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AUSTRALIA PACIFIC LNG PTY LIMITED
AUSTRALIA PACIFIC LNG PROJECT
APPENDIX M - GREENHOUSE GAS MANAGEMENT PLAN
LNG FACILITY
Page iii
Disclaimer
This report has been prepared on behalf of and for the exclusive use of Australia
Pacific LNG Pty Limited, and is subject to and issued in accordance with the
agreement between Australia Pacific LNG Pty Limited and WorleyParsons
Services Pty Ltd. WorleyParsons Services Pty Ltd accepts no liability or
responsibility whatsoever for it in respect of any use of or reliance upon this report
by any third party.
Copying this report without the permission of Australia Pacific LNG Pty Limited or
WorleyParsons is not permitted.
Revision 1 dated 22 November 2010
APLN-000-EN-R01-D-10176
AUSTRALIA PACIFIC LNG PTY LIMITED
AUSTRALIA PACIFIC LNG PROJECT
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Contents
1. Introduction, purpose and scope ........................................................................................ 1
2. Environmental Policy .......................................................................................................... 2
3. Planning ............................................................................................................................. 3
3.1 Coordinator-General Imposed Conditions ......................................................................... 3
3.2 Environmental aspects ....................................................................................................... 3
3.3 Applicable legislation, standards and guidelines ............................................................... 6
3.3.1 Commonwealth government policy position ......................................................... 6
3.3.2 Commonwealth government legislation ................................................................ 6
3.3.3 Queensland Government position ......................................................................... 9
3.4 Objectives and targets ....................................................................................................... 9
4. Implementation strategy ................................................................................................... 14
4.1 Construction ..................................................................................................................... 14
4.1.1 Reduction of GHGs during construction.............................................................. 14
4.2 Operations ........................................................................................................................ 14
4.2.1 Reduction of GHGs from turbines ....................................................................... 14
4.2.2 Reduction of GHGs from flaring .......................................................................... 15
4.2.3 Reduction of GHGs from venting and fugitive emissions .................................... 16
4.2.4 Reduction of GHGs from LNG shipments ........................................................... 16
4.2.5 GHG offset plan ................................................................................................... 16
4.2.6 CO2 recovery plan ............................................................................................... 17
4.3 Resources, roles and responsibilities .............................................................................. 17
4.4 Documentation ................................................................................................................. 20
4.4.1 Record keeping under the NGER Act ................................................................. 20
4.4.2 Record keeping under the under the EEO Act .................................................... 20
4.4.3 Record keeping in relation to the National Carbon Offset Standard ................... 21
5. Monitoring ........................................................................................................................ 22
6. Reporting, auditing and review ........................................................................................ 25
6.1 Reporting .......................................................................................................................... 25
6.1.1 GHG reporting under the NGER Act ................................................................... 25
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6.1.2 Energy Efficiency Opportunity Reporting ............................................................ 30
6.1.3 Reporting under the National carbon offset standard ......................................... 33
6.2 Corrective actions ............................................................................................................ 34
6.3 Auditing ............................................................................................................................ 34
6.4 Management Review ....................................................................................................... 34
7. References ....................................................................................................................... 35
Figures
Figure 6.1 National Greenhouse and Energy reporting thresholds for facilities and corporations .... 27
Figure 6.2 Upper limits for amounts of GHGs and energy data that may be considered incidental .. 30
Figure 6.3 Process for EEO reporting ................................................................................................ 31
Figure 6.4 EEO Assessment and Reporting Cycle ............................................................................ 33
Tables
Table 3.1 Summary of potential impacts, their causes, mitigation and management measures and
the residual risks ................................................................................................................................... 4
Table 3.2 List of GHG objectives, targets and performance indicators .............................................. 10
Table 4.1 Staff roles and responsibilities in relation to GHG management ....................................... 18
Table 5.1 Monitoring activities for reportable GHG sources and emissions ...................................... 22
Table 5.2 Monitoring activities for some scope 3 GHG sources and emissions ................................ 24
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1. Introduction
The overall greenhouse gas (GHG) management objective is to contribute to reducing global GHG
intensity by producing LNG which can substitute for higher GHG intensive fuels. Australia Pacific LNG
will seek to minimise the GHG intensity of LNG production during construction, commissioning and
operational phases of the LNG facility.
This document describes Australia Pacific LNG’s approach to GHG management by:
• Giving an overview of Australia Pacific LNG’s environmental policy in relation to GHG
management.
• Outlining the various GHG related environmental aspects associated with the activities and
products of the LNG facility.
• Discussing the applicable Commonwealth and Queensland government policy and legislation.
• Discussing Australia Pacific LNG’s objectives, targets and programmes for mitigating GHG
emissions at the LNG facility during construction, commissioning, and operations phases.
• Describing the implementation and operation of the plan including who is responsible.
• Discussing additional GHG mitigation measures such as a biodiversity offset strategy which will
generate GHG offsets.
• Describing the monitoring, evaluation and auditing to be undertaken to demonstrate that all
construction, commissioning and operational activities comply with the requirements of this
plan.
• Describing the management review and continuous improvement to be implemented.
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2. Environmental Policy
Australia Pacific LNG recognises that climate change poses significant risks to its business, but this
also offers opportunities to improve environmental performance. Australia Pacific LNG will be pro-
active in building a business that will be well-positioned in a low-carbon economy. Origin’s and
ConocoPhillips’ established corporate strategies on climate change will underpin Australia Pacific
LNG’s response to the challenges of climate change.
Origin has long recognised the need to address the global issues of climate change, and has built a
business that is well-positioned in a more carbon-constrained regulatory, social and investment
environment. Origin has a strong portfolio of natural gas reserves in Australia and New Zealand and
invests in renewable energy sources including wind, solar and geothermal. Origin has developed a
series of retail offerings, such as GreenPower, to encourage customer participation in GHG
reductions.
Origin has engaged strongly in the development of government policy in relation to mitigating GHG
emissions and reducing the impacts of climate change. This includes contributions to the Garnaut
Review (Garnaut 2008), the Carbon Pollution Reduction Scheme and other government processes,
and participation in the media and public debate. Origin has also taken significant measures to
understand and reduce its carbon footprint.
With operations around the globe, ConocoPhillips seeks to encourage external policy measures at the
international level that deliver the following principles:
• Slow, stop and ultimately reverse the rate of growth in global GHG emissions.
• Establish a value for carbon emissions, which is transparent and relatively stable and sufficient
to drive the changed behaviours necessary to achieve targeted emissions reductions.
• Develop and deploy innovative technology to help avoid or mitigate GHG emissions at all
stages of the product’s life.
• Ensure energy efficiency is implemented at all stages of the product’s life.
• Recognise consumer preference for reduced GHG-intensive consumption, and work towards
meeting these expectations.
• Deploy carbon capture and storage as a practical near-term solution if technically and
economically feasible.
• Develop processes that are less energy and material intensive.
• Build price of carbon into base-case business evaluations.
• Ensure energy and materials efficiency is part of the project development/value improvement
processes.
The project will use the commitment and technical strengths of both of its co-venturers to develop and
implement a GHG management plan that includes GHG mitigation measures, monitoring, reporting,
and assessment of business-specific actions.
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3. Planning
3.1 Coordinator-General Imposed Conditions
The Coordinator-General’s Imposed Conditions describe the specific management objectives for the
GHG management plan:
• To describe the GHG emissions policy.
• To describe the energy efficiency program.
• To describe the continuous improvement program.
• To describe the improvements in control systems.
• To develop a CO2 recovery plan.
3.2 Environmental aspects
Explicit throughout the terms of reference (TOR) for the environmental impact statement (EIS),
Australia Pacific LNG was required to identify and manage any adverse construction, operation and
decommissioning impacts that its coal seam gas (CSG) to liquefied natural gas (LNG) project may
create. The identification and management of these impacts was undertaken through a risk
assessment.
Risk assessment is a process that evaluates the likelihood (probability and exposure) and
consequences (magnitude) of positive and negative environmental effects occurring as a result of
exposure to one or more hazards.
The EIS for the LNG facility presented a risk assessment as part of the greenhouse gas assessment.
The risk assessment identified each environmental aspect and the causes for the impact associated
with each project aspect. The mitigation and management measures were described and the residual
risk from each impact was assigned a rating if the impact materialised. The risk assessment was
undertaken based on the project design developed in the EIS. Table 3.1 summarises the results of the
risk assessment.
The potential impact is the release of GHGs to the environment and their likely long-term impact on
global climate change. The causes for the GHG emissions were found to have arisen from the
construction and operation activities associated with the LNG facility. Mitigation measures were
developed to specifically reduce GHG emissions from these sources and the residual risk was
assessed.
In general, the residual risk was found to be low or negligible for each impact. A risk matrix that
describes each level of risk in terms of likelihood and consequence is given in the Table 4.6, Chapter
4, Volume 1 of the Australia Pacific LNG Project EIS.
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Table 3.1 Summary of potential impacts, their causes, mitigation and management measures and the residual risks
Potential impacts Possible causes Mitigation and management measures Residual risk level
GHG emissions to the
atmosphere; potential long term
climate change impacts
Operation of construction machinery
and transport equipment hauling
Optimise transport logistics to reduce energy consumption, and use fuel
efficient vehicles and machinery where practicable
Low
Operation of gas liquefaction facilities
(power generation and refrigeration
turbines)
Use high efficiency turbines that produce lower GHG emissions.
Install waste heat recovery units to meet the process heat requirements of
the LNG facility
Low
Transportation of people, construction
materials and liquefied natural gas
Optimise transport logistics to reduce energy consumption and use fuel
efficient ships
Negligible
Flaring and venting CSG during
maintenance and process upsets
Reduce flaring by capturing liquefied natural gas boil off gases from normal
ship loading using boil-off gas compressors.
Activating the spare gas compressor to avoid flaring when a compressor is
down for maintenanceDevelop and implement plans for preventative
maintenance and operational efficiencies to reduce flaring
Low
Low
Embedded energy in materials Consider less energy intensive construction materials during design phase
of the Project
Low
GHG emissions from LNG facility
processes and other indirect
emissions such as third party and
worker transportation
Develop and implement a GHG management plan to monitor and assess
GHG emissions from the Project. Use this plan to define and execute
actions to reduce GHG emissions
Low
Land clearing releases CO2 and Land clearing for construction of Progressively rehabilitate cleared areas as described in Volume 4 Chapter Low
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Potential impacts Possible causes Mitigation and management measures Residual risk level
reduces CO2 uptake project infrastructure 8 of the EIS.
Develop biodiversity offset strategy which will generate GHG offsets
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3.3 Applicable legislation, standards and guidelines
The Commonwealth and Queensland governments have developed policy, strategy and legislation in
relation to the management of GHGs. Much of the policy landscape is still uncertain, especially at the
Commonwealth level. However, Australia Pacific LNG has taken a proactive approach to finding
technological solutions to reducing its GHG emissions, as well as considering biodiversity offsets.
Australia Pacific LNG has chosen this approach so that they will be well-positioned in terms of their
GHG liabilities once the policy landscape is clear.
3.3.1 Commonwealth government policy position
Prior to the 21 August 2010 Commonwealth election, the proposed carbon pollution reduction scheme
(CPRS) was the Australian Government’s central policy instrument for reducing the GHG emissions
Australia produces. This was to be an emissions trading scheme in which GHG emissions would be
capped, permits would be allocated up to the cap, and emissions permits would be traded. Liable
entities would have been required to obtain carbon pollution permits to acquit their GHG emissions
liabilities. The Commonwealth Government intended that the CPRS would commence on 1 July 2011.
However the CPRS Bills were defeated in August and December 2009, and in May 2010 the CPRS
was delayed until at least 2013. Since the 21 August 2010 Commonwealth election, the GHG policy
landscape in relation to the remains CPRS uncertain.
If the CPRS or similar scheme to regulate GHG emissions is introduced, Australia Pacific LNG will
likely have a liability in respect of GHG emissions permits.
Despite the policy uncertainties, the Commonwealth government has retained:
• A long term GHG reduction target of 60% of 2000 levels by 2050.
• An unconditional medium term GHG reduction target of 5% below 2000 levels by 2020.
3.3.2 Commonwealth government legislation
The NGER Act (2007)
The National Greenhouse and Energy Reporting Act 2007 (NGER Act) establishes a national
framework for Australian corporations to report GHG emissions, and energy consumed and produced
from 1 July 2008. The NGER Act and supporting systems are administered by the Commonwealth
Department of Climate Change and Energy Efficiency. The NGER system was also designed to
provide a robust database for the proposed CPRS.
From 1 July 2008, corporations are required to report if:
• They control facilities that emit 25,000 tonnes or more GHGs in CO2-e units, or produce or
consume 100 terajoules or more of energy.
• Their corporate group emits 50,000 tonnes CO2-e, or produces or consumes 200 terajoules or
more of energy for 2010-11 and beyond.
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Companies must register by 31 August and report by 31 October following the financial year in which
they first exceed a threshold. A report must be submitted every year once registered even in those
years where the threshold is not triggered. Origin and ConocoPhillips report under the National
Greenhouse and Energy Reporting Act (2007), and so both partners in Australia Pacific LNG are
familiar with the Act's requirements.
Australia Pacific LNG proposes to use the NGER system under which the LNG facility will report its
GHG emissions following project start-up. Refer to section 6 for details of NGERS reporting
requirements.
Energy Efficiency Opportunities Act (2006)
The Energy Efficiency Opportunities Act 2006 (EEO Act) was introduced by the Department of
Resources, Energy and Tourism (DRET). It requires significant energy users, consuming over 0.5 PJ
per annum of energy, to take part in a transparent process of energy efficiency assessment and
reporting.
The program’s requirements are set out in the legislation, which came into effect on 1 July 2006.
Participants in the program are required to assess their energy use and report publicly on cost
effective opportunities to improve energy efficiency. In particular, corporations must report publicly on
opportunities with a financial payback period of less than four years. Australia Pacific LNG joint
venture partners Origin Energy and ConocoPhillips have been reporting under the energy efficiencies
opportunities scheme since 2006 and 2007 respectively, so both partners in Australia Pacific LNG are
familiar with the scheme's requirements.
Australia Pacific LNG proposes to use the EEO program to assess its energy use and to quantify the
opportunities identified to save energy at the LNG facility following project start-up. Refer to section 6
for details of EEO reporting requirements.
National Carbon Offset Standard (NCOS)
NCOS is a voluntary standard that took effect from 1 July 2010. The NCOS is intended to provide a
benchmark for consumers and businesses to assess claims of carbon neutrality or the credibility of
offset products available for sale in the voluntary carbon market.
The following units are currently accepted under the NCOS for the purposes of voluntary carbon
offsetting:
• Carbon Pollution Reduction Scheme (CPRS) permits, known as Australian Emissions Units
(AEUs), including those issued for forestry projects and any offsets allowed under the CPRS (if
it is introduced).
• Other units accepted for compliance under the CPRS which include the following units
generated under the United Nations Framework Convention on Climate Change (UNFCCC)
flexible mechanisms:
− Certified Emissions Reductions (CERs), excluding temporary (tCERs) and long term
(lCERs) CERs
− Emission Reduction Units (ERUs); and Removal Units (RMUs)
− Voluntary Emissions Reductions (VERs) issued by the Gold Standard
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• Voluntary Carbon Units (VCUs) issued by the Voluntary Carbon Standard, including credits
issued for agriculture, forestry and other land use (AFOLU) and reduced emissions from
deforestation and degradation (REDD) projects, where they apply methodologies approved by
the Australian Government.
• Offsets generated from emissions sources in Australia not counted toward Australia’s Kyoto
Protocol target and using a methodology that has been approved by the Australian
Government.
Under the NCOS, offset projects may be developed within Australia from emissions sources and sinks
currently not counted towards Australia’s obligations under the Kyoto Protocol target, such as:
• Enhanced forest management (the management of forests established before 1990).
• Cropland and grazing land management (net greenhouse gas emissions from soil, including
biochar, crops and vegetation on cropland and grazing land).
• Revegetation (establishment of vegetation that does not meet the Kyoto Protocol definitions of
afforestation and reforestation).
Methodologies for producing offsets from these emissions sources must be proposed and approved
under the NCOS before offset projects can be implemented.
Domestic offset projects must meet the following eligibility criteria:
• Additional - GHG reductions generated by the LNG facility must be beyond what would be
required to meet regulatory obligations under any Australian laws or regulations or undertaken
as part of ‘business-as-usual’ investment. The level of additional emissions reductions
generated by an offset project is the difference between the emissions associated with the LNG
facility (‘project emissions’) and emissions under a business-as-usual scenario.
• Permanent - GHG reductions must be permanent. In the case of sinks, this requires that the
carbon stored is sequestered and will not be released into the atmosphere in the future.
• Measurable - methodologies used to quantify the amount of emissions reductions generated
must be robust and based on a defensible scientific method. Methodologies must clearly define
a boundary for the emissions reduction project, emissions sources and emissions factors and
activity levels. They must specify the calculation of a baseline emissions forecast reflecting
business-as-usual and the means of comparing it to expected emissions from the project to
determine the carbon offsets generated. The methodology must specify the uncertainty
associated with the calculation of offsets generated. It should also specify the risks associated
with achieving the forecast abatement and how they will be managed.
• Transparent - consumers and other interested stakeholders must be able to examine
information on domestic offset projects, including the applied methodology, emissions
calculations and project monitoring arrangements, by accessing a publicly available website.
The information provided should clarify data sources, exclusions, inclusions and assumptions.
• Independently audited - eligibility of methodologies, offset projects and GHG emissions
reductions generated must be audited by an independent third party. Existence of a conflict of
interest should be determined. Further information on audit requirements is provided under the
Audit section.
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• Registered - emissions reduction units generated must be registered and tracked in a publicly
transparent registry. The equivalent number of eligible units to offset the total emissions
associated with any product or organisation (or specified part of an organisation) should be
voluntarily surrendered and retired into a registry. Registry arrangements for the domestic
offsets generated under the NCOS will be determined as part of the NCOS administrative
framework. Administrative arrangements are yet to be finalised.
The NCOS will be reviewed on an annual basis and updated as required to reflect changes in
Australian standards and legislation, international standards, best practice, domestic and international
carbon markets and international emissions accounting rules.
3.3.3 Queensland Government position
The Queensland Government’s ClimateSmart 2050 strategy (2007) outlines key long-term climate
change targets. The Queensland Government has agreed to the national target of achieving a 60%
reduction in national GHG emissions by 2050, compared with 2000 levels. This will involve cuts in
GHG emissions of more than 30 Mt CO2-e over 10 years and save the Queensland economy about
$80 million each year (Queensland Government 2007).
To help achieve this target, the Queensland Government has developed the Queensland gas scheme,
where Queensland electricity retailers and large users of electricity are required to source at least 13%
of their electricity from gas-fired generators.
The gas scheme is aimed at reducing Queensland’s emission intensity from 0.917 tonnes CO2-e/MWh
(2000-2001 levels) to 0.794 tonnes CO2-e/MWh by 2011-2012. The 13% target under this scheme has
been increased to 15% by 2010 with the provision to increase it to 18% by 2020.
It should be noted that the LNG facility will generate its own power from natural gas, which will assist
the Queensland government to meet its 2020 objective of 18% power generated from natural gas.
In 2008 the Queensland Government commenced a review of Queensland’s climate change strategies
in response to national and international developments in climate change science and policy. In
August 2009, the Queensland Government released ClimateQ: toward a greener Queensland. This
strategy consolidates and updates the policy approach outlined in ClimateSmart 2050 and
Queensland's ClimateSmart Adaptation Plan 2007-12. The revised strategy presents investments and
policies to ensure Queensland remains at the forefront of the national climate change response
(Queensland Government 2009).
3.4 Objectives and targets
The overall GHG management objective is to contribute to reducing global GHG intensity by producing
LNG which can substitute for higher GHG intensive fuels. Australia Pacific LNG will seek to minimise
the GHG intensity of LNG production during construction, commissioning and operational phases of
the LNG facility. To minimise the GHG intensity of LNG production, the following objectives, targets
and performance indicators are given in the table below.
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Table 3.2 List of GHG objectives, targets and performance indicators
Project
Phase
Objective Target Performance indicator(s)
Operation To minimise GHG emissions during LNG facility
operation
For operations at the LNG facility at Curtis Island, achieve a
GHG intensity of 0.31 tonne CO2-e/tonne LNG produced
GHG intensity of LNG facility
Measure GHG emissions of all operations
and tonnes LNG produced
Construction To use fuel efficient vehicles and machinery
where practicable and optimise transport
logistics (of people and equipment) to reduce
fuel consumption
For on-site diesel consumption for transport, achieve GHG
emissions of approximately 15,000 tonnes CO2-e per annum
over the 4.75 year construction period
For on-site diesel consumption for power generation, achieve
GHG emissions of approximately 57,000 tonnes CO2-e per
annum over the 4.75 year construction period
Annual volumes of diesel and other fuels
consumed.
Reporting volume of fuels consumed and
GHG emissions under NGERS
Design/Constru
ction
To reduce the use of energy intensive
construction materials during design phase of
the LNG facility
Minimise the embedded energy related GHG emissions.
As a guide, the lifecycle GHG emission intensities for the
following materials are:
-galvanised steel; 2.7 kg CO2-e/kg
-concrete; 0.13 kg CO2-e/kg
-copper cable; 3.8 kg CO2-e/kg
-insulation; 1.35 kg CO2-e/kg
Note, these intensities will vary depending on the region in
which the materials were produced. These intensities ignore
transport-related emissions.
Life cycle greenhouse gas emissions of
major materials and their alternatives
during the detailed design phase
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Project
Phase
Objective Target Performance indicator(s)
Construction To minimise land clearances during construction
of LNG facility infrastructure to limit releases of
GHGs
Develop a biodiversity offset strategy which will
generate GHG offsets such as biosequestration
opportunities
Progressively rehabilitate cleared areas
Complete a review of practicable GHG offsets option
completed prior to operations commencing
Minimise the GHG emissions from land-clearing
Offset all GHG emissions associated with land clearing and
some of the other project emissions.
Area of land to be cleared for construction
GHG emissions associated with land
clearing
The number of GHG offsets created
GHG offset study report and
recommendations
Progress selection and implementation of
acceptable offset projects
Commissioning To minimise GHG emissions from gas flaring
Use less than the benchmark quantity of gas to start up each
LNG train
Fully assess the options of ground flaring versus elevated
flaring during detailed design phase.
Volume of gas flared.
Option assessment report
Operations To minimise GHG emissions from routine and
non-routine gas flaring
Achieve a GHG intensity of 0.015 tonnes CO2-e/tonne LNG
produced. This covers all flaring activities such as dry, wet,
and marine flaring, and non-routine gas flaring.
Reduce GHG emissions by approximately 100,000 tonnes
CO2-e per train per year by capturing LNG boil-off gases
Volume of gas flared
Reporting annual GHGs, and energy
consumption and production for gas flaring
under NGERS.
Operations To reduce GHG emissions from refrigeration
compressor and power generation turbines
using high efficiency turbines. To be achieved by
selecting generator and compressor turbines
For the refrigerator compressors, reduce GHG emissions by
25% compared with commonly used Frame 5D turbines -
achieve a GHG intensity of 0.2 tonnes CO2-e/tonne LNG
produced
Volume of fuel gas consumed for power
generation
Audit assessments
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Project
Phase
Objective Target Performance indicator(s)
based on benchmarked GHG emissions
intensity, and perform optimisation of the
number and mode of operation of the power
generation turbines
For the power generation turbines, achieve an intensity of
0.03 tonnes CO2-e/tonne LNG produced
During periods where ship-loading is occurring, achieve an
intensity of 0.055 tonnes CO2-e/tonne LNG produced
Energy consumption and energy efficiency
reporting under the EEO Act
Annual reporting of GHGs (tonnes CO2-e)
and energy production and consumption
from natural gas for combustion for power
generation and refrigeration turbines under
NGERS
Operations To minimise GHG emissions from heating the
hot oil and the dehydration systems using
recovered waste heat
Reduce GHG emissions by approximately 63,000 tonnes
CO2-e per train per annum
Achieve an intensity of 0.004 tonnes CO2-e/tonne LNG
produced
Audit assessments
Energy consumption and energy efficiency
reporting under the EEO Act
Annual reporting of GHGs, and energy
consumption and production data
associated with the hot oil system under
NGERS
Operations To minimise GHG emissions from acid gas
venting and GHG impurities in vented nitrogen
Achieve an intensity of 0.03 tonnes CO2-e/tonne LNG
produced for vented acid gases
Achieve an intensity of 0.015 tonnes CO2-e/tonne LNG
produced for vented nitrogen
Volumes of gases vented
Audit assessments
Annual reporting of GHGs, and energy
consumption and production data
associated with the acid gas rejection unit
under NGERS
Operations To optimise LNG shipment logistics to reduce For ships powered by gas only, achieve a GHG intensity of Volume of fuel(s) consumed in shipping
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Project
Phase
Objective Target Performance indicator(s)
energy consumption –e.g. LNG ships and routes
selected based on benchmarked fuel efficiency
0.43 kg CO2-e/kWh of shipping power required. From the
EIS, estimated 0.12 tonnes CO2-e/tonne LNG shipped
Dual fuel (fuel oil/gas) powered ships should achieve a GHG
intensity of 0.53 kg CO2-e/kWh of shipping power required.
Fuel oil powered ships should achieve a GHG intensity of
0.63 kg CO2-e/kWh of shipping power required
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4. Implementation strategy
4.1 Construction
4.1.1 Reduction of GHGs during construction
The GHG emissions will primarily arise from use of construction machinery and site vehicles, and
vehicles used in transporting people and construction materials.
Engineering controls include:
• Selecting fuel efficient vehicles and machinery.
• Assessment of construction techniques to determine the most fuel efficient and least GHG
intensive methods, i.e. on-site versus modular construction.
• Assess alternative fuels will e.g. CNG, LNG, LPG and biodiesel versus diesel and petrol.
• As GHG emissions will arise from land-clearing for construction, cleared areas will be
progressively rehabilitated.
Operational controls include:
• Back-loading of trucks and sourcing materials and services from local suppliers.
• Operating the vehicles and machinery in a fuel efficient manner e.g. on-site vehicles to be
operated at an optimal speed, and no idling for extended periods.
4.2 Operations
4.2.1 Reduction of GHGs from turbines
Australia Pacific LNG has an objective to reduce the GHG intensity of its production processes. The
liquefaction/refrigeration process is highly energy intensive and it is therefore a key area where energy
efficiency improvements will focus on an ongoing basis.
Annual baseline calculations of GHG emissions (tonnes CO2-e) from turbine exhaust stack emissions
will be performed during first year of operations, to verify actual plant performance against design
basis. Volume of fuel gas consumed will also be monitored. Frequency of testing will be adjusted
based on results when compared to project design criteria and vendor equipment performance
specifications.
Engineering controls include:
• Install waste heat recovery units on gas turbine exhausts. This will provide heat for the hot oil
system and the dehydration regeneration gas system for two of the refrigeration gas turbines.
• Use GE LM2500+G4 aero-derivative gas turbines are among the most fuel efficient turbines
available. Frame 5D turbines operate with 30.3% thermal efficiency and the GE LM2500+G4
operate with 41.1% thermal efficiency. The GE LM2500+G4 produce 26% fewer GHG
emissions.
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• Implement inlet air-cooling, which will improve the efficiency of the turbines over a wide range of
operating temperatures and humidities.
Operational controls include:
• Optimising the number, type and rating of power generation gas turbines depending on the
optimisation of power requirements.
• Optimising turbine operating conditions, project phasing, reliability, GHG emissions and
capital/operating costs.
These optimisation processes will be part of a continuous improvement process.
4.2.2 Reduction of GHGs from flaring
Australia Pacific LNG proposes to use a ground flare similar to that currently used at ConocoPhillips’
Darwin LNG facility. This type of flare burns more cleanly than the conventional elevated pipe flare
and results in fewer GHG emissions overall. Australia Pacific LNG will perform a detailed comparison
of ground and elevated flaring GHG emissions. An assessment report will be generated detailed the
preferred options.
During commissioning of each train, the amount of gas needed for train start-up will be carefully
assessed to reduce GHGs from flaring.
Baseline calculations of annual routine and non-routine flaring volumes will be conducted from the first
year of operations to verify actual plant performance against design predictions. A comparison of
actual versus predicted annual flaring volumes will be used to define total annual flaring volume
reduction targets for subsequent years.
Baseline calculations of annual routine and non-routine flaring contributions to GHG emissions (tonnes
CO2-e) from first year of operations will be performed. This data will be used to verify actual plant
performance against design GHG emissions calculations. The annual GHG intensity target (tonnes
CO2-e)/tonne LNG production) for subsequent years will be defined on this basis
Engineering controls include recovering the boil-off gas from LNG storage and ship loading rather than
flaring it.
Operational controls include:
• The Australia Pacific LNG Plant asset management system.
• A dry and wet flare system start-up and operating procedure.
• Marine flare start-up and operating procedure.
• Australia Pacific LNG Marine Terminal Handbook to minimise night-time flaring during LNG
offloading.
• Activating the spare gas compressor to avoid flaring when a compressor is down for
maintenance. A spare gas compressor will be piped into the system so that in the event of
maintenance being required on the other compressors, the spare can be utilised instantly. This
reduces GHG emissions by continuing gas compression rather than flaring the unused CSG.
• A leak detection program and a strategy to minimise plant shutdowns.
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4.2.3 Reduction of GHGs from venting and fugitive emissions
Fugitive emissions of methane arise from equipment including piping connectors, valves, pumps and
flanges. Vented emissions arise from the acid gas rejection unit, the nitrogen rejection unit, and from
equipment maintenance venting.
Baseline calculation of annual routine and non-routine venting volumes will be conducted from first
year of operations to verify actual plant performance against design predictions. A comparison of
actual versus predicted annual vented volumes will be used to define total annual venting volume
reduction targets for subsequent years.
Baseline calculations of annual routine and non-routine venting contributions to GHG emissions
(tonnes CO2-e) from first year of operations will be performed. This data will be used to verify actual
plant performance against design GHG emissions calculations. The annual GHG intensity target
(tonnes CO2-e)/tonne LNG production) for subsequent years will be defined on this basis.
Engineering controls include:
• Thermally oxidising the methane in the rejected nitrogen stream.
• Thermally oxidising the methane in the rejected acid gas stream.
• Plant design (valve specifications, flange minimisation).
It is proposed that regular energy audits be conducted to evaluate and benchmark energy use and to
identify energy efficiency opportunities. These will be evaluated, and once developed; those
opportunities with sound business cases will be implemented in accordance with Australia Pacific
LNG’s business plan and EEO guidelines.
4.2.4 Reduction of GHGs from LNG shipments
LNG transport via ship is a large source of scope 3 emissions for Australia Pacific LNG. The estimates
from the EIS suggested that GHGs from LNG shipments could be of the order of two million tonnes
CO2-e annually.
The key operational control will be to assess the ship’s fuel efficiency. Heede (2006) developed GHG
intensities for LNG shipping based on the GHGs per kWhr of power required for the journey,
depending upon the fuels used. The following are GHG indicators of ship performance that could be
used in ship selection (amongst others):
• As only: 0.43 kg CO2-e/kWhr.
• Dual fuel (fuel oil/gas): 0.53 kg CO2-e/kWhr.
• Fuel oil 0.63 kg CO2-e/kWhr.
To further reduce fuel consumption and GHG emissions, routes to major ports will be optimised using
satellite navigation/GPS.
4.2.5 GHG offset plan
It is expected that the GHGs associated with land clearing and some of the project emissions will be
offset to some degree.
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Review and evaluation of greenhouse gas emission offset opportunities will be an on-going part of the
GHG management plan for the Australia Pacific LNG facility during its operational lifetime. Details of
selected emission offset projects will be included in the strategy that will be submitted to the
Commonwealth Department of Environment, Water, Heritage and the Arts (DEWHA), the Queensland
Department of Environment and Resource Management (DERM) and the Department of Employment
Economic Development and Innovations (DEEDI). These departments have confirmed that terrestrial
and marine offsets will be required to compensate for significant unavoidable impacts of land-clearing.
The key measures are to:
• Develop a biodiversity offset strategy which will generate GHG offsets such biosequestration
projects.
• The offset strategy for domestic offsets will include an assessment of the additionality,
permanency, measurability, transparency, independent auditing and registration of offsets as
required under the National Carbon Offsets Standard.
• Prepare a GHG offset options study report prior to operations commencing at the LNG facility.
• Recommendations from the report will be used as the basis for selection and implementation of
acceptable offset projects.
Given the spatial extent of the Project and its various components, it is proposed that offset properties
will be largely located within 100km of the study area defined in the EIS.
4.2.6 CO2 recovery plan
Before conversion to LNG, the coal seam gas contains about 1% CO2. The current design uses a-
MDEA to remove the CO2 from the CSG.
A CO2 recovery plan will be developed that considers the following:
• A study to consider the options for enhanced recovery of CO2 from the CSG e.g. using the latest
alternative CO2 absorbents. Solvents should avoid co-releases of methane.
• The installation of equipment which is carbon capture ready. However, at present there are
there are no feasible reservoirs for CO2 storage currently available.
• Develop an CSG-LNG industry response for CO2 re-use. Consider feasibility of re-use options
such as enhanced oil recovery or piping CO2 back to CSG fields to enhance CSG recovery.
Investigate synergies with local industries for CO2 use.
4.3 Resources, roles and responsibilities
Responsibility for day-to-day operations of the LNG facility will be assigned to the Australia Pacific
LNG Environmental Manager. The Environmental Manager will be responsible for ensuring that the
requirements of the Environmental Management Plan (EM Plan) and the Health, Safety and
Environmental Management System (HSEMS) are effectively implemented. Technical support is
provided by the Australia Pacific LNG Operations Team. This responsibility also includes the regular
review and update of the EM Plan and other HSEMS documentation to ensure that they reflect current
activities and policy requirements.
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In relation to GHG reporting under the NGER Act and energy usage/energy efficiency reporting under
the EEO Act, the roles and responsibilities for the following Australia Pacific LNG staff have been
identified in Table 4.1 below. The specific GHGs to be reported and their frequency are described in
more detail in Section 5. Specific reporting timelines under the EEO Act and the NGER Act are
described in section 6.
Table 4.1 Staff roles and responsibilities in relation to GHG management
Reporting
requirements
Accountable Project leader Data to be gathered and
reported
Actions
Energy Efficiency
under the EEO
Act
LNG facility
Operations
Centre Manager
Senior Process
Engineer
Energy usage data
Identify and evaluate energy
efficiency opportunities.
Cost and payback periods for
each opportunity
Annual review of
identified energy
efficiency
opportunities
Conduct energy
efficiency assessment
Gather energy data
and manage
verification and audit
of data
Register to report if
threshold is triggered
GHG reporting
under the NGER
Act
Internal report to
Australia Pacific
LNG Corporate
HSE Manager
Environmental
Supervisor
Volume of gas flared (routine
and non-routine flaring)
Volumes of gas from process
venting (acid gas removal
unit, NRU gas venting)
Volumes of gases released
from fugitive emissions from
LNG processing equipment
Volumes of fuel consumed
(diesel and fuel gas) from
power generation turbines,
and refrigeration compressor
gas turbines
Volumes of fuel consumed
(diesel and petrol) from site
vehicles and construction
machinery
Collect relevant data,
calculate GHG
emissions, energy
production and
energy consumption
data (see section 6
for details) using the
GHG and energy
reporting system.
Register with
Greenhouse and
Energy Data Officer
to report by 31
August in the year
after NGER
thresholds have been
triggered.
Manage verification
audit of greenhouse
and energy data prior
to 31 October
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Reporting
requirements
Accountable Project leader Data to be gathered and
reported
Actions
Report data to the
Department of
Climate Change and
Energy Efficiency by
October 31 August in
the year after NGER
thresholds have been
triggered
Scope 3 GHGs for
internal report to
APLNG Corporate
HSE Manager
Environmental
Supervisor
Fuels consumed (fuel oil and
natural gas) by LNG ships
Masses of construction
materials for embedded
energy related GHG
emissions; emission factors
for each material
Collect relevant data,
calculate GHG
emissions for internal
reporting.
Reporting GHG
intensity to
APLNG Corporate
HSE Manager
Environmental
Supervisor
All flaring activity, power
generation turbines, and
refrigeration compressors,
process vents and fugitive
emissions
Volumes of gas vented.
volumes of fuels combusted ,
production volumes (LNG,
fuel gas)
Calculate GHG
Intensity (tonnes
GHG emitted per
tonne production).
Publish data in the
Annual report for
preceding calendar
year (1 January to 31
December) to be
completed by 1 May
Identifying GHG
reduction
opportunities
LNG facility
Operations
Centre Manager
Environmental
Supervisor
Identify GHG reduction
opportunities via workshops
Volume of GHG reductions
Internal reporting on
an Annual basis.
Management Team to
review opportunities
to facilitate
continuous
improvement of the
GHG Management
Plan
Carbon offset
projects
HSE Manager
Environmental
Supervisor
Identify carbon offset projects
Volume and type of offsets
generated and purchased
Manage offsets
(purchase and
retirement of offsets)
Reporting offset
activities
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Reporting
requirements
Accountable Project leader Data to be gathered and
reported
Actions
Manage verification
and audit of offsetting
projects
4.4 Documentation
4.4.1 Record keeping under the NGER Act
Australia Pacific LNG will be required to keep records for seven years from the end of the reporting
year in which the activities recorded took place. This means that records for the 2010–11 reporting
year should be kept until the end of 2017–18.
Records that will be kept include any information that can be used to verify the relevance,
completeness, consistency, transparency and accuracy of reported data during an external audit.
Records to be retained include:
• A list of all sources monitored.
• The activity data used for calculation of greenhouse gas emissions for each source, categorised
by process and fuel or material type.
• Documentary evidence relating to calculations—for example, receipts, invoices and details of
payment methods.
• Documentation of the methods used for greenhouse gas emissions and energy estimations.
• Documents justifying selection of the monitoring methods chosen.
• Documentation of the collection process for activity data for a facility and its sources.
• Records supporting business decisions, especially for high-risk areas relating to reporting
coverage and accuracy.
When facility-specific emissions factors are used, records will document the monitoring methods used
and the results from the development of these emissions factors, as well as information such as
biomass fractions and oxidisation or conversion factors.
Records can be kept on paper or in electronic form. They should, however, be stored in a format that
is accessible to the Greenhouse and Energy Data Officer or external auditors if required. Australia
Pacific LNG will consult AS ISO 15489 (the Australian and international standard for record
management) for guidance about record-keeping processes.
4.4.2 Record keeping under the under the EEO Act
Adequate records must be retained for seven years to demonstrate that Australia Pacific LNG has met
the program requirements.
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Records should include evidence gathered for the assessment and reporting schedule, assessments,
reporting and any other documentation prepared for, or used in the participation of, Energy Efficiency
Opportunities.
The record keeping principles outlined under the NGER Act should apply to records obtained for
reporting under the EEO Act.
4.4.3 Record keeping in relation to the National Carbon Offset Standard
Australia Pacific LNG will keep records of and disclose the offset units in a registry and record
appropriate details to verify this cancelling activity (i.e. registry name, serial number, cancellation
certificate, etc). These details are required as part of the Public Disclosure Summary.
Records will be kept to prove that sufficient eligible offsets have been acquired to offset the proportion
of the total carbon footprint associated with the activities of the organisation (or specified part of the
organisation) or products committed to be offset.
Appropriate records will be maintained to allow emissions reductions claims under NCOS to be
audited.
For GHG inventory/carbon footprint verification purposes in relation to NCOS, records will be
maintained including monitoring records, utility bills, test reports, failure reports, internal audit and
management review records, customer complaints and statistics related to the operations and the
manufacture of the product. The relevant NGER report can be used if it has been used to develop a
carbon footprint.
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5. Monitoring
Monitoring activities will be undertaken throughout the life of the project to ensure that the objectives
and targets are met. The activities below will be performed as part of the GHG monitoring program
and energy-efficiency programs. Note that the data reported below are “reportable” emissions under
the NGER system (i.e. for the LNG facility these are scope 1 from fuel combustion, fugitive and vented
emissions), for which reporting is mandatory. GHG emissions calculations from purchased fuels like
diesel will be based on the “full fuel cycle” emissions factors, which include scope 1 emissions due to
combustion of the fuel and the scope 3 emissions from the extraction, production and transport of
those fuels.
The NGER reporting requirements are explained in more detail in Section 6.1.1.
Table 5.1 Monitoring activities for reportable GHG sources and emissions
Activity to be measured Frequency of
monitoring
Data evaluation
method
Data to be reported
Operation of construction
machinery, site vehicles and
diesel fired power
generators
Monthly Fuel consumption from
invoices
Volumes of fuels
consumed
GHG emissions (tonnes):
CO2, CH4, N2O and CO2-e
Land clearing during
construction
Daily Mapping/geomatics-GIS Area of land cleared
(hectares) and the
vegetation types
Emissions from land-
clearing in tonnes CO2-e
Gas flaring during plant
commissioning
Daily Calculations based on
average design daily
flowrates
Volume of gas flared
GHG emissions (tonnes):
CO2, CH4, N2O and CO2-e
Gas flared (routine flaring
from dry and wet flares,
purge and pilot gas flaring)
Daily Calculations based on
average design daily
flowrates
Volume of gas flared
GHG emissions (tonnes):
CO2, CH4, N2O and CO2-e
Gas flared (non-routine
flaring - process upsets,
planned full or partial blow-
downs, and emergency
flaring from dry and wet
flares)
Per event Calculations based on
continuous flow
monitoring
Volume of gas flared
GHG emissions (tonnes):
CO2, CH4, N2O and CO2-e
Gas flared (routine flaring
from marine flare – flare
Daily Calculations based on
average design daily
Volume of gas flared
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Activity to be measured Frequency of
monitoring
Data evaluation
method
Data to be reported
purge and pilots gas flaring flowrates GHG emissions (tonnes):
CO2, CH4, N2O and CO2-e
Gas flared (routine flaring
from marine flares -ship
cool-down and flaring during
loading operations)
Per loading event Calculations based on
continuous flow
monitoring
Volume of gas flared
GHG emissions (tonnes):
CO2, CH4, N2O and CO2-e
Non-routine gas flaring from
marine flare
Per event Calculations based on
continuous flow
monitoring
Volume of gas flared
GHG emissions (tonnes):
CO2, CH4, N2O and CO2-e
Process venting (acid gas
removal unit, nitrogen
rejection unit gas venting)
Per event Calculations based on
flow monitoring
Volume of gas vented
GHG emissions (tonnes):
CO2, and CH4 and CO2-e
Fugitive emissions from
LNG processing equipment
Annual reporting Calculations based on
fuel throughput
tonnes CH4 emitted
Operation of power
generation turbines, and
refrigeration compressor gas
turbines and provision of
process heating from
recovered waste heat
Daily Flow metering and
equipment run-time
hours
Fuel consumption (diesel
and fuel gas)
Energy consumption (TJ)
GHG emissions (tonnes):
CO2, and CH4 and CO2-e
All flaring activity, power
generation turbines, and
refrigeration compressors,
process vents and fugitive
emissions
Monthly Reporting based on
measurement and
calculation
Calculate GHG intensity:
tonnes GHG in CO2-e
emitted per tonne
production
Australia Pacific LNG will consider reporting significant scope 3 emissions such as embedded energy
related emissions and LNG shipping related emissions, as determined in the EIS. The monitoring
activities required are listed below.
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Table 5.2 Monitoring activities for some scope 3 GHG sources and emissions
Activity to be
measured
Frequency of
monitoring
Data evaluation
method
Data to be reported
Use of construction
materials
Monthly Data from invoices
Emission factors for
each material from
databases
Mass of construction
materials used.
Embedded energy related
emissions in tonnes CO2-e
LNG shipping Annually Data from fuel
invoices and quantity
of LNG boil-off gas
consumed during
shipment
Volumes of fuels consumed
GHG emissions (tonnes):
CO2, CH4, N2O and CO2-e
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6. Reporting, auditing and review
Reporting, auditing and reviews will be undertaken during the construction, commissioning and
operations phases of the project.
6.1 Reporting
List of required reports:
• GHG and energy reporting under the NGERs Act – annual.
• Energy Efficiency Opportunities.
• Reporting under the National Carbon Offset Standard.
• Annual GHG and energy audits to assess opportunities for improvements in GHG intensity
during facility life.
• Construction Contractor Environmental Manager will provide monthly updates to the
Construction Contractor Site Manager on routine monitoring and auditing results
• Construction Contractor Site Manager to provide Australia Pacific LNG with periodic updates on
routine monitoring and auditing results
• Non-routine monitoring and auditing results will be communicated by the Construction
Contractor Site Manager to Australia Pacific LNG as they become available
• Data to be captured by internal GHG and energy data management and reporting system on a
monthly basis:
− Flaring volumes from routine and non-routine processes
− All unplanned emergency flaring events
− Planned and unplanned venting volumes and fugitive emissions; and associated flaring
events
− Fuel gas consumption for power generation turbines and refrigeration/compressor turbines;
GHGs arising from power generation turbines and refrigeration/compressor turbines
− Diesel volumes and GHGs from combustion from power generation
− Diesel volumes and GHGs combustion for on-site transport and construction machinery
− Gasoline volumes and GHGs from combustion from on-site transport
6.1.1 GHG reporting under the NGER Act
Australia Pacific LNG will use the National Greenhouse and Energy Reporting Guidelines to determine
its reporting obligations under the NGER Act. Australia Pacific LNG will use the National Greenhouse
and Energy Reporting (Measurement) Determination 2008 to quantify its GHG emissions.
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Australia Pacific LNG will determine its participation by using its GHG and energy data management
and reporting system to collate data on GHG emissions (GHG emissions will be calculated in units
tonnes CO2-e) and offsets, and to review, verify and report this data under NGER Act. This system will
also require contractors to provide a monthly report detailing a record of unplanned GHG releases.
NGER GHG and energy reporting
The thresholds for GHG and energy reporting are shown in Figure Figure 6.1. There are three types
of facility thresholds:
• Combined scope 1 and scope 2 GHG emissions of 25 kilotonnes of CO2-e.
• Energy production of 100 terajoules.
• Energy consumption of 100 terajoules.
If any one of these thresholds is met the Australia Pacific LNG will register and report all GHG
emissions, energy produced and energy consumed.
Scope 1 and scope 2 GHG emissions for the LNG facility are:
• Scope 1 GHGs arise from generation of heat and electricity from fuel (e.g. fuel gas, diesel and
petrol) combustion; manufacturing processes that produce emissions; transport of materials,
waste and people; fugitive or unintentional releases of greenhouse gases from pipes and joints;
and flaring of gas.
• Scope 2 GHGs emissions arise from the generation of electricity purchased from the grid and
consumed (if applicable).
Energy production and energy consumption will also be reported in units of gigajoules or terajoules for
all GHG generating activities except vented and flared GHGs.
The GHGs to be reported are carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O).
Hydrofluorocarbons from air conditioning and sulphur hexafluoride (SF6) are also reportable.
In the event that the thresholds are triggered, Australia Pacific LNG will be required to submit a report
to the Greenhouse and Energy Data Officer using the OSCAR system.
From the GHG assessment for the LNG facility performed in the EIS, it is likely that construction and
commissioning activities alone will trigger the NGERS thresholds. Therefore, the GHG and energy
data reporting system will be need to be established prior to commencement of construction and
commissioning works. GHG and energy data during operations will be reported annually throughout
the lifetime of the LNG facility.
The timelines for registering and reporting under NGERS are also described in Figure 6.1 and will be
discussed in more detail below.
Australia Pacific LNG will apply for registration by the 31 August after the financial year in which a
threshold is met. The Chief Executive Officer (or an authorised representative) of the controlling
corporation must register on behalf of all businesses within the corporate group.
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Figure 6.1 National Greenhouse and Energy reporting thresholds for facilities and
corporations
Reporting requirements for Joint Ventures
In its first year of reporting under the NGER Act, Australia Pacific LNG, being a joint venture between
CoP and Origin Energy, will resolve which of the JV partners will assume reporting responsibility,
based on the following criteria.
Under the NGER Act, an incorporated joint venture will not generally be taken as falling within the
definition of ‘joint venture’. Only unincorporated joint ventures will fall within the definition of ‘joint
venture’ for the purposes of the NGER Act.
• If the JV is an incorporated JV and it fulfils the definition of a controlling corporation (under the
Corporations Act 2001) it will be required to register and report in its own right.
• Where an incorporated joint venture falls within the definition of ‘subsidiary’, the joint venture
company will be included in its parent company’s corporate group.
Only unincorporated joint ventures fall within the definition of a joint venture, these are the only types
of arrangements where participants in a joint venture will be required to nominate a responsible
reporting entity. Further details can be found in the NGER supplementary guidelines on joint ventures
and defining a corporate group.
Operational Control
Australia Pacific LNG will also resolve the issue of which member has ‘operational control’ over
individual facilities. Obligations under the NGER Act are based on which members have operational
control over facilities that meet a facility threshold or that contribute to meeting a corporate-level
threshold. The concept of operational control will be used for allocating responsibility for reporting
energy and GHG emissions data for the LNG facility.
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A corporation is considered to have operational control over a facility if the member has authority to
introduce and implement operating, health and safety, and environmental policies. Only one
corporation can have operational control over a facility at any time. The corporation deemed to have
operational control will be the one with the greatest authority to introduce and implement operating
and environmental policies.
If a third party is contracted to manage or operate a facility on behalf of the owner, it is expected that
authority to introduce policies will be shared between the owner and the manager or operator
according to conditions specified in the contract between the parties. The greatest authority to
introduce policies is thus dependent on the contractual relationship between the parties.
Facility definition
The activities at the LNG facility represent a separate “facility” under the NGER Act because:
• The activities produce GHGs or produce or consume energy.
• The activities are part of a production process.
• The LNG production activities occur at a ‘single site’.
• The activities are attributable to a single industry sector.
The facility reporting boundary for construction activities will include:
• Scope 1 emissions from diesel and gasoline combustion for on-site transport.
• Scope 1 emissions from diesel for power generation.
• GHG emissions from land clearing.
GHG emissions from transport of workers, materials and equipment by third parties, waste disposal
and embedded energy related emissions from construction materials are scope 3 emissions for the
LNG facility and are not reportable under NGERs.
The facility reporting boundary for operational activities will include:
• All fuel gas combustion by power generation and refrigeration/compressor turbines.
• All flaring and venting activities.
• All fugitive emissions from LNG processing.
• All diesel consumed by standby power generators.
GHG emissions from LNG shipping, transport of workers, materials and equipment by third parties,
and waste disposal are scope 3 emissions for the LNG facility and are not reportable under NGERs.
GHG emissions and energy data from major contractors at a facility will be identified if the contractors’
activities emit 25 kilotonnes or more of CO2-e or consume or produce 100 terajoules or more of
energy. GHG emissions and energy data from the entire facility will be reported initially by Australia
Pacific LNG, with major contractor GHG emissions and energy data identified separately but attributed
to the industry sector the facility data are reported against. Major contractors will be identified by their
ABN (Australian Business Number).
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Contractors’ activities the LNG facility that emits less than 25 kilotonnes of CO2-e or consumes or
produces less than 100 terajoules of energy will not be identified separately. They are reportable by
the JV member with operational control over the LNG facility. The GHG and energy data from the
contractor’s activities will be reported against (attributed to) the industry sector the facility reports
against—rather than construction or any other contractor activity.
Contractors’ GHG and energy data will be reported under the Australia Pacific LNG GHG and energy
data management and reporting system.
GHG and energy reporting principles
The NGER (Measurement) Determination 2008 sets out the following general principles for measuring
emissions:
• Transparency - emission estimates must be documented and verifiable.
• Comparability - emission estimates using a particular method and produced by a registered
corporation in an industry sector must be comparable with emission estimates produced by
similar corporations in that industry sector using the same method and consistent with the
emission estimates published by the Department of Climate Change in the National
Greenhouse Accounts.
• Accuracy- uncertainties in emission estimates must be minimised and any estimates must
neither be over nor under estimates of the true values at a 95 per cent confidence level.
• Completeness. All identifiable emission sources within the energy, industrial process and waste
sectors as identified by the National Inventory Report must be accounted for.
Estimates of GHG emissions and energy production and consumption will be prepared in accordance
with these principles.
Calculating GHG and energy data
The National Greenhouse and Energy Reporting (Measurement) Determination 2008 outlines four
methods that can be used to estimate GHG emissions and energy produced or consumed. Australia
Pacific LNG will report on the methods used. Broadly, the four methods are as follows:
• Method 1 - the default methods, derived directly from the methods used for the National
Greenhouse Accounts and the same as those used in OSCA.
• Method 2 - a facility-specific method using industry sampling and Australian or international
standards listed in the Determination or equivalent for analysis.
• Method 3 - a facility-specific method using Australian or international standards listed in the
Determination or equivalent standards for both sampling and analysis of fuels and raw
materials. Method 3 is very similar to method 2, but it requires reporters to comply with
Australian or equivalent documentary standards for sampling.
• Method 4 - direct monitoring of emission systems, on either a continuous or a periodic basis.
One method for a GHG source must be used for 4 reporting years unless a higher order method is
used.
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A detailed GHG measurement plan based on the four reporting methods under the National
Greenhouse and Energy Reporting (Measurement) Determination 2008 will be developed for each
GHG source.
Estimating incidental greenhouse gas emissions and energy
Incidental greenhouse gas emissions and energy are small sources of GHGs or energy at a facility. If
GHGs or energy sources from a facility are incidental, the Australia Pacific LNG will estimate the
amounts using its an internally developed methodology.
Figure 6.2 indicates the upper limits for GHG emissions and energy data.
Incidental GHGs will be separated by source; energy produced or consumed (divided by energy type).
• GHGs and energy data may be treated as ‘incidental’ only if more accurate estimation is difficult
or expensive.
• The data is not otherwise required for reporting in another government program.
Figure 6.2 Upper limits for amounts of GHGs and energy data that may be considered
incidental
Reporting GHG emissions to the Greenhouse and Energy Data Officer
Once registered, Australia Pacific LNG will submit a Corporate report (inclusive of all reportable
emissions from upstream and downstream sources) by 31 October following the reporting period
(financial year).
Australia Pacific LNG will report GHG emissions and energy data for the financial year during which it
first meets a threshold. A report will be provided to the Greenhouse and Energy Data Officer for every
year after the year the thresholds are first met. GHG emissions and energy data reports will be lodged
on the federal government’s OSCAR (the Online System for Comprehensive Activity Reporting),
administered by the Commonwealth Department of Climate Change and Energy Efficiency.
6.1.2 Energy Efficiency Opportunity Reporting
The five steps for reporting Energy Efficiency Opportunities is given in Figure 6.3.
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Figure 6.3 Process for EEO reporting
Determine participation
If Australia Pacific LNG on a corporate level (inclusive of upstream and downstream activities) uses
more than 0.5PJ of energy in a financial year, it will participate in Energy Efficiency Opportunities. The
responsibility for participating in Energy Efficiency Opportunities rests with the controlling corporation.
Register with the Department of Resources, Energy and Tourism
Registration will be undertaken within nine months following the end of the financial year in which the
energy use of the corporate group exceeds 0.5PJ. That year is referred to as the trigger year. The
Chief Executive Officer (or an authorised representative) of the controlling corporation must register on
behalf of all businesses within the corporate group.
Prepare an assessment and reporting schedule
After registering, Australia Pacific LNG will prepare an assessment and reporting schedule (termed
‘Assessment Plan’ in the legislation). The scope of the assessment will include the LNG facility only.
This schedule will be submitted to the Department within 18 months following the end of the trigger
year.
An assessment and reporting schedule covers a five-year assessment cycle and will comprise:
• An outline of corporate structure and related information.
• Current energy use and savings data.
• An assessment schedule – outlining how and when Australia Pacific LNG will conduct
assessments.
• A reporting schedule – outlining how, where, and when the Australia Pacific LNG intends to
report to the Department and to the public.
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An assessment and reporting schedule will be submitted within 18 months of the end of the trigger
year. For example, if the trigger year is 2012-13, the assessment and schedule must be submitted by
31 December 2014. Schedules for second and subsequent cycles will be submitted within 18 months
of the end of the previous cycle.
Conduct assessments
Energy use will be assessed to identify cost effective opportunities for improving energy efficiency with
up to four year paybacks. Australia Pacific LNG will ensure that each member of the corporate group
that is scheduled to conduct assessments completes its first assessment for at least one site, key
activity or business unit within the first two years of the assessment cycle.
The Australia Pacific LNG will ensure that at least 80% (current reporting cycle; 90% in subsequent
cycles) of its total energy use is assessed, including all sites that use more than 0.5PJ per year, within
the five year assessment cycle.
Energy use data collected as part of the assessment will be accurate to within ±5%. If an accuracy
level of ±5% accuracy cannot be met, Australia Pacific LNG will apply in their schedule to report less
accurate energy use data.
To ensure assessments are rigorous and comprehensive, the minimum standard detailed in the
Assessment Framework will be met. The key elements of the Assessment Framework are:
• Leadership support for the assessment and the improvement of energy use.
• The involvement of a range of skilled and experienced people, and people with a direct and
indirect influence on energy use during the assessment process.
• Information and data that is appropriately, comprehensively and accurately measured and
analysed.
• A process to identify, investigate and evaluate energy efficiency opportunities with paybacks of
four years or less.
• Business decision making and planning for opportunities that are to be implemented or
investigated further.
• Communicating the outcomes of the assessment and the investment decisions made regarding
the opportunities identified and proposed business response, to senior management, the board
and personnel involved.
Report on assessment outcomes and business response
Australia Pacific LNG will publicly report the outcomes of the first assessment or assessments,
including their business response, within 15 months of the first assessment’s completion. Annual
updates of further assessments and business responses will be provided. Australia Pacific LNG will
ensure that public reports will be readily available to investors, shareholders, other key stakeholders
and interested members of the public. Typically, ConocoPhillips have included them in annual financial
or other similar reports.
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Australia Pacific LNG will also report to the Department on the outcomes and the business response
to the assessments by the time their first public report is made, and again within six months of the end
of the assessment cycle.
Figure 6.4 gives a summary of the EEO program cycle.
Figure 6.4 EEO Assessment and Reporting Cycle
6.1.3 Reporting under the National carbon offset standard
Australia Pacific LNG will issue a periodic report that may be made publicly available on a website to
communicate progress on emissions reduction activities and carbon offsetting of carbon neutral
organisations and products. The periodic report will be made against an Emissions Management Plan
and should include the following:
• The total carbon footprint of the activities of the organisation (or specified part of the
organisation) or the product sold in the given period, including any actions taken to reduce total
greenhouse gas emissions before offsetting.
• A statement on the emissions reduction activities undertaken in accordance with the emissions
reduction strategy and the resulting quantity of emissions reduced.
• Records to prove that sufficient eligible offsets have been acquired to offset the proportion of
the total carbon footprint associated with the activities of the organisation (or specified part of
the organisation) or products committed to be offset.
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• Details of the quantity and type of offset units purchased and register into which they have been
retired, or cancelled.
6.2 Corrective actions
Corrective actions will be implemented in accordance with Section 6.10, Volume 1 – Overview EM
Plan and ConocoPhillips’ HSEMS element No.10 – Non conformance, investigation and corrective
actions
6.3 Auditing
Australia Pacific LNG and its contractors will conduct internal compliance audits against this
management plan on an annual basis.
Audits of GHG and energy data should be performed on an annual basis.
For established GHG offset projects, GHG emissions reductions and offsetting activities should be
reported and independently audited on an annual basis. Audited progress reports may be made
publicly available
6.4 Management Review
The Management Team will conduct an annual review of the GHG management plan.
As part of the annual review, a review will be conducted of current and potential GHG abatement
opportunities and this will be reported to the Management Team for consideration.
This process will facilitate continuous improvement of the GHG Management Plan.
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7. References
Australian Government 2006 Energy Efficiencies Opportunities Act.
Australian Government 2008a National Greenhouse and Energy Reporting Act 2007
Australian Government 2008b National Greenhouse and Energy Reporting (Measurement)
Determination.
Australian Government 2010 National Carbon Offset Standard.
Australia Pacific LNG Environmental Impact Statement, 2010, http://www.aplng.com.au/process.
Darwin LNG, 2005, Darwin LNG Operations, Health, Safety, & Environment, Environmental
Management Plan, Document No: DLNG/HSE/PLN/001 Section 5, Revision 1.
Garnaut, R 2008 The Garnaut Climate Change Review-final report. Cambridge University Press,
Chapter 12, p. 284
Heede, R 2006 LNG supply chain greenhouse gas emissions for the Cabrillo Deepwater Port: natural
gas from Australia to California
Australia Pacific LNG, 2010, Draft Environmental Offset Strategy, Q-LNG01-15-EA-0021.
Queensland Government 2007 ClimateSmart 2050: Queensland climate change strategy 2007: a low
carbon future.
Queensland Government 2009 ClimateQ: toward a greener Queensland. Source
http://www.climatechange.qld.gov.au/whats_being_done/queensland_climate_change_strategy.
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