Eraring Power Station Ash Dam AQMP 2022 Final Rev1 Approved

Eraring Power Station Coal Combustion Management Facility
Air Quality Management Plan
Final | Revision 1
27 May 2022
Origin Energy Eraring Pty Ltd
GEN-HSE-AQMP-EPS
A ir Quality Mana gem en t Pla n

Origin E ner gy E rari ng P ty L td
Eraring Power Station Coal Combustion Management Facility
Project No: IA316800

Document Title: Air Quality Management Plan
Document No.: Final
Revision: Revision 1
Date: 27 May 2022
Client Name: Origin Energy Eraring Pty Ltd
Client No: GEN-HSE-AQMP-EPS
Project Manager: Shane Lakmaker
Author: Shane Lakmaker
File Name: Eraring Power Station Ash Dam_AQMP 2022_Final_rev1.docx
Jacobs Group (Australia) Pty Limited

ABN 37 001 024 095
Level 4, 12 Stewart Avenue
Newcastle West NSW 2302 Australia
PO Box 2147 Dangar NSW 2309 Australia
T +61 2 4979 2600
F +61 2 4979 2666
www.jacobs.com
© Copyright 2019 Jacobs Group (Australia) Pty Limited. The concepts and information contained in this document are the property of Jacobs.
Use or copying of this document in whole or in part without the written permission of Jacobs constitutes an infringement of copyright.
Limitation: This document has been prepared on behalf of, and for the exclusive use of Jacobs’ client, and is subject to, and issued in accordance with, the
provisions of the contract between Jacobs and the client. Jacobs accepts no liability or responsibility whatsoever for, or in respect of, any use of, or reliance
upon, this document by any third party.
Document history and status
Revision Date Description Author Reviewed Approved
D1R1 4/3/20 Draft plan S. Lakmaker (Principal Air Quality) P. Horn (Principal Environment) P. Horn (Principal Environment)
D2R0 12/3/20 Final draft plan (D2R0) S. Lakmaker (Principal Air Quality) P. Horn (Principal Environment) P. Horn (Principal Environment)
Final 9/3/22 Final – Revision 0 S. Lakmaker (Principal Air Quality) P. Horn (Principal Environment) P. Horn (Principal Environment)
Final 27/5/22 Final – Revision 1 S. Lakmaker (Principal Air Quality) P. Horn (Principal Environment) P. Horn (Principal Environment)
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Contents
1. Introduction ............................................................................................................................................................ 1
1.1 Background ............................................................................................................................................................................... 1
1.2 Purpose ....................................................................................................................................................................................... 1
1.3 Scope ........................................................................................................................................................................................... 1
1.4 Objectives................................................................................................................................................................................... 1
2. Legislative Requirements .................................................................................................................................... 2
3. Existing Environment ............................................................................................................................................ 4
3.1 Local Setting ............................................................................................................................................................................. 4
3.2 Meteorological Conditions .................................................................................................................................................. 5
3.3 Potential Impacts .................................................................................................................................................................... 7
4. Air Quality Management System ....................................................................................................................... 8
4.1 Overview ..................................................................................................................................................................................... 8
4.2 Management Measures ........................................................................................................................................................ 8
4.3 Monitoring Program ........................................................................................................................................................... 10
4.4 Visual Monitoring................................................................................................................................................................. 14
4.5 Proactive Management...................................................................................................................................................... 14
4.6 Compliance ............................................................................................................................................................................ 16
5. Complaint Management ................................................................................................................................... 17
6. Incident and Non-compliance Reporting...................................................................................................... 18
7. Access to Information and Record Keeping ................................................................................................. 19
7.1 Access to Information ........................................................................................................................................................ 19
7.2 Record Keeping .................................................................................................................................................................... 19
8. Review and Training ........................................................................................................................................... 20
8.1 Plan Review ............................................................................................................................................................................ 20
8.2 Training and Communication ......................................................................................................................................... 20
9. Roles and Responsibilities ................................................................................................................................ 21
10. Definitions ............................................................................................................................................................ 22
11. References ............................................................................................................................................................ 23
List of figures
Figure 1 Location of Ash Dam and nearest sensitive receptors .................................................................................................. 4
Figure 2 Wind-roses from data collected at Eraring Power Station Ash Dam between 2017 and 2019 .................. 6
Figure 3 Overview of the air quality management system ..........................................................................................................10
Figure 4 Location of air quality and meteorological monitoring stations for Ash Dam dust management .........13
Figure 5 Example daily environmental forecast ..............................................................................................................................15
List of tables
Table 1 Air Quality Management Plan Requirements ..................................................................................................................... 2
Table 2 Dust management measures ..................................................................................................................................................... 9
Table 3 Trigger level definitions .............................................................................................................................................................10
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Table 4 Air quality and meteorological monitoring for Ash Dam dust management.....................................................11
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1. Introduction
1.1 Background
This Air Quality Management Plan (AQMP) is one of a series of plans that together form the Environmental
Management System for the Eraring Power Station (EPS) coal combustion product management facility. The
coal combustion product management facilities include including collection, storage, conditioning and pumping
facilities and are hereafter referred to as the Ash Dam activities.
Ash production is directly related to the energy produced and the type of coal utilised at the EPS. If the energy
production rates and coal type are maintained into the future, as they have been in the recent past, the annual
ash production will be approximately 1.5 million tonnes per annum (Mtpa) in future years.
Modification 1 (MOD1) of the ash dam expansion project approval provides for up to an additional 5 million
cubic metres (Mm3) storage capacity in the ash dam. The current estimated ash storage volume is 2.25 Mm3
based on the latest design information.
This AQMP has been prepared by Jacobs Group (Australia) Pty Limited as the suitably qualified and experienced
person/s required by Condition 4.8 of Schedule 2 of Project Approval (PA) 07_0084 as modified (MOD 1).
1.2 Purpose
This Plan has been prepared by Jacobs on behalf of Origin Energy Eraring Pty Ltd (Origin) and in consultation
with the Environment Protection Authority (EPA). The plan was submitted to the Planning Secretary on
14/03/2022 and approved on 09/06/2022.
The purpose of this AQMP is to ensure that statutory requirements are met, in particular Conditions 2.8, 2.9, 4.8,
5.1 and 5.2 of Schedule 2 of the PA 07_0084 as modified.
1.3 Scope
This Plan applies to all activities at the Ash Dam including the MOD1 expansion area and outlines the controls to
be implemented for the management and monitoring of air quality associated with the Ash Dam.
1.4 Objectives
The objectives of this AQMP are to:

 Identify the potential impacts of the Ash Dam on the local air quality environment;
 Detail the controls and strategies to be implemented to minimise air quality impacts on local receptors;
 Establish an air quality monitoring system to assess the air quality impact;
 Provide a protocol to assess impacts and to evaluate compliance;
 Manage air quality-related community complaints in a timely and effective manner; and
 Detail the procedure for reporting potential non-compliances to relevant stakeholders.
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2. Legislative Requirements
Operation of the EPS Ash Dam is subject to the conditions of PA 07_0084 MOD1. 1 shows the relevant
conditions of PA 07_0084 MOD1 and where they are addressed within this AQMP.
Table 1 Air Quality Management Plan Requirements
Project Approval Condition Section of this Plan
Condition 2.8 of Schedule 2 of PA 07_0084 MOD1 Section 4 which outlines the air
The Proponent shall construct the project in a manner that minimises dust emissions from the site, quality management system and
including wind-blown and traffic-generated dust. All activities on the site shall be undertaken with the measures to minimise dust
objective of preventing visible emissions of dust from the site. Should such visible dust emissions occur emissions from the site.
at any time, the Proponent shall identify and implement all practicable dust mitigation measures,
including cessation of relevant works, as appropriate, such that emissions of visible dust cease.
Condition 2.9 of Schedule 2 of PA 07_0084 MOD1 Section 3.3, odour is not

The Proponent shall not permit any offensive odour, as defined under section 129 of the Protection of identified as an air quality issue
the Environment Operations Act 1997, to be emitted beyond the boundary of the site. for the Ash Dam.
Condition 4.8 of Schedule 2 of PA 07_0084 MOD1
The Proponent must prepare an Air Quality Management Plan to the satisfaction of the Planning This Plan has been prepared by
Secretary. This plan must: an air quality specialist at Jacobs.
a) be prepared by a suitably qualified and experienced person/s;
b) be prepared in consultation with the EPA; Appendix A provides relevant

external consultation records.
c) be submitted to the Planning Secretary for approval within 3 months of approval of MOD 1 This Plan was submitted to the
or other timeframe agreed by the Planning Secretary, Planning Secretary on
14/03/2022 and approved on
09/06/2022. Appendix A
provides a copy of relevant
consultation records.
d) describe the air quality management system in detail; and Section 4 outlines the air quality
management system.
e) describe the measures to be implemented to ensure: Section 4, in particular Section
i) compliance with the air quality operating conditions of this approval; and 4.2 and 4.3, provides details on
ii) the air quality impacts of the project are minimised during adverse meteorological the measures.
conditions and extraordinary events;
f) include an air quality monitoring program, undertaken in accordance with the Approved Section 4.3 describes the
Methods for Sampling and Analysis of Air Pollutants in New South Wales (DEC, 2007), that: monitoring program.
i) uses monitors to evaluate the performance of the project to guide day to day Section 4.3
operations;
ii) adequately supports the air quality management system; and Section 4.3
iii) includes a protocol for identifying any air quality-related incident or non-compliance Section 6
and for notifying the Department and relevant stakeholders of these events.
Condition 5.1 of Schedule 2 of PA 07_0084 MOD1 Section 6

5.1 The Proponent must immediately notify the Department and any other relevant agencies
immediately after it becomes aware of an incident. The notification must be in writing and identify the
development (including the development application number and name) and set out the location and
nature of the incident.
Condition 5.2 of Schedule 2 of PA 07_0084 MOD1 Section 6

5.1 Within seven days of becoming aware of a non-compliance, the Proponent must notify the
Department of the non-compliance. The notification must be in writing and identify the development
(including the development application number and name), set out the condition of this consent that
the development is non-compliant with, why it does not comply and the reasons for the non-
compliance (if known) and what actions have been, or will be, undertaken to address the non-
compliance.
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Project Approval Condition Section of this Plan

Note: A non-compliance which has been notified as an incident does not need to also be notified as a
non-compliance
Environment Protection Licences (EPLs) are administered by the EPA. EPL No. 1429 specifies the monitoring
requirements and operating conditions in order to manage impacts to air quality from all activities at the EPS,
not just at the Ash Dam. The relevant EPL conditions are commensurate with those imposed by PA 07_0084
MOD1 and state:
 O3.1 The premises must be maintained in a condition which minimises or prevents the emission of dust from
the premises.
 O3.2 All operations and activities occurring at the premises must be carried out in a manner that will
minimise the emission of dust from the premises.
The EPA was consulted on the preparation of the plan but did not provide any feedback relevant to its
preparation.
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3. Existing Environment
3.1 Local Setting
The EPS is surrounded by predominantly undeveloped bushland. There are a number of coal mines located in
the vicinity of the power station, including the Myuna Colliery to the east, Mandalong Mine to the west, and the
Newstan Colliery to the north.
Local environmental conditions with direct implications for air quality management include the prevailing
meteorology and location and proximity of sensitive receptors in relation to the Ash Dam. In this context,
sensitive receptors relate to residences, schools and hospitals (EPA, 2016). The nearest sensitive receptors to the
Ash Dam are labelled on Figure 1 and include the residential suburbs of:
 Dora Creek, approximately 4 km to the southwest;

 Eraring, approximately 1.5-2 km to the south; and
 Wangi Wangi, Arcadia Vale, Buttaba and Rathmines, approximately 3 km to the east.
Figure 1 Location of Ash Dam and nearest sensitive receptors
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There are various sources of emissions that have the potential to contribute to the local air quality. In particular,
the local air quality may be influenced by emissions from EPS coal combustion, the coal conveyors and
stockpiles, periodic construction works, bushfires and ‘burning off’, local industry, vehicles, roads, wind-blown
dust from nearby and remote areas, fragments of pollens, domestic wood fires, sea-salt, and so on.
3.2 Meteorological Conditions
Meteorological conditions are important for determining the direction and rate at which emissions from
activities, such as ash disposal and management, will disperse. The key meteorological parameters for air quality
management are wind speed and wind direction.
The prevailing winds in the vicinity of the Ash Dam are from the west, although winds at the site can occur from
all directions depending on the season. This is demonstrated by the wind-roses shown in Figure 2 which
summarise the wind data collected between 2017 and 2019 by the EPS weather station. Based on these winds,
the sensitive receptors at most risk of dust impacts from the Ash Dam activities will be those to the east, that is,
Wangi Wangi, Arcadia Vale and Buttaba.
The meteorological conditions that most commonly lead to elevated dust concentrations include:
 Warm weather and extended periods without rainfall, resulting in lower surface moisture;
 Wind speeds greater than 6 m/s. These winds are conducive to higher wind erosion rates; and
 Stable conditions, such as at night with light winds and when a temperature inversion is present.
The existing environment is characterised by higher rainfall in summer and autumn and lower rainfall in winter
and spring. The prevailing westerly winds mean that the sensitive receptors of Wangi Wangi, Arcadia Vale and
Buttaba will be downwind of Ash Dam activities for the majority of the time.
The most effective air quality mitigation measures will focus on controlling emissions under unfavourable
meteorological conditions, such as dry and windy conditions, stable night-time conditions and/or when winds
are blowing from the Ash Dam towards sensitive receptors.
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Figure 2 Wind-roses from data collected at Eraring Power Station Ash Dam between 2017 and 2019
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3.3 Potential Impacts
The key air quality issue to be managed at the Ash Dam is dust, that is, airborne particulate matter in the form of
TSP, PM10 or PM2.5). Dust emissions have the potential to be generated from:
 Ash placement activities;
 Exposed areas of the Ash Dam surface, resulting in wind-blown dust; and
 Vehicles travelling over unsealed surfaces, resulting in wheel generated dust.
Emissions from the Ash Dam surface are transient in nature (i.e. brief, temporary, short-lived) and typically occur
over a few hours in a day. Based on the prevailing westerly winds, the sensitive receptors at most risk of dust
impacts from Ash Dam activities are those located to the east, with potential impacts most likely to be
experienced in the residential areas of Wangi Wangi, Arcadia Vale and Buttaba. The control measures in this
AQMP have focused on those sources listed above with consideration of the nature and potential impacts of Ash
Dam emissions, and for areas of highest potential impacts.
There are no odour emissions associated with ash placement and management, other than fumes from the
combustion of diesel in machinery used for the ash placement activity. Origin’s contractors maintain plant in a
proper and efficient manner and any odour would not be noticeable except in the immediate vicinity of the
machinery. As such, the Ash Dam will be operated in a manner to prevent any offensive odour beyond the
boundary of the site in accordance with section 129 of the Protection of the Environment Operations Act 1997.
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4. Air Quality Management System

4.1 Overview
Air quality management at the existing Ash Dam aims to ensure compliance with the air quality operating
conditions of PA 07_0084 MOD1, specifically Conditions 2.8 and 2.9 as outlined in Section 1.
Air quality management is carried out in accordance with Origin’s Eraring Power Station Ash Dam Dust
Management Procedure (Origin, 2022). Appendix B includes a copy of the Procedure. This is an internal
document that forms a part of the Generation wide safe systems of work and is to be used in conjunction with the
Generation HSE Management Plan (Origin, 2021) and Eraring Power Station (EPS) Safe Systems of Work (Origin,
2021). The plan is updated annually by the Ash Dam Health Safety Environment (HSE) Advisor and approved by
the Generation - Head of Operation Services.
The ash dam expansion, as approved by PA 07_0084 MOD1, expands the ash dam to the west, with operations
being the same in this area as the existing ash dam. As such the dust management procedures outlined in the
Ash Dam Operations Safety and Dust Management Plan (Origin, 2020) are appropriate for implementation in
the MOD1 project area for ongoing air quality management. In addition, Origin has increased the proactive
nature of air quality management at the Ash Dam with the recent implementation of a site specific dust forecast
system as described in Section 4.5.
The Eraring Power Station Ash Dam Dust Management Procedure (Origin, 2022) includes a combination of the
following types of measures:
 Elimination / Substitution (for example, capping, ash reuse, proactive strategies as prescribed in a Trigger
Action Response Plan (TARP));
 Engineering (for example, polymer, and ash placement);
 Administration (including plans and procedures for dust mitigation); and
 Reactive controls (for example, spray irrigation and helicopter water bombing).
Origin implements these measures to minimise emissions and impacts on the air quality surrounding the Ash
Dam. Dust impacts have been defined as those where dust emissions generated by the Ash Dam led to an event
which caused, or had the potential to cause, an observed nuisance impact at off-site sensitive receptor locations.
4.2 Management Measures
Table 2 outlines the specific management measures that are implemented at the Ash Dam for preventing,
controlling and minimising dust emissions at the Ash Dam. These management measures are also applied to the
MOD1 project area in addition to the existing ash dam. All management measures are intended to:
 Minimise dust emissions;
 Prevent visible dust emissions; and
 Manage visible dust.
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Table 2 Dust management measures
Emission source Management measures Responsibility
Clearing and Progressive clearing of Modification 1 construction area to minimise exposed area. Ash Dam Contractor
construction of Environment Team
Modification 1
Application of water or polymer during construction and clearing to minimise dust Ash Dam Contractor
area
emissions generated from site including wind-blow and traffic generated dust. Environment Team
Minimising of exposed areas through progressive rehabilitation and/or stabilisation where Ash Dam Contractor
possible. Environment Team
Observation of weather conditions during construction activities and modifying or ceasing Ash Dam Contractor
placement if excessive wind blown or traffic generated dust is visible. Environment Team
Ash placement Adoption of appropriate ash placement strategies, such as dense phase ash placement Ash Dam Contractor
activities and dry stacking. Environment Team
Observation of weather conditions during ash placement and modifying or ceasing Ash Dam Contractor
placement if excessive wind-blown dust is visible. Environment Team
Wind erosion Wetting the surface using water spray irrigation, or cannon, during dry, high wind Ash Dam Contractor
from exposed conditions. Environment Team
areas of the Ash
Progressive rehabilitation where possible. Ash Dam Contractor
Dam surface
Environment Team
Application of crusting agents or polymers on an exposed ash surface where no discharge Ash Dam Contractor
is likely to occur imminently, if deemed to be potentially effective. An EPA approved Environment Team
crusting agent or polymer will be utilised.
Ash Dam capping in areas of persistent dust issues and where ash placement is unlikely to Ash Dam Contractor
occur in the future. Environment Team
Water bombing by helicopter in the event of significant dust events. Environment Team
Wheel-generated Application of water, using a wet ring, during truck loading or unloading activities. Ash Dam Contractor
dust from Environment Team
vehicles
Observation of weather conditions during unloading and ceasing unloading if excessive Ash Dam Contractor
travelling over
wind-blown dust is visible. Environment Team
unsealed
surfaces Reduction of speed when operating to minimise dust generated from traffic. Ash Dam Contractor
Watering of unsealed haulage routes, using a water cart, if dust is observed with vehicle Ash Dam Contractor
movements. Environment Team
Sweeping of paved roads, using a road sweeper, if dust is observed with vehicle Ash Dam Contractor
movements. Environment Team
The Ash Dam Operations Safety and Dust Management Plan (Origin, 2020) will be reviewed and updated if
required to incorporate the management measures outlined in this AQMP. Existing management measures will
continue to be implemented including the following general measures for mitigating dust generation:
 Continue to utilise dense phase ash placement;
 Progressive rehabilitation of completed surfaces;
 Direct water application through sprays or water cannon;
 Application of fresh fly ash slurry or purpose specific crusting agents; and
 Consideration of vegetative screens, bunds, and wind breaks.
Implementation of the management measures described above is informed by a combination of visual

monitoring, meteorological monitoring, ambient air quality monitoring and automated daily forecasting. Figure
3 provides an overview of this management system.
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“Triggers” are used to inform the necessary management measures / actions. As shown in Figure 3 triggers are
based on real-time (air quality and meteorological) monitoring, visual monitoring, and forecast data.
Figure 3 Overview of the air quality management system
Table 3 shows the trigger level definitions, including a summary of actions that apply to each level. The full
Trigger Action Response Plan (TARP) is included in Appendix B.
Table 3 Trigger level definitions
Level Description Summary of action(s)
Reasonably expected conditions in day to day operations Polymer application

Normal state
No cause for action, routine dust management to be continued
Change from normal indicating a potential risk Polymer application

Level 1 Triggers Not of a serious nature, acts as an alert and requires monitoring to Spray irrigation
detect further trends
Moderate risk of dust related impacts occurring Polymer application

Level 2 Triggers
Remedial action needs to be planned and executed Spray irrigation, intensified
High risk of dust related impacts occurring Polymer application

Level 3 Triggers A situation has occurred that poses an immediate risk and remedial Spray irrigation, intensified
action must be undertaken Helicopter water bombing considered
4.3 Monitoring Program
Origin maintains an existing air quality and meteorological monitoring program as required by Condition M2, M3
and M6 of EPL No. 1429. This program operates in compliance with the “Approved Methods for Sampling and
Analysis of Air Pollutants in New South Wales” (DEC, 2007). In addition the EPS ash dam has a network of four
(4) dust and wind monitors, plus an additional meteorological station that are designed and integrated with the
TARP described in Section 4.2 for real-time dust management. This system is applied to the expanded ash dam
(MOD1 project area) as required by the PA 07_0084 MOD1.
Table 4 provides details of the Ash Dam monitoring program and Figure 4 shows the monitoring locations. The
monitoring program consists of four mobile meteorological and airborne Particulate Matter (PM10) monitors,
and one permanent 10 m weather station.
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Table 4 Air quality and meteorological monitoring for Ash Dam dust management
Monitoring Type Indicator Frequency Justification

site(s)
Site 1-ES3 E-Sampler PM10 Continuous (5 minute resolution) Real-time monitoring to the SSE of
the Ash Dam, near the site boundary,
towards Myuna Bay.
Site 2-ES1 E-Sampler PM10 Continuous (5 minute resolution) Real-time monitoring to the SSE of
the Ash Dam, close to the Ash Dam.
Site 3-ES4 E-Sampler PM10 Continuous (5 minute resolution) Real-time monitoring to the SE of the
Ash Dam, in the direction of Wangi
Wangi and Arcadia Vale.
Site 4-ES2 E-Sampler PM10 Continuous (5 minute resolution) Real-time monitoring to the E of the
Ash Dam, in the direction of
Rathmines and Buttaba.
WS Weather station Meteorology Continuous (10 minute resolution) Site-specific monitoring to detect
(temperature, wind adverse meteorological conditions
speed, wind direction, and allow for the evaluation of
rainfall) particulate matter monitoring.
The Ash Dam monitoring program is designed to:

 Detect particulate matter emissions from the Ash Dam in directions of key sensitive receptors;
 Detect particulate matter emissions from the Ash Dam under conditions that have historically been
identified as high risk (i.e. adverse conditions) for visible dust, particularly, strong west to northwest winds;
 Permit the calculation of the Ash Dam’s contribution to air quality, through the use of monitors in multiple
directions relative to the Ash Dam;
 Allow for the evaluation and interpretation of particulate matter data using site specific meteorological
data; and
 Support the air quality management system via real-time alarms to inform actions.
The real time mobile PM10 monitors have been setup to record directional dust sources. The real time monitors
can be accessed remotely by ash dam contractors or environmental staff to monitor the performance of the ash
dam and guide the performance of the project on a day to day. In combination with visual inspections, the real
time monitors allow the ability to make operational changes or preventative measures prior to receiving alarm
triggers.
Alarms have been setup to trigger when the measured PM10 concentrations exceed prescribed levels with
contributions from the Ash Dam. These levels are defined in the TARP of Origin’s Ash Dam Dust Management
Procedure (Origin, 2022) (see Appendix B). Wind direction ranges have been calculated based on the position of
each monitor relative to the Ash Dam activities to make sure that alarms are representative of potential impacts
from the Ash Dam. The wind direction ranges are also outlined in the TARP of Origin’s Ash Dam Dust
Management Procedure (Origin, 2022).
Origin also operates four dust deposition gauges around the power station. These monitors are not used for
operational Ash Dam dust management purposes however, if required, the data from these monitors will be used
to further understand air quality related events.
Condition 4.8(e)(ii) of PA 07_0084 MOD1 requires that this Plan describes the measures to be implemented to
ensure that the air quality impacts of the project are minimised during adverse meteorological conditions and
extraordinary events. In this context, visible dust from the Ash Dam has historically been most commonly
associated with strong westerly winds over 6 m/s as an hourly average. The meteorological monitoring provides
real time data on rainfall, wind direction and speed, humidity and temperature for the site. The Environment
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Team collates the weather data to allow the Ash Dam Supervisor to monitor weather conditions on a weekly
basis and advise the Ash Dam Management Contractor where adverse weather conditions are forecast in line
with the trigger values in the TARP. The Environment Team and Ash Dam Management Contractor also receive
severe weather alerts by text message. Meteorological triggers have been developed to minimise the air quality
impacts of the Ash Dam during adverse meteorological conditions and extraordinary events. The triggers are
defined in the TARP of Origin’s Ash Dam Dust Management Procedure (Origin, 2022) and are applied to wind
speed, ambient air temperature and rainfall data logged at 10-minute intervals.
Alarm notifications are issued to the Ash Dam Contractor and Environment Team. Upon receiving these alarms,
the Environment Team or Ash Dam Contractor should contact the Ash Dam Supervisor to ensure that the
appropriate TARP actions are being carried out. If the alarms are received out of hours, the Shift Manager will be
notified. In the event an alarm is triggered, the site will record actions taken in response to the alarms in
accordance with the site procedures. This includes the review of any additional necessary management measures
to minimise dust generation.
The following processes are also implemented at the Ash Dam to monitor and respond to dust events:
 Maintenance of a documented register of all air quality monitoring units (via the EPS Data Acquisition
System);
 Establishment and operation of air quality monitoring stations that are fit for the purposes of this Plan; and
 Periodic inspections of dust management across the Ash Dam site.
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Figure 4 Location of air quality and meteorological monitoring stations for Ash Dam dust management
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4.4 Visual Monitoring
Surface condition monitoring is carried out at on a daily basis as a visual inspection by the Ash Dam
Management Contractor and Environment Officer, to determine whether dry fly ash is present, and is likely to
result in dust mobilisation. The visual inspection aims to identify if a hard crust has not formed, if the surface is
powdery in nature, or has formed into ripples.
Visual triggers, in order of increasing potential impact, are described as follows:

 Loose dust present on areas of the dam but not mobilised;
 Dust has mobilised but is localised and not travelling off-site; or
 Dust has mobilised and may be visible offsite.
All personnel working at the Ash Dam must complete an EPS and Ash Dam HSE induction. This includes a
requirement to report all observed environmental incidents including dust emissions at the ash dam. Such
incidents are reported to the Ash Dam Supervisor who will implement the relevant TARP procedures.
4.5 Proactive Management
Origin’s Environmental Forecast System comprises site specific meteorological forecasting and dust dispersion
modelling for the Ash Dam. This system aims to provide early warning of adverse meteorological conditions and
potential dust risks, thus facilitating proactive management of activities in order to reduce the potential for dust
generation.
Automated meteorological and dust risk forecasts are issued via email to Origin environmental and ash dam
operation teams each morning. The forecasts include two-day forecasts of site-specific meteorological
conditions and dust dispersion. Figure 5 shows an example of the site-specific daily environmental forecast.
The meteorological and dust risk forecasts are discussed at the start of each shift at the ash dam as part of
Toolbox Talks. This allows ash dam contractors and supervisor to prepare for dust management, as per the
TARP, if adverse meteorological conditions that could result in ash dam dust emissions are to develop as
forecast.
Environmental and ash dam operations staff are to review the daily forecast prior to the beginning of each shift
and, if required, discuss potential contingency measures with ash dam management staff to make sure that the
dust generation potential is minimised.
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Figure 5 Example daily environmental forecast
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4.6 Compliance
Origin implements a Compliance Tracking Program to track compliance with the conditions PA 07_0084 MOD1
including those relating to air quality. The process in which Origin implements the Compliance Tracking Program
and associated reporting in accordance with Condition 5.3 and 5.4 is captured as part of the Construction
Environmental Management Plan (CEMP) for the Project. In summary, the Compliance Tracking Program
include:
a) Provisions for periodic review of the compliance status of the proposal and each of its components;
b) Provisions for periodic reporting of compliance status to the relevant approval authority;
c) A program for independent environmental auditing of the proposal, in accordance with ISO 19011:2002 –
Guidelines for Quality and/or Environmental Management Systems Auditing; and
d) Mechanisms for rectifying any non-compliance identified during environmental auditing or review of
compliance.
Additionally, it provides for the provisions of regular compliance reporting to the Department on the project in
accordance with the relevant Compliance Reporting requirements (DPE, 2020).
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5. Complaint Management
Complaints will be managed in accordance with Origin’s Incident Management Procedures (Origin, 2021) and
the Eraring Power Station Environmental Management Plan (Origin, 2021).
Origin maintains a Community Response Line (phone number 02 4973 0700) that is allocated to the receipt of
community complaints. The Community Response Line is publicly advertised and operates 24 hours per day,
seven days a week, to receive any complaints from neighbouring residents or other stakeholders. The
Community Response Line also available on the Eraring Power Station website
(https://www.originenergy.com.au/about/who-we-are/what-we-do/generation.html).
Complaints are logged in a specific Eraring Power Station Complaints Register. Investigations will commence
within 24 hours of the receipt of a complaint to determine the likely cause of the complaint (i.e. meteorological
conditions and nature of site activities). This investigation will be used to develop appropriate mitigation
measures and timeframes for implementation. A summary of complaints and actions taken are discussed at the
Eraring Power Station Community Consultative Committee (CCC) Meetings.
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6. Incident and Non-compliance Reporting

PA 07_0084 MOD1 defines an incident as “a set of circumstances that causes or threatens to cause material
harm to the environment”. Condition 5.1 and 5.2 of Schedule 2 of PA 07_0084 MOD1 outline the conditions for
incident and non-compliance reporting.
In the context of the Ash Dam, an air quality-related incident has been defined as a time when dust emissions
generated by the Ash Dam had the potential to cause or threaten to cause material harm. These may defined by
a number of community complaints, significant/repetitive air quality trigger alarms or uncontrollable dust
emissions from the ash dam.
Incidents (including information on the location and nature of the incident) will be notified to the Department
and the EPA immediately in writing and identify the development (including the development application
number and name) and set out the location and nature of the incident. All incidents will be investigated to
determine compliance with PA 07_0084 MOD1.
Investigations of incidents will involve:

a) Documenting the date, time, and nature of the incident;
b) Identifying the cause (or likely cause) of the incident using appropriate monitoring data;
c) Describing what action has been taken to date; and
d) Describing the proposed measures to address the incident; and
e) Determining compliance with the relevant consent condition(s).
Incidents determined to represent a potential non-compliance will be documented in a written report and
submitted to the Department and the EPA within seven days of the incident notification. Incidents will be
managed in accordance with Origin’s Incident Management Procedures (Origin, 2021) and the Eraring Power
Station Environmental Management Plan (Origin, 2021).
In the event of a potential non-compliance with PA 07_0084 MOD1, within seven days of becoming aware of
non-compliance, notification to the Department must be completed in writing and include:
 The development application number and the name;
 The conditions of the consent that the development is non-compliant with;
 Information on why the development is not complying with the conditions of consent;
 The reasons for the non-compliance (if known)
 What actions have been, or will be, undertaken to address the non-compliance.
A non-compliance which has been notified to the Department as an incident does not need to also be notified as
a non-compliance.
Final 18
7. Access to Information and Record Keeping

7.1 Access to Information
In accordance with Condition 5.6 of PA 07_0084 MOD1, Origin will make the following information publicly
available, as it relates to this AQMP, on its website as relevant to the stage of the project:
 The EA’s;
 Current statutory approvals for the project;
 Approved strategies, plans and programs required under the conditions of this approval;
 A comprehensive summary of the monitoring results of the project, which have been reported in accordance
with the various strategies, plans and programs approved under the conditions of this approval;
 A complaint register; which is to be updated on a monthly basis;
 Any independent environmental audit, and the Proponents response to the recommendations in any audit;
and
 Any other matter required by the Secretary.
7.2 Record Keeping
In accordance with the Environmental Planning and Assessment Act 1979:

 Air quality monitoring data is maintained on the premise for a period of at least 5 years after the data were
collected.
 Documentation on air quality management and monitoring is maintained on the premise for a period of at
least 5 years after production, for the purposes of environmental auditing.
Final 19
8. Review and Training

8.1 Plan Review
This AQMP Plan will be reviewed in accordance with PA 07_0084 MOD1 and the Origin Environmental
Management System, that is:
 Every three years;
 Following an audit, where findings are relevant to this Plan;
 Following an environmental incident or community complaint relevant to the control measures outlined in
this Plan; or
 Following relevant outcomes from a risk assessment or change management process.
If any significant modifications to the AQMP are required as an outcome of the review, relevant government
agencies will be consulted regarding the changes and the revised AQMP will be submitted to the Department for
approval. Minor changes such as formatting edits will be discussed verbally with the Department prior to
completion and will be made following the Department’s confirmation.
This AQMP may also be revised due to:

 deficiencies being identified;
 the introduction of additional mitigation measures or controls;
 changing environmental requirements;
 improvements in knowledge or technology becoming available;
 changes in legislation; or
 the identification of a requirement to alter this AQMP following a risk assessment.
Additionally, in accordance with Condition 5.5 of PA 07_0084 MOD1, the AQMP will also be reviewed within 3
months of:
a) the submission of an incident report under condition 5.1; or
b) any modification to the conditions of the approval (unless the conditions require otherwise).
Origin will review, and if necessary, revise the AQMP to the satisfaction of the Planning Secretary. Where this
review leads to revisions of the AQMP, then within 4 weeks of the review, the revised management plan must be
submitted to the Planning Secretary for approval.
8.2 Training and Communication
Training with respect to Ash Dam dust management includes:

 Specific training sessions to employees and contractors as required.
 Communication of new or updated procedures at Ash Dam operations meetings and through site
communications.
 Toolbox talks for personnel involved in Ash Dam related activities.
Final 20
9. Roles and Responsibilities

A description of the roles and responsibilities for environmental management (including air quality
management) at the Ash Dam is provided in the Eraring Power Station Ash Dam Dust Management Procedure
(Origin, 2022). This includes the responsibility of all employees (including contractors) to environmental
management of the Ash Dam.
The Environment and Community Manager (or delegate) has direct oversight of developing, implementing, and
reviewing air quality management and monitoring procedures (including this plan) in conjunction with other
senior management team personnel. The Environment and Community Manager (or delegate) also has direct
responsibility for responding to community complaints (Section 4.6) and reporting incidents (Section 6). The
day to day responsibility of responding to real-time dust triggers (including forecast weather conditions) is
outlined in Table 2.
Final 21
10. Definitions
Term Definition
AQMP Air Quality Management Plan
DPE Department of Planning and Environment
EPA Environment Protection Authority
EPS Eraring Power Station
HSE Health, Safety, Environment
PM2.5 Airborne particulate matter with equivalent aerodynamic diameters of less than 2.5 micrometres (µm)
PM10 Airborne particulate matter with equivalent aerodynamic diameters of less than 10 micrometres (µm)
TARP Trigger Action Response Plan
TSP Total suspended particulates. The nominal size of this fraction has particles up to 50 micrometres (µm)
Final 22
11. References
DEC (2007) “Approved Methods for Sampling and Analysis of Air Pollutants in New South Wales”.
EPA (2016) “Approved Methods for the Modelling and Assessment of Air Pollutants in NSW”. Environment
Protection Authority.
DPE (2018) “Compliance Reporting – Post Approval Requirements”. May 2020.
Origin (2021) “Eraring Power Station Environmental Management Plan”. GEN-HSE-EMP-EPS.
Origin (2021) “Incident Management Procedures”.
Origin (2021) “Generation HSE Management Plan”.
Origin (2021) “Eraring Power Station (EPS) Safe Systems of Work”.
Origin (2022) “Ash Dam Dust Management Procedure”. EPS-ENV-PRC-002. Version 2.0, released 10 February
2022.
Final 23
Appendix A. External Consultation Records
Final
Department of Planning and Environment
Our ref: MP07_0084-PA-1

Matt Davies
Principal Advisor Environment
Origin Energy Eraring Pty Ltd
09/06/2022
Subject: Air Quality Management Plan for Eraring Power Station – Ash Dam Expansion
(MP07_0084)
Dear Mr. Davies
I refer to your submission dated 14 March 2022, requesting approval of the Air Quality Management
Plan (Revision 0, March 2022). I also acknowledge your response to the Department’s review
comments and requests for additional information.
I note the Air Quality Management Plan has been prepared in consultation with the EPA and contains
the information required by the conditions of approval.
As nominee of the Planning Secretary, I approve the Air Quality Management Plan (Revision 1 June
2022) under Condition 4.8.
Please ensure that the approved plan is placed on the project website at the earliest convenience.
If you wish to discuss the matter further, please contact Charissa Pillay on 02 99955944.
Yours sincerely
Stephen O'Donoghue
Director
Resource Assessments
As nominee of the Planning Secretary
4 Parramatta Square, 12 Darcy Street, Parramatta NSW 2150 www.dpie.nsw.gov.au

1
Locked Bag 5022, Parramatta NSW 2124
Appendix B. Eraring Power Station Ash Dam Dust Management

Procedure
Final
Procedure
EPS-ENV-PRC-002
Eraring Power Station

Ash Dam Dust Management Procedure
Version: 2.0
Released: 10 February 2022
Document owner: Eraring Operations Manager, BOP and ERAD
Review date: 10 February 2023
Please see document control section for more information.

For internal Origin use and distribution only.
Subject to employee confidentiality obligations. Once printed, this is an uncontrolled version.
Please check this is the latest version on the Generation Controlled Document Dashboard.
Good energy also means being kind to the environment. Ask yourself, ‘Do I really need to
print this document?’
EPS Dust Management Procedure
Contents
1. Purpose.......................................................................................................................... 3
2. Scope ............................................................................................................................. 3
3. Definitions ...................................................................................................................... 4
4. Responsibilities .............................................................................................................. 5
4.1 Legislation ............................................................................................................... 6
4.2 Assessment of Sensitive Receptors ........................................................................ 7
4.3 Risk Reviews........................................................................................................... 7
5. Resources ...................................................................................................................... 8
5.1 Access to the Ash Dam ........................................................................................... 8
6. Safety ............................................................................................................................. 8
7. Implementation ............................................................................................................... 8
7.1 Dust Management ................................................................................................... 8
7.2 Trigger Action Response Plan (TARP) .................................................................... 9
7.3 Ash Dam Surface Dust Control Measures ............................................................... 9
7.3.1 Dust Mitigation ................................................................................................. 9
7.3.2 Pro Active CCP Management Strategies .......................................................... 9
7.3.3 Crusting Agents or Polymer.............................................................................10
7.3.4 Spray Irrigation ................................................................................................10
7.3.5 Ash Placement ................................................................................................11
7.3.6 Ash Dam Capping ...........................................................................................11
7.3.7 Helicopter Water Bombing Procedure .............................................................11
7.3.8 Dust Generation from Truck Movements .........................................................11
8. Incident & Complaint Management ................................................................................12
8.1 Training and Awareness.........................................................................................12
9. Monitoring .....................................................................................................................12
9.1 Surface Condition Monitoring .................................................................................12
9.2 Air Quality Monitoring .............................................................................................13
10. Weather Monitoring ...................................................................................................13
11. Reporting ...................................................................................................................13
12. Review .......................................................................................................................13
13. References ................................................................................................................14
14. Document Control ......................................................................................................15
Appendix 1. Examples – Visual Assessment for Raising a Dust Incident .....................16
Appendix 2. Trigger Action Response Plan (TARP) .....................................................17
Appendix 3. Ash Dam Surface Condition Inspection ....................................................18
EPS-ENV-PRC-002
Released 10 February 2022 – Version 1.0 Page 2 of 18
1. Purpose
The purpose of the Ash Dam Dust Management Procedure is to outline the process of
dust management to be applied when accessing and completing work on the Eraring
Power Station Ash Dam (ERAD).
It forms a part of the Generation wide safe systems of work and is to be used in
conjunction with the Generation HSE Management Plan and Eraring Power Station
(EPS) Safe Systems of Work.
It specifies:
• Roles, responsibilities and accountabilities,
• Provisions for planning, implementation, monitoring and review, and
• A framework for responding to escalating risk through predetermined actions.
2. Scope
This procedure applies to the ERAD live storage area and all personnel accessing or
working on the ash dam, including employees and contractors.
This procedure applies to any person working for Origin in any capacity, including
employees, contractors and consultants.
EPS-ENV-PRC-002
3. Definitions
Term / Acronym Definition
Approved Activities Operating and maintenance activities requiring access to the
ash surface as approved under SOP EPS-AMs-PRC-004,
Section 3.1.
Ash Dam Team Ash Strategy and Management Lead, Ash Dam Civil Engineer
and Ash Dam Supervisor
Ash Surface All historic or future fly ash surfaces created by hydraulic
placement (wet sluiced) or Dry Stack.
Cell Ash deposition impoundment areas created by constructing
bunds, typically from excavated ash sourced adjacent to the
bunds.
DSEP Dam Safety Emergency Plan.
EoR Engineer of Record.
ERP Emergency Response Plan.
EPA Environmental Protection Authority.
EPS Eraring Power Station.
ERAD Eraring Power Station Ash Dam.
JSEA Job Safety Environmental Analysis.
Lone Worker Workers working on the ash dam footprint that are not within
verbal communication range of another worker.
These workers are required to have completed an Ash Dam
Induction, carry an individual mobile phone and if operating in
equipment have an operating UHF radio to channel 32.
Routine Activities Routine activities conducted on the ash dam:
• Vacuum trucks.
• Earth works, e.g. grading, excavation, stockpiling.
• Road repair.
• Ash dam inspection, maintenance and remediation.
• Long reach activities.
• Landscape maintenance, i.e. mowing, shrub removal,
mulching and weed removal.
• Drains maintenance.
• Ash deposition.
• Polypipe installation.
• Dust Management
SOP Standard Operating Procedure.
SWMS Safe Work Method Statements.
TGS Traffic Guidance Scheme.
TMP Traffic Management Plan.
TARP Trigger Action Response Plan.
EPS-ENV-PRC-002
4. Responsibilities
Origin Energy (Dam Owner):
• To comply with Dam Owner statutory responsibilities under the Dams Safety Act.
Eraring Power Station (EPS) Management:
• To administer all affairs relating to the ERAD,
• To develop, implement and monitor operational policy,
• To ensure the provision of adequate resources to maintain the ERAD,
• To authorise water release from the ERAD to Crooked Creek, and
• Is accountable for the safe operations of the ERAD.
EPS Ash Dam Operations and Maintenance:
• To ensure operation of the ERAD mechanical and electrical equipment,
• To update the Operations Log,
• To record the decant pond data,
• To report emergency conditions,
• To operate the decant pond, Return Water Pond and Toe Drain Pond, and associated
auxiliary infrastructure and equipment,
• To operate fly ash and bottom ash slurry pumps,
• To operate demineralised plant wastewater and other process water pumps that
convey water into the ERAD, and
• To ensure maintenance of the ERAD mechanical and electrical equipment is
completed in accordance with requirements detailed in Section 8.10.
Dam Safety Consultant / Engineer of Record:
• To conduct comprehensive annual surveillance inspections,
• To conduct special ERAD safety inspections,
• To identify and report to EPS Management any ERAD deficiencies,
• To recommend remedial measures,
• To provide engineering support to the Ash Dam Team,
• To validate designs related to the stability of the dam embankment, and
• To validate design of works that will be undertaken over liquefiable soils.
Ash Dam Team:
The Ash Dam Team is composed of:
• ERAD & BOP Manager,
• Ash Manager,
• Ash Dam Engineering Specialist,
• Ash Dam Reliability and Compliance Specialist,
• Ash Dam Operations and Maintenance Specialist, and
• The Ash Dam Team is supported by a dedicated H&S Business Partner.
The main responsibilities of the Ash Dam Team are:
• To report to and liaise with Dams Safety NSW,
• To implement ERAD safety management activities,
• To report on dam conditions,
EPS-ENV-PRC-002
• To define and implement the ash placement strategy,
• To maintain the ERAD structures and appurtenances,
• To implement ERAD preventative and corrective maintenance,
• To analyse monitoring data,
• To conduct routine ERAD inspections,
• To manage ERAD contractors,
• To maintain and update ERAD related documents, including the annual update of
this Manual, and
• To define and implement strategies to mitigate dust.
4.1 Legislation
The Protection of the Environment Operations Act 1997 and its associated Regulations
are the primary legislation relating to dust and air quality management.
Under the provisions of this Act, Eraring Power Station holds Environmental Protection
Licence 1429, which contains the following conditions relevant to dust management:
• O1.1 – Licensed activities must be carried out in a competent manner. This includes
a) The processing handling, movement and storage of materials and substances
used to carry out the activity and b) the treatment, storage, processing, processing,
reprocessing, transport and disposal of waste generated by the activity,
• O2.1 – All plant and equipment installed at the premises or used in connection with
the licensed activity a) must be maintained in a proper and efficient manner and b)
must be operated in a proper and efficient manner.
• O3.1 – The premises must be maintained in a condition which minimises or prevents
the emission of dust,
• O3.2 – All operations and activities occurring at the premises must be carried out in
a manner that will minimise the emission of dust from the premises, and
• O3.3 – Trucks entering and leaving the premises that are carrying loads of dust
generating materials must have their loads covered at all times, except during loading
and unloading.
The Eraring Power Station Ash Dam is also subject to the conditions of Project Approval
06_238 under Section 75J of the Planning and Assessment Act 1979. This Project
Approval contains the following conditions relating to dust management:
• 2.1 - The Proponent shall construct the project in a manner that minimises dust
emissions from the site, including windblown dust and traffic generated dust. All
activities on the site shall be undertaken with the objective of preventing visible
emissions of dust from the site. Should such visible dust emissions occur at any time,
the Proponent shall identify and implement all practicable dust mitigation measures,
including cessation of relevant works, as appropriate, such that emissions of visible
dust cease.
EPS-ENV-PRC-002
4.2 Assessment of Sensitive Receptors
Ash Dam Dust Dispersion modelling (AECOM, 2016) identified that the communities
most at risk of dust impacts were Rathmines, Arcadia Vale, Balmoral, Buttaba, and
Wangi Wangi to the east of EPS (Figure 1), and to a lesser extent Myuna Bay and
Toronto. These communities would be most impacted by winds from a north westerly
direction. There is also potential for impact at the Myuna Bay Sport and Recreation
facility where northerly winds occur, due to its proximity to the ash dam.
The modelling predicted that the NSW PM10 criterion would potentially be exceeded on
one day of the year, although the likelihood of an exceedance was considered low. All
predicted exceedances were in spring or winter. The modelling indicated that all heavy
metals met relevant EPA assessment criteria by some margin.
Figure 1 Sensitive Receptors
4.3 Risk Reviews

Dust risk will be reassessed and control measures tracked by the attendees at Ash Dam
Operations meetings at the frequency indicated in the Trigger Action Response Plan in
Appendix 2Error! Reference source not found. and communicated to Management at
monthly Risk and Compliance Meetings by the Senior Environment Business Partner.
EPS-ENV-PRC-002
5. Resources
The Ash Dam Operations and Maintenance Specialist must consult with all stakeholders
and EPS Management on an annual basis to ensure that sufficient resources are
allocated to fulfil the requirements within this Plan. Resource considerations should
include budget allocation, personal and equipment requirements.
Arrangements must be made available for resourcing to manage dust events outside of
normal hours, with on call staff to be deployed as required in the Trigger and Response
Plan.
5.1 Access to the Ash Dam
Before accessing the ERAD, all personnel and contractors must be ash dam inducted.
The Ash Dam Standard Operating Procedure – Accessing the ERAD Ash Surface for
Approved Operating and Maintenance Activities (EPS-AMS-PRC-004) provides
instruction for gaining safe access to the ash dam surface for approved activities or
maintenance, by foot or approved equipment.
Access to the ash surface is otherwise prohibited, unless risk assessed as being safe to
access and technically validated and approved by the Engineer of Record (EoR).
The induction must be completed annually
6. Safety
A full risk assessment must be undertaken in line with Origin procedures, and any
identified controls are to be implemented. Any access restrictions should be adhered to.
Refer to the Ash Dam Operations & Maintenance Manual and EPS Emergency
Response plan for further detail on safety requirements
Roles, responsibilities and accountabilities are as per those defined within the Ash Dam
Asset Management Strategy.
7. Implementation
7.1 Dust Management
During periods of high wind, operators may be required to cease operations to reduce
exposure to, and the creation of dust. Dust masks are to be in all vehicles and where
vehicles are air conditioned, they shall be operated with the windows closed.
The Ash Dam Operations and Maintenance Specialist must consult with all stakeholders
and EPS Management on an annual basis to ensure that sufficient resources are
allocated to fulfil the requirements within this Plan. Resource considerations should
include budget allocation, personnel and equipment requirements. Refer section 4.2 for
Assessment of Sensitive Receptors.
The EPS Ash Placement Plan (EPS-AMS-PLN-002) details the ash placement
methodology that minimises dust risk through various methods.
The Ash Dam Contractor provides the arrangements for resourcing to manage dust
events outside of normal hours (weekends and public holiday), with on call staff to be
deployed as required in the TARP. This is communicated to the Ash Dam Operations
and Maintenance Specialist on a weekly basis, who in turn will inform the Ash Manager
so that updates may be made to TARP levels.
EPS-ENV-PRC-002
7.2 Trigger Action Response Plan (TARP)
A Trigger Action Response Plan (TARP has been developed and is included in Appendix
2. A TARP is designed to provide guidance for the levels of response when normal
operating conditions begin to change and where these changes may lead to unwanted
or undesirable impacts on Origin’s HSE policy, plant and our communities.
As conditions deteriorate the TARP provides the required information for the escalation
of the response required and those who must be notified and involved in the decision-
making process and the specific steps to be followed. The Ash Manager is responsible
for designating and communicating TARP risk levels.
Consideration should be given to the hierarchy of controls when assessing appropriate
solutions (1 being most effective, 4 being least effective)
1. Elimination/Substitution (e.g. capping, ash reuse, proactive strategies)

2. Engineering (polymer, ash placement)
3. Administration (plans and procedures for dust mitigation)
4. Reactive Controls (e.g.spray irrigation, helicopter water bombing)
7.3 Ash Dam Surface Dust Control Measures
A number of dust control measures may be applied, and are summarised below.
7.3.1 Dust Mitigation

Weather events, including wind speed and direction are monitored at the start of the shift
and periodically through the day to minimise dusting events. Due to the fine particle size
and moisture content of the ash, dusting events as shown in Appendix 1 can occur
resulting in a dust incident
Dust risk will be assessed, and control measures tracked by the frequency indicated in
the TARP in Appendix 2 and communicated to the Environment Team.
If winds are elevated, placement of polymer and water cannons are deployed as
necessary to minimise the creation of airborne dust. At the start of a shift if moderate to
high winds are forecast (greater than 20km/h), planning is undertaken to respond with
dust management measures which can be deployed as winds increase.
Vehicles can create airborne dust and speed is minimised in the dam area to 40km/h
and 20km/h on the ash surface. If the road behind the vehicle is dusting at this speed,
speed must be reduced to minimise the amount of dust creation.
Weather forecasts are reviewed daily by the Ash dam contractors and the Ash dam
Operations and Maintenance Specialist to determine any preventative measures that
may be required.
7.3.2 Pro Active CCP Management Strategies

Dusting risk can be minimised by ensuring that the CCP plant and ash dam are operated
and maintained to design specifications. Regular review of maintenance and operating
strategies for CCP assets should be undertaken to ensure that this is occurring.
Examples may include reviews of
• Ash classifiers and truck loading plant availability optimisation
• Dense phase ratios
• Effective strategy around slurry valves and lines
• Placement strategy
EPS-ENV-PRC-002
• Maximising CCP recycling options
The Ash Dam Asset Management Strategy should be updated at the frequency specified
within that Plan to ensure these reviews are incorporated.
7.3.3 Crusting Agents or Polymer

Crusting agents or polymer may be applied on any exposed ash surface where no
discharge is likely to occur imminently. Experience has shown that polymer is less
effective on areas where there is a deep layer of fine fly ash material, due to instability
causing the surface film to crack. In these circumstances, strategic ash placement may
present a more effective option.
Any crusting agent or polymer used on the ERAD must be approved by the
Environmental Protection Authority (EPA) before use, and any monitoring and reporting
required by the EPA must be completed.
When required to use any crusting agent or polymer the manufacturer’s advice should
be followed to ensure application and dosage rates are applicable and efficient. Polymer
may be applied using hoses or mobile spray irrigation units, in accordance with the
Eraring Power Station Ash Dam Standard Operating Procedure – Accessing the ERAD
Ash Surface for Approved Operating and Maintenance Activities (EPS-AMS-PRC-004).
Care should be taken to avoid spraying the product near waterways.
The Ash Dam Operations and Maintenance Specialist should report monthly to the Ash
Dam Supervisor on the condition of polymer through the Start of Day Ash Manager Form
(EPS-AMS-FRM-004), to inform priority areas.
Where any disturbance of the ash surface has occurred (for example, node building, ash
excavation) polymer should be applied to that area as soon as practicable to prevent
dust mobilisation.
7.3.4 Spray Irrigation

Water supply may be sourced from the ash dam pondage, freshwater catchment
(Settling Pond 1) to the north-east, from water trucks, or 10 South bore (Awaba Mine
water). Local water supplies should be the preference where available.
Spray irrigation may be used as a proactive or reactive dust suppression measure in line
with the TARP specifications in Appendix 2 on the ash dam surface or on bottom ash
stockpiles.
It is preferable spray irrigation only be used in the short term where dust mobilisation is
occurring. A more sustainable solution such as polymer application, strategic placement
or capping should be considered where a persistent problem is identified.
The ash dam spray irrigation infrastructure includes:
• 4 high head pressure diesel pump sets
• 25 x 23kl water tanks and fittings
• 2 x 0.5 Mega litre tanks
• 15 water cannons
• 130 misting sprays and associated infrastructure
Weather forecasts should be monitored by the Ash Operations and Maintenance

Specialist, who should then relocate sprays proactively (preferably two days prior) to
account for any dry areas identified in Surface Condition Monitoring and ahead of windy
and/or dry conditions.
EPS-ENV-PRC-002
7.3.5 Ash Placement
Dust risk may be reduced by placing ash strategically to ensure that as much surface
area as possible is kept moist.
The Ash Dam Asset Management Strategy and Ash Dam Operations and Maintenance
Manual detail an ash placement methodology which minimises dust risk through cycling
ash placement over a number of ash cells or terraces on a regular basis. The Ash Dam
Operations and Maintenance Specialist may request that the Committee review this
methodology where the dusting risk looks to be increasing in a particular area.
7.3.6 Ash Dam Capping

Capping is the most effective solution to address ash dam dust where there is a
persistent problem and ash discharge is not likely to occur again in an area over the life
of the dam. Any proposal to cap the dam should be assessed by the Ash Dam Civil
Engineer before being presented to the Generation Head of Operation Services by the
Ash Manager. Management of Change protocols must be adhered to.
Any capping materials obtained from offsite must be approved by the EPA or have been
assessed as certified ENM or VENM in accordance with EPL1429 and the EPS VENM
procedure. EPS fill receival procedure must be adhered to.
EPL1429 also permits material meeting the definitions within the Compost, Manure and
Mulch Order and Exemption, and the Biosolids Order and Exemption. No material
classified as a waste under NSW EPA guidelines should be accepted onsite unless
authorised in EPL1429.
Sufficient monitoring must occur in line with the EPS fill receival procedure for any
materials brought onsite as certified exempt wastes, to verify that they meet the definition
of that exempt waste. Regular visual inspections should also be conducted to ensure
exempt waste meets specifications. A full risk assessment should be carried out to
ensure appropriate controls have been implemented prior to such exempt waste being
brought onsite.
Appropriate sediment controls must be put in place where loose material is being stored
or placed.
If capping materials are being sourced from onsite, the EPS Environment Team must be
consulted for advice.
7.3.7 Helicopter Water Bombing Procedure

Where a significant dust event is occurring, the EPS Group Manager or ERAD & BoP
Manager may authorise the use of water bombing helicopters. Water bombing should be
considered a last resort when a serious Level 3 dust event is underway, as outlined in
the TARP in Appendix 2.
Lake Macquarie Helicopters can be contacted on 0408 434 639.
7.3.8 Dust Generation from Truck Movements

Any road registered trucks carrying ash materials when leaving the Ash Dam footprint,
must be covered at all times, except during loading and unloading.
During loading or unloading activities, the material should be kept moist to minimise dust
using a wet ring.
EPS-ENV-PRC-002
A water supply is available at the truck unloading area west of the siphon pond. Weather
conditions should be monitored closely during unloading, and the job stopped
immediately if excessive windblown dust is visible.
Where truck movements are occurring on the Ash dam roadways, a water truck should
be used to wet the road surface to minimise generation of dust.
Where paved roads are generating dust, road sweepers should be utilised. If required, a
regular road sweeping routine should be implemented to minimise mobilisation of dust.
8. Incident & Complaint Management

Dust incidents and complaints will be managed in accordance with Origin’s Incident
Management Procedures and the Eraring Power Station Environmental Management
Plan. GEN-HSE-EMP-EPS Guidance on what constitutes a dust incident on the ash dam
is provided in Appendix 1.
8.1 Training and Awareness
Training implemented with respect to ash dam dust management includes the following:
• Issue specific training sessions provided to employees and contractors as required.
• New or updated procedures being communicated at Ash Dam Operations Meetings
and through site communications.
• Toolbox Talks for impacted personnel.
9. Monitoring
Monitoring to inform on the likelihood of a dust event occurring is summarised below.
9.1 Surface Condition Monitoring
Each week surface condition on each of the ash dam areas should be assessed, to
determine whether further dust mitigation controls need to be applied, using the Surface
Condition Monitoring Inspection in Appendix 3.
The Surface Condition Monitoring Inspection entails a visual inspection undertaken by
the Ash Dam Operations and Maintenance Specialist and Environmental Business
Partner, to determine whether dry fly ash is present, and is likely to result in dust
mobilisation. If the ash surface:
• Has not formed a hard crust
• Is powdery in nature an becomes airborne when disturbed
• Has formed into ripples
Plans should be put into place by the Ash Dam Operations and Maintenance Specialist
to apply additional polymer to such areas or assess the need for permanent capping.
In situ ash surface moisture probes may be installed in any areas where a potential issue
has been identified. Any ash surface with less than 5% moisture should be considered
high risk.
The results of each inspection are to be presented at the ash dam operations meeting
and a review undertaken into the adequacy of polymer application during the meeting. A
copy of the condition monitoring inspection map and details of decisions made with
regard to whether any further polymer application is required should be tabled in meeting
minutes.
EPS-ENV-PRC-002
9.2 Air Quality Monitoring
The air quality monitoring network for the ash dam consists of four meteorological and
mobile airborne Particulate Matter (PM10) monitors and stationed around the ash dam,
PM2.5 and PM10 TEOMs at Marks Point and Dora Creek ambient air monitoring stations,
and four dust deposition gauges positioned around site. EPA monitoring sites are shown
on the map in DOC16/63431..
Air quality monitoring is undertaken in accordance with the relevant Australian Standards
and legislation and the NSW Office of Environment and Heritage, Approved Methods for
the Sampling and Analysis of Air Pollutants in New South Wales (DECCW, 2007).
Air quality monitoring data is recorded in the EPS Data Acquisition System.
The mobile airborne particulate monitors around the ash dam send alarm notifications to
the Ash Dam Supervisor and Origin Environment Team when dust levels exceed given
criteria.
Upon receiving these alarms, the Origin Environment Team or Ash Dam Operations and
Maintenance Specialist should contact the Ash Dam contractors to ensure that the
appropriate TARP actions are being carried out. If the alarms are received out of hours
and the Ash Dam Contractor is unavailable, the Shift Manager should notify the Ash
Operations and Maintenance specialist. The Ash Dam Team must communicate any
instances of alarms to the Ash Manager so that TARP levels can be reviewed.
10. Weather Monitoring

A weather station is position is positioned on the western side of the dam, and the four
mobile PM10 monitors stationed around the ash dam are equipped with meteorological
monitoring. This provides real time data on rainfall, wind direction and speed, humidity
and temperature for the site.
The Origin Environment Team collects weather data to allow the Ash Operations and
Maintenance Specialist to monitor weather conditions on a weekly basis and advise the
Ash Dam contractor where adverse weather conditions are forecast in line with the
trigger values within the Trigger Action Response Plan in Appendix 2
The Environment team and Ash Dam contractor also receive severe weather alerts by
text message.
11. Reporting
The Ash Manager should minute and communicate any changes in health, safety or
environmental risk level to the Plant Manager so that current risk ratings can be updated,
and the changes communicated at Risk Governance meetings.
Any actions relating to dust risk management must be documented and tracked by the
Ash Dam Civil Engineer, with outstanding actions being reviewed by the Ash Manager.
The Ash Manager must specify what trigger level of the TARP applies at each Ash Dam
Short Term Placement Meeting.
12. Review
This plan is to be reviewed every year, or within three months after any dust events have
occurred.
EPS-ENV-PRC-002
13. References
• Origin HSE Systems Directive.
• Eraring Ash Dam Operations and Maintenance Plan (EPS-ASM-PLN-001).
• Eraring Power Station Ash Placement Plan (EPS-AMS-PLN-002).
• Eraring Power Station Ash Dam Safety Emergency Plan (EPS-HSE-PLN-008).
• Eraring Power Station Emergency Response Plan (EPS-HSE-PLN-003).
• Eraring Power Station Ash Dam Standard Operating Procedure – Accessing the
ERAD Ash Surface for Approved Operating and Maintenance Activities (EPS-AMS-
PRC-004).
• Ash Dam Start of Day Inspection Form (EPS-AMS-FRM-004).
• EPS Environmental Management Plan (GEN-HSE-EMP-EPS).
• EPS Environmental Compliance Manual (EPS-ENV-PLN-003).
• Ash Dam Induction (EM-GEN-WBT11458).
• Eraring Power Station Traffic Management Plan (EPS-HSE-PLN-018).
• Eraring Power Station Two-Way Radio Guideline (EPS-HSE-GDL-006).
• AECOM, 2016 - Ash Dam Dust Emission and Dispersion Study pp. 68. OpenText ID:
30790888.
• AECOM, 2017 - Eraring Power Station Ash Dam Asset Management Strategy.
• Origin, 2015 VENM procedure (EPS-AMS-GDL-001).
• Contractor Ash Dam Traffic Management Plan(s).
EPS-ENV-PRC-002
14. Document Control
Author (To Whom any changes are to be recommended)
Position Incumbent
Senior Environment Business Partner Gemma Dobson
Stakeholders and other contributors
Position Incumbent
Reviewed by
Position Incumbent Review date
Health and Safety Business Partner Jodie Haylock 02/02/2022
Approved by
Position Incumbent Approval date
Eraring Operations Manager, BOP & ERAD Rob Chapman 10/02/2022
History
Date Author Version Nature of change
March 2017 Gemma Dobson 1.0 Initial release.
Minor change: updated dust
management practices & TARP,
29/01/2019 Gemma Dobson 1.1
safety provisions and truck dust
control
Major change: separated Ash Dust
27/09/2021 Jodie Haylock 2.0 Management Plan from Ash Dam
Ash and Dust Management Plan
Related Documents
Title Document ID
Ash Dam Asset Management Strategy TBA
Ash Dam Operations and Maintenance Plan OT ID: 30768179
Ash Dam Emergency Response Scenario OT ID: 30828115
Review Requirements
This document is next due for review 10 February 2023 by Senior Environment
Business Partner
Controlled Document Location
OpenText ID: 33326293
EPS-ENV-PRC-002
Appendix 1. Examples – Visual Assessment for Raising a Dust Incident
Level 1 Level 2 – Raise Minor Environmental Incident Potential Level 3 – Check to see if visible Off Site and
consider EPA report.
A Loose dust is present on areas of the dam but has not B Dust has mobilised but is localised and not travelling C Dust has mobilised and may be visible offsite – check
visibility from Wangi Road between EPS and Rathmines.
mobilised offsite.
EPS-ENV-PRC-002
Appendix 2. Trigger Action Response Plan (TARP)
Note: A TARP is designed to provide guidance for the levels of response when normal operating conditions begin to change and where these changes may lead to unwanted or undesirable impacts
on Origin’s HSE policy, plant and our communities. As conditions deteriorate the TARP provides the required information for the escalation of the response required and those who must be notified
and involved in the decision-making process and the specific steps to be followed.
Trigger Normal Level 1 Level 2 Level 3

Trigger Criteria All of the following apply: No level 2 or 3 triggers apply and any of the  A dust incident is occurring or has occurred in  A dust incident is occurring or has occurred in the past 7 days
 Winds are forecast 0-20km/hr from following apply: the past 7 days but is not visible offsite and was potentially visible offsite
any direction over the next 7 days  Winds are forecast over 20km/hr for  Dust monitors have alarmed  Dust monitors have alarmed
 No dust incidents have occurred the next 7 days
within the past three months;  Areas of dry (<5% moisture) or loose
 No significant areas of loose ash ash have been identified through ash
have been identified from dam inspections. And/Or
inspections over the past month.  A dust incident has occurred between
7 days and 1 month ago.
Polymer Polymer coverage effectiveness to be Polymer coverage effectiveness to be Where no other viable solutions can be deployed, Where no other viable solutions can be deployed, polymer coating is to
Application reviewed monthly as per the Ash Dam reviewed fortnightly as per the Ash Dam polymer coating is to be applied to area of concern be applied to area of concern where safe and practicable by Ash Dam
Surface Condition Monitoring Check sheet Surface Condition Monitoring Check sheet by where and practicable by Ash Dam Contractor. Contractor.
by Ash Dam Contractor, and reapplied as Ash Dam Contractor and reapplied where
necessary. necessary.
Spray Irrigation No proactive spray irrigation necessary. Spray irrigators to be deployed proactively by Spray irrigators to be positioned in area of concern by Spray irrigators to be positioned in area of concern by Ash Dam
Ash Dam Contractor where wind and/or Ash Dam Contractor and be deployed for as long as Contractor and be deployed for as long as practicable while Level 2
temperature are forecast above thresholds in practicable while Level 2 current. current.
next 7 days to keep ash surface moist. Ash
Dam Operations and Maintenance Specialist
to review effectiveness of spray irrigation and
assess merits of polymer application or
capping as alternatives.
Helicopter Not required. Not required. Not required. May be used as an emergency measure at the discretion of the Plant
Water Bombing Manager or ERAD & BoP Manager.
Safety Work in accordance with the Ash Dam Work in accordance with the Ash Dam Work in accordance with the Ash Dam Operations and Work in accordance with the Ash Dam Operations and Maintenance
Considerations Operations and Maintenance Plan and EPS Operations and Maintenance Plan and EPS Maintenance Plan and EPS Emergency Response Plan. Plan and EPS Emergency Response Plan. Undertake risk
Emergency Response Plan. Undertake risk Emergency Response Plan. Undertake risk Undertake risk assessment before working on or around assessment before working on or around the dam. Avoid accessing
assessment before working on or around assessment before working on or around the the dam. Avoid accessing areas where dust is occurring areas where dust is occurring unless necessary. No access to be
the dam. No specialist PPE required. P2 dam. At a minimum a P2 dust mask and unless necessary. No access to be made to dusting made to dusting areas unless wearing a Powered Air Purifying
dust mask and sealed goggles should be sealed goggles should be worn if any dust areas unless wearing a Powered Air Purifying Respirator.
on hand if working on or around the dam mobilisation is likely to impact work area. Respirator.
surface should conditions change.
Monitoring Ash Dam Operations Meeting to convene Ash Dam Operations Meeting to convene Ash Dam Operations Meeting to convene weekly and Ash Dam Operations Meeting to convene weekly and review weather,
weekly and review weather, surface weekly and review weather, surface condition, review weather, surface condition, incidents and polymer surface condition, incidents and polymer coverage as agenda items
condition, incidents and polymer coverage incidents and polymer coverage as agenda coverage as agenda items, with information provided by with information provided by the ash dam contractor.
as agenda items, with information provided items, with information provided by the ash the ash dam contractor.
by the ash dam contractor. dam contractor. A full review of the effectiveness of dust mitigation measures should
A full review of the effectiveness of dust mitigation be undertaken, with a documented plan developed and communicated
measures should be undertaken, with a documented by the Ash Dam Coordinator for reducing the dust risk.
plan developed and communicated by the Ash Dam
Operations and Maintenance Specialist for reducing the
dust risk.
Reporting Ash Dam Operations and Maintenance Ash Dam Operations and Maintenance Ash Dam Operations and Maintenance Specialist to Ash Dam Operations and Maintenance Specialist to report and minute
Specialist to report and minute current level Specialist to report and minute current level at report and minute current level at Ash Dam Operations current level at Ash Dam Operations Meeting. All dust incidents to be
at Ash Dam Operations Meeting Ash Dam Operations Meeting. Meeting. All dust incidents to be logged in the incident logged in the incident management system. Incidents assessed as
management system. level 3 to be referred to Group Manager Eraring Operations or
delegate as potentially EPA reportable.
EPS-ENV-PRC-002
Appendix 3. Ash Dam Surface Condition Inspection
Date:.......................................... Time:............................................ Name..........................................
Instructions: Other Comments:

.........................................................................................
1. On latest available Nearmaps aerial, cross hatch any areas where loose, dried out ash is present and may become
mobilised, or any areas where a previously applied polymer coating is degrading. Record actions to be taken to address .........................................................................................
any identified issues below, responsibility and forecast completion date.
.........................................................................................
Action Responsibility Due
Date
Status .........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
2. Hatch any areas where polymer has been applied and appears effective and stable.
........................................................................................
..…………………………...................................................
3. Email copy of report back to Environment Team and Ash Dam Coordinator monthly or fortnightly depending on trigger
level. .........................................................................................
4. These checksheets should be reviewed at the Ash Dam Operations Meeting, with actions determined and filed with the .........................................................................................
Ash Manager.
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
.........................................................................................
....
EPS-ENV-PRC-002

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Eraring Power Station Coal Combustion Management Facility

Air Quality Management Plan

Origin Energy Eraring Pty Ltd

A ir Quality Mana gem en t Pla n

Eraring Power Station Coal Combustion Management Facility

Project No: IA316800

Jacobs Group (Australia) Pty Limited

Document history and status

Revision Date Description Author Reviewed Approved

The objectives of this AQMP are to:

Table 1 Air Quality Management Plan Requirements

Project Approval Condition Section of this Plan

Condition 2.9 of Schedule 2 of PA 07_0084 MOD1 Section 3.3, odour is not

b) be prepared in consultation with the EPA; Appendix A provides relevant

Condition 5.1 of Schedule 2 of PA 07_0084 MOD1 Section 6

Condition 5.2 of Schedule 2 of PA 07_0084 MOD1 Section 6

Project Approval Condition Section of this Plan

 Dora Creek, approximately 4 km to the southwest;

Figure 1 Location of Ash Dam and nearest sensitive receptors

3.2 Meteorological Conditions

3.3 Potential Impacts

4. Air Quality Management System

4.2 Management Measures

Table 2 Dust management measures

Emission source Management measures Responsibility

Implementation of the management measures described above is informed by a combination of visual

Figure 3 Overview of the air quality management system

Table 3 Trigger level definitions

Level Description Summary of action(s)

Reasonably expected conditions in day to day operations Polymer application

Change from normal indicating a potential risk Polymer application

Moderate risk of dust related impacts occurring Polymer application

High risk of dust related impacts occurring Polymer application

4.3 Monitoring Program

Monitoring Type Indicator Frequency Justification

The Ash Dam monitoring program is designed to:

4.4 Visual Monitoring

Visual triggers, in order of increasing potential impact, are described as follows:

4.5 Proactive Management

Figure 5 Example daily environmental forecast

6. Incident and Non-compliance Reporting

Investigations of incidents will involve:

7. Access to Information and Record Keeping

7.2 Record Keeping

In accordance with the Environmental Planning and Assessment Act 1979:

8. Review and Training

This AQMP may also be revised due to:

8.2 Training and Communication

Training with respect to Ash Dam dust management includes:

9. Roles and Responsibilities

AQMP Air Quality Management Plan

DPE Department of Planning and Environment

EPA Environment Protection Authority

EPS Eraring Power Station

HSE Health, Safety, Environment

TARP Trigger Action Response Plan

DPE (2018) “Compliance Reporting – Post Approval Requirements”. May 2020.

Origin (2021) “Eraring Power Station Environmental Management Plan”. GEN-HSE-EMP-EPS.