Your ref: L5366/1972/14 Government of Western Australia Our ref: 2010/007578 Department of Environment Regulation Enquiries: Peter Johns Phone: (08) 9333 7522 Fax: (08) 9333 7550 Email: [email protected]

Mr Leigh Amos Manager, Leith Road NAVAL BASE WA 6165

Dear Mr Amos

ENVIRONMENTAL PROTECTION ACT 1986 — AMENDMENT TO LICENCE

Licence: L5366/1972/14 Premises: Kwinana Power Station

Further to my letter dated 20 March 2015, please find enclosed your amended Environmental Protection Act 1986 licence, If you have any questions or objections relating to the licence, please do not hesitate to contact the enquiries officer above on (08) 9333 7522 for clarification or discussion of any grievances you have. If you are concerned about, or object to any aspect of the amendment, you may lodge an appeal with the Minister for the Environment within 21 days from the date on which this licence is received. The Office of the Appeals Convenor can be contacted on 6467 5190 to find out the procedure and fee. Members of the public may also appeal the amendments. The Appeals Registrar at the Office of the Appeals Convenor can be contacted after the closing date of appeals to check whether any appeals were received. Yours sincerely

Ed Schuller Officer delegated under Section 20 of the Environmental Protection Act 1986

16 April 2015 enc: copy to: Local Government Authority: 0 2. TL0571 v

The Atrium, 168 St Georges Terrace, Perth WA 6000 Phone (08) 6467 5000 Fax (08) 6467 5562 Postal Address: Locked Bag 33, Cloisters Square, Perth WA 6850 www.derva.gov.au Government of Western Australia Department of Environment Regulation

AprLicence

Environmental Protection Act 1986, Part V

Licensee: Electricity Generation and Retail Corporation T/A Synergy Licence: L5366/1972/14

Registered office: Australia Place, 11th Floor 15-17 William St PERTH WA 6000

ACN:

Premises address: Kwinana Power Station Part of Lot 22 on Diagram 72310, Weston Street; Part of Lot 218 on Plan 215932; and Lot 3002 on Plan 46763, Barter Road NAVAL BASE WA 6165 as depicted in Schedule 1.

Issue date: Thursday 16 August 2012

Commencement date: Monday 20 August 2012

Expiry date: Saturday 19 August 2017

Prescribed Premises Category Schedule 1 of the Environmental Protection Regulations 1987 Category production or design capacity Approved premises Category Category production or design number description capacity 12 Screening, etc. of 50000 tonnes or more per year 50 000 tonnes per annual material geriod 52 Electric power 20 megawatts or more in aggregate (using generation natural gas) 860 MWe 10 megawatts or more in aggregate (using a fuel other than natural +as Bulk material loading 100 tonnes or more per day 58 1500 tonnes per day or unloadin. Liquid waste facility 100 tonnes or more per year 11500 tonnes per annual 61 period Bulk storage of 1000 cubic metres in aggregate 73 188,655 m3 chemicals, etc. Conditions This Licence is subject to the conditions set out in the attached pages.

Officer delegated under section 20 of the Environmental Protection Act 1986

Environmental Protection Act 1986 Page 1 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

Contents Licence 1 Contents 2 Introduction 2 Licence Conditions 5 1 General 5 2 Emissions 10 3 Monitoring 13 4 Improvements 17 5 Information 18 6 EPP monitoring requirements 21 Schedule 1: Maps 21 Schedule 2: Reporting & notification forms 27 Schedule 3: Data format 36 Introduction

This Introduction is not part of the Licence conditions.

DER's industry licensing role The Department of Environment Regulation (DER) is a government department for the state of Western Australia in the portfolio of the Minister for Environment. DER's purpose is to advise on and implement strategies for a healthy environment for the benefit of all current and future Western Australians.

DER has responsibilities under Part V of the Environmental Protection Act 1986 (the Act) for the licensing of prescribed premises. Through this process DER works with the business owners, community, consultants, industry and other representatives to prevent, control and abate pollution and environmental harm to conserve and protect the environment. DER also monitors and audits compliance with works approvals and licence conditions, takes enforcement action as appropriate and develops and implements licensing and industry regulation policy.

Licence requirements This Licence is issued under Part V of the Act. Conditions contained within the Licence relate to the prevention, reduction or control of emissions and discharges to the environment and to the monitoring and reporting of them.

Where other statutory instruments impose obligations on the Premises/Licensee the intention is not to replicate them in the licence conditions. You should therefore ensure that you are aware of all your statutory obligations under the Act and any other statutory instrument. Legislation can be accessed through the State Law Publisher website using the following link: http://wvvw.s1 wa. qov. au/leo is lation/statutes. nsf/defau It. htm I

For your Premises relevant statutory instruments include but are not limited to obligations under the:

• Environmental Protection (Unauthorised Discharges) Regulations 2004 — these Regulations make it an offence to discharge certain materials such as contaminated stormwater into the environment other than in the circumstances set out in the Regulations.

• Environmental Protection (Controlled Waste) Regulations 2004 - these Regulations place obligations on you if you produce, accept, transport or dispose of controlled waste.

• Environmental Protection (Noise) Regulations 1997— these Regulations require noise emissions from the Premises to comply with the assigned noise levels set out in the Regulations.

Environmental Protection Act 1986 Page 2 of 36 Licence: L5366/1972114 Amendment date: Thursday, 16 April 2015 File Number: 2010/047578 IRLB_TI0679 v2.E Government of Western Australia Department of Environment Regulation

You must comply with your licence. Non-compliance with your licence is an offence and strict penalties exist for those who do not comply.

Licence holders are also reminded of the requirements of section 53 of the Act which places restrictions on making certain changes to prescribed premises unless the changes are in accordance with a works approval, licence, closure notice or environmental protection notice.

Licence fees If you have a licence that is issued for more than one year, you are required to pay an annual licence fee prior to the anniversary date of issue of your licence. Non payment of annual licence fees will result in your licence ceasing to have effect meaning that it will no longer be valid and you will need to apply for a new licence for your Premises.

Ministerial conditions If your Premises has been assessed under Part IV of the Act you may have had conditions imposed by the Minister for Environment. You are required to comply with any conditions imposed by the Minister.

Premises description and Licence summary Kwinana power station (KPS) is located in an area zoned as "general industry" under the Town of Kwinana's Town Planning Scheme No. 2. Cockburn Sound, which is subject to the State Environmental (Cockburn Sound) Policy 2005, is located to the west of the Premises and Alcoa's Kwinana Alumina Refinery is located to the north. Other surrounding land uses include heavy industry and the Kwinana industrial area. The nearest residential area is located approximately 1km east and the Naval Base Holiday Village is located approximately 2km north of KPS.

KPS is a mid merit power station and as such rarely runs at full capacity outside the summer peak period between November and March. KPS emits emissions to air via five discharge stacks; Stage A, Stage C, Gas Turbine KWGT1, and HEGTs KWGT2 and KWGT3. Boiler Units 1 and 2 feed the Stage A stack, Boiler Units 5 and 6 feed the Stage C stack and the Gas Turbines each have a single source emission point. Stage A, the oldest part of KPS, was put on Care and Maintenance in October 2011 and was decommissioned in 2013. Stage C- Unit 5 was shut down on 30 June 2014 and Unit 6 is scheduled to be decommissioned in April 2015. There are 7 electricity generating units at KPS. Each unit's electricity generating and fuel burning capabilities are detailed below. Each stage is serviced by one exhaust stack.

Production design capacities of different units at Kwinana Power Station UNIT CAPACITY (MWe) FUEL Stage A —Unit 1 120 , or Gas Stage A — Unit 2 120 Coal, or Gas Stage C — Unit 5 200 Coal, Gas or Low sulfur distillate Stage C — Unit 6 200 Coal, Gas or Low sulfur distillate KWGT1 - Gas Turbine 20 Gas or Low sulfur distillate KWGT2 — HEGT1 100 Gas or Ultra Low sulfur distillate KWGT3 — HEGT2 100 Gas or Ultra Low sulfur distillate

Main air emissions from operation of the power station include nitrogen oxides, sulfur dioxide and particulates. Each coal-fired boiler at KPS has two electrostatic precipitators (ESPs) followed by an optical density (opacity) meter. The fly ash accumulated on ESP plates is removed, slurried and pumped off site through a pipeline to Perron Quarry, which holds licence L4193/1989/11. KPS has an ISO 14001 certified Environmental Management System.

KPS is located within the area regulated under the Environmental Protection (Kwinana) (Atmospheric Wastes) Regulations 1992 and the Environmental Protection (Kwinana) (Atmospheric Waste) Policy 1999 (EPP). The EPP prescribes stack SO2 emission limit for the KPS. Synergy is also required to undertake ambient air monitoring as per the requirements of the EPP.

Environmental Protection Act 1986 Page 3 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.f Government of Western Australia Department of Environment Regulation

This Licence is the result of an amendment sought by DER to include standard conditions as part of the REFIRE program. The licences and works approvals issued for the Premises since 20/07/2006 are:

Instrument log Instrument Issued Description L5366/1972/11 27/07/2006 Reissue of Licence. L5366/1972/11 16/08/2007 Reissue of Licence. L5366/1972/12 14/08/2008 Reissue of Licence. L5366/1972/13 12/11/2009 Reissue of Licence. Tenure of Licence increased from 1 to 3 years. W4593/2009/1 25/3/2010 Construction of two 100 MW HEGTs to replace Stage B units at KPS. L5366/1972/14 16/08/2012 Reissue of Licence. L5366/1972/14 27/03/2013 Licence Amendment to include operation of two HEGTs. L5366/1972/14 18/12/2014 Licence Amendment to REFIRE format and to include improvement requirements relating to Predictive Emissions Monitoring System as per Synergy's licence amendment application. L5366/1972/14 This Licence amendments to implement PEMS Monitoring for NOx Amendment on HEGTs

Severance It is the intent of these Licence conditions that they shall operate so that, if a condition or a part of a condition is beyond the power of this Licence to impose, or is otherwise ultra vires or invalid, that condition or part of a condition shall be severed and the remainder of these conditions shall nevertheless be valid to the extent that they are within the power of this Licence to impose and are not otherwise ultra vires or invalid.

END OF INTRODUCTION

Environmental Protection Act 1986 Page 4 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

Licence Conditions

1 General

1.1 Interpretation

1.1.1 In the Licence, definitions from the Environmental Protection Act 1986 apply unless the contrary intention appears.

1.1.2 For the purposes of this Licence, unless the contrary intention appears:

'Act' means the Environmental Protection Act 1986;

'AB Cooling Water Canal' means canal where cooling from Kwinana Power Station Stage A, KWGT2 and KWGT3 is discharged;

'annual period' means the inclusive period from 1 July until 30 June in the following year;

'AS 3580.1.1' means the Australian Standard AS 3580.1.1 Methods for sampling and analysis of ambient air— Guide to siting air monitoring equipment;

'AS 3580.4.1' means the Australian Standard AS 3580.4.1 Methods for sampling and analysis of ambient air - Determination of sulfur dioxide - Direct reading instrumental method;

'AS 3580.2.2' means the Australian Standard AS 3580.2.2 Methods for sampling and analysis of ambient air - Preparation of reference test atmospheres - Compressed gas method;

'AS 3580.14' means the Australian Standard AS 3580.14 Methods for sampling and analysis of ambient air - Meteorological monitoring for ambient air quality monitoring applications;

'AS 4323.1' means the Australian Standard AS4323.1 Stationary Source Emissions Method 1: Selection of sampling positions;

'AS/NZS 5667.1' means the Australian Standard AS/NZS 5667.1 Water Quality — Sampling — Guidance of the Design of sampling programs, sampling techniques and the preservation and handling of samples;

'AS/NZS 5667.4' means the Australian Standard AS/NZS 5667.4 Water Quality — Sampling — Guidance on sampling from lakes, natural and man-made;

'ASINZS 5667.6' means the Australian Standard AS/NZS 5667.6 Water Quality — Sampling — Guidance on sampling of rivers and streams;

'AS/NZS 5667.9' means the Australian Standard AS/NZS 5667.9 Water Quality — Sampling — Guidance on sampling from marine waters;

'AS/NZS 5667.10' means the Australian Standard AS/NZS 5667.10 Water Quality — Sampling — Guidance on sampling of waste waters;

'averaging period' means the time over which a limit or target is measured or a monitoring result is obtained;

'CEMS' means continuous emissions monitoring system;

'GEMS Code' means the current version of the Continuous Emission Monitoring System (GEMS) Code for Stationary Source Air Emissions, Department of Environment & Conservation, Government of Western Australia;

Environmental Protection Act 1986 Page 5 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

`' means the prescribed premises which holds current version of Licence L7860/2003 issued under the Act;

'code of practice for the storage and handling of dangerous goods' means the document titled 'Storage and handling of dangerous goods: Code of Practice' published by the Department of Mines and Petroleum, as amended from time to time;

`dangerous goods' has the meaning defined in the Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007;

`CEO' means Chief Executive Officer of the Department of Environment Regulation;

`CEO' for the purpose of correspondence means; Manager Licensing (Greater Swan) Department of Environment Regulation Locked Bag 33 CLOISTERS SQUARE WA 6850 Telephone: (08) 9333 7510 Facsimile: (08) 9333 7550 Email: qrswanbooragoonder.wa.qov.au;

`environmentally hazardous material' means material (either solid or liquid raw materials, materials in the process of manufacture, manufactured products, products used in the manufacturing process, by-products and waste) which if discharged into the environment from or within the premises may cause pollution or environmental harm. Note: Environmentally hazardous materials include dangerous goods where they are stored in quantities below placard quantities. The storage of dangerous goods above placard quantities is regulated by the Department of Mines and Petroleum;

'EPP' means the Environmental Protection (Kwinana) (Atmospheric Wastes) Policy 1999;

'ESP' means electrostatic precipitator;

'Filterable Reactive Phosphorous' means the total phosphorous concentration filtered through a 0.45 micron filter paper;

`fugitive emissions' means all emissions not arising from point sources identified in Sections 2.2, 2.3, 2.4 and 2.5;

`HEGT1 means the High Efficiency Gas Turbine constructed and commissioned under works approval W4593/2009/1;

`ISO' means International Organisation for Standardisation;

'KWGT' means Kwinana Gas Turbine;

'Licence' means this Licence numbered L5366/1972/14 and issued under the Act;

`Licensee' means the person or organisation named as Licensee on page 1 of the Licence;

`MWe' means power output (electricity generated) in megawatts;

NATA' means the National Association of Testing Authorities, Australia;

`NATA accredited' means in relation to the analysis of a sample that the laboratory is NATA accredited for the specified analysis at the time of the analysis;

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`normal operating conditions' means any operation of a particular process (including abatement equipment) excluding start-up, shut-down and upset conditions, in relation to stack sampling or monitoring;

`NOx' means oxides of nitrogen, calculated as the sum of nitric oxide and nitrogen dioxide and expressed as nitrogen dioxide;

`oily water separator' means waste water treatment system which separates oil from water as depicted in Schedule 1;

`PEMS' means predictive emissions monitoring system;

`ppm' means parts per million;

`Premises' means the area defined in the Premises Map in Schedule 1 and listed as the Premises address on page 1 of the Licence;

`Relevant Determination' means a determination under clause 7(3) of the Environmental Protection (Kwinana) (Atmospheric Wastes) Policy 1999 determining the sulfur dioxide limits for the Licensee;

'Schedule 1' means Schedule 1 of this Licence unless otherwise stated;

`Schedule 2' means Schedule 2 of this Licence unless otherwise stated;

`shut-down' means the period when plant or equipment is brought from normal operating conditions to inactivity;

`six monthly' means the 2 inclusive periods from 1 July to 31 December and 1 January to 30 June in the following year;

`stack test' means a discrete set of samples taken over a representative period at normal operating conditions;

`STP dry' means standard temperature and pressure (0° Celsius and 101.325 kilopascals respectively), dry;

`USEPA' means United States (of America) Environmental Protection Agency;

`USEPA Method 2' means the Test Method 2 — Determination of Stack Gas Velocity and Volumetric Flow Rate;

`USEPA Method 3' means the Test Method 3 — Gas Analysis for the Determination of Dry Molecular Weight;

`USEPA Method 4' means the Test Method 4 — Determination of Moisture Content in Stack Gases;

`USEPA Method 5' means the Test Method 5— Determination of Particulate Matter Emissions from Stationary Sources;

'USEPA Method 6C' means the Test Method 6C- Determination of Sulfur Dioxide Emissions from Stationary Sources (Instrumental Analyzer Procedure);

`USEPA Method 7E'means the Test Method 7E - Determination of Nitrogen Oxide Emissions from Stationary Sources (Instrumental Analyzer Procedure);

`USEPA Method 10' means the Test Method 10- Determination of Carbon Monoxide Emissions from Stationary Sources;

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Government of Western Australia Department of Environment Regulation

`LISEPA Method 17' means the Test Method 17— Determination of Particulate Matter Emissions from Stationary Sources (In stack filtration); and

`LISEPA PS 16' means the Performance Specification 16 — Predictive Emissions Monitoring Systems; and

`usual working day' means 0800 — 1700 hours, Monday to Friday excluding public holidays in Western Australia.

1.1.3 Any reference to an Australian or other standard in the Licence means the relevant parts of the standard in force from time to time during the term of this Licence.

1.1.4 Any reference to a guideline or code of practice in the Licence means the version of that guideline or code of practice in force from time to time, and shall include any amendments or replacements to that guideline or code of practice made during the term of this Licence.

1.2 General conditions

1.2.1 Nothing in the Licence shall be taken to authorise any emission that is not mentioned in the Licence, where the emission amounts to: (a) pollution; (b) unreasonable emission; (c) discharge of waste in circumstances likely to cause pollution; or (d) being contrary to any written law.

1.2.2 The Licensee shall operate and maintain all pollution control and monitoring equipment to the manufacturer's specification or any relevant and effective internal management system.

1.2.3 The Licensee, except where storage is prescribed in section 1.3, shall only store environmentally hazardous materials if: (a) they are stored in accordance with the code of practice for the storage and handling of dangerous goods; or (b) they are stored within compounds or vessels that: (i) were constructed prior to 18/12/2014; (ii) have not previously met the requirements of conditions 1.2.3(a); and (iii) are the subject of improvement requirements 1R2 in section 4.

1.2.4 The Licensee shall immediately recover, or remove and dispose of spills of environmentally hazardous materials outside an engineered containment system.

1.2.5 The Licensee shall implement all practical measures to prevent stormwater run-off becoming contaminated by the activities on the Premises.

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1.3 Premises operation

1.3.1 The Licensee shall ensure that material specified in Table 1.3.1 is only stored and/or treated within vessels or compounds provided with the infrastructure detailed in that Table.

Table 1.3.1: Containment infrastructure Vessel or compound Material Requirements

Coal stockpile storage area Coal Compacted in-situ soils.

Storage of bottom ash and treated wastewater from the oil water separator generated on Clay lined with underdrainage the Premises and system and geofabric liner. Any Ash storage dam leachate collected to be reused Storage of process wastewater in the ashing process. generated on the Cockburn Power Station as required.

1.3.2 The Licensee shall only allow waste to be accepted on to the Premises if it is of a type listed in Table 1.3.2.

Table 1.3.2: Waste acceptance Waste Quantity Limit Specification' Process wastewater generated at To be stored in the Ash storage dam Cockburn Power specified in Table 1.3.1. Station Contaminated None specified stormwater To be directed to the oil water separator for generated at final disposal in the Ash storage dam Cockburn Power specified in Table 1.3.1. Station Note 1: Additional requirements for the acceptance of controlled waste are set out in the Environmental Protection (Controlled Waste) Regulations 2004.

1.3.3 The Licensee shall ensure that all wastewater that may be contaminated with hydrocarbons is directed to the oily water separator as depicted in Schedule 1.

Environmental Protection Act 1986 Page 9 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_TI0679 v2.E Government of Western Australia Department of Environment Regulation

2 Emissions

2.1 General

2.1.1 The Licensee shall record and investigate the exceedance of any descriptive or numerical limit or target specified in any part of section 2 of this Licence.

2.2 Point source emissions to air

2.2.1 The Licensee shall ensure that where waste is emitted to air from the emission points in Table 2.2.1 and identified on the map of emission points in Schedule 1 it is done so in accordance with the conditions of this Licence.

Table 2.2.1: Point source emission points to air Emission point Emission Emission Source, including any abatement reference and Point point height location on Map of (m) emission points

Al Stage A Stack 114 Boiler Unit 1 and 2. ESPs installed. A2 Stage C Stack 189 Boiler Unit 5 and 6. ESPs installed. A3 KWGT1 Stack 8 Gas Turbine fired on natural gas or low sulfur distillate. A4 KWGT2 Stack 60 HEGT Unit 1 Gas Turbine fired on natural gas or low sulfur distillate, Wet Low NOx burner A5 KWGT3 Stack 60 HEGT Unit 2 Gas Turbine fired on natural gas or low sulfur distillate. Wet low NOx burner.

2.2.2 The Licensee shall not cause or allow point source emissions to air greater than the limits listed in Table 2.2.2.

2.2.3 The Licensee is exempt from compliance from condition 2.2.2. if in the case of an event in Table 2.2.4 the corresponding management action is taken.

Table 2.2.2: Point source emission limits to air Emission Parameter Fuel type Limit Averaging period point (including reference units)1' 2 Natural gas 1 hour average 70 mg/m3 A4, A5 NOx Ultra low 1 hour average Sulphur diesel 150 mg/m3

Note 1: All units are referenced to STP dry and to 15% 02. Note 2: Limits apply for power output greater than or equal to 20114We.

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2.2.3 The Licensee shall target point source emissions to air at or below the levels specified in Table 2.2.3.

Tale 2.2.3: Point source emission targets to air Emission Parameter Fuel type Target Averaging period point (including units)' reference Al, A2 Particulates Coal 250 mg/m' CEMS (1 hour average) Al NOx Natural Gas 1000 mg/m' 1 hour average A2 NOx or Distillate 500 mg/m3 1 hour average A3 NOx 350 mg/m" 1 hour average Note 1: All units are referenced to STP dry Note 2: Units for A1-A2 (except particulates) are referenced to 7% 02. Note 3: Units for A3-A5 (except particulates) are referenced to 15% 02.

2.2.4 The Licensee shall take the specified management action in the case of an event in Table 2.2.2 or 2.2.3.

Table 2.2.4: Management actions Emission Event/ Event Management action point action reference reference Al — A2 EA1 USEPA Performance The Licensee shall notify the CEO in Specification 11 CEMS writing 7 days prior to commencement of correlation via manual stack the annual GEMS calibration curve sampling causes correlation. exceedance of Particulates target Al -A5 EA2 Start up and shutdown The Licensee shall take all practical measures to minimise emissions. Al-A2 EA3 Any time the CEMS is The Licensee shall take all practical indicating that particulate measures to minimise particulates emissions exceed the emissions below the relevant target in relevant target in Table 2.2.3 Table 2.2.3.

The Licensee shall reduce feed within 60 minutes of the start of any event unless particulate emissions have already dropped below the relevant target in Table 2.2.3. A4-A5 EA4 Running without NOx water The Licensee shall notify the CEO in injection pumps for the writing a minimum of 24 hours prior to purpose of developing the commencement of testing without NOx PEMS model which may pumps. result in an exceedance of the NOx emission limits

Environmental Protection Act 1986 Page 11 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

2.3 Point source emissions to surface water

2.3.1 The Licensee shall ensure that where waste is emitted to surface water from the emission points in Table 2.3.1 and identified on the map of emission points in Schedule 1 it is done so in accordance with the conditions of this Licence.

Table 2.3.1: Emission points to surface water Emission point Emission point Description Source reference and reference on Map location on Map of of emission points emission points W1 Stage C cooling Discharge canal to Cooling water and RO water canal Cockburn Sound wastewater discharged to W2 Stage AB cooling Cockburn Sound water canal

2.3.2 The Licensee shall not cause or allow point source emissions to surface water greater than the limits listed in Table 2.3.2.

2.3.3 The Licensee is exempt from compliance from condition 2.3.2. if in the case of an event in Table 2.3.3 the corresponding management action is taken.

Table 2.3.2: Point source emission limits to surface water Emission Monitoring Parameter Limit Averaging period point point (including reference reference units) W2 KPI I, KPI2 Temperature variation 9 ° Celsius Continuous between seawater (60 minute intake (KPI1) and average) discharge (KPI2) KPI2 Total Residual Chlorine 0.5 ppm Continuous (60 minute average)

2.3.4 The Licensee shall take the specified management action in the case of an event in Table 2.3.3.

Table 2.3.3: Management actions Emission Event/ Event Management action point action reference reference W2 EA5 Any time the monitoring The Licensee shall investigate the cause indicates that temperature of exceedance of the Limit and rectify variation between intake and the cause as soon as practicable such discharge water in Stage AB that the temperature variation returns cooling water canal exceeds below the Limit specified in Table 2.3.2 the limit specified in Table within 6 hours of the start of the event. 2.3.2.

2.4 Point source emissions to groundwater

There are no specified conditions relating to point source emissions to groundwater in this section.

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Government of Western Australia Department of Environment Regulation

2.5 Emissions to land

There are no specified conditions relating to emissions to land in this section.

2.6 Fugitive emissions

2.6.1 The Licensee shall ensure that no visible dust generated from coal storage, transfer or the electricity generation process crosses the boundary of the premises.

2.7- 2.8 Odour and Noise

There are no specified conditions relating to odour and noise in these sections.

3 Monitoring

3.1 General monitoring

3.1.1 The licensee shall ensure that: (a) all water samples are collected and preserved in accordance with AS/NZS 5667.1; (b) all wastewater sampling is conducted in accordance with AS/NZS 5667.10; (c) all surface water sampling is conducted in accordance with AS/NZS 5667.4, AS/NZS 5667.6 or AS/NZS 5667.9 as relevant; and (d) all laboratory samples are submitted to and tested by a laboratory with current NATA accreditation for the parameters being measured.

3.1.2 The Licensee shall ensure that : (a) monthly monitoring is undertaken at least 15 days apart; (b) six monthly monitoring is undertaken at least 3 months apart; and (c) annual monitoring is undertaken at least 9 months apart.

3.1.3 The Licensee shall record production or throughput data and any other process parameters relevant to any non-continuous, CEMS or PEMS monitoring undertaken.

3.1.4 The Licensee shall ensure that all monitoring equipment used on the Premises to comply with the conditions of this Licence is calibrated in accordance with the manufacturer's specifications.

3.1.5 The Licensee shall, where the requirements for calibration cannot be practicably met, or a discrepancy exists in the interpretation of the requirements, bring these issues to the attention of the CEO accompanied with a report comprising details of any modifications to the methods.

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3.2 Monitoring of point source emissions to air

3.2.1 The Licensee shall undertake the monitoring in Table 3.2.1 according to the specifications in that table.

Table 3.2.1: Monitoring of point source emissions to air Emission Parameter Units ' Averaging Frequency Method point 3 period reference Al, A2 NOx mg/m3 Stack Test Six monthly USEPA Method 7E CO (Minimum 30 USEPA Method 10 SO2 minute USEPA Method 6C average) Particulates Stack Test Six monthly USEPA Method 5 or (Minimum 60 17 minute average) Particulates n/a Continuous CEMS via suitable annual correlation of referenced particulates4 PMis Stack Test Annually USEPA Method 201A (Minimum 60 minute average) Metals - As, Be, Stack Test Annually USEPA Method 29 Cd, Co, Cr, Cu, (Minimum 60 Hg, Mn, Ni, Pb, minute Zn average)

A3 NOx Stack Test Annually USEPA Method 7E5 (Minimum 30 minute average) A4, A5 NOx Stack Test Annually USEPA Method 7E5 (Minimum 30 minute average) NOx 30 minutes Continuous USEPA PS-16 (After 30 September 2015)6 Note 1: All units are referenced to STP dry. Note 2: Units for A1-A2 are referenced to 7% 02. Note 3: Units for A3-A5 are referenced to 15% 02. Note 4: Where applicable, USEPA Performance Specification 11 including Appendix F, Procedure 2 will be used to convert and substantiate the calculation of particulate matter from raw instrument data. Note 5: The monitoring requirement shall not apply if a gas turbine is operated less than 100 hours per year. Note 6: Subject the completion of IR1, the Licensee must implement a Predictive Emissions Monitoring System (PEMS) for monitoring NOx emissions.

3.2.2 The Licensee shall ensure that sampling required under Condition 32.1 of the Licence is undertaken at sampling locations in accordance with the AS 4323.1 or relevant part of the CEMS Code.

3.2.3 The Licensee shall ensure that all non-continuous sampling and analysis undertaken pursuant to condition 3.2.1 is undertaken by a holder of NATA accreditation for the relevant methods of sampling and analysis.

3.2.4 For any parameter in Table 3.2.1 requiring continuous monitoring the Licensee shall ensure that the CEMS is regularly operated, maintained and calibrated in accordance with the CEMS Code and PEMS is operated according to the Quality Assurance Manual prepared in accordance with IR1.

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Government of Western Australia Department of Environment Regulation

3.3 Monitoring of point source emissions to surface water

3.3.1 The Licensee shall undertake the monitoring in Table 3.3.1 according to the specifications in that table.

Table 3.3.1: Monitoring of point source emissions to surface water Emission Monitoring Parameter Units Averaging Frequency point point period reference reference W1, W2 KPI2, W1 pH range - - Total phosphorus ug/L Instantaneous 7 Filterable Reactive gm/day consecutive Phosphorus days in each Total Nitrogen quarter Nitrate Nitrogen (NO3) Ammonium ion Nitrogen (NH4+) Total Residual Chlorine Metals including Aluminium, Arsenic, Cadmium, Total Chromium, Cobalt, Copper, Iron, Lead, Manganese, Mercury, Nickel and Zinc Volume of combined cooling ms/day - Daily water and wastewater discharged W2 KPI2 Total Residual Chlorine ppm Instantaneous Continuous for the Temperature °C Instantaneous duration of the discharge' Note 1: Monitoring shall be undertaken at intervals less than or equal to 60 seconds.

3.4 Monitoring of point source emissions to groundwater

There are no specified conditions relating to monitoring of point source emissions to groundwater in this section.

3.5 Monitoring of emissions to land There are no specified conditions relating to monitoring of point source emissions to groundwater in this section.

Environmental Protection Act 1986 Page 15 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

3.6 Monitoring of inputs and outputs

3.6.1 The Licensee shall undertake the monitoring in Table 3.6.1 according to the specifications in that table.

Table 3.6.1: Monitoring of inputs and outputs Input/Output Parameter Units Averaging period Frequency

KPI1 Stage AB Temperature C Instantaneous Continuous for the Cooling water inlet duration of the discharge' KPI I , KPI2 Temperature °C 60 minutes Continuous Stage AB cooling variation water inlet and between inlet outlet and outlet Note 1: Monitorina shall be undertaken at intervals less than or eaual to 60 seconds.

3.7 Process monitoring

There are no specified conditions relating to process monitoring in this section.

3.8-3.9 Ambient environmental quality monitoring and meteorological monitoring

There are no specified conditions relating to ambient environmental quality monitoring and meteorological monitoring in this section.

Environmental Protection Act 1986 Page 16 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia s Department of Environment Regulation

4 Improvements

4.1 Improvement program

4.1.1 The Licensee shall complete the improvements in Table 4.1.1 by the date of completion in Table 4.1.1.

4.1.2 The Licensee, for improvements not specifically requiring a written submission, shall write to the CEO stating whether and how the Licensee is compliant with the improvement within one week of the completion date specified in Table 4.1.1.

Table 4.1.1: Improvement program Improvement Improvement Date of reference completion IR 1 The Licensee shall submit to the CEO a Quality Assurance No later than Manual for the PEMS technology selected. The Manual shall: 30 days after (a) clearly define the operating envelope as per USEPA completion of PS 16; commissioning (b) clearly define the sensors that are used for the prediction as per USEPA PS 16; (c) provide parameters for which the sensor evaluation system deems sensors to be working as per USEPA PS 16; (d) define the PEMS principle of operation as per USEPA PS 16; (e) define actions in the instance that PEMS fails RATA; (f) define actions in the instance that the availability target is not achieved; and (g) define a programme for the development of the operating envelope whilst operating on diesel fuel. The development programme should occur in foreseeable situations or extended periods (greater than one week) where diesel fuel is burned. IR 2 The Licensee shall submit to the CEO a report on all existing 6 months from infrastructure holding environmentally hazardous materials date of issue identifying whether they are compliant with the standards in of the licence Condition 1.2.3 for new tanks. The report will include a list of actions for each non-compliant tank required to meet these requirements.

Environmental Protection Act 1986 Page 17 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.€ Government of Western Australia Department of Environment Regulation

5 Information

5.1 Records

5.1.1 All information and records required by the Licence shall: (a) be legible; (b) if amended, be amended in such a way that the original and subsequent amendments remain legible or are capable of retrieval; (c) except for records listed in 5.1.1(d) be retained for at least 6 years from the date the records were made or until the expiry of the Licence or any subsequent licence; and (d) for those following records, be retained until the expiry of the Licence and any subsequent licence: (i) off-site environmental effects; or (ii) matters which affect the condition of the land or waters.

5.1.2 The Licensee shall ensure that: (a) any person left in charge of the Premises is aware of the conditions of the Licence and has access at all times to the Licence or copies thereof; and (b) any person who performs tasks on the Premises is informed of all of the conditions of the Licence that relate to the tasks which that person is performing.

5.1.3 The Licensee shall complete an Annual Audit Compliance Report indicating the extent to which the Licensee has complied with the conditions of the Licence, and any previous licence issued under Part V of the Act for the Premises for the previous annual period.

5.1.4 The Licensee shall implement a complaints management system that as a minimum records the number and details of complaints received concerning the environmental impact of the activities undertaken at the Premises and any action taken in response to the complaint.

Environmental Protection Act 1986 Page 18 of 36 Licence: L5366/1972114 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

5.2 Reporting

5.2.1 The Licensee shall submit to the CEO an Annual Environmental Report by 13 August each year after the end of the annual period. The report shall contain the information listed in Table 5.2.1 in the format or form specified in that table.

Table 5.2.1: Annual Environmental Report Condition or table Parameter Format or form (if relevant) - Summary of any failure or malfunction of any pollution None specified control equipment and any environmental incidents that have occurred during the annual period and any action taken 2.1.1 Summary of target exceedances None specified 3.2.1 Point source emissions to air monitoring results AR1 3.2.4,3.2.5,3.2.6 CEMS or PEMS data required by any condition of this None specified Licence in electronic form Tabular and graphical representation of CEMS or PEMS data comparison with Licence limits and/or targets - Results of Dust Concentration Monitor calibrations, None specified including individual run data, correlation graphs and comparisons against previous calibration data 3.3.1, 3.3.2 Monitoring data for discharges to Cockburn Sound None specified including: (a) Weekly combined average of cooling water and wastewater discharged to Cockburn Sound in m3/day; (b) Weekly average daily concentration of and load of Nitrogen, Copper and Zinc in .igIL and gm/day; (c) Weekly average temperature difference; and (d) Daily average concentration and load of substances listed in Table 3.3.1 Cumulative load of the substances monitored as listed in None specified Table 3.3.1 and presentation of the data in graphical form. 5.1.3 Compliance AACR 5.1.4 Complaints summary None specified 5.2.4 GEMS and PEMS availability None specified Note 1: Forms are in Schedule 2

Environmental Protection Act 1986 Page 19 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

5.2.2 The Licensee shall ensure that the Annual Environmental Report also contains: (a) any relevant process, production or operational data recorded under condition 3.1.3; (b) an assessment of the information contained within the report against previous monitoring results and Licence limits and/or targets.

5.2.3 The Licensee shall submit the information in Table 5.2.2 to the CEO according to the specifications in that table.

Table 5.2.2: Non-annual reporting requirements Condition or Parameter Reporting Reporting date Format or table period (after end of the forml (if relevant) reporting period) Table 2.2.3 Target exceedance Monthly 28 calendar days ET1 - Copies of original monitoring Not Within 14 days of As received by reports submitted to the Applicable the CEOs request the Licensee Licensee by third parties from third parties Note 1: Forms are in Schedule 2

5.2.4 The Licensee shall ensure that results from CEMS and PEMS are made available on request as tabulated data and time series graphs including: (a) times and dates; (b) unavailability of abatement; (c) target or limit exceedances; and (d) an assessment of the information contained within the report against previous submissions and Licence limits and/or targets.

5.3 Notification

5.3.1 The Licensee shall ensure that the parameters listed in Table 5.3.1 are notified to the CEO in accordance with the notification requirements of the table.

Table 5.3.1: Notification requirements Condition Parameter Notification requirement Format 2 or table or form (if relevant) 2.2.2, Breach of any limit specified in the Part A: As soon as practicable but N1 2.3.2,2.6.1 Licence no later than 5pm of the next usual - Any failure or malfunction of any working day. pollution control equipment or any incident, which has caused, is Part B: As soon as practicable but causing or may cause pollution within 15 usual working days of the exceedance or breach becoming known.

2.3.3 Limit exceedance where As soon as practicable but no later EL1 management action taken than seven working days after the event. 3.1.5 Calibration report As soon as practicable. None specified Note 1: Notification requirements in the licence shall not negate the requirement to comply with s72 of the Act Note 2: Forms are in Schedule 2.

Environmental Protection Act 1986 Page 20 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

6 EPP monitoring requirements

6.1 General monitoring

6.1.1 The Licensee shall undertake monitoring required by 6.3.1 and 6.4.1 at the relevant sites specified in Table 6.1.1.

Table 6.1.1: Location of monitors Monitoring Location station EPPM1 Western Power gas pumping station, Abercrombie Road, Kwinana EPPM2 BP hydrocarbon pumping station, Miguel Road, Cockburn EPPM3 Tindal Avenue, Beeliar EPPM4 Alcoa C lakes, Kwinana

6.1.2 Monitoring stations EPPM1 — EPPM3 are to be maintained in the relevant portion of the environment, pursuant to Clause 11(1)(b) of the EPP. Monitoring stations EPPM1 and EPPM2 are permanently located at the sites described in Table 6.1.1.Monitoring station EPPM3 may be relocated in accordance with AS 3580.1.1, with written approval from the CEO. A period of one month is allowed for relocation of the monitoring station.

6.1.3 The Licensee shall control the discharge of sulfur dioxide from each source listed in the Relevant Determination within the Premises, so as to comply with the limits in the Relevant Determination.

6.1.4 As and when requested by the CEO the Licensee shall provide in written form within five working days of that request, data from the meteorological and sulfur dioxide monitoring systems covering the period specified by the CEO.

6.1.5 The Licensee shall provide the data specified in condition 6.1.4 as a time-series listing in accordance with Schedule 3.

6.2 CEMS monitoring

6.2.1 The Licensee shall establish and maintain a CEMS to monitor the discharge of waste gases from each of the sources listed in the Relevant Determination and located within the boundary of the licensed premises

6.2.2 The CEMS specified in condition 6.1.3 shall measure or otherwise estimate using approved procedures the following quantities for each specified source: (a) Concentration of sulfur dioxide in g/s; (b) Volumetric flow rate of waste gases in m3/s; (c) Calculation of sulfur dioxide mass emission rate in g/s from data generated in (a) and (b); and (d) Density of waste gases in g/m3.

6.2.3 For any CEMS operated pursuant to Condition 6.2.1 the Licensee shall ensure that the CEMS is regularly operated, maintained and calibrated in accordance with the CEMS Code.

Environmental Protection Act 1986 Page 21 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

6.3 Ambient air monitoring

6.3.1 The Licensee shall undertake the ambient monitoring specified in Table 6.3.1, as outlined in section 7.2 of EPA Bulletin 644 or otherwise as determined by the CEO.

Table 6.3.1: Ambient monitoring Monitoring station ( as Parameter Units Method depicted in Schedule 1 — Map of monitoring locations) EPPM1 — EPPM3 Sulfur dioxide ppb AS 3580.4.1 and AS 3580.2.2.

6.3.2 Prior to the commissioning of ambient sulfur dioxide monitoring and data acquisition equipment the Licensee shall obtain approval from the CEO for its use and the relevant procedures to be followed.

6.3.3 Prior to any significant changes to monitoring and data acquisition equipment the Licensee shall obtain approval from the CEO for its use and the relevant procedures to be followed.

6.3.4 The licensee shall ensure that the approved monitoring equipment referred to in condition 6.3.1 is operated and calibrated in accordance with approved procedures and is maintained so as to provide valid data for greater than 90% of the time in every calendar month, and greater than 95% of the time over any 12 consecutive calendar months.

6.4 Meteorological monitoring

6.4.1 The licensee shall undertake the meteorological monitoring specified in Table 6.4.1.

Table 6.4.1: Meteorological monitoring Monitoring station Parameter Units Method Wind speed m/s EPPM1 — EPPM4 Wind direction Degrees Air temperature °C Wind direction standard deviation Differential air temperature °C AS 3580.14 Relative humidity EPPM4 Barometric pressure hPa Net radiation W/m2 Rainfall mm

6.4.2 The licensee shall ensure that the meteorological monitoring equipment is operated and calibrated in accordance with approved procedures and is maintained so as to provide valid data for greater than 90% of the time in every calendar month, and greater than 95% of the time over any 12 consecutive calendar months.

Environmental Protection Act 1986 Page 22 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLELT10679 v2.E Government of Western Australia Department of Environment Regulation

6.5 Reporting

6.5.1 The Licensee shall submit to the CEO a monthly report within 14 calendar days after the end of the monthly period or within such period of time as is approved by the CEO. The report shall contain the information listed in Table 6.5.1 in the format or form specified in that table.

Table 6.5.1: Reporting requirements Condition Parameter Averaging period Format or table (if relevant) 6.3.1 Sulfur dioxide 24 hour average Summarised one calendar Daily maximum 60 month table, one for each minute average, which monitoring station. may span midnight Sulfur dioxide data Daily recovery (%) Sulfur dioxide 10 minute average Time series listing on an approved computer-readable medium in the format specified in Schedule 3. 6.4.1 Wind speed 10 minute average Time series listing on an Wind direction approved computer-readable Air temperature medium in the format specified Wind direction in Schedule 3. standard deviation Differential air temperature Relative humidity Barometric pressure Net radiation Rainfall 6.1.4 Calibration report Not applicable None specified

Environmental Protection Act 1986 Page 23 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

6.6 Notification

6.6.1 Parameters listed in Table 6.6.1 shall be notified to the CEO and in accordance with the notification requirements of the table.

Table 6.6.1: Notification requirements Condition Parameter Notification Format or table requirement (if relevant) 6.2.1 Exceedance of As soon as practicable None specified ambient sulfur dioxide but within two usual standard or limit for the working days. site for any of the Within five usual A listing of sulfur dioxide averaging periods as working days. emissions from each source established by the listed in the relevant EPP determination and located within the boundary of the licensed Premises, for the period which includes and extends one hour either side of the period in which the exceedance occurred.

A listing of ambient sulfur dioxide data from each monitoring station, for the period which includes and extends one hour either side of the period in which the exceedance occurred.

6.1.4 Where the As soon as practicable. Calibration report comprising requirements for details of any modifications to calibration cannot be the methods. practicably met, or a discrepancy exists in the interpretation of the requirements

Note on requirements Without limiting the Licensee's responsibility and obligation to fulfil all of the requirements for monitoring and reporting specified in requirements 6.1.1 — 6.4.1 the CEO will, if so requested by the Licensee, approve the monitoring and reporting functions being performed on behalf of The Licensee by a nominated agent, as part of a cooperative arrangement between industries. Notwithstanding this, advice on exceedances of the standard or limit together with sulfur dioxide emissions and ambient sulfur dioxide data during those exceedances as required by condition 6.5.1 must be provided directly by the Licensee.

Environmental Protection Act 1986 Page 24 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

Schedule 1: Maps

Premises map

The Premises is shown in the map below. The pink line depicts the Premises boundary.

643722 E437230111/i

6436i4firniirfir, r ,r 4.2h . 6436155mN

Page 25 of 36 Environmental Protection Act 1986 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 20101007578 IRLB_T10679 v2.E

Government of Western Australia Department of Environment Regulation

Map of emission points

The locations of the emission points defined in Tables 2.2.1 and 2.3.1 are shown below. P , N!figent) 7"I 11437535TH •t _la_ it i m I

,. A atoll -I.) - . ,!a 11 t t. alw 4.3 A3 /A4 iOily Water jh W2 1.0NGT2 stack KWGT1 stack .Separalor Stage AB lc _ Cooling Water Canal r, AS • .2 ,11 KWGT3 -- • Dams li stack

Al Stage A stack

WI Stage C Cooling Water Canal A2 Stage C stack

tt

Coal Stockpile

!311,-7- 1 • g Ft__ (4 144.. 84311110MN LEGEND C.01,0,141em Pupa Him APP-1 ag110 Fr]MOM, s_-k ISM 1.13pW.61.11..1..4NiLVIZA, Clecnaitc DatunIA iortala 12X Nvin•fia.:111.11.13• hi* ra-I ban xtri..1 wyresf.typormgee dhfreorin mannearrom...... cargo. Crum orri ride Pm End fire DM. Wh1]p1]]xle PIA

kvcrrsicri *WWI tranta rep IP.euEltn ,1411.7.1vt, In in esAMInn...... 6%. Eir ....111..erwortyr

:-..jr;%, 0 4:1-311e Pr: 4jitlx,) GPM 0111.1001 and C0111101%11.143te ray. arm" [0.11 .610, Ash. Ili w16•21:rtjt

Environmental Protection Act 1986 Page 26 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

Map of monitoring points The locations of the monitoring points defined in Table 3.6.1 are shown below.

Inlet monitoring point (heat exchangers are Outlet located inside the turbine hall) monitoring point

Stage AB canal

Map of monitoring points The locations of the monitoring points defined in Table 6.1.1 are shown below.

Environmental Protection Act 1986 Page 27 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E

Government of Western Australia Department of Environment Regulation

ItrAllirfr.v"

Miguel Road 387886 60 m E 6445888-98 m S

EPPM2

'Fuldale Avenue 387606.51 m E • • ...IP • zwr 6443908 20 m S 41.1

11412? EPPM3

r. • U Alcoa C Lakes 385852 41 m E 6435560 19 m S

EPPM4 Abecrornbie Road • 387413.56 m E 6433982 27 ni S

EPPM1

61314161M

LEGEND N I WV ..r.. 1.I••nonfilan erre 1;141Limitfm•-"-th. Er..• 'I TIM flower** 0•1•11Ausirall0 11;911 Als• 11.11 ••• Ass AVNE• Morn. •••••••• Amermr.

Ilmme r• nr new ma e,kr.•1 f...Y...••••• menne, •••.. •

• t-m....11.••t• Yot• A.. nal e.s, pa*, ru.N 11•••• contact rp..p math.. b. IMO..

Environmental Protection Act 1986 Page 28 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

Schedule 2: Reporting & notification forms

These forms are provided for the proponent to report monitoring and other data required by the Licence. They can be requested in an electronic format.

SECTION A LICENCE DETAILS Licence Number: Licence File Number:

Company Name: ABN:

Trading as:

Reporting period:

to

STATEMENT OF COMPLIANCE WITH LICENCE CONDITIONS 1. Were all conditions of the licence complied with within the reporting period? (please tick the appropriate box)

Yes ❑ Please proceed to Section C

No ❑ Please proceed to Section B

Each page must be initialled by the person(s) who signs Section C of this Annual Audit Compliance Report (AACR).

Initial:

Environmental Protection Act 1986 Page 29 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

SECTION B DETAILS OF NON-COMPLIANCE WITH LICENCE CONDITION.

Please use a separate page for each licence condition that was not complied with. a) Licence condition not complied with:

b) Date(s) when the non compliance occurred, if applicable:

c) Was this non compliance reported to DER?:

❑ Yes ❑ Reported to DER verbally ❑ No Date

❑ Reported to DER in writing Date

d) Has DER taken, or finalised any action in relation to the non compliance?:

e) Summary of particulars of the non compliance, and what was the environmental impact:

f) If relevant, the precise location where the non compliance occurred (attach map or diagram):

g) Cause of non compliance:

h) Action taken, or that will be taken to mitigate any adverse effects of the non compliance:

i) Action taken or that will be taken to prevent recurrence of the non compliance:

Each page must be initialled by the person(s) who signs Section C of this AACR

Initial:

Environmental Protection Act 1986 Page 30 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.€ Government of Western Australia Department of Environment Regulation

SECTION C

SIGNATURE AND CERTIFICATION This Annual Audit Compliance Report (AACR) may only be signed by a person(s) with legal authority to sign it. The ways in which the AACR must be signed and certified, and the people who may sign the statement, are set out below.

Please tick the box next to the category that describes how this AACR is being signed. If you are uncertain about who is entitled to sign or which category to tick, please contact the licensing officer for your premises.

If the licence holder The Annual Audit Compliance Report must be signed and is certified: o by the individual licence holder, or An individual ci by a person approved in writing by the Chief Executive Officer of the Department of Environment Regulation to sign on the licensee's behalf. a by the principal executive officer of the licensee; or A firm or other unincorporated 111 by a person with authority to sign on the licensee's behalf who is company approved in writing by the Chief Executive Officer of the Department of Environment Regulation.

LI by affixing the common seal of the licensee in accordance with the Corporations Act 2001; or o by two directors of the licensee; or 0 by a director and a company secretary of the licensee, or A corporation 0 if the licensee is a proprietary company that has a sole director who is also the sole company secretary — by that director, or D by the principal executive officer of the licensee; or 0 by a person with authority to sign on the licensee's behalf who is approved in writing by the Chief Executive Officer of the Department of Environment Regulation. p by the principal executive officer of the licensee; or A public authority by a person with authority to sign on the licensee's behalf who is (other than a local n approved in writing by the Chief Executive Officer of the government) Department of Environment Regulation. 0 by the chief executive officer of the licensee; or a local government 0 by affixing the seal of the local government.

It is an offence under section 112 of the Environmental Protection Act 1986 for a person to give information on this form that to their knowledge is false or misleading in a material particular. There is a maximum penalty of $50,000 for an individual or body corporate.

I/We declare that the information in this annual audit compliance report is correct and not false or misleading in a material particular. SIGNATURE: SIGNATURE: NAME: NAME: (printed) (printed) POSITION: POSITION: DATE: I 1 DATE:

Environmental Protection Act 1986 Page 31 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

Licence: L5366/1972/14 Licensee: Electricity Generation and Retail Corporation T/A Synergy Form: ET1 Period: Name: Target exceedances

Form ET1: Target exceedances Please provide an analysis of the target exceedances for the month, including but not limited to: (a) the emission point (b) the root cause analysis for the exceedances; (c) any common or contributory factors including but not limited to fuel, mass emissions, gas flow rates, inlet & exit temperature, abatement status; (d) a description of remedial measures taken or planned to be taken, including those taken to prevent recurrence of the exceedances; (e) complaints received that may have been caused by this exceedance; and (f) for those exceedances that may have caused complaints, meteorological details: temperature, wind speed and wind direction, humidity.

Signed on behalf of Electricity Generation and Retail Corporation T/A Synergy: Date:

Environmental Protection Act 1986 Page 32 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E

Government of Western Australia Department of Environment Regulation

Licence: L5366/1972/14 Licensee: Electricity Generation and Retail Corporation T/A Synergy Form: EL1 Date of exceedance: Name: Limit exceedance under exemption where relevant management action taken

Form ELI: Limit exceedance under exemption where relevant management action taken Emission Exemption Date & time Parameter Peak discharge Average discharge Duration of Date & time point event variation variation exceedance process reference restarted (if stopped) oc °C

Please provide details of the exceedance, including but not limited to: (a) from 1 hour prior to the exceedance to the end of the exceedance; (i) the 1 minute average data of emissions recorded by the CEMS; (b) reasons for the exceedance and any contributory factors; (c) a description of remedial measures taken (including relevant management actions) or planned to be taken, including those taken to prevent recurrence of the exceedance; (d) any impacts that may have been caused by this exceedance.

Signed on behalf of Electricity Generation and Retail Corporation T/A Synergy: Date:

Environmental Protection Act 1986 Page 33 of 36 Licence: L536611972/14 Amendment date: Thursday, 16 April 2015 Pile Number: 2010/007578 IRLB_T10679 v2.E

Government of Western Australia Department of Environment Regulation

Licence: L5366/1972/14 Licensee: Electricity Generation and Retail Corporation T/A Synergy Form: N1 Date of breach:

Notification of detection of the breach of a limit or any failure or malfunction of any pollution control equipment or any incident which has caused, is causing or may cause pollution.

These pages outline the information that the operator must provide. Units of measurement used in information supplied under Part A and B requirements shall be appropriate to the circumstances of the emission. Where appropriate, a comparison should be made of actual emissions and authorised emission limits.

Part A Licence Number Name of operator Location of Premises Time and date of the detection

Notification requirements for the breach of a limit Emission point reference/ source Parameter(s) Limit Measured value Date and time of monitoring Measures taken, or intended to be taken, to stop the emission

Notification requirements for any failure or malfunction of any pollution control equipment or any incident which has caused, is causing or may cause pollution Date and time of event Reference or description of the location of the event Description of where any release into the environment took place Substances potentially released Best estimate of the quantity or rate of release of substances Measures taken , or intended to be taken, to stop any emission Description of the failure or accident

Environmental Protection Act 1986 Page 34 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

Part B Any more accurate information on the matters for notification under Part A.

Measures taken, or intended to be taken, to prevent a recurrence of the incident.

Measures taken, or intended to be taken, to rectify, limit or prevent any pollution of the environment which has been or may be caused by the emission.

The dates of any previous N1 notifications for the Premises in the preceding 24 months.

Name Post Signature on behalf of Electricity Generation and Retail Corporation T/A Synergy Date

Environmental Protection Act 1986 Page 35 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 20101007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

Schedule 3: Data format

Note on data format The Licensee shall ensure that results of ambient air and meteorological monitoring are provided to the CEO as a space delimited time series and on a suitable computer readable medium in the following format:

SITE NAME:XXXXXXXXXX ----blank line---- column description column description ----blank line---- ddmmyyyy HHMM xxxx.xx xxxx.xx xxxx.xx ddmmyyyy HHMM xxxx.xx xxxx.xx xxxx.xx

1 ddmmyyyy HHMM xxxx.xx xxxx.xx xxxx.xx where: dd is the two digit day of the month i.e. 01, 02,...,31 mm is the two digit month of the year i.e. 01, 02,...,12 yyyy is the four digit year i.e. 2009, 2010, ... HH is the two digit hour code i.e. 01, 02,...,24 MM is the two digit minute code i.e. 05, 10, 15,...,55, 00 xxxx.xx is the format of the data represented which shall be right justified and in FORTRAN notation F7.2 or F7.1. Each datum shall be separated by at least one blank space.

The time period shall represent the end of the data period. Hence the first time stamp for any day shall be 0010 hours and the data associated with this time stamp shall be the averaged data for the period up to this time i.e. from midnight to 0010 hours.

The last time for any day shall be 2400 and the data associated with this time stamp shall be the averaged data for the period up to this time i.e. from 2350 hours to midnight (2400 hours). An example is provided below.

STATION :- GENERIC AQMS

DATE TIME SO2 SP10 WD10 SIG PM10 PRES ppb msA 2 deg deg ug/mA 2 hPa

01072011 0010 0.00 5.34 229.63 13.83 18.77 1020.2 01072011 0020 0.05 4.37 272.00 28.00 13.96 1020.2

31072011 2350 0.02 -99.00 326.04 15.66 14.34 1020.2 31072011 2400 0.02 1.37 333.12 20.10 14.89 1020.2

There shall be no gaps in the time series listing.

Environmental Protection Act 1986 Page 36 of 36 Licence: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10679 v2.E Government of Western Australia Department of Environment Regulation

Decision Document

Environmental Protection Act 1986, Part V

Proponent: Electricity Generation and Retail Corporation TIA Synergy Licence: L5366/1972/14

Registered office: Australia Place, 11th Floor 15-17 William St PERTH WA 6000

ACN:

Premises address: Kwinana Power Station Part of Lot 22 on Diagram 72310, Western Street; Part of Lot 218 on Plan 215932, Barter Road; and Lot 3002 on Plan 46763, Barter Road NAVAL BASE WA 6165

Issue date: Thursday 16 August 2012

Commencement date: Monday 20 August 2012

Expiry date: Saturday 19 August 2017

Decision

Based on the assessment detailed in this document the Department of Environment Regulation (DER), has decided to issue an amended licence. DER considers that in reaching this decision, it has taken into account all relevant considerations and legal requirements and that the Licence and its conditions will ensure that an appropriate level of environmental protection is provided.

Decision Document prepared by: Peter Johns Licensing Officer

Decision Document authorised by: Ed Schuller Manager Licensing

Environmental Protection Act 1986 Page 1 of 10 Decision Document: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10669 v2.6 Government of Western Australia Department of Environment Regulation

Contents

Decision Document 1 Contents 2 1 Purpose of this Document 2 2 Administrative summary 3 3 Executive summary of proposal and assessment 4 4 Decision table 5 5 Advertisement and consultation table 9 6 Risk Assessment 10

1 Purpose of this Document

This decision document explains how DER has assessed and determined the application and provides a record of DER's decision-making process and how relevant factors have been taken into account. Stakeholders should note that this document is limited to DER's assessment and decision making under Part V of the Environmental Protection Act 1986. Other approvals may be required for the proposal, and it is the proponent's responsibility to ensure they have all relevant approvals for their Premises.

Works approval and licence conditions DER has three types of conditions that may be imposed on works approvals and licences. They are as follows;

Standard conditions (SC)

DER has standard conditions that are imposed on all works approvals and licences regardless of the activities undertaken on the Premises and the information provided in the application. These are included as the following conditions on works approvals and licences:

Works approval conditions: 1.1.1-1.1.4, 1.2.1, 1.2.2, 5.1.1 and 5.1.2.

Licence conditions: 1.1.1-1.1.4, 1.2.1-1.2.4, 5.1.1-5.1.4 and 5.2.1.

For such conditions, justification within the Decision Document is not provided.

Optional standard conditions (OSC)

In the interests of regulatory consistency DER has a set of optional standard conditions that can be imposed on works approvals and licences. DER will include optional standard conditions as necessary, and are likely to constitute the majority of conditions in any licence. The inclusion of any optional standard conditions is justified in Section 4 of this document.

Non standard conditions (NSC)

Where the proposed activities require conditions outside the standard conditions suite DER will impose one or more non-standard conditions. These include both premises and sector specific conditions, and are likely to occur within few licences. Where used, justification for the application of these conditions will be included in Section 4.

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2 Administrative summary

Administrative details

Works Approval ❑ Application type New Licence ❑ Licence amendment I Works Approval amendment ❑ Assessed design Category number(s) capacity period050 00 tonnes per annual 12 Activities that cause the premises to become prescribed premises 52 860MWe 58 1500 tonnes per day 61 11500 tonnes per annual period 73 188,655 m3 Application verified Date: N/A Application fee paid Date:N/A Yes❑ No❑ N/A A Works Approval has been complied with Compliance Certificate received Yes• No❑ N/A El Commercial-in-confidence claim Yes❑ No 41 Commercial-in-confidence claim outcome ❑ Is the proposal a Major Resource Project? Yes No •

Was the proposal referred to the Environmental Referral decision No: ❑ Protection Authority (EPA) under Part IV of the Yes NoNo/1 Managed under Part V ❑ Environmental Protection Act 1986? Assessed under Part IV • Ministerial statement No: Is the proposal subject to Ministerial Conditions? Yes❑ Nog EPA Report No:

Does the proposal involve a discharge of waste Yes❑ Noe into a designated area (as defined in section 57 of the Environmental Protection Act 1986)? Department of Water consulted Yes ❑ No ❑

Is the Premises within an Environmental Protection Policy (EPP) Area Yes No ❑ If Yes include details of which EPP(s) here. Environmental Protection (Kwinana) (Atmospheric Wastes) Policy 1999; Environmental Protection (Kwinana) (Atmospheric Wastes) Regulations 1992; and State Environmental (Cockburn Sound) Policy 2005. Is the Premises subject to any EPP requirements? Yes /1 No ❑ If Yes, include details here, Premises is subject to SO2 requirements of Kwinana EPP.

Environmental Protection Act 1986 Page 3 of 10 Decision Document: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10669 v2.6 Government of Western Australia Department of Environment Regulation

3 Executive summary of proposal and assessment

The Electricity Generation and Retail Corporation (T/A Synergy) is a State Government trading enterprise established under the Electricity Corporation Act 2005. The Kwinana Power Station (KPS) is a mid-merit plant with the ability to burn coal, natural gas and low sulfur distillate to generate up to 860MWe of electricity for customers in the South West Interconnected System. The power station is rarely run at full capacity outside the summer peak period between • November and March. The power station emits to air through five significant discharge stacks which include Stage A, Stage C, Gas Turbine KWGT1, and the two High Efficiency gas Turbines (HEGTs) KWGT2 and KWGT3. Boiler Units 1 and 2 feed the Stage A stack, Boiler Units 5 and 6 feed the Stage C stack and the Gas Turbines each have a single source emission point. Stage A, the oldest part of KPS, was put on Care and Maintenance in October 2011 and was decommissioned in 2013. Stage C- Unit 5 was shut down on 30 June 2014 and Unit 6 is scheduled to be decommissioned in April 2015. KPS is situated in the Kwinana Industrial Strip, located approximately 40km south of Perth. Surrounding land uses include heavy industry including other electricity generating facilities such as Cockburn power station (also owned by Synergy) and the NewGen power sttaion. Alcoa Alumina Refinery is located to the north of the premises, the Desalination Plant to the south and BGC Cement is located on the south east boundary. Cockburn Sound, which is subject to the State Environmental (Cockburn Sound) Policy 2005, is directly west of the premises. All industry located in the Kwinana Industrial Area is subject to the Environmental Protection (Kwinana) (Atmospheric Wastes) Policy 1992 (EPP). The nearest residential area is located approximately 3.5km south east and the Naval Base Holiday Village is located approximately 2km north of KPS. The surface geology of the Kwinana area is comprised of highly permeable Safety Bay Sand to a depth of 15-19m. Depth to groundwater at KPS is 3-5m within the Safety Bay Sand formation and flow is west-northwest before discharging to Cockburn Sound. Current groundwater quality is moderate and lies within the salinity range of 500-1000mg/L.

Key air emissions from operation of the power station include nitrogen oxides, sulfur dioxide and particulates. Each coal-fired boiler at KPS has two electrostatic precipitators (ESPs) to reduce particulate emissions, which are measured in the stack by an optical density (opacity) meter. The fly ash accumulated on ESP plates is removed, slurried and pumped off site through a pipeline to Perron Quarry, which holds licence L4193/1989/11. The EPP prescribes stack SO2 emission limit for the KPS to be implemented by licence conditions. Synergy is also required to undertake ambient air monitoring by licenence conditions to implement the requirements of the EPP. Bottom ash is stored in ash storage dams on the Premises prior to final disposal at Perron Quarry.

This partial Decision Document summarises the change of monitoring of NOx emissions the high efficiency gas turbines (HEGT) from Continuous Emissions Monitoring Systems (CEMS) to Predictive Emissions Monitoring Systems (PEMS). As part of this ammendment, DER has not re-assessed the acceptability or impacts of emissions and discharges from the Premises or re-visited any existing emission control levels. No changes to the conditions on the previous licence have been made with the exception of conditions of the licence pertaining to CEMS and PEMS.

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4 Decision table

All applications are assessed in line with the Environmental Protection Act 1986, the Environmental Protection Regulations 1987, DEC's Policy Statement - Limits and targets for prescribed premises (2006), and DER's Operational Procedure on Assessing Emissions and Discharges from Prescribed Premises. Where other references have been used in making the decision they are detailed in the decision document.

DECISION TABLE

Works Condition OSC Justification (including risk description & decision methodology where Reference Approval I number or relevant) documents Licence W = Works Approval NSC section 1...= Licence General N/A General Conditions have not been changed as part of this amendment. Environmental conditions Quality Guidelines for Cockburn Sound (EPA, 2005), Moderate Protection Area

Environmental Protection (Unauthorised Discharges) Regulations 2004

Premises N/A N/A Premises operation has not been reassessed as part of this amendment. Environmental operation Refer to DER's risk assessment and decision making for emissions to Protection stormwater. (Unauthorised Discharges) Regulations 2004

State Environmental (Cockburn Sound) Policy 2005

Environmental Protection Act 1986 Page 5 of 10 Decision Document: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_TI0669 v2.6 Government of Western Australia Department of Environment Regulation

DECISION TABLE

Works Condition OSC Justification (including risk description & decision methodology where Reference Approval / number or relevant) documents Licence W = Works Approval NSC section L= Licence General provisions of the Environmental Protection Act 1986 Emissions N/A Descriptive and numeric limits have been set through section 2.2 and 2.3 of the N/A general licence. OSC regarding recording and investigation of exceedances of limits or targets has been included. Point source L2.2.4 OSC Before this amendment the licence has prescribed CEMS monitoring of the NOx emissions to L3.2.2 emissions, however this approach has not been successful for this site. Synergy air including L3.2.4 proposed replacing the CEMS with PEMS as a solution to this problem and in monitoring the interim have been doing weekly stack testing to back up the CEMS.

Synergy has procurred a Predictive Emissions Monitoring System (PEMS) to monitor air emissions from the two High Efficiency Gas Turbines (HEGTs) on the Premises which will be in full operation by 30 September 2015.

DER has required Synergy to ensure that the PEMS technology chosen is compliant with the requirements of USEPA 40 Code of Federal Regulations (CFR) Part 60, Performance Specification 16 and 40 CFR Part 75 which outline the quality control activities that are required to be undertaken to assess acceptability of PEMS when they are initially installed.

These changes will not change the nature of emissions from the stacks during normal operations. Monitoring conditions included in Section 3.2 of this Licence require Synergy to monitor HEGT emissions using PEMS technology in accordance with the Quality Assuarance Manual which inturn must comply with Performance Specification 16.

Synergy have commenced collecting operating parameter data and the

Environmental Protection Act 1986 Page 6 of 10 Decision Document: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10669 v2.6 Government of Western Australia Department of Environment Regulation

DECISION TABLE

Works Condition OSC Justification (including risk description & decision methodology where Reference Approval / number or relevant) documents Licence W = Works Approval NSC section L= Licence commissioning program will provide significant monitoring data over the commissioning period. Synergy have committed to perform monthly stack testing during this period where commissioning work hasn't occurred. Synergy will provide DER with monthly updates of the NOx emission data collected.

Completing the PEMS model will require a limited number of short duration tests without the NOx water pumps operating. This in turn means there is a risk that there will be short duration breaches of the NOx limits. These breaches are necessary to calibrate the PEMS and will not be required to be performed again for the lifetime of this particular PEMS monitoring system.

Emission Description Emission: Oxides of nitrogen (NOx) from the gas turbines via the stacks A4 and A5. Impact: Short term reduction in local air quality which is unlikely to be above NEPM standard. Nearest sensitive receptor is 2 kilometres away. Controls: No abatement controls are proposed because emission is short term for the purpose of PEMS calibration.

Risk Assessment Consequence: Minor Likelihood: Unlikely Risk Rating: Moderate

OSC2.2.4 has been amended to require that the licensee provide notice of running without the NOx water injection pumps to validate the PEMS model. OSC3.2.1 and 3.2.4 have been amended to allow the use of PEMS instead of CEMS to measure NOx and to operate PEMS in accordance with the Quality Assurance Manual.

Residual Risk Environmental Protection Act 1986 Page 7 of 10 Decision Document: L5366/1972/14 Amendment date: Thursday, 16 April 2015 File Number: 2010/007578 IRLB_T10669 v2.6

Government of Western Australia Department of Environment Regulation

DECISION TABLE

Works Condition OSC Justification (including risk description & decision methodology where Reference Approval / number or relevant) documents Licence W = Works Approval NSC section L= Licence Consequence: Minor Likelihood: Unlikely Risk Rating: Moderate

Improvements N/A OSC Improvemnet condition 1 and 2 have been removed from the previous licence as - PEMS is now included in the licence under condition 3.2.1 Information L5.2.1 SC SC5.2.1 has been amended to included the reporting of PEMS. - L5.2.4 OSC OSC5.2.4 has been amended to include the reporting of availability of PEMS. EPP OSC The Premises is located in within Area A of the EPP. Conditions relevant to EPP Environmental monitoring requirements have been transferred from previous licence as below: Protection conditions The conditions relating to EPP monitoring have not been changed by this (Kwinana) amendment. (Atmospheric Wastes) Policy 1999

Environmental Protection (Kwinana) (Atmospheric Wastes) Regulations 1992 Licence N/A N/A Duration of the Licence has not been changed through this amendment. - Duration Previous licence was granted for a period of 5 years. This Licence expires on Saturday 19 August 2017.

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Government of Western Australia Department of Environment Regulation

5 Advertisement and consultation table

Date Event Comments received/Notes How comments were taken into consideration Not Applicable Amendment has not been Not Applicable Not applicable. advertised.

Environmental Protection Act 1986 Page 9 of 10 Decision Document: L536611972114 Amendment date: Thursday, 16 April 2015 File Number: 20101007578 IRLB_T10669 v2.6

Government of Western Australia Department of Environment Regulation

6 Risk Assessment Note: This matrix is taken from the DER Corporate Policy Statement No. 07 - Operational Risk Management

Table 1: Emissions Risk Matrix

Likelihood Consequence Aim Ai. _aindinifs,, ad 1 -1iii-----midiga 11101111.1111Sever=

Almost Certain Moderate High High Extreme Extreme Likely Moderate Moderate High High Extreme

Possible Low Moderate Moderate High Extreme Unlikely Low Moderate Moderate Moderate High

Rare Low Low Moderate Moderate High

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