C o m u N i w ALLIANCE FOR POSITIVE SOLUTIONS INC (CAPS)

P.O Box 69, Yarloop, WA 6218 0409335011 or 0409370235 Email: caps6218@yahoo.com Web: www.caps6218.org.au

20* May 2015 Jason Banks Department of Environmental Regulation Locked Bag 33 Cloisters Square Perth WA 6850

Wagerup Refinery Distillate Use

Dear Mr. Banks.

On a number of occasions we have raised questions about the number of operating hours allowed each year for distillate use by the co-generation plant at Alcoa's Wagemp refinery and have been advised it was just 100 hours pa. Our assertions that during the Varanus Island Gas crisis in 2008 Alcoa were allowed unlimited hours have always been denied.

However, it has now come to light that this was in fact the case and is confirmed in Attachment 2 in Statement 729 "Change to description of Proposal" approved on 18/6/08 which states under FEATURES OF MODIFIED PROPOSAL "Operating hours- distillate use, unlimited hours for the year 2008".

Considering the above, can you please advise on the following:

Why was this major change to the licence not published for comment or put up for appeal?

Given the widely known adverse health (carcinogenic) effects of PM2.5 emissions associated with the burning of distillates, why was the community not warned of this change, which was very likely to have an adverse effect on the health of many at-risk people in the area?

Were any health studies conducted in the area before, during and/or after this period of unlimited use of distillate to determine possible harm caused and if so, could you please provide copies of the findings?

Did the DER (Then DEC) and/or DoH as the relevant agencies check to ensure the environmental acceptability of this practice? If not, please advise why not?

In view of the seriousness of this matter we would appreciate a prompt reply and a full explanation of the conflicting information provided earlier.

Yours sincerely.

Vince Puccio Merv McDonald, AFSM Co-Chairs: Community Alliance for Positive Solutions Inc.

Cc; Hon Colin Barnett MLA, Premier, Hon Alt)ert Jacob MLA, Professor Tarun Weeramanthri

?i!°yf^s.!i&&°rtecl^^^^

V SHINE ^ L A W Y E R S

RIGHT WRONG,

ERIN BROCKOVICH

Yarloop

Waroona

Hamel

Harvey

Cookernup

Wagerup

Other Impacted Areas

lof 1

Hon Mark McGowan MLA Minister lor the Environmavt Statement No.

Radng and Gaming 197 St Geoiges Terrace, Perth WESTERN AUSTRALIA «X» fi,i-i/-ry% Telephone: 8) 9222 9 m FMainaK<+61 8) 9222 9410 U U U 7 ^ S

Emaa nuurk-mcgowanedpcwa.gov.au • Website: w%w4iiiirisfers.wa.gcnuiu/mcgowan/

STATEMENT THAT A PROPOSAL M A Y BE IMPLEMENTED (PURSUANT TO THE PROVISIONS OF THE

ENVIRONMENTAL PROTECTION ACT 1986)

WAGERUP COGENERATION PROJECT

Proposal: The constructioD, operation and maintraiance of a co-gCTieration facility of 350 Megawatts electrical output and 460 toimes per hour of steam output at Wagerup, as documented in schedule 1 of this statement.

Proponent: Alinta Cogaaeration (Wagerup) Pty Ltd

Proponent Address: GPO Box W2030

PERTH WA 6846

Assessment Number: 1643

Report of the Environmental Protection Authority: Bulletin 1223

The proposal refaied to above may be implemented by the proponent subject to the following conditions:

1 Proposal Description

1 -1 The proponent shall in >lement the proposal as documented and described in schedule 1 of this statement subject to the conditions of this statement

2 Proponent Nomination and Contact Details

2-1 The proponent for the time bdng nominated by the Minister for the Biviranment under section 38(6) of the Emnronmental Protedion Act 1986 is responsible for the implementation of the im>posal.

2-2 The proponent shall notify the Chief Executive Ofl5cer of the Department of Eaviromnerit and Conservation (CEO) of any change of the name and address for the saving of notices or other correspondence within 30 days of such chan^.

Published on 27 SB* tm%

3 Time Limit of Anthorisatioii

3-1 The avtfliorisation to implranent the proposal provided for in this statanent shall lapse and be void within five years aftCT the date of this statemait if the proposal to which this statement refers is not substantially commaiced,

3-2 The proponent shall provide the CEO with mittsa evidence which demonstrates that the proposal has substantially commoiced on or before the expiration of five years from the date of this statemait

4 Compliance Reporting

4-1 The proponent shall submit annually an audit compliance rqport, for the previous twelve-motath period.

The audit compliance rq>ort shall: 1. be endorsed by the proponent's GmCTal Manager or a person, approved in writing

by the Department of Enviroimient and Conservation, delegated to sign on the proponent's General Manner's bdialf;

2. mclude a statement as to whether the proponent has complied witih the conditions, procedures, commitments and actions within the Envirrarmental Management Plans;

3. identify ail non-compliance and describe the related corrective and preventative actions taken;

4. review the effectiveness of all corrective and preventative actioiui takea; 5. provide verifiable evidence of compliance with the conditions, procedures and

conmiitments; 6. describe the state of implementation of the proposal; and 7. be prepared in accordance with an audit program and in a format acceptable to the

Department of Environment and Conservation.

4- 2 The proponent shall ihake the audit compliance report publicly available in a manner ^proved by the Departmait of Environment and Conservation.

5 Performance Review

5- 1 The proponent shall submit a Parformance Review report every two years after the start of production to the CEO, which addresses:

1. tiie niajor environmental issues associated with in^Iesnoiting the project; the environmental objectives for those issue; the m^odologies used to achieve these; and the key indicators of ^viromnental paformance measured against those objectives;

2. the level of progress in the achievanent of sound mvironmental perfonnance, including industry bmchmaridng, and the use of best available technology where practicable;

3. significant improvements gained in environmcaital management, including the use of external peer reviews;

4. stakeholder and community consultation about enyiroimxaital performance and the outcomes of that consultation, including a report of any on-going concerns bemg expressed; and

5. the proposed envux)nmental objectives over the next two years, including improvCTQcnts in technology aiid management processes.

6 Greenhouse Gas Abatement

6-1 Prior to commaicetnent of constraction, the proponent shall develop a Greenhouse Gas Abatemait Program to:

• ensure lhat the plant is designed and operated in a manna: which achieves reductions in "gresihouse gas" emissions as far as practicable;

• provide for ongoing "greenhouse gas" ODnissions reductions over time;

• ensure that through the use of best practice, the total net "greenhouse gas" emissions and/or "greenhouse gas" emissions per unit of product ftom tihe project are minimised; and

• manage "greenhouse gas" emissions in accordance with the Framework Convention on Climate Change 1992, and consistent with the National Greenhouse Strategy;

to the requirements of the Minister for the Environment on. advice of the Environmental Protection Authority.

This Program shall include:

1. calculation of the "greenhouse gaa" anissions associafed with the proposal, as advised by the Environmental Protection Authority;

Note: The current rajuirements of the Enviroimjeatal Protection Authority are set out in: Minimising Greenhouse Gas Emissions, Guidance for the AssessTnent of Environmental Factors, No.' 12 published by the Environmental Protection Authority (Octoba- 2002). This document may be updated or replaced fi-om time to time.

2. specific measm«s to minimise the total net "greenhouse gas" emissions and/or the "greenhouse gas" emissions per xmit of product associated with the proposal using a combination of "no regrets" and "beyond no regrets" measures;

Note: The following definitions apply above:

1. **no regrets" measures are iboss which can be imploneated by a proponent and which are effectively cost-neutral.

2. '*beyond no regrets" measures are those which can be implemented by a proponent and which involve additional costs which are not ejcpected to be recovered.

3. the implementation and ongoing review of "greenhouse gas" offeet strategies witti such offsets to remain in place for the life of the proposal;

4. estimation of &e "greaahouse gas" eflSciency of the project (per unit of product and/or otiier agreed performance indicators) and comparison witii the efficiencie of oAer comparable projects producing a similar product, both wifliin Australia and overseas;

5. implemaitation of thermal efiBciency desiga and operating goals consistent wift the Australian Greenhouse Office Technical EfSciaicy guidelines in deign and operational managanent;

6. actions for the monitoring, regular auditing and aimual r^r t ing of "greenhouse gas" emissions and emission reduction strategies;

7. target set by the proponent for the progressive reduction or abatanent of total net "greaahouse gas" emissions or "greenhouse gas" emissions per unit of product, through the iirqjlementation of on-site or off-site ofl&ets and/or the use of renewable energy sources such as solar, wind or hydro power and annual reporting of progress made in achieving this target;

8. a program to achieve a reduction or abatement in "greenhouse gas" emissions, consistait with the target referred to in (7) above;

9. entry, wh^er on a project-specific basis, company-wide airangetiient or within an industrial groiqjing, as ^ropriate, into the Commonwealth Govanment's "Greenhouse Challenge" voluntary coopaative agreement program.

Components of the agreemait program include: 1. an inventory of emissions; 2. opportunities for abating "greeahouse gas" emissions in the organisation; 3. a "greenhouse gas" mitigation action plan; 4. regular monitoring and reporting of performance; and 5. indepaident performance verification.

10. Review of practices and available technology; and

11. "Continuous inqirovement approach" so that advances in technology and potential operational improvemOTts of plant performance are adopted.

Hie proponent shall implanent the Greaahouse Gas Abatement Program required by con(Ktion6-L

6- 3 Prior to commenconent of coiistruction, tiie proponent shall make the Greenhouse Gas Abatement Program required by condition 6-1 publicly available in a manner approved by the Department of Enviromnait and Conservation.

7 Stack Emissions

7- 1 Prior to consfruction of the co-gmeration facility, the proponent shall prepare a Stack Emissions Management Plan, to:

• ensure that best available practicable and efficient technologies are used to minimise total air emissions from the co-gaieration facility;

to the requirements of the Minister for the Environment on advice of the Environmental Protection Authority.

This Plan shall address:

1. specific measures to minimise total air emissions fix»m the co-gaieration faciEty to meet emission limits consistent with best practicable technology and current industry standards;

2. stack testing during commissioning of both Stage 1 and Stage 2 to fiiUy characterise all constituents listed in the plan, including minor emissions such as formaldehyde, acetalddhyde, toluene and baizene;

3. on going monitoring of key air emissions identified in the stack testing required by point 2; and

4. public reporting of air emissions and any complaints about air onissions.

7-2 The proponent shall implement the Stack Snissions yimagemeiit Plan required by condition 7-1.

7-3 The proponent shall make the Stack Emissions Management Plan, required by condition 7-1 publicly available in a manner proved by the Department of Environment and ConservatioiL

8 Noise

8-1 Prior to construction of Stage 2, the proponent shall prepare a Noise Management Plan, to ensure that the proposal will not increase noise impact, to the requirements of the Minister for the Enviromnent on advice of the Envuoimiaatal Protection Authority.

This Plan shall address:

1 revised noise modelling using detailed design noise source data;

2 ground truthing of noise predictions fix>m Stage 1; and

3 land use changes.

8-2 The proponent shall implement the Noise Management Plan required by condition 8-1.

8-3 The proponent shall make the Noise Management Plan required by condition 8-1 publicly available in a manner approved by the Department of Enviromnent and Conservation,

Notes

1. The CEO may seek the advice of tbe Environmental Protection Au&ority, govenrment agencies and relevant parties, as necessary, for the preparation of written notice to the proponent.

2. The proponent shall relinquish the nomination following the procedure under section 3S(62L)ofiheEnvironmetital Protection Act 1986.

3. The proponoit is required to apply for a Works Approval and Licence for this project under the provisions of Part V of tiie Environmental Protection Act 1986.

HON M A R K McGOWAN M L A MINISTER FOR THE ENVIRONMENT; RACING AND GAMING

2 7 SEP tm%

Schedule 1

The Proposal (Assessment No. 1643)

The proposal is to constmct a natural gas-fired power station with a nominal generation capacity of 350 megawattis electrical output and 460 tonnes per hour of steam output on a site located at Alcoa's Wagerap alumina re f i r^ (location ^own in Figures 1 and 2). The proposal is to be implemented m two stages, with a transition phase between Stage 1 and Stage 2.

Stage 1: Open-cycle peak load power station

Purpose: To supply electricity to the South West Intacoimected System (SWIS) Life of project: Approximately 25 years

Table 1 - Key Proposal Characteristics (Stage 1)

Element Description Power Generation

350 megawatts (nominal)

Plant Facilities Gas turbine specifications

Numbs-of stadcs Height of Slacks

2 X gas turbine of 175 megawatts nominal geneaating capacity fitted with dry low NO, burners two 35 metres

Thermal EfBciency (based on net higher beating value at 41 degrees Celsius and 40% relative humidity)

approxinately 30%

Operating Hours Total per unit (gas and distillate) Distillate

up to 1000 hours a year up to 100 hours a year

Inputs Natural Gas Distillate

approximately 3.4 petajoules per annum aj^oximately 0.4 petajoules per annum

Air Emissions Carbon dioxide equivalent (CO:^) Oxides of nitrogen (NO O

225 000 tonnes per annum 1331 tonnes per annum

Transition phase: Open-cycle with increased operating hoars

Once the proponent has advised the Envinmmental Protection Authority of its decision to develop Stage 2, the gas turbines may be operated m open-cycle mode for a total of 15 500 hours per unit in addition to those hours allowed in Table 1. The transition phase is expected to last around three years and the proponait may apportion the 15 500 additional operating hours over these yeare as they see fit

Stage 2: Co-generatioii base-load power station

Puipose: To supply power to the SWIS and steam to the Wagen^ alumina refinery.

Table 2 - Key Proposal Characteristics (Stage 2)

Element D^ription Generation Power output Steam output

350 megawatts (nomfaal) 460 tonnes per hour ftypicaO

Plant FaeOities Gas turbine specifications

Heat recovery steam genraator (HRSG) Nuirijer of stacks Height of HRSG stacte

2 X gas tmbme of 175 megawatts nominal gsieratiag capacity fitted wife dry low NO, burners 2 X HRSGs widi a cs jacity of430 tonnes per hour 4 (including fte two disconnected opeorcyde stacks) 2 X 50 metres (co-geiKTation), 2x35 metres (disconnected)

Thermal ££Bdency (based on net higher heating value at 18 degrees Celsius and 20% relative humidity)

^rproximately 74% (based on one gas turbme and one HRSG fiiily fired)

Operadng Hoars Perunit up to 8760 hours per annum

Inputs Natural Gas approximately 31.8 petajoules per annum

Air Emissions Carbon dioxide equivalent (C02e) Oxides of nitrogen (NOx)

1 783 000 trames per annum 1331 tonnes per annum

figures (attached)

Figure 1 - Regional location Figure 2 - Site layout

F^re J - Regional iocaUon

Figure 2 - Site h^out

Attachment 1

Attachment to Statement 729

Change to Description of Proposal

PROPOSAL: WAGERUP COGENERATION PROJEGT - the consttnction, operation and maintenance of a cogeneration facility of 350 M^watts electrical ou^nt and 4 ^ tonnes per hour of steam output at Wageinp, as documented in Schedule 1 of statement 729.

PROPONENT: ALINTA COGENERATION (WAGERUP) PTY LTD.

ASSESSMENT NO: 1643

CHANGE: IN STATEMENT 729, SCHEDULE 1, TABLE 1 - KEY PROPOSAL CHARACTERISTICS (STAGE 1) - an increase in the aUowabie 'operating hours - distillate use' for the 2008 year.

FEATURES OF CURRENT PROPOSAL:

Element Quantities/Description

Operatmg hours — distillate use • Up to 100 hours pei yeai,.

FEATURES OF MODIFIED PROPOSAL:

Element Quantities/Description

Opei ating hours— distillate use • Up to 200 horns for the 2008 year..

• Up to 100 hours per year fcK the 2009 year

onward.

Approved under delegation from Minister for the Enviroimient:

Approval Date: lo . ^ . t9 /

Attactuuent 2

Attachment to Statement 729

Change to Description of Proposal

WAGmUP COGENERATION PROJECT - the construction, operation and maintenance of a cogeneration fiacilily of 350 Megawatts electrical output and 460 tonnes per hour of steam output at Wagerap, as dociunented in Scbeduie 1 of statement 729.

ALINTA COGENERATION (WAGERUP) PTY LTD.

ASSESSMENT NO: 1643

CHANGE: IN STATEMENT 729, SCHEDULE 1, TABLE 1 - KEY PROPOSAL CHARACTERISTICS (STAGE 1)- an increase in the allowable 'operating hours - distillate nse' for the 2008 year.

FEATURES OF CURRENT PROPOSAL:

Element Quantities/Description

Operating hours - distillate use • up to 100 hours per year.

FEATURES OF MODIFIEn PROPOSAL:

Element Quantities/D^cription .

Operatmg hom-s- distillate use • unlimited hours for the 2008 year.

• up to 100 hours per year for tlie 2009 year

onward.

Approved under delegation from Minister for the Environment:

Approval Date: / f .^-"^ f

1

PROPOSAL:

PROPONENT: