – Formaldehyde

(Sensitive Receptor #33 – 20.4 ug/m3, 51% design criterion)

24

Sensitive Receptor #33 – Frequency Plot

25

CONCLUSIONS

26

Conclusions – Operational Impact Assessment

• Emission to air from FSRU – Scenario’s 1 – 3 – Comply with SEPP (AQM) design criteria – Sensitive Receptors

– Produce exceedances within approximately:

• 50 metres of FSRU – NO2 (all scenarios)

• 200 metres of FSRU, over-water areas to the south & east, and small

areas of the Crib Point foreshore – Formaldehyde (gas-fuelled scenarios)

• Exceedances require a ‘risk assessment’

– NO2 exceedances – low risk, based on:

• Implementation of an exclusion zone – safety

• ‘Ultra-conservative’ predictions

– Formaldehyde exceedances

• See evidence of Dr Drew

27

Additional Opinions & Response to Submissions

28

Additional Opinions & Response to Submissions

TRG Comments Register:

Choice of Model – Coastal Influences

Comment ID No’s #19,25 & 35 raise the issue of using AERMOD for an assessment in a

coastal location.

Response:

I consider the adoption of AERMOD to be appropriate and able to represent and

incorporate the key drivers of the impacts for this case.

Background Concentrations:

Comment ID No’s #9 & 15 raise issues re the background concentrations adopted.

Response:

Refer to previous comments.

29

Additional Opinions & Response to Submissions

EPA Submission:

Response:

o TAPM is a complete package, continues to be supported, and the approach adopted

has been accepted by EPA for numerous assessments.

o TAPM has a published base of verification studies & additional information

requested from AECOM provides further checking in regard to the important role of

solar radiation in determining the current meteorology.

Response:

o No relevant hourly data are available and 70th percentile is acceptable.

o Values adopted by AECOM are ultra-conservative.

30

Additional Opinions & Response to Submissions

EPA Submission:

Response:

o EPA recommendation is an appropriate mitigation measure subject to the outcomes

of the recommended testing of emission rates.

Response:

o AECOM already provides the results of the recommended assessment in Appendix D

of the Technical Report.

o The role of SEPP (AAQ) in assessing the impact of a specific source(s) requires

clarification.

31

Additional Opinions & Response to Submissions

General Submissions:

General & specific concerns re dust, fine particulates, hydrocarbon & odour

Response:

o Refer to recommended extension to mitigation measure MM-AQ07 – re dust.

o Refer to recommended extension to mitigation measure MM-AQ11 re formaldehyde.

o Refer to evidence of Dr Drew re HHRA.

o Refer to conclusions re compliance with SEPP(AQM).

32

Additional Opinions & Response to Submissions

Review of Mitigation Measures:

o MM-AQ01-06 are appropriate for construction activities

o MM-AQ07 should be extended to include monitoring of fine particulates

o MM-AQ09 are appropriate for operational activities

o MM-AQ11 should be extended to specifically include formaldehyde

testing to confirm emission rates

Confirmed in “Day1 EPRs”

33

Additional Opinions & Response to Submissions

Technical Advice #2 – Colin McIntosh:

Issue #1 – Appropriate “worst case” modelling of emissions

• I agree with the “Reason” provided

• However:

– The modelled ‘worst case’ has already triggered a risk assessment, testing of the

emission rates and possibly monitoring

– Compliance at all sensitive receptors still results for a 20% increase in emissions

Issue #2 – Adequacy of risk assessment

• Consideration of mitigation measures needs to be in keeping with the significance of

the risk

• The screening assessment and Dr Drew’s assessment suggest a low risk.